3 Bars Ecosystem and Landscape 

Restoration Project

Final Environmental Impact Statement

Volume 2: Chapters 4 through 7, Appendices, and 

Response to Comments on Draft EIS

October 2016

Cooperating Agencies: 

Eureka County

National Park Service 

Nevada Department of Wildlife

Mount Lewis Field Office 

50 Bastian Road

Battle Mountain, NV 89820 

Phone: 775-635-4000 

Fax: 775-635-4034 

U.S. Department of the Interior 

Bureau of Land Management

Environmental Impact Statement 

BLM-NV-BM/ES/16-07+1793
Final Environmental Impact Statement

3 Bars Ecosystem and Landscape Restoration Project

Volume 2: 

Chapters 

4 – 7 

Appendices

Response 

to Comments 

on Draft EIS

DOI

BLM

October

2016
TABLE OF CONTENTS AND LIST OF 

TABLES 
This page left blank intentionally.
TABLE OF CONTENTS 

TABLE OF CONTENTS 

VOLUME TWO 

Chapter 4. Consultation and Coordination ...............................................................................................................4-1

4.1 Preview of this Section.............................................................................................................................................4-1

4.2 Summary of Major Changes between the Draft and Final EIS...........................................................................4-1

4.3 Public Involvement ..................................................................................................................................................4-1

4.3.1 Public Scoping ...........................................................................................................................................4-1 

4.3.1.1 Federal Register Notices and Newspaper Advertisements.......................................................................4-1

4.3.2 Public Review and Comment on the Draft EIS ........................................................................................4-2

4.4 Agency Coordination and Consultation ..................................................................................................................4-3

4.4.1 Endangered Species Act Section 7 Consultation ......................................................................................4-3

4.4.2 Cultural and Historic Resource Consultation ............................................................................................4-3

4.5 Government-to-Government Consultation ..............................................................................................................4-3

4.6 List of Preparers of the 3 Bars EIS ..........................................................................................................................4-4

Chapter 5. References ..................................................................................................................................................5-1 

Chapter 6. Glossary ......................................................................................................................................................6-1 

Chapter 7. Index ...........................................................................................................................................................7-1 

Appendixes 

Appendix A. Common and Scientific Names of Plants and Animals Given in this EIS ...................................... A-1 

Appendix B. Programmatic Agreement between the Mount Lewis Field Office of the BLM and the State 

Historic Preservation Officer ............................................................................................................... B-1 

Appendix C. Standard Operating Procedures .......................................................................................................... C-1 

C.1 General Standard Operating Procedures ................................................................................................................ C-1 

C.2 Project Specific Standard Operating Procedures ................................................................................................... C-1 

C.2.1 General ........................................................................................................................................................ C-1 

C.2.2 Livestock ................................................................................................................................................... C-12

C.2.3 Wild Horses ............................................................................................................................................... C-14

C.2.4 Erosion Control ......................................................................................................................................... C-16

C.2.5 Planting and Seeding ................................................................................................................................ C-16

C.2.6 Protective Fences ...................................................................................................................................... C-16

C.2.7 Riparian Management ............................................................................................................................... C-17

C.2.8 Aspen Management .................................................................................................................................. C-18

C.2.9 Pinyon-juniper Management .................................................................................................................... C-19

C.2.10 Sagebrush Management ............................................................................................................................ C-19

C.2.11 Prescribed Fire and Fire for Resource Benefit ......................................................................................... C-20

3 Bars Project Final EIS TOC - i October 2016
TABLE OF CONTENTS 

3 Bars Project Final EIS TOC - ii October 2016

C.2.12 Activity Fuel Disposal Methods ............................................................................................................... C-20

C.3 Special Precautions 

C.3.1 Prevention of Weeds and Early Detection and Rapid Response ....................................................... C-22

 C.3.2 Plants and Animals ............................................................................................................................. C-23

 C.3.3 Native American Concerns and Cultural Resources ......................................................................... C-26

 C.3.4 Paleontological Resoures .................................................................................................................... C-27

 C.3.5 Wilderness Study Areas ..................................................................................................................... C-28

C.4 References ........................................................................................................................................................ C-29

Appendix D. Response to Public Comments on the Draft EIS .............................................................................. D-1 

D.1 Introduction ........................................................................................................................................................ D-1

D.2 Comment Response Process .............................................................................................................................. D-1

D.3 Quantitative Analysis of Comments Received .................................................................................................. D-1 

D.3.1 Summary of Comments Received on the Draft EIS and the Response Process ................................ D-1

D.3.2 Public Meetings and Oral Comments .................................................................................................. D-2 

D.3.3 Comments by Affiliation ..................................................................................................................... D-2

D.4 Summary of Issues Identified in Non-substantive Comments .......................................................................... D-2 

D.5 Summary of Issues Identified in Substantive Comments.................................................................................. D-3

D.5.1 Air Quality ............................................................................................................................................ D-5 

D.5.2 Alternatives .......................................................................................................................................... D-7 

D.5.3 Assessment Methodology ..................................................................................................................D-12

D.5.4 Cumulative Effects .............................................................................................................................D-19

D.5.5 Fish and Other Aquatic Resources ....................................................................................................D-23

D.5.6 Glossary ..............................................................................................................................................D-26

D.5.7 Livestock Grazing ..............................................................................................................................D-27

D.5.8 Meteorology and Climate Change .....................................................................................................D-34

D.5.9 Mitigation and Monitoring .................................................................................................................D-35

D.5.10 Native and Non-invasive Vegetation Resources ...............................................................................D-37

D.5.11 Noxious Weeds and other Invasive Non-native Vegetation .............................................................D-55

D.5.12 Proposed Action and Purpose and Need ............................................................................................D-57

D.5.13 Recreation ...........................................................................................................................................D-61

D.5.14 Social and Economic Values and Environmental Justice .................................................................D-62

D.5.15 Soil Resources ....................................................................................................................................D-62

D.5.16 Standard Operating Procedures ..........................................................................................................D-66

D.5.17 Vegetation Treatments Planning and Management ..........................................................................D-68

D.5.18 Water Resources .................................................................................................................................D-85

D.5.19 Wetlands; Floodplains; and Riparian Zones ......................................................................................D-90

D.5.20 Wilderness Study Areas and other Special Management Areas .......................................................D-92

D.5.21 Wild Horses ........................................................................................................................................D-93

D.5.22 Wildland Fire and Fire Management .................................................................................................D-98

D.5.23 Wildlife Resources ...........................................................................................................................D-106

D.6 References ......................................................................................................................................................D-113

D.7 List of Agencies, Non-government Organizations, and Individual Providing Comments ..........................D-117
TABLE OF CONTENTS 

3 Bars Project Final EIS TOC - iii October 2016

D.7.1 List of Agencies Providing Comments ...........................................................................................D-117

D.7.2 List on Non-government Organizations Providing Comments ......................................................D-117

D.7.3 List of Individuals Providing Comments ........................................................................................D-117

D.8 Comment Letters ...................................................................................................................................................D-169

Appendix E. ARMPA-MD Fire 23 Documentation ................................................................................................ E-1 

List of Tables 

4-1 List of Preparers of the 3 Bars EIS.....................................................................................................................4-5 

C-1 Vegetation Treatment Methods Standard Operating Procedures and Guidelines ........................................... C-2 

C-2 Raptor Nest Buffers ......................................................................................................................................... C-25

D-1 Affiliation of Commenters on the Draft EIS .................................................................................................... D-2 

D-2 Summary of Comment Topics and Where Addressed in this Appendix ......................................................... D-3 
TABLE OF CONTENTS 

3 Bars Project Final EIS TOC - iv October 2016

This page left blank intentionally.
CHAPTER 4 

CONSULTATION AND COORDINATION 
This page left blank intentionally.
CONSULTATION AND COORDINATION 

CHAPTER 4 

CONSULTATION AND COORDINATION 

4.1 Preview of this Section 

This section summarizes the public involvement, scoping, and Draft EIS review process for the preparation of the 3 

Bars Project EIS. Summaries of agency and government-to-government consultation are provided. The individual 

preparers of the EIS, with their areas of expertise and/or responsibility, are also listed. 

4.2 Summary of Major Changes between the Draft and 

Final EIS 

One major change was made to the 3 Bars Project Draft EIS and incorporated into this chapter of the Final EIS 

based on public comments on the Draft EIS. This change is (and Section where the change is made): 

1. Added a new section describing public review and comment on the Draft EIS (Section 4.3.2). 

4.3 Public Involvement 

4.3.1 Public Scoping 

4.3.1.1 Federal Register Notices and Newspaper Advertisements 

On January 25, 2010, the BLM published a Notice of Intent in the Federal Register (Volume 75, Number 15, 

pages 3916-3917) notifying the public that the BLM had formed a team to prepare an EIS on restoration activities 

proposed for the 3 Bars Ecosystem. The Notice stated that public comments on the proposal would be accepted 

until February 24, 2010. However, the BLM stated at the public scoping meetings that it would consider all 

comments received prior to the close of the scoping period or 15 days after the last public meeting, whichever was 

later, during development of the Draft EIS. The last scoping meeting was on February 23, 2010, and scoping 

comments were accepted through March 10, 2010. The dates and locations of the scoping meetings were 

announced at least 15 days in advance through local new media, newspapers, and the BLM web site at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field.html. 

3 Bars Project Final EIS 4-1 October 2016 
CONSULTATION AND COORDINATION 

4.3.1.2 Scoping Meetings 

Public scoping meetings were held in Battle Mountain on February 22 and Eureka, Nevada, on February 23, 2010. 

The scoping meetings were conducted in an open-house style. Informational displays were provided at the 

meetings, and handouts describing the project, the NEPA process, and issues/alternatives were given to the public. 

A formal presentation provided the public with additional information on program goals and objectives. 

Representatives from the BLM and their consultant responsible for preparing the EIS were present to answer 

questions from the public. 

The BLM received 24 comment letters on the proposed 3 Bars Project EIS. In addition, comments were recorded 

from informal discussions with the public at the public scoping meetings. However, not all individuals commenting 

orally at the meeting were able to be identified, making it difficult to determine the exact number of individuals 

presenting comments at the meetings. Based on written and oral comments given during the scoping period, 637 

catalogued individual comments were recorded during scoping for the 3 Bars Project EIS. 

A Scoping Comment Summary Report for the 3 Bars Ecosystem and Landscape Restoration Project EIS (Scoping 

Report; AECOM 2010) was prepared that summarized the issues and alternatives identified during scoping. This 

document was made available to the public in February 2012 on the 3 Bars Project website at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/national_environmental/0.html. 

4.3.2 Public Review and Comment on the Draft EIS 

The Notice of Availability of the Draft Environmental Impact Statement for the 3 Bars Ecosystem and Landscape 

Restoration Project in Eureka County, NV was published in the Federal Register on September 27, 2013 (Federal 

Register, Volume 78, Number 188, Pages 59712-59713). The public comment period was originally scheduled 

from September 27 through November 12, 2013; however, due to a government shutdown, a notice extending the 

public comment period to November 29, 2013, was published in the Federal Register on November 12, 2013 

(Federal Register, Volume 78, Number 218, Pages 67392-67393). The BLM issued a news release on September 

27, 2013, notifying the public that the Draft EIS was available for public review, and listing the schedule for public 

comment hearings. The BLM also issued a news release on October 22, 2013, notifying the public that the 

comment period had been extended due to the government shutdown. Information on the Draft EIS was also posted 

on the BLM website. The public was able to access the website to download a copy of the Draft EIS. 

A public meeting was held in Eureka, Nevada, on November 7, 2013. The Draft EIS meeting was conducted in an 

open-house style. Informational displays were provided at the meeting, and handouts describing the project, the 

NEPA process, and issues/alternatives were given to the public. In addition, a formal presentation provided the 

public with additional information on program goals and objectives. Representatives from the BLM and their 

consultant responsible for preparing the Draft EIS were present to answer questions from the public. Three 

individuals attended the meeting, in addition to BLM and contractor staff. 

The BLM accepted all comments received from September 27 through November 29, 2013. Over 6,800 comment 

submissions were received on the Draft EIS; nearly all (99 percent) of these were from a non-government 

organization mass mailing. Comments included letters and electronic mail. Appendix D of this Final EIS contains a 

summary of the issues and includes BLM responses to specific comments. 

3 Bars Project Final EIS 4-2 October 2016 
CONSULTATION AND COORDINATION 

4.4 Agency Coordination and Consultation 

4.4.1 Endangered Species Act Section 7 Consultation 

As part of this EIS, the BLM consulted with the USFWS as required under Section 7 of the Endangered Species 

Act. The BLM prepared a formal initiation package that included: 1) a description of the program, listed threatened 

and endangered species, species proposed for listing, and critical habitats that may be affected by the program; and 

2) a Biological Assessment for the 3 Bars Ecosystem and Landscape Restoration Project (USDOI BLM 2014). The 

Biological Assessment (BA) evaluated the likely impacts to listed species, species proposed for listing, and critical 

habitats from the 3 Bars Project and identified management practices to minimize impacts to these species and 

habitats. Consultation is ongoing and will be completed before publication of the ROD. 

4.4.2 Cultural and Historic Resource Consultation 

The BLM consulted with the Advisory Council on Historic Preservation and Nevada SHPO as part of Section 106 

consultation under the National Historic Preservation Act to determine how proposed treatment actions could 

impact cultural resources. A Programmatic Agreement between the Mount Lewis Field Office of the Bureau of 

Land Management and the Nevada State Historic Preservation Officer regarding National Historic Preservation 

Act Compliance for the 3Bars Ecosystem and Landscape Restoration Project, Eureka County, Nevada, was 

prepared to ensure that historic properties will be treated to avoid or mitigate effects to the extent practicable to 

satisfy the BLM’s National Historic Preservation Act Section 106 responsibilities for all aspects of the 3 Bars 

Project (Appendix B). Consultation is ongoing and will be completed before publication of the ROD. Formal 

consultations with the Nevada SHPO and Native American tribes also may be required during implementation of 

projects at the local level. 

4.5 Government-to-Government Consultation 

Federally-recognized tribes have a unique legal and political relationship with the government of the United States, 

as defined by the U.S. Constitution, treaties, statutes, court decisions, and executive orders. These definitive 

authorities also serve as the basis for the federal government’s obligation to acknowledge the status of federally 

recognized tribes. 

The BLM consults with federally recognized tribes, consistent with the Presidential Executive Memorandum dated 

April 29, 1994, on Government-to-Government Relations with Native American Tribal Governments; and 

Executive Order 13175 dated November 6, 2000, on Consultation and Coordination with Indian Tribal 

Governments. 

The BLM consults with federally recognized tribes before making decisions or undertaking activities that will have 

a substantial, direct effect on federally recognized tribes, or their assets, rights, services, or programs. The BLM 

initiated consultation with various tribes and bands of the Western Shoshone to identify their cultural values, 

religious beliefs, traditional practices, and legal rights that could be affected by BLM actions. This included 

sending out letters to the tribes and groups that could be directly affected by vegetation treatment activities, 

3 Bars Project Final EIS 4-3 October 2016 
CONSULTATION AND COORDINATION 

requesting information on how the proposed activities could impact Native American interests, including the use of 

vegetation and wildlife for subsistence, religious, and ceremonial purposes, and conducting meetings and site visits 

with the interested tribes by the BLM’s Native American Coordinator. The results of the meetings and trips are 

summarized in the 3 Bars Ecosystem and Land Restoration Project: Native American Contacts Review (Bengston 

Consulting 2012). Tribes consulted for the project are: 

 Te-Moak Tribe of Western Shoshone and constituent bands: 

o Battle Mountain Band 

o South Fork Band 

o Elko Band 

 Duckwater Shoshone Tribe 

 Ely Shoshone Tribe 

 Yomba Shoshone Tribe. 

4.6 List of Preparers of the 3 Bars EIS 

The following specialists (and company/agency and area of specialty) that participated in the development of the 

EIS are listed below (Table 4-1). Agencies included the BLM, NDOW, National Park Service, and Eureka County 

Board of Commissioners. Subcontractors that provided assistance to the BLM during preparation of the EIS 

included AECOM, Bengston Consulting, Blankenship Consulting, Eastern Nevada Landscape Coalition, and

Sammons/Dutton Consulting. 

3 Bars Project Final EIS 4-4 October 2016 
CONSULTATION AND COORDINATION 

TABLE 4-1 

List of Preparers of the 3 Bars EIS 

3 Bars Project Final EIS 4-5 October 2016 

Contributor Areas of Specialty Years of 

Experience Highest Degree/Education 

Bureau of Land Management 

Ethan Arky Recreation, Wilderness, 

Auditory Resources 

Visual, and 

1 B.S., Recreation, 

Studies 

Park, and Leisure 

Noxious Weeds and Invasive and NonKent Bloomer native Species, and Health and Human 

Safety 

5 M.A., Geography 

Chris Cook Field Manager 15 M.S., Anthropology 

Ethan Ellsworth Wildlife and Special Status Species 20 Ph.D., Wildlife Resources 

Steve Foree 

Team Leader, Project Manager, 

Contracting Officer’s Representative, 

Native American Coordinator 

and 32 B.S., Biology 

Kathy Graham Geographic Information System Mapping 16 B.S., Wildlife Management 

Dorothy Harvey Information Technology 

Acting Public Affairs Of

Specialist and 

ficer 

20 B.S., Business Technology 

Ashley Johnson Rangeland, Soils, and Vegetation 4 M.S., Rangeland Management/ 

Watershed Management 

Casey Johnson Rangeland, Soils, and Vegetation 10 B.S., Range Resources Management 

Cheryl LaRoque Hazardous Materials 12 B.S., Environmental Science 

Chad Lewis 

Team Leader, 

Forestry, Fire 

Quality 

Project Manager, 

Management, and 

Fuels, 

Air 20 B.S., Forestry 

Management 

and Natural Resource 

Nancy Lockridge Land Use 10 A.A., Business 

Shawna Richardson Wild Horses and Burros 20 B.S., Natural Resource Management 

Kat Russell Cultural Resources, Geographic 

Information System, and Paleontology 

30 B.A., Archaeology 

Alden Shallcross 

Riparian Soils, Water Quality and 

Quantity, and Wetlands, Floodplains, 

Riparian Zones 

and 2 M.S., Hydrologic Sciences 

Jon Sherve Minerals, Mining, and Geology 17 M.S., Hydrology/Hydrogeology 

Gloria Tibbetts NEPA, Environmental 

and Economic Values 

Justice, and Social 

9 B.A., 

Maste

Environmental Studies, and 

r of Public Administration 

Josh Tibbetts Fuels, Fire Management, and Air Quality 13

Undergraduate Certificate - 

Biological Sciences for Federal 

Land Managers 
CONSULTATION AND COORDINATION 

3 Bars Project Final EIS 4-6 October 2016 

TABLE 4-1 (Cont.) 

List of Preparers of the 3 Bars EIS 

Contributor Areas of Specialty Years of 

Experience Highest Degree/Education

Bureau of Land Management (Cont.)

Noxious Weeds and Invasive and NonMike Vermeys native Species and Health and Human 

Safety

16 B.A., Biology

Nevada Department of Wildlife

Steve Foree Wildlife 32 B.S., Biology

Alan Jenne Habitat 19 B.S., Wildlife Management

Mike Podborny Wildlife 27 B.S., Wildlife Ecology

Mike Starr Fisheries 2

B.S., Wildlife Ecology 

Conservation

and 

Eureka County 

Jake Tibbitts Natural Resources and Socioeconomics 8

M.S., Geographic Information 

Science – Geospatial Rangeland

National Park Service

Lee Kreutzer Cultural Resources and Historic Trails 20 Ph.D., Archaeology

AECOM

Kimberly Anderson 

Noxious Weeds 

Human Health

and Invasive Species and

14 M.S., Botany

Bill Berg Geology, Topography, 

Paleontology

Minerals, and 24 M.S., Geology

Robert Berry Groundwater Resources 37 Ph.D., Geology and Geochemistry

Jim Burrell Surface Water Resources 33 M.S., Surface Water Resources

Sergio Cappozi Recreation 12 M.S., Forestry

Sue Coughenour Document Production 26 General Studies Degree

Rollin Daggett Fish and other Aquatic Resources 36 M.S., Aquatic Ecology

Richard Deis Archaeology 22 M.A., Archeology

Doree DuFresne Project Coordinator 25 B.S., Biology and Chemistry

Chris Dunne

Livestock 

Horses

Grazing, Rangeland, and Wild 

15 B.S., 

Management

Natural Resources 

David Fetter Water Resources 8 B.S., Watershed Science

Steve Graber

Land Use, Wilderness 

Socioeconomics

Study Areas, and 8 B.S.,

Mana

Natural Resources 

gement, B.A., Economics

Liza Gould Fish and Wildlife Resources 13 B.S., Botany

Ecology

and Vegetation 

Jim Harvey Administrative Record 25 B.A., Physics, Mathematics and 

Economics
CONSULTATION AND COORDINATION 

TABLE 4-1 (Cont.) 

List of Preparers of the 3 Bars EIS 

Years of Contributor Areas of Specialty Highest Degree/Education Experience 

AECOM(Cont.) 

Steve Heipel Cultural Resources 33 B.S., Anthropology

M.A., Environmental Studies and 

Ashley Lunde Fire, Forestry, and Hazardous Materials 7 Political Science 

M.S., Environmental Policy and 

Melanie Martin Assistant Project Manager 13 Management and Natural Resources 

Management 

Terra Mascarenas Soil Resources 15 B.S., Soil and Crop Science 

B.S., Geology, Master of Business Tina Mirabile Human Health 13

Administration 

Merlyn Paulson Visual Resources 36 M.S., Landscape Architecture 

Kathy Paulus Administrative Record 26 M.Ed., Education

Project Manager, Wildlife Resources, and 

Stuart Paulus 33 Ph.D., Wildlife Ecology Fire Management 

M.S., Watershed Science, and Brent Read Geographic Information System Lead 11

Geographic Information System 

Peggy Roberts Public Participation 15 M.S., Biolo gy

Vince Scheetz Air Quality 43 M.S., Systems Management 

M.S., Geographic Information Jason Thoene Geographic Information System 13

System 

Petra Unger Vegetation 19 Diploma (similar to M.S.), Biology 

Bengston Consulting 

Ginny Bengston Native American Resources 22 M.A., Anthropology 

Blankenship Consulting 

George Social Resources 33 M.S., Urban and Regional Planning Blankenship 

Eastern Nevada Landscape Coalition

M.S., Range Science and Wildlife Moira Kolada Rangeland Resources 6 

Management 

Betsy MacFarlan Executive Director 20 M.S., Animal Science 

Sammons/Dutton 

Ron Dutton Socioeconomics 33 M.S., Economics 

 

3 Bars Project Final EIS 4-7 October 2016 
CONSULTATION AND COORDINATION 

3 Bars Project Final EIS 4-8 October 2016 

This page left blank intentionally.
CHAPTER 5 

REFERENCES 
This page left blank intentionally.
REFERENCES

3 Bars Project Final EIS 5-1 October 2016 

CHAPTER 5 

REFERENCES

Advisory Council on Historic Preservation. 1980. Treatment of Historic Properties: A Handbook. Washington, 

D.C. 

AECOM. 2010. Scoping Comment Summary Report for the 3 Bars Ecosystem and Landscape Restoration Project 

EIS. Report Prepared for the USDOI BLM, Battle Mountain District, Mount Lewis Field Office, Battle 

Mountain, Nevada. Seattle, Washington. 

AECOM. 2011a. 3 Bars Ecosystem and Landscape Restoration Project Pinyon-Juniper Assessment. Report 

Prepared for the USDOI BLM, Battle Mountain District, Mount Lewis Field Office, Battle Mountain, 

Nevada. Seattle, Washington. 

AECOM. 2011b. 3 Bars Ecosystem and Landscape Restoration Project Cheatgrass Assessment. Report Prepared 

for the USDOI BLM, Battle Mountain District, Mount Lewis Field Office, Battle Mountain, Nevada. 

Seattle, Washington. 

AECOM. 2012. Cultural Context 3 Bars Ecosystem and Landscape Restoration Project. Report Prepared for the 

USDOI BLM, Battle Mountain District, Mount Lewis Field Office, Battle Mountain, Nevada. Sacramento, 

California. 

Agee, J. 1993. Fire Ecology of Pacific Northwest Forests. Island Press. Washington, D.C. 

Aikens, C.M., and D.B. Madsen. 1986. Prehistory of the Eastern Area. Pages 149-160 in The Great Basin (W.L. 

d’Azevedo, Editor). In Handbook of North American Indians, Volume 11 (W.G. Sturtevant, General 

Editor). Smithsonian Institution, Washington, D.C. 

Amaral, A. 1976. Mustang: Life and Legends of Nevada’s Wild Horses. University of Nevada Press, Reno.

American Chemistry Council. 2005. Forest Fires: A Major Source of Dioxins. Washington, D.C. Available at 

URL: http://www.dioxinfacts.org/sources_trends/forest_fires2.html. 

American Geological Institute. 1997. Dictionary of Mining, Mineral, and Related Terms, 2nd Edition. Alexandria, 

Virginia. 

American Sheep Industry. 2006. Targeted Grazing Handbook. American Sheep Industry. Available at URL: 

www.sheepusa.org/targetedgrazing. 

Anderson, M.D. 2002. Leymus cinereus. In Fire Effects Information System. U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory, Fort Collins, Colorado. 

Available at URL: http://www.fs.fed.us/database/feis/. 
REFERENCES

3 Bars Project Final EIS 5-2 October 2016

Anderson, M.D. 2004. Ephedra nevadensis. In Fire Effects Information System. U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory, Fort Collins, Colorado. 

Available at URL: http://www.fs.fed.us/database/feis/. 

Ansley, R.J., and G.A. Rasmussen. 2005. Managing Native Invasive Juniper Species using Fire. Weed Technology 

19:517-522. Available at URL: 

http://www.jstor.org/discover/10.2307/3989470?uid=2&uid=4&sid=21103317865241. 

Association for Fire Ecology, International Association of Wildland Fire, Tall Timbers Research Station, and The 

Nature Conservancy. 2013. The Merits of Prescribed Fire Outweigh Potential Carbon Emission Effects. 

Eugene, Oregon. 

Atamian, M.T., J.S. Sedinger, J.S. Heaton, and E.J. Blomberg. 2010. Landscape-level Assessment of Brood 

Rearing Habitat for Greater Sage-grouse in Nevada. Journal of Wildlife Management 74:1533-1543. 

Ausich, W.I. 1978. Pisocrinus from California, Nevada, Utah and Gaspe Peninsula. Journal of Paleontology 52(2): 

487-491. 

Bailey, L.R. 1966. Indian Slave Trade in the Southwest. Western Lore Press, Los Angeles, California. 

Bailey, R.G. 1997. Map: Ecoregions of North America (Revised). U.S. Department of Agriculture, Forest Service 

in Cooperation with the Nature Conservancy and the U.S. Geological Survey. Washington, D.C. 

Bailey, R.G. 2002. Ecoregions. Pages 235-245 in The Physical Geography of North America (A.R. Orme, Editor). 

Oxford University Press. Oxford, England. 

Baker, H.G. 1986. Patterns of Plant Invasion in North America. In Ecology of Biological Invasions of North 

America and Hawaii (H.A. Mooney and J.A. Drake, Editors). Springer-Verlag, Berlin, Germany. 

Balda, R.P., and N. Masters. 1980. Avian Communities in the Pinyon-juniper Woodland: A Descriptive Analysis. 

Pages 146-169 in Workshop Proceedings: Management of Western Forests and Grasslands for Nongame 

Birds (R.M. DeGraaf and N.G. Tilghman, Editors). General Technical Report INT-86. U.S. Department of 

Agriculture, Forest Service Intermountain Research Station, Ogden, Utah. Available at URL: 

http://www.fs.fed.us/rm/pubs_int/int_gtr086/int_gtr086_146_169.pdf. 

Barger, N.N., H. Guenther, M. Miller, and J. Herrick. 2012. Consequences of Fuel Load Management on Erosional 

Processes in Pinyon-Juniper Systems. In Ecology in a Dusty World: Integrating Dust Flux, Human 

th Dimensions, and Ecological Processes in Drylands. 97 Ecological Society of America Annual Meeting 

(August 5-10, 2012). Available at URL: http://eco.confex.com/eco/2012/webprogram/Paper33676.html. 

Bartos, D.L., and W.F. Mueggler. 1979. Influence of Fire on Vegetation Production in the Aspen Ecosystem in 

Western Wyoming. Pages 75-78 in North American Elk: Ecology, Behavior, and Management (M.S. 

Boyce and L.D. Hayden-Wing, Editors). University of Wyoming, Laramie. Available at URL: 

http://digitalcommons.usu.edu/cgi/viewcontent.cgi?article=5706&context=aspen_bib&seiredir=1&referer=http%3A%2F%2Fwww.bing.com%2Fsearch%3Fq%3D.%2BInfluence%2Bof%2BFire%

2Bon%2BVegetation%2BProduction%2Bin%2Bthe%2BAspen%2BEcosystem%2Bin%2BWestern%2B

Wyoming.%26qs%3Dn%26form%3DQBRE%26pq%3D.%2Binfluence%2Bof%2Bfire%2Bon%2Bvegeta
REFERENCES

3 Bars Project Final EIS 5-3 October 2016 

tion%2Bproduction%2Bin%2Bthe%2Baspen%2Becosystem%2Bin%2Bwestern%2Bwyoming.%26sc%3

D0-32%26sp%3D1%26sk%3D%26cvid%3D09ffb8ee693c4e239589790809b05efc#search=%22.%20Influence%20Fire%20

Vegetation%20Production%20Aspen%20Ecosystem%20Western%20Wyoming.%22. 

Bartos, D.L., and W.F. Mueggler. 1981 Early Succession in Aspen Communities Following Fires in Western 

Wyoming. Journal of Range Management 34:315-318. 

Bartos, D.L., W.F. Mueggler, and R.B. Campbell, Jr. 1991. Regeneration of Aspen by Suckering on Burned Sites 

in Western Wyoming. General Research Paper INT-448. U.S. Department of Agriculture, Forest Service 

Intermountain Research Station, Ogden, Utah. Available at URL: 

http://www.fs.fed.us/rm/pubs_int/int_rp448.pdf. 

Bartos, D.L., J.K. Brown, and G.D. Booth. 1994. Twelve Years Biomass Response in Aspen Communities 

following Fire. Journal of Range Management 47:79-83. Available at URL: 

http://www.jstor.org/discover/10.2307/4002846?uid=2&uid=4&sid=21103058071091. 

Bauer, J.M., and P.J. Weisberg. 2009. Fire History of a Central Nevada Pinyon-juniper Woodland. Canadian 

Journal of Forest Research 39:1589-1599. 

Beck, C. 1999. Models for the Millennium: Great Basin Anthropology Today. University of Utah Press, Salt Lake 

City. 

Beck, C., and G.T. Jones. 1988. Western Pluvial Lakes Tradition Occupation in Butte Valley, Eastern Nevada. In

Early Human Occupation in Far Western North America: The Clovis-Archaic Interface (J.A. Willig, C.M. 

Aikens, and J.L. Fagan, Editors). Nevada State Museum Anthropological Papers 21:273-301. Carson City, 

Nevada. 

Beck, C., and G.T. Jones. 1997. The Terminal Pleistocene/Early Holocene Archaeology of the Great Basin. Journal 

of World Prehistory 11(2):161–236. 

Belnap, J., R. Rosentreter, S. Leonard, J.H. Kaltenecker, J. Williams, and D. Eldridge. 2001. Biological Soil 

Crusts: Ecology and Management. U.S. Department of the Interior, BLM, National Science and 

Technology Center. Report Technical Reference 1730-2. Denver, Colorado. Available at URL: 

http://www.blm.gov/nstc/library/pdf/CrustManual.pdf. 

Belsky, A.J., and J.L. Gelbard. 2000. Livestock Grazing and Weed Invasions in the Arid West. Oregon Natural 

Desert Association. Bend, Oregon. 

Bengston, G. 2003. Northern Paiute and Western Shoshone Land Use in Northern Nevada: A Class I Ethnographic/ 

Ethnohistoric Overview. Cultural Resource Series No. 12. Prepared for the USDOI BLM, Nevada State 

Office, Reno. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/cultural/reports.Par.99842.File.dat/12_N_Pauite.pdf. 

Bengston, G. 2010. Ethnographic Assessment for the Newe (Western Shoshone): Proposed Ruby Pipeline Project in 

Nevada. Sparks, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-4 October 2016

Bengston Consulting. 2007. Mount Hope Molybdenum Mine Ethnographic Assessment. Bengston Consulting, Sun 

Valley, Nevada. 

Bengston Consulting. 2012. 3 Bars Landscape and Restoration Project: Native America Contact Review. Report 

Prepared for the USDOI BLM, Battle Mountain District, Battle Mountain, Nevada. Sun Valley, Nevada. 

Benton, R., and J. Reardon. 2006. Fossils and Fire: A Study on the Effects of Fire on Paleontological Resources at 

Badlands National Park. In Fossils from Federal Lands (S.G. Lucas, J.A. Spielmann, P.M. Hester, J.P. 

Kenworthy, and V.L. Santucci, Editors). New Mexico Museum of Natural History and Science Bulletin 

34:47-54. Available at URL http://www.treesearch.fs.fed.us/pubs/26828. 

Bentrup, G., and J.C. Hoag. 1998. The Practical Streambank Bioengineering Guide: a User’s Guide for Natural 

Streambank Stabilization Techniques in the Arid and Semi-arid Great Basin and Intermountain West. 

Interagency Riparian/Wetland Project, Plant Materials Center, U.S. Department of Agriculture, Natural 

Resources Conservation Service, Aberdeen, Idaho. Available at URL: 

http://www.nrcs.usda.gov/Internet/FSE_PLANTMATERIALS/publications/idpmcpu116.pdf. 

Beschta, R.L., D.L. Donahue, D.A. DellaSala, J.J. Rhodes, J.R. Karr, M.H. O’Brien, T.L. Fleischner, and C.D. 

Williams. 2013. Adapting to Climate Change on Western Public Lands: Addressing the Ecological Effects 

of Domestic, Wild, and Feral Ungulates. Environmental Management 51:471-492. Available at URL: 

http://fes.forestry.oregonstate.edu/sites/fes.forestry.oregonstate.edu/files/PDFs/Beschta/Beschta_2012Env

Man.pdf. 

Blankenship Consulting LLC and Sammons/Dutton LLC. 2008. Mount Hope Project Socioeconomic Assessment. 

Prepared for General Moly, Inc. June 2, 2008. Denver, Colorado. 

Bonneville Power Administration. 2000. Transmission System Vegetation Management Program Final 

Environmental Impact Statement. Portland, Oregon. Available at URL: 

http://energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/EIS-0285-FEIS-01-2000.pdf. 

Bowers, M.H., and H. Muessig. 1982. History of Central Nevada: An Overview of the Battle Mountain District. 

Cultural Resource Series No. 4. USDOI BLM, Nevada State Office, Reno. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/cultural/reports.Par.8872.File.dat/04_History_of_Central

_NV,_Battle_Mountain_District_1982.pdf. 

Bradford, M.J., and J.S. Heinonen. 2008. Low Flows, Instream Flow Needs and Fish Ecology in Small Streams. 

Canadian Water Resources Journal 33(2):165-180. Available at URL: 

http://www.highbeam.com/doc/1G1-180517851.html. 

Bradley, P.V., M.J. O’Farrell, J.A. Williams, and J.E. Newmark (Editors). 2006. The Revised Nevada Bat 

Conservation Plan. Nevada Bat Working Group. Reno, Nevada. Available at URL: 

http://wbwg.org/conservation/conservationplans/NVconservationplan.pdf. 

Braun, C.E. 2006. A Blueprint for Sage-grouse Conservation and Recovery. Tucson, Arizona, Available at URL: 

www.sagebrushsea.org/sage_grouse_blueprint.htm. 
REFERENCES

3 Bars Project Final EIS 5-5 October 2016 

Braun, C.E., M.F. Baker, R.L. Eng, J.S. Gashwiler, and M.H. Schroeder. 1976. Conservation Committee Report on 

the Effects of Alteration of Sagebrush Communities on the Associated Avifauna. Wilson Bulletin 88:165-

171. Available at URL: 

http://www.jstor.org/discover/10.2307/4160730?uid=2&uid=4&sid=21103433355261. 

Braun, C.E., O.O. Oedekoven, and C.L. Aldridge. 2002. Oil and Gas Development in Western North America: 

Effects on Sagebrush Steppe Avifauna with Particular Emphasis on Sage Grouse. Transactions of the 

North American Wildlife and Natural Resources Conference 67:337-349. Available at URL: 

http://www.oilandgasbmps.org/docs/GEN094.pdf. 

Brockway, D.G., R.G. Gatewood, and R.B. Paris. 2002. Restoring Grassland Savannas from Degraded Pinyonjuniper Woodlands: Effects of Mechanical Overstory Reduction and Slash Treatment Alternatives. Journal 

of Environmental Management 64:179-197. Available at URL: 

http://www.srs.fs.usda.gov/pubs/ja/ja_brockway030.pdf. 

Brown, J.K 1995. Fire Regimes and Their Relevance to Ecosystem Management. In Proceedings of the Society of 

American Foresters National Convention 171-178. 

Bryan, A.L. 1979. Smith Creek Cave. In The Archeology of Smooth Creek Canyon, Eastern Nevada (D.R. Tuohy 

and D.L. Rendall, Editors). Nevada State Museum Anthropological Papers 17:162–251. 

Bryce, S.A., A.J. Woods, J.D. Morefield, J.M. Omernik, T.R. McKay, G.K. Brackley, R.K. Hall, D.K. Higgins, 

D.C. McMorran, K.E. Vargas, E.B. Petersen, D.C. Zamudio, and J.A. Comstock. 2003, Ecoregions of 

Nevada. U.S. Geological Survey, Reston, Virginia. Available at URL: 

ftp://ftp.epa.gov/wed/ecoregions/nv/nv_front.pdf. 

Bukowski, B.E., and W.L. Baker. 2013. Historical Fire Regimes, Reconstructed from Land-survey Data, Led to 

Complexity and Fluctuation in Sagebrush Landscapes. Ecological Applications 23:546-564. 

Cappannari, S.C. 1960. The Concept of Property among Shoshoneans. Pages 133–144 in Essays in the Science of 

Culture in Honor of Leslie A. White (G.E. Dole and R.L. Carneiro, Editors). Thomas Y. Crowell, New 

York, New York. 

Chino, M., J. LaValley, D. Haff, D. Harris, and A. Rivers. 2010. Injury in Nevada. University of Nevada, Las 

Vegas School of Community Health Sciences, Nevada State Health Division Bureau of Child Family and 

Community Wellness. Available at URL: http://www.health.nv.gov/PDFs/InjuryInNevada.pdf. 

Clarke, S.E., and S.A. Bryce (Editors). 1997. Hierarchical Subdivisions of the Columbia Plateau and Blue 

Mountains Ecoregions, Oregon and Washington. General Technical Report PNW-GTR-395. U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. Portland, Oregon. 

Available at URL: http://www.fs.fed.us/pnw/pubs/pnw_gtr395.pdf. 

Clawson, M. 1950. The Western Range Livestock Industry. McGraw-Hill, New York. 

Clifton, C., R. Harris, and S. Wondzell. 2006. Effects of Prescribed Fire and Fuels Treatments on Water Quality 

and Aquatic Habitat in the Blue Mountains, Oregon and Washington. Presented at the Watershed 

Management Council Biannual Conference, Walla Walla, Washington. 
REFERENCES

3 Bars Project Final EIS 5-6 October 2016

Cochrane, M.A., C.J. Moran, M.C. Wimberly, A.D. Baer, M.A. Finney, K.L. Beckendorf, J. Eidenshink, and Z. 

Zhu. 2012. Estimation of Wildfire Size and Risk Changes Due to Fuels Treatments. International Journal 

of Wildland Fire. Available at URL: www.publish.csiro.au/journals/ijwf. 

Coffin, P.D. 1981. Distribution and Life History of the Lahontan/Humboldt Cutthroat Trout, Humboldt River 

Drainage Basin. Nevada Department of Wildlife, Reno. 

Coffin, P.D., and W.F. Cowan. 1995. Recovery Plan for the Lahontan Cutthroat Trout. U.S. Fish and Wildlife 

Service, Region 1, Portland, Oregon. Available at URL: 

http://ecos.fws.gov/docs/recovery_plans/1995/950130.pdf. 

Cohen, P. 1964. A Brief Appraisal of the Ground-water Resources of the Grass Valley Area, Humboldt and 

Pershing Counties, Nevada. Nevada Department of Conservation and Natural Resources, Ground-water 

Resources Reconnaissance Report. Carson City, Nevada. 

Collopy, M.W., and W.M. Lammers. 2005. Effects of High Voltage Transmission Lines on Dynamics of Sage 

Grouse Populations: Avian Predators. Progress Report: Year 2. University of Nevada-Reno. Reno, 

Nevada. 

Connelly, J.W. 2013. Federal Agency Responses to Greater Sage-Grouse and the ESA: Getting Nowhere Fast. 

Northwest Science 88:61-64. 

Connelly, J.W., M.A. Schroeder, A.R. Sands, and C.E. Braun. 2000. Guidelines to Manage Sage Grouse 

Populations and Their Habitats. Wildlife Society Bulletin 28:967-985. Available at URL: 

http://sagemap.wr.usgs.gov/Docs/Sage_Grouse_Guidelines.PDF. 

Connelly, J.W., S.T. Knick, M.A. Schroeder, and S.J. Stiver. 2004. Conservation Assessment of Greater Sagegrouse and Sagebrush Habitats. Western Association of Fish and Wildlife Agencies. Cheyenne, Wyoming. 

Available at URL: wdfw.wa.gov/publications/01118/. 

Cornell Lab of Ornithology. 2011. Species Profiles. Available at URL: http://bna.birds.cornell.edu/bna/species. 

Cornell University Weed Ecology and Management Laboratory. No Date. Tillage Prompts Germination. Available 

at URL: http://weedecology.css.cornell.edu/manage/manage.php?id=20. 

Council on Environmental Quality. 1997 Considering Cumulative Effects under the National Environmental Policy 

Act. 

Council on Environmental Quality. 1998. Final Guidance for Incorporating Environmental Justice Concerns in 

USEPA’s NEPA Compliance Analyses. April 1998. Washington, D.C. Available at URL: 

http://www.epa.gov/region1/ej/pdfs/ej_guidance_nepa_epa0498.pdf. 

Council on Environmental Quality. 2005. Guidance on the Consideration of Past Actions in Cumulative Effects 

Analysis. Memorandum from J. Connaughton, Chairman. Washington, D.C. Available at URL: 

http://energy.gov/sites/prod/files/nepapub/nepa_documents/RedDont/G-CEQ-PastActsCumulEffects.pdf. 

Council on Environmental Quality. 2012.Cumulative Effects. Federal Register 40 (1508.207):1,002. Washington, 

D.C. 
REFERENCES

3 Bars Project Final EIS 5-7 October 2016 

Cowley, E.R. 2002. Guidelines for Establishing Allowable Levels of Streambank Alteration. USDOI BLM, Idaho 

State Office, Boise, Idaho. Available at URL: 

http://www.fs.fed.us/rm/boise/research/techtrans/projects/pacfish/Allowable%20Levels%20of%20Streamb

ank%20Alteration.pdf. 

Crawford, J.A., R.A. Olson, N.E. West, J.C. Mosley, M.A. Schroeder, T.D. Whitson, R.F. Miller, M.A. Gregg, and 

C.S. Boyd. 2004. Synthesis Paper Ecology and Management of Sage-grouse and Sage-grouse Habitat. 

Journal of Range Management 57:2-19. Available at URL: 

http://wdfw.wa.gov/publications/01301/wdfw01301.pdf. 

Creel, C. 1964. History of Agriculture in Nevada. Max C. Fleishmann College of Agriculture, University of 

Nevada, Reno. 

Davies, K.W., A.M. Nafus, and R.L. Sheley. 2010. Non-native Competitive Perennial Grass Impedes the Spread of 

an Invasive Annual Grass. Biological Invasions 12:3187-3194. Available at URL: 

http://naldc.nal.usda.gov/download/46029/PDF. 

Davis, J.O., and M.K. Rusco. 1987. The Old Humboldt Site—26PE670. I Studies in Archaeology, Geology and 

Paleontology at Rye Patch Reservoir, Pershing County, Nevada (M.K. Rusco and J.O. Davis, Editors). 

Nevada State Museum Anthropological Papers 20, Carson City. 

d’Azevedo, W. 1986. Introduction. Pages 1-14 in The Great Basin (W.L. d’Azevedo, Editor). In Handbook of 

North American Indians, Volume 11 (W.G. Sturtevant, General Editor). Smithsonian Institution, 

Washington, D.C. 

Deaver, S. 1993. Consultation with the Western Shoshone Regarding Newmont’s South Operations Area Project. 

Carlin, Nevada. On File, USDOI BLM, Elko, Nevada. 

DeBoodt, T.L. 2008. Watershed Response to Western Juniper Control. Ph.D. Dissertation, Oregon State 

University, Corvallis. Available at URL: http://ir.library.oregonstate.edu/xmlui/handle/1957/8588. 

DeByle, N. 1985. Wildlife. Pages 135-152 in Aspen: Ecology and Management in the Western United States (N.V. 

DeByle and R.P. Winokur, Editors). General Technical Report RM-119. U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Forest and Range Experiment Station, Fort Collins, Colorado. Available 

at URL: http://www.fs.fed.us/rm/pubs_rm/rm_gtr119/rm_gtr119_135_152.pdf. 

Deines, L., R. Rosentreter, D.J. Eldridge, and M.D. Serpe. 2007. Germination and Seedling Establishment of Two 

Annual Grasses on Lichen-dominated Biological Soil Crusts. Plant Soil 295:23-35. Available at URL: 

http://gaiavisions.org/deiSHerb/FOIAcomments/Public%20Comment%20809%20Attachment/Soil%20Crusts/Deines%20et%20al%202007%20

Germination%20and%20seedling%20establishment%20of%20.pdf. 

Delacorte, M.G., A. Gilreath, and M.C. Hall. 1992. A Class II Sample Survey for the Cortez Cumulative Effects 

Study Area, Lander and Eureka Counties, Nevada. Prepared for USDOI BLM, Battle Mountain and Elko 

Districts, by Far Western Anthropological Research Group, Inc., Davis, California. 
REFERENCES

3 Bars Project Final EIS 5-8 October 2016

DellaSala, D.A. 2009. The Role of Federal Lands in Combating Climate Change. Public Hearing, House 

Subcommittee on National Parks, Forests, and Public Lands, March 3, 2009. Washington D.C. 

Dewson, Z.S., A.B.W. James, and R.G. Death. 2007. A Review of the Consequences of Decreased Flow for 

Instream Habitat and Macroinvertebrates. Journal of the North American Benthological Society 

26(3):401-415. 

Dickerson, B.R., and G.L. Vinyard. 1999. Effects of High Chronic Temperatures and Diel Temperature Cycles on 

the Survival and Growth of Lahontan Cutthroat Trout. Transactions of the American Fisheries Society 

123:267-282. 

Dixon, G., and R. McGonagle. 2004. Mount Tenabo Properties of Cultural and Religious Importance 

Determinations of Eligibility to the National Register of Historic Places. BLM Report 6-2352-1. On File at 

the USDOI BLM, Elko/Battle Mountain Field Offices, Battle Mountain, Nevada. 

Driesner, D., and A. Coyner. 2011. Major Mines of Nevada 2010 Mineral Industries in Nevada’s Economy. The 

Nevada Division of Minerals. College of Science, MacKay School of Earth Sciences and Engineering, 

University of Nevada, Reno. Available at URL: http://www.nbmg.unr.edu/dox/mm/mm10.pdf. 

Driver, H.E. 1937. Culture Element Distributions, VI: Southern Sierra Nevada. University of California 

Anthropological Records 1(2):53–154. 

Drut, M.S., W.H. Pyle, and J.A. Crawford. 1994. Technical Note: Diets and Food Selection of Sage Grouse Chicks 

in Oregon. Journal of Range Management 47:90-93. Available at URL: 

http://www.jstor.org/discover/10.2307/4002848?uid=2&uid=4&sid=21103493640141. 

Dunham, J.B., and G.L. Vinyard. 1996. Dysfunctional Characteristics of Small Trout Populations. Final Report. 

Submitted to USDA Forest Service, Intermountain Research Station. Research Joint Venture Agreement 

INT-92731-RJVA. Fort Collins, Colorado. 

Dunham, J.B., M.M. Peacock, B.E. Rieman, R.E. Schroeter, and G.L. Vinyard. 1999. Local and Geographic 

Variability in the Distribution of Stream-living Lahontan Cutthroat Trout. Transactions of the American 

Fishery Society 128:875-889. Available at URL: 

http://www.fs.fed.us/rm/boise/publications/fisheries/rmrs_1999_dunhamj004.pdf. 

Eakin, T.E. 1961. Ground-Water Appraisal of Pine Valley, Eureka and Elko Counties, Nevada. Ground-Water 

Resources – Reconnaissance Series Report 2. Prepared in Cooperation with the U.S. Geological Survey. 

Nevada Department of Conservation and Natural Resources, Carson City. 

Eakin, T.E. 1962. Groundwater Appraisal of Diamond Valley, Eureka and Elko Counties, Nevada. Nevada 

Department of Conservation and Natural Resources – Groundwater Reconnaissance Series Report #6, 

Carson City. 

Eastern Nevada Landscape Coalition and AECOM. 2012. Landscape Restoration Project Rangeland Health Report. 

Report Prepared for the USDOI BLM, Battle Mountain District Mount Lewis Field Office, Battle 

Mountain, Nevada. Ely, Nevada, and Seattle, Washington. 
REFERENCES

3 Bars Project Final EIS 5-9 October 2016 

EDAW. 2001. Falcon to Gonder 345 KV Transmission Project. Final Environmental Impact Statement and 

Resource Management Plan Amendments. Sacramento, California. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/nep

a/falcon_to_gonder_345kv.Par.7338.File.dat/0.0%20Executive%20Summary.pdf. 

Egan, H.R. 1917. Pioneering the West, 1846–1878: Major Howard Egan’s Diary. Howard R. Egan Estate, 

Richmond, Utah. 

Eggan, F. 1980. Shoshone Kinship Structures and Their Significance for Anthropological Theory. Journal of the 

Steward Anthropological Society 11(2):165–193. 

Elliott, J. 2004. Lahontan Cutthroat Trout Species Management Plan for the Upper Humboldt River Drainage 

Basin. Department of Wildlife, Carson City, Nevada. Available at URL: 

http://www.ndow.org/uploadedFiles/ndoworg/Content/public_documents/Wildlife_Education/Publications

/lct_smp.pdf. 

Elliott, J. 2013a. Co-operating Agency Review of 3 Bars Ecosystem and Landscape Restoration Project 

Environmental Preliminary Draft EIS. NDOW. Elko, Nevada. 

Elliott. J. 2013b. Eastern Region Fisheries Supervisor, NDOW, Elko, Nevada. Electronic Mail Communication 

with S. Foree, Wildlife Biologist, USDOI BLM Battle Mountain District, Battle Mountain, Nevada 

Regarding Lahontan Cutthroat Trout Occurrence in 3 Bars Project Area, April 25, 2013. 

Elliott, R.R. 1987. History of Nevada. University of Nebraska Press. Lincoln. 

Ellsworth, E. 2013. Wildlife Biologist, U.S. Department of the Interior, BLM Battle Mountain District, Battle 

Mountain, Nevada. Electronic Mail Communication with L. Gould, AECOM, Seattle, Washington, 

Regarding Wildlife Species on the 3 Bars Project Area, Various Dates. 

Elston, R.G. 1982. Good Times, Hard Times: Prehistoric Change in the Western Great Basin. Pages 186-206 in

Man and Environment in the Great Basin (D.B. Madsen and J.F. O’Connell, Editors). Society for 

American Archaeology Papers 2. 

Elston, R.G. 1986. Prehistory of the Western Area. Pages 135-148 in The Great Basin (W.L. d’Azevedo, Editor). 

In Handbook of North American Indians, Volume 11, W.C. Sturtevant, General Editor). Smithsonian 

Institution, Washington, D.C. 

Elston, R.G., J.O. Davis, and R. Clerico. 1979. Archaeological Site 26NY1908: A Late Pleistocene Gravel Bar in 

Railroad Valley, Nevada. Manuscript on File at the USDOI BLM, Ely District Office, Ely, Nevada. 

Elston, R.G., J.O. Davis, S. Clerico, R. Clerico, and A. Becker. 1981. Archeology of Section 20, North Valmy 

Power Plant, Humboldt County, Nevada. University of Nevada Desert Research Institute Social Sciences 

Technical Report 19, Reno. 

Elzinga, C.L., D.W. Salzer, and J.W. Willoughby. 1998. Measuring and Monitoring Plant Populations. USDOI 

BLM Technical Reference 1730-1. BLM/RS/ST-98/005+1730. Denver, Colorado. Available at URL: 

www.blm.gov/nstc/library/pdf/MeasAndMon.pdf. 
REFERENCES

3 Bars Project Final EIS 5-10 October 2016

ENSR. 2005a. Annual Emissions Inventory for BLM Vegetation Treatment Methods Final Report. Prepared for the 

USDOI BLM, Reno, Nevada. Westford, Massachusetts. 

ENSR. 2005b. Air Quality Modeling for BLM Vegetation Treatment Methods Final Report. Prepared for the 

USDOI BLM, Reno, Nevada. Westford, Massachusetts. 

Erickson, H.E., and R. White. 2008. Soils under Fire: Soils Research and the Joint Fire Science Program. U.S. 

Department of Agriculture, Forest Service General Technical Report PNW-GTR-759. May 2008. U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station, Forest Sciences 

Laboratory, Portland, Oregon. Available at URL: http://www.fs.fed.us/pnw/pubs/pnw_gtr759.pdf. 

Eureka County. 2010. Eureka County Master Plan. Eureka, Nevada. Available at URL: 

http://www.co.eureka.nv.us/PDF/Master_Plan_Final%20_2010.pdf. 

Eureka County. 2011. Comprehensive Annual Financial Report, County of Eureka, State of Nevada, for the Fiscal 

Year Ended June 30, 2011. Available at URL: www.co.eureka.nv.us/audit/Eureka%20FS%202011.pdf. 

Eureka County. 2012. Eureka County Economic Development – Crescent Valley Businesses. Available at URL: 

http://www.eurekacounty.com/directory/cv_businesses.html. 

Everett, D.E., and F.E. Rush. 1966. Brief Appraisal of the Water Resources of Grass and Carico Lake Valleys, 

Lander and Eureka Counties, Nevada. Nevada Department of Conservation and Natural Resources –

Groundwater Reconnaissance Series Report #37. 

Fadali, E., W.W. Riggs, K. Dorris, and T.R. Harris. 2005. Updated Economic Linkages in the Economy of Eureka 

County. University of Nevada, Reno – University Center for Economic Development. Available at URL: 

http://www.unr.edu/Documents/business/uced/technical-reports/eureka/2005-06-14.pdf. 

Federal Emergency Management Agency (FEMA). Current FEMA Issued Flood Maps. Eureka County. 2013. 

FEMA Map Service Center, Oakton, Virginia. Available at URL: 

https://msc.fema.gov/webapp/wcs/stores/servlet/CategoryDisplay?storeId=10001&catalogId=10001&lang

Id=-

1&categoryId=12001&parent_category_rn=12001&type=1&stateId=&countyId=&communityId=&stateN

ame=&countyName=&communityName=&dfirm_kit_id=&future=false&dfirmCatId=null&isCountySele

cted=1&isCommSelected=1&userType=G&urlUserType=G&sfc=0&cat_state=13035&cat_county=14743

&cat_community=349058. 

Ffolliott, P.F., and G.J. Gottfried. 2012. Hydrologic Processes in the Pinyon-juniper Woodlands: A Literature 

Review. General Technical Report RRMRS-GTR-271. U.S. Department of Agriculture, Forest Service 

Rocky Mountain Research Station, Fort Collins, Colorado. 

Finch, D.M., and L.F. Ruggiero. 1993. Wildlife Habitats and Biological Diversity in the Rocky Mountains and 

Northern Great Plains. Natural Areas Journal 13:191-2003. Available at URL: 

http://www.fs.fed.us/rm/pubs_other/rmrs_1993_finch_d002.pdf. 
REFERENCES

3 Bars Project Final EIS 5-11 October 2016 

Foree, S. 2012. Wildlife Biologist, U.S. Department of the Interior BLM Battle Mountain District, Battle 

Mountain, Nevada. Electronic Mail Communication with S. Paulus, AECOM, Seattle, Washington, 

Regarding Bighorn Sheep, October 29, 2012. 

Fowler, C.S. 1977. Ethnography and Great Basin Prehistory. Pages 11-48 in Models and Great Basin Prehistory: A 

Symposium (D.D. Fowler, Editor). University of Nevada, Desert Research Institute Publications in the 

Social Sciences 12, Reno. 

Fowler, C.S. 1982. Settlement Patterns and Subsistence Systems in the Great Basin: The Ethnographic Record. 

Pages 121-138 in Man and Environment in the Great Basin (D.B. Madsen and J.F. O’Connell, Editors). 

Society for American Archaeology Papers 2, Washington, D.C. 

Fowler, C.S. 1986. Subsistence. Pages 64-98 in The Great Basin (W.L. d’Azevedo, Editor). In Handbook of North 

American Indians, Volume 11 (W.G. Sturtevant, General Editor). Smithsonian Institution, Washington, 

D.C. 

Fresquez, T., C. Scheck, and B. Hopkins. 2002. Biological Assessment for the Glenwood Spring Field Office Fire 

Management Plan. USDOI BLM. Glenwood Springs, Colorado. 

Garside, L.J., and R.H. Hess. 2011. Qualitative Petroleum Potential Map of Nevada. Nevada Bureau of Mines and 

Geology Open-file Report 11-2. Carson City, Nevada. Available at URL: 

http://www.nbmg.unr.edu/dox/of112_text.pdf. 

General Moly. 2012. General Moly Molybdenum Properties. Available at URL: 

http://www.generalmoly.com/properties.php. Accessed April 18, 2012. 

George, J.M. 2000. Ethnobotany and Land Management Among the Duckwater Shoshone. Unpublished Master’s 

Thesis on File at University of Nevada, Reno. 

Georgetta, C. 1972. Golden Fleece in Nevada. Venture Publishing Company Ltd., Reno, Nevada. 

Gillihan, S.W. 2006. Sharing the Land with Pinyon-juniper Birds. Partners in Flight Western Working Group. Salt 

Lake City, Utah. Available at URL: http://wildlife.utah.gov/pdf/pinyon-juniper-birds_high.pdf. 

Godfrey, A. 1994. Pony Express National Historic Trail, Historic Resource Study. USDOI National Park Service. 

Washington, D.C. Available at URL: http://www.nps.gov/history/history/online_books/poex/hrs/hrsp.htm. 

Goetzmann, W.H. 1966. Exploration and Empire: The Explorer and Scientist in the Winning of the West. Vintage 

Books, New York, New York. 

Gottfried, G.J., and S. Overby. 2011. Assessing Mechanical Mastication and Thinning-piling-burning Treatments 

on the Pinyon-juniper Woodlands of Southwestern Colorado. Joint Fire Science Program 145:1-4. 

Available at URL: http://www.firescience.gov/projects/briefs/05-2-1-98_FSBrief145.pdf. 
REFERENCES

3 Bars Project Final EIS 5-12 October 2016

Gottfried, G.J., T.W. Swetnam, C.D. Allen, J.L. Betancourt, and C. MacCoubrey. 1995. Pinyon-juniper 

Woodlands. Pages 95-132 in Ecology, Diversity, and Sustainability of the Middle Rio Grande Basin. 

General Technical Report RM-268. U.S. Department of Agriculture, Forest Service Rocky Mountain 

Forest and Range Experiment Station. Fort Collins, Colorado. Available at URL: 

http://www.fs.fed.us/rm/pubs_rm/rm_gtr268.pdf. 

Grayson, D.K. 1993. The Desert’s Past: A Natural Prehistory of the Great Basin. Smithsonian Institution Press, 

Washington, D.C. 

Grayson, D.K. 2006. The Late Quaternary Biogeographic Histories of Some Great Basin Mammals (Western 

USA). Quaternary Science Reviews 25:2964–2991. Available at URL: 

faculty.washington.edu/grayson/qsr06.pdf. 

Great Basin Bird Observatory. 2010. Nevada Comprehensive Bird Conservation Plan, Version 1.0. Reno, Nevada. 

Available at URL: http://www.gbbo.org/pdf/bcp/NV_Bird_Conservation_Plan_ver1.0_Dec2010.pdf. 

Great Basin Bird Observatory. 2011. Trends and Habitat Use of Pinyon-Juniper Songbirds and Their Implications 

for Woodland Management. Reno, Nevada. 

Great Basin Ecology, Inc. 2008. Kobeh Valley Wellfield Baseline Survey Report. Report Prepared for Eureka 

Moly, LLC, Mount Hope Project. 

Greenwood, D.L. 2006. Landscape Analysis of Tree Mortality and Pinyon-Juniper Woodland Structure in the 

Great Basin. Master of Science Thesis. University of Nevada, Reno. Available at URL: 

http://www.cabnr.unr.edu/weisberg/publications/DGThesisFinal.pdf. 

Grosscup, G.L. 1977. Notes on Boundaries and Culture of the Panaming Shoshone and Owens Valley Paiute. 

University of California Archaeological Research Facility Contributions, Pages 35–109. Berkeley. 

Gullett, B.K., and A. Touati. 2003. PCDD/F Emissions from Forest Fire Simulations, Atmospheric Environment 

37:803-813. Available at URL: http://cfpub.epa.gov/ncea/CFM/recordisplay.cfm?deid=55505#Download. 

Habich, E.F. 2001. Ecological Site Inventory, Inventorying and Monitoring Technical Reference 1734-7. 

BLM/ST/ST-01/003+1743. U.S. Department of the Interior, BLM, Denver, Colorado. Available at URL: 

www.blm.gov/nstc/library/pdf/1734-7.pdf. 

Hafen, L. 2004 [1926]. The Overland Mail. A. H. Clark, Cleveland, Ohio. 

Hall, S.R. 1994. Romancing Nevada’s Past: Ghost Towns and Historic Sites of Eureka, Lander, and White Pine 

Counties. University of Nevada Press, Reno. Available at URL: http://www.amazon.com/RomancingNevadaS-Past-Historic-Counties/dp/0874172284. 

Handman, E.H., and K.C. Kilroy. 1997. Ground-water Resources of Northern Big Smoky Valley, Lander and Nye 

Counties, Central, Nevada. U.S. Geological Survey Water Resources Investigation Report 96-4311. 

Reston, Virginia. Available at URL: http://pubs.usgs.gov/wri/1996/4311/report.pdf. 
REFERENCES

3 Bars Project Final EIS 5-13 October 2016 

Hann, W.J., and D.L. Bunnell. 2001. Fire and Land Management Planning and Implementation across Multiple 

Scales. International Journal of Wildland Fire 10:389-403. Available at URL: 

http://www.firelab.org/ScienceApps_Files/downloads/coarsescale/h_b.pdf. 

Hardman, G., and H.G. Mason. 1949. Irrigated Lands of Nevada. University of Nevada Agricultural Experiment 

Station Bulletin #183. 

Hardy C.C., K.M. Schmidt, J.P Menakis, and R.N. Sampson. 2001. Spatial Data for National Fire Planning and 

Fuel Management. International Journal of Wildland Fire 10:353–372. 

Harrill, J.R. 1968. Hydrologic Response to Irrigation Pumping in Diamond Valley, Eureka and Elko Counties, 

Nevada, 1950-65: State of Nevada Department of Conservation and Natural Resources Water Resources 

Bulletin No. 35. Carson City, Nevada. 

Harrill, J.R., J.S. Gates, and J.M. Thomas. 1988. Major Ground-Water Flow Systems in the Great Basin Region of 

Nevada, Utah, and Adjacent States. U.S Geological Survey Hydrologic Investigations Atlas HA-694-C. 

Denver, Colorado. 

Hastings, B.K., F.M. Smith, and B.F. Jacobs. 2003. Rapidly Eroding Pinyon-Juniper Woodlands in New Mexico. 

Journal of Environmental Quality 32:1290-1298. 

Hess, R.H., and L.J. Garside. 2007. Nevada Oil and Gas Well Database (NVOILWEL), in “Petroleum Data Map of 

Nevada.” Nevada Bureau of Mines and Geology Map 162. Available at URL: 

http://www.nbmg.unr.edu/dox/dox.htm. 

Hickman, T., and R.F. Raleigh. 1982. Habitat Suitability Index Models: Cutthroat Trout. Report No. 

FWS/OBS/82/10.5. U.S. Department of the Interior, USFWS, Office of Biological Services, Washington, 

D.C. Available at URL: http://www.nwrc.usgs.gov/wdb/pub/hsi/hsi-005.pdf. 

Holecheck, J.L., R.D. Pieper, and C.H. Herbel. 1998. Range Management, Principles and Practices. Prentice Hall. 

New York, New York. Available at URL: http://www.amazon.com/Range-Management-PrinciplesPractices-Edition/dp/0135014166. 

Holloran, M.J., and S.H. Anderson. 2004. Sage-grouse Response to Natural Gas Field Development in 

Northwestern Wyoming. Proceedings of the Western Agencies Sage and Columbian Sharp-tailed Grouse 

Technical Committee 24:16. Available at URL: 

http://sagemap.wr.usgs.gov/Docs/2004_Western_Grouse_Workshop_Proceedings.pdf. 

Holzworth, G.C. 1972. Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution throughout the 

Contiguous United States. Office of Air Programs. Publication AP-101. U.S. Environmental Protection 

Agency, Washington, D.C. Available at URL: 

http://nepis.epa.gov/Exe/ZyNET.exe/20013CDS.txt?ZyActionD=ZyDocument&Client=EPA&Index=Prior

%20to%201976&Docs=&Query=&Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&TocEn

try=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&UseQField=&IntQFieldOp=0&ExtQFieldO

p=0&XmlQuery=&File=D%3A%5CZYFILES%5CINDEX%20DATA%5C70THRU75%5CTXT%5C000

00005%5C20013CDS.txt&User=ANONYMOUS&Password=anonymous&SortMethod=h%7C-

&MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r75g8/x150y150g16/i425&Display=p
REFERENCES

3 Bars Project Final EIS 5-14 October 2016

%7Cf&DefSeekPage=x&SearchBack=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&Max

imumPages=1&ZyEntry=3. 

Houng-Ming, J., J.H. Trimmer, and R. Jewell. 1983. Nevada Watershed Studies, 1963-1980. Publication 

BLMNVPT830014340. Denver, Colorado. 

Howard, J.L. 1993. Camassia quamash. In Fire Effects Information System. U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory, Fort Collins, Colorado. 

Available at URL: http://www.fs.fed.us/database/feis/plants/forb/camqua/all.html. 

Hulse, J.W. 1990. The Nevada Adventure. University of Nevada Press, Reno. 

Hunter, M.L., Jr. 1990. Wildlife, Forests, and Forestry. Principles of Managing Forests for Biological Diversity. 

Regents/Prentice Hall. Englewood Cliffs, New Jersey. 

Ice, G.C., D.G. Neary, and P.W. Adams. 2004. Effects of Wildfire on Soils and Watershed Processes. Society of 

American Foresters. Journal of Forestry, September 2004. Bethesda, Maryland. Available at URL: 

http://www.colorado.edu/geography/class_homepages/geog_3511_s12/readings/Fire_Watersheds_JForestr

y.pdf. 

Intergovernmental Panel on Climate Change (IPCC). 2007. Summary for Policymakers. In Climate Change 2007: 

The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the 

Intergovernmental Panel on Climate Change (S. Solomon, D. Qin, M. Manning, Z. Chen, M. Marquis, 

K.B. Avery, M. Tignor, and H.L. Miller, Editors). Cambridge University Press, Cambridge, United 

Kingdom and New York, New York. Available at URL: 

http://www.ipcc.ch/publications_and_data/publications_ipcc_fourth_assessment_report_wg1_report_the_

physical_science_basis.htm. 

James, S.R. (Editor). 1981. Prehistory, Ethnohistory, and History of Eastern Nevada: A Cultural Resources 

Summary of the Elko and Ely Districts. Cultural Resource Series No. 3. U.S. Department of the Interior 

BLM, Carson City and University of Utah Archaeological Center, Salt Lake City. 

Janetski, J. 1994. Recent Transitions in the Eastern Great Basin: The Archaeological Record. Pages 157-178 in

Across the West: Human Population Movement and the Expansion of the Numa (D.B. Madsen and D. 

Rhode, Editors). University of Utah Press, Salt Lake City. 

Janetski, J., and D.B. Madsen. 1990. Wetland Adaptations in the Great Basin. Museum of Peoples and Cultures 

Occasional Papers 1, Brigham Young University. Provo, Utah. 

JBR Environmental Consultants, Inc. (JBR). 2009. Roberts Mountains Surface Water Hydrology Evaluation, 

Spring 2009. Prepared for Eureka Moly, LLC, Elko, Nevada. JBR Project Number B.A07004.00, JBR 

Report Number 873 Final. Elko, Nevada. 

Jennings, J. D. 1986. Prehistory: Introduction. Pages 107-112 in The Great Basin (W.L. d’Azevedo, Editor). In

Handbook of North American Indians, Volume 11 (W.C Sturtevant, General Editor). Smithsonian 

Institution, Washington, D.C. 
REFERENCES

3 Bars Project Final EIS 5-15 October 2016 

Jensen, M., I. Goodman, K. Brewer, T. Frost, G. Ford, and J. Nesser. 1997. Biophysical Environments of the 

Basin. Pages 99-320 in An Assessment of Ecosystem Components in the Interior Columbia Basin and 

Portions of the Klamath and Great Basins (T.M. Quigley and S.J. Arbelbide, Technical Editors). General 

Technical Report PNW-GTR-405. U.S. Department of Agriculture, Forest Service, Pacific Northwest 

Research Station. Portland, Oregon. Available at URL: 

http://www.fs.fed.us/pnw/publications/icbemp.shtml. 

Johnson, J.G. 1962. Brachiopod Faunas of the Central Nevada Formation (Devonian) in Central Nevada. Journal of 

Paleontology 36 (1):165-169. Available at URL: 

http://www.jstor.org/discover/10.2307/1301244?uid=2&uid=4&sid=21103826350881. 

Jones, A., J. Catlin, and E. Vasquez. 2012. Mechanical Treatment of Pinyon-juniper and Sagebrush Systems in the 

Intermountain West A Review of the Literature – Draft. Wild Utah Project, Salt Lake City, Utah. 

Available at URL: wildutahproject.org/files/images/MechTrt_LitReview_Draft.doc. 

Jones, B.E. 2010 Restoring Aspen under Grazed Landscapes. Ph.D. Dissertation, University of California at Davis, 

Davis. Available at URL: 

http://media.proquest.com/media/pq/classic/doc/2162639421/fmt/ai/rep/NPDF?_s=idK9NUsICG%2F5QY

EokleLZh3H6VE%3D. 

Jones, G.T., C. Beck, F.L. Nials, J.J. Neudorfer, B.J. Borwnholtz, and H.B. Gilbert. 1996. Recent Archaeological 

Investigations at the Sunshine Locality, Long Valley, Nevada. Journal of California and Great Basin 

Anthropology 18(1):48–63. Available at URL: http://escholarship.org/uc/item/8d5528wp#page-1. 

Karl, T.R., J.M. Melillo, and T.C. Peterson. 2009. Global Climate Change Impacts in the United States. Cambridge 

University Press, New York, New York. Available at URL: http://www.globalchange.gov/what-wedo/assessment/nca-overview. 

Katzner, T.E., and K.L. Parker. 1998. Long Distance Movements from Established Burrow Sites by Pygmy 

Rabbits (Brachylagus idahoensis) in Southwestern Wyoming. Northwestern Naturalist 79:72-74. 

Available at URL: http://todd_katzner.forestry.wvu.edu/r/download/78873. 

Kay, C.E. 2001. The Condition and Trend of Aspen Communities on BLM Administered Lands in Central Nevada. 

Final Report to the USDOI BLM Battle Mountain Field Office, Battle Mountain, Nevada. 

Kay, C.E. 2002. The Condition and Trend of Aspen Communities on BLM Administered Lands in North-Central 

Nevada – With Recommendations for Management. Final Report to USDOI BLM Elko Field Office, Elko, 

Nevada. Wildlife Management Services. Providence, Utah. 

Kay, C.E. 2003. Aspen Management Guidelines for BLM Lands in North-central Nevada. Final Report to the 

USDOI BLM, Battle Mountain Field Office, Battle Mountain, Nevada. Wildlife Management Services. 

Providence, Utah. Available at URL: 

http://digitalcommons.usu.edu/cgi/viewcontent.cgi?article=8062&context=aspen_bib&seiredir=1&referer=http%3A%2F%2Fwww.bing.com%2Fsearch%3Fq%3DThe%2BCondition%2Band%2B

Trend%2Bof%2BAspen%2BCommunities%2Bon%2BBLM%2BAdministered%2BLands%2Bin%2BNort

hCentral%2BNevada%2B%26qs%3Dn%26form%3DQBRE%26pq%3Dthe%2Bcondition%2Band%2Btren
REFERENCES

3 Bars Project Final EIS 5-16 October 2016

d%2Bof%2Baspen%2Bcommunities%2Bon%2Bblm%2Badministered%2Blands%2Bin%2Bnorthcentral%2Bnevada%2B%26sc%3D0-0%26sp%3D1%26sk%3D%26cvid%3D879bb67cf81846ae912331b4de06c9a4#search=%22Condition%20Trend%20A

spen%20Communities%20BLM%20Administered%20Lands%20North-Central%20Nevada%22. 

Kelly, R.L. 1997. Late Holocene Great Basin Prehistory. Journal of World Prehistory 11(1):1–50. Available at 

URL: http://anthro.utah.edu/PDFs/field_school/kelly_1997.pdf. 

Kerr, A., and M. Salvo. 2007. Managing Western Juniper to Restore Sagebrush Steppe and Quaking Aspen Stands. 

Sagebrush Sea Campaign, Chandler, Arizona. Available at URL: 

http://www.sagebrushsea.org/pdf/SSC_WJ_Position_Paper.pdf. 

Knick, S.T., D.S. Dobkin, J.T. Rothenberry, M.A. Schroder, W.M. Vander Haegen, and C. Van Riper III. 2003. 

Teetering on the Edge or Too Late? Conservation and Research Issues for Avifauna of Sagebrush 

Habitats. The Condor 105:611-634. Available at URL: 

http://sagemap.wr.usgs.gov/Docs/Condor_105p611-634.pdf. 

Kreutzer, L. 2013. Co-operating Agency Review of 3 Bars Ecosystem and Landscape Restoration Project 

Environmental Preliminary Draft EIS. National Park Service, Salt Lake City, Utah. 

Kroeber, A.L. 1925. Handbook of the Indians of California. Bureau of American Ethnology Bulletin 78. 

Washington, D.C. 

Lanner, R.M., and P. Frazier. 2011. The Historical Stability of Nevada’s Pinyon-juniper Forest. Phytologia 93:360-

387. Available at URL: http://www.phytologia.org/uploads/2/3/4/2/23422706/933360-

387lannerpinyonjunipernevada.pdf. 

Larrucea, E.S., and P.F. Brussard. 2008. Habitat Selection and Current Distribution of the Pygmy Rabbit in Nevada 

and California, USA. Journal of Mammalogy 89:691-699. Available at URL: 

http://gaiavisions.org/deiSHerb/FOIAcomments/Public%20Comment%20809%20Attachment/Pygmy%20Rabbits/Larrucea,%20Brussard,%202

008%20Habitat%20Selection%20And%20Current%20Distr.pdf. 

Lauer, J.L., and J.M. Peek. 1976. Big Game-livestock Relationships on the Bighorn Sheep Winter Range, East 

Fork Salmon River, Idaho. University of Idaho Forest, Range, and Wildlife Experiment Station Bulletin 

No. 12. 

Launchbaugh, K., and J.W. Walker. 2006. Targeted Grazing - A New Paradigm for Livestock Management. Pages 

2-9 in Target Grazing: A Natural Approach to Vegetation Management and Landscape Enhancement (K. 

Launchbaugh, Editor). Cottrell Printing, Centennial, Colorado. Available at URL: 

http://www.webpages.uidaho.edu/rx-grazing/Handbook/ASITargetGrazingBook2006.pdf. 

Lewis, C. 2014. Fuels Program Manager Desert Basin Zone, USDOI BLM, Battle Mountain District, Battle 

Mountain, Nevada. Electronic Mail Communication with S. Paulus, AECOM, Seattle, Washington, 

Regarding Cheatgrass in Red Hills, May 20, 2014. 
REFERENCES

3 Bars Project Final EIS 5-17 October 2016 

Lossing, S. 2012. Singleleaf Pinon and Utah Juniper Canopy Interception and Understory Characteristics in Central 

Nevada. M.S. Thesis, University of Idaho, Moscow. 

Lowie, R.H. 1924. Notes on Shoshonean Ethnography. Anthropological Papers of the American Museum of 

Natural History 20(3):185–314. New York. 

Lumos and Associates. 2007. Mineral Assessment Report, Eureka County, Nevada. Prepared for Eureka County, 

October 2007. Available at URL: http://www.yuccamountain.org/mineral/index.htm. 

Lyon, A.G., and S.H. Anderson. 2003. Potential Gas Development Impacts on Sage-grouse Nest Initiation and 

Movement. Wildlife Society Bulletin 31:486-491. Available at URL: 

http://deq.state.wy.us/eqc/orders/Land%20Closed%20Cases/11-

4803%20Lost%20Creek%20ISR,%20LLC/Exhibit%2015.pdf. 

Lyon, L.G., E.S. Telfer, and D.S. Schreiner. 2000a. Direct Effects of Fire and Animal Responses. Pages 17-23 in

Wildland Fire in Ecosystems Effects of Fire on Fauna (J.K. Smith, Editor). General Technical Report 

RMRS-GTR-42, Volume 1. U.S. Department of Agriculture, Forest Service Rocky Mountain Research 

Station. Fort Collins, Colorado. Available at URL: http://www.treesearch.fs.fed.us/pubs/4553. 

Lyon, L.J., R.G. Hooper, E.S. Telfer, and D.S. Schreiner. 2000b. Fire Effects on Wildlife Foods. Pages 51-58 in

Wildland Fire in Ecosystems Effects of Fire on Fauna (J.K. Smith, Editor). General Technical Report 

RMRS-GTR-42. U.S. Department of Agriculture, Forest Service Rocky Mountain Research Station, Fort 

Collins, Colorado. Available at URL: http://www.treesearch.fs.fed.us/pubs/4553. 

Mack, E.M., and B.W. Sawyer. 1965. Here is Nevada: A History of the State. Western Printing and Publishing Co., 

Reno, Nevada. 

MacMahon, J.A. 1992. Deserts. Alfred A. Knopf, Inc. New York, New York. 

Madsen, D.B. 1982. Salvage Excavations at Ticaboo Town Ruin (42Ga2295). In Archaeological Investigations in 

Utah at Fish Springs, Clay Basin, Northern San Rafael, South Henry Mountains. U.S. Department of the 

Interior, BLM, Utah State Office, Cultural Resource Series 12, Salt Lake City. 

Madsen, D.B., and D. Rhode. 1994. Across the West: Human Population Movement and the Expansion of the 

Numa. University of Utah Press, Salt Lake City. 

Madsen, D.B., and D.M. Simms. 1998. The Fremont Complex: A Behavioral Perspective. Journal of World 

Prehistory 12(3):255–336. 

Malouf, C. 1950 [1940]. The Gosiute Indians. University of Utah, Museum of Anthropology Archaeology and 

Ethnology Papers Reprinted Edition. University of Utah Anthropological Papers 3:29-36. 

Marcus, N., S. Woods, S. Simmons, N. Jester, D. Wand, M. Weidemann, and C.K. Morey. 2011. Pinon-Juniper 

Management. FM 2011-11. Colorado State Forest Service, Fort Collins, Colorado. Available at URL: 

http://csfs.colostate.edu/pdfs/120866_PinonJuniperGuide_www.pdf. 
REFERENCES

3 Bars Project Final EIS 5-18 October 2016

Marwitt, J.P. 1986. Fremont Culture. Pages 161-172 in The Great Basin (W.L. d’Azevedo, Editor). In Handbook of 

North American Indians, Volume 11 (W.G. Sturtevant, General Editor). Smithsonian Institution, 

Washington, D.C. 

Maser, C., and J.S. Gashwiler. 1978. Interrelationships of Wildlife and Western Juniper. Pages 37-82 in

Proceedings of the Western Juniper Ecology and Management Workshop (R.E. Martin, J.E. Ealy, and O.L. 

Carter, Editors). General Technical Report PNW-74. U.S. Department of Agriculture, Forest Service 

Pacific Northwest Research Station, Portland, Oregon. Available at URL: 

http://juniper.oregonstate.edu/bibliography/documents/phpVkfX0L_pnw_gtr074.pdf. 

McBride, T. 2002. Exploration and Early Settlement in Nevada: Historic Context. Nevada State Historic 

Preservation Office, Carson City, Nevada. 

McQueen, R., S.W. Hall, A.A. Konoske, and E. Johnson. 2009. Recording of the Eureka and Palisade Railroad 

(Site 26EU743/787, CrNV-63-1235/12-4125) for Sierra Pacific’s 345kV Falcon Transmission Line, 

Eureka County, Nevada. Prepared for NV Energy (Sierra Pacific Power Company), Reno, Nevada, by 

Summit Envirosolutions, Inc., Reno. 

Meyer, J., M. Sale, P. Mulholland, and N. Poff. 1999. Impacts of Climate Change on Aquatic Ecosystem 

Functioning and Health. Journal of the American Water Resources Association 35(6):1373-1386. 

Available at URL: http://onlinelibrary.wiley.com/doi/10.1111/j.1752-1688.1999.tb04222.x/abstract. 

Miller, J. 1983. Numic Religion: An Overview of Power in the Great Basin of Native North America. Anthropos 

78:337–354. 

Miller, R.F. 2001. Managing Western Juniper for Wildlife. In Woodland Fish and Wildlife. Washington State 

University Cooperative Extension and the USDA, Pullman. Available at URL: 

http://www.sagebrushsea.org/pdf/Miller_Juniper_Wildlife_Mgmnt.pdf. 

Miller, R.F., and J.A. Rose. 1999. Fire History and Western Juniper Encroachment in Sage-brush Steppe. Journal 

of Range Management 52:550-559. Available at URL: 

http://oregonstate.edu/dept/eoarc/sites/default/files/researchhome/documents/430.pdf. 

Miller, R.F., and R.J. Tausch. 2000. The Role of Fire in Pinyon and Juniper Woodlands: A Descriptive Analysis. 

Pages 15-30 in Fire Conference 2000: The First National Congress on Fire, Ecology, Prevention and 

Management (K. Galley and T. Wilson, Editors). Invasive Species Workshop: The Role of Fire in the 

Control and Spread of Invasive Species. U.S. Department of Agriculture, Forest Service Tall Timbers 

Research Station, Tallahassee, Florida. Available at URL: 

http://www.sagestep.org/educational_resources/bibliographies/articles/2002_MillerTausch.pdf. 

Miller, R.F., M. Willis, J.A. Rose, D. Rickensmyer, and B. Anthony. 1999. The Affects of Juniper Woodlands on 

Avian Populations. Pages 106-111 in History, Ecology, and Management of Juniper Woodlands. Range 

Field Day Annual Report. Oregon State Agricultural Experiment Station Special Report 1022. Corvallis. 

Available at URL: http://oregonstate.edu/dept/EOARC/sites/default/files/publication/437m.pdf. 
REFERENCES

3 Bars Project Final EIS 5-19 October 2016 

Miller, R.F., J.D. Bates, T.J. Svejcar, F.B. Pierson, and L.E. Eddleman. 2005. Biology, Ecology, and Management 

of Western Juniper (Juniperus occidentalis). Oregon State University Technical Bulletin 152. Corvallis. 

Available at URL: extension.oregonstate.edu/catalog/html/tb/tb152/tb152.pdf. 

Miller, R.F., R.J. Tausch, E.D. McArthur, D.D. Johnson, and S.C. Sanderson. 2008. Age Structure and Expansion 

of Piñon-juniper Woodlands: A Regional Perspective in the Intermountain West. Research Paper Report 

RMRS-RP-69. U.S. Department of Agriculture, Forest Service Rocky Mountain Research Station, Fort 

Collins, Colorado. Available at URL: http://oregonstate.edu/dept/EOARC/pinonjuniper/material/Milleretal2008.pdf. 

Moench, R., and J. Fusaro. 2012. Soil Erosion Control after Wildfire. Colorado State University Extension. Fort 

Collins. Available at URL: http://www.ext.colostate.edu/pubs/natres/06308.html. 

Monson, S.B. 2002. Restoration and Management of Sagebrush/Grass Communities Workshop. Elko, Nevada. 

Available at URL: www.rangenet.org/trader/2002_Elko_Sagebrush_Conf.pdf. 

Montgomery and Associates. 2010. Hydrogeology and Numerical Flow Modeling, Volume 1, Text and Tables, 

Mount Hope Project, Eureka County, Nevada, with Appendices. July 2010. Prepared for Eureka Moly, 

Elko, Nevada. Prepared by Montgomery and Associates, Interflow Hydrology, Inc. and Barranca Group 

LLC. Tucson, Arizona. 

Morefield, J.D. 1993. Status Report Castilleja salsuginosa Monte Neva Paintbrush. U.S. Department of the 

Interior, U.S. Fish and Wildlife Service Great Basin Field Office, Carson City, Nevada. 

Muir, J. 1894. The Mountains of California. The Century Company, New York, New York. 

Myrick, D.F. 1992. Railroads of Nevada and Eastern California, Volume I. University of Nevada Press, Reno. 

National Academy of Sciences. 2010. Advancing the Science of Climate Change. The National Academic Press, 

Washington, D.C. Available at URL: http://www.nap.edu/catalog.php?record_id=12782. 

National Conference of State Legislatures. 2008. Climate Change Nevada from National Association of State 

Legislatures. Washington, D.C. Available at URL: 

http://www.cier.umd.edu/climateadaptation/Climate%20change--NEVADA.pdf. 

National Interagency Coordination Center. 2011. Wildlife Fire Summary and Statistics Annual Report 2011. Boise, 

Idaho. Available at URL: 

http://www.predictiveservices.nifc.gov/intelligence/2011_statssumm/2011Stats&Summ.html. 

National Interagency Fire Center. 2012. Prescribed Fires and Burns by Agency by Acre 10 year, 1998–2011. 

Boise, Idaho. Available at URL: http://www.nifc.gov/fireInfo/fireInfo_stats_prescribed.html. 

National Invasive Species Council. 2001. Management Plan for Meeting the Invasive Species Challenge. 

Washington, D.C. Available at URL: http://www.invasivespeciesinfo.gov/docs/council/mp.pdf. 

National Wildfire Coordinating Group. 2010. NWCG Wildland Firefighter Fatalities by Cause 1999-2009. 

Available at URL: 

http://www.nwcg.gov/branches/pre/rmc/summaries/fatalities_by_cause_1999_2009.pdf. 
REFERENCES

3 Bars Project Final EIS 5-20 October 2016

Neary, D.G., C.C. Klopatek, L.F. DeBano, and P.F. Ffolliott. 1999. Fire Effects on Belowground Sustainability: A 

Review and Synthesis. Forest Ecology and Management 122:51-71. Available at URL: 

http://www.cfr.washington.edu/classes.esrm.409/Reading/Neary%20et%20al.%201999.pdf. 

Nevada Department of Education. 2012. Research Bulletins – An Annual Series. Accessed at URL: 

http://www.doe.nv.gov/Resources_Research_Bulletin/. 

Nevada Department of Employment, Training and Rehabilitation. 2012. Nevada Labor Statistics. Carson City, 

Nevada. Available at URL: http://www.nevadaworkforce.com/. 

Nevada Department of Taxation, Division of Assessment Standards. 2012. 2010-11 Statistical Analysis of the Roll. 

Available at URL: http://tax.nv.gov/LocalGovt/PolicyPub/ArchiveFiles/Statistical_Analysis_of_the_Roll/. 

Nevada Department of Wildlife (NDOW). 2004. Lahontan Cutthroat Species Management Plan for the Upper 

Humboldt River Drainage Basin. Reno. Available at URL: 

http://www.ndow.org/uploadedFiles/ndoworg/Content/public_documents/Wildlife_Education/Publications

/lct_smp.pdf. 

NDOW. 2008a. Vector Digital Data: Wildlife Sighting and Collection Records. File Name: bmd_diversity 

_2008_NDOW. Reno. 

NDOW. 2008b. Vector Digital Data: Distribution of Pronghorn Antelope in the Battle Mountain District. File 

Name: Pronghorn_Distribution_2007. U.S. Department of the Interior, BLM, Battle Mountain District, 

Battle Mountain, Nevada. Reno. 

NDOW. 2009a. Species Population Inventory Summary for Birch Creek and Pete Hanson Creek. July 2009. Reno. 

NDOW. 2009b. Vector Digital Data: Herpetofauna Collection Records. File Name: 

CommercialReptileCollections_2009. Reno. 

NDOW. 2009c. Vector Digital Data: Wildlife Sighting and Collection Records. File Name: 

bmd_wildlife_sight_2009_NDOW. Reno. 

NDOW. 2009d. Vector Digital Data: Distribution of Mule Deer within the Battle Mountain District. File Name: 

Mule Deer_Distribution_all. Reno. 

NDOW. 2009e. Vector Digital Data: Pygmy Rabbit Sightings within the Battle Mountain District. File Name: 

bmd_pyg_sightings_2009_NDOW. Reno. 

NDOW. 2010a. Vector Digital Data: Wildlife Sighting and Collection Records. File Name: 

bmd_wildlife_sight_2009_NDOW. Reno. 

NDOW. 2010b. Vector Digital Data: Bighorn Sheep Distribution in the Battle Mountain District. File Name: 

Bighorn Sheep_Distribution_2010. Reno. 

NDOW. 2012a. Electronic Mail Communication to Rollin Daggett, Aquatic Wildlife Biologist, AECOM, Fort 

Collins, Colorado, Regarding Moist Area Sites within the 3-Bars Project Area, March 23, 2012. Elko. 
REFERENCES

NDOW. 2012b. Electronic Mail Communication from M. Starr to Steven Foree Battle Mountain Field Office, 

Battle Mountain, Nevada, Regarding Lahontan Cutthroat Trout Habitat within the 3 Bars Project Area, 

July 27, 2012. 

NDOW. 2012c. 2011-2012 Big Game Status. Reno. 

NDOW. 2012d. Electronic Mail Communication to Steve Foree, Wildlife Biologist, USDOI BLM Battle Mountain 

District, Battle Mountain, Nevada, Regarding Wildlife Species Known or Suspected to Occur within the 3-

Bars Project Area, February 27, 2012. Reno. 

NDOW. 2012e. Vector Digital Data: Greater Sage Grouse Nesting Habitat Clipped to the 3 Bars Project Area. File 

Name: SageGrouse_NestingHabitat. Reno. 

NDOW. 2012f. Big Game Harvest Statistics and Draw Odds Website. Reno. Available at URL: 

http://www.ndow.org/hunt/resources/odds/index.shtm#ant. 

NDOW. 2012g. Expanded Statistics and Data Summaries for Roberts Creek, Roberts Creek Reservoir, Pete 

Hanson Creek, Vinini Creek, JD Ponds, Denay Creek, and Tonkin Reservoir. Data Provided by NDOW to 

USDOI BLM, Battle Mountain, Nevada. Reno. 

Nevada Division of Environmental Protection. 2012. Central Region and Roberts Creek Water Quality Standards. 

Carson City. Bureau of Water Quality Planning. Available at URL: http://www.leg.state.nv.us/nac/nac445a.html#NAC445ASec2008. 

Nevada Division of Environmental Protection and Nevada Division of Conservation Districts. 1994. Handbook of 

Best Management Practices. Carson City. Available at URL: 

http://www.cicacenter.org/pdf/NVBMPHandbook.pdf. 

Nevada Division of State Parks. 2010. Statewide Comprehensive Outdoor Recreation Plan. Department of 

Conservation and Natural Resources. Carson City. Available at URL: http://parks.nv.gov/wpcontent/uploads/2009/10/Test2010_SCORP.pdf. 

Nevada Division of Water Resources. 2012. Nevada’s Hydrographic Regions, Basins, and Sub-basins, and 

Hydrographic Area Summaries. Carson City. Available at URL: http://water.nv.gov/data/underground/ and 

http://water.nv.gov/programs/planning/counties/. 

Nevada Natural Heritage Program. 2001. Nevada Rare Plant Atlas. Carson City. Available at URL: 

http://heritage.nv.gov/atlas/. 

Nevada Natural Heritage Program. 2006. Cuckoo. Carson City. 

Nevada Natural Heritage Program. 2010. Animal and Plant At-Risk Tracking List. Carson City. Available at URL: 

http://heritage.nv.gov/sites/default/files/library/track.pdf. 

Nevada Natural Heritage Program. 2011. Climate Change Vulnerability Index (Release 2.01). Select Results for 

Wildlife Action Plan Conservation Priority Species. March 11, 2011. Carson City. Available at URL: 

https://connect.natureserve.org/science/climate-change/ccvi. 

3 Bars Project Final EIS 5-21 October 2016 
REFERENCES

Nevada Natural Heritage Program. 2012. Digital Data Containing the Recorded Endangered, Threatened, 

Candidate and At-risk Plant and Animal Elements (Taxa) within the 3 Bars Ecosystem Landscape 

Restoration Project Area Assumed to be Extant, unless Mentioned Otherwise. Provided on February 23, 

2012. Carson City. 

Nevada State Demographer. 2012a. Nevada County Certified Population Estimates July 1, 2000 to July 1, 2011, 

Includes Cities and Towns. Carson City. Available at URL: http://nvdemography.org/wpcontent/uploads/2012/03/Popul-of-Nevadas-Counties-and-Incorp-cities-2011-Certified-Series-031112.pdf. 

Nevada State Demographer. 2012b. Nevada County Age, Sex, Race, and Hispanic Origin Estimates and 

Projections 2010 to 2030. Prepared By: The Nevada State Demographer’s Office J. Hardcastle, Nevada 

State Demographer and A. Mitchell, Student Assistant University of Nevada-Reno. October 1, 2011, 

revised April 23, 2012. Carson City. Available at URL: http://nvdemography.org/data-andpublications/age-sex-race-and-hispanic-origin-estimates-and-projections/. 

Nevada State Health Division. 2005. Report on Trauma and Other Injuries in Nevada. Center for Health Data and 

Research, Bureau of Health Planning and Statistics. Carson City. Available at URL: 

health.nv.gov/PDFs/Traumareport00_02.pdf. 

Nevada State Health Division. 2011a. Healthy People Nevada Moving From 2010 to 2020. Report for Eureka 

County. Available at URL: http://health.nv.gov/PDFs/HSPER/HP/countyrpts/EurekaCountyReport.pdf. 

Nevada State Health Division. 2011b. Healthy People Nevada: Moving from 2010 to 2020. Nevada Department of 

Health and Human Services. Carson City. Available at URL: http://health.nv.gov/HSPER_HP.htm. 

Nevada Surveyor General and State Land Register. 1880. Annual Reports 1865–1890. On File at Nevada State 

Library and Archives, Carson City. 

Noelle, S.M. 2012. Effects of Intercanopy Vegetation Cover and Pinon-Juniper Slash Presence on Surface Runoff 

and Sediment Production from Steep Slopes. M.S. Thesis, University of Arizona, Tucson. 

Nonne, D., E. Blomberg, and J. Sedinger. 2011. Dynamics of Greater Sage-grouse (Centrocercus urophasianus) 

Populations in Response to Transmission Lines in Central Nevada. Department of Natural Resources and 

Environmental Sciences, University of Nevada-Reno. Reno, Nevada. Available at URL: 

http://view.officeapps.live.com/op/view.aspx?src=http%3A%2F%2Fwww.ag.unr.edu%2Fsedinger%2FSa

ge-grouse%2FProgress_Report_2010%2520-%2520Final.doc. 

Noson, A.C. 2002. Avian Communities in Relation to Habitat Influenced by Fire in Sagebrush Steppe Landscape. 

M.S. Thesis, Oregon State University, Corvallis. 

O’Meara, T.E., J.B. Haufler, L.H. Steleter, and J.G. Nagy. 1981. Nongame Wildlife Responses to Chaining of 

Pinyon-juniper Woodlands. Journal of Wildlife Management 45:381-389. Available at URL: 

http://www.jstor.org/discover/10.2307/3807919?uid=2&uid=4&sid=21103841958021. 

Ogle, D.G. 2006. Crested Wheatgrass. U.S. Department of Agriculture Natural Resources Conservation Service 

Idaho State Office, Boise. Available at URL: plants.usda.gov/plantguide/pdf/pg_agcr.pdf. 

3 Bars Project Final EIS 5-22 October 2016
REFERENCES

3 Bars Project Final EIS 5-23 October 2016 

Olson, B.E. 1999. Grazing and Weeds. Pages 85-97 in Biology and Management of Noxious Rangeland Weeds 

(R.L. Sheley and J.K. Petroff, Editors). Oregon State University Press. Corvallis. 

OTAK, Inc. 2011. Visual Resource Inventory, BLM Battle Mountain, Nevada District Office. U.S. Department of 

the Interior, BLM, Battle Mountain, Nevada. Carbondale, Colorado. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/rmp

.Par.76234.File.dat/Pages%201_20%20from%20BattleMtnVRI_Sections1-5II.pdf. 

Otis, D.L., J.H. Schulz, D. Miller, R.E. Mirarchi, and T.S. Baskett. 2008. Mourning Dove (Zenaida macroura), 

The Birds of North America, (A. Poole and F. Gill, Editors). The Academy of Natural Sciences, 

Philadelphia, Pennsylvania, and The American Ornithologists' Union, Washington, D.C. 

Paher, S.W. 1970. Nevada Ghost Towns and Mining Camps. Nevada Publications, Las Vegas, Nevada. 

Paige, C., and S.A. Ritter. 1999. Birds in a Sagebrush Sea: Managing Sagebrush Habitats for Bird Communities. 

Partners in Flight Western Working Group. Boise, Idaho. Available at URL: 

http://www.partnersinflight.org/wwg/sagebrush.pdf. 

Patterson, E. 1965. Early Cattle in Elko County. Nevada Historical Society Quarterly 8:5-12. 

Payne, N.F., and F.C. Bryant. 1998. Wildlife Habitat Management of Forestlands, Rangelands, and Farmlands. 

Krieger Publishing Company. Malabar, Florida. 

Pehrson, K.A., and B.F. Sowell. 2011. Converting Crested Wheatgrass Stands to Enhance Big Sagebrush: A 

Literature Review. Natural Resources and Environmental Issues 16:16. Available at URL: 

http://digitalcommons.usu.edu/nrei/vol16/iss1/16. 

Pellant, M. 2002. Cheatgrass: Invasion, Occurrence, Biological/Competitive Features, and Control Measures. 

Restoration and Management of Sagebrush/Grass Communities Workshop. Elko, Nevada. Available at 

URL: www.rangenet.org/trader/2002_Elko_Sagebrush_Conf.pdf. 

Petersen, J. 2012. Fishery Biologist, NDOW, Elko, Nevada. Electronic Mail Communication with R. Daggett, 

AECOM, Fort Collins, Colorado, March 2012. 

Petersen, S.L., and T.K. Stringham. 2008. Infiltration, Runoff, and Sediment Yield in Response to Western Juniper 

in Southeast Oregon. Rangeland Ecology and Management 61:74-81. 

Pierson, F.B., J.D. Bates, T.J. Svejcar, and S.P. Hardegree. 2007. Runoff and Erosion after Cutting Western 

Juniper. Rangeland Ecology and Management 60:285-292. 

Pierson, F.B., P.R. Kormos, and C.J. Williams. 2008. Hydrologic and Erosional Impacts of Pinyon and Juniper 

Encroachment into Sagebrush Steppe Communities of the Great Basin, USA. Contribution Number 9 of 

the Sagebrush Steppe Treatment Evaluation Project, United States Joint Fire Science Program, Boise, 

Idaho. 
REFERENCES

Pierson, F.B., C.J. Williams, S.P. Hardegre, P.E. Clark, P.R. Kormos, and O.Z. Al-Hamdan. 2013. Hydrologic and 

Erosion Responses of Sagebrush Steppe Following Juniper Encroachment, Wildfire, and Tree Cutting. 

Society for Range Management 66:274-289. Available at URL: 

http://www.bioone.org/doi/full/10.2111/REM-D-12-00104.1. 

Pilliod, D.S., R.B. Bury, E.J. Hyde, C.A. Pearl, and P.S. Corn. 2003. Fire and Amphibians in North America. 

Forest Ecology and Management 178:163–181. Available at URL: 

http://leopold.wilderness.net/pubs/474.pdf. 

Poff, N.L., and J.K.H. Zimmerman. 2010. Ecological Responses to Altered Flow Regimes: A Literature Review to 

Inform the Science and Management of Environmental Flows. Freshwater Biology 55:194-205. Available 

at URL: 

http://filebox.vt.edu/users/dorth/E%20Flow%20Readings%20%20/Poff%20and%20Zimmerman%202010

%20ecological%20responses%20%20to%20altered%20flow%20%20%20a%20literature%20review.pdf. 

Poff, N.L., B.D. Richter, A.H. Arthington, S.E. Bunn, R.J. Naiman, E. Kendy, M. Acreman, C. Apse, B.P. Bledsoe, 

M.C. Freeman, J. Henriksen, R.B. Jacobson, J.G. Kennen, D.M. Merritt, J.H. O’Keeffe, J.D. Olden, 

K. Rogers, R.E. Tharme, and A. Warner. 2010. The Ecological Limits of Hydrologic Alteration (ELOHA): 

A New Framework for Developing Regional Environmental Flow Standards. Freshwater Biology 55:147-

170. Available at URL: 

http://www.colorado.edu/geography/class_homepages/geog_4501_s10/readings/Poff%20eloha%2009.pdf. 

Ponce, D.M., and J.M.G. Glen. 2008. Relationship of Epithermal Gold Deposits to Large-scale Fractures in 

Northern Nevada. Economic Geology and the Bulletin of the Society of Economic Geologists 97(1):3–9.

Available at URL: http://geomaps.wr.usgs.gov/gump/people/ponce/pubs/02econ_geol_ponce.pdf. 

Price, J.G., A.R. Coyner, J. Muntean, and D. Driesner. 2010. Update on Nevada Mineral Production and 

Exploration, Nevada Bureau of Mines and Geology. Available at URL: 

http://www.nbmg.unr.edu/_docs/Presentations/NWMAupdate10.pdf. . 

Radle, A.L. 2007. The Effect of Noise on Wildlife: A Literature Review. Available at URL: 

http://wfae.proscenia.net/library/articles/radle_effect_noise_wildlife.pdf. 

Rau, B.M., J.C. Chambers, R.R. Blank, and W.W. Miller. 2005. Hydrologic Response of a Central Nevada PinyonJuniper Woodland to Prescribed Fire. Rangeland Ecology and Management 58:614-622. Available at 

URL: http://www.firescience.gov/projects/01B-3-3-01/project/01B-3-3-

01_01B_3_3_01_Deliverable_15.pdf. 

Reinhardt, T.E., R.D. Ottmar, and A.J.S. Hanneman. 2000. Smoke Exposure among Firefighters at Prescribed 

Burns in the Pacific Northwest. U.S. Department of Agriculture, Forest Service Research Pacific 

Northwest Research Station. Research Paper PNW-RP-526, Seattle, Washington. Available at URL: 

http://www.depts.washington.edu/wildfire/resources/smokefire.pdf. 

Reisner, M.D. 2010. Drivers of Plant Community Dynamics in Sagebrush Steppe Ecosystems: Cattle Grazing, 

Heat, and Water Stress. Ph.D. Dissertation, Oregon State University, Corvallis. Available at URL: 

http://www.sagestep.org/pubs/pubs/055Reisner_2010.pdf. 

3 Bars Project Final EIS 5-24 October 2016
REFERENCES

3 Bars Project Final EIS 5-25 October 2016 

Reisner, M.D., J.B. Grace, D.A. Pyke, and P.S. Doescher. 2013. Conditions Favoring Bromus tectorum Dominance 

of Endangered Sagebrush Steppe Ecosystems. Journal of Applied Ecology 50:1039-1049. Available at 

URL: 

http://ir.library.oregonstate.edu/xmlui/bitstream/handle/1957/38539/jpe_12097_Rev_EV.pdf?sequence=1. 

Reno, R.L., V.L. Clay, A. Dansie, Foothill Resource Associates, A. Graham, L. Hause, M.R. Rose, and T. Burke 

(Editors). 1994. The Charcoal Industry in the Roberts Mountains, Eureka County, Nevada: Final Report 

for the Mitigation of Adverse Effects to Significant Cultural Properties from Atlas Precious Metals’ Gold 

Bar II Mine Project. Prepared for Atlas Corporation, Denver, Colorado, by Archaeological Research 

Services, Inc., Virginia City, Nevada. Available at URL: http://www.worldcat.org/identities/ncarcheological%20research%20services%20inc/. 

Resource Concepts, Inc. 2001. Nevada Grazing Statistics Report and Economic Analysis for Federal Lands in 

Nevada. Prepared for State of Nevada Department of Agriculture and Nevada Association of Counties. 

Carson City. Available at URL: 

http://agri.nv.gov/uploadedFiles/agrinvgov/Content/Animals/Livestock/NVGrazingStatsFullReport.pdf. 

Roberts, R.J., and L.M. Montgomery. 1967. Mineral Resource Map of Eureka County, Nevada. In Geology and 

Mineral Resources of Eureka County, Nevada (R.J. Roberts, K.M. Montgomery, and R.E. Lehner, 

Editors). Nevada Bureau of Mines and Geology, Bulletin 64. MacKay School of Mines, University of 

Nevada, Reno. 

Roberts, R.J., K.M. Montgomery, and R.E. Lehner. 1967. Geology and Mineral Resources of Eureka County, 

Nevada. Nevada Bureau of Mines and Geology Bulletin 64. Available at URL: 

http://www.worldcat.org/title/geology-and-mineral-resources-of-eureka-county-nevada/oclc/152143. 

Robinson, B.P., W. Thordarson and W.A. Beetem. 1967. Hydrologic and Chemical Data for Wells, Springs, and 

Stream in Central Nevada, Townships 1 through 21 North, Ranges 41 through 57 East. Report TEI-871. 

U.S. Geological Survey Open File Report 67-190. Prepared for the U.S. Atomic Energy Commission, 

USGS, Denver, Colorado. 

Romme, W., C. Allen, J. Bailey, W. Baker, B. Bestelmeyer, P. Brown, K. Eisenhart, L. Floyd-Hanna, D. Huffman, 

B. Jacobs, R. Miller, E. Muldavin, T. Swetnam, R. Tausch, and P. Weisberg. 2007. Historical and Modern 

Disturbance Regimes for Pinyon-Juniper Vegetation in the Western U.S. Colorado Forest Restoration 

Institute and The Nature Conservancy, Fort Collins, Colorado. Available at URL: 

http://www.fs.fed.us/rm/pubs_other/rmrs_2009_romme_w001.pdf. 

Romme, W., C. Allen, J. Bailey, W. Baker, B. Bestelmeyer, P. Brown, K. Eisenhart, L. Floyd-Hanna, D. Huffman, 

B. Jacobs, R. Miller, E. Muldavin, T. Swetnam, R. Tausch, and P. Weisberg. 2009. Historical and Modern 

Disturbance Regimes, Stand Structures, and Landscape Dynamics in Pinon-Juniper Vegetation of the 

Western United States. Rangeland Ecology and Management 62:203-222. Available at URL: 

http://www.ltrr.arizona.edu/~tswetnam/tws-pdf/PJSynthesis_6-08.pdf. 
REFERENCES

Rosentreter, R. 1986. Compositional Patterns within Rabbitbrush (Chrysothamnus) Community of the Idaho Snake 

River Plain. Pages 273-277 in Proceedings – Symposium on the Biology of Artemesia and Chrysothamnus

(E.D. McArthur and B.L. Welch, Editors). General Technical Report INT-200. U.S. Department of 

Agriculture, Forest Service Intermountain Research Station, Ogden, Utah. Available at URL: 

http://www.ntc.blm.gov/krc/uploads/643/1984%20Compositional%20patterns%20within%20a%20rabbitb

rush%20(Chrysothamnus)%20community%20of%20the%20Idaho%20Snake%20River%20plain--

handout.PDF. 

Rucks, M. 2000. A Report on Ethnographic Study Conducted to Assist the Bureau of Land Management in the 

Evaluation of Traditional Cultural Properties in the Mt. Tenabo Area. Prepared for Cortez Gold Mines, 

Inc., Beowawe, Nevada, by Summit Envirosolutions Inc., Carson City, Nevada. 

Rucks, M. 2003. Ethnographic for Pediment Project. Prepared for ENSR, Fort Collins, Colorado, by Summit 

Envirosolutions Inc., Carson City, Nevada. 

Rucks, M. 2004. An Ethnographic Study Completed for the Cortez Gold Mines Pediment Project. Prepared by 

Summit Envirosolutions Inc., Carson City, Nevada. 

Rucks, M. 2011. Report on Ethnographic Study Conducted to Facilitate Consultation with Western Shoshone 

Tribal Governments of Central Nevada for the Sierra Pacific Power Falcon to Gonder 324kV 

Transmission Line. Report Prepared by Summit Envirosolutions, Inc., Carson City, Nevada. 

Rusco, M.K. 2000. Background Ethnographic Study for Cortez Joint Venture. Prepared for JBR Environmental, 

Reno, Nevada. 

Rush, F.E., and D.E. Everett. 1964. Ground-water Appraisal of Monitor, Antelope, and Kobeh Valleys, Nevada. 

Ground-Water Resources – Reconnaissance Series Report 30. Prepared in Cooperation with the USGS. 

Nevada Department of Conservation and Natural Resources, Carson City. 

Russell, K. 2004. Intensive Cultural Resources Inventory of the Sevenmile Fuels Reduction Project: Phase I. BLM 

Report 6-2479-0 (P). On file at the U.S. Bureau of Land Management, Battle Mountain Field Office, 

Battle Mountain, Nevada. 

Ruyle, G., and P. Ogden. 1993. What is an A.U.M? Rangeland Management. Arizona Ranchers’ Management 

Guide, Arizona Cooperative Extension Service, University of Arizona, Tempe. Available at URL: 

http://ag.arizona.edu/arec/pubs/rmg/1%20rangelandmanagement/1%20aum93.pdf. 

Sage- and Columbian Sharp-tailed Grouse Technical Committee. 2008. Greater Sage-grouse Population Trends: 

An Analysis of Lek Count Databases 1965-2007. Western Association of Fish and Wildlife Agencies. 

Cheyenne, Wyoming. Available at URL: http://www.fws.gov/mountainprairie/species/birds/sagegrouse/archives.html. 

Saldi-Caromile, K., K. Bates, P. Skidmore, J. Barenti, and D. Pineo. 2004. Stream Habitat Restoration Guidelines: 

Final Draft. Co-published by the Washington Departments of Fish and Wildlife and Ecology and the 

USDOI, USFWS, Olympia, Washington. Available at URL: 

http://wdfw.wa.gov/publications/00043/wdfw00043.pdf. 

3 Bars Project Final EIS 5-26 October 2016
REFERENCES

3 Bars Project Final EIS 5-27 October 2016 

Sauer, J.R., J.E. Hines, and J. Fallon. 2008. The North American Breeding Bird Survey, Results and Analysis 

1996-2007. Version 5.15.2008. U.S. Geological Survey Pawtuxet Wildlife Research Center, Laurel, 

Maryland. Available at URL: http://www.mbr-pwrc.usgs.gov/bbs/bbs2007.html. 

Schmidt, K.M., J.P. Menakis, C.C. Hardy, W.J. Hann, and D.L. Bunnell. 2002. Development of Coarse-scale 

Spatial Data for Wildland Fire and Fuel Management. U.S. Department of Agriculture, Forest Service, 

Rocky Mountain Research Station General Technical Report RMRS-GTR-87. Fort Collins, Colorado. 

Available at URL: http://www.firelab.org/ScienceApps_Files/downloads/coarsescale/fuelman.pdf. 

Scott, V.E., and E.L. Boeker. 1977. Responses of Merriam’s Turkey to Pinyon-juniper Control. Journal of Range 

Management 30:220-223. Available at URL: 

http://www.jstor.org/discover/10.2307/3897475?uid=2&uid=4&sid=21103845656551. 

Shepperd, W.D. 1993. Initial Growth, Development, and Clonal Dynamics of Regenerated Aspen in the Rocky 

Mountains. Research Paper RM 312. U.S. Department of Agriculture, Forest Service. Rocky Mountain 

Forest and Range Experiment Station, Fort Collins, Colorado. 

Shepperd, W.D. 2008. Aspen Ecology and Management: the Foundation for Planning into the Future. Fort Collins, 

Colorado. Available at URL: www.safnet.org/fp/documents/aspen_mgt_08.pdf. 

Shepperd, W.D., and F.W. Smith. 1993. The Role of Near-surface Laterial Roots in the Life Cycle of Aspen in the 

Central Rocky Mountains. Forest Ecology and Management 61:157-170. 

Shepperd, W.D., and S.A. Mata. 2005. Planting Aspen to Rehabilitate Riparian Areas: A Pilot Study. Research 

Note RMRS-RN-26. U.S. Department of Agriculture, Forest, Service Rocky Mountain Research Station, 

Fort Collins, Colorado. Available at URL: http://www.fs.fed.us/rm/pubs/rmrs_rn026.pdf. 

Soil Quality Institute. 2001. Rangeland Soil Quality—Wind Erosion. U.S. Department of Agriculture Natural 

Resources Conservation Service, Washington, D.C. Available at URL: 

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_052501.pdf. 

SRK. 2007a. Baseline Studies for the Mount Hope Project. Report Prepared for Idaho General Mines, Inc. January 

2007, Revised May 2007. Elko, Nevada. 

SRK. 2007b. Baseline Studies for the Mount Hope Project - Wellfield, Power Line, and Transmission Line. Report 

Prepared for Idaho General Mines, Inc. September 2007. Elko, Nevada. 

SRK. 2008. Mount Hope Project Baseline Surface Water and Groundwater Report. Report Prepared for General 

Moly Inc., Elko, Nevada. 

SRK. 2010. Mount Hope Project Regional Snail Survey Fall 2007. Report Prepared for Eureka Moly LLC. April 

2010. Elko, Nevada. 

Starr, M. 2011. Field Trip Report – Willow Creek Fish Population Survey. Prepared by M. Starr, September 19–20, 

2011. Reno. 

Stevens, B.S. 2011. Impacts of Fences on Greater Sage-Grouse in Idaho: Collision, Mitigation, and Spatial 

Ecology. M.S. Thesis, University of Idaho, Moscow. 
REFERENCES

Steward, J. 1941. Culture Element Distributions, XIII: Nevada Shoshone. University of California Anthropological 

Records 4(2):209–360. 

Steward, J. 1943. Some Western Myths. Anthropological Papers 31. Bureau of American Ethnology Bulletin 

136:249–299. 

Steward, J. 1970 [1938]. Basin-Plateau Aboriginal Sociopolitical Groups. Bureau of American Ethnology Bulletin 

120. Washington, D.C. 1970 Reprinted Edition. University of Utah Press, Salt Lake City. 

Stone, S.M., and J.M. Berdan. 1984. Some Late Silurian (Pridolian) Ostracodes from the Roberts Mountains 

Central Nevada. Journal of Paleontology 58(4):977-1009. 

Stoner, E.J., M.K. Rusco, and R. Deis. 2000. Toolstone Quarriers and Stone Tool Carriers: The Archaeology of 

Nine Sites in the Egan Range, White Pine County, Nevada. Cultural Resources Report Prepared by 

Western Culture Resource Management, Inc., Sparks, Nevada, for BHP Copper and USDOI BLM, Ely 

District, Ely, Nevada. 

Tall Timbers Research Station. 2001. Proceedings of the Invasive Species Workshop: The Role of Fire in the 

Control and Spread of Invasive Species. Miscellaneous Publication No. 11. Allen Press, Inc. Lawrence, 

Kansas. Available at URL: http://www.talltimbers.org/publications4sale.html#misc. 

Tague, C., S. Valentine, and M. Kotchen. 2008. Effect of Geomorphic Channel Restoration on Streamflow and 

Groundwater in a Snowmelt-dominated Watershed. Water Resources Research 44(10)415-424. Available 

at URL: environment.yale.edu/kotchen/pubs/stream.pdf. 

Tausch, R.J. 1999. Transitions and Thresholds: Influences and Implications for Management in Pinon and Utah 

Juniper Woodlands. Pages 61-65 in Proceedings: Ecology and Management of Pinon-juniper Communities 

within the Interior West. General Technical Report RMRS-P-9. U.S. Department of Agriculture, Forest 

Service Rocky Mountain Research Station, Fort Collins, Colorado. Available at URL: 

http://www.fs.fed.us/rm/pubs/rmrs_p009/rmrs_p009_361_365.pdf. 

Tausch, R.J., and S. Hood. 2007. Pinyon/Juniper Woodlands. General Technical Report RMRS-GTR-202. U.S. 

Department of Agriculture, Forest, Service Rocky Mountain Research Station, Fort Collins, Colorado. 

Available at URL: http://www.fs.fed.us/rm/pubs/rmrs_gtr202.pdf. 

Tausch, R.J., R.F. Miller, B.A. Roundy, and J.C. Chambers. 2009. Pinon and Juniper Field Guide: Asking the 

Right Questions to Select Appropriate Management Actions. USGS Circular 1335. Reston, Virginia. 

Thomas, D.H. 1981a. How to Classify the Projectile Points from Monitor Valley, Nevada. Journal of California 

and Great Basin Anthropology 3(1):7–43. Available at URL: 

http://escholarship.org/uc/item/6477q5zn#page-1. 

Thomas, D.H. 1981b. Complexity Among Great Basin Shoshoneans: The World’s Least Affluent Hunter-gathers? 

Pages 19-52 in Affluent Foragers: Pacific Coast East and West (S. Koyama and D.H. Thomas, Editors). 

National Museum of Ethnology, Osaka, Japan. 

3 Bars Project Final EIS 5-28 October 2016
REFERENCES

3 Bars Project Final EIS 5-29 October 2016 

Thomas, D.H. 1982a. An Overview of Central Great Basin Pre-history. Pages 156–171 in Man and Environment in 

the Great Basin (D. B. Madsen and J. F. O’Connell, Editors). Society of American Archaeological Papers 

2.

Thomas, D.H. 1982b. The 1981 Alta Toquima Village Project. Desert Research Institute Social Science Technical 

Report Series No. 17. Desert Research Institute, Reno, Nevada. 

Thomas, D.H. 1983a. The Archaeology of Monitor Valley: 2. Gatecliff Shelter. Anthropological Papers of the 

American Museum of Natural History 59(1). New York, New York. 

Thomas, D.H. 1983b. The Archaeology of Monitor Valley: 1. Epistemology. Anthropological Papers of the 

American Museum of Natural History 58(1). New York, New York. 

Thomas, D.H. 1988. The Archaeology of Monitor Valley: 3. Survey and Additional Excavations. Anthropological 

Papers of the American Museum of Natural History 66(2). New York, New York. 

Thomas, D.H. 1997. Phone Conversation with Richard Deis. David Hurst Thomas, Curator, Department of 

Anthropology. American Museum of Natural History, New York, New York. 

Thomas, D.H., and R.L. Bettinger. 1976. Prehistoric Pinon Ecotone Settlements of the Upper Reese River Valley, 

Central Nevada. Anthropological Papers of the American Museum of Natural History 53(3). New York, 

New York. 

Thomas, D.H., L.S.A. Pendleton, and S.C. Cappannari. 1986. Western Shoshone. Pages 262-284 in The Great 

Basin (W. d’Azevedo, Editor). In Handbook of North American Indians, Volume 11 (W.G. Sturtevant, 

General Editor). Smithsonian Institution, Washington, D.C. 

Thomas, J.W., C. Maser, and J. Rodiek. 1979. Wildlife Habitats in Managed Rangelands -The Great Basin of 

Southeastern Oregon Riparian Zones. General Technical Report PNW-80. U.S. Department of 

Agriculture, Forest Service Pacific Northwest Forest and Range Experiment Station, Portland, Oregon. 

Thurow, T.L., and J.W. Hester. 2012. How an Increase in Juniper Cover Alters Rangeland Hydrology. Texas 

Natural Resources. Texas A&M Agrilife Research and Extension Center, San Angelo, Texas. Available at 

URL: http://texnat.tamu.edu/library/symposia/juniper-ecology-and-management/how-an-increase-orreduction-in-juniper-cover-alters-rangeland-hydrology/. 

Tilley, D.J., D. Ogle, L. St. John, B.L. Waldron, and R.D. Harrington. 2006. Forage Kochia. U.S. Department of 

Agriculture Natural Resources Conservation Service Plant Guide. Washington, D.C. Available at URL: 

plants.usda.gov/plantguide/pdf/pg_kopr80.pdf. 

Tingley, J.V. 1998. Mining Districts of Nevada, Second Edition, Nevada Bureau of Mines and Geology, Report 47. 

November 19, 1998. Available at URL: http://www.nbmg.unr.edu/dox/dox.htm. 

Tirmenstein, D. 1999. Artemisia tridentata spp. tridentata. In Fire Effects Information System. U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory, Fort Collins, 

Colorado. Available at URL: http://www.fs.fed.us/database/feis/. 

Townley, J.M. 1986. The Pony Express Guidebook. Great Basin Studies Center, Reno, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-30 October 2016

Trotter, P.C. 1987. Cutthroat, Native Trout of the West. Colorado Associated University Press. Boulder. 

Tsukamoto, G.K. 2003. Nevada’s Pronghorn Antelope Ecology, Management and Conservation. Bulletin 13. 

Revised by G. Tanner, K. Beckstrand, L. Gilbertson, C. Mortimore, and J. Himes. NDOW, Reno. 

Available at URL: 

http://www.ndow.org/uploadedFiles/ndoworg/Content/public_documents/Wildlife_Education/Publications

/pronghorn.pdf. 

Tsukamoto, G.K. 2006. Management Plan for Mule Deer. NDOW, Reno. 

Tumbusch, M.L., and R.W. Plume. 2006. Hydrogeologic Framework and Ground Water in Basin-Fill Deposits of 

the Diamond Valley Flow System, Central Nevada. U.S. Geological Survey Scientific Investigations 

Report 2006-5249. Prepared in Cooperation with Eureka, Lander, and Nye Counties, Nevada, and the 

State of Nevada Department of Conservation and Natural Resources, Division of Water Resources, Carson 

City. 

U.S. Army Corps of Engineers. 1987. Corps of Engineers Wetlands Delineation Manual. Wetlands Research 

Program Technical Report Y-87-1. Environmental Laboratory, Washington, D.C. Available at URL: 

http://www.wetlands.com/pdf/wdm0225e.pdf. 

U.S. Bureau of Economic Analysis. 2012a. Series CA05N -- Personal Income and Earnings by Industry. 

Washington, D.C. Available at URL: http://www.bea.gov/. 

U.S. Bureau of Economic Analysis. 2012b. Series CA45 – Farm Income and Expenses. Washington, D.C. 

Available at URL: http://www.bea.gov/. 

U.S. Bureau of Economic Analysis. 2012c. Regional Economic Accounts, Local Area Personal Income and 

Employment, 1969 to 2010. Washington, D.C. Available at URL: 

http://www.bea.gov/iTable.cfm?ReqID=70&step=1&isuri=1&acrdn=5. 

U.S. Bureau of Economic Analysis. 2012d. Series CA25 and CA25N – Total Full-time and Part-time Employment 

by Industry. Washington, D.C. Available at URL: http://www.bea.gov/. 

U.S. Census Bureau. 2002. 2002 Economic Census. Washington, D.C. Available at URL: 

http://www.census.gov/econ/census02/. 

U.S. Census Bureau. 2009. TIGER/Line Shapefiles, 2009, Nye and White Pine Counties, Nevada, Current All 

Lines. Washington, D.C. Available at URL: http://www.census.gov/geo/maps-data/data/tiger-line.html. 

Accessed on July 20, 2009. 

U.S. Census Bureau. 2010a. TIGER/Line Shapefiles, 2009, Elko County, Nevada, Current All Lines. Washington, 

D.C. Available at URL: http://www.census.gov/geo/maps-data/data/tiger-line.html. 

U.S. Census Bureau. 2010b. TIGER/Line Shapefiles, 2010, Eureka and Lander Counties, Nevada, Current All 

Lines. Washington, D.C. Available at URL: http://www.census.gov/geo/maps-data/data/tiger-line.html. 
REFERENCES

3 Bars Project Final EIS 5-31 October 2016 

U.S. Census Bureau. 2011a. TIGER/Line Shapefiles, 2011, Churchill, Humboldt and Pershing Counties, Nevada, 

All Roads. Washington, D.C. Available at URL: http://www.census.gov/geo/maps-data/data/tigerline.html. 

U.S. Census Bureau. 2011b. 2010 Census, Summary File 1. Profile of General Population and Housing 

Characteristics, Table DP-1. Washington, D.C. Available at URL: 

http://factfinder2.census.gov/faces/nav/jsf/pages/searchresults.xhtml?ref=geo&refresh=t#none. 

U.S. Census Bureau. 2011c. Table 1. Annual Estimates of the Resident Population for Counties of Nevada: April 1, 

2000 to July 1, 2009. Washington, D.C. Available at URL: http://www.census.gov/popest/. 

U.S. Census Bureau. 2012. Small Area Income and Poverty Estimates, 2010. Washington, D.C. Available at URL: 

http://www.census.gov/did/www/saipe/data/interactive/. 

U.S. Department of Agriculture (USDA) Forest Service. 2000. Wildland Fire in Ecosystems Effects of Fire on 

Flora. General Technical Report RMRS-GTR-42-vol. 1 Rocky Mountain Research Station, Ogden, Utah. 

Available at URL: http://www.fs.fed.us/rm/pubs/rmrs_gtr042_1.pdf. 

USDA Forest Service, USDOI National Park Service, and USDOI USFWS. 2010. Federal Land Managers’ Air 

Quality Related Values Work Group (FLAG): Phase I Report - Revised (2010). Natural Resource Report 

NPS/NRPC/NRR—2010/232. Denver, Colorado. Available at URL: 

http://www.nature.nps.gov/air/pubs/pdf/flag/FLAG_2010.pdf. 

USDA National Agricultural Statistics Service. 2009. 2007 Census of Agriculture – Volume 1, Chapter 2: County 

Level Data. Washington, D.C. Available at URL: 

http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Chapter_2_County_Level/Nev

ada/.

USDA National Agricultural Statistics Service. 2012a. Cropscape Cropland Data Layer. Washington. D.C. 

Available at URL: http://nassgeodata.gmu.edu/CropScape/. 

USDA National Agricultural Statistics Service. 2012b. 2011 Nevada Agricultural Statistics Bulletin. Washington, 

D.C. Available at URL: 

http://www.nass.usda.gov/Statistics_by_State/Nevada/Publications/Annual_Statistical_Bulletin/2010-

11.pdf . 

USDA National Agricultural Statistics Service. 2013. Agricultural Prices, A Monthly and Annual Data and 

Publication Series, 1999 to 2013. Washington, D.C. Available at URL: 

http://usda.mannlib.cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1002. 

USDA Natural Resources Conservation Service. 1997. Introduction to Microbiotic Crusts. Soil Quality Institute, 

Grazing Lands and Technology Institute. Washington, D.C. Available at URL: 

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_053263.pdf. 

USDA Natural Resources Conservation Service. 1998. Nevada Annual Precipitation. Scale 1:1,190,000 Map. 

Prepared in Cooperation with Oregon State University. National Cartography and Geospatial Center, Fort 

Worth, Texas. Available at URL: http://www.wcc.nrcs.usda.gov/gis/precip.html. 
REFERENCES

3 Bars Project Final EIS 5-32 October 2016

USDA Natural Resources Conservation Service. 2000. NSSH Part 622. Ecological and Interpretive Groups, Prime 

Farmlands. Washington, D.C. Available at URL: 

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/home/?cid=nrcs142p2_054226. 

USDA Natural Resources Conservation Service. 2006. Land Resource Regions and Major Land Resource Areas of 

the United States, the Caribbean, and the Pacific Basin. U.S. Department of Agriculture Handbook 296. 

Washington, D.C. Available at URL: 

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_050898.pdf. 

USDA Natural Resources Conservation Service. 2012. Soil Survey Geographic (SSURGO) Database for Eureka 

County, Nevada. Available at URL: http://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm. 

USDA and USDOI. 1999. Sampling Vegetation Attributes Interagency Technical Reference. National Applied 

Resource Sciences Center, Denver, Colorado. Available at URL: 

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb1044175.pdf. 

U.S. Department of the Interior (USDOI). 2004. Interagency Burned Area Emergency Stabilization and 

Rehabilitation Department Manual Part 620, Chapter 3, Wildland Fire Management. Washington, D.C. 

Available at URL: http://elips.doi.gov/app_DM/act_getfiles.cfm?relnum+3610. 

USDOI. 2007a. Healthy Lands Initiative. Washington, D.C. Available at URL: 

http://www.blm.gov/wo/st/en/info/newsroom/2007/february/healthy_lands_intiative.html. 

USDOI. 2007b. Standards and Guidelines for Grazing and Wild Horses and Burros. Nevada Northeastern Great 

Basin Resource Advisory Council. Available at URL: 

http://www.blm.gov/nv/st/en/res/resource_advisory/northeastern_great/s_gs/wild_horses.html. 

USDOI. 2012. Safety Management Information System. January 1, 2009 through December 31, 2011. Denver, 

Colorado. 

USDOI Bureau of Land Management (BLM). 1976. Federal Land Policy and Management Act, as Amended. 

Denver, Colorado. Available at URL: http://www.blm.gov/flpma/FLPMA.pdf. 

USDOI BLM. 1984a. Shoshone-Eureka Resource Management Plan Environmental Impact Statement Final. Battle 

Mountain District, Battle Mountain, Nevada. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/nep

a/rmp.Par.42659.File.dat/Shoshone-Eureka%20RMP%20EIS%20Final.PDF. 

USDOI BLM. 1984b. Visual Resource Management. Manual Handbook Number 8400-1. Washington, D.C. 

Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_manua

l.Par.34032.File.dat/8400.pdf. 

USDOI BLM. 1986a. Shoshone-Eureka Resource Area Record of Decision. Battle Mountain District, Battle 

Mountain, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-33 October 2016 

USDOI BLM. 1986b. Manual H-8410-1. Visual Resource Inventory. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handb

ook.Par.31679.File.dat/H-8410.pdf. 

USDOI BLM. 1986c. Visual Resources Contrast Rating Handbook H-8431-1. Washington, D.C. Available at 

URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handb

ook.Par.79462.File.dat/8431.pdf. 

USDOI BLM. 1987a. Shoshone-Eureka Resource Management Plan Amendment Record of Decision. Battle 

Mountain District, Battle Mountain, Nevada. 

USDOI BLM. 1987b. Greenstripping Handbook. Boise, Idaho. 

USDOI BLM. 1991a. Record of Decision for Final Environmental Impact Statement Vegetation Treatment on 

BLM Lands in Thirteen Western States. BLM Wyoming State Office. Casper, Wyoming. 

USDOI BLM. 1991b. Forest Management (Public Domain). Manual Number 5000-1. Washington, D.C. 

USDOI BLM. 1991c. Final Environmental Impact Statement Vegetation Treatment on BLM Lands in Thirteen 

Western States. BLM Wyoming State Office. Casper, Wyoming. 

USDOI BLM. 1992a. BLM Manual 1737, Riparian-Wetland Area Management. Washington, D.C. 

USDOI BLM. 1992b. Integrated Weed Management. BLM Manual Section 9015. Washington, D.C. Available at 

URL: http://www.blm.gov/ca/st/en/prog/weeds/9015.html. 

USDOI BLM. 1996. Partners Against Weeds: An Action Plan for the Bureau of Land Management. Washington, 

D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Planning_and_Renewable_Resources/fish__wildlife_and

/weeds.Par.16974.File.dat/Partners%20Against%20Weeds%20-

%20An%20Action%20Plan%20for%20the%20BLM%20January%201996.pdf. 

USDOI BLM. 1997. Nevada Perennial Streams Spatial Dataset. Available at URL: 

http://sagemap.wr.usgs.gov/ftp/nevada/BLM/pernstream.htm. 

USDOI BLM. 1998a. Riparian Area Management, A User Guide to Assessing Proper Functioning Condition and 

Support Science for Lotic Areas. Technical Report 1737-15. U.S. Department of the Interior, BLM in 

Cooperation with the USDA Forest Service and Natural Resources Conservation Service. U.S. Department 

of the Interior, BLM National Business Center, Denver, Colorado. Available at URL: 

http://www.blm.gov/or/programs/nrst/files/Final%20TR%201737-15.pdf. 

USDOI BLM. 1998b. Pulling Together: National Strategy for Invasive Plant Management. Washington, D.C. 

Available at URL: http://www.blm.gov/weeds/PullingTogether/PullingTogether.htm. 

USDOI BLM. 1999a. Diamond Mountain Complex Evaluation. Battle Mountain District, Battle Mountain, 

Nevada. 
REFERENCES

3 Bars Project Final EIS 5-34 October 2016

USDOI BLM. 1999b. State Protocol Agreement between the USDOI BLM, Nevada, and the Nevada State Historic 

Preservation Office. On File at USDOI BLM, Nevada State Office, Reno. Available at URL: 

http://firearchaeology.com/firearchaeology/Arch_&_Fire_Management_files/Nevadaa_BLM_PA.pdf. 

USDOI BLM. 2000a. Public Rewards from Public Lands 2000 – Great Basin Restoration. Washington, D.C. 

Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Communications_Directorate/general_publications/rewa

rds/2000.Par.87227.File.dat/PublicRewards2000.pdf. 

USDOI BLM. 2000b. The Great Basin: Healing the Land. Washington, D.C. Available at URL: 

http://www.biodiversitylibrary.org/item/128754#page/1/mode/1up. 

USDOI BLM. 2001. Handbook H-4180-1. Rangeland Health Standards. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handb

ook.Par.61484.File.dat/h4180-1.pdf. 

.USDOI BLM. 2002. Resource Management Plan Amendment for Fire Management with Environmental 

Assessment NV61-EA97-071 Decision Record. Shoshone-Eureka Planning Area. Battle Mountain Field 

Office. Battle Mountain, Nevada. Available at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_programs/planning/resource_management.htm

l. 

USDOI BLM. 2003a. Decision Record and Finding of No Significant Impact Wildland Urban Fire Interface/Fire 

Defense Systems, Eureka and Diamond Valley, Nevada, Battle Mountain Field Office. Environmental 

Assessment NV-064-EA-02-64. Battle Mountain, Nevada. 

USDOI BLM. 2003b. Riparian Area Management, A User Guide to Assessing Proper Functioning Condition and 

Support Science for Lentic Areas. Technical Report 1737-16. U.S. Department of the Interior, BLM in 

Cooperation with the USDA Forest Service and Natural Resources Conservation Service. U.S. Department 

of the Interior, BLM National Business Center, Denver, Colorado. Available at URL: 

http://www.blm.gov/nstc/library/pdf/Final%20TR%201737-16%20Revision.pdf. 

USDOI BLM. 2003c. Pygmy Rabbit Surveys. Nevada State Office Instructional Memorandum No. NV-2003. 

Reno. 

USDOI BLM. 2004a. Battle Mountain District Fire Management Plan. Battle Mountain District, Battle Mountain, 

Nevada. 

USDOI BLM. 2004b. Fish Creek Complex Evaluation and Rangeland Health Assessment. Battle Mountain 

District, Battle Mountain, Nevada. 

USDOI BLM. 2005a. Decision Memorandum on Action and for Application of: Categorical Exclusion 1.12, Red 

Hills Hazardous Fuels Reduction Project. NV-064-2823-JM-JF28. Battle Mountain Field Office, Battle 

Mountain, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-35 October 2016 

USDOI BLM. 2005b. Decision Memorandum on Action and for Application of: Categorical Exclusion 1.12, 

Tonkin Hazardous Fuels Reduction Project. NV-064-2823-JQ-JF27. Battle Mountain Field Office, Battle 

Mountain, Nevada. 

USDOI BLM. 2005c. Handbook H-1601-1. Land Use Planning Handbook. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handb

ook.Par.38665.File.dat/h1601-1.pdf. 

USDOI BLM. 2006. Worksheet Documentation of Land Use Plan Conformance and NEPA Adequacy (DNA). 

Battle Mountain Field Office Document Number NV064-DNA06-016. Battle Mountain, Nevada. 

USDOI BLM. 2007a. Record of Decision Vegetation Treatments Using Herbicides on Bureau of Land 

Management Lands in 17 Western States Programmatic Environmental Impact Statement. 

Reno, Nevada. Available at URL: http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

USDOI BLM. 2007b. Final Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Impact Statement. Reno, Nevada. Available at URL: 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

USDOI BLM. 2007c. Final Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Report. Reno, Nevada. Available at URL: 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

USDOI BLM. 2007d. Environmental Assessment Roberts Mountain Wildlife Habitat Enhancement Project. 

NV062-EA07-075. Battle Mountain District, Battle Mountain, Nevada. 

USDOI BLM. 2007e. Instruction Memorandum No. 2008-009. Potential Fossil Yield Classification (PFYC) 

System for Paleontological Resources on Public Lands. Available at URL: 

http://www.blm.gov/wo/st/en/prog/more/CRM/paleontology/paleontological_regulations.html. 

USDOI BLM. 2007f. 2007 Monitoring Report Dry Creek Allotment. Battle Mountain District, Battle Mountain, 

Nevada. 

USDOI BLM. 2007g. Handbook H-1740-1, Renewable Resource Improvement and Treatment Guidelines and 

Procedures. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_manua

l.Par.95813.File.dat/MS-1740.pdf. 

USDOI BLM. 2007h. Roberts Mountain Complex Wild Horse Gather Environmental Assessment NV062-EA07-

120. Battle Mountain District, Battle Mountain, Nevada. May 2007. Available at URL: 

http://www.saveourwildhorse.com/PDF/Herd-Stat/NV-Stat/RobertsMt/RobertsMtPreEA5-07.pdf. 

USDOI BLM. 2008a. National Environmental Policy Act Handbook H-1790-1. National Environmental Policy Act 

Program. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handb

ook.Par.24487.File.dat/h1790-1.pdf. 
REFERENCES

3 Bars Project Final EIS 5-36 October 2016

USDOI BLM. 2008b. Integrated Vegetation Management H-1740-2 Release 1714. Washington, D.C. Available at 

URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handb

ook.Par.59510.File.dat/H-1740-2.pdf. 

USDOI BLM. 2008c. Manual 8270, Paleontological Resource Management. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Planning_and_Renewable_Resources/coop_agencies/pal

eontology_library.Par.75198.File.dat/ms8270.pdf. 

USDOI BLM. 2008d. Handbook H-8270-1 General Procedural Guidance for Paleontological Resource 

Management. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/ut/natural_resources/cultural/paleo/Paleontology_Document

s.Par.64888.File.dat/8270_hbk.pdf. 

USDOI BLM. 2008e. Instruction Memorandum 2009-011, Assessment and Mitigation of Potential Impacts to 

Paleontological Resources, December 10, 2008. Available at URL: 

http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/national_instruction/200

9/IM_2009-011.html. Accessed May 9, 2012. 

USDOI BLM. 2008f. 2008 Fluffy Flat Fire Wildfire Management and Livestock Closure Decision. Mount Lewis 

Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2008g. Cortez Hills Expansion Project Final Environmental Impact Statement. Document 

NVN067575, NV063-EIS06-011. U.S. Department of the Interior, BLM, Battle Mountain Field Office. 

Battle Mountain, Nevada. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/nepa/c

ortez_hills_seis.Par.43919.File.dat/Draft_SEIS-508.pdf. 

USDOI BLM. 2008h. Manual 6840 Special Status Species Management. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_manua

l.Par.43545.File.dat/6840.pdf. 

USDOI BLM. 2008i. Battle Mountain Field Office Division of Fire Management General Project Monitoring 

Template Red Hills Project. Battle Mountain Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2008j. Manual 1740, Renewable Resource Improvement and Treatments. Washington, D.C. 

Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_manua

l.Par.89904.File.dat/MS-1740.pdf. 

USDOI BLM. 2008k. Final Gather and Removal Report, January 24, 2008. Battle Mountain District, Battle 

Mountain. 

USDOI BLM. 2008l. Roberts Mountain HMA. Battle Mountain District, Battle Mountain, Nevada. Available at 

URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_programs/wild_horse_and_burro/battle_mount

ain_field/roberts_mountain_hma.html. 
REFERENCES

3 Bars Project Final EIS 5-37 October 2016 

USDOI BLM. 2008m. Instruction Memorandum No. 2008-203. Rights-of-way Management. Washington, D.C. 

Available at URL: 

http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/national_instruction/200

80/IM_2008-203.html. 

USDOI BLM. 2009a. Draft Assessment of Existing and Current Conditions for the Proposed 3 Bars Ecosystem and 

Landscape Restoration Project Environmental Impact Statement, Battle Mountain District, Mount Lewis 

Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2009b. Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field Office 

and Tonopah Field Office. Battle Mountain District, Battle Mountain, Nevada. 

USDOI BLM. 2009c. Supplemental Authorities to Consider in National Environmental Policy Act (NEPA) 

Documents. Instruction Memorandum No. NV-2009-030. Reno, Nevada. 

USDOI BLM. 2009d. Sulphur Springs Hazardous Fuels Reduction Project, Eureka County, Nevada, 

Environmental Assessment. NV064-EA-08-077. Battle Mountain District Office, Battle Mountain, 

Nevada. 

USDOI BLM. 2009e. Roberts Creek Allotment. Battle Mountain District, Battle Mountain, Nevada. 

USDOI BLM. 2009f. GIS Data of Strategic Areas of Ongoing Assessments. Mount Lewis Field Office, Battle 

Mountain, Nevada. 

USDOI BLM. 2009g. Callaghan Complex Gather Summary Report December 2008-January 2009. January 2009. 

Battle Mountain, Nevada. 

USDOI BLM. 2009h. Callaghan Complex Genetic Report of 2009. Battle Mountain District, Battle Mountain, 

Nevada. 

USDOI BLM. 2010a. Healthy Lands Initiative National. Available at URL: 

http://www.blm.gov/wo/st/en/info/newsroom/2008/April/HLI_09_Fact_Sheets.html. 

USDOI BLM. 2010b. Healthy Lands Initiative Oregon-Idaho-Nevada Shrub-Steppe Landscape. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Communications_Directorate/public_affairs/healthy_lan

ds_initiative.Par.18421.File.dat/HLI-OR_ID_NV_FY09.pdf. USDOI BLM. 2010c. Notice of Intent to 

Prepare an Environmental Impact Statement for the Proposed 3-Bars Ecosystem and Landscape 

Restoration Project, Eureka County, Nevada. Federal Register 75 (15):3916-3917. Washington, D.C. 

Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/fed

eral_register_notices.Par.83831.File.dat/noi_prepare_eis_3bars_project.pdf. 

USDOI BLM. 2010c. Notice of Intent to Prepare an Environmental Impact Statement for the Proposed 3-Bars 

Ecosystem and Landscape Restoration Project, Eureka County, Nevada. Federal Register 75 (15):3916-

3917. Washington, D.C. 

USDOI BLM. 2010d. Aspen (Populus tremuloides) Condition Report 3-Bars Project. Mount Lewis Field Office 

Bureau of Land Management. Battle Mountain, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-38 October 2016

USDOI BLM. 2010e. Elephant Head Fire. 2010a DRK0. Monitoring Summary FY2011 Closeout Summary. Battle 

Mountain District, Battle Mountain, Nevada. 

USDOI BLM. 2010f. Cain Fire DR0J. Monitoring Summary FY2010 Closeout Summary. Battle Mountain District, 

Battle, Mountain, Nevada. 

USDOI BLM. 2010g. Carico Fire DRC2. Monitoring Summary FY2010 Closeout Summary. Battle Mountain 

District, Battle, Mountain, Nevada. 

USDOI BLM. 2010h. Elephant Fire DB3B. Monitoring Summary FY2010 Closeout Summary. Battle Mountain 

District, Battle, Mountain, Nevada. 

USDOI BLM. 2010i. Paris Fire DR35. Monitoring Summary FY2010 Closeout Summary. Battle Mountain 

District, Battle, Mountain, Nevada. 

USDOI BLM. 2010j. Raven Fire DRJ6. Monitoring Summary FY2010 Closeout Summary. Battle Mountain 

District, Battle, Mountain, Nevada. 

USDOI BLM. 2010k. Cheatgrass Locations. Mount Lewis Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2010l. Wild Horses and Burros Management BLM Handbook H-4700-1. Washington, D.C. 

Available at URL: 

http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/blm_handbooks.html. 

USDOI BLM. 2010m. GIS data of Herd Management Areas. Nevada State Office, Reno. 

USDOI BLM. 2010n. Record of Decision, Callaghan and New Pass/Ravenswood Complex Wild Horse Gather 

Plan and Environmental Assessment DOI-BLM-NV-BOIO-2010-0087-EA. Battle Mountain, Nevada. 

Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/wild_horse___burro/

callaghan_npr_gather0/callaghan_npr_documents.Par.2024.File.dat/FINALCallaghan_New%20Pass%20

Gather%20FINALEA.pdf. 

USDOI BLM. 2011a. Greater Sage-grouse Interim Management Policies and Procedures. Instructional 

Memorandum 2012-043. Washington, D.C. Available at URL: 

http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/national_instruction/201

2/IM_2012-043.html. 

USDOI BLM. 2011b. BLM National Greater Sage-grouse Land Use Planning Strategy. Instructional Memorandum 

2012-044. Washington, D.C. Available at URL: 

http://www.blm.gov/wo/st/en/info/regulations/Instruction_Memos_and_Bulletins/national_instruction/201

2/IM_2012-044.html. 

USDOI BLM. 2011c. GIS Data of Treatment Polygons. Mount Lewis Field Office, Battle Mountain, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-39 October 2016 

USDOI BLM. 2011d. Authorized Geothermal Parcels (2010). Nevada State Office – Mineral Division, Reno, 

Nevada. Available at URL: 

http://www.blm.gov/nv/st/en/prog/more_programs/geographic_sciences/gis/geospatial_data.html. 

Accessed on March 20, 2011. 

USDOI BLM. 2011e. Fluffy Flat Fire. 2011. Monitoring Summary FY2011 Closeout Summary. Battle Mountain 

District, Battle Mountain, Nevada. 

USDOI BLM. 2011f. Callaghan Fire ECM8. Monitoring Summary FY2011 Closeout Summary. Battle Mountain 

District, Battle Mountain, Nevada. 

USDOI BLM. 2011g. Noxious Weeds, Invasive and Non-native Species. BLM Battle Mountain District Office 

RMP Planning Fact Sheet. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/rmp

.Par.33571.File.dat/WEEDS.pdf. 

USDOI BLM. 2012a. GIS data of Land Status/Ownership. Nevada State Office – Mapping Sciences, Reno. 

Available at URL: 

http://www.blm.gov/nv/st/en/prog/more_programs/geographic_sciences/gis/geospatial_data.html. 

Accessed on February 21, 2012. 

USDOI BLM. 2012b. Mount Hope Project Final Environmental Impact Statement. Battle Mountain District, 

Mount Lewis Field Office, Battle Mountain, Nevada. Available at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/national_environmental/mount_h

ope_project0.html. 

USDOI BLM. 2012c. GIS Data of Cumulative Effects Study Areas. Mount Lewis Field Office, Battle Mountain, 

Nevada. 

USDOI BLM. 2012d. GIS Data of Grazing Allotments. Nevada State Office – Mapping Sciences, Reno, Nevada. 

Available at URL: 

http://www.blm.gov/nv/st/en/prog/more_programs/geographic_sciences/gis/geospatial_data.html, 

Accessed on September 26, 2012. 

USDOI BLM. 2012e. GIS Data of Wildfires. Mount Lewis Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2012f. GIS Data Provided in Response to Data Request. Mount Lewis Field Office, Battle 

Mountain, Nevada.

USDOI BLM. 2012g. Spruce Mountain Restoration. Wells Field Office, Elko, Nevada. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/elko_field_office/information/nepa/eas/arch

ives/spruce_restoration0.Par.19106.File.dat/Spruce%20Mountain%20Restoration_reduced.pdf. 

USDOI BLM. 2012h. GIS Data of Key Management Areas. Mount Lewis Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2012i. GIS Data of Forest Products. Mount Lewis Field Office, Battle Mountain, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-40 October 2016

USDOI BLM. 2012j. Electronic Mail Communication from Steve Foree, Wildlife Ecologist, Mount Lewis Field 

Office, Battle Mountain, Nevada, to B. Read, AECOM, Fort Collins, Colorado, Regarding Perennial 

Streams and Lahontan Cutthroat Trout Habitat Within the 3-Bars Project Area, September 26, 2012. 

USDOI BLM. 2012k. GIS Data of Preliminary Greater Sage-grouse Habitat Categories on BLM and USFS 

Administered Lands in Nevada. Nevada State Office, Reno. Available at URL: 

http://www.blm.gov/nv/st/en/prog/more_programs/geographic_sciences/gis/geospatial_data.html. 

Accessed on March 3, 2012. 

USDOI BLM. 2012l. GIS Data of Battle Mountain Visual Resource Management Areas. State Office – Mapping 

Sciences, Reno, Nevada. 

USDOI BLM. 2012m. Recreation Management Information System. Mount Lewis Field Office, Battle Mountain, 

Nevada. 

USDOI BLM. 2012n. Management of National Scenic and Historic Trails and Trails under Study or 

Recommended as Suitable for Congressional Designation (Public). Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_manua

l.Par.1039.File.dat/M6280%20NSHT%20Management_Final_091212%20(2).pdf. 

USDOI BLM. 2012o. Battle Mountain District Office Recreation Website, Battle Mountain, Nevada. Available at 

URL: http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_programs/recreation.html. Access on 

April 9, 2012. 

USDOI BLM. 2012p. Manual 6330 Management of Wilderness Study Areas (Public). Release 9-935. Washington, 

D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_manua

l.Par.31915.File.dat/6330.pdf. 

USDOI BLM. 2012q. BLM Nevada Fire Summary, Resource Advisory Councils Annual Meeting, 1-26-2012. Available at 

URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/resources/racs/trirac/jan_2012.Par.93234.File.dat/Fire.pdfLas 

Vegas, Nevada. 

USDOI BLM. 2013a. Draft Biological Assessment for the 3 Bars Ecosystem and Landscape Restoration Project. 

Battle Mountain District Mount Lewis Field Office. Battle Mountain, Nevada. 

USDOI BLM. 2013b. Herd Management Area Cumulative Effects Study Areas. Mount Lewis Field Office, Battle 

Mountain, Nevada. 

USDOI BLM. 2013c. Nevada and Northeastern California Sub-regional Greater Sage-grouse Resource 

Management Plan Amendment/EIS. Reno, Nevada. Available at URL: https://www.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=31103. 

USDOI BLM. 2013d. GIS Data Irrigated Cropland Map. Mount Lewis Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2013e. GIS Data of Seed Harvest Areas. Mount Lewis Field Office, Battle Mountain, Nevada. 
REFERENCES

3 Bars Project Final EIS 5-41 October 2016 

USDOI BLM. 2013f. GIS Data Christmas Tree/Fuelwood Areas. Mount Lewis Field Office, Battle Mountain, 

Nevada. 

USDOI BLM. 2013g. GIS Data of Frazier Fire Seeding Areas. Mount Lewis Field Office, Battle Mountain, 

Nevada. 

USDOI BLM. 2013h. GIS Data of Proper Functioning Conditions. Mount Lewis Field Office, Battle Mountain, 

Nevada. 

USDOI BLM. 2013i. GIS Data of Range Utilization. Mount Lewis Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2013j. Draft Wildlife Survey Protocols BLM Nevada. Reno. 

USDOI BLM. 2013k. GIS Data of Range Improvements. Mount Lewis Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2013l. Land Use Authorizations. Mount Lewis Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2014. Final Biological Assessment for the 3 Bars Ecosystem and Landscape Restoration Project. 

Battle Mountain District Mount Lewis Field Office. Battle Mountain, Nevada. 

USDOI BLM 2015. Nevada and Northeastern California Greater Sage-Grouse Approved Resource Management 

Plan Amendment (ARMPA). September 2015. 

USDOI BLM and Colorado Wood Utilization and Marketing Program. 2008. Managing Pinyon-Juniper 

Ecosystems for Pine Nut Production. Available at URL: 

http://pinonnuts.org/PJE_mgmt_rpt_March_08.pdf. 

USDOI BLM and U.S. Geological Survey (USGS). 2001. Biological Soil Crusts Ecology and Management. 

Technical Reference 1730-2. Washington, D.C. Available at URL: 

http://www.blm.gov/nstc/library/pdf/CrustManual.pdf. 

USDOI National Park Service. 1999. Comprehensive Management and Use Plan Final Environmental Impact 

Statement for the California National Historic Trail and the Pony Express National Historic Trail. National 

Park Service Long Distance Trails Office, Salt Lake City, Utah. Available at URL: 

http://www.nps.gov/cali/parkmgmt/upload/CALI-CMP-SM-updated.pdf. 

USDOI National Park Service. 2004. Lincoln Highway, Special Resource Study Environmental Assessment. U.S. 

Department of the Interior. Washington, D.C. Available at URL: 

http://archive.org/stream/lincolnhighway00nati/lincolnhighway00nati_djvu.txt. 

USDOI National Park Service. 2012. Pony Express National Historic Trail Website. Available at URL: 

http://www.nps.gov/poex/index.htm. 

USDOI and USDA. 2001. Managing the Impact of Wildfires on Communities and the Environment (National Fire 

Plan). Washington, D.C. Available at URL: 

http://www.forestsandrangelands.gov/resources/reports/documents/2001/8-20-en.pdf. 
REFERENCES

3 Bars Project Final EIS 5-42 October 2016

USDOI and USDA. 2006a. A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the 

Environment 10-Year Comprehensive Strategy Implementation Plan. Washington, D.C. Available a URL: 

http://www.forestsandrangelands.gov/resources/plan/documents/10-yearstrategyfinal_dec2006.pdf. 

USDOI and USDA. 2006b. Protecting People and Sustaining Resources in Fire Adapted Ecosystems: A Cohesive 

Strategy. Washington, D.C. Available at URL: 

http://www.forestsandrangelands.gov/resources/documents/CFTS_03-03-06.pdf. 

USDOI U.S. Fish and Wildlife Service (USFWS). 2008. Greater Sage-Grouse Interim Status Update. MountainPrairie Region, Wyoming Ecological Services Office. Available at URL: 

www.sagebrushsea.org/sage_grouse_interim_report.htm. 

USDOI USFWS. 2010. Lahontan Cutthroat Trout (Oncorhynchus clarkii henshawi). Nevada Fish and Wildlife 

Office, Pacific Southwest Region. Available at URL: 

http://www.fws.gov/nevada/protected_species/fish/species/lct.html. 

USDOI USFWS. 2011. Endangered and Threatened Wildlife and Plants; Review of Native Species that are 

Candidates for Listing as Endangered or Threatened; Annual Notice of Findings on Resubmitted Petitions; 

Annual Description of Progress on Listing Actions. Federal Register 76(207):66370-66439. Washington, 

D.C. Available at URL: http://www.fws.gov/policy/library/2011/2011-27122.html. 

USDOI USFWS. 2012. 1977 to Present. Wetlands and Deepwater Habitats of the Coterminous United States. 

National Wetland Inventory Polygon Data. Washington, D.C. Available at URL: 

http://www.fws.gov/wetlands/Data/metadata/FWS_Wetlands.xml. 

USDOI U.S. Geological Survey (USGS). 2004. National Gap Analysis Program. Provisional Digital Land Cover 

Map for the Southwestern United States. Version 1.0. RS/GIS Laboratory, College of Natural Resources, 

Utah State University. 

USDOI USGS. 2012a. Mineral Resources Data System (MRDS) 2005. Reston, Virginia. Available at URL: 

http://tin.er.usgs.gov/mrds. 

USDOI USGS. 2012b. National Hydrography Dataset. Washington, D.C. Available at URL: http://nhd.usgs.gov/. 

USDOI USGS. 2012c. National Water Information System. 2012. Flow and Water Quality Data for Coils Creek, 

Henderson Creek, Pete Hanson Creek, Roberts Creek, and Tonkin Spring. Available at URL: 

http://waterdata.usgs.gov/nv/nwis and http://waterdata.usgs.gov/nwis/qwdata. 

USDOI USGS. 2012d. Reducing Population Growth Rates: Fertility Control in Wild Horse Mares. Available at 

URL: https://www.fort.usgs.gov/WildHorsePopulations/Contraception. 

U.S. Department of Labor Bureau of Labor Statistics. 2011a. Supplemental New Release Tables. Charts Presenting 

the 2010 Survey Results. Washington, D.C. Available at URL: http://www.bls.gov/iif/oshsum.htm. 

U.S. Department of Labor Bureau of Labor Statistics. 2011b. State Data for Nonfatal Occupational Injury and 

Illness Cases Requiring Days Away From Work for Musculoskeletal Disorders by Nature of Injury or 

Illness and Part of Body. Washington, D.C. Available at URL: http://www.bls.gov/iif/msd_state.htm. 
REFERENCES

3 Bars Project Final EIS 5-43 October 2016 

U.S. Department of Labor Bureau of Labor Statistics. 2012. Local Area Unemployment Statistics. Washington, 

D.C. Available at URL: http://www.bls.gov/lau/. 

U.S. Department of Transportation. 2010a. Traffic Safety Facts Eureka County, Nevada 2006-2010. Washington, 

D.C. Available at URL: http://www-nrd.nhtsa.dot.gov/departments/nrd30/ncsa/STSI/32_NV/2010/Counties/Nevada_Eureka%20County_2010.PDF. 

U.S. Department of Transportation. 2010b. National Highway Traffic Safety Administration. Traffic Safety Facts 

Nevada 2006-2010. Washington, D.C. Available at URL: http://www-nrd.nhtsa.dot.gov/departments/nrd30/ncsa/STSI/32_NV/2010/32_NV_2010.pdf. 

U.S. Environmental Protection Agency (USEPA). 1998. Final Guidance for Incorporating Environmental Justice 

Concerns in EPA’s NEPA Compliance Analyses. Washington, D.C. Available at URL: 

www.epa.gov/region1/ej/pdfs/ej_guidance_nepa_epa0498.pdf. 

USEPA. 2012a. Ecoregions. Washington, D.C. 

USEPA. 2012b. National Greenhouse Gas Emissions Data. Washington, D.C. Available at URL: 

http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html. 

USEPA. 2013. Update to An Inventory of Sources and Environmental Releases of Dioxin-Like Compounds in the 

United States for the Years 1987, 1995, and 2000. External Review Draft. National Center for 

Environmental Assessment, Office of Research and Development. Washington, D.C. Available at URL: 

http://cfpub.epa.gov/ncea/CFM/recordisplay.cfm?deid=235432#Download. 

University of Nevada Cooperative Extension. 2010. Nevada Noxious Weed Field Guide. Reno. Available at URL: 

http://www.unce.unr.edu/publications/files/nr/2010/sp1001.pdf. 

Utah Division of Wildlife Resources. 2003. The Pygmy Rabbit (Brachylagus idahoensis). Available at URL: 

http://wildlife.utah.gov/habitat/pdf/pygmy_rabbit.pdf. 

Vlasich, J.A. 1981. History. In Prehistory, Ethnohistory, and History of Eastern Nevada: A Cultural Resources 

Summary of the Elko and Ely Districts (S.R. James, Editor). USDOI BLM, Reno, Nevada, Cultural 

Resources Series No. 3. 

Wasley, T. 2004. Mule Deer Population Dynamics: Issues and Influences. Nevada Department of Wildlife, Reno. 

Available at URL: 

http://www.ndow.org/uploadedFiles/ndoworg/Content/public_documents/Wildlife_Education/Publications

/muledeer.pdf. 

Waters, T. 1995. Sediment in Streams. Sources, Biological Effects, and Control. American Fisheries Society 

Monograph 7. Available at URL: http://www.worldcat.org/title/sediment-in-streams-sources-biologicaleffects-and-control/oclc/33986956. 

Welch, P.H. 1979. Historic Overview of the Shoshone-Eureka Resource Area. U.S. Department of the Interior, 

BLM Technical Report No. 7, Battle Mountain District. Battle Mountain, Nevada. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/cultural/reports/technical_reports.Par.74473.File.dat/07_

Historic_%20Overview_ShoshoneEureka_Resource_Area.pdf. 
REFERENCES

Western Regional Climate Center. 2012. Precipitation Data for Eureka, NV, Station Number 262708. Available at 

http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?nv2708. 

Whittington, D.M., and G.T. Allen. 2008. Guidelines for Raptor Conservation in the Western United States. U.S. 

Fish and Wildlife Service Region 9, Division of Migratory Bird Management, Washington, D.C. 

Wiedinmyer, C., and M.D. Hurteau. 2010. Prescribed fire as a Means of Reducing Forest Carbon Emissions in the 

Western United States. Environmental Science and Technology, 44:1926-1932. 

 Wilcox, B.P., and D.W. Davenport. 1995. Juniper Encroachment: Potential Impacts to Soil Erosion and Morphology. 

Interior Columbia Basin Ecosystem Management Project, Portland, Oregon. Available at URL: 

www.icbemp.gov/science/wilcox.pdf. 

Wilde, J.D., and R.A. Soper. 1999. Baker Village: Draft Report of Excavations, 1990–1994. Brigham Young 

University Museum of Peoples and Cultures, Technical Series No. 99-12. Office of Public Archaeology, 

Brigham Young University, Provo, Utah. 

Wildlife Action Plan Team. 2006. Nevada Wildlife Action Plan. NDOW, Reno. Available at URL: 

http://www.ndow.org/wild/conservation/cwcs/. 

Wildlife Action Plan Team. 2012. Nevada Wildlife Action Plan Public Review Draft. Nevada Department of 

Wildlife. Reno, Nevada. Available at URL: http://www.ndow.org/wild/conservation/cwcs/. 

Wildlife Habitat Council. 2005. Riparian Areas of the Great Basin A Management Guide for Landowners. Wildlife 

Habitat Council, Silver Spring, Maryland. Available at URL: 

http://www.partnersinflight.org/pubs/riparian%20great%20basin.pdf. 

Wiens, J.A., and M.I. Dyer. 1975. Rangeland Avifaunas: Their Composition, Energetics, and Role in the 

Ecosystem. Pages 146-182 in Proceedings of the Symposium on Management of Forests and Range 

Habitats for Nongame Birds (D.R. Smith, ed.). General Technical Report WO-1. U.S. Department of 

Agriculture, Forest Service. Washington, D.C. 

Willis, M.J., and R.F. Miller. 1999. Importance of Western Juniper Communities to Small Mammals. Pages 210-

214 in Proceeding: Ecology and Management of Pinyon-Juniper Communities within the Interior West 

(S.B. Monsen, S. Richards, R.J. Tausch, R.F. Miller, and C. Goodrich, Compilers). RMRS-P-9. U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fort Collins, Colorado. 

Available at URL: http://www.fs.fed.us/rm/pubs/rmrs_p009/rmrs_p009_210_214.pdf. 

Willms, W., A.W. Bailey, A. McLean, and R. Tucker. 1981. The Effects of Fall Defoliation on the Utilization of 

Bluebunch Wheatgrass and its Influence on the Distribution of Deer in Spring. Journal of Range 

Management 34:16-18. Available at URL: 

http://www1.foragebeef.ca/$foragebeef/frgebeef.nsf/e5ae854df3230ce787256a3300724e1d/81a11a71de17

9d0e87256daa005f3d0b/$FILE/Rangedistribution.pdf. 

Wooley, D.E. 1999. The Waltis and Other Early Settlers of Eureka and Lander County, Nevada. Eureka, Nevada. 

Available at URL: http://www.rainesmarket.com/books.htm. 

3 Bars Project Final EIS 5-44 October 2016
REFERENCES

World Health Organization. 2014. Dioxins and their Effects on Human Health. Geneva, Switzerland. Available at 

URL: http://www.who.int/mediacentre/factsheets/fs225/en/. 

Wyman, S., D. Bailey, M. Borman, S. Cote, J. Eisner, W. Elmore, B. Leinard, S. Leonard, F. Reed, S. Swanson, L. 

Van Riper, T. Westfall, R. Wiley, and A. Winward. 2006. Riparian Area Management: Grazing 

Management Processes and Strategies for Riparian-wetland Areas. Technical Reference 1737-20. 

BLM/ST/ST-06/002+1737. U.S. Department of the Interior, BLM, National Science and Technology 

Center, Denver, Colorado. Available at URL: http://www.blm.gov/or/programs/nrst/files/final_tr_1737-

20.pdf. 

Wyoming Game and Fish Department. 2010. Protocols for Treating Sagebrush to Benefit Sage Grouse (11-29-

2010). Cheyenne, Wyoming. 

Young, B., E. Byers, K. Gravuer, K. Hall, G. Hammerson, A. Redder, K. Szabo, and J. Newmark. 2009. Using the 

NatureServe Climate Change Vulnerability Index: A Nevada Case Study. NatureServe, Arlington, 

Virginia. Available at URL: http://www.georgetownclimate.org/resources/using-the-natureserve-climatechange-vulnerability-index-a-nevada-case-study. 

Young, J.A., and J.D. Budy. 1979. Historic Use of Nevada’s Pinyon-Juniper Woodlands. Journal of Forest History 

23:113–121. 

Zeedyk, B., and V. Clothier. 2009. Let the Water Do the Work: Induced Meandering, an Evolving Method for 

Restoring Incised Channels. Quivira Coalition, Santa Fe, New Mexico. Available at URL: 

http://quiviracoalition.org/Detailed/1113.html. 

Zehner, R., M. Coolbaugh, and L. Shevenell. 2009. Preliminary Geothermal and Exploration Activity in Nevada. 

Nevada Bureau of Mines and Geology Open-File Report 09-10. Carson City. Available at URL: 

http://www.nbmg.unr.edu/dox/of0910_text.pdf. 

Zeier, C.D. 1985. Archaeological Data Recovery Associated with the Mt. Hope Project, Eureka County, Nevada. 

Nevada State Office Bureau of Land Management Cultural Resource Series No. 8. Reno, Nevada. 

Zeier, C.D. 1987. Historical Charcoal Production Near Eureka, Nevada: An Archeological Perspective. Historical 

Archeology 21:81-101 

Zouhar, K., J.K. Smith, S. Sutherland, and M.L. Brooks. 2008. Wildland Fire in Ecosystems: Fire and Nonnative 

Invasive Plants. General Technical Report RMRS-GTR-42-Volume 6. U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station, Ogden, Utah. Available at URL: 

http://www.fs.fed.us/rm/pubs/rmrs_gtr042_6.pdf. 

3 Bars Project Final EIS 5-45 October 2016 
REFERENCES

This page left blank intentionally.

3 Bars Project Final EIS 5-46 October 2016
CHAPTER 6 

GLOSSARY 
This page left blank intentionally.
GLOSSARY 

CHAPTER 6 

GLOSSARY 

A 

Active ingredient (a.i.): The chemical or biological component that kills or controls the target pest. 

Activity fuel: Fuels resulting from, or altered by, forestry practices such as timber harvest or thinning, as opposed to 

naturally created fuels. 

Adaptive management: A system of management practices based on clearly identified outcomes, and monitoring to 

determine if management actions are meeting outcomes, and if not, to facilitate management changes that will 

best ensure that outcomes are met or are re-evaluated. 

Additive effect: A situation in which the combined effects of exposure to two effects simultaneously is equal to the 

sum of the effects given alone. 

Adverse impact: Impact that causes harm or a negative result. 

Air pollutant: Any substance in the air that, if in high enough concentration, could harm humans, animals, 

vegetation, or material. Air pollutants may include almost any natural or artificial matter capable of being 

airborne, in the form of solid particles, liquid droplets, gases, or a combination of these. 

Air quality: The composition of air with respect to quantities of pollution therein; used most frequently in connection 

with “standards” of maximum acceptable pollutant concentrations.

Allotment (grazing): Area designated for the use of a certain number and kind of livestock for a prescribed period of 

time. 

Alternative: In an Environmental Impact Statement (EIS) or Environmental Assessment, one of a number of possible 

options for responding to the purpose and need for action. 

Ambient air: Any unconfined portion of the atmosphere; open air and surrounding air. Often used interchangeably 

with “outdoor air.” 

Animal Unit (AU): A standardized unit of measurement for range livestock that is equivalent to one mature cow of 

approximately 1,000 pounds and a calf as old as 6 months, one horse, five sheep, five goats, or four reindeer, all 

over 6 months of age. 

Animal Unit Month (AUM): The amount of feed or forage required by one animal unit grazing on a pasture for 1 

month. 

Appropriate Management Level (AML): An estimate of the number of wild horses and burros that public lands can 

support while maintaining a thriving natural ecological balance.

3 Bars Project Final EIS 6-1 October 2016 
GLOSSARY

3 Bars Project Final EIS 6-2 October 2016 

Aquatic: Growing, living in, frequenting, or taking place in water; used to indicate habitat, vegetation, or fish or 

wildlife in freshwater. 

Areas of Critical Environmental Concern: An area within public lands that requires special management attention 

to protect and prevent irreparable damage to important historic, cultural, or scenic values; fish and wildlife 

resources; other natural systems or processes; or to protect life or provide safety from natural hazards. 

Attainment area: A geographic area that is in compliance with the National Ambient Air Quality Standards 

(NAAQS). An area considered to have air quality as good as or better than the National Ambient Air Quality 

Standards as defined in the Clean Air Act. 

B 

Baffle: A baffle is a deflector of various configurations and materials, used to create lateral erosion of a streambank in 

order to widen the channel and alter the meander geometry. A baffle functions by concentrating stream velocity 

along the opposite bank while decreasing velocity along the adjacent bank. The result is accelerated erosion of the 

opposite bank with a commensurate increase in sediment deposition along the adjacent bank, causing point bar 

formation. As the point bar becomes colonized by riparian vegetation, it becomes increasingly resistant to erosion 

and more effective at deflecting flow towards the opposite bank. In order to achieve the desired meander pattern, 

baffles must be properly sized and spaced. 

Biological Assessment (BA): A document prepared by or under the direction of a federal agency that addresses 

federally listed and proposed species and designated and proposed critical habitat that may be present in the 

action area, and evaluates the potential effects of the action on such species and habitat. 

Biological diversity (biodiversity): The variety and variability among living organisms and the ecological 

complexes in which they occur. 

Biological soil crust: Thin crust of living organisms on or just below the soil surface and composed of lichens, 

mosses, algae, fungi, cyanobacteria, and bacteria. 

Broad scale: A large, regional area, such as a river basin; typically a multi-state area. 

Buffer strip/zone: A strip of vegetation that is left or managed to reduce the impact that a treatment or action on one 

area might have on another area. 

Bunchgrass: A grass having the characteristic growth habit of forming a bunch and lacking stolons or rhizomes. 

C 

Carrying capacity: The maximum population of a particular species that a particular region can support without 

hindering future generations’ ability to maintain the same population.
GLOSSARY 

3 Bars Project Final EIS 6-3 October 2016 

Class I area: Under the 1977 Clean Air Act amendments, all international parks, parks larger than 6,000 acres, and 

national wilderness areas larger than 5,000 acres that existed on August 7, 1977. This class provides the most 

protection to pristine lands by severely limiting the amount of additional air pollution that can be added to these 

areas. 

Classical biological control: The use of agents, including invertebrate parasites and predators (usually insects, fungi, 

mites, and nematodes) and plant pathogens, to reduce populations of invasive plants. 

Clean Air Act: Establishes a mandate to reduce emissions of specific pollutants via uniform federal standards. Under 

the Act, the U.S. Environmental Protection Agency (USEPA) is responsible for setting standards and approving 

state implementation plans to ensure that local agencies comply with the Act. The standards set by the USEPA 

include primary and secondary NAAQS for six pollutants, referred to as criteria pollutants, to protect public 

health and welfare. The criteria pollutants are sulfur dioxide, nitrogen dioxide, carbon monoxide, ozone, lead, and 

particulate matter. 

Climate: The composite or generally prevailing weather conditions of a region throughout the year, averaged over a 

series of years. 

Climate change: Climate change refers to a change in the state of the climate that can be identified (e.g., by using 

statistical tests) by changes in the mean and/or the variability of its properties, and that persists for an extended 

period, typically decades or longer. Climate change may be due to natural internal processes or external forcings, 

or to persistent anthropogenic changes in the composition of the atmosphere or in land use. The United Nations 

Framework Convention on Climate Change (UNFCCC), in its Article 1, defines climate change as: “a change of 

climate which is attributed directly or indirectly to human activity that alters the composition of the global 

atmosphere and which is in addition to natural climate variability observed over comparable time periods.” The 

UNFCCC thus makes a distinction between climate change attributable to human activities altering the 

atmospheric composition, and climate variability attributable to natural causes.

Coarse woody debris: Pieces of woody material derived from tree limbs, boles, and roots in various stages of decay, 

generally having a diameter of at least 3 inches and a length greater than 3 feet. 

Code of Federal Regulations (CFR): A codification of the general and permanent rules published in the Federal 

Register by the executive departments and agencies of the federal government.

Consultation: Exchange of information and interactive discussion; when the “C” in consultation is capitalized it 

refers to consultation mandated by statute or regulation that has prescribed parties, procedures, and timelines 

(e.g., Consultation under the National Environmental Policy Act or Section 7 of the Endangered Species Act). 

Cooperating Agency: Under Council on Environmental Quality regulations implementing the National 

Environmental Policy Act, tribal, state, and local governments, as well as other federal agencies, that cooperate 

with the lead agency (BLM for the 3 Bars Project) in the preparation of an EIS. Agencies that have been granted 

cooperating agency status for preparation of the 3 Bars Project EIS are the National Park Service, Nevada 

Department of Wildlife, and Eureka Board of County Commissioners. 

Council on Environmental Quality (CEQ): An advisory council to the President of the United States and

established by the National Environmental Policy Act (NEPA) of 1969. It reviews federal programs for their 

effect on the environment, conducts environmental studies, and advises the President on environmental matters. 
GLOSSARY

3 Bars Project Final EIS 6-4 October 2016 

Countervailing: A type of cumulative impact where negative effects are compensated for by beneficial effects. 

Cover: 1) Trees, shrubs, rocks, or other landscape features that allow an animal to partly or fully conceal itself, and 2) 

the area of ground covered by plants of one or more species, usually expressed as a percent of the ground surface. 

Criteria pollutants: Air pollutants designated by the USEPA as potentially harmful and for which ambient air quality 

standards have been set to protect the public health and welfare. The criteria pollutants are carbon monoxide, 

sulfur dioxide, particulate matter, nitrogen dioxide, ozone, hydrocarbons, and lead. 

Cultural resources: Nonrenewable evidence of human occupation or activity as seen in any area, site, building, 

structure, artifact, ruin, object, work of art, architecture, or natural feature. 

Culvert retrofit: A method of stabilization that consists of raising the effective invert elevation of an existing culvert 

without replacing the existing installed pipe. Streambed control can be achieved without the cost of a new culvert 

installation. 

Cumulative effects: Impacts on the environment that result from the incremental impact of an action when added to 

other past, present, and reasonably foreseeable future actions. Cumulative effects can result from individually 

minor, but collectively significant, actions taking place over a period of time. 

D 

Degradation: Physical or biological breakdown of a complex compound into simpler compounds. 

Densification: As it applies to the 3 Bars Project, an increase in the density of pinyon-juniper within woodland stands 

due to fire exclusion and livestock grazing. 

Density: The number of individuals per a given unit area. 

Desired plant community: One of the several plant communities that may occupy a site that has been identified 

through a management plan to best meet the plan’s objectives for the site.

Direct effects: Impacts on the environment that are caused by the action and occur at the same time and place. 

Dispersed recreation: Recreation that does not occur in a developed recreation site; for example, hunting or 

backpacking.

Dispersion: The act of distributing or separating into lower concentrations or less dense units. 

Disturbance: Refers to events that alter the structure, composition, or function of terrestrial or aquatic habitats. 

Natural disturbances include, among others, drought, floods, wind, fires, wildlife grazing, and insects and pathogens. Human-caused disturbances include actions such as timber harvest, livestock grazing, roads, and 

introduction of exotic species. 

Dominant: A group of plants that by their collective size, mass, or number exerts a primary influence onto other 

ecosystem components. 
GLOSSARY 

3 Bars Project Final EIS 6-5 October 2016 

Draft Environmental Impact Statement (Draft EIS): The draft statement of the environmental effects of a major 

federal action which is required under Section 102 of the NEPA, and released to the public and other agencies for 

comment and review. 

Drift: That part of a sprayed chemical that is moved by wind off a target site.

E 

Early successional stage: A successional stage, or collection of stages, that occurs immediately following a 

disturbance. 

Ecological site: A type of land with specific physical characteristics that differs from other types of land in its ability 

to produce distinctive kinds and amounts of vegetation and its response to management. 

Ecological site inventory: The basic inventory of present and potential vegetation on BLM rangelands. Ecological 

sites are differentiated on the basis of the kind, proportion, or amount of plant species. 

Ecological status: The present state of vegetation of a range site in relation to the potential natural community for that 

site. 

Ecoregion: Ecoregions are geographic areas that are delineated and defined by similar climatic conditions, 

geomorphology, and soils. Since these factors are relatively constant over time and strongly influence the ecology 

of vegetative communities, ecoregions may have similar potentials and responses to disturbance.

Ecosystem: Includes all the organisms of an area, their environment, and the linkages or interactions among all of 

them; all parts of an ecosystem are interrelated. The fundamental unit in ecology, containing both organisms and 

abiotic environments, each influencing the properties of the other and both necessary for the maintenance of life. 

Ecosystem health (forest health, rangeland health, aquatic system health): A condition where the parts and 

functions of an ecosystem are sustained over time and where the system’s capacity for self-repair is maintained, 

such that goals for uses, values, and services of the ecosystem are met. 

Edge effect: The influence of two communities on populations in their adjoining boundary zone or ecotone, affecting 

the composition and density of the populations in these bordering areas. 

Effect: Environmental change resulting from a proposed action. Direct effects are caused by the action and occur at 

the same time and place, while indirect effects are caused by the action but are later in time or further removed in 

distance, although still reasonably foreseeable. Indirect effects may include growth-inducing effects and other 

effects related to induced changes in the pattern of land use, population density, or growth rate, and related effects 

on air and water and other natural systems, including ecosystems. Effect and impact are synonymous as used in 

this document. 

Encroachment: Natural succession resulting in densification or interspace in-filling, causing an understory or 

previously dominant species to decline. 

Endangered species: Plant or animal species that are in danger of extinction throughout all or a significant part of 

their range. 
GLOSSARY

3 Bars Project Final EIS 6-6 October 2016 

Endemic species: Plants or animals that occur naturally in a certain region and whose distribution is relatively limited 

to a particular locality. 

Environment: 1) The physical conditions that exist within an area (e.g., the area that will be affected by a proposed 

project), including land, air, water, minerals, flora, fauna, ambient noise, and objects of historical or aesthetic 

significance; and 2) the sum of all external conditions that affect an organism or community to influence its 

development or existence. 

Environmental Assessment: A concise public document, for which a federal agency is responsible, that serves to: 1) 

briefly provide sufficient evidence and analysis for determining whether to prepare an EIS or a finding of no 

significant impact; 2) aid an agency’s compliance with the NEPA when no EIS is necessary; and 3) facilitate 

preparation of an EIS when one is necessary. 

Environmental Impact Statement (EIS): A required report for all federal actions that will lead to significant effects 

on the quality of the human environment. The report must be systematic and interdisciplinary, integrating the 

natural and social sciences as well as the design arts in planning and decision-making. The report must identify 1) 

the environmental impacts of the proposed action, 2) any adverse environmental effects which cannot be avoided 

should the proposal be implemented, 3) alternatives to the proposed action, 4) the relationship between short-term 

uses of human environment and the maintenance and enhancement of long-term productivity, and 5) any 

irreversible and irretrievable commitments of resources which would be involved in the proposed action should it 

be implemented. 

Erosion: The wearing away of the land surface by running water, wind, ice, gravity, or other geological activities. 

Erosion can be accelerated or intensified by human activities that reduce the stability of slopes or soils.

Exotic species: Includes species introduced into an area that may have adapted to the area and compete with resident 

native (indigenous) species. 

Expansion: Occurs when vegetation, such as pinyon-juniper, expands into new areas where it was not found 

historically. 

Evapotranspiration: Discharge of water from the earth’s surface into the atmosphere by transpiration by plants 

during growth and by evaporation from the soil, lakes, and streams. 

F 

°F: Degrees Fahrenheit. 

Fauna: The vertebrate and invertebrate animals of the area or region. 

Feasible: Capable of being accomplished in a successful manner within a reasonable period of time, taking into 

account economic, environmental, legal, social, and technological factors. 

Federal Land Policy and Management Act: Law mandating that the BLM manage lands under its jurisdiction for 

multiple uses. Establishes guidelines for its administration and provides for the management, protection, 

development, and enhancement of the public lands, among other provisions. 
GLOSSARY 

Fertility control: A tool to decrease fertility and which, when implemented, reduces (slows) population growth rates 

and extends the wild horse gather cycle. 

Final Environmental Impact Statement (Final EIS): A revision of the Draft EIS based on public and agency 

comments on the draft. 

Fire adapted: Plants that can withstand a certain frequency and intensity of fire. 

Fire break: A fire break is a gap in vegetation or other combustible material that acts as a barrier to slow or stop 

the progress of a wildfire. A firebreak may occur naturally where there is a lack of vegetation, such as a river, 

lake, or canyon. Firebreaks may also be man-made, and many of these also serve as roads, such as a logging 

road, four-wheel drive trail, secondary road, or a highway.

Fire dependent: An ecosystem evolving under periodic perturbations by fire and that consequently depends on 

periodic fires for normal ecosystem function. 

Fire intolerant: Species of plants that do not grow well with or die from the effects of too much fire. 

Fire management plan: A strategic plan that defines a program to manage wildland and prescribed fires and 

documents the Fire Management Program in the approved land use plan. The plan is supplemented by operational 

procedures such as preparedness plans, pre-planned dispatch plans, prescribed fire plans, and prevention plans. 

Fire regime: The patterns of fire occurrences, frequency, size, and severity, and sometimes vegetation and fire 

effects, in a given area or ecosystem. 

Fire return interval: The average time between fires in a given area. 

Fisheries habitat: Streams, lakes, and reservoirs that support fish populations. 

Fishery: The act, process, occupation, or season of taking an aquatic species. 

Floodplain: The area starting at or just above the bankfull elevation of the stream channel, where frequent flood 

events spill out of the channel. The floodplain is inundated relatively frequently, such as once every 1 to 3 years. 

The floodplain is normally a relatively flat topographic feature adjacent to the stream channel that allows 

floodwaters to spread out and thus dissipate energy. 

Forage: Vegetation eaten by animals, especially grazing and browsing animals. 

Forbs: Broad-leafed pants; includes plants that commonly are called weeds or wildflowers. 

Forestland: Land where the potential natural plant community contains 10 percent or more tree canopy cover. 

Formulation: The commercial mixture of both active and inactive (inert) ingredients. 

Fossilization: The process of fossilizing a plant or animal that existed in some earlier age; the process of being turned 

to stone.

Fragmentation (habitat): The breaking-up of a habitat or cover type into smaller, disconnected parcels. 

3 Bars Project Final EIS 6-7 October 2016 
GLOSSARY

Fuel (fire): Dry, dead parts of trees, shrubs, and other vegetation that can burn readily. 

Fuel break: A fuel break is a strip or block of land on which the vegetation, debris, and detritus have been reduced 

and/or modified to control or diminish the risk of the spread of fire crossing the strip or block of land.

Functional-at-risk: Riparian or wetland areas are in functional condition, but an existing soil, water, or vegetation 

attribute makes them susceptible to degradation. 

G 

General Habitat Management Areas (GHMA): General Habitat Management Areas consist of habitat types of 

moderate importance to Greater sage-grouse, however, GHMA may also include areas of higher quality habitat 

that lacks bird survey and inventory data to support a priority habitat ranking. General Habitat Management 

Areas provides some benefit to Greater sage-grouse populations but, in many instances, lacks a key component, 

such as adequate shrub height or density or sufficient herbaceous understory, which prevents it from meeting its 

full ecological potential. General Habitat Management Areas also may include areas burned recently that have 

not sufficiently recovered or sagebrush communities with pinyon-juniper encroachment. The BLM and the Forest 

Service define GHMA as lands where some special management will apply to sustain Greater sage-grouse 

populations. General Habitat Management Areas have the potential to be reclassified as Priority Habitat 

Management Areas if restoration efforts enhance the habitat quality or ongoing field efforts document Greater 

sage-grouse use. 

Geographic Information System (GIS): An information processing technology to input, store, manipulate, analyze, 

and display data; a system of computer maps with corresponding site-specific information that can be combined 

electronically to provide reports and maps. 

Great Basin: The Great Basin is defined as the area wedged between the Sierra Nevada Mountains on the west and 

the Wasatch branch of the Rocky Mountains on the east, and the Snake River to the north. Its southern boundary 

cuts across the lower tip of Nevada and the southwestern corner of Utah, where land takes on the characteristics 

of the Mojave and Sonora Deserts. Within the region, three major plant communities grow: sagebrush, salt desert 

shrub, and pinyon and/or juniper woodlands. 

Groundwater: Subsurface water that is in the zone of saturation. The top surface of the groundwater is the “water 

table.” Source of water for wells, seeps, and springs.

H 

Habitat: The natural environment of a plant or animal, including all biotic, climatic, and soil conditions, or other 

environmental influences affecting living conditions. The place where an organism lives. 

Habitat fragmentation: The break-up of a large land area (such as forest) into smaller patches isolated by areas 

converted to a different land type. The opposite of connectivity. 

Hardened rock crossing: A form of low water crossing with utilizes rock to reduce the impact of vehicle and animal 

traffic on a stream crossing. 

3 Bars Project Final EIS 6-8 October 2016 
GLOSSARY 

Hazardous fuels: In the context of wildfire includes living and dead and decaying vegetation that form a special 

threat of ignition and resistance to control. 

Headcut: An erosional feature of some intermittent streams and perennial streams, also known as a knickpoint, where 

an abrupt vertical drop in a streambed occurs. The knickpoint, where a headcut begins, can be as small as an 

overly-steep riffle zone or as a large as a waterfall. When not flowing, the headcut will resemble a very short cliff 

or bluff. A small plunge pool may be present at the base of the headcut due to the high energy of falling water. As 

erosion of the knickpoint and the streambed continues, the headcut will migrate upstream. 

Herbaceous: Non-woody plants that include grasses, grass-like plants, and forbs. 

Herbicide: A chemical pesticide used to control, suppress, or kill vegetation, or severely interrupt normal growth 

processes. 

Herbivore: An animal that feeds on plants. 

Herd Area: Geographic area of the public lands identified as habitat used by wild horses and burros at the time the 

Wild and Free-roaming Horses and Burros Act was enacted (December 15, 1971). 

Herd Management Area (HMA): Areas designated for the long-term management of wild horses. Herd 

Management Areas are designated through the land use planning process for the maintenance of wild horse and 

burro herds. In delineating each HMA, the authorized officer shall consider the AML for the herd, the habitat 

requirements of the animals, the relationships with other uses of the public and adjacent private lands, and the 

constraints contained in 43 CFR 4710.4. 

Hydric soil: Soils that are saturated, flooded, or ponded long enough during the growing season to develop anaerobic 

conditions that favor the growth and regeneration of hydrophytic vegetation. Hydrophytic (wetland) vegetation is 

defined as any macrophyte that grows in water or on a substrate that is at least periodically deficient in oxygen as 

a result of excessive water.

Hydrologic Unit Code: A hierarchical coding system developed by the U.S. Geological Survey to identify 

geographic boundaries of watersheds of various sizes. 

Hydrophobic: Any macrophyte that grows in water or on a substrate that is at least periodically deficient in oxygen 

as a result of excessive water. 

I 

Indigenous: Living or occurring naturally in an area; native, endemic people, flora, or fauna. 

Indirect effects: Impacts that are caused by an action, but are later in time or farther removed in distance, although 

still reasonably foreseeable. 

Infilling: An increase in the density and competition as a result of encroachment by an invasive species, such as 

pinyon-juniper, into the native plant community, such as a sagebrush community, at a rate that exceeds the 

natural vegetation replacement rate. 

3 Bars Project Final EIS 6-9 October 2016 
GLOSSARY

Infiltration: The movement of water through soil pores and spaces. 

Interim Management Policy for Lands under Wilderness Review: Policy for managing public lands under 

wilderness review. Section 603(c) of the Federal Land Policy and Management Act states: “During the period of 

review of such areas and until Congress has determined otherwise, the Secretary shall continue to manage such 

lands according to his authority under this Act and other applicable laws in a manner so as not to impair the 

suitability of such areas for preservation as wilderness, subject, however, to the continuation of existing mining 

and grazing uses and mineral leasing in the manner and degree in which the same was being conducted on the 

date of approval of this Act: Provided, that, in managing the public lands the Secretary shall by regulation or 

otherwise take any action required to prevent unnecessary or undue degradation of the lands and their resources 

or to afford environmental protection.” Manual 6330 – Management of Wilderness Study Areas (WSAs), states 

the desire by the BLM not to approve any activity in WSAs which may impair their suitability for Wilderness 

designation via Congressional action. 

Intermittent stream: A stream that flows only at certain times of the year when it receives water from other streams 

or from surface sources such as melting snow. 

Invasive plants: Plants that 1) are not part of (if exotic), or are a minor component of (if native), the original plant 

community or communities; 2) have the potential to become a dominant or co-dominant species on the site if 

their future establishment and growth is not actively controlled by management interventions; or 3) are 

classified as exotic or noxious plants under state or federal law. Species that become dominant for only one to 

several years (e.g., short-term response to drought or wildfire) are not invasive plants. 

Invasive species: Per Executive Order 13112, an invasive species means an alien species whose introduction does or 

is likely to cause economic or environmental harm or harm to human health. 

Invertebrate: Small animals that lack a backbone or spinal column. Spiders, insects, and worms are examples of 

invertebrates. 

Irretrievable commitment: A term that applies to losses of production or commitment of renewable natural 

resources. For example, while an area is used as a ski area, some or all of the timber production there is 

“irretrievably” lost. If the ski area closes, timber production could resume; therefore, the loss of timber production 

during the time the area is devoted to skiing is irretrievable, but not irreversible, because it is possible for timber 

production to resume if the area is no longer used as a ski area. 

Irreversible commitment: A term that applies to non-renewable resources, such as minerals and archaeological sites. 

Losses of these resources cannot be reversed. Irreversible effects can also refer to the effects of actions on 

resources that can be renewed only after a very long period of time, such as the loss of soil productivity. 

Issue: A matter of controversy, dispute, or general concern over resource management activities or land uses. 

3 Bars Project Final EIS 6-10 October 2016 
GLOSSARY 

J 

K 

Key species: Forage species whose use serves an indicator to the degree of use of associated species, or those species 

which must, because of their importance, be considered in a management program. 

Knickpoint: Sharp break in the slope of the channel due to erosion; also see Headcut.

L 

Ladder fuel: Material on or near the ground that will carry fire from the ground to the crowns of trees; sagebrush, 

bitterbrush, and dead and down woody material. 

Land management: The intentional process of planning, organizing, programming, coordinating, directing, and 

controlling land use actions. 

Landscape: All the natural features such as grasslands, hills, forest, and water, which distinguish one part of the 

earth’s surface from another part; usually that portion of land that the eye can comprehend in a single view, 

including all of its natural characteristics. 

Land use allocation: The assignment of a management emphasis to particular land areas with the purpose of 

achieving the goals and objectives of some specified use(s) (e.g., campgrounds, wilderness, logging, and mining). 

Land Use Plan: Land Use Plans are prepared in accordance with established land use planning procedures in 43 CFR

§ 1600 and pursuant to Federal Land Policy and Management Act. They establish goals and objectives (desired 

outcomes), identify the management actions needed to achieve the desired outcomes, and identify the allowable 

uses of the public lands. 

Large woody debris: Pieces of wood that are of a large enough size to affect stream channel morphology. 

Leasable minerals: Minerals that are leased to individuals for exploration and development. The leasable minerals 

have been subdivided into two classes, fluid and solid. Fluid minerals include oil and gas, geothermal resources 

and associated by-products, and oil shale, native asphalt, oil impregnated sands and any other material in which 

oil is recoverable only by special treatment after the deposit is mined or quarried. Solid leasable minerals are 

specific minerals such as coal and phosphates.

Lek: A traditional place where males assemble during the mating season and engage in competitive displays that 

attract females. For purposes of the 3 Bars Project, lek refers to a place where male Greater sage-grouse 

congregate to attract female sage-grouse.

Lifeways: The manner and means by which a group of people lives; their way of life. Components include 

language(s), subsistence strategies, religion, economic structure, physical mannerisms, and shared attitudes. 

Litter: The uppermost layer of organic debris on the soil surface, which is essentially the freshly fallen or slightly 

decomposed vegetation material such as stems, leaves, twigs, and fruits. 

3 Bars Project Final EIS 6-11 October 2016 
GLOSSARY

3 Bars Project Final EIS 6-12 October 2016 

Locatable minerals: Locatable minerals include precious and base metallic ores and nonmetallic minerals such as 

bentonite, gypsum, chemical grade limestone, and chemical grade silica sand. Uncommon varieties of sand, 

gravel, building stone, pumice, rock, and cinders are also managed as locatable minerals. Locatable minerals are 

acquired by a company or individual under the General Mining Law of 1872, as amended and Surface Use and 

Occupancy Act of July 23, 1955. 

Log and fabric step fall: A structure used to control headcuts advancing through wet soil areas such as wet meadows 

and spring seeps. The erosive action can be stopped if a healthy mat of wet soil vegetation can become 

established to hold the lip of the headwall in place. 

Long-term: Generally refers to a period longer than 10 years. 

M 

Memorandum of Understanding (MOU): Usually documents an agreement reached amongst federal and/or state 

agencies. 

Microbiotic crust: See biological crust. 

Minimize: Apply best available technology, management practices, and scientific knowledge to reduce the 

magnitude, extent, and/or duration of impacts. 

Mitigation: Steps taken to: 1) avoid an impact altogether by not taking a certain action or parts of an action; 2) 

minimize an impact by limiting the degree or magnitude of the action and its implementation; 3) rectify an impact 

by repairing, rehabilitating, or restoring the affected environment; 4) reduce or eliminate an impact over time by 

preserving and maintaining operations during the life of the action, and, 5) compensate for an impact by replacing 

or providing substitute resources or environments (40 CFR § 1508.20).

Mitigation measures: Means taken to avoid, compensate for, rectify, or reduce the potential adverse impact of an 

action. 

Monitoring: The orderly collection, analysis, and interpretation of resource data to evaluate progress toward meeting 

management objectives. 

Multiple uses: A combination of balanced and diverse resource uses that takes into account the long-term needs of 

future generations for renewable and nonrenewable resources. These may include recreation, range, timber, 

minerals, watershed, wildlife, and fish, along with natural scenic, scientific, and historical values. 

N 

National Ambient Air Quality Standards (NAAQS): Standards set by the USEPA for the maximum levels of 

pollutants that can exist in the outdoor air without unacceptable effects on human health or the public welfare.

National Environmental Policy Act (NEPA): An act of Congress passed in 1969, declaring a national policy to 

encourage productive and enjoyable harmony between people and the environment, to promote efforts that will 

prevent or eliminate damage to the environment and the biosphere and stimulate the health and welfare of people, 
GLOSSARY 

3 Bars Project Final EIS 6-13 October 2016 

and to enrich the understanding of the ecological systems and natural resources important to the nation, among 

other purposes. 

National Landscape Conservation System: A single system that encompasses some of the BLM’s premier land 

designations. By putting these lands into an organized system, the BLM hopes to increase public awareness of 

these areas’ scientific, cultural, educational, ecological, and other values. 

Native species: Species that historically occurred or currently occur in a particular ecosystem and were not 

introduced. 

Natural community: An assemblage of organisms indigenous to an area that is characterized by distinct 

combinations of species occupying a common ecological zone and interacting with one another. 

Natural resources: Water, soil, plants and animals, nutrients, and other resources produced by the earth’s natural 

processes. 

No action alternative: The most likely condition to exist in the future if current management direction were to 

continue unchanged.

Non-native species: A species living outside its native distributional range.

Non-target: Any plant, animal, or organism that a method of treatment is not aimed at, but may accidentally be 

injured by the treatment.

Noxious weed: A plant species designated by federal or state law as generally possessing one or more of the 

following characteristics: aggressive and difficult to manage; parasitic; a carrier or host of serious insects or 

disease; or non-native, new, or not common to the U.S.

O 

Objective: A concise, time-specific statement of measurable planned results that respond to pre-established goals. An 

objective forms the basis for further planning to define the precise steps to be taken and the resources to be used 

to achieve identified goals. 

Other Habitat Management Areas (OHMA): Other Habitat Management Areas consist of lands identified as 

unmapped Greater sage-grouse habitat that are within the planning area and contain seasonal or connectivity 

habitats. 

Overgrazing: Continued heavy grazing which exceeds the recovery capacity of the plant community and creates a 

deteriorated rangeland. 

Overstory: The upper canopy layer. 

P 

Paleontological resources: A work of nature consisting of or containing evidence of extinct multicellular beings and 

includes those works or classes of works of nature designated by the regulations as paleontological resources. 
GLOSSARY

3 Bars Project Final EIS 6-14 October 2016 

Paleontology: A science dealing with the life of past geological periods as known from fossil remains. 

Particulate Matter (PM): A complex mixture consisting of varying combinations of dry solid fragments, solid cores 

with liquid coatings, and small droplets of liquid. These tiny particles vary greatly in shape, size and chemical 

composition, and can be made up of many different materials such as metals, soot, soil and dust. 

Particulates: Solid particles or liquid droplets suspended or carried in the air. 

Passive restoration: Allowing natural succession to occur in an ecosystem after removing a source of disturbance. 

Pathogen: An agent such as a fungus, virus, or bacterium that causes disease. 

Payments in lieu of taxes: Payments made to counties by the BLM to mitigate for losses to counties because public 

lands cannot be taxed. 

Per capita income: Total income divided by the total population. 

Perennial: A plant that lives for 2 or more years. 

Perennial stream: A stream or reach of a stream that flows continuously throughout the year and whose upper 

surface is generally lower than the water table in the region adjoining the stream. 

Permit: A revocable authorization to use public land for a specified purpose for up to 3 years. 

Persistence: Refers to the length of time a compound, once introduced into the environment, stays there. 

Petroglyph: An image recorded on stone, usually by prehistoric peoples, by means of carving, pecking, or otherwise 

incised on natural rock surfaces. 

pH: A measure of how acidic or alkaline (basic) a solution is on a scale of 0 to 14 with 0 being very acidic, 14 being 

very alkaline, and 7 being neutral. The abbreviation stands for the potential of hydrogen. 

Phase class: Phases of woodland succession for pinyon-juniper. Phase I, trees are present but shrubs and herbs are the 

dominant vegetation that influence ecological processes (hydrologic, nutrient, and energy cycles) on the site; 

Phase II, trees are co-dominant with shrubs and herbs and all three vegetation layers influence ecological 

processes on the site; and Phase III, trees are the dominant vegetation and the primary plant layer influencing 

ecological processes on the site. 

Phreatophytes: Plants (including, but not limited to, greasewood, rabbitbrush, and saltgrass in the 3 Bars Project 

area) whose root systems tap into the water table. 

Plant community: A vegetation complex, unique in its combination of plants, which occurs in particular locations 

under particular influences. A plant community is a reflection of integrated environmental influences on the site, 

such as soil, temperature, elevation, solar radiation, slope aspect, and precipitation. 

Playas: Flat land surfaces underlain by fine sediment or evaporate minerals deposited from a shallow lake on the floor 

of a topographic depression. 

PM2.5: Fine particulates that measure 2.5 microns in diameter or less. 
GLOSSARY 

3 Bars Project Final EIS 6-15 October 2016 

PM10: Particulate matter that measures 10 microns in diameter or less.

Porosity: The ratio of the volume of void space in a material (e.g., sedimentary rock or sediments) to the volume of 

its mass. 

Potential Natural Community: The plant community that will persist under pre-settlement disturbance regimes and 

climate. It is an expression of environmental factors such as topography, soil, and climate across an area where 

the cover type is a classification of the existing vegetation community. 

Predator: An organism that captures and feeds on parts or all of a living organism of another species. 

Preferred alternative: The alternative identified in an EIS that has been selected by the agency as the most 

acceptable resolution to the problems identified in the purpose and need. 

Priority Habitat Management Areas (PHMA): Priority Habitat Management Areas consist of essential, 

irreplaceable and important habitats for Greater sage-grouse. These areas include breeding habitat (lek sites and 

nesting habitat), brood-rearing habitat, winter range, and important movement corridors. Priority Habitat 

Management Areas primarily consist of sagebrush, but may also include riparian communities, perennial 

grasslands, agricultural land, and restored habitat, including recovering burned areas. The BLM and the Forest 

Service define PHMA as having the highest conservation value to maintaining sustainable Greater sage-grouse 

populations. 

Prescribed fire: A management ignited wildland fire that burns under specified conditions and in a predetermined 

area, and that produces the fire behavior and fire characteristics required to attain fire treatment and resource 

management objectives. An approved prescribed fire plan, and conformance with the NEPA, are required prior to 

ignition. 

Prescribed fire projects: Includes the BLM’s efforts to utilize fire as a critical natural process to maintain and restore 

ecosystems, rangeland, and forestlands, and to reduce the hazardous buildup of fuels that may threaten healthy 

lands and public safety. 

Prescribed grazing: The careful application of grazing or browsing prescriptions (i.e., specified grazing intensities, 

seasons, frequencies, livestock species, and degrees of selectivity) to achieve natural resource objectives. 

Livestock production is a secondary objective when using prescribed grazing as a natural resource management 

tool. 

Prevention of Significant Deterioration (PSD): A USEPA program in which state and/or federal permits are 

required in order to restrict emissions from new or modified sources in places where air quality already meets or 

exceeds primary and secondary ambient air quality standards. 

Productivity: The innate capacity of an environment to support plant and animal life over time. Plant productivity is 

the rate of plant production within a given period of time. Soil productivity is the capacity of a soil to produce 

plant growth, due to the soil’s chemical, physical, and biological properties.

Programmatic EIS: An area-wide EIS that provides an overview when a large-scale plan is being prepared for the 

management of federally administered lands on a regional or multi-regional basis. 
GLOSSARY

Proper Functioning Condition: Riparian and wetland areas achieve Proper Functioning Condition when adequate 

vegetation, landform, and/or large woody debris are present to dissipate stream energy associated with high water 

flows. This reduces erosion and improves water quality; filters sediment, captures bedload, and aids in floodplain 

development; improves floodwater retention and groundwater recharge; develops root masses that stabilize 

streambanks against cutting; develops diverse ponding and channel characteristics to provide habitat and water 

depth, duration, and temperature necessary for fish production, avian breeding habitat, and other uses; and 

support greater biodiversity. 

Proposed action: A proposal by a federal agency to authorize, recommend, or implement an action. 

Public lands: Any land and interest in land owned by the United States that are administered by the Secretary of the 

Interior through the BLM, without regard to how the United States acquired ownership, except for (1) lands 

located on the Outer Continental Shelf, and (2) lands held for the benefit of Native Americans, Aleuts, and 

Eskimos. Includes public domain and acquired lands. 

Public scoping: A process whereby the public is given the opportunity to provide oral or written comments about the 

influence of a project on an individual, the community, and/or the environment. 

Q 

Qualitative: Traits or characteristics that relate to quality and cannot be readily measured with numbers. 

Quantitative: Traits or characteristics that can be measured with numbers. 

R 

Radiometric dating: The use of the naturally occurring isotope of carbon-14 in radiometric dating to determine the 

age of organic materials. 

Rangeland: Land on which the native vegetation is predominantly grasses, grass-like plants, forbs, or shrubs; not 

forests. 

Rangeland health assessment: Assessment used to determine if rangeland conditions are achieving Land Use Plan 

objectives and Rangeland Health Standards and Guidelines. The Indicators of Rangeland Health—actual use, 

utilization, use pattern maps, ecological status, rangeland trend studies, and professional judgment—are used 

to evaluate conditions in accordance with BLM’s Handbook 4180, Rangeland Health Standards.

Raptor: Bird of prey; includes eagles, hawks, falcons, and owls. 

Receptor: An ecological entity exposed to a stressor. 

Recharge: Replenishment of water to an aquifer. 

Record of Decision (ROD): A document separate from, but associated with, an EIS, which states the decision, 

identifies alternatives (specifying which were environmentally preferable), and states whether all practicable 

means to avoid environmental harm from the alternative have been adopted, and if not, why not. 

3 Bars Project Final EIS 6-16 October 2016 
GLOSSARY 

Recovery plan: Identifies, justifies, and schedules the research and management actions necessary to reverse the 

decline of a species and ensure its long-term survival. 

Registered herbicide: All herbicides sold or distributed in the United States must be registered by the USEPA, based 

on scientific studies, showing that they can be used without posing unreasonable risks to people or the 

environment. 

Rehabilitation: The “repair” of an area using native and/or non-native plant species to obtain a stable plant 

community that will protect the area from erosion and invasion by noxious weeds. 

Resident fish: Fish that spend their entire life in freshwater. 

Resource Management Plan (RMP): Comprehensive land management planning document prepared by and for the 

BLM’s administered properties under requirements of the Federal Land Policy and Management Act. Bureau of 

Land Management lands in Alaska are exempted from this requirement. 

Restoration: Implementation of a set of actions that promotes plant community diversity and structure and that 

allows plant communities to be more resilient to disturbance over the long-term. 

Revegetation: Establishing or re-establishing desirable plants on areas where desirable plants are absent or of 

inadequate density, by management alone (natural revegetation), or by seeding or transplanting (artificial 

revegetation). 

Rights-of-way (ROW): A permit or an easement that authorizes the use of lands for certain specified purposes, such 

as the construction of forest access roads or a gas pipeline. 

Riparian: Occurring adjacent to streams and rivers and directly influenced by water. A riparian community is 

characterized by certain types of vegetation, soils, hydrology, and fauna and requires free or unbound water or 

conditions more moist than that normally found in the area. 

Riparian vegetation manipulation: The selective planting or removal of protective streambank vegetation to 

increase or decrease the rate of erosion or deposition of material within a stream channel. 

Risk: The likelihood that a given exposure to an item or substance that presents a certain hazard will produce illness 

or injury. 

Risk assessment: The process of gathering data and making assumptions to estimate short- and long-term harmful 

effects on human health or the environment from particular products or activities. 

Rock channel liner: A long, narrow one rock dam, much longer than it is wide, built in a recently incised gully 

bottom and used to armor the bed and/or reconnect bankfull flow with the recently abandoned floodplain. 

Runoff: That part of precipitation, as well as any other flow contributions, that appears in surface streams, either 

perennial or intermittent. 

3 Bars Project Final EIS 6-17 October 2016 
GLOSSARY

S 

Salable minerals: Salable minerals are all other common mineral materials that were not designated as leasable or 

locatable, and include sand, gravel, roadbed, ballast, and common clay. 

Salmonids: Fishes of the family Salmonidae, including salmon, trout, chars, whitefish, ciscoes, and grayling. 

Scoping: The process by which significant issues relating to a proposal are identified for environmental analysis. 

Scoping includes eliciting public comment on the proposal, evaluating concerns, and developing alternatives for 

consideration. 

Sedimentation: The process of forming or depositing sediment; letting solids settle out of wastewater by gravity 

during treatment. 

Sediments: Unweathered geologic materials generally laid down by or within waterbodies; the rocks, sand, mud, silt, 

and clay at the bottom and along the edge of lakes, streams, and oceans. 

Sensitive species: 1) Plant or animal species susceptible or vulnerable to activity impacts or habitat alterations, and 2) 

species that have appeared in the Federal Register as proposed for classification or are under consideration for 

official listing as endangered or threatened species. 

Seral: Refers to the stages that plant communities go through during succession. Developmental stages have 

characteristic structure and plant species composition. In a forest, for example, early seral forest refers to seedling 

or sapling growth stages; mid-seral refers to pole or medium saw timber growth stages; and mature or late seral 

forest refers to mature and old-growth stages. 

Short-term impacts: Impacts occurring during project construction and operation, and normally ceasing upon project 

closure and reclamation. The definition of short-term may vary for each resource. 

Significant: The description of an impact that exceeds a certain threshold level. Requires consideration of both 

context and intensity. The significance of an action must be analyzed in several contexts, such as society as a 

whole, and the affected region, interests, and locality. Intensity refers to the severity of impacts, which should be 

weighted along with the likelihood of its occurrence. 

Slope: The inclination of the land surface from the horizontal. Percentage of slope is the vertical distance divided by 

horizontal distance, and then multiplied by 100. Thus, a slope of 20 percent is a drop of 20 feet in 100 feet of 

horizontal distance. 

Snag: A standing dead tree, usually larger than 5 feet tall and 6 inches in diameter at breast height. 

Sociocultural: Of, relating to, or involving a combination of social and cultural factors. 

Socioeconomic: Pertaining to, or signifying the combination or interaction of social and economic factors. 

Soil adsorption: The tendency of a chemical to bind to soil particles. Adsorption occurs onto clay particles and onto 

both the solid and dissolved forms of organic matter.

3 Bars Project Final EIS 6-18 October 2016 
GLOSSARY 

Soil compaction: The compression of the soil profile from surface pressure, resulting in reduced air space, lower 

water holding capacity, and decreased plant root penetrability. 

Soil horizon: A layer of soil material approximately parallel to the land surface that differs from adjacent, genetically 

related, layers in physical, chemical, and biological properties. 

Soil texture: The relative proportions of sand, silt, and clay particles in a mass of soil. 

Solitude: The state of being alone or remote from habitations; a lonely, unfrequented, or secluded place. The intent is 

to evaluate the opportunity for solitude in comparison to habitations of people. 

Solubility: Tendency of a chemical to dissolve in water.

Special status species: Refers to federally listed threatened, endangered, proposed, or candidate species, and species 

managed as sensitive species by the BLM. 

Stand: A group of trees in a specific area that is sufficiently alike in composition, age, arrangement, and condition so 

as to be distinguishable from the forest in adjoining areas. 

Standard Operating Procedures (SOPs): Procedures that are followed by the BLM to ensure that risks to human 

health and the environment from treatment actions are kept to a minimum. 

Step-down: Refers to the process of applying broad-scale science findings and land use decisions to site-specific 

areas using a hierarchical approach of understanding current resource conditions, risks, and opportunities. 

Step pools and rock rundowns: A stabilization method that repairs a high energy headcut by laying back the headcut 

at a less steep gradient by building a series of step pools to gradually dissipate the energy of the falling water. 

Several structures of different types applied in sequence are often required to stabilize a headcut. 

Stream channel: The hollow bed where a natural stream of surface water flows or may flow; the deepest or central 

part of the bed, formed by the main current and covered more or less continuously by water. 

Subsistence: Customary and traditional uses of wild renewable resources (plants and animals) for food, shelter, fuel, 

clothing, tools, etc. 

Succession: A predictable process of changes in structure and composition of plant and animal communities over 

time. Conditions of the prior plant community or successional stage create conditions that are favorable for the 

establishment of the next stage. The different stages in succession are often referred to as seral stages. 

Suckering: The regeneration process for aspen by developing new shoots along the root system of the parent tree. 

The new shoots are called root suckers.

Sustainability: 1) meeting the needs of the present without compromising the abilities of future generations to meet 

their needs; emphasizing and maintaining the underlying ecological processes that ensure long-term productivity 

of goods, services, and values without impairing productivity of the land, and 2) in commodity production, refers 

to the yield of a natural resource that can be produced continually at a given intensity of management. 

Synergistic: A type of cumulative impact where total effect is greater than the sum of the effects taken independently. 

3 Bars Project Final EIS 6-19 October 2016 
GLOSSARY

T 

Target species: Plant species of competing vegetation that is controlled in favor of desired species. 

Terrestrial: Of or relating to the earth, soil, or land; inhabiting the earth or land. 

Threatened species: A plant or animal species likely to become an endangered species throughout all or a significant 

portion of its range within the foreseeable future. 

Threshold: A dose or exposure below which there is no apparent or measurable adverse effect. 

Tier: In an EIS, refers to incorporating by reference the analyses in an EIS or similar document of a broader scope. 

For example, this 3 Bars Ecosystem and Landscape Restoration Project EIS tiers to the Vegetation Treatments 

Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental 

Impact Statement.

Total suspended particles (TSP): A method of monitoring airborne particulate matter by total weight. 

Toxicity: A characteristic of a substance that makes it poisonous. 

Transpiration: Water loss from plants during photosynthesis. 

Trend: The direction of change in ecological status observed over time. Trend is described as toward or away from 

the Potential Natural Community, or as not apparent. 

Tribe: Term used to designate any Native American tribe, band, nation, or other organized group or community 

(including any Alaska Native village or regional or village corporation as defined in or established pursuant to the 

Alaska Native Claims Settlement Act), which is recognized as eligible for the special programs and services 

provided by the U.S. to Native Americans because of their status as Native Americans. 

U 

Understory: Plants that grow beneath the canopy of other plants. Usually refers to grasses, forbs, and low shrubs 

under a tree or shrub canopy. 

Undesirable plants: Species classified as undesirable, noxious, harmful, exotic, injurious, or poisonous under state or 

federal law, but not including species listed as endangered by the Endangered Species Act, or species indigenous 

to the planning area. 

Upland: The portion of the landscape above the valley floor or stream. 

Utilization: The proportion or degree of the current year’s forage production that is consumed or destroyed by 

animals (including insects). Utilization may refer either to a single plant species, a group of species, or to the 

vegetation as a whole. Utilization is synonymous with use. 

3 Bars Project Final EIS 6-20 October 2016 
GLOSSARY 

V 

Vane: A type of deflector that utilizes an upstream-point-barb to divert high velocity flow away from a cutbank or the 

outboard side of a meander bend. A vane can also be used to direct flow into the opposite bank initiating bank 

erosion and causing the channel to widen in that direction. 

Vertebrate: An animal with a backbone. Fish, amphibians, reptiles, birds, and mammals are vertebrates. 

Visual resource: The visible physical feature of a landscape. 

Visual resource inventory: Visual resource inventory is an inventory based on scenic quality, sensitivity level, and 

distance zone criteria and indicates the overall value of the landscape. 

Visual Resource Management System: The Visual Resource Management (VRM) System is used by the BLM to 

manage visual resources on public land. Visual Resource Management objectives are established in RMPs in 

conformity with land use allocations. The BLM uses the VRM System to systematically identify and evaluate 

visual resource values and to determine the appropriate level of scenery management. The VRM process involves 

1) identifying scenic values, 2) establishing management objectives for those values through the land use 

planning process, and 3) designing and evaluating proposed activities to analyze effects and develop mitigation 

measures to meet the established VRM objectives. 

W 

Water quality: The interaction between various parameters that determines the usability or non-usability of water for 

on-site and downstream uses. Major parameters that affect water quality include: temperature, turbidity, 

suspended sediment, conductivity, dissolved oxygen, pH, specific ions, discharge, and fecal coliform. 

Watershed: The region draining into a river, river system, or body of water. 

Wattle: Erosion control wattles are used to control sediment, silt, and sand in stream channels during stream 

reconstruction. Wattles are frequently staked into the ground to help filter water and prevent pollution in water 

collection and transport areas. 

Weed: A plant considered undesirable and that interferes with management objectives for a given area at a given 

point in time. 

Weir: A structure of various material content which spans the bankfull width of a channel used to control the slope or 

grade of a stream. 

Wetlands: Those areas that are inundated or saturated by surface water or groundwater at a frequency and duration 

sufficient to support, and that under normal circumstance do support, a prevalence of vegetation typically adapted 

for life in saturated soil conditions. Wetlands include habitats such as swamps, marshes, and bogs. 

Wilderness: Land designated by Congress as a component of the National Wilderness Preservation System. For an 

area to be considered for Wilderness designation it must be roadless and possess the characteristics required by 

Section 2(c) of the Wilderness Act of 1964. These characteristics are: 1) naturalness - lands that are natural and 

3 Bars Project Final EIS 6-21 October 2016 
GLOSSARY

primarily affected by the forces of nature; 2) roadless and having at least 5,000 acres of contiguous public lands; 

and 3) outstanding opportunities for solitude or primitive and unconfined types of recreation. In addition, areas 

may contain “supplemental values,” consisting of ecological, geological, or other features of scientific, 

educational, scenic, or historical importance. 

Wilderness Study Area (WSA): Areas that have been designated by the BLM as having wilderness characteristics, 

thus making them worthy of consideration by Congress for wilderness designation. While Congress considers 

whether to designate a WSA as permanent Wilderness, the BLM manages the area to prevent impairment of its 

suitability for wilderness designation.

Wildfire: Unplanned human or naturally caused fires in wildlands. 

Wild Free-roaming Horses and Burros: All unbranded and unclaimed horses and burros that use public lands 

within ten contiguous Western States as all or part of their habitat, or that have been removed from these lands by 

the authorized officer, or have been born of wild horses or burros in authorized BLM facilities, but have not lost 

their status under the Wild and Free-roaming Horses and Burros Act (16 United States Code § 1332 [f]).

Wildland fire: Occurs on wildlands, regardless of ignition source, damages, or benefits, and include wildfire and 

prescribed fire. 

Wildland fire for resource benefit: A fire ignited by lightening, but allowed to burn within specified conditions of 

fuels, weather, and topography, to achieve specific objectives. 

Wildland Urban Interface (WUI): An area where structures and other human development intermingle with 

undeveloped wildlands or vegetative fuels. 

Woodland: A forest in which the trees are often small, characteristically short-bolded relative to their crown depth, 

and forming only an open canopy with the intervening area being occupied by lower vegetation, commonly grass. 

X 

Xeric: Very dry region or climate; tolerating or adapted to dry conditions. 

YZ

Zuni bowl: A headcut control structure which uses the principle of the natural cascade or step pool. Rather than spill 

water directly over a high falls, the cascade is used to build a series of smaller steps and pools thus keeping the 

water velocity within manageable range. 

3 Bars Project Final EIS 6-22 October 2016 
CHAPTER 7 

INDEX 
This page left blank intentionally.
INDEX 

CHAPTER 7 

INDEX 

Air Quality Consultation and Coordination 

Description: 3-37 Chapter 4 of the EIS is devoted to consultation and coEffects: 3-38 ordination; also see: 

Cumulative Effects: 3-46 Cooperating Agencies: 1-18 

Effects by Alternative: 3-39 Coordination and Education: 2-11 

Irreversible Effects: 3-48 Description: 1-20

Methodology for Assessing Effects: 3-37 Other Governmental Agencies: 1-20 

Mitigation: 3-48 

Scoping Comments and Other Issues Evaluated in Cultural Resources 

the Assessment: 3-38 Description: 3-435

Short- and Long-term Effects: 3-48 Effects: 3-449 

Significance of Effects: 3-48 Cumulative Effects: 3-455 

Unavoidable Effects: 3-47 Effects by Alternative: 3-450 

Regulatory Framework: 3-33 Irreversible Effects: 3-458 

Methodology for Assessing Effects: 3-435 

Alternatives Mitigation: 3-459 

Chapter 2 of the EIS is devoted to describing the Scoping Comments and Other Issues Evaluated in 

alternatives. the Assessment: 3-449 

Chapter3 is devoted to analyzing the effects of the No Short- and Long-term Effects: 3-457 

Action Alternative and Alternatives A, B, and C. Significance of Effects: 3-458 

Development of the Alternatives: 1-22 Unavoidable Effects: 3-457 

Description of the Alternatives: 2-3 Regulatory Framework: 3-435 

Alternative A: 2-3 Special Precautions: C-26 

Alternative B: 2-21 

Alternative C: 2-22 Cumulative Effects 

Alternative D - No Action Alternative: 2-22 Reasonably Foreseeable Future Actions: 3-8 

Alternatives Considered but Not Further Analyzed: 2- Irreversible Effects: 3-21

43 Resource Protection Measures Considered in the 

Summary of Impacts by Alternatives: 2-40 Cumulative Effects Analysis: 3-21 

Structure of the Cumulative Analysis: 3-5 

Biological Crust Temporal and Spatial Domain: 3-6 

See Soil Resources Unavoidable Adverse Effects: 3-21 

See also Chapter 3 for an assessment of cumulative 

Climate effects for 3 Bars Project cultural, natural, and social 

See Meteorology and Climate Change resources. 

3 Bars Project Final EIS 7-1 October 2016
INDEX

Decisions to be Made Scoping Comments and Other Issues Evaluated in 

Decisions to be made by Decision-maker: 1-9 the Assessment: 3-270 

Short- and Long-term Effects: 3-283 

Demographic Significance of Effects: 3-283 

See Social and Economic Values and Environmental Unavoidable Effects: 3-283 

Justice Regulatory Framework: 3-262 

Ecological Site Descriptions Fire 

See Chapter 3, Section 3.11.2.2, Vegetation See Wildland Fire and Fire Management 

Communities. 

Geology and Minerals 

Economic Environment Description: 3-50

See Social and Economic Values and Environmental Effects: 3-55 

Justice. Cumulative Effects: 3-56 

Effects by Alternative: 3-55 

Effects Irreversible Effects: 3-57 

Comparison of Alternatives: 2-37 Methodology for Assessing Effects: 3-50 

Cumulative Effects: 3-5 Mitigation: 3-58 

Direct and Indirect Effects: 3-4 Scoping Comments and Other Issues Evaluated in 

How the Effects of the Alternatives Were Evaluated: the Assessment: 3-55 

3-4 Short- and Long-term Effects: 3-57 

Chapter 3 is devoted to analyzing the direct, indirect, Significance of Effects: 3-58 

and cumulative effects of the No Action Alternative Unavoidable Effects: 3-57 

and Alternatives A, B, and C for 3 Bars Project Regulatory Framework: 3-49 

cultural, natural, and social resources. 

Human Health and Safety 

Environment Description: 3-504 

Chapter 3 of the EIS is devoted to a description of the Effects: 3-510 

natural, cultural, and social environment and analysis Cumulative Effects: 3-514 

of effects on the environment. Effects by Alternative: 3-510 

Irreversible Effects: 3-517 

Environmental Justice Methodology for Assessing Effects: 3-504 

See Social and Economic Values and Environmental Mitigation: 3-518 

Justice. Scoping Comments and Other Issues Evaluated in 

the Assessment: 3-510 

Fish and Other Aquatic Organisms Short- and Long-term Effects: 3-517 

Description: 3-262 Significance of Effects: 3-517 

Effects: 3-270 Unavoidable Effects: 3-516 

Cumulative Effects: 3-279 Regulatory Framework: 3-504 

Effects by Alternative: 3-271 

Irreversible Effects: 3-283 

Methodology for Assessing Effects: 3-262 

Mitigation: 3-284 

3 Bars Project Final EIS 7-2 October 2016
INDEX 

Impacts Cumulative Effects: 3-32 

See Alternatives and Effects Effects by Alternative: 3-31 

Scoping Comments and Other Issues Evaluated in 

Issues and Concerns the Assessment: 3-31 

Issues and Concerns: 1-22 Regulatory Framework: 3-27 

Issues Not Addressed in this EIS: 1-22 

Need for the Project: 1-7 Mitigation 

Purposes of the Project: 1-6 Description: 2-36 

See also Fish and other Aquatic Resources, Livestock 

Land Use and Access Grazing, Cultural Resources, and Native American 

Description: 3-391 Traditional/Cultural Values, Practices, and 

Effects: 3-405 Resources. 

Cumulative Effects: 3-407 

Effects by Alternative: 3-405 Native American Cultural Resources 

Irreversible Effects: 3-409 Consultation and Coordination: 4-3 

Methodology for Assessing Effects: 3-391 See Paleontological Resources, Cultural Resources, 

Mitigation: 3-409 and Native American Traditional/Cultural Values, 

Scoping Comments and Other Issues Evaluated in Practices, and Resources section in Chapter 3. 

the Assessment: 3-391 

Short- and Long-term Effects: 3-409 Native American Traditional/Cultural Values, 

Significance of Effects: 3-409 Practices, and Resources 

Unavoidable Effects: 3-409 Description: 3-461

Regulatory Framework: 3-389 Effects: 3-467 

Cumulative Effects: 3-475 

Livestock Grazing Effects by Alternative: 3-468 

Description: 3-346 Irreversible Effects: 3-479 

Effects: 3-352 Methodology for Assessing Effects: 3-461 

Cumulative Effects: 3-361 Mitigation: 3-480 

Effects by Alternative: 3-353 Scoping Comments and Other Issues Evaluated in 

Irreversible Effects: 3-365 the Assessment: 3-467 

Methodology for Assessing Effects: 3-346 Short- and Long-term Effects: 3-478 

Mitigation: 3-365 Significance of Effects: 3-479 

Scoping Comments and Other Issues Evaluated in Unavoidable Effects: 3-478 

the Assessment: 3-352 Regulatory Framework: 3-459 

Short- and Long-term Effects: 3-364 Special Precautions: C-26 

Significance of Effects: 3-365 See Paleontological Resources, Cultural Resources, 

Unavoidable Effects: 3-364 and Social and Economic Values and Environmental 

Regulatory Framework: 3-345 Justice. 

Meteorology and Climate Change

Climate Change: 3-29 

Description: 3-28

Effects: 3-31 

3 Bars Project Final EIS 7-3 October 2016
INDEX

Native and Non-invasive Vegetation Resources Scoping Comments and Other Issues Evaluated in 

Description: 3-148 the Assessment: 3-60 

Effects: 3-206 Short- and Long-term Effects: 3-64 

Cumulative Effects: 3-219 Significance of Effects: 3-64 

Effects by Alternative: 3-206 Unavoidable Effects: 3-64 

Irreversible Effects: 3-223 Regulatory Framework: 3-58 

Methodology for Assessing Effects: 3-148 Special Precautions: C-26 

Mitigation: 3-224 

Scoping Comments and Other Issues Evaluated in Prime Farmland 

the Assessment: 3-206 Description: 3-207 

Short- and Long-term Effects: 3-222 

Significance of Effects: 3-223 Public Involvement 

Unavoidable Effects: 3-222 Draft EIS Meetings: 1-26 and 4-2 

Regulatory Framework: 3-147 Public Comments on the Draft EIS – Appendix D 

Special Precautions: C-23 Public Involvement: 4-1 

Special Status Species: 3-202 Public Scoping Meetings: 1-21 and 4-2 

Noxious Weeds and Other Invasive and Non-native Purpose and Need for the Proposed Action 

Species Proposed Action: 1-5 

Description: 3-225 Purpose and Need: 1-6

Effects: 3-227 

Cumulative Effects: 3-235 Recreation 

Effects by Alternative: 3-230 Description: 3-410 

Irreversible Effects: 3-237 Effects: 3-414 

Methodology for Assessing Effects: 3-225 Cumulative Effects: 3-421 

Mitigation: 3-238 Effects by Alternative: 3-415 

Scoping Comments and Other Issues Evaluated in Irreversible Effects: 3-424 

the Assessment: 3-227 Methodology for Assessing Effects: 3-410 

Short- and Long-term Effects: 3-237 Mitigation: 3-425 

Significance of Effects: 3-237 Scoping Comments and Other Issues Evaluated in 

Unavoidable Effects: 3-237 the Assessment: 3-414 

Regulatory Framework: 3-224 Short- and Long-term Effects: 3-425 

Special Precautions: C-21 Significance of Effects: 3-424 

Unavoidable Effects: 3-424 

Paleontological Resources Regulatory Framework: 3-409 

Description: 3-60

Effects: 3-60 Riparian Management 

Cumulative Effects: 3-62 Description: 2-3, C-17 

Effects by Alternative: 3-61 

Irreversible Effects: 3-64 

Methodology for Assessing Effects: 3-60 

Mitigation: 3-65 

3 Bars Project Final EIS 7-4 October 2016
INDEX 

Scoping Regulatory Framework: 3-65 

Scope of Analysis: 1-12 

Public Involvement, Scoping, and Issues: 1-12 Special Precautions:

See Chapter 4, Consultation and Coordination. See Special Precautions provide for several resources 

in Appendix C. 

Smoke Management Policies and Regulations 

See Wildland Fire and Fire Management. Special Status Species 

Special Precautions: C-23 

Social and Economic Values and Environmental See Native and Non-invasive Vegetation, Fish and 

Justice Other Aquatic Resources, and Wildlife Resources in 

Description: 3-480 Appendix C. 

Effects: 3-494 

Cumulative Effects: 3-501 Species 

Effects by Alternative: 3-496 Common and Scientific Names of Species: 

Irreversible Effects: 3-504 Appendix A 

Methodology for Assessing Effects: 3-480 

Mitigation: 3-504 Statues, Regulations, and Policies 

Scoping Comments and Other Issues Evaluated in Laws, Regulations, and Policies that Influence 

the Assessment: 3-494 Restoration Treatments: 1-16 

Short- and Long-term Effects: 3-504 

Significance of Effects: 3-504 Standard Operating Procedures 

Unavoidable Effects: 3-503 See Appendix C.

Regulatory Framework: 3-480 

Threatened and Endangered Species 

Soil Compaction Consultation: Chapter 4 

See Soil Resources. See Special Status Species. 

Soil Erosion Visual Resources 

See Soil Resources. Description: 3-368

Effects: 3-375 

Soil Resources Cumulative Effects: 3-385 

Description: 3-66 Effects by Alternative: 3-375 

Effects: 3-81 Irreversible Effects: 3-389 

Cumulative Effects: 3-90 Methodology for Assessing Effects: 3-368 

Effects by Alternative: 3-82 Mitigation: 3-389 

Irreversible Effects: 3-93 Scoping Comments and Other Issues Evaluated in 

Methodology for Assessing Effects: 3-65 the Assessment: 3-375 

Mitigation: 3-94 Short- and Long-term Effects: 3-389 

Scoping Comments and Other Issues Evaluated in Significance of Effects: 3-389 

the Assessment: 3-81 Unavoidable Effects: 3-388 

Short- and Long-term Effects: 3-93 Regulatory Framework: 3-367 

Significance of Effects: 3-93 

Unavoidable Effects: 3-93 

3 Bars Project Final EIS 7-5 October 2016
INDEX

3 Bars Project Final EIS 7-6 October 2016

Water Resources Regulatory Framework: 3-327 

Description: 3-95

Effects: 3-112 Wilderness Study Areas and other Special Areas

Cumulative Effects: 3-124 Description: 3-426 

Effects by Alternative: 3-113 Effects: 3-428 

Irreversible Effects: 3-127 Cumulative Effects: 3-432 

Methodology for Assessing Effects: 3-95 Effects by Alternative: 3-428 

Mitigation: 3-129 Irreversible Effects: 3-434 

Scoping Comments and Other Issues Evaluated in Methodology for Assessing Effects: 3-426 

the Assessment: 3-112 Mitigation: 3-435 

Short- and Long-term Effects: 3-127 Scoping Comments and Other Issues Evaluated in 

Significance of Effects: 3-128 the Assessment: 3-428 

Unavoidable Effects: 3-127 Short- and Long-term Effects: 3-434 

Regulatory Framework: 3-94 Significance of Effects: 3-434 

Unavoidable Effects: 3-434 

Wetlands, Floodplains, and Riparian Zones Regulatory Framework: 3-425 

Description: 3-131 Special Precautions: C-28 

Effects: 3-133 

Cumulative Effects: 3-142 Wildland Fire and Fire Management 

Effects by Alternative: 3-135 Description: 3-240 

Irreversible Effects: 3-146 Effects: 3-252 

Methodology for Assessing Effects: 3-131 Cumulative Effects: 3-258 

Mitigation: 3-147 Effects by Alternative: 3-253 

Scoping Comments and Other Issues Evaluated in Irreversible Effects: 3-261 

the Assessment: 3-133 Methodology for Assessing Effects: 3-240 

Short- and Long-term Effects: 3-145 Mitigation: 3-262 

Significance of Effects: 3-146 Scoping Comments and Other Issues Evaluated in 

Unavoidable Effects: 3-145 the Assessment: 3-252 

Regulatory Framework: 3-129 Short- and Long-term Effects: 3-260 

Significance of Effects: 3-261 

Wild Horses Unavoidable Effects: 3-260 

Description: 3-327 Regulatory Framework: 3-238 

Effects: 3-333 

Cumulative Effects: 3-340 

Effects by Alternative: 3-334 

Irreversible Effects: 3-345 

Methodology for Assessing Effects: 3-327 

Mitigation: 3-345 

Scoping Comments and Other Issues Evaluated in 

the Assessment: 3-333 

Short- and Long-term Effects: 3-344 

Significance of Effects: 3-345 

Unavoidable Effects: 3-344 
INDEX 

3 Bars Project Final EIS 7-7 October 2016

Wildlife Resources 

Description: 3-287

Effects: 3-308 

Cumulative Effects: 3-321 

Effects by Alternative: 3-309 

Irreversible Effects: 3-326 

Methodology for Assessing Effects: 3-287 

Mitigation: 3-327 

Scoping Comments and Other Issues Evaluated in 

the Assessment: 3-308 

Short- and Long-term Effects: 3-325 

Significance of Effects: 3-325 

Unavoidable Effects: 3-325 

Regulatory Framework: 3-285 

Special Status Species: C-23

Woodland Products 

Description: 3-203
INDEX

3 Bars Project Final EIS 7-8 October 2016

This page left blank intentionally.
APPENDIX A 

COMMON AND SCIENTIFIC NAMES OF 

PLANTS AND ANIMALS GIVEN IN THE EIS 
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS October 2016 

This page left blank intentionally.
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS A-1 October 2016 

APPENDIX A 

COMMON AND SCIENTIFIC NAMES 

OF PLANTS AND ANIMALS 

GIVEN IN THE EIS 

This appendix contains a list of the common and scientific names of plant and animal species mentioned in the text 

of the EIS. 

Common Name Scientific Name 

Grasses and Grass-like Plants

PLANTS

Alkali Sacaton Sporobolus airoides

Barley, Foxtail Hordeum jubatum

Beargrass Xerophyllum tenaz

Bluegrass Poa spp.

Bluegrass, Alkali Poa juncifolia

Bluegrass, Kentucky Poa pretensis

Bluegrass, Nevada Poa nevadensis

Bluegrass, Sandberg’s Poa secunda

Brome, Downy Bromus tectorum

Brome, Mountain Bromus carinatus

Brome, Red Bromus rubens

Cheatgrass Bromus tectorum

Cordgrass, Alkali Spartina gracilis

Corn Zea mays

Fescue, Idaho Festuca idahoensis

Grama, Blue Bouteloua gracilis

Hairgrass, Tufted Deschampsia cespitosa

Muhly Grass Muhlenbergia capillaris

Muttongrass Poa fendleriana

Needle-and-thread Hesperostipa comata

Needlegrass, Columbia Achnatherum nelsonii

Needlegrass, Letterman’s Achnatherum lettermanii

Needlegrass, Thurber’s Achnatherum thurberianum

Needlegrass, Western Achnatherum occidentale

Quackgrass Elymus repens

Redtop Agrostis gigantea

Ricegrass, Indian Achnatherum hymenoides

Rush, Baltic Juncus balticus

Rush, Spike Eleocharis spp.

Saltgrass Distichlis spicata

Rye, Medusahead Taeniatherum caput-medusae

Saltgrass, Inland Distichlis spicata

Sedge, Clustered Field

Sedge, Nebraska 

Carex praegracilis

Carex nebrascensis
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS A-2 October 2016 

Common Name Scientific Name

PLANTS (Cont.)

Grasses and Grass-like Plants (Cont.)

Sedge, Water-loving Carex aquatilis

Squirreltail Elymus spp.

Squirreltail, Bottlebrush Elymus elymoides

Timothy, Alpine Phleum alpinum

Wheatgrass, Bluebunch Pseudoroegneria spicata

Wheatgrass, Crested Agropyron cristatum

Wheatgrass, Slender Elymus trachycaulus

Wheatgrass, Western Pascopyrum smithii

Wildrye, Basin Leymus cinereus

Forbs and Nonvascular Plants

Balsamroot Balsamorhiza spp.

Bassia, Fivehook Bassia hyssopifolia

Beet Beta vulgaris

Buckwheat, Beatley Eriogonum beatleyae

Bulrush Scirpus spp.

Cabbage Brassica oleracea

Camas Camassia spp.

Cat-tail Typha latifolia

Cinquefoil Potentilla spp.

Clover, Sierra Trifolium spp.

Cress, Hoary Cardaria draba

Eriogonum Eriogonum spp.

Forage Kochia Bassia prostrata

Goldenweed Haplopappus acaulis

Halogeton Halogeton glomeratus

Hawksbeard Crepis spp.

Henbane, Black Hyoscyamus niger

Houndstongue Cynoglossum officinale

Iris, Wild Iris missouriensis

Knapweed, Russian Acroptilon repens

Knapweed, Spotted Centaurea stoebe

Lahontan Beardtongue Penstemon palmeri

Least Phacellia Phacelia minutissima

Locoweed Oxytropis lambertii

Lupine Lupine spp.

Milkvetch, One-leaflet Torrey Astragalus calycosus

Mint Mentha spp.

Mustard, Elongated Brassica elongata

Mustard, Tansy Descurainia pinnata

Mustard, Wild Sinapis arvensis

Nevada Willowherb Epilobium nevadense

Onion Allium sp.

Paintbrush, Monte Neva Castilleja salsuginosa

Parsnip Allium cepa

Penstemon Penstemon spp.

Pepperweed, Perennial Lepidium latifolium

Phlox Phlox spp.
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS A-3 October 2016 

Common Name Scientific Name

Forbs and Nonvascular Plants (Cont.)

PLANTS (Cont.)

Pickleweed Salicornia spp.

Potato Solanum tuberosum

Puncturevine Tribulus terrestris

Ragwort, Tansy Senecio jacobaea

Reedgrass Calamagrostis spp.

Scarlet Globe-mallow Sphaeralcea coccinea

Seepweed Suaeda intermedia

Snakeweed Gutierrezia spp.

Snakeweed, Broom Gutierrezia sarothrae

Sorrel Rumex acetosa

Spikerush Elocharis spp.

Spurge, Leafy Euphorbia esula

St. Johnswort, Common Hypericum perforatum

Thistle, Bull Cirsium vulgare

Thistle, Canada Cirsium arvense

Thistle, Musk Carduus nutans

Thistle, Russian Salsola tragus

Thistle, Scotch Onopordum acanthium

Tomato Solanum lycopersicum

Turnip Brassica rapa

Watercress Nasturtium officinale

Whitetop, Tall Lepidium latifolium

Yarrow Achillea spp.

Shrubs and Trees

Aspen, Quaking Populus tremuloides

Birch, Water Betula occidentalis

Bitterbrush, Antelope Purshia tridentata

Bud Sagebrush Picrothamnus desertorum

Cactus, Cholla Opuntia spp.

Ceanothus Ceanothus spp.

Chokecherry Prunus virginiana

Cottonwood, Black Populus balsamifera var. trichocarpa

Cottonwood, Narrow-leaf Populus salicifolia

Creosote Larrea tridentata

Dogwood, Redosier Cornus sericea

Fir, White Abies concolor

Gooseberry Ribes spp.

Greasewood Sarcobatus spp.

Greasewood, Black Sarcobatus vermiculatus

Greenstem Paperflower Psilostrophe sparsiflora

Hemlock, Poison Conium maculatum

Hopsage Grayia spp.

Hopsage, Spiny Grayia spinosa

Horsebrush, Littleleaf Tetradymia glabrata

Iodine Bush Allenrolfea occidentalis

Juniper, Utah

Mahogany, Cur-leaf Mountain

Juniperus osteosperma

Cercocarpus ledifolius
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS A-4 October 2016 

Common Name Scientific Name

PLANTS (Cont.)

Shrubs and Trees (Cont.)

Manzanita Arctostaphylos spp.

Mormon Tea Ephedra spp.

Nevada Ephedra Ephedra nevadensis

Pine, Limber Pinus flexilis

Pinyon, Singleleaf Pinus monophylla

Poison hemlock Conium maculatum

Rabbitbrush Chrysothamnus spp. and Ericameria spp.

Rabbitbrush, Douglas’ Chrysothamnus viscidiflorus

Rabbitbrush, Rubber Chrysothamnus nauseosus

Rose, Wild Rosa spp.

Sage, Mediterranean Salvia aethiopis

Sagebrush Artemisia spp.

Sagebrush, Basin Big Artemesia tridentata tridentata

Sagebrush, Big Artemisia tridentata

Sagebrush, Black Artemisia nova

Sagebrush, Low Artemisia arbuscula

Sagebrush, Mountain big Artemesia tridentata ssp. vaseyana

Sagebrush, Wyoming big Artemesia tridentata spp. whyomingensis

Saltbush Atriplex spp.

Saltbush, Four-wing Atriplex canescens

Saltcedar (tamarisk) Tamarix ramosissima

Serviceberry Amelanchier utahensis

Shadscale Atriplex confertifolia

Snowberry Symphoricarpos albus

Willow Salix spp.

Willow, Arroyo Salix lasiolepis

Willow, Narrow-leaf Salix exigua

Willow, Rock Salix vestita

Winterfat Krascheninnikovia lanata

INVERTEBRATES

Beetle Coleoptera

Caddisfly Trichoptera

Fly Diptera

Leach Hirdinea

Mayfly Ephemeroptera

Snail Gastropoda

Springsnail Pyrgulopsis spp.

Stonefly Plecoptera

True Bug Hemiptera

FISH

Chub, Newark Valley Tui Siphateles bicolor newarkensis

Chub, Tui Gila spp.

Dace, Monitor Valley Speckled Rhinichthys osculus spp.

Dace, Speckled Rhinichthys osculus

Shiner, Redside Cyprinella lutrensis

Sucker, Mountain Catostomus platyrhynchos

Sucker, Tahoe Catostomus tahoensis
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS A-5 October 2016 

Common Name Scientific Name

FISH (Cont.)

Trout, Brook Salvelinus frontinalis

Trout, Brown Salmo trutta

Trout, Rainbow Oncorhynchus myliss

REPTILES AND AMPHIBIANS

Boa, Rubber Charina bottae

Coachwhip Masticophis flagellum

Frog, Columbia Spotted Rana luteiventris

Frog, Northern Leopard Lithobates pipiens

Lizard, Great Basin Collared Crotaphytus bicinctores

Lizard, Greater Short-horned Phrynosoma douglasii

Lizard, Long-nosed Leopard Gambelia wislizenii

Lizard, Sagebrush Sceloporus graciosus

Lizard, Western Fence Sceloporus occidentalis

Rattlesnake, Western Crotalus oreagnus

Snake, Long-nosed Rhinocheilus lecontei

Snake, Ringneck Diadophis punctatus

Toad, Great Basin Spadefoot Spea intermontana

Toad, Western Anaxyrus boreas

Whipsnake, Striped Masticophis taeniatus ornatus

BIRDS

American Bittern Botaurus lentiginosus

American Kestrel Falco sparverius

American Robin Turdus americanus

Black Rosy-finch Leucosticte atrata

Bluebird, Mountain Sialia currucoides

Bluebird, Western Sialia mexicana

Chickadee, Mountain Poecile gambeli

Cowbird, Brown-headed Moluthrus ater

Cuckoo, Yellow-billed Coccyzus americanus 

Dove, Mourning Zenaida macroura

Eagle, Bald Haliaeetus leucocephalus

Eagle, Golden Aquila chrysaetos

Falcon, Peregrine Falco peregrinus

Falcon, Prairie Falco mexicanus

Finch, Cassin’s Haemorhous cassinii

Flicker, Northern Colaptes auratus

Flycatcher, Gray Empidonax wrightii

Flycatcher, Willow Empidonax traillii

Gnatcatcher, Blue-gray Polioptila caerulea

Goose, Canada Branta canadensis

Goose, Snow Chen hyperborea

Grouse, Sharp-tailed Tympanachus phasianellus

Hawk, Cooper’s Accipiter cooperi 

Hawk, Ferruginous Buteo regalis

Hawk, Red-tailed Buteo jamaicensis

Hawk, Rough-legged Buteo lagopus

Hawk, Sharp-shinned Accipiter striatus

Hawk, Swainson’s Buteo swainsoni
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS A-6 October 2016 

Common Name Scientific Name

BIRDS (Cont.)

Heron, Black-crowned Night Nycticorax nycticorax

Heron, Great Blue Ardea herodias

Jay, Pinyon Gymnorhinus cyanocephalus

Jay, Western Scrub Apelocoma californica

Mallard Anas platyrhynchos

Meadowlark, Western Sturnella neglecta

Merlin Falco columbarius

Nighthawk, Common Chordeiles minor

Northern Coot Fulica americana

Northern Goshawk Accipiter gentilis

Northern Harrier Circus cyaneus

Nuthatch, Red-breasted Sitta canadensis

Owl, Barn Tyto alba

Owl, Flammulated Otus flammeolus

Owl, Great Horned Bubo virginianus

Owl, Long-eared Asio otus

Owl, Northern Pygmy Glaucidium gnoma

Owl, Northern Saw-whet Aegolius acadicus

Owl, Short-eared Asio flammeus

Owl, Western Burrowing Athene cunicularia

Partridge, Chukar Alectoris graeca

Quail, Mountain Oreortyx pictus

Raven, Common Corvus corax

Robin, American Turdus americanus

Sage-grouse, Greater Certrocercus urophasianus

Screech-owl, Western Otus asio

Shrike, Loggerhead Lanius ludovicianus

Solitaire, Townsend’s Myadestes townsendi

Sora Porzana carolina

Sparrow, Black-throated Amphispiza bilineata

Sparrow, Brewer’s Spizella breweri

Sparrow, Lark Chondestes grammacus

Sparrow, Sage Amphispiza belli

Sparrow, Vesper Pooecetes gramineus

Swan, Tundra Cygnus columbianus

Thrasher, Sage Oreoscoptes montanus

Titmouse, Juniper Baeolophus ridgwayi

Towhee, Green-tailed Pipilo chlorurus

Vulture, Turkey Cathartes aura

Warbler, Black-throated Gray Setophaga nigrescens

Warbler, Macgillvray’s Geothlypis tolmiei

Warbler, Orange-crowned Oreothlypis celata

Warbler, Virginia’s Vermivora virginiae

Waxwing, Cedar Bombycilla cedrorum

Woodpecker, Lewis’ Melanerpes lewis

Wren, Bewick’s Thryomanes bewickii
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

3 Bars Project Final EIS A-7 October 2016 

Common Name Scientific Name

MAMMALS

Antelope, Pronghorn Antilocapra americana

Bat, Little Brown Myotis lucifugus

Bat, Silver-haired Lasionycteris noctivagans

Bat, Townsend’s Big-eared Corynorhinus townsendii

Cottontail, Mountain Sylvilagus nuttallii

Cougar Puma concolor

Cow, Domestic Bos primigenius taurus

Coyote Canis latrans

Deer, Mule Odocoileus hemionus

Dog, Domestic Canis lupus familiaris

Horse Equus ferus caballus

Jackrabbit, Black-tailed Lepus californicus

Marmot, Hoary Marmota caligata

Mouse, Dark Kangaroo Microdipodops megacephalus

Mouse, Deer Peromyscus maniculatus

Mouse, Pinyon Peromyscus truei

Myotis, California Myotis californicus

Myotis, Fringed Myotis thysanodes

Myotis, Hoary Lasiurus cinereus

Myotis, Long-eared Myotis evotis

Myotis, Long-legged Myotis volans

Myotis, Western Small-footed Myotis ciliolabrum

Pipistrelle, Western Parastrellus hesperus

Porcupine Erethizon dorsatum

Rabbit, Pygmy Brachylagus idahoensis

Rat, Desert Kangaroo Dipodomys deserti

Rat, Ord’s Kangaroo Dipodomys ordii

Sheep, Bighorn Ovis canadensis

Sheep, Domestic Ovis aries

Shrew, Montane Sorex monticolus

Vole, Sagebrush Lemmiscus curtatus

Woodrat, Bushy-tailed Neotoma cinerea
COMMON AND SCIENTIFIC NAMES OF PLANTS AND ANIMALS 

This page left blank intentionally.

3 Bars Project Final EIS A-8 October 2016 
APPENDIX B 

PROGRAMMATIC AGREEMENT 

BETWEEN THE MOUNT LEWIS FIELD 

OFFICE OF THE BLM AND THE NEVADA 

STATE HISTORIC PRESERVATION 

OFFICER 
This page left blank intentionally.










APPENDIX C 

STANDARD OPERATING PROCEDURES
This page left blank intentionally.
STANDARD OPERATING PROCEDURES 

APPENDIX C 

STANDARD OPERATING PROCEDURES 

This section identifies Standard Operating Procedures (SOPs) that would be followed by the U.S. Department of the 

Interior (USDOI), Bureau of Land Management (BLM), under all alternatives to ensure that risks to human health and 

the environment from 3 Bars Project treatment actions would be kept to a minimum. Standard Operating Procedures 

are the management controls and performance standards required for streambank restoration and vegetation 

management treatments. These practices are intended to protect and enhance natural resources that could be affected 

by future treatments. 

C.1 General Standard Operating Procedures 

The BLM will comply with SOPs identified in the 17-States PEIS (USDOI BLM 2007a:2-22 to 2-38), and PER 

(USDOI BLM 2007b:2-31 to 2-44). These SOPs are provided in Table C-1. These SOPs have been identified to 

reduce adverse effects to environmental resources and human health from vegetation treatment activities based on 

guidance in BLM manuals and handbooks, regulations, and standard agency and industry practices. The SOPs listed 

in these documents are not all encompassing, but give an overview of practices that should be considered when 

designing and implementing a vegetation treatment project on public lands. In addition to these SOPs, the Mount 

Lewis Field Office has identified the following additional SOPs that would apply to the 3 Bars Project. 

C.2 Project Specific Standard Operating Procedures 

C.2.1 General 

1. Several site-specific projects would likely take place each year. Treatment locations and acreage to be treated 

within any one year would be dependent upon availability of funding. The BLM will coordinate with the 

affected livestock operator(s) to ensure that livestock are managed in a way that supports the accomplishment 

of treatment objectives. 

2. If multiple projects are proposed for an area, the BLM will try to complete all or several of the projects at 

similar times to reduce/avoid the occurrence of multiple disturbances in the area over an extended period of 

time. 

3. Treatments would occur during those times of the year when they are most likely to be successful. The BLM 

will make every effort to ensure through treatment design that restorative actions achieve site-specific 

objectives. 

4. The BLM will consult the LR2000 database to identify locations of existing authorizations and avoid 

disturbance of active mining claim markers prior to any treatment. The LR2000 is the BLM’s Legacy 

Rehost System that provides reports on BLM land and mineral use authorizations for oil, gas, and 

geothermal leasing, rights-of-way, coal and other mineral development, land and mineral title, mining 

claims, withdrawals, and classifications, on federal lands or on the federal mineral estate. 

3 Bars Project Final EIS C-1 October 2016 
Resourc

Guidance 

General 

Land Use 

TABLE C-1 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines

e Element 

Wildland Fire Mechanical Manual Biological 

Treatment Method

Documents BLM handbooks H-9211-1 (Fire 

Management Activity Planning 

Procedures) and H-9214-1 

(Prescribed Fire Management), and 

manuals 1112 (Safety), 9210 (Fire 

Management), 9211 (Fire 

Planning), 9214 (Prescribed Fire), 

and 9215 (Fire Training and 

Qualifications).

BLM Handbook H-5000-1 (Public 

Domain Forest Management), and 

manuals 1112 (Safety) and 9015 

(Integrated Weed Management).

BLM Domain Forest Management, 

and manuals 1112 (Safety), and 9015 

(Integrated Weed Management).

BLM manuals 1112 (Safety), 4100 

(Grazing Administration), 9014 

(Use of Biological Control Agents 

on Public Lands), and 9015 

(Integrated Weed Management),

and Handbook H-4400-1 

(Rangeland Health Standards).

Prepare a fire management plan.

Use trained personnel with adequate 

equipment.

Minimize frequent burning in arid 

environments.

Avoid burning herbicide-treated 

vegetation for at least 6 months.

Ensure that power cutting tools have 

approved spark arresters.

Ensure that crews have appropriate

fire-suppression tools during the fire 

season.

Wash vehicles and equipment before 

leaving weed infested areas to avoid 

infecting weed-free areas.

Keep equipment in good operating 

condition.

Ensure that crews have appropriate 

fire-suppression tools during fire 

season.

Minimize soil disturbance, which 

may encourage new weeds to 

develop.

Use only biological control agents 

that have been tested and approved 

to ensure they are host specific.

If using domestic animals, select 

sites with weeds that are palatable 

and non-toxic to the animals.

Manage the intensity and duration 

of containment by domestic animals 

to minimize overutilization of 

desirable plant species.

Utilize domestic animals to contain 

the target species in the treatment 

areas prior to weed seed set. Or if 

seed set has occurred, do not move 

the domestic animals to uninfested 

areas for a period of 7 days.

Carefully plan fires in the wildland 

urban interface to avoid or minimize 

loss of structures and property.

Collaborate 

with nearby 

agencies.

on project development 

landowners and 

Collaborate 

with nearby 

agencies.

on project development 

landowners and 

Notify nearby residents and 

landowners who could be affected 

by biological control agents.

Notify nearby residents and 

landowners who could be affected 

by smoke intrusions or other fire 

effects.

3 Bars Project Final EIS 

STANDARD OPERATING PROCEDURES

C-2 

October 2016 
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element 

Wildland Fire Mechanical 

Treatment Method 

Manual Biological 

Air Quality

See Manual 7000 

Water, and Air 

Management).

Have clear smoke management 

objectives. (Soil, 

Evaluate weather conditions, 

including wind speed and 

atmospheric stability, to predict 

effects of burn and impacts from 

smoke.

Burn when weather conditions favor 

rapid combustion and dispersion.

Burn under favorable moisture 

conditions.

Maintain equipment in optimal Maintain equipment in optimal 

working order. working order.

Conduct treatment activities during Conduct treatment activities during 

the wetter seasons. the wetter seasons.

Use heavy equipment under adequate Minimize vehicle speeds on unpaved 

soil moisture conditions to minimize roads.

soil erosion. Minimize dust impacts to the extent 

Minimize vehicle speeds on unpaved practicable.

roads.

Minimize dust impacts to the extent 

practicable.

Soil Resources

Use backfires, when applicable.

Burn small vegetation blocks, when 

appropriate.

Manage smoke to prevent air quality 

violations and minimize impacts to 

smoke-sensitive areas.

Coordinate with air pollution and 

fire control officials, and obtain all 

applicable smoke management 

permits, to ensure that burn plans 

comply with federal, state, and local 

regulations.

Assess the susceptibility of the 

treatment site to soil damage and 

Assess the susceptibility of the Assess the susceptibility of the 

treatment site to soil damage and treatment site to soil damage and 

Assess the susceptibility of the 

treatment site to soil damage and See Manual 7000 (Soil, erosion prior to treatment. erosion prior to treatment. erosion prior to treatment. erosion prior to treatment. Water, and Air 

Management). Prescribe broadcast and other burns 

that are consistent with soil 

Time treatments to avoid intense Time treatments to avoid intense 

rainstorms. rainstorms.

Minimize the use of domestic 

animals if removal of vegetation 

management activities. Time treatments to encourage rapid Time treatments to encourage rapid may cause significant soil erosion or 

Plan burns so as to minimize 

damage to soil resources.

recovery of vegetation. recovery of vegetation.

Further facilitate revegetation by Further facilitate revegetation by 

impact biological soil crusts.

Closely monitor the timing and 

Conduct burns when the moisture seeding or planting following seeding or planting following intensity of biological control with 

content of large fuels, surface treatment. treatment. domestic animals.

organic matter, and soil is high to 

limit the amount of heat penetration 

into lower soil surfaces and protect 

Use equipment that minimizes soil Minimize soil disturbance and 

disturbance and compaction. compaction.

Avoid grazing on wet soil to 

minimize compaction and shearing.

 STANDARD OPERATING PROCEDURE

S

C-3 October 2016 3 Bars Project Final EIS 
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element Treatment Method

Wildland Fire Mechanical Manual Biological

Soil Resources (cont.) surface organic matter.

Time treatments to encourage rapid 

recovery of vegetation.

Further facilitate revegetation by 

seeding or planting following 

treatment.

When appropriate, re-seed following 

burning to re-introduce species, or to 

convert a site to a less flammable 

plant association, rather than to 

specifically minimize erosion.

Minimize use of heavy equipment on 

slopes greater than 20 percent.

Conduct treatments when the ground 

is sufficiently dry to support heavy 

equipment.

Implement erosion control measures 

in areas where heavy equipment use 

occurs.

Minimize disturbances to biological 

soil crusts (e.g., by timing treatments 

when crusts are moist).

Reinoculate biological crust 

organisms to aid in their recovery, if 

possible. 

Conduct mechanical treatments along 

topographic contours to minimize 

runoff and erosion.

When appropriate, leave plant debris 

on site to retain moisture, supply 

nutrients, and reduce erosion.

Minimize disturbance to biological 

soil crusts (e.g., by timing treatments 

when crusts are moist).

Reinoculate biological crust 

organisms to aid in their recovery, if 

possible. 

When appropriate, leave plant debris 

on site to retain moisture, supply 

nutrients, and reduce erosion.

Prevent oil and gas spills to minimize 

damage to soil.

Water Resources

See Manual 7000 

Water, and Air 

Management).

(Soil, 

Prescribe burns that are consistent 

with water management objectives.

Plan burns to minimize negative 

impacts to water resources.

Minimize burning on hillslopes, or 

revegetate hillslopes shortly after 

burning.

Maintain a vegetated buffer between 

treatment areas and water bodies.

Minimize the removal of desirable 

vegetation near residential and 

domestic water sources.

Do not wash equipment or vehicles 

water bodies.

Maintain a minimum 25-foot wide 

vegetated buffer near streams and 

wetlands.

in 

Maintain a vegetated buffer near 

residential and domestic water 

sources.

Minimize the removal of desirable 

vegetation near residential and 

domestic water sources.

Minimize the removal of desirable 

vegetation near water bodies.

Minimize the use of domestic 

animals near residential or domestic 

water sources.

Minimize the use of domestic 

animals adjacent to water bodies if 

trampling or other activities are 

likely to cause soil erosion or 

impact water quality.

Wetlands 

Zones

and Riparian Following treatment, reseed or 

replant with native vegetation if 

native plant community cannot 

recover and occupy the site 

sufficiently.

the 

Manage riparian areas to provide 

adequate shade, sediment control, 

bank stability, and recruitment of 

wood into stream channels.

Following treatment, reseed or 

replant with native vegetation if the 

Following treatment, reseed or 

replant with native vegetation if 

native plant community cannot 

recover and occupy the site 

sufficiently.

the 

Manage animals to prevent 

overgrazing and minimize damage 

to wetlands.

Following treatment, reseed or 

replant with native vegetation if the 

native plant community cannot 

3 Bars Project Final EIS C-4 October 2016 

STANDARD OPERATING PROCEDURES
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element

Wildland

Wetlands and

Zones (cont.)

Riparian

Vegetation Keep fires as small as

meet the treatment obj See Handbook H-4410-

1 (National Range Conduct low intensity

Handbook), and minimize adverse imp

manuals 5000 (Forest vegetation.

Management) and 9015 Limit area cleared for

(Integrated Weed and clearings to reduce

Management). for weed infestations.

Where appropriate, us

treatments to prepare f

reintroduction of fire.

Identify and implemen

temporary domestic li

grazing and/or supple

restrictions needed to e

desirable vegetation re

following treatment.

Consider adjustments i

grazing permit, includi

application of state or

grazing administration

needed to maintain des

vegetation on the treat

Use plant stock or see

same seed zone and fr

similar elevation for re

Fish and Other Aquatic

Resources

See Manual 6500

(Wildlife and Fisheries

Management).

Maintain vegetated bu

fish-bearing streams to

soil erosion and soil ru

streams.

Minimize treatments n

bearing streams during

when fish are in sensiti

Treatment Method

Fire Mechanical Manual Biological

native plant

recover and

sufficiently.

community cannot

occupy the site

recover and

sufficiently.

occupy the site

possible to

ectives.

Power wash vehicles and equipment

to prevent the introduction and spread

Remove damaged trees and treat

woody residue to limit subsequent

Use domestic animals at the time

they are most likely to damage

burns to of weed and exotic species. mortality by bark beetles. invasive species.

acts to large Remove damaged trees and treat Identify and implement any Manage animals to prevent

woody residue to limit subsequent temporary domestic livestock grazing overgrazing and minimize damage

fire breaks mortality by bark beetles. and/or supplemental feeding to sensitive areas.

the potential Use plant stock or seed from the restrictions needed to enhance Identify and implement any

same seed zone and from sites of desirable vegetation recovery temporary domestic livestock

e mechanical

orests for the

similar elevation when conducting

revegetation activities.

following treatment.

Consider adjustments in the existing

grazing and/or supplemental

feeding restrictions needed to

Identify and implement any grazing permit, including the enhance desirable vegetation

t any

vestock

mental feeding

nhance

covery

temporary domestic livestock grazing

and/or supplemental feeding

restrictions needed to enhance

desirable vegetation recovery

following treatment.

application of state or regional

grazing administration guidelines, 

needed to maintain desirable

vegetation on the treatment site.

Use plant stock or seed from the

recovery following treatment.

Consider adjustments in the existing

grazing permit, including the

application of state or regional

grazing administration guidelines,

Consider adjustments in the existing same seed zone and from sites of needed to maintain desirable

n the existing

ng the

grazing permit, including the

application of state or regional

similar elevation when conducting

revegetation activities.

vegetation on the treatment site.

Use plant stock or seed from the

regional

guidelines,

grazing administration guidelines,

needed to maintain desirable

same seed zone and from sites of

similar elevation when conducting

irable vegetation on the treatment site. revegetation activities.

ment site.

d from the

om sites of

vegetation.

ffers near

minimize

noff into

ear fishperiods

ve life stages

Minimize treatments adjacent to fishbearing waters.

Do not wash vehicles in streams or

wetlands.

Refuel and service equipment at least

100 feet from water bodies to reduce

the chance for pollutants to enter

Refuel and service equipment at least

100 feet from water bodies to reduce

the chance for pollutants to enter

water.

Minimize removal of desirable

vegetation near fish-bearing streams

and wetlands.

Limit the access of domestic

animals to streams and other water 

bodies to minimize sediments

entering water and potential for

damage to fish habitat.

3 Bars Project Final EIS C-5 October 2016 

 STANDARD OPERATING PROCEDURES
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element Treatment Method

Wildland Fire Mechanical Manual Biological

Fish and Other Aquatic 

Resources (cont.)

(e.g., embryo). water.

Maintain an adequate buffer between 

treatment area and water body to 

reduce the potential for sediments 

and other pollutants to enter water 

body.

Wildlife Resources

See Manual 6500 

(Wildlife and Fisheries 

Management).

Minimize treatments during nesting 

and other important periods for birds 

and other wildlife.

Minimize treatments of important 

forage areas immediately prior to 

important use period(s), unless the 

burn is designed to stimulate forage 

growth.

Minimize treatments during nesting 

and other important periods for birds 

and other wildlife.

Retain wildlife trees and other unique 

habitat features where practical.

Minimize treatments during nesting 

and other important periods for birds 

and other wildlife.

Retain wildlife trees and other unique 

habitat features where practical.

Minimize the use of livestock 

grazing as a vegetation control 

measure where and/or when it could 

impact nesting and/or other 

important periods for birds and 

other wildlife.

Consider and minimize potential 

adverse impacts to wildlife habitat 

and minimize the use of livestock 

grazing as a vegetation control 

measure where it is likely to result 

in removal or physical damage to 

vegetation that provides a critical 

source of food or cover for wildlife.

Threatened and 

Endangered Species

See Manual 6840 

(Special Status Species) 

and Vegetation 

Treatments Using 

Herbicides on BLM 

Lands in 17 Western 

States Programmatic 

Biological Assessment.

Survey for special status species of 

concern if project may impact 

federally or state-listed species.

Minimize direct impacts to special 

status species of concern, unless 

studies show that species will 

benefit from fire.

All burn piles must be located at 

least 30 feet from Lahontan 

cutthroat trout occupied streams.

Minimize use of ground-disturbing 

equipment near special status species 

of concern.

Survey for species of concern if 

project could impact these species.

Use temporary roads when long-term 

access is not required.

Within riparian areas, do not use 

vehicle equipment off of established 

roads when possible.

Survey for special status species of 

concern if project could impact these 

species.

Survey for special status species 

concern if project could impact 

these species.

of 

Livestock

See Handbook 

1 (Grazing 

Management).

H-4120-

Notify permittees of proposed 

treatments and identify any needed 

livestock grazing, feeding, or 

slaughter restrictions.

Design treatments to take advantage 

of normal livestock grazing rest 

Notify permittees of proposed 

treatments and identify any needed 

livestock grazing, feeding, or 

slaughter restrictions.

Design treatments to take advantage 

of normal livestock grazing rest 

Notify permittees of proposed 

treatments and identify any needed 

livestock grazing, feeding, or 

slaughter restrictions.

Design treatments to take advantage 

of normal livestock grazing rest 

Notify permittees of proposed 

treatments and identify any needed 

livestock grazing, feeding, or 

slaughter restrictions.

Design treatments to take advantage 

of normal livestock grazing rest 

3 Bars Project Final EIS C-6 October 2016 

STANDARD OPERATING PROCEDURES
TABLE C-1 (Cont.) 

 STANDARD OPERATING PROCEDURE

S

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element Treatment Method

Wildland Fire Mechanical Manual Biological

Livestock (cont.) periods, when possible, and 

minimize impacts to livestock 

grazing permits.

Provide alternative forage sites for 

livestock, if possible.

Notify permittees of the project to 

improve coordination and avoid 

potential conflicts and safety 

concerns during implementation of 

the treatment.

periods, when possible, and minimize 

impacts to livestock grazing permits.

Provide alternative forage sites for 

livestock, if possible.

Notify permittees of the project to 

improve coordination and avoid 

potential conflicts and safety 

concerns during implementation of 

the treatment.

periods, when possible, and minimize 

impacts to livestock grazing permits.

Provide alternative forage sites for 

livestock, if possible.

Notify permittees of the project to 

improve coordination and avoid 

potential conflicts and safety 

concerns during implementation of 

the treatment.

periods, when possible, and 

minimize impacts to livestock 

grazing permits.

Provide alternative forage sites for 

livestock, if possible.

Notify permittees of the project to 

improve coordination and avoid 

potential conflicts and safety 

concerns during implementation of 

the treatment.

Wild Horses 

Burros

and Minimize potential hazards to 

horses and burros by ensuring 

adequate escape opportunities.

Avoid critical periods and minimize 

impacts to critical habitat that could 

adversely affect wild horse or burro 

populations.

Avoid critical periods and minimize 

impacts to habitat that could 

adversely affect wild horse or burro 

populations.

Avoid critical periods and minimize 

impacts to habitat that could 

adversely affect wild horse or burro 

populations.

Avoid critical periods and minimize 

impacts to habitat that could 

adversely affect wild horse or burro 

populations.

Paleontological and 

Cultural Resources

See handbooks H8120-1 (Guidelines for 

Conducting Tribal 

Consultation) and H8270-1 (General 

Procedural Guidance 

for Paleontological 

Resource 

Management), and 

manuals 8100 (The 

Foundations for 

Managing Cultural 

Resources), 8120 

(Tribal Consultation 

Under Cultural 

Resource Authorities), 

and 8270 

(Paleontological 

Follow standard procedures for 

compliance with Section 106 of the 

National Historic Preservation Act 

as implemented through the 

National Programmatic Agreement 

and state protocols or 36 Code of 

Federal Regulations (CFR) Part 800, 

including necessary consultations 

with the State Historic Preservation 

Officers and affected tribes.

Follow BLM Handbook H-8270-1 

to determine known Condition 1 and 

Condition 2 paleontological areas, 

or collect information through 

inventory to establish Condition 1 

and Condition 2 areas, determine 

resource types at risk from the 

proposed treatment, and develop 

appropriate measures to minimize or 

mitigate adverse impacts.

Follow standard procedures for 

compliance with Section 106 of the 

National Historic Preservation Act as 

implemented through the National 

Programmatic Agreement and state 

protocols or 36 CFR Part 800, 

including necessary consultations 

with the State Historic Preservation 

Officers and interested tribes.

Follow BLM Handbook H-8270-1 to 

determine known Condition 1 and 

Condition 2 paleontological areas, or 

collect information through inventory 

to establish Condition 1 and 

Condition 2 areas, determine resource 

types at risk from the proposed 

treatment, and develop appropriate 

measures to minimize or mitigate 

adverse impacts.

Identify cultural resource types at risk 

Follow standard procedures for 

compliance with Section 106 of the 

National Historic Preservation Act as 

implemented through the National 

Programmatic Agreement and state 

protocols or 36 CFR Part 800, 

including necessary consultations 

with the State Historic Preservation 

Officers and interested tribes.

Follow BLM Handbook H-8270-1 to 

determine known Condition 1 and 

Condition 2 paleontological areas, or 

collect information through inventory 

to establish Condition 1 and 

Condition 2 areas, determine resource 

types at risk from the proposed 

treatment, and develop appropriate 

measures to minimize or mitigate 

adverse impacts.

Identify cultural resource types at risk 

Follow standard procedures for 

compliance with Section 106 of the 

National Historic Preservation Act 

as implemented through the 

National Programmatic Agreement 

and state protocols or 36 CFR Part 

800, including necessary 

consultations with the State Historic 

Preservation Officers and interested 

tribes.

Follow BLM Handbook H-8270-1 

to determine known Condition 1 

and Condition 2 paleontological 

areas, or collect information through 

inventory to establish Condition 1 

and Condition 2 areas, determine 

resource types at risk from the 

proposed treatment, and develop 

appropriate measures to minimize 

or mitigate adverse impacts.

3 Bars Project Final EIS C-7 October 2016 
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element Treatment Method

Wildland Fire Mechanical Manual Biological

Resource 

Management).

See also: 

Programmatic 

Agreement among the 

Bureau of Land 

Management, the 

Advisory Council on 

Historic Preservation, 

Identify cultural resource types at 

risk from fire use and design 

inventories that are sufficient to 

locate these resources. Provide 

measures to minimize impacts.

Identify opportunities to meet tribal 

cultural use plant objectives for 

projects on public lands.

Monitor significant paleontological 

from mechanical treatments and 

design inventories that are sufficient 

to locate these resources. Provide 

measures to minimize impacts.

Identify opportunities to meet tribal 

cultural use plant objectives for 

projects on public lands.

Consult with tribes to locate any 

areas of vegetation that are of 

from manual treatments and design 

inventories that are sufficient to 

locate these resources. Provide 

measures to minimize impacts.

Identify opportunities to meet tribal 

cultural use plant objectives for 

projects on public lands.

Consult with tribes to locate any 

areas of vegetation that are of 

Identify opportunities to meet tribal 

cultural use plant objectives for 

projects on public lands.

Consult with tribes to locate any 

areas of vegetation that are of 

significance to the tribe and that 

might be affected, adversely or 

beneficially, by biological 

treatments.

and the National 

Conference of State 

Historic Preservation 

Officers Regarding the 

Manner in Which BLM 

Will Meet Its 

Responsibilities Under 

the National Historic 

Preservation Act 

(1997).

and cultural resources for potential 

looting of materials where they have 

been exposed by fire.

significance to the tribe and that 

might be affected, adversely or 

beneficially, by mechanical 

treatments.

significance to the tribe and that 

might be affected, adversely or 

beneficially, by manual treatments.

Visual Resources Minimize use of fire in sensitive 

watersheds to reduce the creation of 

Minimize dust drift, especially near 

recreational or other public use areas.

Minimize dust drift, especially near 

recreational or other public use areas.

At areas such as visual overlooks, 

leave sufficient vegetation in place, See handbooks H8410-1 (Visual 

Resource Inventory) 

large areas of browned vegetation.

Consider the surrounding land use 

Minimize loss of desirable vegetation 

near high public use areas.

Minimize loss of desirable vegetation 

near high public use areas.

where possible, to screen views of 

vegetation treatments.

and H-8431-1 (Visual before assigning fire as a treatment At areas such as visual overlooks, At areas such as visual overlooks, Lessen visual effects in Class I and 

Resource Contrast method. leave sufficient vegetation in place, leave sufficient vegetation in place, Class II visual resource areas.

Rating), and Manual At areas such as visual overlooks, where possible, to screen views of where possible, to screen views of Design activities to repeat the form, 

8400 (Visual Resource leave sufficient vegetation in place, vegetation treatments. vegetation treatments. line, color, and texture of the natural 

Management). where possible, to screen views of Minimize earthwork and locate away Lessen visual effects in Class I and landscape character conditions to 

vegetation treatments.

Avoid use of fire near agricultural or 

from prominent topographic features.

Revegetate treated sites.

Class II visual resource areas.

Design activities to repeat the form, 

meet established VRM objectives.

densely populated areas, where 

feasible.

Lessen visual effects in Class I and 

Lessen visual effects in Class I and 

Class II visual resource areas.

line, color, and texture of the natural 

landscape character conditions to 

meet established VRM objectives.

Class II visual resource areas. Design activities to repeat the form, 

line, color, and texture of the natural 

Design activities to repeat the form, 

line, color, texture of the natural landscape character conditions to 

meet established VRM objectives.

3 Bars Project Final EIS C-8 October 2016 STANDARD OPERATING PROCEDURES
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element Treatment Method

Wildland Fire Mechanical Manual Biological

Visual Resources 

(cont.).

landscape conditions to meet 

established Visual Resource 

Management (VRM) objectives.

Wilderness and Other Minimize soil-disturbing activities Use the least intrusive methods Use the least intrusive methods Use the least intrusive methods 

Special Areas during fire control or prescribed fire 

activities.

possible to achieve objectives, and 

use non-motorized equipment in 

possible to achieve objectives, and 

use non-motorized equipment in 

possible to achieve objectives, and 

use non-motorized equipment in See handbooks H8550-1 (Management 

of Wilderness Study 

Areas (WSAs)), and HRevegetate sites with native species 

if there is no reasonable expectation 

of natural regeneration.

wilderness and off existing routes in 

wilderness study areas, and where 

possible in other areas.

wilderness and off existing routes in 

wilderness study areas, and where 

possible in other areas.

wilderness and off existing routes in 

wilderness study areas, and where 

possible in other areas.

8560-1 (Management Maintain adequate buffers for Wild If mechanized equipment is required, Revegetate sites with native species if Maintain adequate buffers for Wild 

of Designated and Scenic Rivers. use the minimum amount of there is no reasonable expectation of and Scenic Rivers.

Wilderness Study equipment needed. natural regeneration.

Areas). Time the work for weekdays or offseason.Maintain adequate buffers for Wild 

and Scenic Rivers.

Require shut down of work before 

evening if work is located near 

campsites.

If aircraft are used, plan flight paths 

to minimize impacts on visitors and 

wildlife.

Revegetate sites with native species if 

there is no reasonable expectation of 

natural regeneration.

Maintain adequate buffers for Wild 

and Scenic Rivers.

Recreation Control public access to potential 

burn areas.

Control public access until potential 

treatment hazards no longer exist.

Control public access until potential 

treatment hazards no longer exist.

Control public access in areas with 

control agents to ensure that agents See Handbook H-1601-

1 (Land Use Planning Schedule treatments to avoid peak Schedule treatments to avoid peak Schedule treatments to avoid peak are effective.

Handbook). recreational use times, unless 

treatments must be timed during 

recreational use times, unless 

treatments must be timed during peak 

recreational use times, unless 

treatments must be timed during peak 

Schedule treatments to avoid peak 

recreational use times, unless 

peak times to maximize times to maximize effectiveness. times to maximize effectiveness. treatments must be timed during 

effectiveness.

Notify the public of treatment 

Notify the public of treatment 

methods, hazards, times, and nearby 

Notify the public of treatment 

methods, hazards, times, and nearby 

peak times to maximize 

effectiveness.

methods, hazards, times, and nearby alternative recreation areas. alternative recreation areas. Notify the public of treatment 

alternative recreation areas. methods, hazards, times, and nearby 

3 Bars Project Final EIS C-9 October 2016 

 STANDARD OPERATING PROCEDURES
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element Treatment Method

Wildland Fire Mechanical Manual Biological

Recreation (cont.) alternative recreation areas.

Social and Economic Post treatment areas. Post treatment areas. Post treatment areas. Post treatment areas.

Values Notify adjacent landowners, grazing 

permittees, the public, and 

emergency personnel of treatments.

Notify adjacent landowners, grazing 

permittees, the public, and 

emergency personnel of treatments.

Notify adjacent landowners, grazing 

permittees, the public, and 

emergency personnel of treatments.

Notify adjacent landowners, grazing 

permittees, the public, and 

emergency personnel of treatments.

Control public access to treatment 

areas.

Control public access to treatment 

areas.

Control public access to treatment 

areas.

Control public access to treatment 

areas.

Consult with Native American tribes Consult with Native American tribes Consult with Native American tribes Consult with Native American 

and Alaska Natives whose health and Alaska Natives whose health and and Alaska Natives whose health and tribes and Alaska Natives whose 

and economies might be affected by 

the project.

economies might be affected by the 

project.

economies might be affected by the 

project.

health and economies might be 

affected by the project.

To the extent feasible, hire local 

contractors and purchase supplies 

locally.

To the extent feasible, hire local 

contractors and purchase supplies 

locally.

To the extent feasible, hire local 

contractors and purchase supplies 

locally.

To the extent feasible, hire local 

contractors and purchase supplies 

locally.

Rights-of-way Coordinate vegetation management 

activities where joint or multiple 

uses of a rights-of-way (ROW)

exists. 

Notify other public land users within 

or adjacent to the ROW proposed 

for treatment.

Manage burns under powerlines so 

as to avoid negative impacts to the 

powerline.

Coordinate vegetation management 

activities where joint or multiple use 

of a ROW exists. 

Notify other public land users within 

or adjacent to the ROW proposed for 

treatment.

Apply appropriate safety measures 

when operating equipment within 

utility ROW corridors.

Minimize exposed soil areas during 

treatment.

Coordinate vegetation management 

activities where joint or multiple use 

of a ROW exists. 

Notify other public land users within 

or adjacent to the ROW proposed for 

treatment.

Always use appropriate safety 

equipment and operating procedures.

Utilize methods for disposal of 

vegetation that prevent spreading or 

reinfestation of unwanted vegetation.

Coordinate vegetation management 

activities where joint or multiple use 

of a ROW exists. 

Notify other public land users 

within or adjacent to the ROW 

proposed for treatment.

Keep operations within prescribed 

ROW. 

Human 

Safety

Health and Use some form of pretreatment, 

such as mechanical or manual 

treatment, in areas where fire cannot 

be safely introduced because of 

hazardous fuel buildup.

Wear appropriate safety equipment 

and clothing, and use equipment that 

is properly maintained.

Wear appropriate safety equipment 

and clothing, and use equipment that 

is properly maintained.

Cut all brush and tree stumps flat, 

where possible, to eliminate sharp 

points that could injure a worker or 

the public.

Ensure that only qualified personnel 

Wear appropriate safety equipment 

and clothing, and use equipment that 

is properly maintained.

Cut all brush and tree stumps flat, 

where possible, to eliminate sharp 

points that could injure a worker or 

the public.

Wear appropriate safety equipment 

and clothing, and use equipment 

that is properly maintained.

3 Bars Project Final EIS C-10 October 2016 

STANDARD OPERATING PROCEDURES
TABLE C-1 (Cont.) 

Vegetation Treatment Methods Standard Operating Procedures and Guidelines 

Resource Element Treatment Method

Wildland Fire Mechanical Manual Biological

Human Health and Notify nearby residents who could cut trees near powerlines.

Safety (cont.) be affected by smoke.

Maintain adequate safety buffers 

between treatment area and 

residences/structures.

Burn vegetation debris off ROWs to 

ensure that smoke does not provide 

a conductive path from the 

transmission line or electrical 

equipment to the ground.

3 Bars Project Final EIS C-11 October 2016 

 STANDARD OPERATING PROCEDURES
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-12 October 2016 

5. No new roads will be constructed. 

6. Some sites could likely be treated with a combination of methods. For example, an area with cheatgrass 

could be burned, then disked, then drill seeded with desirable plant species. 

7. Although manual and mechanical methods are labor intensive and costly on a per unit of area basis compared 

to prescribed burning, they are highly selective and can be used in areas such as sensitive habitats or where 

human health and safety are concerns. Manual and mechanical treatments will be applied when prescribed 

burning is not appropriate. 

8. Several mechanical methods are available for vegetation treatment. With any mechanical treatment, steps 

will be taken to minimize both soil disturbance and the spread of invasive species. Treatment methods will be 

matched with site characteristics and potential based on ecological site description. 

9. Thinning will be conducted in a manner that blends treated areas into untreated areas, thus maximizing the 

“edge effect,” or the amount of area between two adjacent habitat types. Stumps will be cut as low as 

possible to the ground. 

10. Treatment areas will be maintained using one or more treatment methods based on the alternative chosen by 

the BLM for the 3 Bars Project. 

11. Initiation of maintenance treatments would be based on monitoring results that show that project objectives 

were not being met. 

12. All treatment units would be inventoried for cheatgrass and treated, if necessary, prior to project 

implementation in a unit. 

13. All treatment units will be monitored for noxious weeds or other non-native invasive vegetation for 1 to 3 

years following treatment. If noxious weeds or other non-native invasive vegetation were found on the 

treatment unit, they would be treated with an appropriate and approved method in accordance with the 

Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field Office and Tonopah 

Field Office (USDOOI BLM 2009). 

14. Map mountain mahogany occurrence prior to conducting treatments in units containing mountain mahogany. 

Remove mountain mahogany only where it compromises riparian habitat treatment objectives. Use hand 

thinning only, where feasible, near mountain mahogany. 

C.2.2 Livestock 

There are 12 livestock allotments within the 3 Bars ecosystem. The following procedures will ensure that the health 

and safety of livestock are not compromised by treatment activities, and that treatment activities will have minimal 

impacts on livestock operators. Standard Operating Procedures specific to livestock are: 

1. Notify allotment permittee(s) of proposed vegetation treatments to discuss dates of treatment and restoration, 

current grazing practices, and additional site-specific mitigation, and to resolve issues they may have with the 

proposed treatments. This will help to ensure safe implementation of treatments. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-13 October 2016 

2. Do not implement any restoration activities unless proper livestock management is in place. 

3. Design treatments to take advantage of normal livestock grazing rest periods for a particular area, when 

possible, to minimize impacts to livestock grazing permits. 

4. Rangeland improvements would be documented prior to initiating treatment projects and any damaged 

improvements will be repaired to previous condition or current BLM standards as soon as project activities in 

the immediate area are complete. 

C.2.2.1 Temporary Livestock Grazing Closures 

1. Design treatments to take advantage of normal livestock grazing rest periods for a particular area, when 

possible, to minimize impacts to livestock grazing permits. 

2. Close areas, as needed, for at least 2 growing seasons, or until treatment objectives are met. Closure 

decisions are associated with the range regulations 43 CFR § 4160 and are required to close the treatment 

areas to livestock grazing. Animal Unit Months associated with the treatment areas may be temporarily 

suspended. 

3. Re-open treated area to grazing in accordance with livestock grazing mitigation actions developed in the 3 

Bars Project EIS or in accordance with existing permitted uses. 

Depending upon the vegetation management treatment method used, the length of the temporary grazing closure will 

vary. Any treatment method used to release understory vegetation, and that meets the following criteria, will result in 

a temporary closure of that area for a minimum of 2 growing seasons or until vegetation establishment objectives are 

met. These criteria are: 

1. The proposed treatment area understory lacks perennial understory vegetation that is expected and described 

in the Ecological Site Description(s) for the Ecological Site(s) for the treatment area. 

2. Rest from livestock grazing is considered necessary to aid in the establishment/improvement of desired 

perennial vegetation. Perennial plant species that meet site-specific restoration objectives will be determined 

by the BLM. 

3. Treatment area requires reseeding. 

For prescribed fire treatments, a year of grazing rest prior to a prescribed fire treatment may be required in order to 

build up an adequate amount of fine fuels needed to carry the fire. The BLM will determine if a growing season’s rest 

is required before the prescribed fire treatment. Following the prescribed fire treatment, a minimum of 2 growing 

seasons of grazing rest may be required to meet vegetation establishment objectives. 

Riparian treatment areas will be closed for a minimum of 2 years; however, closure could be extended until the 

streambank is stabilized and vegetation establishment objectives are met. 

The BLM will take steps to reduce the impact of treatment closures on permittees though targeting general areas for 

treatment as opposed to scattering treatments across the 3 Bars Project Area. The BLM will also work within grazing 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-14 October 2016 

authorizations to modify patterns of use to accommodate treatment closure when possible, thus limiting impacts to 

current management strategies. 

C.2.3 Wild Horses 

There are four Herd Management Areas (HMAs) within the 3 Bars ecosystem. The wild horse population in the 3 

Bars Project area is in excess of the established Appropriate Management Level (AML) in the Roberts Mountains 

Complex. The Rocky Hills HMA population is currently below AML, but is heavily concentrated in the vicinity of 

Cadet Trough Spring. The following procedures will ensure that the health and safety of wild horses are not 

compromised by treatment activities. The procedures will also ensure a desirable distribution of wild horses, and few 

areas of overuse by wild horses, to ensure treatment success. To meet these objectives, SOPs specific to wild horses 

are: 

C.2.3.1 Roberts Mountains Complex

1. Use temporary fencing to protect riparian treatment areas and include water gaps or off-site water 

development (trough placement). 

2. Where fencing is needed within HMAs, use temporary electric fencing around sagebrush and pinyon-juniper 

treatment areas to protect from use by wild horses. 

3. No use of barbed wire or let-down fencing will be allowed within HMA boundaries, and let-down fencing 

will not be used where wild horses are present and may become entrapped in the fence.

4. The Roberts Mountain Complex will remain a priority for gathers and use of population growth suppressants 

to achieve and maintain the AML in order to reduce wild horse impacts on treatment success. 

C.2.3.2 Rocky Hills Herd Management Area 

1. The Rocky Hills HMA is part of the Catch, Treat, and Release gather and fertility control program. National 

direction has been to return to these HMAs on a 2- to 3-year basis to re-treat the mares for fertility control. 

The timing of the gathers will be determined by the BLM Nevada State Office. The Rocky Hills HMA is a 

priority for gathering and for maintaining the AML through subsequent gathers during the life of the 3 Bars 

Project. 

2. Use temporary fencing to protect riparian treatment areas and include water gaps or off-site water 

development (trough placement). 

3. Where fencing is needed within HMAs, use temporary electric fencing around sagebrush and pinyon-juniper 

treatment areas to protect from use by wild horses. 

4. No use of barbed wire or let-down fencing will be allowed within HMA boundaries, and let-down fencing 

will not be utilized where wild horses are present and may become entrapped in the fence. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-15 October 2016 

C.2.3.3 Other Measures 

1. Minimize disturbance associated with restoration activities within wild horse HMAs during the peak foaling 

season (March 1-June 30). 

2. Do not implement any restoration activities without appropriate adjustments in the management of livestock 

or wild horses. 

3. Aircraft will not be flown in the HMAs below 500 feet above ground level between March 1-June 30 to 

prevent disruption during foaling period and orphaned or abandoned foals. 

4. Aerial application of herbicides will be restricted within HMAs. Aerial applications will only take place after 

conducting pre-flights of the proposed treatment area to document wild horse numbers and locations. A 

separation distance between area of herbicide application and wild horse herds will be determined based on 

animal movement behavior and known use of the area. A Project Inspector or Wild Horse and Burro 

Specialist will be on-site during aerial applications to ensure that wild horses are not within the treatment 

area and to ensure that an adequate buffer is maintained between the herbicide spray and wild horses. 

5. Where fencing is constructed around riparian areas, access to water by wild horses will be maintained. If 

water is not already available in the immediate vicinity of the proposed temporary exclosure, then either a 

water gap will be planned or water will be developed through piping to a trough or troughs. 

6. Routine monitoring of the wild horses, vegetation and water sources will continue within the project area 

with inventory flights scheduled every 2-3 years to document wild horse distribution and estimate the 

population size. Any post-treatment monitoring would also involve documentation of wild horse sign, 

observations, and use patterns 

7. Should monitoring indicate that wild horses are being negatively impacted by the treatment activities, the 

Mount Lewis Field Office Manager may require additional measures for the protection of wild horses such as 

seasonal restrictions during the peak foaling period. 

8. Beyond riparian temporary exclosures, no permanent or temporary barbed wire fences will be constructed 

within HMAs within the 3 Bars Project area. Should protection of vegetation from grazing animals be 

needed, temporary fences constructed of electric fence poly rope, poly tape, or high tensile cable will be 

used. Fences will be flagged appropriately and/or bright or reflective electric poly tape will be used. Any 

steel posts used for riparian or electric fences will be white-topped for visibility, and may include steel post 

safety caps. Additional reflectors may be necessary if problems with horses impacting fences occur. 

9. When livestock are not present, gates will be left open throughout the HMAs to allow for unrestricted 

movement of wild horses. 

10. During treatment, contractors and BLM staff will remain aware of the presence of wild horses in the area and 

potential conflicts that could result in injury to wild horses. Operations will be modified as needed to prevent 

excessive disturbance to wild horses. Issues will be reported to the Mount Lewis Field Office Wild Horse and 

Burro Specialist immediately. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-16 October 2016 

C.2.4 Erosion Control 

1. Follow guidance provided in the Nevada Contractors Field Guide for Construction Site Best Management 

Practices (Nevada Division of Environmental Protection 2008) and in An Introduction to Erosion Control

(Zeedyk and Jansens 2006). 

2. Stabilize terrestrial areas as quickly as possible after treatment, including reseeding or replanting with native 

vegetation, if the existing native plant community cannot recover and revegetate the site sufficiently. 

3. Install sediment traps in streams if prescribed fire is used near streams. 

4. Leave downed trees and mulch in areas with large-scale pinyon-juniper removal to prevent sediment from 

entering nearby waterways. 

5. Use mulch, wood straw, wattles, and other erosion control features to minimize erosion and movement of 

sediments into nearby water bodies in areas treated using prescribed fire or where other large-scale 

vegetation removal occurs. 

C.2.5 Planting and Seeding 

1. Seeding and planting could be used on all treatment units. 

2. Follow BLM Handbook H-1742-1, Burned Area Emergency Stabilization and Rehabilitation Handbook 

(USDOI BLM 2007c) during the seed procurement process, including the sampling and testing of all seed 

lots for noxious weeds and invasive species, to ensure that noxious weed and other invasive non-native 

species seed are not present. 

3. Follow the contour of the land as much as possible when drill seeding to reduce potential water erosion. Do 

not disturb intact stands of sagebrush and native perennial vegetation. 

4. Non-native seeds could be used to support hazardous fuels projects in areas with low moisture and that have 

previously burned; in old fire scar areas that cannot be successfully treated using Emergency Stabilization 

and Rehabilitation methods; and only where seeding using native species will not be successful. 

C.2.6 Protective Fences 

1. Build fences in accordance with BLM Manual H-1741, Renewable Resource Improvements, Practices, and 

Standards (USDOI BLM 1989). Modifications may be incorporated into the design based on consultation 

with the Nevada Department of Wildlife (NDOW) and subsequent recommendations to minimize adverse 

impacts to wildlife. Let-down fences could be constructed in big game ranges and migration corridors where 

feasible and necessary. 

2. Use existing fence infrastructure as much as is practical to protect treatment areas. This may entail 

modification of grazing on a pasture basis to ensure the appropriate amount of protection for seeding and 

restoration activities. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-17 October 2016 

3. Use temporary protective fences when feasible. Permanent fences besides those proposed for the 3 Bars 

Project, if needed, will be analyzed under the National Environmental Policy Act for the effects to cultural, 

natural, and social resources from the fencing. 

4. Construct livestock, wild horse, and other wild ungulate exclusion fences around treatment boundaries. These 

protective fences will be on an as-needed basis to allow vegetation to establish, and to reduce the need to 

remove livestock from the pasture or allotment. As noted in Sections C.2.3.1 and C.2.3.2, no use of barbed 

wire or let-down fencing will be allowed within HMA boundaries, and let-down fencing will not be utilized 

where wild horses are present and may become entrapped in the fence. 

5. Place the top fence wire above horizontal braces to minimize perching by predatory birds. 

6. Place domed pipe caps on the top of steel pipes, if steel pipe corners are used, to prevent wildlife entry and to 

minimize predatory bird perching. 

7. Enhance the visibility of fences constructed within Greater sage-grouse habitat or HMAs by using 

appropriate measures such as installing wide stays, deflectors, and/or white-topped posts. Type or brand of 

reflectors used will be selected from those that have been previously tested and determined to be effective. 

Additional measures to reduce impacts to Greater sage-grouse include constructing fences with larger and 

more conspicuous wooden fence posts, ensuring that fence segments are less than 13 feet wide, avoiding 

fence construction within 1,640 feet of an inactive lek, and avoiding fence construction within 11⁄4 miles of 

an active lek. 

C.2.6.1 Types of Temporary Fencing 

1. Riparian Treatments - Standard barbed wire fence and temporary electric fence may be used. 

2. Aspen Treatments – Standard barbed wire fence and temporary electric fence may be used. 

3. Pinyon-juniper Treatments – Temporary electric fence may be used in Birch Creek and Upper Pete Hanson 

treatment areas, and temporary barbed wire fencing outside of areas utilized by wild horses. 

4. Sagebrush Treatments – Temporary electric fencing. Temporary barbed wire fencing will only be used 

outside of areas utilized by wild horses. 

C.2.7 Riparian Management 

1. The BLM will work with federal and state agencies to ensure compliance with the Sections 401 and 404 of 

the Clean Water Act to ensure that impacts to streams are minimal and that treatments are in compliance with 

federal and state laws. 

2. Remove non-riparian trees within the historic floodplains. 

3. Chainsaw hand thinning is the preferred method for tree cutting in riparian units. However, other methods 

may be considered on a case-by-case basis. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-18 October 2016 

4. Mechanical equipment will not be used within the stream where feasible, but could be used to place items or 

structures within the stream to address stream structural issues. 

5. Remove vegetation incrementally over several years if loss of shade near streams and other waterbodies is of 

concern to minimize stream temperature effects. 

6. Hand thinning is the preferred method to remove vegetation around springs. 

7. Use only existing fencing or small temporary exclosures to protect treatment units. 

8. No fueling within 300 feet of water bodies. 

9. No felling of trees, skidding, rigging, or construction of tractor or truck roads or landings, or the operation of 

vehicles may take place within 200 feet, measured on the slope, of the high-water mark of any lake, 

reservoir, stream, or other body of water unless a variance is first obtained under the criteria from a 

committee composed of the State Forester Fire Warden, the Director of the NDOW, and the State Engineer 

(Nevada Revised Statute § 528.053). The committee may grant a variance authorizing any of the activities 

prohibited by Statute subsection 1 within a 200-foot buffer area if the committee determines that the goals of 

conserving forest resources and achieving forest regeneration, preserving watersheds, reaching or 

maintaining water quality standards adopted by federal and state law, continuing water flows, preserving and 

providing for the propagation of fish life and stream habitat, and preventing significant soil erosion will not 

be compromised. In acting on a request for such variances, the committee shall consider the following 

factors: 

a. the extent to which such requested activity is consistent with good forestry management for the 

harvesting of timber; 

b. the extent to which such requested activity significantly impedes or interrupts the natural volume and 

flow of water; 

c. the extent to which such requested activity significantly affects a continuation of the natural quality of 

the water pursuant to state and federal water quality standards; 

d. the extent to which such requested activity is consistent with the prevention of significant soil erosion; 

e. the extent to which such requested activity may significantly obstruct fish passage, cause sedimentation 

in fish spawning areas, infringe on feeding and nursing areas and cause variations of water temperatures; 

and

f. the filtration of sediment-laden water as a consequence of timber harvesting on adjacent slopes. 

C.2.8 Aspen Management 

1. Chainsaw hand thinning is the preferred method for tree cutting in aspen units. However, other methods may 

be considered on a case-by-case basis. 

2. Use only existing fencing or small temporary exclosures to protect treatment units. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-19 October 2016 

3. Slash accumulations will remain in place to promote seedling and sapling establishment. 

4. Pinyon-juniper removal activities may extend 200 feet beyond the aspen stand. 

5. The BLM may protect treated aspen stands until the stand density is 1,500 stems per acre and sapling reach at 

least 7 feet in height with temporary exclosure fencing. Typically, objectives are met in 3 to 5 years as a 

result of exclusion. 

C.2.9 Pinyon-juniper Management 

1. The BLM will survey for old-growth pinyon-juniper and limber pine and map their occurrence prior to 

treating an area and will make every effort to avoid areas with old-growth pinyon-juniper and limber pine 

stands. 

2. Prescribed fire could be utilized in all pinyon-juniper phase classes and may be carried out at any time of the 

year depending on treatment objectives. 

3. Chainsaw hand thinning is the preferred method for tree cutting. However, other methods may be considered 

on a case-by-case basis. 

4. In most instances, treatment of pinyon-juniper will occur predominately in Phase I and Phase II sites. Only 

hand-thinning treatments will be use on Phase I sites. Treatments on Phase II and III could include prescribed 

fire as necessary, and would generally occur in phases of about 550 acre blocks. Treatments within Phase III 

sites will be used to disrupt the continuity of fuels and reduce the risk of catastrophic wildfire, as well as 

improve forest health. 

5. The BLM may leave downed trees and mulch in areas with large-scale pinyon-juniper removal to prevent 

sediment from entering nearby waterways. 

6. Treatment design will allow for up to 100 cords of fuel wood (greenwood and deadwood combined) to be 

removed for commercial sale annually. 

7. For all pinyon-juniper removal projects, the BLM will implement SOPs to minimize the chance of noxious 

weeds and other invasive non-native vegetation becoming established on the treatment units, and will 

monitor all units for noxious weeds and other invasive non-native vegetation for up to 5 years after treatment. 

8. Biological control methods would only be used to treat cheatgrass. 

9. Fuel breaks will be constructed along existing roads and two-tracks where possible using narrow and smallscale green-stripping. Fuel breaks will not be constructed where they could adversely impact important 

cultural or natural resources. 

C.2.10 Sagebrush Management 

1. Treatments will adhere to the September 2015 BLM Nevada and Northeastern California Greater SageGrouse Approved Resource Management Plan Amendment and Record of Decision (ARMPA) including the 

Required Design Features (RDFs) specified for fuels and fire management and the strategies outlined in the 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-20 October 2016 

Fire and Invasives Assessment Tool (FIAT - Appendix G of the ARMPA) including integrating resilience 

and resistance concepts for managing Sage-Grouse habitat at the landscape scale. 

2. Any treatments on Greater sage-grouse habitat will utilize a mosaic design where treated areas have a width 

of no greater than 200 feet between untreated areas. No treatment will occur within 0.6 miles of any occupied 

lek that results in a decrease in canopy cover of greater than 15 percent, unless additional site-specific 

objectives are identified. 

3. Soil tests will be conducted to determine if suitable seeds are present in the seedbank before treatments occur 

in sagebrush communities. 

4. Biological control methods would only be used to treat cheatgrass. 

5. Chainsaw hand thinning is the preferred method for tree cutting within sagebrush treatment units. However, 

other methods may be considered on a case-by-case basis. 

6. Treatment design will allow for up to 100 cords of fuel wood (greenwood and deadwood combined) to be 

removed for commercial sale annually. 

7. Only native seed would be used for overseeding in sagebrush units. Seed type would be determined based on 

monitoring and adaptive management. 

C.2.11 Prescribed Fire and Fire for Resource Benefit 

1. Develop a burn plan prior to any prescribed burn occurring. 

2. Ignite burns under fair to excellent ventilation conditions and suspend operations under poor smoke 

dispersion conditions. 

3. Minimize dirt content when slash piles are constructed. 

4. Consolidate burn piles and other burn materials to enhance fuel consumption and to minimize smoke 

production. 

5. The BLM may suspend grazing on burned areas for at least 2 years after the burn, or until standards are met. 

6. Use fencing, if necessary, to allow desirable plants to become established in burned areas. 

7. Treatments may be conducted next to roads to improve the roads’ usefulness as fuel breaks and as control 

lines for wildfires and prescribed fires. 

C.2.12 Activity Fuel Disposal Methods 

The following actions will be taken to dispose of felled trees, slash, and other woody materials that remain from 

treatments to reduce the buildup of hazardous fuels and potential for wildfire. 

1. Dispose of activity fuels (slash) using one or more of the disposal options from the activity fuel disposal 

alternatives listed below. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-21 October 2016 

2. Remove biomass in a manner that minimizes the spread of noxious weeds and other invasive non-native 

species and promote seeding establishment and development. Should slash accumulations exceed 4 tons/acre, 

these activity fuels will be disposed of with one or more of the activity fuel disposal methods listed below. 

3. Burn during the fall, winter, and spring to take advantage of conditions of soil moisture, snow, precipitation, 

and vegetation green-up to reduce fire impacts to non-target vegetation. 

4. Where appropriate, leave tree materials on the ground and positioned perpendicular to slopes to minimize 

erosion. 

5. Where appropriate, lop and scatter felled trees to reduce fuel loading, buck and stack close to access points to 

minimize erosion and spread of noxious weeds and other invasive non-native species, or burn in slash piles to 

minimize ground litter. 

6. Where appropriate, allow felled trees to be used for public wood harvesting per District policy and to aid in 

the removal of tree materials. 

C.2.12.1 Biomass Utilization 

1. Where appropriate, make juniper activity fuels that are wider than 3 inches available to the public (personal 

use or commercial) for fire wood or posts. 

2. Where appropriate, make activity fuel available to the public (personal use or commercial) as mulch. 

3. Where feasible, use coarse and large woody debris for stream restoration to slow stream water flow and 

reduce the potential for stream erosion. 

4. Place coarse and large wood debris perpendicular to slopes greater than 10 percent. 

5. Where appropriate, make activity fuel available for personal and commercial biomass use. 

C.2.12.2 Pile Burn 

1. Burn piles should not exceed 10 feet long by 10 feet wide by 6 feet high. 

2. Burn piles will be piled with fine fuels and slash on the interior and larger fuels on the exterior. 

3. Burn piles maybe covered with wax paper or similar material (no plastic). 

4. Piles will be burned in the spring, fall, or winter. 

C.2.12.3 Slash Burn 

1. Scatter activity fuels according to guidance from the Fire Behavior Fuel Models for slash. 

2. Slash will be burned in the spring, fall, or winter. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-22 October 2016 

C.2.12.4 Leave on Site 

1. Where appropriate, leave some material piled on site to provide wildlife habitat or for erosion control. 

C.3 Special Precautions 

C.3.1 Prevention of Weeds and Early Detection and Rapid Response 

Once weed populations become established, infestations can increase and expand in size. Weeds colonize highly 

disturbed ground and invade plant communities that have been degraded, but are also capable of invading intact 

communities. Therefore, prevention, early detection, and rapid response are the most cost-effective methods of weed 

control. Prevention, early detection, and rapid response strategies that reduce the need for vegetative treatments for 

noxious weeds should lead to a reduction in the number of acres treated using herbicides in the future by reducing or 

preventing weed establishment. 

As stated in the BLM’s Partners Against Weeds - An Action Plan for the BLM (USDOI BLM 1996), prevention and 

public education are the highest priority weed management activities. Priorities are as follows: 

 Priority 1: Take actions to prevent or minimize the need for vegetation control when and where feasible, 

considering the management objectives of the site. 

 Priority 2: Use effective nonchemical methods of vegetation control when and where feasible. 

 Priority 3: Use herbicides after considering the effectiveness of all potential methods or in combination with 

other methods or controls. 

Prevention is best accomplished by ensuring the seeds and reproductive plant parts of new weed species are not 

introduced into new areas. 

The BLM is required to develop a noxious weed risk assessment when it is determined that an action may introduce 

or spread noxious weeds or when known noxious weed habitat exists (USDOI BLM 1992). If the risk is moderate or 

high, the BLM may modify the project to reduce the likelihood of weeds infesting the site and to identify control 

measures to be implemented if weeds do infest the site. The following are actions that can be taken by the BLM to 

slow the introduction or spread of noxious weeds and other invasive vegetation: 

1. To eliminate the transport of vehicle-borne weed seeds, roots, or rhizomes, all vehicles and heavy equipment 

that could cause ground disturbance, or are authorized for off-road use, will be cleaned to ensure that they are 

free of soil and debris capable of transporting weed propagules. All vehicles and equipment will be cleaned 

prior to entering or leaving the project area. Cleaning efforts will concentrate on vehicle tracks, feet and tires, 

and undercarriage. Cleaning efforts will also focus on axles, frames, cross members, motor mounts, steps, 

running boards, and front bumper/brush guard assemblies. Vehicle cabs will be swept out and refuse will be 

disposed of in waste receptacles. 

2. Equipment will be washed prior to being moved between project units. Equipment will arrive at the project 

unit area already cleaned of all dirt and debris. Any subsequent cleanings (i.e., before moving between units) 

will be recorded using Global Positioning System units or other mutually acceptable equipment and provided 

to the District Office Weed Coordinator or designated person. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-23 October 2016 

3. All treatment areas where soil is disturbed will be monitored to determine if noxious weeds and other 

invasive non-native vegetation establish on the site. If so, they will be treated to remove them from the site. 

4. Project areas will be surveyed for noxious weeds prior to project implementation. Any noxious weeds 

discovered within the 3 Bars Project area will be flagged and project treatments will not be allowed within 75 

yards of the noxious weed infestation. 

C.3.2 Plants and Animals 

C.3.2.1 Special Status Species 

Federal policies and procedures for protecting federally listed threatened and endangered plant and animal species and 

species proposed for listing were established by the Endangered Species Act of 1973 (Act) and regulations issued 

pursuant to the Act. The purposes of the Act are to provide mechanisms for the conservation of threatened and 

endangered species and their habitats. Under the Act, the Secretary of the Interior is required to determine which 

species are threatened or endangered and to issue recovery plans for those species. 

Section 7 of the Act specifically requires all federal agencies to use their authorities in furtherance of the Act to carry 

out programs for the conservation of listed species, and to ensure that no agency action is likely to jeopardize the 

continued existence of a listed species or adversely modify critical habitat. Policy and guidance (BLM Manual 6840, 

Special Status Species; USDOI BLM 2008a) also stipulates that species proposed for listing must be managed at the 

same level of protection as listed species. 

The BLM state directors may designate special status species in cooperation with their respective state. These special 

status species must receive, at a minimum, the same level of protection as federal candidate species. The BLM will 

also carry out management activities for the conservation of state-listed species, and state laws protecting these 

species will apply to all BLM programs and actions to the extent that they are consistent with Federal Land Policy and 

Management Act and other federal laws. Threatened, endangered, and other special status species are discussed in 

Sections 3.12 (Native and Non-invasive Vegetation Resources), 3.15 (Fish and Other Aquatic Resources), and 3.16 

(Wildlife Resources) of the 3 Bars Project Final EIS. 

Before any vegetation treatment or ground disturbance occurs, BLM policy requires that the Mount Lewis Field 

Office survey the treatment site for species listed or proposed for listing, and for special status species. This must be 

done by a qualified biologist and/or botanist who consults the state and local databases and visits the site during the 

appropriate season. For wildlife surveys, the biologist will follow the BLM Nevada Wildlife Survey Protocols (USDOI 

BLM 2013). If a proposed project may affect a proposed or listed species or its critical habitat, the BLM will consult 

with the USFWS. A project with a “may affect, likely to adversely affect” determination requires formal consultation 

and receives a Biological Opinion from the USFWS. A project with a “may affect, not likely to adversely affect” 

determination requires informal consultation and receives a concurrence letter from the USFWS. 

The BLM consulted with the USFWS during development of the 3 Bars Project EIS as required under Section 7 of 

the Act. As part of this process, the BLM prepared a formal consultation package that included a description of the 

program; species listed as threatened or endangered, species proposed for listing, and critical habitats that could be 

affected by the program; and a Biological Assessment that evaluated the likely impacts to listed species, species 

proposed for listing, and critical habitats from the proposed vegetation treatment programs. The Lahontan cutthroat 

trout was the only species that required evaluation in the Biological Assessment. The BLM will also consult with the 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-24 October 2016 

USFWS and NDOW before conducting prescribed fire and other treatments that could adversely impact Lahontan 

cutthroat trout when working near Lahontan cutthroat trout occupied or potential habitat. 

C.3.2.2 Fish 

1. To ensure fish passage and to protect fish, all culverts will be designed to ensure fish passage unless 

specifically designed and located to minimize interaction of fish species in coordination with NDOW and 

U.S. Fish and Wildlife Service (USFWS). 

2. Hardened water crossings or raised culverts would be considered in all locations where roads cross lotic or 

lentic areas. 

3. No in-stream treatments would be allowed in waters occupied by Lahontan cutthroat trout during January 1-

July 15 to help protect spawning fish and their eggs and young. 

C.3.2.3 Migratory Birds 

1. The BLM will conduct migratory bird nest surveys prior to any surface disturbing activities that would occur 

during the avian breeding season (April 1-July 31) following guidance in BLM Nevada Wildlife Survey 

Protocols (USDOI BLM 2013). If nests are found within the treatment area, or if other evidence of nesting 

(i.e., mated pairs, territorial defense, carrying nest material, transporting food) is observed, treatment 

activities may be postponed until after the completion of nesting, or a protective buffer (the size depending 

on the habitat requirements of the species) will be delineated and the buffer area will be avoided to prevent 

destruction or disturbance to nests and birds until they are no longer active, or the area will be removed from 

project consideration. 

2. Raptor nest sites are subject to seasonal and spatial protection from disturbance to avoid displacement and 

mortality of raptor young as shown in Table C-2. 

3. A BLM-approved wildlife biologist will conduct raptor nesting surveys using guidance in the BLM Nevada 

Wildlife Survey Protocols (USDOI BLM 2013). Surveys will be conducted no more than 14 days prior to 

commencement of surface-disturbing activities in an area. If disturbance does not occur within 14 days of the 

survey, the site will be resurveyed. If during any surveys nests or nesting behavior are documented, the area 

will be avoided until the young have fledged from the nest or the nest fails. Compliance with this SOP does

not constitute full compliance with, or exemption from, the Migratory Bird Treaty Act as amended, or any 

other legislation. 

C.3.2.4 Mule Deer, Pronghorn Antelope, and other Mammals 

1. Ground disturbing activities will not occur in mule deer and pronghorn antelope winter range from 

November 15-March 16 to avoid displacement and mortality to mule deer and pronghorn antelope during 

winter. The BLM will consult seasonal range maps prepared by the NDOW to delineate winter range for 

mule deer and pronghorn antelope at the time of treatment activities. 

2. Ground disturbing activities will not occur in pronghorn antelope kidding areas from May 1-June 30 to avoid 

displacement and mortality to pronghorn antelope during the kidding season. The BLM will consult seasonal 

range maps prepared by the NDOW to delineate kidding areas at the time of treatment activities. 
STANDARD OPERATING PROCEDURES 

3. BLM will not conduct treatments within 40 meters (131 feet) of active pygmy rabbit burrows. 

TABLE C-2 

 Raptor Nest Buffers 

Species Seasonal Restrictions Spatial Buffers (miles)

Turkey vulture 2/1 – 8/15 0.5

Northern harrier 4/1 – 8/15 0.25

Cooper’s hawk 3/15 – 8/31 0.25

Sharp-shinned hawk 3/15 – 8/31 0.25

Northern goshawk 3/1 – 8/15 0.5

Red-tailed hawk 3/15 – 8/15 0.33

Swainson’s hawk 3/1 – 8/31 0.25

Ferruginous hawk 3/1 – 8/1 1.0

Bald eagle 1/1 – 8/31 1.0

Golden eagle 1/1 – 8/31 0.5

American kestrel 4/1 – 8/15 0.125

Prairie falcon 3/1 – 8/31 0.5

Peregrine falcon 2/1 – 8/31 1.0

Barn owl 2/1 – 9/15 0.125

Burrowing owl 3/1 – 8/31 0.25

Flammulated owl 4/1 – 9/30 0.25

Great-horned owl 12/1 - 9/30 0.125

Long-eared owl 2/1 – 8/15 0.125

Northern pygmy-owl 4/1 – 8/1 0.25

Northern saw-whet owl 3/1 – 8/31 0.125

Short-eared owl 3/1 – 8/1 0.25

Western screech-owl 3/1 – 8/15 0.125

Sources: Herron et al. (1985), Romin and Muck (1999), Whittington and Allen (2008), and USDOI 

BLM (2013).

C.3.2.5 Greater Sage-grouse 

1. Ground disturbing activities will not occur within 4 miles of active sage grouse leks from 6 p.m. to 9 a.m., 

Pacific Time, during March 1-May 15, or in accordance with any revised guidelines and policies. The BLM 

will conduct lek and other surveys based on the BLM Nevada Wildlife Survey Protocols (USDOI BLM 2013) 

and the September 2015 ARMPA. 

2. Ground disturbing activities will not occur in sage-grouse brood rearing areas from May 15-September 15, or 

in accordance with current guidelines and policies. The BLM will consult seasonal range maps prepared by 

NDOW to delineate Greater sage-grouse use areas at the time of treatment activities. 

3. Ground disturbing activities will not occur in sage-grouse winter habitat use areas from November 1-

February 28, or in accordance with current guidelines and policies. The BLM will consult seasonal range 

maps prepared by NDOW to delineate Greater sage-grouse use areas at the time of treatment activities. 

3 Bars Project Final EIS C-25 October 2016 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-26 October 2016 

C.3.3 Native American Concerns and Cultural Resources 

The BLM meets its responsibilities for consultation and government-to-government relationships with Native 

American tribes by consulting with appropriate tribal representatives prior to taking actions that affect tribal interests. 

The BLM’s tribal consultation policies are detailed in BLM Manual 8120 (Tribal Consultation under Cultural 

Resource Authorities; USDOI BLM 2004a) and Handbook H-8120-1 (Handbook H-8120-1, General Procedural 

Guidance for Native American Consultation: Guidelines for Conducting Tribal Consultation; USDOI BLM 

2004b). The BLM consulted with various tribes and bands of the Western Shoshone during development of this EIS. 

Information gathered on important tribal resources and potential impacts to these resources from restoration activities 

is presented in the analysis of impacts. 

The BLM meets its responsibilities for compliance with Section 106 of the National Historic Preservation Act, and 

has adopted the following SOPs that would in part ensure compliance. All disturbance activities would comply with 

Section 106 in accordance with the measures outlined in the State Protocol Agreement between the Bureau of Land 

Management and the Nevada State Historic Preservation Office for Implementing the National Historic Preservation 

Act (Protocol Agreement) and specifically the Programmatic Agreement for the 3 Bars Project between the Nevada 

BLM and the Nevada State Historic Preservation Office. Actions that could be taken to address Native American 

concerns and cultural resources and to meet its responsibilities for compliance with Section 106 of the National 

Historic Preservation Act include: 

1. All disturbance activities will comply with Section 106 of the National Historic Preservation Act. 

Compliance will be achieved in accordance with the measures outlined in the Protocol Agreement. 

2. Wherever possible, the project will be designed to avoid potential adverse effects to historic properties (i.e. 

archeological sites eligible for inclusion on the National Register of Historic Places[NRHP]). Where it is not 

possible to avoid potential adverse effects, a mitigation plan will be crafted in accordance with National 

Historic Preservation Act as guided by the 36 CFR § 800 regulations and the site(s) will be fully mitigated. 

3. Each treatment will be monitored to ensure that avoidance measures have been effective and that project 

activities have not impacted cultural resources in an unforeseen manner. All persons participating in the 

construction, operation, or maintenance of a project will not disturb, alter, injure, or destroy any scientifically 

important remains, or any eligible archeological site, structure, building, object or artifact on lands associated 

with the project. Individuals involved in illegal activities will be subject to penalties under the Archaeological 

Resource Protection Act (16 United States Code [USC] § 470ii), the Federal Land Policy and Management 

Act (43 USC § 1701), the Native American Graves and Repatriation Act (16 USC § 1170), or other 

applicable statutes. 

4. If human remains/burials or other previously unidentified cultural resources or vertebrate paleontological 

resources are discovered during project operations, all activities within 300 feet of the discovery will 

immediately cease and the BLM archeologist will be notified by telephone, followed by written 

confirmation. Work will not resume and the discovery will be protected until the BLM authorized officer 

issues a Notice to Proceed. All discoveries of human remains (regardless of location in association with the 

project area) will be reported to the BLM Mount Lewis Field Office. 

5. Sites identified as holding special significance to Native American groups from a cultural or spiritual 

importance will be avoided if restoration activities would compromise the site’s value. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-27 October 2016 

6. Phase III cultural resource inventories Handbook H-8120-1, General Procedural Guidance for Native 

American Consultation: Guidelines for Conducting Tribal Consultation be conducted prior to project 

implementation. 

Under all alternatives, the BLM Handbook H-8120-1, General Procedural Guidance for Native American 

Consultation: Guidelines for Conducting Tribal Consultation implement the following measures as outlined in the 

Programmatic Agreement prepared for the 3 Bars project and signed by the BLM and Nevada State Historic 

Preservation Officer on September 5, 2012. 

1. Complete a cultural resource inventory of the proposed project area and consult with the Tribes in 

accordance with Stipulation III (A) of the Programmatic Agreement. 

2. For each phase of the undertaking, evaluate cultural resources for NRHP eligibility, consult with the Tribes 

or tribal members regarding areas of cultural or traditional religious importance, and consult with the State 

Historic Preservation Office and tribes regarding the NRHP determinations per Stipulation III(B) of the 

Programmatic Agreement. 

3. Develop and implement appropriate treatment measures to mitigate adverse effects to those resources 

determined eligible for inclusion in the NRHP and in accordance with Stipulation III(C) of the Programmatic 

Agreement. 

4. Treat unanticipated finds in accordance with the protocols outlined in Stipulation VII of the Programmatic 

Agreement. 

5. Provide training to all BLM and contract personnel to ensure compliance with the Archeological Resource 

Protection Act of 1979 (16 USC § 470), as amended, and ensure that human remains and burial associated 

items are treated with respect and are handled according to the provisions of the Native American Grave 

Protection and Repatriation Act and Nevada Revised Statute 383 in accordance with Stipulation VIII of the 

Programmatic Agreement. 

C.3.4 Paleontological Resources 

Standard Operating Procedures that apply to paleontological resources are in BLM Manual 8270, Paleontological 

Resource Management, and BLM Handbook H-8270-1, General Procedural Guidance for Paleontological Resource 

Management (USDOI BLM 2008b, c). 

If it is the opinion of the authorized officer that particular treatment areas may contain valuable fossil resources that 

may be placed at risk by invasive treatments, then paleontological surveys will be conducted by a BLM-permitted 

paleontologist. Paleontological surveys would assess the potential for valuable resources to be present by using the 

Potential Fossil Yield Classification (PFYC) System. Once geologic deposits have been classified according to the 

PFYC system, and if there is a medium to high potential for valuable fossil resources to be present in a given area, 

then protective measures according to BLM rules and guidance will be implemented to protect potential fossil 

resources. Such protective measures will include, but are not limited to, the following actions: 

1. If any scientifically important fossils are found during a field survey, a program will be developed and 

implemented to remove at risk fossils prior to ground disturbing activities. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-28 October 2016 

2. Treatment areas identified as having a high potential for buried paleontological resources based upon field 

surveys will be monitored by a qualified paleontologist during ground disturbing activities. The method of 

treatment will determine the level of monitoring needed. For instance, a stream restoration that potentially 

involves substantial excavation will require more intense monitoring than other activities. 

3. Personnel will be instructed about the types of fossils they could encounter and the steps to take if fossils are 

uncovered during construction. Instruction would stress the nonrenewable nature of paleontological resources 

and that collection or excavation of fossil materials from federal land without a federal permit is illegal. 

4. Fossils recovered during the field surveys or monitoring will be prepared in accordance with standard 

professional paleontological techniques. A report on the findings of the salvage program, including a list of 

the recovered fossils, will be prepared following completion of the program. A copy of this report will 

accompany the fossils to the BLM-approved facility where they are curated. 

C.3.5 Wilderness Study Areas 

The guidance for managing each Wilderness Study Areas (WSAs) is provided in the BLM Manual 6330 

(Management of Wilderness Study Areas; USDOI BLM 2012). The general management standard is that the 

suitability of the WSAs for preservation as Wilderness must not be impaired. Additional policies for specific activities 

are provided in the manual and will be followed for the 3 Bars Project. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-29 October 2016 

C.4 References 

Connelly, J.W., M.A. Schroeder, A.R. Sands, and C.E. Braun. 2000. Guidelines to Manage Sage Grouse Populations 

and Their Habitats. Wildlife Society Bulletin 28:967-985.

Herron, G.B., C.A. Mortimore, and M.S. Rawlings. 1985. Nevada Raptors: Their Biology and Management. Nevada 

Department of Wildlife Biological Bulletin No. 8. Reno, Nevada. 

Nevada Division of Environmental Protection. 2008. Nevada Contractors Field Guide for Construction Site Best 

Management Practices. Bureau of Water Quality Planning, Carson City, Nevada. Available at URL: 

http://ndep.nv.gov/bwqp/bmp05.htm. 

Romin, L.A., and J.A. Muck. 1999. Utah Field Office Guidelines for Raptor Protection from Human and Land Use 

Disturbances. U.S. Department of the Interior USFWS Utah Field Office, Salt Lake City. Available at URL: 

www.fws.gov/utahfieldoffice/Documents/MigBirds/Raptor%20Guidelines. 

USDOI BLM. 1989. BLM Manual H-1741, Renewable Resource Improvements, Practices, and Standards. 

Washington, D.C. 

USDOI BLM. 1992. Integrated Weed Management. BLM Manual Section 9015. Washington, D.C. 

USDOI BLM. 1996. Partners Against Weeds: An Action Plan for the Bureau of Land Management. Washington, 

D.C. 

USDOI BLM. 2004a. BLM Manual 8120 - Tribal Consultation under Cultural Resource Authorities. Washington, 

D.C. 

USDOI BLM 2004b. Handbook H-8120-1, General Procedural Guidance for Native American Consultation: 

Guidelines for Conducting Tribal Consultation. Washington, D.C. 

USDOI BLM. 2007a. Final Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Impact Statement. Reno, Nevada. 

USDOI BLM. 2007b. Final Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Report. Reno, Nevada. 

USDOI BLM. 2007c. Handbook H-1742-1, Burned Area Emergency Stabilization and Rehabilitation. Washington, 

D.C. 

USDOI BLM. 2008a. Special Status Species Management. Washington, D.C. 

USDOI BLM. 2008b. Manual 8270, Paleontological Resource Management. Washington, D.C. 

USDOI BLM. 2008c. Handbook H-8270-1 General Procedural Guidance for Paleontological Resource Management. 

Washington, D.C. 

USDOI BLM. 2009. Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field Office and 

Tonopah Field Office. Battle Mountain District, Battle Mountain, Nevada. 
STANDARD OPERATING PROCEDURES 

3 Bars Project Final EIS C-30 October 2016 

USDOI BLM. 2012. Manual 6330 Management of Wilderness Study Areas (Public). Release 9-935. Washington, 

D.C. 

USDOI BLM. 2013. Draft Wildlife Survey Protocols BLM Nevada. Reno, Nevada. 

USDOI BLM 2015. Nevada and Northeastern California Greater Sage-Grouse Approved Resource Management Plan 

Amendment (ARMPA). September 2015. 

Whittington, D.M., and G.T. Allen. 2008. Guidelines for Raptor Conservation in the Western United States. U.S. Fish 

and Wildlife Service Region 9, Division of Migratory Bird Management, Washington, D.C. 

Wyoming Game and Fish Department. 2010. Protocols for Treating Sagebrush to Benefit Sage Grouse (11-29-2010). 

Cheyenne, Wyoming. 

Zeedyk, B., and J. Jansens. 2006. An Introduction to Erosion Control. Earth Works Institute, The Quivira Coalition, 

and Zeedyk Ecological Consulting. Second Edition. Santa Fe, New Mexico. Available at URL: 

http://quiviracoalition.org/Publications/Publications_for_Download/index.html. 
APPENDIX D 

RESPONSE TO PUBLIC COMMENTS ON 

THE DRAFT EIS 
This page left blank intentionally.
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-1 October 2016 

APPENDIX D 

RESPONSE TO PUBLIC COMMENTS ON 

THE DRAFT EIS 

D.1 Introduction 

This chapter provides a summary of the public and agency comments that were received on the 3 Bars Ecosystem and 

Landscape Restoration Project Draft Environmental Impact Statement (Draft EIS) and responses to those comments. 

Additional information about the public comment period can be found in Chapter 4 of the Final EIS. 

D.2 Comment Response Process 

All comments were reviewed and organized so that an objective analysis and presentation of the comments could be 

made. Comment letters were assigned tracking numbers and entered into a database. All comments received on the 

Draft EIS documents are included in the Administrative Record. 

The project interdisciplinary team reviewed all comments. Per guidance in the U.S. Department of the Interior 

(USDOI), Bureau of Land Management (BLM), National Environmental Policy Act Handbook H-1790-1 (USDOI 

BLM 2008), a comment was deemed substantive and received a specific response if it 1) questioned, with reasonable 

basis, the accuracy of information in the EIS; 2) questioned, with reasonable basis, the adequacy of, methodology for, 

or assumptions used for the environmental analysis; 3) presented new information relevant to the analysis; 4) 

presented reasonable alternatives other than those analyzed in the EIS; or 5) caused changes for revisions in one or 

more of the alternatives. Each individual communication was assigned a number and each substantive comment was 

identified within a comment response database. Substantive comments were identified and responded to in this 

chapter (see Section D.5). Comments deemed non-substantive were also evaluated and any resulting issues are 

summarized below in Section D.4. Non-substantive comments included opinions in favor or against the project or an 

alternative and communications that expressed an opinion about the project. Non-substantive comments were 

recorded, but no response is included in the summary in Section D.4. The original letters and emails and a copy of the 

comment response database output have been entered into the Administrative Record and copies of unique letters are 

included at the end of this Appendix in Section D.8.

D.3 Quantitative Analysis of Comments Received 

D.3.1 Summary of Comments Received on the Draft EIS and the Response 

Process 

Approximately 6,819 email communications were received on the Draft EIS. Of these, approximately 6,530 reflected 

the views of, and closely mirrored language suggested by, members and other interested persons associated with the 

American Wild Horse Preservation Campaign; numerous individuals submitted their comment more than once. Each 

of the comment letters and emails was read and substantive and non-substantive issues were identified. Substantive 

comments were collated and responded to by the project team. Substantive comments and the project team’s 
INTRODUCTION AND SUMMARY OF ISSUES

3 Bars Project Final EIS D-2 October 2016 

responses are provided in Section D.5. A petition style email that was submitted by American Wild Horse 

Preservation Campaign and its member/interested individuals included several substantive comments. This letter was 

included in the comment review as a single response, even though it was submitted by over 6,500 individuals. 

D.3.2 Public Meetings and Oral Comments 

A public meeting was held at the Eureka Opera House, Eureka, Nevada, on November 7, 2013. The meeting started 

with an informal open house to encourage open dialogue between the project team and members of the public. BLM 

staff members were available to answer questions. Posters describing the project were displayed, and copies of the 

Draft EIS were available for the public to review and take with them. The public was also provided with a mail-in 

comment form and an email address for submitting comments. BLM staff presented a PowerPoint presentation that 

explained the project and gave a brief summary of the contents of the Draft EIS. The presentation was followed by a 

question and answer session to allow people the opportunity to ask questions in an open forum. Three individuals, 

representing Eureka County (2) and Nevada Department of Wildlife (NDOW; 1), attended the meeting, in addition to 

BLM staff and contractor representatives. No oral comments were taken at the meeting. 

D.3.3 Comments by Affiliation 

Table D-1 presents a breakdown of the affiliation of comments received (where the author stated an affiliation). 

Agency comments were received from the U.S. Environmental Protection Agency, USDOI National Park Service, 

NDOW, and Eureka County Board of Commissioners. Two non-government organizations, American Wild Horse 

Preservation Campaign and Western Watersheds Project, provided comments. In addition, 14 individuals provided 

unique comment letters, while about 6,530 individuals provided comments similar to those of the American Wild 

Horse Preservation Campaign through a mass mailing. The names of individuals providing comments are provided in 

Section D.7. Copies of agency and public letters are provided in Section D.6. 

TABLE D-1 

Affiliation of Commenters on the Draft EIS 

Affiliation Number of Comments Received

Federal Agencies 2

State Agencies 1

Local Agencies 1

Non-government Organizations 2

Individuals 6,544

D.4 Summary of Issues Identified in Non-substantive Comments 

The majority of non-substantive comments were summaries of text given in the Draft EIS; opinions on the 

appropriateness of the treatments, treatment areas, and methods given in the Draft EIS to restore the health of the 

landscape; and opinions on the need to protect Special Status Species, springs and other water sources, pinyonjuniper, and other resources on the 3 Bars Project area. Other non-substantive comments included: 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-3 October 2016 

 Livestock industry experts were the source for information in the Draft EIS. 

 The ownership of the Mount Hope Project bought public lands with grazing permits to acquire water rights 

and deflect rancher concerns. 

 The BLM needs to reduce the number of livestock grazing on the 3 Bars Project area. 

 The BLM wasted public money in developing the Draft EIS. 

 The BLM doesn’t know what it is doing.

 The BLM is really trying to make the 3 Bars ecosystem unnatural and unbalanced. 

 The BLM plans to use the 3 Bars Project area for toxic waste incineration. 

 The BLM needs to reconsider further land sales. 

D.5 Summary of Issues Identified in Substantive Comments 

This section provides substantive comments received on the Draft EIS, followed by the BLM’s responses to those 

comments. The comments were organized into 23 main topic areas. Table D-2 lists where specific comment topics 

were addressed in the Comment Summary. Text has been added to some comments to help clarify the comment; this 

text is included in brackets [ ]. Each comment letter provided in Section D-8 that included substantive comments is 

given a unique document and comment number (e.g., 4-1) to allow the reader to cross-reference comments and 

comment responses given below to the comment letter. The full citations for documents referenced in BLM responses 

are given in Section D-8. 

TABLE D-2 

Summary of Comment Topics and Where Addressed in this Appendix 

Topic Page Number

Air Quality D-5

Alternatives D-7

Assessment Methodology D-12

Cumulative Effects D-19

Fish and other Aquatic Resources D-23

Glossary D-26

Livestock Grazing D-27

Meteorology and Climate Change D-34

Mitigation and Monitoring D-35

Native and Non-invasive Vegetation Resources D-37

Noxious Weeds and other Invasive Non-native Vegetation D-55

Proposed Action and Purpose and Need D-57

Recreation D-61

Social and Economic Values and Environmental Justice D-62

Soil Resources D-62

Standard Operating Procedures D-66

Vegetation Treatments Planning and Management D-68

Water Resources D-85

Wetlands, Floodplains, and Riparian Zones D-90
INTRODUCTION AND SUMMARY OF ISSUES

TABLE D-2 (Cont.) 

Summary of Comment Topics and Where Addressed in this Appendix 

3 Bars Project Final EIS D-4 October 2016 

Topic Page Number

Wilderness Study Areas and other Special Management Areas D-92

Wild Horses D-93

Wildland Fire and Fire Management D-98

Wildlife Resources D-106
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-5 October 2016 

D.5.1 Air Quality 

Comment No. 4-121 from Western Watersheds Project: 

Contrary to BLM’s Three [3] Bars claims - This all represents a massive release of carbon dioxide now naturally 

stored in woody and other vegetation into the atmosphere. It represents significant loss and destruction of soil (that 

will erode in wind and spur early snowmelt and other adverse climate change amplifying impacts, microbiotic crusts 

(that sequester carbon, stabilize soils, and help retain moisture on-site). 

Response to Comment No. 4-121: 

As discussed under Environmental Consequences in Final EIS Sections 3.5 (Meteorology and Climate Change) and 

3.6 (Air Quality), modeling was done to estimate carbon dioxide emissions, including emissions from prescribed fire. 

Based on modeling, carbon dioxide emissions would be insignificant when compared to other carbon dioxide 

emissions in Nevada, and that use of prescribed fire would reduce the likelihood of wildfire, especially large-scale 

wildfire. In a modeling study by Wiedinmyer and Hurteau (2010) that evaluated the use of prescribed fire as a means 

of reducing forest carbon emissions, they found that carbon dioxide fire emissions could be reduced by 18 to 25 

percent in the western U.S., and by as much as 60 percent in some forest systems, by using prescribed fire as 

prescribed burns typically release substantially less carbon dioxide emissions than wildfires of the same size. The 

Association of Fire Ecology and others (2013) noted that prescribed fires can be used to reduce the risk of wildfire 

and help to promote a stable and resilient ecosystem and long-term carbon sequestration. This information has been 

included in Section 3.5.3 (Meteorology and Climate Change, Environmental Effects) of the Final EIS. 

3 Bars Project EIS Final Section 3.9 (Soil Resources) discusses the potential for short-term loss and alteration of soils 

due to prescribed fire and other treatment methods. It identifies areas where 3 Bars lands are susceptible to fire 

damage (see Figure 3-19); the BLM would limit use of prescribed fire in highly susceptible areas where feasible. As 

discussed in Section 3.9.3 (Soil Resources, Environmental Consequences) of the Final EIS, however, prescribed fires 

generally have fewer impacts on soils than wildfires. Reducing the incidence and severity of wildfires is an important 

long-term goal of 3 Bars Project treatments and would result in improved soil function in treated areas long-term, as 

noted in Section 3.9.3.3.1 under Beneficial Impacts and elsewhere in Section 3.9 of the Final EIS. 

Comment No. 4-131 from Western Watersheds Project: 

Dioxins are an insidious risk. The D[raft] EIS does not assess potential dioxin pollution from burning biomass. 

Response to Comment No. 4-131: 

Dioxins are a by-product of biomass combustion from wildfire and prescribed fire (Gullett and Touati 2003) and can 

be harmful to human health (World Health Organization 2014). The American Chemistry Council (2005) and U.S. 

Environmental Protection Agency (2013) found that wildfires are the largest source of dioxin emissions in the U.S. 

These studies are discussed Section 3.6 of the Final EIS. A primary goal of the 3 Bars Project is to reduce the 

incidence of wildfire through use of a combination of treatment methods, including prescribed fire. Although 

prescribed fire treatments may lead to a short-term increase in dioxin emissions, treatments should improve the health 

and resiliency of vegetation and result in a long-term reduction in wildfire incidence and dioxin emissions. 
AIR QUALITY

3 Bars Project Final EIS D-6 October 2016 

Comment No. 4-163 from Western Watersheds Project: 

Alt[ernative] C effects are not similar to Alt[ernative] A for Air Quality. D[raft] EIS claims at 3.5.3.4.3 are false. 

BLM cavalierly proposes no mitigation measures for air quality. BLM also ignores adverse impacts of wind erosion 

and dust deposition, the degree to which climate change will amplify risks of cheatgrass dominating treatments 

(especially since the D[raft] EIS fails to control livestock grazing impacts across the treated watersheds, and relies on 

vague promises of some future livestock actions. 

Response to Comment No. 4-163: 

As discussed in Final EIS Section 3.6.3.4.3, Air Quality, Environmental Consequences, Cumulative Effects, 

Cumulative Effects under Alternative C, non-3 Bars Project reasonably foreseeable future actions on air quality would 

be similar to those described under Alternative A. This is because reasonably foreseeable future actions that are not 

associated with the 3 Bars Project are reasonably likely to occur under all alternatives. Thus, emissions associated 

with these actions should be similar under all alternatives. The BLM has identified numerous Standard Operating 

Procedures (SOPs) in Appendix D of the Final EIS to minimize 3 Bars Project-related air emissions. Because air 

emissions from the 3 Bars Project are negligible and are not likely to meet or exceed the significance criteria given in 

Final EIS Section 3.6.3.2, no additional mitigation measures to reduce air emissions are proposed.

The BLM discusses the potential for wind erosion and dust deposition associated with treatments to contribute to air 

quality impacts in Final EIS Section 3.6.3.3, Air Quality, Environmental Consequences, Direct and Indirect Effects, 

and more specifically in Table 3-5. Although it is difficult to determine the effects of climate change on cheatgrass 

incidence in the 3 Bars Project area within the project timeframe, 3 Bars Project actions would help to reduce the 

incidence of cheatgrass within the 3 Bars Project area, and reduce the potential for wildfire occurrence in areas 

currently dominated by cheatgrass and in other vegetation types (e.g., decadent and diseased pinyon-juniper). 

Treatments would reduce long-term air quality impacts associated with degraded landscapes, as discussed in Section 

3.6.3.3.2 of the Final EIS. 

Comment No. 4-177 from Western Watersheds Project: 

BLM must assess the amount of dust that is attributable to livestock disturbance, loss and degradation of microbiotic 

crusts, etc. 

Response to Comment No. 4-177:

As discussed under Comment 4-163 (Air Quality – Environmental Consequences), 3 Bars Project treatments would 

result in dust emissions. As discussed under Final EIS Section 3.9.3.3, Soil Resources, Environmental Consequences, 

Sagebrush Treatments, treatments could impact biological soil crusts, although biological soil crusts are not likely to 

be well developed in areas dominated by non-native vegetation. It would be very difficult to determine the amount of 

dust attributed specifically to livestock disturbance and degradation of microbiotic crusts, in addition to wildfires, 

noxious weeds and other invasive non-native vegetation, and other soil-disturbing factors on the 3 Bars Project area, 

and this amount would vary widely from year-to-year. The BLM has proposed mitigation measures to minimize the 

impacts of livestock in treatment areas (see Final EIS Section 3.18.4, Livestock Grazing, Mitigation). 3 Bars Project 

actions should help to improve soil function and air quality in the 3 Bars Project area long-term. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-7 October 2016 

D.5.2 Alternatives 

Comment No. 4-24 from Western Watersheds Project: 

This demonstrates the complexity of the situation, the grave risk of severe losses under the massive disturbance of the 

Preferred Alternative, and the need for BLM to do a Supplemental EIS that analyzes a range of greatly modified 

alternatives that minimize disturbance and harm – not anything like the Preferred Alternative. 

Response to Comment No. 4-24: 

The BLM evaluated several alternatives in the Draft and Final EIS, ranging from treating about 12,700 acres annually 

using manual and mechanical methods, biological controls, and fire (prescribed fire and wildland fire for resource 

benefit) under Alternative A, to action alternatives that use fewer methods and treat less acreage to minimize shortterm impacts and disturbance to the environment (Alternatives B and C), to the No Action Alternative, under which 

no new treatments would be authorized. These treatment alternatives provide a reasonable range of disturbance 

actions that would result in short- and long-term impacts to the landscape, and these actions and impacts are evaluated 

in the Final EIS. 

Comment No. 4-31 from Western Watersheds Project: 

A very viable alternative treatment method here, that can be coupled with selective active restoration such as hand 

cutting, is retirement of the public lands grazing permits the mine acquired. Please provide mapping and analysis of 

these permits. What allotments are these? How much land area do they cover? What are the values, sensitive species, 

HMAs [Herd Management Areas] etc. in lands grazed under these permits? BLM should prepare a Supplemental EIS 

to assess a new and greatly expanded range of alternatives, including this. 

Response to Comment No. 4-31:

Prior to any treatment, appropriate livestock management would be in place. If the treatment is determined to be 

appropriate, livestock grazing permits would be evaluated under the Rangeland Health Evaluation/Permit renewal 

process. The evaluation would be separate from the 3 Bars Project and would occur prior to any 3 Bars Project 

treatments occurring in any given area. 

Comment No. 4-34 from Western Watersheds Project:

BLM has failed to assess a broad range of alternatives under NEPA [the National Environmental Policy Act]. 

Response to Comment No. 4-34: 

See response to Comment 4-24 (Alternatives). 

Comment No. 4-39 from Western Watersheds Project: 

 It [The BLM] has not considered a reasonable range of passive and some active restoration actions. 
ALTERNATIVES

3 Bars Project Final EIS D-8 October 2016 

Response to Comment No. 4-39:

As discussed under Comment 4-24 (Alternatives), the BLM considered a reasonable range of alternatives that differed 

in treatment methods used and acres treated. As discussed in Final EIS Section 2.7 (Alternatives Considered but not 

Further Analyzed), a “passive restoration and use only treatments having minimal land disturbance” alternative was 

considered but not further analyzed in the Draft and Final EIS. This alternative was eliminated because it does not 

meet the purpose for the project as stated in Section 1.5 (Purposes for the Project). Specifically, this alternative would 

not control the spread of unwanted vegetation or improve the health of the vegetation communities within the 3 Bars 

ecosystem, and it would prohibit some human-related activities allowed under the Federal Land Policy and 

Management Act. The use of treatment methods that would result in minimal disturbance to the landscape were 

evaluated under Alternative C (Minimal Land Disturbance Alternative). 

Comment No. 4-64 from Western Watersheds Project: 

Why is BLM not then addressing all livestock grazing disturbance across this landscape up front, long before issuing 

a massive treatment EIS with a bioengineering Preferred Alternative?–instead of avoiding dealing with problem 

grazing areas? 

Response to Comment No. 4-64:

Long- term changes in authorized livestock grazing will be conducted under the Rangeland Health Evaluation/Permit 

renewal process, separate from this effort and prior to treatments in any given area. Short-term grazing closures can be 

used post-treatment to help meet the treatment objectives. Unless related to mitigation for specific treatment 

proposals, evaluation of livestock grazing permits is outside the scope of this project. 

Comment No. 4-83 from Western Watersheds Project: 

It is critical in a restoration EIS to address and take a science-based hard look at passive as well as active restoration 

measures. 

Response to Comment No. 4-83:

As discussed under Comment 4-39 (Alternatives), the BLM evaluated a reasonable range of treatment alternatives, 

including Alternative C, the Minimal Land Disturbance Alternative. Under this alternative, the BLM would treat only 

about 3,175 acres annually, and would only use manual and classical biological control (use of nematodes, fungi, 

mites, and insects) methods; use of livestock for biological control would not be allowed. The BLM would also not

use mechanical methods or fire. This alternative was developed in response to the proposed “passive restoration and 

use only treatments having minimal land disturbance alternative,” which was submitted during public scoping and is 

discussed in Final EIS Section 2.7, Alternatives Considered but not Further Analyzed. The direct, indirect, and 

cumulative effects of passive and active restoration measures are assessed under Alternative C for resource areas 

evaluated in the EIS. 

Comment No. 4-113 from Western Watersheds Project: 

BLM ignores a full and fair analysis of passive restoration. As we earlier described, BLM claims that larger acres just 

can’t be treated by hand cutting. This is simply not the case. There are millions of people needing jobs in this country. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-9 October 2016 

So instead of paying wealthy contractors for feller bunchers, crushers, tree shearers, choppers, bulldozers, etc. BLM 

can readily and feasibly hire crews to hand cut trees – greatly minimizing weed risk, damage to habitats, damage to 

sagebrush, damage to mature and old growth trees, etc. 

Response to Comment No. 4-113:

As discussed under Comment 4-39 (Alternatives), the BLM evaluated a reasonable range of treatment alternatives, 

including Alternative C, the Minimal Land Disturbance Alternative. Under this alternative, the BLM would treat only 

about 3,175 acres annually, and would only use manual and classical biological control (use of nematodes, fungi, 

mites, and insects) methods; use of livestock for biological control would not be allowed. Potentially, an unlimited 

number of acres could be treated by hand cutting if treatment funding was unlimited. However, funding for 3 Bars 

Project treatments would be limited, and as discussed in Final EIS Section 3.25.3.3, Socioeconomics, Environmental 

Consequences, Direct and Indirect Effects, the costs per acre of treatment would be greater under Alternative C than 

under Alternatives A and B. This reflects, in part, the higher expenditures associated with manual and classical 

biological control treatments, which generally cost 3 to 5 times or more per acre to implement than do fire and 

mechanical treatments (also see Table 3-73; Estimated Treatment Costs per Acre). However, as noted by the 

commenter, mechanical and fire treatments can have greater short-term impacts than manual and classical biological 

control treatments. As noted in Section 2.2, Summary of Major Changes between the Draft and Final EIS, the BLM 

has made modifications to proposed treatments based on public input. These include using manual treatments to 

remove most, if not all, pinyon-juniper in riparian and aspen treatment units; Phase I pinyon-juniper in pinyon-juniper 

treatment units; and Phase I and II, and often Phase III pinyon-juniper in sagebrush treatment units. The BLM also 

would not use chaining to treat vegetation. 

Comment No. 4-134 from Western Watersheds Project: 

Why is it so imperative to treat 1,000 acres in Pete Hanson Creek, for example, under one alternative and 200 acres 

under another? WHY should two alternatives – A, and B, almost always entail the same battery of roller choppers, 

feller bunchers tree shearers, bull hogs, seeding, chaining mowing and activity fuel dispersal (biomass utilization, 

chipping, pile burn, broadcast burn and leave onsite). 

Response to Comment No. 4-134:

As discussed under Comment 4-39 (Alternatives), the BLM evaluated a reasonable range of treatment alternatives. 

Under Alternative A, the BLM would be able to use manual and mechanical methods, biological control, and fire 

(prescribed fire and wildland fire for resource benefit), while under Alternative B the BLM would use the same 

methods, except fire. Fire and mechanical treatments would not be allowed under Alternative C. Because mechanical 

methods could be used under Alternatives A and B, the effects of mechanical treatments are discussed for these two

alternatives. As noted under Comment 4-113 (Alternatives), manual and classical biological control treatments cost 3 

to 5 times or more per acre to implement than do fire and mechanical treatments. Assuming a similar amount of 

funding for treatment projects under each alternative, the amount of acreage treated under Alternative C would be 

about one-fourth the acreage treated under Alternative A. About one-half of the acreage that would be treated using 

fire under Alternative A would not be treated under Alternative B. 
ALTERNATIVES

3 Bars Project Final EIS D-10 October 2016 

Comment No. 4-135 from Western Watersheds Project: 

The only difference is acres in pre-selected land areas. These concerns apply to all Units in Table 2-3 and the EIS. 

BLM is merely going through the NEPA motions of shuffling some things around in order to try to pass muster on 

NEPA. It has not selected a reasonable range of alternatives in this fragile, arid, weed-prone landscape. 

Response to Comment No. 4-135:

As discussed in Final EIS Section 2.1, Alternatives, Introduction, four alternatives are evaluated in the EIS—the All 

Treatment Methods Alternative (Alternative A; Preferred Alternative); the No Fire Use Alternative (Alternative B); 

the Minimal Land Disturbance Alternative (Alternative C); and the No Action Alternative (Alternative D; Continue 

Current Management). Alternative actions are those that could be taken to feasibly attain the BLM’s objectives for 

improving the health of, and reducing risks to, the 3 Bars ecosystem. The alternatives differ primarily in the types of 

treatment methods allowed and the amount of acreage that can reasonably be treated over the life of the project. For 

the Final EIS, the BLM has removed Tables 2-1 to 2-4 that were found in the Draft EIS, and replaced them with text 

descriptions of the types of activities that would be conducted for each treatment unit, including estimated acres 

treated and methods used. About half of the acres treated under Alternative A would involve the use of fire; this 

acreage would not be treated under Alternative B. The BLM estimated that only about one-fourth as many acres 

would be treated under Alternative C as compared to Alternative A. 

Comment No. 4-149 from Western Watersheds Project: 

BLM arbitrarily rejected the passive restoration alternative elements combined with hand cutting. Yet, BLM claims 

that this EIS was to address livestock grazing as well. Significantly reducing and/or removing livestock disturbance 

from watersheds so that weed risk can be minimized and recovery of native understories and microbiotic crusts can 

occur is reasonable passive restoration - especially when some permits are held by the mine that is poised to drain the 

aquifer further. 

Response to Comment No. 4-149:

See response to Comment 4-39 (Alternatives). 

Comment No. 4-154 from Western Watersheds Project: 

BLM also makes reasonable alternatives sound like extremes – by suggesting a passive restoration alternative would 

be a complete ban on logging, grazing, etc. BLM has constructed an alternative it will never choose, instead of a 

reasonable range of passive actions (reductions in livestock, introduction of beaver, much more stringent controls on 

livestock use) and minimally disturbing active restoration such as hand cutting, fence removal, carefully stabilizing 

some headcuts with small rocks without the use of heavy equipment, etc. 

Response to Comment No. 4-154:

As discussed under Comment 4-39 (Alternatives), the BLM evaluated a reasonable range of treatment alternatives, 

including Alternative C, Minimal Land Disturbance Alternative. As discussed in Final EIS Section 2.7 (Alternatives 

Considered but not Further Analyzed), a “passive restoration and use only treatments having minimal land 

disturbance” alternative was considered but not further analyzed in the 3 Bars Project EIS. This alternative was
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-11 October 2016 

eliminated because it did not meet the purpose for the project, as described in Final EIS Section 1.5 (Purposes for the 

Project), and because it would not control the spread of unwanted vegetation or improve the health of the 3 Bars 

ecosystem. Additionally, it would prohibit some human-related activities allowed under the Federal Land Policy and 

Management Act. 

The text in Final EIS Section 2.7 (Alternatives Considered but not further Analyzed) has been revised to state that “... 

passive restoration and use only treatments having minimal land disturbance alternative. Under this alternative, the 

BLM could reduce or eliminate human-related activities, an important objective of passive restoration, and use only 

treatments having minimal land disturbance, to reduce the effects of activities on the landscape that contribute to 

resource impacts, such as grazing, timber harvest, and mining.” As discussed in the Final Scoping Report 3 Bars 

Ecosystem and Landscape Restoration Project (AECOM 2010), several scoping comments from the public suggested 

that the BLM eliminate grazing and remove livestock from areas without significant components of cheatgrass and 

other weeds (see Table 3 of Scoping Report and Table 5-1 in Final EIS Chapter 1, Proposed Action and Purpose and 

Need). 

The use of treatment methods that would result in minimal disturbance to the landscape are being evaluated under 

Alternative C (Minimal Land Disturbance Alternative). Under Alternative C, fire and mechanical treatment methods, 

and use of livestock for biological control, would not be allowed. The BLM would rely mostly on manual methods, 

such as hand cutting, for vegetation removal. Riparian restoration treatments would involve the use of manual 

methods such as hand placement of rocks; heavy equipment would not be used to stabilize headcuts or other stream 

restoration activities. Fencing would only be used on a temporary basis to protect treatment areas from livestock, wild 

horses, and other wild ungulates. As noted in Final EIS Section 3.17.3.4, Wild Horses, Environmental Consequences, 

Cumulative Effects, fence removal is a long-term goal to help manage wild horses. In addition, under all alternatives, 

the BLM would implement livestock grazing management to ensure treatment success (also see Mitigation in Final 

EIS Section 3.18.4, Livestock Grazing, Mitigation). 

Comment No. 4-229 from Western Watersheds Project: 

Alternative C would not restore fire as an integral part of the ecosystem, reduce the risk of a large-scale wildfire, or 

reduce extreme, very high, and high wildfire risks to moderate risk or less. Only about 500 to 1,000 acres would be 

treated annually to reduce hazardous fuels, and the BLM estimates that the FRCC would be reduced on only about 

3,750 to 7,500 acres over the next 10 to 15 years, fewer acres than under Alternatives A and B. Where is the scientific 

basis for discounting this? It would minimize flammable weeds. It would maximize retaining snow and rain on-site - 

resulting in a shorter fire season. We have often seen BLM claim any tree cutting reduces fire. This is yet another an 

illustration of the bias of the EIS. 

Response to Comment No. 4-229:

There are two parts to this answer. First, no use of fire for resource benefit would be authorized under Alternative C 

and thus the BLM would suppress all wildfires that occur, and not allow any wildfires to play a natural role in the 

ecosystem. Second, fewer acres treated equates to fewer acres that can be moved to a better (lower) Fire Regime 

Condition Class (FRCC) through management actions. This would result in conditions that are less favorable to the 3 

Bars ecosystem than allowing wildfires to play a natural role in the ecosystem in the future. 
ALTERNATIVES

3 Bars Project Final EIS D-12 October 2016 

Comment No. 4-238 from Western Watersheds Project: 

BLM constantly unfairly tries to downplay the benefits of Alternative C, and appears to have purposefully excluded a 

series of passive restoration actions and some active restoration from Alt[ernative] C. For example, eradicating the 

forage kochia and crested wheatgrass, and planting sagebrush and native grasses should be part of Alt [ernative] C.

Response to Comment No. 4-238

As discussed under Comment 4-135 (Alternatives), and Final EIS Chapter 2.3 (Description of the Action 

Alternatives), the alternatives differ primarily in the types of treatment methods allowed and the amount of acreage 

that can reasonably be treated over the life of the project. Proposed treatment units could be treated under any of the 

action alternatives, including Alternative C, Minimal Land Disturbance Alternative; only the methods used and acres 

treated vary among action alternatives. Thus, the BLM could remove forage kochia and crested wheatgrass and plant 

sagebrush and native grasses, as long as only manual and classical biological control methods are used, for treatments 

under Alternative C. 

D.5.3 Assessment Methodology 

D.5.3.1 Assessment Methodology – Baseline Studies 

Comment No. 4-77 from Western Watersheds Project: 

Improve woodland, rangeland, and riparian health, productivity, and functionality. Then where is the baseline data 

on to what degree is livestock grazing impairing these values? Mining? Geothermal activity? 

Response to Comment No. 4-77:

The Final Assessment of Existing and Current Conditions for the Proposed 3 Bars Ecosystem and Landscape 

Restoration Project EIS (USDOI BLM 2009a) and Landscape Restoration Project Rangeland Health Report (Eastern 

Nevada Landscape Coalition and AECOM 2012), were prepared to show rangeland conditions on the 3 Bars Project 

area based on field studies. Based on these reports, and discussion of rangeland conditions that is provided in Final 

EIS Section 3.12.2.3 (Native and Non-invasive Vegetation Resources, Allotment Vegetation and Monitoring Studies), 

and Figure 3-29 (Current Rangeland Conditions) was prepared to show current rangeland conditions. As discussed 

under Cumulative Effects for each resource section in the EIS, numerous factors, including livestock management, 

wild horse use, noxious weeds and other invasive non-native vegetation, mining and other land uses, and wildfire 

have contributed to current rangeland conditions. 

Comment No. 4-97 from Western Watersheds Project: 

BLM fails to provide necessary site-specific information on wild horse and wildlife use of this landscape so that the 

differential impacts of the massive habitat loss and disturbance to be imposed can be understood. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-13 October 2016 

Response to Comment No. 4-97:

Wildlife use of the 3 Bars Project area is discussed in Final EIS Section 3.16.2, Wildlife Resources, Affected 

Environment. Wild Horse use of the 3 Bars Project area is discussed in Final EIS Section 3.17.2, Wild Horses, 

Affected Environment. 

Comment No. 4-148 from Western Watersheds Project: 

BLM fails to adequately describe the present situation. It cannot rely on the ENLC [Eastern Nevada Landscape 

Coalition] information, or NRCS [Natural Resources Conservation Service] Ecosites [Ecological Site Descriptions] 

and state and transition and FRCC and other models that are based on inaccurate much too abbreviated disturbance 

intervals and other inaccurate assumptions. 

Response to Comment No. 4-148:

The BLM has collected a substantial amount of information regarding species occurrence, rangeland health, and other 

resource conditions on the 3 Bars Project area. Much of this information is provided in the Final Assessment of 

Existing and Current Conditions for the Proposed 3 Bars Ecosystem and Landscape Restoration Project EIS (USDOI 

BLM 2009a). This document describes the conditions of most resources discussed in the EIS, rangeland health, and 

areas in need of treatment. A draft copy of this document was provided to the public during public scoping. Many of 

the resources found on the 3 Bars Project area were surveyed for the Mount Hope Project EIS. The results of these 

studies are provided in the Mount Hope Project Final EIS, which is available at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/national_environmental/mount_hope_project

0.html. In addition, several studies were conducted for the 3 Bars Project EIS, including vegetation and rangeland 

health studies. These are discussed in Section 1.3, Background, and in Section 3.12, Native and Non-invasive 

Vegetation Resources, of the 3 Bars Project Final EIS. Numerous assessments of plant and animal sensitive species 

were conducted for the Mount Hope Mine Project EIS. These are discussed under the Affected Environment section 

of Sections 3.15 (Fish and other Aquatic Resources) and 3.16 (Wildlife Resources) for the 3 Bars Project Final EIS. 

Thus, the BLM relied on multiple sources of information to describe the baseline conditions on the 3 Bars Project 

area, and relied upon studies where data were accurately collected and without bias. Except for air quality analysis, 

the BLM did not conduct modeling to assess baseline conditions and treatment effects for the 3 Bars Project EIS. The 

BLM did rely upon modeling conducted by other resource agencies to describe historic, current, and reasonably 

foreseeable future conditions. Although no model is perfect, modeling used in support of the 3 Bars Project was based 

on scientifically peer reviewed studies, assumptions, and analyses, and were judged to be reflective of past, present, 

and future conditions based on the current state-of-the-science. 

Comment No. 4-160 from Western Watersheds Project: 

Preparation of a Supplemental EIS that is based on systematically collected baseline data that takes into account the 

full habitat needs of a broad range of sensitive species. 

Response to Comment No. 4-160:

See response to Comment 4-148 (Assessment Methodology - Baseline Studies). 
ASSESSMENT METHODOLOGY

3 Bars Project Final EIS D-14 October 2016 

Comment No. 4-169 from Western Watersheds Project: 

[The BLM] has not conducted the necessary site-specific analysis to understand sensitive species occurrence and 

threats across this landscape, vulnerability of lands to loss of intermittent and perennial flows from individual and 

combined disturbance effects, etc. 

Response to Comment No. 4-169:

See response to Comment 4-148 (Assessment Methodology – Baseline Studies). Extensive analysis and modeling of 

water surface and groundwater flows were done for the Mount Hope Project EIS, and were used during preparation of 

the 3 Bars Project EIS, as discussed in Final EIS Section 3.10, Water Resources. The results of these studies are 

provided in the Mount Hope Project Final EIS, which is available at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/national_environmental/mount_hope_project

0.html. 

Comment No. 4-192 from Western Watersheds Project: 

BLM simply cannot rely on the [17-States] PER report – as no NEPA at all was ever conducted on the [17- States] 

PER. 

Response to Comment No. 4-192:

The 3 Bars Project EIS tiers to the Record of Decision Vegetation Treatments on BLM Lands in 13 Western States 

(13-States EIS), Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western 

States Programmatic Environmental Impact Statement (17-States PEIS), and Vegetation Treatments on Bureau of 

Land Management Lands in 17 Western States Programmatic Environmental Report (17-States PER; USDOI BLM 

1991, 2007a, b), as discussed in Final EIS Section 1.9, Documents that Influence the Scope of the EIS. The 17-States 

PEIS addressed the cumulative effects from all treatment methods, and the 13-States EIS and 17-States PER 

addressed the BLM’s use of non-herbicide vegetation treatment methods, including the use of prescribed fire and 

manual, mechanical, and biological control methods, on BLM-administered lands in the western U.S., including 

Nevada. Where appropriate, information in these documents that is relevant to analysis of the current proposal is cited 

and incorporated by reference. 

The 17-States PER discloses the general impacts on the environment of using non-herbicide treatment methods, 

including fire use, and mechanical, manual and biological control methods, to treat hazardous fuels, invasive species, 

and other unwanted or competing vegetation. Non-herbicide treatment methods have been analyzed in earlier 

national, state, and local EISs, and because of this dynamic continuum of treatment, revegetation, monitoring, and 

maintenance, the BLM did not anticipate there would be any different or significant impacts identified beyond what 

has been analyzed in previous EISs that would require analysis in the 17-States PER under the NEPA. The 17-States 

PER is linked to the 17-States PEIS in the cumulative impacts analysis of the PEIS, where all methods of treatment, 

including the use of herbicides, are assessed. 

The 17-States PER provides useful information on the effects on non-herbicide vegetation treatments used by the 

BLM in the western U.S., including Nevada. The information in the 17-States PER was primarily taken from peerreviewed scientific literature and agency documents. In addition to using information from the 17-States PER, the 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-15 October 2016 

BLM used other peer-reviewed scientific literature and agency documents to prepare the 3 Bars Project EIS. About 

500 additional documents were used to develop the 3 Bars Project Final EIS, as provided in Chapter 5, References. 

D.5.3.2 Assessment Methodology – Definitions 

Comment No. 4-165 from Western Watersheds Project: 

It is unclear how long-termed is defined. 

Response to Comment No. 4-165:

For many resources, short- and long-term are defined under Environmental Consequences, Significance Criteria. 

Unless stated otherwise, long-term is generally 5 years or more, or the time needed for the beneficial effects of 

treatments to manifest themselves. 

D.5.3.3 Assessment Methodology – General 

Comment No. 4-78 from Western Watersheds Project: 

What was all baseline information used to identify Potential Natural Vegetation Communities across the project area. 

Was this based on NRCS [Natural Resources Conservation Service] Ecosites [Ecological Site Descriptions]? How did 

you vet the NRCS Ecosites? Do the NRCS Ecosites contain any PJ [pinyon-juniper] across the Three [3] Bars Project 

area? If so, where? Where are all persistent pinyon-juniper sites, as defined by Foresters? Please provide us with a 

map of these areas? Please provide the vegetation communities that were used as the ideals in the D[raft] EIS 

mapping - such as Map 1 that identifies all kinds of problems - especially in the areas where junipers are supposed to 

be growing - rugged mountainous terrain. What were the Ecosites/ideal communities/models used in the ENLC 

[Eastern Nevada Landscape Coalition] and other Veg[etation] info[rmation] in the EIS? Did these claim that junipers 

were not supposed to be present anywhere? 

Response to Comment No. 4-78:

We are not clear what “Map 1” you are referring to, as there was no “Map 1” in the Draft EIS. However, it appears 

you may be referring to a “Map 1” that was used during the public scoping meetings that identified areas in need of 

change. The map of current vegetation types given in the Draft EIS (Figure 3-26; Current Vegetation Communities) 

was based on pinyon-juniper (AECOM 2011a) and cheatgrass (AECOM 2011b) field studies conducted for the 3 Bars 

Project, and U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (2012) vegetation 

mapping. The map of potential vegetation (Figure 3-26; Major Vegetation Communities in the 3 Bars Project Area 

based on Ecological Site Data) was based on mapping done by the USDA Natural Resources Conservation Service 

(2012) and based on Ecological Site Descriptions developed for the 3 Bars Project area, as discussed in Section 

3.12.2.2, Native and Non-invasive Vegetation Resources, Vegetation Communities, of the Final EIS. We did not 

“vet” the data and methodology used by the USDA Natural Resources Conservation Service (2012), as we relied 

upon agency scientists to do this. More information on how the USDA Natural Resources Conservation Service 

developed the Ecological Site Descriptions can be found at URL: https://esis.sc.egov.usda.gov/. Another good source 

of information is Chapter 3 in the BLM Technical Reference 1734-7, Ecological Site Inventory (Habich 2001). 
ASSESSMENT METHODOLOGY

3 Bars Project Final EIS D-16 October 2016 

As shown on Table 3-22 (Current and Expected Vegetation Types within the 3 Bars Project Area), pinyon-juniper 

comprises about 25 percent of the vegetation on the 3 Bars Project area; other vegetation types mapped during the 

study are also shown on this table and on Figures 3-25 and 3-26. The locations of pinyon-juniper by phase classes are 

shown on Figure 3-27 (Pinyon-juniper Phase Classes), including old-growth stands. These older stands and most 

Phase III stands tend to be found in more remote, rugged areas of the 3 Bars Project area. As discussed in Section 

3.12.2.3, Native Vegetation and Non-invasive Vegetation Resources, Allotment Vegetation and Monitoring Studies, 

of the Final EIS, Eastern Nevada Landscape Coalition collected rangeland health data by evaluating rangeland 

conditions at Key Management Areas throughout the 3 Bars Project area. They measured rangeland health based on 

plant production, desired dominant species, and Potential Natural Community for grass, forb, and shrub species. A 

Potential Natural Community is defined as the biotic community that would become established on an ecological site 

if all successional sequences were completed without interference by people under the present environmental 

conditions (Habich 2001). Potential Natural Community production is based on the Ecological Site Description for 

the site. Eastern Nevada Landscape Coalition only recorded grass, forb, and shrub species to evaluate production, 

dominant species, and Potential Natural Community, and thus did not provide any “claims” as to the occurrence of 

pinyon-juniper on the 3 Bars Project area. The results of the Eastern Nevada Landscape Coalition rangeland health 

assessment are provided in the Landscape Restoration Project Rangeland Health Report (Eastern Nevada Landscape 

Coalition and AECOM 2012), which can be reviewed at the BLM Battle Mountain District Office. As shown on 

Figure 3-27, however, pinyon-juniper is common on the 3 Bars Project area. 

Comment No. 4-90 from Western Watersheds Project: 

Where are the baseline assessments of pygmy rabbit, loggerhead shrike, sage sparrow, pinyon jay, ferruginous hawk, 

etc.? We cannot find them. 

Response to Comment No. 4-90:

Baseline wildlife assessments were conducted for the Mount Hope Project and used for the 3 Bars Project EIS. This 

information and supporting references can be found on the Mount Hope Project website at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/nepa/mount_h

ope_project/mount_hope_feis.Par.83818.File.dat/Vol%202%20-%203.23.pdf. General surveys of the 3 Bars Project 

area have been conducted by the BLM, Nevada Department of Wildlife, Nevada Natural Heritage Program, and 

others and are referenced in Final EIS Section 3.16, Wildlife Resources. 

D.5.3.4 Assessment Methodology – Mapping 

Comment No. 4-108 from Western Watersheds Project: 

All of the D[raft] EIS soils, veg[etation] and other mapping is much too general to use at the site-specific scale. In 

fact, important rare and sensitive species like pygmy rabbit rely on deep soil sites which are often small inclusions in 

larger expanses of shallow soils. These inclusions support taller sage[brush] that is critical for loggerhead shrike, sage 

thrasher, gray flycatcher. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-17 October 2016 

Response to Comment No. 4-108:

The development of the 3 Bars Project EIS adheres to the intent of the Council on Environmental Quality regulations 

by following guiding principles and policies as outlined in the BLM NEPA Handbook and 40 Code of Federal 

Regulations 1500-1502. For the 3 Bars Project EIS, these included: 1) clarity of expression, logical thought processes, 

and rational explanations will be considered more important than the length or format in the discussion of impacts; 2) 

descriptions of the affected environment will be no longer than is necessary to understand the impacts of the 

alternatives; 3) the length of the EIS will be kept to a minimum by incorporating materials by reference; and 4) the 

EIS will be concise, clear, and to the point, and supported by evidence that the agencies have made the necessary 

environmental analyses. Mapping was provided in the 3 Bars Project EIS that provided the public with an overview of 

resource conditions on the 3 Bars Project area, but were not so detailed (and would require many pages of maps) that 

the public would have difficulty understanding resource conditions and issues needed to compare the impacts and 

benefits of the alternatives. Since maps were developed based on field studies, aerial photographic interpretation, and 

other sources of data, and analyzed using Geographic Information System (GIS), more detailed mapping can be 

prepared by the BLM for treatment units before conducting treatments to better identify wildlife special status species 

and other resources of concern at the site-specific level. 

D.5.3.5 Assessment Methodology – Risk Assessments 

Comment No. 4-7 from Western Watersheds Project: 

In this process, BLM must also conduct comprehensive Risk Assessments, not only of the chemicals and treatment 

methods to be applied, but also fully and fairly take NEPA’s required “hard look” at risks of all kinds - to air quality, 

dust transport and depletion linked to early snowmelt and climate change, a broad body of climate change effects, 

soils, native vegetation, sensitive species, WSA [Wilderness Study Area] impairment, HMA impacts, migratory birds, 

water quality and quantity, viability of sensitive species populations and quality and quantity of habitat. 

Response to Comment No. 4-7:

The Environmental Consequences section for each resource discussed in the 3 Bars Project EIS provides a “hard 

look” at the adverse and beneficial effects of proposed 3 Bars Project treatments. A subsection entitled “adverse 

effects” is provided under each treatment type (riparian, aspen, pinyon-juniper, and sagebrush) that discusses the risks 

associated with treatments in units for that treatment type. The 3 Bars Project does not include the use of herbicides. 

However, the BLM can use up to 18 herbicides on the 3 Bars Project area based on authorization given in 

the Environmental Assessment Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field 

Office and Tonopah Field Office (USDOI BLM 2009b) and Record of Decision Vegetation Treatments Using 

Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact 

Statement (17-States PEIS ROD; USDOI BLM 2007a). Ecological and human health risk assessments were 

conducted in support of the 17-States PEIS and can be reviewed at URL: 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

D.5.3.6 Assessment Methodology – Significance Criteria

Comment No. 4-186 from Western Watersheds Project: 

BLM’s significance criteria are inadequate, and it is unclear how they were derived. BLM does not conduct adequate 

analysis to address them. 
ASSESSMENT METHODOLOGY

3 Bars Project Final EIS D-18 October 2016 

Response to Comment No. 4-186:

As stated in 40 Code of Federal Regulations 1508.27: 

Significantly as used in NEPA requires considerations of both context and intensity: (a) Context. This means that the 

significance of an action must be analyzed in several contexts such as society as a whole (human, national), the 

affected region, the affected interests, and the locality. Significance varies with the setting of the proposed action. For 

instance, in the case of a site-specific action, significance would usually depend upon the effects in the locale rather 

than in the world as a whole. Both short- and long-term effects are relevant. (b) Intensity. This refers to the severity of 

impact. Responsible officials must bear in mind that more than one agency may make decisions about partial aspects 

of a major action. The following should be considered in evaluating intensity: 1) Impacts that may be both beneficial 

and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be 

beneficial. 2) The degree to which the proposed action affects public health or safety. 3) Unique characteristics of the 

geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and 

scenic rivers, or ecologically critical areas. 4) The degree to which the effects on the quality of the human 

environment are likely to be highly controversial. 5) The degree to which the possible effects on the human 

environment are highly uncertain or involve unique or unknown risks. 6) The degree to which the action may 

establish a precedent for future actions with significant effects or represents a decision in principle about a future 

consideration. 7) Whether the action is related to other actions with individually insignificant but cumulatively 

significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the 

environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small 

component parts. 8) The degree to which the action may adversely affect districts, sites, highways, structures, or 

objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of 

significant scientific, cultural, or historical resources. 9) The degree to which the action may adversely affect an 

endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species 

Act of 1973. 10) Whether the action threatens a violation of Federal, State, or local law or requirements imposed for 

the protection of the environment. 

Using this guidance from the Council on Environmental Quality, and guidance provided in BLM National 

Environmental Policy Handbook H-1790-1 (USDOI BLM 2008:70-74), significance criteria were developed for each 

resource area based on BLM and other agency regulatory standards; review of significance criteria used for the Mount 

Hope Project EIS and other BLM and other agency EISs and Environmental Assessments conducted for projects that 

were similar to the 3 Bars Project; and discussions among the BLM 3 Bars Project Interdisciplinary Team (BLM ID 

Team). Draft significance criteria were developed, and then underwent several reviews by the BLM ID Team to 

ensure that the criteria would critically evaluate the significance of proposed actions based on context and intensity. 

These criteria are presented in Chapter 3 for each resource area under Environmental Consequences, Significance 

Criteria. An analysis of the significance of the project-related effects are discussed under Environmental 

Consequences for the alternatives, and an effects determination is given in the subsection entitled “Significance of the 

Effects under the Alternatives,” for each resource area.
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

D.5.4 Cumulative Effects 

D.5.4.1 Cumulative Effects – Assessment Methodology 

Comment No. 4-157 from Western Watersheds Project: 

Figure 3-6 does not show mining or other claims. It merely shows mining districts. Where is a map showing all 

energy or other rights-of-way, as well? Where is an overlay of the project polygons on the mapping that is provided? 

Please assess the full foreseeable mining development in this region. 

Response to Comment No. 4-157:

3 Bars Project Final EIS Figure 3-6 (Cumulative Impacts from Mining Operations and Oil and Gas Production) shows 

mining districts, mining operations, oil and gas production facilities, and geothermal lease areas. Final EIS Figure 3-5 

(Cumulative Impacts from Utilities and Infrastructure) shows utilities and infrastructure, including rights-of-way. 

Initially, treatment areas (polygons) were overlaid onto Final EIS Figures 3-1 to 3-7, but they were very difficult to 

see within the context of the larger cumulative effects study area, thus it was decided that Final EIS Figures 3-1 to 3-7 

should not show treatment units. Since mining claims are not necessarily indicative of reasonably foreseeable future 

mining activity, they were not included on Figure 3-6. The effects of past, present, and reasonably foreseeable future 

mining activity are discussed under Cumulative Effects for each resource section evaluated in the EIS. 

Comment No. 4-158 from Western Watersheds Project: 

[The] CESA [Cumulative Effects Study Area] is much too small for all mapping and cumulative effects analysis for 

all elements of the environment, and must include large areas mined/undergoing mining development to the north, 

east, south in particular, aquifer drawdown effects of mining, irrigation etc. across the underlying shallow and deeper 

ground water aquifers. How over-allocated are these already? How is that already impacting/likely to impact ground 

and surface waters? How much water would the Mount Hope mine use? Where would it come from? How about the 

plethora of gold mines all surrounding this landscape? New mining actions like the Pan mine, ever-expanding Barrick 

and other operations all over the place? 

Response to Comment No. 4-158:

The CESA varies by resource as shown on Figure 3-1 (Cumulative Effects Study Area) of the Final EIS. The 

rationale used to develop the CESA is discussed under each resource description. For geology and minerals, the 

CESA is the 3 Bars Project area, although Figure 3-6 (Cumulative Impacts from Mining Operations and Oil and Gas 

Production) shows mining, geothermal, and oil and gas leases and operations within the largest CESA (cultural 

resources CESA) as well as leases and operations outside of the CESA. The CESA for cumulative effects to water 

resources is the Hydrologic Unit Code 10 watersheds wholly or partially within the project area. The cumulative 

effects of mining and other land uses on 3 Bars Project resources, including surface and groundwater, wildlife, wild 

horses, land use, etc., are discussed under cumulative effects for each resource. Most of the mine projects shown on 

Figure 3-6 are no longer active, or are too far away from the 3 Bars Project area to have an influence on 3 Bars Project 

resources. The cumulative effects of the Mount Hope Project and other non-3 Bars Project activities on resources are 

discussed in detail in the cumulative effects sections for each resource. More specific information on the Mount Hope 

Project, including surface water and groundwater use, is available in the Mount Hope Project Final EIS. 

3 Bars Project Final EIS D-19 October 2016 
CUMULATIVE EFFECTS

3 Bars Project Final EIS D-20 October 2016 

D.5.4.2 Cumulative Effects – General 

Comment No. 4-13 from Western Watersheds Project: 

What populations [of special status wildlife species] were previously supported? What will now survive, and will they 

be viable? How will expanding mine development and a[l]l the human footprint associated with that further eat into 

and threaten these sensitive species habitats? How will mine development and the increased human footprint in the 

landscape stress or affect the wild horse herds and their use of the HMAs? Even though the current mine proposed is 

not [in] the HMAs, there will be a greatly increased human presence in the landscape. 

Response to Comment No. 4-13:

3 Bars Project Final EIS Section 3.16.2, Wildlife, Affected Environment, discusses special status wildlife and other 

wildlife species historically and/or currently found on/near the 3 Bars Project area. Section 3.16.3, Wildlife, 

Environmental Consequences, also discusses how 3 Bars Project treatments, and reasonably foreseeable future actions 

within the CESA, could impact wildlife. Section 3.16.3 discusses how 3 Bars Project treatments would affect wildlife, 

including their health, behavior, and habitat use, and the potential adverse and beneficial effects to wildlife 

populations from treatment actions. By following SOPs provided in Appendix C (Standard Operating Procedures) of 

the Final EIS, adverse effects to special status wildlife would be insignificant and short-term, while there would be 

long-term benefits. As discussed under Cumulative Effects in Final EIS Sections 3.16.3.4, Wildlife Resources, 

Environmental Consequences, Cumulative Effects, and 3.17.3, Wild Horses, Environmental Consequences, 

Cumulative Effects, the Mount Hope Project would adversely affect pygmy rabbits and other special status wildlife, 

and could have adverse effects on these animals and mitigation was provided to address impacts to both species. 

Other land uses near the 3 Bars Project area could also affect special status wildlife and wild horses. The effects are 

discussed under Cumulative Effects in Sections 3.16.3 and 3.17.3 of the 3 Bars Project Final EIS, and in the Mount 

Hope Project Final EIS. The potential impacts to wild horses from development of the Mount Hope Project were 

analyzed in the Mount Hope Project Final EIS, as well as in Section 3.17.3 of the 3 Bars Project Final EIS (Wild 

Horses, Environmental Consequences, Cumulative Effects). 

Comment No. 4-17 from Western Watersheds Project: 

What is the intensity of the current conflicts of livestock, mining etc. with the HMAs, the TNEB [thriving natural 

ecological balance] in the HMAs, etc. 

Response to Comment No. 4-17:

The effects of the proposed 3 Bars Project, and past, present, and reasonably foreseeable future actions within the 

cumulative effects study area, to wild horses, and HMAs and their thriving natural ecological balance, are discussed 

in Section 3.17.3, Wild Horses, Environmental Consequences, of the Final EIS. As discussed in the Mount Hope 

Project EIS, a perimeter fence around the mine site would exclude wild horses from about 13,998 acres of designated 

HMAs, potentially increasing pressure on forage and water resources for wild horses that are outside the perimeter 

fence. Livestock congregation and concentrated use near streams, springs, and wetlands have contributed to the loss 

of riparian habitat and forage, and impacts to stream channels and their ability to function properly and provide 

abundant and high quality water for wild horses. The BLM would continue ongoing management reviews to 

determine if livestock grazing management is resulting in utilization levels that are moderate to severe and adversely 

impact wild horse forage, and if needed, would determine if changes in the current terms and conditions of the grazing 

permit would be required to maintain the long-term success of the proposed treatments. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-21 October 2016 

Comment No. 4-48 from Western Watersheds Project: 

BLM plans to focus on ripping apart the best remaining communities – dealing a double blow to sage-grouse and 

other sensitive species. First, BLM will allow serious degradation to continue indefinitely – and with lands on a 

downward trajectory, plus the large-scale mining geothermal, powerline and other impacts. The combined adverse 

effects of the battery of treatment disturbance and continued livestock grazing of degraded lands is (as well as all the 

treated lands, too) are highly likely to doom sage-grouse, pygmy rabbit, pinyon jay and other sensitive species 

persistence and population viability in the Three [3] Bars Ecosystem. 

Response to Comment No. 4-48:

Based on analysis in the EIS, 3 Bars Project treatments would lead to short-term impacts to resources on the project 

area, including soil, water, and vegetation. The BLM, however, would focus treatments on habitats, such as streams, 

decadent and diseased pinyon-juniper, and areas with noxious weeds and other invasive non-native vegetation, and 

not areas where the habitat is functioning and at or near its Potential Natural Community. In addition, the BLM would 

use SOPs to minimize impacts to treatment areas. As discussed in Chapter 1 of the EIS (Proposed Action and Purpose 

and Need), the BLM would reduce the downward trend in landscape health by focusing treatments in areas where the 

ecosystem has characteristics that suggest its health can be substantially improved through land restoration activities. 

As noted for Comment 4-17 (Cumulative Effects-General), the BLM would continue ongoing management reviews to 

determine if livestock grazing management is resulting in utilization levels that are moderate to severe and adversely 

impact wild horse forage, and if needed, would determine if changes in the current terms and conditions of the grazing 

permit would be required to maintain the long-term success of the proposed treatments. Long-term, 3 Bars Project 

treatments should slow the degradation of, or improve, habitat for special status and other wildlife species and provide 

conditions that lead to healthy populations. 

Comment No. 4-89 from Western Watersheds Project: 

BLM has failed to adequately evaluate land uses (grazing, fire suppression, mining) – as we described in Scoping and 

throughout these D[raft] EIS comments. Moreover, many other issues were raised – like transmission lines, roading, 

and addressing the direct, indirect and cumulative adverse impacts of infrastructure and development, and the adverse 

impacts of these in the region are glossed over. BLM ignores livestock facility and forage and other vegetation 

treatments adverse impacts and degree and severity of degradation. 

Response to Comment No. 4-89:

Grazing, fire suppression, mining, transmission lines, and roads are all described in Final EIS Section 3.3.2.3.3 and 

their impacts are cumulatively evaluated in each of the individual resource sections in Final EIS Chapter 3. 

Comment No. 4-91 from Western Watersheds Project: 

By failing to take a hard look at the adverse impacts of livestock grazing, livestock facilities, often linked road 

networks, the colossal footprint of large gold, molybdenum and other mines, the adverse impacts of a battery of 

livestock facilities, etc. – BLM avoids addressing causes of degradation and cumulative impacts and threats. Instead, 

the D[raft] EIS flails around scapegoating native trees that provide crucial habitat for many sensitive species, for wild 
CUMULATIVE EFFECTS

horses, for big game, and that are also crucial for watershed protection in this grazing-depleted and mining-depleted 

landscape (historical, ongoing mining). 

Response to Comment No. 4-91:

The effects of livestock management, roads, mining activities, and other land uses on 3 Bars Project area resources on 

and near the 3 Bars Project area are discussed under Cumulative Effects for each resource section in the Final EIS. As 

discussed in Final EIS Sections 3.10 (Water Resources), 3.11 (Wetlands, Floodplains, and Riparian Zones), 3.12 

(Native and Non-invasive Vegetation Resources), 3.15 (Fish and other Aquatic Resources), 3.16 (Wildlife 

Resources), and 3.17 (Wild Horses), the BLM would remove decadent and diseased pinyon-juniper, remove pinyonjuniper that is encroaching into sagebrush, aspen, and riparian habitats, and thin dense stands of pinyon-juniper to 

reduce hazardous fuels. As discussed under Environmental Consequences in these resource sections, removal of 

pinyon-juniper would adversely affect short-term habitat use for wildlife, including some special status species, and 

wild horses, but would lead to long-term benefits for these animals. By not conducting treatments, the health of some 

pinyon-juniper stands would continue to deteriorate, wildfire risk in some stands would remain high, and trees would 

encroach into sagebrush and other habitats that are critical to greater sage-grouse and pygmy rabbit, and provide 

forage and fawning habitat for mule deer and wild horses. As noted for Comment 4-17 (Cumulative Effects-General), 

the BLM would continue ongoing management reviews to determine if livestock grazing management is resulting in 

utilization levels that are moderate to severe and adversely impact wild horse forage, and if needed, would determine 

if changes in the current terms and conditions of the grazing permit would be required to maintain the long-term 

success of the proposed treatments. 

Comment No. 4-98 from Western Watersheds Project: 

How will grazing degradation, grazing disturbance, mining disturbance, geothermal or other energy development and 

explo[ration] activities impact wildlife use of the landscape and the viability of populations, wild horse use and herd 

viability, wildfire habitats and populations, recreational uses and enjoyment, etc.? 

Response to Comment No. 4-98:

The effects of livestock management, roads, mining activities, and other land uses on resources on and near the 3 Bars 

Project area are discussed under Cumulative Effects for each resource section in the EIS. Please refer to Final EIS 

Sections 3.14 (Wildland Fire and Fire Management), 3.16 (Wildlife Resources), 3.17 (Wild Horses), and 3.21 

(Recreation) for information specific to resources of concern to the commenter. 

Comment No. 4-104 from Western Watersheds Project: 

We are greatly concerned that this EIS package of bioengineering projects is aimed at enabling BLM to more speedily 

ok more mining, geothermal and other development by having an already packaged scheme to spend mitigation 

dollars. So lands will be bared in treatments – easy mining explo[ration] will occur and/or the sensitive species of 

concern will have been wiped out by the treatment and continued grazing schemes. So down the road, neither the 

woody vegetation or the rare species will be any impediment at all to massive mining destruction across the Three [3] 

Bars landscape. 

3 Bars Project Final EIS D-22 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-104:

See response to Comment 4-91 (Cumulative Effects – General). The proposed 3 Bars Project is designed to restore 

lands that have been impacted by past land uses. Although the BLM may use mitigation funds generated by 

reasonably foreseeable future mining and other development within the 3 Bars Project area to fund some 3 Bars 

Project work, the bulk of the funding for 3 Bars Project work would come from the U.S. Treasury. Each reasonably 

foreseeable future mining or energy project proposed for the 3 Bars Project area would undergo NEPA analysis to 

determine the adverse and beneficial effects of the proposed action, and if mitigation is needed to offset adverse 

effects. The BLM would welcome opportunities to use mitigation funds to offset adverse effects from development 

while enhancing 3 Bars Project resources, but would not use the potential for mitigation funding for 3 Bars Project 

treatments to drive decisions related to future mining, energy, or other development on the 3 Bars Project area. As 

discussed in the 3 Bars Project Final EIS in Appendix C, the BLM will conduct surveys for sensitive species and 

other resources, as needed, prior to conducting 3 Bars Project or other land-disturbing activities on the 3 Bars Project 

area. 

D.5.5 Fish and other Aquatic Resources 

D.5.5.1 Fish and other Aquatic Resources – Affected Environment 

Comment No. 4-240 from Western Watersheds Project: 

We understand that the U.S. Fish and Wildlife Service (USFWS) has said that the LCT [Lahontan cutthroat trout] 

here, since they were moved in from other drainages, are not as important as LCT elsewhere. Is that the case? 

Response to Comment No. 4-240:

Lahontan cutthroat trout are found on the 3 Bars Project area in Birch Creek, Pete Hanson Creek, and Willow Creek. 

Although LCT were stocked Pete Hanson Creek by NDOW in 1983, the origin of the Birch Creek and Willow Creek 

LCT is unknown. The fish in these streams are pure LCT, are a federally listed threatened species, and are afforded 

protection under the Endangered Species Act. Thus, LCT found on the 3 Bars Project area are afforded the same 

protections as LCT elsewhere in Nevada and California. The BLM prepared a Biological Assessment for the 3 Bars 

Ecosystem and Landscape Restoration Project (USDOI BLM 2014) that discusses the population status and habitat 

for LCT on the 3 Bars Project area, origin of fish found in 3 Bars Project streams, and potential effects to LCT from 3 

Bars treatment actions. The BLM would consult with the USFWS before conducting treatments in or along streams 

with known or potential habitat for LCT. As discussed in Section 3.15.2.3.2, Fish and other Aquatic Resources, 

Lahontan Cutthroat Trout, genetic analyses have determined that pure strains (i.e., fish with unmixed lineage over 

many generations) of Lahontan cutthroat trout are found in Pete Hanson Creek. Recent genetic analysis on the Birch 

Creek Lahontan cutthroat trout has shown a small degree of hybridization with rainbow trout. Of the 30 fish sampled, 

8 had rainbow trout alleles at one locus that were the result of an historic hybridization event. Results for the genetic 

analysis on the Willow Creek population are pending. Pete Hanson Creek was stocked with Lahontan cutthroat trout 

from Shoshone and Santa Fe Creeks (Elliott 2013). 

Comment No. 4-242 from Western Watersheds Project: 

To what degree are Vinini and Henderson creeks currently connected (map 3-39)? 

3 Bars Project Final EIS D-23 October 2016 
FISH AND OTHER AQUATIC RESOURCES

Response to Comment No. 4-242:

As shown on Final EIS Map 3-38 (Lahontan Cutthroat Trout Habitat), Vinini Creek and Henderson Creek join near 

State Highway 278 and are perennial streams where they meet. Also see Figure 3-22, Streams, Lakes, Ponds, and 

Wetlands, which shows perennial and intermittent streams. 

D.5.5.2 Fish and other Aquatic Resources – Assessment Methodology 

Comment No. 4-243 from Western Watersheds Project: 

Have springsnail and native amphibian surveys been systematically conducted across the Three [3] Bars landscape? 

If so, when and where? 

Response to Comment No. 4-243:

Springsnail (Pyrogulopsis spp.) surveys were not conducted for the 3 Bars Project EIS, but were conducted for the 

Mount Hope Project EIS. As discussed in Section 3.23.2.1.2 of the Mount Hope Project Final EIS (URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/battle_mountain_field/blm_information/nepa/mount_h

ope_project/mount_hope_feis.Par.83818.File.dat/Vol%202%20-%203.23.pdf), a presence/absence survey for 

springsnails was conducted on the Mount Hope Project Area on July 9, 2007. The survey was conducted in the 

middle of summer when perennial springs were flowing and intermittent springs would be at low flow. A subsequent 

presence or absence springsnail survey was conducted between September 27 and October 31, 2007. Streams in the 

larger regional area, including streams near the 10-foot water drawdown contour, were surveyed. Although no 

springsnails were present within the Mount Hope Mine Project area or the predicted 10-foot water drawdown contour 

surveyed, springsnails were noted in locations near the predicted drawdown boundary (to the northwest of the 

northern boundary and to the southeast of the southern mine project boundary; see Figure 3-37, Snail Observations, in 

3 Bars Project EIS). No systematic surveys for amphibians were conducted for the Mount Hope Project or 3 Bars 

Project. 

D.5.5.3 Fish and other Aquatic Resources – Environmental Consequences 

Comment No. 4-32 from Western Watersheds Project: 

In this context, no reasonable scientist would propose anything remotely resembling the Preferred Alternative – for 

example –killing all PJ [pinyon-juniper] within 200 feet of streams. The water is likely to reach lethal temperatures 

for aquatic biota as all shade is removed, and deforestation of the lands near the stream – which in grazed arid lands 

are typically the most highly degraded - will result in significantly decreased watershed stability and erosion, as well. 

Response to Comment No. 4-32:

As discussed in Final EIS Appendix C, Standard Operating Procedures, Section C.2.7, Riparian Management, the 

BLM would remove vegetation incrementally over several years to minimize stream temperature effects. As 

discussed in Final EIS Section C.2.9, Pinyon-juniper Management, most treatments of pinyon-juniper would occur 

predominately in Phase I and Phase II pinyon-juniper stands. Treatments within Phase III pinyon-juniper stands 

would be used to disrupt the continuity of fuels and reduce the risk of catastrophic wildfire, as well as improve forest 

health. In addition, the BLM may leave downed trees and mulch in areas with large-scale pinyon-juniper removal to 

prevent sediment from entering nearby waterways. Thus, treatments would not lead to deforestation, significantly 

3 Bars Project Final EIS D-24 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-25 October 2016 

decreased watershed stability and erosion, or lethal temperatures for aquatic biota. Additional information on the 

effects of treatments on fish and other aquatic resources can be found in Final EIS Section 3.15, Fish and other 

Aquatic Resources. 

Comment No. 4-118 from Western Watersheds Project: 

Lahontan cutthroat trout or other rare species eggs will be choked with sediment spilling from the treated, grazed 

slopes and bioengineered, clearcut artificial stream[s]. BLM cannot conduct ESA [Endangered Species Act] 

consultation with USFWS based on the self-serving and inaccurate analysis of the EIS. A[n] SEIS [Supplemental 

EIS] that honestly addresses the serious risks and uncertainties with this proposal must be prepared as the basis for 

consultation. 

Response to Comment No. 4-118:

See response to Comment 4-32 (Fish and Other Aquatic Resources - Environmental Consequences). Final EIS 

Section 3.15.3, Fish and Other Aquatic Organisms, Environmental Consequences, discusses the potential for erosion 

and stream sedimentation associated with proposed treatments to impact habitat used by Lahontan cutthroat trout. 

Section 5 of the Biological Assessment 3 Bars Ecosystem and Landscape Restoration Project also discusses the 

effects of treatments on habitat use by Lahontan cutthroat trout within the 3 Bars Project area (USDOI BLM 2014). 

Section C.2.4 ( Erosion Control) of Appendix C (Standard Operating Procedures) of the 3 Bars Project Final EIS 

discusses the SOPs the BLM would use to minimize erosion and stream sedimentation to ensure that effects to 

Lahontan cutthroat trout from 3 Bars Project treatments would be minimal, while Section C.3.2.2, Fish, notes that no 

in-stream treatments would be allowed in waters occupied by Lahontan cutthroat trout during January 1 and July 15 to 

help protect spawning fish and their eggs and young. As noted in Section C.3.2.1, Special Status Species, the BLM 

consulted with the USFWS and NDOW during development of the 3 Bars Project EIS and Biological Assessment, 

and would consult with these agencies before conducting any work that could adversely impact Lahontan cutthroat 

trout. 

Comment No. 4-241 from Western Watersheds Project: 

Yet what are the actual concrete watershed-level actions that will result in habitat - other than removal of livestock 

from the watersheds – not just new barbed wire strips? What pastures cab [can] be closed to better protect 

watersheds? 

Response to Comment No. 4-241:

As discussed in Final EIS Section 2.3, Description of the Action Alternatives, actions would be taken under all action 

alternatives to improve wetland, riparian zone, and floodplain habitat for fish and other aquatic resources. These 

include stream restoration, vegetation plantings, and removal of pinyon-juniper where it encroaches into riparian 

habitat. Temporary fencing would be used to protect treatment areas from livestock, wild horse, and other wild 

ungulate use until treatment areas are revegetated. As noted for Comment 4-17 (Cumulative Effects - General), the 

BLM would continue ongoing management reviews to determine if livestock grazing management is resulting in 

utilization levels that are moderate to severe and adversely impact wild horse forage, and if needed, would determine 

if changes in the current terms and conditions of the grazing permit would be required to maintain the long-term 

success of the proposed treatments. 
FISH AND OTHER AQUATIC RESOURCES

3 Bars Project Final EIS D-26 October 2016 

Comment No. 4-244 from Western Watersheds Project: 

Riparian vegetation is an important habitat component for aquatic species, as plants provide overhanging cover, 

temperature control via shading, bank stability, a food source from insects on the vegetation, and nutrient input to the 

stream from loss of leaves and branches. Then why is BLM killing all the PJ [pinyon-juniper] within 200 ft [feet] of 

the streams? 

Response to Comment No. 4-244:

As noted in Final EIS Section 3.15.3.3.1, Fish and other Aquatic Resources, Direct and Indirect Effects Common to 

All Action Alternatives, following the text cited above, “beneficial effects would result from riparian restoration 

actions that would improve riparian community health and resiliency. These include stream channel restoration and 

removal of pinyon-juniper from the riparian zone. Replacing invasive plant species with native vegetation can 

improve food availability to insectivorous fish species, as native plants typically support a more diverse native insect 

community. The removal of noxious weeds and other invasive non-native vegetation and restoration of the streamside 

vegetation to include native plant species would be beneficial to the stream morphology and the ecological 

requirements for aquatic species long-term.” As noted in Final EIS Section 3.11.3.3.2, Wetlands, Floodplains, and 

Riparian Zones, Direct and Indirect Effects under Alternative A, pinyon and juniper are not riparian species’, and are 

not as effective as native vegetation in stabilizing soil. Also see response to Comment 4-32 (Fish and other Aquatic 

Resources-Environmental Consequences). 

D.5.6 Glossary 

Comment No. 4-42 from Western Watersheds Project: 

The D[raft] EIS needs to be drastically revised. First and foremost BLM needs to carefully define restoration. 

Response to Comment No. 4-42:

As defined in Chapter 6 (Glossary) of the 3 Bars Project Final EIS, restoration is the implementation of a set of 

actions that promotes plant community diversity and structure and that allows plant communities to be more resilient 

to disturbance over the long-term. 

Comment No. 4-52 from Western Watersheds Project: 

Where did the new silly term “densification” come from? How was the so-called “densification” on all sites 

determined? 

Response to Comment No. 4-52:

As given in Chapter 6 (Glossary) of the 3 Bars Project Final EIS, densification, as it applies to the 3 Bars Project, is an 

increase in the density of pinyon-juniper within woodland stands due to fire exclusion and livestock grazing. As 

shown in Table 1-2 (Restoration Goals and Objectives) of the EIS, dense stands of pinyon-juniper occur where stand 

density exceeds 1,200 stems per acre or 80 trees per acre (Miller et al. 2008, USDOI BLM 2009a). The term 

densification has been used in several publications that discuss pinyon-juniper densities in the western U.S. Miller et 

al. (2008), among others, provide an informative discussion of age structure and expansion of pinyon-juniper 

woodlands in the western U.S. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-27 October 2016 

Comment No. 4-56 from Western Watersheds Project: 

How has BLM defined key species? 

Response to Comment No. 4-56:

Key species are forage species whose use serves an indicator to the degree of use of associated species, or those 

species which must, because of their importance, be considered in a management program. A more detailed 

discussion of key species and inventory methods is in the following document—Cooperative Extension Service, 

USDA Forest Service, Natural Resource Conservation Service Technology Institute, and USDOI BLM. 1999. 

Utilization Studies and Residual Measurements. Bureau of Land Management National Applied Resource Sciences 

Center, Denver, Colorado, Page 4 and Chapter 4. We have added this term to Chapter 6 (Glossary) in the 3 Bars 

Project Final EIS. 

D.5.7 Livestock Grazing 

D.5.7.1 Livestock Grazing – Affected Environment 

Comment No. 4-70 from Western Watersheds Project: 

What systematic methods were used in monitoring? How closely did livestock monitoring actually track livestock use 

periods? 

Response to Comment No. 4-70:

Eastern Nevada Landscape Coalition documented existing ecosystem conditions on 532,000 acres within the 3 Bars 

Project area and compared them to desired conditions (3 Bars Ecosystem and Landscape Restoration Project 

Rangeland Health Report [Eastern Nevada Landscape Coalition and AECOM 2012]). Monitoring data collected 

included production, nested frequency, soil stability, gap intercept, line-point intercept and use pattern mapping. The 

monitoring data collected were used to determine rangeland health. 

Comment No. 4-99 from Western Watersheds Project: 

What has livestock actual use been over the past two decades? During the past decade? This is critical information, 

because the current damage being caused by livestock is due to the actual use stocking levels. Further, has BLM ever 

verified the accuracy of actual use reports by ranchers? If so, when and where? Also, has there been non-compliance 

in this landscape? If so, when and where? What sensitive species habitats and populations, wild horse bands, 

recreational uses, watersheds and streams, springs and seeps have been impacted? Aren’t some of the recent drought 

closure decisions Battle Mountain is issuing a result of permittees failing to abide by agreements the ranchers violated 

that were to limit use during drought? Example: Bates Mountain area/Dry Creek? In a landscape with a history of 

non-compliance, BLM’s ability to live up to promises to control livestock use after treatments/bioengineering is 

highly uncertain. And this just further illustrates the hubris of this bioengineering scheme. How can BLM possibly 

hope to flawlessy bioengineer a wild landscape, when it cannot get the livestock operations under control yet? 
LIVESTOCK GRAZING

3 Bars Project Final EIS D-28 October 2016 

Response to Comment No. 4-99

Use data are available in the Final 3 Bars Ecosystem and Landscape Restoration Project Rangeland Health Report 

(Eastern Nevada Landscape Coalition and AECOM 2012) and are available from the BLM Mount Lewis Field Office 

upon request. Impacts from the proposed action and cumulative impacts to sensitive species habitats, wild horses, 

recreational uses, watersheds and streams, springs and seeps can found in those respective sections in the Final EIS. 

Comment No. 4-137 from Western Watersheds Project: 

Despite this EIS having been billed as addressing livestock grazing, the comparison of Alternatives Table fails to 

provide any information at all on current actual use, current active/allowable use current standards of use, current 

seasons of use, current degree and severity of livestock degradation, or really any meaningful information at all on 

livestock grazing. 

Response to Comment No. 4-137:

The Final EIS includes the season of use, livestock type, and stocking rate for treatment areas (see Section 3.18.2, 

Livestock Grazing, Affected Environment). Areas identified for treatment that do not have proper grazing 

management would require modification to permitted use prior to treatment implementation. Proper grazing 

management includes the correct season of use, stocking rate and duration of grazing. If proper management cannot 

be achieved, the project will not be approved for implementation. 

Comment No. 4-138 from Western Watersheds Project: 

Table 3-49 lacks actual use information by pasture and allotment, and lacks breakdown of the grazing schedules by 

pasture, or any overlay of areas with HMAs, sage-grouse seasonal habitats, etc. 

Response to Comment No. 4-138:

Final EIS Figure 3-44 shows use pattern mapping throughout the 3 Bars Project area and identifies areas of moderate 

to severe utilization. This map identifies areas that have either distribution or stocking rate issues. Herd Management 

Area (Section 3.18.2; Livestock Grazing, Affected Environment) and wildlife habitats (3.16.2; Wildlife Resources, 

Affected Environment) are covered under their respective sections in the Final EIS. Season of use for allotments is 

also provided in Table 3-49 of the Final EIS. 

Comment No. 4-139 from Western Watersheds Project: 

Are the “AUs” [Animal Units] based on a 1000 pound cow or an 800 pound cow? Or cows with 500 lb. calves? 

Response to Comment No. 4-139:

Based on the National Range and Pasture Handbook (USDA Natural Resources Conservation. 2003. Grazing Lands 

Technology Institute. Chapter 6. Washington, D.C. Available at URL: 

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/landuse/rangepasture/?cid=stelprdb1043084), an AU is 

generally one mature cow of approximately 1,000 pounds and a calf as old as 6 months, or their equivalent. An 

animal unit month (AUM) is the amount of forage required by an animal unit for 1 month. Animal unit equivalents 

vary somewhat according to kind and size of animals. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-29 October 2016 

States can establish their own AU guides on the basis of locally available data relative to forage requirements. The 

handbook provides AU equivalents for other livestock and large wildlife. We have revised the definition of AU in the 

glossary to incorporate this information. 

Comment No. 4-140 from Western Watersheds Project: 

Why is it not being retired as mitigation, and why isn’t this considered in an alternative action? There are nearly 100 

pastures. How can many these fences be removed and lands combined to reduce fencing, and fencing removed to help 

sage-grouse, enhance free roaming wild horses, etc.? Where are fences a concern on what seasonal ranges? 

Response to Comment No. 4-140:

Public lands are administered by the BLM for multiple use. Retirement of grazing permits/allotments is not identified 

in the Shoshone-Eureka Resource Management Plan (USDOI BLM 1987). Range improvements and facilities are 

analyzed during the evaluation process. If range improvements are identified as a health risk for wild horses, wildlife, 

or other species, they would be addressed on a case-by-case basis. 

D.5.7.2 Livestock Grazing – Cumulative Effects 

Comment No. 9-2 from K. Gregg: 

One example of BLM’s omission of a major cause of public land destruction that is not sufficiently proposed is the 

removal/reduction of private livestock on public land. The D[raft] EIS professes to restore lands to their natural 

condition by introducing fire and mechanical manipulation and chemical application to the ecosystem, but the 

proposal does not address the fact that livestock grazing is a major and continuing cause of altered fire cycles, 

understory loss, soil compaction, pinyon-juniper expansion, riparian destruction or that burned and grazed juniper 

sites on BLM lands are being invaded by non-native grasses. 

Response to Comment No. 9-2:

See response to Comment 4-140 (Livestock Grazing – Affected Environment).

D.5.7.3 Livestock Grazing – Environmental Consequences 

Comment No. 4-3 from Western Watersheds Project: 

BLM fails to take a hard look at the severe ecological damage and irreversible weed invasions, water loss, and loss of 

sensitive species habitats and populations that will result from continued livestock grazing being imposed across all of 

these areas over the next couple of decades. This will be amplified by the adverse impacts of climate change. See 

Belsky and Gelbard 2000, Beschta et al. 2012, Reisner Dissertation, Reisner et al. 2013, Briske et al. 2013. 

Response to Comment No. 4-3:

The BLM has reviewed the documents cited by the commenter that evaluate the effects of livestock grazing on 

rangelands and how livestock managers and other resource users may have to modify their management practices in 

response to global climate change. These could include reductions in numbers of livestock grazed on an area, seasonal 

restrictions on livestock use of an area, and studies that evaluate livestock impacts on resources in response to global 
LIVESTOCK GRAZING

climate change. A summary of several of these studies is included in Final EIS Section 3.5.2.2 (Meteorology and 

Climate Change, Climate Change) of the 3 Bars Project EIS. As discussed in Final EIS Section 3.18.3.4, Cumulative 

Effects, Livestock Grazing, about 6 percent of the 3 Bars Project area is experiencing moderate to severe forage 

utilization due to livestock, wild horses, and other wild ungulates. In response to the concerns addressed by the 

commenter, the BLM has targeted about a third of 3 Bars Project restoration treatment acreage in areas with moderate 

to severe forage utilization, as discussed in Section 3.18 (Livestock Grazing). The BLM would implement mitigation 

measures (see Final EIS Section 3.18.4, Livestock Grazing, Mitigation) and SOPs (Appendix C, Section C.2.2, 

Livestock), to manage livestock and ensure that treatments are successful. In addition, and as suggested by Beschta et 

al. (2013) and other studies, the BLM would conduct monitoring to evaluate rangeland conditions prior to and after 

treatments to ensure treatment success. 

Comment No. 4-10 from Western Watersheds Project: 

D[raft] EIS at ES-3 claims the need for the EIS is to address the “long recognized” resource conflicts in the Three [3] 

Bars area. There is no certainty that the grazing changes will be made. Grazing decisions may be appealed, and 

appeals upheld. 

Response to Comment No. 4-10:

Livestock management would be examined prior to implementation as outlined in Section 3.18.4 (Livestock Grazing, 

Mitigation) of the Final EIS. 

Comment No. 4-11 from Western Watersheds Project: 

BLM fails to conduct the necessary capability, suitability, and sustainability analysis to determine if it is necessary to 

remove livestock disturbance conflicts from at least some significant and stressed habitat areas of the landscape. No 

treatment would be conducted without appropriate livestock management in place prior to that treatment. 

Response to Comment No. 4-11:

See response to Comment 4-10 (Livestock Grazing – Environmental Consequences).

Comment No. 4-23 from Western Watersheds Project: 

Will continuing to graze severely depleted lands as well as lands at high risk of flammable cheatgrass invasion render 

any supposed benefits of “improvement” from massive treatment intervention moot? 

Response to Comment No. 4-23:

As discussed in Section 1.8 of the 3 Bars Project Final EIS, Scope of the Analysis and Decisions to be Made, 

“Human-related activities and natural processes have inherent risks and threats to the health of the land, which can 

lead to the decline of plant communities and ecosystems. Although this EIS refers to activities consistent with the 

authorities under the Federal Land Policy and Management Act and other statutes that may contribute, in some cases, 

to short-term land and resource impacts, its focus is on proactive treatments to maintain and restore ecosystem health 

in the long-term. The focus of the EIS is not to restrict, limit, or eliminate Federal Land Policy and Management Actauthorized activities as a means to restore ecosystem health. These types of management actions are defined and 

considered under land use planning regulations (43 Code of Federal Regulations [CFR] § 1610) and are outside the 

scope of this EIS.” Thus, the BLM will continue to allow grazing on the 3 Bars Project area. However, the BLM 

3 Bars Project Final EIS D-30 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

would implement mitigation measures (see Final EIS Section 3.18.4, Livestock Grazing, Mitigation) and SOPs 

(Appendix C, Section C.2.2, Livestock), to manage livestock and ensure that treatments are successful. These could 

include livestock grazing closures, shifts in livestock season of use, and limits on livestock utilization rates to ensure 

the long-term success of treatments. This may result in changes to the current terms and conditions of the grazing 

permit. In addition, and as suggested by Beschta et al. (2013) and other studies, the BLM would conduct monitoring 

to evaluate rangeland conditions prior to and after treatments to ensure treatment success. 

Comment No. 4-35 from Western Watersheds Project: 

BLM has failed to identify large blocks of lands where continued livestock grazing disturbance conflicts with passive 

restoration, and with active restoration as well. 

Response to Comment No. 4-35:

Figure 3-44 of the Final EIS identifies areas where there is “Moderate to Severe Range Use.”

Comment No. 4-36 from Western Watersheds Project: 

The EIS lacks necessary solid baseline data, and a hard look at magnitude of historical and ongoing livestock 

degradation. 

Response to Comment No. 4-36:

Use data are available in the Final 3 Bars Ecosystem and Landscape Restoration Project Rangeland Health Report 

(Eastern Nevada Landscape Coalition and AECOM 2012), and are also available from the BLM Mount Lewis Field 

Office upon request. 

Comment No. 4-46 from Western Watersheds Project: 

D[raft] EIS at 3-7: “Open range livestock operations are expected to continue ... short-term (typically 2 to 4 year) 

temporary suspensions of AUMs would be expected in response to prescribed fires and the temporary loss of forage 

...”. This time period is greatly inadequate to recover the understories, microbiotic crusts, hiding cover, shrubs to 

promote site stability, shade the ground surface, slow snowmelt, block wind, and overall site recovery. etc. It also 

represents a view of these lands that pervades the EIS – that “forage” is what really matters, and everything else is 

expendable.

Response to Comment No. 4-46:

Final EIS Appendix C, Section C.2.2.1 (Temporary Livestock Grazing Closures), addresses temporary grazing 

closures. 

Comment No. 4-47 from Western Watersheds Project: 

This shows that BLM has not prepared the necessary up-front grazing analyses with full public involvement that 

would allow it to understand where these areas are. Where is a map showing the highly degraded areas that BLM 

plans to avoid like the plague? How was this determined? Why is BLM not planning to issue Full Force and Effect 

decisions to address the chronic grazing abuse that is occurring, and try to heal the lands before tearing them to 

3 Bars Project Final EIS D-31 October 2016 
LIVESTOCK GRAZING

pieces? Why is there a large “dis-connect” between action on grazing (which promotes flammable exotic species and 

altered fire cycles, and causes habitat degradation and loss) and any “treatments”? 

Response to Comment No. 4-47:

Figure 3-44 of the Final EIS identifies areas where there is “Moderate to Severe Range Use.”

Comment No. 4-57 from Western Watersheds Project: 

What role has livestock grazing disturbance had in this: Sagebrush monocultures are present. Sagebrush 

“monocultures” are naturally occurring vegetation communities – and there is often considerable structural diversity 

and age class diversity as well as well-developed microbiotic crusts present. What will the effects of removing 

livestock grazing for decades be in turning this around? What is preferable?` The EIS also states: Some streams, 

springs, and meadows are functioning at less than their proper condition. Where are these, and what role has livestock 

grazing had in this? 

Response to Comment No. 4-57:

See response to Comment 4-46 (Livestock Grazing – Environmental Consequences). Also see the Final 3 Bars 

Ecosystem and Landscape Restoration Project Rangeland Health Report (Eastern Nevada Landscape Coalition and 

AECOM 2012). Also see Final EIS Figure 3-24, Proper Functioning Condition Rating, for the location of streams and 

riparian zones that have been surveyed for Proper Functioning Condition.

Comment No. 4-59 from Western Watersheds Project: 

What will BLM actually do about livestock grazing as a cause of deterioration? How will you ensure the lands will 

heal prior to massive bioengineering disturbance? 

Response to Comment No. 4-59: 

See response to Comment 4-10 (Livestock Grazing – Environmental Consequences).

Comment No. 4-60 from Western Watersheds Project: 

What will BLM do about livestock grazing as a cause of deterioration? 

Response to Comment No. 4-60: 

See response to Comment 4-23 (Livestock Grazing - Environmental Consequences). 

Comment No. 4-73 from Western Watersheds Project: 

Why does BLM consistently obsess over livestock forage grass, and not degradation of microbiotic crusts, or 

simplification of sagebrush structural complexity due to livestock that renders areas less suitable for many sagebrush 

species like pygmy rabbit, and for migratory birds and sage-grouse that require complex overhead shrub cover to hide 

nests? Or livestock degradation of understories and microbiotic crusts - which promotes increased tree densities? 

3 Bars Project Final EIS D-32 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-73: 

As noted in 3 Bars Project Final EIS Section 1.3.6, Proposed Action and Purpose and Need, Livestock, and from 

studies cited in the Final Assessment of Existing and Current Conditions for the Proposed 3 Bars Ecosystem and 

Landscape Restoration Project EIS (USDOI BLM 2009a), and Landscape Restoration Project Rangeland Health 

Report (Eastern Nevada Landscape Coalition and AECOM 2012), key perennial grass species are scarce and 

production is below the potential for the natural community over portions of the 3 Bars Project area. Thus, livestock 

would benefit from treatments that improve perennial species, including forage grasses, as would wild horses, other 

wild ungulates, and wildlife. However, the overall goal of the 3 Bars Project is to develop the 3 Bars ecosystem into a 

sustainable, healthy, and resilient landscape for the benefit of a variety of resources, including special status species, 

such as greater sage-grouse, pygmy rabbit, and several species of migratory birds. As discussed in Chapter 2 

(Alternatives) and Section 3.16 (Affected Environment and Environmental Consequences, Wildlife Resources) of the 

Final EIS, treatments are designed to improve riparian, aspen, pinyon-juniper, and sagebrush habitats on the 3 Bars 

ecosystem by providing conditions that favor species that currently use the ecosystem. These include treatments to 

enhance sagebrush cover and promote grass and forb understory to benefit general and special status wildlife, 

including greater sage-grouse, Brewer’s sparrow, sage thrasher, pygmy rabbit, mule deer, and pronghorn antelope. 

Although sagebrush cover is important for these species, they also require forbs and grasses associated with sagebrush 

habitat for their life needs. 

See response to Comment 4-23 (Livestock Grazing - Environmental Consequences), for the scope of analysis 

regarding livestock management on the 3 Bars ecosystem. 

Comment No. 4-96 from Western Watersheds Project: 

BLM wrongly cut out consideration of a new AML [Appropriate Management Level], and addressing the serious 

adverse ecological footprint of the livestock facility network – not only on wild horses, but also on a broad range of 

important and sensitive species and other uses of the public lands. 

Response to Comment No. 4-96:

The AML for wild horses is established through the rangeland health evaluation process.

Comment No. 4-144 from Western Watersheds Project: 

Also, BLM constantly makes highly uncertain statements like “the season of use may be shifted”. Thus, there is no 

way at all of knowing the outcome of effectiveness of the livestock grazing schemes to be imposed on this landscape. 

BLM fails to provide any pastures or allotments as reference areas where grazing is removed so the actual impacts of 

livestock vs. wildlife vs. [wild] horses can be understood. It fails to provide any significant periods of rest to jump 

start recovery. 

Response to Comment No. 4-144:

See response to Comment 4-10 (Livestock Grazing – Environmental Consequences).

3 Bars Project Final EIS D-33 October 2016 
METEOROLOGYAND CLIMATE CHANGE

D.5.8 Meteorology and Climate Change 

D.5.8.1 Meteorology and Climate Change – Cumulative Effects 

Comment No. 4-95 from Western Watersheds Project: 

It [3 Bars Project EIS] greatly fails to address significant impacts of drought in adding to current stresses on the 

landscape. It fails to assess the adverse impacts of inflicting large-scale treatment disturbances on a perennially 

drought-stricken landscape. 

Response to Comment No. 4-95:

Section 3.5, Meteorology and Climate Change, of the 3 Bars Project Final EIS discusses the potential effects of global 

climate change in the Southwest U.S., and notes that some scientists predict an increase in average temperature and 

decrease in average precipitation in the region due to global climate change. Important goals of the 3 Bars Project are 

to improve the health and functionality of the landscape (Final EIS Section 1.1; Introduction), and to improve stream 

and wetland functionality (Final EIS Section 1.3.2; Wetland and Riparian Areas and Water Quality and Quantity). 

Riparian zones were one of four treatment areas targeted for treatment under the proposed 3 Bars Project and 

numerous projects were identified by the BLM in the EIS (see Chapter 2, Alternatives) to improve stream water flows 

and functionality to benefit plants and animals living in a drought environment. Under pinyon-juniper treatments, the 

BLM has identified several projects to thin and/or remove pinyon-juniper to potentially increase water flows in 

streams and improve water infiltration. The adverse and beneficial effects of these treatments are discussed under 

Environmental Consequences in many of the resource sections in the Final EIS. 

D.5.8.2 Meteorology and Climate Change – Environmental Consequences 

Comment No. 4-155 from Western Watersheds Project: 

BLM’s rejection of a full and fair analysis of the adverse effects of climate change on the project and livestock 

grazing that would continue in the disturbed lands must be corrected in a[n] SEIS [Supplemental EIS]. The contractor 

uses the standard rejection language that ignores Beschta et al. 2012, BLM’s own Pellant 2007 Congressional 

Testimony, Dellasala Testimony, Chambers et al. 2009, as well as USFWS’s WBP [Warranted but Precluded] 

Finding for GSG [greater sage-grouse], Knick and Connelly 2009/2011 Studies in Avian Biology, etc. 

Response to Comment No. 4-155:

See response to Comments 4-3 (Livestock Grazing – Environmental Consequences) and 4-95 (Meteorology and 

Climate Change – Cumulative Effects). The BLM is not clear what rejection language is provided by the BLM in the 

EIS, and is therefore unable to respond further. A summary of several of these studies is included in Final EIS Section 

3.5.2.2 (Meteorology and Climate Change, Climate Change) and 3.5.3.3 (Meteorology and Climate Change, 

Cumulative Effects) of the 3 Bars Project Final EIS. 

Comment No. 4-161 from Western Watersheds Project: 

BLM does not seriously assess these concerns, and instead glosses over them and presents information maximally 

supporting its outdated view and incorrect fire and disturbance intervals, that ignore the historical vegetation 

3 Bars Project Final EIS D-34 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

communities, natural plant succession, and the needs of the sensitive species for structurally complex mature and old 

growth woody shrubs and trees, as well as the critical role of microbiotic crusts in land health. 

Response to Comment No. 4-161:

We have discussed the issues identified by the commenter in Final EIS Sections 3.5.2 (Affected Environment) and 

3.5.3 (Environmental Consequences) for Meteorology and Climate Change in the southwestern U.S., including the 3 

Bars Project ecosystem, and discussed the risks to the ecosystem from climate change in qualitative terms. The role of 

microbotic crusts, historic and current vegetation conditions, wildfire intervals, and wildlife habitat, and their 

relationship to land health, are discussed in Chapter 3, Affected Environment and Environmental Consequences, in 

Sections 3.9 (Soil Resources), 3.12 (Native and Non-invasive Vegetation Resources), 3.13 (Noxious Weeds and other 

Invasive Non-native Vegetation), 3.14 (Wildland Fire and Fire Management), and 3.16 (Wildlife Resources) of the 

Final EIS. The information presented in the 3 Bars Project EIS is based on a multitude of studies, as discussed in 

response to Comment 4-148 (Assessment Methodology – Baseline Studies). 

Comment No. 4-162 from Western Watersheds Project: 

BLM includes generic paragraphs about GHG [greenhouse gases], but ignores the loss of the sequestered carbon, and 

loss of the ability to sequester large amounts of carbon, especially if weeds choke the landscape. Then, BLM makes 

unsubstantiated assumptions that: “significant adverse effects will not occur”. This claim is based on minimal 

consideration of GHG only, and while ignoring the loss of sequestered carbon, the strong likelihood of weed 

invasions, added and cumulative impacts from losses due to grazing, mining, and other stresses on the lands, 

vegetation, waters, sensitive species. 

Response to Comment No. 4-162:

See responses to Comments 4-95 (Meteorology and Climate Change – Cumulative Effects) and 4-121 (Air Quality –

Environmental Consequences). 

D.5.9 Mitigation and Monitoring 

Comment No. 4-100 from Western Watersheds Project: 

How has BLM monitoring separated out relative impacts to soils, crusts, vegetation, watersheds, riparian areas, etc. of 

wild horse use vs. cattle/sheep impacts? Where are all monitoring sites? When and how fairly were they established? 

Please provide all monitoring data for the past decade. Has BLM conducted compliance checks to make sure 

livestock were not grazing when not authorized in these areas? 

Response to Comment No. 4-100:

As discussed in Final EIS Section 1.3, Background, numerous factors have contributed toward the current conditions 

of the 3 Bars Project landscape, including livestock management, wild horses, wildfire, and noxious weed 

establishment and spread. The BLM monitors rangeland health through use of rangeland health assessments and 

conducts regular monitoring to verify grazing permit compliance for all current permits. Seventy Key Management 

Areas (KMAs) were evaluated for the Landscape Restoration Project Rangeland Health Report (Eastern Nevada 

3 Bars Project Final EIS D-35 October 2016 
MITIGATION AND MONITORING

Landscape Coalition and AECOM 2012) prepared for the 3 Bars Project EIS. See response to Comment 4-170 (Soil 

Resources - Assessment Methodology) for more information on KMAs, how they were established on the landscape, 

and their use during the study. The BLM establishes monitoring sites on wildfire and other restoration sites. 

Discussion of the results of some of these monitoring studies is given in Final EIS Section 3.12.3, Native and Noninvasive Vegetation Resources, Environmental Consequences, Direct and Indirect Effects, Pinyon-juniper 

Treatments; also see references to monitoring studies in Chapter 5, Reference, under USDOI BLM. These studies can 

be requested from the BLM Battle Mountain District Office. Additional information on monitoring can be found in 

Final EIS Section 2.5.5, Monitoring, and in Appendix C, Standard Operating Procedures. 

Comment No. 4-123 from Western Watersheds Project: 

The BLM proposed monitoring methods and limited periods are greatly inadequate. 

Response to Comment No. 4-123:

Monitoring methods and periods given Section 2.5.5 (Monitoring), in Chapter 3 (Affected Environment and 

Environmental Consequences) for affected resources, and in Appendix C (Standard Operating Procedures) of the 

Final EIS, were developed by the BLM based on the past experience, discussions with resource agencies, and 

scientific literature. As discussed in Final EIS Section 3.18.4, Mitigation, for Livestock Grazing, the BLM would 

follow an adaptive management approach that involves the use of monitoring prior to, during, and after treatments to 

make sure that treatments are designed to meet treatment goals, and to ensure treatment success. As new information 

become available, the BLM would revise monitoring methods and periods if these changes improve future treatment 

success. 

Comment No. 4-124 from Western Watersheds Project: 

The D[raft]EIS is lacking certainty about effectiveness in monitoring and adequate mitigation for this massive 

cumulative disturbance across this landscape. 

Response to Comment No. 4-124:

Monitoring measures and guidance are provided in Section 2.5.5, Monitoring, of the 3 Bars Project Final EIS. 

Standard Operating Procedures used to increase treatment success and to minimize environmental impacts are 

discussed in Appendix C of the Final EIS. The BLM conducts ongoing monitoring studies of past restoration 

treatments on the 3 Bars Project area and nearby, and uses information gained from these studies to improve treatment 

success on future projects; several of these monitoring studies are discussed in the Final EIS, primarily in Section 3.12 

(Native and Non-invasive Vegetation) and 3.13 (Wildland Fire and Fire Management). Although there is no guarantee 

that a treatment will be 100 percent successful, or that there will be no impacts from a treatment, by following 

monitoring measures and guidance, Standard Operating Procedures, and lessons learned from past projects, treatment 

success is greatly improved. 

3 Bars Project Final EIS D-36 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

D.5.10 Native and Non-invasive Vegetation Resources 

D.5.10.1 Native and Non-invasive Vegetation Resources – Affected Environment 

Comment No. 4-67 from Western Watersheds Project: 

What is all the underlying information used in compiling Map 1? BLM lumps many different factors together, and 

colors in areas to massively disturb and promote weeds in, and greatly alter, fragment and destroy PJ communities 

and sagebrush communities, as well. We note the underlying contours show that BLM in particular targets naturally 

occurring PJ communities in steep, rugged mountainous terrain at higher elevations –which is precisely where PJ is 

the naturally occurring native vegetation community across the region. Is this derived in some part from the Scoping 

Mapping? If so, that showed there should be no PJ present in the landscape – at all – which is incorrect and false. 

Response to Comment No. 4-67:

See response to Comment 4-78 (Assessment Methodology - General). The Map 1 presented during scoping was 

developed by integrating maps prepared for the Final Assessment of Existing and Current Conditions for the 

Proposed 3 Bars Ecosystem and Landscape Restoration Project EIS (USDOI BLM 2009a) that showed degraded 

conditions for numerous resources found on the 3 Bars Project area. Resource conditions were developed based on 

field studies, aerial photography, GIS, and other methods, and maps were used to preliminarily identify potential 

treatment areas for review by the public during scoping. Based on this information, and discussions with other 

agencies, the BLM Interdisciplinary Team identified specific treatment areas through an iterative process, as 

discussed in Final EIS Section 2.3 (Description of the Action Alternatives). As discussed under Comment 4-78, 

pinyon-juniper is found on about 25 percent of the study area; older Phase III pinyon-juniper stands comprise about 

19 percent of pinyon-juniper woodlands (see Final EIS Section 3.12.2.2.9; Native and Non-invasive Vegetation 

Resources, Pinyon-juniper Woodland). About 20 percent of pinyon-juniper treatments would be in Phase III stands, 

primarily to remove dead and unhealthy trees and to thin trees to improve forest health and pine nut production and 

reduce hazardous fuels and risk of wildfire. Although some pinyon-juniper trees may be removed from steep, rugged 

terrain, these areas would typically be avoided for treatments due to access difficulty, risk of a prescribed fire leaving 

the treatment area, risks to paleontological resources found in rock outcrops, and potential to inadvertently kill or 

harm old-growth pinyon-juniper and limber pine.

Comment No. 4-68 from Western Watersheds Project: 

So, is the Scoping mapping part of the basis for the D[raft]EIS? What vegetation community baseline information was 

used in developing Map 1, and all the findings of deficiencies lumped in various categories? 

Response to Comment No. 4-68:

See response to Comment 4-78 (Assessment Methodology - General).

Comment No. 4-146 from Western Watersheds Project: 

The livestock cumulative effects analysis claims that the health studies have shown that early to mid-seral vegetation 

dominates the allotments. What does this mean? How was this determined? The sage[brush] communities are not 

3 Bars Project Final EIS D-37 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

3 Bars Project Final EIS D-38 October 2016 

early seral. How is “seral” defined by AECOM/ENLC [Eastern Nevada Landscape Coalition]? Is this referring to the 

areas that burned in fires? Won’t the treatments make there be many more acres in early-mid seral, not fewer? 

Response to Comment No. 4-146:

It means that early- to mid-seral vegetation dominates the allotments. Seral refers to the stages that plant communities 

go through during succession. Developmental stages have characteristic structure and plant species composition. In a 

forest, for example, early seral forest refers to seedling or sapling growth stages; mid-seral refers to pole or medium 

saw timber growth stages; and mature or late seral forest refers to mature and old-growth stages as defined in the 

glossary. Treatments may increase acres that are early-seral stage.

Comment No. 4-197 from Western Watersheds Project: 

Table 3-22 [of the EIS] shows that there is actually less sage[brush] and less PJ [pinyon-juniper] than is expected 

based on the soil surveys.[Page] 3-152 [of the Draft EIS] shows how out of whack the excess “grasslands” are –

Response to Comment No. 4-197:

Table 3-22 (Current and Expected Vegetation Types within the 3 Bars Project Area) of the 3 Bars Project EIS 

indicates that there may be less pinyon-juniper and sagebrush on the 3 Bars Project area than is expected based on 

USDA Natural Resources Conservation Service (2012) assessments. However, as noted in Final EIS Section 

3.12.2.2.9, Native and Non-invasive Vegetation Resources, Pinyon-juniper Woodland, and Table 3-22, existing 

acreage of pinyon-juniper does not include about 118,000 acres of Phase I pinyon-juniper stands. Although most 

Phase I pinyon-juniper stands consist of trees scattered within other vegetation types, they are indicative of areas 

where pinyon-juniper is encroaching into other vegetation types and, over time, could be the dominant vegetation in 

those areas and would result in pinyon-juniper occupying more area than is expected within the 3 Bars Project area. 

Recent large fires have resulted in the conversion of sagebrush habitat to grassland comprised of native, fire-induced, 

and man-made grass cover, as referenced in Table 3-22. As discussed in Final EIS Section 2.3.1.4, Sagebrush 

Treatment Units, over 60 percent of sagebrush treatment acreage would be to convert grassland habitat back to 

sagebrush habitat in areas where sagebrush historically occurred. 

Comment No. 4-198 from Western Watersheds Project: 

This shows there are too many grasslands already – yet the projects will make more grasslands! So why in the world, 

once it realized this – why didn’t BLM stop right there and focus on restoring 47,000 acres of grassland to native 

shrubs and trees???

Response to Comment No. 4-198:

See response to Comment 4-197 (Native and Non-invasive Vegetation Resources – Affected Environment). 

Comment No. 4-204 from Western Watersheds Project: 

What is included in the understory production figures – wood? What is the “understory production” of crusts 

supposed to be? It is clear this 20 to 35 percent figure for juniper is drawn out of thin air. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-204:

It is not clear what the commenter is referring to, although it appears to be related to Table 3-30, Ecological Sites for 

Pinyon-juniper Community, which indicates that the average canopy cover for pinyon-juniper is about 20 to 35 

percent based on the USDA Natural Resources Conservation Service Rangeland Ecological Site Description for 

Potential Native Vegetation (also called Potential Natural Community). Understory production is for grasses, forbs, 

and shrubs within 4.5 feet of the ground surface, and includes species listed in Table 3-30 (Ecological Sites for 

Pinyon-juniper Community). This information is based on Ecological Site Descriptions developed by the USDA 

Natural Resources Conservation Service (2012) for the 3 Bars Project area, as discussed in Section 3.12.2.2, Native 

and Non-invasive Vegetation Resources, Vegetation Communities, of the Final EIS. More information on how the 

USDA Natural Resources Conservation Service developed the Ecological Site Descriptions can be found at: 

https://esis.sc.egov.usda.gov/. Another good source of information is Chapter 3 in the BLM Technical Reference 

1734-7, Ecological Site Inventory (Habich 2001). 

Comment No. 4-217 from Western Watersheds Project: 

What was the climax vegetation community that the early middle and late successional status (used by ENLC 

[Eastern Nevada Landscape Coalition] and shown in Map Figure 3-29.

Response to Comment No. 4-217:

As discussed in Final EIS Section 3.12.2.3, Native and Non-invasive Vegetation Resources, Allotment Vegetation 

and Monitoring Studies, the successional status shown on Figure 3-29 of the Draft EIS (Current Rangeland 

Conditions) is based on the relationship between vegetation found on the area in comparison to the Potential Natural 

Community. As discussed in Section 2.1.1 of the Landscape Restoration Project Rangeland Health Report (Eastern 

Nevada Landscape Coalition and AECOM 2012), “a potential natural community (PNC) is defined as the biotic 

community that would become established on an ecological site if all successional sequences were completed without 

interference by people under the present environmental conditions (Habich 2001). PNC production is based on the 

Ecological Site Description for the site.” See response to Comment 4-204 (Native and Non-invasive Vegetation 

Resources – Affected Environment) and Final EIS Section 3.12.2.1, Native and Non-invasive Vegetation Resources, 

Study Methods and Analysis Area, on how Ecological Site Descriptions were developed for the 3 Bars Project area 

and used in the vegetation analysis for the 3 Bars Project EIS. 

D.5.10.2 Native and Non-invasive Vegetation Resources – Affected Environment - Pinyonjuniper 

Comment No. 4-19 from Western Watersheds Project: 

Where are forest areas producing pine nut seeds for pinyon jays? 

Response to Comment No. 4-19:

Pinyon pine produce pine nuts where the trees occur, based upon natural cycles, and not for specific animals. 

Comment No. 4-21 from Western Watersheds Project: 

Where have trees been treated, removed, cut, chained, burned, etc. in the past for all periods for which records have 

been kept? 

3 Bars Project Final EIS D-39 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

Response to Comment No. 4-21:

The BLM has implemented projects that have removed trees for the Red Hills and Sulphur Springs fuels projects, and 

Roberts Mountain Bootstraps project. Personal use and commercial use fuel wood removal also occurs within the 

project area. 

Comment No. 4-25 from Western Watersheds Project: 

We have repeatedly asked BLM to consult its own historical survey records in order to understand the naturally 

occurring native vegetation across the Battle Mountain District and central Nevada. When were the original General 

Land Office surveys conducted for this region? Which areas had early survey records? What does cross-walking the 

info[rmation] on occurrence of pinyon-juniper vegetation (and also water in drainages/springs) show about the 

elevations and other conditions where pinyon-juniper is the naturally occurring historical plant community? 

What role does livestock grazing and climate change play in this? What role has past BLM treatment played in this? 

Response to Comment No. 4-25:

The original General Land Office surveys were conducted from the mid-1800s to the early 1900s. The goals and 

objectives of this project can be found in Chapter 2 of the EIS, but do not include achieving any “historic” 

distribution. 

Comment No. 4-58 from Western Watersheds Project: 

Other key vegetation concerns identified in the AECC included the expansion of the pinyon-juniper plant community 

onto adjacent range sites and encroachment into the interspaces within woodland sites. Where specifically is there 

expansion, and how has BLM determined this is expansion and not re-occupation and/or natural succession? 

Response to Comment No. 4-58:

See response to Comment 4-78 (Assessment Methodology - General) on how pinyon-juniper communities were 

mapped on the 3 Bars Project area. As shown on Figure 3-27, Pinyon-juniper Phase Classes, and discussed in Section 

3.12.2.2.9, Native and Non-invasive Vegetation Resources, Pinyon-juniper Woodlands, of the Final EIS, Phase I and 

II areas are areas where pinyon-juniper woodland expansion is occurring. The BLM determined that areas of potential 

expansion are areas where pinyon-juniper woodlands have not historically been present, based on the Ecological Site 

Descriptions and soil surveys for those areas. 

Comment No. 4-76 from Western Watersheds Project: 

Where are all historic Pinyon-juniper communities, and how did you identify them? What is a “proper ecological 

state”, and how was it defined, descried, and what scientific studies and site-specific information is this based on? 

Response to Comment No. 4-76:

See response to Comment 4-78 (Assessment Methodology – General). As discussed in the 3 Bars Ecosystem and 

Landscape Restoration Project Pinyon-juniper Assessment (AECOM 2011a), field surveys of the project area were 

conducted during November 2009 and February 2010 to identify and map the occurrence of pinyon-juniper stands by 

phase class, and to identify old growth pinyon-juniper. Surveyors used visual observations of tree characteristics to 

3 Bars Project Final EIS D-40 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-41 October 2016 

help determine tree age in the field based on information provided in Romme et al. (2007). At locations where trees 

exhibited old-growth characteristics, surveyors verified tree age by extracting tree cores and cross-dating the rings. 

Only pinyon pines were selected for age analysis, since junipers are generally very difficult to cross-date. 

Comment No. 4-79 from Western Watersheds Project: 

BLM proposes to remove all Phase I and Phase II Pinyon-juniper – this is disastrous. Why in the world would you 

propose this? Many areas of Phase I and Phase II PJ [pinyon-juniper] are actually trees re-occupying sites in which 

they naturally occur. Like sites where BLM purposefully destroyed them in the past. How were all Phase I and Phase 

II sites identified? Was ENLC [Eastern Nevada Landscape Coalition] involved in this? How were trees aged? Was 

there evidence of old burned wood, or stumps on the ground? What did Historical survey and mining era records 

show? 

Response to Comment No. 4-79:

See response to Comment 4-76 (Native and Non-invasive Vegetation Resources – Affected Environment – Pinyonjuniper ) regarding studies used to identify and age pinyon-junipers within the 3 Bars Project area. Eastern Nevada 

Landscape Coalition was not involved in pinyon-juniper mapping. Final EIS Section 3.12.2.6, Native and Noninvasive Vegetation Resources, Historic Use of Pinyon-juniper Woodlands, discusses the historic use of pinyonjuniper woodlands within and near the 3 Bars Project area. Only about a sixth to a third of the area with pinyonjunipers would be treated during the life of the proposed 3 Bars Project under Alternative A. Of this area, about 80 

percent consists of Phase I and Phase II pinyon-juniper. For many projects, only a portion of trees would be removed 

(thinned). 

Comment No. 4-80 from Western Watersheds Project: 

BLM claims it plans to keep old growth trees greater than 150 years in Phase I and Phase II elimination zones. Where 

are all such trees? How were they inventoried and identified? Doesn't the presence of the old growth trees show you 

that they are the naturally occurring native vegetation communities on these sites, or at a minimum – a very important 

component of the native vegetation community and biodiversity? 

Response to Comment No. 4-80:

See response to Comment 4-76 (Native and Non-invasive Vegetation Resources – Affected Environment – Pinyonjuniper). Old-growth pinyon-juniper stands are shown on Final EIS Figure 3-27, Pinyon-juniper Phase Classes. 

Because of their importance to wildlife, wild horses, Native Americans, general public, and other users, pinyonjunipers are an important component of the native vegetation community and contribute to the biodiversity on the 3 

Bars Project area; they are one of four treatment groups evaluated in the EIS. As noted for the purposes of the project 

in Final EIS Section 1.5 (Purposes of the Project), proposed BLM treatments include efforts to manage pinyon-juniper 

woodlands to promote healthy, diverse stands within persistent woodlands and to manage pinyon-juniper and other 

woodlands stands to benefit wildlife, and Native Americans that use these trees for medicinal purposes. 

Comment No. 4-82 from Western Watersheds Project: 

BLM must assess where the significant impacts of continued grazing disturbance are: Retarding passive restoration 

and failing to allow native understories and microbiotic crusts to recover, and/or conflicts with the recovery of treated 

lands and also with the needs of sensitive species. A recent Ninth Circuit decision specifically said that at the Project 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

level, BLM needed to consider livestock allocations. In order to address the livestock grazing conflicts with 

restoration, biodiversity, HMAs, etc. and the degree to which continued livestock grazing will promote hazardous 

flammable fuels, this EIS is the appropriate and proper place to do so. 

Response to Comment No. 4-82: 

Impacts to resources from the proposed actions and cumulative impacts, including from livestock grazing, can be 

found in Chapter 3 for each resource in the Environmental Consequences sections. 

Comment No. 4-202 from Western Watersheds Project: 

The D[raft] EIS states that PJ [pinyon-juniper] now covers (only) approx[imately] 25% of the project area. (Phase II 

and III). The Ecological [Site] description finds trees should be present on 27 % of the area. So why the need for 

massive expensive treatments? 

Response to Comment No. 4-202:

See response to Comment 4-197 (Native and Non-invasive Vegetation Resources – Affected Environment). 

Comment No. 4-205 from Western Watersheds Project: 

BLM repeatedly cites Romme 2007, ignoring the series of Romme et al. 2009 papers that undermine the long-held 

myths perpetuated by Miller (who has always been dramatically wrong about sage-brush) and Tausch who does not 

concern himself with understanding the impacts of historical mining deforestation in the Great Basin but yet has 

always drawn sweeping conclusions about PJ [pinyon-juniper] communities. 

Response to Comment No. 4-205:

The BLM included the Romme et al. (2007) article entitled Historical and Modern Disturbance Regimes, Stand 

Structures, and Landscape Dynamics in Pinon-Juniper Vegetation of the Western United States in Draft EIS Section 

3.12.2.2.9, Native and Non-invasive Vegetation Resources, Pinyon-juniper Woodland. This article was referenced in 

the discussion of pinyon-juniper phase classes. For the Final EIS, the BLM has included information from the article, 

which was published in 2009 in the journal Rangeland Ecology and Management, on the mechanisms of infill and 

expansion, and other papers that discuss pinyon-juniper infill and expansion, in Section 3.12.2.2.9, Native and Noninvasive Vegetation Resources, Pinyon-juniper Woodland. 

Comment No. 4-206 from Western Watersheds Project: 

Generally, areas of potential expansion are areas in which pinyon-juniper woodlands have not historically been 

...What does this mean? Is BLM treating areas where the trees are not yet present? 

Response to Comment No. 4-206:

As discussed in Section 3.12.2.2.9 (Native and Non-invasive Vegetation Resource, Pinyon-juniper) of the Final EIS 

(and on page 3-177 of the Draft EIS), where this statement is referenced, generally, areas of potential expansion are 

areas in which pinyon-juniper woodlands have not historically been present, such as sagebrush and riparian habitat. 

Pinyon-juniper have begun to encroach into these areas (Phase I), and the BLM proposes to use manual and other 

methods to remove a portion of pinyon-juniper currently found in these areas before they have the opportunity to 

3 Bars Project Final EIS D-42 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

dominate the area and lead to the loss of vegetation that is, and historically has been, the dominant vegetation on the 

treatment area. 

Comment No. 4-207 from Western Watersheds Project: 

How do you end up delineating the area into Juniper Phases if there are not trees? Is this done to justify spending 

more money on million dollar EISs? 

Response to Comment No. 4-207:

Only areas with pinyon-juniper were mapped on Final EIS Figure 3-27, Pinyon-juniper Phase Classes. In Phase I 

areas and to a lesser extent in Phase II areas, however, pinyon-juniper are generally scattered and do not cover most or 

all of the area. Areas that did not include pinyon-juniper were mapped as other vegetation types, as shown on Figures 

3-25 (Current Vegetation Communities) and 3-26 (Major Vegetation Communities in the 3 Bars Project Area based 

on Ecological Site Data). 

D.5.10.3 Native and Non-invasive Vegetation Resources – Affected Environment - 

Sagebrush 

Comment No. 4-50 from Western Watersheds Project: 

Try figuring out just how little sage[brush] the Ecosites [Ecological Site Descriptions] claim should be present - not 

enough to hide a sagebrush vole, let alone a pygmy rabbit. A Supplemental EIS must be prepared t[o] examine this 

factor alone. 

Response to Comment No. 4-50:

As discussed in Section 3.12.2.2, Affected Environment, Vegetation Communities, and shown on Figures 3-25 

(Current Vegetation Communities) and 3-26 (Major Vegetation Communities in the 3 Bars Project Area based on 

Ecological Site Data) of the Final EIS, there are approximately 430,709 acres of sagebrush on the 3 Bars Project area, 

comprised of big sagebrush, low sagebrush, and black sagebrush. Sagebrush comprises about 57 percent of the 3 Bars 

Project area. Based on studies conducted by the USDA Natural Resources Conservation Service (2012), 

approximately 460,144 acres of sagebrush are expected on the area, with about half of the difference associated with 

the black sagebrush community. As discussed in Final EIS Section 2.3 1.4, Sagebrush Treatments, the BLM proposes 

to treat approximately 31,300 acres to enhance sagebrush habitat; much of this acreage would include treatments to 

reseed or replant sagebrush in areas that are degraded, but historically contained sagebrush habitat. 

Comment No. 4-53 from Western Watersheds Project: 

BLM and the false Ecosites [Ecological Site Descriptions] ignore the recent work by Bukowski and Baker and others 

that show naturally dense sagebrush was historically commonplace across the Great Basin. They ignore the work by 

Romme et al., Lanner and Frazier 2012, and the classic work on Nevada’s PJ [pinyon-juniper] communities – Dr. Ron 

Lanner’s The Pinyon Pine. 

Response to Comment No. 4-53:

See response to Comment 4-205, Native and Non-invasive Vegetation Resources – Affected Environment – Pinyonjuniper. The BLM included information on historical fire regimes in sagebrush landscapes from the Bukowski and 

3 Bars Project Final EIS D-43 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

3 Bars Project Final EIS D-44 October 2016 

Baker (2013) paper in Final EIS Section 3.12.2.2.2, Native and Non-invasive Vegetation Resources, Big Sagebrush. 

As discussed in Final EIS Section 3.2, Summary of Major Changes between the Draft and Final EIS, the BLM is no 

longer proposing to thin sagebrush within the 3 Bars Project area. 

Comment No. 4-203 from Western Watersheds Project: 

What is the basis for the 20 to 35 percent canopy cover claims for mixed Wyoming big sage[brush], juniper sites 

“assumed to be representative”? What specific reference sites and other information are all these percentages based 

on? 

Response to Comment No. 4-203:

See response to Comment 4-204 (Native and Non-invasive Vegetation Resources – Affected Environment). 

D.5.10.4 Native and Non-invasive Vegetation Resources – Assessment Methodology –

Baseline Studies 

Comment No. 4-26 from Western Watersheds Project: 

BLM has not conducted the systematic baseline species, resource and habitat use inventories necessary to understand 

how severe the impacts will be, and if there is enough population or habitat or perennial water flow to absorb the 

habitat destruction and bioengineering bulldozing blows the projects will unleash. This is all necessary to understand 

the sustainability of the resources affected and/or threatened by the project. These are ALL the resources and values 

of the public lands BLM discusses in EIS These inventories must be conducted across the entire project area and 

surrounding lands. BLM cannot rely on the severely flawed AECOM ENLC [Eastern Nevada Landscape Coalition] 

vegetation info[rmation] in this at all - which finds nearly all lands unhealthy, and where almost the only way an areas 

would be considered healthy would be to destroy all the woody vegetation structure that the sensitive sage[brush] and 

PJ [pinyon-juniper] species rely upon, and that serves to protect watersheds. 

Response to Comment No. 4-26:

As discussed in response to Comments 4-78 (Assessment Methodology - General) and 4-148 (Assessment 

Methodology – Baseline Studies), the BLM, other agencies, and contractors have conducted numerous studies of the 

natural resources found on the 3 Bars Project area. These included studies for the Mount Hope Mine Project and 3 

Bars Project. The Landscape Restoration Project Rangeland Health Report (Eastern Nevada Landscape Coalition and 

AECOM 2012) describes the methods and results of a study to evaluate rangeland health on the 3 Bars Project area. 

The BLM has also conducted studies of rangeland health on those areas within the 3 Bars Project area that were not 

evaluated by Eastern Nevada Landscape Coalition. Rangeland health is defined as “the degree to which the integrity 

of the soil, vegetation, water, and air, as well as the ecological processes of the rangeland ecosystem are balanced and 

sustained.” Integrity in this circumstance is defined as “maintenance of the functional attributes characteristic of a 

locale, including normal variability” (University of Nevada Cooperative Extension et al. 2006). 

The rangeland health assessments followed established protocols developed by the BLM and other federal and state 

agencies, as described in Section 2 of the Landscape Restoration Project Rangeland Health Report. The rangeland 

health assessment conducted by Eastern Nevada Landscape Coalition was not designed to identify the cause(s) of 

resource problems, or suggests treatments to restore degraded resources, but to identify areas that are degraded or are 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-45 October 2016 

at risk of degradation. The information derived from the report will be used by the BLM to determine rangeland 

health and to facilitate corrective actions to improve rangeland health. 

Comment No. 4-49 from Western Watersheds Project: 

We stress that the interested public was not informed of these assessments, even though they greatly impact the fate of 

grazing allotments and HMAs. 

Response to Comment No. 4-49:

The Final Assessment of Existing and Current Conditions for the Proposed 3 Bars Ecosystem and Landscape 

Restoration Project EIS (USDOI BLM 2009a) was provided to the public at the time of public scoping (early 2010). 

This document referenced several field studies that were needed in support of the 3 Bars Project EIS. Field studies 

associated with the Landscape Restoration Project Rangeland Health Report (Eastern Nevada Landscape Coalition 

and AECOM 2012) were just beginning at the time of public scoping, and were not completed until about a year after 

scoping concluded; it took another year to prepare the report. Several other field studies conducted for the 3 Bars 

Project, including pinyon-juniper (AECOM 2011a) and cheatgrass (AECOM 2011b) studies, were not completed 

until 2012. Please contact the BLM Mount Lewis Field Office if you would like to review these documents. 

Comment No. 4-196 from Western Watersheds Project: 

It is entirely inadequate to merely rely on Mount Hope rare plant studies –as they were conducted over only one small 

part of this very large and significant land area. 

Response to Comment No. 4-196:

The BLM relied on several sources for information on rare plants as discussed in Section 3.12.2.1, Native and Noninvasive Vegetation Resources, Study Methods and Analysis Area, of the Final EIS, including the Mount Hope Mine 

Project EIS, Nevada Natural Heritage Program and Nevada Native Plant Society databases and resources, and 

observations from BLM and other state and federal agency scientists, including the USFWS. As discussed in Final 

EIS Appendix C, Section C.3.2.2, Special Status Species, “before any vegetation treatment or ground disturbance 

occurs, BLM policy requires that the Mount Lewis Field Office survey the treatment site for species listed or 

proposed for listing, and for special status species. This must be done by a qualified biologist and/or botanist who 

consults the state and local databases and visits the site during the appropriate season.” By consulting previous studies 

and conducting pre-treatment surveys, potential risks to rare plants should be avoided or minimized. 

Comment No. 4-223 from Western Watersheds Project: 

BLM states that: No focused special status plant surveys have been conducted in support of this project. Well, if BLM 

truly was interested in native vegetation, protection of biodiversity, etc. it would have systematically conducted 

special status plant surveys across the project area. 

Response to Comment No. 4-223:

See response to Comment 4-196 (Native and Non-invasive Vegetation Resources – Assessment Methodology –

Baseline Studies). 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

3 Bars Project Final EIS D-46 October 2016 

D.5.10.5 Native and Non-invasive Vegetation Resources – Assessment Methodology–- Key 

Management Areas 

Comment No. 4-141 from Western Watersheds Project: 

We are concerned that BLM arbitrarily cherry-picked 70 new key areas (or was it AECOM/ENLC [Eastern Nevada 

Landscape Coalition]?), but does not appear to have involved the public in this. We are concerned that there appears 

no rationale for why the particular allotments were selected. 

Response to Comment No. 4-141:

Rangeland health studies included assessments of the ecological status and erosion potential at 70 Key Management 

Areas (KMAs) found within the 3-Bars ecosystem. KMAs are indicators that are able to reflect what is happening on 

a larger area because of on the ground management actions. The KMAs were established by the BLM based on the 

following criteria: area selected representative of a larger area of interest (i.e. wildlife habitat or livestock grazing); 

area is located within a single ecological site and plant community; area contains key species; and the area is capable 

of, and likely to show, a response to management actions, this response should be indicative of the response that is 

occurring on larger scale. Nearly all of the proposed treatment areas are found within areas evaluated with KMAs. 

D.5.10.6 Native and Non-invasive Vegetation Resources – Assessment Methodology –

Modeling 

Comment No. 4-27 from Western Watersheds Project: 

So just how does this current D[raft]EIS mapping and info[rmation] differ from Scoping info? Wasn’t that the basic 

information that was used (at least in part) in developing the treatments? The agency, still bound at the hip with the 

livestock industry, continues to rely on flawed livestock forage-biased NRCS [Natural Resources Conservation 

Service] Ecosite [Ecological Site Descriptions] and Soil Survey models, and severely flawed FRCC [Fire Regime 

Condition Class] and other schemes. These models claim, essentially, that pinyon-juniper should not occur across vast 

areas of this landscape - including right here in the very elevation and precipitation range where plant ecologists have 

long recognized they naturally occur. This is also the same elevation and precipitation range where General Land 

Office Records from the original land surveys conducted across Nevada show that pinyon-juniper was historically the 

naturally occurring natural climax vegetation type.

Response to Comment No. 4-27:

See response to Comment 4-78 (Assessment Methodology - General) regarding mapping done for public scoping and 

Ecological Site Inventories conducted by the USDA Natural Resources Conservation Service. As shown on Figure 3-

27, Pinyon-juniper Phase Classes, and discussed in Final EIS Section 3.12.2.2.9, Native and Non-invasive Vegetation 

Resources, Pinyon-juniper Woodlands, pinyon-juniper is found on about 209,176 acres in Phases II and III, and 

another 118,000 in Phase I, or about 43 percent of the 3 Bars Project area (although trees are more widely scattered in 

areas with Phase I and II areas). Thus, pinyon-juniper has been mapped on over 40 percent of the 3 Bars Project area. 

Phase III areas are those with dense stands of pinyon-juniper, including climax communities, and comprise about 19 

percent of all pinyon-juniper acreage. Section 3.12.2.6, Native and Non-invasive Vegetation Resources, Historic Use 

of Pinyon-juniper Woodlands, of the Final EIS discusses the historic use of pinyon-juniper woodlands within the 3 

Bars Project area. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Comment No. 4-28 from Western Watersheds Project: 

And, where the trees do occur, and where there is any mature or old growth sage[brush] (i.e. sensitive species habitat), 

the models claim the sage[brush] and trees are ‘unhealthy” “decadent”, and only killing a lot of it to foster forage 

grasses can result in a “healthy” (based on the flawed models) landscape. 

Response to Comment No. 4-28:

See response to Comment 4-204 (Native and Non-invasive Vegetation Resources – Affected Environment) and Final 

EIS Section 3.12.2.1, Native and Non-invasive Vegetation Resources, Study Methods and Analysis Area, on how 

Ecological Site Descriptions were developed for the 3 Bars Project area and used in the vegetation analysis for the 

EIS. These descriptions are used to determine the Potential Natural Community, as shown in Table 3-30 (Ecological 

Sites for Pinyon-juniper Community) of the EIS for pinyon-juniper. They do not provide information on the health of 

the pinyon-juniper community. The health of pinyon-juniper stands in proposed 3 Bars Project treatment areas was 

determined by on-the-ground assessments conducted by the BLM. As discussed under response to Comment 4-80 

(Native and Non-invasive Vegetation Resources – Affected Environment – Pinyon-Juniper), proposed BLM 

treatments include efforts to manage pinyon-juniper woodlands to promote healthy, diverse stands within persistent 

woodlands and to manage pinyon-juniper and other woodlands stands to benefit wildlife, and Native Americans that 

use these trees for medicinal purposes (see Final EIS Section 1.5, Purposes for the Project). These include treatments 

to improve production of forage to benefit wildlife and wild horses. 

Comment No. 4-29 from Western Watersheds Project: 

This flawed reasoning must be set aside by BLM. You can’t save this landscape by the equivalent of waging war on it 

and killing off the woody vegetation as the “enemy”. The NRCS [Natural Resources Conservation Service] Ecosites 

[Ecological Site Descriptions] are modeled, not based on reality. In Nevada, many of the recent soil surveys were 

done based on only the vegetation that was currently growing on the sites, with no effort to examine the site history, 

historical natural vegetation, (like wood stumps, burned wood, etc.) etc. They were also conducted long after BLM’s 

massive “treatment” wave that started in the 1950s, which was preceded of course by massive mining era 

deforestation (see Dr. Ron Lanner’s book The Pinyon Pine), and chronic promiscuous burning by sheepherders and 

others in the late 1800s and early 1900s. They are based on incorrect assumptions about the natural woody vegetation 

occurrence, woody vegetation density, and incorrect claims about fire return intervals as well. They are also strikingly 

biased towards grass (vs. sage[brush] and trees and critical microbiotic crusts). They rely upon inaccurate fire 

disturbance and historical range of variability information. 

Response to Comment No. 4-29:

See response to Comment 4-78 (Assessment Methodology - General) regarding mapping done for public scoping and 

Ecological Site Inventories conducted by the USDA Natural Resources Conservation Service. See response to 

Comment 4-76 (Native and Non-invasive Vegetation Resources – Affected Environment –Pinyon-juniper) for a 

discussion of field studies to assess pinyon-juniper found on the 3 Bars Project area. Section 3.12.2.6, Native and 

Non-invasive Vegetation Resources, Historic Use of Pinyon-juniper Woodlands, of the Final EIS discusses the 

historic use of pinyon-juniper woodlands within the 3 Bars Project area. The BLM has no intention to remove all of 

the woody vegetation on the 3 Bars Project area. As discussed under response to Comment 4-80 (Native and Noninvasive Vegetation Resources – Affected Environment – Pinyon-Juniper), proposed BLM treatments include efforts 

to manage pinyon-juniper woodlands to promote healthy, diverse stands within persistent woodlands and to manage 

3 Bars Project Final EIS D-47 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

pinyon-juniper and other woodlands stands to benefit wildlife, and Native Americans that use these trees for 

medicinal purposes (see Final EIS Section 1.5, Purposes for the Project). Removal of pinyon-juniper would primarily 

occur in Phase I stands where trees are encroaching into other vegetation communities, such as riparian and 

sagebrush. Treatments in Phase II and III stands would primarily focus on removing decadent and diseased trees to 

reduce hazardous fuels and to improve woodland health, as discussed in Final EIS Sections 2.3.1.3, Alternatives, 

Pinyon-juniper Treatments, and 3.12.3, Native and Non-invasive Vegetation Resources, Environmental 

Consequences. 

D.5.10.7 Native and Non-invasive Vegetation Resources – Assessment Methodology –

Pinyon-juniper 

Comment No. 4-214 from Western Watersheds Project: 

How has BLM determined areas of potential expansion? 

Response to Comment No. 4-214:

See response to Comment 4-79 (Native and Non-invasive Vegetation Resources – Affected Environment –PinyonJuniper) for a discussion of field studies to assess pinyon-juniper found on the 3 Bars Project area. More detailed 

information is found in Final EIS Section 3.12.2.1, Native and Non-invasive Vegetation Resources, Study Methods 

and Analysis Area, and in the 3 Bars Ecosystem and Landscape Restoration Project Pinyon-juniper Assessment 

(AECOM 2011a). 

D.5.10.8 Native and Non-invasive Vegetation Resources – Assessment Methodology –

Rangeland Health 

Comment No. 4-142 from Western Watersheds Project: 

Honestly and accurately conduct valid rangeland health assessments. These are not properly selected sites or properly 

conducted assessments under the FRH [Fundamentals of Rangeland Handbook]. 

Response to Comment No. 4-142:

See response to Comment s4-26 and 4-78 (Assessment Methodology - General).

Comment No. 4-199 from Western Watersheds Project: 

Yet BLM’s AECOM/ENLC [Eastern Nevada Landscape Coalition] reporting is developed to maximize disturbance, 

and this greatly biases the EIS alternatives against passive restoration. 

Response to Comment No. 4-199:

See response to Comment 4-26 (Native and Non-invasive Vegetation Resources - Assessment Methodology –

Baseline Studies). The rangeland health assessments conducted by Eastern Nevada Landscape Coalition and the 

BLM, were not designed to identify the cause(s) of resource problems, or suggest treatments to restore degraded 

resources, but to identify areas that are degraded or are at risk of degradation. The information derived from these 

assessments is being used by the BLM to determine rangeland health and to facilitate corrective actions to improve 

rangeland health. As discussed in Chapter 2 of the EIS, alternatives were developed to respond to the purposes and 

3 Bars Project Final EIS D-48 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

needs for the 3 Bars Project, as discussed in Chapter 1. Alternatives differ by methods used and acres treated, and 

include Alternative C, the Minimal Land Disturbance Alternative, which only involves the use of manual and 

classical biological control methods, which would have cause little disturbance to the land. All action alternatives, 

however, would seek to improve rangeland health. 

Comment No. 4-215 from Western Watersheds Project: 

How were the KMAs in the so-called range health assessment that ENLC [Eastern Nevada Landscape Coalition] was 

involved in, selected? Are these the BLM “trend” sites – if so, those are specifically selected for measuring cow 

utilization, are often not representative at all of rugged or rough areas, or areas that actually receive a significant 

amount of livestock use. They provide no valid basis for conducting a systematic rangeland health assessment. 

Response to Comment No. 4-215:

See response to Comment 4-141 (Native and Non-invasive Vegetation Resources – Assessment Methodology–- Key 

Management Areas). 

Comment No. 4-216 from Western Watersheds Project: 

Why did ENLC [Eastern Nevada Landscape Coalition] conduct rangeland health studies in December? Forbs would 

be all dried up and scarcely noticeable. This, of course, would bias the outcome of the “health” assessment to come 

out more unhealthy, and thus in need of treatment. How severe were the sites grazed? Was there snow?

Response to Comment No. 4-216:

Data collection for the rangeland health assessment was conducted by Eastern Nevada Landscape Coalition during 

fall 2009, including 1 week in December, and spring and summer 2010. Utilization data were collected during fall 

2009. 

BLM protocol does not require measuring the utilization of forbs for rangelands, but does require measuring the 

utilization of perennial grasses and shrubs. Thus, the condition of forbs during late fall 2009 was not a factor in 

determining utilization. 

Eastern Nevada Landscape Coalition did not collect field data if snow impeded the viewing of plants. Snow was 

scarce during fall 2009, and where it occurred it was patchy and primarily under shrubs. Eastern Nevada Landscape 

Coalition normally does not collect utilization data under shrub canopies because cattle typically graze in the 

interspaces. Figure 3-44 (Range Use and Treatment Areas) in the 3 Bars Project EIS shows areas with moderate to 

severe range use. 

Comment No. 4-218 from Western Watersheds Project: 

Production is a measurement of the above-ground weight of the sampled vegetation. Desired dominance ??? refers to 

the species types that should be present on an ecological site given its stage of succession ???[Succession to WHAT 

climax community?]. The Potential Natural Community is a measurement of composition, not to be confused with 

production. A site could be experiencing high production, but have low Potential Natural Community, if it is only 

producing a single grass, forb, or shrub ... species. Where do diverse and intact microbiotic crusts fit into this??? 

BLM has developed false models that allow it find nearly all lands in the Great Basin unhealthy - due to the 

vegetation and not current chronic livestock grazing disturbance - and thus in need of very expensive treatment. 

3 Bars Project Final EIS D-49 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

Response to Comment No. 4-218:

See response to Comment 4-141 (Native and Non-invasive Vegetation Resources – Assessment Methodology–- Key 

Management Areas) for a discussion of how rangeland health assessments were conducted by Eastern Nevada 

Landscape Coalition and the BLM. Measurements of biological soil crusts were not part of the assessment. 

D.5.10.9 Native and Non-invasive Vegetation Resources – Assessment Methodology –

Sagebrush 

Comment No. 4-30 from Western Watersheds Project: 

Miller and Rose claimed astonishingly short sagebrush disturbance intervals, despite a large body of evidence 

available even at the time that this was wrong. Given the preponderance of evidence that these researchers whose 

slanted work forms the basis of Ecosites [Ecological Site Descriptions] and models that BLM and its contractors use, 

but who are so often wrong, BLM must issue a Supplemental D[raft]EIS that actually takes a careful and hard look at 

the historical record that refutes Miller, Perryman and others. 

Response to Comment No. 4-30:

It is not clear what Miller and Rose study is being referred to by the commenter. See response to Comment 4-204 

(Native and Non-invasive Vegetation Resources – Affected Environment) and Final EIS Section 3.12.2.1, Native and 

Non-invasive Vegetation Resources, Study Methods and Analysis Area, on how Ecological Site Descriptions were 

developed for the 3 Bars Project area and used in the vegetation analysis for the EIS. See response to Comment 4-26 

(Native and Non-invasive Vegetation Resources - Assessment Methodology – Baseline Studies) regarding how 

rangeland health assessments conducted by Eastern Nevada Landscape Coalition and the BLM were used to identify 

areas that are degraded or are at risk of degradation based on the Potential Natural Community. Studies conducted by 

Miller and others (see Chapter 5, References) were used to determine how to assess the status and condition of 

pinyon-juniper communities, but not to determine the Ecological Site Description or Potential Natural Community. 

The BLM is aware of the fire return intervals for sagebrush, as discussed in Final EIS Section 3.14, Wildland Fire and 

Management, and would take this into consideration before conducting treatments in sagebrush. Also see response to 

Comment 4-53 (Native and Non-invasive Vegetation Resources – Affected Environment – Sagebrush) regarding 

information on historical fire regimes in sagebrush landscapes from the Bukowski and Baker (2013) paper that is 

included in Final EIS Section 3.12.2.2.2, Native and Non-invasive Vegetation Resources, Big Sagebrush. As 

discussed in Final EIS Section 2.2, Alternatives, Summary of Major Changes between the Draft and Final EIS, the 

BLM is no longer proposing to thin sagebrush within the 3 Bars Project area. 

D.5.10.10 Native and Non-invasive Vegetation Resources – Cumulative Effects 

Comment No. 4-61 from Western Watersheds Project: 

... decrease in pine nut production and tree vigor. What role has drought had in this, or impacts of livestock 

compacting soils and otherwise influencing ecological processes? How has BLM determined what causal factors may 

be pine nut production changes; decrease in the occurrence and health of traditional, edible, and medicinal plants used 

by Native Americans; What role has livestock grazing had in this decrease? 

3 Bars Project Final EIS D-50 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-61:

A number of factors, including drought and livestock grazing, could contribute to a decline in woodland species and 

health and pine nut production and vigor as discussed in Final EIS Section 3.5.2.2 (Climate Change), and the 

Cumulative Effects sections for Native and Non-invasive Vegetation Resources (Section 3.12.3.4) and Native 

American Traditional/Cultural Values, Practices, and Resources (Section 3.24.3.4). The reduction of pine nut 

production is of concern to the BLM. In recognition of the importance of pine nut production to Native Americans 

and other users, as discussed under response to Comment 4-80 (Native and Non-invasive Vegetation Resources –

Affected Environment – Pinyon-Juniper), proposed BLM treatments include efforts to manage pinyon-juniper 

woodlands to promote healthy, diverse stands within persistent woodlands and to manage pinyon-juniper and other 

woodlands stands to benefit wildlife, and Native Americans that use these trees for medicinal purposes (also see Final 

EIS Section 1.5, Purposes of the Project). 

Comment No. 4-62 from Western Watersheds Project: 

... decline in woodland species and health. 

Response to Comment No. 4-62:

See response to Comment 4-61 (Native and Non-invasive Vegetation Resources - Cumulative Effects). 

D.5.10.11 Native and Non-invasive Vegetation Resources – Environmental Consequences 

Comment No. 4-45 from Western Watersheds Project: 

“Mosaic” treatment is also the perfect recipe for maximizing rapid-fire cheatgrass and other invasive species spread 

across the landscape. Instead of doing what BLM used to do – essentially level a square section of land – the very 

harmful mosaic scheme will maximize acreage of native vegetation exposed to increased weed risk will be spread out 

over much larger areas – thus making weed risk exponentially greater and exponentially harder to deal with. 

Response to Comment No. 4-45:

Based on public comments on the Draft EIS, the BLM no longer plans to burn or thin sagebrush.. Although seeding 

and planting treatments could result in the short-term establishment and spread of cheatgrass, as discussed in Final 

EIS Section 3.12.3 under Sagebrush Treatments, the BLM would use methods and SOPs to minimize this risk. In 

riparian and sagebrush areas, the BLM plans to use plantings and seedings of native vegetation, and in a few areas 

with non-native grasses, to restore areas degraded by cheatgrass as discussed in Final EIS Sections 3.12.3.6 and 

3.16.3.6, Relationship between the Local Short-term Uses and Maintenance and Enhancement of Long-term 

Productivity, to the benefit of vegetation and wildlife. 

Comment No. 4-51 from Western Watersheds Project: 

Natural succession is natural succession, it is not “encroachment”. In order to understand succession, BLM must first 

determine the natural historical vegetation community on the site. The use of the Nevada NRCS [Natural Resources 

Conservation Service] Ecosites [Ecological Site Descriptions] and ENLC’s [Eastern Nevada Landscape Coalition] 

models will not enable the BLM to do this. 

3 Bars Project Final EIS D-51 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

Response to Comment No. 4-51:

We agree that “natural succession is natural succession.” As discussed in Final EIS Section 1.6, Need for the Project, 

the 3 Bars ecosystem has long been recognized as an area in resource conflict due to the many and often competing 

uses occurring within the ecosystem. Some of these uses include mineral exploration and development, livestock 

grazing, woodland product harvest, recreation, and wilderness activities. In addition to competing land uses, other 

factors affecting land uses and health in the ecosystem result from the effects of past grazing practices, changes to the 

natural fire regime, establishment and spread of noxious weeds and other invasive non-native species, and expansion 

and densification of pinyon-juniper woodlands. Collectively, these have caused substantial changes in the native 

vegetation community and loss of important ecosystem components, and have altered natural succession. Based on 

these changes, the BLM has determined that there is a need to improve rangeland health in some areas and to provide 

a sustainable habitat for wildlife. 

As discussed in response to Comment 4-217, Native and Non-invasive Vegetation Resources – Affected 

Environment, the successional status shown in Figure 3-28 (Current Rangeland Conditions) is based on the 

relationship between vegetation found on the area in comparison to the Potential Natural Community. As discussed in 

Section 2.1.1 of the Landscape Restoration Project Rangeland Health Report (Eastern Nevada Landscape Coalition 

and AECOM 2012), “a potential natural community is defined as the biotic community that would become 

established on an ecological site if all successional sequences (i.e., natural succession) were completed without 

interference by people under the present environmental conditions (Habich 2001). Potential natural community 

production is based on the Ecological Site Description for the site.” See response to Comment 4-204 (Native and 

Non-invasive Vegetation Resources – Affected Environment) and Final EIS Section 3.12.2.1, Native and Noninvasive Vegetation Resources, Study Methods and Analysis Area, on how Ecological Site Descriptions were 

developed for the 3 Bars Project area and used in the vegetation analysis for the EIS. 

Comment No. 4-159 from Western Watersheds Project: 

The ENLC [Eastern Nevada Landscape Coalition] AECOM info relies on Ecosite descriptions that claim that 

minimal sage[brush] canopy cover is an ideal state. 

Response to Comment No. 4-159:

See response to Comment 4-204 (Native and Non-invasive Vegetation Resources – Affected Environment) and Final 

EIS Section 3.12.2.1, Native and Non-invasive Vegetation Resources, Study Methods and Analysis Area, on how 

Ecological Site Descriptions were developed for the 3 Bars Project area and used in the vegetation analysis for the 

EIS. The Landscape Restoration Project Rangeland Health Report (Eastern Nevada Landscape Coalition and 

AECOM 2012) did not make claims regarding the ideal amount of sagebrush that should occur on the landscape. 

Based on the Potential Natural Community descriptions for sagebrush given in Final EIS Tables 3-24 and 3-25, the 

Potential Natural Community is comprised grasses, forbs, and shrubs, without about a 10 to 50 percent cover of 

shrubs, including sagebrush, and generally with more than a 30 percent cover of shrubs. 

Comment No. 4-178 from Western Watersheds Project: 

BLM ignores literature that shows prescribed fire kills native grasses. See Bunting paper on Idaho fescue, USFS [U.S. 

Department of Agriculture Forest Service] Fire Effects database describing fire impacts on native grasses. 

3 Bars Project Final EIS D-52 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-178: 

The BLM agrees that prescribed fire kills non-target native grasses. However, as discussed in Final EIS Section 

3.12.3.3, Native and Non-invasive Vegetation Resources, Environmental Consequences, Direct and Indirect Effects, 

fire can also enhance native plant (re)establishment in areas where noxious weeds and other invasive, non-native 

vegetation, or pinyon-juniper, dominate a site and exclude native grasses and other desirable vegetation. The BLM 

would limit burning in sagebrush units to the West Simpson Park unit, which is dominated by cheatgrass and other 

non-native vegetation; no burning would be conducted in areas dominated by sagebrush. 

D.5.10.12 Native and Non-invasive Vegetation Resources – Environmental Consequences - 

Aspen 

Comment No. 4-75 from Western Watersheds Project: 

So why is BLM not focusing on removing livestock browse pressure and pressure to sensitive watersheds, and/or 

applying mandatory measurable use standards that sharply limit aspen browse? These must be conservative standards 

of 5 to 10% or less of readily accessible aspen suckers can show any browsing impacts. 

Response to Comment No. 4-75:

See response to Comment 4-10 (Livestock Grazing – Environmental Consequences).

D.5.10.13 Native and Non-invasive Vegetation Resources – Environmental Consequences –

Pinyon-juniper 

Comment No. 4-94 from Western Watersheds Project: 

The D[raft]EIS Preferred Alt.[ernative] will thin (or completely wipe out) reforesting persistent woodland sites (Phase 

I and II), does not protect old growth through its profligate use of fire, aggressive mechanical methods are likely to 

injure old growth and/or cause insect infestations due to attraction of pinyon insects to pitch in tree wounds. Wood 

chips attract insects as well. Thus, tree mortality will ultimately be much greater than the just the trees killed outright 

in the treatments. 

Response to Comment No. 4-94: 

Pinyon-juniper phase classes and old-growth stands were mapped for the 3 Bars Project EIS (Figure 3-27t, Pinyonjuniper Phase Classes). The BLM has no plans to conduct fire treatments in old-growth areas, while manual and 

mechanical methods would be favored in areas where the BLM would like to avoid harming old-growth pinyonjuniper, because the BLM would have greater control over the area treated using these methods. Felled or downed 

trees could be chipped for use as mulch, and this mulch could attract insects. However, its value in retaining moisture, 

reducing erosion, and preventing establishment of noxious weeds and other invasive non-native vegetation likely 

outweighs the risk of insect infestation of nearby pinyon-juniper stands. One of the 3 Bars Project goals is manage 

pinyon-juniper woodlands to promote healthy, diverse stands, by thinning pinyon-juniper and removing diseased and 

decadent trees. By promoting pinyon-juniper health, the BLM should discourage insect infestations that can harm or 

kill remaining and future pinyon-juniper trees by making trees more resistant to insect infestation. 

3 Bars Project Final EIS D-53 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES

Comment No. 4-209 from Western Watersheds Project: 

Decreased tree vigor and pine nut production. How much impact is drought having on this? Or livestock soil 

compaction? 

Response to Comment No. 4-209: 

See response to Comments 4-61 ((Native and Non-invasive Vegetation Resources - Cumulative Effects). 

Comment No. 4-225 from Western Watersheds Project: 

The BLM plans to conduct most burns on Phase II or Phase III sites to initiate stand replacement and to avoid 

impacts to shrubby vegetation including sagebrush. These sites generally have a depleted understory ... Doesn't even 

Miller say not to burn these sites??? WHAT does all this self-serving circular reasoning nonsense mean? 

Response to Comment No. 4-225:

Prescribed fire, manual, and mechanical treatments would be used to manage pinyon-juniper. As discussed in 3 Bars 

Project Final EIS Section 12.3.3 under Native and Non-invasive Vegetation, Environmental Consequences, Pinyonjuniper Treatments, “prescribed fire treatments can produce desirable results on sites with woodlands in Phases I and 

II particularly when there is an abundance of perennial natives in the understory (Tausch et al. 2009). The BLM plans 

to conduct most burns on Phase II or Phase III sites to initiate stand replacement and to avoid impacts to shrubby 

vegetation including sagebrush. These sites generally have a depleted understory, thus 1) fire may be difficult to carry 

through the stand as a result of limited ground and ladder fuels, 2) treatment may be more costly due to the need for 

higher inputs, and 3) site response may be less predictable and has a lower potential for success (for example, more 

annuals versus perennials may establish as a response to fire compared to treating sites that are in earlier stages of 

woodland succession). Where tree dominance is high and woodlands are contiguous, crown fires can rapidly cover 

large areas. When pinyon pines dominate, their bark can easily carry fire into the crown. When weeds, such as 

cheatgrass, are present on the site, risk of failure is increased, especially if the site is warm and dry, or where soils are 

shallow or fine-textured. Hydrophobicity can be a problem directly beneath the tree canopy resulting in limited 

seedling establishment and increased soil erosion (Tausch et al. 2009). Thus, to limit these risks, the BLM may also 

use mechanical treatments to increase native herbaceous vegetation prior to burning and improve the potential for 

successful prescribed fire treatments.” 

As noted on page 3-216 of the Draft EIS, several studies do suggest that dense stands of Phase II and III Class pinyonjuniper stands cannot be managed effectively by fire alone. Manual and mechanical treatments without the use of fire, 

however, generally do not provide long-term control if pinyon-juniper remains nearby. As noted in Section 2.2, 

Summary of Major Changes between the Draft and Final EIS, the BLM has made modifications to proposed 

treatments based on public input. These include using manual treatments to remove most, if not all, pinyon-juniper in 

riparian and aspen treatment units; Phase I pinyon-juniper in pinyon-juniper treatment units; and Phase I and II, and 

often Phase III pinyon-juniper in sagebrush treatment units.

3 Bars Project Final EIS D-54 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

D.5.11 Noxious Weeds and other Invasive Non-native Vegetation 

D.5.11.1 Noxious Weeds and other Invasive Non-native Vegetation – Affected Environment 

Comment No. 4-227 from Western Watersheds Project: 

Figure 3-33 [of the Draft EIS] shows no cheatgrass, and no cheatgrass potential. Where is the mapping, and what 

assumptions were used? Who did it? Was ENLC [Eastern Nevada Landscape Coalition] involved? 

Response to Comment No. 4-227:

As shown by the blue polygons on Final EIS Figure 3-32, Cheatgrass and other Weeds, cheatgrass is found at 

numerous locations throughout the 3 Bars Project area. Areas within the “Large Fire Perimeter” shown on Figure 3-

33, Fire History and Occurrence, are areas with cheatgrass potential, along with roads and other rights-of-way. A 3 

Bars Ecosystem and Landscape Restoration Project Cheatgrass Assessment was prepared for the 3 Bars Project EIS 

that summarized the results from an assessment of the occurrence and distribution of cheatgrass and other noxious 

weeds and invasive non-native vegetation on the 3 Bars ecosystem (AECOM 2011b). This assessment was conducted 

by AECOM but also included records of cheatgrass occurrence found during rangeland health studies conducted by 

Eastern Nevada Landscape Coalition for the Landscape Restoration Project Rangeland Health Report (Eastern 

Nevada Landscape Coalition and AECOM 2012). 

Comment No. 4-228 from Western Watersheds Project: 

How in the world could BLM do an EIS and not even know where cheatgrass is located in the project area? BLM 

must conduct a Supplemental EIS based on this shortcoming alone. 

Response to Comment No. 4-228:

See response to Comment 4-227 (Noxious Weeds and other Invasive Non-native Vegetation – Affected 

Environment). As discussed in Appendix C, Standard Operating Procedures, all treatment units would be inventoried 

for cheatgrass and treated, if necessary, prior to project implementation in a unit. 

D.5.11.2 Noxious Weeds and other Invasive Non-native Vegetation – Environmental 

Consequences 

Comment No. 4-9 from Western Watersheds Project: 

How much will cheatgrass increase in 10 years with and without the projects? In 20 years? How much herbicide will 

be used, and what kinds, and where – under the various alternatives? What non-target vegetation or habitats will be 

impaired? 

Response to Comment No. 4-9:

It would be extremely difficult to predict cheatgrass acreage on the 3 Bars Project area in 10, 20, or more years with 

or without the project. Numerous reasonably foreseeable, and unforeseeable, factors would contribute the 

establishment and spread, or removal, of cheatgrass on the 3 Bars Project landscape, based on the discussion in Final 

3 Bars Project Final EIS D-55 October 2016 
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION

EIS Section 3.13.3.4, Cumulative Effects, Noxious Weeds and other Invasive Non-Native Vegetation. It is 

anticipated, however, that cheatgrass acreage on the 3 Bars Project area would decrease long-term, assuming adequate 

funding is available to conduct treatments proposed under Alternative A. 

Only manual, mechanical, and biological control methods, and fire use (prescribed fire and wildland fire for resource 

benefit) are evaluated in the 3 Bars Project EIS. As discussed in Final EIS Section 3.3.2.3.3, Past, Present, and 

Reasonably Foreseeable Future Actions, the BLM can use herbicides to control local occurrences of noxious weeds 

and other invasive non-native vegetation as authorized by the Environmental Assessment Integrated Weed 

Management Plan Battle Mountain District Nevada Mt. Lewis Field Office and Tonopah Field Office (USDOI BLM 

2009b). The BLM can also use herbicides on areas burned by wildfires under Burned Area Emergency Stabilization 

and Rehabilitation authorizations. 

The BLM is authorized to use the 18 herbicide active ingredients authorized in the 17-States PEIS. Pesticide Use 

Proposals have been developed by the Battle Mountain District BLM for 11 herbicides—2,4-D, clopyralid, 

chlorsulfuron, dicamba, glyphosate, imazapic, imazapyr, metsulfuron methyl, picloram, tebuthiuron, and triclopyr. In 

2011, only five herbicide active ingredients were used on the 3 Bars Project area—2,4-D, glyphosate, imazapyr, 

metsulfuron methyl, and picloram. It is likely that the BLM would also use imazapic to treat cheatgrass in the future. 

Comment No. 4-132 from Western Watersheds Project: 

BLM will spawn massive cheatgrass infestation by conducting this. Ely BLM treatments have already proven that this 

is the case. 

Response to Comment No. 4-132:

See response to Comment 4-9 (Noxious Weeds and other Invasive Non-native Vegetation - Environmental 

Consequences). As discussed in Final EIS Section 3.12.3.3, Native and Non-invasive Vegetation Resources, 

Environmental Consequences, for Pinyon-juniper Treatments, the BLM has been successful in restoring treated areas 

and controlling the establishment and spread of cheatgrass on the 3 Bars Project area, especially during years with 

adequate moisture after seeding or planting. To ensure vegetation success, the BLM would follow SOPs identified in 

Appendix C of the 3 Bars Project Final EIS, including prohibiting livestock access to the area through grazing closure 

decisions that are effective upon issuance. The BLM may also use temporary fencing, including electric fencing, 

which has been used effectively at wildfire restoration sites to improve revegetation success by excluding livestock, 

wild horses, and other wild ungulates. The BLM may also conduct follow-up treatments, including use of herbicides 

(see Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field Office and Tonopah Field 

Office [USDOI BLM 2009b]) or mechanical treatments to control new infestations of noxious weeds and other 

invasive non-native vegetation in treated areas. 

Comment No. 4-193 from Western Watersheds Project: 

D[raft] EIS 3-140 purposefully ignores the role of livestock grazing in promoting cheatgrass and cheatgrass invasion. 

Response to Comment No. 4-193:

Numerous factors have contributed to landscape degradation on the 3 Bars Project area, as discussed in Chapter 1, and 

in the Cumulative Effects discussions found under Environmental Consequences for each of the resource areas 

3 Bars Project Final EIS D-56 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-57 October 2016 

evaluated in the EIS. As noted in these sections, and throughout the Final EIS, livestock grazing has been one of 

several factors contributing to historic landscape degradation, including the spread of cheatgrass. 

Comment No. 4-237 from Western Watersheds Project: 

How will you eradicate the forage kochia weed that was purposefully seeded? With herbicides? How long were these 

areas rested from grazing following the fire? How will you eradicate the hazardous cheatgrass fuel? 

Response to Comment No. 4-237:

Please refer to Final EIS Chapter 2, Section 2.5.3.3, Biological Control Treatments, and Appendix C, Section C.2.2.1, 

Temporary Livestock Grazing Closures. 

D.5.12 Proposed Action and Purpose and Need 

D.5.12.1 Proposed Action and Purpose and Need – Decisions to be Made 

Comment No. 4-103 from Western Watersheds Project: 

BLM must commit to preparing an EA [Environmental Assessment] and/or EIS for all projects tiered to this loose and 

highly uncertain massive landscape denuding scheme. 

Response to Comment No. 4-103:

As discussed in Section 1.8 of the Final EIS, Scope of Analysis and Decisions to be Made, the EIS analyzes the 

effects of using a variety of treatments to improve ecosystem health on the 3 Bars ecosystem. Decisions expected to 

be made through this EIS process include: 

 Determine which areas within the 3 Bars ecosystem would be treated. 

 Determine which treatment methods would be used to accomplish management objectives. 

 Determine which management actions would be taken to facilitate restoration of public lands. 

 Identify criteria to guide future restoration activities within the 3 Bars ecosystem. 

At least 30 days after the U.S. Environmental Protection Agency (USEPA) publishes the Notice of Availability of the 

final EIS, the BLM decision-maker will prepare a Record of Decision (ROD). The decision may be to select one of 

the alternatives in its entirety, or to combine features from several alternatives that fall within the range of alternatives 

analyzed in this EIS. The ROD will address significant impacts, alternatives, mitigation measures, and relevant 

economic and technical considerations. 

No additional EISs or EAs would be prepared for treatments and treatment areas evaluated in the Final EIS and 

allowed under the ROD; however, additional projects outside the analysis of this EIS would require additional NEPA. 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS D-58 October 2016 

D.5.12.2 Proposed Action and Purpose and Need – Documents that Influence the Scope of 

the EIS 

Comment No. 4-224 from Western Watersheds Project: 

BLM cannot rely on the [17- States] PER, because it did not undergo NEPA, and is based on flawed and woefully 

outdated science. The ESA consultation was not over the [17- States] PER, but the herbicides, and that too is old and 

outdated. See Beck and Mitchell 2012, Jones et al. 2013, etc. Full and complete new consultation must occur here. 

Response to Comment No. 4-224:

See response to Comment 4-192 (Assessment Methodology – Baseline Studies) regarding use of the Vegetation 

Treatments on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Report (17-

States PER; USDOI BLM 2007b) to prepare the 3 Bars Project EIS. The BLM also prepared a Final Biological 

Assessment for Vegetation Treatments on Bureau of Land Management Lands in 17 Western States that included a 

discussion of the effects of herbicide and non-herbicide treatments on federally listed and proposed species, and their 

critical habitats. Information on the effects of non-herbicide methods was required by the USFWS and National 

Marine Fisheries Service as part of Endangered Species Act consultation to help the Services better understand the 

cumulative effects of all BLM treatment methods on federally listed and proposed species, and their critical habitats. 

The BLM has prepared a Biological Assessment for the 3 Bars Ecosystem and Landscape Restoration Project

(USDOI BLM 2014) that will be used for Endangered Species Act consultation with the USFWS for the 3 Bars 

Project. The BLM has included additional information on the use of mechanical treatments on pinyon-juniper 

ecosystems in Final EIS Section 3.12.3.3, Native and Non-invasive Vegetation Resources, Environmental 

Consequences, Direct and Indirect Effects, as discussed in the Jones et al. (2012). As discussed in Section 2.2, 

Alternatives, Summary of Major Changes between the Draft and Final EIS, the BLM no longer proposes to conduct 

treatments to thin sagebrush. 

D.5.12.3 Proposed Action and Purpose and Need – Public Involvement - Development of 

the Alternatives 

Comment No. 4-105 from Western Watersheds Project: 

BLM cut the public out from identification of treatments, and this process. 

Response to Comment No. 4-105:

The public was encouraged to provide input on treatment alternatives, methods, and areas during the public scoping 

process, as discussed in Section 1.13 of the Final EIS, Public Involvement and Analysis of Issues, and at public 

scoping meetings. A summary of issues brought up by the public during scoping is available in Table 1-5 in Final EIS 

Chapter 1 (Proposed Action and Purpose and Need), and the Final Scoping Report 3 Bars Ecosystem and Landscape 

Restoration Project (AECOM 2010), which is available at URL: https://www.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=37403. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-59 October 2016 

Comment No. 4-133 from Western Watersheds Project: 

BLM did not engage the public in site selection, has not considered a reasonable range of alternatives, and has turned 

a blind eye to the immense irreparable damage that will be done to habitats and populations of sensitive species, wild 

horses, big game, and other uses of the public lands. 

Response to Comment No. 4-133:

See response to Comment 4-105 (Proposed Action and Purpose and Need – Public Involvement – Development of the 

Alternatives). 

D.5.12.4 Proposed Action and Purpose and Need – General 

Comment No. 4-81 from Western Watersheds Project: 

What in the world does this mean? The focus of the EIS is not to restrict, limit, or eliminate Federal Land Policy and 

Management Act-authorized activities as a means to restore ecosystem health. These types of management actions 

are defined and considered under land use planning regulations (43 Code of Federal Regulations [CFR] § 1610) and 

are outside the scope of this EIS. Does this mean that BLM will not act in any way to remove cattle and sheep from 

even a single acre of treated land – no matter if the public has invested millions of dollars in treatment, and no matter 

if the grazing 5 or 10 years down the line will cause a proliferation of cheatgrass. This is typically what happens in 

sites that had little cheatgrass present before treatment. Once BLM destroys the protective woody vegetation by 

aggressive mechanical treatment and/or fire, cheatgrass increases over time – especially starting 5-6 years down the 

line. Plus – if this is indeed what this confusing statement means – does that mean the promises that livestock will be 

properly dealt with in the EIS false?

Response to Comment No. 4-81:

As discussed in Section 3.18.4, Livestock Grazing, Mitigation, this action would include provisions for temporary 

modifications to livestock grazing permits to protect the investment required to conduct the proposed treatments. 

Permanent or unrelated modifications to livestock grazing permits would be handled separately through the 

Rangeland Health Evaluation and permitting process. 

D.5.12.5 Proposed Action and Purpose and Need – Public Involvement - Scoping Issues 

and Concerns 

Comment No. 4-40 from Western Watersheds Project: 

A large majority of the comments expressed serious concerns about the harms caused by aggressive vegetationdestroying treatments, impacts to wild horses, etc. These were downplayed or largely ignored in the EIS. 

Response to Comment No. 4-40:

Issues and concerns raised by the public during scoping and listed in the Final Scoping Report 3 Bars Ecosystem and 

Landscape Restoration Project (AECOM 2010) are identified at the beginning of the Environmental Consequences 

section as relevant for each resource area evaluated in the 3 Bars Project EIS. These issues and comments guided the 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS D-60 October 2016 

analysis in the Environmental Consequences for each resource section. The 17- States PER provides useful 

information on the effects on non-herbicide vegetation treatments used by the BLM in the western U.S., including 

Nevada. The information in the [17- States] PER was primarily taken from peer-reviewed scientific literature and 

agency documents. In addition to using information from the [17- States] PER, the BLM used other peer-reviewed 

scientific literature and agency documents to prepare the 3 Bars Project EIS. About 500 additional documents were 

used to develop the 3 Bars Project EIS, as referenced in Chapter 5, References. These studies were used to evaluate 

the adverse and beneficial effects of the 3 Bars Project on resources in the 3 Bars Project area, as discussed in the 

Environmental Consequences section for each resource evaluated in the EIS. 

We tried to provide a balanced assessment of adverse and beneficial effects from the 3 Bars Project and relied upon 

the public and federal, state, and local resource agency specialists to help us determine important issues and concerns 

to be addressed in the 3 Bars Project EIS. 

Comment No. 4-41 from Western Watersheds Project: 

BLM claims: All relevant issues identified through public scoping have been analyzed in this EIS to the extent 

practicable. BLM uses “to the extent practicable” to cast aside any concerns that do not fit with its biased circular 

reasoning that is used to justify the Proposed Alternative. This violates NEPA’s hard look requirement. BLM also 

fails to consider a broad range of current ecological science that shows the very high and extreme risk associated with 

this tens of millions of dollars bio-engineering scheme. 

Response to Comment No. 4-41:

See responses to 4-40 (Proposed Project and Purpose and Need – Public Involvement – Scoping Issues and Concerns) 

and Comment 4-87 (Proposed Action and Purpose and Need – Public Involvement – Scoping Issues and Concerns). 

Limitations on what analysis is not included in the 3 Bars Project Final EIS are discussed in Section 1.14, Limitations 

of this EIS. The BLM asserts that this document does meet the “hard look” requirement of NEPA. 

Comment No. 4-87 from Western Watersheds Project: 

Table 1-5 lists a very large number of concerns and issues raised in comments on this proposal. Yet, the 

underpinnings of the entire scheme largely ignored these comments. The D[raft] EIS ignores fully and fairly assessing 

scientific information in light of the comments and scientific literature that has been provided to BLM. Instead, BLM 

relies on the NEPA-less, outdated [17- States] PER as cover for its bioengineering scheme. 

Response to Comment No. 4-87:

See response to Comments 4-105 (Proposed Action and Purpose and Need – Public Involvement – Development of 

the Alternatives) and 4-192 (Assessment Methodology – Baseline Studies). Issues and concerns raised by the public 

during scoping and listed in the Final Scoping Report 3 Bars Ecosystem and Landscape Restoration Project (AECOM 

2010) are identified at the beginning of the Environmental Consequences section as relevant for each resource area 

evaluated in the 3 Bars Project EIS. These issues and comments guided the analysis in the Environmental 

Consequences section. The [17- States] PER provides useful information on the effects on non-herbicide vegetation 

treatments used by the BLM in the western U.S., including Nevada. The information in the [17- States] PER was 

primarily taken from peer-reviewed scientific literature and agency documents. In addition to using information from 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

the [17- States] PER, the BLM used other peer-reviewed scientific literature and agency documents to prepare the 3 

Bars Project EIS. About 500 additional documents were used to develop the 3 Bars Project EIS, as referenced in 

Chapter 5, References. 

Comment No. 4-102 from Western Watersheds Project: 

Thus, all of the concerns listed under Environmental Comments of Table 1-5 are not adequately assessed, examined 

on the basis of flawed and limited outdated information, fail to take a hard look at cumulative impacts (such as 

treatment disturbance coupled with continue imposition of gazing disturbance, or the role of mine and irrigation 

aquifer drawdown on deteriorating riparian conditions and habitat loss for sage-grouse brood rearing for aquatic 

species, for migratory birds, and loss of recreational uses and enjoyment). 

Response to Comment No. 4-102:

See response to Comments 4-87 (Proposed Action and Purpose and Need – Public Involvement – Scoping Issues and 

Concerns) and 4-105 (Proposed Action and Purpose and Need – Public Involvement – Development of the 

Alternatives). The Cumulative Effects section was included under Environmental Consequences for each resource 

area. The assessment of cumulative effects includes issues identified by the commenter. The BLM asserts that this 

document does meet the “hard look” requirement of NEPA.

D.5.12.6 Proposed Action and Purpose and Need – Relationship to Statutes, Regulations, 

and Policies 

Comment No. 3-2 from the Nevada Department of Wildlife: 

We were unable to determine how BLM would apply NRS [Nevada Revised Statute] 528.053 which sets a 200-foot 

buffer from stream channels for any impacting activity unless a variance is authorized by NDF [Nevada Department 

of Forestry], NDOW and NDWR [Nevada Department of Water Resources]. 

Response to Comment No. 3-2:

The BLM believes that Nevada Revised Statute 528.053 does not pertain to the BLM taking actions on federal land. 

D.5.13 Recreation 

Comment No. 2-1 from the National Park Service: 

An erroneous statement is contained in the D[raft] EIS analysis of impacts to recreation, Section 3.21.3.3.1 [of the 

Draft EIS] on page 3-420, which says “There are no recreation resources of regional and/or national importance”

within the project’s Area of Potential Effect. As noted elsewhere in the D[raft] EIS, the congressionally designated 

Pony Express National Historic Trail is a recreation resource of national significance. A correction should be provided 

in the Final EIS. 

Response to Comment No. 2-1:

The text has been corrected in the Final EIS in Section 3.21.3.3.1. 

3 Bars Project Final EIS D-61 October 2016 
SOIL RESOURCES

D.5.14 Social and Economic Values and Environmental Justice 

Comment No. 4-1 from Western Watersheds Project: 

How much would all of the projects and bioengineering cost if implemented? How much would it cost to try to “fix” 

rampant weed invasions, erosion, etc.? 

Response to Comment No. 4-1:

See response to Comment 4-113 (Alternatives). 

D.5.15 Soil Resources 

D.5.15.1 Soil Resources – Affected Environment 

Comment No. 4-109 from Western Watersheds Project: 

BLM claims to map “shredder susceptibility”. We are greatly concerned that the EIS lacks necessary site-specific 

detail and integration of slope, topography and other information essential to understand the severity of soils 

displacement, compaction, etc. 

Response to Comment No. 4-109:

The USDA Natural Resources Conservation Service (2012) provided the information used to determine shredder 

susceptibility. Factors considered in determining shredder suitability are discussed in Final EIS Section 3.9.2.3.2, 

Shedder Susceptibility. As shown on Figure 3-20, Mechanical Treatment Suitability (Shredder), steep and 

moderately-steep hillslopes are moderately to poorly suited for shredder treatments. This information would be used 

by the BLM during pre-treatment assessments to help in determining the final treatment area. 

Comment No. 4-110 from Western Watersheds Project: 

Table 3-13 provides meaningless information for site-specific and even overall understanding. It is based on 

generalizations that fail to take into account operation of equipment when wet or muddy, slope, aspect, number of 

turns and slopes where turns would occur (masticators really tear up soils when turning on any significant slope area), 

etc. It also fails to take into account the degree and severity of denuding that will occur. 

Response to Comment No. 4-110:

Table 3-13 (Soil Suitabilities for Vegetation Treatments) provides the reader with an overall view of the acreage that 

is susceptible to various treatment methods based on soil suitability. A visual representation of the collective risks to 

soil from the various treatments is shown in Figure 3-21 (Site Degradation Susceptibility). Section 3.9.3 of the Final 

EIS, Soil Resources, Environmental Consequences, discusses the potential effects of slope, muddy conditions, 

equipment operation, and other factors mentioned by the commenter. These factors would be taken into consideration 

by the BLM prior to initiating treatments on a site, and the BLM would follow Standard Operating Procedures (see 

Appendix C of the Final EIS) to minimize adverse treatment effects on the soil. 

3 Bars Project Final EIS D-62 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Comment No. 4-200 from Western Watersheds Project: 

There is not a word, not a mention at all - of microbiotic crusts in the “plant community dynamics” section of the 

long series of Tables that BLM uses to set up the landscape for massive destruction and conversion to cheatgrass. It is 

clear that BLM is not interested in the health of native communities, restoration of ecological processes, biodiversity, 

and preventing weeds – as it blows off an consideration of microbiotic crusts in what it considers important related to 

“rangeland health”.

Response to Comment No. 4-200:

The information provided under “Plant Community Dynamics” in 3 Bars Project EIS Tables 3-23 to 3-30 was taken 

from the USDA Natural Resources Conservation Service (2012) Ecological Site Descriptions. This agency did not 

include information on biological soil (microbiotic) crusts in these descriptions. The Draft EIS does discuss potential 

risks to biological soil (microbiotic) crusts from vegetation treatments in Final EIS Section 3.9 (Soil Resources). We 

have added additional information on biological soil crusts and their functions in Final EIS Section 3.9.2.2.8.

Comment No. 4-201 from Western Watersheds Project: 

BLM’s description of pinyon-juniper communities shows its (and AECOM/ENLC’s [Eastern Nevada Landscape 

Coalition]) blatant disregard for microbiotic crusts: 

Response to Comment No. 4-201:

See response to Comment 4-200 (Soil Resources – Affected Environment). 

D.5.15.2 Soil Resources – Assessment Methodology 

Comment No. 4-170 from Western Watersheds Project: 

It [Draft EIS] fails to explain how determinations were made that soil productivity, quality, erosion from wind, 

treatment suitability, etc. were actually determined, and what models they were based on. WHAT is the current 

condition of the weed-preventing and watershed-stabilizing microbiotic crusts? 

Response to Comment No. 4-170:

Soil survey data were obtained from the USDA Natural Resources Conservation Service soils website at URL: 

http://www.nrcs.usda.gov/wps/portal/nrcs/site/soils/home/. This website provides information on how soil data are 

collected and analyzed, and how they can be used to evaluate soil conditions and treatment suitability. See response to 

Comment 4-200 (Soil Resources – Affected Environment) regarding biological soil (microbiotic) crusts. As noted in 

Section 3.9.3 of the Final EIS, Soils, for Sagebrush Treatments, biological soil crusts are unlikely to be found in areas 

dominated by cheatgrass or other noxious weeds. 

Comment No. 4-171 from Western Watersheds Project: 

It is impossible to understand how the various damage “susceptibilities” – fire, shredder, chaining, site degradation, 

etc. are determined. 

3 Bars Project Final EIS D-63 October 2016 
SOIL RESOURCES

Response to Comment No. 4-171:

See response to Comment 4-170 (Soil Resources – Assessment Methodology). 

Comment No. 4-172 from Western Watersheds Project: 

The NRCS [Natural Resources Conservation Service] has also then developed flawed methods to make broad brush 

claims about “susceptibility” - that fail to take into account, for example, the severity of degradation of the drainage 

network, combined with the harshness of the treatment, and overlapping multiple treatments in the same watershed - 

making lands highly vulnerable to erosion, watersheds highly vulnerable to sedimentation, downcutting and 

permanent loss of sustainable perennial flows, etc. This is made even worse by the typical BLM rangeland health 

assessment avoiding any steeper slopes, seeking ideal communities on flat terrain distant from areas of more intensive 

livestock use. 

Response to Comment No. 4-172:

See response to Comment 4-170 (Soil Resources - Assessment Methodology) regarding the methodology used to 

evaluate soil suitabilities for vegetation treatments. See response to Comment 4-110 (Soil Resources – Affected 

Environment) for other factors that can influence to suitability of treatments on slopes, muddy conditions, etc. See 

response to Comment 4-141 (Native and Non-invasive Vegetation Resources – Assessment Methodology–- Key 

Management Areas) for a discussion of how rangeland health assessments were conducted by Eastern Nevada 

Landscape Coalition and the BLM. 

Comment No. 4-173 from Western Watersheds Project: 

This NRCS [Natural Resources Conservation Service] soils modeling exercise greatly ignores wind, wind direction, 

unpredictable drought or lack of rain effects post-treatment, and many other factors that can result in treatments being 

a big failure and weed invasion promoter. 

Response to Comment No. 4-173:

The USDA Natural Resources Conservation Service based soil limitations, as shown on 3 Bars Project EIS Table 3-

10, Project Area Soil Limitations, and associated figures, on soil physical characteristics. The study did not consider 

microclimate, or effects of drought post-treatment. These factors would be considered by the BLM during pretreatment planning. As discussed under response to Comment 4-132 (Noxious Weeds and other Invasive Non-native 

Vegetation – Environmental Consequences), drought or lack of rain post-treatment can reduce treatment success. 

Although the BLM cannot control the weather, it can conduct seeding and planting treatments during the times of the 

year when soil moisture should be plentiful. 

Comment No. 4-174 from Western Watersheds Project: 

Where is the baseline information to support the level of erosion that is actually occurring under the grazing burden 

(historic and chronic/current)/load, roading load, the severity of use allowed under the grazing permits, the complete 

and total lack of upland trampling standards, the lack of riparian trampling standards, and the overall degree and 

severity of desertification? 

3 Bars Project Final EIS D-64 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-174:

The BLM qualitatively assesses erosion indirectly by performing Proper Functioning Condition assessments in 

riparian areas (see Final EIS Section 3.11.2.5, Proper Functioning Condition Surveys) and 17 Indicators of Rangeland 

Health in the uplands. Both protocols require an evaluation of phenomena related to erosion and/or sediment 

transport.

D.5.15.3 Soil Resources – Environmental Consequences 

Comment No. 4-55 from Western Watersheds Project: 

BLM states: Key concerns identified in the AECC [Final Assessment of Existing and Current Conditions for the 

Proposed 3 Bars Ecosystem and Landscape Restoration Project EIS (USDOI BLM 2009a)] for range resources are 

that one or more key perennial grass species are absent. Why is the absence or reduction and degradation of 

microbiotic [biological soil] crusts not a key concern? 

Response to Comment No. 4-55:

The absence or reduction and degradation of biological soil (microbiotic) crusts was not identified as a key concern in 

the AECC (USDOI BLM 2009a). It was identified as an issue during scoping (see Section 3.9.3.1 of the Final EIS, 

Soil Resources, Environmental Consequences) and the potential effects of 3 Bars Project vegetation treatments on 

biological soil crusts are discussed in Final EIS Section 3.9.3.

Comment No. 4-107 from Western Watersheds Project: 

All of these soils suffer significant wind erosion when burned, churned up by livestock, etc. The mapping in the EA [3 

Bars Project EIS] greatly downplays the risk. BLM must also assess the degree of erosion of remaining topsoil and 

soil nutrients that are likely to occur. Windblown dust from grazing disturbance and fire harms ecosystems far away. 

It amplifies the adverse impacts of climate change on early/premature snowmelt. Thus, it is likely to increase fire risk 

in other sites – as they become hotter, drier, more cheatgrass prone and with longer fire seasons due to windblown 

BLM treatment and grazing dust deposition. 

Response to Comment No. 4-107:

Section 3.9, Soil Resources, of the Final EIS describes potential soil hazards associated with the 3 Bars Project, and 

includes several maps that show areas susceptible to soil erosion and loss of topsoil, and loss of topsoil from 

mechanical and fire treatments. As discussed in Section 3.9.3, Soil Resources, Environmental Consequences, the 

BLM would consult information in this section and maps showing soil susceptibility to erosion before conducting 

treatments. The BLM would limit or avoid treatments in areas susceptible to soil erosion. As discussed throughout the 

EIS, BLM treatments could lead to short-term increase in erosion and fire risk, but would lead to long-term reduction 

in erosion and fire risk due to long-term improvement in ecosystem health due to proposed treatments. 

3 Bars Project Final EIS D-65 October 2016 
SOIL RESOURCES

D.5.15.4 Soil Resources – Mitigation 

Comment No. 4-179 from Western Watersheds Project: 

D[raft]EIS at 3-93 states “Soil resources would benefit from mitigation and monitoring in Draft EIS Section 3.17.4 

livestock. Then it states: No mitigation or monitoring measures are recommended specifically for soil resources. 

Response to Comment No. 4-179:

Based on analysis in Final EIS Section 3.9.3, Soil Resources, Environmental Consequences, and summarized in 

3.9.3.8, Significance of the Effects under the Alternatives, the BLM determined that there would be no significant 

impacts to soil resources and that mitigation to reduce or eliminate potential impacts was not warranted. However, the 

BLM has proposed livestock management mitigation measures to ensure treatment success, as discussed under 

Livestock Grazing in Final EIS Section 3.18.4, Mitigation. These measures would benefit soils and other resources on 

the 3 Bars Project area. 

D.5.16 Standard Operating Procedures 

Comment No. 1-1 from U.S. Environmental Protection Agency: 

The F[inal] EIS [should] provide additional information on the potential interface between the stream restoration work 

planned for the 3 Bars Project and Section 404 of the Clean Water Act (CWA); such restoration work could result in 

impacts to waters of the U.S. 

Response to Comment No. 1-1:

Information on stream restoration work is provided in Final EIS Chapter 2, Alternatives. This includes a more detailed 

discussion of treatment activities than was included in the Draft EIS. The BLM will work with federal and state 

agencies to ensure compliance with the Clean Water Act to ensure that impacts to streams are minimal and that 

treatments are in compliance with federal and state laws. We have included this information in Final EIS Appendix C, 

Section C.2.7, Standard Operating Procedures, Riparian Management, and in Section 3.11.1.4, Wetlands, Floodplains, 

and Riparian Zones, Sections 401 and 404 of the Clean Water Act. 

Comment No. 1-2 from U.S. Environmental Protection Agency: 

The F[inal] EIS should describe how jurisdictional waters will be identified over the life of the 3 Bars Project, and 

how the BLM will coordinate with the U.S. Army Corps of Engineers to ensure that any stream restoration activities 

comply with the permit requirements of Section 404 of the CWA [Clean Water Act]. 

Response to Comment No. 1-2:

See response to Comment 1-1 (Standard Operating Procedures). The BLM would delineate affected waters prior to 

conducting work in streams and wetlands, and would work with the U.S. Army Corps of Engineers to ensure that 

treatments are in compliance with federal and state regulations under Sections 401 and 404 of the Clean Water Act. 

We have included this information in Final EIS Appendix C, Section C.2.7, Standard Operating Procedures, Riparian 

Management, and in Section 3.11.1.4, Wetlands, Floodplains, and Riparian Zones, Sections 401 and 404 of the Clean 

Water Act. 

3 Bars Project Final EIS D-66 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Comment No. 1-3 from U.S. Environmental Protection Agency: 

We also recommend that the BLM analyze and include a description, in the F[inal] EIS, of the potential for further 

reductions in air emissions, in proposed forest treatments, by lessening or eliminating pile burning of residual fuels in 

favor of biomass energy production.

Response to Comment No. 1-3:

As discussed in Final EIS Section 2.5.3.8, Activity Fuels Disposal, pile burning is one of several options to remove 

activity fuels from treatments. Other methods include leaving material on site, chipping, forest product utilization, and 

slash and broadcast burning. The BLM would consider all Activity Fuels Disposal alternatives during treatment and 

select the method that results in the fewest impacts and greatest benefits. 

Comment No. 4-122 from Western Watersheds Project: 

The list of SOPs is entirely inadequate and highly uncertain, including the combination that may or may not be 

applied. The [17- States] PER never underwent any NEPA at all. Thus, there is no valid assessment of the efficacy of 

the long scattershot lists of BMPs [Best Management Practices] and SOPs. Plus there is no valid assessment of the 

potentially massive and costly amounts of toxic herbicides that may be used. 

Response to Comment No. 4-122:

As discussed in 3 Bars Project Final EIS Appendix C, Standard Operating Procedures, SOPs have been identified to 

reduce adverse effects to environmental resources and human health from vegetation treatment activities based on 

guidance in BLM manuals and handbooks, regulations, and standard agency and industry practices. The SOPs listed 

in these documents are not all encompassing, but give an overview of practices that should be considered when 

designing and implementing a vegetation treatment project on public lands. In addition to these SOPs, the Mount 

Lewis Field Office has identified additional SOPs that would apply to the 3 Bars Project. As noted by the commenter, 

some of the SOPs were derived from SOPs given in the Vegetation Treatments on Bureau of Land Management 

Lands in 17 Western States Programmatic Environmental Report (17-States PER; USDOI BLM 2007b). As noted in 

the 17-States PER, non-herbicide treatment methods and SOPs have been evaluated under NEPA in earlier EISs and 

EAs, as discussed under response to Comment 4-192 (Assessment Methodology – Baseline Studies). The use of 

herbicides is not assessed in the 3 Bars Project EIS because it is not a treatment method proposed under the action 

alternatives. However, the BLM can use herbicides under previous authorizations. See responses to Comments 4-7 

(Assessment Methodology – Risk Assessments) and 4-9 (Noxious Weeds and other Invasive Non-native Vegetation - 

Environmental Consequences) for more information on herbicide use on the 3 Bars Project area. 

Comment No. 4-167 from Western Watersheds Project: 

There is great uncertainty in applying BMPs. They are typically decades is not centuries behind the times in applying 

scientific information to minimize damage and disturbance. They greatly ignore the degree and severity of 

degradation that exits in the landscape, and how vulnerable it actually is to weeds, erosion, etc. They ignore drought, 

weather extremes, etc. 

3 Bars Project Final EIS D-67 October 2016 
STANDARD OPERATING PROCEDURES

Response to Comment No. 4-167:

As noted in Final EIS Section 2.5.5, Monitoring, monitoring ensures that resource management is an adaptive process 

that builds upon past successes and learns from past mistakes. The regulations of 43 CFR § 1610.4-9 require that 

BLM land use plans establish intervals and standards for monitoring and evaluating land management actions. During 

preparation of implementation plans for a specific project, treatment objectives, standards, and guidelines are stated in 

measurable terms, where feasible, so that treatment outcomes can be measured, evaluated, and used to guide future 

treatment actions. This approach ensures that restoration treatment processes are effective, adaptive, and based on 

prior experience. It also helps to ensure that project objectives are met. Numerous factors, including treatment 

location and methods and weather extremes, can influence treatment success. These are taken into consideration 

during treatment development and monitoring. Through an adaptive process, the BLM uses monitoring to establish 

baseline conditions, identify responses of natural, social, and cultural resources to treatments, identify treatment 

components that are successful and unsuccessful, and formulate new treatment methods and strategies, as needed, 

based on this process of adaptive management. 

Comment No. 4-168 from Western Watersheds Project: 

BMPs greatly fail to take into account cumulative impacts, including of multiple disturbances occurring in the same 

watershed. 

Response to Comment No. 4-168:

In several sections of the Final EIS, including Section 3.10.3.8 for Water Resources, the BLM notes that in the areas 

of overlap, riparian zones and associated wetland areas may be subject to multiple project disturbances. The BLM 

would try to minimize multiple treatment disturbance by conducting treatments within the same general area at the 

about the same time. An assessment of cumulative effects has been provided for each resource area discussed in the 

EIS that discusses the potential effects of past, present, and reasonably foreseeable future actions that could occur 

within and near the 3 Bars Project area and could interact in an additive, countervailing, or synergistic effect upon the 

3 Bars Project landscape. See Section 3.3.2, Cumulative Effects, for a more detailed discussion of how cumulative 

effects were analyzed in the 3 Bars Project Final EIS. 

D.5.17 Vegetation Treatments Planning and Management 

D.5.17.1 Vegetation Treatments Planning and Management – General 

Comment No. 4-8 from Western Watersheds Project: 

BLM must review the failures of herbicides to control weeds (especially in the face of continued chronic livestock 

grazing disturbance) – based on the agencies own experience with its many failed fire rehab[ilitation] efforts, and 

other treatments where 5 or 6 years after fire, chipping, mowing, roatbeating, etc. – cheatgrass chokes the treated 

areas. It must critically examine the failures of the actions never assessed under NEPA in the [17- States] PER _ i.e. 

all the bioengineering and treatment disturbance methods proposed under the Preferred Alternative to tear apart the 

landscape. 

3 Bars Project Final EIS D-68 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-8:

No herbicides would be used under the proposed 3 Bars Project. Herbicides could be used in the area for non-3 Bars 

Project treatments under existing authorizations. See responses to Comments 4-7 (Assessment Methodology – Risk 

Assessments) and 4-9 (Noxious Weeds and other Invasive Non-native Vegetation - Environmental Consequences) for 

more information on herbicide use on the 3 Bars Project area. 

Bioengineering and other treatments that would disturb the landscape were evaluated for their adverse and beneficial 

direct, indirect, and cumulative effects in the 3 Bars Project EIS, an EIS prepared in accordance with the National 

Environmental Policy Act. See response to Comment 4-192 (Assessment Methodology – Baseline Studies) for the 

role of the 17-States PER in development of the 3 Bars Project EIS. 

Comment No. 4-12 from Western Watersheds Project: 

How much high quality habitat will remain undisturbed by treatments? For example, BLM seeks to destroy critical 

blocks of pygmy rabbit, sage sparrow, sage thrasher, and Brewer’s sparrow nesting habitat by mowing, chopping, 

crushing, seeding for livestock grass. After BLM gets done with all of these treatments, how much habitat will remain 

across the landscape? How fragmented will it be? 

Response to Comment No. 4-12:

As discussed in Final EIS Sections 3.12.3 and 3.13.3 for Native and Non-invasive Vegetation Resources, and Noxious 

Weeds and other Invasive Non-native Vegetation, under Environmental Consequences, Sagebrush Treatments, the 

BLM proposes to conduct treatments to improve the health of native sagebrush, and use sagebrush plantings and 

seedings to restore degraded lands that historically had sagebrush. As discussed in Final EIS Section 2.3.1.4, 

Alternatives, Sagebrush Treatment Units, treatments would primarily consist of seeding and planting, and removal of 

pinyon-juniper. No sagebrush would be removed. Long-term, it is expected that the amount of sagebrush habitat on 

the 3 Bars Project area would increase from current levels. 

Comment No. 4-65 from Western Watersheds Project: 

Why are you then promoting aggressive weed-spreading treatments of naturally dense sagebrush and sage[brush] sites 

with few weeds currently present? The focus of treatments would be to control the spread of noxious weeds and 

invasive annual grasses found within the 3 Bars ecosystem and to encourage the establishment of native and desirable 

non-native species. 

Response to Comment No. 4-65:

As noted by the commenter, the focus of 3 Bars Project treatments would be to control the spread of noxious weeds 

and other invasive non-native annual grasses found within the 3 Bars ecosystem and to encourage the establishment 

of native and desirable non-native species. See response to Comment 4-45 (Native and Non-invasive Vegetation 

Resources - Environmental Consequences) and Section 2.3.1.4 (Alternatives, Sagebrush Treatment Units) of the Final 

EIS, Alternatives, Sagebrush Treatments, for proposed treatments within sagebrush and actions the BLM would take 

to reduce the likelihood of treatments in sagebrush causing the spread of noxious weeds. 

3 Bars Project Final EIS D-69 October 2016 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

Comment No. 6-1 from J. Brown: 

Site-specific preferred actions must be clearly identified and analyzed in the EIS; this must include the timeframe for 

any actions (time of year for actions, duration of proposed actions, etc.). 

Response to Comment No. 6-1:

Site-specific treatment locations and actions are clearly defined in Section 2.3, Description of the Alternatives. 

Impacts to wild horses can be found in Chapter 3 (Section 3.17.3, Wild Horses, Environmental Consequences) and 

Standard Operating Procedures that are designed to minimize impacts to wild horses can be found in Appendix C of 

the Final EIS. 

Comment No. 7-1 from K. DeBoer: 

It is stated in the EIS that, “Human related activities allowed under the Federal Land Policy and Management Act, 

such as livestock grazing and off highway vehicle use would continue to be allowed on the 3 Bars ecosystem.” Would 

these activities still be allowed during restoration? Would the vehicles disrupt the paths for the fires? Would this then 

cause new paths to be formed, which would potentially cause more damage to the area? And finally will the human 

activity disrupt hopes of restoration after land management is implemented? 

Response to Comment No. 7-1:

This statement declares that existing land use authorizations as identified by the Federal Land Policy and 

Management Act and the Shoshone-Eureka RMP would be allowed to continue, and are not being changed by the 

proposed action. 

Comment No. 8-1 from M. Devlin: 

Please define each preferred action, identify the exact location where it is to be carried out, and provide a time-line as 

to when it will commence (month, year) and how long it should take (duration). 

Response to Comment No. 8-1:

See response to Comment 6-1 (Vegetation Treatments Planning and Management – General). 

Comment No. 9-1 from K. Gregg: 

The D[raft]EIS does not specify exactly what treatments will be used on which portions of the project and when these 

treatments will be used and to what extent these treatments will be used – thus the BLM is providing itself with an 

open-ended capability to take these actions outside of the public’s knowledge.

Response to Comment No. 9-1:

See response to Comment 6-1 (Vegetation Treatments Planning and Management – General). 

3 Bars Project Final EIS D-70 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Comment No. 9-3 from K. Gregg: 

The current Draft EIS fails to provide specific actions for specific locations; the preferred actions are ambiguous and 

raise serious concerns. The BLM must clearly define each preferred action, identify the specific locations and outline 

the time frame (time of year, duration, etc.) for each action. 

Response to Comment No. 9-3:

See response to Comment 6-1 (Vegetation Treatments Planning and Management – General). 

Comment No. 9-5 from K. Gregg: 

Site-specific preferred actions must be clearly identified and analyzed in the EIS; this must include the timeframe for 

any actions (time of year for actions, duration of proposed actions, etc.). 

Response to Comment No. 9-5:

See response to Comment 6-1 (Vegetation Treatments Planning and Management – General). 

Comment No. 10-3 from E. Hennessy: 

Exactly how would this proposal of mass destruction lead to “improvement” of the range?

Response to Comment No. 10-3:

As noted in Section 1.1, Introduction, “Resource conditions on several areas within the ecosystem, however, have 

deteriorated due to past land use activities, causing the BLM to target this area for restoration. Although 3 Bars 

ecosystem health is in decline in some areas, the ecosystem has characteristics that suggest its health can be 

substantially improved through land restoration activities. Given the opportunity to improve 3 Bars ecosystem health, 

the 3 Bars Ecosystem and Landscape Restoration Project (3 Bars Project) is being proposed by the BLM to develop 

the 3 Bars ecosystem into a sustainable, healthy, and resilient landscape.” Section 1.5, Purposes for the Project, 

describes the primary objectives of the 3 Bars Project. If some or all of these objectives are met, the BLM would 

promote long-term improvement in the health and function of the 3 Bars ecosystem. By not undertaking the 3 Bars 

Project, however, it is likely that the establishment and spread of noxious weeds and other invasive, non-native 

vegetation, pinyon-juniper encroachment, increase in wildfire occurrence and spread, and degradation of the health of 

riparian, aspen, pinyon-juniper, and sagebrush habitats would lead to a substantial loss in health and function of the 3 

Bars ecosystem. 

Comment No. 10-4 from E. Hennessy: 

The current Draft EIS fails to analyze the long-term impacts of these proposed actions which would result in loss of 

vital protective coverage, necessary forage, habitat access and inadequate range restoration, important details that 

must be seriously addressed and thoroughly examined in the revised EIS. 

Response to Comment No. 10-4: 

Final EIS Chapter 3, Affected Environment and Environmental Consequences, provides extensive information on 

baseline conditions and short- and long-term effects of proposed treatments. This information is supported by baseline 

3 Bars Project Final EIS D-71 October 2016 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

studies conducted for the 3 Bars Project and Mount Hope Project, peer-reviewed scientific studies, and supporting 

documents, such as the 17-States PEI, 17-States PER, and AECC. 

D.5.17.2 Vegetation Treatments Planning and Management – Literature 

Comment No. 4-5 from Western Watersheds Project: 

A large body of recent current Literature shows the battery of aggressive very expensive BLM treatments are not 

effective, and will likely lead to ruin. See Beck and Mitchell 2012, Jones et al. 2103 review, for example. 

Response to Comment No. 4-5:

As discussed in the Final EIS, treatments conducted by the BLM in the past on the 3 Bars and other project areas have 

shown varying degrees of success. The BLM records resource conditions prior to, and for several years after, 

conducting treatments, and uses this information to learn from past treatments and ensure greater treatment success in 

the future. There is also a large body of literature that has shown what the effects are of not treating noxious weeds 

and other non-native vegetation, reducing the risk of wildfire, slowing pinyon-juniper encroachment, and restoring 

riparian and aspen habitats, on the health of the landscape and natural and social resources. 

D.5.17.3 Vegetation Treatments Planning and Management – Methods - Activity Fuels 

Comment No. 4-84 from Western Watersheds Project: 

We stress that the EIS greatly fails to assess potential deforestation, nutrient loss and export, loss of critical habitat 

components with biomass schemes. The EIS also specifically discusses “biochar”.

Response to Comment No. 4-84:

As discussed in Final EIS Section 2.5.3.8, Activity Fuels Disposal, pinyon and juniper activity fuels larger than 3 

inches in diameter could be made available for firewood, fence posts, pellets, etc. Coarse and large wood could be 

placed in-stream to reduce vertical incisement and shear stresses in riparian restoration projects. Additionally, activity 

fuel could be removed by commercial entities through contracts. The BLM anticipates that most activity fuels would 

be burned or left on site. 

Comment No. 4-85 from Western Watersheds Project: 

A[n] SEIS [Supplemental EIS] must be prepared just to address the biomass concerns alone – as the often oblique and 

uncertain wording of the EIS appears to be in part covering up significant potential biomass actions as the EIS plays 

out. Is this what the odd references to dump trucks are about? Exporting nutrients and essential small mammal habitat 

components form the site - to burn in an incinerator and pollute the air? Further, biomass schemes are really often just 

a front for getting the facility built, then it burns through the wood, then the plant becomes used for toxic waste 

incineration, polluting the air and harming human health. 

Response to Comment No. 4-85:

See responses to Comments 4-84 and 4-112 (Vegetation Treatments Planning and Management – Methods – Activity 

Fuels) regarding the use of activity fuels generated by proposed 3 Bars Project treatments. The amount of activity fuel 

3 Bars Project Final EIS D-72 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

exported for forest products use is expected to be minimal, if any. Most activity fuel would remain on site as mulch 

and for stream and wildlife enhancement, although some activity fuel would be burned on site to reduce the amount of 

hazardous fuels that could be burned by a wildfire, as discussed in Final EIS Section 3.14.3, Wildland Fire and Fire 

Management, Environmental Consequences, Pinyon-juniper Treatments. 

Comment No. 4-111 from Western Watersheds Project: 

Spewing wood chips all over the ground surface smothers native vegetation and microbiotic crusts, promotes weeds, 

reduces potential “forage” production, destroys habitat for ground nesting bees and other native pollinators of rare 

plants, simplifies logs and woody debris essential for many small mammals and decomposition processes that return 

nutrients to the soil, and also smothers the forbs that sage-grouse require. Plus sage-grouse chicks eat insects – and a 

sea of wood chips is a sterile, dead understory. Smothering the ground surface makes a uniform chip bed - with little 

to no diversity for the native microfauana. It also creates a layer of continuous fine fuel. 

Response to Comment No. 4-111:

The BLM agrees that mastication of trees and shrubs leaves wood material on the soil surface that can impact 

microbiotic crusts, low growing vegetation, and insects and other wildlife and their habitats, and create continuous 

fine fuel. These issues were also identified by Gottfried and Overby (2011) in their review of the effects of 

mastication of pinyon-juniper. However, these authors and others have noted several benefits of leaving wood chips 

on the ground, including reducing erosion, increasing infiltration, and reducing soil temperature; these effects are 

summarized in Final EIS Section 3.9.3.3.2 (Soil Resources, Environmental Consequences, Direct and Indirect Effects 

under Alternative A). As noted by Gottfried and Overby, land managers need to implement a “balanced, thoughtful 

approach to determine which fuel treatment method makes the most economical and ecological sense for a given 

landscape.” As discussed in Final EIS Section 2.5.3.2 (Alternatives, Mechanical Treatments), the BLM would 

mulch/shred trees on-site. Sites with suitable understory vegetation and that require little or no seeding are appropriate 

for mulching/shredding. The BLM would evaluate adverse and beneficial effects of available treatment methods, 

including mulching, when determining how to best use activity fuels generated by manual and mechanical treatments. 

Comment No. 4-112 from Western Watersheds Project: 

BLM even mentions dump trucks – which can only mean it is contemplating massive export of wood for biomass. 

Response to Comment No. 4-112:

Dump trucks would be used to haul equipment, temporary fencing, rock, grade stabilization structures, and dirt as 

discussed in Final EIS Section 2.3.1.1, Alternatives, Riparian and Aspen Treatment Units. A contractor could use 

dump trucks to haul wood used for forest products. 

Comment No. 4-130 from Western Watersheds Project: 

This is a very foreseeable outcome of any biomass/biochar proposal in this landscape, and full and detailed analysis of 

air and water pollution and human health risks of this must be assessed. Along with the human health risks of drift of 

the likely massive amounts of herbicide that would end up being used in the treatment and bioengineering-desolated 

Three [3] Bars landscape. 

3 Bars Project Final EIS D-73 October 2016 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

3 Bars Project Final EIS D-74 October 2016 

Response to Comment No. 4-130:

See responses to Comments 4-84, 4-85 ((Vegetation Treatments Planning and Management – Methods – Activity 

Fuels), and 4-112 (Vegetation Treatments Planning and Management – Methods – Activity Fuels) regarding the use 

of activity fuels generated by proposed 3 Bars Project treatments. The BLM would not use herbicides for proposed 3 

Bars Project treatments; see responses to Comments 4-7 (Assessment Methodology – Risk Assessments) and 4-9 

(Noxious Weeds and other Invasive Non-native Vegetation - Environmental Consequences) for more information on 

herbicide use on the 3 Bars Project area. As discussed under Environmental Consequences in Final EIS Sections 3.6 

(Air Quality) and 3.10 (Water Resources), risks to air and water would likely be greater from wildfire than proposed 

prescribed fire and activity fuel disposal using fire. An important objective of the 3 Bars Project is to reduce the risk 

of wildfire, and the Project is expected to benefit air quality and water resources long-term by reducing the risk of 

wildfire and noxious weed and other invasive non-native vegetation. 

D.5.17.4 Vegetation Treatments Planning and Management – Methods - Bioengineering 

Comment No. 4-4 from Western Watersheds Project: 

It is clear that a Supplemental EIS must be prepared (if BLM chooses any treatment action other than selective hand 

cutting of younger trees) to take a current, science-based look at the need for, and impacts of, a massive and massively 

expensive bioengineering scheme in the heart of the Great Basin Ecosystem that faces unprecedented climate change, 

cheatgrass/brome flammable weed invasion, and other disturbance risks. See Connelly et al. 2004, Knick and 

Connelly 2009.2011, USFWS WBP [Warranted but Precluded] Finding for greater sage-grouse, USD[O]I BLM Great 

Basin REA [Rapid Ecoregional Assessment]. 

Response to Comment No. 4-4:

As discussed under Comment 4-199 (Native and Non-invasive Vegetation Resources – Assessment Methodology –

Rangeland Health Assessment), and in Chapter 2 of the EIS, alternatives were developed the respond to the purposes 

and needs for the 3 Bars Project, as discussed in Chapter 1. Alternatives differ by methods used and acres treated, and 

include Alternative C, the Minimal Land Disturbance Alternative, which only involves the use of manual and 

classical biological control methods and would cause little disturbance to the land. All action alternatives, however, 

would seek to improve rangeland health. No treatments would be authorized under Alternative D, the No Action 

Alternative. As noted in Section 2.2, Summary of Major Changes between the Draft and Final EIS, the BLM has 

made modifications to proposed treatments based on public input. These include using manual treatments to remove 

most, if not all, pinyon-juniper in riparian and aspen treatment units; Phase I pinyon-juniper in pinyon-juniper 

treatment units; and Phase I and II, and often Phase III pinyon-juniper in sagebrush treatment units. The BLM also 

would not use chaining to treat vegetation. Chapter 3 of the EIS evaluates the risks to the natural, social, and cultural 

environment from proposed 3 Bars Project treatments, including stream bioengineering. As discussed in Final EIS 

Section 1.6.1, Healthy Lands Initiative, the BLM recognizes the issues facing the Great Basin Ecosystem, including 

the 3 Bars Project area, and is proposing treatments on the 3 Bars Project area to help address these issues. 

D.5.17.5 Vegetation Treatments Planning and Management – Methods - Fencing 

Comment No. 4-129 from Western Watersheds Project: 

At Denay Pond, Lone Spring, and Treasure Well, the BLM would use protective fencing, but no other treatments ... Is 

this permanent fencing? Many of these projects are livestock projects and are wrongfully bundled in with this Three 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-75 October 2016 

[3] Bars bioengineering scheme. All of these projects must be subject to the OHA [Office of Hearings and Appeals] 

Appeals regulations. 

Response to Comment No. 4-129:

As discussed in Final EIS Section 2.3.1.1, Alternatives, Riparian Treatment Units, temporary, small exclosures would 

be used to protect treatment areas from livestock, wild horse, and other wild ungulate use until treatments are 

revegetated. Treatments at Denay Pond, Lone Spring, and Treasure Well would be designed to allow these areas to 

restore themselves using passive methods. No bioengineering methods would be used at these sites. 

Comment No. 4-145 from Western Watersheds Project: 

Why does BLM need fences - it can pull livestock use back to existing fences to aid recovery, or actually enforce 

conservative standards of livestock use instead. 

Response to Comment No. 4-145:

As stated in Final EIS Appendix C (Standard Operating Procedures) Section C.2.6, Protective Fences, existing 

fencing would be used as much as is practical and may entail modification of grazing permits. 

Comment No. 4-187 from Western Watersheds Project: 

BLM has not explained what is meant by claims “BLM will not completely block access to water sources” by 

livestock, horses, wildlife, etc. What does this mean? Will entire allotments or pastures be closed? Or is BLM just 

planning to shift, and intensify sever impacts into other sensitive erodible, weed-prone sites? Or will it have dustbowl 

water haul or water gap feedlot-like sites? 

Response to Comment No. 4-187:

As discussed in Final EIS Section 2.3.1.1, Alternatives, Riparian Treatment Units, let-down fencing using barbed wire 

and posts that can be let-down easily to allow animals to pass, and electric wire fencing could be used to protect 

smaller areas, while barbed wire and post fencing or 2-rail steel pipe fencing would likely be used to protect larger 

areas from animal intrusion. Maintenance for fencing would be determine on a project-by-project basis and would be 

reflected in the individual cooperative agreements for each project. Final EIS Appendix C, Section C.2.6, Protective 

Fences, discusses Standard Operating Procedures that apply to fencing use during proposed 3 Bars Project treatments. 

As discussed in this section, the BLM would construct small, temporary exclusion fences around treatment 

boundaries. These protective fences will be on an as-needed basis to allow vegetation to establish, and to reduce the 

need to remove livestock from the pasture or allotment. No barbed wire or let-down fencing will be allowed within 

HMA boundaries, and let-down fencing will not be used where wild horses are present and may become entrapped in 

the fence. Where exclusionary fencing is constructed around water features, the BLM will provide access to water 

through the form of a water gap or impoundment. 

Entire pastures or allotments may be closed in accordance with the mitigation found in Final EIS Section 3.18.4

(livestock Grazing, Mitigation). Animal Unit Months would be adjusted accordingly. 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

3 Bars Project Final EIS D-76 October 2016 

Comment No. 6-2 from J. Brown: 

The proposed fencing raises serious concerns. Even temporary fencing will have a negative impact on wild horse 

movement. Any plans for fencing in or around any Herd Areas or Herd Management Areas must be thoroughly 

disclosed - including the minimum and maximum duration for each fencing proposal. 

Response to Comment No. 6-2:

Specifics on protective fencing can be found in Final EIS Appendix C, Section C.2.6, Protective Fences, and SOPs 

that are designed to minimize impacts to wild horses can also be found in Appendix C. No permanent or barbed wire 

fence would be constructed within the HMAs except for small riparian or aspen enclosures that would not affect wild 

horse movement patterns. The need for fencing, and the duration, would be determined on a case-by-case basis after 

consideration of the needs for the treatment and potential for treatment success with or without fencing that excludes 

grazing animals. 

Comment No. 8-3 from M. Devlin: 

Please disclose where temporary fences will be installed within or around HAs and HMAs. Please provide a time-line 

as to the exclosures' commencement and duration. Also, how will you determine which fences are necessary? What 

are the criteria? 

Response to Comment No. 8-3:

See response to Comment 6-2 (Vegetation Treatments Planning and Management – Methods – Fencing). 

Comment No. 9-6 from K. Gregg: 

The proposed fencing raises serious concerns. Even temporary fencing will have a negative impact on wild horse 

movement. Any plans for fencing in or around any Herd Areas or Herd Management Areas must be thoroughly 

disclosed - including the minimum and maximum duration for each fencing proposal. 

Response to Comment No. 9-6:

See response to Comment 6-2 (Vegetation Treatments Planning and Management – Methods – Fencing). 

Comment No. 10-2 from E. Hennessy: 

Fencing of any kind - permanent or “temporary” - severely impairs wild horse movement therefore, any such 

proposed action to erect Temporary fencing requires in-depth analysis examining the negative impacts of each and 

every fencing proposal including disclosure of the projected duration of such actions. It goes without saying that any 

such fencing projects must not be proposed to somehow justify wild horse roundups and permanent removals in a 

quest to ultimately zero out more wild horses Has [Herd Areas]/HMAs. 

Response to Comment No. 10-2:

See response to Comment 6-2 (Vegetation Treatments Planning and Management – Methods – Fencing). 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-77 October 2016 

D.5.17.6 Vegetation Treatments Planning and Management – Methods - Fire for Resource 

Benefit 

Comment No. 4-249 from Western Watersheds Project: 

This “fire for resource benefit” means BLM is planning to nurse wildfires along. So why all the hysteria about the 

need for treatment, when BLM proposes to just let lands burn up anyway? 

Response to Comment No. 4-249:

As discussed in Final EIS Section 2.5.3.4 (Alternatives, Fire, Management of Wildland Fire for Resource Benefit), 

“In areas where there is no threat to human life or property, naturally ignited wildfires can be used to meet resource 

objectives to maintain ecosystems that are functioning within their normal fire regime or help return ecosystems to a 

more natural fire regime. These fires must meet specific environmental prescriptions, and be thoroughly evaluated for 

potential risk before being managed to benefit the resource. They are utilized only in pre-planned areas and when 

there are adequate fire management personnel and equipment available to achieve defined resource objectives. 

Natural ignitions within the project areas could be managed to achieve desired resource objectives if the 

environmental conditions allow for attainment of those objectives. Each wildland fire is evaluated at the time of 

ignition though the use of the Wildland Fire Decision Support System to determine whether the fire should be allowed 

to burn, or if suppression activities are required to put out the fire.” Based on this information, the BLM does not 

propose to “just let lands burn up anyway.” The BLM has only proposed to use of wildland fire for resource benefit in 

the Sulphur Spring Wildfire Management Area, an area where there is no threat to human life or property, and only 

when natural fire ignitions can be managed to meet desired resource objectives. 

D.5.17.7 Vegetation Treatments Planning and Management – Methods - Herbicides 

Comment No. 4-2 from Western Watersheds Project: 

What toxic herbicides would this involve, and what would their effects be? 

Response to Comment No. 4-2:

No herbicides would be used under the proposed 3 Bars Project. Herbicides could be used in the area for non-3 Bars 

Project treatments under existing authorizations. See responses to Comments 4-7 (Assessment Methodology – Risk 

Assessments) and 4-9 (Noxious Weeds and other Invasive Non-native Vegetation - Environmental Consequences) for 

more information on herbicide use on the 3 Bars Project area. 

Comment No. 4-6 from Western Watersheds Project: 

This Supplemental Three [3] Bars EIS [as proposed by Western Watersheds Project] must also take a current, fresh 

and hard look at the use of any and all herbicides, the amount of herbicide that will be used, the specific herbicides 

that will be used – alone or in combination, their breakdown products and degradates, their persistence in the soils, 

and drift in wind, soil, or water. 

Response to Comment No. 4-6:

No herbicides would be used under the proposed 3 Bars Project. Herbicides could be used in the area for non-3 Bars 

Project treatments under existing authorizations. See responses to Comments 4-7 (Assessment Methodology – Risk 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

3 Bars Project Final EIS D-78 October 2016 

Assessments) and 4-9 (Noxious Weeds and other Invasive Non-native Vegetation - Environmental Consequences) for 

more information on herbicide use on the 3 Bars Project area. 

D.5.17.8 Vegetation Treatments Planning and Management – Methods - Manual 

Treatments 

Comment No. 4-106 from Western Watersheds Project: 

It is not true that hand cutting has limited value over large areas. They cost the same as the use of highly destructive 

feller buncher chipper choppers, chaining, etc. BLM has hidden the massive cost of its bioengineeering scheme – and 

hand cutting is no more expensive that the rest of the immense battery of destruction. Plus it employs many more 

people 

Response to Comment No. 4-106:

Hand cutting, along with classical biological control, are the only treatment methods allowed under Alternative C, 

Minimal Land Disturbance Alternative. The direct, indirect, and cumulative adverse and beneficial effects associated 

with treatments associated with this alternative compared to the other action alternatives are discussed under the 

Environmental Consequences sections for each resource area evaluated in the 3 Bars Project EIS. As shown in Table 

3-73 (Estimated Treatment Costs per Acre) under Social and Economic Values and Environmental Justice, and 

discussed for response to Comment 4-113 (Alternatives), manual and classical biological control treatments cost 3 to 

5 times or more per acre to implement than do fire and mechanical treatments per acre treated. As noted in Section 

2.2, Summary of Major Changes between the Draft and Final EIS, the BLM has made modifications to proposed 

treatments based on public input. These include using manual treatments to remove most, if not all, pinyon-juniper in 

riparian and aspen treatment units; Phase I pinyon-juniper in pinyon-juniper treatment units; and Phase I and II, and 

often Phase III pinyon-juniper in sagebrush treatment units. 

D.5.17.9 Vegetation Treatments Planning and Management – Methods - Mechanical 

Treatments 

Comment No. 8-4 from M. Devlin: 

Please reconsider whether destroying vegetation is advisable. Holistic Grazing Management consultant Alan Savory 

found that mechanical treatments, such as chaining, actually made matters worse. 

Response to Comment No. 8-4:

Based on public comments on the Draft EIS, the BLM would not use chaining under the proposed action alternatives. 

Comment No. 8-5 from M. Devlin: 

Please reconsider whether using heavy machinery, such as bulldozers, to stabilize the area’s streams is advisable. 

Won't such construction equipment create landscape-disturbances? Bulldozers are also noisy, resulting in yet more 

disturbances that will adversely impact the wild horses. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 8-5:

Comment noted. 

D.5.17.10 Vegetation Treatments Planning and Management – Methods - Planting and 

Seeding 

Comment No. 4-54 from Western Watersheds Project: 

Why is BLM planning to destroy the Three [3] Bars landscape by planting species like crested wheatgrass or forage 

kochia, at the same time it is removing them? 

Response to Comment No. 4-54:

As discussed in 3 Bars Project Final EIS Section 2.5.3.5, Alternatives, Seeding and Planting, seed mixes would 

primarily be composed of native species; however, non-native species may be used to meet restoration objectives in 

areas where interim measures associated with site stabilization are required (phased succession). Species selection 

would be based on site potential and objectives. A variety of seeding methods may be used. 

Comment No. 4-66 from Western Watersheds Project: 

Why are you encouraging the establishment of desirable non-native species? This reinforces that this EIS is aimed at 

promoting livestock forage grass – at the expense of all other values of the public lands and all other components of 

the Three [3] Bars sagebrush and PJ [pinyon-juniper] ecosystems and watersheds. 

Response to Comment No. 4-66:

See response to Comment 4-54 (Vegetation Treatments Planning and Management – Methods – Planting and 

Seeding) regarding the use of native and non-native species. 3 Bars Project treatments would benefit forb and grass 

production for the benefit of a variety of plants and animals, not just livestock. 

Comment No. 4-101 from Western Watersheds Project: 

It appears since BLM refuses to use native plant species in any seedings and is promoting massive vegetation 

disturbance in a cheatgrass-prone landscape – it will end up with a coarse grass and weedland. First, weeds represent 

a loss of sustainable perennial forage for horses and livestock, and even less stability during Nevada’s never-ending 

drought years. Second, seeding exotics just results in even worse grazing problems –as range cons stock lands based 

on coarse unpalatable grasses that get eaten less than native species. So native grasses, forbs, and even shrubs bear the 

brunt of the grazing pressures. Also, mapping shows some existing cwg [crested wheatgrass] areas already. WHY is 

BLM not focusing its bioengineering energy on these – and acting to restore them, and recover biodiversity including 

seeding sage[brush], bitterbrush, or other shrubs? 

Response to Comment No. 4-101:

See response to Comment 4-54 (Vegetation Treatments Planning and Management – Methods – Planting and 

Seeding) regarding the use of native and non-native species. 

3 Bars Project Final EIS D-79 October 2016 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

Comment No. 4-153 from Western Watersheds Project: 

BLM also arbitrarily failed to assess revegetating with only native species and local native ecotypes, in outright 

defiance of current best available science for Great Basin systems. This helps to demonstrate that this is at its heart a 

livestock forage project, 

Response to Comment No. 4-153:

See response to Comment 4-54 (Vegetation Treatments Planning and Management – Methods – Planting and 

Seeding) regarding the use of native and non-native species. The BLM’s preference is to use native species, except in 

some instances where non-native species, such as forage kochia and crested wheatgrass, may be better able to 

stabilize the site and prevent revegetation by cheatgrass until native species can establish and flourish on the treatment 

site. 

Comment No. 4-226 from Western Watersheds Project: 

What is a “replacement” species? Are we to have hybridized weedy coarse exotic and pseudo-native cow forage 

cultivars strewn across this supposed “restoration” landscape?

Response to Comment No. 4-226:

The commenter refers to text found on page 3-114 of the Draft EIS: “The key factors relating to the removal of a 

water consumptive species and increased infiltration are topographic slope, soil permeability, precipitation frequency 

and duration, and the water consumptive nature of the replacement species.” In the context of the information 

provided on page 3-114, pinyon-juniper is the species being removed. As discussed in the previous paragraph on page 

3-114, “removal of pinyon-juniper and replacement with a less water consumptive species is often cited as the prime 

example of the beneficial effect to groundwater recharge from removal of an invasive water consumptive species.” In 

this case, native riparian species would revegetate the treatment site and result in improvement in groundwater 

recharge. 

D.5.17.11 Vegetation Treatments Planning and Management – Methods – Riparian 

Treatments 

Comment No. 4-117 from Western Watersheds Project: 

Or alternatively but not considered, BLM could control the livestock sufficiently to allow willows to recover, and reintroduce beavers – Nature’s Bioengineer! Are any beavers currently present in the project area? 

Response to Comment No. 4-117:

The BLM would use several approaches to improve riparian habitat as discussed in Final EIS Section 2.5.3.7, 

Alternatives, Streambank Stabilization and Channel Restoration. This could include plantings of willows, and could 

include use of small, temporary exclosure fencing to exclude livestock, wild horses, and other wild ungulates to 

ensure treatment success. In addition, as discussed in Final EIS Section 3.18.4, Livestock Grazing, Mitigation, 

Riparian Treatments Monitoring and Mitigation Measures, the BLM would implement monitoring and mitigation 

measures associated with livestock management to promote riparian treatment success, including restrictions on 

3 Bars Project Final EIS D-80 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

grazing season of use, removing livestock if herbaceous and shrubby vegetation conditions deteriorate, and using 

temporary fencing and water developments to manage livestock use patterns. 

Comment No. 4-119 from Western Watersheds Project: 

One thing might actually fix these watersheds, stabilize headcuts, store water naturally in systems, and increase 

sustainable perennial flows – i.e. nature’s own living, breathing, chewing dam building, water-retaining engineer – the 

beaver. 

Response to Comment No. 4-119:

Wildlife is managed by NDOW, and the BLM would be willing to work with NDOW on any reintroduction of native 

wildlife species. 

Comment No. 4-176 from Western Watersheds Project: 

BLM relied on natural recovery, and beavers, the stream could over time be brought closer to being in contact with its 

floodplain. 

Response to Comment No. 4-176:

See response to Comment 4-119 (Vegetation Treatments Planning and Management – Methods – Riparian 

Treatments). 

Comment No. 4-190 from Western Watersheds Project: 

Removal of PJ [pinyon-juniper] may reduce, degrade, stream systems and hydrology, and result in lethal temperatures 

for aquatic species, algae blooms, etc. it may cause large-scale new headcutting and erosional events. 

Response to Comment No. 4-190:

Potential concerns associated with the removal of pinyon-juniper and other vegetation near streams are discussed in 

Final EIS Section 3.11.3 (Wetlands, Floodplains, and Riparian Zones, Environmental Consequences), including the 

potential for short-term increases in stream temperature and channel degradation. The BLM would consult with the 

USFWS and NDOW to ensure that proposed treatments would not harm Lahontan cutthroat trout, as discussed in 

Final EIS Section 3.15.3 (Fish and other Aquatic Resources, Environmental Consequences). Long-term, treatments 

should help to reduce adverse alterations to channel morphology, moderate stream temperature, and increase the 

amount of stream habitat in Proper Functioning Condition, as discussed in Final EIS Section 3.11.3.6, Relationship 

between the Local Short-term Uses and Maintenance and Enhancement of Long-term Productivity, for Wetlands, 

Floodplains, and Riparian Zones. 

Comment No. 4-191 from Western Watersheds Project: 

None of the stream channels is actually big enough for a bulldozer to fit into, is it? 

3 Bars Project Final EIS D-81 October 2016 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

Response to Comment No. 4-191:

Bulldozers would primarily be used to transport and install natural (e.g., plantings, rock) and man-made (e.g., weir) 

structures to address streambank structural issues. Dirt work within the stream would most likely be done by a backhoe rather than a bulldozer, as movement of dirt can be more carefully controlled using a back-hoe than bulldozer. 

Give that most stream channels are relatively narrow on the 3 Bars Project area, and to minimize stream channel 

disturbance, back-hoes would be positioned outside of the stream channel and would reach into the stream channel to 

manipulate soil. It is highly unlikely that bulldozers would enter stream channels. The BLM would not conduct any 

in-stream work within Willow Creek. 

Comment No. 4-194 from Western Watersheds Project: 

the BLM would maintain vegetated buffers between the treatment area and wetlands ... How would you propose 

doing that when you are planning to destroy the only vegetation that has been able to survive the scorched earth 

grazing BLM has been imposing on these lands all of these years – i.e. the PJ [pinyon-juniper] in steep, rugged 

terrain? 

Response to Comment No. 4-194:

See response to Comment 4-32 (Fish and other Aquatic Resources - Environmental Consequences) and 4-191 

(Vegetation Treatments Planning and Management – Methods – Riparian Treatments) regarding treatments near 

streams and wetlands. The BLM would remove vegetation incrementally over several years if loss of shade near 

streams and other waterbodies is of concern to minimize stream temperature effects. 

Comment No. 4-245 from Western Watersheds Project: 

BLM claims it will replant its bulldozed, devegetated, cut banks – how long will it take for willows to recover to the 

height of junipers? 

Response to Comment No. 4-245:

It could take up to ten years for planted willows to mature. The larger concern to the BLM is the type of vegetation 

found within riparian treatment areas. As noted in Final EIS Section 3.11.3.3, Wetland, Floodplains, and Riparian 

Zones, Direct and Indirect Effects, pinyon and juniper are not riparian species, and are not as effective as native 

vegetation in stabilizing soil. Under pinyon-juniper treatments, the BLM has identified several projects to thin and/or 

remove pinyon-juniper to potentially increase water flows in streams and improve water infiltration. 

D.5.17.12 Vegetation Treatments Planning and Management – Roads 

Comment No. 4-86 from Western Watersheds Project: 

We stress that BLM never addresses very likely road upgrades associated with all parts of this project. Small two 

tracks will be smoothed out into roads, Trees will be cleared and sage[brush] crushed and destroyed - opening up 

wildlife habitats. 

3 Bars Project Final EIS D-82 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-86:

As noted in Final EIS Appendix C, Section C.2.1, Project Specific Standard Operating Procedures, General, under 

Item 5, “No new roads will be constructed.” Two-tracks are not proposed to be maintained or upgraded to ensure 

compliance with the Shoshone-Eureka RMP, which requires that any improved roads be designated through a travel 

management plan. 

Comment No. 4-166 from Western Watersheds Project: 

BLM fails to address the potential road upgrades and improvements that would occur as its fleet of dump trucks, 

crushers, choppers, pile burning scorching the soils, chainers, fire vehicles, etc. are unleashed on the landscape and 

sensitive watersheds. 

Response to Comment No. 4-166:

See response to Comment 4-86 (Vegetation Treatments Planning and Management – Roads). 

D.5.17.13 Vegetation Treatments Planning and Management – Treatment Costs 

Comment No. 4-37 from Western Watersheds Project: 

BLM has not adequately revealed how extraordinarily expensive the Preferred Alt.[ernative] actions are, and how 

much all linked and connected actions, including massive seeding, herbiciding, etc. as weeds invade would be. 

Response to Comment No. 4-37:

As shown in Table 3-73 (Estimated Treatment Costs per Acre) in Final EIS Section 3.25.3, Social and Economic 

Values and Environmental Justice, Environmental Consequences, and discussed in response to Comment 4-113

(Alternatives), treatment costs vary by method, with manual and classical biological control treatments costing 3 to 5 

times or more to implement per acre treated than do fire and mechanical treatments. Since the BLM would have the 

opportunity to use all proposed treatment methods under Alternative A (Preferred Alternative), it could use lower cost 

per acre treatments, and treat more acres for a fixed cost, than under Alternatives B and C. The effects of connected 

actions are discussed under Environmental Consequences for direct, indirect, and cumulative effects for each resource 

evaluated in the 3 Bars Project EIS. 

Comment No. 4-38 from Western Watersheds Project: 

It has also not quantified the scenic, cultural, natural historic, wildlife and wild horse viewing, water sustainability 

loss and other treatment-related costs and losses values. 

Response to Comment No. 4-38:

See response to Comment 4-37 (Vegetation Treatments Planning and Management – Treatment Costs) on the cost of 

treatments. As discussed in Final EIS Section 1.14, Limitations of this EIS, it was not possible for the BLM to 

quantify some impacts due to limited or unavailable information. Values referenced by the commenter vary by 

individual depending upon the individual’s interest in the resource area and value the individual places upon the 

3 Bars Project Final EIS D-83 October 2016 
VEGETATION TREATMENTS PLANNING AND MANAGEMENT

resource. As discussed in the 3 Bars Project EIS under Environmental Consequences, and in particular under 

“Relationship between the Local Short-term Use and Maintenance and Enhancement of Long-term Productivity,” the 

BLM anticipates that there will be short-term losses of resource values from treatments, but that resource values 

would improve long-term from current conditions. 

D.5.17.14 Vegetation Treatments Planning and Management – Treatment Areas - Riparian 

Comment No. 4-125 from Western Watersheds Project: 

BLM claims it will undertake 3,885 acres of riparian treatment. How many actual riparian acres are currently present? 

How many were historically present? How much of this area is has wet soils at present? How will this be altered by 

the project? How many miles of perennial flows? Where? Please provide detailed mapping? How has 2013 drought 

affected this? What types of springs are providing flows? Are they dependent on snowmelt? 

Response to Comment No. 4-125:

The BLM proposes to conduct treatments on about 3,885 acres adjacent to streams, ponds, and springs. There are 

approximately 96 miles of permanent stream that provide riparian habitat and wet soils year-round, and 2,335 miles of 

intermittent/ephemeral stream that also provide some riparian habitat and wet soils during a portion of the year, on the 

3 Bars Project area. The BLM would restore about 31 miles of perennial streams, 17 miles of intermittent streams, 

and 40 springs. There are also about 2,363 acres of wetlands on the 3 Bars Project area that have wet soils during all 

or part of the year. The location of streams, lakes, ponds, wetlands, and springs are shown on Final EIS Figure 3-23 

(Streams, Lakes, Ponds, and Wetlands) and summarized in Table 3-15 (Perennial and Intermittent/Ephemeral Streams 

on the Project Area), under Water Resources. Final EIS Section 3.10.2.3.3, Water Resources, Springs, discusses the 

status of springs on the 3 Bars Project area; EIS Table 3-18 (Flow Measurements at Springs) provides flow 

measurements for several springs. Most springs are in mountainous portions of the project area, and would thus 

benefit from snowmelt during the spring. The Environmental Consequences sections of Final EIS Sections 3.10, 

Water Resources, and 3.11, Wetlands, Floodplains, and Riparian Zones, discuss the effects of proposed treatments on 

riparian resources in the Riparian Treatments subsections. The term “historically” was not defined by the commenter, 

but riparian acreage has likely changed little during the past several decades. Drought conditions would affect the 

duration and amount of flow in streams and springs. 3 Bars Project Final EIS Section 3.5.2.2, Climate Change, 

discusses predicted effects to precipitation and water flows. 

D.5.17.15 Vegetation Treatments Planning and Management – Treatment Areas - 

Sagebrush 

Comment No. 3-1 from the Nevada Department of Wildlife: 

It was our recommendation that within mid and lower elevation sagebrush communities treatment test plots be 

conducted (several hundred acres or less) in an effort to ensure that we can effect positive change in these drier 

sites. We recommended that these tests be conducted prior to identified large scale treatments. At present, 

knowledge concerning the reestablishment of native herbaceous species within a sagebrush over story is not well 

known. It is thought that before BLM initiates treatment in these vegetation communities on a large scale that we 

should have a good idea that the treatment applied will be successful.

3 Bars Project Final EIS D-84 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 3-1:

Treatments in sagebrush would be limited to removing pinyon-juniper and seeding with native species. The BLM is 

willing to work with NDOW on the design and implementation of these proposed projects. 

D.5.18 Water Resources 

D.5.18.1 Water Resources – Affected Environment 

Comment No. 4-151 from Western Watersheds Project: 

BLM has not provided necessary detailed and site-specific information not only on the ones [springs] the EIS would 

attack, it has also not provided detailed site-specific information on the ones it would leave alone. Mapping of their 

location, assessment of their conditions, flows over the course of the year, predicted effects of mine and climate 

change, etc. - in the Three [3] Bars landscape have not been conducted. All of this information is necessary to assess 

the relative scarcity of undeveloped or unaltered springs – and understand the full context and intensity of the loss that 

would if BLM’s bulldozing dries up springs, or spring-fed segments of streams. 

Response to Comment No. 4-151:

The location of streams, lakes, ponds, wetlands, and springs are shown on Final EIS Figure 3-22 (Streams, Lakes, 

Ponds, and Wetlands) and summarized in EIS Table 3-15 (Perennial and Intermittent/Ephemeral Streams on the 

Project Area). Final EIS Section 3.10.2.3.3, Water Resources, Springs, discusses the status of springs on the 3 Bars 

Project area; EIS Table 3-18 (Flow Measurements at Springs) provides flow measurements for several springs. Most 

springs are in mountainous portions of the project area, and would thus benefit from snowmelt during the spring. The 

locations of 12 springs that would be treated by the BLM are shown on Final EIS Figure 2-1, Riparian Treatment 

Areas; the remaining 322 springs shown on Final EIS Figure 3-22 would not be treated. 

Comment No. 4-152 from Western Watersheds Project: 

Despite the endless EIS tables listing various habitat treatment destruction all over the place, even the most minimal 

and basic information on the streams and springs is lacking. For example, what is the volume of perennial water flow 

in all stream, spring, springbrook areas over all months of the year? How has it been altered by grazing, past 

treatments, roads, water developments for livestock, etc. Were there water inventories done here in the 1970s-1990s? 

If so, what was found? How do past flow rates for any periods that data is available compare to current flow rates? 

How much climate change adversely impact perennial flows? How long is the current perennial wetted 

segment/segments of the stream spring system? How has this changed over time? 

Response to Comment No. 4-152:

Information on water resources is provided in Final EIS Sections 3.10, Water Resources, and 3.11, Wetlands, 

Floodplains, and Riparian Zones, including information on flows. Additional discussion of flows and water quality of 

streams on much of the 3 Bars Project area is provided in the Mount Hope Project EIS (available at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/national_environmental/mount_hope_project

0.html.) and for streams with Lahontan cutthroat trout in the Biological Assessment for the 3 Bars Ecosystem and 

Landscape Restoration Project (USDOI BLM 2014). As discussed under Environmental Consequences, Cumulative 

Effects, Final EIS Sections 3.10 (Water Resources) and 3.11 (Wetlands, Floodplains, and Riparian Zones), livestock 

3 Bars Project Final EIS D-85 October 2016 
WATER RESOURCES 

management, roads, water developments, pinyon-juniper encroachment, noxious weeds, wildfire, and other factors 

have altered surface water flows and contributed to the need to restore several streams and springs on the 3 Bars 

Project area. Information on seasonal flow rates for several streams is given in EIS Tables 3-16 (Flow Summary from 

U.S. Geological Survey Monitoring Stations) and 3-17 (Site-specific Stream Investigations); more detailed 

information is provided in the Mount Hope Project EIS. The BLM does not have data on historic flows for streams 

and springs, other than for data presented in the EIS. Final EIS Section 3.10.2.5, Water Resources, Groundwater 

Resources, provides historical information on groundwater resources on the 3 Bars Project area. Drought conditions 

would affect the duration and amount of flow in streams and springs. Final EIS Section 3.5.2.2, Climate Change, 

discusses predicted effects to precipitation and water flows due to climate change. 

Comment No. 4-183 from Western Watersheds Project: 

Table 3-15 shows how very little perennial stream flow exists. When and how was the info collected that this is based 

on? 

Response to Comment No. 4-183:

Data provided in Table 3-15 ((Perennial and Intermittent/Ephemeral Streams on the Project Area) were based on 

several sources—JBR (2009), Montgomery and Associates (2010), and U.S. Geological Survey (2012a). Studies in 

support of the Mount Hope Project were conducted during 2007 and 2010 by JBR and Montgomery and Associates, 

while U.S. Geological Survey monitoring was done during 2010 to 2012, as shown in Final EIS Table 3-16 (Flow 

Summary from U.S. Geological Survey Monitoring Stations). Other historic information on water flows in the 3 Bars 

Project area is given in Final EIS Section 3.10.2.3.2, Streams and Creek Flows by Basin.

D.5.18.2 Water Resources – Assessment Methodology 

Comment No. 4-185 from Western Watersheds Project: 

How has BLM determined the effects of deforestation on rapid water loss and site drying, including in hotter, harsher, 

windier drier sites where water will simply be lost to the wind? 

Response to Comment No. 4-185:

The effects of thinning and removal of pinyon-juniper and noxious weeds and other invasive non-native vegetation on 

water resources are discussed in Final EIS Section 3.10, Water Resources. Short-term, there could be an increase in 

runoff and erosion due to vegetation removal, although studies have also shown an improvement in infiltration shortterm due to removal of pinyon-juniper in Phase II and III woodlands. Long-term, treatments should improve 

hydrologic function, stream flows, water infiltration, groundwater recharge, and water quality while reducing erosion. 

D.5.18.3 Water Resources – Cumulative Effects 

Comment No. 4-156 from Western Watersheds Project:

BLM must also fully assess the impacts of geothermal activity or other energy activity that may use fracking. Does 

mining use a process akin to fracking, as well? It appears to us that the massive bioengineering scheme – which is 

certain to further deplete, destroy and diminishing perennial surface waters will also serve as “cover” for the masking 

the large-scale adverse impacts of all the declines that are underway (and/or highly foreseeable) in the aquifer – from 

3 Bars Project Final EIS D-86 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

mining aquifer drawdown, continued irrigation of marginal crops using ground water pumping, and from foreseeable 

fracking-like activity associated with geothermal development. 

Response to Comment No. 4-156:

The cumulative effects from past, present, and reasonably foreseeable future actions for water resources are discussed 

in Final EIS Section 3.10.3.4, Water Resources, Cumulative Effects. Waste rock and ore are removed by blasting 

during mining. Fracking could be used for geothermal development projects on or near the 3 Bars Project area. 

Although there could short-term loss of soil and deterioration of water quality due to proposed stream treatments, 

these treatments, including bioengineering treatments, would restore stream functionality and improve water flows 

and quality long-term (see Final EIS Sections 2.3.1.3.7, Streambank Stabilization and Channel Restoration, and 

3.10.3.3, Water Resources, Direct and Indirect Effects). 

Comment No. 4-181 from Western Watersheds Project: 

[Page] 3-107 [of the Draft EIS] admits the Kobeh Valley is losing water due to pumpage from groundwater storage. It 

is clear that the Diamond Valley is turning into a dustbowl DEIA [Draft EIS] at [Page] 3-108 state that irrigation 

pumping has created a groundwater depression, and the southern part of the valley is subsiding. What effect is overall 

mine depletion of ground water – Cortez to Robinson and all points in between – having on this, as well? 

Response to Comment No. 4-181:

The cumulative effects from past, present, and reasonably foreseeable future actions for water resources are discussed 

in Final EIS Section 3.10.3.4, Water Resources, Cumulative Effects. As noted in Table 4.2-4 (Past, Present, and 

Reasonably Foreseeable Future Actions for the Native American Traditional Concerns Cumulative Effects Study 

Area) of the Mount Hope Project EIS, dewatering and groundwater consumption have occurred at several mines in 

the 3 Bars Project cumulative effects study area (available at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/national_environmental/mount_hope_project

0.html). These effects, and those that would occur from development of the Mount Hope Project, are discussed in 3 

Bars Project Final EIS Section 3.10.3.4 (Water Resources, Cumulative Effects), and in the Mount Hope Project EIS. 

Comment No. 4-182 from Western Watersheds Project: 

Grass Valley is also in serious trouble, and now the Ormat geothermal developers are punching holes in the aquifer all 

over the place. Are they using processes akin to fracking? Instead, though, of looking at any current information –

BLM uses figures from 1966 in its so-called “analysis”. We are greatly concerned that no information on mining 

impacts to aquifers (current or projected) is in here at all. 

Response to Comment No. 4-182:

Geothermal development may use fracking. The cumulative effects from past, present, and reasonably foreseeable 

future actions for water resources are discussed in Final EIS Section 3.10.3.4, Water Resources, Cumulative Effects. 

Much of the information in this section related to mining, including effects of mining, agriculture, and other water 

uses on groundwater resources and water balance, was taken from the Mount Hope Project EIS from studies 

conducted in 2009 and 2010 (Montgomery and Associates 2010; see 3 Bars Project Final EIS Section 3.10.2.5, Water 

Resources, Groundwater Resources). The reader is encouraged to review this report and other groundwater studies 

3 Bars Project Final EIS D-87 October 2016 
WATER RESOURCES 

conducted in support of the Mount Hope Project EIS at URL: 

http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/national_environmental/mount_hope_project

0.html. 

D.5.18.4 Water Resources – Environmental Consequences 

Comment No. 4-128 from Western Watersheds Project: 

Track-hoes, back-hoes, and dump trucks would be used for dirt work and to haul rock. BLM is highly likely to 

puncture and destroy the underlying clay layers where spring waters seep out, or impact areas of snowmelt deposition. 

See Sada et al. 2001, BLM Technical Bulletin. This will result in killing all surface flows – which instead of 

“improving” wildlife habitat and aquatic species habitat, will destroy it. Many important wild land springs will be 

ripped and torn apart:

Response to Comment No. 4-128:

See response to Comments 4-125 (Vegetation Treatments Planning and Management – Treatment Areas - Riparian), 

4-151 (Water Resources – Affected Environment), and 4-191 (Vegetation Treatments Planning and Management –

Methods – Riparian Treatments). 

Comment No. 4-147 from Western Watersheds Project: 

The EIS refused to consider a significant concern – the aquifer depletion from the moly [molybdenum] mine, the 

Carlin trend mines to the north, mines to the east, and from ag[riculture] pumping in the valleys. It is impossible to 

understand how this all will affect use of the landscape by all animals, recreation, impairment of the values of the 

WSA [Wilderness Study Area], and many important components of the public lands. Is this then why BLM plans to 

cut down all trees within 200 ft of the stream? Hoping to reduce transpiration and magically make there be more 

water - because the mines are drying up the springs, seeps and streams across the region? And is this why the 

bulldozing of the streams? 

Response to Comment No. 4-147:

See response to Comments 4-186 and 4-187 (Water Resources – Cumulative Effects) for the effects of past, present, 

and reasonably foreseeable future mining, agriculture, and other activities on surface and groundwater resources 

within the 3 Bars Project cumulative effects study area. The adverse and beneficial effects of vegetation removal on 

hydrologic function, stream flows, water infiltration, groundwater recharge, water quality, and erosion are discussed 

in Final EIS Section 3.10.3, Water Resources, Environmental Consequences. The use of bulldozers near streams, and 

their effects, are discussed under Comment 4-191 (Vegetation Treatments Planning and Management – Methods –

Riparian).

Comment No. 4-150 from Western Watersheds Project: 

So then why has BLM not addressed the aquifer concerns WWP [Western Watersheds Project] raised in Scoping? 

3 Bars Project Final EIS D-88 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Response to Comment No. 4-150:

As noted in the Final Scoping Report 3 Bars Ecosystem and Landscape Restoration Project (AECOM 2010; available 

at URL: https://www.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=37403), Table 3, 

Scoping Comment Issue Summary, and 3 Bars Project Final EIS Section 3.10.3, Water Resources, Environmental 

Consequences, effects on local aquifers from 3 Bars and other projects on groundwater resources were identified as a 

key issue to be addressed in the 3 Bars Project EIS. See response to Comments 4-181 and 4-182 (Water Resources –

Cumulative Effects) for the effects of past, present, and reasonably foreseeable future mining, agriculture, and other 

activities on surface and groundwater resources within the 3 Bars Project cumulative effects study area. One 

commenter during public scoping asked the BLM to evaluate the effects of groundwater removal from the Southern 

Nevada Water Project on 3 Bars Project water resources. The BLM did not conduct this analysis because groundwater 

resources that would be used for the Southern Nevada Water Project are far removed from the 3 Bars Project area and 

do not interact with those on the 3 Bars Project area. 

Comment No. 4-180 from Western Watersheds Project: 

How many of the 334 springs have been dug into, piped, or otherwise altered for livestock? What were the impacts? 

What is the aquatic habitat condition at these? How dependent are they on snow accumulation? How will 

deforestation and denuding of the landscape reduce snow accumulation and speed. 

Response to Comment No. 4-180:

Impacts from the proposed action to Water Resources can be found in Section 3.10 of Chapter 3, and impacts to 

Wetlands, Floodplains and Riparian Zones can be found in Section 3.11 of Chapter 3, of the Final EIS. Also see 

Figure 3-24 (Water Developments and Water Uses) in the Final EIS for the locations of water developments on the 3 

Bars Project area. 

Comment No. 4-184 from Western Watersheds Project: 

There is no clear evidence that killing trees will increase water to any significant extent, especially after the full extent 

of erosion and grazing plays out. Will treatments remove stockponds? And what kind of water developments are 

being considered? 

Response to Comment No. 4-184:

Studies that discuss the pros and cons of pinyon-juniper removal to improve water flows and infiltration are discussed 

in Final EIS Section 3.10.3, Water Resources, Environmental Consequences, Pinyon-juniper Treatments. The BLM 

does not propose to remove stockponds, or create water developments, under the 3 Bars Project. 

Comment No. 4-188 from Western Watersheds Project: 

BLM admits that “restoration”/destruction of native vegetation and disturbance of soils making them susceptible to 

erosion would affect surface water quality. The studies BLM cites do not account for livestock grazing effects. See 

Belsky 1996, for example. Note the Pierson study showing that erosion was 20-fold greater on burned sites. 

3 Bars Project Final EIS D-89 October 2016 
WATER RESOURCES 

Response to Comment No. 4-188:

The effects of livestock grazing and other past, present, and reasonably foreseeable future actions on water resources 

are discussed in Final EIS Section 3.10.3.4, Water Resources, Cumulative Effects. Pierson (2013; see Section 3.10.3, 

Water Resources, Environmental Consequences) did observe that runoff and erosion increased post fire, but also 

stated that activities that stimulate vegetation productivity may provide long-term reduction of soil loss, especially 

when compared to untreated areas with pinyon-juniper. The BLM has included this information in Final EIS Section 

3.10.3, Water Resources, Environmental Consequences.

Comment No. 6-3 from J. Brown: 

Any “treatments” to water sources (including use of motorized machinery) must be clearly outlined – specific 

locations, duration of each treatment, etc. must be disclosed and analyzed, and alternative actions with fewer 

impacts must be analyzed to ensure the most environmentally-friendly “treatment” is implemented. 

Response to Comment No. 6-3: 

Site-specific treatment locations and actions are clearly defined in Chapter 2. See response to Comment 4-135

(Alternatives) for a discussion of alternatives proposed for the 3 Bars Project. 

Comment No. 9-7 from K. Gregg: 

Any “treatments” to water sources (including use of motorized machinery) must be clearly outlined – specific 

locations, duration of each treatment, etc. must be disclosed and analyzed, and alternative actions with fewer 

impacts must be analyzed to ensure the most environmentally-friendly “treatment” is implemented. 

Response to Comment No. 9-7: 

See response to Comment 6-3 (Water Resources – Environmental Consequences). 

D.5.19 Wetlands, Floodplains, and Riparian Zones 

D.5.19.1 Wetlands, Floodplains, and Riparian Zones – Affected Environment 

Comment No. 4-126 from Western Watersheds Project: 

BLM here refers to PFC [Proper Functioning Condition]. PFC provides no valid assessment of aquatic habitat 

components. Who conducted PFC? When? Why was no assessment of aquatic habitat composition conducted? What 

biases are associated with PFC? 

Response to Comment No. 4-126:

BLM ecologists have conducted Proper Function Condition surveys on about 179 miles of stream and 167 acres of 

wetlands. Surveys were conducted during the past 2 decades. Important components considered during the studies are 

discussed in Final EIS Section 3.11.2.5 (Wetlands, Floodplains, and Riparian Zones, Proper Functioning Condition 

Surveys), and in Riparian Area Management, A User Guide to Assessing Proper Functioning Condition and Support 

Science for Lotic Areas (USDOI BLM 1998; available at URL: 

3 Bars Project Final EIS D-90 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

www.blm.gov/or/programs/nrst/files/Final%20TR%201737-15.pdf). Based on this guidance, BLM ecologists conduct 

field assessments of 17 riparian/aquatic habitat components to determine if riparian-wetland areas are functioning 

properly. These include components that help to determine if adequate vegetation, land form, or large woody debris 

are present to: 

• dissipate stream energy associated with high waterflows, thereby reducing erosion and improving water 

quality; 

• filter sediment, capture bedload, and aid floodplain development; 

• improve floodwater retention and groundwater recharge; 

• develop root masses that stabilize streambanks against cutting action; 

• develop diverse ponding and channel characteristics to provide the habitat and the water depth, duration, and 

temperature necessary for fish production, waterfowl breeding, and other uses; 

• and support greater biodiversity. 

The methodology provided in the Guide helps BLM ecologists with the assessment process and helps to reduce the 

potential for bias among field surveyors. 

Comment No. 4-189 from Western Watersheds Project: 

Who conducted the PFC [Proper Functioning Condition] inventories and when? How was trend determined? How 

might these treatments degrade conditions? How can highly degraded watersheds withstand treatments? How and 

when does grazing occur? What is actual use any pasture? What riparian standards are in place, and where and when 

are they measured? What does monitoring show, and please provide this. 

Response to Comment No. 4-189:

Proper Functioning Condition surveys and monitoring studies have been conducted by the BLM since the 1990s. The 

criteria for determining Proper Functioning Condition, and results of these studies, are given in Final EIS Section 

3.11.2.5, Wetlands, Floodplains, and Riparian Zones, Proper Functioning Condition Surveys. The methods used to 

conduct Proper Functioning Condition are in Riparian Area Management, A User Guide to Assessing Proper 

Functioning Condition and Support Science for Lotic Areas (USDOI BLM 1998; available at URL: 

www.blm.gov/or/programs/nrst/files/Final%20TR%201737-15.pdf). As discussed in Final EIS Section 3.11.3, 

Wetland, Floodplains, and Riparian Zones, Environmental Consequences, proposed 3 Bars Project treatments could 

lead to short-term degradation of riparian function, but should lead to long-term improvement in riparian function. 

Highly degraded streams would be most in need for treatment to ensure that they do not continue to degrade. Grazing 

management is discussed in Final EIS Section 3.18, Livestock Grazing. Riparian standards are discussed in USDOI 

BLM (1998), and Final EIS Appendix C, Standard Operating Procedures. The BLM has also proposed mitigation and 

monitoring measures for the 3 Bars Project to ensure treatment success in riparian and other areas on the 3 Bars 

Project area, as discussed in Final EIS Section 3.18.4, Livestock Grazing, Mitigation. 

D.5.19.2 Wetlands, Floodplains, and Riparian Zones – Environmental Consequences 

Comment No. 4-33 from Western Watersheds Project: 

Much more detailed analysis that must be conducted that avoids disturbance in RHCAs [Riparian Habitat 

Conservation Areas]. 

3 Bars Project Final EIS D-91 October 2016 
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES

Response to Comment No. 4-33:

Aquatic Conservation Strategy standards and guidelines for riparian areas, including Riparian Habitat Conservation 

Areas, have been developed and are included in all BLM and Forest Service resource management plans through the 

Northwest Forest Plan (USDA Forest Service and USDOI BLM. 2004. Amending Resource Management Plans for 

Seven Bureau of Land Management Districts and Land and Resource Management Plans for Nineteen National 

Forests Within the Range of the Northern Spotted Owl. Decision to Clarify Provisions Relating to the Aquatic 

Conservation Strategy. Portland, Oregon. Available at URL: 

http://www.reo.gov/documents/acs/FinalROD03_17_04.pdf) to protect anadromous fish and bull trout within the 

Columbia River Basin. Riparian Habitat Conservation Areas were not developed for Nevada. However, as discussed 

in 3 Bars Project Final EIS Section 2.3.1.1, Alternatives, Riparian Treatment Units, the BLM has identified about 

3,885 acres of riparian zone habitat for restoration on the 3 Bars Project area. In Final EIS Section 3.11, Wetlands, 

Floodplains, and Riparian Zones, and Appendix C, Section C.2.7, Standard Operating Procedures, Riparian 

Management, the BLM has identified numerous SOPs to ensure protection of riparian zones treatment areas and other 

riparian zone habitat within the 3 Bars Project area. 

D.5.20 Wilderness Study Areas and other Special Management Areas 

D.5.20.1 Wilderness Study Areas and other Special Management Areas – Affected 

Environment 

Comment No. 4-246 from Western Watersheds Project: 

Why haven't you done a Lands with Wilderness Characteristics study across the Three [3] Bars area? Particularly in 

the Simpson Park area? 

Response to Comment No. 4-246:

An inventory of Lands with Wilderness Characteristics was completed in 2012 for Battle Mountain District, as part of 

the Resource Management Plan Revision in progress for the District. That inventory did not show any areas meeting 

the criteria for Lands with Wilderness Character in the 3 Bars Project area, and the proposed land treatments and 

project activities as part of the 3 Bars Project should not impact any Lands with Wilderness Character. Future project 

activities in upcoming years may be subject to additional and appropriate site-specific review under NEPA, and the 

inventory may be updated at that time as part of such site-specific review. The inventory also will be updated as the 

Resource Management Plan Revision further progresses for the whole Battle Mountain District. 

D.5.20.2 Wilderness Study Areas and other Special Management Areas – Cumulative 

Effects 

Comment No. 4-247 from Western Watersheds Project: 

BLM has failed to provide an adequate baseline of the current degree and severity of impairment of values from 

livestock grazing degradation or other threats to the WSAs. 

Response to Comment No. 4-247:

3 Bars Project Final EIS D-92 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

Impacts to WSAs can be found in Final EIS Chapter 3, Sections 3.22.3.3 and 3.22.3.4 (Wilderness Study Areas and 

other Special Management Areas). 

Comment No. 4-248 from Western Watersheds Project: 

We are very concerned about all the BLM proposed herbicide use, including aerial application where there is 

significant risk of drift. 

Response to Comment No. 4-248:

No herbicides are being proposed for use as part of any proposed action for the 3 Bars Project. 

D.5.20.3 Wilderness Study Areas and other Special Management Areas – Environmental 

Consequences 

Comment No. 4-127 from Western Watersheds Project: 

Where is a current survey for Lands with Wilderness Characteristics? Please provide us with this document. How will 

this affect and impair the values of both WSAs and LWC [Lands with Wilderness Characteristics]? 

Response to Comment No. 4-127:

An inventory of Lands with Wilderness Characteristics was completed in 2012 for Battle Mountain District, as part of 

the Resource Management Plan Revision in progress for the District. That inventory did not show any areas meeting 

the criteria for Lands with Wilderness Character in the 3 Bars Project area, and the proposed land treatments and 

project activities as part of the 3 Bars Project should not impact any Lands with Wilderness Character. Future project 

activities in upcoming years may be subject to additional and appropriate site-specific review under NEPA, and the 

inventory may be updated at that time as part of such site-specific review. The inventory also will be updated as the 

Resource Management Plan Revision further progresses for the whole Battle Mountain District. 

D.5.21 Wild Horses 

D.5.21.1 Wild Horses – Affected Environment 

Comment No. 4-18 from Western Watersheds Project: 

Where are the areas of the HMAs with less disturbance and intrusion? 

Response to Comment No. 4-18:

Final EIS Figure 3-43 shows areas within HMAs where habitat needs improvement. It is unclear what type of 

disturbance or intrusion the commenter is referring to in this question. 

Comment No. 4-72 from Western Watersheds Project: 

Where are all foaling areas, winter habitats, etc. and how do the horses and individual horse bands use this landscape? 

Response to Comment No. 4-72:

3 Bars Project Final EIS D-93 October 2016 
WILD HORSES

3 Bars Project Final EIS D-94 October 2016 

The affected environment for wild horses within the 3 Bars Project Area is described in Section 3.17.2 (Wild Horses, 

Affected Environment) of the EIS. The Battle Mountain District does not have records of specific foaling areas by 

HMA, or information about individual bands of horses within the HMAs. 

The Roberts Mountain HMA is the largest HMA within the project area. This HMA consists of lower elevation 

Wyoming big sagebrush and higher elevation sites that either support pinyon-juniper woodlands or mountain big 

sagebrush. Wild horse movement and usage patterns are affected by many variables including climate and weather; 

forage and water availability; wild horse population size and resulting competition for space, forage, and water; 

human activity (mining, hunting, recreating, ranching); and wild horse gathers. Within the Roberts Mountain HMA, a 

portion of the wild horse population resides in both lower and higher elevations during the year. During winter, many 

horses may move into the lower elevations of Kobeh Valley in the Roberts Mountain HMA, and the Kobeh Valley 

Herd Area, where snow is not as deep. In the summer, many horses use the open mountain big sagebrush slopes on

higher elevations where forage and water are available, and temperatures are cooler. In recent years, with the HMA 

population in excess of AML, a large portion of the population resides north of the HMA boundary in the Three Bars 

and Roberts Mountain Allotments. 

The small portion of the Fish Creek HMA within the project area is associated with the Roberts Mountain HMA and 

these two areas are managed as a Complex. No perennial waters are found within the Fish Creek HMA. Wild horses 

use the Kobeh Herd Area surrounding the Fish Creek HMA as they pass through Kobeh Valley into the Roberts 

Mountain and Whistler Mountain HMAs. During summer, only a few wild horses are typically observed near the Fish 

Creek HMA. Populations may increase in winter based on the severity of snow in the valley as wild horses move into 

lower elevations with less snow to forage. 

The Whistler Mountain HMA is also associated with the Roberts Mountain HMA. Wild horses are not typically found 

within the Whistler Mountain HMA year-round, as the HMA is small and lacks water sources. Instead, horses move 

back and forth between the Whistler Mountain HMA, Kobeh Valley, and the Roberts Mountain HMA. 

Rocky Hills is near, but not associated with, the Roberts Mountain HMA, although occasional movement of wild 

horse between the two areas does occur. The Rocky Hills HMA is comprised of lower valley areas supporting black 

and Wyoming big sagebrush, and rolling terrain covered with varying amounts of pinyon-juniper woodlands. The 

area endured a large wildfire in 1999 (Trail Canyon Fire) that burned a large portion of the HMA. Currently, crested 

wheatgrass and forage kochia are present in the northern portion of the Rocky Hills HMA due to seeding efforts 

following the 1999 Trail Canyon Wildfire. Wild horses do not currently, and have not historically, used the HMA 

evenly. Most wild horses congregate in the northern portion of the HMA near Cadet Springs. No use of the southern 

portion of the HMA has been documented since 1998, and wild horses rarely utilize the western portion of the HMA 

in the Grass Valley Allotment. 

D.5.21.2 Wild Horses – Environmental Consequences 

Comment No. 4-69 from Western Watersheds Project: 

How has BLM systematically and methodically separated wild horse impacts from livestock impacts? How has BLM 

taken livestock trespass and non-compliance into account in this? Please provide all the monitoring and other data this 

claim is based on in a Supplemental EIS. 

Response to Comment No. 4-69:
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

See Final EIS Chapter 3, Section 3.17.2 (Wild Horses, Affected Environment) for information on the affected 

environment for wild horses, and Section 3.18.2 (Livestock, Affected Environment) for information on the affected 

environment for livestock. The analysis for this project does not require that the impacts from wild horses be 

separated from livestock. As discussed in Section 3.17.3 (Environmental Consequences, Cumulative Effects), 

historical use by both wild horses and livestock have had impacts within the 3-Bars ecosystem. It is unclear what 

claim the commenter is referring to, or what particular monitoring data are being requested. 

3 Bars Project Final EIS D-95 October 2016 
WILD HORSES

3 Bars Project Final EIS D-96 October 2016 

Comment No. 4-71 from Western Watersheds Project: 

What reference areas is BLM using to separate livestock vs. wild horse impacts? Are there any? Where? What size? 

What do they show? This Project spans 4 HMAs, and Fish Creek extends beyond the Project area. What is the 

condition of lands outside the Project area? What are the threats to those areas – from mines, weeds, energy, grazing, 

roads, etc.? 

Response to Comment No. 4-71:

See response to Comment 4-69 (Wild Horses – Environmental Consequences). See Final EIS Chapter 3, Section 

3.17.2 (Wild Horses, Affected Environment) for information on the affected environment for wild horses The 

conditions of lands outside the project area are considered in the cumulative impacts analysis in Section 3.17.3.4 

(Wild Horses, Environmental Consequences, Cumulative Effects). 

Comment No. 4-92 from Western Watersheds Project: 

The D[raft]EIS fails to ensure viable wild horse herds, because it lacks necessary detailed information and analysis of 

the projects that will be conducted, how grazing will be dealt with, the many stresses on the HMAs and herds, and 

many other serious concerns. 

Response to Comment No. 4-92:

As discussed in Section 1.3.5 of the Final EIS, Proposed Action and Purpose and Need, Wild Horses, there is concern 

regarding the effects of multiple factors on rangeland resources for wild horses. An important objective of the RMP 

for the Shoshone-Eureka Resource Area is to manage viable herds of sound, healthy, wild horses in a wild and freeroaming state (see Table 1-1 in Final EIS Section 1.6.2, Shoshone-Eureka RMP). Information on how projects would 

be conducted is provided in Final EIS Chapter 2, Alternatives. The effects of treatments on wild horses are discussed 

in Final EIS Section 3.17.3, Wild Horses, Environmental Consequences, and includes a discussion of the stresses on 

wild horses and HMAs. As discussed in Section 3.17.3, there would be short-term adverse effects, but long-term 

benefits from 3 Bars Project treatments on wild horses and HMAs. The BLM has developed SOPs specific to wild 

horses (see Final EIS Appendix C, Section C.2.3, Wild Horses), to ensure that the health and safety of wild horses are 

not compromised by treatment activities. 

Comment No. 4-93 from Western Watersheds Project: 

How will these treatments increase likelihood of gathers? How will these treatments, fencing, and all kinds of 

disturbance impact wild and free roaming herds, family bands, use of important seasonal habitats? 

Response to Comment No. 4-93:

3 Bars Project Final EIS Section 3.17.3, Wild Horses, Environmental Consequences, discusses the direct, indirect, and 

cumulative effects from proposed 3 Bars Project treatments on wild horses, their habitat use, and movements, and on 

the need for future gathers, under 3 Bars Project alternatives. There is no indication that any treatment implemented 

would increase the frequency of gathers within the project area. Future gathers will be influenced by application of 

population growth suppressants in addition to population size and habitat health. Improvements to the habitat would 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-97 October 2016 

be monitored through future years and evaluated as it pertains to wild horses in a Rangeland Health Assessment or 

other similar document. 

Comment No. 4-220 from Western Watersheds Project: 

How is BLM protecting wild horse foaling areas from grazing, for instance? 

Response to Comment No. 4-220:

There is no information to suggest that wild horses need protection from livestock grazing during the peak foaling or 

other seasons of the year. Standard Operating Procedures that could affect wild horses are provided in Final EIS 

Appendix C, Section C.2.3, Wild Horses. 

Comment No. 5-1 from G. Kuhn, American Wild Horse Preservation Campaign: 

Does this area include any Herd Management Areas or Herd Areas? If so could you provide what specific ‘habitat 

enhancement and/or hazardous fuel reduction treatments’ would be taking place in those HMA’s/HA’s?

Response to Comment No. 5-1:

A discussion of HMAs that could be affected by the 3 Bars Project is provided in Final EIS Section 3.17.2.3, Wild 

Horses, Individual HMA Characteristics. Proposed hazardous fuels and habitat enhancement projects that would 

occur on HMAs are discussed in Chapter 2, Alternatives, and in Section 3.17.3, Wild Horses, Environmental 

Consequences. 

Comment No. 6-4 from J. Brown: 

Each proposed action must specifically be analyzed to determine if there is any temporary or permanent impact these 

actions may have on wild horses, their movement, their access to natural environmental components (cover, water, 

forage), etc. 

Response to Comment No. 6-4:

Site-specific treatment locations and actions are clearly defined in Chapter 2 and impacts to wild horses can be found 

in Section 3.17.3 (Wild Horses, Environmental Consequences). No barbed wire or let-down fencing will be allowed 

within HMA boundaries, and let-down fencing will not be used where wild horses are present and may become 

entrapped in the fence. Where exclusionary fencing is constructed around water features, the BLM will provide access 

to water through the form of a water gap or impoundment. 

Comment No. 8-2 from M. Devlin: 

The project as currently described is likely to displace the wild horses during landscape-treatment periods. The horses 

will be further displaced by being fenced out for prolonged periods during landscape-recovery. The HMAs’

configurations will shift, thereby disrupting the horses’ use of land that is dedicated for their principal use. How will 

you mitigate these adverse effects? 

Response to Comment No. 8-2:

See response to Comment 6-4 (Wild Horses – Environmental Consequences). 
WILD HORSES

3 Bars Project Final EIS D-98 October 2016 

Comment No. 8-6 from M. Devlin: 

Please disclose how BLM will ensure the continuation of viable wild-horse herds in spite of the project. The viability 

plan must be predicated on an analysis of each affected herd’s:

history, 

characteristics, 

local water sources, 

seasonal pastures, 

migration routes, 

roundup-and-removal record, 

fertility-control record, 

genetic-testing record, and 

genetic-test results and recommendations. 

Response to Comment No. 8-6:

Site-specific treatment locations and actions are clearly defined in Chapter 2 and impacts to wild horses can be found 

in Section 3.17.3 (Wild Horses, Environmental Consequences). Also see response to Comment 6-4 and 8-2 (Wild 

Horses – Environmental Consequences). 

Comment No. 9-4 from K. Gregg: 

The Draft EIS fails to adequately analyze the impact of the preferred or proposed actions on wild horses, wildlife and 

the wild horse Herd Areas in the targeted Project area. 

Response to Comment No. 9-4:

Site-specific treatment locations and actions are clearly defined in Final EIS Chapter 2. Adverse and beneficial effects 

to wild horses and wildlife as discussed in Final EIS Sections 3.16.3 (Wildlife Resources, Environmental 

Consequences) and 3.17.3 (Wild Horses, Environmental Consequences). 

Comment No. 9-8 from K. Gregg: 

Each proposed action must specifically be analyzed to determine if there is any temporary or permanent impact these 

actions may have on wild horses, their movement, their access to natural environmental components (cover, water, 

forage), etc. 

Response to Comment No. 9-8: 

See response to Comment 6-4 (Wild Horses – Environmental Consequences). 

Comment No. 10-1 from E. Hennessy: 

There would surely be long-term impacts on mustangs and other wildlife from the proposed actions in the Project’s 

targeted areas due to BLM removing protective cover, or poor site recovery. The long-term impacts of such actions, 

which would result in loss of vital protective coverage, necessary forage, habitat access and inadequate range 

restoration, have not been seriously considered and must be thoroughly examined in the revised EIS. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-99 October 2016 

Response to Comment No. 10-1:

See response to Comment 9-4 (Wild Horses, Environmental Consequences). 

D.5.22 Wildland Fire and Fire Management 

D.5.22.1 Wildland Fire and Fire Management – Affected Environment 

Comment No. 4-74 from Western Watersheds Project: 

Key concerns from the AECC for fire include excessive hazardous fuel loads and fuel situations, and declining 

ecosystem health in some areas, which are contributing to high wildfire potential and threats to resource values. Then 

WHY haven’t there been immense and large-scale fires here, like so many other places? The largest sage[brush] lands 

fires occur in large stands of grass, and particularly with cheatgrass in the interspaces. 

Response to Comment No. 4-74:

There have been several large fires within the 3 Bars area as documented in Table 3-40 and Figure 3-34 in the EIS. 

Comment No. 4-88 from Western Watersheds Project: 

The underlying vegetation information (and DFC/”Desired” [Future] Condition) used to justify this are based on 

models that use wildly inaccurate fire return and disturbance intervals, and fundamentally ignore the natural historical 

vegetation community across much of the project area and broader landscape in the Great Basin. 

Response to Comment No. 4-88:

The BLM selects methods for evaluation based on the most recent science, policy, and other information available. 

Comment No. 4-114 from Western Watersheds Project: 

What are the fire return and disturbance intervals that the 2004 Plan was based on? How do these compare to 

information in Knick and Connelly 2009, 2011 Studies in Avian Biology Baker and other Chapters, Bukowski and 

Baker 2013n? 

Response to Comment No. 4-114:

The 2004 Fire Management Plan uses Landfire data and is intended to be a coarse scale guide to assist Fire 

Management decisions. This is the standard that has been established for use by the U.S. Department of the Interior. 

Comment No. 4-115 from Western Watersheds Project: 

See also Romme et al. 2009, Lanner The Pinyon Pine, describing much longer fire return/disturbance intervals for 

pinyon juniper, and PJ [pinyon-juniper] naturally burns very infrequently (every 200 years or much longer) in what 

BLM fear mongering jargon terms “catastrophic” fires. A very large body of current information and science on fires 

– that simply did not exist at the time of the old 2004 Fire Plan and was ignored in the ]17-States] Veg[etation 

Treatments] PEIS and NEPA-less [17- States] PER shows that large fires are climate-driven – i.e. very hot, dry, 

windy conditions, and that that thinning and other efforts to fire-proof large wild landscapes are not effective under 

the conditions when the big fires, burn. 
WILDLAND FIRE AND FIRE MANAGEMENT

3 Bars Project Final EIS D-100 October 2016 

Response to Comment No. 4-115:

Fire regimes are classified by BLM specialists based on site specific field observations. Fire regimes for pinyonjuniper can be generally classified as either a III or a V based on the area and existing conditions. 

The five natural (historical) fire regimes are classified based on average number of years between fires (fire 

frequency) combined with the severity (amount of replacement) of the fire on the dominant overstory vegetation. 

These five regimes include: 

I – 0-35 year frequency and low (surface fires most common) to mixed severity (less than 75 percent of the dominant 

overstory vegetation replaced); 

II – 0-35 year frequency and high (stand replacement) severity (greater than 75 percent of the dominant overstory 

vegetation replaced); 

III – 35-100+ year frequency and mixed severity (less than 75 percent of the dominant overstory vegetation replaced); 

IV – 35-100+ year frequency and high (stand replacement) severity (greater than 75 percent of the dominant overstory 

vegetation replaced); and 

V – 200+ year frequency and high (stand replacement) severity. 

Comment No. 4-116 from Western Watersheds Project: 

In fact, the “hazardous fuel” pinyon-juniper are the landscape areas that are actually the least likely to burn. They burn 

primarily in large-scale wind and dry conditions fire events – where no amount of very expensive chipping, chopping 

crushing, etc. will make much difference. Please provide much more detailed analysis of how fire proof these systems 

really naturally are. 

Response to Comment No. 4-116:

While it is true that pinyon-juniper are less likely to burn than a sagebrush fuel type, and dry conditions and wind do 

contribute to pinyon-juniper burning, pinyon-juniper are not “fire proof.” First, dry conditions and wind will 

contribute to increased fire behavior in almost all vegetation types. Second, pinyon-juniper are considered fire 

dependent, meaning that they need fire at some point in their life-cycle. In the case of pinyon-juniper, the role of fire 

is to open older, closed-canopy stands to allow for new growth. 

Comment No. 4-208 from Western Watersheds Project: 

What is the fire return interval and historical range of variability time intervals that are being used to determine this? 

You cannot rely on Rick Miller, who has been dead wrong about fire intervals. 

Response to Comment No. 4-208:

The currently accepted definitions for fire return intervals are as follows: 

“A natural fire regime is a general classification of the role fire would play across a landscape in the absence of 

modern human mechanical intervention, but including the influence of aboriginal burning (Agee 1993, Brown 1995). 

Coarse scale definitions for natural (historical) fire regimes have been developed by Hardy et al. (2001) and Schmidt 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-101 October 2016 

et al. (2002) and interpreted for fire and fuels management by Hann and Bunnell (2001). This information has been 

included in Final EIS Section 3.14.2.3 (Fire Regimes and Condition Classes in the 3 Bars Project Area).The five 

natural (historical) fire regimes are classified based on average number of years between fires (fire frequency) 

combined with the severity (amount of replacement) of the fire on the dominant overstory vegetation. These five 

regimes include: 

I – 0-35 year frequency and low (surface fires most common) to mixed severity (less than 75 percent of the dominant 

overstory vegetation replaced); 

II – 0-35 year frequency and high (stand replacement) severity (greater than 75 percent of the dominant overstory 

vegetation replaced); 

III – 35-100+ year frequency and mixed severity (less than 75 percent of the dominant overstory vegetation replaced); 

IV – 35-100+ year frequency and high (stand replacement) severity (greater than 75 percent of the dominant overstory 

vegetation replaced); and 

V – 200+ year frequency and high (stand replacement) severity.”

D.5.22.2 Wildland Fire and Fire Management – Assessment Methodology - Fire Intervals 

Comment No. 4-219 from Western Watersheds Project: 

What are the intervals and assumptions (based on what scientific information?) that [Draft EIS] Table 3-45 Fire 

regime condition Class relies? Is it the ever-changing, always out of date on-line blackbox of the agency Landfire 

site? How does this all take into account the typical dense rabbitbrush, cheatgrass, rabbitbrush and cheatgrass, and 

other conditions that result from many BLM fires/treatments – such as mowing, crushing, chopping, shredding? How 

does it take into account the fact that removal of protective shade, snowmelt retaining and moisture retaining 

vegetation that ends up making the fire season several weeks longer? 

Response to Comment No. 4-219:

A Fire Regime Condition Class (FRCC) is a classification of the amount of departure from the natural regime (Hann 

and Bunnell 2001). Coarse-scale FRCC classes have been defined and mapped by Hardy et al. (2001) and Schmidt et 

al. (2001). They include three condition classes for each fire regime. The classification is based on a relative measure 

describing the degree of departure from the historical natural fire regime. This departure results in changes to one (or 

more) of the following ecological components: vegetation characteristics (species composition, structural stages, 

stand age, canopy closure, and mosaic pattern); fuel composition; fire frequency, severity, and pattern; and other 

associated disturbances (e.g. insect and disease mortality, grazing, and drought). There are no wildland vegetation and 

fuel conditions or wildland fire situations that do not fit within one of the three classes. 

The three classes are based on low (FRCC 1), moderate (FRCC 2), and high (FRCC 3) departure from the central 

tendency of the natural (historical) regime (Hann and Bunnell 2001, Hardy et al. 2001, Schmidt et al. 2002). The 

central tendency is a composite estimate of vegetation characteristics (species composition, structural stages, stand 

age, canopy closure, and mosaic pattern); fuel composition; fire frequency, severity, and pattern; and other associated 

natural disturbances. Low departure is considered to be within the natural (historical) range of variability, while 

moderate and high departures are outside the natural historical) range of variability. 
WILDLAND FIRE AND FIRE MANAGEMENT

3 Bars Project Final EIS D-102 October 2016 

Comment No. 4-221 from Western Watersheds Project: 

What fire return intervals is BLM relying upon in making the claim that it is going to: Restore pinyon pine and 

juniper woodland density and coverage to the approximate values found under natural fire return intervals. 

Response to Comment No. 4-221:

See response to Comment 4-115 (Wildland Fire and Management – Affected Environment). 

Comment No. 4-230 from Western Watersheds Project: 

Figure 3-35 [in the Draft EI] is labeled Natural Fire Regimes. Is this based on the same fire intervals as the ENLC 

[Eastern Nevada Landscape Coalition] Ecosite [Ecological Site Condition] and any other assessments or analysis 

were based on? 

Response to Comment No. 4-230:

Figure 3-34 (Natural Fire Regimes) in the Final EIS is based on Landfire data. 

Comment No. 4-231 from Western Watersheds Project: 

EIS mapping makes no sense in relation to greasewood and other veg[etation] communities. When one compares 

[Draft EIS] Map Figure 3-26 (if we are interpreting the pastel colors correctly), then it appears that greasewood and 

playas are in Group V. 

Response to Comment No. 4-231:

Greasewood is accurately described as a Fire Regime Group V in Final EIS Figure 3-34 (Natural Fire Regimes). Fire 

Regime Group is described as a “200+ year frequency and high (stand replacement) severity” 

Comment No. 4-232 from Western Watersheds Project: 

Then, the next map is Fire Regime condition class – where it shows these areas as Group 1. An earlier map shows 

these areas as Moderate risk of “Catastrophic” [note BLM use of biased Fear-mongering terminology] fire. What is 

going on? Can BLM just dream up models and schemes until it hits upon one that shows what it wants to justify 

spending tens of millions of dollars? Are different schemes being applied with different fire and disturbance intervals, 

and different assumptions? And what are the recovery intervals, and how is recovery defined? What science is this 

based on? 

Response to Comment No. 4-232:

Fire risk is different than Fire Regime Condition Class. Fire risk involves several factors, including ignition sources, 

fuels topography, and weather, while Fire Regime Condition Class is a classification of the amount of departure from 

the natural regime. We have included additional text in Final EIS Section 3.14.2.3, Wildland Fire and Fire 

Management, Fire Regimes and Fire Condition Classes in the 3 Bars Project Area, based on guidance from Hann and 

Bunnell (2001). 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-103 October 2016 

Comment No. 4-233 from Western Watersheds Project: 

Please provide detailed analysis of the intervals, assumptions, scientific basis for all of these various schemes to 

portray native vegetation communities as unhealthy or having particular risks involved. 

Response to Comment No. 4-233:

Fire regime and fire regime condition class data in the figures is based on Landfire data, which can be found at URL: 

www.landfire.gov. Risk of catastrophic wildfire is based on the professional assessment of ignition sources, fuels 

topography, and weather. 

Comment No. 4-239 from Western Watersheds Project: 

This is what BLM has claimed elsewhere is needed to prevent fuel breaks – not tearing up the whole landscape. 

Despite all the EIS bulk, there is not strategic planning and analysis of wind direction, slope, and other factors to 

identify fire risk. 

Response to Comment No. 4-239:

The BLM would treat about 17 percent of the 3 Bars Project area under the Preferred Alternative. Treatments would 

be focused on areas with greatest need for restoration. However, the threat of wildfire and loss of habitat and other 

resources could occur throughout the 3 Bars Project area, including untreated areas. To reduce this risk to 3 Bars 

Project resources, and to protect treatment areas, the BLM would develop fire and fuel breaks to halt fire spread to the 

extent practicable. These include creating green strips and shaded fuel breaks, and using thinning and plantings near 

existing barriers/breaks to enhance their effectiveness. The effects of topography, vegetation, soil (as shown on Final 

EIS Figure 3-19, Fire Damage Susceptibility), weather, and other factors on fire risk on the 3 Bars Project area were 

evaluated in the Battle Mountain District Fire Management Plan (USDOI BLM 2004), and would be considered 

when identifying the locations for fire and fuel breaks and in treating vegetation to reduce the risk of wildfire.

D.5.22.3 Wildland Fire and Fire Management – Assessment Methodology - Fire 

Management Plan 

Comment No. 4-234 from Western Watersheds Project: 

BLM tries to rely on its greatly outdated 2004 BLM Fire Plan. BLM states: In the amendment, the BLM developed 

fire management categories, ranging from wildland fire not appropriate and full suppression with an aggressive 

initial attack is recommended (Category A), to wildland fire is appropriate and there are no constraints (Category 

D). Under the fire management plan, most of the 3 Bars Project area dominated by pinyon-juniper vegetation was 

categorized as Category C. Under Category C, wildland fire is appropriate, but there are constraints on its use. The 

world has changed dramatically since that old plan, based on even older and outdated assumptions about fire, 

cheatgrass, climate change, was develop. Did that plan ever undergo NEPA? If I recall correctly, it does not appear 

that the highly flawed Ely plan of that same vintage was ever subjected to NEPA. What scientific information was 

that plan based? On the unsupported Miller and Rose, Perryman or other claims that Basin big sage[brush] in valleys 

burned every 25 years or so, or that PJ burned every 35-50 years and then only in light little fires, and other long since 

disproven “range” friendly myths that Miller, Tausch and others had been promoting in that era?
WILDLAND FIRE AND FIRE MANAGEMENT

3 Bars Project Final EIS D-104 October 2016 

Response to Comment No. 4-234:

The reference to “In the amendment, the BLM developed fire management categories, ranging from wildland fire not 

appropriate and full suppression with an aggressive initial attack is recommended (Category A), to wildland fire is 

appropriate and there are no constraints (Category D). Under the Fire Management Plan, most of the 3 Bars Project 

area dominated by pinyon-juniper vegetation was categorized as Category C. Under Category C, “wildland fire is 

appropriate, but there are constraints on its use,” which is from the 2002 Fire Land Use Plan Amendment (FLUPA) to 

the Shoshone-Eureka RMP; an EA was completed to analyze this document. The Fire Management Plan (FMP) was 

updated in 2004 and was an update of the existing FMP into a new format, and included existing land management 

decisions from the Shoshone-Eureka and Tonopah RMPs, the FLUPA, and other policy documents concerning fire 

management (i.e., Wilderness Study Area policy). 

D.5.22.4 Wildland Fire and Fire Management – Environmental Consequences 

Comment No. 4-63 from Western Watersheds Project: 

... excessive buildup of hazardous fuels. What is the basis for saying fuels are “excessive”? Under the FRCC [Fire 

Regime Condition Class] Models (which are based on inaccurate historical and disturbance regimes completely 

unsupported by current science) pretty much anything other than bare dirt and an occasional grass plants are 

categorized as “excessive”. This is just like the Ecosite and ENLC [Eastern Nevada Landscape Coalition] models 

finding any older vegetation is fit only for treatment destruction. 

Response to Comment No. 4-63:

Determinations of fuel build up and FRCC are different items. Fuel loading is determined using several methods. 

Brown’s transects (Brown, J.K. 1974. Handbook for Inventorying Downed Woody Material. General Technical 

Report INT-16. Intermountain Forest and Range Experiment Station, Forest Service, U.S. Department of 

Agriculture, Ogden, Utah) and the Stereo Photo Series For Quantifying Natural Fuels in the Americas (R.D. Ottmar, 

R.E. Vihnanek, and C.S. Wright. 1998. USDA Forest Service, Fire and Environmental Research Applications 

Team, Seattle, Washington) are two of these methods and involve the professional judgment of trained and 

experienced fire management personnel. 

Comment No. 4-222 from Western Watersheds Project: 

In general, proposed treatments would have few adverse impacts on wildfire risk. This seems to be BLM claiming it 

won’t cause hot, dry, cheatgrass-choked sites. This ignores the vast body of science on cheatgrass adaptations to grow 

on hot, dry sites, flammability, and drastically altered fire cycles that doom native ecosystems. BLM only considers 

risks of treatment vehicles in transporting weeds – and not the fact that destruction of the woody vegetation opens up 

country to all manner of motorized travel. Plus, removes denser woody vegetation that, in combination with slope, 

topography, water limitations, may have previously acted to reduce livestock impacts in less accessible areas. It 

ignores the full battery of adverse impacts of grazing imposition on treatments. For example, even Robin Tausch 

found that grazing use 5 or 6 years after a treatment caused cheatgrass – in the Shoshone Underdown site. It ignores 

that the treatment results in a hotter, drier, windier, more uniform site. And that cheatgrass, heat, dryness, weather 

extremes, etc. are all expected to favor the ever-adapting exotics like cheatgrass and other bromes. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-105 October 2016 

Response to Comment No. 4-222:

The BLM acknowledges that cheatgrass has an influence on fire return intervals, fire behavior, and fire effects. As 

discussed in Final EIS Section C.2.1, Project Specific Standard Operating Procedures, General, the BLM is required 

to conduct pre-treatment surveys for cheatgrass, with treatments for cheatgrass occurring prior to any other treatment 

as necessary. Post-treatment monitoring for cheatgrass is also required by the BLM, and cheatgrass would be treated 

as necessary, for all proposed vegetative treatments. 

Comment No. 4-235 from Western Watersheds Project: 

By increasing canopy spacing among pinyon-juniper, the potential for a crown fire would be less, while residual trees 

would provide surface shading that lowers fuel temperatures (Tausch et al. 2009). Tausch turns out to have been 

wrong about PJ [pinyon-juniper] mining era deforestation, fire return intervals, and also selectively aged trees. This 

claim is disproven by the on-the-ground effects of recent fires across a variety of forest types that show that winddriven fires put out embers far from the fire front, and that thinning of the type described here does not work in those 

conditions. 

Response to Comment No. 4-235:

Crown fires and ember wash from a fire are different issues. Increasing canopy spacing reduces the possibility of a 

crown fire, but does not eliminate it, and creates a safer fire environment to deal with spotting, ember wash, and 

surface fires. Fuels treatments are designed to reduce the loss of natural resources to wildfire, not eliminate it. 

Comment No. 4-236 from Western Watersheds Project: 

BLM references 2008 Red Hills monitoring – but this was only a short time after the fire. How much cheatgrass is 

present now? We are also strongly opposed to BLM’s reliance on expensive and harmful chemical herbicides that are 

very prone to drift when applied in wildland settings. 

Response to Comment No. 4-236:

Red Hills is a separate project and is not within the scope of this action. Cheatgrass is present in the Red Hills project 

area, but its coverage is very spotty across the landscape both in where it occurs and how much occurs. No monitoring 

was done in 2013, but is scheduled for 2014 (Lewis 2014). 

No use of herbicides is proposed as part of the 3 Bars Project. 

D.5.22.5 Wildland Fire and Fire Management – Environmental Consequences - Pinyonjuniper 

Comment No. 4-210 from Western Watersheds Project: 

Increased pathogen infestations resulting in greater than 20 percent ongoing mortality within a given stand. Then

why not just let the stand alone to self-thin through natural mortality agents? Why is this a problem? These are natural 

ways that the forests world-wide self-thin. This also reduces “flammable fuels”. 
WILDLAND FIRE AND FIRE MANAGEMENT

3 Bars Project Final EIS D-106 October 2016 

Response to Comment No. 4-210:

The BLM intends to have a proactive treatment option to maintain healthy pinyon-juniper stands, from which 

multiple uses (i.e. fuel wood, fence posts, pine nuts, etc.) can be achieved. When trees die they become dead fuels, 

which are generally more flammable than live fuels. 

Comment No. 4-211 from Western Watersheds Project: 

Stand conditions in excess of 1,200 trees per acre in several watersheds. Is the forest undergoing self-thinning there, 

too? What are the age classes of the trees? If there is limited understory, even the miller models show you should not 

burn. 

Response to Comment No. 4-211:

See response to Comment 4-210 (Wildland Fire and Management – Environmental Consequences – Pinyon-juniper). 

Age classes of the trees within the project area vary from sapling to old growth. 

Comment No. 4-212 from Western Watersheds Project: 

Many of these indicators have been observed in Phase III (or late successional) pinyon-juniper woodlands, which 

generally have a high density of trees and buildup of fuels. How was high density determined, and how does this vary 

by slope, terrain, past mining era or treatment history, etc.? 

Response to Comment No. 4-212:

Table 1-2 (Restoration Goals and Objectives for Each Resource for the 3 Bars Ecosystem) of the 3 Bars Project Final 

EIS shows restoration goals and objectives for pinyon-juniper and other vegetation on the 3 Bars Project area. In 

general, high density pinyon-juniper occurs where stocking rates exceed 1,200 stems per acre. Higher densities are in 

Phase III pinyon-juniper areas, which tend to occur at higher elevations and on slopes. A number of factors can 

influence stocking density, including past stand use by historic mining, woodland harvest, and recreational uses, 

disease, and wildfire, and would vary by location on the 3 Bars Project area. 

Comment No. 4-213 from Western Watersheds Project: 

What is the basis for the claim that large fires are caused by a “build up” of shrubs? And again, where are trees reoccupying, undergoing natural successional processes? How many of the various Phase areas are persistent 

woodlands, and where are they located? How did BLM determine this? 

Response to Comment No. 4-213:

We are unaware that the Draft EIS made the claim that large fires are caused by the build up of shrubs, although dense 

shrubland could contribute to the spread of wildland fire. Based on guidance from the USDA Natural Resources 

Conservation Service Ecological Site Conditions, Romme et al. (2007), and Miller et al. (2008), and as discussed in 

Final EIS Section 3.12.2.2.9 (Native and Non-invasive Vegetation Resources, Affected Environment, Pinyon-juniper 

Woodland), Phase I areas are where pinyon-juniper are expanding into areas where they were not found historically, 

while Phase III areas are areas where pinyon-juniper are the dominant species (historically and currently). Phase II 

areas are transitional between the two other phases. Final EIS Figure 3-28 (Pinyon-juniper Phase Classes) shows 

where these phases are found on the 3 Bars Project area. These areas were identified based on Ecological Site 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Conditions, field studies, and aerial photography, as discussed in the 3 Bars Ecosystem and Landscape Restoration 

Project Pinyon-juniper Assessment (AECOM 2011a). Also see response to Comment 4-76 (Native and Non-invasive 

Vegetation Resources – Affected Environment - Pinyon-juniper).

D.5.23 Wildlife Resources 

D.5.23.1 Wildlife Resources – Affected Environment 

Comment No. 4-16 from Western Watersheds Project: 

Where are areas of remaining higher quality sage-grouse, pygmy rabbit, Brewer’s sparrow, loggerhead shrike and 

other habitats? Please map and identify these, and develop a solid plan to remove livestock disturbance from them, 

and conduct any treatment with minimal disturbance to soils, native vegetation, microbiotic crusts, etc. 

Response to Comment No. 4-16:

Higher quality habitat for greater sage-grouse is shown on Final EIS Figure 3-42 (Greater Sage-grouse Leks and 

Habitat). The BLM did not map higher quality habitat areas for the other sagebrush obligate species mentioned by the 

commenter, but in general these would include areas being of high importance to greater sage-grouse. Final EIS 

Figure 3-40 (Areas with Degraded Habitat Conditions), shows areas with degraded habitat for mule deer, pronghorn 

antelope, and greater sage-grouse that use sagebrush on the 3 Bars Project area. These areas would also have degraded 

habitat for sagebrush obligate and other wildlife species. 

The BLM identified three action alternatives in the 3 Bars Project EIS that differed in the types of treatments allowed 

and acres treated. Alternative A (All Treatment Methods Alternative), would cause the greatest short-term disturbance 

and long-term enhancement to the landscape, while Alternatives B (No Fire Use Alternative) and C (Minimal Land 

Disturbance Alternative) would have less adverse and beneficial effects on the landscape. Section 3.18.4, Livestock 

Grazing, Mitigation, of the Final EIS describes measures the BLM would take to manage livestock to ensure 

treatment success. Other livestock disturbances would be address through analysis separate from this EIS. 

Comment No. 4-20 from Western Watersheds Project: 

How has the 2013 collapse of the pine nut crop in Nevada impacted pinyon jay, Clark’s nutcrackers, and other species 

that rely on large-seeded pines? 

Response to Comment No. 4-20:

Pine nut production is highly variable from year to year, and is based on a variety of factors. A reduction in the supply 

of pine nuts could adversely affect the pinyon jay and other wildlife that use pine nuts if they are unable to find 

another suitable food source. 

Comment No. 4-22 from Western Watersheds Project: 

How has loss of whitebark pine impacted Clarks’ nutcracker across the species range?

3 Bars Project Final EIS D-107 October 2016 
WILDLIFE RESOURCES

Response to Comment No. 4-22:

No whitebark pine is found on the 3 Bars Project area. Thus, the EIS did not evaluate the relationship between 

whitebark pine occurrence on Clarks’ nutcracker populations.

Comment No. 4-250 from Western Watersheds Project: 

BLM omits many sensitive species from its paragraph descriptions in the EIS. 

Response to Comment No. 4-250:

Special Status Species that are known to or may occur on the 3 Bars Project area are listed in Table 3-45 of the Final 

EIS; this list is based on several sources, as given in the footnote to the table. All of these species are discussed in the 

paragraph descriptions in Final EIS Section 3.16.2.3.4, Wildlife Resources, Special Status Species.

D.5.23.2 Wildlife Resources – Assessment Methodology – Baseline Studies 

Comment No. 4-15 from Western Watersheds Project:

BLM has not conducted the necessary baseline surveys across the Three [3] Bars area to determine the status of local 

habitats and populations, the habitat quality and quantity, areas of seemingly suitable habitat that may be unoccupied, 

etc. 

Response to Comment No. 4-15:

The status and habitat use of wildlife found on the 3 Bars Project area are given in Final EIS Section 3.16.2, Wildlife 

Resources, Affected Environment; suitable habitat conditions are also provided for several species. Studies and other 

information used to prepare this section are cited in Section 3.16.2. For purposes of the 3 Bars Project EIS, the BLM 

considers that suitable habitat is potentially occupied by the community of species that typically occur in these 

habitats, in order to better address potential adverse and beneficial effects to these species from proposed 3 Bars 

Project treatments. 

Comment No. 4-136 from Western Watersheds Project: 

Why didn't BLM start by conducting necessary baseline biological surveys across the landscape - which are essential 

to understand where species like ferruginous hawk sage sparrow, sage thrasher, pygmy rabbit - all currently occupy 

the landscape, and use of seasonal habitats, or conditions across the HMAs [Herd Management Areas] and identify 

livestock conflicts or other problems. 

Response to Comment No. 4-136:

See response to Comments 4-15 (Wildlife Resources - Assessment Methodology – Baseline Studies) and 4-90 

(Assessment Methodology - General) for sources of information used to describe biological conditions on the 3 Bars 

Project area, including wildlife populations and habitat use. 3 Bars Project Final EIS Section 3.17.2, Wild Horses, 

Affected Environment, discusses the characteristics of wild horse populations, habitat use, and herd management 

areas. The effects of livestock management on wildlife and wild horses are discussed in the Cumulative Effects 

sections under Environmental Consequences for these two resources. 

3 Bars Project Final EIS D-108 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

Comment No. 4-195 from Western Watersheds Project: 

This is the severely flawed baseline for sensitive species – not where the species live on the land, or determining 

where they can no longer lives due to degradation, or how important the lands AECOM/ENLC [Eastern Nevada 

Landscape Coalition] range studies claim need to be unhealthy may actually be for these species. 

Response to Comment No. 4-195:

See response to Comments 4-15 (Wildlife Resources - Assessment Methodology – Baseline Studies) and 4-90 

(Assessment Methodology - General), and Final EIS Section 3.17.2, Wildlife Resources, Affected Environment, for 

sources of information used and studies conducted to describe biological conditions on the 3 Bars Project area, 

including special status species wildlife populations and habitat use. The effects of current habitat conditions, and 

habitat conditions that could result short- and long-term from proposed treatments, on special status species and other 

wildlife are discussed in Final EIS Sections 3.16. 3, Wildlife Resources, Environmental Consequences. The rangeland 

health assessment conducted by Eastern Nevada Landscape Coalition and summarized in the Landscape Restoration 

Project Rangeland Health Report (Eastern Nevada Landscape Coalition and ACEOM 2012) determined rangeland 

health condition based on vegetation. The study was not designed to identify the cause(s) of resource problems, or 

suggests treatments to restore degraded resources, but to identify areas that are degraded or are at risk of degradation. 

The information derived from the report will be used by the BLM to determine rangeland health and to facilitate 

corrective actions to improve rangeland health. 

D.5.23.3 Wildlife Resources – Environmental Consequences 

Comment No. 4-14 from Western Watersheds Project: 

How will the treatments affect the sustainability of the pinyon jay population, including drought years like 2013, 

when birds had to travel over large areas to find food? 

Response to Comment No. 4-14:

A discussion of the potential adverse and beneficial effects of 3 Bars Project treatments on wildlife species, including 

pinyon jays, that use pinyon-juniper for all or a portion of their life needs is provided in Final EIS Section 3.16.3, 

Wildlife Resources, Environmental Consequences, for Pinyon-juniper Treatments. As noted for the purposes of the 

project in Final EIS Section 1.5 (Purposes of the Project), proposed BLM treatments include efforts to manage 

pinyon-juniper woodlands to promote healthy, diverse stands within persistent woodlands and to manage pinyonjuniper and other woodlands stands to benefit wildlife. 

Comment No. 4-43 from Western Watersheds Project: 

BLM claims a mosaic will be good. A mosaic represents habitat fragmentation of a vegetation community. Imposing 

an artificial mosaic in a complex wild landscape result in extensive edges and disturbed areas that promote invasive 

species, livestock concentration in disturbed open “treated” sites, favor mesopredators that rely on disturbed habitats, 

causes a loss of security and hiding cover, and represents overall habitat loss and fragmentation. In fact, a “mosaic” 

represents fragmentation – for sage-grouse, Brewer’s sparrow, sage thrasher, sage sparrow, loggerhead shrike, pygmy 

rabbit and other important, rare and sensitive sagebrush species. This is especially the case because the habitats are 

already often frequently broken up and disrupted by roads, past treatments, cattle salting sites, cattle fences, water 

troughs, mine exploration damage, etc. 

3 Bars Project Final EIS D-109 October 2016 
WILDLIFE RESOURCES

Response to Comment No. 4-43:

See response to Comment 4-45 (Native and Non-invasive Vegetation Resources - Environmental Consequences). 

Comment No. 4-44 from Western Watersheds Project: 

BLM ignores the basic biology of species needs – for example, Steve Knick’s work in the Snake River Birds of Prey 

Area found that sage sparrows are area-dependent and require large continuous blocks of sagebrush for nesting. 

Pygmy rabbits require dense sagebrush – which agencies always try to destroy in treatments – because of the longstanding range biases against any denser woody vegetation. This is precisely the habitat the “mosaic” treatment 

destruction will seriously alter. We have observed Ely BLM’s vegetation mosaics from mowing, beating, crushing, 

and herbiciding. They selectively target the taller more structurally complex dense sage[brush] – i.e. – the exact kind 

of sites where pygmy rabbits live, or sage-grouse may nest – and selectively destroy those areas in a claimed 

“mosaic”. 

Response to Comment No. 4-44:

See response to Comment 4-45 (Native and Non-invasive Vegetation Resources - Environmental Consequences). 

Comment No. 4-120 from Western Watersheds Project: 

Material generated – will be left on site in piles for wildlife. Why in the world won't BLM just let the woody material 

naturally de-compose on-site, and not drag it into a pile –further tearing up the landscape with skidders and heavy 

equipment ? A wide variety of native wildlife require complex woody structure and understory composition as 

essential habitat components. The piles are likely to encourage mesopredators like skunks. 

Response to Comment No. 4-120:

Final EIS Section 2.5.3.8, Alternatives, Activity Fuels Disposal, discusses the various methods that could be used to 

dispose of activity fuels generated by treatments. These include leaving activity fuels on site, chipping activity fuels, 

and placing coarse and large wood in streams, which would benefit fish and wildlife habitat and soil resources. 

However, some activity fuels may be selectively piled, and some piles may be burned. Material would be placed into 

piles, and in some cases burned, to reduce the risk of woody material serving as fuel for a wildfire. 

Comment No. 4-143 from Western Watersheds Project: 

Here we are told that this project is to “restore” grouse habitats, and BLM allows 35% of the shrub growth to be 

eaten. This will also greatly impair any young sage[brush] recovery post-treatment. 

Response to Comment No. 4-143:

As discussed in Final EIS Appendix C, Standard Operating Procedures, Section C.3.2.5, Greater Sage-grouse, to 

ensure that treatments benefit greater sage-grouse, sagebrush restoration treatments would adhere to the most recent 

guidance available at the time of treatment implementation, currently the Western Association of Fish and Wildlife 

Agencies and the Wyoming Game and Fish Department greater sage-grouse guidelines, and the BLM Nevada State 

Office and Washington Office Instructional Memoranda when restoring sagebrush habitats. 

3 Bars Project Final EIS D-110 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-111 October 2016 

As discussed in Final EIS Section 3.3.2, Cumulative Effects, for Grazing and Grazing Management, Range 

Improvement, and Allotment Management, the BLM would manage livestock to meet greater sage-grouse foraging 

and nesting habitat objectives identified in the Nevada and Northeastern California Sub-regional Greater Sagegrouse Resource Management Plan Amendment/EIS (USDOI BLM 2013). This report provides the latest guidance on 

habitat objectives for sage-grouse. These objectives include having a sagebrush cover of greater than 20 percent, and 

total shrub cover of greater than 40 percent for nesting cover; ensuring that at least five plant species used by greater 

sage-grouse broods are present in brood-rearing areas; ensuring that sagebrush canopy cover equals or exceeds 10 

percent, and sagebrush height equals or exceeds 25 centimeters in the winter use area; and ensuring that allowable use 

levels for livestock for herbaceous species are less than or equal to 45 percent in mountain big sagebrush, and 35 

percent in Wyoming big and black sagebrush stands, and less than or equal to 35 percent for all sagebrush types for 

utilization of shrub species. 

Comment No. 4-164 from Western Watersheds Project: 

BLM ignores the adverse impacts of noise on wildlife, and this battery of aggressive bulldozer, dump truck, chaining, 

helicopter and off-highway vehicle prescribed fire activity may cause significant initial displacement of wildlife, and 

this of course will be followed by long-term displacement. 

Response to Comment No. 4-164:

The effects of noise on wildlife are discussed in Final EIS Section 3.16.3.3.1, Wildlife Resources, Environmental 

Consequences, Direct and Indirect Effects Common to All Action Alternatives. 

Comment No. 4-175 from Western Watersheds Project: 

If BLM applies a 40% upland utilization level on the herbaceous vegetation and Key larger sized grass species that 

means that many other grass plants get grazed to much higher levels. 40% upland utilization fails to provide necessary 

residual nesting cover for sage-grouse, and also must be viewed in terms of how little watershed cover it provides, and 

how little vegetation is present to capture snow, shade the ground and slow evaporation following rainfall events, and 

block the wind 

Response to Comment No. 4-175:

See response to Comment 4-143 (Wildlife Resources – Environmental Consequences). 

D.5.23.4 Wildlife Resources – Standard Operating Procedures 

Comment No. 4-251 from Western Watersheds Project: 

BLM violates the National Technical Team Report and its own Instruction Memos for sage-grouse. It violates the 

Conservation Plan for sage-grouse, and may thwart the outcome of the Greater sage-Grouse Regional EIS process by 

prematurely destroying vegetation in aggressive treatments that would be limited under that EIS. 
WILDLIFE RESOURCES

3 Bars Project Final EIS D-112 October 2016 

Response to Comment No. 4-251:

The BLM reviewed the documents identified by the commenter to ensure that 3 Bars Project treatments would not 

violate guidance for the protection and enhancement of sage-grouse and their habitat. As shown on Final EIS Table 1-

2, Restoration Goals and Objectives for Each Resource for the 3 Bars Ecosystem, and in Section 3.16, Wildlife 

Resources, ensuring against the decline or loss of greater sage-grouse populations, and enhancing and restoring 

greater sage-grouse habitat, are key goals of the 3 Bars Project. Activities such as wind, solar, and mineral 

development, which would not be allowed under the Preferred Alternative of the Nevada and Northeastern California 

Greater Sage-grouse Draft Land Use Plan Amendment and EIS (USDOI BLM 2013), are not part of the 3 Bars 

Project, but their effects on greater sage-grouse from past, present, and reasonably foreseeable future development, 

are discussed in Final EIS Section 3.16.3.4, Wildlife Resources, Environmental Consequences, Cumulative Effects. 

Should these development activities be proposed on the 3 Bars Project area in the future, their effects on greater sagegrouse would be evaluated under a separate NEPA analysis. Under the Preferred Alternative, the BLM would restore 

approximately 31,300 acres of existing sagebrush habitat, and habitat that historically was dominated by sagebrush 

but now consists of noxious weeds and other invasive non-native vegetation, pinyon-juniper, or other vegetation. 

There would be some short-term disturbance, primarily in areas where the BLM would plant and seed to promote the 

growth of forms and grasses. Long-term, treatments should enhance sagebrush habitat and increase the amount of 

acreage dominated by sagebrush. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-113 October 2016 

D.6 References 

The following references were used by the BLM to prepare their responses to public comments. 

AECOM. 2010. Scoping Comment Summary Report for the 3 Bars Ecosystem and Landscape Restoration Project 

EIS. Report Prepared for the USDOI BLM, Battle Mountain District, Mount Lewis Field Office, Battle 

Mountain, Nevada. Seattle, Washington. 

AECOM. 2011a. 3 Bars Ecosystem and Landscape Restoration Project Pinyon-Juniper Assessment. Report Prepared 

for the USDOI BLM, Battle Mountain District, Mount Lewis Field Office, Battle Mountain, Nevada. Seattle, 

Washington. 

AECOM. 2011b. 3 Bars Ecosystem and Landscape Restoration Project Cheatgrass Assessment. Report Prepared for 

the USDOI BLM, Battle Mountain District, Mount Lewis Field Office, Battle Mountain, Nevada. Seattle, 

Washington. 

Agee, J. 1993. Fire Ecology of Pacific Northwest Forests. Island Press. Washington, D.C. 

American Chemistry Council. 2005. Forest Fires: A Major Source of Dioxins. Washington, D.C. Available at URL: 

http://www.dioxinfacts.org/sources_trends/forest_fires2.html. 

Association for Fire Ecology, International Association of Wildland Fire, Tall Timbers Research Station, and The 

Nature Conservancy. 2013. The Merits of Prescribed Fire Outweigh Potential Carbon Emission Effects. 

Eugene, Oregon. 

Beschta, R.L., D.L. Donahue, D.A. DellaSala, J.J. Rhodes, J.R. Karr, M.H. O’Brien, T.L. Fleischner, C.D. 

Williams. 2013. Adapting to Climate Change on Western Public Lands: Addressing the Ecological Effects 

of Domestic, Wild, and Feral Ungulates. Environmental Management 51:471-492. Available at URL: 

http://fes.forestry.oregonstate.edu/sites/fes.forestry.oregonstate.edu/files/PDFs/Beschta/Beschta_2012Env

Man.pdf. 

Brown, J.K. 1974. Handbook for Inventorying Downed Woody Material. General Technical Report INT-16. 

Intermountain Forest and Range Experiment Station, Forest Service, U.S. Department of Agriculture, Ogden, 

Utah. 

Brown, J.K 1995. Fire Regimes and Their Relevance to Ecosystem Management. In Proceedings of the Society of 

American Foresters National Convention 171-178.

Bukowski, B.E., and W.L. Baker. 2013. Historical Fire Regimes, Reconstructed from Land-survey Data, Led to 

Complexity and Fluctuation in Sagebrush Landscapes. Ecological Applications 23:546-564. 

Cooperative Extension Service, USDA Forest Service, Natural Resource Conservation Service Technology Institute, 

and USDOI BLM. 1999. Utilization Studies and Residual Measurements. Bureau of Land Management 

National Applied Resource Sciences Center, Denver, Colorado. 

Eastern Nevada Landscape Coalition and AECOM. 2012. Landscape Restoration Project Rangeland Health Report. 

Report Prepared for the USDOI BLM, Battle Mountain District Mount Lewis Field Office, Battle Mountain, 

Nevada. Ely, Nevada, and Seattle, Washington. 
REFERENCES

Elliott, J. 2013. Co-operating Agency Review of 3 Bars Ecosystem and Landscape Restoration Project 

Environmental Preliminary Draft EIS. NDOW. Elko, Nevada. 

Gottfried, G.J., and S. Overby. 2011. Assessing Mechanical Mastication and Thinning-piling-burning Treatments on 

the Pinyon-juniper Woodlands of Southwestern Colorado. Joint Fire Science Program 145:1-4. Available at 

URL: http://www.firescience.gov/projects/briefs/05-2-1-98_FSBrief145.pdf. 

Gullett, B.K., and A. Touati, A. 2003. PCDD/F Emissions from Forest Fire Simulations, Atmospheric Environment 

37:803-813. Available at URL: http://cfpub.epa.gov/ncea/CFM/recordisplay.cfm?deid=55505#Download. 

Habich, E.F. 2001. Ecological Site Inventory, Inventorying and Monitoring Technical Reference 1734-7. 

BLM/ST/ST-01/003+1743. USDOI BLM, Denver, Colorado. Available at URL: 

www.blm.gov/nstc/library/pdf/1734-7.pdf. 

Hardy C.C., K.M. Schmidt, J.P Menakis, and R.N. Sampson. 2001. Spatial Data for National Fire Planning and Fuel 

Management. International Journal of Wildland Fire 10:353–372.

Hann, W.J., and D.L. Bunnell. 2001. Fire and Land Management Planning and Implementation across Multiple 

Scales. International Journal of Wildland Fire 10:389-403. Available at URL: 

http://www.firelab.org/ScienceApps_Files/downloads/coarsescale/h_b.pdf. 

JBR Environmental Consultants, Inc. (JBR). 2009. Roberts Mountains Surface Water Hydrology Evaluation, Spring 

2009. Prepared for Eureka Moly, LLC, Elko, Nevada. JBR Project Number B.A07004.00, JBR Report 

Number 873 Final. Elko, Nevada. 

Jones, A., J. Catlin, and E. Vasquez. 2012. Mechanical Treatment of Pinyon-juniper and Sagebrush Systems in the 

Intermountain West A Review of the Literature – Draft. Wild Utah Project, Salt Lake City, Utah. Available 

atURL: wildutahproject.org/files/images/MechTrt_LitReview_Draft.doc . 

Lewis, C. 2014. Fuels Program Manager Desert Basin Zone, USDOI BLM, Battle Mountain District, Battle 

Mountain, Nevada. Electronic Mail Communication with S. Paulus, AECOM, Seattle, Washington, 

Regarding Cheatgrass in Red Hills, May 20, 2014. 

Miller, R.F., R.J. Tausch, E.D. McArthur, D.D. Johnson, and S.C. Sanderson. 2008. Age Structure and Expansion of 

Piñon-juniper Woodlands: A Regional Perspective in the Intermountain West. Research Paper Report 

RMRS-RP-69. USDA Forest Service Rocky Mountain Research Station, Fort Collins, Colorado. Available at 

URL: http://oregonstate.edu/dept/EOARC/pinon-juniper/material/Milleretal2008.pdf. 

Montgomery and Associates. 2010. Hydrogeology and Numerical Flow Modeling, Volume 1, Text and Tables, 

Mount Hope Project, Eureka County, Nevada, with Appendices. July 2010. Prepared for Eureka Moly, Elko, 

Nevada. Prepared by Montgomery and Associates, Interflow Hydrology, Inc. and Barranca Group LLC. 

Tucson, Arizona. 

Ottmar, R.D., R.E. Vihnanek, and C.S. Wright. 1998. Stereo Photo Series For Quantifying Natural Fuels in the 

Americas. USDA Forest Service, Fire and Environmental Research Applications Team, Seattle, Washington. 

3 Bars Project Final EIS D-114 October 2016 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-115 October 2016 

Pierson, F.B., C.J. Williams, S.P. Hardegre, P.E. Clark, P.R. Kormos, and O.Z. Al-Hamdan. 2013. Hydrologic and 

Erosion Responses of Sagebrush Steppe Following Juniper Encroachment, Wildfire, and Tree Cutting. 

Society for Range Management 66:274-289. Available at URL: 

http://www.bioone.org/doi/full/10.2111/REM-D-12-00104.1. 

Romme, W., C. Allen, J. Bailey, W. Baker, B. Bestelmeyer, P. Brown, K. Eisenhart, L. Floyd-Hanna, D. Huffman, B. 

Jacobs, R. Miller, E. Muldavin, T. Swetnam, R. Tausch, and P. Weisberg. 2007. Historical and Modern 

Disturbance Regimes for Pinyon-Juniper Vegetation in the Western U.S. Colorado Forest Restoration 

Institute and The Nature Conservancy, Fort Collins, Colorado. Available at URL: 

http://www.fs.fed.us/rm/pubs_other/rmrs_2009_romme_w001.pdf. 

Schmidt, K.M., J.P. Menakis, C.C. Hardy, W.J. Hann, and D.L. Bunnell. 2002. Development of Coarse-scale Spatial 

Data for Wildland Fire and Fuel Management. U.S. Department of Agriculture, Forest Service, Rocky 

Mountain Research Station General Technical Report RMRS-GTR-87. Fort Collins, Colorado. Available at 

URL: http://www.firelab.org/ScienceApps_Files/downloads/coarsescale/fuelman.pdf. 

Tausch, R.J., R.F. Miller, B.A. Roundy, and J.C. Chambers. 2009. Pinon and Juniper Field Guide: Asking the Right 

Questions to Select Appropriate Management Actions. USGS Circular 1335. Reston, Virginia. 

USDA Forest Service and USDOI BLM. 2004. Amending Resource Management Plans for Seven Bureau of Land 

Management Districts and Land and Resource Management Plans for Nineteen National Forests Within the 

Range of the Northern Spotted Owl. Decision to Clarify Provisions Relating to the Aquatic Conservation 

Strategy. Portland, Oregon. Available at URL: http://www.reo.gov/documents/acs/FinalROD03_17_04.pdf. 

USDA Natural Resources Conservation Service. 2003. National Range and Pasture Handbook. Grazing Lands 

Technology Institute. Chapter 6. Washington, D.C. Available at URL: 

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/national/landuse/rangepasture/?cid=stelprdb1043084),

USDA Natural Resources Conservation Service. 2012. Soil Survey Geographic (SSURGO) Database for Eureka 

County, Nevada. Available at URL: http://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm. 

USDOI BLM. 1987. Shoshone-Eureka Resource Management Plan Amendment Record of Decision. Battle Mountain 

District, Battle Mountain, Nevada. 

USDOI BLM. 1991. Record of Decision for Final Environmental Impact Statement Vegetation Treatment on BLM 

Lands in Thirteen Western States. BLM Wyoming State Office. Casper, Wyoming. 

USDOI BLM. 1998. Riparian Area Management, A User Guide to Assessing Proper Functioning Condition and 

Support Science for Lotic Areas. Technical Report 1737-15. USDOI BLM in Cooperation with the USDA 

Forest Service and Natural Resources Conservation Service. USDOI BLM National Business Center, 

Denver, Colorado. Available at URL: http://www.blm.gov/or/programs/nrst/files/Final%20TR%201737-

15.pdf. 

USDOI BLM. 2001. Handbook H-4180-1. Rangeland Health Standards. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handboo

k.Par.61484.File.dat/h4180-1.pdf. 
REFERENCES

3 Bars Project Final EIS D-116 October 2016 

USDOI BLM. 2004. Battle Mountain District Fire Management Plan. Battle Mountain District, Battle Mountain, 

Nevada. 

USDOI BLM. 2007a. Record of Decision Final Vegetation Treatments on Bureau of Land Management Lands in 17 

Western States Programmatic Environmental Impact Statement. Reno, Nevada. Available at URL: 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

USDOI BLM. 2007B. Final Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Report. Reno, Nevada. Available at URL: 

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

USDOI BLM. 2008. National Environmental Policy Act Handbook H-1790-1. National Environmental Policy Act 

Program. Washington, D.C. Available at URL: 

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Information_Resources_Management/policy/blm_handboo

k.Par.24487.File.dat/h1790-1.pdf. 

USDOI BLM. 2009a. Draft Assessment of Existing and Current Conditions for the Proposed 3 Bars Ecosystem and 

Landscape Restoration Project Environmental Impact Statement, Battle Mountain District, Mount Lewis 

Field Office, Battle Mountain, Nevada. 

USDOI BLM. 2009b. Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field Office 

and Tonopah Field Office. Battle Mountain District, Battle Mountain, Nevada. 

USDOI BLM. 2013. Nevada and Northeastern California Sub-regional Greater Sage-grouse Resource Management 

Plan Amendment/EIS. Reno, Nevada. Available at URL: https://www.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage¤tPageId=31103. 

USDOI BLM. 2014. Biological Assessment for the 3 Bars Ecosystem and Landscape Restoration Project. Battle 

Mountain District, Battle Mountain, Nevada. 

USEPA. 2013. Update to An Inventory of Sources and Environmental Releases of Dioxin-Like Compounds in the 

United States for the Years 1987, 1995, and 2000. External Review Draft. National Center for Environmental 

Assessment, Office of Research and Development. Washington, D.C. Available at URL: 

http://cfpub.epa.gov/ncea/CFM/recordisplay.cfm?deid=235432#Download. 

University of Nevada Cooperative Extension. 2010. Nevada Noxious Weed Field Guide. Reno. Available at URL: 

http://www.unce.unr.edu/publications/files/nr/2010/sp1001.pdf. 

Wiedinmyer, C., and M.D. Hurteau. 2010. Prescribed fire as a Means of Reducing Forest Carbon Emissions in the 

Western United States. Environmental Science and Technology, 44:1926-1932. 

World Health Organization. 2014. Dioxins and their Effects on Human Health. Geneva, Switzerland. Available at 

URL: http://www.who.int/mediacentre/factsheets/fs225/en/. 
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-117 October 2016 

D.7 List of Agencies, Non-government Organizations, and Individual Providing Comments 

D.7.1 List of Agencies Providing Comments 

Eureka County Board of Commissioners (Document 11) 

Nevada Department of Wildlife (Document 3) 

U.S. Department of the Interior National Park Service (Document 2) 

U.S. Environmental Protection Agency (Document 1) 

D.7.2 List of Non-government Organizations Providing Comments 

Western Watersheds Project (Document 4) 

American Wild Horse Preservation Campaign (Document 5) 

D.7.3 List of Individuals Providing Comments 

(Note: Individuals providing unique comment letters with substantive comments that are included in Section D.7 have 

a comment number next to their last name. Responses to their comments are provided in Section D.5. The remainder 

of individuals responded to a mass emailing request and their emails were similar to those shown for Document 6 in 

Section D.8. Individuals that did not include the full spelling of their last name are not included in the list below.)

Valerie

Anja

Bruce

Darlene

Holly

Aliaa

Olga

Michelle

Jane 

Al 

Sally

Felipe

Shelley

Leticia

Jan

Julie

Janine

Jackie

Aaland-Madrid

Abbott

Abbott

Abbott

Abbott

Abdel-Gawad

Abella

Abouchabki

Abraham

Abrams

Abrams

Abrigo

Abuble

Acevedo

Ackerman

Acs-Ray

Adair

Adam

Charles

David

Carol

Carolyn

Kaatje

Kim 

Phillip

Rebecca

Richard

Ruth

Debra

Toni 

Patti

Wendy

Diana

Kaitlin

Nancy

Diego

Gayle

Alice

Adam 

Adam 

Adams

Adams

Adams

Adams

Adams

Adams

Adams

Adams

Adimey

Adisano

Adkins

Adler

Afshari

Agee

Agrusa

Aguirre

A'Harrah

Ahern

Eugenia

Heidi

Shanida

May

Michael

Michael

Lloma

Lori

Patricia

Shan

Tracy

Allison

Freda

Michael

Judy

Margaret

Mark

Natalie

Steve

Maureen

Ahern

Ahlstrand

Ahmad

Ahmed

Aijlman

Akstull

Alameda

Alaniva

Albers

Albert

Albert

Alberts

Albrecht

Albrecht

Albury

Alderfer

Alexander

Alexander

Alfieri

Alfonso
LIST OF COMMENTERS

3 Bars Project Final EIS D-118 October 2016 

Tiffany

Paul

Aileen 

Amanda

Frances

J.

Kimberly

Laura

Rachael

Susan 

Vanessa

Peter

Donna

Carol

Nancy

Joao

S.P.

Jan-Paul

Jeff

Mary

Kathy 

China

Jim 

Choky

Geraldo

Gloriamarie

Gaetano

Joseph

Julie

Jan

Greg

Maeve

Harry

Alessandro

Bonnie

Isabella

Philip 

Julie

Alyson

Beret

Annette

Jennifer

Kristin

Alfrey

Ali

Allen

Allen

Allen

Allen

Allen

Allen

Allen

Allen

Allen

Allenbacher

Alleyne-Chin

Allie

Allis

Almeida

Almskaar

Alon

Altaffer

Altamirano

Alter

Altman

Altree

Alvarez

Alves

Amalfitano

Amato

Amato

Amato

Amba

Ambrose

Ambrose

Ameen

Amicone

Amino

Amoroso

Amos

Amsler

Amsterdam

Amundson

Ancel-Wisner

Andersen

Andersen

Patricia

Allison

Barbara

Carolyn

Christeen

Christina

Connie

Dave

Diana

Donna

Dorothy

Douglas

Edna

George

Jennifer

Kristina

Lynnette

Meldean

Michelle

Pat

Patricia

Rick

Tina

Toni

Virginia

Saliane

Gunvor

Patricia

Jeaneen

Elizabeth

Anneke

Lory

Aimee

Beth

J.

Joseph

Marjorie

Sally

Billy

Lisa

Laura

Anne 

Lea 

Andersen

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderson

Anderssen

Andersson

Anderton

Andretta

Andrews

Andries

Anello

Ang

Angel

Angell

Angelo

Angelo

Angelo

Angus

Annecone

Annunziata

Anthony

Anthony

Joanne

Georgia

Tuesday

Laura

Maryanne

Virginia

Stephanie

Karen

Arlene

Debra

Nancie

Douglas

Sandra

Isabel

Michele

Tracy 

Cristina

Juanita

Elaine

Danielle

Francesca

Terri 

Tadd

Salme

Tami

John

Marshia

Vicki

Diane

Linda

Ben

Charles

Kathleen 

Sarah

Mikki

Barbara

Ardith

Elizabeth 

Eric

Charlisa

David

Madeleine

Rich 

Anton

Antonopoulos

Antonowicz

Apley

Appel

Apple

Appleton

Aquila

Aquino

Arab

Araki

Arana

Arapoudis

Araujo

Archbold

Arcure

Ardavin

Arellanes

Arellano

Arfin

Argiro

Armao

Armbruster

Armijo

Armitage

Armstrong

Armstrong

Armstrong

Arnal

Arndt

Arnold

Arnold

Arnold

Arnsdorff

Aronoff

Aronowitz

Arrington

Arrowood

Arroyo

Arthur

Arthur

Ascott

Ash
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-119 October 2016 

Connie

Kait

Jackie

William

Karen

Curt

Carrie

Andrea

C.

Alisha

Nancy

Peggy

Kay

Nickole

Patty

Andrew

Shauna

Rossi

Marilyn

Sylvie

Joyce

Susan

Joann

Christine

Sandy

Teresa

Thomas

Ron

Yarel

Annette

Ben

Barbara

Kris

Gabriele

Jonathan

Sharon

Susan

Gloria

Karen

Rachel

Christina

Anna

Elaine

Ashbaugh

Ashenfelter

Ashley

Ashworth

Askelson

Asman

Asmar-O'Guin

Atef

Atkins

Atkinson

Atkinson

Atwood

Aubrey-Chimene

Aubuchon

Auch

Aucoin

Auditor

Audrey

Auer

Auger

August

Ault

Aurand

Austin

Austin

Avant

Avery

Avila

Avitia

Ayling

Ayotte

Azari

Azzarello

Baader

Babb

Babbitt

Babbitt

Babcock

Babcock

Babitz

Babst

Bach

Backal

Pam

Evelyn

Barbara

Clea

Mariamelia

Theresa

Jill

Diana

Janet

Angie

Carol

Mary

Helen

Karen

Marcia

Melissa

Sharon

Matthew

Pamela

Melissa

Katherine

Ceceile

Diana

Jean

Jenna

Leslie

Natalie

Nelson

Susan

Tina

Theresa

Marilyn 

Mary

Patricia

Evelyn

Eleonor

Brigitte

Karen

Lidia

Margo

Lisa

Charlene

Martha

Bacon

Badeau

Bader

Badion

Badoza

Badus

Badyrka

Baerveldt

Bagby

Bahris

Baier

Baier

Bailey

Bailey

Bailey

Bailey

Bailey

Bailis

Baillio

Baines

Bair

Baker

Baker

Baker

Baker

Baker

Baker

Baker

Baker

Baker

Bakko

Balduff

Baldwin

Baley

Ball

Ballot

Ballouard

Balmer

Baltazar

Bangert

Banik

Bantula

Banuelos

Sandra

Stacy

Melissa

Mary 

Viola

Bonnie

Lynn 

Penny

Robin

Caroline

Stephanie

Ann

Carolyn

Elaine

Nani

Robyn

Sheryl

Melinda

Ines

Laura

Bevin

Constance

Keiko

Marlene

Simon

Steven

Susan

Amy

Marina

Karen

Don

Lisa

Eileen

Judy

Angela

Jane

Sarah

Purnima

Melinda

Anna

Bobbi

Jessica

Suzanne

Baran

Barbagallo

Barbella

Barczak

Bare

Barfield

Barker

Barker

Barker

Barkley

Barlow

Barnes

Barnes

Barnes

Barnes

Barnes

Barnes

Barnett

Barreiros

Barrera

Barrett

Barrett

Barrett

Barrett

Barrett

Barrett

Barrow

Barry

Barry

Bartell

Barth

Barth

Bartholomew

Bartholomew

Barton

Barton

Barton-King

Barve

Bashen

Bashkirova

Baskerville

Baskett

Baskett
LIST OF COMMENTERS

3 Bars Project Final EIS D-120 October 2016 

Cindy

Andrea 

Martyn

Bonnie

Cindy

Judith

Kristina

Bruce

Marlene

Alisa

Deby

Candace

Margaret

Becky

Deborah

Karen

Kim 

Melissa

Thomas

Lee

Lou

Regina

Karen

Paula

Heidi

Kathy

Dove

Mindy

Helen

Jane 

Mary Kay

Debbie

Jo Ann

Katness

Cobina

Jessica

Ed 

Christine

Chris

Elisabeth

Brenda

Barbara

Carla

Bassar

Bassett

Bassett

Bassey

Bassham

Basye

Batcanova

Batchelor

Bateman

Battaglia

Battaglia

Batten

Batterman

Bauer

Bauer

Bauer

Bauer

Bauer

Bauer

Baum

Baxter

Baxter

Bayour

Bdiwi

Bean

Bean

Bear

Beardsley

Beasley

Beattie

Beattie

Beatty

Beatty

Beatty

Beaudette-Wellman

Beaudry

Beaulieu

Beaumont

Beaver

Bechmann

Bechtol

Beck

Beck

Claudine

Colleen

Elzbieta

Jeff

Lynee

Susan

Barbara

Carol

Klaus

Oksana

Anna

Marion

Joanne

Toni

Paulette

Daniel 

Elizabeth

D.

Denise

Jodi

Lynette

Sylvie

Nancy

Anna

Jorge

Alice

Connie

Ludmila

R.

Pamela

Lis 

Sherry

Teresa

Catherine

Nadine

Jessica

Julianna 

Michelle

Lynn 

Ilene

Sharon

Brenda

Jonathan

Beck

Beck

Beck

Beck

Beck

Beck

Becker

Becker

Becker

Becker

Bedirian

Beens

Beeson

Beetham

Begon

Belachew

Belasco

Bell

Bell

Bell

Bell 

Bellemare

Bellers

Bellin

Belloso-Curiel

Bellotti

Bellows

Belousova

Belsher

Benavides

Bender

Bender

Bender

Bendig

Benedetti

Benefield

Benefield

Benes

Bengston

Beninson

Benkovic

Bennett

Bennett

Keri

Tamera

Virginia

Shirley

Kathy

Mona 

Robyn

Corie

Pamela

Ramona

Patricia

Danielle

Herve

Hayley

Myra

T.J.

Marie-Ange

James

Patricia

Sheryl

Arthur

Christine

Keith

Susan

Brad

Thomas

Debi

Brittney

Carol

James

Suzy

Marie 

G. 

Janice

Martin

William

Brother

Toni

Dana

Kathy

Sarah

Silvia

Kathleen 

Bennett

Bennett

Bennett

Bensetler

Benson

Benson

Benson

Bento

Benton

Benton

Benward

Benz

Berard

Berario

Berario

Berario

Berchem

Berchert

Bereczki

Berg

Berger

Berger

Berger

Berger

Bergeron

Bergqvist

Bergsma

Bergstrom

Berkeley

Berkheimer

Berkowitz

Bernache

Bernard

Bernard

Bernard

Bernard

Bernardine

Bernardo

Bernbach

Berquist

Berry

Bertano

Berto
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-121 October 2016 

Julie

Judy 

Linda

Ruth

Richard

Gary

Kathleen 

Arie

Jamie

J.

Ann 

Jean

Wendy

K.

Cheryl

Debra

Diletta

Mark

Ann

Leigh

Maureen

Melissa

Debbie

Amy

Helene

Leslie

Nancy

Stacy

Suzanne

Jodi

Angela

Gina

Bogdan

Janet

Randall

Linda

Caroline

Kenneth

Melissa

Paul

Yvonne

Bonnie

Carol

Bertolucci

Berube

Bescript

Bescript

Best

Bettega

Betters

Bettsack

Beutler

Beverley

Beverly 

Bevsek

Beyda

Bhojwani

Biale

Bialko

Bianco

Bick

Bicking

Bidwell

Biedron

Biela

Biere

Biggs

Bigvaiev

Billings

Billings

Billings

Billings

Billingsley

Bilotti

Bilwin

Bilyk

Bindas

Bingham

Bingle

Bird

Bird

Bird

Bird

Bird

Bisbee

Bischoff

Patricia

Beth

Mary

Julia

Elisabeth

Judith

Lacie

Rebecca

Shar 

Christie

Joan

Kimme

Viki

Angela

Beverly 

Catherine

Bruce

Sherry 

Paula

Sara 

Daisy

Gail

Linda

Sally

Casey

Rosa 

Thomas

E.

Donna

Jaime

Marci

Eileen

Michele

Tanner

Denise

Silvia

Trent

Lisa

Claudia

Darren

Hanna

Joyce

Barbara

Biscoe

Biscuso

Bisesi

Bishop

Bittremieux

Bixby

Bizzell

Bjelland

Bjeree

Black

Black

Black

Black

Blackburn

Blackburn

Blackburn

Blacknight

Blackshear

Blackwell

Blaise

Blake

Blakely

Blakely

Blakey

Blanchard

Blanckaerts

Blaney

Blankers

Blascczyk

Blasingim

Blatt

Bleidorn

Bleymeyer

Bleymeyer

Bligh

Block

Block

Blodgett

Bloom

Bloom

Bloom

Bloom

Blount-Powell

Sherry

Steven

Kit 

Jane

Mixa

Sherry

Brent

Melantha

Ralph

John

Kathryn

Sharon

Tom

Sigrid

Barbara

Bill

Corrie

Izabela

Crickett

Martha

Jennifer

Carol

Deniz

Beverley

Deb

Becky

Pamela

Rebecca

Petra

Carol

Carmen

Debbie

Corinne

Monica

Deborah

Amy

Barbara

Carolyn

Gracie

Kiana

Sara 

Patrick

Vita

Blue

Blumenfeld

Blumenstein

Blythe

Bmixa

Bobick

Bobo

Bobrick

Bobroski

Bodfish

Bodine

Bodkin

Boe

Boehm

Boettcher

Bogacki

Bogtstra

Boguslawska

Bohanan

Bohannon

Bohn

Boice

Bolbol

Boling

Boller

Boman

Bonaventura

Bondarewicz

Bonello

Bonfield

Bonilla-Jones

Bonnet

Bonnici

Bonualas

Boomhower

Boone

Boone

Boor

Booth

Booth

Booth

Bopp

Bordonaro
LIST OF COMMENTERS

3 Bars Project Final EIS D-122 October 2016 

Serena

Diane

Maria

Magdalena

Gavin

Kat

Carol 

Barbara

Christy

Laura

Anne 

Marianne

Eric

Kristen

Vic

John 

Linda

Thomas

Renee

David

Michelle

Claudia 

Stefano

Sharon

Fran

Laraine

Pat

Sarah

Anna

SarahLynn

Barbara

Alexandra

Candy

Jason

Jeff

Jessie

Sheila

Susan

Alice

Helene

Gen

Charlene

Katie

Borella

Borger-Ness

Borges

Borkowska

Bornholtz

Boron 

Boronkay

Boros

Borriello

Borst

Bosard

Boschen

Bosers

Bossert

Bostock

Boswell

Boswell

Boswell

Boteilho

Bott

Bourg

Bourque

Bovero

Bowden

Bowen

Bowen

Bowen

Bowen

Bower

Bower

Bowie

Bowman

Bowman

Bowman

Bowman

Bowman

Bowman

Bowman

Bowron

Bowyer

Boyd

Boydston

Boyle

Christine

Diane

Eliette

Kyle

Jeanne

Denver

Denver

Charles

Donna

Maria

Ryan

Sabine

Stacey

Denise

Emma

Tasha

Laurie

Emma

Deborah

Chandra

Jenny

Victoria

Carol

Frauke

V.

Susan

Carolyn

Michael

Corine

Chris

Leenie

Marina

Ann

Paul

Becky

Patricia

Cvetka

Maximilian

Denise

Nancy

Natasha

Natasha

Lorenzo

Boysen

Bozarth

Bozzola

Bracken

Bradbury

Braden

Braden

Bradford

Bradley

Bradley

Bradley

Bradley

Bradley

Bradshaw

Bradshaw

Bradshaw

Brady

Bragg

Brake

Brambles

Bramlette

Brandon

Brandt

Brandt

Brandt

Brandwein

Bratton

Braunstein

Brayton

Brazis

Breckenridge

Bredda

Breeden

Breeden

Breeding

Breedlove

Bregant

Brek

Brennan

Brenner

Brenner

Brenner

Bresciani

Gail

Daniela

Ginger

Ginger

Stacey

Bonnie

John

Kay 

Lisa

Laura

Julie

Brenda

Judy

Sherry

Adrienne

Debbie

Vicki

Karen

Diane

Peggie

Joyce

Hope

Belinda

Sandra

Julia

Barbara

Robin

Elena

Seymour

Becky

Carol

Ginny

Wendy

Pauline

Theresa

Irene

Gerald 

Patti

A.

Anita

Bonnie

Chanel

Cheryl

Breslin

Bress

Brewer

Brewer

Brewer

Brezette

Brian

Brian

Brice

Briden

Bridge

Bridges

Bridges

Bridgford

Brietzke

Briggs

Brine

Bringol

Brinks

Bristow

Britcher

Britt

Britton

Britton

Broad

Brockell

Brockman

Brodskaya

Brodsky

Brok

Broll

Brommelsick

Bronson

Brooks

Brooks

Brosseit

Brothen

Brotman

Brown

Brown

Brown

Brown

Brown
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-123 October 2016 

Denise Brown Barbara Bryant Alice Burkett

Dennia Brown Elizabeth Bryant Imogene Burkhart

Dianne Brown Lauren Bryant Kerri Burnett

Fiona Brown Mary Bryce Carol Burney

Georgine Brown Sara Bryce Kathleen Burnham

Heather Brown Roberta Brzozowski G. Burns

Heike Brown Susan Bubbers Jerry Burns

Jan Brown Cathy Buccola Joy Burns

Janet Brown (6) James Bucolo Susan Burns

Kristina Brown Cynthia Buczkowske Jim Burris

Linda Brown Ilene Budin Shannon Burt

Marie Brown Sherry Budniak Stacy Burt

Melanie Brown Anita Buffer Christina Burton

Michael Brown Douglas Buffo Debbie Burwell

Mimi Brown Heidi Bujak Jennifer Burwinkle

Nancy Brown Tanis Bula Donna Buscemi

Ronald Brown Jill Bule Martha Bushnell

Shawna Brown Sharon Bull Chantal Buslot

Susan Brown Heather Bullard Ray Bustos

Valerie Brown Karen Bullis Betty Butler

Vickie Brown Patricia Bullock Bruce Butler

William Brown Donna Bungo Connie Butler

Harvey Brown, Jr. Ineke Bunink David Butler

Marsha Browne Brooke Bunting Ruth Butler

Lauren Browning Craig Bunting Sheila Butler

Clifford Bruber Shirin Bunting Abby Butterfield

Jessica Bruce Clarissa Bunuel Ricky Buttery

Virginia Bruce Pauline Burak Kate Buttles

Debra Bruegge George Buras Pat Button

Paula Brugger-Neves Michelle Burawski Brenda Byler

Michelle Brugiere Jason Burch Sue Byorick

Charles Brumleve Jayme Burch Leeann Byrne

Leland Brun Elena Burge Lindsay Byrne

Roger Bruneau Ryan Burger Nicolas Caballero

Bobby Bruner Diane Burgin Linda Cabanban

Curzio Bruni Joan Burgins John Cabe

Linda Brunner Angela Burgio Nike Cacoullos

Alison Bruno Cynthia Burgner Sandy Cadwell

Robert Bruno Eleanor Burke Eugene Cahill

Shelley Brunskill Russell Burke Lisa Cahill

Debbie Brush Shirley Burke Terrie Cahoe

Babette Bruton Diane Burket Deborah Caiaga

Barbara Bryan Paula Burket Eileen Cain
LIST OF COMMENTERS

3 Bars Project Final EIS D-124 October 2016 

Misa

Barbara

Laura

Phillip

Becky

Doreen

Deborah

Anne 

Jane

Julie

Deirdre

Christina

Carmen

Karen

Susan

Monika

Nil 

Tammy

Linda

Carolina

Elizabeth 

Gloria

Greg

James

Jean

Lois

Patrick

Stephanie

Edward

Jaime

Elizabeth

Grant

Joan

Kevin

Laura

Linda

Monica

Nancy

Sandra

Eduardo

Ursula

John

Kathleen 

Cajnko

Calamai

Calderon

Caler

Calhoun

Calise

Calkins

Callace

Callahan

Callahan

Callan

Callas

Calleja

Callies

Calltharp

Calvert

Cam 

Camacho

Camac-Vittorio

Camarillo

Cambareri

Cameron

Cameron

Cameron

Cameron

Cameron

Cameron

Cameron

Camilleri

Cammarata

Campbell

Campbell

Campbell

Campbell

Campbell

Campbell

Campbell

Campbell

Campbell

Campos

Campos

Canavan

Canfield

Barbara

John

Mark

Gary

Linda

M.

Elaine

Eva 

Ronald

Cindy

Anthony

Cinzia

Jeanette

Joan

Silvia

Leigh Ann

Michele

Audrey

Giuliana

Hilary

Elizabeth

Michele

Gina

Kitty

Brenda

Edward

Carla

Anne

Ida

Ida

Sioux

Jeff

Alessa

Chris

Nicole

Corrine

Sara 

Susan

Laura

Selva

Michael

Wendy

Gina 

Cangiano

Cannon

Canright

Cantara

Canter

Canter

Cantrell

Cantu

Capek

Capellen

Capobianco

Caporali

Capotorto

Cappelluti

Cappi

Cappizi

Capra

Caprio

Caprioglio

Capstick

Caputo

Caputo

Caracci

Cardaci

Carey

Carey

Cargballo

Cargill

Carideo

Carideo

Carlgren

Carlin 

Carlino

Carlon

Carlson 

Carlson-Cox

Carmichael

Carmody

Carmona-Mancilla

Carnevale

Carney

Carney

Carollo

Kim

Steve

Gary

Sylvie

Mary

Rebecca

Viola

Elaine

Adriana

Cynthia

Kathryn

Laura

Glenn

M.

Sandra

Brandon

Evelyn

Michelle

Natalie

Judith

Sandi

Maurico

Debbie

Susan

Uli

Chris 

David

Dawn

Joynce

Neelie

Julia

Chris 

Judy

Susie

Virginia

Victoria

Kristine

Allison

Beverly 

June

Liana

Ruth

D.

Carothers

Carothers

Carpenter

Carpentier

Carptenter

Carr

Carr 

Carrick

Carrico

Carroll

Carroll

Carron

Carson

Carson

Carstensen

Carswell

Carter

Carter

Carter

Cartisano

Cartwright

Carvajal

Carvouniaris

Casad

Casares

Casey

Casey

Casey

Casey

Casey

Caspar

Casper

Cassario

Cassens

Cassidy

Castaneda

Castillo

Castle

Castricone

Castro

Castro

Castro

Caswell
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-125 October 2016 

Lexie

Paola

Ellen

Diana

Joseph

Linda

Andrea

Janet

Pauline

Violet

Michelle

Jan

Carolyn

Judy

James

Elizabeth

Catherine 

Ingrid

Louie

Nancy

Isabel

Jean

Jillian

Elizabeth 

Judy

Sheila

Cathy

Debbie

Shirley

Adriana

Patsy

Kari

Barton

Connie

Martha

Peggy

Tara

Nancy

Jaci

Persia

Wallace

Rani

Michael

Cataldo

Catapano

Cather

Cato

Cator

Caulk

Cavalier

Cavallo

Cavanagh

Cavanaugh

Cech

Cejka

Celler

Centineo

Cerniglia

Cerny

Cerqua

Cerqueni

Cervantes

Cervenka

Cervera

Cervi

Cessna

Cewmar

Chace

Chaffins

Chaipis

Challman

Chalmers

Chalson

Chamberlain

Chamberlin

Chambers

Chambers

Chambers

Chambers

Chambers

Champion

Chan

Chan

Chan

Chandi

Chang

Sharon

Zella

Lin 

Stanley

Cindy

Danielle

Donna

Judith

Nadine

Therese

Leonor

Morris

Jean 

Lois 

Lori

Marie

Melodie

Suzy

Lee

Belinda

Kathryn

Antonia

Barbara

Leonardo

Judy

Margaret

Marilyn 

D. 

Pete

Janet

Kim

Sun

Kelly

Kay

Shawn

Madra

Yvonne

Laura

Angela

Gina

A.

Jean

Janelle

Chang

Chapman

Charania

Charles

Charnetski

Charney

Charter

Chase

Chatel

Chatelain

Chavez

Chay

Cheesman

Cheesman

Cheezem

Chellino

Cheney

Chersky

Chesterfield

Chettle

Cheyne

Chianis

Chichester

Chiconello

Childers

Childers

Childers

Childress

Childs

Chirrick

Chmel

Cho

Choi

Chrissis

Christenson

Christian

Christison

Christman

Christopher

Chronowicz

Chupa

Chuprevich

Church

Lucile

Sandra

Terry

Teresa

Annmarie

Karen

Fran 

Laura

Jordan

Edna

Alexis

Carol

Dale

Donna

Jay

June

Laurie

Leilani

Randi

Irina

Michele

Arlene

Linda

Lisa

Susan

Kate

Susanna

Heather

Gerald

Sue

Holly

Agustin

Rhonda

Harriett

Marilyn 

Leslie

Louise

Cynthia

Jill 

Sherry

Hannah

Lauren

Marian

Church

Church

Church

Cichon

Ciesla

Cignoli

Cilella

Cimino

Cinqmars

Ciurleo

Claar

Clark

Clark

Clark

Clark

Clark

Clark

Clark

Clark

Clark 

Clark 

Clarke

Clarke

Clark-Kahn

Clarkson

Clark-Spencer

Clason

Clausner

Clawson

Clayton

Cleary

Clemente

Clements 

Clementson

Clemenza

Clemmons

Clendenen

Cleveland

Cleveland

Cliborne

Clifford 

Clinch

Clinton
LIST OF COMMENTERS

3 Bars Project Final EIS D-126 October 2016 

Marjorie

Heather

Heather

Lois Ann

Imogene

Scott

Beverly 

Edith

Patty

Robert

Sandra

Susan

Joyce

Lance

Margery

Peggy

Cameron

Kathleen 

Lauri

Patricia

Izabela

Harriet

Linda 

Roslyn

Susan

Ken

Marie

Rebecca

Kathleen

Chris

Kevin

Patrice

Sunnie

Dori

Brandt

Deanna

Edith

Janet

Elizabeth

J. 

Cathleen

Carla

Vicki

Clisson

Clough

Clough

Clouthier

Clymore

Coahran

Coates

Coates

Coates

Cobb

Cobb

Cody

Coe

Coffel

Coffey

Coffey

Coffman

Coffman

Coffman

Coffman

Cogelja

Cohen

Cohen

Cohen

Cohen

Cohn

Coiscaud

Colaw

Colburn

Cole

Cole

Cole

Cole

Cole 

Coleman

Coleman

Coleman

Coleman

Collard

Collens

Collett

Collier

Collier-Chambers

Brenda

E.

Gerry

Heather

Holly

Janet

Laura

Lyle

Megan

Patricia

Teresa

Helga

Fundacion

Peggy

Margaret

Connie

Kathleen 

Silvana

Mary Anne

Pat 

Kathy

Margaret

Christian

Melissa

Melissa

John

Liza

Susan

Cherie

Alice

Bob

Jim

Laurie

Peggy

Michelle

Margaret

Carolyn

Luana

Susan

Debra

Linda

Mary

Necole 

Collins

Collins

Collins

Collins

Collins

Collins

Collins

Collins

Collins

Collins

Collins

Collister

Colombia

Colonna

Colony

Colvin

Colvin

Comacchio

Combs

Combs

Compagno

Compton

Comstock

Conley

Conn 

Connelly

Connelly

Conner

Connick

Connor

Conrich

Conroy

Conroy

Conroy

Constantine

Conti

Contreras

Contreras

Conway

Cook

Cook

Cook

Cook

Theresa

Richard

Kenneth

Janice

Grace

Donald

Susan

Mitzi

Ann

Cassandra

Charlene

David

Dayton

Rebecca

Sylvia

Alan

Beth

Denys

Gwen

Shari

Tracy

Terri

Marguerite

Jeanne

Ute

Donnell

Norma

Angelina

Harmony

Adrian

Bonnie

Joan

Sarah

Athena

Bev

Nancy

Claudia

M. Cecilia

Stefania

Mike

A.

Bene

Christine

Cook

Cooke

Cooksey

Coombes

Coon

Cooney

Cooney

Coons

Cooper

Cooper

Cooper

Cooper

Cooper

Cooper

Cooper

Coote

Copanos

Cope

Cope

Copeland

Copper

Coppersmith

Cordell

Cordner

Cordova

Corelle

Corey

Coriandoli

Coriddi

Cormier

Cormier

Cornett

Cornish

Coroneos

Corp-King

Correa

Correia

Correia

Corrias

Corsello

Corte

Corti

Corutky
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-127 October 2016 

W. Michael

Fletcher

Camila

Angela

Sandra

Dee

Sanda

Pamela

Renee

Rita

Robert

Laura

Elise

Sandrine

Brigid

Carole

Monika

Meri

Betsy

Annie

Melita

Laurel

Linda

Camille

Jane 

Lorena

Nora

Ann

Ben

Jeanne

Summer 

Janice

Desiree

Evelyn

Michelle

Phyllis

Marcella

Margo

Mark

McKenzie

Patricia

Barbara

Rebecca

Cosby

Cossa

Cossio

Costa

Costa

Costello

Costello

Cote

Cote

Cote

Cote

Cotter

Coughlin

Coulon

Courtney

Courtney

Courtney

Coury

Cousins-Coleman

Coustaty

Covic

Covington

Covington

Cox

Cox

Cox

Coyle

Coz

Crabb

Crabb

Crabtree

Craddock

Craig

Craig

Craig

Craig

Crane

Crane

Crane

Crane

Cranmer

Craven

Craven

Holly 

Joyce

Marianne

Tina

Marcia

James

Ashtin

Jill

Theresa

Laura

Rose

Kim 

Pamela

Andrea 

Stacy

Frances

Mary

Clifford

Bob

Saralee

Victoria

Jennifer

Gena

Jan

Diane

Lorraine 

Karen

Drew

Bernadette

Stephanie

Sarah

Elaine

Leslie

Linda

Alyssa

Shirley

Debra

Judy

Frank

Connie

Janet

Elizabeth

Edward

Crawford

Crawford

Crawford

Crawford

Cree

Creely

Crenshaw

Cresko

Creten

Crevillen

Cribbs

Crickard

Criscio

Crisp

Croan

Crocco

Croft

Crook

Crosby

Cross

Cross

Crossette

Crow 

Crowder

Crummett

Cruz

Cucci

Cucuzza

Cuellar

Cuellar

Culp

Cummings

Cummings

Cummings

Cunniff

Cupani

Curci

Curcuru

Curley

Curnow

Curran

Curry

Curtin

Catherine

Cynthia

Janet

Patricia

Janice

Shelley

Steve

Alex

Rebecca

Marianne

Cathleen

Cathleen

Barbara

Deborah

Philip

Robert

Felicia

Linda

Sheila

Jenette

Lisa

Nancy

Giustina

Elizabeth

Krishna

Debra

Laura

Giboin

Joan

Kristin 

Meghann

Marie 

Nathalie

Karis

Ruth

Wanda

Donna

Anne

Nancy 

Heather

Anita

Melinda

Roxanne

Curtis

Curtis

Curtis

Curtis

Cyrill

Czeizler

Czerviski

Czurylo

Czurylo

Daggres

Dagher

Dagher

Dague

Dahlgren

Dahlheimer

Dahm

Dale

Daley

Dallas

D'Allessandro

Daloia

Daly

Damiano

Dana

Dangol

Daniel

Daniel

Danielle

Daniels

Dankworth

Danley

D'Anna

Daoust

Daphne

Darden

Darland

Darling

Darlington

Darlington

Darrow

Das

Dastrup

Daus
LIST OF COMMENTERS

3 Bars Project Final EIS D-128 October 2016 

Juliette

Fran 

Nora

Regina

Lawrence

Simone

Lynne

Milly

A.

Ali 

Ashlee

Barbara

Carol

Celeste

Darlene

Donna

Jim

Lisa

Pam

Terri

Betty

Angel

Alexandria

Cris

Robyn

Sheila

Terri

Ingrid

Sylvia

Alicia

Victori

Nicholas

Alicia

Sylvie

Natasha

Phillip

Karon

Rayline

Franshisca

William

Michael

Louann

Anthony

Dauterive

Daversa

Davidoff

Davidshofer

Davidson

Davie

Davies

Davies

Davis

Davis

Davis

Davis

Davis

Davis

Davis

Davis

Davis

Davis

Davis

Davis

Davison

Dawson

Day

Day

Day

Day

Day

de Baintner

De Braca

De Dios

De Goff

De La Cruz

De Leon

de Parny

De Santis

Deal

Dean

Dean

Dearmas

Dearstyne

Dearth

DeBerry

DeBiase

R.

Katrina

Deborah

Mary 

Debra

Karen

Christine

Cindy

Kelene

Callie

Robert

Kim

Lisa 

Denise

John

Theresa

Vali

Donna

Roberta 

Kellie

Jennifer

Sheelagh

Xandra

Dagmar

Gina

Patricia

Sherry

Patricia

Amy

Denise

Kate

Chris

Elizabeth

Crystal

Dru Ann

Ximena

Debera

Barbara

Catherine

Sheila

Debora 

Launa

Patricia

deBlaey

Deboer (7)

DeBois

DeBono

Debra

DeBraal

DeCamp

DeCarlo

Deccio

Decena

Deck

Decker

Deckert

DeCunzo

Deddy

Deery

Dees

Deese

DeFoe

DeFosset

DeGerolamo

Degnan

DeGraeve

Degree

DeGrenier

Dehler

Deitrich

Delagrange

Delaney

Delatorre

DelCorpo

Delcourt

DeLeon

Delgado

Delgado

Delgado

Delgatto

Delis

Delise

Dellarma

Dellinger

Delp

Deluca

Megan

Jan

Tony

Jackie

Diane

Tracey

Pinelopi

Shane

Christian

Sandra

Roberta

Susan

Laurie

Dianne

Beth

Gudrun

Lori

Brett

Carolyn

Lana

Coleen

Sheri

Donna

George

Marianne

Carm

Nancy

Shirley

Karen

Shirley

R.E.

Sheila

Donna

Michele

Catherine

Joanne

Teresa

Joan

Vicki

Valerie

Marybeth

Missy

Justine

DeLucia

DeLuke

DeMalio

Demarais

DeMartini

Demartini

Demetriadou

Demone

Demottes

Dempsey

DeNieu

Denike

Denis

Denney

Dennis

Dennis

Dennis

Dennison

Dennison

DeNoni

Denson

DeOrio

DePauw

Deprelle

DeRitis

Derrico

Deruchie

DeRuchie

Descamps

deSilva

Desmond

Desmond

Desrosiers

Dessons

Deuter

Devaney

Devaney

DeVanzo

DeVaux

Devigne

Devlin (8)

Devlin

Devoe
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-129 October 2016 

Lisette

Pat

Marda 

Anna

Andrea

Alice

Janet

Robin

Kimberly

Charyl

Aaron

Diane

Marie

Amanda

Kim 

Stacey

Patricia

Thomas

Roxanne

Kim

Beate

Katharine

Lissa

Eileen

Diahann

Carol

Christi

Mary

Sheila

Ivana

Joyce

Martha

Nicola

Mary

Joanne

Angela

Cynthia

Mary

Kathleen

Judy

Maria

Linda

Donna

deWaard

Dewar

DeWet

Dewing

Dezendorf

Di Gregorio

Diamond

Diaz

DiBartolomeo

Dick

Dickens

Dickens

Dickenson

Dickinson

Dickinson

Dieck

Diekman

Diener

Dierking

Dieter

Dietrich

Dietrich

Diffenderfer

Dignardi

DiLella

Dillingham

Dillon

Dillon

Dillon

Dimovski

Dindlebeck

Dingilian

Dingley

Dinino

Dinsmore

Dinter

Disanto

DiStefano

Dittmar

Ditton

Divirgilio

DiVittorio

Dixon

Joyce

Kathleen 

Toxi

Sofia

Bonnie

Kathleen 

Melanie

Sara

Sherri

Beth

Joanne

P.

Colleen

Andreas

Iris

Francine

Warren

Jill

Mary

Cheryl

Ken

Jeanette

Chuck

Melissa

Sandra

Susan

Gloria

Cheryl

Debbie

Richard

Judy

Nanina

Karen

Diana

John

Brianna

Susan

Joan 

Alan

Suzanne

Din

Mary

Linda

Dixon

Dixon

Dixon

Dober

Dobrowski

Dodd

Dodson

Dodson

Dodson

Doherty

Doherty

Doherty

Dolan

Dolezal

Dolezal

Dolins

Doll, Jr.

Dombrowski

Dominic

Donahue

Donar

Donato

Donegan

Donham

Donlon

Donmoyer

Donn

Donnelly

Donnelly

Donner

Donofrio

D'Onofrio

Donohue

Dooley

Doorish

Dorantes

Dorchin

Doren

Dorfman

Dorman

Dornseif

Dorr

DosSantos

Wanda

John

Twyla

Lisha

Dianne

Virginia

Lisa 

Natasha

Brenda

Janice

Larry

Kristine

Deborah

Holly

Craig

Jean 

PK

AniMaeChi

Lucy

Laura

Sommer

Ryan

Heather

Linda

Gail

Arlene

Jane 

Barbara

Diana

James

Shelli

Anna

Gary

Vicky 

Harris

Anne

Jason

Diana

Nadia

Emerald

Tim

Terri

Roseann

Dossey

Dotta

Douaire

Doucet

Douglas

Douglas

Douglass

Douglass

Doulin

Douma

Douma

Dove

Dowling

Dowling

Downer

Downey

Doyle

Drabic

Drahorad

Drake

Drake

Draper

Drees

Drescher

Dressel

Drewniak

Drews

Drinkwater

Driver

Drogo

Drummer

Drummond

Dube

Dubie

Dubin

Dubois

Dubois

Ducharme

Duclaud

DuCoeur

Duda

Duderstadt

Dudrick
LIST OF COMMENTERS

3 Bars Project Final EIS D-130 October 2016 

Diana

Monica

Jeff

Jacqueline

Robert

Lorraine

Lynette

Janie

Janie

Katherine

Nicole

Joan

Beverly 

John

Kathy

Kristi 

Leslene

Vicki

Donna

Janet

Laurie

M.

Michael

Kimberly

Craig

Gail

Jeff

Sylvia

Michele

Darlene

Shirley

Darlene

Susanna

Joseph

Cheryl

Karen

Janina

Aeyrie

Susan 

Teresa

Gail

Teresa

SueAnne

Duffy

Duffy

Duflon

DuFoe

Duke

Dumas

Dumont

Duncan

Duncan

Dunk

Dunlap

Dunlavey

Dunn

Dunn

Dunn

Dunn

Dunn

DuPraw

Duran

Duran

Durante

Durrenberg

Dutton

Duval

Dvorkin

Dwyer

Dwyer

Dwyer

Dye

Dyer

Dykhuis

Dynega

Dzhabrailowa

Dziczek

Dzubak

Eachus

Eager

Eagle

Earle

Earle

Earls

Earp

Easter

Tina

Sarah

Brian

Eileen

Aleene

Kathleen

Paula

Samuel

Victoria

Carlos

J.

Everlyn

William

Cheryl

Carole

Pandora

Ariane

Betty

Cynthia

Rose

Mary

Deborah

Janice

Stuart

Karin

Brenda

Carolyn

Amy

Brad

Joan

Patricia

Lisa 

Amy

David

Julie 

Nancy 

Marlen

Eva

Ingrid

Jane

Laura

Kate

Judith

Easterbrook 

Eastin

Easton

Easton

Eastwood

Eaton

Eaton

Eaton

Eberwein

Echevarria

Eck

Eckert

Edelman

Eden

Edmonds

Edmonston

Edmundson

Edwards

Edwards

Edwards

Effron

Efron

Egan

Egan

Eichten

Eisenhart

Eisenmenger

Ekelman

Ekstrand

Elder

Elder

Eldred

Elepano

Elfin

Elfin

Elgin 

Elias

Eliassen

Elkins

Ellenberg

Ellenwood

Elliot

Elliott-Brown

Cori

Sara 

Maura

Sanchez

Carolyn

Lora

Mari

Jack 

Tracy

Breanne

Janet

Ann

Wendilyn

Jill

Richard

Ann

Nancy

Kayla

Carrie

Susan

I. 

Encanta

Raya

Denie

Donna

Jill

Charles

Rose

Jordan

Lindzie

Jackie

Jacqueline

Pam

Shelly

Hilarie

Jessica

Paula

Susan

Susan

Richard

John

Nicolas

Karen

Ellison

Ellisson

Ellyn

Elodie

Elsey

Elstad

Elvi

Ely

Ely

Emerine

Emerson

Emmerson

Emrys

Ender

Eng 

Engebretson

Engebretson

Engelson

England

England

Engle

Engleby

Engler

English

English

English

Engman

Enloe

Ennis

Ennis

Enright

Enright

Erb

Erickson

Ericson

Eskew

Esposito

Esposito

Esposito

Espuga

Essman

Estevez

Estok
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-131 October 2016 

Denisa

Jenny

Elaine

Joan 

Elissa

Jillian

Ann

Barbara

Bronwen

Christopher

Kelly

MaryAnn

Roberta

Rochelle

Walker

Sheryl

Anne

Heather

Rosemary

Jet

Leigh

Carol

Judith

Justine

Kerry

Diane

Judy

Judith

Daniel 

Richard

Bonnie

Karli

Veronica

Fred

Nanci

Nancy

Barbara

Susan

Linda

Melissa

Maryam

Sam

Janice

Estokova

Estripeaut

Eudy

Eukitis

Eunice

Evangelista

Evans

Evans

Evans

Evans

Evans

Evans

Evans

Evans

Everette

Ewald

Eynern

Eyssi

Eyssi

Ezra

Fabbri

Facey

Fader

Faeth

Fagone

Fairfield

Fairless

Fairly

Faisal

Faith 

Faith-Smith

Fajdiga

Falcon-Gomez

Fall

Falley

Fanara

Faner

Fanning

Fante

Farago

Faresh

Fargnoli

Farley

Gail

Sandra

Wendy

Phyllis

Yvonne

Ani 

Peter

Jeanne 

Thierry

Dimitria

Marilyn

Melinda

Joann 

Susan

Ingrid

Albert

Susan

Karen

Kristina

Tatiana

Audrey

Brian

Sarah

Anne

Veronica

John

Jill

Felix

Kate

Grace

Heike

Patricia

Nancy

David

Ellen

Steph

Louise

Donna

Elizabeth

Jan

Tara

Carl

Gail

Farmer

Farrell

Farrell

Fast

Fast

Faulkner

Faure

Faust

Favre

Fay

Fay

Fay

Feather

Featherstone

Fechner

Fecko

Federici

Federov

Fedorov

Fedotova

Fee

Feeney

Feick

Feingold

Feinstein

Feissel

Feist

Felde

Feldman

Feldmann

Feldmann

Felice

Fenstermacher

Ferger

Ferguson

Ferguson

Fernandes

Fernandez

Ferrari

Ferraro

Ferraro

Ferrie

Ferriera

Felicia

Theresa

Shari

David

Sharon

Suzanne

Chris

George

Merrily

Renee

David

Patricia

Doska

Gayle

Laurie

James

James

Craig

Ana

Jamie

John

Jacqueline

Kathleen

Gabriele

Rebecca

Marilyn

Jeri

Sara

Dan 

Cheryl

Dennis

Karla

David

Doris

Kay 

Linda

Monika

Nancy

Jessica

Ted

Bernice

Katie

Cathy

Ferrington

Ferritto

Ferro

Ferrucci

Fetter

Ficara

Fick 

Fick 

Fickert

Fiebelkorm

Fiedler

Fiedler

Field

Fieldgrove

Fiesler

Fife

Fife

Figtree

Figueiredo

Fillmore

Finazzo

Finch

Finch

Fincham

Finley

Finnelli

Fioramanti

Fisch

Fischbach

Fischer

Fischer

Fischer

Fisher

Fisher

Fisher

Fisher

Fisher

Fisher

Fishman

Fishman

Fishstein

Fite

Fitzgerald
LIST OF COMMENTERS

3 Bars Project Final EIS D-132 October 2016 

Deborah

Kathleen

Ruth

Tamara

Trish

Sylvia

Judy

Nicholas

Trish

Glen

Robert

Nancy

Diane

Patricia

Jessica

Veronica

Bobbie

Ginny

Mary

Kris

Sara

Terezia

Rose

Meaghan

Sunshine

Erin 

James

Mary

Robert

Jessica

Christina

Douglas

Cheryl

M.

J.D. 

John

Carolyn

M.

Robert

Stephen

Robert

Fay

Janet

Fitzgerald

Fitzgerald

Fitzgerald

Fitzgerald

Fitzgerald

Fitzpatrick

Flanagan

Flanagan

Flanagan

Flaningham

Fleck

Fleming

Flohre

Flood 

Flores

Flores

Flowers

Flowers

Floyd

Fobes

Fogan

Fogarasi

Fogarty

Fogerty

Fogleman

Foley

Foley

Foley

Foley

Folger

Fong

Fonley

Fontaine

Fontenoy

Forbes

Forbes

Ford

Ford

Ford

Foree

Forgette

Forman

Forman

Mary

Nuria

Bruce

Jack

Wendy

Janet

Tina

Beverley

Merle

Ronnie

David

Dreana

Ashley

Caroll

Elizabeth

Linda

Luci

Carole

Ellen

R.

Rachelle

Karen

Sabrina

Jim

Laurie

Irena

Julie

Stacey

Linda

Lynne

Harriette

Keely

Marie-Therese

Mitzi

Robert 

Daniel

Michelle

William

Ingrid 

Ann

Marion

Shelley

Carolyn

Forman

Forrellad

Forster

Forster

Forster

Fortner

Foss

Foster

Foster

Foster

Foulger

Fountain

Fowler

Fowler

Fowler

Fowler

Fowler

Fox

Fox

Fox

Fox

Fox 

Fox-Bosetti

Frageman

France

Franchi

Francis

Francis

Francisco

Francovich

Frank

Frank

Frank

Frank

Frank 

Frankal

Franke

Franklin

Frassl

Fraueheim

Frazier

Frazier

Frederick

Lee

Roberta 

Erik

Karen

Helen

Heather

Linda

Deborah

Dianna

LeeAnn

Rosemary

Janet

Kimberly

Jacqueline

Jamie

Susan

Joyce

Manuela

Arkadij

Susan

Dina

Vida

Joyce

J.

Anna

Sue

Davina

Peggy

Nancy

Paul

Stacey 

Christine

Margie

Laura

Chad

Ann 

Mary

Shearle

Pia

Midori

Derrelle

Carol 

Irena

Frederick

Frederick

Fredrickson

Freebersyser

Freedman

Freeman

Freeman

French

French

French

Freskos

Frey

Frey

Friederichsen

Friedlander

Friedlander

Friedman

Friedrich

Friedt

Fries

Frigo

Fritz

Frohn

Froiland

Frondoso

Frounfelter

Fryman

Fugate

Fuller

Fullerton

Fulton

Fultz

Fultz

Fung

Fuqua

Furey

Furlong

Furnish

Furtkamp

Furutate

Gable

Gabor

Gabut
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-133 October 2016 

Carole

Linda

Lauren

Susan

Pamela

Lori

Elizabeth

Linda

D.

Debra

Maria 

Cristina

Diana

Julie

Patti

Ronda

Susan

Richard

Rosa

Croitiene

Anna

Coleen

Jodi

Lisa

Kathe 

Sonya

Beverly 

Dulce

Edwina

Erin 

Flora

Laura

Suz

Margaret

Cinda

Cinda

Jeanne

Anu

T.

Joan 

Sharon

Jeff

Kristen

Gaerte

Gaffney

Gaffney=blum

Gage

Gagliardo

Gagne-Hockenberry

Gaida

Gainey

Gakeler

Gakeler

Galbiati

Galiano

Gallant

Gallegos

Gallo

Gallo

Gallo

Gamache

Gamazo

GanMoryn

Gannon

Gannon

Garbarino

Garbarino

Garbrick

Garbutt

Garcia

Garcia

Garcia

Garcia

Garcia

Garcia

Garcia

Gardiner

Gardner

Gardner

Gardner

Garg

Gargiulo

Gariazzo

Garlena

Garmon

Garneau

Liz

Marsha

Niki

Grace

Esther

Evelyn

Donna

Nicolette

Cheri

Marilyn 

Ellen

Elaine

Gina

Nathalie

Sarah

Terri

Tammielyn

Judith

Karen

Ina

Traci

Linda

Sandra

Peter

Carol

Terri

Richard

Charlotte

Judy

Genny

Anneliese

Lynn

R.

Rothery

Mija

Diane

Carla

LaQuita

Rita

Angeliki

Constance

Jason

Jason

Garratt

Garrett

Garrett

Garrigan

Garvett

Garvey

Gasbarro

Gascon

Gaspero

Gast

Gaston

Gates

Gatto

Gauw

Gavison

Gawlinski

Gay

Gayle

Geampa

Gebert

Gee

Geeson

Gehri-Bergman

Geidel

Gelfand

Gellin

Geltman

Gem

Genandt

Genevich

Gengel

Gennrich

Genovese

Gensel

Gentes

Gentile

Gentry

Gentry

Gentry

Georganta

George

George

Gerdes

Tamara

Priscilla

Christian

Susan

Jo

Ginger

Howard

Valerie

Susan

Janell

Kathleen 

Isabelle

Nikos

Julie

Cynthia

Lourdes

Carolyn

Jody

Devin

Drea

Elsa

Jody

Scott

Sharon

Jill

Ivy

Cathe 

Valerie

David

Bryan

Carol

Peggy

Nancy

Ron

Debra

Erma

Mark

Nancy

Chris

Carol 

Vicki

Barbara

Andrea 

Gerdts

Gerfen

Gerlach

Gerlach

Germano

Geronimo

Gershon

Gerster

Getejanc

Ghiorso

Giacca

Giagni

Giannakis

Gianni

Gibb

Gibbons

Gibbs

Gibney

Gibson

Gibson

Gibson

Gibson

Gibson

Gideo

Giencke

Giessen

Giffuni

Gilbert

Gilbertson

Gilderoy

Giles-Straight

Gilges

Gilkyson

Gilliland

Gillis

Gillis

Gillono

Gilman

Gilmer

Gingue

Ginoli

Ginsberg

Giolli
LIST OF COMMENTERS

3 Bars Project Final EIS D-134 October 2016 

Karen

Katrina

Deanna 

Cindy

Carolyn

Laura

Jennifer

Chiara

Philip

Marian 

Joan

Lisa 

Debra

Jill

Andrea

Ingeborg

Elizabeth

Petr

Joseph

Jane

William

Jean

Tammy

B.

Andrea 

Marie

Susan

Leslie

Meredith

Robin

Chris

Tony

Jill

Nita

Judith

Linda

Michael

Jan

Laurie

Frank

Patti

Paul

Anita

Giordano

Gioshes

Giovacchini

Girgenti

Girten

Gish

Gitschier

Giudice

Glaser

Glass

Glasser

Glazier

Gleason

Gleeson

Glenn

Glier

Glixman

Glotov

Glynn

Goebel

Goedker

Goetinck

Goetschel

Goheen

Goiolli

Gois

Golberg

Gold

Gold 

Goldansky

Golden

Goldin

Goldman

Goldman

Goldner

Goldstein

Golembeski

Golick

Gomes

Gomez

Gomez

Gomez

Goncalves

Nina

Virginia

Cassandra

Roco

S. 

Doris

Starr

Beverly 

Jennifer

Nancy

Claudia 

Ellen

Mary

Bradford

Heather

Lynn

Mattie

Sherry

Matthew

Shelli 

Lynne

Ewa

Margaret

Lisa

Richard

W. 

Kathy

Kathy

Judith

Susan

Jyrica

Simon

Reisa

Joan

Roland

Beverlee

Bogna

Ella

Pamela

Amanda

Danielle 

Diane

Dolores

Gondos

Gonsalves

Gonzales

Gonzalez

Gooch

Good

Goode

Goodell

Goodell

Goodell

Goodman

Goodman

Goodman

Goodwin

Goodwin

Goodwin

Goodwin

Goodyear

Gordon

Gordon

Gordon-Watson

Gorniak

Goscilo

Gosnell

Gosney

Gosney

Goss

Gosselin

Gottesman

Gottfried

Gough

Gould

Gould-Donath

Gove

Goyette

Goynes

Grabicka

Grace

Graff

Graham

Graham

Graham

Graham

Jim

Joan

Karen

Lynn

Rosemary

Luisa

Sandy

Susan

Jessica

Stephanie

Constance

Lorraine

Walter

Vivienne

Beberly

Lynn

Robin

Jeanne

Marilyn

Denise

Ronda

Angelica

Annette

Joseph

Geraldine

Ingrid

Jamie

Kerstin

Kristin

Mike

Pam

Pamela

Penny

Marilyn 

Paulena

Estelle

Glenn

Ken

Kristopher

Barbara

Laurie

Cathy

Jeff

Graham

Graham

Graham

Graham

Graham-Gardner

Granados

Grandchamp

Granias

Grant

Grashaw

Grasso

Grasso

Graue

Graves

Gray

Gray

Gray

Graziani

Graziano

Greaves

Greaves

Greco

Greco

Greco

Green

Green

Green

Green

Green

Green

Green

Green

Green

Greenberg

Greene

Greener

Greenwald

Greenwald

Greenwald

Greenwood

Greenwood

Greer

Greer
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-135 October 2016 

Kathy 

Ana

Penny

Chilton

Leslie

Marilyn

Probyn

Louis

Pamylle

Cassie

Ann

Annie

Laurel

S.

Dawn

Carmen

Carmen

Meg

Rickey

Rose

Saundra

Eric

L.

Sue

Charlotte

Kathy

Gigi

Mirrell

Risa

Christiane

Wiebke

Keith

Nicola

Vincent

Kim 

Harriet

Tracy

Anna

Cindy

Regina

Cathleen

Linda

Carol

Gregg (9)

Gregorio

Gregorio

Gregory

Gregory

Gregory

Gregory

Greiner

Greinke

Greisheimer

Grenci

Grenier

Gress

Grey

Grib

Griffin

Griffin

Griffin

Griffin

Griffin

Griffin

Griffith

Griffiths

Griffiths

Grillot

Grim

Grim 

Grimes

Grimes

Grimm

Grimm

Grimson

Grobe

Gromley

Groom

Grose

Grossberg

Groth

Grove 

Grover

Groves

Groves

Grubb

Christine

Kathy 

Daniel 

Larry

Valerie

D.

Donatella

Mary

Rachel

Cindy

Merry

Kaye

Martine

Jean 

Berenice

Dennis

Denny

Sheila

Beryl

Ken

Joanne

Laura

Steve

Angel 

Patti

Billie

Elizabeth

Randi

Sabrina

Mary

Naia

Laura

Tisha

Ntasha

Lourdes

Anita

Gloria

Randolph

Claudia

Kimberly

Gilbert-Joseph

Patricia

Valerie

Gruber

Gruber

Grunberg

Grunspan

Gruver

Gryk

Gualandi

Guard

Guarino

Guarnieri

Guben

Gucciardo

Guerinet

Guerrier

Guides de Sa

Guiney

Guinta

Gunn

Gunning

Gunther

Gura

Gural

Gurner

Gurrazzi

Guss

Gutgsell

Guthrie

Guthrie

Guthrie

Gutierrez

Gutsche

Guttridge

Guy 

Guyot

Guzman

Gwinn

Gysbertsen

Gyulay

Haas

Haas

Hache-Gallant

Hackney

Hackney

Joann

Jane 

Nicole

Misty

Deborah

Delphine

Laurie

Mary

J. 

Barbara

Brenda

Joel

Ali 

Lynda 

Marcia

Theresa

Ellen

Kim 

Nicki

Patty

Clara

Lale

Joanne

Sandra

Silvia

Jennifer

Leslie

Linda

Daniele

Everett

Pamela

Pat

Suzanne

Bethany

Charles

Claudia

Donna

F.

Hedda

Lois

Patricia

Theresa

Lisa 

Haddock

Hadfield

Hafemeyer

Haffner

Hagan

Hagan

Haggard

Haggerty

Hagler

Hagofsky

Haig

Hailey

Haines

Haines

Haines

Haines

Halbert

Hale

Hale

Haley

Halfin

Halimoglu

Hall

Hall

Hall

Hall 

Hall 

Hall 

Halle

Halligan

Halsey

Halter

Hamer

Hamilton

Hamilton

Hamilton

Hamilton

Hamilton

Hamilton

Hamilton

Hamilton

Hamilton

Hammer
LIST OF COMMENTERS

3 Bars Project Final EIS D-136 October 2016 

Lori

Lori

Patricia

Pat

Jenny

Lynn 

Marcia

Margie

Dan

Tucker

Lu 

Linda 

Susan

Kathleen 

Janice

Jody

Arthur

Dawn

Jeff

Jens

Linnea

Linnea

Sandy

Alice

Barbara

Christine 

Mary Jane 

Susan

CarolAnn

Judith

Constance

Carolyn

Kris

Alicia

Larry

Stevan

Karen

Valesca

Marilynn

Rebecca

Joan

Lene

Tyler

Hammett

Hammon

Hampton

Hanbury

Hancey

Hancock

Hancock

Hancock

Hand

Handerson

Haner

Hanick

Hanlon

Hanold

Hansard

Hansell

Hansen

Hansen

Hansen

Hansen

Hansen

Hansen

Hansen

Hanson

Hanson

Hanson

Hanson

Hanson

Harbolt

Hardin

Hardt

Hardy

Harker

Harlow

Harmsen

Harnad

Harp

Harp

Harper

Harper

Harrell

Harries

Harrington

Frankie

Hilary

Karen

Kathy 

Krystal

Melissa

S.

Shirley

Catherine

Donna

Jamie

Leanne

Linda

Randy

Scott

Susan

Dawn

Codee

Ralph

Stan

Karryn

David

Cynthia

Jackie

LaRee

Nancy

George

Bruce

Mitchell

Shelley

Marie

Janet

Joanne

Margaret

Ellen

Carol

Robert

John

Kathleen

Lisa

Shelly

Alicia

Carol

Harris

Harris

Harris

Harris

Harris

Harris

Harris

Harris

Harrison

Harrison

Harrison

Harrison

Harrison

Harrison

Harrison

Harrison

Harrod

Hart

Hart

Hart

Hart 

Hartje

Hartley

Hartman

Hartman

Hartman

Hartmann

Hartog

Harty

Hartz

Harubin

Harvath

Harvey

Hashmi

Hassett

Hatfield

Hatfield

Hatton

Hatton

Haugen

Haugen

Haupt

Hauschild

Kathy

Kathy 

Angela

Carol

Debra

Hollie

Jennifer

Kyle

Jennifer

Tiffany

Jon

Jeanne

Jennifer

Linda 

Laurie

Michelle

Erika

Laura

Chris

Ashley

Katherine

Paddy

Cora

Richard

Jeanett

Bonnie

Marian

Andrea

Sam

Elaine

Brenda

Barbara

Petra

Linda 

Carole

Linda 

Frances

Linda

Shelby

Laurie

Richard

Nancy

Gail

Haverkamp

Haverkamp

Hawk

Hawk

Hawkes

Hawkins

Hawkins

Hawkins

Hawthorne

Hayden

Hayenga

Hayes

Hayes

Hayes

Haynes

Hayward

Hazen

Hazucha

Hazynski

Head

Head

Head

Healy

Heaning

Heard 

Hearthstone

Heath

Heaton

Heaton

Heberling-Aungst

Heddictch

Hegedus

Hegenscheidt

Heiartz

Heide

Heidt

Heijman

Heimbach

Heimbach

Hein

Heinlein

Heintz

Heinz
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-137 October 2016 

Theresa

Jeanne

Lee

Sheila

Dee

Ricki

Kathleen

Laurice

A. 

Jennifer

Annette

Lynn

Maria

C.

Carol

Charlene

Debbie

Eileen

Paula

Anne

Devin

Mallika

Patricia

Wendy

Stephanie

Lana

Theresa

Gary

Emily 

Amy

Jill

Suzanne

Katie

Janine

Kellee

Bill

Kelsey

Mark

Mai

Laura

Karlie

Daniel

Juan

Helander

Held-Warmkessel

Heller

Hellevang

Hellings

Hellner

Helmer

Helmer

Hemenway

Hemmingway

Henderson

Henderson

Henderson

Hendrickson

Hendrickson

Henley

Hennessey

Hennessy (10)

Henriques

Henry

Henry

Henry

Henry

Henry

Hensley

Henson

Hentges

Hepner

Herald

Herber

Herbers

Herbruck

Herd

Hering

Herington

Herman

Herman

Herman

Hermann

Herndon

Heron

Herrera

Herrera

Beverly 

Andria

Vickie

Mary

Susan

Stephen

Joanne

Joanne

Judy

Cynthia

Debra

Rhoda

Meera

Robert

Kathryn

Luann

P.

Bethany

Carol

Cass 

Cherrie

Gail

Judi 

Clyde

James

Ronald

Valerie

Jon

Michelle

Linda

April

Charles

Ginger

Harry

Helen 

Jennifer

Joann 

Karen

LeAnn

Marian

Teresa

Harold

Reuben

Herrington

Herron

Hersh

Herzberg

Herzer

Heselwood

Hesselink

Hesser

Hestehave

Hever

Heverly

Hewett

Hewett-Ruggia

Hewlett, Jr.

Hibbs

Hickey

Hickey

Hicks

Hicks

Hicks

Higgins

Higgins

Higgins

Hiland

Hildebrand

Hildebrand

Hildebrand

Hilderbrand

Hiles

Hilf

Hill

Hill

Hill

Hill

Hill

Hill

Hill

Hill

Hill

Hill

Hill

Hills

Hills

Carol

Faith

Holly

Kristina

Nikki

Rebecca

Barbara

Elizabeth

Lanier

Jeremy

Ann 

Tammera

Melinda

Wendy

Larry

Karen

Alice

Mike

Lisa

Ehren

Suszanne

Carol

Rhonda 

Mimi

Harold 

Terry

Rebecca

Joseph

Theresa

Susan

Carolyn

Karen

Murray

Marla

Melany

Ellen

Roberta

Daniela

Robert

Carol

Jackie

Marla

Alan

Hilton

Hilton

Hilton

Hilton

Hilton

Hilton

Himmelright

Hines

Hines

Hinkson

Hinshaw

Hinshaw

Hirsch

Hirsch

Hirsch 

Hirschfeld

Hissim

Hlat

Hobson

Hock

Hodges

Hodgman

Hodgman 

Hodsoll

Hoell

Hoenig

Hoeschler

Hoess

Hoff

Hoffer

Hoffman

Hoffman

Hoffman

Hoffmann

Hogan

Hogarty

Hohman

Hohn

Hoitela

Hoke

Hoke

Holbrook

Holder
LIST OF COMMENTERS

3 Bars Project Final EIS D-138 October 2016 

Sandra

Lynne

Laura

B.J.

David

Carol

Hollie

Renee

Carolyn

Daniela

David

Diane

Ella

Julie

Margaret

Debi

Gina

Rhonda

Stuart

Tracy

John

Lawrence

Dominque

Gisele

Leslie

Patricia

Nancy

Marie

Nancy

Denise

Marie

Robert

Melanie

Nick

Roxanne

Sharon

J.

Nan

Deborah

Katherine

Gwen

Jeff

Kathleen

Hollander

Holley

Holliday

Hollifield

Hollister

Hollomon

Hollon

Holme

Holmes

Holmes

Holmes

Holmes

Holmes

Holmes

Holmes

Holt

Holt

Holt

Holt

Holthaus

Holton

Holtzman

Holy

Holy

Homan

Homsy

Homyak

Honey Jones

Honeychuck

Honeycutt

Honey'Jones

Honish

Honneysett

Hood

Hoople

Hoornstra

Hoover

Hoover

Hope

Hope

Hopkins

Hopkins

Hopkins

Suzy

Lindy

Sandra

Yumiko

Pamela

Cindy

Terry

Denise

Deanna

Jeff

Marc

Sally

Susan

Linda

Brenda

Walter

Cathy

Nickie

Bonnie

Eliza

Jaye

Melinda

Ruth

Wayne

James

Jeff

Amber

Lisa

Mary

Robyn

Valerie

Jordan

Julie

Sherrie

Karen

Mishel

Phyllis

Virginia

Eddie

Misty

Cheryl

Karen

Julie

Hopkins

Hoppe

Hoppmann

Horie

Hormiotis

Horn

Horner

Horning

Horton

Horton

Horton

Horton

Hoskam

Hoskins

Hoten

Hoten

Houde

House

Howard

Howard

Howard

Howard

Howard

Howard

Howarth

Howe

Howell

Howell

Howell

Howell

Howell

Howells

Howitt

Hoyer

Hoyle

Hromoko

Huang

Huang

Hubbard

Hubbard

Hubbell

Hubbell

Hubers

Elizabeth

Dorothy

Julie

Kathy

Sallie

Shelly

Tammy

Chris

Joan

Athena

Jink

Margie

Cheryl

Haley

James

Kathryn

Michelle

Dan

Cynthia

Melissa

Vicky

Toni

Michelle

Debra

Jill

Steph

Kristy

Shannon

Vivian

Rachelle

Lisa

Nena

Susan

Kimberly

Susan

Laurel

Kimberly

Belinda

Kristi

Debra

Rick

Jinx

Patti

Hucker

Hudecek

Hudson

Hudson

Hudson

Hudson

Hudson

Huff

Huff

Huff-Sandstrom

Huge

Huggins

Hughes

Hughes

Hughes

Hughes

Hughes

Hughett

Hull

Hull

Humbarger

Hummell

Hunsicker

Hunt

Hunt

Hunt

Hunter

Hunter

Huntley

Hurd

Hurley

Hurley

Hurley

Hurschik

Hurwitz

Hutcherson

Hutchinson

Hutchison

Hutchison

Hutto

Huyett

Hydeman

Hyman
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-139 October 2016 

Lisa

Danielle

Dostana

Betty

Alunni

Charlene

Carole

Harriet

Susan

Teresa

Pam

Bridget

Sherry

Susan

Janet

Takako

Zia

Kathy 

Miriam

Zara

Mrianne

Dana

Rebecca

Donna

Lisa

Jocelyn

Ginny

Jan

Julie

Maureen

Monica

Shirley

Sheena

Josh

Kathy

Louisa

Susan

Vincent

Frances

Lisa 

Sharon

Pat 

Carrolle

Iannucci

Ifrah

Ijusic

Ikrent

Ilaria

Inglis

Ingram

Ingram

Inman

Inselman

Iraci

Irons

Irvin 

Irving

Isaacs

Ishii-Kiefer

Islam

Ison

Ivaldi

Ivanova

Ivarsson

Ivers

Ivie

Jabillo

Jablow

Jackman

Jackson

Jackson

Jackson

Jackson

Jackson

Jackson

Jacob 

Jacobs

Jacobs

Jacobs

Jacobs

Jacobs

Jacobson

Jacobson

Jacobs-Salinas

Jacoby 

Jacques

Laus

Ellen

Leonard

Elan

Peggy

Deborah

Darlene

Barb

Damian

Donna

Joy

Ondine

Russell

Suzanne

April

Ghazale

Cheryl

Kathy

Joyce

Ica

Sarah

Eric 

Gayle

Lisa 

Brenda

Debra

C.K. 

Adelina

Elizabeth

Vickie

Cheyenne

Colin

Jo Ann

Kathrine

Robin

Lynn

Robert 

Cheryl

Janell

Jean

Kathy

Dana

Marilyn

Jacques

Jaedicke

Jaffee

Jagger

Jakopak

Jakubek

Jakusz

James

James

James

James

James

James

James

James-Hooper

Jamsheed

Janachione

JanFrisco

Janicki

Jans

Jansen

Janty

Janzen

Jaramillo

Jarrard

Jarvis

Jasiorkowski

Jaudal

Javinsky

Jay

Jenkins

Jenkins

Jenkins

Jenkins

Jenkins

Jenkinson

Jenks

Jennings

Jensen

Jensen

Jenson

Jeon

Jesmain

Darynne

Nicole

Jo

Quinton

Lorraine

Rose

S.

Shirley

Toby

Kim

Barbara

Barbara

Caren

Carol

Cheryl

Jane

Janice 

Jeanne

Karen

Linda

Lyndaroux

Mark

Nita

Nona

Nora

Patrice 

Sue

Summer 

Whitney

Yvonne

J.B.

Gail

Susan 

Audrone

Allison

Betti

Brenda

Charlotte

Eileen

Eleanor

Joyce

Karen

Lauren

Jessler

Jessup

Jetson

Jewellen

Jiminez

Jiminez

Jitreun

Johannsen

Johansen

Johns

Johns 

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson

Johnson-Allen

Johnston

Johnston

Jokubauskiena

Jones

Jones

Jones

Jones

Jones

Jones

Jones

Jones

Jones
LIST OF COMMENTERS

3 Bars Project Final EIS D-140 October 2016 

Linda

Megan

Mike

Nancy

Sandra

Shannon

Sian

Valerie

Yvonne

Mary

Stanley

Ruth

Casey

L.

Janet

Jay

Elizabeth

Leopoldina

John

Tonie

Gail

Jennifer

Brumby

Esther

Mary

Mari 

Marilou

Carol

Cynthia

Elaine

Lauren

Shelley

Leslie

Lillian

George

Jason

Kathy

Edith

Peter

Jane 

Stephanie

Karen

Teri

Jones

Jones

Jones

Jones

Jones

Jones

Jones

Jones

Jones

Jones-Giampalo

Jones-Umberger

Jonston

JoRemy

Jorna

Joseph

Joslin

Jost

Jovanovski

Jovino

Joy

Joyiens-Salam

Juarez

Judkins

Juhl

Junek

Jung

Jung

Jurczewski

Jurkovic

Jurumbo

Jusek

Juss

Just

Just

Kacouris

Kadar

Kae

Kagy

Kahigian

Kahikina

Kalfayan

Kalmenson

Kaluza

Lacey

Sarah

Rob 

Joyce

Jill

Kathy

Patricia

Marilynne

Barbara

Deborah

Dori

Jana

Nancy

Franklin

Anastasia

Kelly

Alan

Gerald

David

Tina

Jane 

Heike-Ingeborg

A.

Barbara

Maxann

Vivian

Amanda

Gelly

Afroditi

D.C.

Alissa

Mahabba

Karen

Stephanie

Ilene

Jehana

Kristin

Maggie

Colleen

Karen

Bruce

Carter

Susan 

Kammerer

Kampel

Kamps

Kandalaft

Kane

Kane

Kane

Kanter

Kantola

Kaplan

Kaplan

Kaplan

Kapsaskis

Kaputska

Karagiannidis

Karbon

Kardoff

Karlovitz

Karopkin

Karstens

Kartes

Karwatzki

Kasbarian

Kasch

Kasdan

Kasey

Kassa

Kastania

Katsikis

Katten

Katz

Kauffman

Kawszan

Kaylan

Kazak

Kearney

Kearns

Kearns

Keating

Keating-Secular

Keegan

Keegan

Keeler 

Rhonda

Sandy

John

Lori

Susannah

Tyler

Michelle

Andrea

Norm 

Cheri

Nancy

Dixie

Dianna

Janis

Myriam

Robert

Carol

Marci

Nancy

Steven

Barbara

Debbie

Diane

Doe

Joanne

John

Karen

Kathy

Leanne

Monica

Phyllis

Bonnie

Jason

Debbie

Tina

Eden

Betty

Dianne

Holly

Karen

Mitzie

Robert 

Sharon

Keen

Keese

Kegler

Kegler

Kegler

Kegler

Kehm

Kehoe

Keiser

Keisner

Keiter

Keith

Keller

Keller

Keller

Keller

Kelley

Kelley

Kelley

Kellman

Kelly

Kelly

Kelly

Kelly

Kelly

Kelly

Kelly

Kelly

Kelly

Kelly

Kelly

Kelsey

Kemple

Kendall

Kendall

Kennan

Kennedy

Kennedy

Kennedy

Kennedy

Kennedy

Kennedy

Kennedy
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-141 October 2016 

Kate

Janet

Ellen

Steve 

Kris

Mary

Mark

Judy

Lorna

Susan

Cindy

Lindsay

Robin

Katha

Gloria

Gloria

Rhonda

Darice

Ronald

Sharon

Lance

Susan

Lori Beth

Nicole

Linda 

Sara

Jennifer

Kaye

Cricket

Melinda

Shirley

Rebecca

Kris

Karen

Deanna

Elizabeth

Judith

Julia

Paula

Sandra

Stephanie

Janis

Eileen

Kenner

Kennington

Kent

Kent

Kenyon

Kenyon

Kenzer

Keown

Kepes

Kepner

Kern

Kern

Kern

Kerr

Kersey

Kersey

Kess

Kessler

Kestler

Ketcherside

Ketterling

Ketterling

Kidd

Kieber

Kiernan

Kilbara

Kilgore

Kilgore

Killen

Killen

Kim-Ng

Kimsey

Kindberg

Kindel

King

King

King

King

King

King

King

Kinslow

Kippen

Yvonne

Crystal

Connie

Maryann

David

Judy

Melissa

M.

Karen

Esther

Sandra

Alexis

Kathleen

Richard

Donna

Eveline

Una

Madi

Jennifer

Craig

Peggy

Christine

Anne 

Julie

Joan

Diana

Gloria

Debra

Elissa

Rebecca

Karen

Sally

Walter

Dave

Toni

Susann

Tina

Carole

Christine

Terri

Karen

Loretta

Susan

Kirby

Kirchner

Kirkham

Kirkhoff

Kirkman

Kirkman

Kirkpatrick

Kirsch 

Kirschling

Kirshenbaum

Kisieleski

Kiss

Kitchen

Kite

Kitti

Kjelstrup

Kjerulf

Klawitter

Kleb

Kleber

Klee

Kleiman

Klein

Klein

Klengler

Kliche

Klimczak

Kline

Kline

Kline

Klinefelter

Klinke

Klockenbrink

Klommhaus

Klos

Klose

Klosiewski

Klumb

Klunder

Knauber

Knebel

Kneebone

Knieriemen

Bronzesean

Linda

Susan

Rose

Madeleine

Darlene

Elena

Barry

Tricia

Kate

Emily 

Denise

Evelynb

Melissa

June

Lisa

Renee

Sharon

Mirjam

Bette

Amala

Bodhi 

Vanessa 

Alan

Melanie

Stephanie

Kim 

Irina

Elaine

Joni

Karen

Alex

Margot

Lisa 

Edib

Carollina

Meryle

A.

Lucille

Nancy

Dawn

Nancy

JoAnn

Knight

Knight

Knoll

Knopff

Knowlton

Knox

Knox

Knudsen

Kob

Kobayashi

Kobroff

Kobylarz

Kocket

Kodaly

Ko-Dial

Koehl

Koenitzer

Koester

Koesterke

Koetz

Kohler

Kohler 

Kohlgruber

Kohn

Kohn

Kokal

Koker

Kolomietz

Komorny

Kooken

Koop

Kopac

Kopecky

Kordich

Korkut

Kormann

Korn

Korstanje

Korwin

Kosa

Kosec

Kost

Kostenbader
LIST OF COMMENTERS

3 Bars Project Final EIS D-142 October 2016 

Ekaterina

Steven

Dee

Kate

Debbie

Linda

Jaynellen

Wendy

Christina

Douglas

Christopher

Jennkfer

Kelly

Manuela

Raianna

Sandra

Lois

Kelly

Hannah

Doug

Susan

Darla

Ed

Elinore

David

Miki

Marilee

Dean

Robert 

Kerry

Susanne

Diane

Pamela

Kathy

Megan

Robert

Stephanie

Kathryn

Erika

Jennifer

Leslie

Nichole

Phyllis

Kostina

Kostis

Kotinas

Koum

Koundry

Kourtis

Kovacevich

Kovacs

Kowaleski

Kowalewski

Kowalski

Koziol

Kraemer

Kraft

Krahn

Krakowiak

Kral

Kramer

Kraus

Krause

Krause

Kravetz

Kraynak

Krell

Kremer

Krenelka

Krenik

Kresila

Krikourian

Krininger

Krispien

Kristoff

Kritner

Kron

Krout

Krueger

Krumm

Krusen

Krushinsky

Kruzel

Krygier

Krysil

Krystal

Ernest

Olga

Barbara

Ewa

Gary

Barbara

Martha

L.

Grace

Kirsten

Holly

Kelly

Marie

Linda

Nancy

A. 

Carrie

Madelaine

Deborah

Ann

Sheri 

Mariposa

Cindy

Jolanda

Donna

Joan 

Jill

Sharon

Gloria

Lynne

Monique

Deborah

Dwain

Ioana

Yveline

Frank

Sharon

Phylana

Elizabeth

Patricia

Barbara

Mark

Carol

Kuban

Kubareva

Kucala

Kuczenska

Kuehnapfel

Kuehner

Kuepper

Kuhar

Kuhn (5)

Kuhre-Holmquist

Kukkonen

Kulauzovic

Kullman

Kurgan

Kurinec

Kurjian

Kurtz

Kurzer

Kuskye

Kuter

Kuticka

Kutler

Kuziel-Romero

Kuzmanic

Kwilosz

Kyler

Kyriakopulos

Kyriakos

La Fleur

La Fleur

La Marca

Labb

LaBrooy

Lacatus

Lacave

Lachelli

Lacy

Ladd

Ladiana

LaDue

Lahrson

Lainer

Laitinen

Jennifer

Renee

Sanja

Anne

Joan

Monique

Jeanette

Anne 

Cynthia

Alexis

Debbie

Trudy

Kristina

Maria

Mark

Deborah

David

Doug

Luba

Cindy

Mireya

Maggie

Windi

April

Aubri

Bethann 

Deborah

Elizabeth

Judy 

Rachel

Robin

Susie

Vanessa

Nancy

Susan

Lea

Sally

Sandra

Joe

Kelly

Lethie

Puller

Emerald

Lake

Lake

Lalic

Lalley

LaLonde

LaMarca

Lamb

Lambert

Lambert

LaMere

Lamm

LaMonica

Lamons

Lamothe

Lamport

Lancman 

Land

Landau

Landeka

Landice

Landin-Erdei

Landis

Landis-Stermer

Lane

Lane

Lane

Lane

Lane

Lane

Lane

Lane

Lane

Lane

Lang

Lang

Lange

Langer

Langer

Langford

Langston

Lanham

Lanigan

Lanto
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-143 October 2016 

Virginia

Gary

Matthew

Larry

Dan 

Heather

Sandra

Laurie

Linda

Kim

Sharon

Beverly 

Beverlee 

Cristina

Lisa

Sheryl

Barbara

Laura

Anja

Katherine

Lanece

Terry

Janeen

Daniela

Barb

Mary

Jillana

Nicole

Fredricka

Dana

David

Karen

Jacqueline

Michelle

Lava

Leslie

Rhonda

Carol

Leslie

Melissa

Carol

Kathy

Jason

Laolante

Lapid

Lapointe

Lapuyade

Larivey

Lariviere

LaRocca

LaRock

LaRoy

Larsen

Larsen

Larson

Larsson

Larsson

Lashaway

Lashway

Lasley

Lassiter

Lasthaus

Latham

Lathauer

Latschar

Latta

Laudata

Lauer

Lauer

Laufer

Lauren

Laurian

Lauritsen

Laux

Lavender

Laverdure

LaVitola

Lavyn

Law

Lawford

Lawler

Lawrence

Lawrence

Lawson

Lawson

Lawson-St. Hill

Robert

Diana

Ometh 

Marianne

Robin

Katherine

Debby

Lorraine

Crystal

Geoff

Diana

Candy

Daniela

Laraine

Linda

Amber

Camryn

Christine

Debbie

Joan

Rex

Aubrey

Pennie

Laura

Tahoe

Katherine

Dagmar

Carmen

Mary Ann 

Jean 

Carl 

Almides

Bernadete

Ronald

Sylvie

Bettina

Jess

Kathryn

Terri

Denise

Sandra 

Clint

Tijana

Lawton

Laxdal

Layton

Lazarus

Lea

Lea 

Leadbetter

Leal

Leaman

Leavell

Leavitt

LeBlanc

LeBlanc

Lebron

Leckliter

Lee

Lee

Lee

Lee

Lee

Lee

Lees

Lefkowitz

Leifer

Leigh

Leinster

Leischow

Leitch

Leitch

LeMarquand

Lemelin

Lemes

Lemes de Sa

Lemmert

Lemmet

Lemmon

Lemmon

Lemoine

LeMoyne

Lenardson

Lenart

Lendard

Lendvai

Donna

Toni

Mary

Barbara

Deidre

Richard

Anna

James

Jonathan

James

Alice

Annick

Cody

Michelle

Viviane

Jose 

Kathi

Peggy

Michelle

Alex

M.

Deborah

Natalie

Carol 

Jacqueline

Christi

Laura

Beth

Christy

Lacey

Paula

Elizabeth

Jamie

Joann

Julie

Margaret

Michelle

Patricia

Sunny

Shariann

Wendy

Debra

Dominic

Lenhart

Leo

Leon

Leonard

Leonard

Leonard

Leone

Leopold

Leopold

Lep

Lepage

Leparque

LePow

Lerner

Lerner

Leroux

Lese

Lesley

Lesmond

Lester

Leszczynski

Letsche

Leu

Leuenberger

Leuener

Levannier

Levey

Levine

Levine

Levitt

Leweke

Lewis

Lewis

Lewis

Lewis

Lewis

Lewis

Lewis

Lewis

Lewitt

Li

Libby

Libby
LIST OF COMMENTERS

3 Bars Project Final EIS D-144 October 2016 

Wendy

Antonina

Jonine

Esther

Laura

Rhonda

Horacio

Vida

Al

Evelyn

Yee 

Britt

Eric

Michelle

Marie

Aleksander

Kay

Patty

Margit

Erin

Pamela

Sharon

Nancy

Harriet

Liu

Orlando

Vicki

Lyn 

David

Gail

Stu

Shannon's

Deborah

Linda

Robert

Adriana

Michael

Suzie

Alison

Joann 

Tania

Elaine

Treena

Libman

Licastri

Lichtenwald

Lidstrom

Lieberman

Lieberman

Liedo

Liera

Lilla

Lilly

Lim

Lind

Lind

Lind

Lindberg

Lindemann

Linder

Linder

Lindner

Lindquist

Lindquist

Lindsley

Lines

Ling

Ling

Linhares

Linkin

Linkous

Linnane

Linnerson

Lip

Lipke

Lipman

Lippert

Lipsky

Lisman

Little

Little

Litton

Liuzzo

Liva

Livesey-Fassel

Livesley

Cynthia

Deborah

Michelle

Beth

E.

Kitten

Sheila

Sheila

Delphi

Joanna

Stacey

Peggy

Mary Lou

Donna

J.

S.

T.

Lisa

Annette

Carolyn

Robert

Eva

Donna

Rose 

Deborah

Richard

Tamara

Twila

Ki 

Cynthia

Mia

Ed

Tamara

Cheryl 

Susan

Christa

John

Jose

Kathie

Marie

Nelly

Sonia

Andy

Livingston

Livingston

Livingston

Livingstone

Lloyd

Lloyd

Loayza

Lobel

Locey

Lochowska

Lock

Loe

Loesch

Logan

Logan

Logan

Logan

Logic

Lombardi

Lombardi

Lombardi

Lonborg-Madsen

London

London

Long

Long

Long

Longenecker

Longfellow

Longo

Longo

Loosli

Loperfito

Lopes

Lopes

Lopez

Lopez

Lopez

Lopez

Lopez

Lopez

Lopez

Lora

Gina

Rosalie

Elisa

Larry

Jannette

Cathy

Judith

Amanda

Keith

Laurine

Lanelle

Terra

Janis

Dhona

Barbara

Karen

Kay

Nancy

Candice

Melinda

Maryanne 

Cindy

Lorraine

Joni

Silvia

Mary

Bonita

Toni

Diane

Susan

Nicolette

Nenad

Michelle

Anna

Aggie

Jaedra

Tara

Sherry

Sonja

Nils

Lorraine 

Ellaine

Andrew

Lordo

Lorenzen

Lorenzetti

Lorinsky

Loshbough

Louwers

Lovas

Love

Love

Love

Lovelace

Lovelace

Lovi

Lovick

Lowden

Lowe

Lowe 

Lowell

Lowery

Lowery

Lowman

Lowry

Lowry

Lowther

Lozano

Lu Kelley

Lubinsky

Lubka

Luck

Lucking

Ludolphi

Lukac

Lukasiewicz

Lukaszewicz

Lukaszewski

Luke

Lulla

Lund

Lund

Lunde

Luntsford

Lurie-Janicki

Lustig
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-145 October 2016 

Darlene

Jeanette

Maresa

Janet

Kelli

Fran

Sandy

Angela

Kathi

Marilyn

Mike

Terry

Monique

Kelly

Colleen

Meghan

Nilah

Pattie

Theresa

Adrienne

Thomas

Larry

Sherry 

Kerry

Michael

Krista

Kerry

Frances

Chris

Lynette

Melanie

Eileen

Susan

Michelle

Nelson

Karen

David

Laurra

Chelsea

Theory 

Kathy

Heloisa

Gay

Luth

Luttrell

Luzier

Lynch

Lynch

Lynghaug

Lynn

Lyon

Lyons

Lyons

Lyons

Maag

Maas

MacCaulay

MacDonald

MacDonald

MacDonald

MacDonald

MacDonald

MacFarlane

MacFarlane

Machado

Macias

MacInnes

MacIntyre

Mack

Mackenzie

Mackiewicz

MacKrell

MacLagan

MacLennan

Macmillan

MacPhee

Macy

Madariaga

Maddalena

Madden

Maddock

Madison

Madison

Madlem

Madureira

Maestas

Samantha

Mona

Lilithe

Caroi 

Jennifer

Kathleen 

Eileen

Anna

Mary

Margaret

Roberto

Diana

Karen

Romina

Eve

Janet

Rosa

Karen

Jacquie

Vicki

Christina

Jaime

Robi 

Hilary

Katherine

Susan

Austin

Jace

Rebecca

Joseph

Michaelene

Lindsay

Susan

Christine

Jacqueline

Nancy

Teri

Audrey

Cate

Mark

Lida

Nicholas

Kimberly

Maffeo

Magana

Magdalene

MaHarry

Maharry

Mahoney

Mahood-Jose

Maier

Main

Mainelli

Mainetti

Maiocco

Maish

Maja

Major

Maker

Malagisi

Malcolm

Malette

Malick

Malm

Malone

Malone

Malyon

Malzahn-Bass

Mamich

Manchester

Mande

Mandich

Mangarelli

Manion

Mann

Mann

Mannetta

Manning

Manning

Manno

Mannolini

Manochio

Mansfield

Mansouri

Mantas

Manuel

Flavio

Tania

Babs

Diane

Christina

Diane

Debra

Martin

Nan

Shawn

Patricia

Carolyn

Lisa 

Jacobus

Steven

Ann

Zinaida

Jan

Joan

Joel

P.

Patricia

Kathryn

Bryan

Yvonne

James

Dale

Marci

Bev

Susan

Joseph

Christine

Allie

Nina

Cynthia

Jennifer

Nancy

P.

Empathy

Heather

Michael

Sherry 

Amelia

Manzi

Marchand

Marchands

Marciano

Marcus

Marcus

Marge

Margolis

Margraves-Hoover

Mariella

Marino

Marion

Markel

Markesteijn

Markgraf

Markham

Markine

Markkarian

Marks

Marks

Marks

Marlatt

Marlett

Marley

Marley

Marlow

Marlowe

Marmor

Marnewick

Maroc

Marotta

Marquette

Marriott

Marrocco

Marrs

Marrs

Marschel

Marsella

Marsh

Marsh

Marsh

Marsh

Marshall
LIST OF COMMENTERS

3 Bars Project Final EIS D-146 October 2016 

Kay

Laurie

Rebecca

Rose

Jon

Julie

Kim 

Linda

Ann

Cynthia

Gerry

Julie

Melanie

Sherri

Becky

Schuyler

Diane

Amy

Bonnie

Coral

Corrine

Harriet 

Janet

Valerie

Patricia

R.

Joan

A. 

Janet

Nathana

Tracy

Anna

Susan

Cherie

Dawn

Joyce

Kellie

Marla

Ellen

J.

J.

Darice

Dolores

Marshall

Marshall

Marshall

Marteeny

Martell

Martenson

Marthens

Marticek

Martin

Martin

Martin

Martin

Martin

Martin

Martin 

Martin 

Martin-Brodak

Martinez

Martinez

Martinez

Martinez

Martinez

Martinez

Martinez

Martins

Martire

Martorano

Marts

Martucci

Marunich

Marzano

Mashevcich

Mashevcich

Mason

Mason

Mason

Mason

Mason

Mass

Massarini

Massetti

Massey

Massey

Justine

Mary

Ramie

Gene

J. 

Sandra

Barbara

Carole

Rita

Sue

Lynette

Vicky

Paul

Ashley

Donna

Nan

Phillip

Rogene

Cinzia

Georgia

Karen

Anne Marie

Laurie

Jerry

Alana

Casee

Marygrace

Cactus

Chris

Ellen

Jackie

Marisol

Ramona

Monica

Donna

Margaret

Ann

Gloria

Teresa

Tasunka

Darius

Katy

Lisa

Massey

Massey

Massie

Massion

Masters

Materi

Mathes

Mathis

Mathues

Mathys

Maton

Matsui

Mattera

Matthews

Matthews

Matthews

Matthews

Matthews

Mattiace

Mattingly

Matulina

Matzko

Mauler

Mawhorter

Mawson

Maxfield

Maxwell

May

May

May

May

Mayell

Mayer

Mayes

Mayfield

Maynard

Mayo

Mayo

Mays

Maza

Mazaheri

Mazoch

Mazur

Susan

Janet

Lisa

Rebecca

Janet

Helen

Carol

Jennifer

James

Cheryl

Elaine

Nancy

Bonnie

Kathleen

Toni

Keith

Rosa

Diane

Susan

Mary 

Georgina

Julie

Sue

Lorraine

Betsy

Cynthia

Walter

Elizabeth 

Harriet

Jeff

Ellen

Mary

Bonny

Devin

I. 

Jacque

Jean

Sandy

Virginia

Lorie

Bernadette

Terese

Jan

Mazza

Mazzarini

Mazzola

McAlary

McAlister

McAllister

McArdle

McArdle

McArthur

McAtee

McAuliffe

McBride

McCabe

McCabe

McCalley

McCampbell

McCann

McCarter

McCarter-Wade

McCarthy

McCartney

McCarty

McCasey

McCawley

McClain

McClain

McClatchey

McCleary

McCleary

McCollim

McConnell

McConnell

McCormick

McCormick

McCormick

McCormick

McCormick

McCoy

McCoy

McCracken

McCrea

McCready

McCreary
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-147 October 2016 

Gail

Jim

Kara

C.

Graham

John

Karen

Nancy

Rita

Stacey

Susan

Rosemary

Andrew

Margaret

Joanne

Vandy

Michele

Sandra

Carol

Joy

Martin

Jeanne

Colleen

Alice

Hollie

Cindy

Karen

Brian

William

Margaret

S.

Judith

Barbara

Malva

Zena

Patricia

Diane

Marianne

Tracy

Christina

Katherine

Shelley

Patricia

McCredie

McCue

McCullar

McDonald

McDonald

McDonald

McDonald

McDonald

McDonald

McDonald

McDonald

McDonnell

McDowall

McEldowney

McEntee

McEwen

McFerran

McGee

McGeehan

McGinty

McGladdery

McGlenister

McGlone

McGough

McGovern

McGrady

McGranahan

McGuigan

McGuire

McHugh

McHugh

McInnis

McIntosh

McIntosh

McIntosh

McIver

McJunkin

McKay

McKay

McKee

McKee

McKee

McKelvie

Deki

Cathy

Debbie

Sharon

Linda

Kate 

Terri

Susan

Cynthia

Elizabeth

Patricia

Anah

Mair

Maureen

Deann 

Diana

Amanda

Laurie

Colleen

Brenda

Stephanie

Doris

Donna

Kathryn

Janice

Myron

Stephen

Sharon

Marta

Suzanne

Katrina

Ernest

Patricia

Janique

Tara

Judith

Joan

Suzana

Mona

Gwendolyn

Dawn

Tim

Francine

McKenney

McKesson

McKitrick

McKnight

McLain

McLaughlin

McLaughlin

McLenaghan

McLendon

McLinton

McMahan

McMahon

McNamara

McNamara

McNeal

McNeel

McNeill

McNevan

McNicoll

McNorton

McQueen

McQuiddy

McQuirter

McRoden

McShane

McVeigh

Mead

Meagher

Meares

Meathrell

Meddings

Medeiros

Medeiros

Mednis

Meehan

Meek

Meeker

Megles

Mehas

Mehring

Meier

Meier

Meinelschmidt

Ken

Margaret

Linda

Vikki

Lisa

Jim

Kathryn

Gwenn

Cecilia

German

Tatiana

Virginia

Vince

Lynn 

Keith

Michele

Mary

Rosemary

Olga

Bunni

Ralph

Adele

Judy 

Sandra

Jean

Wendy

Brian

Nancy

Daniela

Susan

Constance

Pat

Bonna

Harvey

Claire

Dianne

Moranda

Sarah

Lori

Priscille

Jeanette

Tina

Chris

Meinhardt

Meinschein

Melichar

Melnick

Melone

Melton

Melton

Meltzer

Mendez

Mendez

Mendez

Mendez

Mendieta

Menefee

Menteer

Mercer

Merchant

Meredith

Merinova

Merk

Merlino

Meroni

Merrick

Merrill

Merritt

Merritt

Mesich

Mesich

Mess

Messerschmitt

Messina

Metsinger

Mettie

Metzger

Metzler

Meyer

Meyer

Meyers

Meyrick

Meystre

Micca

Michael-Dahlmann

Michaelides
LIST OF COMMENTERS

3 Bars Project Final EIS D-148 October 2016 

Cheryl

MaryLynn

Elaine

Judye

Raelyn

Kim 

Marilyn

Janine

Wayne

I.

Anne

Susan

Jeannine 

Lisa

Liz

Barbara

Sandra

Amanda

James

Lesli

Marilyn

Renee

Julia

Ljiljana

Arlene

Ann

Betsy

Angelita

Brad

Carol

Carolyn

Catherine

Denise

Devon

Diane

Donna

Eileen

Elaine

Helen

Jennifer

Jessica

Joanne

Kathy

Michaelis

Michaelis

Michaels 

Michaels 

Michaelson

Michels

Mick 

Mickley

Middleton

Mies

Migone

Migues

Mihalek

Mikolich

Mikre

Milano

Mileham

Miles

Miles

Miles

Miles

Miles

Milford

Milic

Miljour

Millan

Millard

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Linda

Marlene

Nancy

Ruth

Sandra

Sherie

Sherriey

Tanja

Vicky 

Vince 

Stephanie

Treena

Robert

Irene

Lee Anne

Melayne

Shirley

Martha

Lisa

Nikolaos

Bruno

Joanna

Alexander

Barb

Curt

Marcia 

Ivana

Ila

Crystal

Natalia

Lupyta

Urbain

Susan

Janet

Joanne

Alicia

Bo 

Cheryl

Crystal

Desiree

Elizabeth 

Jan

Julie

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Miller

Millet

Millett

Milligan

Mills

Mills

Mills

Mills

Milne

Milo

Milonas

Milone

Miloszewska

Minaev

Minar

Miner

Miner

Minic-Lukac

Minton

Mintz

Miramontes

Miranda

Mireille

Misa

Mishler

Mitcham

Mitchell

Mitchell

Mitchell

Mitchell

Mitchell

Mitchell

Mitchell

Mitchell

Linda

Margaret

Marilynn

Robert

Stephen

Lisa

Mihaela

Michael

William

Larry

Eugenia

Jean

Rachel

Cindy

Deidre

Jan

Rebecca

Christopher

Amanda

Michael

Julia

Kaye

Erika

Lea

Suzanne

Madelaine 

Jean

Jean

Phyllis

Judith

Jane

Irene

Aggie

Suzi

Dean 

Janis

Katherine

Marni

Anthony

June

Deborah

Marti

Marjie

Mitchell

Mitchell

Mitchell

Mitchell

Mitchell

Mitrano

Mitrea

Mitsuda

Mittig

Mix

Mixon

Mixon

Mobley

Moczarney

Moderacki

Modjeski

Moed

Moehl

Moeller

Moeller

Moes

Mohammadi

Mohos

Mohr

Mohr

Moir

Molinari

Mollack

Mollen

Monarch

Monday

Moneyhun

Monfette

Monk

Monroe

Monstad

Montague

Montanez

Montapert

Monteleone

Montero

Montoya

Montrose
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-149 October 2016 

Margaret

Lenny

Michele

Benita

Catherine

Colleen

Gayle

J.K.

Janet

Jessica

Pauline

Robert

Sally

Thomas

Tony

Rey

Marco

Tanya

Brenda

Dee

Judy

Michael

Sally

Pam 

Kathleen

Rosalie

Diane

Angel 

Linda

Joni

Alexa 

Michelle

V.

Carla

Raphael

Dennis

Mary

S.

Jan

David

Ana

Jean 

Michele

Monty

Moon

Mooney

Moore

Moore

Moore

Moore

Moore

Moore

Moore

Moore

Moore

Moore

Moore

Moore

Mora

Morales

Morales

Moran

Moran

Moran

Moran

Moran

Morarre

Moraski

More

Morency

Moreno

Morero

Moretti

Morgan

Morgan

Morgan

Morin

Morin

Morley

Morley

Moroney

Morong

Morres

Morris

Morris

Morris

Wendy

Sue

Christine

Hank

Lynn 

Maureen

Ali

Vivianne

Theresa

Lance

Bettina

Rochelle

Connie

Nicole

John

Marcie

Kim 

Hussein

Carine

Helene

Cary

Tamara

K.

Theresa

James 

Diane

Jan 

Sharon

Julie

Margy

Michael

Amanda

Audrey

Bambi

Alice

Vinny

Laura

Sharon

Sherrie

Dorothy

Lynn 

Jaime

Donald

Morris

Morrison

Morrissey

Morrow

Morrow

Morse

Mosa

Mosca-Clark

Moscowitz

Moseley

Moser

Moser

Moses

Moss

Moszyk

Mott

Motyka

Mourtada

Moustier

Mowka

Moy

Moyer

Mueller

Muir

Mulcare

Mulhern

Mulholland

Mullane

Mullen

Mullen

Mullen

Muller

Muller

Muller

Mullins

Mullins

Mulvaney

Mulvaney

Munday

Munderloch

Mundinger

Munera

Munn

Laura

Allysa

Linda

Jo 

Maki

Laura

Elizabeth

Marian 

Becky

Betty

Cynthia

Karen

Linda

Mary

Michelle

Molly

Paula

Bonnie

Cristy

Kathy 

Lisa

Marcia

Casey

Anna

Keli

Mary

Teresa

Josee

Janis

Sandra

Ram 

Kimberly

Dorrie

Bob

Elizabeth

Alexandra

Barbara

Isabel

Theresa

John

Gabriele

Patricia

Lina

Munoz

Muntean

Muntner

Munz

Murakami

Murchison

Murdoch

Murez

Murine

Murphy

Murphy

Murphy

Murphy

Murphy

Murphy

Murphy

Murphy

Murray

Murray

Murray

Murray

Murray

Mushkin

Mxitarova

Myers

Myers

Myers

Nadeau

Nagengast

Naidich

Nair

Najarian

Nang

Napier

Napier

Napoleon

Nardone

Nash

Nason

Nattrass

Naumann

Nazzaro

Nedergaard Hjorth
LIST OF COMMENTERS

3 Bars Project Final EIS D-150 October 2016 

Janet

Grace

Miriam

David

Janet

Laura

Mary

Margaret

Alexandra

Anna

Carrie

Cecelia

Connie

Hilleary

Jackie

Judith

Julie

Mary

Pam 

Rebecca

Rita

Mandy

Justina

Sue

George

Lisa

Leanne

Ruby

Debbie

Kelly

Karen

Keri

Julia

Mary

Nancy

Marleen

Kandace

Laura

Shelly

Maureen

Lisa 

Anita

Jacqueline

Needler

Neff

Neff

Neiberger

Neihart

Neiman

Neivens

Nelmes

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Nelson

Neltner

Nemoy

Nerad

Neste

Neste

Nester

Nester

Netardus

Nettesheim

Neubauer

Neuling

Neumaier

Neumann

Neumann

Neus

Nevin

Nevins

Newell

Newey

Newkirk

Newman

Newman

Kathy

Kristy

Terry

Emain

Tuan

Chris

Roxanne

Carol

Rey

Bonni 

Lisah

Pamela

Monique

Jeanette

Nicola

Sarah

Patricia

Seiglinde

Susanna

Claudia

Katherine

Antonella

Irene

Sonja

Susann

Marie

Amir

Jennifer

Kathy

Robert

Martha

James

Letitia

Laurence

Katherine

Tina

Maria

Cheryl

Jill

Jane

I.

Marc 

Jasmine

Newman

Newman

Newman

Ng

Nguyen

Nicholas

Nicholas

Nichols

Nichols

Nicholson

Nicholson

Nickell

Nickerson

Nicola

Nicolai

Nicoll

Nicolosi

Nieberle

Nieddu

Niehues

Nield

Nielsen

Nielsen

Nielsen

Nielsen

Nieves

Niknam

Nitz

Nix

Nobrega

Nochimson

Noe

Noel

Nokel

Nolan

Noland

Nolen

Noone

Nord

Norling

Norris

Norris

North

Lisa

Emma

Laurie

Thea

Paul 

Denise

Collette

Cristina

Jan

Sylwia

Deborah

Noris

Julie

Diane

Annabelle

Dorothy

Carl

Candace

Karen

Rebecca

Donna

Carolyn

Dennis

Loreen

Kathryn

Kim

Barbara

Chris

Sherry

Mary 

Siochain

Ellen

Laura

Norma

Anne

Joanne

Jessica

Carl

Mark

Edith

Iwona

Jayme

Jeanne

Northrup

Norton

Norton

Norton

Norup

Nostro

Novak

Novelo

Novotny

Nozderko

Nudelman

Nunez

Nurenberg

Nushawg

Nye

Nylen

Nylund

Oakes

Oakes

Oberlin

O'Berry

O'Brien

O'Brien

O'Brien

Obryan

O'Bryan

O'Cassel

Ocean

Ochoa-Rounkles

O'Connel

Oconnor

O'Connor

O'Connor

Odell

O'Donnell

O'Donnell

O'Doski

Oerke

Offerman

Ogella

Ogg

Oglesby

Ogorzaly
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-151 October 2016 

Danielle

Carol

Lilli

Sam

Audrey

Kimberly

Doris

Barbara

Elizabeth 

Mariana

Roberto

L.

Leslie

J.JoAnn

Gloria

Debbie

Jessica

Mare

Sufi

Angela

Renie

Jennifer

Maureen

Bonnie

Kay

Ellen

Fiona

Tim

Frank

Desire

Carol

Phyllis

Ilene

Triinu

Valerie

Karen

Joanne

Elene

Danielle

Rosa

Janet

Ginger

Jayne 

Ohanesian

Ohlendorf

Ohse

Oksner

Okubo

Okumoto

Oldham

O'Leary

Oliveira

Oliveira

Oliveira

Oliver

Oliver

Ollar

Olman

Olmstead

Olnhausen

Olsen

Olsen

Olson

Olson

O'Neal

O'Neal

O'Neil

O'Neil

O'Neill

O'Neill

O'Neill

Onishuk

Oosthuizen

Orbino

O'Reilly

Orem

Org

Ornatowski

Ornelas

Oroark

O'Rourke

Orr

Orsetti

Ortega

Ortiz

Ortiz

Arlene

Tina

Linda 

Ewa

Susen

Claudia

Sherry

Julie

Michael

Kathleen

Kathleen

Sarah 

Annmarie

Lynn 

Mick

Fran

Velma 

Kristin

Dalila

Patti

Judy

Annette

Steve

Jane

Karen

Nada

Sibel

Dogan

Paula

Barbara

Lisa

Susan

Patti

Theodosia

Wendy

Beverly

Grace

Don 

Sergio

Cinzia

Lane

Deb

Anne

Ory

Osborne

Osburn

Oscarsdotter

Oseth

Osorio

Oster

Ostoich

Ostrosky

O'Sullivan

O'Sullivan

Oswald

O'Toole

O'Toole

Otten

Ottinger

Ottmar

Otto

Ouai

Ouderkirk

Oust

Overstreet

Overton

Owens

Owens

Owens

Ozer

Ozkan

Ozzello

Pabisz

Pace

Pacheco

Packer

Paclawskyj

Pacquette

Pacquin

Padelford

Paden

Padilla

Paganuzzi

Page

Paget

Pagliaro

Alexis

Dice

Vera

Laura

Tami

Michele

R. 

Michelle

Linda

Ruth

Rosiris

Theresa

April

Sara 

Kathy

Melodie

Alexandra

Rachael

Mary

Laurie

Loretta

Heather

Julie

Marco

Al

Anthony

Julie

Neal

Valerie

Daphne

Evelyn

Lonna 

Molinda

Patricia

Sandra

Terrence

Marion

Tim

Kirsten

Stephen

Nancy

Sharon

Jane 

Pagoulatos

Pain

Paisner

Pajot

Palacky

Palermo

Palermo

Palladine

Palm

Panella

Paniagua

Pankey

Paoff

Paoluzzi

Papineau

Papoojian

Pappano

Pappano

Paquet

Paquin-Leet

Paraguassu

Paravella

Parcells

Pardi

Paris 

Parisi

Parisi

Parisi

Park

Parker

Parker

Parker

Parker

Parker

Parker-Turnage

Parkhurst

Parkyn

Parmly

Parris

Parsons

Partin

Partington

Pascarella
LIST OF COMMENTERS

3 Bars Project Final EIS D-152 October 2016 

Eric

D. 

Rashid

A.

Arlene

Barry

Duane

Tina

Jan

Lorraine

Martina

Shelley

Sherry

Barbara

Karin

Rashida

Terry

George

Christi

Gabi

Giana

Elizabeth

Elizabeth

Nancy

Juliet

Nancy

Rose

Tia

Cindy

Joan

Sharon

Ashley

Lisa 

Jenna

Elaine

Diane

Jim

Benita

Mark

B.

Susan

Roberto

Apollonia

Pash

Pasha

Patch

Pathen

Patoray

Patrick

Patrick

Patrick

Patterson

Patterson

Patterson

Patterson

Pattillo

Patton

Patze

Paul

Pauls

Pavlinos

Pawlak

Payne

Paz

Peach

Peacock

Pearlmutter

Pearson

Pearson

Pearson

Pearson

Peart

Peaslee

Peck

Pedersen

Pedersen

Pelella

Pelke

Pell

Pell

Pelletier

Peltan

Pelton

Peltonen

Penaherrera

Peniceni

Marsha

Barbara

Janie

Lisa

Kathye

Natalie

Jana

Paul

Connie

Karen

Julie

Dan

Elena

Jaime

Janet

Julie

Marcia

Susan

Lela

Nina

Barbara

Joel

Lela

Nancy

Eleanor

Ralph

Sue

Alison

Cyrle

Lisa

Rita

Leslie

Amy

Maria 

Alice

Ann

Dannette

Elaine

Stefan

Al

Alfred

Beverly

Carrie

Penner

Pennington

Pennington

Penny

Pepka

Pepper

Peppin

Peraino

Perala

Peralta

Perco

Perdios

Perez

Perez

Perez

Perez

Perez

Perez

Perin

Perino

Perkins

Perkins

Perkins

Perkins

Perkis

Pero

Perrin

Perry

Perry

Perry

Persichetty

Persons

Pestritto

Peteinaraki

Petersen

Petersen

Petersen

Petersen

Petersen

Peterson

Peterson

Peterson

Peterson

Kristina

Lorri

Maree

Nicole

Judy

Loretta 

Laetitia

Rositsa

Shari

Sandra

Mike

Lynn 

Maryke

Mary

Angela

Kevin

Allison

Barbara

Janice 

Loni

Laura

Linda

Tami

Neysa

Kimberly

Nina

Robert

Rita

Catherine

Nancy

David

Dominika

Ewa

Ivette

Gloria

Frank

Lisa 

John

Kayla

Mason

Melissa

Iornaa

Annette

Peterson

Peterson

Peterson

Peterson

Peterson 

Peterson 

Petit 

Petkova

Peto

Petranek

Petro

Petronella

Petruzzi

Pettengill

Petty

Petty

Petzko

Petzko

Pfeiffer

Phariss

Pheasant

Phelan

Phelps

Phillippi

Phillips

Phillips

Phillips

Philo

Phipps

Phipps

Photos

Piasecka

Piasecka

Picazo

Picchetti

Pickens

Pickens

Pickett

Pickford

Pickholz

Pickle

Pickrell

Pieniazek
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-153 October 2016 

E.

Beatrice

Evelyn

Tanya

Isabelle

Catherine

Alba

Sharon

Kathy

Harry

Vikki

Debra

Judy

Meryl

Linda 

Juliann 

Angela

Sandra

Victoria

Jolene

Karen

Bryna

Carolyn

Leah

Patricia

Ray

Franklin

Margaret

Debra

Marilyn

Madeline

Piotr

Wanda

JoAnn 

Jamie

Annette

Katherine

Charlene

Jane

Cheryl

Alice

Michelle

Pamela

Pierce

Pierre 

Pietrowski-Ciullo

Piker

Piller

Pillsbury

Pillwein

Pilon

Piltz

Pinand

Pingle

Pinkham

Pinkham

Pinque

Pinsent

Pinto

Piojda

Pirro

Pitchford

Pitman

Pitt

Pizzo

Plaisance

Plant

Plasky

Plasse

Platizky

Plese

Plishka

Plott

Plucinski

Plucinski

Plucinski

Pochciol

Poe

Poerschke

Poff

Poglitsch

Poklemba

Pokomo

Polesky

Poliart

Polizzi

Janelle

Joanna

Sheri

Deb

Kathy

Susan

Kim

Lesa

Carole

Margaret

Kevin

Katie

Kelly

Kelly

Nancy

Ailsa

Carol

Kaye

Susan

Christina

Lina

Jeanne

Susan

Steven

Doris

Heather

Laurie

Richard

Linda

Anne

Mona

Alexis

Miyuki

Peggy

Robin

Inara 

Laura

Laurel

Nina

Sandra

Paula

Claudia 

Emma

Pollock

Poloczek

Polski

Pomfret

Pomicter

Pommer

Pond

Pond

Pooler

Pooler

Popeck

Popiel

Popp

Popp

Porcino

Porter

Porter

Porter

Porter

Posey

Poskiene

Posner

Posner

Potosky

Potter

Potthoff 

Pottish

Potts

Pouncey

Powder

Powe 

Powell

Powell

Powell

Powell

Powers

Powers

Powers

Powers

Powers

Powers 

Prado

Prascio

Kristen

Yvonne

Kris

Robin

Jennifer

Catherine

Bill 

Mary

Charlotte

Maxine

Meredith

Sherry

Steven

Jeanne

Kathryn

Isabelle

Hellen

Suda

Paula

Dolores

Lauri 

Leoncio

Paula

Jana

Nicholas

Jennifer

Andrey

Marlene

Richard

Susan

Jean 

Robert 

Elena

Norman

Frederic

Stephanie

Christine

Lisa

Deeanne

Paula

Holly

A.

Kevin

Prasek

Pratt

Preslan

Pressler

Prezant

Preziosi

Price

Price

Priddy

Priest

Priestley

Prince

Prince

Principe

Prins

Pritchett

Prodocimo

Prohaska

Propst

Proubasta

Provencher

Provoste

Pruner

Pruse

Prychodko

Pryor

Pshenitskiy

Puaoi

Puaoi

Puaoi

Public

Puca

Pucci

Pugliese

Pulcini

Pulfer

Puliselic

Purcell

Purchase

Purviance

Putnam

Puza

Quail
LIST OF COMMENTERS

3 Bars Project Final EIS D-154 October 2016 

Joel

Susan

Nthalie

Dana

Mary

Maureen

Elise

Heather

Ursela

Rebecca

Elena

Debi

Heike 

Irene

Jocelyn

Laura

Patricia

MarieElaina

Cecelia

Alicia

Kelli

Dee

Christina 

Debra

Lisa

Julianne

Karen

Armando

Mary Lou

Jaime

Joann

Paul

Carmen

Dorene

Debra

Linda

Monica

Mary 

Shirley

Caroline

Gordon

Melanie

James

Quaintance

Querze

Quesnel

Quillman

Quimby

Quinlan

Quinn

Quinn

Rabe

Rabinowitz

Racansky

Rachel

Rade

Radsack

Rafferty

Raforth

Ragazzon

Rago

Ragusa

Rahe

Rain

Rainey

Rainwater

Rajchel

Ramaci

Ramaker

Rambat

Ramirez

Ramirez

Ramos

Ramos

Ramos

Ramsey

Randall

Randazzo

Randel

Randell

Randolph

Randolph

Rankin

Rankin

Ransom

Ranstrom

Pearl

Linda 

Shannon

Karen

Heather

Jackie

Lauren

Tim

Stanley

Carol

Gigi

Leslie

Bobbie

Becky

Elaine

Dale

Sa

Charlene

Tara

Janice 

Laine

Maria

Fran

Ann

Tracy

Vicki

Stephanie

Laura

Lauren

Mark

Kathy

Toby

Lynn

Ella

Kathleen

Lenore

Raelynn

Toni 

Maria 

Evelynb

Laura

Nora

Vanessa

Ranstrom

Rappoport

Ratliff

Ratzlaff

Raubenheimer

Raven

Rawlings

Rawlings

Rawlins

Ray

Ray

Ray

Rayburn

Raymond

Raynor

Rdiehart

Re

Reader

Reale

Reamer

Reams

Reato

Recca

Reddick

Reddig

Redding

Redgate

Redgrave

Rednour

Reed

Reese

Reese

Reeser

Reeves

Reeves

Reeves

Reeves

Reeves

Regam

Regan

Regan

Regan

Register

Sonia

Gary

Ingrid

Robyn

Christine

Nina

Susan

Kathleen

Alta

Rose

Shirley

Joan

Jennifer

Diane

James

Deb

Maria

Lynore

Angela

Ania

Cornelia

Cheryl

Matt

Edward

Ann

Joe

Kylie

Cynthia

Rebecca

Sandra

Shannin

Karin

Barbara

Rocky

Cathy

Reynaldo

Audrey

Judith

P.

Kimberly

Donna

Michelle

Susan

Rego

Rehs

Reich

Reichert

Reid

Reid

Reid

Reifke

Reimund

Reina-Rosenbaum

Reinartz

Reinbott

Reinert

Reinhold

Reinke

Reis

Reis

Reiseck

Relder

Religa

Relyea

Remington

Remmington

Rendon

Rennaker

Renneke

Renner

Rennick

Rens

Repiquet

Resendes

Rettig

Reukauf

Reuter

Revis

Reyna

Reynolds

Reynolds

Reynolds

Rhodemyre

Rhodes

Rhodes

Rhynhart
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-155 October 2016 

Bodil

Sherida

Tina

Marie

Angel

Karol

Laura

Kimberly

Deborah

Jody

Caroline

Connie

Diane

Fay

Keisha

Stacey

Susan

Teri

Virginia

John

Ionna

Amanda

Elisabeth

Carolyn

Barbara

Lynette

Iva 

Carolyne

Carlene

Heather

Betsy

Bill

Janet

Nina

Kathy

Barbara

S

Karen

Nancy

Kristin

Mary

Nicole

Callie

Ribel

Ribordy

Ricb

Riccardi

Ricci

Rice

Rich

Richard

Richards

Richards

Richardson

Richardson

Richardson

Richardson

Richardson

Richardson

Richardson

Richardson

Richardson

Richkus

Richmond

Richter

Richter

Ricketts

Rickus

Ridder

Riddle

Rideg

Ridenour

Rider

Ridge

Ridgeway

Rieben

Riechers

Riemer

Ries

Rietz

Rigatti

Riggins

Riggs

Riggs

Rigney

Riley

Liz

Geraldine

Roberta 

Cindy

Suzanne

Joanne

Mark

Calvin

Philip

Mary

Teresa

Will 

Alexandria

Javier

Macarena

Robert 

Doug

Carol

Joanne

Ann

Chris

Jolene

Nancy

Julaine

Claudia 

Deborah

Irma

Jan 

Kathy

Kimberly

Lynne

Sandra

Emilyn

Karen

Les

S.

Gail

Jennie

Jill

Kenneth

Tamela

Tina

Barbara

Riney

Ring

Ringstrom

Riplinger-Konrath

Rish

Rist

Rist

Rittenhouse

Ritter

Rivas

Rivas

Rivas

Rivera

Rivera

Rivera

Rivera

Riverdale

Rivielle

Roach

Robarge

Robbins

Robbins

Robbins

Roberson

Roberts

Roberts

Roberts

Roberts

Roberts

Roberts

Roberts

Roberts

Roberts 

Roberts 

Roberts 

Roberts 

Robertson

Robertson

Robertson

Robertson

Robertson

Robichaux

Robinson

Brenda

Cathy

Dameta

Joyce

Julie

Lois

Margaret

Ron

Shirley

Fernando

April

Cheryl

Candace

Nidia

Sylvie 

Jessica

Paulinka

Dianne

Marcia

Paula

Christian

Norma

Terrell

Nola 

Kelly

Mary

Stephani 

Amber

Angela

Iliana

Isabel

Jamie

Nuria

Selene

Steven

Susan

Nancy

Margaret

Michelle

Lynn

Diana

Shirley

Suzanne

Robinson

Robinson

Robinson

Robinson

Robinson

Robinson

Robinson

Robinson

Robinson

Robles

Roby

Rocca

Rocha

Rocha

Rochat

Rocheleau

Rochemont

Rochenski

Rock

Rock

Rocklein

Rockman

Rodefer

Roden

Rodgers

Rodgers

Rodin-Zinn

Rodman

Rodrigues

Rodriguez

Rodriguez

Rodriguez

Rodriguez

Rodriguez

Rodriguez

Rodriguez

Roeber

Roebuck

Roesch

Rogalsky

Rogers

Rogers

Rogers
LIST OF COMMENTERS

3 Bars Project Final EIS D-156 October 2016 

Tracey

Laurel

Paola

Hank

Jelica

Mike

Angelika

Peggy

Susa 

Pat

Jennie

Mary Ann

Gwen

Jennifer

Elke

Bettina

Susan

Arleen

Elizabeth 

Jessie

Tammy

Everlyn

Greg

Margarita

David

Dawn

Diana

Elizabeth 

Karen

Bill

Helene

Rebecca

Jon 

Henry

Zachary

Katrin

Adrienne

Beth

Bruce 

Jan

Traci

Wendy

Jean

Rogers

Rohrer

Rojas

Roland

Roland

Rolbeck

Roll

Rollie 

Rollison

Rollo

Rolon

Roma 

Romani

Romans

Romer

Romero

Romersa

Rooney

Root

Root

Root

Rorick

Rosas

Rosberg

Rose

Rose

Rose

Rose

Rose 

Roseberry

Rosen

Rosenberger

Rosenblatt

Rosenfeld

Rosenfeld

Rosinski

Ross

Ross

Ross

Ross

Ross

Ross

Ross 

Kate

Marsha

Bernice

Daniela

Laura

Paul 

Deborah

Ada

Doris

Jamie

Monika

Maria

Richard

Tamara

Sharon

Jodi

Edward

Susanne

Donna

Susan

Ed 

Ann 

Abraham

Louise

Patty

Vickie

Amanda

Linda

Gina

Marianne

Kat

Merle

Serena

Janet

Carole

Liliana

Elena

Lori

Margaret

Patti

Rita

Kathy

Carhy

Ross 

Ross 

Rossana

Rossi

Rossi

Rossilli

Rossum

Rote

Roth

Roth

Roth

Rothstein

Rothstein

Rousseau

Routledge

Rowe 

Rowell

Rowell

Rowland

Roy

Royko

Roylance

Rozman

Ruck

Rucker

Rudd

Rudisill

Rudman

Rueck

Ruegg

Ruelle

Ruf

Ruffilli

Ruggiero

Ruise

Ruiz

Rumiantseva

Rumpf

Runfors

Ruocco

Ruocco

Ruopp

Ruperti

Kelly

Bob

Julia

Terri

M.

Robin

John 

Janet

Darlene

Kim 

Kitty

Mary

Richard

Theresa

Wayne

Cindy

Joanne

Frank

Robin

Susan

Amandine

Elaine

Vera

Patty

Melody

Miriam

Rodolfo

Eve

Charlotte

Marie

Don

Jean 

R.

Emanuela

Leyda

Lisa 

Rocio

Diane

Natasha

Kinga

Mary

Lynn

Dorian

Rushby

Rusk

Russell

Russell

Russi

Russo

Rutherford

Rutigliano

Ryan

Ryan

Ryan

Ryan

Ryan

Ryan

Ryan

Rybarczyk

Ryczak

Rydzinski

Rysavy

Saari

Sablonnieres

Sabotka

Sadkovsky

Saffran

Safken

Sagania

Sagardua

Saglietto

Sahnow

Saint

Saito

Saja

Sakiyama

Sala 

Salamanca

Salazar

Salazar

Salek

Salgado

Salierno

Salomon

Salzberger

Samaniego
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-157 October 2016 

Max Sampson Sandra Schaefer Jean Schmitz

Tara Samra Adrianne Schafer Christine Schneebeli

Debbie Sams Helen Schafer Caitlin Schneider

Sharon Samuelson Maggie Schafer Gretchen Schneider

J. San Diego Julie Schampel Linda Schneider

Sofia Sanborn Karen Schams Lucy Schneider

Angela Sanchez Delia Schamsai Lynn Schneider

Naila Sanchez Candy Schanks Maria Schneider

Mike Sand Victoria Schanzle Sharon Schneider

Renae Sandber Cathy Schaupp Douglas Schneller

Martina Sander Nancy Schechterle LeeAnna Schniebs

Kari Sanderson Sue Schedin Rosa Scholes

Leigh Sanderson Norman Scheele Barbara Scholl

Julia Sandler Stephanie Scheetz Nick Scholtes

Thomas Sandman Ken Schefter Sandra Schomberg

Adele Sands Maria Scheibl Tamara Schrama

Denise Sands Angelika Scheidt Kristin Schroeder

Sarah Sanford Candice Schellenger Stephanie Schubert

Gloria Santillo Wenke Schellhas Darlene Schueler

Eloy Santos Charles Schenck Crystal Schuh

Saskia Santos Michelle Schenck Lois Schuler

Aldana Santto-Quinnell Kathie Schenk Theresa Schulke

Anna Santucci Cheryl Scher Mary Schultz

GinaMarie Sapanaro Elizabeth Scherbak Amy Schumacher

Diane Sapone Deborah Scherrer Brandy Schumacher

Steven Sapp Renate Schewcyzk Cindy Schumacher

Linda Sapp-Cox Linda Schiavo Donna Schutter

Robert Sargent John Schill Bettina Schwan

Julie Sasaoka Donna Schiller Brock Schwartz

Cassandra Sather Christy Schilling Diane Schwartz

Liz Sauer Linda Schimpf Maxine Schwartz

Alexandra Saulino Cindy Schlener Sibylle Schwartz

John Saunders Sybil Schlesinger Susan Schwartz

Mary Savage Barbara Schlitz Kurt Schwenk

Judith Savard Olivia Schlosser Teena Schwering

Ellen Sawyer

Lise Sayer

Linda Saylor

Melody Scamman

Kelley Scanlon

Belinda Scarborough

Alayne Schaefer

Norma Schaefer

Darlene Schmall

Marti Schmauss

Eva Schmelzer

Jacqui Schmidt

Ron Schmidt

Shelli Schmidt

Sylvia Schmidt

Heather Schmitz

Casey Schynaible

Kimberly Scibetta

Charlotte Scoble

Paola Scodellari

Mary Scollin

Joseph Scorcia

Barbara Scott

David Scott
LIST OF COMMENTERS

3 Bars Project Final EIS D-158 October 2016 

J. David

Jennifer

Judith

L.J.

Marty 

P.

Shannon

Theresa

Joan

Ann

P.

Sheila

Bar 

Kathleen

Linda

Cynthia

Ann

Kathy

Debra

Frank

Ellen 

Jetera

Kathy 

Gabby

Angeles

Sharon

Ginger

Rob 

Meg

Michelle

Toni

Diane

Aaron

Zoe

Julie

Sonia

Gabriella

Nina

Ruth

Carole

Karen

Anne 

Char 

Scott

Scott

Scott

Scott

Scott

Scott

Scott

Scott

Scott 

Scotti

Scoville

Seaman

Sears

Sears

Sebastian

Sebregts

Seccombe

Seckinger

Secor

Seewester

Segal

Sehart

Seitzer

Sekuterski

Selgas

Selinski

Selman

Seltzer

Selzer

Semaan

Semple

Senatore

Senegal

Seppi

Septrion

Sequeira

Serafino

Serman

Serra

Serras

Sessions

Settanni

Settle

Greg

Susan

Caroline

Michelle

Susan

Sue

Jacqueline

Priscilla

Tamara

Melissa

Floss

Gerald

Bennie

Elsy

Heather

Evan

Anita

VickyLou

Andrew

Cynthia

June

Linda

Jennifer

Diane

Charles

Fred 

Ingrid

Jessica

Linn

Pamela

Phyllis

Susan

Karen 

Linda

George 

Jeanne

Duane

Denise

Diana

Shirley

Nancy

Justine

Ramanda

Settle

Setzke

Sevilla

Sewald

Sewell

Sexton

Sgroi

Shade

Shaffer

Shaffer-O'Connell

Shahbegian

Shaia

Shalbetter

Shallman

Shambarger

Shamoon

Shapiro

Sharer

Sharp

Sharp

Sharp

Sharp

Shatraw

Shaughnessy

Shauver

Shaw

Shaw

Shaw

Shaw

Shaw

Shaw

Shaw

Shaw 

Shawhan

Shea

Sheats

Sheehan

Sheehy

Sheffield

Shelangoski

Shelley

Shelton

Shelton

Roderick

Peter

Colleen

Theresa

Richard

William

Ester

Jennifer

Julie

Nancy

Nina

Elena

Dennis

Clare

Anita 

Kim

Pam

Rick

Theresa

Kim

Irene

H. Dennis

Tamar

Jeanette

Lois

George

Ann

Debbie

Suzy 

Toni

Alice

Barbara

Bob

Carlyn

Dar

Barbara

Uly

Margaret

Ron

Beatrice

Jean

Amanda

Jennifer

Shepard

Shephard

Shepherdson

Sheridan

Sherman

Sherman

Shields

Shields

Shields

Shinn

Shirina

Shirlina

Shivers

Shomer

Shook 

Shrader

Shreeves

Shreve

Shrum

Shultz

Shum 

Shumaker

Shurghaia

Shutay

Siberstein

Sidoti

Siegel

Siegel

Siegmann

Siegrist

Sievert

Siewert

Sigmund

Sikes

Sikora

Silber

Silkey

Silver

Silver

Silvestre

Sim 

Simao

Simbrow
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-159 October 2016 

Janice

Chris

Irene

Johanna

Karen

Naomi

Susan

Sharon

Jill

Sonnta

Thomas

Anita

Dulcey

Alice

Crysyal

Edith

Katherine

Linda

Terri

Victoria

Mary

Millicent

Kate

Esther

Jodi

Linda

Tara

Janice

Dawn

Cindy

Kathryn

Mindie

Nicole

Betty

Sandra

Penny

Margaret

Kathy

Candace

Matthew

Birthe

Catherine

Linda

Simmonds

Simmons

Simmons

Simmons

Simmons

Simmons

Simmons

Simms

Simon

Simon

Simon

Simons

Simpkins

Simpson

Simpson

Simpson

Simpson

Simpson

Simpson

Simpson

Sims

Sims

Sims 

Simson

Sinclair

Sinclair

Sinclair

Singer

Sink

Sinks

Sipes

Sivey

Siwak

Sizelove

Sizemore

Skaff

Skeel

Skees

Skelton

Skinner

Skov

Sky

Slabenak

Jonette

Debbie

Julie

Carrie

Susie

Nancy

Alice

Cheryl

Donna

Brian

Sharon

Susan

Lisa

Stephanie

St.

Mari

Laurie

Isabel

Isabelle

Angela

Aubury

Barbara

Bette

Charlotte

Claud

Deanna

Denise

Donna

Elena

J.P.

Janet

Jen

Joyce

Judith

Kathleen 

Katrina

Kellie

Kristin

Laura

Lea

M.K.

Madeleine

Marsha

Slabey

Slack

Slater-Giglioli

Slayton

Sleight

Slesinger

Sloan

Sloan

Slocum

Smale

Small

Small

Smallegan

Smedley

Smeets

Smet

Smida

Smirnoff

Smirnoff

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Noah

Pat 

Randy

Shanti

Shiela

Stephanie

Sue

Teresa

Vickie

Joan

Kathe

Linda

Daniel 

Madelaine

Jay

April

Cheryl

Gloria

Lori

Margaret

Marilyn

Sandy

Tina

Jan

Susana

Michael

Patricia

Michael

John

Diane

Robin

Lisa

Cynthia

Donna

JoAnna

Cindy

Elaine

Dawn

Julie

Sally

L.

Mary Ann

Kari

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith

Smith 

Smothers

Smyth

Sneed

Snell

Snider

Snyder

Snyder

Snyder

Snyder

Snyder

Snyder

Snyder

Snyder

Soares

Soares

Sobel

Sobel

Sodos

Sodrel

Sohn

Solari

Soldavini

Solomon

Sommers

Sonnier

Sooy

Sorensen

Sorenson

Sorenson

Sorenson

Sorkin

Sorokie

Sorrenti
LIST OF COMMENTERS

3 Bars Project Final EIS D-160 October 2016 

Shirley

Patricia

Teresa

Lisa

Margaret

Morgan

Bob

Theodore

Tracy

Deb

Diana 

Donita

Michelle

Rick

Louise 

Judy

Dennis

Christina 

Maribeth

Carole

Dawn

Deborah

Emily

Joanne

Sandra

Shawna

Steph

Linda

George

Dawn

Herman

Joseph

Connie

May

Dawn

Richard

Linda

Laurel

Amy

Andrea

Irene

Suneet

Pauline

Sostman

Sottile

Soufas

Soulliere

Southwell

Sowell

Sowers

Spachidakis

Spader

Spanhake

Sparks

Sparks

Sparks

Sparks

Spartali 

Spaulding

Spears

Spence

Spence 

Spencer

Spencer

Spencer

Spencer

Spencer

Spencer

Spencer

Spencer

Sperber

Speros

Spilman

Spinelli

Spinelli

Spinks

Spiridon

Spivey

Spratley

Springer

Spsiak

Squires

Sreiber

Sriboonwong

Srivastava

St. Denis

Diana

Dan

Dorothy

Linda

Peggy

Faith

Jane

Ilsa

Megan

Rachael

Sharon

Periel

Janice

Cathy

Sandra

Sharon

Jack 

Mary

Sue

Daniel 

Laura

Megan

Lucy

Sheila

Carolyn

Pamela

Richard

Tom

Dennis

Lynn 

Maryann

Josine

Traci

Lori

Carol

Roberta

Cynthia

Brian

Dorrie

Linda

Matt 

Nanci

Carlene

St. Gaudens

Stabel

Staby

Staelens

Staffort

Staggs

Stahl

Stai

Stalker

Stalker

Stamm

Stanfield

Stanger

Staniunas

Stanley

Stanley

Stansfield

Stanton

Stanton

Staples

Staples

Staples

Starbuck

Starcevich

Stark

Stark

Stark

Stark

Starkins

Starner

Staron

Starrels

Starsinic

Staten

Statton

Stauffacher

Stave

Stearns

Stebbins

Steck

Stedman

Steeb

Steel

Lisa

Nichelle

Karen

Catherine

Jacqueline

Cheryl

Kim

Rebeca

A.L.

Catherine

Loreny

Diane

Monica

Laurie

Dusty

Ron

Dorothea

Kathryn

Ed

Hella

Allondra

Denise

Hilary

John

Kathleen

Melody

Richard

Julia

Ashley

Christine

Courtney

Jenny

Maggie

Mara

Patricia

Sharron

Susan

William

Ann

Sheila

Jeanne

Lorelei

Denise

Steele

Steele

Steen

Steer

Stehr

Stein

Steinbach

Steinberg

Steiner

Steinher

Steininger

Steitz

Stella

Sten

Stepanski

Stepchuk

Stephan

Sterngold

Stetson

Steurbaut

Stevens

Stevens

Stevens

Stevens

Stevens

Stevens

Stevens

Stevenson

Stewart

Stewart

Stewart

Stewart

Stewart

Stewart

Stewart

Stewart

Stewart

Stewart

Stickel

Stickel

Stidham

Stierlen

Stiewel
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-161 October 2016 

Deanne

Lee

Tonya

Donna

Elizabeth

Sonja

Susan

Elaine

Lorri

Emil

Carolyn

Kimberley

Lynne

Gina

Maria

Frank

Bella

A.

Betty

Deborah

Gwenyth

Lauren

Ronald

Stephanie

Valerie

Martha

Michelle

Lada

Connie

Bobbi

Darlene

Veda

Susanne

Kris

Gerald

Patricia

Anne 

Jeanie

Boel

Lise

Susan

Hagit

Katherine

Stiff

Stiff

Stiffler

Stillabower

Stillman

Stimmer

Stiver

Stockley

Stockowski

Stockton

Stoeber

Stoecklein

Stokes

Stoll

Stoll

Stolp

Stolz

Stone

Stone

Stone

Stone

Stone

Stone

Stone

Stone

Stopa

Storace

Storer

Storie

Stout

Stover

Stram

Strasen

Strate

Stratman

Strecker

Streeter

Streit

Stridbeck

Strieder

Stringfellow

Strnfeld

Stroh

Kirsten

Carolyn

Dianne

J. 

Sandy

Melya

Astrid

Jan 

Peggy

Cassandra

Gail

Gayle

Jay

Kate

Michele

Susan

Tanya

Authur

Laurie

Mary

Minde

Barbara

Natalie

Janet

Dawn

Margaret

Jennifer

Cheryl

Glenn

Apurvo

Susan 

John

Ellyn

Sandy

Per

Maria 

Lauren

Gerard

Gabrielle

J. 

Robyn

Sandra

Autumn

Strom

Strong

Struse

Stufflebeam

Stuhaan

Stylos

Suchanek

Suche

Sufall

Sullivan

Sullivan

Sullivan

Sullivan

Sullivan

Sullivan

Sullivan

Sullivan

Summers

Summers

Summitt

Sunde

Sundholm

Sunflower

Supar

Surges

Surmiak

Suther

Sutherland

Sutherland

Sutherland 

Sutherland 

Sutkowski

Sutton

Sutton

Svenningsen

Svorenova

Swaim

Swainson

Swanberg

Swanson

Swanson

Swanson

Sweeley

Ann

Jean

Michelle

Alexendra

Constance

John

Joe

Gina

Lisa

Sandra

Robin

Wretha

Terry

Pam

Sally

Michele

Sonja

Kenneth

Janice

Beatka

Denise

Diane

Paige

Jaycel

Barbara

Carol

Marie-Claire

Albert

Cat

Hikari

Morgan

Roya

Valerie

Binh

Donna

Martha

Rachelle

Carol

Yvette

Elaine

Patricia

Sharon

Stephen

Sweeten

Sweezey

Sweigart

Sweitzer

Sweitzer

Swiencicki

Swierkosz

Swift

Swift

Swift

Swindle

Swinehart

Swisse

Sydney

Symanski

Symington

Syne

Synnott

Szalaj

Szkop

Szyszlo

Tabbott

Tabor

Tacchi

Tacker

Taggart

Tagnati

Tahhan

Tailer

Taiyono

Takach

Talezadeh

Tan

Tang

Tanner

Tanner

Tanner

Tao

Tapptico

Tarango

Tarantino

Tarantino

Tassell
LIST OF COMMENTERS

3 Bars Project Final EIS D-162 October 2016 

Debra

Kathy

Jessica

Cynthia

Alison

Cathy

Charlot 

Chriistine

Daphne

Debbie

Derek

Donna

Elaine

Emily

Felicity

Jean

Jennifer

Lauren

Lauren

Llew

Patty

Peggy

Shawn 

Lisa

Terry

John

Raquel

Bonnie

Joyce

Tanya

Allie

Nancee

Lee

Thomas

Marilyn

Marga 

Barbara

Hope

Marie Ann

Paul 

Carol

Jessica

Joseph

Tate

Tate

Tatton

Tawil

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Taylor

Tays

Teal

Tedesco-Kerrick

Teevan

Tejeda

Templeton

TenEyck

Teneyuque

Tennant

Tepley

Terbot

Terreault

Terry

Terstal

Tetro

Thacker

Thaler Shenk

Thandi

Thatcher

Thatcher

The

Zette

Mary

Laura

Bob

Cynthia

Danny

Debbie

Denise

Irene

Joan

Mary

Patricia

Randy

Sandy

Angel

Teresa

Carol

Chris

Deborah

Paula

Astrid

Barbars

Susie

Tricia

Cathy

Colleen

Marie 

Michael

Mary

Michelle 

Susan

Anna

Mary 

Jake

Catherine

Cindy

Audrey

Liza

Eugene

Sue

Carolyn

Rebecca

Shereen

Thierry

Thoma

Thomae

Thomas

Thomas

Thomas

Thomas

Thomas

Thomas

Thomas

Thomas

Thomas

Thomas

Thomas

Thomason

Thomason

Thompson

Thompson

Thompson

Thompson

Thomsen

Thomson

Thomson

Thomson

Thornburn

Thorne

Thorne-Thomsen

Thornton

Thorpe

Thrower

Thurairatnam

Thurman

Tibbetts

Tibbitts

Tierney

Tierney

Tillinghast

Timmers

Timpe

Tinder

Tinus

Tippins

Tippss

Lori 

Rita

Mary

Martha

Kathleen 

Kris

Helen

Suzan

Larry

Melissa

Bartlomiej

Lisa 

William

Michael

Claudette

Isabel

Debora 

Susan

Tatiana

Cindy

Camilla

Jennifer

Liliana

Nan 

Erline

Patricia

Debra

Kerstin

Jeannette

Danielle 

Lynn

Barb 

Terry

Carol

James

Jessica

Valerie

Carol

Dale

Valerie

Federica

Tia 

Sheena

Tishgart

Tobachnik

Tobey

Tocco

Todd

Tohm

Tollefson

Toma

Toman

Tomaszewski

Tomczak

Tomlin

Toner

Tonne

Tooley

Torisi

Toro

Torres

Torres

Torrey

Torsander

Toth

Toth

Towle 

Towner

Townsend

Tracy

Tracy

Trajan

Tran

Traub

Travis

Travis

Treacy

Treanor

Treece

Treichel

Treloar

Trethaway

Trimarco

Trimboli

Triplett

Troite
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-163 October 2016 

Roxanne

Alessandra

Jacquie

Rosemary

Shirley

Sharon

Priscilla

Barbara

Kathy

Kathleen 

Donna

Mary

Stormey

Lee

Ramon

Sandra

Jen 

Jackie

Barbara

Sauwah

Grigoria

Cheryl

Catherine

Nancy

Debbie

Dena

Kathleen 

Meredith

Veronica

Sophia

Mary

Gabriella

Donna

M.J. 

P. 

Barbara

Julie

Kathleen

Keith

Lynne

Robert

Marilyn

Ilya

Trombly

Tromboni

Trontell

Trosper

Trottier

Truax

Trudeau

Trudell

Truders

True

Trueblood

Truelove

Trujillo

Trujillo-Lopez

Trumbull

Trushel

Trusty

Tryggeseth

Trypaluk

Tsang

Tsiakmaki

Tuchbreiter

Tucher

Tucher

Tucker

Tucker

Tucker

Tucker

Tucker

Tuckman

Tulloch

Turek

Turiano

Turick

Turick

Turner

Turner

Turner

Turner

Turner

Turner

Turney

Turov

Kat 

Joe

Valerie

Karen

Anne

Nya

Jeanne

Theresa

Tobi

Margaret

Mary

Judy

Lucia

M.

The

Candace

DeAne

Lesa

S.

Jan

Missy

Rebecca

Susan

Irena

Damir

Margo

Helen

Anne 

Lorraine

Nina

Sanja

Rio

Jennifer

Tonya

David

Jan

Michelle

Adriana

Victoria

Jim

Gail

Christine

Berinda

Turro

Tutt

Tuttle

Tweedy-Holmes

Twine

Tyan

Tyler

Tyler

Tyler

Tyska

Tytko

Uhing

Uihlein

Uitendaal

Unger

Unzueta

Urban

Urban

Urton

Usher

Utegirl

Uurtamo

Uustal

Vacikova

Val

Val

Valborg

Valdez

Valdez

Valecic

Valecic

Valencia

Valentine

Valentine

Valentino

Valentino

Vallee

Vallese

Vallis

Valluzzi

Van

Van Boening

Van Cleave

Patricia

Michiel

Milca

Holland

Piet

Valrey

Valerie

Ineke

Natalie

Doraine

Keaven

Julie

Linda

Ce 

Gerard 

Maud

Betty

Cheryl

Phil

Corinne

Theodora

Susan

Jill

Janet

Diane

Gail

Aimee

John

Dolores

Serena

Myriam

Serge

Robin

Beth

Teresa

Donna

Carolina

Brenda

Eve

Karin

Pascale

Elaine

Madhulika

Van dee Poel

Van Den Bussche

Van Den Steene

Van Dieren

Van Gils

Van Gundy

Van Haltern

Van Huyck

Van Leekwijck

Van Lew

Van Lom

Van Ness

Van Singel

Van Tassell

Van Tol

Van Tol

Van Wicklen

Vana

Vanasse

Vanbegin

Vance

Vanden Bos

Vanderbyl

Vandergrift

Vandiver

Vangelist

Van-Goey

VanKleef

VanKluyve

Vann

Vanstalle

Vantalon

VanTassell

VanWicklin

VanZeller

Varcoe

Varga

Vargas

Vargas

Vargas

Vargiu

Vario

Varma
LIST OF COMMENTERS

3 Bars Project Final EIS D-164 October 2016 

Veronica

Bonnie

Tuba

Fabiola

Cheryl

Jeanna

Theresa

Ilona

Claudia

Patricia

June

Ordell

Ashley

Veronica

Venkatesh

Kent

Rebecca

Jet

Sherrie

Thalia

Marlene

Robert

Tara

Alexis

Sheri 

Nadine

Carol

Cathy

Oda

Tracy

William

Melinda

Phoenix

Merri

Angela

Paul 

Beatriz

Cristina

Linda

Courtney

Peter

Renee

Olga

Varner

Varnum

Varol

Vasquez

Vaugh

Vaughn

Vaughn

Vaupel

Vazquez

Vazquez

Vearling

Vee

Veil

Velasquez

Velayutham

Vella

Velthoen

Venbeek

Venezia

Ventouris

Venture

Veralli

Verbridge

Verdugo

Verges

Vergilia

Vergot

Verret

Vervoort

Vetter

Vickers

Vickrey

Vie

Vieira

Viera

Vilches

Villa

Villanueva

Viloria

Vincent

Vincent

Vincent

Vinogradova

Dolores

Carlene

Lisa

Micele

Theresa

Nervo

Valerie

Andreas

Ralph

Marion

Patricia

Jutta

Alex 

Anne

Mary

Kelly

Kay

Ronald

Serge

Vicki

Pamela

Stavroula

Janice

Thuan

Mario

Lillian

Felicia

Lauren

Maur

Vicki 

Joan 

Lisa

Cate

Melanie

Natalie

Roberta

Sienna

Jani 

Jamie

Andrea

Richard

Aurea

Carol

Vinson

Visperas

Vitale

Vitaliano

Vittorini

Viviane

Vlasaty

Vlasiadis

Vobroski

Vogel

Vogel

Vogelbacher

Vollmer

Voloshin

Von

Von Borstel

Von Tress

Von Wagner

VonDuvillard

Voss

VourosCallahan

Voutsiotis

VrMeer

Vu

Vuotto

Wachtstetter

Wade

Wade

Wade

Wadler

Wager

Wager

Wagner

Wagner

Wagner

Wagner

Wagner

Wagter

Walbeck

Walbert

Waldo

Walker

Walker

Charlotte

David

Deborah

Fern

Kathy

Latonya

Margaret

Susan

Kelly

Amber

Lu

Aleta 

Lorna

Violet

Deborah

Lawrence

James

Sabrina

Kathy

Sharon

Bryan

Marilyn 

Alison

Dixie

Jennifer

Elizabeth

Jo

Michelle

David

Margrethe

Helen 

Linda

Lynn 

Hope

Steve

Leslie

Caroline

Diana

Lyn

Ralph

Rosemary

Susan

Terrence

Walker

Walker

Walker

Walker

Walker

Walker

Walker

Walker

Wall

Wallace

Wallace

Wallach

Wallach

Wallach

Wallen

Wallen

Walls

Walser

Walsh

Walsh

Walston

Waltasti

Walter

Walter

Walter

Walters

Walters

Walters

Walther

Walther

Walton

Walzer

Wancata 

Wang

Wanninger

Wantz

Ward

Ward

Ward

Ward

Ward

Ward

Ward
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS

3 Bars Project Final EIS D-165 October 2016 

Alicia

Natalie

Shari

Christina

Barbara

Kay

Donna

Doris

Deborah

Elodie

Lucinda

Brandy

Scott

Jonathan

Natalie

Leslie

Andrea

Gisele

Hiroe

Terry

Kristin 

Glenna

Michelle

Billie

Liz

Carolyn 

Danuta

Anne

Bonnie

Carol

Celena

Courtney

Donna

Jackie

Laura

Steve 

Cheryl

Tammy

Whitney

Gary

Teckla

Chris

Elizabeth

Warden

Ware

Warlick

Warlm

Warner

Warner

Warnick

Warnstedt

Warot

Warren

Warren

Warsavage

Warwick

Washburn

Washburn

Washington

Wasserman

Wasylyszyn

Watanabe

Wataszko

Water

Waterman

Waters

Watkins

Watkins

Watkinson

Watola

Watson

Watson

Watson

Watson

Watson

Watson

Watson

Watson

Watson

Watters

Watters

Watters

Wattles

Wattman

Watts

Watts

Susan

Elizabeth 

Susan

Margaret

BethAnne

Laurie

Shirley

Verba

Christine

Davida

Helen

K.

Marissa

Nicole

Zorina

Nicole

Donna

Sandra

Allison

Emily

J.

Krystal

D.

Henry

Nona

Diane

Dora

David

Christina

Wanda

Deb

Ron

Sharon

Gasrry

Cheryl

Lori

Melody

Deborah

Donna

Elizabeth

Linda 

Thomas

M. J.

Watts

Watzke

Wayne

Weatherbee

Weatherford

Weaver

Weaver

Weaver

Webb

Weber

Weber

Weber

Weber

Weber

Weber

Weber 

Webster

Webster

Weideman

Weil 

Weil 

Weilage

Weiler

Weinberg

Weiner

Weinstein

Weinstein

Weinstock

Weinzieri

Weir

Weise

Weise

Weishaar

Weisman

Weiss

Welch

Welch

Wellington

Wells

Wells

Wells

Welton

Welz

Bobbie

Karolin

Robert 

Jennifer

Shell

Kenneth

Hillary

Jackie

Lynda

Friederike

Dona

Diane

Pam 

Doug

Benjamin

Lynn 

Mel

Amanda

Sherry

Kimberly

Patrick

Denise

Beth

Carla

Cleveland

Dorothy

Kelcia

Norma

Dawn

Jane 

Corinne

Deborah

Denise

Janet 

John

Joseph

Karen

Kathleen 

Kim

Margie

Marlene

Nathanael

Shirley

Wendelken

Wenkman

Wentzell

Wenzel

Wenzel

Wenzer

Werhane

Werner

Wesch

Wesendahl

Wesley

Wesson

West

Westerndorp

Westervelt

Westlake

Westlund

Wetherill

Weyandt

Whalen

Whalen

Wheatley

Wheeler

Wheeler

Wheeler

Wheeler

Wheeler

Wheeler

Whelan

Whitaker

White

White

White

White

White

White

White

White

White

White

White

White

White
LIST OF COMMENTERS

3 Bars Project Final EIS D-166 October 2016 

Tim

Tina

Vic

Sally

Deirdre

H.

Carol

Penelope

Regina

Carol

Erica

Elin

Marty

Wendy

Lisa 

Jodi

Rhonda

Christopher

Jeff

Jill

Anna

Tamara

Gaye

Lynn

Mary

Betty

Klaus

Teena

Lisa

Kimberly

Sandra

Cheryl

April

Gail

Sandy

Daniel 

Linda

Ma

Nancy

Trista

Debra

Brigitte

Carole

White

White

White

White 

Whitehead

Whitehead

Whitehurst

Whiting

Whitman

Whitmore

Whitney

Whittier

Whittle

Whyko

Wiater

Wick

Wickline

Widby

Widmer

Wiechman

Wieder

Wiesmann

Wiesner

Wilbur

Wilcox

Wilde

Wilde

Wildman

Wiles

Wiley

Wiley

Wilhite

Wilk

Wilke

Wilkey

Wilkinson

Wilkinson

Wilkinson

Wilkinson

Wilkinson

Wilks

Williams

Williams

Chris

Deirdre

Heather

Jane

Janet

Jesse

Joseph

Kendra

Marcus

Robert

Sara

Stephania

Terrie

Trudy

Vicki

Bridget

Carol

Debbie

Alana

Christine

Frank

Beth

Christi

Jennifer

Mary 

Roger

Ronald

Ryan

Sharon

Susan

Sybille

Tamar

Tina

Tracy

Jane 

Terri

Yvette

Virginia

Steph 

Karin

Mark

Sherri

Julie

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williams

Williamson

Williamson

Williamson

Willroth

Wills

Wilsey

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson

Wilson 

Wilson-Torres

Wiltcher

Winckel

Windsor

Winegar

Winfrey

Winfrey

Wingate

Crystal

Elke

Jackie

Karen

Jess

Cody

Ellen

Gail

Judith

Edward

Gordon

Anita

Louisa

Eleanor

Ann

Marcia

Jason

Katharina

Chris

Penny

Ursula

Marc 

Michael

Barbara

James

Leslie

Aleta

Betsy

Karin

Rachel

Valarie

Faith

Cathy

Cynthia

Ellen

Alcinda

Dennis

Pat 

Manuela

Leila

Ann

Barbara

Becky

Winger

Winkler

Winn

Winnick

Winstanley

Winstead

Winston

Winter

Winters

Wintraecken

Wirth

Wisch

Wistos

Witherite

Witkowski

Witte

Wittenbrader

Wittig

Witting

Wittmann

Woelcken

Woerschling

Wohlleb

Wojtas

Wolcott

Wolcott

Wolf

Wolf

Wolf

Wolf

Wolf

Wolf 

Wolfe

Wolfe

Wolfe

Wolff

Wolff

Wolph

Wolter

Wolvinya

Womack

Wood

Wood
RESPONSE TO PUBLIC COMMENTS ON THE DRAFT EIS 

3 Bars Project Final EIS D-167 October 2016 

Charles Wood Erin Yarrobino Robin Zeplin 

Judy Wood Gayla Yates Debi Zickefoose 

Margaret Wood Serineh Yeghikian Penny Zielstorf

Peter Wood Edith Yelland Laura Ziemba 

Shelva Wood Crystal Yengich Lorraine Zigman 

Virginia Wood Bonnie Yenney Gediminas Zilinskas 

Barbara Wood Rob Yers Janet Zimmerman 

Judy Wood Cassandra Yinger Jerry Zimmerman 

Sandra Woodall Anna Yona Andrea Zinn 

Sharon Woodlief Deborah Yoo Carole Zirk 

Billy Woods Allan Yorkowitz Carol Zorn 

Frances Woods Brandy Younce Sandy Zouzaneas 

Gary Woods Barbara Young C. Zub 

Lynn Woods Bonita Young Renee Zuba 

Stacie Wooley David Young Sandra Zuckerman 

Ivan Woolf Kyle Young E. Zuniga 

Clair Woolley Lance Young Carly Zurla 

Colette Woolley Marjorie Young Randi Zwaduk 

Kimberly Worman Mary Young 

Mary Wormell Mike Young 

Kathleen Worobey Jeneal Young 

Courtney Worrall Spencer Young 

Patricia Wrex Stephanie Zaccagnini 

Holli Wright Solvejg Zaferes 

Ken Wright Iva Zafirovska 

Rene Wright Deanna Zagin 

Sheila Wright Fran Zahler 

Trigg Wright Anna Zalewski 

Vivienne Wulff Aslan Zamazal 

Lisa Wyatt Esther Zamora 

Mia Wyatt Marla Zanelli 

Nancy Wyatt Rosi Zang 

Denise Wycoff Sandra Zaninovich 

Kimberly Wyke Jan Zanoni 

Annoula Wylderich Sandra Zastrow 

Shelley Wyndham Stephanie Zeerip 

Brenda Wyrick Pam Zeidman 

I. Yaco Sandra Zelasko 

Robert Yancey Julie Zelenka 

Renee Yank Cheryl Zellmer 

Bridget Yankowitz Daniel Zelter 

Alexandr Yantselovskiy Sherry Zendel 

Jan Yarker Joan Zentarski 
LIST OF COMMENTERS

3 Bars Project Final EIS D-168 October 2016 

This page left blank intentionally.
COMMENT LETTERS 

3 Bars Project Final EIS D-169 October 2016 

D.8 Comment Letters 

The following are comment letters with substantive comments 
COMMENT LETTERS 

3 Bars Project Final EIS D-170 October 2016 

This page left blank intentionally.
Bureau of Land ManagementMount Lewis Field OfficeBattic Mountain District

50 Bastian Road

Battic Mountain, Nevada 89820

Subject: Draft Environmental Impact Statement for the 3 Bars Ecosystem and Landscape Restoration

Project, Eureka County, Nevada (CEQ # 20130280)

Dear Mr. Lewis:

The U.S. Environmental Protection Agency has reviewed the Draft Environmental Impact Statement for

the 3 Bars Ecosystem and Landscape Restoration Project (3 Bars Project) pursuant to the National

Environmental Policy Act, Council on Environmental Quality regulations (40 CFR Parts 1500-1508),

and Section 309 of the Clean Air Act.

The EPA strongly supports the objectives of the 3 Bars Project. The land restoration treatments proposed

should, when implemented in conjunction with the standard operating procedures outlined in Appendix

C, help to achieve objectives—including to restore riparian, aspen, and sagebrush habitats, slow

singleleaf pinyon pine and Utah juniper encroachment, and thin pinyon-.juniper communities—identified

by the BLM as central to the 3 Bars Project.

Based on our review of the subject DEIS, we have rated the Preferred Alternative and the document as

LO-1, Lack of Objections — Adequate (see the enclosed “Summary of EPA Rating Definitions”). TheEPA recognizes the need for the use of mechanical thinning and prescribed fire and wildfire to achieve

long-term restoration objectives. We commend the BLM for committing, in the Preferred Alternative, tostrong best management practices and soil and water conservation measures to protect sensitive

resources during mechanical harvest and fire treatments. We would also like to acknowledge the

description, in the DEIS, of the possible effects of climate change on the 3 Bars planning area. We

recommend that the Final EIS and Record of Decision include a commitment to mitigate such effects,

and to adapt management strategies accordingly, over the life of the 3 Bars Project.

We are also pleased with the riparian area restoration goals proposed in the 3Bars Project. These goals,

including plans to “restore 31 miles of perennial streams, 17 miles of intermittent streams, and 40springs that are within the riparian treatment zone” should aid efforts to protect sensitive riparian andaquatic species. We recommend, however, that the FEIS provide additional information on the potential

interface between the stream restoration work planned for the 3Bars Project and Section 404 of the

Clean Water Act (CWA); such restoration work could result in impacts to waters of the U.S. The DEIS

states that no formal delineation of wetlands has been done for the project area, but that based on the

USFS National Wetlands Inventory, the project area contains approximately 2,363 acres of wetlands. 
and wildfires to the greatest possible extent. We also recommend that the BLM analyze and include a

description, in the FEIS, of the potential for further reductions in air emissions, in proposed forest

treatments, by lessening or eliminating pile burning of residual fuels in favor of biomass energyproduction.We appreciate the opportunity to review this DEIS, and are available to discuss our comments. When

the FEIS is released, please send one CD copy to this office (specify Mail Code CED-2). If you have

any questions, please contact me at 415-972-3521, or contact Jason Gerdes, the lead reviewer for this

project. Mr. Gerdes can be reached at 415-947-4221 or gerdes.jason@epa.gov.

Sincerely,

JVL.L( L(Ui’l; -,

Kathleen Martyn Goforth, Manager

Environmental Review Office

Enclosure: Summary of EPA Rating Definitions

2
“LO” (Lack of Objections)

The EPA review has not identified any potential environmental impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation measures that could be accomplished with no more than minor changes to the proposal.

“EC” (Environmental Concerns)

The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact. EPA would like to work with the lead agency to reduce these impacts.

“EO” (Environmental Objections)

The EPA review has identified significant environmental impacts that should be avoided in order to provide adequate protection for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration of some other project alternative (including the no action alternative or a new alternative). EPA intends to

work with the lead agency to reduce these impacts.

“EU” (Environmentally Unsatisfactory)

The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory from the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce these impacts. If the potentially unsatisfactory impacts are not corrected at the final EIS stage, this proposal will be recommended for referral to the Council on Environmental Quality (CEQ).

ADEOUACY OF TIlE IMPACT STATEMENT

“Category 1” (Adequate)

alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer

may suggest the addition of clarifying language or information.

“Category 2” (Insufficient Information)

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are

within the spectrum of alternatives analysed in the draft EIS, which could reduce the environmental impacts of the action. The identified additional information, data, analyses, or discussion should be included in the final EIS.

“Category 3” (Inadequate)

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or theEPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analysed in the draft EIS, which should be analysed in order to reduce the potentially significant environmental impacts. EPA believes

that the identified additional information, data, analyses, or discussions are of such a magnitude that they should have full

public review at a draft stage. EPA does not believe that the draft ElS is adequate for the purposes of the NEPA and/or

Section 309 review, and thus should be formally revised and made available for public comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal could be a candidate for referral to the

CEQ.

*From EPA Manual 1640, Policy and Procedures for the Review of Federal Actions impacting the Environment

1

---------- Forwarded message ---------- 

From: PWR Regional Director, NPS <pwr_regional_director@nps.gov> 

Date: Fri, Nov 15, 2013 at 11:00 AM 

Subject: ER 13\0208 Draft EIS for 3-Bars Ecosystem and Landscape Restoration Project 

To: 3Bars_Project@blm.gov

Cc: Alan Schmierer <alan_schmierer@nps.gov>, Lee Kreutzer <lee_kreutzer@nps.gov>, NPS WASO EQD 

ExtRev <waso_eqd_extrev@nps.gov> 

OFFICIAL CORRESPONDENCE BY ELECTRONIC MAIL

NO HARD COPY TO FOLLOW

DEPARTMENT OF THE INTERIOR

NATIONAL PARK SERVICE

Pacific West Regional Office

333 Bush Street, Suite 500

San Francisco, California, 94104-2828

L7619 (PWR)

November 13, 2013

Chad Lewis, Project Lead         DOCUMENT #2

BLM Battle Mountain District

50 Bastian Road

Battle Mountain, NV 89820

3Bars_Project@blm.gov

Dear Mr. Lewis:

Re: ER 13\0208 Draft EIS for 3‐Bars Ecosystem and Landscape Restoration Project

Thank you for the opportunity to review the 3‐Bars Ecosystem and Landscape Restoration Project Draft Environmental Impact Statement (DEIS).

Overall, the National Park Service (NPS) anticipates that the proposed landscape restoration activities will largely benefit the historic corridor and

setting of the Pony Express National Historic Trail (NHT), which is administered by the NPS through its historic trails office headquartered in Santa

Fe, New Mexico.

As noted in the DEIS, however, the surface‐disturbing nature of some of the planned activities do have the potential to disturb the NHT’s setting, as

well as any intact trail remnants and associated sites or station ruins that may exist within the project area.  The Bureau of Land Management’s

(BLM) planned approach to conduct further field survey and evaluation of historic properties before initiating restoration activities, and to

implement site avoidance strategies specified in the 2012 Protocol and Programmatic agreements between the BLM and the Nevada State Historic

Preservation Officer, will help minimize that potential.

The NPS welcomes the BLM’s engagement with our trails office and consulting to establish appropriate protective boundaries to buffer trail

properties from project impacts. If, however, adverse impacts to specific NHT‐related properties are later found to be unavoidable or are

inadvertently incurred while implementing this or future undertakings, NPS asks to further participate in NHPA §106 consultations to help identify

appropriate mitigation.

Secondarily, an erroneous statement is contained in the DEIS analysis of impacts to recreation, section 3.20.3.3.1 on page 3‐420, which says “There

are no recreation resources of regional and/or national importance” within the project’s Area of Potential Effect. As noted elsewhere in the DEIS, the congressionally

designated Pony Express National Historic Trail is a recreation resource of national significance.  A correction should be provided in the Final EIS.[Recreation –

Environmental Consequences – 2‐1]
2

The willingness to consult NPS as a cooperating agency in this environmental review process over the past several years is much appreciated, and we thank the

Mount Lewis Field Office personnel and consultants for their thoughtful consideration and integration of our comments on an earlier version of this document.

For any further assistance, please continue to coordinate with Ms. Lee Kreutzer, Cultural Resource Specialist, National Trails Intermountain Region, Santa Fe,

New Mexico (801) 741‐1012 x118.

Sincerely,

Christine Lehnertz

(signed original on file)

Christine S. Lehnertz

Regional Director, Pacific West Region

cc:

NPS NTIR lee_kreutzer@nps.gov

NPS EQD waso_eqd_extrev@nps.gov
Paulus, Stuart

To: BMDO3BarsProject, BLM_NV

Subject: RE: 3 Bars Ecosystem and Landscape Restoration Project Draft EIS

From: c1lewis@blm.gov [mailto:c1lewis@blm.gov] On Behalf Of BMDO3BarsProject, BLM_NV DOCUMENT #3

Sent: Wednesday, December 04, 2013 10:45 AM 

To: Paulus, Stuart 

Subject: Fwd: 3 Bars Ecosystem and Landscape Restoration Project Draft EIS 

---------- Forwarded message ---------- 

From: Stephen Foree <sforee@ndow.org> 

Date: Fri, Nov 29, 2013 at 4:16 PM 

Subject: 3 Bars Ecosystem and Landscape Restoration Project Draft EIS 

To: "3bars_project@blm.gov" <3bars_project@blm.gov> 

Cc: "c1lewis@blm.gov" <c1lewis@blm.gov>, Mike Podborny <mpodborny@ndow.org>, John Elliott 

<jelliott@ndow.org>, Michael Starr <mstarr@ndow.org> 

The Nevada Department of Wildlife continues to appreciate the opportunity to work with BLM on this 

important landscape restoration project. We remain committed to work with BLM in an effort to improve 

habitats for a myriad of wildlife species within the 3 Bars Project area. While projects of this magnitude and 

the acres potentially effected by subsequent treatments can be concerning, we feel that the safeguards in place 

via identified protective measures will mitigate most of our concerns. Based on our comments relative to the 

PDEIS we did not see that BLM had adequately address two previous concerns. [ Vegetation 

Treatments Planning and Management – Treatment Areas – Sagebrush – 3-1] 1. It was our recommendation 

that within mid and lower elevation sagebrush communities treatment test plots be conducted (several hundred 

acres or less) in an effort to ensure that we can effect positive change in these drier sites. We recommended that 

these tests be conducted prior to identified large scale treatments. At present knowledge concerning the 

reestablishment of native herbaceous species within a sagebrush over story is not well known. It is thought that 

before BLM initiates treatment in these vegetation communities on a large scale that we should have a good 

idea that the treatment applied will be successful. [Proposed Action and Purpose and Need – 

Relationship to Statutes, Regulations, and Policies – 3-2] 2. We were unable to determine how BLM would 

apply NRS 528.053 which sets a 200-foot buffer from stream channels for any impacting activity unless a 

variance is authorized by NDF, NDOW and NDWR. 

 

NDOW is hopeful that BLM will afford those, who will implement the actions analyzed in this EIS, the greatest 

array of methods and tools to enhance habitat important to key wildlife species such as sage-grouse and 

Lahontan cutthroat trout when a decision is finally rendered. To exclude key methods such as fire or various 

forms of machinery will only increase treatment costs and compromise the potential benefits of this habitat 

enhancement project. We look forward to continuing to work with BLM on project planning and 

implementation. We compliment Battle Mountain BLM for the foresight to initiate restoration planning on a 

scale such as this. 

1
2

 

 

Steve Foree 

Eastern Region Habitat Supervisor 

60 Youth Center Road 

Elko, NV 89801 

775.777.2306 

sforee@ndow.org

 


November 29, 2013

Mr. Chad Lewis Document #4

EIS Project Manager

Mount Lewis Field Office

Battle Mountain District

50 Bastian Road

Battle Mountain, NV 89820

Email: 3Bars_Project@blm.gov. Fax: 775-635-4034 Attn: Chad Lewis, 3 Bars Project.

Comments on Battle Mountain BLM Three Bars EIS

Here are comments of Western Watersheds Project and the American Wild horse Preservation

Campaign on the 3 Bars Ecosystem and Landscape Restoration Draft Environmental Impact Statement

(DEIS).

Massive 3⁄4 Million Acre Project Area and Public Lands Resources Are Impacted – Yet the EIS

Lacks A Hard Look at Baseline Environmental Conditions

The Three Bars landscape in the arid Great Basin is an immense area of nearly 3⁄4 million acres. This

region is facing grave threats to its perennial waters, water quality and quantity, watershed function,

integrity of native vegetation communities, habitat quality and quantity for viable populations of

sensitive and imperiled species, and preservation of special management areas including Wild Horse

Herd Areas, Wilderness Study Areas, and Lands with Wilderness Characteristics. There are serious

questions about long-term persistence of sage-grouse, pygmy rabbit, ferruginous hawk, pinyon jay,

flammulated owl, migratory songbirds, aquatic biota and other rare species.

BLM manages four wild horse Herd Management Areas in Three Bars that are impacted by the Project.

These areas must be managed to protect and preserve their specific values and the free roaming wild

horses, and ameliorate and minimize conflicts with other uses.

There are also many threatened cultural sites in this landscape, from Native American sites suitable for

inclusion in the National Register but where BLM has not acted to register and protect them, to historic
mining era sites that aid in understanding the natural historical presence of pinyon-juniper across much

of the Three Bars project area. See Zeier 1985. This historical pinyon-juniper information contradicts

the entire basis for much of the Three Bars project, including its modeling of fire return intervals,

disturbance intervals, the AECOM/ENLC range “health” assessments, and assumptions made about

the extent and prominence of historic forested vegetation at middle and higher elevations across the

region.

An Environmental Impact Statement is supposed to minimize uncertainty. Instead, BLM has produced

a voluminous muddle of self-serving and biased analysis - 500 pages of the EIS alone, plus several

hundred pages of Reports (AECOM, ENLC). The EIS’s Report underpinnings are based on flawed and

incorrect models of “ideal” vegetation types that do not accurately reflect historical information,

current science on both sagebrush and pinyon-juniper disturbance intervals, fire frequency,

composition of vegetation communities, risks of cheatgrass and other flammable weed invasion and

expansion, sensitive species habitat and population needs, etc. It is based on the same flawed claims

and disregard for natural landscapes as a series of recent disastrous Ely BLM projects.

The EIS even involves many of the same parties who were responsible for the disastrous Ely Lincoln

County Sage-Grouse treatments and other wildly expensive projects that have destroyed and

fragmented sage-grouse and pygmy rabbit, and pinyon jay habitats, and caused the dominance of and

expansion of cheatgrass in the treatments where Ely BLM destroyed the woody plants (sage and trees).

See WWP Ely BLM Lincoln County and Cave-Lake documents submitted on cd.

The EIS Preferred Alternative is a horrow show of aggressive highly destructive and very expensive

“treatments”. It represents irrational agency hubris that disregards the sensitivity of the landscape, and

the fragility and complexity of the animal, plant and other resources that are found in Three Bars and

surrounding areas. The EIS serves to produce more questions and environmental uncertainty about all

components of the environment – and these are all unaddressed and unmitigated.

BLM proposes to spend what in reality will be tens of millions of tax dollars to tear this landscape to

pieces and “bioengineer” it. The agency references the term bioengineer dozens of times in the EIS.

BLM has apparently not learned anything from all of its past efforts to “treat” arid wild landscapes

subject to temperature and weather extremes - from drought to thunderstorm deluges and snowmelt

runoff erosion, and treats Three Bars as if it were a flat irrigated farm field where all factors can be

controlled. The problem is – that is not the case, and there are so many direct, indirect and cumulative

and synergistic adverse effects of the proposals - and so many things that can go wrong.

Not the least of this is BLM could kill remaining areas of perennial flow in the already highly depleted

streams, springs, and springbrooks by its treatment denuding of the landscape and bulldozing of the

stream channels themselves. With the scale of these projects, and the heavy equipment that will be

imposed across rugged, wild, weed prone terrain – ranging from D-9 cats with ship’s anchor chains

strung between them uprooting and tearing pinyon pine, juniper and sagebrush out of the ground – to

dump trucks driving crosscountry hauling wood chips for biomass incineration, to giant chipper

machines that turn pinyon jay nesting sites to piles of chips on the forest floor (and crushing and

destroying the sage as collateral damage) to BLM’s proposals to burn large areas of trees growing in

higher elevations in persistent PJ sites where all current science shows the trees are supposed to be

growing, there can be no doubt that the risks are great. The outcomes are highly uncertain, and undue

degradation of the public lands in violation of FLPMA is certain.

In reality, projects gone awry will be beyond the BLM’s ability to control, or fix the land, once the

treatments tear it apart. BLM cannot even figure out how to address the effects of grazing in its series
of Ecoregional assessments http://www.peer.org/news/news-releases/2011/11/30/-grazing-puntedfrom-federal-study-of-land-changes-in-west-/

BLM ignores or inadequately addresses the large body of threats it admitted to in the topics that were

covered in the Ecoregional assessments:

http://www.blm.gov/wo/st/en/prog/more/Landscape_Approach/reas.html

For example, the latest Great Basin assessment shows grave concern for sage-grouse and pygmy rabbit

due to loss of sage habitats. This project destroys sage habitats. The REA also shows retraction of

pinyon-juniper and many other adverse effects of climate change, that show how flawed the massive

PJ destroying treatments of the Preferred Alternative really are.

BLM cannot even count and be accountable for how many wild horses are in its pens – yet it proposes

massive disruption of 3⁄4 million acres.

No amount of bioengineering is going to replace the 400 year old trees that are killed as “collateral”

damage from prescribed fire or injured by masticators. Or the fragile Wyoming big sage and black

sage sites that will become choked with cheatgrass when the sage is thinned, crushed, smashed,

chopped, mowed, and otherwise destroyed - including in “targeted grazing”.

We understand that this EIS may have already cost almost a million dollars. How much has been spent

so far? [Socioeconomics - Environmental Consequences - 4-1] How much would all of the projects

and bioengineering cost if implemented? How much would it cost to try to “fix” rampant weed

invasions, erosion, etc.?] [Vegetation Treatment Planning and Management - Methods - Herbicides 4-

2] What toxic herbicides would this involve, and what would their effects be?] How successful has

BLM ever been at controlling cheatgrass, medusahead, annual bromes or other weeds across large

landscapes?

BLM fearmongers. A reader of the EIS is told, essentially, that if BLM does not kill the trees and sage,

“catastrophic” fire will.

The EIS appears to be an effort to implement the massive vegetation manipulation schemes of the

BLM Weed EIS and the NEPA-less PER Report. In the mid-2000s, BLM developed a highly

controversial programmatic Weed EIS - Vegetation Treatment in 17 Western States. This EIS

expanded the arsenal of chemical herbicides that BLM was allowed to use across the public lands, and

was a boon to the herbicide purveyors. This is despite BLM having had disastrous outcomes of

previous weed treatments, such as the cheatgrass herbicide Oust drift debacle in Idaho. See

http://www.claimsjournal.com/news/west/2009/08/25/103289.htm

We incorporate by reference into these Three Bars comments all comments and information at the

Sagebrush Sea site below. WWP is also attaching our comments on the Weed/17 states process for this

record.

http://www.sagebrushsea.org/mn_BLM_weeds.htm

Despite a broad range of environmental concerns about the BLM’s failure to address causes of weeds,

BLM was in reality adopting a Spray and Walk Away approach. It refused to address passive

restoration and minimizing aggressive management.
BLM in the middle of the Weed EIS process issued a parallel but NEPA-less Report – The PER report.

Dozens if not hundreds of pages in the current Three Bars EIS reference this PER report and/or the

bioengineering heavy equipment bulldozing, chopping, chaining, crushing, mashing and burning of

the public lands, wildlife habitat, HMAs, watersheds – that the PER report endorsed under the claim

that these “treatments” were “restoration”.

When environmentalists concerned about the both EIS and the PER Report asked BLM where was the

NEPA analysis and environmental review for the PER Report, BLM said there was none – that the

Weed EIS would only focus on herbicides. And not the causes of the disturbance to soils, microbiotic

crusts, waters, watersheds – that generated the weeds – that resulted in BLM’s claimed “need” for

herbicides. And not the adverse effects of the battery of treatments laid out in the PER. So in reality,

BLM chose to ignore the colossal chronic livestock grazing disturbance, excessive road networks often

linked to livestock facilities or livestock management, and its past treatments that had caused weeds –

and would not concern itself with scrutinizing the PER under NEPA The Weed EIS NEPA Review

only addressed allowing many harmful herbicides, including new ones, to be sprayed across public

lands and waters. Integrated weed management was ignored.

Environmentalists requested that BLM consider the following alternative:

The Restore Native Ecosystems Coalition (RNEC) was created to develop an alternative for the

proposed BLM vegetation management EIS that identifies the causes of weed spread and fire fuel

build-up and prescribes measures to prevent conditions that favor invasive species and hazardous

forest fuel loads, and restore sites that would be sprayed, burned, chained, or logged by BLM to

reduce invasive species and fuel loads on public lands. RNEC's scoping letter described why the

Restore Native Ecosystems Alternative (RNEA) was within the scope of the EIS and was a

"reasonable" alternative under NEPA. An outline of the RNEA was attached to the letter, which was

signed by twenty-six organizations.

BLM ignored this.

So what this process in reality did was to ignore the current causes of the weeds, only look at imposing

more harmful expensive chemical herbicides, and try to legitimize the massive disturbance and

destruction of sage, PJ, other woody vegetation under the PER.

BLM’s flawed and uncertain Three Bars EIS is a direct derivative of the Weed EIS and PER. BLM

twists itself in knots trying to justify spending tens of millions of dollars on “treating” and

manipulating native vegetation communities. These vegetation treatments have a long history in

Nevada of just leading to further ecological ruin. The most recent of which are the tragically degrading

cheatgrass-spawning Ely BLM projects, as described in WWP’s Lincoln County sage, Cave-Lake and

other comments, photo essays and appeals submitted on cd.

High levels of injurious domestic livestock grazing are occurring across this landscape and

surrounding BLM lands (where BLM has not adequately assessed the full range of cumulative impacts

of habitat loss, weed invasion risk, disturbance during sensitive breeding and other periods, etc.).

Under this Three Bars EIS, large-scale livestock grazing would still persist at high levels, during

harmful periods of the year for sage-grouse and other sensitive species, and there is no certainty that it

would be adequately controlled, or harms not shifted into untreated areas.
[Livestock GrazingȂEnvironmental Consequences - 4-3] BLM fails to take a hard look at the

severe ecological damage and irreversible weed invasions, water loss, and loss of sensitive species

habitats and populations that will result from continued livestock grazing being imposed across all of

these areas over the next couple of decades. This will be amplified by the adverse impacts of climate

change. See Belsky and Gelbard 2000, Beschta et al. 2012, Reisner Dissertation, Reisner et al. 2013,

Briske et al. 2013.

How desertifed are lands and watersheds at present? See Sheridan CEQ 1986, describing

desertification symptoms and impacts. See USDI BLM Great Basin Ecoregional Assessment. How

much of the potential of riparian areas has already been lost? Can these systems tolerate any more

disturbance – let alone massive bulldozing, herbiciding, fencing, and being converted to bare dirt in a

drought-plagued landscape? We note that at the same time that the agency is issuing the DEIS (after it

languished for several years getting more and more expensive all the while), Battle Mountain BLM is

issuing a series of drought closure decisions. Every time BLM in Nevada wants to round up wild

horses, it claims there is a drought.

The severity and intensity of drought is highly unpredictable in the arid and desertified Great Basin.

This makes any of the ground and soil disturbing treatments even more risky and uncertain. Once the

bulldozers rips up the stream and obliterates the former banks that reveal how much the system and

water flows have been reduced (by grazing, ag pumping and mines), or once the 300 year old trees are

burned up or the trees and sage are ripped out of the ground by bulldozers and chained, mashed,

shredded, cupped, chipped, slash burned, or hauled off in dump trucks as biomass, any recovery of the

site is highly uncertain.

All of the Three Bars EIS treatments, plus the inter-twined and connected very large and likely very

expensive herbicide dousing of the lands made vulnerable to weeds by the treatments and continued

large-scale grazing disturbance across the landscape, plus expanding mining geothermal and other

exploration and development, will greatly stress this ecosystem and the ecological balance within this

landscape.

[Vegetation Treatment Planning and Management - Methods - Bioengineering - 4-4] It is clear that a

Supplemental EIS must be prepared (if BLM chooses any treatment action other than selective hand

cutting of younger trees) to take a current, science-based look at the need for, and impacts of, a

massive and massively expensive bioengineering scheme in the heart of the Great Basin Ecosystem

that faces unprecedented climate change, cheatgrass/brome flammable weed invasion, and other

disturbance risks. See Connelly et al. 2004, Knick and Connelly 2009.2011, USFWS WBP Finding for

GSG, USDI BLM Great Basin REA.

[Vegetation Treatment Planning and Management - Literature 4-5] A large body of recent current

Literature shows the battery of aggressive very expensive BLM treatments are not effective, and will

likely lead to ruin. See Beck and Mitchell 2012, Jones et al. 2103 review, for example.

[Vegetation Treatment Planning and Management - Methods - Herbicides 4-6] This Supplemental

Three Bars EIS must also take a current, fresh and hard look at the use of any and all herbicides, the

amount of herbicide that will be used, the specific herbicides that will be used – alone or in

combination, their breakdown products and degradates, their persistence in the soils, and drift in wind,

soil, or water.
[Assessment - Risk Assessments - 4-7] In this process, BLM must also conduct comprehensive Risk

Assessments, not only of the chemicals and treatment methods to be applied, but also fully and fairly

take NEPA’s required “hard look” at risks of all kinds - to air quality, dust transport and depletion

linked to early snowmelt and climate change, a broad body of climate change effects, soils, native

vegetation, sensitive species, WSA impairment, HMA impacts, migratory birds, water quality and

quantity, viability of sensitive species populations and quality and quantity of habitat.

[Vegetation Treatment Planning and Management - General - 4-8] BLM must review the failures of

herbicides to control weeds (especially in the face of continued chronic livestock grazing disturbance)

–based on the agencies own experience with its many failed fire rehab efforts, and other treatments

where 5 or 6 years after fire, chipping, mowing, roatbeating, etc. – cheatgrass chokes the treated areas.

It must critically exmaine the failures of the actions never assessed under NEPA in the PER _ i.e. all

the Bioengineering and treatment disturbance methods proposed under the Preferred Alternative to tear

apart the landscape.

[Noxious Weeds and other Invasive Non-native Vegetation - Environmental Consequences - 4-9] How

much will cheatgrass increase in 10 years with and without the projects? In 20 years? How much

herbicide will be used, and what kinds, and where – under the various alternatives? What non-target

vegetation or habitats will be impaired?

This is particularly necessary, because the EIS engages in the worst kind of circular reasoning that

appears to be designed to make its own Preferred Alternative appear perfectly normal, routine,

palatable, and having no impacts that cannot be magically bioengineered away. This circular reasoning

is just like Ely BLM NEPA and data influenced by the same actors that have brought about disastrous

proposals in Ely (like Lincoln County Sage-grouse ‘restoration” EA, Cave-Lake EA, etc.) based on

the same shoddy models that find virtually every square inch of the Three Bars area that has any native

woody vegetation remaining to be unhealthy. This elevates the risk and uncertainty even further.

So does the fact, discussed below --- that the very same chipping, chopping, shredding, burning,

rotobeating, etc. that has been conducted in recent years does not bring about the glowing habitat and

species recovery results that BLM has promised time after time after time. Instead, it leads to worse

problems that the agency cannot fix. And further species loss and endangerment.

Failures of Three Bars Type Treatments

We are attaching a series of recent scientific articles and reports on the failures or adverse impacts of

treatments like BLM is proposing. See Beck and Mitchell 2012, Jones et al. 2013, Bristow, 2012,

Erickson, North Schell Prescribed Fire report.

If BLM had wanted to address the impacts and take NEPA’s required hard look in the EIS, it would

have fully and fairly considered all of the information below, and looked out the window at the BLM

office in Battle Mountain to see the disastrous consequences of too much livestock grazing and other

disturbance imposed on landscapes, like Argenta and Carico Lake areas. In many of these areas,

livestock grazed out the shrubs – just plain ate them on of existence on depleted range The shrubs have

not come back. So what makes BLM think that – once it destroys the woody vegetation here by

mashing, crushing chopping, chipping– things will be miraculously different? These arid systems can

only withstand so much stress, and livestock grazing and climate change are amplifying the effects of

the stresses on the landscape. The Argentas of yesterday are going to be the Three Bars sage
destruction projects of this EIS. BLM is planning to allow continued livestock grazing (with some

undetermined period of ‘rest”) across the treatments, and plans to have the livestock eat a large amount

of the shrub vegetation! It is also planning to shift, alter, and intensify impacts “temporarily” by

building fences so that virtually every untreated acre can continue to suffer intensive grazing

disturbance.

There is great uncertainty with the nebulous fencing schemes, failed treatments, shifted, altered and

intensified impacts, etc. The claimed grazing changes are also highly uncertain and are inadequate to

protect resources in a landscape torn to pieces under the Preferred Alternative.

[Livestock Grazing - Environmental Consequences -4-10] DEIS at ES-3 claims the need for the EIS is

to address the “long recognized” resource conflicts in the Three Bars area.There is no certainty that the

grazing changes will be made. Grazing decisions may be appealed, and appeals upheld.

Mining and geothermal or other resource or energy activity may expand – rendering all remaining

forested habitat essential for security of beleaguered big game and wild horse populations, or all

remaining undeveloped sage habitats crucial for sage sparrow, loggerhead shrike, pygmy rabbit, and

impairing water or other resources necessary for any Thriving Natural Balance in the HMAs.

The grazing changes, besides the uncertainty that they will be implemented, are also very inadequate.

The upland components are particularly meager and ineffective in a landscape suffering many current

problems as well as new and extensive habitat fragmentation from the project.

They do not address many necessary components of the environment that need protection.

They continue to inflict large-scale grazing disturbance across the landscape. This is despite the fact

that BLM in its Purpose and Need admitted that Three Bars was rife with conflicts. [Livestock Grazing

- Environmental Consequences -4-11] BLM fails to conduct the necessary capability, suitability, and

sustainability analysis to determine if it is necessary to remove livestock disturbance conflicts from at

least some significant and stressed habitat areas of the landscape.

BLM is supposed to be protecting sensitive species, forestry values, waters, etc. The wild horse HMAs

wild horse needs are supposed to be protected and sustained. FLPMA specifically states that not all

public lands must be subjected to all uses. That, at its heart, is what “multiple use” really means - not

that every single acre needs to be ground to dust by livestock disturbance, or developed for livestock.

Ever-Increasing Scientific Evidence of Aggressive Vegetation Treatments Being Bad for the

Land and Wildlife

Western land management agencies have caused tremendous damage in decades past by inflicting the

very same severe disturbance and “management” to sagebrush and pinyon-juniper landscapes that

BLM is proposing in Alt.

Examples include the Vale project in eastern Oregon, where massive treatments and exotic seedings

took a devastating toll on wildlife habitats. No there are the whole series of studies, complied in Beck

and Mitchell 2012, Jones et al. 2013, and other sources.

Instead of acting to remove and reduce disturbances, and put in place significant passive restoration

measures as well, BLM is still contemplating a battery of weed-promoting habitat –destroying actions.
Critical Issues Are Unaddressed

The EIS raises many questions that are unanswered, or it answered the actions taken are not sufficient,

or properly mitigated.

How much sage-grouse habitat is at considerable risk of cheatgrass/flammable annual grass and other

weed invasion with continued livestock grazing disturbance imposed on it?

With continued chronic grazing and treatments in the same landscape?

[Vegetation Treatment Planning and Management - General - 4-12] How much high quality habitat

will remain undisturbed by treatments? For example, BLM seeks to destroy critical blocks of pygmy

rabbit, sage sparrow, sage thrasher, and Brewer’s sparrow nesting habitat by mowing, chopping,

crushing, seeding for livestock grass. After BLM gets done with all of these treatments, how much

habitat will remain across the landscape? How fragmented will it be? [Cumulative Effects - General -

4-13] What populations were previously supported? What will now survive, and will they be viable?

How will expanding mine development and al the human footprint associated with that further eat into

and threaten these sensitive species habitats? How will mine development and the increased human

footprint in the landscape stress or affect the wild horse herds and their use of the HMAs? Even though

the current mine proposed is not the HMAs, there will be a greatly increased human presence in the

landscape.]

[Wildlife Resources - Environmental Consequences 4-14] How will the treatments affect the

sustainability of the pinyon jay population, including drought years like 2013, when birds had to travel

over large areas to find food? We stress that the 2013 pine nut crop in Nevada was very low, and this is

very likely to have significant long=-term adverse effects on this social, relatively long-lived species,

as well as other wildlife dependent on pine nuts. Clark’s nutcrackers are of great concern – as the

population in the northern Rockies has crashed due to the loss of the large-seeded whitebark pine

(whitebark now proposed for ESA listing, and nutcrackers should be, as well). Whitebark pine in

Nevada (found at higher elevation in some Nevada ranges) have also suffered die-off.

[Wildlife - Analysis Methodology - Baseline Studies - 4-15] BLM has not conducted the necessary

baseline surveys across the Three Bars area to determine the status of local habitats and populations,

the habitat quality and quantity, areas of seemingly suitable habitat that may be unoccupied, etc. This

must be done prior to finalization of the EIS if the EIS chooses any alternative other than selective

hand cutting, as its Decision.

[Wildlife Resources - Affected Environment - 4-16] Where are areas of remaining higher quality sagegrouse, pygmy rabbit, Brewer’s sparrow, loggerhead shrike and other habitats? Please map and

identify these, and develop a solid plan to remove livestock disturbance from them, and conduct any

treatment with minimal disturbance to soils, native vegetation, microbiotic crusts, etc.

[Cumulative Effects - General - 4-17] What is the intensity of the current conflicts of livestock, mining

etc. with the HMAs, the TNEB in the HMAs, etc.

[Wild Horses - Affected Environment - 4-18] Where are the areas of the HMAs with less disturbance

and intrusion? How do the big game species use the landscape, and how do the horses use the HMAs,
and how does protective tree cover play into the use of the landscape, and minimization of human

harassment?

[Native and Non-invasive Vegetation Resources - Affected Environment - Pinyon-juniper - 4-19]

Where are forest areas producing pine nut seeds for pinyon jays?

[Wildlife Resources - Affected Environment - 4-20] How has the 2013 collapse of the pine nut crop in

Nevada impacted pinyon jay, Clark’s nutcrackers, and other species that rely on large-seeded pines?

[Native and Non-invasive Vegetation Resources - Affected Environment - Pinyon-juniper - 4-21]

Where have trees been treated, removed, cut, chained, burned, etc. in the past for all periods for which

records have been kept?

[Native Wildlife Resources - Affected Environment - 4-22] How has loss of whitebark pine impacted

Clarks’ nutcracker across the species range?

[Livestock Grazing - Environmental Consequences -4-23] Will continuing to graze severely depleted

lands as well as lands at high risk of flammable cheatgrass invasion render any supposed benefits of

“improvement” from massive treatment intervention moot?

The 3 Bars Project ... spans approximately 750,000 acres (3/4 million acres) and includes all or

portions of three major mountain ranges (Roberts Mountain, Simpson Park Range, and Sulphur Spring

Range).

BLM claims: Many factors are contributing to an overall downward trend in land condition within this

area, including an increasing incidence and severity of wildfire, increasing expansion of downy brome

(cheatgrass), increasing expansion and densification of pinyon pine and Utah juniper woodlands, and

increasing human impacts.

[Alternatives - 4-24]This demonstrates the complexity of the situation, the grave risk of severe losses

under the massive disturbance of the Preferred Alternative, and the need for BLM to do a

Supplemental EIS that analyzes a range of greatly modified alternatives that minimize disturbance and

harm – not anything like the Preferred Alternative – which pretty much declares all out War on natural

ecological processes across the public lands.

What Do Historical Records Show?

[Native and Non-invasive Vegetation Resources - Affected Environment – Pinyon-juniper - 4-25]We

have repeatedly asked BLM to consult its own historical survey records in order to understand the

naturally occurring native vegetation across the Battle Mountain District and central Nevada. When

were the original General Land Office surveys conducted for this region? Which areas had early survey

records? What does cross-walking the info on occurrence of pinyon-juniper vegetation (and also water

in drainages/springs) show about the elevations and other conditions where pinyon-juniper is the

naturally occurring historical plant community? We discuss this further in specific comments on the

EIS sections below.

Systematic Baseline Biological and Ecological Inventories Are Lacking
[Native and Non-invasive Vegetation Resources - Assessment Methodology - Baseline StudiesǦ4-26]

BLM has not conducted the systematic baseline species, resource and habitat use inventories necessary

to understand how severe the impacts will be, and if there is enough population or habitat or perennial

water flow to absorb the habitat destruction and bioengineering bulldozing blows the projects will

unleash. This is all necessary to understand the sustainability of the resources affected and/or

threatened by the project. These are ALL the resources and values of the public lands BLM discusses

in EIS These inventories must be conducted across the entire project area and surrounding lands. BLM

cannot rely on the severely flawed AECOM ENLC vegetation info in this at all- which finds nearly all

lands unhealthy, and where almost the only way an areas would be considered healthy would be to

destroy all the woody vegetation structure that the sensitive sage and PJ species rely upon, and that

serves to protect watersheds.

BLM Use of Highly Flawed Modeled and Inaccurate NRCS Ecosites and Soils Descriptions

Renders Whole Expensive Treatment Scheme Invalid

WWP commented in Scoping after we reviewed the vegetation mapping:

BLM can’t really be serious in its veg mapping – claiming that not a single acre is Potential PinyonJuniper? We remind you there is substantial historical info on deforestation of nearly ALL trees within

a 50 miles radius of Eureka during the mining boom.

[Native and Non-invasive Vegetation Resources - Analysis Methodology - Modeling - 4-27] So just

how does this current DEIS mapping and info differ from Scoping info? Wasn’t that the basic

information that was used (at least in part) in developing the treatments? The agency, still bound at the

hip with the livestock industry, continues to rely on flawed livestock forage-biased NRCS Ecosite and

Soil Survey models, and severely flawed FRCC and other schemes. These models claim, essentially,

that pinyon-juniper should not occur across vast areas of this landscape - including right here in the

very elevation and precipitation range where plant ecologists have long recognized they naturally

occur. This is also the same elevation and precipitation range where General Land Office Records from

the original land surveys conducted across Nevada show that pinyon-juniper was historically the

naturally occurring natural climax vegetation type.

[Native and Non-invasive Vegetation Resources - Analysis Methodology - Modeling - 4-28]And,

where the trees do occur, and where there is any mature or old growth sage (i.e. sensitive species

habitat), the models claim the sage and trees are ‘unhealthy” “decadent”, and only killing a lot of it to

foster forage grasses can result in a “healthy” (based on the flawed models) landscape. In essence,

BLM’s twisted reasoning is that only by killing/thinning/chopping/re-seeding with exotic grasses or

hybridized cultivars that bear little resemblance to native grasses and forbs, can lands and species be

somehow “saved”.

[Native and Non-invasive Vegetation Resources - Analysis Methodology - Modeling - 4-29] This

flawed reasoning must be set aside by BLM. You can't save this landscape by the equivalent of waging

war on it and killing off the woody vegetation as the “enemy”. The NRCS Ecosites are modeled, not

based on reality. In Nevada, many of the recent soil surveys were done based on only the vegetation

that was currently growing on the sites, with no effort to examine the site history, historical natural

vegetation, (like wood stumps, burned wood, etc.) etc. They were also conducted long after BLM’s

massive “treatment” wave that started in the 1950s, which was preceded of course by massive mining

era deforestation (see Dr. Ron Lanner’s book The Pinyon Pine), and chronic promiscuous burning by

sheepherders and others in the late 1800s and early 1900s.
They are based on incorrect assumptions about the natural woody vegetation occurrence, woody

vegetation density, and incorrect claims about fire return intervals as well.

They are also strikingly biased towards grass (vs. sage and trees and critical microbiotic crusts). They

rely upon inaccurate fire disturbance and historical range of variability information.

Some land grant college extension and other researchers who make claims that the livestock industry

likes are treated as irrefutable experts on sage and PJ and other vegetation community characteristics,

disturbance and fire return intervals. These same researchers have been wrong time, after time, after

time. Examples:

[Native and Non-invasive Vegetation Resources - Assessment Methodology - Sagebrush - 4-30] Miller

and Rose claimed astonishingly short sagebrush disturbance intervals, despite a large body of evidence

available even at the time that this was wrong.

Given the preponderance of evidence that these researchers whose slanted work forms the basis of

Ecosites and models that BLM and its contractors use, but who are so often wrong, BLM must issue a

Supplemental DEIS that actually takes a careful and hard look at the historical record that refutes

Miller, Perryman and others.

These parties apparently keep getting funded and published because they produce what industry wants

to hear to justify a continued war on sage and trees, and this also distracts from consideration of from

grazing, and mining development and other significant harms occurring in this landscape.

EIS Has Not Taken a Hard look at the Mammoth Ecological Toll Caused By Mining

Large-scale cyanide heap leach gold mining, new proposed molybdenum and other mining, are taking

a devastating toll on ground and surface waters, and loss, degradation and fragmentation of wildlife

habitats, impacts to WSAs, impacts to the HMAs, and many other uses of the public lands. A huge new

foreign-owned molybdenum mine that will further deplete aquifers and drop water tables is planned at

Mount Hope. It appears that the Three Bars EIS is, in part, a way to spend a lot of mitigation funds

linked to the mining or geothermal development.

The mining entity purchased base properties with public lands grazing permits associated with them as

part of acquiring water rights and deflecting rancher concerns.

[Alternatives - 4-31] A very viable alternative treatment method here, that can be coupled with

selective active restoration such as hand cutting, is retirement of the public lands grazing permits the

mine acquired. Please provide mapping and analysis of these permits. What allotments are these? How

much land area do they cover? What are the values, sensitive species, HMAs etc. in lands grazed under

these permits? BLM should prepare a Supplemental EIS to assess a new and greatly expanded range of

alternatives, including this.

Climate Change Impacts Amplify Adverse Impacts of BLM’s Deforestation and Sagebrush

Killing Schemes

Livestock grazing disturbance amplifies the adverse impacts of climate change.
Any possible recovery or rehab of this massive battery of treatments is threatened by climate change

impacts. Hotter temperatures favor cheatgrass. Stream water flows are likely to be reduced by a

combination of hotter temperatures causing earlier snow melt and more rapid and earlier runoff and

erosion, with lower flows later in the year.

Treatments will result in hotter, drier more weed prone and erosion and climate-change vulnerable

sites. This will increase stress on depleted waters, watersheds, and animal and plant habitats and

populations.

[Fish and Other Aquatic Resources - Environmental Consequences -4-32] In this context, no

reasonable scientist would propose anything remotely resembling the Preferred Alternative – for

example –killing all PJ within 200 feet of streams. The water is likely to reach lethal temperatures for

aquatic biota as all shade is removed, and deforestation of the lands near the stream – which in grazed

arid lands are typically the most highly degraded - will result in significantly decreased watershed

stability and erosion, as well.

A reasonable person would look at this situation and say Gee, we first need to address the livestock

degradation and get willows and other trees growing again – rather than destroy the only woody

vegetation whose roots are stabilizing the watershed, and whose trunks and foliage are shading the

water.

The areas that BLM seeks to deforest and bulldoze are the areas that are considered Riparian Habitat

Conservation Areas elsewhere on public lands. The sensitivity of these areas is so well recognized and

well understood that there are a host of limitations to ANY disturbance in the RHAs.

[Wetlands, Floodplains, and Riparian Areas - Environmental Consequences - 4-33ȐMuch more

detailed analysis that must be conducted that avoids disturbance in RHCAs.

Excerpt from USDI BLM’s own analysis using RHCAs in other contexts:

RHCA Widths:

RHCA widths are defined for fish-bearing streams, permanently flowing non-fish bearing streams,

ponds/lakes/reservoirs greater than 1 acre in size, wetlands, intermittent streams, landslides, and

landslide-prone areas. See PACFISH (page C8-C9) or INFISH (page E5-E6) for specific definitions

of RHCA widths.

The Following was excerpted from : Quigley, Thomas M.; Arbelbide, Sylvia J., tech. eds. 1997. An

assessment of ecosystem components in the interior Columbia basin and portions of the Klamath and

Great Basins. Gen. Tech. Rep. PNW-GTR-405. Portland, OR: U.S. Department of Agriculture, Forest

Service, Pacific Northwest Research Station. 4 vol. (Quigley, Thomas M.,tech. ed.; The Interior

Columbia Basin Ecosystem Management Project: Scientific Assessment), Volume 3, pp 1365-1369.

Riparian Area Management—Four biophysical principles underlie any evaluation of a riparian

management strategy: 1) a stream requires predictable and near-natural energy and nutrient inputs;

2) many plant and animal communities rely on streamside forests and vegetation; 3) small streams are

generally more affected by hill-slope activities than are larger streams; and 4) as adjacent slopes

become steeper, the likelihood of disturbance resulting in discernable in-stream effects increases.
Basic information on the protective nature of woody vegetation and natural ecological processes is

absent from the EIS. Instead, it relies on the worst of the backwards land grant college range

department claims that seek to scapegoat trees and other woody vegetation for landscape damage

caused by the BLM’s chronic failure to properly manage domestic livestock grazing.

The EIS, by scapegoating trees for all manner of problems caused in large part by livestock grazing,

tries to bio-engineer away foundational principles of watershed and forest ecology. This is the same

kind of false and flawed scheming that pervade the Ely BLM processes, and that has caused so much

degradation across portions of the Great Basin landscape already.

Killing all the PJ within 200 feet of the stream is like shooting the messenger, and in this case the

messenger is also essential for BLM to keep the watersheds from unraveling and the LCT and other

aquatic biota from baking in the sun or being smothered in sediment. BLM ignores that fact that

similar processes operate in the natural world across many forested types, and that the harms of the

treatments have been well documented in logging and other studies in western North America. We

have attached some RHCA information on cd.

BLM Has Failed to Consider An Adequate Range of Restoration Alternative Actions

[AlternativesǦ4-34ȐBLM has failed to assess a broad range of alternatives under NEPA.

[Livestock Grazing - Environmental Consequences - 4-35] BLM has failed to identify large blocks of

lands where continued livestock grazing disturbance conflicts with passive restoration, and with active

restoration as well.

[Livestock Grazing - Environmental Consequences - 4-36] The EIS lacks necessary solid baseline data,

and a hard look at magnitude of historical and ongoing livestock degradation.

BLM in the Federal Register stated:

In order to implement the proposed 3 Bars Project, the BLM has developed the All Available Methods

Alternative, which is the preferred alternative, with treatments and treatment objectives that meet

previously identified resource management goals. These goals are consistent with the 1986 ShoshoneEureka Resource Management Plan which currently guides land management activities within the 3

Bars Project area. These goals pertain to wildlife and habitat enhancement, fire and fuels

management, control of weeds, woodland and rangeland values, wetland and riparian restoration,

wild horse protection, Native American concerns, and cultural resources. The BLM has identified sitespecific treatment projects that it would like to implement to restore and manage the 3 Bars Project

Area. Treatment projects were identified through an iterative process involving the BLM and other

Federal and State agencies. Treatments would focus on four priority vegetation management

concerns:

x Riparian—treatments in riparian habitats would focus on restoring functionality in areas

where structural integrity (incised channel, headcuts, knickpoints, developments, and

diversions) and/or appropriate species composition are compromised.
x Aspen—treatments in quaking aspen management habitats would focus on improving the health

of aspen stands by stimulating aspen stand suckering and sucker survival.

x Pinyon-juniper—treatments in singleleaf pinyon pine and Utah juniper habitats would focus on

thinning historic pinyon-juniper communities to promote woodland health and removing

pinyon-juniper where it encroaches into riparian areas and upland habitats, including

sagebrush habitat.

x Sagebrush—treatments in sagebrush habitats would focus on restoring the sagebrush

community by removing encroaching pinyon-juniper, promoting the reestablishment of native

forbs and grasses in sagebrush communities, and promoting the development of sagebrush in

areas where it occurred historically.

BLM states:

The 3 Bars Project Draft EIS identifies and evaluates treatment alternatives to implement the proposed

project to meet resource management goals. In addition to the All Available Methods Alternative, three

other alternatives are analyzed in the Draft EIS.

The No Fire Use Alternative would target the same treatment areas, but the methods of treatment

would not include prescribed fire or wildland fire for resource benefit.

The Minimal Land Disturbance Alternative also targets the same areas for treatment, but further limits

the methods of treatment to exclude fire use, mechanical treatments, and non-classical biological

controls.

The BLM anticipates that more acres would be treated under the preferred alternative due to the lower

cost of some of the treatment methods that would not be available under the other alternatives. A No

Action alternative has also been included for comparison purposes with existing management

conditions.

[Vegetation Treatment Planning and Management - Treatment Costs- 4-37] BLM has not adequately

revealed how extraordinarily expensive the Preferred Alt. actions are, and how much all linked and

connected actions, including massive seeding, herbiciding, etc. as weeds invade – would be.

[Vegetation Treatment Planning and Management - Treatment Costs - 4-38] It has also not quantified

the scenic, cultural, natural historic, wildlife and wild horse viewing, water sustainability loss and other

treatment-related costs and losses values. [Alternatives - 4-39] It has not considered a reasonable range

of passive and some active restoration actions.

Three additional alternatives were considered but eliminated from detailed analysis.

... Based on written and oral comments given during the scoping period, 637 catalogued individual

comments were recorded during scoping for the 3 Bars Project EIS.

Vegetation treatment planning and management and vegetation treatment methods were the primary

topics of concern to the public. Respondents were also concerned with the impacts that treatment

actions would have on the spread of invasive species, the viability of wild horses and livestock,

preservation of old growth woodlands, and protection of habitat for wildlife and special status species.
Well, this is because this project was billed from the start as a massive vegetation treatment scheme.

Instead of paying attention to the public comment and removing land areas and watersheds from

treatment destruction that involves large-scale killing of trees and sage as collateral damage, the BLM

persisted in this sprawling destructive scheme under its Preferred Alternative.

[Proposed Project and Purpose and Need - Public Involvement - Scoping Issues and Concerns - 4-40]

A large majority of the comments expressed serious concerns about the harms caused by aggressive

vegetation-destroying treatments, impacts to wild horses, etc. These were downplayed or largely

ignored in the EIS.

In reality, the persistence of the sensitive species (and any appreciable number of big game animals,

too) is doomed in this landscape BLM claims to want to help out sensitive and important species with

an aggressive battery of highly invasive and extremely expensive treatments.

[Proposed Project and Purpose and Need - Public Involvement - Scoping Issues and Concerns - 4-41]

BLM claims: All relevant issues identified through public scoping have been analyzed in this EIS to

the extent practicable. BLM uses “to the extent practicable” to cast aside any concerns that do not fit

with its biased circular reasoning that is used to justify the Proposed Alternative. This violates NEPA’s

hard look requirement. BLM also fails to consider a broad range of current ecological science that

shows the very high and extreme risk associated with this tens of million of dollars bio-engineering

scheme.

We incorporate by reference all our Scoping Comments and Literature submitted as well as concerns

raised by the public - into these comments.

DEIS REVIEW

[GlossaryǦ4-42ȐThe DEIS needs to be drastically revised. First and foremost BLM needs to

carefully define restoration. Because what BLM is calling restoration in Three Bars is just the same

old senseless destruction of sage and pinyon-juniper that the agency has been conducting for over 50

years now. The results of all the past treatments have been ruinous. From the Vale Project in eastern

Oregon that destroyed millions of acres of sagebrush to the Ely sage and PJ treatments that are choking

sage-grouse habitats with cheatgrass.

[Wildlife Resources - Environmental Consequences - 4-43] BLM claims a mosaic will be good. A

mosaic represents habitat fragmentation of a vegetation community. Imposing an artificial mosaic

in a complex wild landscape result in extensive edges and disturbed areas that promote invasive

species, livestock concentration in disturbed open “treated” sites, favor mesopredators that rely on

disturbed habitats, causes a loss of security and hiding cover, and represents overall habitat loss and

fragmentation. In fact, a “mosaic” represents fragmentation – for sage-grouse, Brewer’s sparrow, sage

thrasher, sage sparrow, loggerhead shrike, pygmy rabbit and other important, rare and sensitive

sagebrush species. This is especially the case because the habitats are already often frequently broken

up and disrupted by roads, past treatments, cattle salting sites, cattle fences, water troughs, mine

exploration damage, etc.

Likewise, treatment of PJ in a mosaic represents the same thing – and it increases vulnerability of big

game to poaching, hunting mortality, etc. and wild horses to human disturbances.
Creating a vast network of mosaics in a landscape is akin to allowing proliferation of a vast new road

network – as the blocks, lines, whatever patterns, will all increase weeds and human disturbance – just

like roads do. See the review of Veg treatment failures and WWP Ely treatment information.

[Wildlife Resources - Environmental Consequences - 4-44] BLM ignores the basic biology of species

needs – for example, Steve Knick’s work in the Snake River Birds of Prey Area found that sage

sparrows are area-dependent and require large continuous blocks of sagebrush for nesting. Pygmy

rabbits require dense sagebrush – which agencies always try to destroy in treatments – because of the

long-standing range biases against any denser woody vegetation. This is precisely the habitat the

“mosaic” treatment destruction will seriously alter. We have observed Ely BLM’s vegetation mosaics

from mowing, beating, crushing, and herbiciding. They selectively target the taller more structurally

complex dense sage – i.e. – the exact kind of sties where pygmy rabbits live, or sage-grouse may nest

– and selectively destroy those areas in a claimed “mosaic”.

[Native and Non-invasive Vegetation Resources - Environmental Consequences - 4-45] “Mosaic”

treatment is also the perfect recipe for maximizing rapid-fire cheatgrass and other invasive species

spread across the landscape. Instead of doing what BLM used to do – essentially level a square section

of land – the very harmful mosaic scheme will maximize acreage of native vegetation exposed to

increased weed risk will be spread out over much larger areas – thus making weed risk exponentially

greater and exponentially harder to deal with. Weeds will result form this destruction of protective

woody vegetation that moderates site conditions and protects sites from trampling, from producing

hundreds or thousands of hotter, drier, weed-prone sites, from transport of weeds all over the place in

crosscountry travel, etc. See WWP Ely treatment report, comments, appeals.

The use of the term ‘mosaic” represents the agency trying to use a catchy phrase to cover up attempts

to farm public lands for livestock forage. A mosaic disturbance is in fact, the treatment equivalent of

“sprawl”.

BLM states:

 .... when restoring sagebrush habitats. These include using a mosaic design where treated areas have

a width of no greater than 200 feet between untreated areas, avoiding treatments near greater sagegrouse leks that results in a decrease in canopy cover of greater than 15 percent, and avoiding

treatments in breeding, brood-rearing, and wintering habitats during those times of the year when

greater sage-grouse are using these habitats. The BLM, as mitigation for the 3 Bars Project, may also

manage livestock where necessary to meet greater sage-grouse habitat goals. These goals include

having suitable sagebrush cover in greater sage-grouse nesting, brood-rearing, and wintering areas

and ensuring that allowable use levels for livestock for herbaceous species are appropriate within

greater sage-grouse habitat.

The adverse impacts of the mosaic and other treatments and bio-engineering would be amplified

because BLM will use them to drastically alter the better condition remaining habitats in the landscape.

All that will be left for the wildlife, wild horses, recreational uses and enjoyment are the areas in the

worst condition. The previously better condition ares will be treated to bare dirt ad piles of chips or

crushed sage.

ALL of the above is highly uncertain, and made even worse by the lack of certainty and opaque

wording of the EIS; Examples:
[Livestock Grazing - Environmental Consequences - 4-46] DEIS at 3-7: “Open range livestock

operations are expected to continue ... short-term (typically 2 to 4 year) temporary suspensions of

AUMs would be expected in response to prescribed fires and the temporary loss of forage ...”. This

time period is greatly inadequate to recover the understories, microbiotic crusts, hiding cover, shrubs to

promote site stability, shade the ground surface, slow snowmelt, block wind, and overall site recovery.

etc. It also represents a view of these lands that pervades the EIS – that “forage” is what really matters,

and everything else is expendable.

This is precisely the failed mentality that has resulted in the disastrous outcomes of BLM fire rehabs

across the West.

BLM then, alarmingly, states:

In order to ensure long-term success, restoration projects would not be conducted in areas with

moderate to severe forage utilization until mitigation measures associated with grazing management,

as discussed in Section 3.17.4, are implemented through agreements or decisions subsequent to the 3

Bars Project Record of Decision to ensure proper utilization levels during the appropriate season of

use. The BLM would work with permittees on a permit by permit ...

[Livestock Grazing - Environmental Consequences - 4-47] This shows that BLM has not prepared the

necessary up-front grazing analyses with full public involvement that would allow it to understand

where these areas are. Where is a map showing the highly degraded areas that BLM plans to avoid like

the plague? How was this determined? Why is BLM not planning to issue Full Force and Effect

decisions to address the chronic grazing abuse that is occurring, and try to heal the lands before tearing

them to pieces? Why is there a large “dis-connect” between action on grazing (which promotes

flammable exotic species and altered fire cycles, and causes habitat degradation and loss) and any

“treatments”?

In fact, these are precisely the areas, where sage or PJ is present and weeds have not yet choked the

understories - where Battle Mountain BLM should be focusing its efforts on for removal of livestock

so that passive restoration actions can occur before it is too late, and cheatgrass sweeps the

understories. This is a highly likely outcome unless BLM removes this very significant chronic grazing

disturbance threat, and reduces grazing competition with wildlife and horses.

[Cumulative Effects - General - 4-48] BLM plans to focus on ripping apart the best remaining

communities – dealing a double blow to sage-grouse and other sensitive species. First, BLM will allow

serious degradation to continue indefinitely – and with lands on a downward trajectory, plus the largescale mining geothermal, powerline and other impacts. The combined adverse effects of the battery of

treatment disturbance and continued livestock grazing of degraded lands is (as well as all the treated

lands, too) are highly likely to doom sage-grouse, pygmy rabbit, pinyon jay and other sensitive species

persistence and population viability in the Three Bars Ecosystem.

BLM states:

To reduce the cost of treatments to the taxpayer, the BLM would seek outside funding partnerships

with other resource agencies, non-governmental organizations, or private industries that are

interested in resource management within the 3 Bars ecosystem. Additionally, it is anticipated that

habitat enhancement activities authorized with the 3 Bars Project decision would provide

opportunities to utilize off site mitigation funds ...
This shows that in reality this whole EIS is an effort to find somewhere to readily apply (and likely

waste) millions of dollars mine, geothermal or other mitigation funding. BLM refuses to deny

applications like McGinness Hills, or limit Mount Hope to any significant degree – i.e. the agency has

abandoned a basic consideration in mitigation, i.e. mitigation by avoidance. This also shows that BLM

appears to understand that mining destruction is likely to occur to an even greater scale than already

planned. So, in order to cover up on paper the magnitude of the mining, geothermal and other habitat

destruction that is underway or foreseeable, BLM will just throw stacks of “mitigation” funds at killing

trees and sage somewhere. BLM forgets about another basic consideration in mitigation, i.e. effective

protection of other areas to increase habitat quality and integrity.

This also shows there is no urgency, and really no need for the scale of the project’s destruction – other

than to spend mitigation dollars under the façade that BLM allowing large-scale development in this

landscape can be effectively mitigated. We also note the serious failures of the EIS to properly and

effectively mitigate impacts of any and all of the proposed treatments.

Sage-grouse are a landscape bird. Some of the areas with recalcitrant permittees or that are in degraded

conditions are located in lower elevations and thus are critical winter range or have other very

important habitat attributes that BLM is refusing to protect. Some of these areas suffer severe cattle

degradation, with cattle standing out eating the equivalent of dirt – yet leks cling to existence in the

areas because they are snow-free in spring and still have a little sage left. But instead of undertaking

passive restoration actions to actually remove grazing or greatly decrease it in this landscape and heal

understories as well as expand the sagebrush itself in burned areas– BLM focuses on cutting down

trees, because of the resistance of the livestock industry to change.

BLM must scrap the flawed and inaccurate “modeled” NRCS Ecosites. Use of the NRCS Ecosites is a

big problem. They are models, based on erroneous historical disturbance and fire information. They

are heavily biased towards promoting livestock forage grass at the expense of ALL woody vegetation

and microbiotic crusts. There appears to be no area that ever meets the ideal Ecosite conditions – so all

areas are selected for potential treatment because they are all unhealthy. And the more important the

areas are to sensitive species (older and mature woody veg) the sicker the models portray them to be.

This warped Veg assessment scheme underlies the AECOM ENLC range health assessments. [Native

and Non-invasive Vegetation Resources - Assessment Methodology - Baseline StudiesǦ4-49] We

stress that the interested public was not informed of these assessments, even though they greatly

impact the fate of grazing allotments and HMAs.

[ Native and Non-invasive Vegetation Resources - Affected Environment - Sagebrush - 4-50ȐTry

figuring out just how little sage the Ecosites claim should be present - not enough to hide a sagebrush

vole, let alone a pygmy rabbit. A Supplemental EIS must be prepared t examine this factor alone.

What is the basis for the definitions in the EIS? For example, “encroachment”. These are an example

of arbitrary and circular reasoning – with ever-malleable definitions concocted to justify whatever

BLM wants to do to destroy native vegetation communities all the while spending huge sums of

federal tax dollars.

[Native and Non-invasive Vegetation Resources - Environmental Consequences - 4-51] Natural

succession is natural succession, it is not “encroachment”. In order to understand succession, BLM

must first determine the natural historical vegetation community on the site. The use of the Nevada

NRCS Ecosites and ENLC’s models will not enable the BLM to do this. BLM must examine the
historical information, and the elevation, aspect, precipitation patterns, etc.

[Glossary - 4-52] Where did the new silly term “densification” come from? How was the so-called

“densification” on all sites determined? BLM ignores the inherent natural complexity of native shrub

and tree communities. Complex changes in woody vegetation composition, structure, density, etc.

occur based on subtle changes in soil moisture due to snow deposition, slope, etc.

[Native and Non-invasive Vegetation Resources - Affected Environment - Sagebrush –4-53] BLM and

the false Ecosites ignore the recent work by Bukowski and Baker and others that show naturally dense

sagebrush was historically commonplace across the Great Basin. They ignore the work by Romme et

al., Lanner and Frazier 2012, and the classic work on Nevada’s PJ communities – Dr. Ron Lanner’s

The Pinyon Pine.

Use of a generic one-size-fits-all description will destroy the inherent biodiversity of the sagebrush

communities, and the specific attributes that sensitive species require.

What is the potential natural community? The Scoping maps were wildly incorrect.

What is the scientific basis for the following definitions?

Restoration is the implementation of a set of actions that promotes plant community diversity and

structure that allows plant communities to be more resilient to disturbance and invasive species over

the long term ...Resilience is the ability to recover from or adjust easily to change.

Why did BLM involve a contractor who does biomass plants and co-gen plants and also mine EIS’s -

who then used Eastern Nevada Landscape Coalition - if you wanted an accurate and unbiased

assessment of the Three Bars landscape? See WWP e-mail of 11/18 to BLM Manager Furtado

describing contractor AECOM developing biomass plants, involvement in geothermal facilities,

etc. The end result of all ENLC assessment we have seen agencies use is contrivance used to find

everything unhealthy so that widespread destruction of native communities can be justifiedWe are

submitting our various Appeal filings for the Cave-Lake Vegetation Treatment project for the record in

the Three Bars EIS project.

[Vegetation Treatment Planning and Management – Methods - Planting and Seeding - 4-54] Why is

BLM planning to destroy the Three Bars landscape by planting species like crested wheatgrass or

forage kochia, at the same time it is removing them?

[Soil Resources - Environmental Consequences - 4-55] BLM states: Key concerns identified in the

AECC for range resources are that one or more key perennial grass species are absent. Why is the

absence or reduction and degradation of microbiotic crusts not a key concern?

BLM states: The composition and/or production of key species are below the potential for the natural

community.

[Glossary - 4-56] How has BLM defined key species – this whole section sounds like a plan to try to

get some more cattle use in depleted lands – while destroying sage, crusts, and PJ;

BLM states: Invasive or non-native species are dominant in certain areas. Shouldn’t this be a cause
for alarm at the effects the massive treatments disturbance may have – i.e. invasive species???

[Livestock Management - Environmental Consequences - 4-57] WHAT role has livestock grazing

disturbance had in this: Sagebrush monocultures are present. Sagebrush “monocultures” are naturally

occurring vegetation communities – and there is often considerable structural diversity and age class

diversity as well as well-developed microbiotic crusts present. What will the effects of removing

livestock grazing for decades be in turning this around? What is preferable?` The EIS also states: Some

streams, springs, and meadows are functioning at less than their proper condition. WHERE are these,

and what role has livestock grazing had in this?

[Native and Non-invasive Vegetation Resources - Affected Environment - Pinyon-juniper - 4-58]

Other key vegetation concerns identified in the AECC included the expansion of the pinyon-juniper

plant community onto adjacent range sites and encroachment into the interspaces within woodland

sites. WHERE specifically is there expansion, and how has BLM determined this is expansion and not

re-occupation and/or natural succession? ;

... deterioration in the condition of native plant communities in some areas.

[Livestock Management - Environmental Consequences - 4-59] What will BLM actually do about

livestock grazing as a cause of deterioration? How will you ensure the lands will heal prior to massive

bioengineering disturbance?

 ... degradation of range conditions

[Livestock Grazing - Environmental Consequences - 4-60] What will BLM do about livestock grazing

as a cause of deterioration?

[Native and Non-invasive Vegetation Resources - Cumulative Effects - 4-61] ... decrease in pine nut

production and tree vigor

What role has drought had in this, or impacts of livestock compacting soils and otherwise influencing

ecological processes?

How has BLM determined what causal factors may be pine nut production changes;

decrease in the occurrence and health of traditional, edible, and medicinal plants used by Native

Americans;

What role has livestock grazing had in this decrease?

[Native and Non-invasive Vegetation Resources - Cumulative Effects - 4-62] ... decline in woodland

species and health

What role does livestock grazing and climate change play in this? What role has past BLM treatment

played in this?

[Wildland Fire and Fire Management - Environmental Consequences -4-63] ... excessive buildup of

hazardous fuels.

What is the basis for saying fuels are “excessive”? Under the FRCC Models (which are based on
inaccurate historical and disturbance regimes completely unsupported by current science) pretty much

anything other than bare dirt and an occasional grass plants are categorized as “excessive”. This is just

like the Ecosite and ENLC models finding any older vegetation is fit only for treatment destruction

Weeds categorized by the State of Nevada as “noxious” and invasive, and non-native annual grasses,

occur sporadically throughout the 3 Bars ecosystem, particularly on wildfire burn scars, near roads

and streams, and on disturbed areas. The key concerns from the AECC for noxious weeds and other

undesirable invasive non-native species is the potential for the establishment and spread of noxious

weeds and cheatgrass monocultures resulting from past wildfires and in areas of high soil disturbance.

[Alternatives - 4-64] Why is BLM not then addressing all livestock grazing disturbance across this

landscape up front, long before issuing a massive treatment EIS with a bioengineering Preferred

Alternative?–instead of avoiding dealing with problem grazing areas? [Vegetation Treatment Planning

and Management - General - 4-65] Why are you then promoting aggressive weed-spreading treatments

of naturally dense sagebrush and sage sites with few weeds currently present? The focus of treatments

would be to control the spread of noxious weeds and invasive annual grasses found within the 3 Bars

ecosystem and to encourage the establishment of native and desirable non-native species. [Vegetation

Treatment Planning and Management - Methods - Planting and Seeding - 4-66] Why are you

encouraging the establishment of desirable non-native species? This reinforces that this EIS is

aimed at promoting livestock forage grass – at the expense of all other values of the public lands and

all other components of the Three Bars sagebrush and PJ ecosystems and watersheds.

BLM states:

Key stream components, such as stream channel sinuosity, streambank stability, and occurrence of

woody and rock debris in stream channels that help to dissipate flood energy, are lacking in many

streams. Pinyon-juniper woodlands have encroached into wetland and riparian areas. Wetland and

riparian habitat is declining and plant vigor and density are deteriorating. In addition, upland

perennial deep-rooted herbaceous species are being lost, resulting in decreased infiltration rates and

increased run-off and surface erosion and thus contributing to reduced water quality.

It is often the trees that are the only thing holding watersheds together. The only thing shading streams,

the only vegetation that can withstand the chronic annual onslaught of cattle and sheep across the

landscape. See Riparian HCA documents.

[Native and Non-invasive Vegetation Resources - Affected Environment - 4-67] What is all the

underlying information used in compiling Map 1? BLM lumps many different factors together, and

colors in areas to massively disturb and promote weeds in, and greatly alter, fragment and destroy PJ

communities and sagebrush communities, as well. We note the underlying contours show that BLM in

particular targets naturally occurring PJ communities in steep, rugged mountainous terrain at higher

elevations –which is precisely where PJ is the naturally occurring native vegetation community across

the region. Is this derived in some part from the Scoping Mapping? If so, that showed there should be

no PJ present in the landscape – at all – which is incorrect and false.

[Native and Non-invasive Vegetation Resources - Affected Environment - 4-68] So, is the Scoping

mapping part of the basis for the DEIS? What vegetation community baseline information was used in

developing Map 1, and all the findings of deficiencies lumped in various categories?
The EIS states:

Surveys and monitoring have shown that some sagebrush-steppe, wetland, riparian, and mountain

shrub habitats in the 3 Bars ecosystem are deteriorating, while pinyon-juniper woodlands are

expanding and encroaching into these habitats. Key concerns from the AECC include less than optimal

fish and wildlife habitat; expansion of pinyon-juniper into important habitats; reduction in key habitats

due to degraded range conditions in some areas; invasion of undesirable species into habitats; decline

in the health of native plant communities; and high, very high, or extreme risk of catastrophic wildfire

in greater sage-grouse habitats.

The EIS states:

1.2.5 Wild Horses

The key concern from the AECC for wild horses is rangeland degradation from multiple factors, as

indicated by limited key plant species abundance and recruitment within the understory.

The Project includes Fish Creek North (appears to be part of the larger Fish Creek HMA), Whistler

Mountain, Roberts Mountain (which is adjacent to Whistler Mountain), and Rocky Hills. [Wild Horses

- Environmental Consequences - 4-69] How has BLM systematically and methodically separated wild

horse impacts from livestock impacts? How has BLM taken livestock trespass and non-compliance

into account in this? Please provide all the monitoring and other data this claim is based on in a

Supplemental EIS.

[Livestock Management - Affected Environment - 4-70] What systematic methods were used in

monitoring? How closely did livestock monitoring actually track livestock use periods?

[Wild Horses - Environmental Consequences -4-71] What reference areas is BLM using to separate

livestock vs. wild horse impacts? Are there any? Where? What size? What do they show? This Project

spans 4 HMAs, and Fish Creek extends beyond the Project area. What is the condition of lands outside

the Project area? What are the threats to those areas – from mines, weeds, energy, grazing, roads, etc.?

[Wild Horses - Affected Environment - 4-72] Where are all foaling areas, winter habitats, etc. and how

do the horses and individual horse bands use this landscape? Detailed site-specific information must be

provided in a supplemental EIS so that the full effects of the treatments can be understood, and so that

a range of reasonable alternatives can be developed.

1.2.6 Livestock

Key concerns identified in the AECC for range resources are that one or more key perennial grass

species are scarce; the composition and/or production of key species are below the potential for the

natural community; invasive non-native vegetation is dominant in certain areas; sagebrush

monocultures are present; and some streams, springs, and meadows are functioning at less than their

proper functioning condition.

[Livestock Grazing - Environmental Consequences - 4-73] Why does BLM consistently obsess over

livestock forage grass, and not degradation of microbiotic crusts, or simplification of sagebrush

structural complexity due to livestock that renders areas less suitable for many sagebrush species like

pygmy rabbit, and for migratory birds and sage-grouse that require complex overhead shrub cover to

hide nests? Or livestock degradation of understories and microbiotic crusts - which promotes

increased tree densities?
1.2.7 Fire Management

[Wildland Fire and Fire Management - Affected Environment -4-74] Key concerns from the AECC

for fire include excessive hazardous fuel loads and fuel situations, and declining ecosystem health in

some areas, which are contributing to high wildfire potential and threats to resource values. Then

WHY haven't there been immense and large-scale fires here, like so many other places? The largest

sage lands fires occur in large stands of grass, and particularly with cheatgrass in the interspaces.

BLM states:

The BLM proposes to treat vegetation using manual and mechanical methods, biological controls, and

fire (both prescribed and wild land fire for resource benefit). Treatments would address multiple

resource issues and aid in restoring functionality to key elements of the 3 Bars ecosystem.

The BLM has identified site-specific treatment projects that it proposes to implement to restore and

manage the 3 Bars ecosystem. Treatment projects were identified through an iterative process

involving the BLM and other federal and state agencies. Treatments would focus on four priority

vegetation management concerns ...

Riparian—treatments in riparian habitats would focus on restoring functionality in areas where

stream structural integrity (incised channel, headcuts, knickpoints, developments, and diversions)

and/or appropriate plant species composition are compromised.

We are very concerned that instead of restoring functionality, erosion, weed, and water and habitat loss

will be worsened. Fencing would also shift and intensify impacts in unknown ways. A Supplemental

EIS must be prepared to alleviate this uncertainty.

• Aspen—treatments in quaking aspen (aspen) habitats would focus on improving the health of aspen

stands by stimulating aspen stand suckering and sucker survival. Battle Mountain knows full week how

to do this – control livestock impacts.

Please see Charles Kay’s Battle Mountain aspen studies. In fact, WWP’s Fite recalls participating in a

Charles Kay aspen tour in the Simpson Park Range – where a livestock exclosure drastically showed

the severe adverse impacts that livestock grazing was having on aspen regeneration and clone health

and viability within the Three Bars EIS project area. Please review the series of reports that BLM paid

for showing the dramatic need to address livestock grazing impacts on aspen. [Native and Noninvasive Vegetation ResourcesǦEnvironmental Consequences - Aspen -4-75] So why is BLM not

focusing on removing livestock browse pressure and pressure o sensitive watersheds, and/or applying

mandatory measurable use standards that sharply limit aspen browse? These must be conservative

standards of 5 to 10% or less of readily accessible aspen suckers can show any browsing impacts.

• Pinyon-juniper—treatments in pinyon-juniper habitats would focus on thinning historic pinyonjuniper communities to promote woodland health and removing pinyon-juniper where it encroaches

into riparian zones and upland habitats, including sagebrush habitat, or outside of proper ecological

state.
[Native and Non-invasive Vegetation Resources - Affected Environment- Pinyon-juniper -4-76]

WHERE are all historic Pinyon-juniper communities, and how did you identify them? What is a

“proper ecological state”, and how was it defined, descried, and what scientific studies and sitespecific information is this based on?

• Sagebrush—treatments in sagebrush habitats would focus on restoring the sagebrush community by

removing encroaching pinyon-juniper, promoting the reestablishment of native forbs and grasses in

sagebrush communities, and promoting the development of sagebrush in areas where it should occur

based on ecological site description reference, desired state, or management objective.

The last line obviously refers to BLM using flawed NRCS/AECOM/ENLC models or their ilk to claim

that nearly all lands that currently are occupied by trees of any age should not have any trees present.

This is shown to be false by BLM’s own General Land Office Survey Records across Nevada, and a

broad body of other current research.

The DEIS Purpose and Need is claimed to be:

[Assessment Methodology - Baseline Studies - 4-77] Improve woodland, rangeland, and riparian

health, productivity, and functionality. Then where is the baseline data on to what degree is livestock

grazing impairing these values? Mining? Geothermal activity?

• Increase stream flows and restore channel morphology in degraded streams. Killing off all the trees

will not do this – in fact, it is likely to cause large-scale new erosion, gullying, headcutting and loss of

perennial flows. This is especially the case during summer thunderstorm or winter/spring snowmelt

runoff events in these highly damaged watersheds. In fact, we have just seen these very effects play out

in the Owyhee Canyonlands in an area where BLM extolled a “controlled” wildfire turned run-away

wildfire over 45,000 acres in 2007. BLM claimed the fire was greatly beneficial – as it had burned off

juniper (along with killing significant sagebrush). BLM then rested the area for a mere 2 or 3 years –

and allowed livestock grazing to resume. Then in 2013 there was a summer rainstorm event on the

combination fire and cattle-ravaged redband trout habitat, and the streams blew out. Burning and/or

clearing of trees on steep slopes in mountainous watersheds had highly predictable results.

The lesson of this fire event, and BLM’s glowing claims of how beneficial it was – based solely on the

fact that it killed trees, shows there are grave risks with fire in livestock-degraded habitats. BLM had

“rested” the lands for periods similar to those proposed in this EIS.

• Improve stream habitat for fish and wildlife by implementing physical treatments that include

installing large woody debris, rock clusters, and check dams, and other measures that support

regrowth of riparian vegetation.

• Improve the health of aspen, mountain mahogany, and other mountain tree and shrub stands to

benefit wildlife, and Native Americans that use these plants for medicinal purposes.

• Manage pinyon-juniper woodlands to promote healthy, diverse stands within persistent woodlands.

• Slow the expansion of pinyon-juniper into sagebrush and riparian plant communities.
• Slow the spread of noxious weeds and other invasive non-native vegetation, including cheatgrass.

• Protect and enhance habitat for fish and wildlife, including species of concern such as raptors,

greater sage-grouse, and Lahontan cutthroat trout.

The BLM has also identified project purposes that are specific to fire use and improving ecosystem

management through the use of fire. These include:

• Restore fire as an integral part of the ecosystem; reduce the risk of large-scale wildfire; reduce

extreme, very high, and high wildfire risks to moderate risk or less; and develop fuel breaks within the

treatment and adjacent areas

Protect life, property, and community infrastructure, and protect fish and wildlife habitat from

devastating wildfire effects.

Treatment purposes would be met by implementing land restoration treatments in areas where

resource management goals are not being met, and the likelihood of treatments improving resource

conditions is great. The proposed treatments would range from several acres to several thousand acres,

depending on specific treatment and management goals and desired outcomes for each resource area.

1.5 Need for the Project

The 3 Bars ecosystem has long been recognized as an area in resource conflict due to the many and

competing uses ...

Well, then conduct a proper capability and suitability analysis, figure out the levels of sustainable use,

Then undertake the necessary action to make significant changes in livestock grazing management, and

alleviate livestock conflicts in areas at risk of weed expansion, with reduced microbiotic crusts, with

reduced grass understories, etc. BEFORE imposing bioengineering schemes. You might find out you

do not need to spend tens of millions of dollars tearing the landscape apart.

[Assessment Methodology - General - 4-78] What was all baseline information used to identify

Potential Natural Vegetation Communities across the project area. Was this based on NRCS

Ecosites? How did you vet the NRCS Ecosites?Do the NRCS Ecosites contain any PJ across the Three

Bars Project area? If so, where?Where are all persistent pinyon-juniper sites, as defined by Foresters?

Please provide us with a map of these areas?

Please provide the vegetation communities that were used as the ideals in the DEIS mapping - such as

Map 1 that identifies all kinds of problems - especially in the areas where junipers are supposed to

be growing - rugged mountainous terrain.

WHAT were the Ecosites/ideal communities/models used in the ENLC and other Veg info in the EIS?

Did these claim that junipers were not supposed to be present anywhere?

Use of non-natives is nonsense. Use Sandberg bluegrass, if "nothing" will grow. Is BLM still

proposing to use aggressive non-natives because they provide the tall "forage" that the hazardous fuel

cwg does? AND if there is such a risk that nothing but cwg could possibly survive – then you should

not be doing the project in the first place, and especially not destroying shrubs and trees.

[Native and Non-invasive Vegetation Resources - Affected Environment - Pinyon-juniper -4-79]

BLM proposes to remove ALL Phase I and Phase II Pinyon-juniper – this is disastrous. Why in

the world would you propose this? Many areas of Phase I and Phase II PJ are actually trees re-
occupying sites in which they naturally occur. Like sites where BLM purposefully destroyed them in

the past. How were all Phase I and Phase II sites identified? Was ENLC involved in this?

How were trees aged? Was there evidence of old burned wood, or stumps on the ground? What did

Historical survey and mining era records show?

In the DEIS TABLE of Goals and Objectives, the Goals and Objectives are often greatly at odds with

one another. Sensitive PJ species will be greatly harmed by the massive deforestation that is proposed

So will the forestry values, the watershed values, the riparian values, and all aspects of the

environment It is patently insane to propose removing all the PJ in sites BLM claims are “Phase I” and

“Phase 2”.

[Native and Non-invasive Vegetation Resources - Affected Environment - Pinyon-juniper –4-80]

BLM claims it plans to keep old growth trees greater than 150 years in Phase I and Phase II

elimination zones. Where are all such trees? How were they inventoried and identified? Doesn't the

presence of the old growth trees show you that they are the naturally occurring native vegetation

communities on these sites, or at a minimum – a very important component of the native vegetation

community and biodiversity?

[Proposed Action and Purpose and Need -4-81] WHAT in the world does this mean?

The focus of the EIS is not to restrict, limit, or eliminate Federal Land Policy and Management Actauthorized activities as a means to restore ecosystem health. These types of management actions are

defined and considered under land use planning regulations (43 Code of Federal Regulations [CFR] §

1610) and are outside the scope of this EIS.

Does this mean that BLM will not act in any way to remove cattle and sheep from even a single acre of

treated land – no matter if the public has invested millions of dollars in treatment, and no matter if the

grazing 5 or 10 years down the line will cause a proliferation of cheatgrass. This is typically what

happens in sites that had little cheatgrass present before treatment. Once BLM destroys the protective

woody vegetation by aggressive mechanical treatment and/or fire, cheatgrass increases over time –

especially starting 5-6 years down the line.

Plus – if this is indeed what this confusing statement means – does that mean the promises that

livestock will be properly dealt with in the EIS false?

This is precisely the type of action (closing lands to grazing for decades to allow recovery and protect

the public’s investment in very expensive treatments and very expensive EISs) that BLM must be

contemplating. [Native and Non-invasive Vegetation Resources - Affected Environment - PinyonjuniperǦ4-82] BLM must assess where the significant impacts of continued grazing disturbance are:

RETARDING passive restoration and failing to allow native understories and microbiotic crusts to

recover, and/or CONFLICTS with the recovery of treated lands and also with the needs of sensitive

species. A recent Ninth Circuit decision specifically said that at the Project level, BLM needed to

consider livestock allocations. In order to address the livestock grazing conflicts with restoration,

biodiversity, HMAs, etc. and the degree to which continued livestock grazing will promote hazardous

flammable fuels, this EIS is the appropriate and proper place to do so. [Alternatives –4-83] It is critical

in a restoration EIS to address and take a science-based hard look at passive as well as active

restoration measures.
BLM claims that it: ... Solicits input from national and local conservation and environmental groups

with an interest in land management activities on public lands, such as The Nature Conservancy,

Eastern Nevada Landscape Coalition, Western Watersheds Project.

BLM did far more than solicit input from ENLC – it allowed ENLC to handle the underlying basic

vegetation information used to develop this massive bioengineering and vegetation destruction EIS.

The EIS specifically states ENLC was involved in the baseline reports. This is a serious concern, due

to frequent livestock industry bent of ENLC, and the fact that the entity often takes a cut off the top of

funding for veg work. Moreover, the vegetation analyses that we have seen ENLC involvement in

significant data collection and analyses in Ely have used long-outdated and flawed models and

erroneous disturbance intervals that find nearly all vegetation communities to need treatment. We are

not certain how BLM plans to conduct these “treatments”, but in the Ely situation it also appears that -

after collecting and analyzing information using flawed models, ENLC may then also become a passthrough entity (again taking a cut off the top for administration) for contracting extremely expensive

vegetation contractors. Is that what BLM is proposing here, too? It also appears that this entity has

been involved in biomass proposals that are extremely controversial. [Vegetation Treatments

Planning and Management - Methods - Activity FuelsǦ4-84] We stress that the EIS greatly fails to

assess potential deforestation, nutrient loss and export, loss of critical habitat components with

biomass schemes. The EIS also specifically discusses “biochar”.

The Preferred Alternative also imposes profligate use of highly unselective and destructive fire.

Besides causing cheatgrass and other highly flammable exotic weeds to explode across the landscape,

prescribed fire in Nevada causes uncontrollable weeds, large-scale habitat loss and fragmentation for

forest dependent species like northern goshawk, flammulated owl, pinyon jay, and nesting and

wintering migratory songbirds and raptors. This use of fire may be an initial part of biomass schemes.

Fire kills trees, and they die and dry out. This makes them lighter to haul if harvested for a destructive

biomass scheme. [Vegetation Treatments Planning and ManagementȂMethodsǦActivity FuelsǦ

4-85] A SEIS must be prepared just to address the biomass concerns alone – as the often oblique and

uncertain wording of the EIS appears to be in part covering up significant potential biomass actions as

the EIS plays out. Is this what the odd references to dump trucks are about? Exporting nutrients and

essential small mammal habitat components form the site –to burn in an incinerator and pollute the air?

Further, biomass schemes are really often just a front for getting the facility built, then the it burns

through the wood, then the plant becomes used for toxic waste incineration, polluting the air and

harming human health.

Prescribed fires in Nevada also escape. See for example, North Schell prescribed fire report, where

agencies lit a fire on a hot summer day, and predictably it escaped and burned sage-grouse habitats.

There are a tremendous number of multiple disturbances that may be inflected on the same land area

over time. First, heavy equipment destroying woody vegetation in a multitude of ways. The

crosscountry travel hauling wood chips around, dragging slash, then burning slash. Then the weeds

appear. Then there is crosscountry ATV spraying or drift-prone aerial herbiciding. Then seeding with

tractors and grass drills. All of this will disturb, displace and stress native wildlife and wild horses, and

increase pressures on remaining undisturbed habitats, as well as conflicts with livestock in those areas.

[Vegetation Treatments Planning and ManagementǦRoadsǦ4-86] We stress that BLM never

addresses very likely road upgrades associated with all parts of this project. Small two tracks will be
smoothed out into roads, Trees will be cleared and sage crushed and destroyed- opening up wildlife

habitats.

[Proposed Action and Purpose and NeedǦPublic InvolvementǦScoping Issues and ConcernsǦ4-

87ȐTable 4-5 lists a very large number of concerns and issues raised in comments on this proposal.

Yet, the underpinnings of the entire scheme largely ignored these comments. The DEIS ignores fully

and fairly assessing scientific information in light of the comments and scientific literature that has

been provided to BLM. Instead, BLM relies on the NEPA-less, outdated PER as cover for its

bioengineering scheme.

BLM appears to be unwavering in its course to impose massive and expensive weed-promoting

deforestation schemes. In the process, BLM will also be killing sagebrush as collateral damage and

infesting disturbed lands with flammable weeds. [Wildland Fire and Fire Management - Affected

EnvironmentǦ4-88] The underlying vegetation information (and DFC/”Desired” Condition) used to

justify this are based on models that use wildly inaccurate fire return and disturbance intervals, and

fundamentally ignore the natural historical vegetation community across much of the project area and

broader landscape in the Great Basin.

[Cumulative Effects - General Ǧ4-89ȐBLM has failed to adequately evaluate land uses (grazing, fire

suppression, mining) – as we described in Scoping and throughout these DEIS comments. Moreover,

many other issues were raised – like transmission lines, roading, and addressing the direct, indirect and

cumulative adverse impacts of infrastructure and development, and the adverse impacts of these in the

region are glossed over. BLM ignores livestock facility and forage and other vegetation treatments

adverse impacts and degree and severity of degradation.

[Assessment Methodology ǦGeneralǦ4-90ȐWhere are the baseline assessments of pygmy rabbit,

loggerhead shrike, sage sparrow, pinyon jay, ferruginous hawk, etc.? We can not find them.

BLM failed to update the RMP.

[Cumulative Effects - GeneralǦ4-91ȐBy failing to take a hard look at the adverse impacts of livestock

grazing, livestock facilities, often linked road networks, the colossal footprint of large gold,

molybdenum and other mines, the adverse impacts of a battery of livestock facilities, etc. – BLM

avoids addressing causes of degradation and cumulative impacts and threats. Instead, the DEIS flails

around scapegoating native trees that provide crucial habitat for many sensitive species, for wild horses,

for big game, and that are also crucial for watershed protection in this grazing-depleted and miningdepleted landscape (historical, ongoing mining). Trees help moderate local weather and climate and

result in cooler more moderate conditions in the face of welter of adverse impacts of climate change

that are raining down on the Great Basin, that have tremendous aesthetic value, and that are a crucial

element of native biodiversity in the Great Basin.

[Wild HorsesǦEnvironmental ConsequencesǦ4-92ȐThe DEIS fails to ensure viable wild horse

herds, because it lacks necessary detailed information and analysis of the projects that will be

conducted, how grazing will be dealt with, the many stresses on the HMAs and herds, and many other

serious concerns. Typically in Nevada, when BLM conducts vegetation treatments, it rounds up the

horses. [Wild Horses - Environmental ConsequencesǦ4-93ȐHow will these treatments increase

likelihood of gathers? How will these treatments, fencing, and all kinds of disturbance impact wild and

free roaming herds, family bands, use of important seasonal habitats?
[Native and Non-invasive Vegetation ResourcesǦEnvironmental ConsequencesǦPinyon-juniper

Ǧ4-94ȐThe DEIS Preferred Alt. will thin (or completely wipe out) reforesting persistent woodland

sites (Phase I and II), does not protect old growth through its profligate use of fire, aggressive

mechanical methods are likely to injure old growth and/or cause insect infestations due to attraction of

pinyon insects to pitch in tree wounds. Wood chips attract insects as well. Thus, tree mortality will

ultimately be much greater than the just the trees killed outright in the treatments. promote and actually

specifically targets old growth and mature sagebrush communities for varies forms of mechanical

destruction, fails to adequately analyze and provide necessary passive restoration efforts, etc.

The DEIS, while making many promises about livestock grazing, helping sensitive species and waters,

and about helping wild horses, fails to provide a clear baseline and analysis of existing ecological

conditions, and stresses on the landscape. It greatly fails to balance uses and provide for sustainable

habitats, waters, and a TNEB.

[Meteorology and Climate Change ǦCumulative EffectsǦ4-95ȐIt greatly fails to address significant

impacts of drought in adding to current stresses on the landscape. It fails to assess the adverse impacts

of inflicting large-scale treatment disturbances on a perennially drought-stricken landscape. How can

BLM proposes this massive destruction – at the same time it is issuing a series of drought closure

decisions for livestock? This just shows how out of touch with the real world the entire Three Bars

exorbitantly expensive bioengineering scheme is.

BLM has developed circular reasoning definitions and concepts – cherry-picking only what justifies its

massive treatment disturbance scheme.

We have many other concerns about the failure of the DEIS to address the issues raised by commenters,

and to fully and fairly examine a broad range of opposing scientific viewpoints.

[Livestock Grazing - Environmental ConsequencesǦ4-96ȐBLM wrongly cut out consideration of a

new AML, and addressing the serious adverse ecological footprint of the livestock facility network –

not only on wild horses, but also on a broad range of important and sensitive species and other uses of

the public lands. This action involves serious disruption and disturbance to HMAs, a high risk of a

proliferation of exotic weeds that provide minimal forage, dousing the lands with chemical herbicides

as weeds proliferate (resulting in likely drift into soils, water, and non-target vegetation), destruction of

ALL Phase I and Phase II PJ that currently provide hiding, thermal and other cover for wild horses and

wildlife, as well as crucial habitat for important and sensitive species. Fences kill and injure wildlife

and wild horses, promote weeds, and artificially concentrate cattle and horses so that weed problems

are intensified. Fences cut off horse and big game access to seasonal ranges. The disturbance is likely

to displace wildlife and wild horses into sub-optimal habitats. BLM may impose temporary fences, the

EIS references permanent fencing, use of a slew of unassessed harmful herbicides, etc. BLM is also

highly likely to shift and intensify livestock use in unknown and unassessed ways (including allowing

use above actual use levels) as it tries to keep cheatgrass and weeds from dominating its massive

disturbance zones.

[Assessment MethodologyǦBaseline StudiesǦ4-97ȐBLM fails to provide necessary site-specific

information on wild horse and wildlife use of this landscape so that the differential impacts of the

massive habitat loss and disturbance to be imposed can be understood. [Cumulative Effects - GeneralǦ

4-98ȐHow will grazing degradation, grazing disturbance, mining disturbance, geothermal or other

energy development and explo activities impact wildlife use of the landscape and the viability of
populations, wild horse use and herd viability, wildfire habitats and populations, recreational uses and

enjoyment, etc.? ALL of these concerns are unanswered.

[Livestock ManagementǦAffected EnvironmentǦ4-99ȐWhat has livestock actual use been over the

past two decades? During the past decade? This is critical information, because the current damage

being caused by livestock is due to the actual use stocking levels. Further, has BLM ever verified the

accuracy of actual use reports by ranchers? If so, when and where? Also, has there been noncompliance in this landscape? If so, when and where? What sensitive species habitats and populations,

wild horse bands, recreational uses, watersheds and streams, springs and seeps have been impacted?

Aren’t some of the recent drought closure decisions Battle Mountain is issuing a result of permittees

failing to abide by agreements the ranchers violated that were to limit use during drought? Example:

Bates Mountain area/Dry Creek? In a landscape with a history of non-compliance, BLM’s ability to

live up to promises to control livestock use after treatments/bioengineering is highly uncertain. And

this just further illustrates the hubris of this bioengineering scheme. How can BLM possibly hope to

flawlessy bioengineer a wild landscape, when it can not get the livestock operations under control yet?

[Mitigation and Monitoring Ǧ 4-100Ȑ How has BLM monitoring separated out relative impacts to soils,

crusts, vegetation, watersheds, riparian areas, etc. of wild horse use vs. cattle/sheep impacts? Where

are all monitoring sites? When and how fairly were they established? Please provide all monitoring

data for the past decade. Has BLM conducted compliance checks to make sure livestock were not

grazing when not authorized in these areas?

We stress that existing degree and severity of livestock degradation is likely to be caused by grazing at

actual use levels much below active/allowable use. This means that the livestock are having a per-head

much greater degree of impact than BLM had assumed back when setting the AML. We are greatly

concerned that in allotments where livestock grazing has been at lower levels, BLM will allow

ranchers to shift and intensify impacts into untreated areas – resulting in significantly higher stocking

per acre than has been the norm during the period when the damage is being caused.

It is also essential that BLM balance uses and resolve conflicts before finalizing this action (including

in relation to treatments and any outcomes). [Vegetation Treatments Planning and ManagementǦ

MethodsǦPlanting and SeedingǦ4-101ȐIt appears since BLM refuses to use native plant species in

any seedings and is promoting massive vegetation disturbance in a cheatgrass-prone landscape – it will

end up with a coarse grass and weedland. First, weeds represent a loss of sustainable perennial forage

for horses and livestock, and even less stability during Nevada’s never-ending drought years. Second,

seeding exotics just results in even worse grazing problems –as range cons stock lands based on coarse

unpalatable grasses that get eaten less than native species. So native grasses, forbs, and even shrubs

bear the brunt of the grazing pressures. Also, mapping shows some exiting cwg areas already. WHY is

BLM not focusing its bioengineering energy on these – and acting to restore them, and recover

biodiversity including seeding sage, bitterbrush, or other shrubs?

Further, significant rest from livestock grazing is a fundamental need for any recovery from the loss of

protective woody vegetation, disturbed and disrupted soils, and heavy equipment torn and broken or

burned microbiotic crusts, and to promote recovery of native understory grasses and forbs, as well. It is

also essential to conduct passive restoration, which is essential both to prevent weeds as well as

recover understories across the spectrum of treated as well as untreated lands. This need is made even

greater by the agency’s planned use of mosaics that will maximize disturbance and infestation across

the most possible acres. This greatly increases the likelihood of doom for the native vegetation
communities. Aquifer decline (regional and local mining depletion, irrigation, SNWA or other water

export schemes, plus the added adverse impacts of climate change and aftermath of BLM treatments

all amplify adverse climate change effects. Killing trees and shrubs will result in hotter, drier , windier

sites which retain less water and have longer fire seasons. Local weather and precipitation patterns may

also be altered. All of these adverse effects must be examined intensively. In reality, fire risk is likely

to increase significantly, and not decrease.

BLM has failed to use best available science and fully and fairly consider a broad and ever-increasing

range of scientific information that contradicts, what BLM and its contractors such as AECOM (does

mining and biomass and other energy development proposals) and ENLC relied upon - in the alarming

EIS Rangeland “health” and other reports.

[Proposed Action and Purpose and NeedǦPublic InvolvementǦScoping Issues and ConcernsǦ4-

102]Thus, all of the concerns listed under Environmental Comments of Table 1-5 are not adequately

assessed, examined on the basis of flawed and limited outdated information, fail to take a hard look at

cumulative impacts (such as treatment disturbance coupled with continue imposition of gazing

disturbance, or the role of mine and irrigation aquifer drawdown on deteriorating riparian conditions

and habitat loss for sage grouse brood rearing for aquatic species, for migratory birds, and loss of

recreational uses and enjoyment.

[Proposed Action and Purpose and NeedǦDecisions to be MadeǦ4-103ȐBLM must commit to

preparing an EA and/or EIS for all projects tiered to this loose and highly uncertain massive landscape

denuding scheme.

We again note that killing off the woody vegetation greatly aids the ease of mining or energy

exploration –in what is appearing increasingly to be a mining-doomed landscape.

[Cumulative EffectsǦGeneralǦ4-104ȐWe are greatly concerned that this EIS package of

bioengineering projects is aimed at enabling BLM to more speedily ok more mining, geothermal and

other development by having an already packaged scheme to spend mitigation dollars. So lands will be

bared in treatments – easy mining explo will occur and/or the sensitive species of concern will have

been wiped out by the treatment and continued grazing schemes. So down the road, neither the woody

vegetation or the rare species will be any impediment at all to massive mining destruction across the

Three Bars landscape.

The DEIS states:

Once treatment areas and management concerns were identified, the BLM identified site-specific

projects that could occur for each vegetation management concern. In addition to considering the

current and desired health of the landscape, the team also considered several other factors when

developing site-specific projects, including: 1) how the projects would comply with statutory guidance;

2) BLM program guidance, including the Healthy Lands Initiative and the Great Basin Restoration

Initiative; 3) land use of the project area; 4) likelihood of success; 5) effectiveness and cost of the

treatments; 6) proximity of the treatment area to sensitive areas, such as wetlands, streams, or habitat

for plant or animal species of concern; 7) potential impacts to humans and fish and wildlife, including

non-game species; and 8) need for subsequent revegetation and/or restoration.
[Proposed Action and Purpose and NeedǦPublic InvolvementǦDevelopment of the Alternatives

Ǧ4-105ȐBLM cut the public out from identification of treatments, and this process. BLM must discard

the flawed AECOM/ENLC range health assessment that found nearly all lands unhealthy. BLM needs

to start over, with the public fully engaged. All the rest of the above paragraph elevates the uncertainty

of the projects and the EIS, because none of this is adequately addressed –including the many

resounding failures of the “healthy land initiative” and GBRI.

The DEIS then states:

Once the BLM refined site-specific projects, the Mount Lewis Field Office met with the tribes, NDOW,

Eureka County, and non-government organizations to discuss the approach, identify project priorities,

and to seek advice on the development of individual site-specific projects.

BLM never once met with WWP to discuss the approach, identify project priorities, and to seek advice

– despite knowing full well of WWP’s intense interest in vegetation treatment projects and their

serious adverse effects on native vegetation, hazardous fuels, and sensitive species habitat quality and

quantity, as well as population viability.

The DEIS states:

Manual, mechanical, and biological control methods, and prescribed fire and wildland fire for

resource benefit, could be used by the BLM to restore the 3 Bars ecosystem ...

The word restore could readily be replaced with destroy – as there is highly significant risk involved in

all aspects of this scheme.

The EIS states it relies on the following:

PEIS and PER (USDOI BLM 2007b, c), BLM Handbook H-1740-2, Integrated Vegetation

Management (USDOI BLM 2008b), and Environmental Assessment Integrated Weed Management

Plan Battle Mountain District Nevada Mt. Lewis Field Office and Tonopah Field Office (USDOI BLM

2009b). In addition, the BLM has identified other treatment activities that would be done as part of

projects, and could entail multiple treatment methods. These include seeding, fencing, firewood cutting,

and activity fuels disposal. Some treatment methods would not be available for use depending upon the

alternative that is selected.

Restoration depends on a solid understanding of what the underlying natural historical vegetation is,

and the EIS has not fully and fairly assessed this.

BLM tries to discard minimizing disturbance by making unsupported statements claiming that:

Manual techniques can be used in many areas and usually with minimal environmental impacts.

Although they have limited value for vegetation control over a large area, manual techniques can be

highly selective. Manual treatments can be used in sensitive habitats such as riparian zones, areas

where burning would not be appropriate, and in areas that are inaccessible to ground vehicles.

Selective cutting using chainsaws may occur in specific areas ...
[Vegetation Treatments Planning and ManagementǦMethodsǦManualǦ4-106ȐIt is not true that

hand cutting has limited value over large areas. They cost the same as the use of highly destructive

feller buncher chipper choppers, chaining, etc. BLM has hidden the massive cost of its bioengineeering

scheme – and hand cutting is no more expensive that the rest of the immense battery of destruction.

Plus it employs many more people – and not just BLM”s chosen heavy equipment contractors who get

big contracts for choppers, shredders, bunchers, bulldozers, etc. BLM can expand its Bootstraps

program, and provide job skills for young people. This whole project, instead is a bloated Contractor

boondoggle, from the very expensive EIS (has it really already cost a million dollars), to the

Bioengineering schemes themselves. The EIS must provide detailed information on the costs of fully

implementing each and every one of the projects shown on the mapping.

When one overlays the severe water erosion map, one finds that these severely water erosion sites

correspond to the vegetation communities that are targeted for massive denuding.

[Soil ResourcesǦEnvironmental ConsequencesǦ4-107ȐAll of these soils suffer significant wind

erosion when burned, churned up by livestock, etc. The mapping in the EA greatly downplays the risk.

BLM must also assess the degree of erosion of remaining topsoil and soil nutrients that are likely to

occur. Windblown dust from grazing disturbance and fire harms ecosystems far away. It amplifies the

adverse impacts of climate change on early/premature snowmelt. Thus, it is likely to INCREASE fire

risk in other sites – as they become hotter, drier, more cheatgrass prone and with longer fire seasons

due to windblown BLM treatment and grazing dust deposition.

[Assessment MethodologyǦMappingǦ4-108ȐAll of the DEIS soils, veg and other mapping is much

too general to use at the site-specific scale. In fact, important rare and sensitive species like pygmy

rabbit rely on deep soil sites which are often small inclusions in larger expanses of shallow soils. These

inclusions support taller sage that is critical for loggerhead shrike, sage thrasher, gray flycatcher.

[Soil ResourcesǦAffected EnvironmentǦ4-109ȐBLM claims to map “shredder susceptibility”. We

are greatly concerned that the EIS lacks necessary site-specific detail and integration of slope,

topography and other information essential to understand the severity of soils displacement,

compaction, etc.

[Soil ResourcesǦAffected EnvironmentǦ4-110ȐTable 3-13 provides meaningless information for

site-specific and even overall understanding. It is based on generalizations that fail to take into account

operation of equipment when wet or muddy, slope, aspect, number of turns and slopes where turns

would occur (masticators really tear up soils when turning on any significant slope area), etc. It also

fails to take into account the degree and severity of denuding that will occur.

[Vegetation Treatments Planning and ManagementǦMethodsǦActivity FuelsǦ4-111ȐSpewing

wood chips all over the ground surface smothers native vegetation and microbiotic crusts, promotes

weeds, reduces potential “forage” production, destroys habitat for ground nesting bees and other native

pollinators of rare plants, simplifies logs and woody debris essential for many small mammals and

decomposition processes that return nutrients to the soil, and also smothers the forbs that sage-grouse

require. Plus sage-grouse chicks eat insects – and a sea of wood chips is a sterile, dead understory.

Smothering the ground surface makes a uniform chip bed - with little to no diversity for the native

microfauana. It also creates a layer of continuous fine fuel. Who vetted the NRCS 2012 document cited

here?
BLM (and the USDA) arbitrarily used different factors in looking at chaining “susceptibility” vs.

shredder susceptibility. Similar concerns apply to this entire section of the EIS.

Serious Concern About Contractor Biases and Setting Stage for Biomass, and Actions to Benefit

Energy Developers, Mines and Ranchers

We are concerned with the Contractors involved. AECOM contracted with ENLC, which has a long

involvement in finding lands unhealthy, and in need of very expensive treatment. The ENLC Website

says it was hired by AECOM.

From http://www.aecom.com/What+We+Do/Energy/Thermal,+Geothermal+and+Nuclear

AECOM plays a major role in the thermal and geothermal power engineering market, by providing

our clients with a broad range of services for steam cycle, gas and hydraulic turbines, and internal

combustion engine power plants. We offer clients traditional engineering services as well as

comprehensive advisory services relating to generation planning and financing, private participation,

and client risk mitigation. ...

The website continues:

Thermal, Geothermal and Nuclear services include:

x Combined and open cycle power plants

x Geothermal power plants

x Industrial cogeneration

x Biomass and biogas

x Clean coal technologies

x Nuclear power plants

This elevates concerns that this EIS is aimed at allowing implementation of a large-scale biomass

scheme that has long been sought in Nevada.

Also:

http://www.aecom.com/What+We+Do/Energy/_news/Siemens+partners+with+AECOM+and+Bechtel

+for+the+U.S.+Army%E2%80%99s+$7+Billion+Renewable+and+Alternative+Energy+Power+Produ

ction+Program

http://www.linkedin.com/in/hicksmatthewj

http://www.ijonline.com/Articles/59299/Preview

Other Contractor Conflicts

There appears to be another contractor conflict of interest, as AECOM has also done an EIS for a mine

in Battle Mountain (and googling shows other recent NV mine work, too):

http://aecom.com/What+We+Do/Environment/Practice+Areas/Impact+Assesment+and+Permitting/_c

arousel/EIA+for+Mine+and+Copper+Leaching+Facilities+-+Nevada+USA
Under a third-party contract to the Bureau of Land Management (BLM), assessed the impacts

associated with the proposed expansion of a gold mining and processing facility and prepared two

EISs in compliance with the National Environmental Policy Act (NEPA). mine, which is in the Battle

Mountain Mining District in Lander County, Nevada, lies within a historic mining district that has

been actively mined for gold and copper for more than 100 years. More than 2,473 acres of the

proposed expansion fall on public lands administered by the BLM.

Right now, with the Regional Sage-grouse EIS processes underway, the mining industry in Nevada is

trying to distract from its own damage to watersheds and sage-grouse and other wildlife habitats as the

sage-grouse EIS and listing process plays out. This includes ignoring damage by livestock grazing

conducted under the many large public lands grazing permits spanning millions of acres that are held

by mines in Nevada. Mines buy out ranchers in order to acquire water rights and to quell complaints

about the aquifer drawdown impacts to private lands that these immense mines cause. The mining

industry points to things other than mining and grazing as being major problems for sage-grouse.

Grazing also provides a further political "in" with local county commissions that are often dominated

by ranching interests.

So BLM hired an engineering and mining contractor to do an EIS promoting large-scale destruction of

habitats provided by trees and sage in the red hot Three Bars mining and geothermal area landscape.

Given this background, it makes perfect sense, why the Three Bars EIS in Section 1.12.4 claims the

following are beyond the scope of this supposed landscape restoration EIS (all the while elsewhere

bemoaning water and riparian problems):

Issues Not Addressed in the Draft EIS

Less than 4 percent of comments received were not addressed in the EIS because they were beyond the

scope of the document or were not relevant to the basic purpose and need of the project. The following

represent the comments not addressed in the EIS:

• Complete a new inventory of public lands and associated RMP.

• Provide a new Appropriate Management Level for wild horses that examines the relative impacts of

horses versus livestock and remove livestock competition and set new Appropriate Management Levels

based on the findings. This request included detailed mapping that shows where and how livestock

facilities have proliferated into, and disrupted, wild horse Herd Management Areas.

• Provide an analysis of all demands on, and alteration of, the aquifer including the effects of all the

mining activity near Cortez-Beowawe and other areas, and the proposed Mount Hope molybdenum

mine.

• Establish a series of Areas of Critical Environmental Concern or reserves as part of this process and

act to leave large areas undisturbed.

• Include use of federal fire funds to purchase grazing permits and permanently remove livestock from

degraded lands.

• Prepare a full analysis of the worst case scenario for mining and energy development in the 3 Bars

Project area.
A reasonable person would assume that a federal agency would want to know the full scale of

problems (like aquifer drawdown that might make the springs it seeks to “bioengineer” dry up) facing

a landscape that it sought to restore. In fact, it is essential to understand the magnitude of many of the

summarily rejected concerns above so that BLM identify a sound and reasonable range of

alternatives, conduct credible scientific analysis of threats to species like sage-grouse in this

landscape, and develop sound mitigation actions.

A reasonable person would also assume that a federal agency would want to know the footprint of

mining and energy impacts in the landscape targeted for "restoration" - including to see if in fact the

wildlife in the area were largely doomed, and massive funds spent on supposed restoration would not

make a whit of difference.

A reasonable person would want to understand livestock actual use, competition, have valid rangeland

health assessments (not the AECOM/ENLC veg info based on flawed Ecosites and erroneous

disturbance intervals), and have undertaken necessary measures to allow lands to heal before

authorizing a massive bioengineering scheme. These treatments are certain to impact animal

distribution in the landscape, and access to food, water, cover, as well as the use of space.

The contractor and BLM, instead, have proceeded blindly, ignoring critical information necessary to

understand the feasibility of the bioengineering scheme, how it will impact sustainability of resources

and values of the public lands, and understand the magnitude of things like aquifer declines in order to

understand the agency’s ability (or inability) to minimize or mitigate adverse EIS bioengineering

impacts.

Alternatives Deficiency

BLM appears to be setting the stage for biomassing and exporting vital nutrients and protective woody

vegetation from this vast area of public lands (or at least its contractor AECOM is). The DEIS Chap 2

states:

Mechanical treatment involves the use of vehicles such as wheeled tractors, crawler-type tractors,

specially designed vehicles with attached implements designed to cut, uproot, or chop existing

vegetation, and bulldozers, dump trucks, pickup trucks, and trailers for moving and hauling materials.

The adverse direct, indirect and cumulative impacts of the battery of methods of destruction of native

vegetation in this EIS are mind-boggling. [Vegetation Treatments Planning and ManagementǦ

MethodsǦActivity FuelsǦ4-112ȐBLM even mentions dump trucks – which can only mean it is

contemplating massive export of wood for biomass. Just some of the litany of “treatments” includes:

chaining, mowing, mulching, shredding, tilling, feller buncher, tree shearer, targeted grazing (there is

no such thing, as livestock preferentially eat desirable native plants and cannot make any difference in

fuel loads under the conditions when wildfires actually burn and/or if the site is anything but grass).

Plus cheatgrass has a remarkable ability to produce seeds no matter how low it is grazed – so beating

an area to death one year will only mean more cheatgrass in following years). BLM also lists “classic”

biological control.

So – in its supposed “restoration” EIS treatments, BLM includes a long, long list of actions that

maximize environmental disturbance and damage. Yet, at the same time, it ignores careful and detailed
analysis of a long list of other active restoration actions that would actually help to heal the land and

prevent weeds and cut down flammable cheatgrass risk. [AlternativesǦ4-113ȐBLM ignores a full

and fair analysis of passive restoration. As we earlier described, BLM claims that larger acres just cant

be treated by hand cutting. This is simply not the case. There are millions of people needing jobs in

this country. So instead of paying wealthy contractors for feller bunchers, crushers, tree shearers,

choppers, bulldozers, etc. BLM can readily and feasibly hire crews to hand cut trees – greatly

minimizing weed risk, damage to habitats, damage to sagebrush, damage to mature and old growth

trees, etc.

Fire, prescribed fire, use of wildland fire discussion:

BLM tries to rely on a long-outdated 2004 fire plan that relies on outdated and inaccurate fire return

and disturbance intervals/inaccurate Historical ranges of variability. [Wildland Fire and Fire

ManagementǦAffected EnvironmentǦ4-114ȐWHAT are the fire return and disturbance intervals

that the 2004 Plan was based on? How do these compare to information in Knick and Connelly 2009,

2011 Studies in Avian Biology Baker and other Chapters, Bukowski and Baker 2013n? Note that

Bukowski and Baker is based on actual review of the historical survey records that found that dense

sagebrush is a naturally occurring component of the Great Basin sagebrush landscape – in sharp

contrast to the flawed Ecosites used by AECOM/ENLC in the “health” assessment, that junipers were

fond interfacing and interspersed with sage, and other vegetation information that runs counter to the

EIS claims. [Wildland Fire and Fire ManagementǦAffected EnvironmentǦ4-115ȐSee also Romme

et al. 2009, Lanner The Pinyon Pine, describing much longer fire return/disturbance intervals for

pinyon juniper, and PJ naturally burns very infrequently (every 200 years or much longer) in what

BLM fearmongering jargon terms “catastrophic” fires. A very large body of current information and

science on fires – that simply di not exist at the time of the old 2004 Fire Plan and was ignored in the

Veg PEIS and NEPA-less PER shows that large fires are climate-driven –i.e very hot, dry, windy

conditions, and that that thinning and other efforts to fire-proof large wild landscapes are not effective

under the conditions when the big fires, burn.

In fact, the science and understanding of fire has changed dramatically in recent years. Some western

state leaders are demonstrating this – for example, in Colorado, the concept of a fire plain is being

recognized, and that homes built interfacing with wild areas will be at risk, no matter how much

thinning is done. This shows growing understanding that wild fires often cannot be readily controlled.

Doesn't this 2004 BLM fire plan, of the exact same vintage as the Ely Fire plan used in Cave-Lake,

actually show that of the thousands of ignitions in pinyon-juniper, nearly all fires are of minimal size,

with many naturally being extinguished. That is what the mapping shows – so there appears to be no

need for treatment – as the best case scenario would be for lightning to hit trees, rather than grass.

[Wildland Fire and Fire ManagementȂAffected EnvironmentǦ4-116ȐIn fact, the “hazardous fuel”

pinyon-juniper are the landscape areas that are actually the least likely to burn. They burn primarily in

large-scale wind and dry conditions fire events – where no amount of very expensive chipping,

chopping crushing, etc. will make much difference. Please provide much more detailed analysis of

how fire proof these systems really NATURALLY are.

Further, BLM is attempting to make these systems become UNNATURAL and out of balance. This is

the dead opposite of “restoration”. PJ naturally burned very infrequently. And when it did burn, it

burns in large-stand-replacing fires. That is what is natural. Accepting this, and managing lands for
recovery of forested stands in many area is what true restoration of ecological processes in the Great

Basin ecosystem entails.

Nearly all the PJ systems of Nevada - and particularly the Roberts Mountain- Three Bars area that is

situated so close to Eureka and other areas of massive historical deforestation for use of wood in

processing mine ore, have suffered far too much disturbance. See Lanner The Pinyon Pine. See also

Zeier paper, on the carbonari and historical charcoal kilns within the three Bars Roberts Mountain area.

There was a massive large-scale disturbance event associated with historical late 1800s mining in

Nevada – and Eureka was at its epicenter. THIS is why there are a lot of younger trees in Three Bars.

Then, from the 1950s on, there was the massive purposeful BLM treatment and deforestation using fire,

chaining seeding, chopping, chipping, etc. to promote livestock forage grasses.

Over top of all this wood cutting and removal– since the mid-1800s, highly unnatural damaging

domestic livestock grazing disturbance (Mack and Thompson 1982) has drastically altered site

conditions and ecological processes – ranging from massive erosion of topsoil resulting in harsher,

rockier sites to grazing causing large-scale highly flammable weed invasions (Whisenant 1991,

Billings 1996, Belsky and Gelbard 2000, Reisner Dissertation, Reisner et al. 2013). See also USFWS

WBP Finding for GSG, Knick and Connelly 2009/2011 studies in Avian Biology.

And all of this radical unnatural ecosystem disturbance has been further influenced by the development

of a large network of roads and roading, mining activity with a now modern day mines having a drastic

impact on the aquifer, geothermal plant and road development, frequent cross country exploration for

minerals/geothermal - and perhaps oil and gas, transmission lines and other energy infrastructure, etc..

Roading and extensive crosscountry travel spawns flammable weeds, and this is worsened by livestock

disturbance. See Gelbard and Belsky describing how roads spread weeds.

Seeding and planting. There is a dramatic difference between seeding with a giant Amazon drill

ripping and crushing vegetation, and hand planting. Harrow seeding is very destructive, drag, drill, etc.

are all akin to farming wild lands, and the more aggressive the treatment, and then any seeding

message on top of treatment, the more risk is involved.

Riparian/wetland

BLM proposes a battery of riparian structural fixes that will do nothing to address the large-scale

desertification processes caused by livestock grazing and past deforestation, and that will be radically

amplified by imposing highly destructive veg “treatment” disturbances across this landscape.

The BLM proposes to restore streams by removing, or reducing the effects of, causative factors that

have led to stream degradation, and implementing bioengineering and other streambank stabilization

methods to restore stream functionality. Several approaches would be used to restore streams.

Because a large number of the incised gully type channels in the project area need to erode further

before they can form new floodplains, the BLM would use techniques to induce meandering (Zeedyk

and Van Clothier 2009). These include the use of deflectors and vanes to create lateral erosion of a

streambank in order to widen the channel and alter the meander geometry along the opposite bank

while decreasing velocity along the adjacent bank. The result would be accelerated erosion on the

opposite bank, with an increase in sedimentation along the adjacent bank, causing the formation of a
point bar that becomes colonized by riparian vegetation that helps to reduce erosion.

A rock channel liner, which is a long, narrow, one-rock dam, and much longer than it is wide, could be

built into a recently incised gully bottom and used to armor the bed and/or reconnect bankfull flow

with the recently abandoned floodplain.

The BLM could improve stream functionality through channel fill (i.e., roughened channel bed) to

raise the bed, and installation of large wood, boulder clusters, or other roughness elements that

promote predictable patterns of scour, deposition, and local energy dissipation.

Weirs can be used to control the grade of a stream, while log and fabric step falls, step pools and rock

rundowns, and Zuni bowls could be used to control and repair headcut advance, dissipate the energy

of the falling water, and modify streamflow. Several of these structures may be needed to stabilize the

headcut. The BLM may also stabilize channels by raising the elevation of an existing culvert to achieve

streambed stabilization, and hardening road or animal crossings to reduce the impacts of vehicles and

hooved animals on the stream channel.

[Vegetation Treatments Planning and ManagementǦMethodsǦRiparianȂ4-117ȐOr alternatively

but not considered, BLM could control the livestock sufficiently to allow willows to recover, and reintroduce beavers – Nature’s Bioengineer! Are any beavers currently present in the project area?

It appears to us that BLM plans to tear apart entire wild land watersheds, destroying vegetation

destroying what remains of natural riparian function, destroying wilderness values and values of lands

with Wilderness Characteristics in a massive bioengineering scheme. Bioengineering at a grand scale

will be a path to ecological ruin. There are too many unknowns and unpredictable variables.

This project appears to be a very convenient way to waste millions and millions of supposed

mine/geothermal development “mitigation” dollars – as “cover” for BLM allowing massive new and

harmful mining/geothermal and other development to be imposed in this area. It would rip and tear

apart watersheds without ever addressing the fundamental underlying problems of large-scale

desertification, reductions and losses of flows due to over a century of livestock grazing which

continues to this day, aquifer drawdown due to irrigation pumping and mining aquifer drawdown

across the region.

This will be the Three Bars ecological equivalent of a bridge to nowhere. What difference will it make

if there are gabions and “bioengineered” structures galore – if the water dries up from relentless aquifer

depletion?

Plus, in deforested treated hotter, drier, windier, less moisture retaining watersheds facing climate

change stress that amplifies ALL of these treatment effects (as well as the battery of adverse effects of

inflicting continued livestock grazing disturbance across these watersheds, gabions and other quick

structural fixes are highly likely to blow out in runoff in steep, rugged terrain. The violence of storm

and runoff events is expected to be amplified by climate change impacts. Deforestation, including all

the trees within 200 feet of the streams, will make matters even worse and blow-out prone. All of this

will have devastating effects on fisheries and aquatic biota.

[Fish and Other Aquatic ResourcesǦEnvironmental Consequences -4-118ȐLahontan Cutthroat

trout or other rare species eggs will be choked with sediment spilling from the treated, grazed slopes

and bioengineered, clearcut artificial stream. BLM cannot conduct ESA consultation with USFWS
based on the self-serving and inaccurate analysis of the EIS. A SEIS that honestly addresses the serious

risks and uncertainties with this proposal must be prepared as the basis for consultation.

While this energy, biomass and mining contractor AECOM EIS is full of long lists of multi-million

dollar bioengineering schemes, it conveniently forgets about the [Vegetation Treatments Planning

and ManagementǦMethodsǦRiparianȂ4-119] one thing might actually fix these watersheds,

stabilize headcuts, store water naturally in systems, and increase sustainable perennial flows – i.e.

nature’s own living, breathing, chewing dam building, water-retaining engineer – the beaver.

Not only would beaver reintroduction save massive amounts of federal funds (or mine mitigation funds

that agencies appear desperate to squander), this would also entail dealing with livestock in watersheds

so that aspen, willows, etc. could recover. It would save taxpayers great expense - due to the huge cost

of just administering federal public lands grazing permits – let alone administering them. See

Moskowitz and Romaniello (2002).

BLM clearly states that it will be using Biomass:

2.2.1.3.8 Activity Fuels Disposal

Manual and mechanical methods may result in fuels that need to be removed from the treatment site.

Woody debris and dead material left on site after treatment (activity fuels) would be disposed of

through various methods. All of the following methods would be available under Alternative A,

however, under Alternatives B and C, available methods to dispose of activity fuels would depend on

the specific authorizations allowed under each alternative. Pile and slash burning would be based on

environmental conditions and guidance in a developed burn plan.

Biomass Utilization

Pinyon and juniper activity fuels larger than 3 inches in diameter could be made available for

firewood, fence posts, biochar, pellets, etc. Coarse and large wood could be placed in-stream to

reduce vertical incisement and shear stresses in riparian restoration projects. Additionally, activity

fuel could be removed by commercial entities through contracts.

Pile Burning

Activity fuels would be selectively piled on site and burned under appropriate conditions. Piles should

not exceed 10 feet long by 10 feet wide by 6 feet high. Burn piles would be piled with fine fuels and

slash in the interior and larger fuels on the exterior. Burn piles may be covered with wax paper or

other similar material (no plastic) to promote burning. Piles would generally be burned during the

spring, fall, or winter.

Slash Burning

Activity fuels would be scattered on the treatment site to create a slash Fire Behavior Fuel Model.

Slash units should not exceed 100 acres in size. Slash would be burned during the spring, fall, or

winter.

Chipping

Activity fuels would be turned into wood chips with the use of a mechanized chipper. This activity

could take place on-site or material could be transported off-site to a staging area for chipping.

Broadcast Burning

Activity fuels could be scattered within the treatment area and incinerated using the broadcast burning

method. This would be done in areas where impacts to shrubby vegetation would be minimal.

Leave on Site
[Wildlife ResourcesǦEnvironmental ConsequencesȂ4-120] Material generated – will be left on

site in piles for wildlife. Why in the world won't BLM just let the woody material naturally de-compose

on-site, and not drag it into a pile –further tearing up the landscape with skidders and heavy

equipment ? A wide variety of native wildlife require complex woody structure and understory

composition as essential habitat components. The piles are likely to enourage mesopredators like

skunks.

[Air QualityǦEnvironmental ConsequencesȂ4-121] Contrary to BLM’s Three Bars claims - This

all represents a massive release of carbon dioxide now naturally stored in woody and other vegetation

into the atmosphere. It represents significant loss and destruction of soils (that will erode in wind and

spur early snowmelt and other adverse climate change amplifying impacts, microbiotic crusts (that

sequester carbon, stabilize soils, and help retain moisture on-site).

Wildfires typically do not burn up all the vegetation in the landscape – but are patchy, depending on

the direction of the wind and other weather conditions. These treatments and use of wood export are

highly unnatural.

BLM states:

The BLM will comply with SOPs identified in the 17-States PEIS (USDOI BLM 2007b:2-22 to 2-38),

and PER (USDOI BLM 2007c:2-31 to 2-44). These SOPs have been identified to reduce adverse

effects to environmental and human resources from vegetation treatment activities based on guidance

in BLM manuals and handbooks, regulations, and standard agency and industry practices. In addition

to these SOPs, the Mount Lewis Field Office has identified additional SOPs that would apply to the 3

Bars Project. Standard Operating Procedures that will be used for ...

[Standard Operating ProceduresǦ4-122] The list of SOPS is entirely inadequate and highly

uncertain, including the combination that may or may not be applied. The PER never underwent any

NEPA at all. Thus, there is no valid assessment of the efficacy of the long scattershot lists of BMPs

and SOPs. Plus there is no valid assessment of the potentially massive and costly amounts of toxic

herbicides that may be used.

Monitoring is Highly Uncertain, Limited, and Does Not Continue for Long Enough to

Understand Weed Invasions, Flammable Fuels Problems, Erosional Events as Weeds

Incrementally Colonize Disturbed Areas and De-stabilize watersheds, etc.

[Mitigation and MonitoringǦ4-123ȐThe BLM proposed monitoring methods and limited periods are

greatly inadequate. The DEIS states:

The BLM will comply with SOPs identified in the 17-States PEIS (USDOI BLM 2007b:2-22 to 2-38),

and PER (USDOI BLM 2007c:2-31 to 2-44). These SOPs have been identified to reduce adverse

effects to environmental and human resources from vegetation treatment activities based on guidance

in BLM manuals and handbooks, regulations, and standard agency and industry practices. In addition

to these SOPs, the Mount Lewis Field Office has identified additional SOPs that would apply to the 3

Bars Project. Standard Operating Procedures that will be used for ...

BLM also states:
Post-restoration monitoring of stream stabilizing treatments will be performed for at least 5 years to

identify maintenance needs, evaluate performance of structures and channel response, provide a basis

to modify treatments that are not performing as planned (if needed), measure effects on ecologic,

hydrologic, and geomorphic processes, and meet reporting and Clean Water Act 404/401 permitting

requirements. Photo monitoring will be used to document general changes that take place between

retakes

This proposal is the equivalent of strip mining the landscape for an extraordinarily meager amount of

biomass energy. It will greatly increase wildlife risks and impacts, as well as

The contractor EIS shows a gross and fundamental misunderstanding of natural ecological processes in

the arid landscape of the American West, and the many unpredictable outcomes of disturbance in arid

lands. In landscapes with minimal cheatgrass present pre-treatment, after the treatments, the cheatgrass

gradually increases – and often it takes longer than 5 years for the full blown weed explosion across

the landscape to be present. Plus, if BLM provides its typical minimal rest from livestock grazing, the

effects of continued grazing disturbance will only just be beginning to kick in then.

[Mitigation and MonitoringǦ4-124] The DEIS is lacking certainty about effectiveness in monitoring

and adequate mitigation for this massive cumulative disturbance across this landscape.

More Riparian Concerns

[Vegetation Treatments Planning and ManagementǦRiparian TreatmentsȂ4-125] BLM claims it

will undertake 3885 acres of riparian treatment. How many actual riparian acres are currently present?

How many were historically present? How much of this area is has wet soils at present? How will this

be altered by the project? How many miles of perennial flows? Where? Please provide detailed

mapping? How has 2013 drought affected this? What types of springs are providing flows? Are they

dependent on snowmelt?

[Wetlands, Floodplains, and Riparian AreasǦAffected EnvironmentȂ4-126ȐBLM here refers to

PFC. PFC provides no valid assessment of aquatic habitat components. Who conducted PFC? When?

Why was no assessment of aquatic habitat composition conducted? What biases are associated with

PFC? Sites are located in:

BLM identifies sites including Grass Valley [site of McGinness Hills massive geothermal development

and factory in the desert], JD, Lucky C, Roberts Mountains, and Romano allotments, which are within

the Simpson Park Range and Kobeh and Denay Valleys.

This involves large-scale bulldozing, crosscountry driving, “Track-hoes, back-hoes, and dump trucks

would be used for dirt work and to haul rock”. [Wilderness Study Areas and other Special

Management Areas -Environmental ConsequencesȂ4-127ȐWhere is a current survey for Lands

with Wilderness Characteristics? Please provide us with this document. How will this affect and impair

the values of both WSAs and LWC?

This heavy equipment use in streams amplifies the risk of adverse outcomes of vegetation treatments

by many orders of magnitude. The uplands will be also be de-stabailized, and treated to pieces. The

riparian areas and heart of the watershed will be destroyed.
It also displays a fundamental misunderstanding of the fragility of the tiny areas with perennial flow in

the streams, springs, springbrooks, etc.

With the clear-cutting of riparian habitats and their bulldozing also comes extensive use of harmful

fencing that will shift, intensify and increase damage being done by livestock into other areas, will

increase conflicts and completion with wildlife and wild horses and recreational uses, as well lead to

erosion-caused large-scale and destruction of Native American cultural sites.

[Water ResourcesǦEnvironmental ConsequencesȂ4-128ȐTrack-hoes, back-hoes, and dump trucks

would be used for dirt work and to haul rock. BLM is highly likely to puncture and destroy the

underlying clay layers where spring waters seep out, or impact areas of snowmelt deposition. See Sada

et al. 2001, BLM Technical Bulletin. This will result in killing all surface flows – which instead of

“improving” wildlife habitat and aquatic species habitat, will destroy it.

Many important wild land springs will be ripped and torn apart:

The BLM would conduct treatments similar to those identified in the previous paragraph on about 78

acres at Hash Spring, Garden Spring, McCloud Spring, Railroad Spring, Roberts Mountains Spring,

Stinking Spring, Tall Spring, and Trap Corral Spring (Garden Spring Group). Treatment methods

include manual and mechanical methods and use of prescribed fire. Treatments would include the use

of track-hoes, back-hoes, and dump trucks for dirt work and to haul rock, and grade stabilization

structures, streambank bioengineering, and vegetation plantings. A pickup truck and trailer would be

used to haul protective fencing. The BLM would also remove pinyon-juniper from riparian habitats

using manual and mechanical methods and prescribed fire. Treatment units range in size from about 3

to 18 acres.

The BLM has also identified an additional 3,262 acres of riparian habitat enhancement treatments that

would meet the ...

The BLM would use grade stabilization structures, streambank bioengineering, and vegetation

plantings on Henderson above Vinini Confluence, Lower Henderson 1, Lower Henderson 2, Lower

Henderson 3, Lower Vinini Creek, Upper Vinini Creek, and Upper Willow units (Henderson above

Vinini Confluence Group). At the Frazier Creek, Roberts Creek, Upper Henderson, Vinini Creek, and

Willow Creek units (Frazier Creek Group), the BLM would use grade stabilization structures,

streambank bioengineering, and vegetation plantings, and would also remove pinyon-juniper from

riparian habitats using manual and mechanical methods and prescribed fire. Treatment units range in

size from about 35 to 1,390 acres.

[Vegetation Treatments Planning and Management -MethodsǦFencingȂ4-129ȐAt Denay Pond,

Lone Spring, and Treasure Well, the BLM would use protective fencing, but no other treatments ... Is

this permanent fencing? Many of these projects are livestock projects and are wrongfully

bundled in with this Three Bars bioengineering scheme. All of these projects must be subject to the

OHA Appeals regulations.

BLM plans to destroy the only thing holding any semblance of riparian watersheds together across the

region – i.e. the trees.
So – after BLM strips and destroys and de-forests the watersheds, will it then bring in giant air

conditioners to cool the hot dying streams baking in the sun?

Will it then install giant filters to filter out the large-scale sediment influxes that will smother habitats

for aquatic biota?

Biomass – Typically A Cover for Toxic Waste Incineration Down The Road

Any biomass activity would be massively subsidized, or used to fritter away vast sums of mine sprawl,

geothermal development aquifer and habitat disruption, or other mitigation funds. But soon the funds

would run out, and the wood would run out. What then? Elsewhere, biomass plants have been built as

initial cover for later bringing in toxic waste to incinerate.

[Vegetation Treatments Planning and Management -MethodsȂActivity FuelsǦ4-130ȐThis is a

very foreseeable outcome of any biomass/biochar proposal in this landscape, and full and detailed

analysis of air and water pollution and human health risks of this must be assessed. Along with the

human health risks of drift of the likely massive amounts of herbicide that would end up being used in

the treatment and bioengineering-desolated Three Bars landscape.

http://www.saveamericasforests.org/Forests%20-%20Incinerators%20-

%20Biomass/Documents/Briefing/Presentations/Dioxin%20Narrative.pdf

When hydrocarbons like trees, railroad ties, tires, poultry litter, grass trash, garbage, etc.

are burned in the presence of chlorine, dioxins are created. Almost all biomass contains chlorine.

Creation is the operative word since dioxins do not exist in these fuels before burning.

[Air QualityǦEnvironmental ConsequencesȂ4-131ȐDioxins are an insidious risk. The DEIS does

not assess potential dioxin pollution from burning biomass.

Unassessed and unmitigated damage will be done to watersheds by the combined effects of this battery

of aggressive highly disturbing treatments, will mask and obscure any baseline upon which to

determine the severe adverse impacts of the aquifer drawdown and other serious environmental

disturbances caused by the massive mining operation.

The potential air pollution effects of the various ad sundry mining activities, geothermal plant releases

of toxic elements in steam and vapor, etc. will be in part masked by the likely air pollution from

potential and foreseeable biomass incinerator development linked to the massive deforestation scheme

of the EIS.

Aspen treatments: All the tractor ripping, biomassing, burning, etc. of the aspen treatment scheme is

entirely unnecessary of BLM will just get the cows/sheep out of the watershed. Please review the

series of Charles Kay reports in the BLM forester’s files.

On Page 2-23, BLM states:

An estimated 47,500 to 94,000 acres of treatments involving the thinning and removal of pinyonjuniper would be conducted on Lone Mountain, Roberts Mountains, and other areas within the 3 Bars

ecosystem (Figure 2-3). Selection of treatment areas was based on: 1) the need to remove pinyon-
juniper to develop and enhance movement corridors for greater sage-grouse between low elevation

breeding habitats and upper elevation brood rearing habitats; 2) the need to remove pinyon-juniper to

slow encroachment into greater sage-grouse lekking and nesting areas; 3) the need to remove pinyonjuniper near streams to enhance habitat for Lahontan cutthroat trout; 4) the need to remove and thin

pinyon-juniper to break up the continuity of fuels and reduce the risk of catastrophic wildland fire; 5)

the need to improve wildlife habitat on the Sulphur Spring Wildfire Management Unit using wildland

fire for resource benefit; and 6) the need to improve woodland health. Table 2-3 provides information

on unit size and amount of area to be treated, project goals and objectives, and equipment and

methods used for pinyon-juniper treatments.

The BLM would enhance habitats critical to greater sage-grouse on up to 1,387 acres in the Lone

Mountain area of Kobeh Valley using manual and mechanical methods. The BLM would thin pinyonjuniper stands to remove these trees from historic sagebrush habitats. The BLM would create a series

of fire breaks to moderate fire behavior in treated areas and reduce the risk of loss of habitat from

wildfire.

The BLM would treat pinyon-juniper to enhance habitats that are important to greater sage-grouse in

several drainages on Roberts Mountains using manual, mechanical, and fire treatments. Treatment

units include the Atlas, Frazier, Gable, Henderson, Upper Roberts Creek, and Vinini Corridor units

(Atlas Unit Group). These drainages serve as important greater sage-grouse travel corridors between

lower elevation wintering and lekking habitats and upper elevation nesting and brood-rearing habitats.

Treatments would be completed in phases, with a minimum of 9,328 and ...

We are alarmed at the extreme disturbance methods proposed to treat tress all over the Units in the EIS

Table.

BLM proposes large-scale sagebrush destruction – both alone, and that will occur as collateral damage.

BLM states:

The BLM would reduce hazardous fuels on approximately 20,202 to 55,674 acres on the

Cottonwood/Meadow Canyon, Dry Canyon, 3 Bars Ranch, Tonkin North, Tonkin South, and Whistler

units (Cottonwood/Meadow Canyon Unit Group). Fuels treatments would be done in phases with

approximately 1,000 to 2,000 acres of treatments conducted annually. The BLM would 1) reduce the

amount of hazardous fuels and wildfire risk by mowing and shredding sagebrush and thinning

pinyon-juniper stands in 500- to 2,000-acre increments with chainsaws; 2) use mechanical methods to

create fuel breaks; and 3) slow pinyon-juniper expansion into sagebrush and other plant communities

on 30 to 70 percent of the units through the use of manual and mechanical methods and prescribed fire.

BLM 2-34 states:

The BLM would remove pinyon-juniper trees infested with pathogens and/or pests by removing up to

half the trees within a unit using manual and mechanical methods and prescribed fire on the Tonkin

North and Tonkin South units. Up to 1,729 acres could be treated in these units. On the Lower Pete

Hanson Unit, the BLM would reduce both the amount of hazardous fuels and the wildland fire risk by

mowing and shredding sagebrush and thinning pinyon-juniper stands on up to 1,000 acres by using

chainsaws and mechanical methods to create fuel breaks. The BLM would treat 20 to 40 percent of the

Sulphur Spring Wildfire Management Unit using wildland fire for resource benefit to benefit a variety

of resources and to reduce hazardous fuels. An estimated 12,482 to 24,694 acres would be treated in
the unit in increments up to 1,000 acres annually. The intent of these treatments would be to restore

fire as an integral part of the ecosystem and to improve plant species diversity. By reducing fuel

accumulations and creating canopy openings in the pinyon-juniper, sagebrush and other shrub species

cover should increase by at least 30 percent from current levels. The BLM may allow wildland fire to

burn in areas where fuel loads exceed 2 tons per acre in shrublands, and 10 tons per acre in pinyonjuniper woodlands. After fires, the BLM would promote the use of burned or downed trees for

commercial or private uses. The BLM would monitor the site to limit post-fire occurrence of

cheatgrass and other noxious weeds and invasive non-native vegetation.

In most instances, pinyon-juniper treatments would occur where stands are in the Phase I and II stage

of development, and where soils are characteristic of those found in sagebrush communities. Phases

are based on stand characteristics that differentiate between three transitional phases of woodland

succession based on tree canopy, leader growth ...dominant and understory trees), crown structure,

potential berry production, tree recruitment, and the shrub layer. Pinyon-juniper stands on the 3 Bars

Project area were characterized by phases and mapped in 2010 and 2011, and this information was

used when developing pinyon-juniper treatments (AECOM 2011a). These phases, as described by

Miller et al. (2008), are as follows:

Phase I (early) – trees are present, but shrubs and herbs are the dominant vegetation that influence

ecological processes on the site.

Phase II (mid) – trees are co-dominant with shrubs and herbs, and all three vegetation layers

influence ecological processes on the site.

Phase III (late) – trees are the dominant vegetation and the primary plant layer influencing ecological

processes on the site.

This scheme is useful for identifying the successional stage in expansion communities that may

potentially be targeted for treatment. Phase III woodlands have the greatest tree density, and the

greatest amount of canopy fuels, which puts them at increased risk for loss from high intensity fires

(Tausch 1999 in Miller et al. 2008). However, according to Miller et al., treatments in Phase I and II

expansion woodlands to halt their succession to Phase III woodlands may be more successful and costeffective than treatments in Phase III woodlands.

Manual and mechanical treatments would be primarily utilized to disrupt the continuity of fuels and

reduce the risk of ....

The DEIS also states:

The Mount Lewis Field Office proposes to enhance greater sage-grouse habitat within the 3 Bars

ecosystem by treating approximately 31,300 acres of public lands on the 3 Bars, Flynn Parman, Grass

Valley, JD, Lucky C, Roberts Mountain, and Santa Fe/Ferguson allotments (Figure 2-4). Table 2-4

provides information on unit size and amount of area to be treated, project goals and objectives, and

equipment and methods used for sagebrush treatments.

These areas were selected for treatments primarily to benefit greater sage-grouse habitat and improve

rangeland health. In most areas, plant communities diverge from the expected reference state

vegetation based on ecological site descriptions. Treatments would be completed in phases and

implemented incrementally based on monitoring, funding, and BLM priorities.

At the Alpha, Coils Creek, Kobeh East, Nichols, Roberts Mountain Pasture, and South Simpson units

(Alpha Unit Group), up to 11,016 acres would be treated and treatments would focus on using

mechanical methods to thin low-elevation Wyoming big sagebrush to open up the sagebrush canopy
and to seed to promote the growth of forbs and grasses.

The BLM would use mechanical methods on about 20,297 acres at the Table Mountain, Rocky Hills,

Three Corners, Whistler Sage and West Simpson Park units to thin sagebrush to open up the

sagebrush canopy to promote the growth of forbs and grasses, and to remove or thin pinyon-juniper to

enhance or restore sagebrush communities.

[Noxious Weeds and other Invasive Non-native VegetationǦEnvironmental ConsequencesȂ4-

132ȐBLM will spawn massive cheatgrass infestation by conducting this. Ely BLM treatments have

already proven that this is the case.

This appears to be a massive assault not only on sage-grouse habitats, and also an effort to eliminate

pygmy rabbits as well, and greatly reduce and fragment migratory bird habitats.

It shows no ecological concern for the critical values provided by mature and old growth sagebrush

vegetation communities. This is worse than the worst Ely projects. Has BLM learned absolutely

nothing over the years, and evaluated the weed invasions and other disasters of its previous projects?

Table 2-3 contains in nearly all cells a long litany of severe and harmful treatment disturbances. The

same horror show of severe disturbance actions is listed across Alternatives A,B, C – for example.

Only various tweaks in disturbance acres differ.

In all of this, [Proposed Action and Purpose and NeedǦPublic Involvement –Development of the

AlternativesǦ4-133ȐBLM did not engage the public in site selection, has not considered a reasonable

range of alternatives, and has turned a blind eye to the immense irreparable damage that will be done

to habitats and populations of sensitive species, wild horses, big game, and other uses of the public

lands.

Plus, the willy-nilly alternatives differences make no sense. [AlternativesǦ4-134ȐWhy is it so

imperative to treat 1000 acres in Pete Hanson Creek, for example, under one alternative and 200 acres

under another? WHY should two alternatives –A, and B, almost always entail the same battery of

roller choppers, feller bunchers tree shearers, bull hogs, seeding, chaining mowing and activity fuel

dispersal (biomass utilization, chipping, pile burn, broadcast burn and leave onsite).

This EIS is really no plan at all – just any and all methods of disturbance applied, with no rhyme or

reason. It results in no valid basis for analysis of any kind. The Atlas Unit exemplifies this – with long

lists of Goals, Objectives, and Method/Equipment. [AlternativesǦ4-135ȐThe only difference is acres

in pre-selected land areas. These concerns apply to all Units in Table 2-3 and the EIS. BLM is merely

going through the NEPA motions of shuffling some things around in order to try to pass muster on

NEPA. It has not selected a reasonable range of alternatives in this fragile, arid, weed-prone landscape.

Then, on top of the long lists of potential methods of woody vegetation and riparian area destruction,

BLM elsewhere (and it appears later in a ROD) will apply a long laundry list of programmatic,

uncertain and often ineffective SOPs, BMPS, etc. – lacking any clarity or certainty

Thus, it is impossible to understand the magnitude of the disturbance, the risk of weed invasions, soil

erosion, loss of sensitive species habitats, etc.
[Wildlife Resources - Analysis MethodologyǦBaseline StudiesȂ4-136ȐWhy didn't BLM start by

conducting necessary baseline biological surveys across the landscape _ which are essential to

understand where species like ferruginous hawk sage sparrow, sage thrasher, pygmy rabbit - all

currently occupy the landscape, and use of seasonal habitats, or conditions across the HMAs and

identify livestock conflicts or other problems.

Instead of actually going out and looking to see areas of occupied vs. unoccupied habitats, the quality

of the habitat (presence of complex mature and old growth structurally complex sage communities, i.e.

not beaten up and broken by livestock), AECOM sent out ENLC to come up with vegetation

measurements based on flawed models of idealized veg conditions that fail to provide the necessary

habitat requirements - such as sage structural complexity and canopy cover –required by nearly all

sagebrush sensitive species. See Rich (1979) for example, discussing sensitive migratory songbird

needs for structurally complex mature and old growth sage cover. This is the type of site the Ecosite

and ENLC info finds unhealthy and in need of treatment destruction.

Alternative B is the no fire use alternative. This merely leaves one thing out of the horrorshow of

treatments, yet sites to be treated are the same lands areas, and the same BMPs. SOPS, etc. all apply.

And what about livestock grazing under the alternatives?

[Livestock GrazingǦAffected EnvironmentȂ4-137ȐDespite this EIS having been billed as

addressing livestock grazing, the comparison of Alternatives Table fails to provide any

information at all on current actual use, current active/allowable use current standards of use,

current seasons of use, current degree and severity of livestock degradation, or really any

meaningful information at all on livestock grazing.

In fact, the livestock grazing part is another list of pre-ordained inadequate BMPs and SOPs of a sort.

See FEIS 3-350-370. Uncertainty, as well as lack of alternatives, abounds here, too.

[Livestock GrazingȂAffected EnvironmentǦ4-138ȐTable 3-49 lacks actual use information by

pasture and allotment, and lacks breakdown of the grazing schedules by pasture, or any overlay of

areas with HMAs, sage-grouse seasonal habitats, etc.

[Livestock GrazingȂAffected EnvironmentǦ4-139ȐAre the “AUs” based on a 1000 pound cow or

an 800 pound cow? Or cows with 500 lb. calves?

Table 3-50 shows there are already far too many fences and pastures here – with Roberts Mountain, for

example, having 19 pastures already, and is still needing “Improvement”. Isn’t this grazed by a mining

entity? [Livestock GrazingǦAffected EnvironmentȂ4-140ȐWhy is it not being retired as mitigation,

and why isn’t this considered in an alternative action? There are nearly 100 pastures. How can many

these fences be removed and lands combined to reduce fencing, and fencing removed to help sagegrouse, enhance free roaming wild horses, etc.? Where are fences a concern on what seasonal ranges?

[Native and Non-invasive Vegetation Resources - Analysis MethodologyǦKey Management AreasȂ

4-141ȐWe are concerned that BLM arbitrarily cherry-picked 70 new key areas (or was it

AECOM/ENLC?), but does not appear to have involved the public in this. We are concerned that there

appears no rationale for why the particular allotments were selected.
BLM must start over, scrap the AECOM/ENLC flawed health assessment, and [Native and Noninvasive Vegetation Resources ǦAssessment MethodologyǦRangeland HealthȂ4-142Ȑhonestly

and accurately conduct valid rangeland health assessments. These are not properly selected sites or

properly conducted assessments under the FRH. In fact, it is this kind of ENLC assessment that has led

to the destruction of crucial sagebrush habitat in Lincoln County, and the severely flawed cave-lake

assessment, and other Ely BLM assessments. In these - the problems are always found to be the

woody vegetation and/or horses or “historic” grazing.

There is no valid reason for thinning sagebrush. The sage is not the problem it is the grazing pressure.

FEIS at 3-362.

The entire underpinnings of this scheme are based on flawed models of “Potential Natural Community”

that emphasize livestock forage at the expense of al other values of the public lands. But instead of

trying to address the livestock degradation in an integrated way, in FEIS at 3-370 to 3-372, adds

uncertainty. BLM applies upland utilization rates that will not provide for necessary site healing, or

adequate residual nesting cove for sage-grouse.

BLM also would continue to stock these lands with livestock based on the livestock eating back the

shrub cover. BLM would allow the cows and sheep to eat and break off 35% of the sage, in Wyoming

and Basin big sage sites. This is crazy. Cows are not supposed to survive by eating shrubs. [Wildlife

ResourcesǦEnvironmental ConsequencesȂ4-143ȐHere we are told that this project is to “restore”

grouse habitats, and BLM allows 35% of the shrub growth to be eaten. This will also greatly impair

any young sage recovery post-treatment.

[Livestock GrazingǦEnvironmental ConsequencesǦ4-144ȐAlso, BLM constantly makes highly

uncertain statements like “the season of use may be shifted”. Thus, there is no way at all of knowing

the outcome of effectiveness of the livestock grazing schemes to be imposed on this landscape. BLM

fails to provide any pastures or allotments as reference areas where grazing is removed so the actual

impacts of livestock vs. wildlife vs. horses can be understood. It fails to provide any significant periods

of rest to jump start recovery.

The schemes also rely on an unknown number and configuration of fences and other projects that will

shift, alter and intensify grazing pressure in unexamined ways – including potentially imposing

livestock use at levels far above actual use on lands where use is shifted to.

[Vegetation Treatments Planning and Management -MethodsǦFencingȂ4-145ȐWhy does BLM

need fences - it can pull livestock use back to existing fences to aid recovery, or actually enforce

conservative standards of livestock use instead.

Plus the AECOM ENLC assessments this scheme is based on are gibberish.

[Native and Non-invasive Vegetation ResourcesǦAffected EnvironmentȂ4-146ȐThe livestock

cumulative effects analysis claims that the health studies have shown that early to mid-seral vegetation

dominates the allotments. What does this mean? How was this determined? The sage communities are

not early seral. How is “seral” defined by AECOM/ENLC? Is this referring to the areas that burned in

fires? Won’t the treatments makes there be many MORE acres in early-mid seral, not fewer? What

value judgments are applied here.
We note in FEIS at 3-367, the EIS admits to what is clearly MAJOR aquifer depletion that would stem

from the foreign molybdenum mine – in referring to the mined drying up springs, and new water

sources for horses, wildlife and livestock being provided in new areas. This too is highly uncertain –

but reveals a much larger problem that [Water ResourcesǦEnvironmental ConsequencesȂ4-147Ȑ

the EIS refused to consider a significant concern – the aquifer depletion form the moly mine, the Carlin

trend mines to the north, mines to the east, and from ag pumping in the valleys. It is impossible to

understand how this all will affect use of the landscape by all animals, recreation, impairment of the

values of the WSA, and many important components of the public lands. Is this then why BLM plans

to cut down all trees within 200 ft of the stream? Hoping to reduce transpiration and magically make

there be more water ---- because the mines are drying up the springs, seeps and streams across the

region? And is this why the bulldozing of the streams? To obliterate any understanding of the former

floodplain, and perennial areas and volume of flows? Thus masking the full impacts of the mine (and

potentially the McGinness geothermal project) on the aquifer?

Thus, it is impossible to understand the changes in grazing that may or may not take place. And it is

clear that the DEIS fails to take a hard look at any of the complex aspects of addressing livestock

grazing degradation across the landscape. The EIS is superficial, programmatic, and it is impossible to

understand direct, indirect and cumulative impacts. There is no adequate range of conservative actions,

and alternatives addressed – such as removing livestock from areas where conflicts with sustainable

resources are greatest, or to provide large long-term reference areas.

Other Alternatives

Alternative C is the “Minimal land disturbance alternative”. Alternative D is to continue the present

course. BLM would be greatly ahead and huge sums of tax dollars would have been saved if BLM

would simply have addressed the rampant grazing degradation issues in this landscape in a

comprehensive and upfront way. [Assessment MethodologyǦBaseline StudiesȂ4-148ȐBLM fails

to adequately describe the present situation. It cannot rely on the ENLC information, or NRCS

Ecosites and state and transition and FRCC and other models that are based on inaccurate much too

abbreviated disturbance intervals and other inaccurate assumptions.

Table 2-5 contains glib generalizations that are unsupported by scientific literature and analysis. For

example BLM claims that under Alt A “numerous resources” would benefit. This is highly arbitrary,

and ignores a broad body of science showing that “numerous resources” would NOT benefit – for

example – a wide range of sensitive species would NOT benefit from having their sagebrush habitat

crushed, chopped, chipped, rollerbeaten and converted to crested wheatgrass or “biochar”.

There is no justifiable rationale for claiming that Alt A should be the Preferred Alternative.

Again here, BLM claims that it is going to restore fire as an integral part of the ecosystem – well then

BLM first has to drastically alter its use of baseline scientific understanding of fire return and

disturbance intervals, and conduct brand new accurate and honest range “health” assessments -

scrapping the flawed, inaccurate AECOM/ENLC report info. BLM must then take into full account the

current science on sagebrush and PJ fire intervals, and the severe risk of cheatgrass invasion

permanently and dramatically impacting fire frequency.

Throughout all the EIS charts and tables, the same glib assumptions are made that killing various

plants will magically “improve” habitat.
BLM Arbitrarily Rejected Passive Restoration In Its Supposed “Restoration” EIS That Is Also

Supposed to Be Addressing Livestock Grazing Damage!

[AlternativesȂ4-149ȐBLM arbitrarily rejected the passive restoration alternative elements combined

with hand cutting. Yet, BLM claims that this EIS was to address livestock grazing as well.

Significantly reducing and/or removing livestock disturbance from watersheds so that weed risk can be

minimized and recovery of native understories and microbiotic crusts can occur is reasonable passive

restoration - especially when some permits are held by the mine that is poised to drain the aquifer

further.

Instead, the EIS obsesses over uncertain disturbance methods heaped one on top of another, or one

right next to another, in the same landscape and often the same watershed, BLM ignores collecting

basic, fundamental information on things such as natural spring characteristics. See for example, Sada

and Pohlman

While discharge rates, aquifer sources,

and the presence of rare species (e.g., fishes,

aquatic macroinvertebrates, rare plants, etc.)

have been assessed at some springs, basic

information describing physical and biological

characteristics of arid land springs is very

limited. This paucity of knowledge has often

resulted in permitting activities that adversely

affect spring aquatic and riparian biota (Shepard

1993). Management is challenged to respond to ...

Springs are unique systems

WHAT ARE SPRING SYSTEMS?

Aquifer Sources

Springs are relatively small aquatic and

riparian systems that are maintained by

groundwater flowing onto the land surface

through natural processes (Meizner 1923, Hynes

1970). They are distinct from other aquatic

systems because their water temperature ...

[Water ResourcesǦEnvironmental ConsequencesȂ4-150ȐSo then why has BLM not addressed the

aquifer concerns WWP raised in Scoping?

They are distinct from other aquatic

systems because their water temperature is

relatively constant (at least near their source),

they depend on subterranean flow through

aquifers, they provide the only water over vast

areas and are therefore “biodiversity hotspots”

(Myers and Resch 1999), and many support obligatory, spring-dwelling species

(crenobiontic species) (Hynes 1970, Erman and
Erman 1995, Myers and Resch 1999)

In addition: Springs are supported by precipitation that

seeps into the soil and accumulates in aquifers

where it is stored. They occur where

subterranean water reaches the earth’s surface

through fault zones, rock cracks, or orifices that

occur when water creates a passage by

dissolving rock. Spring hydrology is influenced

by characteristics of regional and local geology,

and how water moves through an aquifer. The

size of an aquifer depends on regional and local

geology and climate, and water chemistry is strongly influenced by aquifer geology. Perched,

local, and regional aquifers are the basic types of

aquifers in the western U.S. These aquifers

differ primarily in their ...

... Mountain Aquifers

In the western U.S., springs at high

elevations (> 1,800 m [~6,000 ft]) and on

mountain blocks are generally supplied by these

aquifers. These aquifers are often perched, they

are relatively small and fed by precipitation

covering a small area (e.g., a drainage basin,

small portion of a mountain range, or series of

hills). Springs they support are cool (<10

o C) usually small, and often dry during periods of

low precipitation. Seasonal and annual

variability in discharge may also be large.

It appears to us that a significant number of the springs and small streams targeted for bulldozing work

may be characterized as dependent on mountain aquifers. Before BLM goes bulldozing away with

structural fixes, intensive studies need to be conducted, and the info and data and risk of even greater

depletion or damage from the EIS actions need to be assessed in a supplemental EIS, with the public

fully engaged.

Local Aquifers

Local aquifers are fed by precipitation from

a larger area (e.g., a mountain range) and springs

they support are located between valley floors

and the base of mountains. Flow through these

aquifers is generally deeper (< 500 m) and

springs are usually cool (> 10oC and < 20o

C), but warmer than mountain springs. Geothermal

springs (> 40oC) are also supported by local

aquifers that circulate near magma that heats

water to temperatures that dissolve rocks to

increase the concentration and number of

chemicals. Discharge from springs fed by these aquifers may also change seasonally and
annually in response to precipitation, but most of

these springs dry only during extended droughts ...

Regional Aquifers

Springs fed by regional aquifers are warm

(>20

o

C) and supplied from recharge extending

over vast areas. Flow through these aquifers is

complex, controlled by fractures, and may

extend beneath valleys and topographic divides

(Mifflin 1968, Winograd and Thordarson 1975,

Thomas et al. 1996). The movement of water

through these aquifers is slow compared to

perched and local aquifers. Water in regional

aquifer springs may also contain elevated ...

Also:

Springs and seeps occur in many sizes and

shapes, and the complex influences of aquifer

geology, morphology, discharge rates, and

regional precipitation and vegetation dictate that environmental characteristics of most springs are

unique (see Hynes 1970, Garside and Schilling

1979). They can be cold (near or below meanannual air temperature), thermal (>5

o

Springs may be broadly categorized by

the morphology of their source.

Limnocrenes

are

springs with water flowing from a deep pool,

helocrenes

are marshy and bog-like, and

rheocrenes

have a well-defined source that

flows directly into a confined channel.

In no way, shape or form do we trust the AECOM EIS to have adequately assessed this broad array of

characteristics and concerns. BLM can not merely deflect our concerns by pointing down the road to

some future analysis before dozens of separate piecemeal projects are conducted under this Three Bars

EIS. BLM has produced a map showing a vast array of springs and streams to bulldoze into.

[Water ResourcesǦAffected EnvironmentȂ4-151ȐBLM has not provided necessary detailed and

site-specific information not only on the ones the EIS would attack, it has also not provided detailed

site-specific information on the ones it would leave alone. Mapping of their location, assessment of

their conditions, flows over the course of the year, predicted effects of mine and climate change, etc. -

in the Three Bars landscape have not been conducted.
All of this information is necessary to assess the relative scarcity of undeveloped or unaltered springs –

and understand the full context and intensity of the loss that would if BLM’s bulldozing dries up

springs, or spring-fed segments of streams.

Please also consider:

Sada and Pohlman also describe:

A number of anthropogenic stress factors

also disturb springs. These include diversion

ground water pumping, spring box capture and

piping to troughs, channelization, etc.),

impoundment, nutrient pollution, introduction of

non-native plants and animals, and trampling by

humans and non-native ungulates (Shepard

1993, Minckley and Unmack 2000, Sada 2001,

Sada and Vinyard 2002). In a survey of 505

springs throughout northern Nevada, Sada et al.

(1992) found greater than 85 percent of springs

were moderately or highly disturbed by

livestock and diversion. Less than five percent

of springs were unaffected by human disturbance.

Biotic and abiotic characteristics of springs

are influenced by elevation, spring size,

aquifer affinities, disturbance stressors

(natural and anthropogenic), and

physicochemical characteristics of aquatic and

riparian environments.

All of these factors have not been adequately assessed.

BLM fails to provide full and comprehensive baseline analysis of spring systems, for example, that are

essential before BLM radically disturbs the springs with backhoes, bulldozers, and deforestation of the

watershed. BLM also fails to asses the present impacts of grazing schemes on springs, streams,

meadows and watersheds in a valid FRH process and analysis.

[Water ResourcesǦAffected EnvironmentȂ4-152ȐDespite the endless EIS tables listing various

habitat treatment destruction all over the place, even the most minimal and basic information on the

streams and springs is lacking. For example, what is the volume of perennial water flow in all stream,

spring, springbrook areas over all months of the year? How has it been altered by grazing, past

treatments, roads, water developments for livestock, etc. Were there water inventories done here in the

1970s-1990s? If so, what was found? How do past flow rates for any periods that data is available

compare to current flow rates? How much climate change adversely impact perennial flows? How long

is the current perennial wetted segment/segments of the stream spring system? How has this changed

over time?

And crucial information on the type and characteristics of the springs –each of which is a unique

system – must be fully understood before BLM revs up the bulldozers and starts ripping away. Or
destroying the water holding and retention capacity of the watershed by burning it up, smashing it, or

converting it all to wood chips. See Sada and Pohlman:

These surveys should be conducted

annually for three to five years to determine

baseline conditions. Sampling frequency may

be reduced to every three to five years once

current or baseline conditions are accurately

quantified. The number of springs, duration

of surveys, and goals and purposes of Level

II surveys should be developed by a team of

managers, ecologists, and hydrologists. These

surveys include water chemistry analyses,

quantitative description of aquatic habitats,

and the identification and enumeration of

riparian and aquatic taxa to species or genus,

respectively. Information provided by these

surveys will 1) quantify current or baseline

conditions at the beginning of a monitoring

program and 2) quantify changes in biotic and abiotic characteristics of springs under existing or

newly implemented management strategies. Level II surveys may include only ...

BLM’s bulldozing of riparian areas while allowing grazing to continue in watersheds runs a grave risk

of promoting highly invasive white top, knapweed and other species that will require large amounts of

chemical herbicide to try to control.

In fact, it appears that BLM is trying to purposefully mislead the public and downplay the amount of

herbiciding this bioengineering scheme will entail. See Grazing Section of EIS that pretends that the

Battle Mountain BLM is not planning on very expensive and drift-prone ground and aerial application

of herbicides. These chemicals and their carriers and adjuvants and breakdown products can pollute

waters, harm aquatic biota, harm ground-dwelling small mammals, nesting birds, and contaminate

forage eaten by sage-grouse, pygmy rabbits, mule deer, wild horses, etc.

[Vegetation Treatments Planning and ManagementǦMethodsǦPlanting and SeedingȂ4-153Ȑ

BLM also arbitrarily failed to assess revegetating with only native species and local native ecotypes, in

outright defiance of current best available science for Great Basin systems. This helps to demonstrate

that this is at its heart a livestock forage project, and Battle Mountain BLM remains shackled to blind

use of destructive exotic species forage.

[AlternativesǦ4-154ȐBLM also makes reasonable alternatives sound like extremes – by suggesting a

passive restoration alternative would be a complete ban on logging, grazing, etc. BLM has constructed

an alternative it will never choose, instead of a reasonable range of passive actions (reductions in

livestock, introduction of beaver, much more stringent controls on livestock use) and minimally

disturbing active restoration such as hand cutting, fence removal, carefully stabilizing some headcuts

with small rocks without the use of heavy equipment, etc.

BLM Provides No Scientific Basis for its Summary and Comparison of Effects on Resources by

Alternative Table 2.6.
[Meteorology and Climate ChangeǦEnvironmental ConsequencesȂ4-155ȐBLM’s rejection of a

full and fair analysis of the adverse effects of climate change on the project and livestock grazing that

would continue in the disturbed lands must b corrected in a SEIS. The contractor uses the standard

rejection language that ignores Beschta et al. 2012, BLM’s own Pellant 2007 Congressional

Testimony, Dellasala Testimony, Chambers et al. 2009, as well as USFWS’s WBP Finding for GSG,

Knick and Connelly 2009/2011 Studies in Avian Biology, etc.

In table 2-6, BLM ignores a full and fair cumulative effects analysis of the Alternative effects on soils,

microbiotic crusts, waters, watersheds, water quality and quantity, sustainability of perennial flows,

habitat quality and quantity for rare, imperiled and sensitive species, impacts on recreational uses and

enjoyment, impacts on cultural sites, etc.

Geothermal Exploration and development Impacts - Akin to Fracking

[Water Resources - Cumulative EffectsǦ4-156ȐBLM must also fully assess the impacts of

geothermal activity or other energy activity that may use fracking. Does mining use a process akin to

fracking, as well?

It appears to us that the massive bioengineering scheme – which is certain to further deplete, destroy

and diminishing perennial surface waters will also serve as “cover” for the masking the large-scale

adverse impacts of all the declines that are underway (and/or highly foreseeable) in the aquifer – from

mining aquifer drawdown, continued irrigation of marginal crops using ground water pumping, and

from foreseeable fracking-like activity associated with geothermal development.

In discussing the minimal info on flow, the EIS states:

An important result of these flow investigations is that flow-gaining and flow-losing reaches occurred

within short distances on upper Birch Creek and Pete Hanson Creek. These flow increases and

decreases often occurred within several hundred feet (or less) of each other, and are likely to result

mainly from groundwater and geologic factors along these headwater channel lengths. On Vinini and

Henderson Creeks, snowmelt conditions and other complicating factors prevented conclusions about

gaining and losing stream sections (JBR 2009).

THIS supports our concerns that bulldozing drainages will have serious adverse consequences- and

may result in permanent loss of surface flows. This would mask the effects of irrigation, mine and

geothermal impacts to the aquifer, as well as mask the effects of the burning, chopping, chipping - and

all the other parts of the treatments that will dry up and desertify this landscape even more.

[Cumulative Effects - Assessment MethodologyǦ4-157]Figure 3-6 does not show mining or other

claims. It merely shows mining districts. Where is a map showing all energy or other rights-of-way, as

well? Where is an overlay of the project polygons on the mapping that is provided? Please assess the

full foreseeable mining development in this region. We also stress that the [Cumulative Effects -

Assessment MethodologyȂ4-158ȐCESA is much too small for all mapping and cumulative effects

analysis for all elements of the environment, and must include large areas mined/undergoing mining

development to the north, east, south in particular, aquifer drawdown effects of mining, irrigation etc.

across the underlying shallow and deeper ground water aquifers. How over-allocated are these already?

How is that already impacting/likely to impact ground and surface waters? How much water would the

Mount Hope mine use? Where would it come from? How about the plethora of gold mines all
surrounding this landscape? New mining actions like the Pan mine, ever-expanding Barrick and other

operations all over the place?

The EIS just throws words and concepts around, without any critical analysis of the sweeping

conclusions that it draws, for example:

As suggested by the CEQ, this EIS considers the following basic types of effects that might occur:

• Additive – total loss of sensitive resources from more than one incident.

• Countervailing – negative effects are compensated for by beneficial effects.

• Synergistic – total effect is greater than the sum of the effects taken independently.

The cumulative effects analysis assumes that maintenance of past treatments has occurred, and that

the BLM would make an investment in maintaining the condition achieved or the objectives of the

project, rather than implementing stand-alone, one-time treatments ..

What does this mean? Across Nevada, BLM vegetation treatments are increasingly infested by

cheatgrass.

Mapping shows generalized, simplistic Ecoregions, then the DEIS states:

Rangeland landscapes are divided into ecological sites for the purposes of inventory, evaluation, and

management. An ecological site, as defined for rangeland, is a distinctive kind of land with specific

physical characteristics that differs from other kinds of land in its ability to produce a distinctive kind

and amount of vegetation. The ecological site descriptions are based on physiographic, climatic,

vegetative, and soil factors for each soil association.

This ignores the vast sterile seas of crested wheatgrass, mottled cheatgrass-weed Sandberg bluegrass,

cwg failed fire rehab sagebrush-less landscape as well as vast areas of burned pinyon-juniper all to the

north.

To understand the full battery of direct, indirect and cumulative effects of this assault on native sage

and PJ, BLM must place the Roberts Mountain area in context, i.e. significant native vegetation

communities remain. They have not generally suffered as much cwg seeding, including disastrous

post-burn or post-treatment seedings, as Elko lands to the north. Thus, they are critical to survival of

many sensitive species, and the DEIS’s efforts to portray large areas as unhealthy (based on the

severely flawed ENLC and AECOM reports that are based on idealized modeled communities and

wildly incorrect fire return and disturbance intervals) must be set aside. A Supplemental EIS must be

prepared that takes a hard look at the habitat that is currently being provided for native biota, with full

and fair baseline inventories for sensitive species presence and habitat needs. Instead, [Native and

Non-invasive Vegetation ResourcesǦEnvironmental ConsequencesȂ4-159Ȑthe ENLC AECOM

info relies on Ecosite descriptions that claim that minimal sage canopy cover is an ideal state. When in

fact, if lands were managed and drastically manipulated to achieve that state, sensitive species ranging

from sage sparrow to loggerhead shrike to pygmy rabbit would be wiped out over vast tracts of the

Three Bars landscape. See Rich 1979, Knick et al. 2003. Dobkin and Sauder 2004.
This project was severely flawed by reliance on ENLC Ecosite information. This flaw can only be

cured by [Asssement MethodologyǦBaseline StudiesȂ4-160Ȑpreparation of a Supplemental EIS

that is based on systematically collected baseline data that takes into account the full habitat needs of a

broad range of sensitive species.

The Ecoregion vegetation is an idealized concept often divorced from the reality on the ground, and

the vulnerability of lands to weed invasion if disturbed. The Ecosites also by and large ignore the

importance and value of microbiotic crusts.

Section 3.4.2.2 minimally describes a hand full of climate change impacts. Notably, it identifies

predicted large-scale losses of PJ in the SW – which makes retention of much of the PJ BLM targets

for destruction here even more vital, and the impacts of the senseless chaining, chipping, chopping,

burning and other destruction of trees based on ENLC info even worse.

Key Issues Are Not Adequately Addressed

BLM claims that Key Issues assessed were:

Concern that big fire years are a result of climate change, and are beyond agency control.

The potential adverse effects of climate change and increasing temperatures, including on noxious

weeds and other invasive non-native vegetation problems, alterations in runoff, and reduction in

perennial flows, and changes to upland conditions.

Whether 3 Bars Project actions may promote desertification, global warming, and climate change

processes.

The current degree of desertification that exists across the District and on adjacent lands and how

climate change may exacerbate effects of deforestation and/or sagebrush removal or eradication

effects.

Effects of global warming and climate change, and increased risk of site desertification and noxious

weeds and other invasive non-native vegetation invasion following treatment, grazing, or other and

overlapping disturbances.

[Meteorology and Climate ChangeǦEnvironmental ConsequencesȂ4-161ȐBLM does not

seriously assess these concerns, and instead glosses over them and presents information maximally

supporting its outdated view and incorrect fire and disturbance intervals, that ignore the historical

vegetation communities, natural plant succession, and the needs of the sensitive species for structurally

complex mature and old growth woody shrubs and trees, as well as the critical role of microbiotic

crusts in land health.

This biased and circular reasoning is shown where [Meteorology and Climate ChangeǦ

Environmental ConsequencesȂ4-162ȐBLM includes generic paragraphs about GHG, but ignores

the loss of the sequestered carbon, and loss of the ability to sequester large amounts of carbon,

especially if weeds choke the landscape.
Then, BLM makes unsubstantiated assumptions that: “significant adverse effects will not occur”.This

claim is based on minimal consideration of GHG only, and while ignoring the loss of sequestered

carbon, the strong likelihood of weed invasions, added and cumulative impacts from losses due to

grazing, mining, and other stresses on the lands, vegetation, waters, sensitive species.

DEIS 3-44 admits:

The 8,300 acre Mount Hope Project, under construction in the southeastern portion of the 3 Bars

Project area, would be a large contributor of dust and other pollutants in the CESA. Emissions of

PM10, PM2.5, and lead would be generated by numerous processes as a result of the mine project,

including the re-suspension of road dust, wind erosion of exposed dirt surfaces, and activities related

to the processing of ore materials.

BLM claims:

In general, air quality impacts from wildfires would be greater than air quality impacts from

prescribed fire on a per acre basis – Yet BLM has just admitted that “Based on long-term averages,

approximately 6,900 acres would burn annually from wildfires in the CESA”.

With the use of prescribed fire comes the very significant risk of escaped fire, and much larger fires.

Plus by creating hotter, drier, windier, potentially grassier sites, and increasing OHV use and travel in a

landscape where the current Land Use Plan fails to control this use in any way, all the impacts of the

treatment are likely to be MUCH greater.

[Air QualityǦEnvironmental ConsequencesȂ4-163ȐAlt C effects are NOT similar to Alt A for Air

Quality. DEIS claims at 3.5.3.4.3 are false. BLM cavalierly proposes no mitigation measures for air

quality.

BLM also ignores adverse impacts of wind erosion and dust deposition, the degree to which climate

change will amplify risks of cheatgrass dominating treatments (especially since the DEIS fails to

control livestock grazing impacts across the treated watersheds, and relies on vague promises of some

future livestock actions.

[Wildlife ResourcesǦEnvironmental ConsequencesȂ4-164ȐBLM ignores the adverse impacts of

noise on wildlife, and this battery of aggressive bulldozer, dump truck, chaining, helicopter and OHV

prescribed fire activity may cause significant initial displacement of wildlife, and this of course will be

followed by long-term displacement. Habitat is VERY slow to recover in these harsh, arid, cheatgrass

prone environments. Increased human access will increase human disturbance, rod noise, etc. All the

mining geothermal plant and other activity and its noise, visual and other disturbances – as well as

outright mortality of wildlife, will have significant unassessed impacts.

While the EIS makes endless rosy claims that “long term” magically things will somehow be better if

massive treatment disturbance is unleashed. [Assessment MethodologyǦDefinitionsȂ4-165ȐIt is

unclear how long termed is defined. Is it the Ely BLM magical 30 years and all will be back to the way

it was before? It is likely to take PJ communities hundreds of years to recover to the structural and age

class complexity destroyed by BLM in afternoon of fire, chaining, chopping, etc. Plus – the full

diversity may never return once the land is essentially leveled, new erosion of topsoil takes place, and
either weeds and/or harmful exotics like crested wheatgrass are seeded as livestock forage in the

eroding, de-stabilized wasteland left by the treatments.

Black sage may take hundreds of years to recover wildlife values the same with Wyoming big sage.

We also stress that mountain big sage is increasingly vulnerable to cheatgrass invasion in these grazing

and climate-stressed arid lands, as is mountain mahogany and mixed sage-bitterbrush or other shrub

communities. See Knick and connelly 2009/2011.

[Vegetation Treatments Planning and ManagementǦRoadsǦ4-166ȐBLM fails to address the

potential road upgrades and improvements that would occur as its fleet of dump trucks, crushers,

choppers, pile burning scorching the soils, chainers, fire vehicles, etc. are unleashed on the landscape

and sensitive watersheds. This will lead to long-term increases in disturbance and ecological stresses.

Playing out across the landscape and watersheds.

Once vegetation is cleared, a path will be opened up for cross-country OHV and pick-up truck use.

This will result in increased fire risk.

Once sage is crushed, new two tracks that then gradually develop into roading will spring up.

DEIS 3-63 to 3-64 refers to BMPs. [Standard Operating ProceduresǦ4-167ȐThere is great

uncertainty in applying BMPs. They are typically decades is not centuries behind the times in applying

scientific information to minimize damage and disturbance. They greatly ignore the degree and

severity of degradation that exits in the landscape, and how vulnerable it actually is to weeds, erosion,

etc. They ignore drought, weather extremes, etc. The DEIS applies endless caveats in admitting that

they are only “reasonably” certain. Then, in grazed landscapes where trespass and non-compliance is

common and often undetected until severe damage is done, any supposed BMP becomes even more

uncertain. [Standard Operating ProceduresȂ4-168ȐBMPs greatly fail to take into account

cumulative impacts, including of multiple disturbances occurring in the same watershed. And BLM

cannot even apply the proper BMPs, even it indeed had a list of great BMPs – as it [Assessment

MethodologyȂBaseline StudiesȂ4-169Ȑhas not conducted the necessary site-specific analysis to

understand sensitive species occurrence and threats across this landscape, vulnerability of lands to loss

of intermittent and perennial flows from individual and combined disturbance effects, etc.

BLM (this is so typical of the Ely ENLC info) presents tables of acres of soil “limitations”, based on

minimal information and gross generalizations. [Soil ResourcesǦAssessment MethodologyǦ4-170Ȑ

It fails to explain how determinations were made that soil productivity, quality, erosion from wind,

treatment suitability, etc. were actually determined, and what models they were based on. And WHAT

is the current condition of the weed-preventing and watershed-stabilizing microbiotic crusts? The

flawed models and assessments used in the “health” analysis downplay crusts, and current science

related to their health.

[Soil ResourcesǦAssessment MethodologyǦ4-171ȐIt is impossible to understand how the various

damage “susceptibilities” – fire, shredder, chaining, site degradation, etc. are determined. We are also

very concerned because NRCS across the sage-grouse landscape has developed false Ecosites based on

incorrect fire return and disturbance intervals, and that have minimal woody vegetation of any kind as

ideal states. Thus, the Ecosites set up the landscape for massive treatment – funded by tax dollars run

thorough NRCS. [Soil ResourcesǦAssessment MethodologyȂ4-172ȐThe NRCS has also then

developed flawed methods to make broad brush claims about “susceptibility” - that fail to take into
account, for example, the severity of degradation of the drainage network, combined with the

harshness of the treatment, and overlapping multiple treatments in the same watershed - making lands

highly vulnerable to erosion, watersheds highly vulnerable to sedimentation, downcutting and

permanent loss of sustainable perennial flows, etc. This is made even worse by the typical BLM

rangeland health assessment avoiding any steeper slopes, seeking ideal communities on flat terrain

distant from areas of more intensive livestock use, and other artifices that essentially “rig” the system

to benefit the livestock industry desires for maximizing livestock forage at the expense of all other

values.

Plus, the NRCS currently downplays the vital role and significance of microbiotic crusts. How much

does the wind and water erosion susceptibility INCREASE in the whole series of flawed soil maps – if

cattle and/or sheep grossly trample soils across the watershed? How is that figured in – either right

before the treatment destruction of vegetation and soil disturbance occurs, or as long-term degradation

that has dramatically reduced crusts as well as understory vegetation? In essence, what “ideal”

conditions are the various models and claims about soils based upon. WHERE do these ideal

conditions exist across this landscape, and where do they not?

[Soil ResourcesǦAssessment MethodologyǦ4-173ȐThis NRCS soils modeling exercise greatly

ignores wind, wind direction, unpredictable drought or lack of rain effects post-treatment, and many

other factors that can result in treatments being a big failure and weed invasion promoter.

It is hard to understand how the same office that developed the drought EA could develop such a

shallow, programmatic, meaningless EIS analysis – and spend a million dollars on this. We stress that

we have noted that all of the projects where ENLC information is used are outrageously expensive –

entailing many hundreds of thousands and often millions of dollars spent in creating weedlands –

based on analysis that looks just like this. We note some of the parties responsible for the Ely Veg EAs

are also involved in this.

In sum, the “site degradation susceptibility” Figure 3-22, and other generic mapping exercises that

assume an ideal world, are useless in the context of the degradation that exists from historic and

chronic livestock grazing impacts, vagaries of weather, etc.

They also greatly fail to take into account the degree to which treatments will INCREASE erosion – by

stripping vegetation, exposing soils, and increasing wind that will increase erosions, as well as make

sites dry out faster – thus becoming wind-erodible faster.

BLM throughout all parts of the EIS soils, veg, wildlife, watersheds, etc. makes generic, self-serving

unsubstantiated statements like this one “although treatments would have short term effects on soil

condition and productivity, it is predicted that disturbance effects resulting from restoration activities

would be less severe than wildfire effects and erosion that would result from lack of restoration. [Soil

ResourcesǦAssessment MethodologyǦ4-174ȐWHERE is the baseline information to support the

level of erosion that is actually occurring under the grazing burden (historic and chronic/current)/load,

roading load, the severity of use allowed under the grazing permits, the complete and total lack of

upland trampling standards, the lack of riparian trampling standards, and the overall degree and

severity of desertification?

Another unintended consequence of livestock grazing—is destruction of soil crusts leading to greater

dust and thus more dust on snowfields causing snow to melt sooner.
http://www.colorado.edu/news/releases/2013/11/14/new-study-dust-warming-portend-dry-futurecolorado-river

All Of these highly destructive treatments will not only make soils more vulnerable to erosion overall

for a VERY long period of time, they will also destroy the protective woody vegetation cover – thus

allowing livestock to trample and de-stabilize the remnant native vegetation as well as microbiotic

crusts areas and herbaceous species protected under plants Plus they will also kill understory

vegetation from mechanical, fire, and even wind erosion damage. And how will grazing levels impact

this? [Wildlife ResourcesǦEnvironmental ConsequencesȂ4-175ȐIf BLM applies a 40% upland

utilization level on the herbaceous vegetation and Key larger sized grass species, that means that many

other grass plants get grazed to much higher levels. 40% upland utilization fails to provide necessary

residual nesting cover for sage-grouse, and also must be viewed in terms of how little watershed cover

it provides, and how little vegetation is present to capture snow, shade the ground and slow

evaporation following rainfall events, and block the wind. In essence, BLM will great vast swaths of

much harsher sites much more prone to erosion in wind (and water runoff) in these chronically grazed

landscapes where the native vegetation communities have vastly longer fire return and disturbance

intervals, and much slower rates of recovery, than the ENLC, NRCS, UNR and other modeled Ecosites

claim. The discussion of adverse and beneficial effects is just generic, programmatic nonsense.

We are concerned that BLM constantly uses fear-mongering wording like “catastrophic” wildfire.

Catastrophic wildlife is how PJ and many other arid western forests naturally burn.

BLM makes endless sweeping statements maligning PJ. The PJ is present in riparian areas because of

chronic livestock degradation, and because of the small narrow drainage area topography and terrain.

Many trees have very significant and much larger root masses stabilizing banks than any of the few

scraggly willows that have managed to survive relentless grazing abuse ever have. Instead of attacking

juniper as an enemy, and killing it and de-stabilizing streams, BLM must work on naturally restoring

the water table. If BLM loses the shade, soil stability, and other effects of PJ, large-scale losses of

biological values will occur in many of these highly degraded drainages. And let’s take this to its

logical extension, If BL does not want plants using water, then put the stream in a pipe, and have the

perfectly engineered environment. The exact same reasons BLM claims it must destroy the PJ in

riparian areas are the reasons used for destroying willows in Nevada private lands –up to the present.

BLM claims it will reconnect streams to their floodplain, We saw an example of this in Smith Creek –

at massive public expense, a downcut stream was obliterated, and the channel filled in with rocks –

thus ensuring that perennial flows will be lost forever from a significant segment of the drainage.

Instead of addressing the grazing degradation, NRCS and other agencies killed the stream. We note

that in Nevada, often the downcut streambanks provide habitats for small mammals, and have some

roses or other vegetation that also provides habitat for migratory birds. In contrast, by bulldozing,

flattening and obliterating the stream channel, BLM simplifies the structure. With streams having such

low to minimal flows, this effectively shortens the length of the drainage that is able to provide

sustainable perennial flows – forever. IN CONTRAST, ig [Vegetation Treatments Planning and

ManagementǦMethodsǦRiparianȂ4-176ȐBLM relied on natural recovery, and beavers, the stream

could over time be brought closer to being in contact with its floodplain The end result of something

like the massive bioengineering of the Smith Creek project is loos of everything –floodplain and

channel with water. The end result is an extraordinarily expensive permanent loss of biodiversity.

These systems can only take so much abuse – and that includes “treatment: abuse –until water flows

are permanently lost.
Regarding dust:

http://www.colorado.edu/news/releases/2013/11/14/new-study-dust-warming-portend-dry-futurecolorado-river

Reducing the amount of desert dust swept onto snowy Rocky Mountain peaks could help Western

water managers deal with the challenges of a warmer future, according to a new study led by

researchers at NOAA’s Cooperative Institute for Research in Environmental Sciences (CIRES) at the

University of Colorado Boulder. - See more at:

http://www.colorado.edu/news/releases/2013/11/14/new-study-dust-warming-portend-dry-futurecolorado-river#sthash.2FeZvrWN.dpuf

Since the mid-1800s, human land use activities have disturbed Southwestern desert soils and broken up

the soil crust that curbs wind erosion, leading to increased dust. In previous research, Deems and his

colleagues showed that increasing dustiness leads to accelerated snowpack melt.

That earlier work was based on the moderately dusty years of 2005-–2008, with about five times as

much dust than in the 1800s. But during 2009, 2010 and 2013, unprecedented amounts of desert dust

fell on Colorado snowpacks, about five times more than observed from 2005–2008. Moreover, other

researchers have reported that climate change is likely to increase the frequency and intensity of

drought in the Southwest, which could increase dust problems further by harming the grasses and

shrubs that reduce surface wind speeds.

For the new work, the researchers used climate and hydrology models to investigate the effect of that

“extreme dust” on the Colorado River’s flow now and in the future, as the Southwest continues to

warm. Snowmelt in the extreme dust scenario shifted even earlier in the season, by another three weeks,

pulling peak water levels in the Colorado River to earlier in the spring and leaving less water for later

in the year.

http://www.hydrol-earth-syst-sci.net/17/4401/2013/hess-17-4401-2013.html

Dust abatement minimizes soil disturbing activities such as large-scale livestock destruction of

microbiotic crusts.

[Air QualityȂEnvironmental ConsequencesǦ4-177ȐBLM must assess the amount of dust that is

attributable to livestock disturbance, loss and degradation of microbiotic crusts, etc.

We note we have also seen large plumes of dust blowing off of mines – such as the ely Robinson mine

which generates dust clouds visible from dozes of miles away.

What wind speeds were the soil erosion models BLM uses based on? What combination of wind speed

and slope and livestock trampling disturbance.

[Native and Non-invasive Vegetation ResourcesǦEnvironmental ConsequencesȂ4-178ȐBLM

ignores literature that shows PRESCRIBED fire kills native grasses. See Bunting paper on Idaho

fescue, USFS Fire Effects database describing fire impacts on native grasses.

The hubris of the EIS modelers is so great that [Soil ResourcesǦMitigationȂ4-179ȐDEIS at 3-93

states “ Soil resources would benefit from mitigation and monitoring in Section 3.17.4 I livestock.
Then it states: No mitigation or monitoring measures are recommended specifically for soil

resources. Don’t look - so you don’t find out you were wrong - is the mantra of this EIS.

[Water ResourcesǦEnvironmental ConsequencesȂ4-180ȐHow many of the 334 springs have been

dug into, piped, or otherwise altered for livestock? What were the impacts? What is the aquatic habitat

condition at these? How dependent are they on snow accumulation? How will deforestation and

denuding of the landscape reduce snow accumulation and speed

[Water ResourcesǦCumulative Effects– 4-181Ȑ3-107 admits the Kobeh Valley is losing water due

to pumpage from groundwater storage. It is clear that the Diamond Valley is turning into a dustbowl

DEIA at 3-108 state that irrigation pumping has created a groundwater depression, and the southern

part of the valley is subsiding. What effect is overall mine depletion of ground water – Cortez to

Robinson and all points in between – having on this, as well?

BLM describes Pine Valley as having shallow groundwater levels. This is an extraordinarily degraded

valley where most of the sage and PJ has burned off, and vast areas have been converted to cwg,

cheatgrass and a blend of weeds and mottled communities. BLM completely ducks any full and fair

analysis of what is occurring her – by trying to focus on only 2/3 of the basin (and not the drier

northern part), as well as providing no information on volume and rates of decline of this or any other

aquifer.

[Water ResourcesǦCumulative EffectsȂ4-182ȐGrass Valley is also in serious trouble, and now the

Ormat geothermal developers are punching holes in the aquifer all over the place. Are they using

processes akin to fracking? Instead, though, of looking at any current information – BLM uses figures

from 1966 in its so-called “analysis”. We are greatly concerned that no information on mining impacts

to aquifers (current or projected) is in here at all.

In order to understand the effects of the massive deforestation, vegetation destruction and

bioengineering project, BLM must explain how surface expression of water in the springs and streams

are linked to shallow and deep aquifers, and the combined effects of the projected battery of

disturbance actions on this.

[Water ResourcesǦAffected EnvironmentȂ4-183ȐTable 3-15 shows how very little perennial

stream flow exists. When and how was the info collected that this is based on?

[Water ResourcesǦEnvironmental ConsequencesȂ4-184ȐThere is no clear evidence that killing

trees will increase water to any significant extent, especially after the full extent of erosion and grazing

plays out. Will treatments remove stockponds? And what kind of water developments are being

considered? [Water ResourcesȂAssessment MethodologyȂ4-185ȐHow has BLM determined the

effects of deforestation on rapid water loss and site drying, including in hotter, harsher, windier drier

sites where water will simply be lost to the wind?

[Assessment MethodologyǦSignificance CriteriaȂ4-186ȐBLM’s significance criteria are

inadequate, and it is unclear how they were derived. BLM does not conduct adequate analysis to

address them.

[Vegetation Treatments Planning and Management -MethodsǦFencingǦ4-187ȐBLM has not

explained what is meant by claims “BLM will not completely block access to water sources” by
livestock, horses, wildlife ,etc. WHAT does this mean? Will entire allotments or pastures be closed?

Or is BLM just planning to shift, and intensify sever impacts into other sensitive erodible, weed-prone

sites? Or will it have dustbowl water haul or water gap feedlot-like sites?

While BLM passingly mentions hillslope runoff and bank stability, it fails to take a hard look at these

effects. [Water ResourcesǦEnvironmental ConsequencesȂ4-188ȐBLM admits that

“restoration”/destruction of native vegetation and disturbance of soils making them susceptible ot

erosion would affect surface water quality. The studies BLM cites do not account for livestock grazing

effects. See Belsky 1996, for example. Note the Pierson study showing that erosion was 20-fold

greater on burned sites.

BLM admits that removal of vegetation could increase surface water runoff and reduce infiltration.

BLM then claims “improvement” over the long term as native vegetation replaces itself. Then why do

this massive destruction in the first place – if only after the naive vegetation such as PJ and sage

returns following the disturbance in the long-term, will conditions actually be improved? The EIS

states that no mitigation or monitoring measures are recommended specifically for water resources.

Since no formal delineation of wetlands has been done for the project area, this places a much higher

burden on the EIS to collect critical baseline info. [Wetlands, Floodplains, and Riparian AreasǦ

Affected EnvironmentȂ4-189ȐWho conducted the PFC inventories and when? How was trend

determined? How might these treatments degrade conditions? How can highly degraded watersheds

withstand treatments? How and when does grazing occur? What is actual use any pasture? What

riparian standards are in place, and where and when are they measured? What does monitoring show,

and please provide this.

The BLM would reseed or replant wetland and riparian zones where the native plant community is

unlikely to recover and occupy the site, and restrict livestock, wild horse, and wild ungulate access to

treatment areas until establishment goals have been reached.

It is highly uncertain and unresolved how this will occur, the effects, including cumulative adverse

effects it will have, and how successful any of this would be.

If BLM would not seek to tear apart the riparian areas with massive bioengineering, they should be

able to revegetate naturally, especially with introduction of beavers and removal of livestock from the

watershed and pastures affecting the riparian system.

[Vegetation Treatments Planning and ManagementǦMethodsǦRiparianȂ4-190ȐRemoval of PJ

may reduce, degrade, stream systems and hydrology, and result in lethal temperatures for aquatic

species, algae blooms, etc. it may cause large-scale new headcutting and erosional events.

Many of the mechanical treatments would occur within stream channels, where heavy equipment

would be used to improve the structural integrity of the stream channel. The potential impacts of

mechanical treatments on wetlands and riparian zones are discussed in the 17-States PER (USDOI

BLM 2007c:4-29 to 4-30). This is insane – especially for these tiny little streams. Reading these

grandiose bulldozing schemes, it appears to us that BLM believes it is the Army Corps of Engineers

stabilizing the Mississippi, or something. [Vegetation Treatments Planning and ManagementǦ

MethodsǦRiparianǦ4-191ȐNone of the stream channels is actually big enough for a bulldozer to fit
into, is it? [Assessment MethodologyǦBaseline StudiesǦ4-192ȐBLM simply cannot rely on the

PER report – as no NEPA at all was ever conducted on the PER. If these activities are to be permitted

by the Army Corps, we will urge the Corps to deny all permits for this nonsense.

BLM again relies on highly uncertain fencing and other schemes:

use of temporary and permanent fencing to restrict livestock, wild horse, and wild ungulate access to

treatment areas.

BLM claims: Pinyon and juniper are not riparian species, and are not as effective as native vegetation

in stabilizing soil.

[Noxious Weeds and other Invasive Non-native VegetationǦEnvironmental ConsequencesǦ4-

193] DEIS 3-140 purposefully ignores the role of livestock grazing in promoting cheatgrass and

cheatgrass invasion.

Non-native vegetation on the 3 Bars Project area is associated with historic wildfires and with

rehabilitation of burned areas following wildfires. Treatments can benefit wetland, floodplain, and

riparian habitats if vegetation removal reduces ...

This section also discusses permanent fencing in several places, and water gaps (feedlot-like) as in The

BLM also proposes to install fencing to limit livestock, wild horse, and wild ungulate access to

treatment areas, although water gaps would be incorporated into fencing along streams to allow these

animals to access water.

BLM refers to Livestock Mitigation in Appendix C.

As discussed in the Mount Hope Project EIS under Wetland and Riparian Zones (USDOI BLM

2012c:Section 3-11), and in this EIS under Water Resources (Section 3.9), there is concern that

pumping of water for future livestock and domestic uses, mining, and agricultural could reduce surface

water flows in streams and wetlands associated with the Diamond Mountains, Diamond Valley,

Roberts Mountain, Kobeh Valley, and Pine Valley. Although the Mount Hope Project EIS determined

that effects on streams and wetlands would not be significant, it did find that effects to groundwater

resources from the mine project and other water users could be significant within the CESA.

THIS makes no sense, and is purposefully constructed to avoid a full and fair consideration of

Alternative C. BLM claims that: Under Alternative C, effects from non-3 Bars Project reasonably

foreseeable future actions on wetlands, floodplains, or riparian zones would be similar to those

described under Alternative A. Adverse, short-term effects to wetlands, riparian zones, and floodplains

associated with the use of fire and mechanized equipment would not occur under Alternative C. By not

being able to use mechanical methods and fire to reduce hazardous fuels and create fire and fuel

breaks, the risk of wildfire and its effects on wetlands, floodplains, and riparian zones would likely

increase on the 3 Bars Project area.

The BLM would conduct hazardous fuels reduction and habitat improvement projects using manual

methods on about 32,000 acres within the 3 Bars Project area, and on about 15,000 acres in other

portions of the CESA, or about 3 percent of acreage within the CESA. Only about 100 acres of

wetland and riparian habitat, and 1 mile of stream habitat, would be restored annually on the 3 Bars

Project area. Wetland, riparian, and floodplain habitat should improve within the 3 Bars Project area
and within the CESA, but not to the extent as would occur under Alternatives A and B.

By removal of livestock from existing pastures, and herding requirements and/or requiring mandatory

measurable standards of use as triggers for livestock removal coupled with cutting livestock to

numbers that the ranchers can actually control so there can be no excuses about not knowing where al

the cows are – could passively restore vast areas – far more than BLM’s pretending it is re-sculpting

the Mississippi River floodplain – albeit in Eureka County. Plus, to do that, first one would have to

find a stream big enough to fit a bulldozer in.

It appears as if some of the Bioengineering DEIS preparers have never set foot in this rugged arid

landscape. For example,

None of the reasonably foreseeable future actions should result in the significant destruction or loss of

wetlands. For upland treatments with the potential to remove large areas of vegetation (fire and

mechanical), [Vegetation Treatments Planning and ManagementǦMethodsǦRiparianǦ4-194Ȑthe

BLM would maintain vegetated buffers between the treatment area and wetlands ... HOW would

you propose doing that when you are planning to destroy the only vegetation that has been able to

survive the scorched earth grazing BLM has been imposing on these lands all of these years – i.e. the

PJ in steep, rugged terrain?

BLM then states:

The majority of stream restoration treatments would be done in streams with little to no streamfloodplain connections. Thus, historical floodplains would only experience flows during very rare high

magnitude discharge events. Treatments to improve the structural integrity of stream channels would

likely improve the flood attenuation functions of those areas over the long term.

So what is the purpose of all this –except to waste a million dollars on an EIS and many millions or

more? Where there are downcut gullies at lower elevations, they are actually providing a diversity of

wildlife habitats – from pygmy rabbits to migratory songbirds inhabiting bankside areas not subject to

intensive trampling. By flattening them out, dumping rocks in, all you will do is dry out the flows

sooner and destroy any hope of eventual recovery of the system once headwater areas are recovered by

beavers and removing cows.

Regarding Ecosites, BLM states:

The USDA Natural Resources Conservation Service (2012) soil survey was used to determine the

ecological site descriptions for the project area. Rangeland landscapes are divided into ecological

sites for the purposes of inventory, evaluation, and management. An ecological site, as defined for

rangeland, is a distinctive kind of land with specific physical characteristics that differs from other

kinds of land in its ability to produce a distinctive kind and amount of vegetation. A description of the

ecological site descriptions can be found in Appendix B of the Landscape Restoration Project

Rangeland Health Report (Eastern Nevada Landscape Coalition and AECOM 2012). The ecological

site descriptions are based on physiographic, climatic, vegetative, and soil factors for each soil

association.

The ecological site descriptions were then grouped by associated dominant vegetation type (overstory

and understory species) into broader vegetation cover types to characterize the Potential Natural

Community for each plant association. The Potential Natural Community is defined as the biotic

community that would become established on an ecological site if all successional sequences were
completed without interference by people under the present environmental conditions (Habich 2001).

The problem is – this is just like Cave-Lake and all the other Ely BLM schemes, and they rely on

drastically inaccurate and incorrect disturbance and fire return intervals and blind focus on grass

components at the expense of shrubs and trees and crusts. They are based on inaccurate assumptions of

the NV soil surveys that become further warped in the modeled Ecosite descriptions, use of FRCC, etc.

We are appalled at the lack of concern for sensitive species. BLM states:

The BLM Special Status Species list was reviewed to determine which special status plant species

could occur in the project area. These were supplemented with notes taken during the project site visit

and kick-off meeting.

[Wildlife Resources - Assessment MethodologyǦBaseline StudiesǦ4-195]THIS is the severely

flawed baseline for sensitive species – not where the species live on the land, or determining where

they can no longer lives due to degradation, or how important the lands AECOM/ENLC range studies

claim need to be unhealthy may actually be for these species.

[Native and Non-invasive Vegetation ResourcesǦAnalysis MethodologyǦBaseline StudiesǦ4-

196]It is entirely inadequate to merely rely on Mount Hope rare plant studies –as they were conducted

over only one small part of this very large and significant land area.

Major vegetation community types in the 3 Bars Project area include pinyon-juniper woodland,

mountain mahogany woodland, aspen, big sagebrush, low sagebrush, black sagebrush, greasewood,

salt desert scrub, grasslands, and cheatgrass (a non-native plant; Figure 3-26, Table 3-22).

Information on noxious weeds and other invasive and non-native vegetation, including cheatgrass, is

provided in Section 3.12.

One of the objectives of the 3 Bars Project is to restore lands to achieve 75 percent of their Potential

Natural Community based on the status of key plant species. A Potential Natural Community is defined

as the biotic community that would become established on an ecological site if all successional

sequences were completed without interference by people under the present environmental conditions

(Habich 2001). Seral status is an expression of the condition of the vegetation community and is useful

in determining whether an area is progressing toward its Potential Natural Community. The Potential

Natural Community is considered achieved with the presence of 77 to 100 percent of the desired key

species in a plant community. Figure 3-27 and Table 3-22 show the location and extent of major

expected vegetation communities, based on ecological site description, in the project area ...

What does this seral status mumbojumbo really mean? Comparing Map 3-26, current vegetation

communities, with the map of proposed treatments, it is clear BLM seeks to destroy nearly all the PJ in

the project area.

[Native and Non-invasive Vegetation ResourcesǦAffected EnvironmentǦ4-197]Table 3-22 shows

that there is actually LESS sage and LESS PJ than is expected based on the soil surveys.3-152 shows

how out of whack the excess “grasslands” are –

About 4,433 acres of the project area should consist of native grassland. Over 52,000 acres are

currently categorized as grassland, however, most (over 47,000 acres) of these acres consist of areas

burned by wildfire, or occupied by non-native grasses (primarily crested wheatgrass) planted by man.
Management actions proposed for sagebrush communities are also expected to indirectly enhance

native grasslands, as they would increase the abundance of native bunchgrasses throughout the

project area, providing additional forage and seed sources, while removing non-native grasses.

[Native and Non-invasive Vegetation Resources ǦAffected EnvironmentǦ4-198ȐThis shows there

are too many grasslands already – yet the projects will make more grasslands! So why in the

world, once it realized this – why didn’t BLM stop right there and focus on restoring 47,000 acres of

grassland to native shrubs and trees???

Generally, the big sagebrush community in the 3 Bars Project area suffers from the following concerns

(USDOI BLM 2009a, Eastern Nevada Landscape Coalition and AECOM 2012):

• Most (if not all) sampled sites examined in the rangeland health assessments lacked an understory of

native bunchgrasses, and those that support bunchgrasses typically only support one species.

• Many sites lack an understory of native perennial forbs. WHAT role does livestock grazing have in

this?

• Shrub diversity on most sites is less than desirable and below what the ecological site would allow.

• Some areas are characterized by monocultures of sagebrush or bitterbrush. These are monocultures,

but contain diverse microbiotic crusts and structurally complex and varied age shrubs. We request a

site visit to these ENLC/AECOM “monocultures” with BLM.

• Some areas have been overtaken by cheatgrass as a result of wildfire.

• Some areas suffer from invasions of noxious weeds and other invasive non-native vegetation.

In addition, large areas that are dominated by big sagebrush have experienced extensive

encroachment from pinyon- areas that are dominated by big sagebrush have experienced extensive

encroachment from pinyon-juniper ...

In other words – this is the standard ENLC Veg assessment finding that everything everywhere is

messed up – so the only thing that can be done is to destroy it.

This is cheatgrass-susceptible grazed to death landscape must have management minimizing

disturbance – by livestock grazing and treatment to native vegetation, microbiotic crusts, and

understories.

[Native and Non-invasive Vegetation Resources ǦAssessment MethodologyǦRangeland HealthǦ4-

199ȐYet BLM’s AECOM/ENLC reporting is developed to maximize disturbance, and this greatly

biases the EIS alternatives against passive restoration.

BLM abjectly ignores a fundamental frontline defense against weeds and a crucial component of native

plat communities in the arid interior west sagebrush, salt desert shrub, and pinyon-juniper landscapes.

[Soil Resources ǦAffected EnvironmentǦ4-200ȐThere is not a word, not a mention at all - of

microbiotic crusts in the “plant community dynamics” section of the long series of Tables that BLM

uses to set up the landscape for massive destruction and conversion to cheatgrass. It is clear that BLM
is not interested in the health of native communities, restoration of ecological processes, biodiversity,

and preventing weeds – as it blows off an consideration of microbiotic crusts in what it considers

important related to “rangeland health”.

While BLM claims it will not specifically target mountain mahogany, any use of fire would likely

result in destruction of mountain mahogany as collateral damage.

[Soil Resources ǦAffected EnvironmentǦ4-201ȐBLM’s description of pinyon-juniper communities

shows its (and AECOM/ENLC’s) blatant disregard for microbiotic crusts:

Pinyon-juniper woodlands generally occur on steep south-trending hillsides and mountains at all

aspects, between 5,500 and 8,600 feet amsl. This vegetation type generally occurs on shallow, loamy

soils with high percentages of coarse fragments. Singleleaf pinyon pine and Utah juniper dominate the

overstory. The understory is often nothing more than barren soil in dense stands of pinyon-juniper ...

The sites that BLM describes as having “barren soils” typically (when not trampled by livestock) are

protected by a diversity of microbiotic crusts that provide a wealth of essential ecological services –

from fixing nitrogen, to preventing soil erosion in wind and water and thus having a very vital

protective effects in preventing dust pollution including on snow, to storing CO2 (see Wolfahrt ), and

slowing water runoff from sites. See BLM Technical Bulletin Belnpa et al. 2001, Deines et al, Ponzetti

et al. on microbiotic crusts. And most crucially, crusts are a frontline defense against cheatgrass and

other highly flammable invasive weeds that drastically alter ecosystem processes, fire return intervals,

and the health of native ecosystems and rare and sensitive species habitats.

Prevey et al. shows that the sage BLM plans to destroy is a frontline defense against cheatgrass, as

well.

[Native and Non-invasive Vegetation Resources ǦAffected EnvironmentǦPinyon-juniperȂͳ-

202]The DEIS states that PJ now covers (only) approx. 25% of the project area. (Phase II and III). The

Ecological description finds trees should be present on 27% of the area. So WHY the need for massive

expensive treatments?

This EIS is pervaded by the range mindset that anything a cow can't eat is worthless.

BLM then states:

The difference (approximately 18,819 acres) shows that pinyon-juniper is less common that it was

historically. This may reflect, in part, the extensive use of pinyon-juniper in the making of charcoal in

the late 1800s (see Section 3.11.2.6), and recent fires (1999 to present), that removed a substantial

acreage of pinyon-juniper on the Simpson Park Mountains and Sulphur Spring Range and on Roberts

Mountains.

BLM then goes on to say:

However, if Phase I stands are also considered, there are about 118,000 more acres with pinyonjuniper than would be expected under normal conditions. The Phase I acreage demonstrates the rapid

expansion of pinyon-juniper woodland in the project area at the expense of other potential natural

vegetation ... BLM has no evidence that these trees are expanding at the expense of PNV, and are not
in fact the actual and true PNV over much of that acreage.

[Native and Non-invasive Vegetation Resources ǦAffected EnvironmentǦSagebrushǦ4-203ȐWhat

is the basis for the 20 to 35 percent canopy cover claims for mixed Wyoming big sage, juniper sites

“assumed to be representative”? What specific reference sites and other information are all these

percentages based on?

This whole section is confusing, lacking in clarity, and lacking in careful and thorough review of

historical records and on-the-ground evidence of past treatments, charcoal, etc. on these sites. WHERE

in Phase I areas has BLM removed trees in the past – for all periods during which records have been

kept? WHERE in Phase II and III? How many communities don't fit these arbitrary Phase models, and

instead vary complexly over time and space?

Sagebrush and forested vegetation communities are naturally dense and varied. BLM tries to impose

one-size-fits-all veg destruction on complex native vegetation communities that vary depending on

slope, aspect, elevation, past human disturbance, chronic grazing disturbance, and stochastic events.

[Native and Non-invasive Vegetation Resources ǦAffected EnvironmentǦ4-204ȐWHAT is included

in the understory production figures – wood? What is the “understory production” of crusts supposed

to be? It is clear this 20 to 35 percent figure for juniper is drawn out of thin air.

Just by all the natural variation alone, we bet one would rarely find a veg community anywhere that fit

in all these tiny little ideal community boxes NRCS has concocted and BLM has so embraced as they

always over-estimate “forage”.

[Native and Non-invasive Vegetation Resources ǦAffected EnvironmentǦPinyon-juniperǦ4-205Ȑ

BLM repeatedly cites Romme 2007, ignoring the series of Romme et al. 2009 papers that undermine

the long-held myths perpetuated by Miller (who has always been dramatically wrong about sagebrush) and Tausch who does not concern himself with understanding the impacts of historical mining

deforestation in the Great Basin but yet has always drawn sweeping conclusions about PJ communities.

Sagebrush on much of the 3 Bars Project area has also been replaced with pinyon-juniper woodlands

(USDOI BLM 2009a, 2012c, AECOM 2011a, Eastern Nevada Landscape Coalition and AECOM

2012). Many of these indicators have been observed in Phase III (or late successional) pinyon-juniper

woodlands, which generally have a high density of trees and buildup of fuels.

The BLM considers two classification schemes when assessing the condition of pinyon-juniper

woodlands. One scheme is based on historical types of pinyon-juniper vegetation (Romme et al. 2007),

and one is based on transitional phases of woodland succession for mountain big sagebrush

associations (Miller et al. 2008). These classification systems are summarized in Table 3-31.

Has the sage “been replaced” as part of a natural plant successional process?

[Native and Non-invasive Vegetation Resources ǦAffected EnvironmentǦPinyon-juniperǦ4-

206]Generally, areas of potential expansion are areas in which pinyon-juniper woodlands have not

historically been ...WHAT does this mean? Is BLM treating areas where the trees are not yet present?

Figure 3-28 differentiates expansion areas from areas of historic occurrence. Based on this mapping,
approximately 46 percent of areas with trees are in Phase I, 35 percent are in Phase II, and 19 percent

are in Phase III (AECOM 2011a). However, pinyon-juniper trees occupy only a portion of the area

delineated into phases, especially for areas dominated by Phase I and II pinyon- juniper. In Phase I

areas, grasses, forbs, and shrubs comprise much, if not most of the area.

[Native and Non-invasive Vegetation Resources ǦAffected EnvironmentǦPinyon-juniperǦ4-207Ȑ

How do you end up delineating the area into Juniper Phases if there are not trees? Is this done to justify

spending more money on million dollar EISs?

This is a huge bias, and something that NV range researchers like Tausch and others have frequently

done –they don't age the junipers –which are often much older on sites than pinyon (takes them longer

to attain size) AND the whole reason they are harder to age is they are much slower growing, wood is

denser, and growth rings much closer together. Pinyon in the past was often selectively removed, as

well for firewood, mining wood, etc.:

Old growth pinyon-juniper stands are 140 years old or greater. Because age is difficult to estimate

from tree core samples from Utah juniper trees, cores from singleleaf pinyon pines are typically used

to determine the age of a particular stand of trees. Old-growth pinyon-juniper stands tend to occur on

slopes, ridges, and inaccessible areas (i.e., areas not easily logged ...

Old-growth pinyon-juniper stands tend to occur on slopes, ridges, and inaccessible areas (i.e., areas

not easily logged; AECOM 2011a). Areas having old growth pinyon-juniper woodlands are Indian

Springs, Pete Hanson Creek, higher elevations on steep slopes, and the northern portion of the Sulphur

Spring Range. Based on sample tree cores from the 3 Bars Project area, the majority of old-growth

trees are between 160 and 200 years old, and as old as 290 years (AECOM 2011a). As discussed in

Section 3.11.2.6, much of the older pinyon-juniper was harvested to make charcoal for the mining

industry in the mid-1800s.

Then there is no need for treatments, since they are re-occupying sites where the naturally occur.

BLM does not explain how it defined a stand, how many trees had to be older for the stand to be

considered old growth, etc.

Lack of understory species diversity, and absence or decline in associated woodland species (e.g.,

aspen, bitterbrush, and curl-leaf mountain mahogany). WHAT role does chronic livestock grazing play

in this? How much of this is the result if natural plant successional processes?

• Widespread occurrence of Fire Regime Condition Class II and III (fire regimes that have been

moderately or significantly altered from their historical range) due to excessive fuel loadings.

[Wildland Fire and Fire Management ǦAffected EnvironmentǦ4-208]WHAT is the fire return

interval and historical range of variability time intervals that are being used to determine this? You

cannot rely on Rick Miller, who has been dead wrong about fire intervals.

[Native and Non-invasive Vegetation Resources ǦEnvironmental ConsequencesȂPinyon-juniperȂ

4-209] Decreased tree vigor and pine nut production. How much impact is drought having on this? Or

livestock soil compaction?
[Wildland Fire and Fire Management ǦEnvironmental ConsequencesǦPinon-juniperȂ4-210Ȑ

Increased pathogen infestations resulting in greater than 20 percent ongoing mortality within a given

stand. THEN why not just let the stand alone to self-thin through natural mortality agents? Why is this

a problem? These are natural ways that the forests world-wide self-thin. This also reduces “flammable

fuels”. The forest is acting just like forests are supposed to, and human intervention is unnecssary.

[Wildland Fire and Fire Management ǦEnvironmental ConsequencesǦPinon-juniperȂ4-211Ȑ

Stand conditions in excess of 1,200 trees per acre in several watersheds. Is the forest undergoing selfthinning there, too? What are the age classes of the trees? If there is limited understory, even the miller

models show you should not burn.

BLM mapping such as 3-28 shows that BLM is conflicted. BLM, having at least recognized the

concept of plant succession – shows here that this fails to fit into the “idealized” model community

boxes that NRCS, Miller, Tausch et al have constructed.

But this is how old growth forests often tend to be – especially when severely impacted by livestock

grazing:

[Wildland Fire and Fire Management ǦEnvironmental ConsequencesǦPinon-juniperǦ4-212ȐMany

of these indicators have been observed in Phase III (or late successional) pinyon-juniper woodlands,

which generally have a high density of trees and buildup of fuels.

How was high density determined, an dhow does this vary by slope, terrain, past mining era or

treatment history, etc.?

WHAT does this mean:

Overall, the area is experiencing issues with invasive annual grass species (mainly cheatgrass) that

are altering the fire regime, as discussed in Section 3.12 (Noxious Weeds and other Invasive Nonnative Vegetation). Large wildfires, caused by a buildup of cheatgrass and shrubs, are compromising

the health of the sagebrush-steppe habitat. The encroachment of pinyon-juniper woodlands is also

compromising the health of the sagebrush-steppe habitat.

[Wildland Fire and Fire Management ǦEnvironmental ConsequencesǦPinon-juniperǦ4-213ȐWhat

is the basis for the claim that large fires are caused by a “build up” of shrubs? And again, where are

trees re-occupying, undergoing natural successional processes? How many of the various Phase areas

are persistent woodlands, and where are they located? How did BLM determine this?

Persistent Woodlands

Table 3-31 defines persistent Woodlands.

BLM tries to omit the areas that might prove more productive for grass if it kills the trees. Relatively

flatter deeper soils at the elevations of much of the project areas also naturally support pinyon-jniper,

and in fact trees (where they have not been destroyed in Nevada) may often attain larger stature in such

sites and be good pine nut producing stands.
[Native and Non-invasive Vegetation Resources ǦAssessment MethodologyȂPinyon-juniperǦ4-

214] How has BLM determined areas of potential expansion?

[Native and Non-invasive Vegetation Resources ǦAssessment MethodologyǦRangeland HealthǦ4-

215ȐHow were the KMAs in the so-called range health assessment that ENLC was involved in,

selected? Are these the BLM “trend” sites – if so, those are specifically selected for measuring cow

utilization, are often not representative at all of rugged or rough areas, or areas that actually receive a

significant amount of livestock use. They provide no valid basis for conducting a systematic rangeland

health assessment.

[Native and Non-invasive Vegetation Resources ǦAssessment MethodologyǦRangeland HealthǦ4-

216ȐWhy did did ENLC conduct rangeland health studies in December? Forbs would be all dried up

and scarcely noticeable. This, of course, would bias the outcome of the “health” assessment to come

out more unhealthy, and thus in need of treatment. How severe were the sites grazed? Was there snow?

It is clear these also sought out “pure” representative communities and not the often mottled and more

disturbed sites.

[Native and Non-invasive Vegetation Resources ǦAffected Environment -4-217ȐWHAT was the

climax vegetation community that the early middle and late successional status (used by ENLC and

shown in Map Figure 3-290.

We strongly object to the use of the term ‘desired dominance” nonsense – that is overwhelmingly

biased towards livestock forage species. BLM cannot predict WHAT will be dominant when it rips up

and tears apart native vegetation communities with its battery of aggressive treatments, highly invasive

seeding techniques, etc. For example, look at the failed fuelbreaks in the Diamond Valley, Austin

fuelbreaks that immediately produced cheatgrass in mowed sage and similar cheatgrass-infested

fuelbreaks across the West. Look at the Ely Tebuthiruon and mowing, beating/roller chopping

cheatgrass profusion. When you remove protective shading and moisture-retaining woody vegetation,

sites become hotter, drier, and there is no competition for cheatgrass so it thrives.

WHAT does this nonsense mean?

[Native and Non-invasive Vegetation Resources ǦAssessment MethodologyǦRangeland HealthǦ4-

218]Production is a measurement of the above-ground weight of the sampled vegetation. Desired

dominance ??? refers to the species types that should be present on an ecological site given its stage

of succession ???[Succession to WHAT climax community?]. The Potential Natural Community is a

measurement of composition, not to be confused with production. A site could be experiencing high

production, but have low Potential Natural Community, if it is only producing a single grass, forb, or

shrub ... species. WHERE do diverse and intact microbiotic crusts fit into this??? BLM has developed

false models that allow it find nearly al lands in the Great Basin unhealthy - due to the vegetation and

not current chronic livestock grazing disturbance - and thus in need of very expensive treatment.

[Wildland Fire and Fire Management ǦAssessment MethodologyǦFire IntervalsǦ4-219]What are

the intervals and assumptions (based on what scientific information?) that Table 3-45 Fire regime

condition Class relies? Is it the ever-changing, always out of date on-line blackbox of the agency

Landfire site? How does this all take into account the typical dense rabbitbrush, cheatgrass, rabbitbrush

and cheatgrass, and other conditions that result from many BLM fires/treatments – such as mowing,
crushing, chopping, shredding? How does it take into account the fact that removal of protective shade,

snowmelt retaining and moisture retaining vegetation that ends up making the fire season several

weeks longer? Once woody vegetation is removed, the hotter, drier uniform windier site just bakes in

the sun.

How does this deal with the fact that mining era deforestation plus BLM treatments have actually made

fires/disturbance be much too frequent and much too extensive. The BLM/AECOM/ENLC models

do not include the actual mining era disturbance in estimating disturbance intervals. Thus, there is a

significant need to minimize loss of recovering and successional PJ and some sage communities, since

the are aberrant compared to the abstruse artificial modeling assumptions that these NV deforestation

and sage destruction schemes are based on?

This is just a series of range myths heaped one on top of the other – and used to justify manipulating

and destroying plant native communities by Ely BLM using this ENLC scheme that finds everything

everywhere to be unhealthy and mixes opposing ecological concepts to impose artificial modeled

states on highly complex wild land systems.

 What is the scientific and historical basis for determining the “functionality”

The similarity index is used to compare the present state of vegetation on an ecological site in relation

to the kinds, proportions, and amounts of vegetation expected for the site. Is this “expected” or what is

wanted to maximize livestock forage grass and expensive treatments?

For many areas within the project area, the goal is to restore the state of the plant community to a

condition that is considered to be in a mid- to late-successional status. However, desired plant

communities may be developed on a treatment-by-treatment basis depending on site-specific

conditions and needs (e.g., use of non-native desired species to combat cheatgrass). THIS means there

are no rules and anything goes and any community can be converted to a crested wheatgrass and

cheatgrass wasteland at will. This is a bioengineering hubris taken to a new level of absurdity.

After management objectives have been developed, one specific plant community may be identified as

the desired plant community.

BLM Is in essence trying to inflict an artificial, farm-like scheme on grazing-stressed wild lands that

are highly vulnerable to weed invasion when disturbed, and where BLM has not ever successfully been

able to extinguish cheatgrass once BLM’s disturbances of grazing and treatment produce a significant

density of this flammable weed.

Once the desired plant community has been identified, it is appropriate to determine the similarity

index of the existing community to the desired plant community. Successional status is determined by

the similarity index, which is expressed as the percentage of a plant community that is on the site

compared to the Potential Natural Community for that site. Early successional status indicates that 0

to 25 percent, mid-successional status indicates that 26 to 50 percent, and late successional status

indicates that 51 to 76 percent of the plant community is presently on the site compared to the

Potential Natural Community. The Potential Natural Community occurs when 77 to 100 percent of the

Potential Natural Community is on the site. Figure 3-30 shows successional status on the 3 Bars

Project area. Tables 3-32 to 3-37 discuss some of the vegetation concerns and plant community status

at each...
BLM then provides a series of tables with meaningless percentages.

Under the EIS fire and other discussions of goals and objectives, BLM has a long list of nice sounding

concepts. But it never balances these often very competing uses and conflicts, as is required under

FLPMA. [Wild HorsesǦEnvironmental ConsequencesǦ4-220ȐHow is BLM protecting wild horse

foaling areas from grazing, for instance? [Wildland Fire and Fire ManagementǦAssessment

MethodologyǦFire IntervalsǦ4-221ȐWhat fire return intervals is BLM relying upon in making the

claim that it is going to:

Restore pinyon pine and juniper woodland density and coverage to the approximate values found

under natural fire return intervals

Etc. on 3-249 to 3-250.

In the EIS’s limited, self-serving analysis of adverse effects of fire, crushing, chopping, mowing,

hacking and other treatment risks, BLM makes the sweeping conclusion that:

[Wildland Fire and Fire ManagementǦEnvironmental ConsequencesǦ4-222ȐIn general,

proposed treatments would have few adverse impacts on wildfire risk. This seems to be BLM claiming

it won’t cause hot, dry, cheatgrass-choked sites.

This ignores the vast body of science on cheatgrass adaptations to grow on hot, dry sites, flammability,

and drastically altered fire cycles that doom native ecosystems. BLM only considers risks of treatment

vehicles in transporting weeds – and not the fact that destruction of the woody vegetation opens up

country to all manner of motorized travel. Plus, removes denser woody vegetation that, in combination

with slope, topography, water limitations, may have previously acted to reduce livestock impacts in

less accessible areas. It ignores the full battery of adverse impacts of grazing imposition on treatments.

For example, even Robin Tausch found that grazing use 5 or 6 years after a treatment caused

cheatgrass – in the Shoshone Underdown site. It ignores that the treatment results in a hotter, drier,

windier, more uniform site. AND that cheatgrass, heat, dryness, weather extremes, etc. are ALL

expected to favor the ever-adapting exotics like cheatgrass and other bromes.

Plus on top of all this is the significant risk that BLM will seed exotic species, or coarse cow forage

pseudo-native cultivars post-fire, introducing a new and cascading series of ecological stresses on the

land.

Special Status Plants Surveys and Baseline Ignored

[Native and Non-invasive Vegetation Resources - Assessment Methodology - Baseline StudiesǦ4-

223ȐBLM states that: No focused special status plant surveys have been conducted in support of this

project. Well, if BLM truly was interested in native vegetation, protection of biodiversity, etc. it would

have systematically conducted special status plant surveys across the project area. The battery of

treatments will disturb and destroy soils where native plant pollinators may live, radically crush, chop,

smother and otherwise destroy plants and pollinators, and promote weed infestations. It will also make

sites more accessible to livestock disturbance due to removing woody vegetation impediments.

Of the six species listed in the table, the Nevada Natural Heritage Program has records of three

occurring within the 3 Bars Project area—Beatley buckwheat, least phacelia, and one-leaflet Torrey
milkvetch. Beatley buckwheat, a BLM Sensitive Species, is known from Roberts Mountains, with an

additional mapped occurrence immediately northwest of the project area. Least phacelia, a BLM

Sensitive Species, is also known from Roberts Mountains. One-leaflet Torrey milk vetch is known from

the southern end of the Kobeh Valley, near U.S. Highway 50. Lahontan beardtongue, a BLM Sensitive

Species, has been documented from the area near the intersection of U.S. Highway 50 and Nevada

State Route 278 near the southeastern corner of (but outside of) the project area.

According to BLM resource specialists, the Monte Neva paintbrush (state listed as critically

endangered) is only found in riparian areas associated with hot springs at low elevations within the

greasewood-rabbitbrush-sand dropseed

BLM imposes massive treatment polygons without ever looking for species both in the polygons and

on the ground across the project landscape. All it does is consult old databases where only small areas

of the sprawling project have had any surveys.

The potential adverse impacts on sustainable pine nut production – for pinyon jay and other species as

well as humans is huge. All pine nuts intended for resale require a permit/contract. The three

designated areas in the 3 Bars Project area for commercial pine nut harvest (North Simpson Park,

Roberts Mountains, and Whistler/Sulphur Spring) total approximately 303,300 acres.

DEIS 3-209 makes self-serving unsubstantiated assumptions. Removal of fuel does not directly

translate into reduced fire danger. With weed invasion, and hotter, drier windier sites – and if

cheatgrass invades – and catalytic converter fires and other increased human incursions with motorized

vehicles occur, these projects are likely to greatly increase fire frequency, and with more areas burned

even more areas will be at risk of rapid, frequent fires. By trying to prevent so-called ”catastrophic” PJ

fires BLM is disrupting the natural fire characteristics of this arid land forested ecosystem, and actually

making it much more likely to burn - and much more out of balance with the natural disturbance and

fire interval.

All treatments that reduce the buildup of hazardous fuels would help reduce the risk of wildfire in the 3

Bars Project area. Therefore, these treatments would be expected to have a long-term benefit by

reducing the likelihood that a catastrophic wildfire could burn sensitive plant species and high quality

native plant communities, such as sagebrush, desert salt scrub, native grasslands, and native

woodlands.

Fuels reduction treatments and creation of fuel and fire breaks would all reduce the risk of

catastrophic wildfire in pinyon-juniper and sagebrush habitat. The reduced risk of wildfire would be

expected to benefit sagebrush and pinyon-juniper communities, which are generally adversely affected

by large wildfires. Again, this is based on incorrect fire return and disturbance models, and does not

take a hard look at all the adverse impacts of the hot dry, open, windier, weed-prone, OHV enticing

treatment effects.

[Proposed Action and Purpose and Need - Documents that Influence the Scope of the EISǦ4-224Ȑ

BLM cannot rely on the PER, because it did not undergo NEPA, and is based on flawed and woefully

outdated science. The ESA consultation was not over the PER, but the herbicides, and that too is old

and outdated. See Beck and Mitchell 2012, Jones et al. 2013, etc. Full and complete new consultation

must occur here.

The BLM may use prescribed fire in Lahontan cutthroat trout occupied drainages under stipulations

developed through the Endangered Species Act Section 7 process. The effectiveness and potential

impacts of prescribed fire are discussed in the 17-States PER (USDOI BLM 2007c: 4-36, 4-54 ...
BLM states:

A 2001 study of aspen stands in the Roberts Mountains area concluded that aspen are generally in

poor condition and that many stands are not readily regenerating (Kay 2001). The BLM has also

observed that aspen regeneration and recruitment are below their potential throughout the 3 Bars

Project area. While fire suppression may be a contributing factor, ungulate herbivory of new growth

from root suckers appears to be the primary factor preventing successful regeneration of aspen stands.

Aspen regeneration is a key management concern and aspen enhancement ...

Indeed, and the Kay report and exclosures like in Simpson Park show it is the cattle and sheep that are

the “ungulates” doing the damage.

In the long term, treatments are expected to result in an expansion of riparian and wetland habitat,

(re)establishment of riparian and wetland habitat where these communities have been lost or

diminished due to erosion, incising, and herbivory, and protection of riparian habitats from wildfire.

Native riparian vegetation is much more resilient to wildfire than riparian corridors that have been

taken over by upland vegetation such as pinyon-juniper or sagebrush. Efforts by the BLM to enhance

wetland and riparian vegetation would help to increase the number of miles of stream and acres of

wetlands that are in Proper Functioning Condition.

Has BLM ever really looked closely at juniper growing in or near aspen stands or many other areas?

Often there are many series of sapsucker holes drilled in the trees – an insect trapline. Juniper also

provides thermal cover for species like bushtits, in areas near riparian zones, and a wealth of other

wildlife values. Plus, the proximity of rocky outcrops, canyon-like settings, etc. mean that PJ often

naturally occurs by, in, or close to riparian areas. The EIS proposes highly unnatural manipulation and

stripping of often the only cover protecting the watersheds and streams.

BLM states:

Mechanical treatments such as chaining generally increase herbaceous biomass, but this improvement

in forb and grass cover may disappear after about 25 years as pinyon-juniper reestablishes [this

shows these are persistent PJ sites!] on the site (Tausch and Hood 2007). Follow-up maintenance

treatments with chainsaws or a roller chopper are typically required within 10 to 20 years of treatment

initiation to remove trees that have persisted from the initial chaining. Use of mechanical equipment

can also be limited by terrain (Miller et al. 2005), and as discussed under Soil Resources (Section 3.8),

much of the area targeted for pinyon-juniper management is not suitable for chaining or shredding

because of steep slopes and other factors. Chaining could also cause the loss of desirable vegetation,

and lead to invasion of the site by noxious weeds and other invasive non-native vegetation. Thus,

chaining would likely be used on a limited basis in the 3 Bars Project area. WELL – all of this just

shows that the sites that were being walloped in the Taush and Miller studies are actually persistent PJ

sites – Plus BLM’s treatments may erode enough soil to make them harsher, drier sites that may be

even more favorable to PJ.

BLM proposes not allowing natural succession to occur, and keep killing off trees and sage into the

future. This project will have serious long-term adverse effects, and there is no semblance of

restoration involved in this perpetual disturbance scheme.

The BLM would utilize fire as one means of removing and thinning pinyon-juniper from treatment

sites ... Fire is highly non-selective, risky, promotes rapid spread of cheatgrass, harms and destroys

understories ... BLM will destroy mature and old growth trees, mahogany mature and old growth sage,
and other vegetation with fire, as well as expose cultural sites to erosion, streams to sedimentation,

soils to erosion in wind, etc.

These are the exact conditions where BLM is not supposed to be burning things –lest treatment effect

conditions end up being like a catastrophic fire:

Prescribed fire treatments can produce desirable results on sites with woodlands in Phases I and II

particularly when there is an abundance of perennial natives in the understory (Tausch et al. 2009).

[Native and Non-invasive Vegetation Resources - Environmental Consequences - Pinyon-juniperǦ

4-225ȐThe BLM plans to conduct most burns on Phase II or Phase III sites to initiate stand

replacement and to avoid impacts to shrubby vegetation including sagebrush. These sites generally

have a depleted understory ... Doesn't even Miller say not to burn these sites??? WHAT does all this

self-serving circular reasoning nonsense mean? Except that it is likely to be wildly expensive, and

make no difference in the end - as all of the lands are likely to become weedlands under the multiple

repeated and overlapping disturbances that BLM seeks to impose.

BLM has not dealt with the very serious risk of adverse outcomes of this project. BLM takes 11% of

the veg being something it seeded as a success.

After broadcast burns, the BLM may need to reseed burned areas with forbs, grasses, and shrubs.

Based on past reseeding treatments conducted for several wildfires burns in the District, seeding and

planting of native and non-native vegetation may have limited success, especially during drought years

and native release of seeds may be the primary mechanism for site revegetation. However, in areas

with sufficient moisture, seedings have been successful and have resulted in an abundance and

diversity of forbs, grasses, and shrubs. For example, at the Fluffy Flat wildland fire site, 11.4 percent

of vegetation was comprised of seeded species and seedling survivorship was 54 percent 3 years after

seeding (USDOI BLM 2011e). To ensure vegetation restoration success, the BLM may prohibit

livestock access to the area through grazing closure decisions that are effective upon issuance. The

BLM may also use temporary fencing, including electric fencing, which has been used effectively at

wildfire restoration sites to improve revegetation success by excluding livestock, wild horses, and wild

ungulates (USDOI BLM 2009d, e, 2010e, f, g, h, i, j, 2011e, f).

It does not even guarantee that cows/sheep will be excluded, just stating ‘may’ and does not deal with

the adverse effects on wildlife wildhorses, recreational uses, etc.

[Vegetation Treatments Planning and Management - Methods - Planting and SeedingǦ4-226]What is

a “replacement” species? Are we to have hybridized weedy coarse exotic and pseudo-native cow

forage cultivars strewn across this supposed “restoration” landscape?

BLM claims its treatment acres are only a small portion the watersheds – however they are typically

the primary areas where water is present and many are concentrated by are within the likely area of

Mount Hope aquifer depletion.

Grasses and forbs would benefit from prescribed fire and would be the first to revegetate the site. If

non-native annual grasses and forbs occur on a site prior to fire, and if fire intensity is high, then nonnative annual grasses and forbs would be the first to establish after a fire. Without other treatments,

non-native annual grasses and forbs may dominate the site (USDOI BLM 2012b). The BLM generally

has had good success in controlling non-native vegetation and allowing native vegetation to establish

on sites treated using prescribed fire on the 3 Bars Project area (see Section 3.12.3.3). However, some
sites could require seeding or other rehabilitation efforts following the fires, or it could take decades

following a fire to fully establish all desired vegetation including understory vegetation

Projects to thin sagebrush (Alpha group), reduce herbaceous dominance (Rocky Hills Unit), open the

sagebrush canopy (Table Mountain 2 Unit group), and treat cheatgrass (West Simpson Park Unit),

would potentially have short-term adverse effects on sagebrush habitats. However, provided project

objectives are met, the long-term goal of these activities is to improve the quality of sagebrush habitats.

In some cases, the species composition at treatment sites would change, as sagebrush enhancement

projects would focus on the components of greater sage-grouse habitat. For instance, at the Rocky

Hills Unit, where there are extensive stands of crested wheatgrass and forage kochia, the BLM would

conduct treatments to minimize the non-native herbaceous component and increase the sagebrush and

native herbaceous component. For the Table Mountain 2 Unit group, mature sagebrush communities

with a minimal understory component would be thinned to reduce shrub cover and promote the growth

of forbs and grasses.

“Treating” cheatgrass certainly means herbicide use. A SEIS is essential to analyze all the adverse

effects of the herbicide use these projects will result in.

We support eradicating the forage kochia and cwg.

Biological control has been identified for use in the Table Mountain, Rocky Hills, and West Simpson

Park units. Targeted grazing ...

Biological control has been identified for use in the Table Mountain, Rocky Hills, and West Simpson

Park units. Targeted grazing would be used to maintain firebreaks to help reduce wildfire risk in these

areas. Grazing can contribute to the spread of noxious weeds and other invasive non-native vegetation

through preferential grazing of native vegetation over noxious weeds and other invasive non-native

vegetation, and by movement of noxious weeds and other invasive non-native vegetation into

uninfested areas via livestock feces (USDOI BLM 2007c). Therefore, there would be some risk of

establishment or spread of noxious weeds and other invasive non-native vegetation in treated

sagebrush sites if these species are already present in the grazed areas, or if the livestock are brought

in from an area where these species occur.

Sagebrush treatments would affect woodland products, as pinyon pine and juniper would be removed

from these. No mitigation or monitoring measures are recommended specifically for native and noninvasive vegetation resources.

Because cheatgrass is so widespread and established in the range within the Battle Mountain District,

surveys for this species are not normally conducted. However, areas of observed cheatgrass and areas

with the potential for cheatgrass monocultures within the project area have been mapped, as shown on

Figure 3-33.

[Noxious Weeds and other Invasive Non-native Vegetation - Affected Environment Ǧ4-227ȐFigure

3-33 shows no cheatgrass, and no cheatgrass potential. Where is the mapping, and what assumptions

were used? Who did it? Was ENLC involved?

Mapped areas include relatively large cheatgrass monocultures in various former burn areas in the

northern half of the project area. Large burn areas in the northern portion of the project area are
considered areas of cheatgrass monoculture potential. However, the BLM has seeded many of these

burn areas with non-native perennial grasses and forage kochia under the BLM Emergency

Stabilization and Rehabilitation Program to combat cheatgrass expansion. During the rangeland

health studies, cheatgrass was observed in sampling areas throughout the project area, with the

greatest frequency of observance in areas that have been affected by wildfire (Eastern Nevada

Landscape Coalition and AECOM 2012). Cheatgrass is likely present in other portions of the 3 Bars

Project area, although not necessarily in quantities that warrant treatment.

[Noxious Weeds and other Invasive Non-native Vegetation - Affected Environment Ǧ4-228ȐHow

in the world could BLM do an EIS and not even know where cheatgrass is located in the project area?

BLM must conduct a Supplemental EIS based on this shortcoming alone.

BLM under Fire states:

[Alternatives Ǧ4-229ȐAlternative C would not restore fire as an integral part of the ecosystem,

reduce the risk of a large-scale wildfire, or reduce extreme, very high, and high wildfire risks to

moderate risk or less. Only about 500 to 1,000 acres would be treated annually to reduce hazardous

fuels, and the BLM estimates that the FRCC would be reduced on only about 3,750 to 7,500 acres over

the next 10 to 15 years, fewer acres than under Alternatives A and B.

Where is the scientific basis for discounting this? It would minimize flammable weeds. It would

maximize retaining snow and rain on-site - resulting in a shorter fire season. We have often seen BLM

claim any tree cutting reduces fire. This is yet another an illustration of the bias of the EIS.

[Wildland Fire and Fire ManagementǦAssessment MethodologyǦFire Intervals Ǧ4-230ȐFigure

3-35 is labeled natural fire Regimes. Is this based on the same fire intervals as the ENLC< Ecosite and

any other assessments or analysis were based on?

[Wildland Fire and Fire ManagementǦAssessment MethodologyǦFire Intervals Ǧ4-231ȐEIS

mapping makes no sense in relation to greasewood and other veg communities. When one compares

Map Figure 3-26 (if we are interpreting the pastel colors correctly) , then it appears that greasewood

and playas are in Group V.

[Wildland Fire and Fire ManagementǦAssessment MethodologyǦFire Intervals Ǧ4-232ȐThen,

the next map is Fire Regime condition class – where it shows these areas as Group 1.An earlier map

shows these areas as Moderate risk of “Catastrophic” [note BLM use of biased Fear-mongering

terminology] fire. What is going on? Can BLM just dream up models and schemes until it hits upon

one that shows what it wants to justify spending tens of millions of dollars? Are different schemes

being applied with different fire and disturbance intervals, and different assumptions? And what are

the recovery intervals, and how is recovery defined? What science is this based on/

Under these crazy schemes, only some cwg seedings, it appears are at low risk of catastrophic fire.

Map 3-37. This is not, though, how the real world works. See WWP Jarbidge BLM Fire Rehab Appeal

comments describing how very readily and frequently cwg burns.

Jarbidge BLM fires, fires all along the northern areas of the Snake River Plain, large-scale recent fires

in eastern Oregon, and many other areas with extensive cwg seedings show that fires burn at breakneck

speed, and quickly grow to immense size, in areas of extensive cwg seedings.
[Wildland Fire and Fire ManagementǦAssessment MethodologyǦFire Intervals Ǧ4-233ȐPlease

provide detailed analysis of the intervals, assumptions, scientific basis for all of these various schemes

to portray native vegetation communities as unhealthy or having particular risks involved.

The interval for PJ communities in the chart 3-41 should be 200 PLUS years for PJ, as well as for plant

communities like black sage, much Wyoming big sage, etc. See Bukowski and Baker (2013, Romme et

al. 2009 a, b, USFWS WBP Finding for GSG, Knick and Connelly 2009/2011, Baker 2006.

The chart says it comes from the Landfire Database, a blackbox site with ever-changing info inputs. At

what specific point in time? This is a common trick used by Ely BLM and others to avoid any

accountability and systematic consideration and analysis of current science. BLM simply points to an

on-line FRCC Landfire database, and never includes the assumptions that were used in the calculations,

data and scientific sources behind the assumptions, etc. Thus, mapping and analysis all is designed to

support destruction of all native veg communities that are present anywhere on the landscape.

The series of maps is based on programmatic modeling and unsupported assumptions that are not

grounded in the ecological reality of the current fire situation across the western public lands.

[Wildland Fire and Fire Management - Assessment MethodologyǦFire Management PlanǦ4-234Ȑ

BLM tries to rely on its greatly outdated 2004 BLM Fire Plan. BLM states:

In the amendment, the BLM developed fire management categories, ranging from wildland fire not

appropriate and full suppression with an aggressive initial attack is recommended (Category A), to

wildland fire is appropriate and there are no constraints (Category D). Under the fire management

plan, most of the 3 Bars Project area dominated by pinyon-juniper vegetation was categorized as

Category C. Under Category C, wildland fire is appropriate, but there are constraints on its use.

The world has changed dramatically since that old plan, based on even older and outdated assumptions

about fire, cheatgrass, climate change, was develop. Did that plan ever undergo NEPA? If I recall

correctly, it does not appear that the highly flawed Ely plan of that same vintage was ever subjected to

NEPA.WHAT scientific information was that plan based? On the unsupported Miller and Rose,

Perryman or other claims that Basin big sage in valleys burned every 25 years or so, or that PJ burned

every 35-50 years and then only in light little fires, and other long since disproven “range” friendly

myths that Miller, Tausch and others had been promoting in that era?

Scientific knowledge about the adverse effects of climate change and adaptations of cheatgrass and

other highly invasive species was not factored into the 2004 Fire Plan.

Despite BLM’s longstanding efforts to claim that cwg is some kind of firebreak – the effects of largescale wildfires across many areas of the west have shown that fires can burn through cwg seedings at

the rate of over 50,000 acres – and at times 100,000 acres per day. Compare that to the rate of fires

spread through even the most juniper covered landscape.

BLM has cobbled together an incomprehensible stack of treatment models and gibberish. It even

embraces the extreme averse disturbance of targeted grazing, which will only serve to increase dust

erosion, increase weed problems, disturb and displace native wildlife during sensitive periods of the

year, obliterate any native species recovery, and cause worse continuous hazardous fuel cover than

already exists, impair HMAs, disrupt the TNEB, etc.
In relation to fuelbreaks, too, BLM makes the assumption that killing vegetation will stop fires and

provide fuelbreaks. This is just plain incorrect:

Because about 17 percent of the 3 Bars Project Area would be treated during the next 10 to 15 years,

and nearly all proposed treatments would provide some benefit toward hazardous fuels reduction, the

BLM estimates that the FRCC on about 95,000 acres would improve over the next 10 to 15 years

under Alternative A.

Instead, BLM is likely to increase hazardous fine fuels and frequent flashy cheatgrass fires.

BLM fails to address the fact that the areas treated are to be nearly all the PJ, and much of the higher

elevation sage, and sage on deeper soils. Instead of re-connecting sage-grouse and pygmy rabbit

haibtats, this is likely to tear them asunder.

BLM clearly is promoting large-scale biomass:

To reduce this risk, felled trees would be used for posts or mulch, sold for commercial biomass

utilization, placed in streams to slow water flow, or burned in piles or as slash.

These systems need nutrients in wood (different from manure and urine from the huge herds of

domestic livestock that have been imposed) for soil, for watershed function, to moderate conditions at

ground level, provide protected and safe sites for native plants to germinate and grow and not be

destroyed by livestock.

These units have been identified as having high to very high risk of catastrophic wildfire, or in the case

of the Tonkin North, Lower Pete Hanson, and Whistler units, very high to extreme wildfire risk (Figure

3-36). These units have moderate amounts of standing dead and dead down wood, excessive surface

litter, and a closed canopy that is conducive for a crown fire (USDOI BLM 2009a). [Wildland Fire

and Fire ManagementǦEnvironmental Consequences Ǧ4-235ȐBy increasing canopy spacing

among pinyon-juniper, the potential for a crown fire would be less, while residual trees would provide

surface shading that lowers fuel temperatures (Tausch et al. 2009). Tausch turns out to have been

wrong about PJ mining era deforestation, fire return intervals, and also selectively aged trees. This

claim is disproven by the on-the-ground effects of recent fires across a variety of forest types that

show that wind-driven fires put out embers far from the fire front, and that thinning of the type

described here does not work in those conditions.

BLM states:

The BLM would restore fire as an integral part of the ecosystem and reduce hazardous fuels on the

Sulphur Spring Wildfire Management Unit by using wildland fire for resource benefit. Several

wildfires have occurred in this area in recent years due to dense fuel accumulations and pinyonjuniper cover. In recent years, the BLM has used chainsaws, mowers/shredders, and prescribed fire to

create fuel breaks and remove diseased pinyon-juniper (USDOI BLM 2009a). By reducing fuel

accumulations and opening up the canopy cover, sagebrush and other shrub ... How many of these

fires, and how any acres, have burned in areas already burned in previous fires?

[Wildland Fire and Fire ManagementǦEnvironmental Consequences Ǧ4-236ȐBLM references

2008 Red Hills monitoring –but this was only a short time after the fire. How much cheatgrass is
present now? We are also strongly opposed to BLM’s reliance on expensive and harmful chemical

herbicides that are very prone to drift when applied in wildland settings.

PLEASE spend all of your time and energy doing something about this area:

The West Simpson Unit was burned during the 1999 Trail Canyon Fire, and has substantial cheatgrass

cover and is in an area rated as high to very high for risk of a catastrophic wildfire. Cheatgrass is

quite flammable during the summer, and efforts to eliminate it or slow its spread would help to reduce

the risk of wildfire. Crested wheatgrass, forage kochia, and cheatgrass dominate ...

[Noxious Weeds and other Invasive Non-native VegetationǦEnvironmental Consequences Ǧ4-

237ȐHow will you eradicate the forage kochia weed that was purposefully seeded? With herbicides?

How long were these areas rested from grazing following the fire? How will you eradicate the

hazardous cheatgrass fuel?

[Alternatives Ǧ4-238ȐBLM constantly unfairly tries to downplay the benefits of Alternative C, and

appears to have purposefully excluded a series of passive restoration actions and some active

restoration from Alt C. For example, eradicating the forage kochia and crested wheatgrass, and

planting sagebrush and native grasses shoud be part of Alt. C.

BLM states:

Fire and fuel break treatments would primarily be limited to stream and aspen habitats, or near roads,

where pinyon-juniper would be removed to enhance or create new breaks ...

[Wildland Fire and Fire ManagementǦAssessment MethodologyǦFire IntervalsǦ4-239ȐThis is

what BLM has claimed elsewhere is needed to prevent fuelbreaks – not tearing up the whole landscape.

Despite all the EIS bulk, there is not strategic planning and analysis of wind direction, slope, and other

factors to identify fire risk.

BLM states: Alternative C would not restore fire as an integral part of the ecosystem ... Actually, Alt.

C would go much further towards restoring the natural and integral role of fire in the ecosystem than

would the BLM’s slash and burn actions. These lands have had too much disturbance – including

mining era deforestation, BLM treatments, chronic livestock grazing disturbance, etc.

Page 2-359 has the classic Ely-ENLC assessment wording about the causes of all the problems – i.e.

the “historic” grazing that lets current chronic grazing disturbance off the hook. When does the current

grazing period start, and when did the historic grazing period end? Is cattle grazing in 2012 considered

“historic”? Why is it the case that cheatgrass is spreading so rapidly recently?

Historic overgrazing, introduction of cheatgrass, large wildfires, and other natural and human-caused

factors have contributed to the departure of the plant communities from the Potential Natural

Community across the 3-Bars ecosystem. This has led to a decrease in the functionality of ecological

processes, thus reducing the resilience and resistance of these ecosystems to disturbance. The

treatments proposed in the 3-Bars ecosystem are designed to provide the means needed for these

ecosystems to recover.

And as with all other parts of this: No mitigation measures are proposed for wildland fire risk. Heaven

forbid BLM accompany this EIS with a concrete Plan to restrict roading, remove or greatly curtail
grazing, etc.

LCT Concerns

[Fish and other Aquatic Resources Ǧ Affected Environment Ǧ 4-240Ȑ We understand that USFWS has

said that the LCT here, since they were moved in from other drainages, are not as important as LCT

elsewhere. Is that the case?

BLM admits that Threats to Lahontan cutthroat trout include

habitat fragmentation due to physical and biological conditions, alteration of stream discharge, w

water quality degradation, and introduction of nonnative fish species (

Coffin and Cowan 2005,

USDOI USFWS ...

[Fish and other Aquatic ResourcesǦEnvironmental ConsequencesǦ4-241ȐYet what are the actual

concrete watershed-level actions that will result in habitat - other than removal of livestock from the

watersheds –not just new barbed wire strips? What pastures cab be closed to better protect watersheds?

[Fish and other Aquatic ResourcesǦAffected Environment Ǧ4-242ȐTo what degree are Vinini and

Henderson creeks currently connected (map 3-39)?

[Fish and other Aquatic ResourcesǦAssessment Methodology Ǧ4-243ȐHave springsnail and native

amphibian surveys been systematically conducted across the Three Bars landscape? If so, when and

where?

The EIS states: A significance criteria is if the action results in long-term (greater than three year

duration) in alteration or loss of habitat. THEN all of the actions, including allowing any more

grazing in these watersheds, results in long-term impacts.

Grazing results in water quality effects that last much longer than 1 month, as sediment, manure and

urine - all promote algae that chokes streams. Destruction of 10o year old juniper shading streams

within 200 ft of streams represents extremely lasting, detrimental and significant threats.

It is extremely likely that large-scale deforestation, bulldozing, etc and continued grazing in the

watershed will result in significant detrimental effects. Climate change alone is likely to result in this

much.

BLM proposes harmful ribbon and strip band-aid fencing, while letting livestock continue to hammer

the watersheds. Plus PJ currently provides all of the following:

[Fish and other Aquatic Resources ǦEnvironmental ConsequencesǦ4-244ȐRiparian vegetation is an

important habitat component for aquatic species, as plants provide overhanging cover, temperature

control via shading, bank stability, a food source from insects on the vegetation, and nutrient input to

the stream from loss of leaves and branches . Then why is BLM killing all the PJ within 200 ft of the

streams?

[Vegetation Treatments Planning and Management - Methods - Riparian Ǧ4-245ȐBLM claims it will

replant its bulldozed, devegetated, cut banks – how long will it take for willows to recover to the height

of junipers? Plus, in these steep streams, the PJ on the slopes are providing critically important shade.
By removing this protective cover, BLM will dramatic increase water temperatures, runoff force

during high severity rain events, etc.

This will also result in rapid runoff and contamination from the herbicides BLM will be applying to

control the white top, knapweed, or other weeds its aggressive scorched earth, PJ stumps and bulldozed

streambank treatments will produce.

BLM provides no scientific basis for this claim:

... Adverse effects of mechanical treatments on water quality would be expected to be

localized and of term in duration, with water quality returning to pre-disturbance conditions within

several days or weeks after treatment is completed ...

.

BLM will be lucky if it recovers the protective cover and shade it previously had within several

decades under the bulldozed streambank and juniper stump approach to riparian management.

Please review the information for Riparian Habitat Areas in the Pacific NW. These were established to

protect trees from logging because of the shade, stabilization, structure and other important attributes

that conifers provide for aquatic systems, especially those inhabited by ESA listed species. Instead

here, BLM wants to essentially denude the entire RHA.

Wilderness, Recreation, Visual, Cultural Concerns

BLM makes sweeping statements that again are not fully fairly and critically evaluated.

For example:

Long term, the effects of treatments on recreation would be positive and would include the following:

• Restoration of the historic landscape that would be beneficial to the visitor experience, including the

Pony Express National Historic Trail retracement experience.

• Improved habitat and associated wildlife.

• A reduction in the presence and number of noxious weeds and invasive non-native vegetation.

• A reduction in the risk of a large-scale, catastrophic wildfire

What are the important natural, scenic, biological and other values of the WSA? Destruction of the

native vegetation communities will impair these and other values. Ugly treatment scars will mar the

values. The battery of direct, indirect and adverse treatment and lose and uncertain grazing schemes

impacts will trammel the landscape with weeds, unnatural scars excessive erosion, streams lacking

natural protective PJ cover within 200 ft. of the stream, etc. BLM also proposes treatments that are not

appropriate in WSAs or LWCs. [Wilderness Study Areas and other Special Management AreasǦ

Affected Environment Ǧ4-246ȐWhy haven't you done a Lands with Wilderness Characteristics study

across the Three Bars area? Particularly in the Simpson Park area?
[Wilderness Study Areas and other Special Management AreasǦCumulative Effects Ǧ4-247ȐBLM

has failed to provide an adequate baseline of the current degree and severity of impairment of values

from livestock grazing degradation or other threats to the WSAs. The treatments will prevent natural

plant successional processes form occurring, and increase risk of impairing cheatgrass that will overrun

wildlife habitats, and watersheds ad result in ugly continuous exotic species areas.

Why will BLM be closing the areas for treatment – AND afterwards?

[Wilderness Study Areas and other Special Management AreasǦCumulative Effects Ǧ4-248ȐWe

are very concerned about all the BLM proposed herbicide use, including aerial application where there

is significant risk of drift.

The Mount Hope mine would disturb more than 8000 or so acres – the noise, lights, excessive water

use, large-scale increase in traffic and human disturbance are a large-scale human disturbance.

Statements like the following are of great concern, and no scientific evidence is provided for the claims

that there will be improvement – and not in fact large-scale degradation.

Treatments would improve the aesthetic and visual qualities of recreation areas for hikers, bikers,

horseback riders, and other public land users; reduce the risk of recreationists coming into contact

with noxious weeds and other invasive non-native vegetation; increase the abundance and quality of

plants harvested from public lands; and improve habitat for fish and wildlife sought by ...

For all parts of the EIS, there is no basis provided for the claims of lightning speed and remarkable

recovery BLM claims will occur. Example:

3 Bars Project restoration treatments could degrade or reduce recreational opportunities in the short

term (< 5 years), but treatments should result in a healthy and functional landscape that provides

additional recreational opportunities. Up to 15,000 acres could be off-limits to the public due to

mining and other land uses for up to 70 years, but these areas are subject to reclamation requirements

and would have minimal long-term effects on recreational opportunities in the CESA ... You have to

be kidding – Mount Hope (if built) will be a huge industrial zone polluting land, air water, standing out

with bright lights visible from 20-30 miles away (at a minimum) with traffic of all kind, noise, and

dramatically increased human disturbances, etc.

WHY won't BLM simply allow natural processes to operate in the WSA – restore beavers, and remove

cows/sheep from existing pastures in WSAs.

BLM admits:

The production of charcoal and cordwood was one of the area’s most significant industries historically,

and it resulted in substantial changes to the environment as it existed before 1850. The furnaces of the

Eureka mining district, as well as those at other mines in the area, required tremendous quantities of

charcoal. In addition, cordwood and lumber were needed for other mining and industrial purposes

such as construction. Pinyon-juniper cordwood was also used for fuel by the E&PRR until 1890, when

the railroad switched to coal (Zeier 1985:18).

By far the largest single consumer of charcoal was the Eureka mills. In 1880, at the height of mining

within the Eureka District, the mills consumed a total of 1.25 million bushels of charcoal. Young and

Budy (1979:117 cited in Zeier 1985:18) stated that “the demand for charcoal was so great that
deforestation became a severe problem” with 4,000 to 5,000 acres of woodland cut annually. By 1878,

the average hauling distance from (charcoal) pit to smelter was 35 miles.

Regarding threats to cultural sites and values, the EIS states:

The greatest risks to cultural resources would be from mechanical and fire treatments.

Chaining, root plowing, tilling and drill seeding, mowing, roller chopping and cutting, blading,

grubbing, and feller-bunching could damage surface and subsurface cultural resources if the sites

were not avoided. Treatments could compromise depositional context and integrity, and damage or

destroy artifacts. Several thousand acres could be burned annually using prescribed fire and wildland

fire for resource benefit. The effects of fire on cultural resources would vary depending on temperature

and duration of exposure to heat. Generally, higher temperature and/or longer exposure to heat

increases the potential for damage to cultural resources. As a general rule, fire does not affect buried

cultural materials. Studies show that even a few inches of soil cover are sufficient to protect cultural

materials. However, there are times when conditions do carry heat below the surface, with the

potential to affect buried materials.

[Vegetation Treatments Planning and Management -MethodsǦFire for Resource BenefitǦ4-249Ȑ

This “fire for resource benefit” means BLM is planning to nurse wildfires along. So why all the

hysteria bout the need for treatment, when BLM proposes to just let lands burn up anyway?

BLM ignores cumulative effects of erosion from disturbance livestock trampling exacerbating erosion,

combined effects of treatments on large-scale erosion and loss of artifacts and scientific values and

stratigraphy at sites.

BLM states:

Wildfire is generally more destructive to cultural resources than prescribed fire, since it results in

effects from both uncontrolled fire and fire suppression. Management decisions may need to balance

the potential effects of a prescribed burn with the risk of damage from an uncontrolled wildfire.

Because prescribed fire can be controlled ... Fires also ESCAPE. See Ely North Schell Escaped

Prescribed Fire report. Plus, there is typically not all the endless messing around manicuring the

landscape with dragging and piling slash, or dump trucks hauling biomass chips away - associated

with wildfires as occurs with this treatment scheme.

BLM defies all logic and reason in its zeal to destroy the forests that naturally occur, and which

historically occurred, in the Three Bars project area.

The harvesting of pinyon nuts, once the most prominent staple among the Western Shoshone and many

other tribes in the region, was not only an important subsistence activity but an important cultural

event, and to some extent is still today. Harvests were provided with a spiritual leader who arranged

and presided over a pinyon nut harvest dance before gathering. This several-day celebration

constituted a major social event and included prayers, songs, dances, gaming and sporting events, and

feasting. New group leaders were chosen, marriages were arranged, and people exchanged

information about resources, harvesting techniques, and political affairs. Plans for subsequent

harvests and social alliances were developed. The largest celebrations and harvests in the project area

occurred on the Roberts Mountains and Sulphur Spring Range with smaller events in the Mount

Tenabo area (Rucks 2004:12). To a great extent, the size of these celebrations was the result of an

increased population in these areas, supported by the diverse and dense resources present in them.
For example, according to Rucks (2004:6), the present-day Western Shoshone still refer to Roberts

Mountains as a resource-rich area (especially pinyon) that Steward (1970 [1938]:141) noted as being

capable of supporting up to 60 households, a far larger population than in many surrounding parts of

Western Shoshone territory.

Cutting live trees for firewood is frowned upon by many present-day Western Shoshone and only dead

wood is cut, a practice that does not harm trees or reduce potential future nut harvests. Although

pinyon nuts no longer constitute a major staple food for the Western Shoshone, they are consumed on

special occasions ...

This all demonstrates that the natural historical vegetation over much of the area targeted by the Three

Bars project area targeted for massive fire, biomass export in dump trucks, bulldozer chaining, slashing,

beating, crushing, chopping, etc. is PJ. BLM has abandoned science and environmental ethics in tis

current zeal to destroy the native PJ and sage systems of the Three Bars area.

Additional Sensitive Species Concerns

[Wildlife ResourcesǦAffected EnvironmentǦ4-250ȐBLM omits many sensitive species from its

paragraph descriptions in the EIS. Those it does mention are incorrectly analyzed, and no systematic

surveys and proper baseline were developed. For example, BLM claims that its treatments would

benefit pygmy rabbits. These treatments will alter, fragment, degrade and destroy pygmy rabbit

habitats. Every part of the aggressive treatment scheme is very harmful to pygmy rabbits and other

sagebrush sensitive species. Direct, indirect and cumulative effects analysis for sensitive species

glosses over serious harms and degradation. Plus the treatment avoidance time periods and methods

are greatly inadequate to protect sensitive species and migratory birds, as well as eagles and native

raptors.

[Wildlife ResourcesǦStandard Operating ProceduresǦ4-251ȐBLM violates the National Technical

Team Report and its own Instruction Memos for sage-grouse. It violates the Conservation Plan for

sage-grouse, and may thwart the outcome of the Greater sage-Grouse Regional EIS process by

prematurely destroying vegetation in aggressive treatments that would be limited under that EIS.

Land Use Plan and Other Legal Violations

The EIS fails to address many provisions and protections of the Land Use plan, including those for

forestry, soils, vegetation, watersheds, sensitive species, WSAs, big game, and other values of the

public lands.

We can only conclude that the EIS is inadequate under NEPA. A supplemental EIS must be prepared

to clear up all the uncertainty and prevent harm and undue degradation to the Three Bars landscape,

and violations of FLPMA, the Wild Horse and Burro Act, the Clean Water Act, the Migratory Bird

Treaty Act, BGEPA, the ESA, BLM’s own sensitive species policy, and conservation plans.
Katie Fite

Western Watersheds Project

PO Box 2863

Boise, ID 83701

208-429-1679

Deniz Bolbol

American Wild Horse Preservation Campaign

P.O. Box 1048

Hillsborough, NC 27278

Appendix A

EXAMPLE OF PLETHORA of MINING PROJECTS with Cumulative Impacts

Here are just some of the mining actions underway in recent years in Battle Mountain and nearby BLM

lands. This demonstrates the tremendous ecological footprint of mining, and new actions that will have

drastic and ever-increasing impacts on aquifer drawdown, facilitate weed invasions and habitat

fragmentation for sage-grouse, and a welter of other adverse impacts. The cumulative impacts area and

assessment of the DEIS is woefully inadequate.

It is essential to understand these effects in order to understand their cumulative impacts on the lands,

species, watersheds, affected by the Three Bars Project.
http://www.blm.gov/pgdata/etc/medialib/blm/nv/resources/racs/moso_rac.Par.19904.File.dat/BMDO.D

M.Report.July2011.pdf

MINERALS MANAGEMENT

MOUNT LEWIS FIELD OFFICE

Eureka Moly Mount Hope Project - BLM comment letter on Version 12 of the Plan of Operations was

issued to Eureka Moly in February 2011. The BLM expects Version 13 prior to the issuance of the

Draft Environmental Impact Statement (DEIS). The interdisciplinary team and cooperating agencies

have reviewed a second version of the Preliminary DEIS in May and the DEIS is expected to be issued

in late August.

Newmont Phoenix Copper Project – The Preliminary Draft Supplemental Environmental Impact

Statement (PDSEIS) has been issued to the interdisciplinary team and cooperating agencies. The

DSEIS is expected to be issued in July.

Newmont Mule Canyon - Newmont is evaluating the possibility of resuming mining at this site. If

mining is not resumed, the closure process will continue. Newmont will inform BLM of their plans in

by the end of June 2011. Newmont continues to operate under terms and conditions of an Interim

Water Management Plan.

Newmont Buffalo Valley Mine - Newmont is in the process of conducting baseline analyses in

preparation for submittal of a Plan of Operations to mine gold.

McCoy/Cove - Reclamation is on-going. Quarterly inspections continue to be conducted. Newmont

Toiyabe Exploration Project – Final bond release has been issued for the reclamation and the

project has been closed.

Barrick Cortez Hills – The Supplemental Environmental Impact Statement was completed in January

2011 and a Record of Decision and Plan Approval were issued in March 2011.

Barrick Cortez Hills-Pipeline Complex – The Amendment to the Plan of Operations is under review by

the BLM. The Amendment includes a road reroute, tailings expansion and borrow pit authorization.

Barrick Horse Canyon Cortez Unified Exploration Plan - BLM issued the Decision Record and Plan of

Operations Amendment Approval in May 2011. Litigation is complete and BLM has authorized

additional drilling.

Barrick Ruby Hill Mine – BLM is currently reviewing an Amendment to the Plan of Operations that

includes a pit expansion and additional process facilities.

Montezuma Mines Red Canyon Exploration Plan of Operations – An EA has been issued to the public.

A decision and Finding of No Significant Impact (FONSI) are expected in July 2011.

3Coral Gold Resources Robertson Project - SRK Consulting is preparing an Amended Plan of

Operations and revised EA for review.

US Gold Corp Gold Pick Exploration Project - A Plan of Operations was submitted to the BLM in

February 2011, and BLM comments have been issued to the proponent.

US Gold Corp Tonkin Springs Closure - An Amended Plan of Operations was submitted to the BLM

and is currently under review.

TONOPAH FIELD OFFICE

Round Mountain Gold Corporation Mine Expansion, Round Mountain Mine - The expansion of the

open pit at Round Mountain and the development of a new mine pit at Gold Hill, 5 miles north of the

existing pit has begun. New leach pads will be constructed at both locations and the tailings

impoundment at Round Mountain will be expanded. An appeal and request for a stay was filed by

Great Basin Resource Watch and the Descendants of Big Smoky Valley. The appellants’ statement of

reasons for requesting the stay and BLM’s response to their comments have been filed with the Interior

Board of Land Appeals.
EA Completed for A.U. Mines, Inc., Manhattan Gulch Mine - The EA for a 553-acre alluvial placer

gold mine was completed in the first quarter of FY 2011. The Plan of Operations has been approved

and mining is expected to begin after the operator submits the reclamation bond and the Historic

Property Treatment Plan has been implemented.

EA is Being Prepared to Analyze Mineral Ridge Gold, LLC, Mineral Ridge Mine Exploration - An EA

is being prepared to analyze a 330-drill-hole exploration amendment to the Plan of Operations. It

should be available for a 30-day public review period in the third or fourth quarter, FY 2011. The mine

went into temporary shutdown mode in 2005 and is expected to come back on line in the fourth quarter

of FY 2011.

Plan of Operations for Exploration Submitted for the Rodinia Minerals, LLC, SP Drilling Project -

Rodinia submitted a 71-drill hole exploration Plan of Operations in the Clayton Valley area of

Esmeralda County. An EA is being prepared to analyze the environmental consequences of permitting

the drill exploration. The EA should be available for a 30-day public review and comment period in the

fourth quarter, FY 2011.

Proposal for Diatomite Mine: Global Silica, Inc., Monte Cristo Mine - The operator has proposed an

open pit diatomite mine with on-site screening, crushing, drying and milling facilities. Additional

information to complete the Plan of Operations has been received and the first draft of the EA is

expected in August 2011.

Proposal for Open Pit Mine: Nekekim Corporation, Nekekim Mine - The operator has proposed a 40-

acre open pit gold mine about 80 miles east of Tonopah. The gold recovery process is not identified at

4

this time. Additional information to complete the Plan of Operations was requested in the second and

third quarters of FY 2011.

Plans to Develop Gravel Pits: Nye County, Mineral Material Pits - The Nye County Road Department

has submitted Mine Plans to develop gravel pits, crushing and screening plants, and stockpile areas in

Amargosa Valley, Moore’s Station Wash and southern Railroad Valley. Development of an EA and 2

CX’s began in the second quarter of FY 2011.

Mine Plans Submitted: Tonopah Solar Energy, LLC, Mineral Material Pit - Tonopah Solar Energy,

LLC has submitted a Mine Plan for a 25 acre gravel pit, crushing and screening plant, and stockpile

area in Big Smoky Valley. The sand and gravel will be used to make concrete for the Crescent Dunes

Solar Power Plant facilities and power tower. A sale contract was sent to the operator in March, 2011.

The sale will be completed when the signed contract and funds have been submitted.

Amendment Review: Columbus SM, LLC, Inland Navigator Mine - An amendment to the Plan of

Operations is being reviewed. A follow-up letter requesting additional information to complete the

amendment has been sent to the operator. NEPA analysis of the amendment will begin as soon as the

amendment is considered complete.

Reclamation Plans Received for Arizona Pumice, Inc., Beatty Pumice Mine - Mine and Reclamation

Plans for the operation have been received. Cost recovery funds have been received and the NEPA

analysis has been completed. The application will be processed when the proponent identifies a sale

quantity.

Clayton Valley Sodium and Potassium Prospecting Permits - The permits have been on hold, pending

determination of the suitability to issue prospecting permits in Clayton Valley. A determination

regarding whether or not issuance of permits is appropriate; or if the available resource information is

sufficient to propose competitive leases of the individual parcels is in process.

June 2011 Nevada BLM Oil and Gas Lease Sale - The June 14, 2011 sale for Battle Mountain District

lease parcels was held as scheduled. Twenty-five parcels sold on the 14th for $662,962.00, no offers

have been received on the remaining 56 parcels.

December 2011 Nevada BLM Oil and Gas Lease Sale - An Environmental Assessment of the 155

parcels proposed for sale in the Tonopah area is being written. On June 6, 2011, a Native American
representative toured the proposed lease parcels; comments and concerns were provided in early July.

Notice of Staking to Drill an Oil Well – G & H Energy has submitted an application for an oil well 6

miles NNE of Nyala, NV. An on-site meeting is scheduled for June 15, 2011.

Oil and Gas Geophysical Survey - Major Oil International, LLC has submitted an application for a 120

point geophysical survey in Hot Creek Valley, 12 miles NNE of Warm Springs.

5

Hazardous Mine Working Closures – Approximately 8 mine shafts and adits are scheduled to be grated,

gated, or backfilled later this year in the Sylvania Canyon area of Esmeralda County.

1

Paulus, Stuart

---------- Forwarded message ---------- 

From: Grace Kuhn <grace@wildhorsepreservation.org> DOCUMENT #5

Date: Mon, Sep 30, 2013 at 11:14 AM 

Subject: Re: Follow-up 

To: 3Bars_Project@blm.gov

Hi Chad, 

This is the second follow-up email from a phone message that I left for you on Friday. As a reminder, I am 

writing in regards to the news release that was sent out on September 27, 2013 about the draft EIS for the 3 Bars 

Project. 

Does this area include any Herd Management Areas or Herd Areas? If so could you provide what specific 

'habitat enhancements and/or hazardous fuel reduction treatments' would be taking place in those HMA's/HA's?

[Wild Horses – Environmental Consequences – 5-1} 

Thank you for your time, and I would appreciate a prompt response. 

Sincerely, 

Grace Kuhn 

American Wild Horse Preservation Campaign 

grace@wildhorsepreservation.org

On Fri, Sep 27, 2013 at 10:56 AM, Grace Kuhn <grace@wildhorsepreservation.org> wrote: 

Hi Chad, 

I just left you a voice mail, but wanted to follow it up with an email. I am writing in regards to the news release 

that was sent out today about the draft EIS for the 3 Bars Project. 

Does this area include any Herd Management Areas or Herd Areas? If so could you provide what specific 

'habitat enhancements and/or hazardous fuel reduction treatments' would be taking place in those HMA's/HA's?

Thank you for your time, and I would appreciate a prompt response. 

Sincerely, 

Grace Kuhn 

American Wild Horse Preservation Campaign 

1

Paulus, Stuart

---------- Forwarded message ---------- 

From: Janet Brown <dana_brown@msn.com> DOCUMENT #6 (mass email)

Date: Tue, Nov 26, 2013 at 12:13 PM 

Subject: Comments on Mt. Lewis Field Office 3 Bars Project Draft EIS 

To: 3Bars_Project@blm.gov

Dear Mr. Lewis and Mr. Furtado, 

The Battle Mountain District's Mt. Lewis Field Office Draft Environmental Impact Statement (EIS) for the 3 

Bars Ecosystem and Landscape Restoration Project raises more questions than it answers. The current Draft EIS 

fails to provide specific actions for specific locations; the preferred actions are ambiguous and raise serious 

concerns. 

The BLM must clearly define each preferred action, identify the specific locations and outline the time frame 

(time of year, duration, etc.) for each action. 

The Draft EIS fails to adequately analyze the impact of the preferred or proposed actions on wild horses, 

wildlife and the wild horse Herd Areas in the targeted Project area. I urge the Lewis Field Office to clarify the 

proposed actions and to specifically address the following: 

1. [Vegetation Treatments Planning and Management – General – 6-1] Site-specific preferred actions must be 

clearly identified and analyzed in the EIS; this must include the timeframe for any actions (time of year for 

actions, duration of proposed actions, etc.). 

2. [Vegetation Treatments Planning and Management – Methods – Fencing – 6-2] The proposed fencing raises 

serious concerns. Even temporary fencing will have a negative impact on wild horse movement. Any fencing in 

or around any Herd Areas or Herd Management Areas must be thoroughly disclosed -- including the minimum 

and maximum duration for each fencing proposal. 

3. [Water Resources – Environmental Consequences - 6-3]Any "treatments" to water sources (including use of 

motorized machinery) must be clearly outlined -- specific locations, duration of each treatment, etc. must be 

disclosed and analyzed, and alternative actions with fewer impacts must be analyzed to ensure the most 

environmentally-friendly "treatment' is implemented. 

4. Proposed destruction of vegetation raises serious concerns as it is well documented that wild horses rely on 

pinion juniper trees for cover to gain protection from the elements. 

5. [Wild Horses – Environmental Consequences] Each proposed action must specifically be analyzed to 

determine if there is any temporary or permanent impact these actions may have on wild horses, their 

movement, their access to natural environmental components (cover, water, forage), etc. 

The public must be provided with future opportunities to comments on site-specific actions and other details as 

requested above. 

Sincerely, 
2

Janet Brown 

 95033 
October 27th, 2013

Comment due: November 12th, 2013 DOCUMENT #7

Mr. Chad Lewis

EIS Project Manager

Mount Lewis Field Office

Battle Mountain District

50 Bastian Road

Battle Mountain, Nevada 89820

Fax: (775) 635-4034

Email: 3Bars_Project@blm.gov

RE: 3 Bars Ecosystem and Landscape Restoration Project Environmental Impact

Statement, Eureka County, Nevada

Chad Lewis,

My name is Katrina De Boer, I am currently a Environmental Design student at the

University of Colorado and I am writing this public comment as an interested and concerned

citizen. It is clear that the 3 Bars Ecosystem is an important environment for several plant and

animal species, some of which are struggling to thrive as a whole, as well as several Native

American tribes. I am thankful to see that the Bureau of Land Management is recognizing the

damages done to the area from over usage and non native plants and are working to take steps to

restore the land and help the species within flourish. I am especially excited about the project in

terms of the potential benefits for the sage grouse, which is a big concern in Colorado. Knowing

that the sage grouse is up for evaluation to be placed on the endangered species list, it is

appealing to see that a large part of their ecosystem might be restored and this gives hope that

some of the issues with the sage grouse might benefit from the 3 Bars Ecosystem project in a

larger extent of its range.

The project itself is very well thought out. Personally I feel that Alternative A should be

the course of action as long as the short term disturbances do not become long term damages.

This area is a fragile environment that has already taken a lot from intrusion and different land

use. I understand the need for controlled burning due to over growth and suffering soil health.

The fires would be beneficial to the land in the long run but is it safe to say that the different

animal species such as the sage grouse within the area will be safe and undisturbed from the

fires? Seeing that Alternatives B, C, and D, all do not intend on any fire use they may be more

beneficial to the animals within the area. But with each alternative less and less of the area would

be restored. Knowing that there would be minimal effects to surrounding areas and to human

health from the fire I would be one hundred percent on board with Alternative A as long as it

was clearly understood how the animals would be secured from the burns. And if that is not

possible then Alternative B is a better option. After all part of the reasoning for the restoration is

improving the environment to help local species thrive.

In addition to the fire concern I am curious about the human activities allowed within the

area. [BLM – Vegetation Treatments Planning and Management – 7-1] It is stated in the EIS

that, “Human related activities allowed under the Federal Land Policy and Management Act,
such as livestock grazing and off highway vehicle use would continue to be allowed on the 3

Bars ecosystem.” Would these activities still be allowed during restoration? Would the vehicles

disrupt the paths for the fires? Would this then cause new paths to be formed, which would

potentially cause more damage to the area? And finally will the human activity disrupt hopes of

restoration after land management is implemented?

After understanding how the BLM plans to address these issues I think it will be very

clear which alternative is the right course of action for this project at this time.

Any questions or follow-up communication may be sent to my school e-mail

katrina.deboer@colorado.edu. I greatly appreciate your time in considering my comments and all

of your public service.

Sincerely,

Katrina DeBoer
Via email: 3Bars_Project@blm.gov DOCUMENT 8

November 29, 2013

Bureau of Land Management

Mount Lewis Field Office

(Battle Mountain District)

50 Bastian Road

Battle Mountain, NV 89820

Attention: Chad Lewis, 3-Bars Project

Document ID: DOI-BLM-NV-B010-2011-0200-EIS

Subject: 3-Bars Ecosystem and Landscape Restoration Project -- Draft EIS

Dear Mr. Lewis:

This e-letter is in response to the subject Draft Environmental Impact Statement (EIS) that

BLM staff prepared in collaboration with AECOM Environment, a contractor. For ease of

reference, below is the link to the Webpage where all documents relating to the Project --

including the Draft EIS -- can be accessed.

x https://www.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodNa

me=renderDefaultPlanOrProjectSite&projectId=27202&dctmId=0b0003e880146c

a5

The focus of my comments is how the proposed actions might affect -- for better or for

worse -- the wild horses that inhabit the land. The Herd Management Areas (HMAs)

involved include:

x Roberts Mountain,

x Whistler Mountain,

x Fish Creek,

x Rocky Hills and some

x currently zeroed-out Herd Areas (HAs).

The subject project would employ various strategies and techniques for restoring

degraded rangelands. However, the Draft EIS is equivocal. Its vagueness sows

uncertainty in the mind of the public reader. Disappointingly, its preparation did not draw

upon the many good ideas contributed through the prior scoping process, particularly with

regard to ground and habitat disturbance. The Draft EIS did not determine the impacts --

short-term, temporary, or long-term -- that the proposed landscape-restoration treatments

will have on the wild horses, their free-roaming movement, and their access to water,

forage, cover, seasonal migration routes, and other resources. Consequently, the Draft

EIS did not satisfactorily analyze the potential impacts to the resident wild horses.
I urge BLM to revise the EIS to include specific information whose meaning and intent is

clear, and to perform a comprehensive analysis of the impacts of the proposed actions on

the wild horses.

x [BLM – Vegetation Treatments Planning and Management – Treatments – 8-1]

Please define each preferred action, identify the exact location where it is to be

carried out, and provide a time-line as to when it will commence (month, year) and

how long it should take (duration). [BLM – Wild Horses – Environmental

Consequences – 8-2] The project as currently described is likely to displace the

wild horses during landscape-treatment periods. The horses will be further

displaced by being fenced out for prolonged periods during landscape-recovery.

The HMAs' configurations will shift, thereby disrupting the horses' use of land that

is dedicated for their principal use. How will you mitigate these adverse effects?

x [BLM – Vegetation Treatments Planning and Management – Methods – Fencing –

8-3] Please disclose where temporary fences will be installed within or around HAs

and HMAs. Please provide a time-line as to the exclosures' commencement and

duration. Also, how will you determine which fences are necessary? What are

the criteria?

x [BLM – Vegetation Treatments Planning and Management – Methods –

Mechanical Treatments – 8-4] Please reconsider whether destroying vegetation is

advisable. Holistic Grazing Management consultant Alan Savory found that

mechanical treatments, such as chaining, actually made matters worse. Further,

wild horses depend on pinion-juniper cover.

x [BLM – Vegetation Treatments Planning and Management – Methods –

Mechanical Treatments – 8-5] Please reconsider whether using heavy machinery,

such as bulldozers, to stabilize the area's streams is advisable. Won't such

construction equipment create landscape-disturbances? Bulldozers are also

noisy, resulting in yet more disturbances that will adversely impact the wild

horses. Alternative treatments with softer impacts should be considered. The

most environmentally-gentle methods should be selected.

x [BLM – Wild Horses – Environmental Consequences – 8-6]Please disclose how

BLM will ensure the continuation of viable wild-horse herds in spite of the project.

The viability plan must be predicated on an analysis of each affected herd's ...

x history,

x characteristics,

x local water sources,

x seasonal pastures,

x migration routes,

x roundup-and-removal record,

x fertility-control record,
x genetic-testing record, and

x genetic-test results and recommendations.

Following amendment of the Draft EIS, there should be another public-comment period

wherein BLM receives feedback on the modifications that have been made. Thank you.

Sincerely,

Marybeth Devlin

6880 SW 27th ST

Miami, FL 33155

marybethdevlin@bellsouth.net

305-665-1727

1

November 29, 2013

U.S. Department of Intrior

Bureau of Land Management

Mount Lewis Field Office

Battle Mountain District

50 Bastian Road

Battle Mountain, NV 89820

Attn: Chad Lewis

3bars_project@blm.gov

Re: Comments on Mt. Lewis Field Office 3 Bars Project Draft EIS

As a life-long visitor to the state of Nevada, which includes visiting the mid-Nevada 

Eureka County area for recreational, photographic, wildlife observation and scientific 

research objectives, I oppose the BLM’s 3 Bars Project as it now written and provided to 

the public for review – i.e. Draft EIS. My opposition is because of the large size of the 

project in land quantity, the duration of the project, the scientific vagueness motivating 

this proposal and the potentially substantial impacts the proposed treatments will have 

on the sage-grouse and on numerous other important sensitive resources and due to 

the lack of a clear purpose and need for any large scale vegetation treatment in the 3 

Bar project area, the high potential for the proposed action to have significant, 

irreversible impacts on the environment.

It is well known that these projects represent a continuing pattern of misguided resource 

management, as range managers attempt to create more range from forested lands and 

fire management plans seek to generate money for the district under the aspics of fuel 

reduction projects. FLPMA requires BLM to “take any action necessary to prevent

unnecessary or undue degradation of the lands” and “minimize adverse impacts on the 

natural, environmental, scientific, cultural, and other resources and values (including 

fish and wildlife habitat) of the public lands involved.” 43 U.S.C. §§ 1732(b), 

1732(d)(2)(a). BLM has failed to properly identify and analyze impacts to the resources. 

As detailed below, the BLM’s failure in this regard violates the most basic requirements 

of NEPA and in addition undermines the BLM’s ability to ensure that the proposal does 

not cause unnecessary and undue degradation of public lands. 
2

Nature has been taking care of this project area land and flora and fauna for thousands

of years without the “help” of the BLM – and yet BLM is proposing many unnatural 

treatments for this land and thus the entire ecosystem will be intimately affected. It is 

our job as owners and stewards of this land to make only the best and most 

environmentally friendly decisions for the land for today and for the future generations. 

Desired ecological conditions depend on management objectives, potential uses for the 

site, and ecological characteristics of the site, such as soil profiles and ecological site 

type. Managers need to identify conditions that are ecologically feasible on a given 

landscape and that will satisfy management objectives over the long term. Then, and 

not until then can they can determine if a treatment or series of treatments could help to 

achieve those results. The DEIS does not specify exactly what treatments will be used 

on which portions of the project and when these treatments will be used and to what 

extent these treatments will be used – thus the BLM is providing itself with an openended capability to take these actions outside of the public’s knowledge. Setting goals 

and objectives requires knowledge and participation by stakeholders beyond a onetime, one-size-fits-all EA proposal. The public may have differing or even conflicting 

ideas about the values that should be emphasized in juniper-dominated rangelands or 

the appropriate ecological condition of those lands and the public has a right to know 

the specifics of the BLM’s proposal. Natural disturbances and changes in environmental 

conditions also may affect the site, and management plans may need to be adjusted as 

a result and again, I state that the public has a right to know the ongoing and changing 

specifics – one size does not fit all. Preparation of a full environmental impact statement 

that analyzes potential water, endangered or critical species, soil and cultural impacts, 

including potential impacts from livestock grazing, mining and other multiple uses is 

required; without which, this BLM has ignored its legal requirement to take a hard look 

at these highly relevant impacts.

Livestock – Hard Look

One example of BLM’s omission of a major cause of public land destruction that is not 

sufficiently proposed is the removal/reduction of private livestock on public land. The 

DEIS professes to restore lands to their natural condition by introducing fire and 

mechanical manipulation and chemical application to the ecosystem, but the proposal 

does not address the fact that livestock grazing is a major and continuing cause of 

altered fire cycles, understory loss, soil compaction, pinyon-juniper expansion, riparian 

destruction or that burned and grazed juniper sites on BLM lands are being invaded by 

non-native grasses.
3

Riparian Destruction by Privately Owned Livestock on BLM-Managed Public Land (above photo)

Livestock grazing has at least the following major negative ecological impacts:

 Significantly Alters Plant and Animal Communities

 Decrease Biodiversity

 Leads to Elimination of Native Predators

 Introduction of Invasive Plants and Diseases

 Soil Compaction and Accelerated Erosion

 Hydrologic Disruption and Contamination

 Habitat Destruction

Another very important question that is not addressed within the EA but is required in 

order to satisfy the NEPA requirement to take a hard look at this very relevant issue and 

incorporate it within the DEIS alternative: Will all livestock grazing be discontinued for 

two or more years after fire and other treatments?

Removal or reduction of livestock grazing in the treated project area would:

1. Allow natural recovery of plants that will recover on their own to occur (from regrowth 

or sprouting), without the added pressure and stress of defoliation from livestock 

grazing. 
2. Allow the germination and initial growth of seeded plants to occur without ground 

disturbance from livestock hoof action and trailing. 

3. Allow seeded plants to establish for at least two years so they are adequately rooted 

in the soil, to avoid them from being physically pulled out of the soil from livestock 

grazing. 

4. Allow seeded plants to grow into mature plants with sufficient leaf growth for 

photosynthesis and the ability to produce seed before they are grazed by livestock. 

5. Allow riparian areas and wetlands, which are highly preferred grazing areas, to rest 

from livestock grazing pressure to allow for full recovery of riparian plant growth and 

vigor to ensure the proper functioning of riparian/wetland sites. 

6. Allow native plants to recover from mow/chop/burn treatments through regrowth and 

sprouting to provide food, cover, and shelter to wildlife - especially in sage grouse 

habitats. 

The Battle Mountain District's Mt. Lewis Field Office Draft Environmental Impact 

Statement (EIS) for the 3 Bars Ecosystem and Landscape Restoration Project raises 

more questions than it answers. The current Draft EIS fails to provide specific actions 

for specific locations; the preferred actions are ambiguous and raise serious concerns. 

The BLM must clearly define each preferred action, identify the specific locations and 

outline the time frame (time of year, duration, etc.) for each action. The Draft EIS fails to 

adequately analyze the impact of the preferred or proposed actions on wild horses, 

wildlife and the wild horse Herd Areas in the targeted Project area. I urge the Lewis 

Field Office to clarify the proposed actions and to specifically address the following: 

1. Site-specific preferred actions must be clearly identified and analyzed in the EIS; this 

must include the timeframe for any actions (time of year for actions, duration of 

proposed actions, etc.). 

2. The proposed fencing raises serious concerns. Even temporary fencing will have a 

negative impact on wild horse movement. Any fencing in or around any Herd Areas or 

Herd Management Areas must be thoroughly disclosed -- including the minimum and 

maximum duration for each fencing proposal. 

3. Any "treatments" to water sources (including use of motorized machinery) must be 

clearly outlined -- specific locations, duration of each treatment, etc. must be disclosed 

and analyzed, and alternative actions with fewer impacts must be analyzed to ensure 

the most environmentally-friendly "treatment' is implemented. 

4. Proposed destruction of vegetation raises serious concerns as it is well documented 

that wild horses rely on pinion juniper trees for cover to gain protection from the 

elements. 

5. Each proposed action must specifically be analyzed to determine if there is any 

temporary or permanent impact these actions may have on wild horses, their 

movement, their access to natural environmental components (cover, water, forage), 

etc. 

4 
5

The public must be provided with future opportunities to comments on site-specific 

actions and other details as requested above. 

BLM’s Idea of Land Health Treatment is Not My Idea of Land Health Treatment (above – BLM photo)

I appreciate the opportunity to participate in the planning decisions on our public lands 

and wish you to leave you with this quote by Ralph Waldo Emerson, “What you do 

speaks so loud that I cannot hear what you say”.

Sincerely,

Ms. Kathleen Gregg

Environmental Researcher

therealgrandmakathy@yahoo.com

Cc: Amy Lueders, Nevada State Director

 alueders@blm.gov

Receipt and Response Requested

1

---------- Forwarded message ---------- 

From: Eileen Hennessy <eileen.hennessy@yahoo.com> 

Date: Fri, Nov 29, 2013 at 8:37 AM 

Subject: Comments on Mt. Lewis Field Office 3 Bars Project Draft EIS 

To: 3Bars_Project@blm.gov

Dear Mr. Lewis and Mr. Furtado, 

As a wild horse and burro advocate and a taxpaying American citizen who has a stake in the public lands 

managed by the Bureau of Land Management (BLM), I want to go on record as voicing my strong opposition to 

the BLM’s proposed action to wreak havoc on a 750,000-acre land area, including federally designated wild 

horse habitats, by proposing the so-called “3-Bars Ecosystem and Landscape Restoration Project, an 

inappropriately named plan to “improve” this area by means of highly destructive slash and burn techniques that 

would cause more harm than good to these rangelands. 

The Battle Mountain District BLM manages an area in Nevada known as "the heart of wild horse country 

which includes 28 Herd Management Areas (HMAs) extending more than 3 million acres. The Herd 

Management Areas (HMAs) threatened by this misguided dangerous and proposal include Roberts Mountain, 

Whistler Mountain, Fish Creek, Rocky Hills and zeroed-out Herd Areas (HAs). Such severe disturbances the 

agency proposes to let loose on these rangelands would most definitely inflict negative impacts on the mustangs 

and other wildlife living in these areas and the resultant wreckage cannot and must not be ignored. The BLM 

must clarify its intentions in explicit detail defining and outlining each and every preferred action before even 

suggesting such a potentially devastating proposal. 

The Draft EIS for the 3 Bars Ecosystem and Landscape Restoration Project is fraught with obscure and illdefined proposed actions that lack salient details and specifics such as locations, time frames among other 

details. Such logistics, as well as a serious and thorough analysis of the negative impacts such proposed actions 

would have on wild horses and all other wildlife in these areas, are absolutely vital and must be included in the 

revised Draft EIS for each and every separate action proposed if, when and where it were to occur. 

[Wild Horses – Environmental Consequences – 10-1] There would surely be long-term impacts on mustangs 

and other wildlife from the proposed actions in the Project’s targeted areas due to BLM removing protective 

cover, or poor site recovery. The long-term impacts of such actions, which would result in loss of vital 

protective coverage, necessary forage, habitat access and inadequate range restoration, have not been seriously 

considered and must be thoroughly examined in the revised EIS.

As wild horse advocates have come to understand the mindset behind the BLM’s Wild Horse Harvesting 

Machine, it comes as no surprise that this rogue agency is specifically targeting and planning the destruction 

(“treatment” and removal) of vegetation required for wild horse foraging as well as those that provide mustangs 

shelter from the elements, including sagebrush and pinion-juniper trees respectively. 

An increase of cheatgrass and other weeds would also result. 

The “Preferred Alternative” also proposes other euphemistically-named “treatments” in these legally designated 

wild horse habitats including so-called “temporary” fencing which would greatly and adversely restrict wild 

horses from their rightful range in their lawfully designated HMAs for extended periods of time. (No doubt, as 
2

wild horse advocates have come to expect, these “temporary” barriers would eventually become PERMANENT 

(as they seem to have done in the PMWHR) allowing the BLM to little by little reduce (chip away) the 

HAs/HMAs to a fraction of their size thus spurring the BLM to declare that they have little choice but to zero 

out the remainder of the already stolen acres of wild horse habitat due to lack of space for the remainder of 

“overpopulated” wild horses who are left crammed into the shamefully reduced habitat. This shameful ploy has 

been used time and time again by the BLM -- first chip away at the wild horses legally designated area, then 

build a few fences until it appears that the scant habitat remaining could not possibly sustain the “massive” 

amount of wild horses left after the agency has dissected their habitat with their intrusive fencing. Thus one 

more wild horse HA/HMA is zeroed out, in direct response to a man-made problem of crowding wild horses 

into ever shrinking habitats, a scenario which the agency itself created to justify mustang removals in order to 

fulfill its land grab agendas. 

[Vegetation Treatments Planning and Management – Methods – Fencing – 10-2] Fencing of any kind -- 

permanent or “temporary” -- severely impairs wild horse movement therefore, any such proposed action to erect 

TEMPORARY fencing requires in-depth analysis examining the negative impacts of each and every fencing 

proposal including disclosure of the projected duration of such actions. It goes without saying that any such 

fencing projects must not be proposed to somehow justify wild horse roundups and permanent removals in a 

quest to ultimately zero out more wild horses HAs/HMAs. 

The damage the agency would wreak with this bulldozing scheme in no way takes into account the utter 

destruction such demolition tactics would have on not only the wild horses but all the existing wildlife living in 

these areas as well as the negative impacts such a toll of annihilation would surely have on the environment, 

including vegetation and water sources. 

The misguided methods of the “Preferred Action” would be devastating to say the least, not only to wild horses 

but other wildlife that exists in these areas. To unwisely propose to implement such range “improvements” as 

“temporary” intrusive fencing, bulldozing and “stabilizing” small streams using heavy equipment in waterways, 

chaining, shredding, tilling, mowing, roller chopping, tree shearing, intensive livestock grazing ("targeted" 

grazing in BLM speak), chopping, burning, hand cutting and destroying myriad vegetation in wild horse habitat, 

is a recipe for disaster and all under the guise of “improving” the landscape is ridiculous even for the BLM as it 

contradicts the agency’s mantra of working toward maintaining “thriving ecological balance”. [Vegetation 

Treatments Planning and Management – General – 10-3] Exactly how would this proposal of mass destruction 

lead to “improvement” of the range? Seriously? 

This proposed onslaught against the land and its wildlife is nothing more than a recipe for disaster. Do the 

agency ever tire of inventing new and more devious ways of “managing” our federally protected wild horses 

into extinction? Does your mandate to preserve and protect these “living symbols of the historic and pioneer 

spirit of the American West” who “contribute to the diversity of life forms within the nation and enrich the lives 

of the American people” and are “fast disappearing from the American scene” according to the Wild Free 

Roaming Horse and Burro Act of 1971, mean anything to you? 

I realize the agency has absolutely no experience in managing wild horses and burros, as they themselves have 

often stated, but I would think a government agency called “Bureau of LAND Management” would be able to 

envision the catastrophic effects of this proposal would unleash on the targeted land areas if this insincerely and 

ironically named “3 Bars Ecosystem and Landscape Restoration Project” were to proceed. The BLM’s gross 

inadequacy at land as well as wildlife (YES, wild horses are, in fact, NATIVE wildlife - not a feral invasive 

species) management is an embarrassment and I do not appreciate my tax dollars being squandered on yet 

another of the agency’s self-serving schemes to eradicate OUR wild horses/burros and other wildlife from OUR 

public lands! 

[Vegetation Treatments Planning and Management – General – 10-4] The current Draft EIS fails to analyze the 
3

long-term impacts of these proposed actions which would result in loss of vital protective coverage, necessary 

forage, habitat access and inadequate range restoration, important details that must be seriously addressed and 

thoroughly examined in the revised EIS. 

The 3 Bars Project Draft EIS must include the above listed revisions and I strongly urge the BLM to work 

toward preserving the rangelands by seriously examining less intrusive and destructive methods of improving 

the targeted areas that will not endanger the existing ecosystem’s wildlife or the surrounding environment 

which must be left intact and unmolested in order for them to survive. 

As a taxpaying member of the public, I demand to be provided with opportunities to comment on any and all 

future proposed actions that would impact our nation’s wild horses/burros and other wildlife as well as their 

ranglelands in the targeted area including specific details on proposals for each separate action such as exact site 

locations, detailed time frames including time of year and duration of such proposed actions. Needless to say a 

thorough analysis of the negative impacts on the wild horses, other wildlife and the environment must be 

included in the revised Draft EIS. 

Thank you for your serious consideration of my comments on this most urgent issue. 

Sincerely, 

Eileen Hennessy 

 02176 

APPENDIX E 

ARMPA-MD FIRE 23 DOCUMENTATION 
This page left blank intentionally.
ARMPA-MD FIRE 23 DOCUMENTATION 

3 Bars Project Final EIS E-1 October 2016

APPENDIX E 

ARMPA-MD FIRE 23 DOCUMENTATION 

Within the 3 Bars Ecosystem and Landscape Restoration Project, prescribed fire treatments are analyzed under 

Alternative A. Not all prescribed fire activities will be in GRSG habitat. However, for prescribed fire (broadcast 

and pile burning) that does occur in GRSG habitat, as stated in MD FIRE 23 within the 2015 ARMPA, the NEPA 

analysis for the Burn Plan will address: 

1) Why alternate techniques were not selected as a viable option: 

Prescribed fire may be used to control vegetation; enhance the growth, reproduction, or vigor of certain plant 

species; manage fuel loads; and maintain vegetation community types that meet multiple-use management 

objectives. Prescribed fire treatments include broadcast burning and the burning of hand stacked piles. Broadcast 

burning treatments would occur in areas where slope is the limiting factor for mechanical treatments. Prescribed 

fire would reduce hazardous fuels loads on a project site and assist in preparation of the site for seeding. 

While pinyon-juniper can be controlled without the use of prescribed fire, non-fire methods generally do not 

provide long-term control if pinyon-juniper remains nearby. Fire treatments, including thinning, piling, and 

burning, typically can remove more trees per unit cost than shredding and mulching, while leaving less woody 

debris on the ground that could serve as fuel for a wildfire (Gottfried and Overby 2011). Studies suggest that dense 

stands of Phase II and III pinyon-juniper, where most BLM fire treatments would occur, cannot be managed 

effectively by fire alone, but must also be treated mechanically to increase herbaceous vegetation that fuels the fire 

(Ansley and Rasmussen 2005, Tausch and Hood 2007, Tausch et al. 2009). Thus, the BLM would use manual and 

mechanical methods, in addition to fire, for those units with Phase II and III stands that are proposed for treatment 

with fire. 

When used in combination with the manual and mechanical treatments, pile burning may be an appropriate action 

to remove fuels from the site. Piles would be constructed using the debris and dead material left on site after the 

implementation of a mechanical treatment. Piles would be burned based on environmental conditions and in 

coordination with a developed burn plan. 

2) How GRSG goals and objectives will be met by its use: 

Prescribed fire (broadcast and pile burning) will meet both GRSG habitat objectives and management objectives. 

For habitat objectives, prescribed fire can improve general landscape level conditions by 

 Reducing tree canopy cover in order to increase the potential for sagebrush and perennial species to establish; 

 Increasing sagebrush extent and connectivity; 

 Reduce GRSG proximity to tall structures. 

Prescribed fire meets ARMPA Objective FIRE 5, which is to “Protect and enhance PHMAs and GHMAs and areas 

of connectivity that support GRSG populations, including large contiguous blocks of sagebrush, through fuels 

management and incorporation of FIAT assessment”.

3) How the COT report objectives will be addressed and met: 

Landscape level Objectives: Prescribed fire can reduce conifer encroachment and increase sagebrush extent, 

which will improve nesting areas, cover and food availability. 
ARMPA-MD FIRE 23 DOCUMENTATION

3 Bars Project Final EIS E-2 October 2016

Lek Objectives: Security can also improve if conifer cover is reduced to less than 3% within 0.6 miles of a lek. 

Nesting Objectives: Prescribed fire, in conjunction with other treatments (ie-seeding), will increase sagebrush and 

native perennial cover to improve nesting cover. Removing conifers within potential nesting habitat will also 

increase security by reducing GRSG proximity to tall structures. 

Brood-Rearing/Summer Objectives: Prescribed fire, in conjunction with other treatments (ie-seeding), will 

increase sagebrush and native perennial cover to improve cover and food availability. 

4) A risk assessment to address how potential threats to GRSG habitat will be minimized: 

Potential threats to GRSG habitat will be minimized by following Standard Operating procedures as stated in 

Appendix C: 

Noxious Weeds: Minimize risk when known noxious weed infestations are present in treatment units. The BLM is 

required to develop a noxious weed risk assessment when it is determined that an action may introduce or spread 

noxious weeds or when known noxious weed habitat exists (USDOI BLM 1992). If the risk is moderate or high, 

the BLM may modify the project to reduce the likelihood of weeds infesting the site and to identify control 

measures to be implemented if weeds do infest the site. 

Prescribed fire treatments would be most successful on sites where perennial grasses are likely to recover and 

establish after treatment, and least successful on sites where cheatgrass is present. 

Greater Sage-Grouse: Prescribed fire activities will adhere to seasonal restrictions to minimize risk to GRSG 

during seasonal life-cycle periods. 

GRSG Habitat: Prescribed fire activities will be conducted to minimize risk of reducing sagebrush cover. The 

BLM plans to conduct most burns on Phase II or Phase III sites to initiate stand replacement and to avoid impacts 

to shrubby vegetation including sagebrush although these sites generally have a depleted understory. Pile burns 

within sagebrush ecosystems (Phase I) will be conducted during the fall, winter, and spring to take advantage of 

conditions of soil moisture, snow, precipitation, and vegetation green-up to reduce fire impacts to non-target 

vegetation. 

Post-burn monitoring and Adaptive Management requirements: Based on post-burn monitoring for noxious 

weeds and habitat and resource objectives, some post-burn restoration and management may be needed. After 

broadcast burns, the BLM may need to reseed burned areas with forbs, grasses, and shrubs. Based on past 

reseeding treatments conducted for several wildfire burns in the District, seeding and planting of native and nonnative vegetation may have limited success, especially during drought years, and native release of seeds may be the 

primary mechanism for site revegetation. However, in areas with sufficient moisture, seedings have been 

successful and have resulted in an abundance and diversity of forbs, grasses, and shrubs. 

Contingency Resources and Patrol Requirements: Prior to prescribed fire, contingency resources and patrol 

requirements will be outlined within the prescribed fire plan, per BLM policy and Interagency Prescribed Fire 

Planning and Implementation Procedures Guide. Contingency resources will be addressed in Element 17: 

Contingency Plan and Element 18: Wildfire Declaration. Patrol requirements will be addressed in Element 21: 

Post-burn Activities