APPENDIX I 

RESTORE NATIVE ECOSYSTEMS 

ALTERNATIVE AND BLM POLICY 

ANALYSIS OF ALTERNATIVE 

RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

TABLE OF CONTENTS 

Page 

Restore Native Ecosystems Alternative.................................................................................................................... I-1 

Bureau of Land Management National Policy Analysis of Restore Native Ecosystems Proposal ......................... I-23 

List of Tables 

I-1 Bureau of Land Management Policy Analysis of Restore Native Ecosystems Proposal .......................... I-24 

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RESTORE NATIVE ECOSYSTEMS ALTERNATIVE

Submitted to the Bureau of Land Management 

Sixteen-state Vegetation Management Plan 

Draft Environmental Impact Statement

Revised 26 August 2002 

In response to Bureau of Land Management comments 

and to conform to the preferred DEIS outline

I. OVERVIEW 1 

II. DEFINITIONS 2 

III. VEGETATION TREATMENT PLANNING 3 

IV. SITE SELECTION AND TREATMENT PRIORITIES 5 

 A. General 5 

B. Invasive Species Treatments 6 

 C. Prescribed Fire, Wildfire, and Fire Suppression Treatments 6 

 D. Fuels Reduction 7 

V. PREVENTION VEGETATION TREATMENTS 8 

 A. General 8 

 B. Invasive Species 8 

 1. Livestock Grazing 9 

 2. Roads and Off-Road Vehicles 9 

 3. Fire Suppression 9 

 4. Wildand-Urban Interface 9 

 5. Timber 10 

 6. Altered Hydrological Regimes 10 

 7. Oil, Gas, and Mineral Exploration and Development 11 

 8. Disturbance to Biological Soil Crusts 12 

 C. Prevention of Excess Fuels 12 

VI. RESTORATION VEGETATION TREATMENTS 13 

 A. Direct Treatments of Invasive Species 13 

 B. Prescribed Fire 14 

 C. Fuels Reduction 15 

 D. Fire Suppression 15 

 E. Forage Enhancement 15 

VII REVEGETATION 16 

VIII. MONITORING AND EVALUATION 16 

IX. TRIBAL RELATIONS FOR VEGETATION TREATMENTS 18 

X. COORDINATION, EDUCATION, AND PUBLIC AWARENESS 19 

Endnotes 21 

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RESTORE NATIVE ECOSYSTEMS ALTERNATIVE 

I. OVERVIEW 

GOAL OVR 1: ECOLOGICAL INTEGRITY 

Enhance the ecological integrity of BLM land by restoring natural processes, native species, ecosystem 

function, and resilience of plant and animal communities (see Endnote 1). 

Action-OVR 1 

Give approximately equal overall effort to vegetation treatments that 

a. Prevent conditions that favor vegetation problems; and 

b. Restore ecological integrity on sites with vegetation problems. 

Action-OVR 2 

Base treatments on the best available science and knowledge. 

a. Assess the likelihood that a proposed treatment will contribute to long-term ecological integrity, 

citing documented, relevant case examples where possible. 

b. If a treatment has not previously been attempted, cite scientific evidence that the treatment could 

be expected to contribute to long-term ecological integrity. 

Action-OVR 3 

State objectives, standards and guidelines in clear, measurable terms, then measure the outcomes of 

treatments so that they can be held accountable to long-term and treatment goals. 

Action-OVR 4 

Perform restoration in a precautionary manner, recognizing that our understanding of complex 

ecosystems and the consequences of our activities is limited. 

Action-OVR 5 

Include realistic and dedicated funding for, and an institutional commitment to, assessment, monitoring 

and appropriate response to monitoring results. Design and implement assessment (including the 

gathering of baseline data) and monitoring systems before activities commence. 

Action-OVR 6 

Encourage and facilitate public participation by local, regional and national stakeholders in such 

activities as assessment, monitoring, early detection of invading species, provision of new and scientific 

information, review of assessment and monitoring protocols, and analysis of alternatives for actions. 

Action-OVR 7 

Provide: 

a. clear and significant incentives (e.g., awards, grants, budgets) for prevention of vegetation 

problems and restoration of ecological integrity; and 

b. disincentives for activities that encourage vegetation problems and delay recovery of ecological 

integrity. 

Action-OVR 8 

Ensure that treatments are accountable to public funding. Rely on best available science, awarding 

contracts on the basis of "best value" for ecological integrity, avoid treatments of symptoms, and use local 

community workforces whenever feasible. 

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II. DEFINITIONS OF TERMS USED IN THE RESTORE NATIVE ECOSYSTEMS ALTERNATIVE 

Actions Activities needed to achieve desired outcomes (goals, objectives, standards), including actions to 

restore or protect land health. These actions include proactive measures as well as criteria that 

shall be applied to guide day-to-day activities occurring on public land. 

Active Restoration Treatments 

 Actions other than suspension of activities to restore ecological integrity or native species 

populations. Includes, but is not limited to 

1. Road and off-road vehicle route removal 

2. Culvert removal 

3. Prescribed burning 

4. Use of biological control introductions, cultural methods, mechanical methods, 

chemical methods, and prescribed fire to directly act on invasive exotic species 

5. Fish and wildlife habitat rehabilitation 

6. Reintroduction of extirpated species 

7. Planting and care of native seeds and plants 

8. Reintroduction of soil biota required by native species, when necessary 

9. Other necessary activities based on priorities established in the ecological restoration 

assessment. 

Conservation Protection of landscape, ecological, and native genetic diversity and the processes that 

maintain them. 

Ecological Integrity The ability of an ecosystem to support and maintain a balanced, adaptive community of 

organisms having a species composition, diversity, and functional organization 

comparable to that of natural habitats within the region. 

Goals Goals are broad statements of desired outcomes (e.g., maintain ecosystem health and 

productivity). 

Historical Fire Regimes The historical range of variation of fire intervals, seasons, intensities by which 

native vegetation and wildlife have been shaped and to which they have adapted 

prior to the arrival of Euro-American settlers. 

Invasive Species Exotic species shown by observation and/or scientific evidence to aggressively expand 

their occupancy of land, whether or not they are viewed as directly impacting economic 

activities, or have been listed on formal “noxious weed” lists. “Invasive species” does not 

include native species that increase in response to particular human activities (e.g., 

juniper, mesquite, sagebrush). 

Objectives Objectives identify specific desired conditions for resources and have established 

timeframes for achievement and are usually quantifiable and measurable. 

Passive Restoration Treatments 

 

 Suspension of activities that cause the loss of ecological integrity or native species 

populations in a specific area Passive restoration treatments may include: 

1. Area , road, and off-road vehicle route closures 

2. Voluntary livestock permit retirement 

3. Retirement of vacant livestock allotments 

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4. Livestock grazing exclosures (e.g., in aggressive weed infestations, uplands “at risk” 

of weed infestation, riparian areas, habitat of threatened or endangered species, 

springs, wetlands) 

5. Restrictions of logging activities 

6. Restrictions of oil and gas and mineral development, including allowing expired 

leases to remain expired 

7. Restrictions on other human activities, as relevant 

8. Prescribed natural fire (i.e., allowing fires to burn under predefined circumstances). 

Prevention Treatments Actions that avoid causing conditions that favor the presence of invasive species. 

Prevention is not limited to prevention of the introduction of invasive species. 

Restoration Actions to regain ecological integrity. 

Standards Standards are limitations placed on management activities to ensure compliance with applicable 

laws and regulations or to limit the discretion authority in project decision-making. Compliance 

with relevant standards is mandatory. 

Vegetation Treatments 

 Actions which, based on scientific evidence, will: 

(1) affect the "conservation and restoration of vegetation communities, watersheds 

and wildlife habitats." They include: 

(a) prevention treatments that result in 

1. measurable soil, hydrological, and vegetation changes that 

resist invasive exotic species; or 

2. forests with understory vegetation and fire regimes that resist 

dense tree growth; 

(b) prevention treatments of vegetation that pose fire hazards to important 

ecological values or unique ecological features; and 

(c) active and passive restoration treatments that restore native vegetation 

and/or conditions favorable to native communities. 

(2) affect the protection of human lives or property threatened by fuels, via 

necessary thinning/fuels reduction, or other treatments. 

Wildlands-Urban Interface The area next to a home where fires most directly threaten structures and 

community space where there are flammable community values. Defensible 

community space should be created (e.g., some thinning) within a treatment zone 

up to 500 meters (which includes a more intensive home-site treatment zone up 

to 60 meters) for firefighter safety and protection of other flammable community 

values. 

III. VEGETATION TREATMENT PLANNING 

GOAL-PLAN 1 

Vegetation treatments are based on assessments of (1) the condition of vegetation; (2) major human causes 

of degraded conditions of the vegetation; (3) opportunities for prevention of soil disturbance and 

vegetation problems; (4) opportunities for conservation of native vegetation ; (5) results of past restoration 

treatments; and (6) comparative likelihood of treatment options for achieving long-term restoration. 

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Action-PLAN 1 

Using existing information initially, map habitats within ecoregions, watersheds, and subwatersheds of the 

16 western states: 

1. key areas of native vegetation and high ecological integrity; areas of mixed native and exotic 

vegetation and condition; and areas of low ecological integrity 

2. suitable and critical habitat for habitat-specialist terrestrial and aquatic wildlife species 

3. suitable habitat for wide-ranging species (e.g., bull trout and sage grouse) that require use of 

extensive or temporally diverse (e.g., winter/summer habitat) areas within the ecoregion 

4. hotspots of plant and wildlife biodiversity 

5. habitats “at risk” of further fragmentation or degradation 

6. important aquatic areas, such as riparian areas, steep/unstable slopes, wet meadows, and aquatic 

species’ strongholds 

7. areas where restoration will increase potential for habitat connectivity 

8. areas that could benefit from improved management or restoration to maintain or enhance 

ecological integrity. 

Action-PLAN 2 

Consult conservation center databases and other sources of information and scientists on species 

occurrence. Lack of data may mean no reliable inventories have been conducted. 

Action-PLAN 3 

Identify spatial and temporal association of particular vegetation problems and compare and contrast with 

the spatial and temporal occurrence of past and continuing human activities. 

Action-PLAN 4 

Overlay the ecoregion habitat maps with: 

1. a grazing allotment assessment with the goal of phasing out grazing in sensitive areas over time. 

These include degraded areas, key habitats, and areas where grazing is clearly incompatible with 

native vegetation and habitat recovery. 

2. a logging assessment with the goal of ceasing logging in areas where there is a high risk that it 

would thwart the recovery of native vegetation or increase existing levels of degradation. 

3. a roads and off-road vehicle routes assessment with the goal of closing and decommissioning 

roads and off-road vehicle routes in ecologically sensitive areas including riparian areas, unstable 

slopes, sensitive watersheds, and wildlife migration corridors (see Endnote 2). 

4. an amphibian assessment. Avoid herbicide use in amphibian habitats, as many amphibians are 

highly vulnerable to herbicide applications and drift. 

Action-PLAN 5 

Using existing data, prepare and update every three years, maps of: 

1. invasive exotic species concentrations within each watershed and subwatershed. 

2. exotic species plantings on BLM lands, and, when available, adjacent private and public 

lands. 

 

Action-PLAN 6 

Prior to implementing site-specific vegetation treatments, prepare goals based on: 

1. vegetation conditions, including invasive species concentrations 

2. vulnerable wildlife and plant species and habitats 

3. habitat important for threatened, endangered, and sensitive species and carnivores; connectivity 

for habitat-specialist wildlife 

4. past and present activities within the watershed leading to vegetation problems 

5. passive and active restoration needs 

6. feasible restoration goals 

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IV. SITE SELECTION AND TREATMENT PRIORITIES

 A. General 

Action- PRIORITIES 1 

Prioritize treatments shown to have a high probability of restoring natural processes and natural biotic 

communities (based on previous experiments or operational use) over treatments without this kind of 

documentation. 

Action- PRIORITIES 2 

Prioritize vegetation treatments based on scientific evidence of efficacy as follows: 

1. cessation of activities that impede natural recovery (i.e., passive restoration) 

2. active restoration treatments that incorporate passive restoration 

3. active restoration treatments to restore ecological integrity. 

Action- PRIORITIES 3 

Vegetation prevention and restoration treatments must utilize: 

1. a precautionary approach, which, in the face of uncertain outcomes, proceeds experimentally and 

cautiously 

2. best available science and experiential and indigenous knowledge where applicable 

3. an adaptive process that regularly incorporates revisions from monitoring and evaluation 

4. a public process 

5. the least intrusive techniques available to restore ecological integrity 

6. the least risky interventions that are likely to provide the greatest ecological benefit 

7. recovery plans for threatened and endangered species, or improvements on such plans 

8. prevention strategies to reduce the need for chemical and mechanical treatments, and prescribed 

fire, so that the number of acres treated annually with these methods will decline over the life of 

the EIS. 

Action- PRIORITIES 4 

Herbicide treatments must be of lower priority than non-chemical treatments, and shall be used only in 

conjunction with: 

 1. elimination or reduction of the conditions that have favored the presence of invasive species 

 2. encouragement of conditions that resist invasive species (see Endnote 3). 

Action- PRIORITIES 5 

 Prior to implementing a site-specific treatment: 

1. identify and prioritize restoration options 

2. select the least intrusive/intensive methods that will effectively move the site toward the stated 

goals of ecological integrity 

3. identify riparian conservation areas, consisting of the riparian community and hydrological energy 

zones; and an outer zone that provides buffers for the riparian conservation area and considers 

slope stability and soil erosion. 

Action- PRIORITIES 6 

 State for all site-specific restoration projects and activities: 

1. measurable conservation and restoration objectives 

2. specific indicators and measures for determining results 

3. timelines for analysis of whether goals, objectives and standards have been met 

4. decision making processes that will be used to respond to analysis of results. 

. 

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 B. Invasive Species Treatments 

GOAL- PRIORITIES 1 

The ecological impact of invasive species shall be minimized through conservation and restoration of 

native vegetation communities, watersheds and wildlife habitats. 

Action- PRIORITIES 7 

Give priority to two facets of the control of invasive species as defined in Executive Order No. 13112, 

“Invasive Species”: 

1. prevent the spread of invasive species from areas where they are present 

2. restore native species and habitats to reduce the effects of invasive species and to prevent further 

invasions. 

Action- PRIORITIES 8 

Give treatment priority to areas in which exotic plant invasions have adverse ecological impacts on 

native plant communities, watersheds, and wildlife habitats. 

Action- PRIORITIES 9 

Develop, with the input of knowledgeable scientists and citizens, a long-term (e.g., 100-year) plan for 

prevention and minimization of unwanted exotic vegetation within the planning area, and restoration of 

ecological integrity, including native vegetation. Short-term plans (e.g., 1, 5, or 10 year horizons) will be 

integrated within the 100-year plan; all shall emphasize experimentation and adaptation. 

Action- PRIORITIES 10 

The long term vegetation management plan for integrated agency action shall include: 

1. identification and lessening of the conditions that cause or favor the introduction, establishment, 

and spread of invasive species, and methods to ameliorate those conditions 

2. plans for preservation or restoration of historical disturbance regimes 

3. restoration of the native vegetation community, via seeding and planting, to increase resistance to 

invasion 

4. active vegetation treatments to reduce the abundance of invasive exotic species populations. 

 C. Prescribed Fire, Wildfire, and Fire Suppression Treatments 

GOAL- PRIORITIES 2 

Natural fire regimes and native vegetation types will be restored, wherever feasible. 

Action- PRIORITIES 11 

Collect baseline data on historical fire regimes and plant and animal communities to use as a guide for 

restoration activities. 

Action- PRIORITIES 1 2 

Base fire management decisions on the 1995 Wildland Fire Policy, the updated 2001 Wildland Fire Policy, 

and current science. As required by the Fire Policy, create Fire Management Plans for every burnable acre. 

Action- PRIORITIES 13 

Through an open process that fully includes the public and utilizes the best available science, develop Fire 

Management Plans that: 

1. allow certain remote wildland areas to burn under carefully prescribed conditions where 

ecological benefits would result 

2. prescribe “Minimum Impact Suppression Tactics” where they would be most appropriate 

3. prohibit aggressive soil-disturbing suppression methods where they would be damaging (e.g. 

bulldozers in roadless areas, chemical retardants in riparian areas) 

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4. determine ecological risks of fire – exotic species, population impacts - in all areas covered by 

plans, and carefully weigh benefits and risks as part of this process. 

Action- PRIORITIES 14 

Based on Fire Management Plans, use fire suppression to protect: 

1. areas of high ecological values that may be at risk from exotic species invasion following fire 

2. areas where human life, developed property or irreplaceable ecological values or cultural 

resources (e.g., rare forest types, a major portion of the population of an endangered species, or 

pictographs) are at stake 

3. areas that should be protected until prescribed burning or other treatments can reduce excess fuels 

4. important wildlife habitats (e.g., within 2 miles of sage grouse leks, big game winter ranges). 

 

Action- PRIORITIES 15 

Fire fighting shall be avoided in: 

1. areas where nearby natural fire barriers such as bodies of water or rocky ridges are likely to 

extinguish the fire 

2. Wilderness Areas, Wilderness Study Areas, roadless areas/potential wilderness areas, Wild and 

Scenic Rivers, and Research Natural Areas, except when fire threatens to escape from these areas 

or permanently impair ecological or cultural values. 

Action- PRIORITIES 16 

Mechanical fire suppression (i.e., with bulldozers) shall be avoided in riparian zones, steep slopes and 

other ecologically sensitive areas. 

 D. Fuels Reduction 

GOAL- PRIORITIES 3 

Human lives and property will be protected from wildfire and natural processes will be restored. 

Action- PRIORITIES 17 

Distinguish between fuels treatments intended to restore ecological integrity and those primarily intended 

to protect property and human life. 

Action- PRIORITIES 18 

 Fuels reduction funds under the National Fire Plan shall be used: 

1. only in the wildlands urban interface to protect lives and property 

2. for strategic fire management planning and firefighter training to maximize the safety, ecological 

soundness, and effectiveness of fire and fuels management actions including prescribed fire, 

wildland fire use, and fire suppression. 

Action- PRIORITIES 19 

Fuels reduction shall, except for restoration or conservation necessity: 

1. minimize or avoid road construction and reconstruction 

2. avoid roadless areas, old growth, endangered species habitat, riparian areas, ecological sensitive 

areas and other areas of high ecological integrity 

3. avoid habitat of threatened and endangered species. 

Action- PRIORITIES 20 

Fuels reduction treatments shall not: 

1. increase motorized vehicle use or livestock access 

2. supply biomass plants 

3. increase fire risk through accumulation of activity fuels 

4. include chaining 

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5. include clearcutting 

6. limit native plant recovery through chipping or ground disturbing activities. 

Action- PRIORITIES 21 

Use positive economic incentives that encourage ecologically based restoration activities and eliminate 

incentives that encourage activities that are ecologically degrading. 

1. contracts for fuels reduction/thinning for wildlands urban interface or restoration shall not include: 

a) commercial timber sales 

b) “goods for services” stewardship contracts 

2. all fuel reduction projects shall be paid for by appropriated dollars and any material of commercial 

value shall be sold in a separate contract and all revenues shall be returned to the treasury or used 

to support monitoring. 

V. PREVENTION VEGETATION TREATMENTS 

 A. General 

Action- PREVENTION 1 

The BLM shall not authorize, fund, or carry out actions that it believes are likely to cause or promote the 

introduction or spread of invasive species unless the agency has determined and made public its 

determination that the public benefits of such actions clearly outweigh the potential harm caused by 

invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in 

conjunction with the actions. 

 B. Invasive Species 

Action- PREVENTION 2 

Develop and implement comprehensive, science-based protocols designed to prevent the spread of 

invasive species in relation to all activities on BLM lands that have been identified in the scientific 

literature as primary facilitators of the establishment and spread of invasive species, watershed 

degradation, and loss of native species. 

 1. Livestock Grazing 

GOAL- PREVENTION 1 

 The introduction, establishment, and spread of invasive species due to livestock grazing shall be 

minimized. 

Action- PREVENTION 3 

Reduce spread of invasive weeds caused by domestic livestock grazing: 

1. retire domestic livestock grazing permits at earliest opportunity where grazing has been found to 

promote invasion or persistence of invasive species 

2. prioritize invasives prevention and restoration activities for areas where domestic livestock 

grazing has been permanently ended 

3. manage livestock movement patterns to insure animals are not moving seeds of invasive species 

from infested to uninfested areas 

4. suspend livestock grazing on non-cohesive soils in perennially saturated meadows. 

5. manage livestock grazing to favor native species 

6. avoid grazing in systems still containing a strong component of native perennials, biological soil 

crusts, or other features known to act as natural barriers to invasion or increase of invasive exotic 

species. 

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 2. Roads and Off-Road Vehicles 

GOAL- PREVENTION 2 

Invasive species introduction, establishment and spread due to road, fire break, and off-road vehicle route 

construction, use, and maintenance shall be minimized. 

Action- PREVENTION 4 

Develop GIS maps and databases of all system (authorized and constructed) and non-system (user-created) 

roads and routes. 

Action- PREVENTION 5 

Precede all road or off-road vehicle route reconstruction, and any consideration of adding existing or 

illegal user-created roads and off-road vehicle routes to the transportation system, by NEPA analyses of 

their impacts, including potential to facilitate the spread of invasive species into native ecosystems. 

Action- PREVENTION 6 

Close or restrict non-essential, designated routes for motorized vehicle travel in areas of high risk for 

spread of invasive species. 

Action- PREVENTION 7 

Implement measures that reduce the likelihood of weed seed dispersal, such as educating equipment 

operators, implementing appropriate protocols for vehicle and equipment washing, restricting recreational 

access and seasonal travel. Consider restricting road grading activities in areas with high populations of 

invasive species. 

Action- PREVENTION 8 

Implement full area closures that prohibit all motorized travel on lands outside of designated and NEPA 

analyzed transportation system roads and off-road vehicle routes. 

Action- PREVENTION 9 

Identify and designate for obliteration non-essential system and non-system roads and off-road vehicle 

routes that do not comply with native vegetation protection goals. 

Action- PREVENTION 10 

Cease new road construction and most road reconstruction in riparian areas 

Action- PREVENTION 11 

 Reclaim obliterated roads to native vegetation. 

3. Fire Suppression 

Action- PREVENTION 12 

Utilize Minimum Impact Suppression Techniques and fully reclaim fire lines with native vegetation after 

fire emergency situations have ended, in order to prevent the spread of invasive species into the disturbed 

fire line corridors and to prevent the use of fire line corridors as illegal off-road vehicle travelways. 

4. Wildland-Urban Interface 

Action- PREVENTION 13 

Home-site treatments in the wildland-urban interface (e.g., thinning, pruning, and mowing of vegetation) 

must be undertaken primarily within a 20 - 60 meter (66-200 feet) intensive treatment zone where fires 

most directly threaten structures and human life. 

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Action- PREVENTION 14 

Defensible community space that may include public and private lands may be created within an 

additional treatment zone up to 500 meters (which includes the 60 meter home-site treatment zone) for fire 

fighter safety and protection of other flammable community values. 

Action- PREVENTION 15 

Treatments to create defensible space may include thinning small diameter trees, pruning, mowing, roof 

cleaning , as well as replacement of flammable landscape and building materials. 

Action- PREVENTION 16 

Long-term maintenance activities within the wildland-urban interface (i.e., prescribed burning, mechanical 

brush removal, etc.) as well as monitoring plans must be considered and a funding commitment secured 

before any action is undertaken. 

Guideline- PREVENTION 1 

Management of the wildland-urban interface zone should be a cooperative partnership between relevant 

agencies, tribes, communities, and homeowners. Cooperation shall extend from the initial risk assessment 

and following through to future maintenance and should account for appropriate access to structures for 

fire fighting as well as fire resistant landscaping and consideration of construction standards and proper 

zoning laws for all land ownerships. 

 

Action- PREVENTION 17 

Restoration priorities must be identified through a restoration assessment before any restoration fuels 

reduction activities take place. 

5. Timber 

GOAL- PREVENTION 3 

The introduction, establishment, and spread of invasive species due to timber sales shall be minimized. 

Action- PREVENTION 18 

Maintain old-growth vegetation communities as bulwarks of vegetational resistance to invasion; minimize 

disturbance of old-growth or late seral vegetation communities; and, whenever possible, maintain intact 

forest canopies adjacent to areas such as roads and clearcuts where invasive species are abundant. 

Action- PREVENTION 19 

Design and plan timber sales for maximum prevention of introduction, spread, and establishment of 

invasive species, including pathogens. 

 6. Altered Hydrological Regimes 

GOAL- PREVENTION 4 

The introduction, establishment, and spread of invasive species due to altered flow regimes of rivers and 

streams will be minimized. 

Action- PREVENTION 20 

Prioritize treatments of riparian areas where restoration is likely to be successful; e.g., areas where the 

natural historic flow regime is extant. 

Action- PREVENTION 21 

Restore native historical flow regimes whenever it is possible to do so. 

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 7. Oil, Gas, and Mineral Exploration and Development 

GOAL- PREVENTION 5 

The introduction, establishment, and spread of invasive species due to oil, gas, and mineral exploration 

and development will be minimized. 

Action- PREVENTION 22 

Prohibit surface disturbance associated with oil and gas exploration, development, and production 

activities in areas with 

 1. endangered, threatened, candidate, sensitive, or rare plant species 

 2. steep slopes. 

Action- PREVENTION 23 

Minimize surface disturbance associated with oil and gas exploration, development, and production 

activities in areas with sensitive soils. 

 

Action- PREVENTION 24 

In areas where seismic exploaration activities are permitted best available technologies must be used (i.e., 

helicopter shot-hole technologies over the use of 65,000 pound thumper trucks. 

Action- PREVENTION 25 

Locate wells and associated roads and pipelines on slopes less than 25% to avoid or minimize surface 

disturbance; on slopes greater than 25%, prohibit surface disturbing activities. 

Action- PREVENTION 26 

Keep removal and disturbance of vegetation to a minimum through construction site management (e.g. 

using previously disturbed areas and existing easements, limiting equipment/materials storage and staging 

area sites etc.) on both individual well locations and within oil and gas project areas. 

Action- PREVENTION 27 

Limit vehicular traffic to the running surface of roads and well locations as authorized in Applications for 

Permit to Drill (APD’s) and Right of Ways (ROWs) thus prohibiting all traffic on two-tracks and trails 

near oil and gas well location and within oil and gas project areas. 

Action- PREVENTION 28 

Require that all gravel and other surfacing materials used for the project are free of noxious weeds. 

Action- PREVENTION 29 

Complete a survey for any and all endangered, threatened, candidate, sensitive, or rare plant species prior 

to allowing any surface-disturbing activities involved with oil and gas exploration, development, and 

production activities. 

Action- PREVENTION 30 

Adopt a “No Net Loss” policy for all special status plant species. 

 

Action- PREVENTION 31 

Each operator must submit a Surface Use Plan containing appropriate erosion control and revegetation 

measures (e.g., reintroduction of biological soil crust or mycorrhizae) with each APD request. 

Action- PREVENTION 32 

Grading and landscaping shall be used during and after construction activities are completed to minimize 

slopes, and water bars shall be installed on disturbed slopes in areas with unstable soils where seeding 

alone may not adequately control erosion. 

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Action- PREVENTION 33 

Upon the completion of the drilling phase, require immediate reclamation of all portions of the pad that 

can be reclaimed using the soils originally removed during construction. 

Action- PREVENTION 34 

With each APD request, the oil and gas operators must submit a reclamation plan that includes, but shall 

not be limited to: 

1. identification of lands to be disturbed 

2. detailed description of the baseline condition and resources on the land including existing uses, 

soil characteristics, slope, topography, vegetative cover, and productivity 

3. methods to control erosion 

4. plans to revegetate and restore the areas disturbed 

5. measures that address steep slopes, sensitive soils, recontouring requirements, short-term seedbed 

preparation measures, seeding mixtures and methods, and long-term reclamation goals 

6. steps to be taken to comply with federal, state, and local environmental laws, regulations, and 

policies. 

8. Disturbance to Biological Soil Crusts 

GOAL- PREVENTION 6 

Biological soil crusts shall be maintained as a partial shield preventing establishment or spread of invasive 

exotic species (See Endnote 4). 

 

Action- PREVENTION 35 

Using existing data, map and describe the presence and integrity of biological soil crusts at the ecoregion 

and watershed levels within the 16 western states; locally develop maps at the subwatershed level. 

Action- PREVENTION 36 

Prepare and implement a general plan for damaged biological soil crusts. 

Action- PREVENTION 37 

Prohibit livestock grazing for at least five years following a fire in areas capable of maintaining biological 

soil crusts. Return of livestock will be delayed past five years if significant recovery of the biological soil 

crust has not occurred. 

 

C. Prevention of Excess Fuels 

Goal- PREVENTION 7 

 Shrub and tree establishment shall be maintained at historical densities to prevent excess fuels. 

Action- PREVENTION 38 

 Reduce or eliminate livestock grazing in forests and shrublands where: 

1. historical grass and forb competition to tree and shrub seedlings density has been or can be 

diminished by grazing 

2. historical understory necessary to carry "cooler" fires has been or can be diminished by grazing. 

Action- PREVENTION 39 

 Exclude livestock for at least five years from forest and shrubland areas following fuels reduction 

treatments (e.g., burning, thinning), and until pre-determined native vegetation composition, density, and 

ground cover have been attained. 

BLM Vegetation Treatments Using Herbicides I-12 June 2007 

Final Programmatic EIS
RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

Action- PREVENTION 40 

 Allow wildland fire and consider prescribed burning in order to maintain capacity for cooler, understory 

fires within shrublands and forests. 

 

VI. RESTORATION VEGETATION TREATMENTS 

 A. Direct Treatments of Invasive Species 

Action- RESTORATION 1 

Use the least intrusive/extensive/risky vegetation treatment methods to enhance wildlife habitat and 

populations. 

Action- RESTORATION 2 

Analyze potential effects of site-specific treatments on an array of species; reliance on assessments of 

effects only on umbrella species is not sufficient (see Endnote 5).

Action- RESTORATION 3 

Direct treatments of invasive species shall be part of an over-all ecologically based restoration plan and 

may include: 

1. Biological control 

2. Cultural (manual) practices 

3. Mechanical treatments 

4. Chemical treatments 

5. Prescribed fire 

Action- RESTORATION 4 

Base the selection of direct treatment methods on: 

a. ecological priorities for restoration rather than potential economic benefits 

b. size of the proposed treatment area, its location, and the biology of the target invasive species. 

 Action- RESTORATION 5 

Except for treatment of small infestations without motorized equipment, prescribe direct treatments within 

designated wilderness or wilderness study areas only in conjunction with efforts to halt avoidable spread 

of invasive species into the wilderness from outside these areas. 

Guideline- RESTORATION 1 

Adopt the Carhart Model (Arthur Carhart National Wilderness Training Center) for completing minimum 

requirement analyses and minimum-impact tool analysis. The model assists managers in making 

administrative decisions concerning wilderness. 

Action- RESTORATION 6 

Prioritize nonchemical methods, unless shown to be ineffective, over chemical methods. 

Action- RESTORATION 7 

Small infestations have higher priority for active restoration treatments than large-scale infestations, with 

the exception of biological control. Use seasonal employees to detect and treat small infestations. 

Action- RESTORATION 8 

Use only those biological control agents that have been demonstrated to pose no threat to native species. 

 

BLM Vegetation Treatments Using Herbicides I-13 June 2007 

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RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

Action- RESTORATION 9 

Use cultural treatments that have been shown effective in restoring native vegetation in scientific studies 

(e.g., use of properly timed fire, properly timed and managed goat grazing, mulching, and hand pulling) 

and conduct operational research to develop new, effective cultural treatments. 

Action- RESTORATION 10 

Plant and seed appropriate native species to compete with exotic species. 

Action- RESTORATION 11 

Use mechanical treatments that have been shown to be effective in restoring native vegetation in scientific 

studies (e.g., mowing, spot fire [flamer], mastication, weed eaters, mulching, and weed wrenches) and 

conduct operational research to develop new, effective mechanical treatments. 

 . 

Action- RESTORATION 12 

For chemical treatments, use application methods that minimize exposure to people, wildlife, and native 

plants. Spot treatment methods shall be preferred over broadcast methods. 

Action- RESTORATION 13 

Do not use broadcast herbicide treatments within 500 feet of endangered, threatened, candidate, sensitive, 

or rare plants. If herbicides are necessary for protection of a rare species, allow only application methods 

that apply herbicides only to the target plants. 

Action- RESTORATION 14 

Avoid application of herbicides and prohibit broadcast spraying in riparian conservation areas. Avoid 

application of herbicides (e.g. atrazine) with adverse effects on aquatic species and amphibians. 

Action- RESTORATION 15 

Prohibit the use of herbicides in known aquatic and terrestrial amphibian habitat, including breeding, 

rearing, and overland dispersal areas. 

Action- RESTORATION 16 

Only herbicides that minimize adverse effects on environmental and human health, based on knowledge of 

all ingredients in the formulation, shall be utilized for chemical control. 

Action- RESTORATION 17 

Prohibit use of sulfonylurea herbicides and other acetolactate synthase-inhibiting herbicides due to their 

demonstrated ability to damage off-site native and crop species. 

Action- RESTORATION 18 

Design treatments to account for wildlife habitat needs, for instance, by the timing and location of 

activities. Avoid treatments during nesting season for migratory birds, and during identified sensitive 

periods for wildlife (e.g., critical wintering habitat for big game or sage grouse). 

 B. Prescribed Fire 

Action- RESTORATION 19 

Use prescribed fire to restore native vegetation, historical fire regimes, and native ecosystems; and to 

mitigate human safety threats, but only in concert with a restoration assessment with clear objectives, and 

where it will not increase invasive species. 

BLM Vegetation Treatments Using Herbicides I-14 June 2007 

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Action- RESTORATION 20 

 Consideration of the following must be documented prior to prescribed burns, if relevant: 

1. long-term damage to biological soil crusts 

2. soil erosion through wind and runoff events 

3. long-term loss of nutrients from already nutrient-deficient landscapes 

4. loss of populations and habitat of special status species 

5. risk of spread of invasive species 

6. the levels of nuclear testing radionuclides in the immediate and adjacent area 

7. interrelation between prescribed burning projects on adjacent Federal/state lands 

8. indigenous uses of plants that may be impacted. 

9. impacts on air quality 

10. lethal effects on mature ponderosa pine, particularly from fire damage of roots

Action- RESTORATION 21 

Burned areas (natural or prescribed) must be protected from livestock grazing for at least five years and 

until measurable recovery criteria are met. 

Action- RESTORATION 22 

Prescribed burning teams shall: 

1. use existing roads 

2. limit ground disturbance 

3. address risk of fire spreading beyond the project area and onto surrounding lands.

 C. Fuels Reduction 

Action- RESTORATION 23 

Fuels reduction to restore natural fire processes shall be based on comprehensive restoration assessments 

with clear objectives, in conjunction with other active or passive methods. 

Action- RESTORATION 24 

Following fire, all standing trees shall be left for wildlife habitat, soil stability, and nutrient cycling, except 

where removal is necessary to maintain public safety or to restore ecological integrity (e.g., possible 

removal of small green trees that "should" have burned, so that future fires can burn more naturally). 

 D. Fire Suppression 

Action- RESTORATION 25 

Minimize introduction of invasive species during and after fire suppression operations: 

 1. clean equipment of invasive species seeds before moving equipment off roads to build fire breaks 

 2. seal all firebreaks to prevent off-road vehicle access. 

Action- RESTORATION 26 

 Minimize post-fire disturbance to burned areas to allow natural recovery. 

Action- RESTORATION 27 

Monitor all fire camps and helicopter spots for invasive species following fire. 

 E. Forage Enhancement 

Action- RESTORATION 28 

Conduct forage enhancement projects only if they incorporate ecological principles to encourage native 

species, and will not result in any net loss of native plant communities. 

BLM Vegetation Treatments Using Herbicides I-15 June 2007 

Final Programmatic EIS
RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

VII. REVEGETATION 

Action- REVEGETATION 1 

In revegetation efforts, whenever it is possible to do so, use native seed and seedlings that have been 

grown from seeds of locally adapted populations. 

Action- REVEGETATION 2 

If native seeds/plants are not available, revegetation projects will rarely be undertaken until native plant 

seed or plants become available. Non-native plant species will be used only in extremely 

degraded/severely altered systems as an intermediate step toward/placeholder for native restoration, 

accompanied by a full commitment to complete restoration of native species. This commitment must 

include funds set aside as part of the project, with specific deadlines for accomplishment. 

Action- REVEGETATION 3 

When reseeding with non-native species, certification must be provided that only 

species that have been documented as non-persistent are present in the seeding mixture. 

Action- REVEGETATION 4 

 Assure availability of native seed and plants: 

1. establish BLM contracting systems that will provide growers the necessary assurance their native, 

locally-adapted seed/plants will be purchased if grown 

2. establish sufficient storage facilities for native seeds for major revegetation efforts. 

Action- REVEGETATION 5 

Determine, in landscape, watershed, and subwatershed vegetation assessments, the feasibility of providing 

habitat for wildlife and plant species that have been extirpated or nearly extirpated.

Action- REVEGETATION 6 

Prepare a public report on potential reintroduction of extirpated species, including foreseeable human 

activities or developments that would foreclose options for such reintroductions. 

Action- REVEGETATION 7 

Collaborate with federal, state, local and private land managers to reduce sale and planting of exotic 

invasive species, and increase availability and use of appropriate native species, with particular attention to 

inholdings and other lands adjacent to BLM lands. 

Action- REVEGETATION 8 

Focus invasive species public education programs on 10-20 of the most ecologically problematic local 

invasive species and those that have the potential to invade a given District. Include information about 

how these species are introduced to public lands. 

Action- REVEGETATION 9 

Following fire or other disturbances, do not propose reseeding unless it can be shown that natural 

regeneration is unlikely. Use native species unless they are not available. Always use certified weed-free 

seed. 

VIII. MONITORING AND EVALUATION 

Action- MONITOR 1 

Before resources are committed to modify a plant community, gather baseline data to reflect existing 

conditions. If treatments are initiated, data shall be collected to substantiate whether or not any of the 

BLM Vegetation Treatments Using Herbicides I-16 June 2007 

Final Programmatic EIS
RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

goals, objectives, and standards have been met. If baseline and post-treatment evaluation monies are not 

available, then the project shall not be approved (see Endnote 6). 

Action -MONITOR 2

Monitoring must be used to: 

1. inventory baseline conditions at the landscape, watershed, subwatershed, and project site levels 

2. measure whether positive goals for native ecosystem recovery, conservation, and integrity are 

being attained 

3. track biodiversity and health using an increaser/decreaser species procedure (including biological 

soil crusts, wildlife, and endemic/sensitive species) 

4. practice precaution, retain flexibility, and respond to change, unforeseen harm, failure to reach 

objectives, and/or new information 

5. quantify invasive species population changes 

6. establish success/problems with specific prevention and restoration treatments in a variety of sites. 

Action- MONITOR 3 

Monitoring and evaluation of vegetation treatments shall: 

1. relate to the clearly stated objectives of all restoration projects 

2. be an integral component of each restoration project 

3. be incorporated into the essential costs of each project 

4. use scientific principles of experimental design including replication and measurements from 

untreated control areas for comparison with treated locations

5. use a process responsive to all-party and scientific input 

6. encourage involvement of local, regional and national stakeholders 

7. be documented in a sixteen-state central database with assessments, objectives, monitoring 

procedures, and analyses in comparable formats 

8. outline clear procedures for responding to monitoring and evaluation results 

Action- MONITOR 4 

Monitoring methods shall be: 

1. Relevant: evaluates progress toward stated objectives 

2. Sensitive: quickly detects change, shows trends, identifies critical features 

3. Available: inexpensive, easily applied 

4. Measurable: accurately quantifiable with acceptable methods 

5. Defensible: minimally subject to individual bias 

6. Verifiable: allows others applying the same methods to achieve similar results 

7. Inclusive: avoids reductionism, where feasible 

8. Scheduled: monitoring interval firmly scheduled. 

Action- MONITOR 5 

Goals, objectives, and standards must be written for all projects tiered to this EIS. All projects must be 

monitored to determine if their goals, objections, standards, and guidelines are being met on schedule. 

Action- MONITOR 6 

Objectives and standards must be written in such a manner as to be measurable with concrete ecosystem 

indicators. Reliance on "professional judgment" without evidence should be minimized, so that 

conclusions and ecosystem conditions can be independently verified. 

Action- MONITOR 7 

Each District must prepare an annual monitoring report of all vegetation restoration projects (passive and 

active). These reports should be available at a central BLM location (see Endnote 7). 

BLM Vegetation Treatments Using Herbicides I-17 June 2007 

Final Programmatic EIS
RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

Action- MONITOR 8 

Each District must annually report whether goals, objectives, and standards are being met. For those that 

are not being met, indicate plans for meeting them. 

Action- MONITOR 9 

All proposals to undertake a vegetation restoration activity must include a description of the monitoring 

that will be necessary to determine the compatibility of the activity with specific goals, objectives, and 

standards; and the treatment efficacy. 

Action- MONITOR 10 

Require the submission of an annual monitoring plan at or near any and all locations disturbed by oil and 

gas activities before granting approval of an Application for Permit to Drill. 

Action- MONITOR 11 

Annually monitor for five years all firelines, fire camps, helicopter spots, and fire retardant-treated areas 

for invasive species; eliminate introduced invasive species. 

Action- MONITOR 12 

Monitor progress toward attainment of long term health and integrity of the watershed, aquatic, riparian, 

and native vegetation and soil resources. 

IX. TRIBAL RELATIONS FOR VEGETATION TREATMENTS 

GOAL- TRIBES 1 

Native American Indian concerns and issues relative to vegetation prevention and restoration treatments 

are addressed and mitigated in full collaboration with Native Tribal people. 

Action- TRIBES 1 

Consultation and collaboration with Native Tribes shall take place throughout the process of developing 

and implementing this EIS in accordance with Executive Order No. 13084, Consultation and Coordination 

with Indian Tribal Governments. 

Action-TRIBES 2 

Contact Native Tribal representatives from Tribal governments and organizations when vegetation 

treatments are being planned. Give particular attention to consultation and collaboration with local Tribal 

people when activities may affect Native cultural resources, hunting, fishing and gathering areas, sacred 

sites, or Tribal trust lands. 

Action- TRIBES 3 

Analyze treatment proposals pursuant to Executive Order No. 12898, Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations. 

Action- TRIBES 4 

In collaboration with Tribal people, identify culturally significant plants used for food, basketweaving and 

other fibers, medicine, and ceremonial purposes. 

Action- TRIBES 5 

Develop protocols for enhancement and protection of culturally significant plants: 

1. utilize traditional indigenous knowledge and wisdom to protect and enhance native vegetation 

communities, native resources, and ecosystems. 

2. prioritize treatments that will enhance and preserve culturally significant plants and animals. 

BLM Vegetation Treatments Using Herbicides I-18 June 2007 

Final Programmatic EIS
RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

3. use minimal impact vegetation treatments or avoidance where culturally significant species are 

known to occur. Vegetation treatments will not result in net loss of native species of importance to 

indigenous people for subsistence or cultural purposes. 

Action- TRIBES 6 

Establish herbicide-free zones to protect culturally significant plant and wildlife resources. 

Action- TRIBES 7 

Provide notification to Indian communities of the exact locations, dates, and times that herbicide 

applications will take place, via letters of notification and posting in prominent locations (such as 

community bulletin boards and local post offices). Also, prior to and following treatments, post boundaries 

of treated lands where traditional activities may occur, to ensure notification of elders and traditionalists 

and protect their health. 

Action- TRIBES 8 

Monitor the impacts of different vegetation treatments upon the viability and health of culturally 

significant plants and animals. Adapt treatment approaches as necessary to ensure culturally significant 

plant and animal resources are protected for seven generations. 

X. COORDINATION, EDUCATION, AND PUBLIC AWARENESS

Action- CEPA 1 

Identify activities that prevent, minimize, or reverse (as well as facilitate) the introduction, establishment, 

spread, and reinvasion of specific invasive exotic plant species (e.g., cheatgrass, ventanata, starthistle) on 

BLM lands. 

Action- CEPA2 

 Incorporate findings of the analysis (CEPA-1) in all site-specific treatment decisions. 

Action- CEPA 3 

Develop and maintain a central web site featuring prevention and passive and active restoration treatments, 

including: 

1. scientific literature on treatment outcomes of relevance to BLM lands 

2. BLM projects that have resulted in reestablishment of native vegetation, reintroduction of 

extirpated species, increase in sensitive species populations, reduction in acres needing restoration 

treatments, or reestablishment of natural fire regimes 

3. successful BLM projects or programs to alter activities that have facilitated the introduction, 

establishment and spread of invasive species. 

Action- CEPA 4 

Establish annual awards to BLM employees, Districts, and inholding landowners for accomplishments 

such as: 

1. successful passive and active restoration of native vegetation 

2. equality of effort to prevention and restoration treatments 

3. exemplary monitoring 

4. significant involvement of NGOs, students, and other volunteers in conservation and restoration 

activities. 

Action- CEPA 5 

 Eliminate funding based on acres of vegetation directly treated the previous year without (a) documented 

alteration of the conditions that favored the presence of the vegetation that was directly treated and (b) 

restoration programs to restore the site to native vegetation. 

BLM Vegetation Treatments Using Herbicides I-19 June 2007 

Final Programmatic EIS
RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

Guideline- CEPA 1 

Offer simple invasive exotic species reporting forms to BLM lands visitors in order to encourage the 

reporting of locations in which particular invasive species are present. 

Action- CEPA 6 

Educate the public, including owners of lands neighboring BLM lands, about: 

1. the natural role of fire and protecting their homes from fire through the Fire Wise Program 

2. prevention of invasive species introduction, establishment, and spread. 

BLM Vegetation Treatments Using Herbicides I-20 June 2007 

Final Programmatic EIS
RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

Endnotes

1. Vegetation (and thus ecosystem) problems on BLM lands in sixteen western U.S. states include fragmentation; 

simplified ecosystems; invasive exotic species; altered fire regimes; compacted and otherwise heavily-disturbed 

soils; and impaired watersheds, with disturbed upland and riparian systems. 

2. The three most common activities on public lands managed by the BLM that continue to contribute to declining 

watershed health are: 

• Livestock grazing, which has caused severe, widespread, long-lasting damage to soils, vegetation, riparian areas, 

streams, and associated species; 

• Roads, which damage water quality, riparian areas, the quantity and timing of water flows, aquatic and riparian 

flora and fauna, and the overall hydrologic and ecological functions of watersheds; and 

• Logging, which has contributed to degradation of water quality, riparian areas, soils, vegetation, and aquatic 

resources. 

These activities lead to elevated sedimentation, degraded soils, degraded riparian areas, and altered stream flows 

within much of the BLM-managed landscape. Fire in watersheds, a natural process, plays a far smaller role in 

watershed degradation than these activities. 

3. This prioritization is essential, as herbicides can (1) have numerous adverse toxic effects on workers; nearby 

residents; beneficial soil organisms; and native plant, aquatic, terrestrial and avian species; (2) simplify the 

vegetation community; and (3) render the treated site more vulnerable to return of invasive species. Herbicides alone 

do not address the conditions that favor the introduction, establishment and spread of invasive species, and yet they 

are often used as stand-alone technological “fixes.” 

4. These crusts of lower plants and cyanobacteria cover soil surfaces between individual plants in healthy arid 

grasslands, shrublands, and dry woodlands. While they fix nitrogen, increase soil fertility, improve water infiltration, 

stabilize soils, and enhance the establishment of vascular plants, they also may provide a shield that reduces or 

prevents establishment and spread of exotic species. Biological soil crusts are particularly susceptible to damage 

from physical disturbance. 

5. An example of the insufficiency of analysis for effects solely on an umbrella species involves sagebrush canopy 

“thinning” for sage grouse. This may negatively impact nesting cover for migratory bird species of concern. 

6. There is an obvious, admitted, ongoing, and institutional failure to adequately monitor, survey, and document the 

impacts of human activities on habitats, native vegetation, and native wildlife on federal public lands. Even when 

monitoring has occurred, land managers have rarely translated the findings into management improvements. Good 

intentions and monitoring plans have been insufficient to direct sufficient funding, staff, or attention to the outcomes 

of vegetation and other restoration treatments, among other human activities. It is essential that both the continuation 

and initiation of vegetation restoration activities be dependent upon prior adequate baseline and post-treatment 

monitoring. “We do what we get funded for" is neither a legally sufficient nor an ecologically responsible approach 

to the required, continuous finding of compatibility of treatment activities with the goals, objectives, standards, and 

guidelines of this EIS. 

7. Monitoring needs to be documented so that it can be independently reviewed by non-BLM scientists, the 

scientifically literate public, and others who are concerned about the ecological health of the nation’s federal public 

lands. 

 

BLM Vegetation Treatments Using Herbicides I-21 June 2007 

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RESTORE NATIVE ECOSYSTEMS ALLIANCE ALTERNATIVE 

BLM Vegetation Treatments Using Herbicides I-23 June 2007 

Final Programmatic EIS

Bureau of Land Management National Policy Analysis of Restore 

Native Ecosystems Proposal 

In 2002, a comprehensive proposal was submitted by a citizen’s coalition during scoping for the PEIS. This 

proposal (Alternative E in the PEIS, and often referred to in public comments as the Restore Native Ecosystems 

proposal) was included as Appendix G in the Draft PEIS. In order to determine whether the proposal had merit for 

analysis relative to the proposed action, or should be dismissed from detailed analysis, a comprehensive policy 

review was conducted of the proposal. The policy review was conducted by the BLM’s National Science and 

Technology Center in Denver, Colorado, during 2002. This review was not included in the Draft PEIS, but has 

been included in the Final PEIS in response to public comments on how the proposal was evaluated in the PEIS. 

The proposal as submitted provided the source and framework for the limited herbicide use alternative analyzed in 

the PEIS as Alternative E. In order to develop Alternative E for analysis in the PEIS, certain components of the 

proposal that were relevant and applicable to herbicide use under the proposed action were carried forward into the 

alternative analyzed in the PEIS. The remaining content of the proposal was determined to be either already 

covered under existing BLM policy and, therefore, already a component of the Preferred Alternative (Alternative 

B), or determined to be outside the scope of analysis for this PEIS. 

The following Table summarizes the BLM’s national policy review of the proposal. The policy analysis comprises 

identification of the individual Goals and Actions outlined in the proposal. Each Goal or Action then has a 

determination whether it is included in current BLM policy (Yes/No) and a citation for the policy. Under Policy 

Analysis, a brief summary is provided outlining the policy. Under Alternative Comparison, the Alternatives that 

apply to the policy are identified. In most cases, this is “common to all alternatives.” The last column outlines the 

programmatic net effect or impact of the policy if the analysis is different from that presented in the PEIS, or 

outside the scope of analysis. 
TABLE I-1 

Bureau of Land Management Policy Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

OVR 1 41; BLM Mission Statement Policy Common to all alternatives. OVR 1 Yes 43 

Prevention of conditions that favor vegetation problems and restoration of ecological integrity in the project design. 

Common to all alternatives. Alternative E would emphasize overall equal effort to these considerations, however, these are already considered together in the project design for vegetation treatments as part of integrated vegetation management. Prevention and restoration have equal consideration under BLM vegetation strategies. 

OVR 2 Yes 29, 41, 42, and 43 

Assessment of treatments and citations of scientific literature are accomplished through project design proposals and associated NEPA analyses. 

Common to all alternatives. 

Ecological Integrity 

OVR 3 Yes 1, 23, 27, and 42 

BLM policy is to state objectives, standards, and guidelines in quantifiable terms where possible. Monitoring of outcomes is built into project design. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-24 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Alternative E would mandate use of the “Precautionary Principle” in all restoration activities. The Precautionary Principle emphasizes not taking action due to limited knowledge, and therefore would favor passive management over active treatments. 

OVR 4 Yes 41, 42, and 43 

The BLM recognizes the limitations of the understanding of complex ecosystems and the effects of activities on them. 

Ecological Integrity(Cont.)

OVR 5 Yes 18, 41, 42, and 44 Monitoring is part of project design. Common to all alternatives. 

OVR 6 Yes 1, 26, 29, and 32 

Public participation is encouraged whenever possible in all BLM activities. 

Common to all alternatives. 

OVR 7 Yes 

29, 41, and 43; Federal Acquisition Regulations (FARs); and Title 4 Appropriations 

BLM provides incentives and disincentives for public lands activities. 

Common to all alternatives. 

OVR 8 Yes 

Title 4 Appropriations and Government Performance and Results Act 

Congress has mandated BLM be accountable to public funding. 

Common to all alternatives. 

Definitions 

No 

Many of the definitions used in the RNE proposal do not comport with agency usage or definitions contained in policy, law, regulations, or executive order. 

Alternative E only. 

BLM Vegetation Treatment Using Herbicides I-25 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PLAN 1 Yes 1,5, and 32 

BLM considers a wide range of factors in planning vegetation treatments including, but not limited to, those outlined in the RNE proposal. 

Common to all alternatives. 

PLAN 1 Yes 1, 5, and 32 

Requirements to map habitat variables including, but not limited to, those listed, are included in land use planning policy guidance. In addition, there are several mapping initiatives and efforts that address various components at different spatial scales, these include , but are not limited to, efforts such as LANDFIRE, GAP, and Re-GAP. 

Common to all alternatives. 

PLAN 2 Yes 6, 9, 26, and 27 

BLM regularly consults with conservation centers, natural heritage centers, the Services, and other data sources on species occurrences. 

Common to all alternatives. 

Vegetation Treatment Planning 

PLAN 3 Yes Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-26 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PLAN 4 No 

Assessment goals are contrary to established uses under FLPMA. 

Alternative E only. 

PLAN 5 Yes 16, 32, and 40 

BLM conducts invasive species inventories on a 3 year cycle. BLM does not map exotic species plantings on a broad scale. Existing seedings are platted on master title plats (MTPs) and can be considered in local vegetation management planning at the field office level. 

Common to all alternatives. 

Vegetation Treatment Planning (Cont.)

PLAN 6 Yes 5, 32, 40, 43, and 50 Actions are included in BLM assessment process Common to all alternatives. 

PRIORITY 1 Yes 4, 16, 32, 40, 41, 43, and 44 BLM treatment priorities consider probability of success. Common to all alternatives. 

Site Selection and Treatment Priorities 

PRIORITY 2 Yes 

BLM vegetation treatment priorities are based on land use planning goals 

Alternative E only. 

4, 16, 32, 40, and 44 

BLM Vegetation Treatment Using Herbicides I-27 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action Current BLM Policy (Yes/No) Policy Source (refer to key at end of table) Policy Analysis Alternative Comparison 

PRIORITY 3 Yes 3, 5, 26, and 42 All planning factors listed are considered in the vegetation treatment design. Common to all alternatives. PRIORITY 4 Yes 4, 7, 32, 40, and 58 Same as BLM herbicide treatment priority policy for all herbicide use activities. 

Alternatives A through D. Alternative E would add elimination or reduction of the conditions favoring the presence of invasive species and encourage conditions that resist invasive species in conjunction with herbicide use. 

PRIORITY 5 Yes 41, 44, and 59 Common to all alternatives. 

Site Selection Priorities (Cont.) 

PRIORITY 6 Yes 4, 5, 32, 38, 41, et al. Common to all alternatives. 

PRIORITY 1 Yes 4, 18, 32, 38, 41, and 42 Common to all alternatives. PRIORITY 7 Yes 4, 16, 32, 40, and 41 Policy by Executive Order and Native Invasive Species Management Plan Common to all alternatives. 

Invasive Species Treatments 

PRIORITY 8 Yes 59 Policy by Executive Order Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-28 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PRIORITY 9 Yes 16 and 32 

National and local level longterm and short-term plans for prevention and minimization inclusive of adaptive management already exist. 

Alternatives A through D. Alternative E would develop 100 year plans. 

Invasive Species Treatments (Cont.)

PRIORITY 10 Yes 4, 16, 32, et al. 

Restoration of historical disturbance regimes, native vegetation communities, and active vegetation treatments to reduce invasive species populations are included within the purpose and need for the PEIS. 

Common to all alternatives. 

PRIORITY 2 Yes 3, 26, 38, and 39 

Restoration of natural fire regimes is included in the purpose and need for the PEIS. 

Common to all alternatives. 

PRIORITY 11 Yes 1, 3, 26, and 39 Collection of baseline data is ongoing. Common to all alternatives. PRIORITY 12 Yes 34 

BLM Fire Management complies with the cited guidance and policy. 

Common to all alternatives. 

Prescribed Fire, Wildfire, and Fire Suppression Treatments 

PRIORITY 13 Yes 29 

BLM Fire Management Planning (FMP) process includes these considerations. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-29 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action Current BLM Policy (Yes/No) Policy Source (refer to key at end of table) Policy Analysis Alternative Comparison 

PRIORITY 14 N/A Wildland Fire Leadership Council provides guidance and direction on fire suppression policy at the national level. PRIORITY 15 N/A Field Office FMPs outline local parameters for fire suppression based on resource values to be protected. 

Prescribed Fire, Wildfire, and Fire Suppression Treatments (Cont.) PRIORITY 16 N/A Field Office FMPs outline local parameters for fire suppression based on resource values to be protected. 

PRIORITY 3 Yes 34 and 37 Protection of human life and property is the highest priority for the BLM by policy. Common to all alternatives. 

PRIORITY 17 Yes 29, 34, and 37 All projects have a purpose and need identified for NEPA 

analysis. 

Common to all alternatives. 

PRIORITY 18 N/A 

Congress determines the priorities for allocation and use of fuels reduction funds associated with the National Fire Plan (NFP). 

Fuels Reduction 

PRIORITY 19 No 1, 34, and 37 

Fuels reduction projects are determined based on local situations and studies, and are guided by parameters contained in local land use plans and FMPs 

N/A 

BLM Vegetation Treatment Using Herbicides I-30 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PRIORITY 20 No 33, 34, 36, and 37 

Restrictions on fuels treatments are contrary to national and agency policy, as set by the Administration and Congress. 

N/A 

Fuels Reduction (Cont.)

PRIORITY 21 No 

29, 41, 43, Federal Acquisition Regulations (FAR), and Title 4 Appropriations 

Fuels reduction contract restrictions are contrary to National Fire Plan Policy and the Healthy Forests Restoration Act. 

N/A 

Prevention Vegetation Treatments 

PREVENT 1 Yes 1, 4, 16, 32, and 40 Policy under Executive Order (E.O.) Common to all alternatives. 

Invasive Species PREVENT 2 Yes 1, 28, 30, 32, and 43 BLM prevention protocols are science-based. Common to all alternatives. 

PREVENT 1 Yes 1, 22, 43. and 45 

These considerations are included within the grazing management program authorizations. 

Common to all alternatives. 

Livestock Grazing 

PREVENT 3 No 

Roads and Off-Road Vehicles PREVENT 2 Yes 1, 21, 32, and 57 BMPs for road construction activities already exist. Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-31 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action Current BLM Policy (Yes/No) Policy Source (refer to key at end of table) Policy Analysis Alternative Comparison 

PREVENT 4 No 1 and 57 Transportation inventory and planning in conducted during land use planning. PREVENT 5 Yes 1, 15, and 29 Invasive species spread analysis is a critical element of the human environment component of all BLM NEPA analyses. Common to all alternatives. PREVENT 6 N/A 1 and 57 PREVENT 7 Yes 32 BLM prevention BMPs in place. Common to all alternatives. PREVENT 8 No 1, 20, 21, and 57 

Designation of Open, Closed, or Limited OHV use and subsequent implementation is accomplished through land use planning. 

Roads and Off-Road Vehicles (Cont.)

PREVENT 9 No 57 

Vegetation protection goals are developed through land use planning. 

BLM Vegetation Treatment Using Herbicides I-32 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PREVENT 10 No 10, 11, and 59 

Road construction is disallowed only in nondiscretionary closures (e.g., Wilderness, Wilderness Study Areas [WSAs]). Discretionary closures are developed through land use planning. 

Roads and Off-Road Vehicles (Cont.)

PREVENT 11 No 29 

Reclamation standards for obliterating roads are guided by local land use and transportation plans. 

Fire Suppression 

PREVENT 12 Yes 3 and 29 

MIST is applied as required under FMPs. Fire line reclamation standards are addressed in ESR plans following wildfire. 

Common to all alternatives. 

PREVENT 13 No 34 Federal agencies have no legal authority on private land. PREVENT 14 No 34 

Defensible community space is developed through collaborative planning with local communities and their fire protection agencies. 

PREVENT 15 No 34 Federal agencies have no legal authority on private land. 

Wildland Urban Interface 

PREVENT 16 34 

Long-term maintenance and monitoring are included in the design of vegetation treatments. 

Common to all alternatives. 

Yes 

BLM Vegetation Treatment Using Herbicides I-33 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Wildland Urban Interface (Cont.)

PREVENT 17 No 34 

Restoration and fuels reduction activities are separate activities with different purposes. 

PREVENT 3 Yes 16 

Prevention of the introduction, establishment, and spread of invasive species is policy by E.O. 

Common to all alternatives. 

PREVENT 18 N/A 35 Vegetation objectives are established in land use plans. 

Timber 

PREVENT 19 Yes 16, 29, 32, and 35 

Project design and NEPA analysis take into consideration factors of invasive species introduction, establishment, and spread. 

Common to all alternatives. 

PREVENT 4 No 11, 16, 43, and 44 

There are no BLM policies pertaining to invasive species and altered hydrologic regimes. Prevention of invasive species introduction, establishment, and spread is policy by E.O. 

Altered Hydrologic Regimes 

PREVENT 20 Yes 11, 43, and 44 

PFC assessments are used in determining riparian restoration priorities. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-34 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Altered Hydrologic Regimes (Cont.) PREVENT 21 No 11, 43, and 44 

PFC assessments are used in determining riparian restoration priorities. 

PREVENT 5 Yes 16 

Prevention of invasive species introduction, establishment, and spread is policy through E.O. 

Common to all alternatives. 

PREVENT 22 No 1 

Restrictions on fluid mineral activities are developed through land use planning. 

PREVENT 23 No 1 

Restrictions on fluid mineral activities are developed through land use planning. 

PREVENT 24 No 1 

Seismic exploration technologies and methods involve varying degrees of surface impacts and provide different data sets; however, none are considered “best available technology” from this standpoint, as the methods utilized are based on the information needs of the operator. 

Oil, Gas, and Mineral Exploration and Development 

PREVENT 25 Yes 1 and 29 

Standard Operating Procedures (SOPs) and Conditions of Approval (COAs) for APDs are developed through land use planning and NEPA analysis. 

BLM Vegetation Treatment Using Herbicides I-35 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PREVENT 26 Yes 1 and 29 

BMPs are applied as mitigation resulting from NEPA analysis. 

PREVENT 27 Yes 1 and 29 

SOPs and COAs for APDs are developed through land use planning and NEPA analysis. 

PREVENT 28 Yes 29 and 32 

Prevention measure incorporated into mineral materials permit authorizations. 

PREVENT 29 Yes 29 

ESA consultation is required for all federal actions involving TES species. 

PREVENT 30 No N/A 

There is no statute, regulation, or E.O. that outlines a “no net loss” policy to adopt for special status plant species. 

PREVENT 31 Yes 43 CFR 3162.3- 1(2) Surface use plans are required with each APD. 

Oil, Gas, and Mineral Exploration and Development (Cont.)

PREVENT 32 Yes 1 and 29 

SOPs and COAs for APDs are developed through land use planning and NEPA analysis. 

BLM Vegetation Treatment Using Herbicides I-36 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PREVENT 32 Yes 1 and 29 

SOPs and COAs for APDs are developed through land use planning and NEPA analysis. 

Oil, Gas, and Mineral Exploration and Development (Cont.)

PREVENT 34 Yes 1, 29, and 43 CFR 3162.3-1 SOPs and COAs for APDs are developed through land use planning and NEPA analysis. 

PREVENT 6 No 12 

There are no national policies regarding biological soil crusts and invasive species prevention. 

Alternative E 

PREVENT 35 No 1 and 29 

Inventory of resources is a function of land use planning and site-specific NEPA analysis. 

Disturbance to Biological Soil Crust 

PREVENT 36 Yes 12 and 29 

Resource damage and mitigation are addressed through project-level NEPA analysis. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-37 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Disturbance to Biological Soil Crust (Cont.)

PREVENT 37 No 3, 12, and 29 Livestock exclusion policies 

for ESR projects are two growing seasons, and may be extended at the discretion of he BLM based on resource recovery objectives. 

Alternative E would extend livestock exclusion for biological crust recovery to five years. 

PREVENT 7 No 5, 22, and 23 The BLM has no policies to 

maintain densities of shrub and tree establishment at historical levels to prevent excess fuels. Historical densities may be characterized by excess fuels in some cases. 

Prevention of Excess Fuels 

PREVENT 38 No 5, 22, and 23 Standards and guidelines are 

established under 43 Code of Federal Regulations (CFR) 4100 and local Resource Advisory Councils (RACs), which guide decisions for reduction or elimination of grazing. 

BLM Vegetation Treatment Using Herbicides I-38 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

PREVENT 39 No 5, 22, and 23 Livestock exclusion policies 

for ESR projects entail two growing seasons, and may be extended at the discretion of the BLM based on resource recovery objectives. 

Alternative E would extend livestock exclusion in forest and shrublands to five years. 

Prevention of Excess Fuels (Cont.)

PREVENT 40 Yes 5, 23, and 34 Local FMPs outline the use of 

fire for resource benefit and prescribed fire for each burnable acre. 

Common to all alternatives. 

RESTORE 1 Yes 4, 32, and 43 The BLM uses an IWM 

approach to vegetation treatments. 

Common to all alternatives. 

RESTORE 2 Yes 4, 29, 30, 31, 32, 

and 43 

Potential effects of projects on resources and species are analyzed at the site-specific level under NEPA. 

Common to all alternatives. 

Restoration Vegetation Treatments 

RESTORE 3 Yes 4 and 32 The BLM uses an IWM 

approach that includes all treatment methods. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-39 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

RESTORE 4 Yes 41 and 42 Ecological priorities and 

treatment area characteristics are considered in vegetation treatment design. 

Restoration Common to all alternatives. Vegetation Treatments (Cont.)

RESTORE 5 Yes 16 E.O. policy requires 

infestations to be treated where found and to prevent their further spread. 

Common to all alternatives. 

RESTORE 1 Yes 65 and Wilderness 

Act 

The BLM utilizes the Carhart Model for minimum requirements analysis and impact tool requirements in Wilderness and WSAs. 

Common to all alternatives. 

RESTORE 6 Yes 4, 8, 16, 32, and 

58 

The BLM utilizes an IWM approach to vegetation treatments. 

Common to all alternatives. 

RESTORE7 Yes 4, 8, 16, 32, and 

58 

BLM treatment priorities for invasive species infestations are developed through an IWM framework. Seasonal employees and volunteers detect and control small infestations. 

Common to all alternatives. 

Guideline 

RESTORE 8 Yes ARS, TAG Biological controls are 

authorized through ARS and approved through the national level multi-agency Technical Advisory Group (TAG). The BLM does not utilize or introduce any biological control agent that has not been approved or scientifically validated through the ARS/TAG testing programs. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-40 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

RESTORE 9 Yes 4 The BLM utilizes cultural 

treatments in an IWM framework, which includes these considerations. 

Common to all alternatives. 

RESTORE 10 Yes 4 BLM IWM and ESR practices 

consider the use of native seed and plants to compete with exotic species. 

Common to all alternatives. 

RESTORE 11 Yes 4 The BLM utilizes mechanical 

treatments in an IWM framework that includes these considerations. The BLM also participates in and helps fund operational research into effective mechanical methods. 

Common to all alternatives. 

RESTORE 12 Yes 4, 8, and 58 The BLM implements SOPs, 

best management practices, training, and certification to ensure that chemical applications minimize exposure to humans, plants, and wildlife. 

Common to all alternatives. 

RESTORE 13 Yes 58 BLM spray buffer zones for 

TES or rare species are determined as a result of specific ESA consultation with USFWS and/or NMFS. 

Alternative E would mandate 500 feet from any threatened, endangered, or sensitive (TES), or rare species. 

Guideline (Cont.)

RESTORE 14 Yes 58 Restrictions or prohibitions to 

spraying in areas of sensitive resources, such as riparian areas and aquatic and amphibian species habitat, are considered in any spray program. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-41 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

RESTORE 15 No 58 BLM policy is to survey an 

area for TES prior to any chemical pest control program. 

Alternative E would prohibit the use of herbicides in known aquatic and terrestrial and amphibian habitat. 

Guideline (Cont.)

RESTORE 16 No 58 The BLM assesses the effects 

of herbicides through detailed toxicological studies and risk assessments to ensure that the active ingredients used are capable of minimizing adverse effects on environmental and human health. 

Alternatives A, B, and D. Alternative E would require toxicology studies on all ingredients in formulation prior to approval and use. 

BLM Vegetation Treatment Using Herbicides I-42 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

RESTORE 17 No 58 The BLM utilizes sulfonylurea 

and ALS-inhibiting herbicides. 

Alternatives A, B, and D. 

Guideline (Cont.)

RESTORE 18 Yes 4, 29, and 58 These considerations and 

compliance with the Migratory Bird Treaty Act (MBTA) are considered when designing vegetation treatment projects. 

Common to all alternatives. 

RESTORE 19 Yes 3, 33, and 34 These considerations are 

required by policy under the Federal Wildland Management Policy. 

Common to all alternatives. 

RESTORE 20 Yes 29 These considerations, if 

relevant, are documented in the site-specific NEPA analysis prior to project implementation. 

Common to all alternatives. 

Prescribed Fire 

RESTORE 21 No 3, 33, and 34 Livestock exclusion policies 

for ESR and prescribed fire projects are two growing seasons, and may be extended at the direction of the BLM based on resource recovery objectives. 

Alternative E would extend livestock exclusion from all burned areas (natural or prescribed) for five years. 

BLM Vegetation Treatment Using Herbicides I-43 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Prescribed Fire (Cont.) 

RESTORE 22 Yes Prescribed Fire 

Handbook 

These considerations are part of the Prescribed Fire Burn Plan. 

Common to all alternatives. 

RESTORE 23 Yes 3 and 33 Fuels reduction activities to 

restore natural fire processes are based on plans and assessments with clear objectives. The BLM utilizes an IWM approach to vegetation treatments, which includes consideration of combinations of active and passive methods. 

Fuels Reduction Common to all alternatives. 

RESTORE 24 No 3, 34, 37, 39, and 

63 

Post-fire assessments and ESR plans are used to determine the disposition of standing trees. Commercial salvage or stewardship contracts may be utilized on standing trees following fire. Standing snags are valued as wildlife habitat features, and are left intact to meet habitat objectives and where public safety is not compromised. 

Fire Suppression RESTORE 25 Yes 32 Vehicle equipment cleaning is 

a standard fire program prevention measure. Fire line rehabilitation is considered in the ESR plan. 

BLM Vegetation Treatment Using Herbicides I-44 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

RESTORE 26 No 3, 4, and 34 Post-fire disturbance is 

minimized where possible; however, some burn areas may require extensive and immediate rehabilitation work using mechanical methods to stabilize watersheds to minimize post-fire flooding from erosion due to loss of plant cover. ESR plans outline the measures that are required for recovery of burned areas. 

Alternatives A, B, C, and D. Alternative E would rely on natural recovery over stabilization and rehabilitation. 

Fire Suppression (Cont.)

RESTORE 27 Yes 39 All fire suppression-related 

logistical facilities, such as fire camps, helispots, equipment staging areas, and fire lines, are rehabilitated as part of the post-fire operations. Monitoring occurs as needed. 

Forage Enhancement RESTORE 28 No 16 Forage enhancement project 

objectives are based on land use plan goals. Project objectives may not necessarily include objectives to encourage native species or result in no net loss of native plant communities 

N/A 

Revegetation REVEG 1 

Yes 4 The BLM utilizes native seeds and seedlings from locally- adapted sources, where possible. Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-45 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Revegetation (Cont.) REVEG 2 No 4 and 32 Native seed availability does 

not drive rehabilitation project feasibility or implementation. Intermediate species may be used when native seed is unavailable. Project funding and implementation for ESR projects is required within the same season as the fire event, and projects may be funded for up to 3 years post fire. BLM funding is determined annually by Congress, and funding processes do not allow the agency to set aside funds for out-year project work. 

REVEG 3 No 3, 39, and FAR All seed bought and used by 

the BLM is required to be noxious weed free. There are no industry standards for defining and screening out non-native species “persistence” in seed mixes. 

Common to all alternatives. 

REVEG 4 Yes BLM has no authority to 

provide growers seed purchase assurance. Contracting procedures can utilize indefinite delivery and indefinite quantity (IDIQ) provisions for seed contracts. BLM seed storage facilities are sufficient for major revegetation efforts. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-46 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Revegetation (Cont.) REVEG 5 No Habitat requirements for 

extirpated species are determined in conjunction with state wildlife agencies, USFWS recovery plans through ESA consultation procedures, and land use plan goals and objectives. 

REVEG 6 No State wildlife agency and 

USFWS recovery plans outline the potential for reintroduction of extirpated species into specific areas. 

REVEG 7 Yes 4, 32, 40, et al. Collaboration with federal, 

state, local, and private land managers is outlined and required in numerous national policy documents. 

Common to all alternatives. 

REVEG 8 Yes 4, 32, and 40 Ongoing public education 

practice throughout BLM field offices. 

Common to all alternatives. 

REVEG 9 Yes 4, 32, and 40 Standard considerations in 

ESR plan development. Reseeding criteria may include the potential for severe erosion within the first two seasons following fire, and may not necessarily be tied to natural regeneration potential. 

Common to all alternatives. 

Monitoring and Evaluation 

MONITOR 1 Yes 9, 11, 40, and 43 Baseline data, existing 

conditions, and monitoring data are all considered in vegetation treatment project design. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-47 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Monitoring and Evaluation (Cont.)

MONITOR 2 No 9, 11, 40, and 43 Baseline conditions, as well as 

monitoring goals and objectives, are identified based on local data needs and the type of monitoring that needs to be accomplished for the specific project proposal. 

MONITOR 3 No 9, 11, 40, and 43 Monitoring and evaluation take 

into consideration most of the points addressed, with the exception of documentation into a central database for 17 states. 

MONITOR 4 

Yes 9, 11, 40, and 43 Monitoring methods contain 

these considerations. 

Common to all alternatives. 

MONITOR 5 Yes 9, 11, 40, and 43 Each project proposal must 

conform to relevant goals and objectives, as identified in guiding land use and other plans. Monitoring is built on project proposals. 

Common to all alternatives. 

MONITOR 6 Yes 1, 9, 11, 40, and 

43 

Objectives and standards are written to be measurable and quantifiable. Professional judgment is also used, as appropriate. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-48 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Monitoring and Evaluation (Cont.)

MONITOR 7 No 9, 11, 40, and 43 There are currently no BLM 

program requirements for each field office to prepare an annual monitoring report to be reported through a central database. However, features of the BLM’s National Monitoring Initiative, such as a national website, will serve as a clearinghouse for monitoring reports and summaries as they are developed. 

MONITOR 8 No 9, 11, 40, and 43 Monitoring uses different time 

intervals for different programs or projects. For example, Land Use Plan monitoring is set by regulation at 5-year intervals. 

MONITOR 9 Yes 9, 11, 40, and 43 Project design includes a 

description of the relevant required monitoring. 

Common to all alternatives. 

MONITOR 

10 

No The type of annual monitoring 

plan related to oil and gas activities is not defined in the RNE submission. 

MONITOR 

11 

No 9, 11, 34, 39, 40, 

and 43 

All fire-suppression-related logistical facilities, such as fire camps, helispots, equipment staging areas, and fire lines, are rehabilitated as part of the post-fire operations. Monitoring occurs as needed. 

BLM Vegetation Treatment Using Herbicides I-49 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Monitoring and Evaluation (Cont.)

MONITOR 

12 

Yes 9, 11, 40, 43, and 

50 

Monitoring progress toward attainment of long-term health and integrity of watersheds for specific resources is guided by the resource monitoring requirements of the program, regulation, or statute. 

Common to all alternatives. 

Tribal Relations TRIBES 1 Yes 19 and 60 Tribal consultation is part of 

the government-to-government and fiduciary trust responsibilities of the federal government. 

Common to all alternatives. 

TRIBES 2 Yes 19 and 60 Tribal consultation is part of 

the government-to-government and fiduciary trust responsibilities of the federal government. 

Common to all alternatives. 

TRIBES 3 Yes 19, 60, and E.O. 

12898 

Environmental Justice must be included in all BLM and NEPA analyses. 

Common to all alternatives. 

TRIBES 4 Yes 19, 60, 62, and 63 To the extent shared by Tribal 

representatives, culturally significant resources and places are identified by the BLM. 

Common to all alternatives. 

TRIBES 5 No 63 Identification and protection of 

resources of cultural significance to Native Americans is accomplished through site-specific consultation. 

Alternatives A, B, C, and D. Alternative E would require development of protocols for enhancement of culturally significant plants. 

BLM Vegetation Treatment Using Herbicides I-50 June 2007 

Final Programmatic EIS
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Tribal Relations (Cont.)

TRIBES 6 No 60 The BLM does not establish 

herbicide-free zones for any resources. Use of herbicides is determined based on project needs in an IWM framework and the results of Native American consultation. In those cases where herbicides are not compatible with resources or resource uses, alternate treatment methods are considered. 

Alternative E. 

TRIBES 7 Yes E.O. 12898, and 

EPCRA 

Notification occurs in compliance with E.O. 12898 for Native Americans and atrisk populations, as well as all publics under community right-to-know statutes. 

Common to all alternatives. 

TRIBES 8 No 63 Monitoring has been addressed 

above. There are no requirements under FLPMA or Native American statutes that require protection of culturally significant plant and animal resources for seven generations. 

Coordination, Education, and Public Awareness 

CEPA 1 Yes 32 The Partners Against Weeds 

(PAW) Action Plan provides for identifying prevention activities. 

Common to all alternatives. 

CEPA 2 No 29, 32, and 43 Site-specific treatment 

decisions are based on NEPA analyses. 

Common to all alternatives. 

BLM Vegetation Treatment Using Herbicides I-51 June 2007 

Final Programmatic EIS
TABLE I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 

Goal Action 

Current 

BLM Policy 

(Yes/No) 

Policy Source 

(refer to key at 

end of table) 

Policy Analysis Alternative Comparison 

Coordination, Education, and Public Awareness (Cont.)

CEPA 3 Yes National websites National websites exist for 

invasive species, fire management, and the BLM’s weed program. Not all websites are structured to provide a comprehensive lessons learned venue for vegetation treatment projects. 

CEPA 4 

BLM Vegetation Treatment Using Herbicides I-52 June 2007 

Final Programmatic EIS

Yes 43 The BLM has various 

incentives and awards programs in place for vegetation management and land stewardship, as well as weeds and invasive species control and management. 

Common to all alternatives. 

CEPA 5 No 43 BLM funding for vegetation 

treatments does not follow the process assumed under CEPA 5. 

CEPA 6 Yes 32 and 40 Fire Wise and invasive species 

education are ongoing aspects of the BLM’s Fire Program and Invasive Species Program. 

Common to all alternatives. 

Key to policy source references: 

1. Land Use Planning Handbook (BLM H-1601-1) 2000. 2. Land Use Planning (BLM 1601-1). 3. Emergency Fire Rehabilitation Handbook (BLM H-1742), July, 1998 (http://www.blm.gov/nhp/efoia/wo/fy98/im98-148.html). 

4. BLM Manual 9015 - Integrated Weed Management. 5. BLM Manual H-4180 - Rangeland Health Standards. 6. BLM Manual Section 660 - Fish, Wildlife and Special Status Plant Resource Inventory and Monitoring . 

7. Departmental Manual Part 517: Pesticide Use Policy. 8. Departmental Manual Part 609: Weed Control Program. 9. BLM Inventory and Monitoring (TR 1734-7) Ecological Site Inventory, December, 2001. 10. BLM Riparian-Wetland Area Management (TR-1737). 11. BLM Riparian Area Management (TR 1737-15), 1998. 
Table I-1 (Cont.) 

Bureau of Land Management Analysis of Restore Native Ecosystems Proposal

BLM Vegetation Treatment Using Herbicides I-53 June 2007 

Final Programmatic EIS

12. BLM Biological Soil Crusts: Ecology and Management (TR 1730-2), 2001. 13. Final Environmental Impact Statement Vegetation Treatment on BLM Lands in Thirteen Western States, May, 1991. 14. (http://elips.doi.gov/elips/release/3042.htm). Date accessed: 1/28/03. 

15. Instruction Memorandum No. 99-178, Subject: Interim Guidance – Changes to the list of critical elements of the human environment in BL

Policy Act (NEPA) Handbook. (http://www.blm.gov/nhp/efoia/wo/fy99/im99-178.htm). Date accessed: 2/5/03. 

16. Executive Order 13112 - Invasive Species (February 3, 1999). 17. Executive Order 11987- 42 F.R. 26949 – Exotic Organisms (May 24, 1977). 18. Executive Order 11514 - Protection and Enhancement of Environmental Quality (March 7, 1970). 19. Executive Order 13175 - Consultation and Coordination with Indian Tribal Governments (http://www.epa.gov/fedrgstr/eo/eo13175.html). 

20. Executive Order 11644 - Use of off-road vehicles on the public lands (February 8, 1972). 21. Off-Road Vehicles (43 CFR Part 8340). 22. Authorized Grazing Use (43 CFR Subpart 4130). 23. Rangeland Health Standards (43 CFR 4180.09). 24. Standards and guidelines for grazing administration (43 CFR 4180.2). 25. EIS for Surface Management Regulation for Locatable Mineral Operations, (43 CFR 3809), October 2000. 26. Federal Land Policy and Management Act of 1976, (43 U.S.C. 170). 27. Public Rangelands Improvement Act Of 1978, (43 U.S.C. §§ 1901-1908). 28. The Carson Foley Act, (Public Law 90-583), October 17, 1968. 29. The National Environmental Policy Act of 1969 (NEPA), as amended (Pub. L. 91-90, 42 U.S.C. 432l et Seq.) (http://web.blm.gov/internal/w

1.htm#III). Last date accessed: 2/7/03. Also: (http://www.ak.blm.gov/ado/neparefs/hb-toc.html). Last date accessed 2/7/03. 

30. Federal Noxious Weed Act of 1974, (7 U.S.C. §§ 2801-2814), January 3, 1975, as amended 1988 and 1994. 31. Weeds: Memorandum of Understanding between (various parties including the Bureau of Land Management), BLM California. 

(http://www.ca.blm.gov/caso/weeds_mou.html). Date accessed: 2/4/03. 

32. Partners Against Weeds – An Action Plan for the Bureau of Land Management. (http://www.blm.gov/education/weed/paws/summery1.html33. Northwest Forest Plan: Authoritative Documents (http://libweb.uoregon.edu/govdocs/forestpl.html). Date accessed: 1/16/03. 

34. Review and Update of the 1995 Federal Wildland Fire Management Policy, January, 2001. 

35. The Northwest Forest Plan – A report to the President and Congress. USDA Office of Forestry and Economic Assistance. December, 1996. 

State College, Grand Junction, CO. 

36. USDA Forest Service North Central Research Station: The National Fire Plan- Research and Development. 2001 Business Summary. 

37. Healthy Forests – An Initiative for Wildfire Prevention and Stronger Communities. August 22, 2002. 38. Unified Federal Policy for a Watershed Approach to Federal Land and Resource Management. (http://www.tmdl.org/ineel/docs/waterpolicy

1/15/03. 

39. Federal Wildland Fire Policy. (http://www.fs.fed.us/land/wdfirex.htm). Date accessed: 1/15/03. 

40. Pulling Together – National Strategy for Invasive Plant Management, 1997. 41. Ecosystem Management in the BLM: From Concept to Commitment, 1994. 42. Blueprint for the Future. 1994. 43. BLM Strategic Plan for FY 2000 – 2005. 44. Creeks and Communities: A continuing strategy for accelerating cooperative riparian restoration and management. December, 2002. 45. Standards for Rangeland Health and Guidelines for Livestock Grazing Management for Public Lands Administered by the Bureau of Land M

Oregon and Washington, August 12, 1997. 

46. Best management Practices for Oil Exploration and Extraction. (http://www.epa.state.il.us/). 
TABLE I-1 (Cont.) Bureau of Land Management Analysis of Restore Native Ecosystems Proposal 47. Normal Fire Rehabilitation Plan Supplement, Environmental Assessment, Coyote Fire, X284 BLM/Ek/PL 2001/070. 48. Final Wilderness Character Inventory Evaluation, Vermillion Basin, June 26, 2001. 49. Report on Management of the Moquith Mountain Wilderness Study Area Staff Report, March 27, 2001. 50. Unified Federal Policy for a Watershed Approach to Federal and Resource Management (http://www.epa.gov/fedrgstr/EPA-IMPACT/2000/

18/i26566.htm). Last date accessed 2/7/03. 51. Northwest Area Noxious Weed final EIS and Supplement (BLM 1989a, 1987a). 52. Western Oregon Management of Competing Vegetation final EIS (BLM 1989b). 53. California Vegetation Management final EIS (BLM 1989a). 54. Vegetation Management in the Coastal Plan/Piedmont final EIS (USDA 1989). 55. Eradication of Cannabis on Federal Lands in the Continental United States final EIS (DEA 1985). 56. EPA American Indian Environmental Office. (http://www.epa.gov/indian/index.htm). 57. National Management Strategy for Motorized Off-Highway Vehicle Use on Public Lands, January 2001 (http://www.or.blm.gov:80/ResourcStrategy/OHV_FNLc.pdf). 58. BLM Manual 9011 Chemical Pest Control. 59. Executive Order 11990, Protection of Wetlands (42 F.R. 26962). 60. General Procedural Guidance For Native American Consultation, (BLM H-8160-1). 61. American Indian Religious Freedom Act (Public Law 95-341). 62. National Historic Preservation Act. 63. Cultural Resource Management Handbook (H-8100). 64. Healthy Forests Restoration Act of 2003. 65. BLM Handbook H-8550-1 Interim Management Policy for Lands under Wilderness Review. 66. Prescribed Fire Handbook. 

67. E.O. 12898. 

BLM Vegetation Treatment Using Herbicides I-54 June 2007 

Final Programmatic EIS