APPENDIX H 

ALASKA NATIONAL INTEREST LANDS 

CONSERVATION ACT (ANILCA) § 810 

ANALYSIS OF SUBSISTENCE IMPACTS 

ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS

TABLE OF CONTENTS 

Page

Introduction..............................................................................................................................................................H-1

Subsistence Evaluation Factors................................................................................................................................H-1

Evaluation of Alternatives and Findings..................................................................................................................H-2

ANILCA § 810(a) Evaluations and Findings for All Alternatives and the Cumulative Case .........................H-2

Environmental Justice....................................................................................................................................H-13

References..............................................................................................................................................................H-14

BLM Vegetation Treatments Using Herbicides H-i June 2007 

Final Programmatic EIS

ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

APPENDIX H 

ALASKA NATIONAL INTEREST LANDS 

CONSERVATION ACT (ANILCA) § 810 

ANALYSIS OF SUBSISTENCE IMPACTS 

Introduction 

On October 11, 2001, the Bureau of Land

Management (BLM) issued a Notice of Intent in the 

Federal Register to prepare a Programmatic 

Environmental Impact Statement (PEIS) on the 

treatment of vegetation on public lands in the western

U.S., including Alaska. Subsequent Federal Register 

Notices in January 2002 notified the public of the

location of public scoping meetings, changes to the

meeting schedule, and extension of the public 

comment period. Information gathered at these

meetings and during the comment period led to the

development of the Draft Vegetation Treatments Using 

Herbicides on Bureau of Land Management Lands in

17 Western States PEIS and the Draft Vegetation

Treatments on Bureau of Land Management Lands in

17 Western States Programmatic Environmental 

Report (PER). Together, these documents assess on a 

national level the BLM’s proposed use of herbicides, 

and describe the environmental impacts of using 

herbicides and other vegetation treatment methods,

such as fire, manual removal, mechanical removal, and 

biological controls. Because of the programmatic 

nature of the proposed use of herbicides by the BLM,

the two documents address a wide range of impacts

that are inclusive of the extensive and diverse land

area under analysis. Should herbicide use be proposed 

locally, then site-specific impacts of all vegetation

treatments would be addressed and analyzed in

additional NEPA documents prepared by local BLM

offices and tiered to the PEIS and PER documents. 

BLM-administered lands (public lands) are federallyowned lands and interests in lands (such as federallyowned mineral estate) that are administered by the

Secretary of the Interior through the BLM. In Alaska, 

public lands also include lands selected, but not yet

conveyed, to the State of Alaska or Native 

Corporations and villages. 

Chapters 3 (Affected Environment) and 4 

(Environmental Consequences) of the PEIS and 

Chapters 3 (Public Land Resources) and 4 (Effects of 

Vegetation Treatments) of the PER provide detailed

descriptions of the affected environment and the

potential effects of the various alternatives on 

subsistence resources. This appendix uses the detailed

information presented in the PEIS and PER to evaluate

the potential impacts to subsistence pursuant to

Section 810(a) of the Alaska National Interest Land

Conservation Act (ANILCA). 

Subsistence Evaluation 

Factors 

Section 810(a) of ANILCA requires that an evaluation

of subsistence uses and needs be completed for any

federal determination to “withdraw, reserve, lease, or 

otherwise permit the use, occupancy or disposition of

public lands.” As such, an evaluation of potential

impacts to subsistence under ANILCA § 810(a) must 

be completed for the PEIS and PER. ANILCA requires 

that this evaluation include findings on three specific 

issues: 

• The effect of use, occupancy, or disposition

on subsistence uses and needs; 

• The availability of other lands for the purpose

sought to be achieved; and 

• Other alternatives that would reduce or

eliminate the use, occupancy, or disposition of

public lands needed for subsistence purposes

(16 USC § 3120). 

A finding that the proposed action may significantly

restrict subsistence uses imposes additional

requirements, including provisions for notices to the 

State of Alaska and appropriate regional and local

BLM Vegetation Treatments Using Herbicides H-1 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

subsistence committees, a hearing in the vicinity of the

area involved, and the making of the following

determinations, as required by Section 810(a)(3):

• Such a significant restriction of subsistence

uses is necessary, and consistent with sound 

management principles for the utilization of

the public lands; 

• The proposed activity will involve the

minimal amount of public lands necessary to

accomplish the purposes of use, occupancy, or 

other disposition; and 

• Reasonable steps will be taken to minimize 

adverse effects upon subsistence uses and 

resources resulting from such actions. 

To determine if a significant restriction of subsistence 

uses and needs may result from any one of the

alternatives discussed in the PEIS or treatments 

reviewed in the PER, including their cumulative

effects, the following three factors in particular are

considered: 

• Reductions in the availability of subsistence

resources caused by a decline in the

population or amount of harvestable

resources; 

• Reductions in the availability of resources 

used for subsistence purposes caused by

alteration of their normal locations and

distribution patterns; and 

• Limitations on access to subsistence

resources, including limitations resulting from

increased competition for the resources. 

Evaluation of Alternatives 

and Findings 

Under each of the alternatives presented below, the

proposed actions involved two primary decisions: 1) 

the determination of which herbicide active ingredients

are available for use on public lands in the western 

U.S., including Alaska, in order to improve the

agency’s ability to control hazardous fuels and

unwanted vegetation; and 2) the development of a

state-of-the-science ecological risk assessment 

methodology to evaluate herbicides that may become

available in the future1

. There are no specific projects

proposed under any of the alternatives. When a project

is proposed, the BLM will be required to initiate a sitespecific NEPA analysis of the proposed actions and 

conduct an additional ANILCA § 810 Analysis of 

Subsistence. During this process, the BLM will invite

public participation and collaborate with Alaska

Natives to identify and protect culturally significant

plants used for food, baskets, fiber, medicine and

ceremonial purposes. For this document, the

evaluation and findings required by ANILCA § 810 

are similar for all five alternatives considered in the

PEIS, primarily because of the programmatic nature of 

the proposed herbicide use. The BLM has found that

none of the alternatives in the PEIS result in a finding

of “may significantly restrict subsistence uses and 

needs. 

A subsistence evaluation and finding under ANILCA § 

810 must also include a cumulative impacts analysis.

The discussion below begins with evaluations and

findings for each of the five alternatives discussed in 

the PEIS. Finally, the cumulative case, as discussed in 

Chapter 4 (Environmental Consequences) of the PEIS,

is evaluated. This approach helps the reader to separate

the subsistence restrictions that would potentially be 

caused by activities proposed under the alternatives 

from those that would potentially be caused by past,

present, and future activities that could occur, or have

already occurred, under the vegetation management 

program. 

ANILCA § 810(a) Evaluations and 

Findings for All Alternatives and the 

Cumulative Case 

The following evaluations are based on information

relating to the environmental and subsistence 

consequences of alternatives A through E and the

cumulative impacts analysis as presented in Chapter 4

(Environmental Consequences) of the PEIS. The 

evaluations and findings focus on potential impacts to

subsistence resources themselves, as well as access to 

resources, and economic and cultural issues that relate

to subsistence use. 

 

1

 To be developed by BLM in consultation with the U.S.

Environmental Protection Agency (EPA), U.S. Fish and 

Wildlife Service (USFWS) and National Oceanic and 

Atmospheric Administration National Marine Fisheries 

Service. 

BLM Vegetation Treatments Using Herbicides H-2 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS

Evaluation and Findings for Alternative A - 

Continue Present Herbicide Use (No Action 

Alternative) 

Under this alternative, the BLM would continue

current vegetation management activities in Alaska, 

and resource values would receive attention at present 

levels. Currently, vegetation management in Alaska

consists of less than 50 acres of weed control, fewer 

than 200 acres of mechanical fuels reduction 

treatments each year, and periodic prescribed burns for

wildlife habitat enhancement. Direction contained in

existing laws, regulations, and policies would continue

to be implemented. In general, most activities would 

be analyzed on a case-by-case basis and few uses

would be limited or excluded, provided they were 

consistent with state and federal laws. Fire would be

managed consistent with the Alaska Land Use Plan 

Amendment for Wildland Fire and Fuels Management

(USDI BLM 2005). 

Evaluation of the Effect of Use, Occupancy, or 

Disposition on Subsistence Uses and Needs 

Selection of this alternative would result in the fewest

acres treated; therefore, levels of risk from herbicide 

and other vegetation management treatments to

subsistence resources would be lower than under the 

other alternatives. Threats from invasive plants and

severe fire, however, would be higher than under the

other alternatives. This alternative is likely to have

more impact on subsistence resources than the 

Preferred Alternative (Alternative B), as it may be less 

effective at controlling invasive plants and excessive

fuels. 

Under the No Action Alternative, the BLM would 

have fewer options to control unwanted vegetation on

BLM lands in Alaska (85.5 million acres). In Alaska,

invasive plant species are generally found on road

rights-of-way and areas of human-caused disturbance

like cities, villages, trails and recreation areas; 

however, they are continually expanding their range.

The focus of invasive species treatments is to control 

infestations before they spread to adjacent areas, where

they are likely to have negative effects on subsistence

resources by displacing native plants that are a food 

source for Native peoples and subsistence animals. 

Without weed and fuel control treatments, changes in

the native plant community could increase over time 

and become permanent. Some invasive plants are 

known to change nutrient cycling regimes or increase

erosion and sedimentation in streams, which could

reduce fish populations. 

Manual vegetation removal treatments, such as

pulling, digging or mowing, can selectively remove 

unwanted vegetation, but may cause trampling and

piling of debris on adjacent plants that could be used

for subsistence and wildlife forage. These impacts

would be limited to small areas. Impacts from

mechanical vegetation removal treatments would be 

similar, but on a greater scale, as heavy equipment 

causes more severe impacts to plants and soil through

disturbance and compaction. Mechanical treatments 

can be conducted over larger areas than manual

treatments, but would be limited in Alaska by cost and

access. The BLM would hire workers from local

communities to conduct vegetation management

activities. Higher levels of treatment could result in an

additional source of income for rural Alaskans who 

depend on subsistence. 

Under this alternative, fuel reduction treatments to 

prevent wildland fires would be more limited than

under other alternatives, and the untreated hazardous

fuels could result in severe fires that threaten life and 

property. Severe fires could destroy homes, and reduce

subsistence opportunities by destroying plants and 

wildlife habitat over large areas. Areas affected by

severe burns may take from several years to several 

decades to revegetate to healthy conditions. However,

fire is still a natural ecosystem process in Alaska, and 

only a few areas in the state have altered fire regimes 

that are more conducive to fires because of human

interference or as a result of insect infestations.

Fighting wildland fires in Alaska and elsewhere is a

major source of seasonal employment for Alaska

Natives throughout the state. The income generated by

this seasonal work comprises a major portion of the

rural economy, and provides the cash necessary to 

purchase equipment and supplies needed for

subsistence harvesting. 

Eva uation of the Availability of Other Lands 

for the Purpose Sought to be Achieved 

l

The purpose sought to be achieved under the No

Action Alternative is to manage public lands in Alaska

to prevent the spread and establishment of invasive

non-native plants and to reduce hazards caused by

excessive fuel loads. Because the PEIS is not areaspecific, but applies to all federal public lands

administered by the BLM, no other lands are

appropriate for the purpose sought to be achieved. As a

result, the “other lands” evaluation as required by

ANILCA is more applicable to the future site-specific 

proposals that could result from the PEIS, at which 

BLM Vegetation Treatments Using Herbicides H-3 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

time discrete, bounded lands would be proposed for

vegetation treatment. 

The lands that would be selected for weed control or 

fuels reduction treatments include areas on public 

lands in Alaska where invasive non-native plants 

occur, or areas with an abundance of fire fuels that

increase the likelihood of catastrophic fire.

Additionally, lands where habitat is much less 

productive than desired for wildlife may be subject to

treatments to improve wildlife habitat. The objectives

of treatments would be to restore land health. In the

future, areas of proposed treatment would be

prioritized and analyzed under an appropriate NEPA

document. Given that the BLM would propose future 

treatments on public lands only, other lands would not

be available for the purpose. Lands administered by

other federal agencies in Alaska are directed by their

own planning documents. State- and Native

Corporation-administered lands cannot be considered

in a BLM plan, and under BLM policy other public

lands outside of Alaska are not considered under

ANILCA. 

Evaluation of Other Alternatives that would 

Reduce or Eliminate the Use, Occupancy, or 

Disposition o Public Lands Needed for 

Subsistence Purposes 

f

Other alternatives that would define the types of

vegetation management actions allowed on public

lands needed for subsistence include the action

alternatives, which are presented and analyzed in

Chapters 2 and 4 of the main body of the PEIS. These

alternatives were created to represent a wide range of 

potential vegetation treatment activities that could 

occur on public lands, along with management actions 

that would serve to protect specific resource values

following current national guidelines. Additional 

alternatives that were considered, but not analyzed in 

detail, are also discussed in Chapter 2. 

Findings 

The No Action Alternative would not significantly

restrict subsistence use and needs in Alaska, as

envisioned vegetation treatment would be minimal and

treatment with herbicides has not been considered for

Alaska. Expansion of invasive species and excessive

hazardous fuel loads could occur under this alternative,

resulting in the loss or displacement of native plants

used by Alaska Natives for subsistence purposes.

Additionally, invasive species and severe fires could

reduce forage and habitat for subsistence animals. 

Potential invasive species spread and severe fires may 

eventually result in a significant reduction of species

available for subsistence use, but this consequence is

not expected to occur during the life of the PEIS and 

PER. Initially, displacement would be localized to

disturbed areas that are easily accessible to humans, 

such as along roads. As more invasive, non-native 

plants are introduced and adapt to local conditions,

they will become more widespread and problematic. 

No limits to access for subsistence purposes are

envisioned as a result of this alternative. 

Evaluation and Finding for Alternative B - Expand 

Herbicide Use and Allow for the Use of New 

Herbicides in 17 Western States (Preferred 

Alternative) 

Under the Preferred Alternative, the BLM would be

able to use four new herbicides in addition to 14

herbicides that have been previously-approved to treat 

approximately 932,000 acres annually across 17

western states. In addition, the BLM would be able to 

use herbicides in Alaska. Although no herbicide

treatments are planned for Alaska under this

alternative, the BLM could use herbicides as a part of 

an integrated vegetation management program that 

would more actively manage invasive non-native and

undesirable plants, thereby reducing their negative

effects on the environment and on subsistence use. It is 

estimated that over the next 10 years, no more than 

1,000 acres of public lands in Alaska would be treated

with herbicides in any year. The herbicides considered 

for use in Alaska must be registered in Alaska. At

present, 13 of the 18 herbicide active ingredients

proposed for use are registered for use in Alaska, and 

the list is further reduced to only certain formulations 

of those active ingredients that are registered in

Alaska. That list is available from the Alaska

Department of Environmental Quality. 

Implementation of the Preferred Alternative would be

guided by Standard Operating Procedures (SOPs) that

serve to protect habitat and resources from potential 

impacts as a result of permitted activity. Standard

Operating Procedures for use with herbicide

application are found in Chapter 2 of the Final PEIS, 

in Table 2-8 and additional mitigations are found in

Table 2-9 of the same chapter. There is concern in 

Alaska about the use of herbicides in sensitive 

environments, including tundra and boreal forests, but

herbicide use may be appropriate where impacts to soil

and other resources would be negligible, and where 

other treatment methods would not provide adequate

vegetation control (Hebert 2001). 

BLM Vegetation Treatments Using Herbicides H-4 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS

If new herbicides are developed in the future that

provide control of unwanted vegetation superior to that

of currently-used or proposed herbicides and with

fewer risks to soil and other resources, the BLM would 

be able to use these herbicides, to the benefit of

resources, upon completion of appropriate risk

assessments and associated NEPA analysis. 

Non-herbicide treatment options (fire use, and

mechanical, manual, and biological control methods) 

would be guided by SOPs listed in Table 2-5 of the 

PER to protect resources. Fire would be managed in 

accordance with the Alaska Land Use Plan

Amendment for Wildland Fire and Fuels Management

(BLM 2005). 

Evaluation of the Effect of Use, Occupancy, or 

Disposition on Subsistence Uses and Needs 

In Alaska, the use of herbicides would have both 

beneficial and adverse effects. The area treated under 

this alternative would be greater than under the No

Action Alternative, and thus the effects of herbicide

use would be greater. By treating a larger area than

under the No Action Alternative, the BLM would have

a greater likelihood of reducing the number of acres

covered by weeds and other invasive vegetation, and

restoring ecosystem function to the benefit of 

subsistence resources. In this way, the Preferred

Alternative has the greatest potential for the long-term

protection of subsistence resources from impact by

invasive plants or catastrophic fire by permitting

flexibility in the management of vegetation resources. 

Impacts to subsistence and wildlife from integrated

weed management and fuels reduction treatments are 

expected to have short-term negative and long-term

positive effects. Undesirable impacts from herbicide

use could include: 1) overspray onto non-target species

that would result in injury or death of plants; 2) 

accidental spills that could kill non-target plants and 

run into wetlands or streams; 3) herbicide drift from

the application site that could damage plants; and 4)

toxicity to organisms, including people, from

excessive contact or ingestion. The BLM has

developed SOPs to minimize the negative effects of

vegetation management treatments. Part of the NEPA 

process for vegetation treatments is consultation with

Native groups and the public to determine the location

of important subsistence resources that might be

affected by herbicide treatments, in order to minimize 

or eliminate the undesirable impacts of the treatments.

The BLM would work closely with subsistence users

to minimize impacts to subsistence resources in

particular, and would follow guidance under Human 

Health and Safety in Chapter 4 of the PEIS in areas 

that may be visited by people after treatments. 

If necessary for the protection of subsistence plants

and wildlife forage, the BLM would: 1) use drift

reduction agents with herbicide, as appropriate, to

reduce the drift hazard to non-target species; 2) refer to

the herbicide label when planning revegetation to

ensure that desirable vegetation would not

subsequently be injured by the herbicide; and 3) 

consider site characteristics, environmental conditions, 

and application equipment in order to minimize 

damage to non-target vegetation. To protect fish and

wildlife, the BLM would: 1) use buffer zones based on

label and risk assessment guidance; 2) minimize 

treatments near fish-bearing water bodies during 

periods when fish are in life stages most sensitive to 

the herbicide(s) used; 3) use appropriate application

equipment/methods near water bodies if the potential

for off-site drift exists; 4) use herbicides least toxic to 

fish; 5) treat only the portion of the aquatic system

necessary to achieve acceptable vegetation 

management; 6) select the appropriate application

method(s) to minimize the potential for injury to

desirable vegetation and aquatic organisms; 7) follow

water use restrictions presented on the herbicide label;

8) minimize treatments during nesting and other 

critical periods for birds and other wildlife; and 9) use

herbicides of low toxicity to wildlife. 

To protect water resources, the BLM would: 1) 

consider climate, soil type, slope, and vegetation type

when determining contamination risk; 2) conduct

mixing and loading operations in an area where an

accidental spill would not contaminate an aquatic

body; 3) refrain from rinsing spray tanks in or near

water bodies; 4) refrain from broadcasting pellets

where there is danger of contaminating water supplies;

5) minimize treating areas with high risk for 

groundwater contamination; 6) maintain herbicide-free 

buffers between treatment areas and water bodies; and

7) use the appropriate herbicide-free buffer zone for 

herbicides not labeled for aquatic use based on risk

assessment guidance, with minimum widths of 100

feet for aerial, 25 feet for vehicle, and 10 feet for hand 

spray applications. 

Impacts of non-herbicide treatments are discussed 

under the No Action Alternative, above. 

BLM Vegetation Treatments Using Herbicides H-5 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

Evaluation of the Availability of Other Lands 

for the Purpose Sought to be Achieved 

The purpose sought to be achieved under the Preferred

Alternative is to more effectively manage public lands

in Alaska to prevent the spread and establishment of

invasive non-native plants and to reduce hazards 

caused by excessive fuel loads. The lands that would 

be selected for weed control or fuels reduction 

treatments include areas on public lands in Alaska

where invasive non-native plants occur and areas with 

an abundance of fire fuels that increase the likelihood 

of catastrophic fire. The objective of treatments is to

restore land health. In the future, areas of proposed

treatment would be prioritized and analyzed under an

appropriate NEPA document. Given that the BLM 

would propose future treatments on public lands only, 

other lands would not be available for the purpose. 

Lands administered by other federal agencies in

Alaska are directed by their own planning documents. 

State- and Native Corporation-administered lands

cannot be considered in a BLM plan, and under BLM 

policy other public lands outside of Alaska are not

considered under ANILCA.

Evaluation of Other Alternatives that would 

Reduce or Eliminate the Use, Occupancy, or 

Disposition o Public Lands Needed for 

Subsistence Purposes 

f

Other alternatives that would define the types of

vegetation management actions allowed on public

lands needed for subsistence include the action

alternatives, and No Action Alternative, which are 

presented and analyzed in Chapters 2 and 4 of the

main body of the PEIS. These alternatives were

created to represent a wide range of potential

vegetation treatment activities that could occur on

public lands, along with management actions that

would serve to protect specific resource values

following current national guidelines. Additional 

alternatives that were considered, but not analyzed in 

detail, are also discussed in Chapter 2. 

Findings 

The Preferred Alternative would not significantly

restrict subsistence use in Alaska, since no herbicide

treatments for Alaska are proposed under this

alternative. Instead, the alternative examines the 

parameters by which herbicides use would be allowed,

and requires individual, site-specific NEPA analyses 

any time that herbicide treatments are proposed in the

future. In this way, the BLM would be able to define

with local input the required SOPs and mitigations that 

would be applied to prevent damage to subsistence 

plants and animals. When projects are proposed, local

communities would be given the opportunity to

participate in the planning process and assist with the 

design of proposed treatments. The Preferred 

Alternative also prescribes a range of mitigations and 

required SOPs that are available for use by the BLM in

order to minimize impacts to resources and human 

health. The list of SOPs is presented in Table 2-8 of 

Chapter 2 of the PEIS, and mitigations are listed in 

Table 2-9, in the same chapter. 

Evaluation and Findings for Alternative C – No Use 

of Herbicides

Alternative C, the No Use of Herbicides Alternative,

would eliminate the risks associated with herbicide 

application that have been identified for the Preferred 

Alternative. However, the risks associated with other 

vegetation management techniques, as discussed under

the No Action Alternative, could be greater under

Alternative C. The greatest risks would likely be

associated with prescribed fire treatments. In addition,

human health might be adversely affected by noxious 

weeds, other invasive plants, and/or fuels being 

maintained at current levels or increasing. Under this

alternative, lands selected by the State and by Native

or Village Corporations could be treated, with the

permission and cooperation of the selecting

organization. 

Under Alternative C, weed control treatments in 

Alaska are expected to increase up to approximately 

300 acres, with approximately 1,000 acres treated

using manual or mechanical fuels reduction methods.

Prescribed fire treatments may occur when conditions 

are appropriate, but are unlikely to occur annually. 

Under this alternative, there would be no risk from

herbicides to paleontological, cultural, and subsistence 

resources, or to the health of Native Americans,

Alaska Natives and other people. No herbicide use has

been proposed or analyzed for public lands in Alaska.

Direction contained in existing laws, regulations, and

policies would continue to be implemented. In general,

proposed vegetation management activities would be

analyzed on a case-by-case basis and few uses would 

be limited or excluded as long as they were consistent

with state and federal laws and SOPs. Fire would be

managed in accordance with the Alaska Land Use Plan

Amendment for Wildland Fire and Fuels Management

(BLM 2005). 

BLM Vegetation Treatments Using Herbicides H-6 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS

Evaluation of the Effect of Use, Occupancy, or 

Disposition on Subsistence Uses and Needs 

Alternative C is likely to have an indirect impact on 

subsistence resources, similar to the No Action

Alternative, as it may be less effective at controlling 

invasive plants and excessive fuel loads than the 

herbicide-use alternatives. Non-native or other

undesirable vegetation can displace native species that

may be used by Alaska Natives for subsistence

purposes, and may result in poorer quality forage and

cover for wildlife used for subsistence. These potential

impacts to subsistence are described in detail under the

No Action Alternative. There would be no direct

impact to subsistence resources from herbicides or

other chemicals under this alternative, as no herbicide 

use would be allowed. However, there would be direct

effects to subsistence resources by manual,

mechanical, and prescribed fire treatments that could

temporarily displace wildlife and damage or kill plants

used for subsistence. See the discussion of the impacts

of these treatments under the No Action Alternative. 

Since more acres would be treated under Alternative C 

than under the No Action Alternative, there would be

more potential direct impacts to subsistence resources 

from vegetation treatments. In addition to the impacts

described for the No Action Alternative, there would 

be more exhaust from equipment used, and smoke 

from prescribed fire, that could impact individuals

sensitive to particulates produced by combustion.

Although the income generated by seasonal work

could supplement the rural economy and provide cash

to purchase equipment and supplies needed for 

subsistence harvesting, individuals conducting these

treatments could suffer injuries from manual labor or 

machinery. 

Evaluation of the Availability of Other Lands 

for the Purpose Sought to be Achieved 

The purpose sought to be achieved under Alternative C

is to manage public lands in Alaska to prevent the

spread and establishment of invasive non-native plants

and to reduce hazards caused by excessive fuel loads.

The lands that would be selected for weed control or 

fuels reduction treatments include areas on public 

lands in Alaska where invasive non-native plants occur

and areas with an abundance of fire fuels that increase

the likelihood of catastrophic fire. The objectives of

treatments are to restore land health. In the future,

areas of proposed treatment would be prioritized and

analyzed under an appropriate NEPA document. Given

that the BLM would propose future treatments on 

public lands only, other lands would not be available

for the purpose. Lands administered by other federal

agencies in Alaska are directed by their own planning 

documents. State- and Native Corporationadministered lands cannot be considered in a BLM

plan, and under BLM policy other public lands outside 

of Alaska are not considered under ANILCA. 

Evaluation of Other Alternatives that would 

Reduce or Eliminate the U e, Occupancy, or 

Disposition o Public Lands Needed for 

Subsistence Purposes 

s

f

Other alternatives that would define the types of

vegetation management actions allowed on public

lands needed for subsistence include the action

alternatives, and No Action Alternative, which are 

presented and analyzed in Chapters 2 and 4 of the

main body of the PEIS. These alternatives were

created to represent a wide range of potential

vegetation treatment activities that could occur on

public lands, along with management actions that

would serve to protect specific resource values

following current national guidelines. Additional 

alternatives that were considered but not analyzed in

detail are also discussed in Chapter 2. 

Findings 

Alternative C would not significantly restrict

subsistence use and needs in Alaska. Within 10 years,

the area treated to control invasive plants is likely to 

increase to not more than 300 acres, and the area

treated to reduce hazardous fuels is likely to increase

to no more than 1,000 acres. Under this alternative,

there would be no risks to paleontological, cultural,

and subsistence resources and human health from

herbicide applications. However, risks to these

resources and human health associated with alternative 

vegetation management methods, such as manual

clearing or prescribed fire use, could be greater than

under this alternative than under the No Action

Alternative. The greatest risks would likely be

associated with prescribed fire treatments (see Chapter

4 in the PER). In addition, human health might be

adversely affected by invasive weeds and poisonous

plants that adversely affect humans being maintained

at current levels or increasing because herbicides were

not a treatment option. In the long run, this alternative

could result in expansion of invasive species and

increased fuel loads and loss of native plants that

provide forage and cover for wildlife used for 

subsistence. 

BLM Vegetation Treatments Using Herbicides H-7 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

Evaluation and Findings for Alternative D – No 

Aerial Application of Herbicides 

Alternative D is the No Aerial Application of

Herbicides Alternative. Restriction on aerial 

applications would reduce the risk of herbicide drift

and impacts to unintended targets. Alternative D

would be much like the Preferred Alternative in that

no aerial herbicide applications are proposed or likely

to be proposed in Alaska under the Preferred 

Alternative. Under Alternative D, the BLM would be

able to use four new herbicides, in addition to 

previously-approved herbicides for 17 western states

that are registered in Alaska. Although aerial herbicide

treatments would not be allowed, the BLM could use

ground-based application as a part of an integrated

vegetation management program. It is estimated that

no more than 1,000 acres of public lands in Alaska

would be treated with herbicides in any year for the 

next 10 years. The herbicides considered for use in 

Alaska must be registered in Alaska. At present, 13 of

the 18 active ingredients are registered for use in

Alaska. This list is further reduced to specific

formulations of the active ingredients registered for 

use in Alaska. 

If new herbicides are developed in the future that

provide control of unwanted vegetation superior to that

of currently-used or proposed herbicides and with

fewer risks to soil and other resources, the BLM would 

be able to use these herbicides to the benefit of 

resources upon completion of appropriate risk

assessments and associated NEPA analysis. 

Non-herbicide treatment options (fire use, and

mechanical, manual, and biological control methods) 

would be guided by SOPs listed in Table 2-5 of the 

PER to protect resources. Fire would be managed in 

accordance with the Alaska Land Use Plan

Amendment for Wildland Fire and Fuels Management

(BLM 2005). 

Evaluation of the Effect of Use, Occupancy, or 

Disposition on Subsistence Uses and Needs 

Alternative D would be much like the Preferred 

Alternative in that no aerial herbicide applications are

proposed or likely to be proposed in Alaska under the

Preferred Alternative. Required SOPs for use with 

herbicide application are found in Table 2-8 of Chapter 

2 of the final PEIS, and additional mitigations are 

found in Table 2-9 of same chapter. 

The use of herbicides would have both beneficial and

adverse effects. The area treated under this alternative

would be greater than the area treated under the No

Action Alternative; thus, the effects associated with 

herbicide use would be greater. However, by treating a

larger area than under the No Action Alternative, the

BLM would have a greater likelihood of reducing the

number of acres covered by weeds and other invasive

vegetation and restoring ecosystem function, to the 

benefit of subsistence resources. 

Alternative D has the potential for long-term

preservation of subsistence resources from impact by 

invasive plants or catastrophic fire by permitting

flexibility in the management of vegetation resources. 

Impacts to subsistence and wildlife from integrated

weed management and fuels reduction treatments are 

expected to have short-term negative and long-term

positive effects. Undesirable impacts from groundbased herbicide applications under this alternative

could include: 1) overspray onto non-target species

that would result in injury or death of plants; 2) 

accidental spills that could kill non-target plants and 

run into wetlands or streams; and 3) herbicide drift off 

the application site that could damage plants. The

SOPs specific to reducing impacts to subsistence

resources would include consultation with Native 

groups and the public to determine the location of

important cultural and subsistence resources that might

be affected by herbicide treatments. The BLM would

work with subsistence users to minimize impacts to

these resources, and would follow Human Health and

Safety guidance provided in Chapter 4 of the PEIS in

areas that may be visited by subsistence users after 

treatments. 

For the protection of subsistence plants and wildlife 

forage, the BLM would: 1) use drift reduction agents, 

as appropriate, to reduce the drift hazard to non-target

species; 2) refer to the herbicide label when planning 

revegetation to ensure that desirable vegetation would

not subsequently be injured by the herbicide; and 3)

consider site characteristics, environmental conditions, 

and application equipment in order to minimize 

damage to non-target vegetation. To protect fish and

wildlife, the BLM would: 1) use buffer zones based on

label and risk assessment guidance; 2) minimize 

treatments near fish-bearing water bodies during 

periods when fish are in life stages most sensitive to 

the herbicide(s) used; 3) use appropriate application

equipment/method near water bodies if the potential

for off-site drift exists; 4) use herbicides least toxic to 

BLM Vegetation Treatments Using Herbicides H-8 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS

fish, yet still effective; 5) treat only the portion of the

aquatic system necessary to achieve acceptable

vegetation management; 6) select appropriate

application method(s) to minimize the potential for 

injury to desirable vegetation and aquatic organisms; 

7) follow water use restrictions presented on the

herbicide label; 8) minimize treatments during nesting

and other critical periods for birds and other wildlife;

9) use herbicides of low toxicity to wildlife, where

feasible; and 10) use timing restrictions, as specified 

on the herbicide label, to minimize impacts to wildlife.

Impacts of non-herbicide treatments are discussed 

under the No Action Alternative, above. 

Evaluation of the Availability of Other Lands 

for the Purpose Sought to be Achieved 

The purpose sought to be achieved under Alternative

D is to manage public lands in Alaska to prevent the

spread and establishment of invasive non-native plants

and to reduce hazards caused by excessive fuel loads,

without the use of aerial herbicide applications. The

lands that would be selected for weed control or fuels

reduction include areas on public lands in Alaska

where invasive non-native plants occur and areas with 

an abundance of fire fuels that increase the likelihood 

of catastrophic fire. The objectives of treatments are to 

restore land health. In the future, areas of proposed

treatment would be prioritized and analyzed under an

appropriate NEPA document. Given that the BLM 

would propose future treatments on public lands only, 

other lands would not be available for the purpose. 

Lands administered by other federal agencies in

Alaska are directed by their own planning documents. 

State- and Native Corporation-administered lands

cannot be considered in a BLM plan, and under BLM 

policy other public lands outside of Alaska are not

considered under ANILCA.

Evaluation of Other Alternatives that would 

Reduce or Eliminate the Use, Occupancy, or 

Disposition o Public Lands Needed for 

Subsistence Purposes 

f

l s

Other alternatives that define the types of vegetation

management actions allowed on public lands needed

for subsistence include the action alternatives, and No 

Action Alternative, which are presented and analyzed

in Chapters 2 and 4 of the main body of the PEIS. 

These alternatives were created to represent a wide 

range of potential vegetation treatment activities that

could occur on public lands, along with management

actions that would serve to protect specific resource

values following current national guidelines.

Additional alternatives that were considered, but not

analyzed in detail, are also discussed in Chapter 2. 

Findings 

Alternative D would not significantly restrict

subsistence use in Alaska. Site-specific treatments

would be analyzed in NEPA documents that would 

identify numerous SOPs and mitigations that would be

required to prevent damage to subsistence plants and 

animals. For proposed projects, local communities 

would be given the opportunity to participate in the

planning process and assist with design of proposed

treatments. This alternative prescribes mitigations and 

SOPs to minimize impacts to resources and human

health. Standard Operating Procedures are listed in

Table 2-8 in Chapter 2 of the Final PEIS, and 

mitigations are listed in Table 2-9 of the same chapter. 

Evaluation and Findings for Alternative E – No Use

of Sulfonylurea and other Acetolactate Synthaseinhibiting Active Ingredients 

Alternative E prohibits the use of Sulfonylurea and

other Acetolactate Synthase (ALS)-inhibiting active

ingredients, which include chlorsulfuron, imazapic, 

imazapyr, metsulfuron methyl, and sulfometuron 

methyl. Alternative E incorporates additional

management practices of limiting application

techniques; however, the resulting effects to

subsistence resources would be similar to those

described under the Preferred Alternative. 

Eva uation of the Effect of U e, Occupancy, or 

Disposition on Subsistence Uses and Needs 

Under Alternative E, the BLM would be able to use 

some herbicides, but not ALS-inhibiting herbicides.

Although no herbicide treatments have been planned 

for Alaska, the BLM could use herbicides under this

alternative as a part of an integrated vegetation 

management program that would more actively 

manage invasive non-native plants and other unwanted

vegetation, thereby reducing their negative affects on

the environment and subsistence uses. It is estimated 

that treatments would start on fewer than 100 acres.

Within 10 years, it is estimated that no more than

1,000 acres of public lands in Alaska would be treated

with herbicides in any year. 

Impacts to subsistence use under this alternative would

be similar to those described under the Preferred 

Alternative. Herbicides would be applied primarily by 

spot spraying, wiping, or injection, which would

BLM Vegetation Treatments Using Herbicides H-9 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

reduce impacts to non-target plants by preventing 

overspray that could damage or kill plants

unintentionally. However, the high concentrations of

herbicides used for these application techniques could 

have increased toxicity to animals exposed to the

herbicide or ingesting treated plants. Non-herbicide 

treatment impacts would be the same as those

described under the No Action Alternative. 

Alternative E, like the Preferred Alternative, would be

guided by a standard set of SOPs that serve to protect

subsistence resources from potential impacts 

associated with vegetation management activities.

Alternative E would be similar to the Preferred

Alternative in reducing impacts from invasive nonnative plants and excessive fuels. Impacts to

subsistence resources are expected to have short-term

negative effects (injury or death to non-target plants,

injury to animals directly exposed to treatments) and 

long-term positive effects (healthy native plant 

communities that support healthy populations of 

subsistence wildlife). Alternative E does place 

increased emphasis on spot rather than broadcast

applications, which would tend to correspond to less

per area risk than under the No Action and Preferred

alternatives. The risk per area treated, however, is not

likely to be dramatically lowered by prohibiting the

use of ALS-inhibiting herbicide active ingredients. In 

addition, because the number of acres proposed for 

treatment under Alternative E and the Preferred 

Alternative are similar (up to 1,000), overall risks 

would be similar for both alternatives. Conversely,

more acres would be treated under Alternative E than

under the No Action Alternative (50), so overall shortterm risk would be greater. 

Under all alternatives, the BLM would collaborate

with Alaska Native groups to identify and protect

culturally significant plants used for food, basketweaving and other fibers, medicine, and ceremonial

purposes, and would use minimal impact treatments or 

avoidance where culturally significant species are

known to occur. In addition, under Alternative E, the 

BLM would establish herbicide-free zones to protect

culturally significant plant and wildlife resources,

which would reduce the likelihood that Alaska Natives

would consume vegetation with herbicide residues. 

Evaluation of the Availability of Other Lands 

for the Purpose Sought to be Achieved 

The purpose sought to be achieved under Alternative E

is to manage BLM lands in Alaska to prevent the

spread and establishment of invasive non-native plants

and to reduce hazards caused by excessive fuel loads,

without using ALS-inhibiting herbicides. The lands

that would be selected for vegetation management 

treatments include areas on public lands in Alaska

where invasive non-native plants occur, areas with an

abundance of fire fuels that increase the likelihood of

catastrophic fire, and areas of degraded wildlife forage

and habitat. The objectives of treatments are to restore 

land health and, subsequently, the subsistence 

resources that depend on healthy plant communities. In 

the future, areas of proposed treatment would be 

prioritized and analyzed under an appropriate NEPA

document. Given that the BLM would propose future 

treatments on pubic lands only, other lands would not 

be available for the purpose. Lands administered by

other federal agencies in Alaska are directed by their

own planning documents. State- and Native

Corporation-administered lands cannot be considered

in a BLM plan, and under BLM policy other public

lands outside of Alaska are not considered under

ANILCA. 

Evaluation of Other Alternatives that would 

Reduce or Eliminate the U e, Occupancy, or 

Disposition o Public Lands Needed for 

Subsistence Purposes 

s

f

Other alternatives that would define the types of

vegetation management actions allowed on public

lands needed for subsistence include the action

alternatives, and No Action Alternative, which are 

presented and analyzed in Chapters 2 and 4 of the

main body of the PEIS. These alternatives were

created to represent a wide range of potential

vegetation treatment activities that could occur on

public lands, along with management actions that

would serve to protect specific resource values

following current national guidelines. Additional 

alternatives that were considered, but not analyzed in 

detail, are also discussed in Chapter 2. 

Findings 

Alternative E would not significantly restrict

subsistence use and needs in Alaska, as a relatively 

small number of acres are being considered for 

herbicide treatments in Alaska (less than 1,000 acres).

Under this alternative, risk per area treated would not

likely be dramatically lowered by prohibiting the use 

of ALS-inhibiting herbicide active ingredients. Even

under accidental exposure scenarios, imazapic,

imazapyr, metsulfuron methyl, and sulfometuron 

methyl do not pose a risk to humans, and chlorsulfuron 

only poses a risk to workers under scenarios involving 

BLM Vegetation Treatments Using Herbicides H-10 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS

ground broadcast applications at the highest

application rate, and risk to the general public under

scenarios involving an accidental spill of a large

amount of chlorsulfuron into a very small pond—an 

unlikely scenario. Bromacil, diquat, and diuron, which

pose the most severe human health risks, could be used

under Alternative E; therefore, risk per area treated is

not likely to be reduced by prohibiting the use of ALSinhibiting herbicide active ingredients. Alternative E 

does place increased emphasis on spot rather than

broadcast applications, which would tend to

correspond to less per area risk than under the No

Action and Preferred alternatives, except in the few 

possible cases where occupational receptors would be

at a greater risk from spot applications. 

Risks to subsistence resources and health risk to 

Native Americans and Alaska Natives associated with

other vegetation management methods would likely be

greater under Alternative E. The greatest risks would 

likely be associated with prescribed fire treatments 

(see the final PER). Because the number of acres

proposed for treatment under Alternative E and the 

Preferred Alternative is similar (up to 1,000), overall

risks would be similar for both alternatives. 

Evaluation and Findings for the Cumulative Case 

The Cumulative Case as presented within the

Cumulative Effects Analysis in Chapter 4 of the PEIS 

is a discussion of impacts that could affect the

management decisions contained within alternatives A

through E. 

For this Programmatic EIS, the analysis of cumulative 

impacts is a four-step process that follows guidance

provided in Considering Cumulative Effects Under the 

National Environmental Policy Act (CEQ 1997): 

• Specify the class of actions of which effects 

are to be analyzed. 

All vegetation treatment methods used by the BLM are 

considered in the analysis. These include herbicide 

use, manual, mechanical, and biological control

methods, and use of fire, as identified in Chapter 2

(Alternatives). For the PEIS, potential cumulative

effects include those assessed for all land ownerships,

including lands administered by other federal agencies

and non-federal lands, particularly effects on air 

quality and terrestrial and aquatic species. The analysis

and disclosure of cumulative effects alerts decisionmakers and the public to the context within which

effects are occurring, and to the environmental 

implications of the interactions of known and likely 

management activities. During subsequent analyses for

site-specific activities, local cumulative effects should 

be important considerations in the design of sitespecific alternatives and mitigation measures. 

• Designate the appropriate time and space

domain in which the relevant actions occur. 

The analysis period covered by the cumulative effects

analysis primarily begins in the 1930s with the passage

of the Taylor Grazing Act, and continues through 

2057. 

For purposes of this analysis, the spatial domain for 

past, present, and reasonably foreseeable activities is 

primarily the 17 western states evaluated in the PEIS. 

• Determine the magnitude of effects on the

receptors and whether those effects are 

accumulating. 

The set of receptors assessed in the cumulative effects

analysis are the physical, biological, and human 

systems discussed in Chapter 3 (Affected 

Environment). 

The potential extent of the total cumulative effects 

(e.g., number of animals and habitat affected), and 

how long the effects might last (e.g., population 

recovery time), are estimated to determine the

magnitude of effects that could accumulate for each 

resource. Where possible, the assessment of effects on

a resource is based on quantitative analysis (e.g., level

of risk to humans from use of an herbicide). However,

many effects are difficult to quantify (e.g., animal 

behaviors; human perceptions) and a qualitative

assessment of effects is made. 

The purpose of the analysis of cumulative effects in

the PEIS is to determine whether the effects are

additive or synergistic or have some other relationship.

Additive (or combined) effects on specific resources 

often are difficult to detect and do not necessarily add 

up in the strict sense of one plus one equals two. It is 

much more likely that an additive or combined effect

would be greater than one but less than two. A 

synergistic effect, in theory, is a total effect that is

greater than the sum of the additive effects on a

resource. To arrive at a synergistic effect in this

example (continuing with the numeric analogy), the

total cumulative effect would need to end up greater 

than two. In the highly variable western U.S. 

environment, where natural variations in population

levels can exceed the impacts of human activity, such

an effect would need to be much greater than the

BLM Vegetation Treatments Using Herbicides H-11 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

hypothetical two to be either measurable or 

noteworthy. A countervailing effect occurs when an

impact has both negative and beneficial effects. For

example, herbicide treatments would harm or destroy 

vegetation used by some species of wildlife (negative

effect), but would improve overall ecosystem health

that would lead to improved watershed conditions and

habitat for other wildlife (positive effect). 

Resource analysts have tried to keep the cumulative

analysis useful, manageable, and concentrated on

meaningful potential effects. The cumulative analysis 

considers in greatest detail activities that are more

certain to happen and that are geographically in or near

public lands, and activities identified during scoping as

being of greatest concern. The guiding principles from

existing standards, criteria, and policies that control

management of the natural resources of concern have

been used to help focus the analysis. For areas where

existing standards, criteria, and policies are not

available, the resource experts used their best

judgment to focus the analysis. 

Evaluation of the Effect of Such Use, 

Occupancy, or Disposition on Subsistence Uses 

and Needs 

The PEIS Cumulative Effects Analysis in Chapter 4

did not include a specific section on subsistence. The 

following information is from the wildlife, fish, and

vegetation sections, since subsistence resources fall

into these categories. 

Based on the number of acres treated, short-term

adverse impacts and long-term improvements to 

wildlife and habitat would be greatest under the

Preferred Alternative, and least under the No Action 

Alternative. The number of acres treated, and the

effects to wildlife and habitat would be similar under

alternatives D and E. Effects to wildlife and habitat 

under Alternative C would be intermediate between

these alternatives and the Preferred Alternative. Shortterm effects from treatments and other human causes

would accumulate, but a countervailing effect of longterm improvement in the ecosystem health, with

success and maintenance of treatments, would offset

short-term losses. 

Alternative E places greater emphasis on passive

restoration than the other alternatives. Passive 

restoration is often considered a critical first step in 

successful restoration of degraded areas, since 

anthropogenic activities that are causing degradation 

or preventing recovery are halted. All alternatives

include both passive and active management. 

Recovery of vegetation through passive management 

is expected to take longer than under active 

management, where treatments such as seeding with 

native species, establishing intermediate vegetation to

control erosion, and use of pre-emergent herbicides to

prevent weed establishment would be expected to

promote faster recovery. 

The risks to wildlife, fish and vegetation from use of 

herbicides could be less under Alternative E than

under the other herbicide use alternatives because

ALS-inhibiting herbicides would not be used under

Alternative E. ALS-inhibiting herbicides are effective 

at very low doses and could drift onto wildlife and 

plants and harm them. However, the ALS-inhibiting

herbicides mostly posed no risk to terrestrial wildlife 

(chlorsulfuron, imazapic, sulfometuron methyl),

except for a few cases of low risk (imazapyr, 

metsulfuron methyl), suggesting that prohibiting the 

use of these herbicides would not likely benefit

wildlife used for subsistence purposes and could 

indirectly harm wildlife if more toxic herbicides that

are currently available to the BLM were used in their 

place. 

The risk of herbicide drift affecting wildlife and their

habitats would be less under alternatives D and E than

under the other herbicide treatment alternatives, as

aerial treatments are prohibited under Alternative D, 

and discouraged under Alternative E. 

The proposed vegetation treatments could kill or harm

wildlife and could cause unavoidable short-term

adverse impacts to wildlife habitat and behavior. The 

extent of these disturbances would vary by the extent

and type of treatment. In general, greatest risks would

be associated with the use of fire and herbicide

treatments. If treatments were successful, species

currently using treatment sites could be displaced by 

species better adapted to restored sites. 

All treatments would have short-term adverse impacts 

to wildlife and their habitats, as discussed above. 

Treatments that improve habitat would provide longterm benefits to wildlife. Treatments that remove 

hazardous fuels from public lands and reduce the risk

of large, intense wildfire would reduce future death 

and injury of wildlife and lead to improved habitat.

Treatments that control populations of non-native

species on public lands would be expected to benefit 

most wildlife over the long term by aiding in the reestablishment of native vegetation and restoring

wildlife habitat to near historical conditions. 

BLM Vegetation Treatments Using Herbicides H-12 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS

Regardless of the alternative chosen, there would be a

cumulative loss of native vegetation and healthy

ecosystem function. Over the long term, treatments 

should slow this loss and help to restore native

vegetation and natural fire regimes and benefit 

ecosystem health and wildlife and their habitats. 

Because herbicide use in the planning area is 

uncertain, the level of vegetation treatments projected

through this plan is minimal. Site-specific analysis

would be conducted on proposed projects, and no

cumulative impacts to subsistence species are 

anticipated. 

Evaluation of the Availability of Other Lands 

for the Purpose Sought to be Achieved 

The purpose sought to be achieved under the PEIS and 

PER is to manage BLM lands to prevent the spread

and establishment of invasive non-native plants and to

reduce hazards caused by excessive fuel loads. The 

lands that would be selected for weed control or fuels

reduction treatments include areas on public lands

where invasive non-native plants occur and areas with 

an abundance of fire fuels that increase the likelihood 

of catastrophic fire. The objectives of treatments are to 

restore land health. In the future, proposed treatment 

areas would be prioritized and analyzed under an

appropriate NEPA document. Given that the BLM 

would propose this future treatment on public lands

only, other lands would not be available for the

purpose. Lands administered by other federal agencies 

in Alaska are directed by their own planning

documents. State- and Native Corporationadministered lands cannot be considered in a BLM

plan, and under BLM policy other public lands outside 

of Alaska are not considered under ANILCA. 

Evaluation of Other Alternatives that would 

Reduce or Eliminate the Use, Occupancy, or 

Disposition o Public Lands Needed for 

Subsistence Purposes 

f

Alternatives that would reduce or eliminate the use of 

public lands needed for subsistence include the four

action alternatives that are presented and analyzed in

Chapters 2 and 4, as well as the No Action Alternative. 

These alternatives were created to represent a range of

potential vegetation management activities that could

occur on public lands, along with management actions 

that would serve to protect specific resource values.

Additional alternatives that were considered, but not

analyzed in detail, are also discussed in Chapter 2. 

Finding 

Actions described in the PEIS and PER, when taken 

into consideration with the analysis presented as the

cumulative case, would not significantly restrict

subsistence use and needs in Alaska, as relatively few

acres are being considered for treatment (less than

6,000 acres of vegetation treatments statewide).

Additionally, these documents do not include any 

proposed on-the-ground projects. When proposed, sitespecific projects will require an additional NEPA

analysis, which will include public input and

consultation with local native communities and entities

that could be affected. A subsequent ANILCA § 810

Analysis of Subsistence Impacts will also be required

for each proposed project. 

Environmental Justice 

Executive Order 12898, Federal Actions to Address

Environmental Justice in Minority Populations and 

Low-Income Populations, and an accompanying 

Presidential memorandum require each federal agency

to make the consideration of Environmental Justice 

part of its mission. The existing demographics (race

and income) and subsistence consumption of plants 

and animals, and mitigating measures and their effects 

are presented.

Consultation and Coordination with Indian Tribal

Governments 

Executive Order 13175, Consultation and 

Coordination with Indian Tribal Governments,

requires consultation with tribal governments on

“actions that have substantial direct effects on one or 

more Indian tribes.” Representatives of the BLM have

met with local tribal governments to discuss

subsistence issues relating to the PEIS and PER (see 

Chapter 5, Consultation and Coordination), and have

established a dialogue on Environmental Justice with

these communities. 

In addition to ANILCA, Environmental Justice, as

defined in Executive Order 12898, also calls for an 

analysis of the effects of federal actions on minority

populations with regard to subsistence. Specifically, 

Environmental Justice is: 

The fair treatment and meaningful involvement 

of all people regardless of race, color, national 

origin, or income with respect to the 

development, implementation, and enforcement 

BLM Vegetation Treatments Using Herbicides H-13 June 2007 

Final Programmatic EIS
ANILCA § 810 ANALYSIS OF SUBSISTENCE IMPACTS 

of environmental laws, regulations, and policies. 

Fair treatment means that no group of people,

including racial, ethnic, or socioeconomic group 

should bear a disproportionate share of the 

negative environmental consequences resulting 

from industrial, municipal, and commercial 

operations or the execution of federal, state, 

local, and tribal programs and policies. 

Section 4-4 of Executive Order 12898, regarding the 

Subsistence Consumption of Fish and Wildlife,

requires federal agencies to collect, maintain, and 

analyze information on the consumption patterns of 

populations that principally rely on fish and/or wildlife

for subsistence, and to communicate to the public any

risks associated with the consumption patterns. To this 

end, the subsistence analyses of all alternatives,

located in Chapter 4 (Environmental Consequences) of

the PEIS, have been reviewed and found to comply 

with Environmental Justice.

Additional guidance is found in the CEQ document, 

Environmental Justice – Guidance under the National

Environmental Policy Act, December 1997, and 

USEPA, Region 2, Interim Environmental Justice

Policy December 2000. 

Government-to-Government Consultation with 

Federally-Recognized Tribes 

The BLM formally consults with federally-recognized 

tribes before taking actions that will have a substantial,

direct effect on federally-recognized tribes or their

assets, rights, services, or programs. The BLM

initiated consultation with Alaska Native groups in the

form of a letter sent on July 3, 2002 to 230 tribes and 

Alaska Native entities that could be directly affected

by vegetation treatment activities. The letter requested 

information on how the proposed activities could

impact Native American and Alaska Native interests,

including the use of vegetation and wildlife for 

subsistence, religious, and ceremonial purposes. A

public scoping meeting for the BLM’s proposed

vegetation management PEIS was held in Anchorage,

Alaska on March 6, 2002. 

When future vegetation treatment projects are

proposed, local BLM offices will initiate site-specific 

analysis and NEPA documentation. This process will

include consultation with Alaska Native groups to

determine if culturally important areas and plants

could be impacted by proposed vegetation treatments.

Proposed treatments of plants that are important for 

maintaining traditional lifeways may need to be

modified or cancelled in certain areas. On the other

hand, there may be long-term benefits, such as

reducing or eliminating invasive non-native plant 

competitors, which would allow proliferation of

traditionally used plants. 

References 

Council on Environmental Quality. 1997.

Considering Cumulative Effects Under the National 

Environmental Policy Act. Washington, D.C.

Hebert, M. 2001. Strategic Plan for Noxious and 

Invasive Plants Management in Alaska. University of 

Alaska. Fairbanks, Alaska. 

U.S. Department of Interior Bureau of Land

Management. 2005. Alaska Land Use Plan 

Amendment for Wildland Fire and Fuels Management.

Fairbanks, Alaska. Available at:

http://fire.ak.blm.gov/content/planning/Complete_

Land_Use_Plan_Amendment_186pages.pdf

BLM Vegetation Treatments Using Herbicides H-14 June 2007 

Final Programmatic EIS