U.S. Department of the Interior 

Bureau of Land Management

Environmental Impact Statement 

BLM-NV-BM/ES/16-07+1793

3 Bars Ecosystem and Landscape 

Restoration Project

Final Environmental Impact Statement

Volume 1: Abstract, Executive Summary, and Chapters 

1 through 3

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 
Final Environmental Impact Statement

3 Bars Ecosystem and Landscape Restoration Project

Volume 1: 

Abstract 

Executive 

Summary

Chapters 

1 through 3

DOI

BLM

October

2016
FINAL 

3 BARS ECOSYSTEM AND LANDSCAPE RESTORATION 

PROJECT ENVIRONMENTAL IMPACT STATEMENT

() DRAFT ( X ) FINAL 

LEAD AGENCY: U.S. Department of the Interior 

Bureau of Land Management 

Mount Lewis Field Office 

PROJECT LOCATION: Eureka County, Nevada 

FOR ADDITIONAL INFORMATION: Mr. Todd Erdody 

EIS Project Manager 

Mount Lewis Field Office 

Battle Mountain District 

50 Bastian Road 

Battle Mountain, Nevada 89820 

Email: 3Bars_Project@blm.gov 

ABSTRACT 

This Environmental Impact Statement (EIS) analyzes the potential direct, indirect, and cumulative impacts associated 

with the Bureau of Land Management’s (BLM’s) proposed land restoration treatments on the approximately 749,810-

acre 3 Bars ecosystem. The BLM evaluated three action alternatives and the No Action Alternative. Alternative A is the 

BLM’s Preferred Alternative. Under this alternative, the BLM would treat about 127,000 acres during the life of the 

project using manual and mechanical methods, fire (both prescribed and wildland fire for resource benefit), and 

biological control (use of livestock and classic biological control [nematodes, fungi, mites, and insects], primarily to 

control noxious weeds and other invasive non-native vegetation). Alternative B differs from Alternative A in that the 

BLM would not use prescribed fire and wildland fire for resource benefit, and the BLM would treat only about 63,500 

acres. Under Alternative C, the BLM would only treat vegetation within treatment areas using manual methods and 

classical biological control; use of livestock for biological control would not be allowed. The BLM would also not be 

able to use mechanical methods or fire, and would treat only about 31,750 acres. The focus of treatments under all three 

action alternatives would be to restore riparian, aspen, and sagebrush habitats; slow singleleaf pinyon pine and Utah 

juniper encroachment into and infilling within these habitats; and thin historic pinyon-juniper communities to promote 

woodland health. Under Alternative D, the No Action Alternative, no new treatments would be authorized as a result of 

this project. However, the BLM would continue to conduct treatments approved under earlier NEPA authorizations. 

RESPONSIBLE OFFICIAL FOR EIS: Jon D. Sherve 

Field Manager 

Mount Lewis Field Office 

Bureau of Land Management 
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EXECUTIVE SUMMARY 
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EXECUTIVE SUMMARY 

EXECUTIVE SUMMARY 

Introduction 

The 3 Bars ecosystem is approximately 749,810 acres in central Eureka County, northwest of Eureka, Nevada. The 

ecosystem is administered by the U.S. Department of the Interior (USDOI), Bureau of Land Management (BLM), 

Mount Lewis Field Office. It is a shrub-steppe ecosystem with important resource values, ranging from habitat for a 

diversity of plants and animals, to providing traditional use areas for several Native American tribes. The 3 Bars 

1

ecosystem provides important habitat for Greater sage-grouse , mule deer, Lahontan cutthroat trout, and numerous 

other fish and wildlife species, including migratory birds, and for wild horses. The 3 Bars ecosystem is also an 

important recreation resource for Nevada residents and visitors. 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, 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. 

The 3 Bars ecosystem provides habitat for Greater sage-grouse, which has been declared a special status species in the 

September 2015 BLM Nevada and Northeastern California Greater Sage-Grouse Approved Resource Management 

Plan Amendment and Record of Decision (ARMPA). To ensure that treatments benefit Greater sage-grouse, 

sagebrush restoration treatments would adhere to ARMPA Required Design Features (RDFs). These include avoiding 

treatments near Greater sage-grouse leks 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 will ensure proper 

livestock management is in place prior to treatments when necessary in order to meet project goals and objectives, 

which would benefit Greater sage-grouse habitat. 

In order to ensure long-term success, treatments would not be conducted in areas with moderate to severe forage 

utilization until mitigation measures associated with livestock management, as discussed in Section 3.18.4, are 

implemented through agreements or decisions subsequent to the 3 Bars Project Record of Decision to ensure 

proper livestock management. The BLM would work with permittees on a permit by permit basis to address any 

changes in livestock management prior to treatment implementation. In all instances, proper changes in livestock 

management through agreements or decisions would be finalized prior to treatment implementation. 

Project funding would come from funds allocated by Congress to the BLM for resource management. 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 account funds associated with various 

development activities within or near the 3 Bars Project area. 

 

1

 Common and scientific names of plant and animals given in this Environmental Impact Statement are provided in 

Appendix A. 

3 Bars Project Final EIS ES-1 October 2016
EXECUTIVE SUMMARY

Proposed Action 

The BLM proposes to treat vegetation using manual, mechanical, and biological control methods, and fire (both 

prescribed and wildland 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 over the life of the project to 

restore and manage the 3 Bars ecosystem. Treatment projects were identified through an iterative process involving 

the BLM and other federal and state cooperating agencies. Treatments would focus on four priority vegetation 

management concerns—riparian, quaking aspen (aspen), singleleaf pinyon pine and Utah juniper (pinyon-juniper), 

and sagebrush, with an emphasis on improving Greater sage-grouse habitat. 

Purposes for the Project 

Using the information from the Assessment of Existing and Current Conditions for the Proposed 3 Bars Ecosystem 

and Landscape Restoration Project Environmental Impact Statement prepared for the project, and field studies, the 

BLM identified several purposes for the 3 Bars Project. Purposes are consistent with the 1986 Shoshone-Eureka 

Resource Management Plan Record of Decision as amended, and the 2015 ARMPA, which guides land 

management activities in the 3 Bars ecosystem. Purposes for the 3 Bars Project include: 

 Improve woodland, rangeland, and riparian health, productivity, and functionality. 

 Increase stream flows and restore channel morphology in degraded streams. 

 Improve stream habitat for fish and wildlife by implementing physical treatments that include installing 

large woody debris, rock clusters, and check dams, and using temporary fencing to exclude livestock and 

wild horses. 

 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 and other 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 areas. 

 Protect life, property, and community infrastructure, and protect fish and wildlife habitat from devastating 

wildfire effects. 

3 Bars Project Final EIS ES-2 October 2016
EXECUTIVE SUMMARY 

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. 

 Need for the Project 

The 3 Bars ecosystem has long been recognized as an area with numerous resource values and uses. Some of these 

resources and uses include mineral exploration and development, livestock grazing, woodland product harvest, 

recreation, wilderness activities, and habitat for wild horses, fish, and wildlife, including sensitive and game fish 

and wildlife species such as Lahontan cutthroat trout, Greater sage-grouse, mule deer, and pronghorn antelope. 

Factors affecting land uses and health in the ecosystem include the effects of past grazing practices, changes to the 

natural fire regime, establishment and spread of noxious weeds and other invasive non-native vegetation, 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. Based on these changes, the BLM 

has determined that there is a need to improve rangeland health. 

Scope of Analysis and Decisions to be Made 

The National Environmental Policy Act (NEPA) mandates that every federal agency prepare a detailed statement 

of the effects, or Environmental Impact Statement (EIS), of “major federal actions significantly affecting the 

quality of the human environment” (42 United States Code § 4321 et sequentia; USDOI BLM 2008a). An EIS is 

intended to provide decision-makers and the public with a complete and objective evaluation of significant 

environmental impacts, beneficial and adverse, resulting from the proposed action and several reasonable 

alternatives. Given the magnitude of treatments and the resulting potential for significant cumulative effects from 

the 3 Bars Project, the BLM has determined that an EIS is required to evaluate impacts from the 3 Bars Project. 

This 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. 

3 Bars Project Final EIS ES-3 October 2016
EXECUTIVE SUMMARY

Alternative Proposals 

Four alternatives are evaluated in this 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. 

Alternative A — All Treatment Methods Alternative (Preferred Alternative) 

Alternative A is the BLM’s Preferred Alternative. The BLM proposes to treat about 127,000 acres during the life 

of the project, using manual and mechanical methods, fire (both prescribed and wildland fire for resource benefit), 

and biological control (primarily to control noxious weeds and other invasive non-native vegetation using livestock 

and classic biological control [use of nematodes, fungi, mites, and insects]). Treatments would focus on protecting 

landscapes and treatment projects would usually address multiple resource issues. 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 channels, headcuts, knickpoints, developments, and diversions) and/or 

appropriate plant species composition are compromised. 

 Aspen—treatments in aspen habitat would focus on improving the health of aspen stands by stimulating 

aspen stand suckering and sucker survival. 

 Pinyon-juniper—treatments in pinyon-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. 

 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. 

About 95 percent of acres treated would be to manage pinyon-juniper and improve sagebrush habitat. Humanrelated activities allowed under the Federal Land Policy and Management Act, such as livestock grazing and offhighway vehicle use would continue to be allowed. The BLM would follow planning processes, apply Standard 

Operating Procedures (SOPs), and implement appropriate mitigation, monitoring and maintenance treatments to 

ensure that vegetation treatments are successful (see Appendix C). 

Alternative B — No Fire Use Alternative 

Alternative B is similar to Alternative A in that the BLM would focus treatments on the four priority management 

concerns—riparian, aspen, pinyon-juniper, and sagebrush—and would focus on the treatment areas identified 

under Alternative A. Alternative B differs from Alternative A in that the BLM would not use prescribed fire and 

wildland fire for resource benefit. Under Alternative B, the BLM would treat vegetation using manual, mechanical, 

and biological control (livestock and classical biological control) methods. This alternative was developed to 

3 Bars Project Final EIS ES-4 October 2016
EXECUTIVE SUMMARY 

address public concerns raised during scoping about the impacts to the landscape from fire, including the potential 

for erosion and spread of noxious weeds and other invasive non-native vegetation from fire treatments. 

The BLM would conduct projects identified under Alternative A, but proposes to treat only about half as many 

acres (63,500 acres) as areas identified for treatment using fire would not be treated and because costs for manual 

and mechanical treatments are more expensive than costs for fire treatments. The planning process, treatment goals 

and objectives, funding mechanisms, and use of SOPs would be similar to those under Alternative A. 

Alternative C — Minimal Land Disturbance Alternative 

Alternative C is similar to Alternative A in that the BLM would focus treatments on the four priority management 

concerns—riparian, aspen, pinyon-juniper, and sagebrush—and would focus on the treatment areas identified 

under Alternative A. Alternative C differs from Alternative A in that the BLM would only treat vegetation within 

treatment areas using manual methods and classical biological control (use of nematodes, fungi, and insects); use 

of livestock for biological control would not be allowed. The BLM also would not be able to 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. Under this alternative, the 

BLM would only use manual methods to treat vegetation, as these methods would cause little land disturbance. 

The BLM would conduct projects identified under Alternative A, but proposes to treat only about one-fourth as 

many acres (31,750 acres) and treatments would generally be small in acreage. The planning process, treatment 

goals and objectives, funding mechanisms, and use of SOPs under this alternative would be similar to those under 

Alternative A. 

Alternative D — Continue Current Management (No Action Alternative) 

Under the No Action Alternative, no new treatments would be authorized as a result of this project. However, the 

BLM would continue to conduct treatments approved under earlier NEPA authorizations. The BLM would have to 

conduct the appropriate level of NEPA analysis for future projects before they could be approved for 

implementation. Should this alternative be chosen by the decision-maker, and if the BLM decides to conduct new 

treatments in the 3 Bars ecosystem in the future, decisions would have to be made at that time regarding the type of 

environmental analysis that must be conducted before treatments would be allowed within the ecosystem. There 

are approximately 15,000 acres of treatments that could occur within the ecosystem that have been authorized by 

the BLM, or may be authorized in the future, during the life of the project. Previously approved treatments are 

discussed in Chapter 3 under Cumulative Effects (Section 3.3.2). 

Summary of Impacts 

The direct and indirect effects of the proposed treatment alternatives on natural and socioeconomic resources are 

evaluated in this EIS. The cumulative effects that result from the incremental impact of treatment actions when 

added to the effects of other past, present, and reasonably foreseeable future actions are also evaluated for proposed 

treatments. Standard Operating Procedures would be used to reduce impacts, and mitigation measures have been 

proposed to reduce potentially significant adverse impacts to more reasonable levels. 

3 Bars Project Final EIS ES-5 October 2016
EXECUTIVE SUMMARY

Direct and Indirect Impacts 

In general, potential direct and indirect adverse impacts and benefits would be greatest under Alternative A and 

least under Alternative D. Fewer acres would be treated, and fewer treatments methods used, under Alternatives B 

and C, so the adverse and beneficial effects under Alternatives B and C would be less than under Alternative A. In 

general, fire and mechanical treatments would have the greatest adverse effects on resources, while manual and 

biological control methods would generally have negligible effects. 

The effects of treatments on local and regional air quality and global climate change would be negligible for all 

alternatives. None of the treatments would result in emissions that exceed Prevention of Significant Deterioration 

thresholds or national or state ambient air quality standards. 

The effects of treatments on mineral resources would be negligible. The BLM would ensure that treatment 

activities do not limit access to mining claims. Most treatments would occur at or above the soil surface, thus risks 

to paleontological resources would be negligible. Paleontological resources have been found in rock outcrops, but 

the BLM does not propose treatments near these areas. 

Treatments would result in short-term adverse effects to soil, primarily from loss of vegetative cover and from soil 

disturbance that would lead to soil erosion and loss of soil productivity. Treatments would benefit soil long-term by 

restoring the health and resiliency of native vegetation, restoring natural fire regimes and reducing the risk of 

catastrophic wildfire, reducing runoff and increasing water infiltration, and slowing the spread of noxious weeds 

and other invasive non-native vegetation, which should reduce soil erosion and improve soil productivity. 

Treatments could lead to short-term increased runoff and erosion that could affect water flows and quality. It is 

possible that lubricants and fuel from equipment used in treatments could also affect water quality. Long-term, 

treatments would improve watershed function and water quality, increase the amount of water infiltrating into the 

ground and reaching streams and the groundwater, and extend the period when water flows in streams. Treatments 

that improve vegetation health and resiliency, and reduce catastrophic wildfire risk, would also benefit water 

resources. 

Treatments pose short-term risks to terrestrial and aquatic vegetation. All treatments would remove or harm 

vegetation, and could cause vegetation communities to return to an early successional stage. Long-term, treatments 

would improve the health and resiliency of native vegetation. Treatments would help to control noxious weeds and 

other invasive non-native vegetation, to the benefit of native vegetation. By thinning and removing pinyon-juniper, 

BLM treatments would benefit riparian, aspen, and sagebrush communities where pinyon-juniper is crowding out 

these vegetation types. Restoring natural fire regimes, using fire and other methods to thin and remove decadent 

and unhealthy pinyon-juniper, and using all methods to control large cheatgrass infestations, would reduce the risk 

of future catastrophic wildfire. 

Treatments pose short-term risks to fish and wildlife. Accidental spills of fuels and lubricants, and soil disturbance 

and erosion associated with treatments, especially mechanical and fire treatments, could harm aquatic organisms, 

including game fish and Lahontan cutthroat trout, a federally listed threatened species. Noise and other 

disturbances could cause wildlife to avoid treatment areas during implementation, and fish and wildlife could be 

directly harmed by treatments. Removal of vegetation would reduce the amount of forage available for wildlife in 

the short-term. Removal of pinyon-juniper could have long-term adverse effects to species that favor pinyonjuniper. The BLM would conduct pre-treatment surveys to ensure that risks to migratory birds and other sensitive 

3 Bars Project Final EIS ES-6 October 2016
EXECUTIVE SUMMARY 

wildlife are minimized or avoided. Long-term, fish and wildlife would benefit from proposed treatments. Many 

treatments are focused on improving habitat for Lahontan cutthroat trout through improvements to stream channel 

and riparian habitats. Aspen treatments would benefit species that use these trees, including northern goshawk. 

Thinning and removal of pinyon-juniper could aid in wildlife movements, enhance sagebrush habitat, and promote 

understory development of native forbs and grasses. Overseeding using native seeds in sagebrush treatment areas 

would benefit Greater sage-grouse, pygmy rabbit, and other sagebrush obligate species by promoting understory 

development. Treatments would improve the health and resiliency of vegetation and help to control noxious weeds 

and other invasive non-native vegetation to the benefit of fish and wildlife. Treatments would also reduce the risk 

of catastrophic wildfire and its effects on fish and wildlife habitat. 

Livestock and wild horses could be affected by treatments through noise and disturbance, loss of forage and water, 

and from reduced water quality. However, the BLM would take actions, where possible, to minimize these risks by 

conducting several treatments within the same area at the same time or conducting treatments when livestock are 

not using the treatment area. Long-term, treatments that restore the health and resiliency of native vegetation, 

remove noxious weeds and other invasive non-native vegetation, promote the development of forbs and grasses, 

and reduce the risk of catastrophic wildfire would benefit livestock and wild horse forage and water availability 

and abundance and better distribute livestock and wild horses across the rangeland. 

While treatments could affect cultural resources near or on the surface, they would be more likely to affect 

traditional cultural practices of gathering plants by Native peoples. Cultural resources could be impacted by 

equipment and fire, but the BLM would conduct pre-treatment cultural resource surveys to mitigate this risk. 

Treatments could result in the loss of vegetation used by Native peoples, including pinyon pine nuts and juniper 

berries, but the BLM would consult with local tribes to identify areas of concern and conduct treatments in a 

manner that minimizes or avoids the loss of vegetation resources used by Native peoples. Long-term, treatments 

would improve the health and resiliency of native vegetation, and reduce the risk of catastrophic wildfire, which 

should ensure the long-term health and availability of vegetation used by Native peoples. 

Treatments could affect visual, wilderness, and recreation resources. Treatments would remove and discolor 

vegetation, making it less visually appealing in the short-term. Over the long-term, landscapes should be more 

appealing as native vegetation is restored. Treatments in Wilderness Study Areas and near the Pony Express 

National Historic Trail may detract from the “naturalness” of the area. Although use of mechanical equipment 

would not occur in Wilderness Study Areas, its use nearby would create noise and reduce the wilderness 

experience. Recreationists could be exposed to treatments, experience less visually-appealing landscapes, or find 

fish and game less plentiful as a short-term result of treatments. In addition, recreational areas could be closed for 

short periods of time during and/or immediately following implementation of treatments to ensure treatment 

success and protect the health of visitors. Long-term, treatments should improve the health and resiliency of native 

vegetation, reduce the occurrence of noxious weeds and other invasive non-native vegetation, and reduce the risk 

of wildfire to the benefit of visual, wilderness, and recreational resources. 

Social effects would be negligible at the scale addressed in this EIS. There would be benefits to communities that 

supply workers, materials, or services in support of treatment activities. Some businesses, such as recreation-based 

businesses and ranching operations, could be adversely affected in the short-term if treatments closed areas used 

for recreation or by domestic livestock. Long-term, treatments should improve the health and functionality of the 3 

Bars ecosystem to the benefit of the local community and other users of the 3 Bars ecosystem.

3 Bars Project Final EIS ES-7 October 2016
EXECUTIVE SUMMARY

Risk to humans from treatments would be negligible. Workers conducting the treatments could be at risk for 

adverse effects from walking on uneven ground, on broken terrain, and in dense vegetation. Other potential adverse 

effects associated with the proposed treatments would vary by treatment method, as there are human health risks 

unique to each method. Treatments that remove noxious weeds and other invasive non-native vegetation near 

public use sites and facilities would benefit public health and welfare. Treatments that reduce the risk of 

catastrophic wildfire on public lands would have similar benefits to human health and safety. 

Cumulative Impacts 

Numerous past and present actions on and near the 3 Bars Project area have contributed to current conditions on 

the 3 Bars Project area. These include actions by entities with an interest in vegetation management, including 

nearby federal land management agencies, State of Nevada, Eureka County and other local governments, and 

private landowners including ranchers, farmers, and private developers. Past and present actions of importance to 

the 3 Bars Project include noxious weeds and other invasive non-native vegetation treatments; agriculture; use and 

harvest of woodland products; utility infrastructure and distribution networks; wildland fires, fuels management, 

and reseeding; habitat stabilization and rehabilitation; livestock and wild horse management activities; recreation; 

land development; mineral development and exploration; and oil, gas, and geothermal leasing and development. 

Short-term, treatments may adversely affect conditions within the 3 Bars Project area, but long-term would provide 

benefits to natural and social resources that would help to offset the adverse effects from past, present, and 

reasonably foreseeable future actions within the project area. As with direct and indirect effects, cumulative effects, 

both adverse and beneficial, would be greatest under Alternative A and least under Alternative D. 

Treatments would contribute only minor amounts of pollutants to the air. Fire use would increase particulate matter 

in the air, but the amount of pollutants generated by fire use, and their effects on human health, should be less than 

those from wildfire, resulting in fewer pollutants accumulating than would occur without treatments. Treatments 

would lead to short-term cumulative loss of soil from the removal of vegetation and erosion, but improvement in 

vegetative abundance, diversity, health, and resiliency should slow soil loss on public lands. Erosion has led to 

poor water quality on portions of public lands. Treatments that slow erosion would also benefit water quality and 

slow the cumulative loss of water quality. Pinyon-juniper removal and thinning has the potential to increase water 

infiltration and stream flows within the 3 Bars Project area. Treatments would improve wetland and riparian area 

functions and values and slow erosion. With improvement in these areas, habitat for fish and other aquatic 

organisms would also improve. 

Fire exclusion, pinyon-juniper expansion, and the spread of noxious weeds and other invasive non-native 

vegetation have degraded vegetation function and quality on the 3 Bars Project and nearby areas and have led to a 

cumulative loss of vegetative productivity, health, and resilience. Treatments would restore ecosystem processes 

and slow this loss. Improvement in vegetation characteristics would benefit wildlife. Some species that have 

adapted to degraded ecosystems could lose habitat as native vegetation is restored, but most species would benefit. 

Factors that have led to the loss of native vegetation and ecosystem health have adversely impacted rangelands 

used by domestic livestock and wild horses, and reasonably foreseeable future actions, such as the Mount Hope 

Project, could further reduce the amount of rangeland available to livestock and wild horses. Treatments should 

improve rangelands for these animals, and ensure that project lands can support viable populations of wild horses 

and a healthy ranching industry. The BLM would evaluate proposed treatment areas, prior to treatment, to ensure 

3 Bars Project Final EIS ES-8 October 2016
EXECUTIVE SUMMARY 

proper livestock management is in place in order to maintain the long-term success of the proposed treatments. The 

BLM would also continue to manage wild horses in accordance with existing laws, policy and guidance. 

Treatments may add to the cumulative loss of paleontological and cultural resources. The BLM has developed a 

Programmatic Agreement with the State Historic Preservation Office to ensure protection of cultural resources, and 

consults regularly with local tribes to ensure that Native people’s resources are protected, and enhanced long-term. 

Treatments may result in some short-term and temporary loss of visual, recreational, wilderness, and other special 

area values due to the removal or discoloration of vegetation that could be additive to loss of these resources from 

past, present, and reasonably foreseeable future actions. In some cases, areas might be closed to visitors during and 

after treatments; however, these impacts would be short-term and any values affected would be restored within 2 

growing seasons in most cases. 

Treatments would benefit local communities by providing jobs and income, and by reducing the risk of 

catastrophic wildfire that could harm people and destroy property. These gains would be negligible in the context 

of the local economy, especially considering ongoing and reasonably foreseeable future mining actions, but would 

still be a cumulative benefit for many rural communities. 

Some treatments may pose a health risk to workers and the public. Most treatments, however, would pose few risks 

to workers and even fewer risks to the public, especially when compared to the mining and agriculture industries. If 

treatments restore natural fire regimes, reduce the risk of catastrophic wildfire, and slow the spread of noxious 

weeds and other invasive non-native vegetation, human health would benefit. 

Significance of Effects of the Alternatives 

Based on criteria used in the EIS, none of the actions taken under the alternatives would have a significant longterm effect on the natural and social resources of the 3 Bars ecosystem. This assumes, however, that the BLM 

would follow SOPs outlined in Appendix C. Livestock grazing could have a significant cumulative effect on 

treatment success, thus the BLM would not implement treatments until proper livestock management is in place. 

Although proposed actions would not have a significant long-term effect on 3 Bars ecosystem resources, reduced 

levels of treatment activity associated with Alternatives B and C, and in particular Alternative D, in comparison to 

Alternative A, could have long-term effects on 3 Bars ecosystem resources. By not using all available methods and 

not treating the maximum number of acres, factors that contribute to loss of native and non-invasive vegetation 

health and resiliency would remain. These include the spread of noxious weeds and other invasive non-native 

vegetation, pinyon-juniper encroachment, and wildfire, and would be greater under Alternatives B, C, and D than 

under Alternative A. In addition, the BLM would do little to move plant communities toward their desired state 

under Alternatives B, C, and D. No treatments would be authorized under Alternative D. Given that resource 

conditions on several areas within the ecosystem have deteriorated due to past land use activities, it is unlikely that 

conditions would improve under Alternative D. 

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EXECUTIVE SUMMARY

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3 Bars Project Final EIS ES-10 October 2016

 
TABLE OF CONTENTS, LISTS OF TABLES 

AND FIGURES, AND ACRONYMS 
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TABLE OF CONTENTS 

3 Bars Project Final EIS TOC - iii October 2016 

TABLE OF CONTENTS 

VOLUME ONE 

Chapter 1. Proposed Action and Purpose and Need ................................................................................................1-1 

1.1 Introduction ..............................................................................................................................................................1-1 

1.2 Summary of Major Changes between the Draft and Final EIS ...............................................................................1-3 

1.3 Background ..............................................................................................................................................................1-3

1.3.1 Vegetation ..................................................................................................................................................1-4

1.3.2 Wetlands and Riparian Zones and Water Quality and Quantity...............................................................1-4

1.3.3 Fish and Wildlife ........................................................................................................................................1-5

1.3.4 Native American Tradition and Cultural Values, Practices, and Resources ............................................1-5

1.3.5 Wild Horses ................................................................................................................................................1-5

1.3.6 Livestock ....................................................................................................................................................1-5

1.3.7 Fire Management .......................................................................................................................................1-5

1.4 Proposed Action .......................................................................................................................................................1-6

1.5 Purposes for the Project ...........................................................................................................................................1-6

1.6 Need for the Project..................................................................................................................................................1-7

1.6.1 Healthy Lands Initiative .............................................................................................................................1-8

1.6.2 Shoshone-Eureka Resource Management Plan ........................................................................................1-9 

1.6.3 Nevada and Northern California Greater Sage-Grouse Approved Resource Management Plan 

Amendment (ARMPA0 .............................................................................................................................1-9

1.7 Restoration Objectives .......................................................................................................................................... 1-10

1.8 Scope of Analysis and Decisions to be Made ...................................................................................................... 1-10

1.9 Documents that Influence the Scope of the EIS ................................................................................................... 1-14

1.10 Relationship to Statutes, Regulations, and Policies ............................................................................................. 1-15

1.10.1 Federal Laws, Regulations, and Policies that Influence Restoration Treatments ................................. 1-15

1.10.2 NEPA Requirements of the Project ........................................................................................................ 1-15

1.11 Interrelationship and Coordination with Agencies ............................................................................................... 1-16

1.11.1 Cooperating Agencies ............................................................................................................................. 1-16

1.11.2 Other Governmental Agencies ............................................................................................................... 1-17

1.11.3 Non-governmental Organizations .......................................................................................................... 1-17

1.12 Consultation and Coordination ............................................................................................................................. 1-17

1.13 Public Involvement and Analysis of Issues .......................................................................................................... 1-19

1.13.1 Public Scoping ........................................................................................................................................ 1-19

1.13.2 Public Review and Comment on the Draft EIS ..................................................................................... 1-21 

1.14 Limitations of this EIS .......................................................................................................................................... 1-25 

Chapter 2. Alternatives ................................................................................................................................................2-1 

2.1 Introduction ..............................................................................................................................................................2-1

2.2 Summary of Major Changes between the Draft and Final EIS ..............................................................................2-1 

2.3 Description of the ction Alternatives (Alternatives A, B, and C) ...........................................................................2-3

2.3.1 Alternative A - All Treatment Methods Alternative (Preferred Alternative) ...........................................2-3

2.3.2 Alternative B - No Fire Use Alternative ................................................................................................ 2-21 
TABLE OF CONTENTS 

2.3.3 Alternative C - Minimal Land Disturbance Alternative ........................................................................ 2-21

2.4 Description of the No Action Alternative - Alternative D - Continue Current Management ............................. 2-22

2.5 Development of the Action Alternatives .............................................................................................................. 2-22

2.5.1 Treatment Area Selection ....................................................................................................................... 2-22 

2.5.2 Site-specific Project Selection ................................................................................................................ 2-22

2.5.3 Treatment Methods ................................................................................................................................. 2-23

2.5.4 Standard Operating Procedures and other Resource Protections........................................................... 2-30

2.5.5 Monitoring ............................................................................................................................................... 2-30

2.5.6 Coordination and Education ................................................................................................................... 2-32

2.6 Summary of Alternatives Analyzed in this EIS .............................................................................................. 2-32 

2.7 Alternatives Considered but not Further Analyzed .............................................................................................. 2-32

2.8 Mitigation .............................................................................................................................................................. 2-36

2.9 Summary of Impacts by Alternative ..................................................................................................................... 2-36

Chapter 3. Affected Environment and Environmental Consequences ................................................................. 3-1 

3.1 Introduction ............................................................................................................................................................. 3-1

3.2 Summary of the Major Changes between the Draft and Final EIS ........................................................................ 3-1 

3.3 How the Effects of the Alternatives Were Evaluated ............................................................................................. 3-4 

3.3.1 Direct and Indirect Effects ........................................................................................................................ 3-4

3.3.2 Cumulative Effects .................................................................................................................................... 3-5

3.3.3 Unavoidable Adverse Commitments ...................................................................................................... 3-20

3.3.4 Irreversible and Irretrievable Commitments .......................................................................................... 3-21

3.3.5 Resource Protection Measures Considered in the Effects Analysis ...................................................... 3-21

3.3.6 Incomplete and Unavailable Information ............................................................................................... 3-21

3.4 General Setting ...................................................................................................................................................... 3-22

3.4.1 Project Area ............................................................................................................................................. 3-22

3.4.2 Ecoregions ............................................................................................................................................... 3-22

3.5 Meteorology and Climate Change ........................................................................................................................ 3-27

3.5.1 Regulatory Framework ........................................................................................................................... 3-27

3.5.2 Affected Environment ............................................................................................................................. 3-27

3.5.3 Environmental Consequences ................................................................................................................. 3-31

3.6 Air Quality ............................................................................................................................................................. 3-33

3.6.1 Regulatory Framework ........................................................................................................................... 3-33

3.6.2 Affected Environment ............................................................................................................................. 3-37

3.6.3 Environmental Consequences ................................................................................................................. 3-38

3.6.4 Mitigation ................................................................................................................................................ 3-48

3.7 Geology and Minerals ........................................................................................................................................... 3-49

3.7.1 Regulatory Framework ........................................................................................................................... 3-49

3.7.2 Affected Environment ............................................................................................................................. 3-50

3.7.3 Environmental Consequences ................................................................................................................. 3-55

3.7.4 Mitigation ................................................................................................................................................ 3-58

3.8 Paleontological Resources .................................................................................................................................... 3-58

3.8.1 Regulatory Framework ........................................................................................................................... 3-58

3.8.2 Affected Environment ............................................................................................................................. 3-60

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

3 Bars Project Final EIS TOC - v October 2016 

3.8.3 Environmental Consequences ................................................................................................................ 3-60

3.8.4 Mitigation ................................................................................................................................................ 3-65

3.9 Soil Resources ....................................................................................................................................................... 3-65

3.9.1 Regulatory Framework ........................................................................................................................... 3-65

3.9.2 Affected Environment............................................................................................................................. 3-65

3.9.3 Environmental Consequences ................................................................................................................ 3-81

3.9.4 Mitigation ................................................................................................................................................ 3-94

3.10 Water Resources .................................................................................................................................................... 3-94

3.10.1 Regulatory Framework ........................................................................................................................... 3-94

3.10.2 Affected Environment............................................................................................................................. 3-95

3.10.3 Environmental Consequences .............................................................................................................. 3-112

3.10.4 Mitigation .............................................................................................................................................. 3-129

3.11 Wetlands, Floodplains, and Riparian Zones ....................................................................................................... 3-129

3.11.1 Regulatory Framework ......................................................................................................................... 3-129

3.11.2 Affected Environment........................................................................................................................... 3-131

3.11.3 Environmental Consequences .............................................................................................................. 3-133

3.11.4 Mitigation .............................................................................................................................................. 3-146

3.12 Native and Non-invasive Vegetation Resources ............................................................................................... 3-147

3.12.1 Regulatory Framework ......................................................................................................................... 3-147

3.12.2 Affected Environment........................................................................................................................... 3-148

3.12.3 Environmental Consequences .............................................................................................................. 3-206

3.12.4 Mitigation .............................................................................................................................................. 3-224

3.13 Noxious Weeds and other Invasive Non-native Vegetation .............................................................................. 3-224

3.13.1 Regulatory Framework ......................................................................................................................... 3-224

3.13.2 Affected Environment........................................................................................................................... 3-226

3.13.3 Environmental Consequences .............................................................................................................. 3-228

3.13.4 Mitigation .............................................................................................................................................. 3-238

3.14 Wildland Fire and Fire Management .................................................................................................................. 3-238

3.14.1 Regulatory Framework ......................................................................................................................... 3-239

3.14.2 Affected Environment........................................................................................................................... 3-241

3.14.3 Environmental Consequences .............................................................................................................. 3-252

3.14.4 Mitigation .............................................................................................................................................. 3-262

3.15 Fish and Other Aquatic Resources..................................................................................................................... 3-262

3.15.1 Regulatory Framework ......................................................................................................................... 3-262

3.15.2 Affected Environment........................................................................................................................... 3-263

3.15.3 Environmental Consequences .............................................................................................................. 3-270

3.15.4 Mitigation .............................................................................................................................................. 3-284

3.16 Wildlife Resources .............................................................................................................................................. 3-285

3.16.1 Regulatory Framework ......................................................................................................................... 3-285

3.16.2 Affected Environment........................................................................................................................... 3-287

3.16.3 Environmental Consequences .............................................................................................................. 3-308

3.16.4 Mitigation .............................................................................................................................................. 3-327

3.17 Wild Horses ......................................................................................................................................................... 3-327

3.17.1 Regulatory Framework ......................................................................................................................... 3-327
TABLE OF CONTENTS 

3.17.2 Affected Environment ........................................................................................................................... 3-327

3.17.3 Environmental Consequences ............................................................................................................... 3-334

3.17.4 Mitigation .............................................................................................................................................. 3-345

3.18 Livestock Grazing ............................................................................................................................................... 3-345

3.18.1 Regulatory Framework ......................................................................................................................... 3-345

3.18.2 Affected Environment ........................................................................................................................... 3-346

3.18.3 Environmental Consequences ............................................................................................................... 3-352

3.18.4 Mitigation .............................................................................................................................................. 3-364

3.19 Visual Resources ................................................................................................................................................. 3-366

3.19.1 Regulatory Framework ......................................................................................................................... 3-366

3.19.2 Affected Environment ........................................................................................................................... 3-366

3.19.3 Environmental Consequences ............................................................................................................... 3-373

3.19.4 Mitigation ............................................................................................................................................. 3-388

3.20 Land Use and Access .......................................................................................................................................... 3-388

3.20.1 Regulatory Framework ......................................................................................................................... 3-388

3.20.2 Affected Environment ........................................................................................................................... 3-389

3.20.3 Environmental Consequences ............................................................................................................... 3-403

3.20.4 Mitigation .............................................................................................................................................. 3-407

3.21 Recreation ............................................................................................................................................................ 3-407

3.21.1 Regulatory Framework ......................................................................................................................... 3-407

3.21.2 Affected Environment ........................................................................................................................... 3-408

3.21.3 Environmental Consequences ............................................................................................................... 3-412

3.21.4 Mitigation .............................................................................................................................................. 3-422

3.22 Wilderness Study Areas and other Special Management Areas ........................................................................ 3-423

3.22.1 Regulatory Framework ......................................................................................................................... 3-423

3.22.2 Affected Environment ........................................................................................................................... 3-424

3.22.3 Environmental Consequences ............................................................................................................... 3-426

3.22.4 Mitigation .............................................................................................................................................. 3-433

3.23 Cultural Resources .............................................................................................................................................. 3-433

3.23.1 Regulatory Framework ......................................................................................................................... 3-433

3.23.2 Affected Environment ........................................................................................................................... 3-433

3.23.3 Environmental Consequences ............................................................................................................... 3-447

3.23.4 Mitigation .............................................................................................................................................. 3-457

3.24 Native American Traditional/Cultural Values, Practices, and Resources ......................................................... 3-457

3.24.1 Regulatory Framework ......................................................................................................................... 3-457

3.24.2 Affected Environment ........................................................................................................................... 3-459

3.24.3 Environmental Consequences ............................................................................................................... 3-465

3.24.4 Mitigation .............................................................................................................................................. 3-478

3.25 Social and Economic Values and Environmental Justice .................................................................................. 3-478

3.25.1 Regulatory Framework ......................................................................................................................... 3-478

3.25.2 Affected Environment ........................................................................................................................... 3-478

3.25.3 Environmental Consequences ............................................................................................................... 3-492

3.25.4 Mitigation .............................................................................................................................................. 3-502

3.26 Human Health and Safety ................................................................................................................................... 3-502

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

3.26.1 Regulatory Framework ......................................................................................................................... 3-502

3.26.2 Affected Environment........................................................................................................................... 3-503

3.26.3 Environmental Consequences .............................................................................................................. 3-507

3.26.4 Mitigation .............................................................................................................................................. 3-516

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

4.3.2 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 

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

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

List of Tables 

1-1 Primary Resource Management Plan Objectives for the Shoshone-Eureka Resource Area ......................... 1-11 

1-2 Restoration Goals for the 3 Bars Ecosystem ................................................................................................... 1-12

1-3 Agencies/Organizations/Individuals Providing Written Comments during Public Scoping ........................ 1-22 

1-4 Comment Subject Breakdown ......................................................................................................................... 1-22 

1-5 Key Issues (and Number of Comments) Identified during Scoping .............................................................. 1-24

2-1 Responses of the Alternatives to the Project Purposes ................................................................................... 2-33 

2-2 Summary and Comparison of Effects on Resources by Alternative .............................................................. 2-37 

3-1 Elements Associated with Supplemental Authorities and Rationale for Detailed Analysis for the Proposed 

Action and other Alternatives ............................................................................................................................ 3-2 

3-2 Resources or Uses other than the Elements Associated with Supplemental Authorities and Rationale for 

Detailed Analysis for the Proposed Action and other Alternatives .................................................................. 3-3 

3-3 Monthly Climate Summary for Eureka, Nevada (1888 through 2012). ........................................................ 3-29

3-4 National and Nevada Ambient Air Quality Standards ................................................................................... 3-34

3-5 State and National Ambient Air Quality Standards Compliance Analysis for Manual Treatments ............. 3-41

3-6 State and National Ambient Air Quality Standards Compliance Analysis for Mechanical Treatments....... 3-42

3-7 State and National Ambient Air Quality Standards Compliance Analysis for Prescribed Fire Treatments . 3-42

3-8 State and National Ambient Air Quality Standards Compliance Analysis for Biological Treatments ......... 3-44

3-9 Potential Fossil Yield Classification ............................................................................................................... 3-59

3-10 Project Area Soil Limitations .......................................................................................................................... 3-69

3-11 Project Area Topsoil Organic Matter Content ................................................................................................ 3-76

3-12 Soil Textures in the Project Area .................................................................................................................... 3-76

3-13 Soil Suitabilities for Vegetation Treatment ................................................................................................... 3-78

3-14 Nevada Hydrographic Areas included in the Water Resources Assessment ................................................. 3-96

3-15 Perennial and Intermittent/Ephemeral Streams in the Project Area ............................................................. 3-100 

3-16 Flow Summary from U.S. Geological Survey Monitoring Stations ............................................................ 3-102

3-17 Site-specific Stream Investigations ............................................................................................................... 3-102 

3-18 Flow Measurements at Springs ..................................................................................................................... 3-107

3-19 2009 Estimated Annual Groundwater Budget for Individual Basins ........................................................... 3-110 

3-20 Percent of Watershed Basin within Treatment Areas ................................................................................... 3-118

3-21 Perennial Stream Miles within Treatment Areas .......................................................................................... 3-118

3-22 Current and Expected Vegetation Types within the 3 Bars Project Area .................................................... 3-150

3-23 Ecological Sites for Grassland Community .................................................................................................. 3-155

3-24 Ecological Sites for Big Sagebrush Community .......................................................................................... 3-156

3-25 Ecological Sites for Low Sagebrush Community ......................................................................................... 3-161

3-26 Ecological Sites for Black Sagebrush Community ....................................................................................... 3-162

3-27 Ecological Sites for Greasewood Community .............................................................................................. 3-164

3-28 Ecological Sites for Salt Desert Scrub Community ...................................................................................... 3-165

3-29 Ecological Sites for Mountain Mahogany .................................................................................................... 3-167

3-30 Ecological Sites for Pinyon-juniper Community .......................................................................................... 3-169

3-31 Pinyon-juniper Classification Schemes ........................................................................................................ 3-179

3-32 Flynn/Parman Allotment KMAs ................................................................................................................... 3-184

3-33 Roberts Mountain Allotment KMAs............................................................................................................. 3-186

3-34 JD Allotment KMAs...................................................................................................................................... 3-190

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

3-35 Three Bars Allotment KMAs ........................................................................................................................ 3-194

3-36 Romano Allotment KMAs ............................................................................................................................ 3-199

3-37 Lucky C Allotment KMAs ............................................................................................................................ 3-201

3-38 Special Status Plant Species That may Occur in the 3 Bars Project Area ................................................... 3-203

3-39 Noxious Weeds in the 3 Bars Project Area................................................................................................... 3-228

3-40 Fire History on the 3 Bars Project Area ........................................................................................................ 3-246

3-41 Fire Regime Descriptions (Historical Fire Regimes) ................................................................................... 3-246

3-42 Fire Regime Condition Class Descriptions ................................................................................................... 3-247

3-43 Habitat Characteristics of Birch, Pete Hanson, and Willow Creeks ............................................................ 3-264

3-44 Summary of Lahontan Cutthroat Trout Surveys in Birch, Pete Hanson, and Willow Creeks .................... 3-268

3-45 Special Status Species Known or with Potential to Occur in the 3 Bars Project Area ................................ 3-297

3-46 Herd Management Areas ............................................................................................................................... 3-330

3-47 Allotments within Herd Management Areas ................................................................................................ 3-333 

3-48 Surface Disturbance by HMA for Management Types ................................................................................ 3-336 

3-49 Grazing Allotments within the 3 Bars Ecosystem ........................................................................................ 3-348 

3-50 Allotment Grazing Management System and Category ............................................................................... 3-348

3-51 Rangeland Improvements by Allotment ....................................................................................................... 3-350

3-52 Acreage Affected by Treatment Types for each Allotment under Alternative A ........................................ 3-355 

3-53 Visual Resource Project Area Inventory and Visual Resource Management Classes Summary ............... 3-372 

3-54 Landscape Scenery Impacts .......................................................................................................................... 3-376 

3-55 Distance Zones and Project Visibility ........................................................................................................... 3-376

3-56 Impacts to Viewers ........................................................................................................................................ 3-376

3-57 Visual Resource Project Area Inventory and Visual Resource Management Classes for Cumulative Effects 

Analysis ......................................................................................................................................................... 3-384

3-58 Land Ownership within the Project Area and Eureka County ..................................................................... 3-391 

3-59 Existing Land Use Authorizations in the Project Area ................................................................................ 3-391

3-60 2011 Harvest by Hunt Unit and Group ......................................................................................................... 3-411

3-61 Annual Average Fishing Use in the Study Area (1980-2010) ..................................................................... 3-411

3-62 Summary of Documented Resources ............................................................................................................ 3-443

3-63 Summary of Document Prehistoric Cultural Sites ....................................................................................... 3-444

3-64 Summary of Documented Historic-era Cultural Sites .................................................................................. 3-445

3-65 Minority Population and the Incidence of Poverty in Eureka County, 2010 ............................................... 3-480

3-66 Eureka County Population, Selected Years, 2000-2011 .............................................................................. 3-481

3-67 Eureka County Labor Force, Unemployed, and Unemployment Rate, Selected Years .............................. 3-482

3-68 Eureka County Personal Income by Place of Residence, Selected Years ................................................... 3-483

3-69 Per Capital Personal Income, Eureka County, Nevada, and the United States ........................................... 3-483

3-70 Farm Income and Expenses, Eureka County, 2007-2010 ............................................................................ 3-487

3-71 Eureka County Budget Summary, Fiscal Years 2007-2011 ........................................................................ 3-490

3-72 Eureka County, Assessed Value, Fiscal Years 2005/2006 through 2010/2011 .......................................... 3-490

3-73 Estimated Treatment Costs per Acre ............................................................................................................ 3-496

3-74 Leading Causes of Death in Nevada and Eureka County, 2000 to 2008 ..................................................... 3-504

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

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

List of Figures 

1-1 General Vicinity Map ........................................................................................................................................ 1-2 

1-2 Public Lands Administered by the Mount Lewis Field Office ...................................................................... 1-18 

2-1 Riparian Treatment Areas ................................................................................................................................. 2-5 

2-2 Aspen Treatment Areas ................................................................................................................................... 2-10

2-3 Pinyon-juniper Treatment Areas ..................................................................................................................... 2-13

2-4 Sagebrush Treatment Areas............................................................................................................................. 2-19 

3-1 Cumulative Effects Study Areas ....................................................................................................................... 3-7 

3-2 Cumulative Impacts from Grazing, Agriculture, and Forest Product Activities ........................................... 3-10

3-3 Cumulative Impacts from Wildland Fires, Fuels Management, and Reseeding............................................ 3-14

3-4 Cumulative Impacts from Recreation and Wilderness ................................................................................... 3-15

3-5 Cumulative Impacts from Utilities and Infrastructure .................................................................................... 3-17

3-6 Cumulative Impacts from Mining Operations and Oil and Gas Production .................................................. 3-19

3-7 Study Area ....................................................................................................................................................... 3-23

3-8 Ecoregions for the 3 Bars Project Area ........................................................................................................... 3-25

3-9 Geologic Formations ....................................................................................................................................... 3-51

3-10 Mineral Resources ........................................................................................................................................... 3-53

3-11 Oil and Gas Resources ..................................................................................................................................... 3-54

3-12 Soil Orders ....................................................................................................................................................... 3-67

3-13 Compaction Prone Soils .................................................................................................................................. 3-68

3-14 Soil Erosion Potential from Water .................................................................................................................. 3-70

3-15 Soil Erosion Potential from Wind ................................................................................................................... 3-71

3-16 Organic Matter within Surface Soils ............................................................................................................... 3-72

3-17 Soil Surface Texture ........................................................................................................................................ 3-73

3-18 Soils with Low Revegetation Potential ........................................................................................................... 3-75

3-19 Fire Damage Susceptibility ............................................................................................................................. 3-77

3-20 Mechanical Treatment Suitability (Shredder) ................................................................................................. 3-79

3-21 Site Degradation Susceptibility ....................................................................................................................... 3-80

3-22 Streams, Lakes, Ponds, and Wetlands ............................................................................................................. 3-99

3-23 Water Developments and Water Uses .......................................................................................................... 3-106

3-24 Deteriorating Riverine/Wetland Plant Communities .................................................................................... 3-134

3-25 Current Vegetation Communities ................................................................................................................. 3-151

3-26 Major Vegetation Communities in the 3 Bars Project Area based on Ecological Site Data ....................... 3-152 

3-27 Pinyon-juniper Phase Classes ........................................................................................................................ 3-180

3-28 Current Rangeland Conditions ...................................................................................................................... 3-181

3-29 Range Allotments and Key Management Areas ........................................................................................... 3-183

3-30 Forest Products (Private Fuelwood, Pine Nuts, Christmas Trees, and Seed Harvest) ................................. 3-205

3-31 Prime Farmlands ............................................................................................................................................ 3-209

3-32 Cheatgrass and other Weeds.......................................................................................................................... 3-229

3-33 Fire History and Occurrence ......................................................................................................................... 3-242

3-34 Natural Fire Regimes ..................................................................................................................................... 3-243

3-35 Current Fire Regime Condition Class ........................................................................................................... 3-244

3-36 Current Risk of Catastrophic Fire and Threat to Resource Values .............................................................. 3-245

3-37 Snail Observations ......................................................................................................................................... 3-266

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

3-38 Lahontan Cutthroat Trout Habitat ................................................................................................................. 3-269

3-39 Mule Deer Habitat ......................................................................................................................................... 3-294 

3-40 Areas with Degraded Habitat Conditions ..................................................................................................... 3-295 

3-41 Pronghorn Habitat ......................................................................................................................................... 3-296 

3-42 Greater Sage-grouse Habitat ......................................................................................................................... 3-301 

3-43 Wild Horse Management Areas and Habitat Improvement Areas .............................................................. 3-329 

3-44 Areas of Moderate to Severe Use and Treatment Areas .............................................................................. 3-347

3-45 Visual Resource Inventory Scenic Quality Rating ....................................................................................... 3-368

3-46 Visual Resource Inventory Sensitivity Level Rating ................................................................................... 3-369 

3-47 Visual Resource Inventory Visual Distance Zone ........................................................................................ 3-370

3-48 Visual Resource Inventory Class .................................................................................................................. 3-371 

3-49 Visual Resource Management Class ............................................................................................................. 3-374 

3-50 Land Ownership and Land-use Authorizations............................................................................................ 3-390

3-51 Cultural Resource Inventories ....................................................................................................................... 3-410

3-52 Eureka County Alfalfa Production 1995-2011............................................................................................. 3-486

3-53 Eureka County Livestock Product 1995-2011.............................................................................................. 3-486

3 Bars Project Final EIS TOC - xi October 2016 
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3 Bars Project Final EIS TOC - xii October 2016
ACRONYMS 

Acronyms 

3 Bars Project 3 Bars Ecosystem and Landscape Restoration Project 

17-States PEIS Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 

Western States Programmatic Environmental Impact Statement

17-States PER Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Report

A.A. Associate of Arts 

AAQS Ambient Air Quality Standard 

AECC Assessment of Existing and Current Conditions for the Proposed 3 Bars Ecosystem and 

Landscape Restoration Project Environmental Impact Statement

AML Appropriate Management Level 

amsl above mean sea level 

AQMA Air Quality Management Area 

AQRV Air Quality Related Values 

ARMPA Approved Resource Management Plan (referring to the September 2015 BLM Record of 

Decision and Approved Resource Management Plan Amendment for the Great Basin 

Region, Including the Greater Sage-Grouse Sub-Regions of Idaho and Southwestern 

Montana, Nevada, and Northeastern California, Oregon, and Utah) 

AUM Animal Unit Month 

B.A. Bachelor of Arts 

BAPC Bureau of Air Pollution Control 

BLM Bureau of Land Management 

BMP Best Management Practice 

BP Before Present 

B.S. Bachelor of Science 

ca. Circa 

CALPUFF California Puff 

CEQ Council on Environmental Quality 

CESA Cumulative effects study area 

CFR Code of Federal Regulations 

cfs cubic feet per second 

CO Carbon monoxide 

CO2 Carbon dioxide 

COC&PP Central Overland California and Pikes Peak 

Cont. Continued 

e.g. for example 

EIS Environmental Impact Statement 

E&PRR Eureka & Palisade Railroad 

ESD Ecological Site Description 

et. al. and others 

et. seq. et sequentia 

°F Degrees Fahrenheit 

FEMA Federal Emergency Management Agency 

3 Bars Project Final EIS xiii October 2016
ACRONYMS 

FMU Fire Management Unit 

FRCC Fire Regime Condition Class 

gpm gallons per minute 

HMA Herd Management Area 

H2SO4 Sulfuric acid 

i.e. in otherwords 

IMPLAN Impact Analysis for Planning 

Inc. Incorporated 

km kilometer 

KMA Key Management Areas 

LCT Lahontan Cutthroat Trout 

LLC Limited Liability Corporation 

M.A. Master of Arts 

M.Ed. Master of Education 

mg/L milligrams per liter 

M.P.A. Master of Public Administration 

M.S. Master of Science 

n Sample size, number 

NA Not applicable 

NAAQS National Ambient Air Quality Standard 

NDOW Nevada Department of Wildlife 

NEPA National Environmental Policy Act 

NNHP Nevada Natural Heritage Program 

NRHP National Register of Historic Places

NO2 Nitrogen dioxide 

NOx Nitrous oxide 

NS Not surveyed 

NV Nevada 

O3 Ozone 

OSHA Occupational Safety and Health Administration 

Pb Lead 

PEIS Programmatic Environmental Impact Statement 

PER Programmatic Environmental Report 

PFYC Potential Fossil Yield Classification 

PM2.5 Particulate matter less than 2.5 microns in size 

PM10 Particulate matter less than 10 microns in size 

PNC Potential Natural Community 

Ppm parts per million 

PSD Prevention of Significant Deterioration 

Q/D Annual emissions divided by distance to nearest PSD Class I area 

Ph.D. Doctorate of Philosophy 

RMP Resource Management Plan 

ROD Record of Decision 

3 Bars Project Final EIS xiv October 2016
ACRONYMS 

3 Bars Project Final EIS xv October 2016

Scoping Report Scoping Comment Summary Report for the 3 Bars Ecosystem and Landscape Restoration 

Project EIS

SHPO State Historic Preservation Office 

SO2 Sulfur dioxide 

SOP Standard Operating Procedure 

tpy tons per year 

URL Uniform Resource Locator 

U.S. United States 

USACE U.S. Army Corps of Engineers 

USC United States Code 

USDA U.S. Department of Agriculture 

USDOI U.S. Department of the Interior 

USEPA U.S. Environmental Protection Agency 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

VFS Volunteer Fire Service 

VOC Volatile organic compounds 

VRI Visual Resource Inventory 

VRM Visual Resource Management 

WSA Wilderness Study Area 

2,4-D Dichlorophenoxyacetic acid 

§ Section 

3 μg/m micrograms per cubic meter 

% percent 
ACRONYMS 

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3 Bars Project Final EIS xvi October 2016
CHAPTER 1 

PROPOSED ACTION AND 

PURPOSE AND NEED 
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PROPOSED ACTION AND PURPOSE AND NEED

TABLE OF CONTENTS 

Page 

1.1 Introduction .....................................................................................................................................................1-1

1.2 Summary of Major Changes between the Draft and Final EIS .....................................................................1-3

1.3 Background .....................................................................................................................................................1-3

1.3.1Vegetation ........................................................................................................................................................1-4

1.3.2Wetlands and Riparian Zones and Water Quality and Quantity ....................................................................1-4

1.3.3Fish and Wildlife .............................................................................................................................................1-5

1.3.4Native American Tradition and Cultural Values, Practices, and Resources ..................................................1-5

1.3.5Wild Horses .....................................................................................................................................................1-5

1.3.6Livestock ..........................................................................................................................................................1-5

1.3.7Fire Management .............................................................................................................................................1-5

1.4 Proposed Action ..............................................................................................................................................1-6

1.5 Purposes for the Project ..................................................................................................................................1-6

1.6 Need for the Project ........................................................................................................................................1-7

1.6.1Healthy Lands Initiative ..................................................................................................................................1-8

1.6.2Shoshone-Eureka Resource Management Plan ..............................................................................................1-9

1.6.3Nevada and Northern California Greater Sage-Grouse Approved Resource Management Plan Amendment 

(ARMPA) ........................................................................................................................................................1-9

1.7 Project Goals and Objectives ....................................................................................................................... 1-10

1.8 Scope of Analysis and Decisions to be Made ............................................................................................. 1-10

1.9 Documents that Influence the Scope of the EIS ......................................................................................... 1-14

1.10 Relationship to Statutes, Regulations, and Policies .................................................................................... 1-15

1.10.1 Federal Laws, Regulations, and Policies that Influence Restoration Treatments .......................... 1-15

1.10.2 NEPA Requirements of the Project ................................................................................................ 1-15

1.11 Interrelationship and Coordination with Agencies ..................................................................................... 1-16

1.11.1 Cooperating Agencies ..................................................................................................................... 1-16

1.11.2 Other Governmental Agencies ........................................................................................................ 1-17

1.11.3 Non-governmental Organizations ................................................................................................... 1-17

1.12 Consultation and Coordination .................................................................................................................... 1-17

1.13 Public Involvement and Analysis of Issues ................................................................................................ 1-19

1.13.1 Public Scoping ................................................................................................................................. 1-19

1.13.2 Public Review and Comment on the Draft EIS .............................................................................. 1-21

1.14 Limitations of this EIS .................................................................................................................................. 1-25

List of Tables 

1-1 Primary Resource Management Plan Objectives for the Shoshone-Eureka Resource Area .............................. 1-11 

1-2 Restoration Goals for the 3 Bars Ecosystem ........................................................................................................ 1-12 

1-3 Agencies/Organizations/Individuals Providing Written Comments during Public Scoping .............................. 1-22 

1-4 Comment Subject Breakdown .............................................................................................................................. 1-22 

1-5 Key Issues (and Number of Comments) Identified during Scoping and Location Where Issues 

are5Addressed in the EIS ...................................................................................................................................... 1-24 

3 Bars Project Final EIS 1-i October 2016 
PROPOSED ACTION AND PURPOSE AND NEED 

3 Bars Project Final EIS 1-ii October 2016 

List of Figures 

1-1 General Location Map ............................................................................................................................................. 1-2 

1-2 Public Lands Administered by the Mount Lewis Field Office ............................................................................ 1-18 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-1 October 2016 

CHAPTER 1 

PROPOSED ACTION AND 

PURPOSE AND NEED 

1.1 Introduction 

The 3 Bars ecosystem is approximately 749,810 acres in central Eureka County, northwest of Eureka, Nevada 

(Figure 1-1). The ecosystem is administered by the U.S. Department of the Interior (USDOI), Bureau of Land 

Management (BLM), Mount Lewis Field Office. It is a shrub steppe ecosystem with important resource values, 

ranging from habitat for a diversity of plants and animals, to providing traditional use areas for several Native 

American tribes; the 3 Bars ecosystem is also an important recreation resource for Nevada residents. 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. 

The 3 Bars ecosystem provides habitat for Greater sage-grouse, a BLM special status species. The BLM is fully in 

conformance with the September 2015 Nevada and Northeastern California Greater Sage-Grouse Approved 

Resource Management Plan Amendment and Record of Decision (ARMPA). To ensure that treatments benefit 

Greater sage-grouse, sagebrush restoration treatments would adhere to ARMPA Required Design Features (RDFs). 

These include avoiding treatments near Greater sage-grouse leks 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 

will ensure proper livestock management is in place prior to treatments when necessary in order to meet project goals 

and objectives, which would benefit Greater sage-grouse habitat. 

In order to ensure long-term success, treatments would not be conducted in areas with moderate to severe forage 

utilization until mitigation measures associated with livestock management, as discussed in Section 3.18.4, are 

implemented through agreements or decisions subsequent to the 3 Bars Project Record of Decision to ensure proper 

livestock management. The BLM would work with permittees on a permit by permit basis to address any changes in 

livestock management prior to treatment implementation. In all instances, proper changes in livestock management 

through agreements or decisions would be finalized prior to treatment implementation. 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Nye County

Elko County

Humboldt County

White Pine

County

Lander

County

Eureka

County

Pershing County

Churchill County

3 Bars

Project

Area

21

49

82

305

766 1

844

228

121

227

306

379

400

89

290

18

376

23

229

11

361

789

892

8

225

2

278

Mount Lewis

Field Office

95

6

50

80

Winnemucca Golconda

Valmy

Elko

Battle

Mountain

Carlin

Austin Eureka

Battle

Mountain

District

Carson City

District

Elko

District

Ely District

Winnemucca

District

0 5 10 15 30

Miles

0 10 20 40

Kilometers

Legend

Land Status

Bureau of Land Management

Bureau of Reclamation

Department of Defense

Native American Reservation

U.S. Fish & Wildlife Service

U.S. Forest Service

Nevada State

Private

Water

City or Town

Interstate Highway

U.S. Highway

State Highway

Major Road

BLM Field Office

County Boundary

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Figure 1-1

General Vicinity Map

3 Bars Ecosystem and

Landscape Restoration Project

Source: BLM 2012a.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-3 October 2016 

Project funding would come from funds allocated by 

Terminology Congress to the BLM for resource management. To 

reduce the cost of treatments to the taxpayer, the BLM Desired Plant Community is the one of the several plant 

communities that may occupy a site that has been identified through would seek outside funding partnerships with other 

a management plan to best meet the plan’s objectives for the site.

resource agencies, non-governmental organizations, or 

Encroachment can be defined as natural succession resulting in private industries that are interested in resource 

densification or interspace in-filling by vegetation, causing an 

management within the 3 Bars ecosystem. understory or previously dominant plant species to decline. It also 

Additionally, it is anticipated that habitat enhancement includes expansion areas. 

activities authorized with the 3 Bars Project decision Infilling can be defined as increase in the density and competition as 

would provide opportunities to utilize off-site a result of pinyon and juniper establishment within woodland 

mitigation account funds associated with various communities at a rate that exceeds the natural stand replacement. 

development activities within or adjacent to the 3 Bars Expansion occurs when vegetation, such as pinyon-juniper, expands 

into new areas where it was not found historically. Project area. 

Hazardous fuels in the context of wildfire include living and dead 

1.2 Summary of Major and decaying vegetation that form a special threat of ignition and 

resistance to control. 

Changes between the Herbicide is a chemical pesticide used to injure or kill vegetation. 

Draft and Final EIS Invasive plants are plants that are not part of (if exotic), or are a 

minor component of (if native), the original plant community or 

Several major changes were made to the 3 Bars communities and are not designated as noxious under federal or state 

statute. Project Draft Environmental Impact Statement (EIS) 

and incorporated into this chapter of the Final EIS Native species are species that historically occurred, or currently 

based on public comments on the Draft EIS. These are occur, in a particular ecosystem and were not introduced. 

(and Section where change is made): Noxious weeds are plants designated by federal or state statute that 

interfere with management objectives for a given area at a given 

1. Conformance with the 2015 BLM ARMPA point in time.

and ROD and its associated Required Design Potential Natural Community is the plant community that would 

Features and other requirements regarding become established if all successional sequences were completed 

fire management, including no sagebrush without interference by man under current environmental conditions. 

thinning would be conducted in sagebrush Prescribed fires are any fire ignited by management actions to meet 

habitat (Section 1.1). specific objectives. A written, approved prescribed fire plan must 

exist, and National Environmental Policy Act requirements (where 

2. Provide information on the Draft EIS public applicable) must be met, prior to ignition. 

review process (Section 1.13.2). Restoration is the implementation of a set of actions that promotes 

plant community diversity and structure that allows plant 

1.3 Background communities to be more resilient to disturbance and invasive 

species over the long-term. 

In order to better understand conditions on the 3 Bars Resilience is the ability to recover from, or adjust easily to, 

change. ecosystem, in 2009 the BLM prepared an Assessment 

of Existing and Current Conditions for the Proposed 3 Undesirable plants are species classified as noxious, invasive, 

harmful, exotic, injurious, poisonous, or otherwise undesirable under Bars Ecosystem and Landscape Restoration Project state or federal law, but not including species listed as endangered by 

Environmental Impact Statement (AECC; USDOI the Endangered Species Act, or species indigenous to the planning 

BLM 2009a). This document summarized baseline area. 

data available to the BLM for the 3 Bars ecosystem, 
PROPOSED ACTION AND PURPOSE AND NEED

including the U.S. Department of Agriculture (USDA) Natural Resources Conservation Service ecological site 

descriptions, studies of proper functioning condition and multiple indicator monitoring for wetland and riparian areas, 

rangeland health assessments, and ecological site inventories. 

In 2010 and 2011, the BLM and its contractors conducted several studies to obtain additional information on 

rangeland and woodland health on the 3 Bars ecosystem. Based on these studies, several reports were prepared: 1) a 3 

Bars Ecosystem and Landscape Restoration Project Pinyon-juniper Assessment that provided the results from an 

assessment of singleleaf pinyon pine and Utah juniper (pinyon-juniper) stands within the 3 Bars ecosystem (AECOM 

2011a); 2) a 3 Bars Ecosystem and Landscape Restoration Project Cheatgrass Assessment that summarized the 

results from an assessment of the occurrence and distribution of cheatgrass and other noxious weeds and invasive 

non-native vegetation within the 3 Bars ecosystem (AECOM 2011b); and 3) a Landscape Restoration Project 

Rangeland Health Report that provided the results of an evaluation of rangeland health on approximately 532,000 

acres within the 3 Bars ecosystem (Eastern Nevada Landscape Coalition and AECOM 2012). 

The AECC and resource studies identified specific elements for each resource component that are in need of 

improvement or change, and served as the framework for developing potential treatments for further consideration 

and analysis in this EIS. The following discusses in more detail why there is a need for change for key resource areas. 

1.3.1 Vegetation

The 3 Bars ecosystem includes diverse upland vegetation community types. Key concerns identified in the AECC for 

range resources are that one or more key perennial grass species are absent; the composition and/or production of key 

species are below the potential for the natural community; noxious weeds and other invasive non-native species are 

dominant in certain areas; and some streams, springs, and meadows are functioning at less than their proper condition. 

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; deterioration in the condition 

of native plant communities in some areas; degradation of range conditions; decrease in pine nut production and tree 

vigor; decrease in the occurrence and health of traditional, edible, and medicinal plants used by Native Americans; 

decline in woodland species and health; and excessive buildup of hazardous fuels. 

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 concern from the AECC for noxious weeds and other undesirable invasive non-native species is the potential 

for the establishment and spread of cheatgrass monocultures resulting from past wildfires and in areas of high soil 

disturbance. The focus of treatments would be to control the spread of noxious weeds and invasive non-native annual 

grasses found within the 3 Bars ecosystem and to encourage the establishment of native species.

1.3.2 Wetlands and Riparian Zones and Water Quality and Quantity

The key concern for wetland and riparian areas and water quality and quantity is the loss of wetland and stream 

functionality. Some streams and associated meadows are being threatened by knickpoints and headcuts, channel 

incision, and streambank erosion. 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 

3 Bars Project Final EIS 1-4 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

are being lost, resulting in decreased infiltration rates and increased run-off and surface erosion and thus contributing 

to reduced water quality. 

1.3.3 Fish and Wildlife

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 pinyonjuniper into important habitats; reduction in key habitats due to degraded range conditions in some areas; invasion of 

undesirable plant 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. 

1.3.4 Native American Tradition and Cultural Values, Practices, and 

Resources 

Various tribes and bands of the Western Shoshone have stated that federal projects and land actions can have 

widespread effects on their culture and traditional practices. Numerous traditional/cultural/spiritual use sites are found 

on the 3 Bars Project area. The BLM will coordinate with affected tribes prior to implementation of individual 

treatments. The BLM will attempt to both identify locations that have traditional/cultural importance, and to reduce or 

eliminate any negative impacts to identified Native American traditional/cultural/spiritual values and practices from 

proposed treatment actions. 

Key concerns identified in the AECC for Native American traditional/cultural/spiritual values and practices included 

a decline in the distribution and abundance of traditional, edible, and medicinal plants, a decrease in pine nut 

production and tree vigor, and a decline in abundance of wild game species. 

1.3.5 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. 

1.3.6 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 nonnative vegetation is dominant in certain areas; and some streams, springs, and meadows are functioning at less than 

their proper functioning condition. 

1.3.7 Fire Management 

Key concerns from the AECC for fire include excessive hazardous fuel loads, and declining ecosystem health in some 

areas, which are contributing to high wildfire potential and threats to resource values. 

3 Bars Project Final EIS 1-5 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

1.4 Proposed Action 

The BLM proposes to treat vegetation using manual and mechanical methods, biological controls, and fire (both 

prescribed and wildland 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 treatments that it proposes to implement to restore and manage the 3 Bars 

ecosystem. Treatments 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. 

 Aspen—treatments in quaking aspen (aspen) habitats would focus on improving the health of aspen stands 

by stimulating aspen stand suckering and sucker survival. 

 Pinyon-juniper—treatments in pinyon-juniper habitats would focus on thinning historic pinyon-juniper 

communities to promote woodland health and removing pinyon-juniper where it encroaches into riparian 

zones and upland habitats, including sagebrush habitats. 

 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. 

1.5 Purposes for the Project 

Using the information from the AECC and field studies, the BLM identified several purposes for the 3 Bars Project. 

Purposes are consistent with the Shoshone-Eureka Resource Management Plan Environmental Impact Statement 

Final (Shoshone-Eureka RMP), as amended, and the Shoshone-Eureka Resource Area Record of Decision

(Shoshone-Eureka ROD), as amended, which guide land management activities in the 3 Bars ecosystem (USDOI 

BLM 1984, 1986a, 1987a); as well as the September 2015 Nevada and Northeastern California Greater Sage-Grouse 

Approved Resource Management Plan Amendment and Record of Decision (ARMPA). Purposes for the 3 Bars 

Project include: 

 Improve woodland, rangeland, and riparian health, productivity, and functionality. 

 Increase stream flows and restore channel morphology in degraded streams. 

 Improve stream habitat for fish and wildlife by implementing physical treatments that include installing large 

woody debris, rock clusters, and check dams in stream channels, 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. 

3 Bars Project Final EIS 1-6 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

 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 sagegrouse, 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 catastrophic wildfire; reduce extreme, very 

high, and high wildfire risks to moderate risk or less; and develop fuel breaks within the treatment 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. 

1.6 Need for the Project 

The 3 Bars ecosystem has long been recognized as an area with numerous resource values and uses. Some of these 

resources and uses include mineral exploration and development, livestock grazing, woodland product harvest, 

recreation, wilderness activities, and habitat for wild horses, fish, and wildlife, including sensitive and game fish and 

wildlife species such as Lahontan cutthroat trout, Greater sage-grouse, mule deer, and pronghorn antelope. 

Factors affecting land uses and health in the ecosystem include the effects of past grazing practices, changes to the 

natural fire regime, establishment and spread of noxious weeds and other invasive non-native vegetation, 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. Based on these changes, the BLM has 

determined that there is a need to improve rangeland health. 

The 3 Bars Project needs identified by the BLM are also based on restoration needs identified in the Healthy Lands 

Initiative (USDOI 2007a, USDOI BLM 2010a); the Shoshone-Eureka RMP, as amended (USDOI BLM 1986a, 

1987a); and the September 2015 Nevada and Northeastern California Greater Sage-Grouse Approved Resource 

Management Plan Amendment and Record of Decision (ARMPA). The ARMPA specifies Required Design Features 

(RDFs) for different uses and management activities, including fire management. ARMPA strategies for Greater 

sage-grouse (GRSG) conservation include: 

 the avoidance and minimization of surface disturbance 

 the improvement of GRSG habitat conditions 

 the reduction of threats from wildfires: 

o identify and prioritize areas that are vulnerable to wildfires and prescribe actions important to GRSG 

protection 

3 Bars Project Final EIS 1-7 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

o restrict the use of prescribed fire for fuel treatments (this plan will not use prescribed fire in 

sagebrush habitat) 

o prioritize post-fire treatments in sagebrush focal areas (SFA), other Priority Habitat Management 

Areas (PHMA), and General Habitat Management Areas (GHMA) 

 the use of monitoring, evaluation and adaptive management techniques to improve GRSG habitat. 

1.6.1 Healthy Lands Initiative 

In recognition of the degradation of the diversity and integrity of plant communities in the western United States 

(U.S.), the USDOI launched the Healthy Lands Initiative in 2007 to accelerate land restoration, increase land 

productivity, and improve the health of public lands in the western U.S. (USDOI 2007a). The goal of the Healthy 

Lands Initiative is to preserve the diversity and productivity of public and private lands across the landscape. The 

Healthy Lands Initiative enables and encourages local land managers to set land restoration priorities across a 

broad scale, and to mitigate adverse impacts to an array of natural resources, in ways not previously available to 

them (USDOI BLM 2010a). 

The Healthy Lands Initiative identified seven regions in need of treatment, including the Oregon-Idaho-Nevada 

shrub-steppe restoration area. The goals for this area include accelerating implementation of habitat restoration 

projects identified in state and local Greater sage-grouse conservation plans, and selecting and implementing land 

treatments to maintain and restore the upland and riparian components of the shrub-steppe (USDOI BLM 2010b). 

Under the Healthy Lands Initiative, the BLM developed the Cooperative Shrub-Steppe Restoration Partnership for 

Oregon, Washington, and Nevada. The Partnership is a coordinated, landscape-level program involving multiple 

partners working together to maintain the health of existing shrub-steppe habitat and to strategically restore shrubsteppe habitat in areas important to wildlife. The Partnership area encompasses 53.5 million acres, roughly 50 percent 

of the remaining sagebrush-steppe habitat in the Great Basin. The diversity and integrity of the plant communities in 

this area support habitat for large populations of Greater sage-grouse, mule deer, pronghorn antelope, and numerous 

other sagebrush-dependent species. The highest priority of the Partnership is to maintain sagebrush-steppe habitat, 

followed by strategically restoring fragmented habitat. Specific Partnership goals include: 

 Join local Greater sage-grouse working groups, federal agencies, and the scientific community in efforts to 

accelerate implementation of habitat restoration projects identified in state and local Greater sage-grouse 

conservation plans. 

 Engage tribes, conservation organizations, and state and federal agencies to strategically select and 

implement land treatments to maintain and restore the upland and riparian components of shrub-steppe 

habitat. 

 Build upon existing programs and initiatives, such as the BLM’s Great Basin Restoration Initiative (USDOI 

BLM 2000a, b), to implement a landscape-restoration strategy. 

 Leverage funds to build on current successes to maximize the positive benefits of restoration at the largest 

scale. 

The 3 Bars Project meets the Healthy Lands Initiative and Cooperative Shrub-Steppe Restoration Partnership goals 

and priorities. 

3 Bars Project Final EIS 1-8 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-9 October 2016 

1.6.2 Shoshone-Eureka Resource Management Plan 

While numerous national BLM plans identify broad objectives for the management of vegetation on public land, 

treatment activities at the regional and local levels are guided by the goals, standards, and objectives of land use plans 

developed for each BLM district office. Policies established at the national level help direct local efforts. 

Land use plans, usually in the form of RMPs, ensure that public lands are managed in accordance with the intent of 

Congress, as stated in the Federal Land Policy and Management Act (43 United States Code [USC] § 1701 et 

sequentia [et. seq.]), under the principles of multiple use and sustained yield. Land use plans guide land use, 

vegetation, and other resource management decisions within the geographic area they cover, and provide specific 

goals, standards, objectives, and expected outcomes that apply to vegetation treatment projects and other restoration 

activities. These plans identify important local resources to be protected; identify historic, current, and future desired 

conditions for vegetation and other resources; and describe land use activities and levels that are appropriate to 

maintain a healthy ecosystem. 

The Shoshone-Eureka RMP and associated ROD and amendments form the land use plan that guides resource 

management on public lands within the Shoshone-Eureka Resource Area of north-central Nevada, including the 3 

Bars ecosystem. The RMP provides for multiple-use management through the protection of fragile and unique 

resources, such as riparian and stream habitat, while not overly restricting the potential for the production of 

commodities from other resources. The RMP offers solutions to eight resource management issues identified by the 

public and the BLM—wilderness designations, land tenure adjustments, utility corridors, woodland products, 

livestock grazing, wild horse use, wildlife habitat management, and riparian and aquatic habitat. The RMP outlines 

objectives, short-term and long-term management actions, Standard Operating Procedures (SOPs), and 

implementation measures for each of these management issues. The primary RMP objectives that would apply to the 

3 Bars Project are shown in Table 1-1. 

1.6.3 Nevada and Northern California Greater Sage-Grouse Approved 

Resource Management Plan Amendment (ARMPA)

The ARMPA lists a key component of the Greater sage-grouse (GRSG) conservation strategy as “Reducing threats of 

rangeland fire to GRSG and sagebrush habitat”. Citing a Conservation Objectives Team (COT) report, the ARMPA 

emphasizes that “rangeland fire (both lightning-caused and human-caused fire) in sagebrush ecosystems is one of the 

primary risks to the greater sage-grouse, especially as part of the positive feedback loop between exotic invasive 

annual grasses and fire frequency”... For this reason, the ARMPAs seek to improve efforts to strategically develop 

1

fuel breaks, in collaboration with GRSG biologists... However, prescribed fire will not be used in sagebrush steppe.”

With fire listed as one of the threats to GRSG and its habitat, the corresponding “Key Management Response” would 

be:

 Identify and prioritize areas that are vulnerable to wildfires and prescribe actions important for GRSG 

protection. 

 Restrict the use of prescribed fire for fuel treatments. 

 Prioritize post-fire treatments in SFAs, other PHMAs, and GHMAs. 

 

1

 ROD and ARMPAs for the Great Basin GRSG Sub-Regions, pp 1-26 – 1-27. 
PROPOSED ACTION AND PURPOSE AND NEED

1.7 Project Goals and Objectives 

Based on the desired future conditions and key concerns for resources on the 3 Bars ecosystem, the BLM identified 

specific objectives for the four treatment groups (Table 1-2). These objectives were used to identify potential 

treatments that could be used to achieve the desired conditions. Treatments proposed by the BLM are discussed in 

Chapter 2. 

1.8 Scope of Analysis and Decisions to be Made 

The National Environmental Policy Act (NEPA) mandates that every federal agency prepare a detailed statement of 

the effects, or EIS, of “major federal actions significantly affecting the quality of the human environment” (42 USC § 

4321 et seq.; USDOI BLM 2008a). An EIS is intended to provide decision-makers and the public with a complete and 

objective evaluation of significant environmental impacts, beneficial and adverse, resulting from the proposed action 

and several reasonable alternatives. Given the magnitude of treatments and the resulting potential for significant 

cumulative effects from the 3 Bars Project, the BLM has determined that an EIS is warranted to evaluate impacts 

from the 3 Bars Project. 

This 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 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. 

This EIS does not evaluate vegetation management that is primarily focused on commercial timber or other woodland 

product enhancement or use activities that are not related to improving woodland or rangeland health or work 

authorized under the Healthy Forests Restoration Act of 2003. 

Commercial timber activities conducted with the primary purpose of providing a sustained yield of timber volume to 

commercial industries are not included in this EIS. Rather, they represent a manner of vegetation harvest (in 

otherwords [i.e.], the species [product] is removed and replanted for future harvest). As part of the 3 Bars Project, 

however, the BLM would designate some treatment areas for small-scale commercial harvest to help meet restoration 

goals. Commercial timber allocations and sustainable harvest were previously analyzed in the Shoshone-Eureka 

RMP. 

3 Bars Project Final EIS 1-10 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-11 October 2016 

TABLE 1-1 

Primary Resource Management Plan Objectives for the Shoshone-Eureka Resource Area 

Riparian and 

Aquatic 

Habitat 

Management

 Improve priority riparian and stream habitat to “good” or “better” condition and prevent the 

decline of remaining areas.

 Improve and maintain habitat for state-listed sensitive species and federally listed threatened and

endangered species. 

Woodland 

Products

 Manage suitable woodlands for optimum production of woodland products on a sustained-yield 

basis, while protecting sensitive resources.

 Maintain, where necessary for management, those access routes currently servicing pinyon-juniper 

harvest areas.

 Set aside certain historical pinyon-juniper woodland areas for non-commercial pine nut gathering 

by Nevada Native Americans and all other members of the public.

Wildlife 

Habitat 

Management

 Maintain and improve wildlife habitat while providing for other appropriate resource uses.

 Provide habitat sufficient to allow big game populations to achieve reasonable numbers in the 

long-term.

 Improve and maintain habitat for state-listed sensitive species and federally listed threatened and

endangered species.

Wild Horse 

Use

 Manage viable herds of sound, healthy, wild horses in a wild and free-roaming state.

 Initially manage wild horse populations at existing numbers based on 1982 aerial counts and 

determine if this level of use can be maintained.

 Manage wild horses within the areas that constituted their habitat when the Wild and Free-roaming 

Horse and Burro Act became law in 1971.

Livestock 

Grazing

 Initially manage livestock at existing levels and determine if such use can be maintained.

 Establish a grazing management program designed to provide key forage plants with adequate rest 

from grazing during critical growth periods.

 Achieve, through management of the livestock and wild horses, utilization levels consistent with 

those recommended by the 1981 Nevada Range Studies Task Group to allow more plants to 

complete growth cycles and to increase storage of reserves for future growth.

 Increase vegetation production while protecting sensitive resources.
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-12 October 2016 

TABLE 1-2 

Restoration Goals for the 3 Bars Ecosystem 

Riparian 

Treatment 

Units

 Improve the extent and vigor of riparian plant communities. 

 Protect riparian community infrastructure. 

 Provide for vegetative and ecological diversity. 

 Improve riparian area resilience to wildfire effects and flood events. 

 Provide links with natural fuel breaks in adjacent areas. 

 Improve the physical and ecological processes of streams, meadows, springs, and seeps by 

mitigating disruptions to the soil, plant, and/or hydrologic components. 

 Improve wetland and riparian function by improving road locations or implementing best 

management practices in areas where roads inhibit function.

 Improve water retention, infiltration, and residence time by reducing historic watershed 

changes that have increased overland flow rates and reduced infiltration rates.

 Ensure water quality parameters are in compliance with State of Nevada water quality 

standards.

 Ensure conditions and trends are progressing towards desired conditions for a given site.

 Improve in-stream habitat conditions for Lahontan cutthroat trout and other aquatic species 

by enhancing in-stream characteristics within existing and potential Lahontan cutthroat trout 

habitat: 

o Ensure stable dimension, pattern, and profile of steam channels.

o Spawning beds should be well oxygenated and relatively silt-free.

o Develop habitat conditions needed by fish and wildlife, including Lahontan 

cutthroat trout.

Aspen 

Treatment 

Units

 Promote and maintain healthy aspen communities.

 Stimulate aspen stand suckering through selective removal of aspen trees. 

 Establish a minimum of three distinct age classes within stands. 

Pinyon-juniper 

Treatment 

Units

 Reduce the severity of future wildfires in the project area by reducing hazardous fuels and 

provide for a safer fire suppression environment. 

 Reduce the likelihood for loss of life and property and natural resources due to catastrophic 

wildfire.

 Provide links with natural fuel breaks in adjacent areas. 

 Improve pinyon-juniper woodland health. 

 Reduce pinyon-juniper encroachment onto sagebrush communities. 

 Improve wildlife habitat in the long-term. 

 Protect Greater sage-grouse habitat from impacts of catastrophic wildfire.

 Improve and maintain Greater sage-grouse habitat connectivity. 

 Establish and maintain resistance and resilient sagebrush vegetation communities to reduce 

Greater sage-grouse habitat fragmentation.

 Protect community infrastructure. 

 Provide for vegetative and ecological diversity. 

 Provide forest products for commercial use. 

 Maintain areas of Fire Regime Condition Class I in order to maintain ecosystem health and 

keep catastrophic wildfire risk from exceeding a “moderate” rating.

 Improve ecosystem health and reduce catastrophic wildfire potential by improving Fire 

Regime Condition Class from III and II to Class I. See Section 3.14.2.3 for a discussion of 

Fire Regime Condition Classes.

 Improve stand health of aspen and mountain mahogany by removing competition. 

 Downgrade fire risk rating by at least 1 step by reducing above-ground biomass (all burnable 

vegetation) in identified areas by 50 to 95 percent. 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-13 October 2016 

TABLE 1-2 (Cont.) 

Restoration Goals for the 3 Bars Ecosystem 

Sagebrush 

Treatment 

Units

 Promote and maintain healthy native plant communities. 

 Increase plant community diversity and health by improving the regeneration and vigor of 

desirable species.

 Improve rangeland conditions by encouraging understory species and desired plant 

communities.

 Improve the frequency and production of desired plant species at rangeland sites where the 

desired dominant and/or co-dominant species are missing. 

 Improve and maintain Greater sage-grouse habitat connectivity. 

 Establish and maintain resistance and resilient sagebrush vegetation communities to reduce 

Greater sage-grouse habitat fragmentation.

 Reduce or remove pinyon-juniper from sagebrush vegetative communities providing Greater 

sage-grouse habitat.

 Provide for vegetative structure and ecological diversity. 

 Reach the potential of any given site based on the Ecological Site Description (ESD) and 

associated State and Transition Model (STM).

 Manage for the best of the current state if one or more of the following factors is present: 1) 

there is no restoration path with current knowledge or technology based on STM; 2) Cost is 

too high to justify; 3) Likelihood of success is low; or 4) Higher resource management 

priorities.

 Increase the distribution and abundance of traditional, edible, and medicinal plants by 

improving the relative abundance of desirable plant species in previously identified locations 

(obtained through Native American consultation). Sustain the regeneration and recruitment 

of desirable species such as aspen, bitterbrush, and mountain mahogany.

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. 

The BLM is currently authorized to use herbicides using ground-based equipment to control local occurrences of 

noxious weeds and other invasive non-native vegetation, and using fixed-wing aircraft and helicopters to control 

cheatgrass, as authorized by the 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), and the Environmental Assessment Integrated Weed Management Plan Battle Mountain 

District Nevada Mt. Lewis Field Office and Tonopah Field Office (USDOI BLM 2009b). Thus, this EIS does not 

propose new herbicide treatments. 

This EIS does not evaluate policies and programs associated with Emergency Stabilization and Burned Area 

Rehabilitation, which mitigates the adverse effects of fire on the soil and vegetation in a cost-effective and expeditious 

manner and to minimize the possibility of wildfire recurrence or invasion of weeds. The terms rehabilitation and 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-14 October 2016 

restoration are often used synonymously. Rehabilitation is the repair of a wildfire area utilizing native and/or nonnative plant species to obtain a stable plant community that will protect the burned area from erosion and invasion of 

weeds. Restoration is defined as the process of returning ecosystems or habitats to their original structure and species 

composition. 

1.9 Documents that Influence the Scope of the EIS 

Much of the scope of this EIS is based on BLM Handbook H-1740-2, Integrated Vegetation Management (USDOI 

BLM 2008b), and Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field Office and 

Tonopah Field Office (USDOI BLM 2009b). These documents provide expectations for a more consistent and 

unified approach to managing vegetation on public lands and clarify multi-program goals, objectives, and priorities 

relative to maintaining and restoring ecologically diverse, resilient, and productive native plant communities. 

The Shoshone-Eureka RMP and associated ROD and amendments form the land use plan that guides resource 

management on public lands within the Shoshone-Eureka Resource Area, including the 3 Bars ecosystem. The RMP 

provides for multiple-use management through protection of fragile and unique resource values, such as riparian and 

stream habitat, while not overly restricting the ability of the other resources to provide for the production of 

commodity values on public lands. 

The September 2015 Nevada and Northeastern California Greater Sage-Grouse Approved Resource Management 

Plan Amendment and Record of Decision (ARMPA) lists Required Design Features in association with fire 

management and the protection of sagebrush habitat for the GRSG. 

This EIS tiers to the Record of Decision Vegetation Treatments on BLM Lands in 13 Western States (13-States EIS),

17-States PEIS, and Vegetation Treatments on Bureau of Land Management Lands in 17 Western States 

Programmatic Environmental Report (17-States PER; USDOI BLM 1991a, 2007b, c). 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. 

Other documents and policies that influence the scope of this EIS include: 

 National Fire Plan (USDOI and USDA 2001). 

 Chapter 1 (Interagency Burned Area Emergency Stabilization and Rehabilitation) in USDOI Department 

Manual 620 (Wildland Fire Management; USDOI 2004). 

 A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment 10-Year 

Comprehensive Strategy Implementation Plan (USDOI and USDA 2006a). 

 Protecting People and Sustaining Resources in Fire Adapted Ecosystems: A Cohesive Strategy (USDOI and 

USDA 2006b). 

 Healthy Lands Initiative of 2007 (USDOI 2010a). 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-15 October 2016 

These documents provide policy and guidance for hazardous fuels reduction and land restoration activities to reduce 

the risk of wildfires and restore fire-adapted ecosystems, and to rehabilitate and restore lands damaged by wildfires. 

In addition, the Partners Against Weeds - An Action Plan for the BLM (USDOI BLM 1996), and Meeting the Invasive 

Species Challenge Management Plan (National Invasive Species Council 2001), were consulted to identify 

appropriate actions to control noxious weeds and other invasive non-native vegetation on public lands. The Great 

Basin Restoration Initiative provides goals and methods to maintain or restore the Great Basin’s native plant 

communities that in turn provide habitat for livestock, wildlife, and wild horses (USDOI BLM 2010a, b). The Nevada 

Northeastern Great Basin Resource Advisory Council’s Standards and Guidelines for Grazing and Wild Horses and 

Burros outlines guidelines for maintaining healthy wild horse and burro herds on herd management areas 

administered by the BLM within the designated geographic area of the Northeastern Great Basin (USDOI 2007b). 

BLM Manual 6280, Management of National Scenic and Historic Trails and Trails under Study or Recommended as 

Suitable for Congressional Designation, provides guidance on management of the Pony Express National Historic 

Trail. 

1.10 Relationship to Statutes, Regulations, and Policies 

1.10.1 Federal Laws, Regulations, and Policies that Influence Restoration 

Treatments 

Several federal laws, regulations, and policies guide BLM management activities on public lands. The Federal Land 

Policy and Management Act of 1976 directs the BLM to manage public lands “in a manner that will protect the 

quality of scientific, scenic, historic, ecological, environmental, air and atmospheric, water resources and 

archeological values” and to develop RMPs consistent with land use plans of state and local governments to the extent 

that BLM programs also comply with federal laws and regulations (USDOI BLM 1976). The Taylor Grazing Act of 

1934 introduced federal protection and management of public lands by regulating grazing on public lands. The Public 

Rangelands Improvement Act of 1978 requires the BLM to manage, maintain, and improve the condition of the 

public rangelands so that they become as productive as feasible. 

Numerous other laws, regulations, and policies pertain to the protection of resources found in the 3 Bars ecosystem. 

These are discussed in Chapter 3 under the resources to which they apply. 

1.10.2 NEPA Requirements of the Project 

The intent of this EIS is to comply with the NEPA by assessing the program impacts of proposed treatments on lands 

within the 3 Bars ecosystem. Additional guidance for NEPA compliance and for assessing impacts is provided in the 

Council on Environmental Quality (CEQ) Regulations for Implementing the Procedural Provisions of NEPA (40 CFR 

§§ 1500-1508), and the BLM National Environmental Policy Act Handbook H-1790-1 (USDOI BLM 2008a). 

In general, the NEPA process may be done at multiple scales depending on the scope of the proposal. The broadest 

level is a national-level programmatic study. This level of study contains broad and regional descriptions of resources, 

provides a broad environmental impact analysis, including cumulative impacts, and focuses on general policies. 

Additionally, it provides an umbrella Endangered Species Act Section 7 consultation for the broad range of activities 

described in the EIS. The 17-States PEIS, which provided Bureau-wide decisions on herbicide use for vegetation 

management, represents an example of a national-level programmatic study. 
PROPOSED ACTION AND PURPOSE AND NEED

The next scale of analysis represents a regional level of analysis, and may be prepared for regional or statewide 

programs. A regional level of analysis would typically focus on methods to be used, regional or statewide issues, and 

provide an Endangered Species Act Section 7 consultation focused on regional issues. The Great Basin Restoration 

Initiative and the Cooperative Shrub-Steppe Restoration Partnership represent examples of these types of analyses and 

programs. 

Below the regional scale of analysis there is the option to prepare a district or field office level of analysis. The 

Shoshone-Eureka RMP represents the district or field office level of analysis. This level of analysis may be prepared 

for district or field office-wide programs. The analysis is tiered to either or both of the two higher scales of analysis 

and focuses on impacts of methods and options for local projects. 

The local scale provides project level analysis and is prepared for site-specific proposals. The analysis may be tiered 

to any or all of the above scales of analysis. The analysis focuses on site-specific impacts of implementing a single 

management proposal as identified through local planning. Examples include, but are not limited to, noxious weed 

control, prescribed fire, hazardous fuel reduction, and wildland-urban interface projects. This EIS for the 3 Bars 

Project is an example of project level analysis. 

Tiering allows local offices to prepare more specific environmental documents without duplicating relevant portions 

of other NEPA documents. Analyses done by local BLM offices will be prepared in accordance with NEPA guidance 

and will include public involvement as regulated by the CEQ, as well as follow USDOI and BLM manual and 

handbook guidance and pertinent instruction memoranda. To the extent practicable, existing environmental analyses 

were used in analyzing impacts associated with the 3 Bars Project, including information contained in documents 

listed in a previous section, Documents that Influence the Scope of the EIS. 

1.11 Interrelationship and Coordination with Agencies 

In its role as manager of approximately 4.4 million acres in central Nevada, the BLM Mount Lewis Field Office has 

developed numerous relationships at the federal, tribal, state, and local levels, as well as with conservation and 

environmental groups with an interest in resource management, and members of the public that use public lands or are 

affected by activities on public lands. The lands administered by the Mount Lewis Field Office are depicted on 

Figure 1-2. 

1.11.1 Cooperating Agencies 

Federal, state, and local regulatory agencies with jurisdiction by law or special expertise relevant to the 3 Bars Project 

were solicited at the beginning of the NEPA process to determine their interest in participating as a cooperating 

agency. The cooperating agency role derives from the NEPA, which called on federal, state, and local governments to 

cooperate with the goal of achieving “productive harmony” between humans and their environment. The CEQ’s

regulations implementing NEPA allow federal agencies (as lead agencies) to invite tribal, state, and local 

governments, as well as other federal agencies, to serve as cooperating agencies in the preparation of environmental 

impact statements. Agencies that have been granted cooperating agency status for preparation of this EIS are: 

 National Park Service, National Trails Intermountain Region 

 Nevada Department of Wildlife (NDOW) 

 Eureka County Board of Commissioners 

3 Bars Project Final EIS 1-16 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-17 October 2016 

In 2005, the BLM amended its planning regulations to ensure that staffs at all levels—state office or field office—

engage their governmental partners consistently and effectively through the cooperating agency relationship whenever 

land use plans are prepared or revised. The BLM was the first federal agency to promulgate regulations that establish 

a consistent, permanent role for cooperating agencies. The BLM believes that by working closely with state, local, 

tribal, and federal government partners, the agency will improve communication and understanding, identify common 

goals and objectives, and enhance the quality of our management of the public lands. 

1.11.2 Other Governmental Agencies 

Several federal, state, and local agencies that are not participating as cooperating agencies administer laws that govern 

activities on public lands. The U.S. Fish and Wildlife Service (USFWS), Advisory Council on Historic Preservation, 

Agricultural Research Service, USDA Natural Resources Conservation Service, USEPA, and U.S. Geological Survey 

(USGS) also have an interest in the project. State agencies, such as the Nevada Department of Agriculture, Nevada 

Division of Environmental Protection, Nevada Division of Forestry, Nevada State Historic Preservation Office 

(SHPO), University of Nevada Cooperative Extension, and Nevada State Clearinghouse, play vital roles in 

coordination with national, tribal, state, county, and private interests through their oversight and coordination 

responsibilities. Local agencies, such as the Eureka County Department of Natural Resources, have an interest in 

resources of interest to local residents. 

These agencies and the BLM regularly coordinate on resource management and control efforts to benefit all federally 

administered lands. Other local coordination includes the sharing of equipment, training, and financial resources, and 

developing resource management plans that cross administrative boundaries. 

1.11.3 Non-governmental Organizations 

The BLM coordinates at the national and local levels with several resource advisory groups and non-governmental 

organizations, including BLM Resource Advisory Councils, Western Governors’ Association, National Association 

of Counties, Western Area Power Administration, National Cattlemen’s Beef Association, National Wool Growers 

Association, Society of American Foresters, and American Forest and Paper Association. The BLM also 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, 

Center for Biological Diversity, and National Mustang Association. These groups provide information on strategies 

for noxious weed and other invasive non-native establishment and spread prevention and treatment methods, use of 

domestic animals to control noxious weeds and other invasive non-native vegetation, landscape-level planning, 

vegetation monitoring, techniques to restore land health, and methods to ensure that prescribed burning does not 

impact the safe operation of power transmission lines. 

1.12 Consultation and Coordination 

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 (Biological Assessment; USDOI 

BLM 2013a, 2014). The Biological Assessment evaluated the likely impacts to listed species, species proposed for 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

80

50

21

82

305

844

376

8

2

278

21

3 Bars

Project

Area

Nye

County

Lander

County

Eureka

County

Austin Eureka

0 5 10 15 30

Miles

0 5 10 15 20 40

Kilometers

Legend

Land Status

Bureau of Land Management

Bureau of Reclamation

Native American Reservation

U.S. Forest Service

Private

Interstate Highway

U.S. Highway

State Highway

Major Road

BLM Field Office

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Figure 1-2

Public Lands Administered by

the Mount Lewis Field Office

3 Bars Ecosystem and

Landscape Restoration Project

Source: BLM 2012a.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
PROPOSED ACTION AND PURPOSE AND NEED

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. 

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. Consultation is ongoing and will be completed in accordance to the programmatic agreement 

specific to the 3 Bars Project. Coordination and consultations with Native American tribes may be required during 

implementation of projects at the local level (Appendix B).

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

an 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, 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 

1.13 Public Involvement and Analysis of Issues 

1.13.1 Public Scoping 

The purpose of public scoping is to focus the analysis in an EIS on the significant issues and reasonable alternatives in 

order to eliminate extraneous discussion and to reduce the length of an EIS. Scoping is an ongoing process that 

involves the public in developing an EIS. 

On January 25, 2010, the BLM published a Notice of Intent notifying the public that the BLM had formed an 

interdisciplinary team to prepare an EIS for proposed restoration activities for the 3 Bars Project (USDOI BLM 

2010c). The Notice of Intent initiated the formal public scoping period for the project. The Notice of Intent stated that 

comments on issues could be submitted in writing until February 24, 2010, in order to be considered in the 

development of the Draft EIS for the 3 Bars Project. 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, 

3 Bars Project Final EIS 1-19 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

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. 

1.13.1.1 Public Scoping Meetings 

Two public scoping meetings were held, one in Battle Mountain, Nevada, on February 22, and one in Eureka, 

Nevada, on February 23, 2010. These meetings were conducted in an open-house style where BLM resource 

specialists were able to answer questions from the public about the 3 Bars Project. Informational displays were 

provided at the meeting, and handouts describing the project, the NEPA process, and issues and alternatives were 

given to the public. A formal presentation was given to the public with additional information on 3 Bars Project goals 

and objectives. In addition to BLM and EIS contractor personnel, 6 individuals attended the meeting in Battle 

Mountain, and 18 individuals attended the meeting in Eureka. 

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

during 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. Table 1-3 lists the agencies 

and organizations that provided comments during public scoping. 

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 on the BLM NEPA 

register. 

1.13.1.2 Scoping Issues and Concerns 

Table 1-4 lists the number of comments received by subject areas in this EIS. Vegetation treatment planning and 

management and vegetation treatment methods were the two most important topics to the public. A wide range of 

issues was identified during scoping. Issues accounting for over 80 percent of the comments received during scoping 

are listed in Table 1-5. A list of all issues identified during scoping can be found in the Scoping Report. 

The primary issue of controversy identified through scoping was the BLM’s proposed treatment approaches for the 

restoration of the 3 Bars ecosystem. Respondents were 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. The public was also concerned about SOPs that would 

be applied during treatments to reduce their effects on natural, cultural, and social resources (see Appendix C, 

Standard Operating Procedures). All relevant issues identified through public scoping, however, have been analyzed 

in this EIS to the extent practicable. 

1.13.1.3 Development of the Alternatives 

The public scoping comments influenced the development of several 3 Bars Project ecosystem resource management 

alternatives. Numerous respondents suggested that the BLM avoid using fire and herbicide treatment methods, or only 

use manual methods, including the use of hand tools such as chainsaws and weed whackers. Based on these 

3 Bars Project Final EIS 1-20 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

comments and NEPA-review requirements, four alternatives addressing restoration and management of the 3 Bars 

ecosystem are evaluated in this EIS. These alternatives are discussed in detail in Chapter 2, Alternatives. 

1.13.1.4 Issues Not Addressed in the 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 the 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 project area. 

1.13.2 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 and the stand-alone Summary. 

A public meeting was held in Eureka, Nevada, on November 7, 2013. This meeting allowed the BLM to provide an 

overview of the alternatives and discuss the project with 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 agency responses to specific comments. 

3 Bars Project Final EIS 1-21 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

TABLE 1-3 

Agencies/Organizations/Individuals Providing Written Comments during Public Scoping

3 Bars Project Final EIS 1-22 October 2016 

Individual/Organization Number of Individual 

Comments Provided

Center for Biological Diversity 29

Eureka County Natural Resources Advisory 

Commission 57

National Mustang Association, Inc. 2

Nevada State Clearinghouse 2

Paiute Pipeline Company 1

State of Nevada Department of Wildlife 25

University of Nevada Cooperative Extension 11

U.S. Environmental Protection Agency 2

Western Watersheds Project 345

Individuals 123

TABLE 1-4 

Comment Subject Breakdown

Comment Subject Number of 

Comments1 Percent of Total

Proposed Action and Purpose and Need for Action

Proposed Action 4 0.6

Purpose and Need for Proposed Action 2 0.3

Scope of Analysis and Decisions to be Made 1 0.2

Relationship to Statutes, Regulations, and Policies 9 1.4

Interrelationships and Coordination with Agencies 13 2.0

Public Involvement and Analysis of Issues 9 1.4

Alternatives Including the Proposed Action

Vegetation Treatment Planning and Management 53 8.2

Description of Treatment Methods 45 6.9

Description of Action Alternatives 6 0.9

Proposed Action – Alternative A 3 0.5

No Action Alternative – Alternative D 2 0.3

Other Possible Alternatives 13 2.0

Alternatives Considered but Eliminated from Analysis 3 0.5

Treatment Standard Operating Procedures 24 3.7

Special Precautions 1 0.2

Studies and Monitoring 33 5.1

Coordination and Education 5 0.8

Mitigation 3 0.5

Affected Environment

Affected Environment – General 2 0.3

Introduction and Study Area 4 0.6
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-23 October 2016 

TABLE 1-4 (Cont.) 

Comment Subject Breakdown

Comment Subject Number of 

Comments1 Percent of Total

Land Use 6 0.9

Climate and Air Quality 1 0.2

Soil Resources 5 0.8

Water Resources (Quantity and Quality) 23 3.5

Wetlands, Floodplains, and Riparian Zones 6 0.9

Vegetation Resources 72 11.1

Fish and other Aquatic Resources 6 0.9

Wildlife Resources 39 6.0

Livestock Grazing 32 4.9

Wild Horses 20 3.1

Wilderness and other Special Areas 2 0.3

Cultural Resources 3 0.5

Social and Economic Values 5 0.8

Environmental Consequences

Environmental Consequences – General 6 0.9

Assumptions for Analysis 10 1.5

Land Use 9 1.4

Climate and Air Quality 6 0.9

Topography, Geology, and Minerals 4 0.6

Soil Resources 2 0.3

Water Resources (Quantity and Quality) 6 0.9

Wetlands, Floodplains, and Riparian Zones 3 0.5

Vegetation Resources 53 8.2

Fish and other Aquatic Resources 2 0.3

Wildlife Resources 10 1.5

Special Status Species 4 0.6

Livestock Grazing 6 0.9

Wild Horses 21 3.2

Wilderness and other Special Areas 4 0.6

Cultural Resources 2 0.3

Recreation 5 0.8

Social and Economic Values 13 2.0

Human Health and Safety 1 0.2

Cumulative Effects Analysis 19 2.9

Other Comments

References 4 0.6

Glossary, Acronyms, and Abbreviations 3 0.5

Comments not Evaluated in this EIS 2 0.3

Total Comments 650 100

1 Total number of comments is greater than actual number of comments provided because a few comments were 

referenced under more than one comment subject.
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-24 October 2016 

TABLE 1-5 

Key Issues (and Number of Comments) Identified during Scoping 

Issues Number of 

Comments

Program Purpose and Need

Evaluate land use (grazing, fire suppression, and mining) on ecosystem health, and provide baseline studies 44

Focus on the recovery and viability of listed, rare, and imperiled species, and provide baseline assessments 27

Work closely with agencies, conservation groups, and private landowners on restoration activities 15

Address how the EIS will impact RMPs and other planning; update RMP 13

Focus on long-term ecosystem sustainability and biological diversity, and clearly define restoration objectives 8

Provide an explanation of the rationale for why these lands need treatment 8

Provide an evaluation and assessment of past treatments on District lands 8

Focus on addressing the causes rather than treating the symptoms 7

Provide assessment of areas that are functioning well 5

Proposed Action

Ensure viable wild horse herds, and provide historic and current conditions of herds 30

Do not thin re-forested/persistent woodlands, protect old growth, and cut only younger age class trees 26

Ensure compliance with existing statutes, regulations, and policies 12

Treatments should be less invasive/more “passive,” and avoid additional disturbances due to treatments 9

Consider all treatment methods, and allow for innovative solutions 7

Describe where acres will be treated and by what methods, and treat areas uniquely 6

Maintain grazing permits and avoid livestock limitations 6

Use selective hand-cutting/drilling and avoid mechanical removal 5

Determine appropriate forage allocations, and distinguish between livestock, wild horses, and big game 5

Other Potential Alternatives

Fuels reduction should only occur in wildland urban interface or where there is a threat of significant wildfire 5

Develop a prescription grazing alternative 5

Restoration Goals and Best Management Practices

Monitor success of treatments and establish performance measures to determine treatment success 35

Use current and consistent ecological concepts, terminology, and theory, and provide methods 31

Restrict grazing during treatments and on un-impacted lands, and provide rest periods following treatments 22

Restoration efforts should focus on restoring native vegetation, and focus on areas seeded to exotics 20

Preserve sagebrush and sagebrush habitat 14

Use native plants and certified native seed, where practical, for revegetation 9

Expand/adjust the boundaries of the project, use natural boundaries, and focus on human-interface areas 5

Focus restoration efforts on restoring natural disturbance regimes, ecosystem processes, and functions 4

Environmental Consequences

Address how treatments would affect the local and regional economy 20

Address the impacts of project activities on available habitat and habitat fragmentation 11

Evaluate the effects of herbicide treatments on non-target species, on water supplies, and on human health 9

Address the impacts of past and future land uses on anticipated success of vegetation treatments 6

Evaluate the potential for return of invasive species following treatment 6

Address the role of grazing in contributing to or controlling weeds, invasive vegetation, and hazardous fuels 6

Address the impacts of treatments on fire/historical range of variation 6

Address the impacts of multiple treatments and application of multiple chemicals in a single area 5

Address economic and habitat value of pinyon pine 5

Evaluate the impacts of project activities on climate change and air quality 5

Address the impacts of roads and off-road vehicle use on vegetation conditions and treatments 4

Evaluate the impacts of treatments on the Pony Express Trail and Wilderness Study Areas 4
PROPOSED ACTION AND PURPOSE AND NEED

1.14 Limitations of this EIS 

The analyses of impacts of the 3 Bars Project treatments proposed in this EIS are based on the best and most recent 

information available. As is always the case when developing management direction for a wide range of resources, 

not all information that might be desired is available. Council on Environmental Quality regulations provide direction 

on how to proceed with the preparation of an EIS when information is incomplete or unavailable: 

“If the information relevant to reasonably foreseeable significant adverse impacts cannot be obtained because the 

overall costs of obtaining it are exorbitant or the means to obtain it are not known, the agency shall include within the 

environmental impact statement: 1) a statement that such information is incomplete or unavailable; 2) a statement of 

the relevance of the incomplete or unavailable information to evaluating reasonably foreseeable significant adverse 

impacts on the human environment; 3) a summary of existing credible scientific evidence which is relevant to 

evaluating the reasonably foreseeable significant adverse impacts on the human environment; and 4) the agency’s 

evaluation of such impacts based upon theoretical approaches or research methods generally accepted in the scientific 

community. For the purposes of this section, “reasonably foreseeable” includes “impacts which have catastrophic 

consequences, even if their probability of occurrence is low, provided that the analysis of the impacts is supported by 

credible scientific evidence, is not based on pure conjecture, and is within the rule of reason” (40 CFR § 1502.22 b).

For this EIS, the primary effect of unavailable information is the inability to quantify certain impacts. Where 

quantification was not possible, impacts have been described in qualitative terms. Existing credible scientific evidence 

that is relevant to evaluating the reasonably foreseeable adverse impacts on the natural, human, and socioeconomic 

environment and support the BLM’s evaluation of such impacts have been included in Chapter 3, in the appendices 

that accompany this EIS, and in supporting documents that were prepared for this EIS, and are available on the 3 Bars 

Project website on the BLM NEPA Register. 

If changes in the proposed project activities and levels occur in the future, they would be reviewed to determine 

whether additional environmental documentation is needed, including an Environmental Assessment or EIS. This EIS 

would serve as a source document that would be used to support any additional documentation that may be required. 

Any new or additional actions would also be evaluated for compliance with federal, state, and local laws and 

regulations prior to implementation, and the public would be informed of any major actions that may be considered 

for implementation by the BLM as part of the NEPA compliance process. 

3 Bars Project Final EIS 1-25 October 2016 
PROPOSED ACTION AND PURPOSE AND NEED

3 Bars Project Final EIS 1-26 October 2016 

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CHAPTER 2 

ALTERNATIVES 
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3 Bars Ecosystem and Landscape Restoration Draft EIS 2-iii October 2016 

TABLE OF CONTENTS 

Page 

2.1 Introduction .....................................................................................................................................................2-1

2.2 Summary of Major Changes between the Draft and Final EIS .....................................................................2-1

2.3 Description of the Action Alternatives (Alternatives A, B, and C) ...............................................................2-3

2.3.1 Alternative A — All Treatment Methods Alternative (Preferred Alternative).................................2-3

2.3.2 Alternative B — No Fire Use Alternative ...................................................................................... 2-21

2.3.3 Alternative C — Minimal Land Disturbance Alternative .............................................................. 2-21

2.4 Description of the No Action Alternative - Alternative D - Continue Current Management ................... 2-22

2.5 Development of the Action Alternatives ..................................................................................................... 2-22

2.5.1 Treatment Area Selection ................................................................................................................ 2-22

2.5.2 Site-specific Project Selection ......................................................................................................... 2-22

2.5.3 Treatment Methods .......................................................................................................................... 2-23

2.5.4 Standard Operating Procedures and other Resource Protections ................................................... 2-30

2.5.5 Monitoring ....................................................................................................................................... 2-30

2.5.6 Coordination and Education ............................................................................................................ 2-32

2.6 Summary of Alternatives Analyzed in this EIS .......................................................................................... 2-32

2.7 Alternatives Considered but not Further Analyzed .................................................................................... 2-32

2.8 Mitigation ..................................................................................................................................................... 2-36

2.9 Summary of Impacts by Alternative ........................................................................................................... 2-36

List of Tables 

2-1 Responses of the Alternatives to the Project Purposes......................................................................................... 2-33 

2-2 Summary and Comparison of Effects on Resources by Alternative ................................................................... 2-37

List of Figures 

2-1 Project Treatment Sites for Riparian Treatment Areas ...........................................................................................2-5 

2-2 Project Treatment Sites for Aspen Treatment Areas ............................................................................................ 2-10

2-3 Project Treatment Sites for Pinyon-juniper Treatment Areas .............................................................................. 2-13

2-4 Project Treatment Sites for Sagebrush Treatment Areas ..................................................................................... 2-19 
INTRODUCTION 

3 Bars Ecosystem and Landscape Restoration Draft EIS 2-iv October 2016 

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ALTERNATIVES

CHAPTER 2 

ALTERNATIVES

2.1 Introduction 

This chapter discusses the proposed and alternative actions that have been identified to promote a sustainable, healthy, 

and resilient landscape on the 3 Bars ecosystem. The proposed and alternative actions are those that could be taken to 

feasibly attain the BLM’s objectives of improving the health of the 3 Bars ecosystem and reducing the risk factors that 

are contributing to its decline. Alternatives were developed in response to the various issues and alternative proposals 

raised during public scoping, and during public review of the Draft EIS, and still meet the project’s purpose and need 

as described in Chapter 1. Alternatives were also developed to ensure BLM compliance with federal, tribal, state, and 

local regulations, and the Shoshone-Eureka RMP. 

As described in the Scoping Report (AECOM 2010), alternative treatment proposals were generated during public 

scoping and focused primarily on the types of restoration treatments that would be used by the BLM. The proposals 

centered on limiting treatment acres, limiting livestock grazing, limiting the use of herbicides and prescribed fire, 

using only passive treatment methods, and restoring land using only native vegetation. Several of these proposals 

were also made during the Draft EIS comment period. 

To help the reader better understand the alternative proposals, this chapter describes the action alternatives and the 

project components that are part of the action alternatives, including the proposed treatment areas, and methods. This 

is followed by a description of the No Action Alternative, and a description of alternatives considered but not 

evaluated in the EIS. Finally, the chapter provides a summary of environmental, cultural, and socioeconomic impacts 

that would result from implementation of the alternatives. 

Four alternatives are evaluated in this 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. 

2.2 Summary of Major Changes between the Draft and Final 

EIS

Several major changes were 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. These changes (and Section where change is made) are as follows: 

1. No range improvements (such as livestock troughs, permanent fencing, etc. ) would be included as part of 

restoration treatments (Section 2.3). 

2. All treatment units would be surveyed for cheatgrass prior to treatment, and treated as needed to ensure 

success of the treatments (Section 2.3). 

3 Bars Project Final EIS 2-1 October 2016 
ALTERNATIVES 

3. No chaining would be implemented within the 3 Bars Project area (Section 2.3.1). 

4. Vegetation treatment goals and objectives have been expanded upon for treatment types (riparian, aspen, 

pinyon-juniper, and sagebrush; Section 2.3.1). 

5. Chainsaw hand thinning would be the preferred method for tree cutting in riparian and aspen treatment units, 

and in Phase I pinyon-juniper stands in pinyon-juniper and sagebrush treatment units. Chainsaw hand 

thinning would also be the preferred method in Phase II and III stands in sagebrush treatment areas. Other 

methods would be considered, however, on a case-by-case basis (Sections 2.3.1). 

6. Mechanical equipment would not be used within the Willow Creek stream channel, but would be used to 

place erosion control features within the channel or to improve stream condition (Section 2.3.1.1). 

7. Only existing permanent fencing, or small, temporary exclosures (let-down fencing constructed of barbed 

wire and posts that can be let-down easily to allow animals to pass, or electric wire fencing), would be used 

to exclude livestock, wild horses, and other wild ungulates from treatment units until seeded and planted 

areas become established (Sections 2.3.1.1, 2.3.1.2). 

8. Prescribed fire, or wildland fire for resource benefit, would not be used as a primary treatment method in 

riparian, aspen, or sagebrush treatment units, but could be used in Phase II and III pinyon-juniper stands in 

pinyon-juniper treatment units and to remove non-native vegetation on the Rocky Hills and West Simpson 

Park sagebrush treatment unit (Section 2.3.1; see discussion of pinyon-juniper phases in Section 2.3.1.3). 

9. Treatment areas would be surveyed for mountain mahogany, pinyon-juniper, and limber pine old-growth 

trees before conducting treatments. Areas containing mountain mahogany, old-growth limber pine, or oldgrowth pinyon-juniper trees would be avoided (Section 2.3.1.3). 

10. Fuel breaks would be constructed along existing roads and two-tracks where possible using narrow and 

small-scale green-stripping. Fuel breaks would not be constructed where they could adversely impact 

important cultural or natural resources (Section 2.3.1.3). 

11. No sagebrush would be removed within sagebrush treatment units (Section 2.3.1.4). 

12. If authorized, livestock could be used to remove cheatgrass within all treatment units (Section 2.3.1.4). 

13. Only seeds of native plant species would be used to seed treatment units. Non-native seedings may be used 

1) to create fuel breaks, 2) in areas that have previously burned and are beyond use of Emergency 

Stabilization and Rehabilitation techniques, 3) to create green strips; and 4) for soil stabilization in low 

precipitation zones. (Section 2.5.3.5). 

14. Treatment design would allow for up to 100 cords of fuel wood (greenwood and deadwood combined) to be 

removed for commercial sale annually, per unit, where removal of pinyon-juniper is an objective (Section 

2.5.3.6). 

15. Included is a summary of mitigation measures proposed for each resource area in Table 2-2, Summary and 

Comparison of Effects on Resources by Alternative. 

3 Bars Project Final EIS 2-2 October 2016 
ALTERNATIVES

16. Prior to implementing any seeding treatment, livestock management will be reviewed to insure proper 

grazing management and AML will be achieved within the associated HMA(s). (Table 2-2, Summary of 

Effects on Livestock and Rangeland Conditions, Cumulative Effects). 

17. The number of acres treated using fire has been reduced by about 40 percent from amounts given in the Draft 

EIS (various sections). 

18. Analysis and justification for use of fire in Greater sage-grouse habitat: MD FIRE 23: If Prescribed fire is 

used in GRSG habitat, the NEPA analysis for the Burn Plan will address: 

 Why alternate techniques were not selected as a viable option 

 How GRSG goals and objectives will be met by its use 

 How the COT report objectives will be addressed and met 

 A risk assessment to address how potential threats to GRSG habitat will be minimized 

These four requirements are addressed in Appendix E: ARMPA - MD FIRE 23 Documentation. 

2.3 Description of the Action Alternatives (Alternatives A, B, and 

C) 

2.3.1 Alternative A — All Treatment Methods Alternative (Preferred 

Alternative) 

Alternative A is the BLM’s Preferred Alternative. Under this alternative, the BLM would treat about 127,000 acres 

during the life of the project, or about 12,700 acres annually, using manual and mechanical methods, fire (both 

prescribed and wildland fire for resource benefit), and biological controls (primarily to control noxious weeds and 

other invasive non-native vegetation using livestock and classical biological [nematodes, fungi, mites, and insects]). 

Treatments would focus on protecting landscapes and treatment projects would usually address multiple resource 

issues. 

The BLM has identified site-specific treatments to be implemented under this alternative in order to improve the 

health of the 3 Bars ecosystem. Treatments would focus on four priority vegetation management concerns—riparian, 

aspen, pinyon-juniper, and sagebrush. 

2.3.1.1 Riparian Treatment Units 

The BLM has identified about 3,885 acres of riparian zone treatments (Figure 2-1). These areas were selected by the 

BLM because they exhibited riparian structural issues such as incised channels, headcuts, and knickpoints; did not 

meet Proper Functioning Condition standards (see Section 3.11 for a discussion of Proper Functioning Condition 

standards); or required treatment to improve habitat for Lahontan cutthroat trout. Treatments to address stream 

structural issues include headcut abatement, to address a headcut at a specific point in a stream; headcut incision 

abatement, to address stream segments where the channel is still actively downcutting and where a headcut is present; 

and incision abatement, where the stream segment has an incised channel but not a headcut. In addition, pinyonjuniper encroachment into some riparian zones is compromising riparian health. Riparian treatment objectives 

include: 

3 Bars Project Final EIS 2-3 October 2016 
ALTERNATIVES 

 Remove non-riparian trees within the historic floodplain, and thin non-riparian trees to 30-feet spacing 

outside of the historic floodplain and within 200 feet of the stream channel. 

 Manage activity fuels using one or more of the Activity Fuel Disposal methods outlined in this chapter. 

 Achieve an increase of occurrence of key riparian species by at least 30 percent in the short term (3-5 years 

post treatment). 

 Reduce the number of headcuts and headcut incisions. 

3 Bars Project Final EIS 2-4 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 2-1

Riparian Treatment Areas

3 Bars Ecosystem and

Landscape Restoration Project

Cadet Spring

Indian Creek

Headwaters North

Indian Creek

Headwaters South

Mud Spring

Hash Spring

Railroad Spring

Trap Corral

Spring

Roberts

Mountain

Spring

Trail Spring

Garden Spring

Lower Henderson 3

Upper

Vinini

Creek

Lower Henderson 2

Rye Patch

Spring

Stinking

Spring

McCloud Spring

Black Spring Frazier

Creek

Henderson above

Vinini Confluence

Denay Pond

Upper Willow

Lone

Mountain

Treasure Well Spring

McClusky

Creek

Roberts Creek

Vinini

Creek

Lower Vinini Creek

Willow Creek

Lower Henderson 1

Upper

Henderson

Indian Creek

Headwaters Middle

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

ROBERTS

MOUNTAIN

SIMPSON

PARK

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Riparian Treatment Area

Wilderness Study Area

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2011c.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 10/02/13)
ALTERNATIVES 

Streams, ponds and springs would be treated within the Grass Valley, JD, Lucky C, Roberts Mountains, and Romano 

allotments, which are within the Simpson Park Range and Kobeh and Denay Valleys. These include treatment units 

associated with the Black Spring Group, Garden Spring Group, and Denay Pond, Lone Spring, and Treasure Well. 

Greater treatments are proposed on 402 acres associated with several streams, ponds, and springs—Black Spring 

Group (Black Spring, Cadet Spring, Indian Creek Headwaters North, Middle, and South, Mud Spring, McClusky 

Creek, and Rye Patch Spring units). Treatment methods include manual and mechanical methods. The Black Spring 

Group includes the following units: 

 Black Spring (15 acres) 

 Cadet Spring (18 acres) 

 Indian Creek Headwaters North (50 acres) 

 Indian Creek Headwaters Middle (6 acres) 

 Indian Creek Headwaters South (4 acres) 

 Mud Spring (8 acres) 

 McClusky Creek (292 acres) 

 Rye Patch Spring (9 acres) 

For the Black Spring Group, the BLM would: 

1. Treat stream segments and springs where Multiple Indicator Monitoring and Proper Functioning Condition 

data indicate that structural treatments are needed. Various methods of treatment may be utilized to address 

identified headcuts and stream incision. These include grade stabilization structures, streambank 

bioengineering, and vegetation planting to initiate stream restoration. Equipment involved would range from 

a track-hoe or back-hoe and dump truck for hauling rock or dirt work, to a pick-up and trailer for hauling 

fencing and planting materials. Existing fencing, or small temporary exclosures (let-down fencing using 

barbed wire and posts that can be let-down easily to allow animals to pass, or electric wire fencing), would be 

used to exclude livestock, wild horses, and other wild ungulates from treatment units until seeded and planted 

areas become established. 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. 

2. Maintenance of fencing would be determined on a project-by-project basis and would be reflected in the 

individual cooperative agreements for each project. 

The BLM would conduct treatments similar to those identified in the previous paragraph on about 78 acres at the 

Hash Spring, Garden Spring, McCloud Spring, Railroad Spring, Roberts Mountains Spring, Stinking Spring, Trail 

Spring, and Trap Corral Spring units (Garden Spring Group). Treatment methods include manual and mechanical 

methods. The BLM would also remove pinyon-juniper from riparian habitats using manual and mechanical methods 

as needed. The Garden Spring Group includes the following units: 

3 Bars Project Final EIS 2-6 October 2016 
ALTERNATIVES

 Hash Spring (3 acres) 

 Garden Spring (7 acres) 

 McCloud Spring (15 acres) 

 Railroad Spring (3 acres) 

 Roberts Mountains Spring (18 acres) 

 Stinking Spring (17 acres) 

 Trail Spring (12 acres) 

 Trap Corral Spring (3 acres) 

For the Garden Spring Group, the BLM would: 

1. Treat stream segments and springs where Multiple Indicator Monitoring and Proper Functioning Condition 

data indicate that structural treatments are needed. Various methods of treatment may be utilized to address 

identified headcuts and stream incision. These include grade stabilization structures, streambank 

bioengineering, and vegetation planting to initiate stream restoration. Equipment involved would range from 

a track-hoe or back-hoe and dump truck for hauling rock or dirt work, to a pick-up and trailer for hauling 

fencing and planting materials. Existing fencing, or small temporary exclosures (let-down fencing using 

barbed wire and posts that can be let-down easily to allow animals to pass, or electric wire fencing), would be 

used to exclude livestock, wild horses, and other wild ungulates from treatment units until seeded and planted 

areas become established. 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. Maintenance of fencing would be determined on a project-by-project basis and would be 

reflected in the individual cooperative agreements for each project. 

2. Remove Phase I and selected Phase II pinyon-juniper from riparian habitats. The BLM would primarily use 

hand-thinning to remove trees around springs and in Phase I pinyon-juniper stands, and a combination of 

manual and mechanical treatment methods in Phase II stands. 

At Denay Pond, Lone Spring, and Treasure Well, the BLM would use protective fencing, but no other treatments, to 

restore riparian habitats. These areas total about 97 acres and mechanical and manual methods would be used for 

treatments. 

The BLM would treat approximately 3,208 acres and 28 miles of riparian habitat associated with units in the 

Henderson above Vinini Confluence Group and Frazier Creek Group that are found along Frazier, Henderson, 

Roberts, Vinini, and Willow Creeks. Treatment objectives are to achieve Proper Functioning Condition (both groups), 

and to remove 70 to 90 percent of pinyon-juniper from within riparian areas (Frazier Creek Group only). Mechanical 

and manual methods would be used to treat vegetation. For treatments along Willow Creek, mechanical equipment 

would not be used within the stream wherever possible, but would be used to place items or structures within the 

stream to address identified issues. 

3 Bars Project Final EIS 2-7 October 2016 
ALTERNATIVES 

In addition to treatment goals discussed earlier, treatment goals for both groups include enhancing habitat for 

Lahontan cutthroat trout in historically occupied streams and Lahontan cutthroat trout recovery streams, and in 

streams occupied by game fish. Treatments would help meet the goals and objectives of the Recovery Plan for the 

Lahontan Cutthroat Trout (Coffin and Cowan 1995). An additional goal for the Frazier Creek Group is to reduce 

pinyon-juniper encroachment onto riparian sites. 

The Henderson above Vinini Confluence Group includes the following units: 

 Henderson above Vinini Confluence (35 acres, 1 mile) 

 Lower Henderson 1 (289 acres, 2 miles) 

 Lower Henderson 2 (79 acres, 0. 5 mile) 

 Lower Henderson 3 (94 acres, 1 mile) 

 Lower Vinini (151 acres, 1 mile) 

 Upper Vinini (64 acres, 1 mile) 

 Upper Willow (46 acres, 0. 5 mile) 

For the Henderson above Vinini Confluence Group, the BLM would: 

1. Treat stream segments where Multiple Indicator Monitoring and Proper Functioning Condition data indicate 

structural treatments are needed. Various methods of treatment may be utilized to address identified headcuts 

and stream incision. These include grade stabilization structures, stream bank bioengineering, and vegetation 

planting to initiate stream restoration. Equipment involved would range from a track-hoe or back-hoe and 

dump truck for hauling rock or dirt work, to a pick-up and trailer for hauling fencing and planting materials. 

Only existing permanent fencing, or small temporary exclosures (let-down fencing using barbed wire and 

posts that can be let-down easily to allow animals to pass, or electric wire fencing), would be used to exclude 

livestock, wild horses, and other wild ungulates from treatment units until seeded and planted areas become 

established. No use of barbed wire or let-down fencing will be allowed within HMA boundaries, and letdown fencing will not be used where wild horses are present and may become entrapped in the fence. 

Maintenance of fencing would be determined on a project-by-project basis and would be reflected in the 

individual cooperative agreements for each project. 

The Frazier Creek Group includes the following units: 

 Frazier Creek (59 acres, 1 mile) 

 Roberts Creek (1,390 acres, 7 miles) 

 Upper Henderson (129 acres, 1 mile) 

 Vinini Creek (644 acres, 7 miles) 

 Willow Creek (328 acres, 5 miles) 

3 Bars Project Final EIS 2-8 October 2016 
ALTERNATIVES

For the Frazier Creek Group, the BLM would: 

1. Treat stream segments where Multiple Indicator Monitoring and Proper Functioning Condition data indicate 

that structural treatments are needed. Various methods of treatment may be utilized to address identified 

headcuts and stream incision. These include grade stabilization structures, streambank bioengineering, and 

vegetation planting to initiate stream restoration. Equipment involved would range from a track-hoe or backhoe and dump truck for hauling rock or dirt work, to a pick-up and trailer for hauling fencing and planting 

materials. Only existing permanent fencing, or small temporary exclosures (let-down fencing using barbed 

wire and posts that can be let-down easily to allow animals to pass, or electric wire fencing), would be used 

to exclude livestock, wild horses, and other wild ungulates from treatment units until seeded and planted 

areas become established. 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. Maintenance of fencing would be determined on a project-by-project basis and would be 

reflected in the individual cooperative agreements for each project. 

2. Remove Phase I and selected Phase II pinyon-juniper from riparian habitats with a combination of 

mechanical and manual treatment methods. Hand-thinning would be the preferred method of tree removal in 

Phase I pinyon-juniper stands. 

No range improvements, such as livestock troughs and permanent fencing, would be included as part of riparian 

treatments. Chainsaw hand thinning would be the preferred method for tree cutting in riparian treatment areas, 

especially near springs and in areas with Phase I pinyon-juniper, but all other treatment methods would be considered 

during project planning. Felled trees from pinyon-juniper removal would be disposed of by using trees for posts and 

as mulch, placing logs and larger wood in streams to slow water flow, selling trees for public or commercial use, 

burning piled or slashed trees, or leaving downed trees on-site for wildlife habitat. All units would be inventoried for 

noxious weeds and invasive non-native vegetation and treated, if necessary, before treatment implementation. Units 

would be monitored for up to 3 years following implementation and if noxious weeds or invasive non-native 

vegetation are found, they would be treated with an appropriate and approved treatment method in accordance with 

the Integrated Weed Management Plan Battle Mountain District Nevada Mt. Lewis Field Office and Tonopah Field 

Office (USDOI BLM 2009b). 

2.3.1.2 Aspen Treatment Units 

The BLM has identified about 451 acres of aspen habitat that would be treated within the Roberts Mountains (RMA2, A5, A7, A9 and A10 units), JD (JD-A1 and A4 units), 3 Bars (TB-A1 Unit), and Santa Fe/Ferguson (SFF-A1 

unit) allotments (Figure 2-2). The BLM has determined that an insufficient number of aspen suckers are surviving to 

maturity in these areas. In addition to these units, the BLM has also identified the Simpson Park East (8,055 acres) 

and Simpson Park Northeast (8,991 acres) units as areas where aspen treatments could occur in the future. Treatments 

would not occur in these two areas until after site-specific aspen inventories are completed and funding for treatments 

becomes available. Aspen treatment objectives include: 

 Achieve an increase of aspen stems per acre, a minimum of 10 percent in the short term (3-5 years post 

treatment). 

 Achieve an increase of sapling aspen stems per acre, a minimum of 10 percent in the short term (3-5 years 

post treatment). 

3 Bars Project Final EIS 2-9 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 2-2

Aspen Treatment Areas

3 Bars Ecosystem and

Landscape Restoration Project

RM-A2 RM-A7

RM-A9

RM-A10

JD-A4

SFF-A1

JD-A1

Simpson

Park East

Simpson Park

Northeast

TB-A1

RM-A5

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

ROBERTS

MOUNTAIN

SIMPSON

PARK

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Aspen Treatment Area

Wilderness Study Area

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2011c.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/10/13)
ALTERNATIVES

 Remove 100 percent of pinyon-juniper in and within 200 feet of aspen stands. 

 Manage activity fuels using one or more of the Activity Fuel Disposal methods outlined in this chapter. 

The BLM would treat approximately 203 acres associated with the JD-A1 Group, 189 acres associated with the RMA2 Group, and 59 acres associated with the JD-A4 Group. Treatment goals are to 1) protect and improve aspen stand 

health; 2) reduce pinyon-juniper encroachment onto aspen sites; 3) protect and improve wildlife habitat in the longterm; 4) provide for vegetative and ecological diversity; and 5) conduct inventories of aspen stands to establish 

current stand health. 

The JD-A4 Group includes the following units: 

 JD-A4 (23 acres) 

 RM-A10 (28 acres) 

 SFF-A1 (8 acres) 

The BLM would treat these three units using manual treatment methods to improve aspen stand health. 

The RM-A2 Group includes the following units: 

 RM-A2 (39 acres) 

 Simpson Park East (150 acres) 

The BLM would treat these two units using mechanical and manual treatment methods. No mechanical treatments 

would be used within Wilderness Study Area (WSA) boundaries. The Simpson Park East Unit is an area where aspen 

treatments could occur in the future. Treatments would not occur on this unit until after site-specific aspen inventories 

are completed and funding for treatments becomes available. 

The JD-A1 Group includes the following units: 

 JD-A1 (3 acres) 

 RM-A5 (4 acres) 

 RM-A7 (6 acres) 

 RM-A9 (36 acres) 

 Simpson Park Northeast (150 acres) 

 TB-A1 (4 acres) 

The BLM would treat these six units using prescribed fire (pile burning only), mechanical, and manual treatment 

methods. The Simpson Park Northeast Unit is an area where aspen treatments could occur in the future. Treatments 

would not occur on this unit until after site-specific aspen inventories are completed and funding for treatments 

becomes available. 

3 Bars Project Final EIS 2-11 October 2016 
ALTERNATIVES 

No range improvements, such as livestock troughs and permanent fencing, would be included as part of aspen 

treatments. Treatments would be conducted using manual and mechanical methods and prescribed fire to selectively 

remove trees. Chainsaw hand thinning is the preferred method for tree cutting, however, other methods may be 

considered on a case-by-case basis. Existing fencing or small, temporary exclosures may be used to protect aspen 

restoration areas from livestock, wild horses, and other wild ungulates and would be similar to those described under 

Riparian Treatments. Treatments would improve the health of aspen stands by stimulating aspen stand suckering and 

sucker survival. 

Slash from removal of pinyon-juniper would be left in place to promote aspen suckering and seedling establishment. 

Removal of pinyon-juniper may extend up to 200 feet from aspen stands, and some treatments may occur near roads 

to improve their effectiveness as fuel breaks. Pinyon-juniper slash would be left in place to act as deadfall, to limit 

ungulate access to the treatment area, and to minimize other site disturbances. If there is the potential for wildfire due 

to extensive slash material, trees having the potential for use as fence posts or for firewood would be gathered up and 

offered for sale to the public; any remaining material would be pile burned. The BLM would follow non-impairment 

standards for treatments in the Roberts Mountains and Simpson Park WSAs. 

2.3.1.3 Pinyon-juniper Treatment Units 

Up to 94,000 acres of treatments involving the thinning and removal of pinyon-juniper would be conducted on Lone 

Mountain, Roberts Mountains, and other areas within the 3 Bars ecosystem (Figure 2-3). 

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 (of 

dominant and understory trees), crown structure, potential berry production, tree recruitment, and shrub and 

herbaceous vegetation canopy cover. 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 cost-effective 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 

catastrophic fire as well as to improve woodland health. Treatments would involve multiple tree removal options 

including the use of chainsaws, hand thinning, ripping, feller-buncher, tree-shearer, prescribed fire, and wildland fire 

3 Bars Project Final EIS 2-12 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 2-3

Pinyon-juniper Treatment Areas

3 Bars Ecosystem and

Landscape Restoration Project

Henderson

Corridor

Vinini

Corridor

Frazier

Corridor

Gable

Corridor

Birch

Creek

Upper

Pete

Hanson

Upper

Roberts

Creek

Whistler Lone

Mountain

Atlas

Three

Bar

Ranch

Dry

Canyon

Lower Pete

Hanson

Tonkin

South

Tonkin

North

Sulphur

Spring

Wildfire

Management

Cottonwood/

Meadow Canyons

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

ROBERTS

MOUNTAIN

SIMPSON

PARK

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Pinyon-juniper Treatment Area

Wilderness Study Area

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2011c.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/10/13)
ALTERNATIVES 

3 Bars Project Final EIS 2-14 October 2016 

for resource benefit. Prior to conducting treatments, treatment areas would be surveyed for mountain mahogany, and 

old-growth pinyon-juniper and limber pine trees. Areas with mountain mahogany and/or old-growth limber pine 

and/or pinyon-juniper trees would be avoided. Most pinyon-juniper trees in Phase I stands would be removed, and 

only hand thinning using chainsaws would be allowed in Phase I stands. The density of trees in woodlands in the 

Phase II and III states would be reduced by a minimum of 50 percent within areas targeted for treatment. Biological 

control methods using livestock would only be used to treat cheatgrass. Fuel breaks would be constructed along 

existing roads and two-tracks wherever possible, unless needed to protect important cultural or natural resources. 

Treatment design would allow for up to 100 cords of fuel wood (greenwood and deadwood combined) to be removed 

for commercial sale annually, per unit. No range improvements, such as livestock troughs or permanent fencing, 

would be included as part of pinyon-juniper treatments. Pinyon-juniper treatment objectives include: 

 Decrease crown fire potential by increasing canopy spacing to an average of 30 feet and/or create multiplecanopy openings totaling 30 to 45 percent of a given contiguous stand in treatment areas (an average canopy 

spacing of 30 feet is roughly 30 to 40 mature trees per acre and is not capable of sustaining crown fires). 

 Reduce fuel loading to 1 to 2 tons per acre in shrub fuel types and to 1 to 5 tons per acre in pinyon-juniper 

fuel types. 

 Reduce hazardous fuel loads of pinyon-juniper within fuel breaks to 10 tons or less per acre. 

 Conduct treatments when fuel loads are greater than 2 tons per acre in shrub fuel types and loadings, or 10 

tons per acre in pinyon-juniper fuel types and loadings, or more than 500 pounds per acre of fine fuels. 

 Remove Phase I pinyon-juniper and selected Phase II pinyon-juniper stands within historic sagebrush 

habitats. 

 Reduce crown closure in Phase II and III pinyon-juniper stands to less than 40 percent to improve stand 

health in areas managed for pinyon-juniper woodlands. 

 Reduce stocking levels in Phase II and III pinyon-juniper stands to less than 200 stems per acre to improve 

stand health in areas managed for pinyon-juniper woodlands. 

The BLM would treat pinyon-juniper to enhance habitats that are important to Greater sage-grouse in several 

drainages on Roberts Mountains and Lone Mountain (Atlas Group) using manual, mechanical, and fire treatments. 

Treatment units include the Lone Mountain, Atlas, Frazier, Gable, Henderson, Upper Roberts Creek, and Vinini 

Corridor units. These areas serve as important Greater sage-grouse habitat and travel corridors between lower 

elevation wintering and lekking habitats and upper elevation nesting and brood-rearing habitats. Treatments would be 

completed in phases, with up to 22,887 acres treated to meet Greater sage-grouse habitat enhancement objectives. 

Treatments would involve removing pinyon-juniper from areas historically occupied by sagebrush and riparian plant 

species, and promoting development of native grasses, forbs, and shrubs through removal of pinyon-juniper. The 

BLM would also create a series of fuel breaks to moderate fire behavior in the treated areas and reduce the risk of loss 

of habitat from wildfire. Activity fuels generated through the treatment of pinyon-juniper would be disposed of by 

using one or more of the Activity Fuels Disposal Methods (see Section 2.5.3.8, Activity Fuels Disposal). Specifically, 

the BLM would conduct the following treatments at these units: 
ALTERNATIVES

3 Bars Project Final EIS 2-15 October 2016 

Lone Mountain (1,387 acres): 

 Treat up to 100 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat up to 1,387 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Atlas (7,085 acres): 

 Treat up to 1,000 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat 20 to 50 percent of the unit (1,400 to 3,543 acres) in 100- to 500-acre increments using prescribed fire. 

 Treat up to 1,000 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Frazier Corridor (2,725 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat up to 1,900 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Gable Corridor (5,012 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat up to 3,000 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Henderson Corridor (9,348 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat 10 to 30 percent of the unit (935 to 2,800 acres) in 200- to 600-acre increments using prescribed fire. 

 Treat up to 3,500 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Upper Roberts Creek (3,894 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 
ALTERNATIVES 

3 Bars Project Final EIS 2-16 October 2016 

 Treat 20 to 50 percent of the unit (780 to 1,947 acres) in 500- to 1,000-acre increments using prescribed fire. 

 Treat up to 500 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

 No mechanical treatments would be used within WSA boundaries. 

Vinini Corridor (3,277 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

methods. 

 Treat up to 400 acres of the unit using prescribed fire. 

 Treat up to 1,600 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

The BLM would create a series of fuel breaks to moderate fire behavior in treated areas, and reduce the risk of loss of 

habitat from wildfire in habitats critical to Lahontan cutthroat trout, in the Birch Creek and Upper Pete Hanson Creek 

drainages on Roberts Mountain. Treatments would encompass about 460 acres and would be developed in 

consultation with the USFWS and coordinated with the NDOW. Thinning and disposal methods for trees would be 

similar to those used at the Atlas Group, and would include placing larger diameter pieces of wood in streams to slow 

water flow. Treatments would adhere to the BLM’s non-impairment standard for the Roberts Mountains WSA. 

Specifically, the BLM would conduct the following treatments in these drainages: 

Birch Creek Unit (218 acres) 

 Treat up to 218 acres of the unit to create fuel breaks using manual treatment methods. 

Upper Pete Hanson Creek Unit (243 acres) 

 Treat up to 243 acres of the unit to create fuel breaks using manual treatment methods. 

The BLM would reduce hazardous fuels on up to 55,700 acres on the Cottonwood/Meadow Canyon, Dry Canyon, 

Three Bars Ranch, Lower Pete Hanson, 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 thinning pinyonjuniper stands in 800- to 2,000-acre increments using manual and mechanical methods; 2) use manual and mechanical 

methods to create fuel breaks; and 3) slow pinyon-juniper expansion into sagebrush and other plant communities on 

10 to 70 percent of the units through the use of manual and mechanical methods and prescribed fire. Specifically, the 

BLM would conduct the following treatments at these units: 

Cottonwood/Meadow Canyon (4,577 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat 13 to 40 percent of the unit (600 to 1,800 acres) in 200- to 600-acre increments using prescribed fire. 
ALTERNATIVES

3 Bars Project Final EIS 2-17 October 2016 

 Treat up to 2,000 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Dry Canyon (2,838 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat 30 to 70 percent of the unit (851 to 1,987 acres) in 100- to 500-acre increments using prescribed fire. 

Lower Pete Hanson (1,580 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat up to 800 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Three Bars Ranch (11,900 acres): 

 Treat up to 1,000 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat 20 to 30 percent of the unit (2,380 to 3,570 acres) in 500- to 1,000-acre increments using prescribed 

fire. 

 Treat up to 2,000 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

Tonkin North (4,389 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat pinyon-juniper on 10 to 37 percent of the unit (500 to 1,600 acres) in 500- to 1,000-acre increments 

using prescribed fire. 

 Treat up to 500 acres of the unit in 5- to 20-acre increments by removing pinyon-juniper stands infested with 

pathogens and/or pests to prevent/or limit the spread of the pathogens and/or pests using a combination of 

mechanical and manual treatment methods. 

Tonkin South (2,458 acres): 

 Treat up to 500 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 
ALTERNATIVES 

3 Bars Project Final EIS 2-18 October 2016 

 Treat up to 50 percent of the unit (1,229 acres) in 5- to 20-acre increments by removing pinyon-juniper 

stands infested with pathogens and/or pests to prevent/or limit the spread of the pathogens and/or pests using 

a combination of mechanical and manual treatment methods. 

Whistler (26,970 acres): 

 Treat up to 1,000 acres of the unit to create fuel breaks using a combination of mechanical and manual 

treatment methods. 

 Treat pinyon-juniper on 30 to 70 percent of the unit (8,091 to 18,879 acres) in 500- to 1,000-acre increments 

using prescribed fire. 

 Treat up to 2,000 acres of pinyon-juniper within the unit using a combination of mechanical and manual 

treatment methods. 

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 on the unit in increments of up to 1,000 to 2,000 acres annually. 

2.3.1.4 Sagebrush Treatment Units 

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). 

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. Treatment objectives include: 

 Remove all Phase I and most Phase II pinyon-juniper trees. See Section 3.12.2.2.9 for a discussion of phase 

classes. 

 Increase plant density of key perennial species an average of one plant per three feet squared above existing 

conditions in the short term (3-5 years post treatment). 

 Increase production of key perennial herbaceous plants by a minimum of 10 percent above existing condition 

in the short term (3-5 years post treatment). 

 Eliminate noxious weeds and other invasive non-native species. 

 Limit noxious weeds and undesirable native and non-native species to the following acreages: 

o 0 acres of Category A State of Nevada noxious weeds. 

o Less than 500 acres of Category B State of Nevada noxious weeds. 

o Less than 1,500 acres of Category C State of Nevada noxious weeds. 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 2-4

Sagebrush Treatment Areas

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Nichols

Roberts

Mountain

Pasture Kobeh

East

Coils

South Creek

Simpson

Alpha

Whistler

Sage

Three

Corners

Table

Mountain

Rocky

Hills

West

Simpson

Park

Elko County

Eureka County

Lander County

Eureka County

ROBERTS

MOUNTAIN

SIMPSON

PARK

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Sagebrush Treatment Area

Wilderness Study Area

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2011c.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/10/13)
ALTERNATIVES 

3 Bars Project Final EIS 2-20 October 2016 

o Cheatgrass monocultures at less than 25 percent in any given fire scar. 

Native species would be used for overseeding and overplanting in sagebrush treatment units when appropriate. Nonnative species could only be used where seedings with native species would be unsuccessful as informed by ESD and 

STM and available science. Where pinyon-juniper is felled, chainsaw hand thinning would be required for Phase I 

stands and chainsaw hand thinning would be the preferred method of tree cutting in Phase II and III stands; however, 

other methods may be considered on a case-by-case basis within sagebrush units. Trees would be disposed of by 

using trees for posts or as mulch, by placing logs and larger wood in streams to slow water flow, by selling trees for 

public or commercial use, by burning piled or slashed trees, or by leaving downed trees on site as wildlife habitat. On 

the Alpha, Coils Creek, Kobeh East, Nichols, Roberts Mountain Pasture, South Simpson, Table Mountain, Three 

Corners, and Whistler Sage units (Alpha Unit Group), up to 29,400 acres would be treated and treatments would 

focus on using manual and mechanical methods, thin Phase I and II pinyon-juniper and seed and plant to promote the 

growth of forbs and grasses. Specifically, the BLM would conduct the following treatments on these units: 

Alpha (12,330 acres): 

 Treat up to 6,100 acres within the unit using seeding and planting treatment methods. 

Coils Creek (3,267 acres): 

 Treat up to 1,600 acres within the unit using seeding and planting treatment methods. 

Kobeh East (7,591 acres): 

 Treat up to 3,800 acres within the unit using seeding and planting treatment methods. 

Nichols (3,305 acres): 

 Treat up to 1,600 acres within the unit using seeding and planting treatment methods. 

Roberts Mountain Pasture (15,190 acres): 

 Treat up to 1,600 acres within the unit using seeding and planting treatment methods. 

South Simpson (13,400 acres): 

 Treat up to 6,700 acres within the unit using seeding and planting treatment methods. 

Table Mountain (24,100 acres): 

 Treat up to 5,000 acres of Phase I and II pinyon-juniper within the unit using a combination of mechanical 

and manual treatment methods. 

 Treat up to 12,000 acres within the unit using seeding and planting treatment methods. 

 Utilize biological control to aid in brush increase and during times of other treatment closures 
ALTERNATIVES

3 Bars Project Final EIS 2-21 October 2016 

Three Corners (2,915 acres): 

 Treat up to 500 acres of Phase I and II pinyon-juniper within the unit using a combination of mechanical and 

manual treatment methods. 

 Treat up to 1,500 acres within the unit using seeding and planting treatment methods. 

Whistler Sage (6,782 acres): 

 Treat up to 1,500 acres of Phase I and II pinyon-juniper within the unit using a combination of mechanical 

and manual treatment methods. 

 Treat up to 3,400 acres within the unit using seeding and planting treatment methods. 

On the West Simpson Park Unit, the BLM would treat up to 1,963 acres of cheatgrass with a combination of 

prescribed fire, mechanical methods, and seeding and plantings to reduce cheatgrass and to promote the establishment 

of a native sagebrush community. 

On the Rocky Hills and the Table Mountain Units the BLM could use livestock to remove cheatgrass, crested 

wheatgrass, and forage kochia to promote the establishment of a native sagebrush community. For all other sagebrush 

treatment units, the BLM would only use livestock to remove cheatgrass. This would be done when determined the 

best time to reduce competition between cheatgrass and sagebrush seedlings to help ensure that broadcast seeding 

would be successful. 

2.3.2 Alternative B — No Fire Use Alternative 

Alternative B is similar to Alternative A in that the BLM would focus treatments on the four priority management 

concerns—riparian, aspen, pinyon-juniper, and sagebrush—and would focus on the treatment areas shown in Figures 

2-1 to 2-4. Alternative B differs from Alternative A in that the BLM would not use prescribed fire and wildland fire 

for resource benefit. Under Alternative B, the BLM would treat vegetation using manual, mechanical, and biological 

control (livestock and classical biological control) methods. This alternative was developed to address public concerns 

raised during scoping about the impacts to the landscape from fire, including the potential for erosion and spread of 

noxious weeds and other invasive non-native vegetation from fire treatments. 

The BLM would conduct projects identified under Alternative A, but would be able to treat only about half as many 

acres (63,500 acres), as about half of the acreage treated under Alternative A would be treated using fire, and because 

costs for manual and mechanical treatments are more expensive than costs for fire treatments. 

2.3.3 Alternative C — Minimal Land Disturbance Alternative 

Alternative C is similar to Alternative A in that the BLM would focus treatments on the four priority treatment 

types—riparian, aspen, pinyon-juniper, and sagebrush—and would focus on the treatment areas shown in Figures 2-1 

to 2-4. Alternative C differs from Alternative A in that the BLM would only treat vegetation within treatment areas 

using manual methods and classical biological control (use of nematodes, fungi, mites, and insects); use of livestock 

for biological control would not be allowed. The BLM also would not be able to use mechanical methods or fire. 
ALTERNATIVES 

3 Bars Project Final EIS 2-22 October 2016 

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 below under 

Alternatives Considered but Not Further Analyzed. 

The BLM would conduct projects identified under Alternative A, but would be able to only treat about one-fourth as 

many acres (31,750 acres) as compared to Alternative A. Treatments would generally be small in acreage. 

2.4 Description of the No Action Alternative - Alternative D - 

Continue Current Management 

Under the No Action Alternative, no new treatments would be authorized as a result of this project. However, as with 

all of the alternatives, the BLM would continue to conduct treatments approved under earlier NEPA authorizations. 

The BLM would have to conduct the appropriate level of NEPA analysis for future projects before they could be 

approved for implementation. Should this alternative be chosen by the decision-maker, and the BLM decides to 

conduct new treatments in the 3 Bars ecosystem in the future, decisions would have to be made at that time regarding 

the type of environmental analysis that must be conducted before treatments would be allowed within the ecosystem. 

There are approximately 15,000 acres of treatments that could occur within the ecosystem that have been previously 

authorized by the BLM, or that are reasonably foreseeable in the future, during the life of the project. These 

treatments are discussed in Chapter 3 under Cumulative Effects (Section 3.3.2). 

2.5 Development of the Action Alternatives 

2.5.1 Treatment Area Selection 

An interdisciplinary team of BLM resource specialists met in August 2010, and in February, November, and 

December 2011, to identify priority treatment areas within the 3 Bars ecosystem, and to develop specific projects to 

improve ecosystem health, based on project purposes. Treatment areas were based on four priority vegetation 

treatment types identified by the interdisciplinary team—aspen, riparian, pinyon-juniper, and sagebrush. For each of 

these treatment types, the BLM identified goals and objectives, methods, and SOPs that would apply to each 

treatment area. 

2.5.2 Site-specific Project Selection 

Once treatment types 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. 

Once the BLM refined the 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 seek advice on the 

development of individual site-specific projects. 
ALTERNATIVES

3 Bars Project Final EIS 2-23 October 2016 

2.5.3 Treatment Methods 

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 methods available to the BLM would depend upon the 

alternative chosen by the decision-maker. The types of tools used with these methods and the benefits and adverse 

impacts from using these treatments are discussed in more detail in the 17-States 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 the project, 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. For example, fire treatment methods could not be used under Alternatives B and C. 

2.5.3.1 Manual Treatments 

Manual treatment involves the use of hand tools and hand-operated power tools (including chainsaws and weed 

whackers) to clear, cut, or prune herbaceous and woody species. Treatments include cutting undesired plants above 

the ground level; pulling, grubbing, or digging out root systems of undesired plants to prevent sprouting and regrowth; 

cutting at the ground level or removing competing plants around desired species; or placing mulch around desired 

vegetation to limit competitive growth (USDOI BLM 2007c). 

All manual treatment methods would be available as treatment options under Alternatives A, B, and C in units where 

it is identified as a treatment option. 

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 and would range from a single tree to multiple acres of 

trees. Selective cutting may include dead, diseased, or healthy trees depending on site evaluation and treatment 

objectives. It may be necessary to cut healthy trees where there are no dead or diseased trees that can be removed to 

meet resource objectives. Cut trees may be removed, chipped, lopped and scattered, or piled and burned if prescribed 

fire is permitted, based on the site evaluation and restoration objectives. 

Other manual treatments that may be used by the BLM in the 3 Bars ecosystem include hand cutting or removal of 

noxious weeds and other invasive non-native vegetation and hand planting of vegetation. In addition, the BLM could 

build wood and rock structures in streams to help trap sediments and construct small, temporary fence exclosures 

around treatment areas by hand. 

2.5.3.2 Mechanical Treatments 

Mechanical treatment involves the use of vehicles such as wheeled tractors and 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 selection of a particular mechanical 

method is based on the characteristics of the vegetation, seedbed preparation and revegetation needs, topography and 
ALTERNATIVES

3 Bars Project Final EIS 2-24 October 2016 

terrain, soil characteristics, climatic conditions, and an analysis of the improvement cost compared to the expected 

productivity (USDOI BLM 2007c:2-14). 

All mechanical treatment methods would be available as treatment options in Alternatives A and B in units where it is 

identified as a treatment option. 

Mechanical methods are effective for removing thick stands of vegetation. Some mechanical equipment can also 

mulch or lop and scatter vegetation debris, so debris disposal is taken care of while the vegetation is removed. 

Mechanical methods are appropriate where a high level of control over vegetation removal is needed, such as in 

sensitive wildlife habitats or near homesites, and are often used instead of prescribed fire or herbicide treatments for 

vegetation control in the wildland-urban interface. 

Mowing 

Mowing tools, such as rotary mowers or straight-edged cutter bar mowers, can be used to cut herbaceous and woody 

vegetation above the ground surface at varying heights. Mowing is often done along highway rights-of-way to reduce 

fire hazards, improve visibility, prevent snow buildup, or improve the appearance of the area. Mowing is also used to 

create a mosaic of uneven aged stands to enhance wildlife habitat. Mowing is most effective on annual and biennial 

plants. 

Mulching/Shredding 

Mulching/shredding is a selective approach to tree removal. 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 

mulching/shredding equipment is mounted onto tracked or wheeled vehicles and may include such equipment as a 

bull-hog, hydro axe, or any other machine designed for the mulching/shredding of tree species. Wood chips and 

branch/leaf mulch would be dispersed on site, not to exceed 3 inches deep. Mulching/shredding equipment is limited 

to slopes of 30 percent or less. Mulching/shredding efforts may be conducted in coordination with seeding operations, 

which would allow mulch and wood chips to cover the seed. 

Tilling 

Tilling involves the use of angled disks (disk tilling) or pointed metal-toothed implements (chisel plowing) to uproot, 

chop, and mulch vegetation. This technique is best used in situations where the complete removal of vegetation or 

thinning is desired, and in conjunction with seeding operations. Tilling leaves mulched vegetation near the soil 

surface, which encourages the growth of newly planted seeds. Tilling is usually done with a brushland plow, a single 

axle with an arrangement of angle disks that covers about 10-foot-wide swaths. An offset disk plow, which consists of 

multiple rows of disks set at different angles to each other, is pulled by a crawler-type tractor or a large rubber tire 

tractor. This method is often used for removal of shrubs, or to reduce annual competition from noxious weeds and 

other invasive non-native vegetation such as cheatgrass, and works best on areas with smooth terrain, and deep, rockfree soils. Chisel plowing can be used to break up soils such as hardpan. 

Roller Chopping 

Roller chopping tools are heavy bladed drums that cut and crush vegetation up to 5 inches in diameter with a rolling 

action. The drums are pulled by crawler-type tractors, farm tractors, or a special type of self-propelled vehicle 
ALTERNATIVES

3 Bars Project Final EIS 2-25 October 2016 

designed for wooded areas or range improvement projects. The drums can be offset to vary the mortality of target 

species. 

Feller-buncher 

Feller-bunchers are machines that grab trees, cut them at the base, pick them up, and move them into a pile or onto the 

bed of a truck. Feller-bunchers are used in woodland thinning to remove potential hazardous fuels. Large chippers, or 

“tub-grinders,” are often used to chip the limbs, bark, and wood of trees to generate mulch or for forest products 

utilization. 

Tree Shearer 

A tree shearer is an implement that attaches to a tractor and can be used to cut down (clip) trees up to about 14 inches 

in diameter with a single pass. The units can cut trees on a vertical or horizontal plane, and can be used to hold and 

move cut trees. 

2.5.3.3 Biological Control Treatments 

Biological control involves the intentional use of domestic animals, insects, nematodes, mites, or pathogens that 

weaken or destroy vegetation (USDOI BLM 2007c). Biological control is used to reduce the targeted vegetation to an 

acceptable level by removing vegetation, stressing target plants, or reducing competition with desirable plant species. 

The BLM is proposing to use targeted grazing to control cheatgrass in pinyon-juniper and sagebrush treatment units, 

and to control cheatgrass, crested wheatgrass, and forage kochia on the Rocky Hills Unit, and Table Mountain Unit 

(see Section 2.3.1.4). The BLM does not currently use classical biological control, but could do so in the future if 

effective control agents are found to control cheatgrass and other noxious weeds and invasive non-native vegetation. 

All biological treatment methods, including livestock grazing, would be available as treatment options under

Alternatives A and B in units where it is identified as a treatment option. 

Targeted Grazing 

Targeted grazing is the purposeful application of a specific kind of livestock at a determined season, duration, and 

intensity, to accomplish defined vegetation or landscape goals (American Sheep Industry 2006, Launchbaugh and 

Walker 2006). Targeted grazing would be conducted on the 3 Bars Project area to control cheatgrass and other nonnative species. The goal of targeted grazing is to give desired plant species a competitive advantage over cheatgrass 

and other non-native species. A successful grazing prescription should: 1) cause significant damage to the target 

species; 2) limit damage to the surrounding vegetation; and 3) be integrated with other control methods as part of an 

overall landscape management strategy. Targeted grazing would be authorized under existing grazing permits terms 

and conditions. 

Classical Biological Control 

Classical biological control involves the intentional use of insects, nematodes, mites, or pathogens (agents such as 

bacteria or fungi that can cause diseases in plants) that weaken or destroy vegetation. Biological control is used to 

reduce the targeted weed population to an acceptable level by stressing target plants and reducing competition with 

desirable plant species. 
ALTERNATIVES

3 Bars Project Final EIS 2-26 October 2016 

Plant-eating insects, nematodes, mites, or pathogens affect plants directly, by destroying vital plant tissues and 

functions, and indirectly, by increasing stress on the plant, which may reduce their ability to compete with other 

plants. Often, several biological control agents are used together to reduce the density of undesired vegetation to an 

acceptable level. 

Biological control agents used by the BLM have been tested by the USDA Agricultural Research Service and 

reviewed and permitted for release by the USDA Animal Plant Health Inspection Service to ensure that they are hostspecific and will feed only on the target plant and not on crops, native flora, or endangered or threatened plant species 

(USDOI BLM 2007c:2-16). 

2.5.3.4 Fire 

Fire includes the use of prescribed fire and wildland fire for resource benefit. Prescribed fire and wildland fire for 

resource benefit 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 

(USDOI BLM 2007c:2-13). To ensure treatment success, the BLM would follow guidance in the 2004 Battle 

Mountain District Fire Management Plan (USDOI BLM 2004a). 

Fire treatment methods would be available as a treatment option under Alternative A as either a primary treatment or 

for activity fuel disposal as identified in this Chapter. 

Prescribed Fire 

Prescribed fire is the intentional application of fire to wildland fuels under specified conditions of fuels, weather, and 

other variables. The intent is for the fire to stay within a predetermined area to achieve site-specific resource 

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. 

Prescribed burning would generally be completed during the spring months (February through June) or fall 

(September through December). For spring burns, the start date would be as early as possible after snowmelt to burn 

trees with minimal impacts to the soil and understory herbaceous vegetation. Fall burns would be scheduled based on 

prescriptions outlined in the burn plans for each specific treatment area. 

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. 

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 to 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. 
ALTERNATIVES

3 Bars Project Final EIS 2-27 October 2016 

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. 

2.5.3.5 Seeding and Planting 

All treatments could involve seeding or hand planting. Seeding would occur on disturbed sites when it has been 

determined that native vegetation growth and on-site seed source are inadequate to ensure successful revegetation of 

the site. If areas of the 3 Bars ecosystem have been impacted by wildfire and the site has not revegetated with 

desirable vegetation, seeding may be needed. Sagebrush treatment units could be overseeded to improve the 

composition and density of forbs, grasses, and shrubs found on the unit. Only native species would be used in 

sagebrush treatment units. Non-native seedings would be used to support fuels projects in areas with low moisture and 

that have previously burned, in old fire scar areas that are beyond use of Emergency Stabilization and Rehabilitation 

techniques, or for fuel breaks. Species selection would be based on site potential and objectives. A variety of seeding 

methods may be used. Depending on the terrain, soil type, soil moisture, and seed species, one or more of the 

following seeding methods may be used. 

Hand Seeding 

Hand seeding includes scattering seed by hand without the use of tools, or by using hand-held broadcast spreaders. 

Small areas may be planted with seedlings of key species such as sagebrush, cliffrose, or at higher elevations, 

bitterbrush. Seedlings would be planted in the early spring while soil moisture is adequate to allow for seedling 

establishment. 

Broadcast Seeding 

Broadcast seeding is the application of seed by tractor, or all-terrain vehicle. 

Drill Seeding

Drill seeding is the application of seed by Rangeland or Truax seed drills pulled behind a tractor, truck, or other 

vehicle. Seed drills operate on the principle of inserting (or drilling) the seed into the soil, thereby ensuring 

appropriate seeding depth and ground-to-seed contact. 

Often, drill seeding is conducted along with tilling. The seed drills, which consist of a series of furrow openers, seed 

metering devices, seed hoppers, and seed covering devices, are either towed by or mounted on a tractor. The seed drill 

opens a furrow in the seedbed, deposits a measured amount of seed into the furrow, and closes the furrow to cover the 

seed. 

Harrow Seeding 

Harrow seeding is the application of seed using a broadcast method, followed by pulling a series of spikes (usually 

attached in rows to a metal frame) along the ground to cover the seed and smooth the soil. This action improves the 

ground-to-seed contact. 
ALTERNATIVES 

3 Bars Project Final EIS 2-28 October 2016 

Aerial Broadcast Seeding 

Aerial broadcast seeding is the application of seed 

using airplanes or helicopters, with the seed falling 

through the air and landing randomly within the 

application area. 

Planting 

Plantings would be done by hand and would utilize 

container stock, bare root stock, or cuttings and would 

involve digging holes and burying root material. 

2.5.3.6 Firewood Cutting 

Many of the proposed treatment areas would be 

opened to green and dead firewood cutting for 

commercial and non-commercial uses. The 

authorization of green and dead firewood cutting 

within the proposed treatment areas would allow the 

public to utilize the pinyon and juniper that are 

proposed for removal. Treatment design would allow 

for up to 100 cords of fuel wood (greenwood and 

deadwood combined) to be removed for commercial 

sale annually, per unit. 

2.5.3.7 Streambank Stabilization and 

Channel Restoration 

As discussed in Chapter 1, natural and anthropogenic 

factors on the 3 Bars ecosystem have led to streams 

and associated meadows that are being threatened by 

knickpoints and headcuts, channel incision, and 

streambank erosion. Key stream components, such as 

stream channel sinuosity, streambank stability, and 

occurrence of woody and rock debris in stream 

channels, help to dissipate flood energy, but are 

lacking in many streams on the 3 Bars Project area. 

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. 

Stream Restoration Terminology 

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. 

Culvert retrofit is a method of stabilization which consists of 

raising the effective invert elevation of an existing culvert without 

replacing the existing installed pipe. Bed control can be achieved 

without the cost of a new culvert installation. 

Hardened rock crossing is a form of low water crossing with 

utilizes rock to reduce the impact of vehicle and animal traffic on a 

stream crossing. 

Log and fabric step fall is 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. 

Rock channel liner is 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. 

Step pools and rock rundowns are stabilization structures 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. 

Vane is 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. 

Vegetation manipulation is 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. 

Weir is a structure of various material content, which spans the 

bankfull width of a channel and is used to control the slope, or 

grade, of a stream. 

Zuni bowl is 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 velocity within a manageable 

range. 
ALTERNATIVES

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 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. 

The BLM would also use bioengineering to restore stream functionality. Bioengineering integrates living woody and 

herbaceous materials with organic and inorganic materials to increase the strength and structure of the soil. In 

particular, this would be accomplished through the use of native plantings that would result in a dense matrix of roots 

to hold the soil together. The above-ground vegetation would increase the resistance to water flow and reduce flow 

velocities by dissipating energy. The biomass also acts as a buffer against the abrasive effect of water-transported 

materials and allows for sediment deposition due to low shear stress near the bank (Bentrup and Hoag 1998). 

2.5.3.8 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. 

Forest Products Utilization 

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. 

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 

3 Bars Project Final EIS 2-29 October 2016 
ALTERNATIVES

3 Bars Project Final EIS 2-30 October 2016 

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 

Material generated from treatment activities would be left on-site in small piles as wildlife habitat. 

2.5.4 Standard Operating Procedures and other Resource Protections 

Standard Operating Procedures would be followed by the BLM under all alternatives to ensure that risks to human 

health and the environment from treatment actions would be kept to a minimum. Standard Operating Procedures are 

the management controls and performance standards required for vegetation management treatments and streambank 

stabilization. These practices are intended to protect and enhance natural resources that could be affected by future 

treatments. 

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 would be used 

for the 3 Bars Project are provided in Appendix C. 

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 (USDOI BLM 2007b:2-35). 
ALTERNATIVES

3 Bars Project Final EIS 2-31 October 2016 

Two types of monitoring of vegetation treatments may be pursued by the BLM. One type is implementation 

monitoring, which answers the question, “Did we do what we said we would do?” The second type is effectiveness 

monitoring, which answers the question, “Were treatment and restoration projects effective?” Implementation 

monitoring is usually done at the land use planning level or through annual work plan accomplishment reporting. 

Effectiveness monitoring is usually done at the local project implementation level. 

Implementation monitoring for vegetation treatments is accomplished through site visits during the growing season of 

the target species to determine whether treatments were implemented correctly and to identify the best time for 

follow-up treatments. Monitoring would be used to phase in treatments over time to ensure objectives are being met. 

The diversity of plant communities on the 3 Bars Project area calls for a diversity of monitoring approaches. 

Monitoring strategies may vary in time and space depending on the target species. Sampling designs and techniques 

vary depending on the type of vegetation. Guidance on monitoring methodologies can be found in such BLM 

documents as Measuring and Monitoring Plant Populations (BLM Technical Reference 1730-1; Elzinga et al. 1998), 

which was developed in cooperation with The Nature Conservancy. Other guidance documents include Sampling 

Vegetation Attributes (USDA and USDOI 1999), developed in cooperation with the Forest Service, the Natural 

Resources Conservation Service, and the Cooperative Extension Service; and Ecological Site Inventory (BLM 

Inventory and Monitoring Technical Reference 1734-7; Habich 2001). These documents, as well as numerous other 

guidance documents for specific plant communities, can be found on the National Science and Technology Center 

website at Uniform Resource Locator (URL): http://www. blm. gov/nstc. These documents, plus any regionally 

specific documents developed to meet management objectives, allow the flexibility needed to monitor the variety of 

vegetation found on public lands. 

Within Greater sage-grouse habitat, effectiveness monitoring would be performed to assess if treatments are meeting 

specific habitat objectives as outlined within Table 2-2 in the Nevada and Northeastern California Greater SageGrouse Approved Resource Management Plan Amendment (USDOI BLM 2015). 

Post-restoration monitoring of stream stabilizing treatments would 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 would be used to 

document general changes that take place between retakes. Vegetation would be monitored to detect changes in plant 

species composition, cover, density, vigor, reproduction, age class distribution, decadence, and mortality. When a 

treatment objective is to improve wildlife or aquatic habitat, the BLM would conduct surveys to detect and measure 

change in ecological conditions favoring different classes or species of animals. Geomorphological monitoring would 

be used to detect and measure changes in dimension, plan, and profile of the project stream reach. This would consist 

of transects or complete 3-dimensional modeling for entire stream reaches. Hydrologic monitoring, through the use of 

piezometers, would be utilized when the primary objective of treatment for the site is to increase base flows. 

Structural design, implementation, and monitoring for stream restoration within the 3 Bars Project Area would follow 

guidelines provided by Zeedyk and Clothier (2009). 

The BLM has prepared numerous guidance and strategy documents, as listed in the 17-States PEIS, to aid field 

personnel in developing and implementing monitoring plans and strategies. This list can be accessed at URL: 

http://www. blm. gov/wo/st/en/prog/more/veg_eis. html. Numerous other technical references for inventory, 

monitoring, and assessment are found at URL: http://www. blm. gov/nstc/library/techref. htm. The results of 

monitoring would be made available to interested parties upon request. 
ALTERNATIVES

3 Bars Project Final EIS 2-32 October 2016 

2.5.6 Coordination and Education 

As demonstrated at public scoping meetings for the EIS, the public is deeply interested in BLM treatment activities. 

This is especially true of individuals who live in close proximity to public lands, who have commercial operations 

dependent on vegetation on or adjacent to public lands including grazing permittees, or who use public lands for 

recreation. The BLM strives to keep the public informed about its treatment activities through regular coordination 

and communication. The BLM also encourages the public to participate in the environmental review process during 

the development and analysis of local vegetation management programs. 

Several laws and Executive Orders set forth public involvement requirements, including involving the public in the 

environmental analysis and land use planning to address local, regional, and national interests. The NEPA process 

ensures that the public is allowed input into management actions on public lands. For treatment projects requiring an 

EIS or Environmental Assessment, the BLM must notify the public of the proposed project and give the public the 

opportunity to comment on the site-specific analysis done for the project. Treatment actions may be modified in 

response to comments posed by the public. The public may also be invited to observe treatment activities and 

participate in project monitoring. 

The BLM is ultimately responsible for land use decisions, including decisions about vegetation management, on 

public lands. The BLM has found, however, that collaborative relationships with stakeholders, including individuals, 

communities, tribes, and local governments, improves communication, provides a greater understanding of different 

perspectives, and helps to find solutions to issues and problems. Input from the public, tribes, and government 

agencies has been critical during development of this EIS. 

3 Bars Project lands are commingled with private lands, and lands under the jurisdiction of tribal, state, or local 

governments or other federal agencies are nearby. Multijurisdictional planning assists land use planning efforts when 

there is a mix of land ownership and government authorities, and there are opportunities to develop complementary 

decisions across jurisdictional boundaries. 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. 

2.6 Summary of Alternatives Analyzed in this EIS 

Table 2-1 shows how each of the alternatives respond to the project purposes. Information contained in these tables is 

discussed in more detail in Chapter 3 (Affected Environment and Environmental Consequences). 

2.7 Alternatives Considered but not Further Analyzed 

Several other alternatives were identified during public scoping and reviewed by the BLM interdisciplinary team. 

These alternatives would not fulfill the purpose and need for the project, are inconsistent with BLM or other federal, 

state, or local policies or regulations, or are not practical based on likely funding for vegetation treatments. The 

alternatives that were considered, but not further analyzed are: 

 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 
ALTERNATIVES

3 Bars Project Final EIS 2-33 October 2016 

TABLE 2-1 

Responses of the Alternatives to the Project Purposes 

Analysis Element

Alternative A 

(Preferred 

Alternative/All 

Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land 

Disturbance)

Alternative D 

(No Action 

Alternative)

Improve woodland and rangeland health, productivity, and functionality. 

Approximate total 

acreage treated during 

life of project1, 2

127,000 63,500 31,750 03

Treatment methods 

used to improve 

ecosystem health

Manual, mechanical, 

biological control, and 

fire

Manual, mechanical, 

and biological control

Manual and classical 

biological control NA

Number of resources 

typically benefitting 

from projects

Numerous resources Numerous resources Numerous resources No resources

Grazing restrictions in 

treated areas

Yes, but can vary with 

treatment objectives Same as Alternative A Same as Alternative A NA

Increase stream flows and restore channel morphology in degraded streams. 

Approximate acreage 

of wetland and 

riparian habitat treated 

annually2

400 200 100 03

Treatment methods 

used

Manual, mechanical, 

and fire

Manual and 

mechanical Manual NA

Possible use of

fencing to restrict 

livestock and horse 

access to riparian 

areas?

Yes Yes Yes NA

Improve stream habitat for fish and wildlife by implementing physical treatments that include installing large 

woody debris, rock clusters, check dams, plantings, and using fencing to minimize use by large herbivores. 

Approximate miles of 

stream restored/ 

enhanced annually2

31 31 8 03

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. 

Approximate acres of 

mountain tree and 

shrub stands treated 

annually2

6,000-9,000 3,000-4,500 750-1,125 03
ALTERNATIVES 

3 Bars Project Final EIS 2-34 October 2016 

TABLE 2-1 (Cont.) 

Responses of the Alternatives to the Project Purposes 

Analysis Element

Alternative A 

(Preferred 

Alternative/All 

Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land 

Disturbance)

Alternative D 

(No Action 

Alternative)

Manage pinyon-juniper woodlands to promote healthy, diverse stands within persistent woodlands. 

Approximate acreage 

of pinyon-juniper

woodlands treated 

annually2

6,000-9,000 3,000-4,500 750-1,125 03

Treatment methods 

used

Manual, mechanical, 

and fire

Manual and 

mechanical Manual NA

Phase classes targeted 

for treatment4 Phases I, II, and III Phases I and II Phase I and limited acreage of Phase II NA

Slow the expansion of pinyon/juniper into sagebrush and riparian plant communities. 

Approximate acreage 

of pinyon-juniper 

encroachment treated 

annually2

7,700-11,600 3,900-5,800 1,925-2,900 03

Treatment methods 

used

Manual, mechanical, 

and fire

Manual and 

mechanical Manual NA

Phase classes targeted 

for treatment4

Phases I and II, and 

some Phase III Phases I and II Phase I and limited amount of Phase II NA

Improve sagebrush habitat and restore sagebrush to areas of historic occurrence by removing trees in 

sagebrush habitats and improving the diversity of sagebrush communities. 

Approximate acreage

of sagebrush habitat 

treated annually2

7,600-11,500 Same as Alternative A 1,900-5,700 03

Acres of historic 

sagebrush habitat 

restored annually2

7,600-11,500 Same as Alternative A 2,400-3,600 03

Treatment methods 

used

Manual, mechanical, 

biological control, and 

fire

Manual, mechanical, 

and biological control

Manual and classical 

biological control NA

Slow the spread of noxious weeds and invasive non-native vegetation, including cheatgrass. 

Approximate acreage 

of noxious weeds and 

other invasive species 

treated annually2

100-250 Same as Alternative A Same as Alternative A 03

Treatment methods 

used

Manual, mechanical, 

biological control, and 

fire

Manual, mechanical, 

and biological control

Manual and classical 

biological control NA
ALTERNATIVES

3 Bars Project Final EIS 2-35 October 2016 

TABLE 2-1 (Cont.) 

Responses of the Alternatives to the Project Purposes 

Analysis Element

Alternative A 

(Preferred 

Alternative/All 

Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land 

Disturbance)

Alternative D 

(No Action 

Alternative)

Protect and enhance habitat for fish and wildlife, including species of concern such as raptors, Greater sagegrouse, and Lahontan cutthroat trout. 

Approximate acres of 

sagebrush habitat

treated annually2

3,100 Same as Alternative A 300-500 03

Approximate acres of 

key habitat treated 

annually to improve 

species diversity2

2,000-3,500 1,500-2,600 200-350 03

Approximate acres of 

key habitat improved 

annually through 

thinning and removal 

of pinyon-juniper in 

expansion areas2

7,700-11,600 Same as Alternative A 1,925-2,900 03

Approximate miles of 

stream restored for 

Lahontan cutthroat 

trout and other aquatic 

organisms2

31 Same as Alternative A 8 03

Restore fire as an integral part of the ecosystem; reduce the risk of a large-scale wildfire; reduce extreme, very 

high, and high wildfire risks to moderate risk or less; create fuel breaks; and protect life, property, community 

infrastructure, and fish and wildlife habitat from wildfire. 

Approximate acreage 

treated annually to 

reduce hazardous 

fuels2

12,700 6,350 3,175 03

Approximate acreage 

converted annually 

from Fire Regime 

Condition Classes III

and II, to Classes II

and I

2

9,525 750-1,500 375-750 03

1 Total acres treated based on maximum number of acres that could be treated in each project unit. 2 Acres and miles treated contingent upon funding and staff resource availability. 3 No new treatments would be authorized under Alternative D. Only projects that are currently authorized by the Mount Lewis Field 

Office, or that would be authorized in the future under new NEPA analysis and decisions, would occur on the 3 Bars Project area. 

Currently authorized projects are discussed in Chapter 3 under Cumulative Effects (Section 3.3.2). 4 Phases are based on stand characteristics that differentiate between three transitional phases of woodland succession based on tree 

canopy, leader growth (of dominant and understory trees), crown lift, potential berry production, tree recruitment, and the shrub layer. 

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. 

NA = Not applicable. 
ALTERNATIVES 

the landscape that contribute to resource impacts, such as grazing, timber harvest, and mining. In addition, 

the BLM would only use vegetation treatment methods that cause little site disturbance, primarily manual 

methods. The BLM would be allowed to continue Emergency Stabilization and Rehabilitation activities, 

including seeding (manual and mechanical) and hand planting of vegetation. This alternative was eliminated 

because it would not control the spread of unwanted vegetation or improve the health of the 3 Bars 

ecosystem, and is not consistent with the Federal Land Policy and Management Act. The use of treatment 

methods that would result in minimal disturbance to the landscape are being evaluated under Alternative C 

(Minimal Land Disturbance Alternative). 

 Revegetate solely with native vegetation. Under this alternative, only native vegetation would be used to 

restore fire-impacted and other degraded public lands. This alternative was eliminated because the use of 

only native vegetation to restore degraded lands would not meet some of the project purposes discussed in 

Chapter 1. However, the use of native vegetation to restore degraded lands has been incorporated into 

Alternatives A, B, and C to the extent practical, as discussed in Section 2.5.3.5 (Seeding and Planting). 

 Exclude logging, grazing, off-highway vehicle use, and energy and mineral development on public 

lands. This alternative was eliminated because the Federal Land Policy and Management Act requires that 

the BLM manage public lands for multiple uses, including those listed, and because it is not consistent with 

the Shoshone-Eureka RMP. 

2.8 Mitigation 

As defined by CEQ regulation 1508.20, mitigation includes: 1) avoiding the impact altogether by not taking a certain 

action or parts of an action; 2) minimizing impacts by limiting the degree or magnitude of the action and its 

implementation; 3) rectifying the impact by repairing, rehabilitating, or restoring the affected environment; 4) 

reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; 

and 5) compensating for the impact by replacing or providing substitute resources or environments (CEQ 2012). 

Mitigation measures for livestock grazing are discussed in Section 3.18.4 (Livestock Grazing, Mitigation), however, 

these are not mitigation measures but, actions that may be made prior to treatment implantation. 

2.9 Summary of Impacts by Alternative 

Table 2-2 summarizes the likely effects of restoration and resource management activities for each alternative. 

Information contained in this table is discussed in more detail in Chapter 3 (Affected Environment and Environmental 

Consequences). 

3 Bars Project Final EIS 2-36 October 2016 
Altern

Direct 

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3 Bars Project Final EIS 2-37 October 2016 

ALTERNATIVES

TABLE 2-2 

Summary and Comparison of Effects on Resources by Alternative 

Alternative A (Preferred 

ative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

SUMMARY OF EFFECTS ON GLOBAL CLIMATE

and Indirect Effects: The use of 

ent and fire treatment methods 

elease carbon dioxide (CO2), a 

use gas, to the environment. 

9,115 tons of CO2 would be 

to the atmosphere annually, but

on global climate change would be 

le. Treatments to reduce the 

ce of wildfire, and associated CO2

ns, would be greatest under this 

ve. 

Direct and Indirect Effects: There would 

be no CO2 emissions from prescribed fire 

and wildland fire for resource benefit 

under this alternative. Mechanical, 

manual, and biological control treatments 

would emit about 5,600 tons of CO2 to the 

environment annually, and effects on 

global climate change would be 

negligible. Treatments would reduce the 

incidence of wildfire, but not to the same 

extent as under Alternative A. 

Direct and Indirect Effects: The only 

CO2 emissions would be from use of 

manual equipment and worker transport. 

Only about 2 tons of CO2 emissions would 

occur annually, and their effects on global 

climate change would be negligible. 

Treatments would do less to reduce 

wildfire risk and smoke emissions than 

under Alternatives A and B. 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no emissions 

of CO2 or other emissions that could 

contribute to global warming. CO2

emissions from wildfire would likely be 

greater under this alternative than the 

action alternatives. 

ative Effects: Effects of future fire 

 and CO2 emissions are hard to 

CO2 emissions in the cumulative 

tudy area (CESA) would occur 

velopment and other projects, but 

s would still be the primary 

utor of CO2 to the atmosphere. 3 

oject treatments would contribute 

000003 percent to the national 

use gas emissions annually and 

negligible cumulative effect. 

Cumulative Effects: CO2 emissions from 

treatment activities under Alternative B 

would be about one-fourth those under 

Alternative A, but would have a negligible 

cumulative effect on regional and national 

greenhouse gas emissions. 

Cumulative Effects: CO2 emissions from 

treatment activities under Alternative C 

would be about 0.01 percent of those 

under Alternative A, and would have a 

negligible cumulative effect on regional 

and national greenhouse gas emissions. 

Cumulative Effects: No treatments 

would be authorized under this alternative 

and there would be no cumulative effects. 

CO2 emissions from wildfires within the 

CESA would likely be greatest under this 

alternative. 

ion: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON AIR QUALITY

and Indirect Effects: Air quality 

e affected from use of vehicles 

er equipment, dust from roads and 

nt activities, and from fire use. 

 the predicted annual emissions by 

t would exceed national or state 

Direct and Indirect Effects: Air quality 

would be affected from use of vehicles 

and other equipment, and dust from roads 

and treatment activities. There would be 

no fire treatments and smoke production. 

None of the predicted annual emissions by 

Direct and Indirect Effects: Air quality 

would be affected from use of vehicles 

and manual equipment; there would be no 

emissions associated with mechanical and 

fire treatments. None of the predicted 

annual emissions by pollutant would 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no air 

emissions. However, the BLM would do 

little to reduce the risk of wildfire, so air 

pollutant emissions could be greater under 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-38 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

air quality standards. Particulate matter 

concentrations from treatments are 

expected to be negligible based on 

modeling. Treatments to reduce wildfire 

occurrence would benefit air quality, as 

wildfire impacts on air quality are 

generally greater than those from 

prescribed fire. 

pollutant would exceed national or state

air quality standards. Particulate matter 

concentrations from treatments are 

expected to be negligible based on 

modeling, and less than those under 

Alternative A. Treatments to reduce 

wildfire occurrence would benefit air 

quality, but benefits would be less under 

Alternative B than under Alternative A. 

exceed national or state air quality 

standards. Particulate matter 

concentrations from treatments are 

expected to be negligible and less than 

those under Alternatives A and B. 

Treatments to reduce wildfire occurrence 

would benefit air quality, but benefits 

would be less under Alternative C than 

under Alternatives A and B. 

this alternative than the other alternatives. 

Cumulative Effects: Land development 

and associated infrastructure would have 

adverse air quality effects. Given that 3 

Bars Project treatments would affect only 

1 percent of the CESA annually, treatment 

effects on regional air quality would be 

negligible. Treatments would reduce the 

likelihood of wildfire, which is an 

important contributor to air quality 

impacts in the CESA. 

Cumulative Effects: 3 Bars Project 

treatments under Alternative B would 

affect only half as much acreage as treated 

under Alternative A, and the BLM would 

not use fire treatments. Thus, particulate 

matter and other air emissions from 

treatments would be substantially less 

under Alternative B than under 

Alternative A and would have a negligible 

cumulative effect on regional air quality. 

Treatments would reduce the likelihood of 

wildfire, but not to the same extent as 

would occur under Alternative A. 

Cumulative Effects: 3 Bars Project 

treatments under Alternative C would be 

substantially less than under Alternatives 

A and B, as manual and biological control 

treatments have few air emissions. Thus, 

particulate matter and other air emissions 

from treatments would have a negligible 

cumulative effect on regional air quality. 

Treatments would reduce the likelihood of 

wildfire, but not to the same extent as 

would occur under Alternatives A and B. 

Cumulative Effects: No treatments 

would be authorized under this alternative 

and there would be no cumulative air 

quality effects. Air quality effects from 

wildfires within the CESA would likely be 

greatest under this alternative. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON GEOLOGY AND MINERALS

Direct and Indirect Effects: Geology 

resources would not be affected. Mineral 

resources may be needed for stream 

restoration, but gravel and rock resources 

in the project area are abundant and 

treatments would have negligible effects 

on minerals. Treatments could hinder 

mineral exploration and development. 

Direct and Indirect Effects: Geology 

resources would not be affected. Effects 

on local gravel and rock resources would 

be similar to those under Alternative A. 

Potential conflicts over access to and use 

of mineral resources should occur about 

half as often as compared to Alternative 

A. 

Direct and Indirect Effects: Geology 

resources would not be affected. Effects 

on local gravel and rock resources would 

be about one-fourth those under 

Alternative A. Potential conflicts over 

access to and use of mineral resources 

should occur about one-fourth as often as 

compared to Alternative A. 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no effects to 

geology and mineral resources. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-39 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Cumulative Effects: Geology resources 

would not be affected. In the context of 

other ongoing and proposed development, 

including mining, in the CESA, 

cumulative effects to mineral resources 

would be negligible under Alternative A. 

Cumulative Effects: Geology resources 

would not be affected. In the context of 

other ongoing and proposed development, 

including mining, in the CESA, 

cumulative effects to mineral resources 

would be similar to those under 

Alternative A. 

Cumulative Effects: Geology resources 

would not be affected. In the context of 

other ongoing and proposed development, 

including mining, in the CESA, 

cumulative effects to mineral resources 

would be negligible under Alternative C 

and about one-fourth less than those under 

Alternatives A and B. 

Cumulative Effects: No treatments 

would be authorized under this alternative 

and there would be no cumulative effects 

to geology or mineral resources. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON PALEONTOLOGICAL RESOURCES

Direct and Indirect Effects: Treatments 

that disturb the soil to depths greater than 

6 inches, or bedrock, have the potential to 

disturb paleontological resources. 

Mechanical treatments in riparian zones, 

and use of prescribed fire near bedrock, 

have the greatest potential to affect 

paleontological resources. However, most 

treatments under Alternative A would 

occur above or only within the first few 

inches of soil. Overall, potential effects to 

paleontological resources from treatments 

would be negligible. 

Direct and Indirect Effects: The BLM 

would use mechanical equipment near 

streams and to till soil. Because the BLM 

would not use fire under this alternative, 

the BLM may use mechanical treatments 

instead of fire treatments in some 

treatment areas. Still, potential effects to 

paleontological resources would be less 

under Alternative B than under 

Alternative A. 

Direct and Indirect Effects: The BLM 

would not use mechanical equipment or 

fire, thus potential effects to 

paleontological resources would be 

substantially less under Alternative C than 

under Alternatives A and B. The BLM 

would treat only a few miles of stream, 

thus there could be future loss of 

paleontological resources from stream 

degradation. 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no adverse 

effects to paleontological resources. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-40 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Cumulative Effects: Surface-disturbing 

activities, including mining and drilling,

could affect paleontological resources in 

the CESA. Less than 2 percent of the 

CESA would be disturbed annually by 3 

Bars Project activities, and most 

treatments would disturb only the upper 

few inches of soil. Thus, cumulative 

effects to paleontological resources from 

project actions would be negligible. 

Cumulative Effects: Although the BLM 

may conduct more mechanical treatments 

under Alternative B than under the other 

alternatives, treatment effects would 

generally be limited to the upper few 

inches of soil. In addition, only about half 

as many acres would be treated under 

Alternative B than under Alternative A. 

Thus, cumulative effects to 

paleontological resources from project 

actions would be negligible. 

Cumulative Effects: The BLM would not 

use equipment or fire for restoration 

treatments, and would treat only onefourth as many acres as under Alternative 

A. Thus, potential cumulative effects to 

paleontological resources from the 3 Bars 

Project would be negligible. 

Cumulative Effects: No treatments

would be authorized under this alternative 

and there would be no cumulative effects 

to paleontological resources. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON SOIL RESOURCES

Direct and Indirect Effects: Restoration 

treatments could lead to short-term 

erosion, and reduced rates of water 

infiltration, from soil disturbance and 

compaction. Effects may be greater for 

stream restoration projects, and where 

heavy equipment or fire are used. Risks 

would be greatest in areas with erosionprone soils and on hillslopes, and areas 

with high fire damage susceptibility. 

Adverse effects would be greatest under 

Alternative A as about 90 percent of 

treatments are in pinyon-juniper, which 

are often found on slopes, and which 

could be burned under this alternative. 

However, treatments would improve the 

health and resiliency of native vegetation, 

reduce the risk of wildfire, and control 

noxious weeds and other invasive nonDirect and Indirect Effects: Short-term

soil erosion and compaction, and loss of 

soil productivity, would occur under 

Alternative B, but not to the extent that 

would occur under Alternative A. The 

BLM would not treat vegetation using 

fire, thus there would be less risk of loss 

of soil organic matter and potential 

formation of water-repellent surface layers 

from fire use. However, in place of fire, 

the BLM may conduct more mechanical 

treatments that could disturb the soil and 

possibly cause erosion to a greater extent 

than fire use. Because the BLM would not 

use fire, it would less able to improve the 

health of pinyon-juniper stands and create 

fuel breaks than would occur under 

Alternative A. The BLM would also treat 

only about half as many acres under 

Direct and Indirect Effects: Short-term 

loss of soil to erosion and soil compaction,

and potential for soil disturbance to lead to 

an increase in noxious weeds and invasive 

non-native vegetation, would be less under 

this alternative than under Alternatives A 

and B as the BLM would only use manual 

and classical biological control treatments, 

and would only treat about 3,200 acres 

annually. However, long-term benefits to 

soil health and productivity would be less 

under this alternative because the BLM 

would be able to do little to improve soil 

fertility, increase infiltration, reduce 

erosion, and implement actions to reduce 

the risk of wildfire. 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no effects to 

soil resources. However, the BLM would 

do little to improve the health of the 

landscape, reduce the occurrence and 

spread of noxious weeds and invasive 

non-native vegetation, or reduce the risk 

of wildfire. Thus, long-term loss of soil 

and soil productivity could be greater 

under this alternative than the other 

alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-41 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

native vegetation, to the benefit of soil 

productivity and reduction of loss of soil 

due to erosion. Treatments should also 

improve soil infiltration, biodiversity, and 

moisture. Since the BLM would treat 

about 12,700 acres annually, adverse and 

beneficial effects of treatments would be 

greatest under Alternative A. 

Alternative B than under Alternative A. 

Thus, the risk of wildfire, and its effects 

on soil, would be greater under this 

alternative than under Alternative A. 

Cumulative Effects: Numerous factors 

have contributed to soil degradation and 

productivity, including historic 

overgrazing, large wildfires, introduction 

of cheatgrass, and mining and other land 

development. To help improve soil 

function and productivity, the BLM would 

treat about 14,200 acres (12,700 for 3 Bars 

Project treatments, and 1,500 for other 

authorized treatments) annually within the 

CESA, or less than 1 percent of the 

CESA, and restore about 31 miles of 

stream, using all treatment methods. 

Treatments would have negligible shortterm cumulative effects, but long-term, 

treatments under Alternative A would help 

to reduce the risk of wildfire, a major 

contributor to soil loss and function, and 

would help to offset the effects from loss 

of soil function and productivity 

elsewhere in the CESA. 

Cumulative Effects: Short-term 

cumulative effects from treatments under 

Alternative B would be similar to those 

under Alternative A. Although fire would 

not be used under this alternative, the 

BLM may have to conduct more 

mechanical treatments to achieve 

treatment goals. Still, the BLM would 

only treat about 7,800 acres (6,300 for 3 

Bars Project treatments, and 1,500 for 

other authorized treatments) annually 

within the CESA, and would not conduct 

fire treatments in pinyon-juniper stands on 

hillslopes, to the short-term benefit of soil 

resources. The BLM would not be able to 

use fire to improve ecosystem health. 

Thus, risks to soil from deterioration in 

ecosystem health and from wildfire would 

be greater under this alternative than under 

Alternative A. 

Cumulative Effects: Because the BLM 

would treat only about 4,700 acres (3,200 

acres for 3 Bars Project treatments, and 

1,500 for other authorized treatments) 

annually within the CESA, and would not 

use mechanical treatments and fire, shortterm effects associated with these methods 

would not occur within the CESA. 

Without these methods, though, 

improvements to the soil would be less, 

and risk of wildfire would be greater, 

within the project area and CESA than 

under Alternative A and B, and loss of soil 

function and health would accumulate 

with losses elsewhere in the CESA. 

Cumulative Effects: No treatments 

would be authorized under this alternative 

and there would be no cumulative effects 

to soil resources from treatments. 

Treatments under Alternative D would do 

little to offset effects to soils from other 

reasonably foreseeable future actions in 

the CESA. The BLM could create fire and 

fuel breaks; thin and remove pinyonjuniper to promote healthy, diverse stands; 

slow the spread of noxious weeds and 

other invasive non-native vegetation using 

ground-based and aerial applications of 

herbicides, especially cheatgrass; restore 

fire as an integral part of the ecosystem; 

and reduce the risk of large-scale wildland 

fire under current and reasonably 

foreseeable future authorized actions, but 

only on about 1,500 acres annually. The 

trend toward large-sized wildfires of 

moderate to high severity in sagebrush and 

large stand-replacing wildfires in pinyonjuniper would likely increase. As a result, 

soil resources would continue to 

deteriorate under this alternative. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-42 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON WATER RESOURCES

Direct and Indirect Effects: Short-term, 

there could be restrictions on water access 

along portions of streams. Removal of 

vegetation and disturbance of the soil 

could lead to increases in water runoff and 

soil erosion and decrease in infiltration, 

groundwater recharge, stream flows, and 

flow duration. Treatments could lead to 

impacts to streambeds and banks due to 

removal of undesirable riparian 

vegetation, and from in-channel 

earthwork, which could cause erosion and 

affect water quality. Long-term, 

hydrologic functions would improve due 

to stream restoration, including 

stabilization or reduction of drainageway 

erosion features such as knickpoints, 

headcuts, gullies, and bank caving, and 

from reconnecting hydrologic pathways. 

Treatments would improve infiltration, 

base streams flows, and the amount of 

time water flows in streams. Treatments 

would help to stabilize soils and reduce 

the risk of wind and water erosion. 

Removal of hazardous fuels from public 

lands and improvements to vegetation 

resiliency would result in a long-term 

benefit to surface water quality by 

reducing the risk of a future high-severity 

wildfire on the treatment site. 

Direct and Indirect Effects: Excluding 

prescribed burns would avoid the 

increases in runoff and erosion common to 

burned areas. Reduced soil infiltration, 

due to resinous sealing after intense 

burning that can occur in high fire 

susceptibility risk areas, would not occur 

as a result of prescribed burns. Long-term, 

the BLM would have fewer options, and 

treat only half as many acres, under 

Alternative B as compared to Alternative 

A to improve pinyon-juniper and other 

vegetation health and resiliency and to 

stabilize soils and reduce the risk of wind 

and water erosion. Less work would be 

done in Phase II and III pinyon-juniper 

stands, to the detriment of base water 

flows, than under Alternative A. This 

could lead to greater risk of wildfire, and 

its effects on water quality and quantity, 

than under Alternative A. If mechanical 

methods are used instead of fire, they 

could result in more soil disturbance than 

the use of fire, which could lead to water 

impacts in areas with high water erosion 

risk. 

Direct and Indirect Effects: The risk of 

localized soil compaction and short-term 

accelerated erosion from treatments, and 

its contribution to water quality impacts, 

would be less under Alternative C than the 

other action alternatives, as there would be 

little ground disturbance under Alternative 

C and only one-fourth as many acres 

would be treated as compared to 

Alternative A. By not being able to use 

mechanical methods and fire to reduce 

hazardous fuels, including noxious weeds 

and invasive non-native vegetation and 

decadent pinyon-juniper, and create fire 

and fuel breaks, the risk of wildfire and its 

impacts on water resources would be 

greater under this alternative than under

the other action alternatives. 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. However, the BLM would do 

little to improve the health of the 

landscape, reduce the occurrence and 

spread of noxious weeds and invasive 

non-native vegetation, or reduce the risk 

of wildfire. Thus, long-term adverse 

effects to water quantity and quality could 

be greater under this alternative than the 

other alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-43 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Cumulative Effects: Numerous factors 

have degraded water resource quantity and 

quality on the project area, including 

historic overgrazing, large wildfires, 

introduction of cheatgrass, and land 

development. The Mount Hope Project 

could impact groundwater levels and 

streamflows on the 3 Bars Project area. 

Hazardous fuels reduction, habitat 

improvement, and noxious weeds and 

invasive non-native species control 

projects would occur on approximately 

142,000 acres, or 8 percent of the CESA 

(about 1 percent of the CESA annually), 

using all treatment methods. The BLM 

would also restore about 31 miles of 

stream. Treatments would have negligible 

short-term cumulative effects, but longterm, there would be benefits to water 

quality and possibly to water flows. 

Treatments would also help to reduce the 

risk of wildfire, a major contributor to 

water degradation, and would help to 

offset the effects from degradation 

elsewhere in the CESA. 

Cumulative Effects: Short-term 

cumulative effects to water resources from 

treatments under Alternative B would be 

similar to those for Alternative A. 

Although fire would not be used under 

this alternative, the BLM may have to 

conduct more mechanical treatments to 

achieve treatment goals. The BLM would 

not conduct fire treatments in pinyonjuniper stands on hillslopes, to the shortterm benefit of water resources. Under 

Alternative B, annual hazardous fuels 

reduction and habitat improvement 

projects could occur on about 6,300 acres 

within the 3 Bars Project area, and on an 

additional 1,500 acres within the CESA, 

or less than 1 percent of acreage within the 

CESA. The BLM would not be able to use 

fire to improve ecosystem health. Thus, 

risks to water resources from deterioration 

in ecosystem health and from wildfire 

would be greater under this alternative 

than under Alternative A. 

Cumulative Effects: Because the BLM 

would not use mechanical treatments and 

fire, short-term effects associated with 

these methods would not occur within the 

CESA. Without these methods, though, 

improvements to water resources would 

be less, and risk of wildfire would be 

greater, within the project area under this 

alternative than under Alternatives A and 

B, and loss of water resource functionality 

would accumulate with losses elsewhere 

in the CESA. 

Cumulative Effects: No treatments 

would be authorized under this alternative 

and there would be no cumulative effects 

to water resources from treatments. The 

BLM would be able to conduct treatments 

on a limited acreage, as discussed above 

under Soil Resources, but treatments 

under Alternative D would do little to 

offset effects to water resources from 

other reasonably foreseeable future actions 

in the CESA. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES

Direct and Indirect Effects: Short-term,

removal of vegetation and soil disturbance 

associated with treatments could lead to 

increased soil erosion and surface water 

runoff, which could lead to channel 

alteration and sedimentation in wetlands 

Direct and Indirect Effects: Under this 

alternative, the BLM would likely be able 

to restore a similar amount of Nonfunctioning and Functioning-at-risk 

wetlands and riparian zones to Proper 

Functioning Condition as under 

Direct and Indirect Effects: Under 

Alternative C, the BLM would only treat 

about 8 stream miles and one-fourth as 

much riparian zone habitat as under 

Alternative A. By treating fewer acres, 

and not using fire and mechanical 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no effects to 

wetlands, floodplains, and riparian zones. 

However, the BLM would do little to 

improve the health of the landscape, 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-44 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

and riparian zones. Siltation could reduce 

the acreage of wetland and riparian 

habitat. Removal of vegetation could also 

decrease the amount of rainfall captured 

by plants, detritus, and soil, potentially 

leading to increased stormwater flows and 

runoff velocity in streams. Increased light 

and disturbance tend to favor early 

successional species, including noxious 

weeds and other invasive non-native

vegetation. Removal of vegetation may 

decrease resistance to overland flow. It 

would also decrease canopy interception 

of precipitation and evapotranspiration, 

which would increase the amount of free 

water. Long-term, vegetation treatments 

would help restore treated wetlands and 

riparian zones to Proper Functioning 

Condition and increase stream flows along 

about 31 miles of stream. Removal of 

pinyon-juniper may improve water flows

in streams and water yields at spring 

sources and in near-surface aquifers. By 

restoring streams to stable channel types, 

reducing runoff, and increasing 

infiltration, water should stay on the land 

longer to the benefit of deep-rooted 

riparian/wetland vegetation, resulting in 

expanded riparian zones and more stable 

streams. Hand-planting native species 

would benefit wetland and riparian zones 

by providing vegetation that would help 

prevent erosion and protect streambanks. 

Alternative A, although the level of 

benefit could be reduced in certain 

locations. Without the use of fire, there 

would be no short-term increase in erosion 

and stream sedimentation, and the spread 

of noxious weeds and other invasive nonnative vegetation, from fire treatments. 

The inability to use fire could reduce the 

effectiveness of pinyon-juniper removal in 

some areas, and long-term benefits to 

spring and stream flows. Risks to 

wetlands, floodplains, and riparian zones 

from wildfire would be greater under 

Alternative B than under Alternative A. In 

general, prescribed fires would have fewer 

impacts than wildfires, however, as they 

are of low severity and can be controlled 

to occur in one particular area. 

treatment methods, the BLM would 

restore less Non-functioning and 

Functioning-at-risk wetlands and riparian 

zones to Proper Functioning Condition as 

compared to Alternatives A and B. By not 

using heavy equipment, however, there 

would be less soil compaction, particularly 

in areas of moist soils, which could

increase surface runoff from the treated 

areas, reduce soil porosity, and limit water 

infiltration. While an improvement in 

wetland/riparian function would be 

expected across all treated areas, the level 

of improvement would likely be less

under Alternative C than under 

Alternatives A and B. Benefits associated 

with improvements to upland community

types would be less under Alternative C 

than under Alternatives A and B, since a 

much smaller portion of the project area 

would be treated, and the reduction in 

wildfire risk would also likely be lower. 

reduce the occurrence and spread of 

noxious weeds and invasive non-native

vegetation, or reduce the risk of wildfire. 

Thus, long-term adverse effects to 

wetland, floodplain, and riparian zone 

functionality could be greater under this 

alternative than under the other 

alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-45 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Cumulative Effects: Past land uses in the 

CESA have resulted in the degradation of 

wetlands, riparian zones, and floodplains 

and reduced their functions. In particular, 

the BLM has indicated that roads, historic 

grazing regimes, wildfire, spread of 

noxious weeds and other invasive nonnative vegetation, and pinyon-juniper 

encroachment have negatively affected 

riparian and wetland functions and values, 

water quantity, quality, and availability. 

Hazardous fuels reduction and habitat 

improvement projects on the 3 Bars 

Project and other areas within the CESA 

would occur on approximately 14,200 

acres annually, or on less than 1 percent of 

the CESA. These treatments would lead to 

short-term increases in soil erosion and 

surface water runoff, but long-term 

benefits to water quality and possibly 

water flows. Long-term, 3 Bars Project 

actions should make a substantial 

contribution toward improving wetland, 

floodplain, and riparian zone conditions 

within the CESA and help to offset 

adverse effects to these resources from 

other reasonably foreseeable future actions

under Alternative A. 

Cumulative Effects: By not using fire on 

the 3 Bars Project area, there would be no 

effects to wetland and stream water 

quantity and quality from fire on several 

thousand acres annually within the CESA. 

The amount of wetland, floodplain, and 

riparian habitat treated under Alternative 

B would be similar to that under 

Alternative A. The BLM would conduct 

hazardous fuels reduction and habitat 

improvement projects using manual and 

mechanical methods on about half as 

many acres within the 3 Bars Project area 

compared to Alternative A, thus the risk of 

future wildfires, and their effects on 

wetlands, floodplains, and riparian zones 

within the CESA, would be greater under 

Alternative B than under Alternative A. 

Cumulative Effects: 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 be greater under Alternative 

C than under Alternatives A and B. 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, although not to the extent as would 

occur under Alternatives A and B. 

Cumulative Effects: No treatments

would be authorized under this alternative 

and there would be no cumulative effects 

to water resources from treatments. The 

BLM would be able to conduct treatments 

on a limited acreage, as discussed above 

under Soil Resources. These treatments 

under Alternative D would do little to 

offset effects to water resources from 

other reasonably foreseeable future actions 

in the CESA. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-46 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

SUMMARY OF EFFECTS ON NATIVE AND NON-INVASIVE VEGETATION RESOURCES

Direct and Indirect Effects: Short-term, 

vegetation removal treatments would 

result in a temporary loss of some 

desirable or more mature vegetation 

through inadvertent removal of non-target 

vegetation. Removal of pinyon-juniper 

could reduce the amount of pine nuts, 

wood, and other woodland products 

available for commercial and individual 

harvest. Thinning and removal of pinyonjuniper also would result in dead wood 

and slash material that, if not removed, 

mulched, or burned, could provide fuel for 

a wildfire. Long-term, treatments would 

enhance native plant (re)establishment, 

and therefore would be expected to have a 

beneficial impact on native vegetation by 

increasing the extent of native plant 

communities in the project area. 

Treatments that benefit native plant 

communities could potentially provide 

habitat that is more suitable for rare and 

sensitive plant species. Treatments would 

result in improved health and vigor of 

riparian, aspen, and sagebrush 

communities. As treatments restore the 

functionality of the ecosystem, the system 

would become more resistant to invasion 

by noxious weeds and other invasive nonnative vegetation, drought, and wildfire. 

Treatments that reduce the buildup of 

hazardous fuels would help reduce the risk 

Direct and Indirect Effects: Under this 

alternative, the total acreage treated would 

be approximately half that of Alternative 

A. By not using fire, there would be less 

risk of loss of non-target native vegetation, 

and establishment and spread of noxious 

weeds and other invasive non-native 

vegetation. It would be difficult for the 

BLM to conduct pinyon-juniper 

treatments on hillslopes, or over large 

acreages, using mechanical methods, 

where fire use treatments would be 

effective. Loss of pinyon-juniper and 

associated increase in sagebrush would be 

less than under Alternative A, as less 

acreage would be treated. The acreage of 

persistent woodlands and sagebrush 

habitats benefiting from treatments would 

be less than under Alternative A. Since 

treatment of Phase III woodlands would 

be minimal, these areas, which have the 

greatest risk for loss from high intensity 

wildfires, would remain at a high risk 

under this alternative. It is likely that the 

amount of area meeting Potential Natural 

Community objectives would be less

under Alternative B than under 

Alternative A. 

Direct and Indirect Effects: Given that 

fire, mechanical methods, and livestock 

would not be used under this alternative, 

risks to non-target native vegetation would

be low. However, the BLM would have 

the fewest options for its treatment 

programs, and these programs would 

likely not be as effective as those under 

the other action alternatives. Mechanical 

methods and fire would not be available to 

promote aspen suckering. The BLM 

would be unable to combine treatment 

methods for optimal control of certain 

species and for enhancement of native 

plant communities. Additionally, removal 

of fuel hazards would be least under this 

alternative, and the risk of catastrophic 

wildfire would be greatest. Seeding and 

planting of native and non-native 

vegetation may have limited success 

without mechanical equipment. The BLM 

would not be able to use mechanical 

methods to create fuel breaks along roads 

or existing linear disturbances. 

Additionally, the BLM would not be able 

to slash and pile burn following treatments 

to reduce the short-term fire hazard, 

although programs to use felled trees for 

posts, mulch, and other uses would help 

minimize the fire risk. The amount of area 

meeting Potential Natural Community 

objectives would be less than would occur 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no effects to 

native and non-invasive vegetation. 

However, the BLM would do little to 

improve the health of the landscape, 

reduce the occurrence and spread of 

noxious weeds and other invasive nonnative vegetation, or reduce the risk of 

wildfire. Thus, long-term benefits to 

native vegetation health and resiliency 

would be less under this alternative than 

under the other alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-47 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

of wildfire on the 3 Bars Project area. under Alternatives A and B. 

Cumulative Effects: 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. Hazardous 

fuels and other habitat improvement 

treatments would occur on about 142,000 

acres within the 3 Bars Project area, or 

about 8 percent of the CESA. These 

treatments would help to reduce the risk of 

wildfire within the CESA. Overall, there 

would be a net beneficial accumulation of 

effects from BLM treatments and treated 

areas would move toward their Potential 

Natural Community. These benefits would 

be greatest under Alternative A. 

Cumulative Effects: Under Alternative 

B, the inability to use prescribed and 

wildland fire for resource benefit would

restrict the BLM’s ability to reduce 

wildfire risk, restore natural fire regimes, 

and influence vegetation communities on 

a large scale within the 3 Bars Project 

area. Prescribed fire use would be limited 

to a few hundred acres annually in other 

portions of the CESA outside the 3 Bars 

Project area based on previous 

authorizations. Hazardous fuels and other 

habitat improvement treatments would 

occur on about 78,000 acres within the 3 

Bars Project area, or about 4 percent of the 

CESA, and would help to reduce the risk 

of wildfire within the CESA. Overall, 

there would be a net beneficial 

accumulation of effects from BLM 

treatments and treated areas would move 

toward their Potential Natural 

Community. However, because the BLM 

would treat fewer acres, and would not be 

able to use fire, benefits to vegetation 

would be less under Alternative B than 

under Alternative A. 

Cumulative Effects: Under Alternative 

C, the BLM would only be able to use 

manual and classical biological control 

methods to treat vegetation. As a result, 

the BLM anticipates treating about onefourth as many acres under Alternative C 

as under Alternative A. These methods 

would cause less vegetation and soil 

disturbance and give the BLM greater 

control of the types and amount of 

vegetation that would be removed than 

under Alternatives A and B. By not being 

able to use mechanical methods and fire to 

improve the health and resiliency of native 

vegetation, reduce hazardous fuels, create 

fire and fuel breaks, and remove downed 

wood and slash, the risk of wildfire and its 

impacts on vegetation would likely 

increase on the 3 Bars Project area. 

Hazardous fuels reduction and habitat 

improvement projects could occur on 

about 47,000 acres within the 3 Bars 

Project area. Collectively, about 3 percent 

of the CESA would be treated by the 

BLM. There would still be a net benefit 

from BLM treatments and treated areas 

would move toward their Potential Natural 

Community on portions of the project 

area. As the BLM would not be able to 

use fire and mechanical treatments, 

however, fewer acres would be treated, 

and benefits to vegetation under 

Cumulative Effects: No treatments 

would be authorized under this alternative 

and there would be no cumulative effects 

from noxious weeds and invasive nonnative vegetation associated with 3 Bars 

Project treatments. However, factors that 

contribute to the loss of native and noninvasive vegetation health and resiliency 

would remain, and would likely be 

greatest under this alternative. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-48 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Alternative C would be less than under 

Alternatives A and B. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON NOXIOUS WEEDS AND INVASIVE NON-NATIVE VEGETATION

Direct and Indirect Effects: Short-term, 

treatments that cause disturbance or 

remove plants from an area could lead to a 

competitive advantage for many noxious 

weeds and other invasive non-native

vegetation, particularly if a seed source is 

present on the site. There is also some 

potential for noxious weeds and other 

invasive non-native vegetation seeds to be 

transported onto treatment sites on 

workers’ shoes and clothing, with the 

plant materials used in rehabilitation 

projects, and on vehicles. Long-term, 

treatments designed to control noxious 

weeds and other invasive non-native

species would be expected to have a 

beneficial impact by reducing populations 

of these species. The reduction of fuel 

loads would decrease the risk of severe or 

repeat wildfires, thereby reducing the risk 

of spread of cheatgrass and other noxious 

weeds and other fire-dependent invasive 

non-native species. By removing these 

species, overall ecosystem health and 

functionality would improve. By restoring

rangeland health, native species would be 

better able to compete with noxious weeds 

and other invasive non-native species. 

Direct and Indirect Effects: Prescribed 

fire could increase the dominance of 

cheatgrass and other introduced annual 

grasses in areas where these species are 

present pre-burn. Because only 

mechanical and manual methods would be 

used, however, it would be difficult for the 

BLM to conduct hazardous fuels 

reduction, and noxious weeds and other 

invasive non-native vegetation treatments 

on steep hillslopes, or over large acreages. 

Grazing can contribute to the spread of 

noxious weeds and other invasive nonnative vegetation. The BLM would not be 

able to use fire to remove the mat of dead 

vegetation in cheatgrass-dominated areas, 

or to promote the health and resiliency of 

native vegetation. Thus, wildfire risk 

would be greater under this alternative 

than under Alternative A, as would the 

potential for establishment and spread of 

noxious weeds and other invasive nonnative vegetation after a wildfire. 

Direct and Indirect Effects: The effects 

of not using fire would be similar to those 

under Alternative B. By not using 

machinery, there would be less risk of 

inadvertent removal of native vegetation, 

and potential to spread the seeds of 

noxious weeds and other invasive nonnative vegetation. Mechanical equipment 

can also damage or crush desirable 

riparian and wetland vegetation or bring 

propagules of non-native species into 

treatment areas and create sites for 

noxious weeds and other invasive nonnative vegetation establishment. These 

effects would be greatest in treatment 

areas with the largest acreage and that 

employ the most extensive mechanical 

treatments (project groups that include 

streambank earthwork as well as pinyonjuniper removal). By not using fire and 

mechanical equipment, however, it is 

unlikely that the BLM would slow the 

spread of noxious weeds and other 

invasive non-native vegetation, including 

cheatgrass; restore fire as an integral part 

of ecosystem; or reduce extreme, very 

high, and high wildfire risks to moderate 

risk or less. Thus, wildfire risk would be 

greater under this alternative than under 

Direct and Indirect Effects: No 

treatments would be authorized under this 

alternative. There would be no effects to 

noxious weeds and other invasive nonnative vegetation. However, the BLM 

would do little to improve the health of the 

landscape, reduce the occurrence and 

spread of noxious weeds and other 

invasive non-native vegetation, or reduce 

the risk of wildfire. Thus, long-term 

adverse effects to ecosystem health and 

resiliency could be greater under this 

alternative than under the other 

alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-49 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Alternatives A and B, as would the 

potential for establishment and spread of

noxious weeds and invasive non-native 

vegetation. 

Cumulative Effects: Past land uses in the 

CESA have resulted in the degradation of 

public and private lands and reduced their 

functions. In particular, the BLM has 

indicated that roads, historic grazing 

regimes, wild horse overpopulation, and 

wildfire have contributed to the 

establishment and spread of noxious 

weeds and invasive non-native vegetation 

within the CESA. Hazardous fuels 

reduction, habitat improvement, and 

noxious weed and other invasive nonnative vegetation control projects would 

occur on up to 142,000 acres, or 8 percent 

of the CESA. These treatments would help 

to reduce the risk of wildfire within the 

CESA, which often leads to the 

establishment and spread of noxious 

weeds and other invasive non-native

vegetation. 

Cumulative Effects: The BLM would 

treat about half as many acres under 

Alternative B as under Alternative A, and 

less effort would be spent by the BLM on 

treatments to reduce wildfire risk and its 

impacts on vegetation, including use of 

fire to restore natural fire regimes. The use 

of mechanical treatments would give the 

BLM greater latitude to control various 

types of vegetation compared to fire 

treatments, but efforts to control 

cheatgrass and other noxious weeds and 

other invasive non-native vegetation

would be difficult on steep slopes and 

over large acreages. Hazardous fuels 

reduction and habitat improvement 

projects could occur on about 63,000 acres 

within the 3 Bars Project area, and on 

about 15,000 acres within other portions 

of the CESA, or about 4 percent of 

acreage within the CESA. Thus, the BLM 

would be less successful in controlling 

noxious weeds and other invasive nonnative vegetation on the project area and 

CESA under Alternative B than under 

Alternative A. 

Cumulative Effects: By not being able to 

use fire, and mechanical methods such as 

mowing, chopping, tilling, disking, 

harrowing, and drill seeding, the BLM 

would do little to reduce hazardous fuels, 

create fire and fuel breaks, treat areas with 

noxious weeds and other invasive nonnative vegetation, plant and seed native 

vegetation, or remove downed wood and 

slash. Thus, the risk of wildfire and spread 

of noxious weeds and other invasive nonnative vegetation would remain high on 

the 3 Bars Project area and within the 

CESA. Only about 47,000 acres, or about 

2 percent of the CESA, would be treated. 

These treatments would benefit the 3 Bars 

ecosystem, but not to the extent as under

Alternatives A and B. 

Cumulative Effects: No treatments 

would be authorized under this alternative 

and there would be no cumulative effects 

from noxious weeds and other invasive 

non-native vegetation associated with 3 

Bars Project treatments. However, factors 

that contribute to the spread of noxious 

weeds and other invasive non-native 

vegetation would remain, and would 

likely be greatest under this alternative. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-50 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

SUMMARY OF EFFECTS ON WILDLAND FIRE

Direct and Indirect Effects: Proposed 

treatments would have few adverse 

impacts on wildfire risk. It is possible that 

the use of vehicles to transport workers to 

treatment sites, or use of chainsaws or 

other gas-powered equipment, could cause 

a spark that results in a wildland fire. 

Slash from manual and mechanical 

treatments could create a short-term fire 

hazard. Long-term, the BLM would 

restore fire as an integral part of the 

ecosystem and reduce hazardous fuels. 

Treatments that remove hazardous fuels 

from public lands would be expected to 

benefit the health of plant communities in 

which natural fire cycles have been 

altered. These include treatments that 

control populations of noxious weeds and 

other invasive non-native species. 

Enhancing fuel breaks in pinyon-juniper 

stands would break up the continuity of 

fuel, moderate fire behavior, and reduce 

the risk of loss of habitat and other 

resources from a catastrophic wildfire. 

Treatments would help to reduce the Fire 

Regime Condition Class (FRCC), and 

meet Fire Management Unit (FMU) 

objectives, over portions of the 3 Bars 

Project area. 

Direct and Indirect Effects: The risk of

treatments causing a wildland fire that 

spreads beyond treatment boundaries 

would be less under this alternative than 

Alternative A. Miles traveled by vehicles, 

the number of acres treated using manual 

and mechanical equipment, the amount of 

downed trees and slash material created, 

and the miles of fire and fuel breaks 

created would be similar between this 

alternative and Alternative A. Because the 

BLM would not use prescribed fire to treat 

vegetation under this alternative, there 

would be no risk of a prescribed fire 

spreading beyond treatment boundaries. 

Without the use of prescribed fire and fire 

for resource benefit, the BLM would be 

unable to restore fire as an integral part of 

the ecosystem, reduce the risk of a largescale wildfire, or reduce extreme, very 

high, and high wildfire risks to moderate 

risk or less. About half as much acreage 

would be treated under Alternative B than 

under Alternative A to reduce hazardous 

fuels and reduce the FRCC. Prescribed 

fire and fire for resource benefit are 

identified as important treatment options 

under the Fire Management Plan for all 

FMUs, except the Big Smoky FMU, but 

would be unavailable to the BLM as a 

management tool under this alternative. It 

is unlikely the trend toward large-sized 

Direct and Indirect Effects: There would 

be no wildland fire risks associated with 

the use of prescribed fire. The BLM 

would not use mechanical equipment 

(other than vehicles to transport work 

crews to treatment sites), so there would 

be no risk of a wildland fire being started 

by tractors, mowers, and other mechanical 

treatment equipment. However, workers 

still would use chainsaws and other handheld power equipment that could cause a 

spark and start a wildland fire. Large 

numbers of workers and their vehicles 

would be needed to accomplish proposed 

treatments under this alternative. Vehicle 

miles traveled would likely be greatest 

under this alternative. Downed trees and 

slash material from treatments would be 

difficult to remove without mechanical 

equipment or pile/slash burning. The 

number of miles of fire and fuel breaks 

created under this alternative would be 

less than under Alternatives A and B, as 

the BLM would not be able to use 

mechanical equipment, such as bulldozers, 

mowers and shredders, and prescribed 

fire, to create fire and fuel breaks. 

Alternative C would not restore fire as an 

integral part of the ecosystem, reduce the 

risk of large-scale wildfire, or reduce 

extreme, very high, and high wildfire risks 

to moderate risk or less. Only about 500 to 

Direct and Indirect Effects: There would 

be no direct effects from wildland fire 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. Under this alternative, the 

BLM would not meet the fire use purposes 

to 1) restore fire as an integral part of 

ecosystem, 2) reduce the risk of largescale wildland fire, 3) reduce extreme, 

very high, and high wildland fire risks to 

moderate risk or less, and 4) develop fuel 

breaks within treatment and adjacent 

areas. There would be little or no 

improvement in the FRCC on the 3 Bars 

Project area and the BLM would not meet 

FMU objectives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-51 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

fires of moderate to high severity in 

sagebrush and large stand-replacing fires 

in pinyon-juniper would slow or reverse in 

the long-term, and the BLM would still 

need an aggressive wildland fire 

prevention and control program for the 

long-term. 

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 

would be reduced under Alternatives A 

and B. The BLM would not meet FMU 

objectives under the Fire Management 

Plan. 

Cumulative Effects: Historic 

overgrazing, introduction and spread 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. 

These actions have made rangeland and 

woodland habitats less fire resilient and 

increased the potential for spread of 

wildfire. Hazardous fuels treatments 

would occur on about 142,000 acres (8

percent) of lands within the CESA. 

Although this would still be a small 

portion of lands within the CESA, 

treatments would be targeted toward 

public lands with high to very high

wildfire risk. Given that over 90 percent of 

acres impacted by future actions are 

focused on hazardous fuels reduction and 

resource management, actions would 

reduce wildfire risk long-term. At fire 

management treatment levels projected to 

occur in the CESA during the next 25 

Cumulative Effects: Because the BLM 

would not use fire to treat vegetation on 

the 3 Bars Project area, the risk of a 

prescribed fire spreading beyond treatment 

boundaries and burning other portions of 

the CESA would be less under this 

alternative than under the other action 

alternatives. However, the BLM would be 

less able to restore fire as an integral part 

of the ecosystem, reduce the risk of a 

large-scale wildland fire, or reduce 

extreme, very high, and high wildfire risks 

to moderate risk or less within the CESA 

under this alternative than under the other 

action alternatives. About 78,000 acres of 

vegetation would be treated to reduce 

hazardous fuels and improve rangeland 

health within the CESA, or about 4 

percent of the CESA. Acres treated to 

reduce the FRCC under this alternative 

would be half that treated under

Alternative A, and it is also less likely that 

the BLM would meet FMU objectives 

under this alternative than under 

Cumulative Effects: The BLM 

anticipates treating about one-fourth as 

many acres under Alternative C as under 

Alternative A, mostly due to the higher 

costs associated with manual and classical 

biological control methods. The risk of 

treatments causing a wildland fire would 

be less under this alternative than 

Alternative A. Miles traveled by vehicles, 

and amount of downed trees and slash 

material created, but not removed, by 

pile/slash burning or other methods would 

be greater under this alternative than under 

Alternatives A and B. By not being able to 

use fire, and mechanical methods such as 

mowing, chopping, tilling, disking, 

harrowing, and drill seeding, the BLM 

would do little to reduce hazardous fuels, 

create fire and fuel breaks, treat areas with 

noxious weeds and other invasive nonnative vegetation, seed and plant native 

vegetation, or remove downed wood and 

slash. Under Alternative C, the BLM 

would conduct fire management 

Cumulative Effects: There would be no 

cumulative effects on wildland fire from 3 

Bars Project treatments as no treatments 

would be authorized under this alternative. 

Based on historic treatments in the 3 Bars 

Project area, only about 1,500 acres would 

be treated annually on the CESA to reduce 

hazardous fuel levels and improve 

ecosystem health. The BLM would do 

little to reduce the FRCC, and it is also 

unlikely that the BLM would meet FMU 

objectives under the Fire Management 

Plan. Given the large number of utilities 

and infrastructure, mineral, oil, gas, 

geothermal, and other land developments 

that are reasonably foreseeable in the 

CESA, the need for an aggressive 

wildland fire prevention and control 

program to protect natural resources and 

public health and infrastructure would

likely increase from current levels. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-52 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

years under Alternative A, the BLM 

should meet the FMU objectives for most 

FMUs. 

Alternative A on the 3 Bars Project area. treatments on only about 2 percent of the 

CESA. It is less likely that the BLM 

would meet FMU objectives under the 

Fire Management Plan under this 

alternative than under Alternatives A and 

B on the 3 Bars Project area. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON FISH AND OTHER AQUATIC RESOURCES

Direct and Indirect Effects: Short-term, 

proposed treatments would disturb aquatic 

habitat if equipment or vehicles enter 

streams or other waterbodies, could cause 

soil disturbance and erosion, and there 

could be a spill of fuel or lubricants into 

water bodies. Removal of vegetation 

could adversely affect aquatic habitat and 

ecological requirements for aquatic 

species, and cause a temporary increase in 

bank erosion. Increases in sediment 

entering a stream could adversely affect 

fish health and stream quality. Prescribed 

fire and mechanical treatments could 

result in erosion and runoff from burned 

areas and sediment could enter streams if 

the disturbance area is within a few 

hundred feet of streams. Long-term, 

treatments that restore channel 

morphology and stream function, remove 

noxious weeds and other invasive nonnative vegetation, improve the health and 

resiliency of riparian vegetation, and 

reduce the risk of catastrophic wildfire 

would benefit water quality and aquatic 

Direct and Indirect Effects: Under 

Alternative B, the number of acres of 

riparian treatments (4,000 acres) and miles 

of stream improved to restore channel 

morphology and function (31 miles) 

would be similar to Alternative A. 

Because the BLM would have to rely 

more on mechanical treatments to reduce 

hazardous fuels and improve woodland

health, improve the health of aspen stands, 

and control non-native vegetation, shortterm soil disturbance and erosion could be 

similar to that under Alternative A, even 

though fewer acres would be treated. 

However, fire-related effects on water 

quality and aquatic habitat would not 

occur under Alternative B. Although this 

would be beneficial to fish and other 

aquatic organisms in the short-term, in the 

long-term there would be a higher risk of 

wildfire as a result of the potential buildup 

of hazardous fuel materials that could 

have been removed through the use of 

prescribed fire and wildfire for resource 

benefit. Treatment benefits to fish and 

Direct and Indirect Effects: Only about 

one-fourth as many total acres, acres of 

wetland, floodplain, and riparian habitat, 

and miles of stream restoration would be 

treated under Alternative C than under 

Alternative A. Short-term soil disturbance 

and erosion would occur in watersheds as 

a result of manual and classical biological 

treatments, but adverse effects would be 

substantially less under this alternative 

than under the other action alternatives 

because fewer acres would be treated, and 

because manual and biological treatments 

cause less soil disturbance compared to 

mechanical and fire treatments. The BLM 

would have limited success in restoring 

channel morphology and function in 

degraded streams to benefit Lahontan 

cutthroat trout and other aquatic 

organisms. The BLM would be able to 

hand place rocks, logs, and other material 

in streams to slow water flows, and may 

be able to make minor changes to the 

stream morphology using hand tools, but 

these improvements would be minor. 

Direct and Indirect Effects: There would 

be no direct effects to fish or other aquatic 

resources from 3 Bars Project treatments 

as no treatments would be authorized 

under this alternative. Alternative D poses 

the greatest threat to Lahontan cutthroat 

trout and other aquatic species through 

long-term habitat loss and degradation. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-53 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

organisms. Treatments would focus on 

streams used by Lahontan cutthroat trout, 

a federally listed threatened species. 

Stream enhancements could involve the 

creation or expansion of pool habitat, 

improvements in the riffle to pool ratio, 

and addition of instream cover for fish. 

Replacing invasive plant species with 

native vegetation would improve food 

availability for insectivorous fish species, 

as native plants typically support a more 

diverse native insect community. The 

BLM would place logs and other woody 

debris from felled pinyon-juniper into 

streams to slow water flow and create fish 

habitat. Protective temporary exclosure

fencing would restrict access to treated 

areas by domestic livestock, wild horses, 

and other wild ungulates. The removal of 

pinyon-juniper vegetation in riparian 

zones could increase stream flows and 

improve aquatic habitat as a result of 

reduced water uptake by vegetation. 

Prescribed fire treatments could benefit 

aquatic species by reducing hazardous fuel 

loads, and therefore the risk of a 

destructive high-intensity wildfire. 

other aquatic organisms under Alternative 

B would be less than under Alternative A, 

but not substantially less, as fire would be 

used sparingly to improve habitat for fish 

under Alternative A. However, risks to 

fish from wildfire would be greater under 

this alternative than under Alternative A. 

Pinyon-juniper would be removed using 

chainsaws. Phase I woodlands and a 

limited acreage of Phase II woodlands 

would be targeted for treatments. Most 

treatments would occur near streams and 

roads to promote their use as fire breaks, 

to the benefit of aquatic resources. 

However, the BLM would not be able to 

conduct fire treatments to reduce fuels, or 

use mechanical equipment to create fire 

and fuel breaks, and thus the risks of 

wildfire and its effects on fish and other 

aquatic resources would be greater under 

this alternative than under the other action 

alternatives. 

Cumulative Effects: Historic livestock 

use has contributed to soil erosion and 

water quality impacts, especially in 

riparian zones and near streams occupied, 

or potentially occupied, by Lahontan 

cutthroat trout and other fish. Recreation, 

Cumulative Effects: Acres and types of 

wetland and riparian habitat treated under 

this alternative would be similar to 

Alternative B. However, less effort would 

be spent by the BLM on treatments to 

reduce wildfire risk and its associated 

Cumulative Effects: Adverse, short-term 

effects to fish and other aquatic resources 

associated with the use of fire and 

mechanized equipment would not occur 

under Alternative C. However, fire use 

and mechanized equipment would be used 

Cumulative Effects: There would be no 

cumulative effects on fish and other 

aquatic organisms from 3 Bars Project 

treatments as no treatments would be 

authorized under this alternative. Based on 

historic treatments in the 3 Bars Project 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-54 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

land and mineral development, and oil, 

gas, and geothermal exploration and 

development have also affected fish and 

other aquatic resources. 3 Bars Project 

treatments would have short-term adverse 

effects on about 4,000 acres of riparian 

habitat, 8 miles of occupied Lahontan 

cutthroat trout streams, and 34 miles of 

potential Lahontan cutthroat trout streams. 

In addition, treatments under Alternative 

A could affect aquatic organisms found in 

almost 1,000 miles of perennial and 

intermittent and ephemeral streams on the 

3 Bars Project area. Because stream 

restoration and enhancement treatments 

on the 3 Bars Project area under 

Alternative A would affect less than 0. 2 

percent of the acreage on the CESA, these 

cumulative effects would be negligible. 

About 17 percent of the 3 Bars Project 

area and 8 percent of the CESA would be 

treated to reduce hazardous fuels. A 

reduction in wildfire risk on the CESA 

would benefit aquatic organisms, and 

would be greatest under Alternative A. 

impacts to aquatic habitat from soil 

erosion, including the use of fire to restore 

natural fire regimes. By not using 

prescribed fire and wildland fire for 

resource benefit, there would be no risks 

to fish and other aquatic resources or their 

habitat from fire on several thousand acres 

annually within the 3 Bars Project area. 

However, the use of fire could occur on 

several hundred acres annually on other 

portions of the CESA. Hazardous fuels 

reduction and habitat improvement 

projects could occur on about 78,000 acres 

within the CESA, or about 4 percent of 

acreage within the CESA. The trend 

toward large-sized wildfires of moderate 

to high severity in sagebrush and large 

stand-replacing fires in pinyon-juniper 

should slow, but treatments to reduce this 

risk on the CESA would be less under 

Alternative B than under Alternative A. 

in other portions of the CESA to improve 

habitat, remove hazardous fuels, and 

reduce the risk of wildfire. By not being 

able to use mechanical methods and fire, 

the risk of wildfire and its impacts on 

water resources would likely increase on 

the 3 Bars Project area, to the potential 

detriment of fish and other resources that 

depend upon water in the CESA. Only 

about 8 miles of stream and 100 acres of 

riparian habitat would be restored to 

benefit fish and other aquatic organisms. 

Treatments in the CESA would affect 

about 42,000 acres, or about 2 percent of 

the CESA; less than 0. 2 percent of 

acreage on the CESA would be affected 

annually. 3 Bars Project restoration 

treatments would have short-term adverse 

and long-term beneficial effects on fish 

and other aquatic resources, but these 

effects would be negligible in the context 

of the acreage within the CESA and other 

types of activities that have effects on 

water resources, such as the Mount Hope 

Project. 

area, only about 1,500 acres would be 

treated annually in the CESA to reduce 

hazardous fuel levels and improve 

ecosystem health under this alternative. 

The BLM would conduct stream 

bioengineering and riparian habitat 

enhancements only on a limited acreage 

and these projects would have to be 

authorized through separate decisions. 

Thus, stream channels and riparian habitat 

would remain degraded and contribute to 

water quality concerns. Hazardous fuel 

levels would likely increase, and only a 

limited number of miles of fuel and fire 

breaks would be constructed under this 

alternative compared to the action 

alternatives. The trend toward large-sized 

fires of moderate to high severity in 

sagebrush and large stand-replacing fires 

in pinyon-juniper would likely increase. 

These effects would be detrimental to fish 

and other aquatic organisms. 

Mitigation: 1) If instream disturbance is 

required as part of treatment, activities 

would be scheduled to avoid spawning 

periods of game fish species or Lahontan 

cutthroat trout. The measure would be 

effective in protecting spawning periods 

of game or special status fish species. 2) If 

water is required for fire control, perennial 

Mitigation: See Alternative A. Mitigation: See Alternative A. Mitigation: See Alternative A. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-55 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

streams with game or special status 

species or springs with connections to 

these perennial streams would not be used 

as water sources. This measure would be 

effective in avoiding flow reductions in 

streams with important aquatic species by 

restricting their use as water sources for 

fire control. 3) The BLM would consult 

with the 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. The measure would be effective in 

protecting stream habitat for Lahontan 

cutthroat trout. 

SUMMARY OF EFFECTS ON WILDLIFE RESOURCES

Direct and Indirect Effects: Short-term 

adverse effects to wildlife include injury 

and loss of life, noise and other 

disruptions associated with treatment 

applications, and habitat effects. 

Treatment work at streams, ponds, and 

springs would involve using heavy

equipment, which could pose a risk of 

injury or death by crushing animals or 

their breeding sites; amphibians would be 

most susceptible to harm or injury. 

Removal of Phase II and III pinyonjuniper would reduce the amount of 

habitat available to pinyon-juniper 

dependent species. Prescribed fire 

treatments pose a risk of death to animals, 

Direct and Indirect Effects: Because the 

BLM would not be able to use fire, there 

would be no harm to or loss of wildlife 

from prescribed fire and wildland fire for 

resource benefit. The few wildlife that use 

dense stands of pinyon-juniper would not 

experience habitat loss under this 

alternative, and may even see habitat gains 

as more pinyon-juniper habitat shows 

Phase II or III characteristics. Acres and 

types of wetland and riparian habitat and 

miles of streams treated would be similar 

to Alternative A. However, less effort 

would be spent by the BLM on slowing 

pinyon-juniper encroachment into 

sagebrush and riparian communities, 

Direct and Indirect Effects: Most of the 

treatments under this alternative would be 

to thin and remove pinyon-juniper using 

chainsaws where it is encroaching into 

riparian, aspen, and sagebrush habitats. 

There would be fewer direct impacts to 

wildlife from treatments under this 

alternative than the other alternatives, 

because adverse impacts, such as harm to 

or death of wildlife and noise and other 

disturbances, would be much less with 

manual methods than the other methods. 

Since fewer acres would be treated, there 

would be fewer benefits to wildlife under 

this alternative than under Alternatives A 

and B. Manual treatments would be small 

Direct and Indirect Effects: There would 

be no direct effects to wildlife resources 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. Because no habitat would be 

restored, Alternative D poses the greatest 

threat to wildlife through long-term 

habitat loss and degradation. Species at

risk from habitat degradation include

Greater sage-grouse, pygmy rabbit, 

northern goshawk, cavity nesting birds, 

and migratory birds through densification 

of pinyon-juniper, loss of aspen habitat, 

and pinyon-juniper encroachment. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-56 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

especially smaller mammals, reptiles, and 

amphibians that may not be able to flee 

the area or enter burrows during a burn. 

Long-term, proposed treatments would 

target areas with declining habitat quantity 

and quality, and would facilitate wildlife 

movement across the landscape. Loss of 

habitat at the landscape level would be 

addressed by reducing levels of pinyonjuniper encroachment into other habitats, 

reducing the spread of noxious weeds and 

other invasive non-native vegetation, and 

reducing the risk of catastrophic wildfire. 

Treatments aimed at restoring natural fire 

cycles would improve vegetation 

resilience and increase plant diversity 

across the landscape, to the benefit of 

wildlife. Treatments would allow more 

desirable vegetation, such as forbs and 

grasses, to better compete and thrive. 

Treatments that restore native vegetation 

in disturbed areas should reduce 

fragmentation and restore connectivity 

among blocks of similar habitat, allowing 

wildlife to move more easily across the 

landscape. 

reducing the amount of Phase II and III 

pinyon-juniper treated using standreplacement fires, restoring historic 

sagebrush habitat, and treating priority 

habitat to improve species diversity, 

especially through cheatgrass control. 

Because fire would not be available to 

reduce hazardous fuel loads, Alternative B 

may pose a greater long-term risk for 

wildfire due to the accumulation of fuels. 

The BLM would also not be able to 

promote more fire resilient and diverse 

habitat on the 3 Bars Project area. 

in scale and mostly targeted to pinyonjuniper stands. Benefits to special status 

species and migratory birds would 

primarily be limited to those species that 

use the pinyon-juniper and sagebrush 

interface; sage-grouse, pygmy rabbit, and 

other sagebrush dependent wildlife would 

see few benefits. 

Cumulative Effects: Historic livestock 

use, land development, and other natural 

and human-caused factors have 

contributed to wildlife habitat loss and 

fragmentation, especially in riparian 

zones. In addition, habitat for Greater

sage-grouse, pygmy rabbit, and other 

Cumulative Effects: Long-term benefits 

from prescribed fire and wildland fire for 

resource benefit, including improving 

pinyon-juniper health, slowing pinyonjuniper encroachment, making vegetation 

more fire resilient, creating openings in 

pinyon-juniper habitat to promote shrub, 

Cumulative Effects: Because fire and 

mechanical treatments would not be used, 

the BLM would not be able to use these 

methods to stimulate aspen suckering on 

about 450 acres. The BLM would be less 

able to reduce the risk of pinyon-juniper 

encroachment into aspen stands, and thin 

Cumulative Effects: There would be no 

cumulative effects on wildlife resources 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. The BLM would be able to 

conduct treatments on a limited acreage, 

as discussed above under Soil Resources, 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-57 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

wildlife will be lost due to the Mount 

Hope Project and future development in 

the CESA. Proposed BLM restoration 

projects would have short-term adverse 

and long-term beneficial effects on about 

142,000 acres of wildlife habitat within 

the CESA during the life of the project. 

About 17 percent of the 3 Bars Project 

Area and 8 percent of the CESA would be 

treated to reduce hazardous fuels and 

improve ecosystem health and resiliency. 

Habitat improvement and a reduction in 

wildfire risk on the CESA would benefit 

wildlife and help offset some of the 

adverse effects to wildlife from other 

reasonably foreseeable future actions in 

the CESA, and would be greatest under 

Alternative A. 

forb, and grass development, and reducing 

the risk of catastrophic wildfire, would 

occur on only a few hundred acres 

annually within the CESA under previous 

and future authorizations under this 

alternative and provide limited benefits for 

wildlife. About 4 percent of the CESA 

would be treated to reduce hazardous 

fuels, improve ecosystem health and 

resiliency, and reduce wildfire risk. 

Treatments within the CESA would 

benefit wildlife and their habitats, but not 

to the extent as for treatments under 

Alternative A. 

and remove pinyon-juniper to create and 

enhance fire and fuel breaks to reduce the 

risk of wildfire destroying aspens. There is 

concern, however, that unless the BLM 

protects aspen stands from livestock, wild 

horses, and other wild ungulates, and is 

successful in stimulating aspen suckering

using manual methods, that aspen stands 

could be lost on the 3 Bars Project area. 

There would be no risk of injury or death 

to wildlife, noise and other disturbances, 

fuel spills, and short-term habitat loss 

associated with use of mechanical 

equipment. The BLM would have less 

success, however, in opening up pinyonjuniper to promote development of shrubs, 

grasses and forbs; reducing hazardous 

fuels; removing cheatgrass and other nonnative species; creating a mosaic of 

habitats; creating fire and fuel breaks; 

restoring stream habitat; and reseeding 

and replanting vegetation to restore 

wildlife habitat compared to Alternatives 

A and B. Under Alternative C, proposed 

restoration projects would have adverse 

and beneficial effects to about 47,000 

acres of wildlife habitat within the CESA 

during the life of the project. Wildlife 

species diversity and numbers, and habitat 

quality, would show little improvement 

under Alternative C, primarily because 

only about 2 percent of the CESA would 

be treated, and the BLM would be limited 

but this alternative would do little to slow 

the loss of wildlife habitat within the 

CESA. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-58 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

in the types of treatments it could conduct 

to reduce the risk of wildfire and improve 

wildlife habitat. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON WILD HORSES

Direct and Indirect Effects: Restoration 

activities could have short-term effects on 

wild horses by exposing them to 

treatments that interfere with their health, 

interfere with their movements, cause 

changes in vegetation that could alter the 

carrying capacity of the herd management 

areas (HMAs), or limit their access to 

water, which could ultimately affect their 

genetic health. Wild horses could 

experience short-term disturbances 

associated with mechanical noise and the 

presence of humans. However, since 

animals could leave the area during 

treatments, effects would be minor. 

Treatments could reduce the capability of 

the treatment site to support wild horses 

by removing native forbs and grasses, 

leading to the spread of noxious weeds 

and other invasive non-native vegetation 

and loss of forage. Wild horses are 

accustomed to migrating in search of food 

and shelter in response to climatic 

variation and natural disturbances that 

alter food supplies, however, and the 

amount of area treated annually would 

comprise only a small portion of the 

HMAs. The BLM could remove crested 

Direct and Indirect Effects: Because the 

BLM would not use fire, there would be 

no adverse effects associated with 

prescribed fire and wildland fire for 

resource benefit. In particular, prescribed 

fire would not contribute to impacts to

wild horse habitat that could result from 

soil erosion, loss of forage, and spread of 

noxious weeds and other invasive nonnative vegetation in burned areas. 

However, with greater reliance on 

mechanical methods, there may be greater 

disturbance to wild horses from use of 

mechanical equipment than would occur 

under Alternative A. Acres and types of 

wetland and riparian habitat treated would 

be similar to Alternative A, and the BLM 

would use temporary exclosure fencing to 

protect treatment areas. Because fire 

would not be available to reduce 

hazardous fuel loads, there may be a 

greater long-term risk for catastrophic 

wildfire due to the accumulation of fuels

under Alternative B than under 

Alternative A. The BLM would be limited 

in promoting more fire resilient and 

diverse vegetation on the 3 Bars Project 

area. Prescribed fire would not be used to 

Direct and Indirect Effects: The 

consequences of not using fire under 

Alternative C would be the same as those 

discussed under Alternative B. Most of the 

treatments under this alternative would be 

to thin and remove pinyon-juniper using 

chainsaws where it is encroaching into 

riparian, aspen, and sagebrush habitats. 

Noise and other disturbance would be less 

with manual methods than the other 

methods. Manual and biological control 

methods result in less land disturbance 

than mechanical methods and, as a result, 

short-term adverse effects to water quality 

from soil erosion and loss of non-target 

vegetation would be less under this 

alternative than under Alternatives A and 

B. Without the use of mechanical 

equipment, the BLM would not conduct 

stream engineering and restoration, except 

on a limited basis on only a few stream 

miles. Fewer acres of noxious weeds and 

other invasive non-native vegetation 

would be controlled and fewer acres of 

pinyon-juniper and sagebrush thinning 

and removal would be conducted to 

promote understory development, except 

on very small areas where this vegetation 

Direct and Indirect Effects: There would 

be no direct or indirect effects to wild 

horses from 3 Bars Project treatments as 

no treatments would be authorized under 

this alternative. The BLM would be able 

to conduct treatments on a limited 

acreage, as discussed above under Soil 

Resources. This alternative, however,

would do little to return the 3 Bars 

ecosystem to its Potential Natural 

Community and improve the distribution 

and genetic health of wild horses. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-59 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

wheatgrass and forage kochia on the 

Rocky Hills Unit to enhance sagebrush 

cover, which could reduce forage for wild 

horses. While up to 50 percent of the unit 

could be treated, crested wheatgrass 

provides more forage for wild horses than 

would native vegetation. Long-term, wild 

horses would benefit from treatments that 

encourage growth of native forbs and

grasses. Treatments would also help to 

move the associated ecological sites 

toward their Potential Natural 

Community, since most of the acreage 

within the HMAs is early- to mid-seral 

status. If the forage amount was increased 

within a given HMA, horses would likely 

be better distributed within the HMA. By 

stabilizing stream channels, revegetating 

treatment sites, and creating access to 

water sources, the BLM would reduce 

erosion and return riparian systems to a 

Proper Functioning Condition for the 

benefit of wild horses. Through these 

treatments, water quality, quantity, and 

duration would be improved within 

HMAs, with water availability improved 

during times of drought. Treatments that 

reduce the risk of future catastrophic 

wildfire through fuels reduction, including 

removal of noxious weeds and other 

invasive non-native vegetation, would also 

benefit wild horses. 

remove downed wood and other 

hazardous fuels associated with thinning 

and removal of pinyon-juniper, thus 

increasing the risk of wildfire in pinyonjuniper treatment areas. These effects 

would not be beneficial to wild horses. 

can be hand pulled or controlled using 

hand tools. Reseeding and replanting of 

restoration sites would be limited to small 

areas where shrubs and other vegetation 

would be planted by hand. Few fire and 

fuel breaks would be created. There would 

be little reduction in the risk of a 

catastrophic wildfire. Wild horse 

movement patterns and distribution, and 

availability and quality of forage and 

water, would be less under this alternative 

than the other action alternatives. These 

effects would be most noticeable during 

drought periods, harsh winters, or during 

periods of wild horse overpopulation. 

Thus, there would be negligible 

improvement in wild horse genetic 

diversity. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-60 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Cumulative Effects: Historic overgrazing 

and other natural- and human-caused 

factors have contributed to an increase in 

wildfire occurrence and intensity and to a 

decrease in native plant diversity, 

specifically in the understory of the 

sagebrush community. In addition, 

livestock congregation and concentrated 

use by overpopulation of wild horses near 

streams, springs, and wetlands has 

contributed to the loss of riparian habitat 

and forage, and degradation of stream 

channels and their ability to function 

appropriately and provide abundant and 

high quality water for wild horses. The 

Mount Hope Project would have an

impact on wild horses in the CESA by 

removing approximately 14,200 acres of 

wild horse habitat and prohibiting wild 

horse access to natural watering sources 

and forage. Long-term, hazardous fuels 

reduction, habitat improvement, and 

noxious weeds and other invasive nonnative vegetation control projects would 

occur on about 66,000 acres within the 

HMAs, or about 26 percent of HMA

acreage within the CESA. Although the 

cumulative effects of human disturbance, 

mining and other development, and 

wildfire in the CESA would impact wild 

horse forage and water quality and 

quantity, treatments to improve forage and 

water quantity and quality, livestock 

Cumulative Effects: Under Alternative 

B, about half as many acres would be 

treated to reduce wildfire risk and its 

impacts on wild horse forage and water 

quality, including use of prescribed fire 

and wildland fire for resource benefit to 

restore natural fire regimes, than under 

Alternative A. By not using fire on the 3 

Bars Project area, there would be no risks 

to vegetation and wild horse forage from 

fire on several thousand acres annually. 

However, long-term benefits to wild 

horses that could be derived from 

prescribed fire and wildland fire for 

resource benefit would not occur under 

this alternative, including improving 

pinyon-juniper health, creating a mosaic 

of habitat, slowing pinyon-juniper 

encroachment, making vegetation more 

fire resilient, creating openings in pinyonjuniper habitat to promote shrub, forb, and 

grass development, and reducing the risk 

of catastrophic wildfire. Hazardous fuels 

reduction and habitat improvement 

projects and other land uses would occur 

on about 37,000 acres within HMAs, or 

about 18 percent of HMA acreage within 

the CESA (1 percent annually). Although 

3 Bars Project treatments would improve 

the physical and genetic health of wild 

horses and help to better distribute wild 

horses across the 3 Bars Project area, these 

benefits would be less than under

Cumulative Effects: Adverse, short-term 

effects to vegetation associated with the 

use of fire and mechanized equipment 

would not occur under Alternative C. The 

risk of wildfire and its impacts on the 

water and vegetation used by wild horses 

would likely increase on the 3 Bars 

Project area under this alternative. The 

BLM would not be able to use mechanical 

methods and fire to reduce hazardous 

fuels, create fire and fuel breaks, thin and 

remove pinyon-juniper to promote more 

fire resilient vegetation, and remove 

downed wood and slash. Restoration 

treatments would impact about 22,000 

acres within HMAs, or about 9 percent of 

the HMA acreage in the CESA; less than 

1 percent of the acreage on the CESA 

would be affected annually. These 

treatments would help to restore plant 

communities back to their Potential 

Natural Community and would improve 

the physical and genetic health of wild 

horses, but not to the extent that would 

occur under Alternatives A and B. 

Cumulative Effects: There would be no 

cumulative effects on wild horses from 3 

Bars Project treatments as no treatments 

would be authorized under this alternative. 

Based on historic treatments in the 3 Bars 

Project area, only about 1,500 acres would 

be treated annually in the CESA to reduce 

hazardous fuel levels and improve 

ecosystem health, and only about a third 

of these treatments would occur on

HMAs, under current and reasonably 

foreseeable future authorized actions. The 

BLM would restore little riparian habitat. 

Thus, water quality would remain 

degraded and water availability could be 

limiting, especially during droughts, for 

wild horses. The trend toward large-sized 

wildfires of moderate to high severity in 

sagebrush and large stand-replacing 

wildfires in pinyon-juniper would likely 

increase. There would be few benefits to 

wild horse habitat, and their physical and 

genetic health, and comprehensive 

improvement to habitat components or 

movement patterns would not occur longterm. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-61 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

adjustments, wild horse gathers, and 

reduction of hazardous fuels would help 

offset the effects, and improve wild horse 

habitat quantity and quality as well as the 

physical and genetic health of the 

populations long-term and lead to a better

distribution of wild horses across the 

HMAs within the CESA. Long-term 

benefits from treatments would be greater 

under this alternative than the other 

alternatives. 

Alternative A, particularly in light of the 

cumulative impacts to wild horse habitat 

loss that could be realized from 

implementation of the Mount Hope 

Project. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON LIVESTOCK AND RANGELAND CONDITIONS

Direct and Indirect Effects: Short-term, 

some treatment methods could result in a 

temporary loss of forage for livestock. 

Livestock injury or death could occur as a 

result of project activities, most likely 

from a vehicle-livestock collision. 

Temporary exclosure fencing could

interfere with livestock use of treatment 

areas and with the movement patterns of 

livestock. Treatments could result in shortterm water quality impacts from soil 

erosion and sedimentation of streams. 

Long-term, treatments that improve 

woodland, rangeland, and riparian health, 

productivity, and functionality would 

benefit livestock and their health. Riparian 

treatments should help several streams 

achieve Proper Functioning Condition and 

improve water flows and quality to the 

benefit of livestock. Removal of pinyonDirect and Indirect Effects: Because the 

BLM would not be able to use fire, there 

would be none of the adverse effects 

associated with fire. In particular, there 

would be no loss of forage, impacts to

water quality from soil erosion, and 

potential spread of noxious weeds and 

other invasive non-native vegetation in 

burned areas. With no use of fire proposed 

by the BLM, permittees would likely have 

more flexibility in managing their herds as 

treatment areas would generally be 

smaller. Many treatments would take 

longer to complete, such as those where 

pinyon-juniper, and noxious weeds and 

other invasive non-native species, are 

controlled using mechanical or manual 

treatments instead of fire, or where stream 

channel and riparian habitat restoration are 

proposed. Thus, the time that permittees 

Direct and Indirect Effects: The 

consequences of not using fire under 

Alternative C would be the same as those 

discussed under Alternative B. Under 

Alternative C, many treatments would 

take longer to complete, such as those 

where pinyon-juniper and noxious weeds 

and other invasive non-native species are 

controlled using manual treatments instead 

of fire and mechanical methods, or where 

stream channel and riparian habitat 

restoration are proposed. Thus, the time 

that permittees would have to adjust their 

grazing plans could be longer than under 

Alternative A. Most of the treatments 

under this alternative would be to thin and 

remove pinyon-juniper using chainsaws 

where it is encroaching into riparian, 

aspen, and sagebrush habitats. Noise and 

other disturbance would be less with 

Direct and Indirect Effects: There would 

be no direct or indirect effects to livestock 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. Thus, this alternative would 

not return the 3 Bars ecosystem to its 

Potential Natural Community and improve 

rangeland conditions for livestock. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-62 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

juniper near streams could increase stream 

flows. Treatments to reduce hazardous 

fuels, remove noxious weeds and other 

invasive non-native vegetation, and 

restore native, fire resilient vegetation 

would reduce the risk of wildfire and its 

adverse impacts on forage and water 

quality and quantity to the benefit of 

livestock. Removal of pinyon-juniper in 

several drainages on Roberts Mountains

would provide forage for livestock in 

areas once dominated by pinyon-juniper, 

and may facilitate livestock movements 

between valley and mountain use areas. 

On the Rocky Hills Unit, the BLM would 

remove crested wheatgrass and re-seed or 

re-plant the area with sagebrush. This 

could result in the loss of forage for 

livestock, and may require that the BLM 

temporarily suspend animal unit months 

(AUMs) during the treatment. 

would have to adjust their grazing plans 

could be longer than under Alternative A. 

Acres and types of wetland and riparian 

habitat treated would be similar to 

Alternative A, and the BLM could use 

temporary exclosure fencing to protect 

treatment areas. However, less effort 

would be spent by the BLM on slowing 

pinyon-juniper encroachment into 

sagebrush and riparian communities, 

reducing the amount of Phase II and III 

pinyon-juniper treated using standreplacement fires, reducing the amount of 

historic sagebrush habitat restored, and 

reducing the acres of priority habitat 

treated to improve species diversity, 

especially through cheatgrass control. 

Thus, there would be fewer gains in forage 

production outside of riparian zones, and 

greater risk of habitat loss from 

catastrophic wildfire, under this alternative 

than Alternative A. Because fire would 

not be available to reduce hazardous fuel 

loads, Alternative B may pose a greater 

long-term risk for wildfire due to the 

accumulation of fuels. Thus, overall 

benefits to livestock from treatment 

actions would be less under this 

alternative than under Alternative A. 

manual methods than the other methods. 

Because land disturbance would be greater 

using mechanical methods and fire than it 

would be with manual and classical 

biological control methods, short-term 

adverse effects to livestock drinking water 

quality from soil erosion, and loss of nontarget vegetation, would be less under this 

alternative than under Alternatives A and 

B. By not being able to use mechanical 

equipment, however, the BLM would also 

not be able to conduct stream engineering 

and restoration, except on a limited basis 

on only a few stream miles; control 

noxious weeds and other invasive nonnative vegetation, except on very small 

areas where this vegetation can be hand 

pulled or controlled using hand tools; 

reseed and replant restoration sites, except 

for small areas where shrubs and other 

vegetation would be planted by hand or

mowed to promote development of 

desirable forbs and grasses; or create fire 

and fuel breaks to reduce the risk of fire 

spread. As a result, there would be less 

improvement in forage and water quantity 

and quality, and more risk of catastrophic 

wildfire than under the other action 

alternatives. Overall benefits to livestock 

from treatment actions would be less 

under this alternative than under 

Alternatives A and B. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-63 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Cumulative Effects: Rangeland health 

studies have shown a need to improve the 

quantity and quality of forage within 

allotments. In addition, livestock often 

congregate near streams, springs, and 

wetlands, causing degradation of riparian 

habitat and forage, and impacts to stream 

channels and their ability to function 

appropriately and provide abundant and 

high quality water for livestock. A total of 

813 AUMs in the Romano and Roberts 

Mountain Allotments would be lost for 70 

years or more as a result of the 14,300-

acre Mount Hope Project. The BLM 

would treat about 127,000 acres in the 3 

Bars Project area, and an additional 

15,000 acres under existing and future 

authorizations, over the next 10 to 15 

years within the CESA, or about 11 

percent of the CESA. Short-term, there 

would be disturbance to and loss of 

vegetation, particularly pinyon-juniper and 

non-native vegetation, and there could be 

an increase in noxious weeds and other 

invasive non-native vegetation, from 

treatments. Long-term, these treatments 

should result in vegetation that is 

healthier, more fire resilient, abundant, 

and diverse, and that is similar to the 

Potential Natural Community. The BLM 

would conduct stream bioengineering and 

plantings on about 31 miles of stream to 

slow stream flow and create pools and wet 

Cumulative Effects: By not using fire on 

the 3 Bars Project area, there would be no 

risks to livestock forage from fire on 

several thousand acres annually within the 

3 Bars Project area. Hazardous fuels 

reduction and habitat improvement 

projects could occur on about 63,000 acres 

within the 3 Bars Project area, and on an 

additional 15,000 acres within the CESA, 

or about 6 percent of the CESA. Overall, 

there would be a net beneficial 

accumulation of effects from BLM 

treatments long-term that would help to 

offset adverse effects to livestock from 

other reasonably foreseeable future 

actions, but not to the extent as would 

occur under Alternative A. 

Cumulative Effects: By not being able to 

use mechanical methods, fire, and 

livestock to reduce hazardous fuels, create 

fire and fuel breaks, and remove downed 

wood and slash, the risk of wildfire and its 

impacts on vegetation and water used by 

livestock would likely increase on the 3 

Bars Project area. Hazardous fuels 

reduction and habitat improvement 

projects would occur on about 32,000 

acres within the 3 Bars Project area, and 

on an additional 15,000 acres within the 

CESA, or about 4 percent of the acreage 

within the CESA. Overall, there would be 

a net beneficial accumulation of effects 

from BLM treatments long-term that 

would help to offset adverse effects to 

livestock from other reasonably 

foreseeable future actions, but not to the 

extent as would occur under Alternatives 

A and B. 

Cumulative Effects: There would be no 

cumulative effects on livestock from 3 

Bars Project treatments as no treatments 

would be authorized under this alternative. 

The BLM would be able to conduct 

treatments on a limited acreage, as 

discussed above under Soil Resources, to 

benefit livestock within the CESA. BLM 

treatments would help to offset some of 

the effects to livestock from non-3 Bars 

Project actions, but not to the extent as 

would occur under the action alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-64 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

meadows to improve wetland and riparian 

habitat and water flows and quality. In 

addition, the BLM would thin and remove 

pinyon-juniper and noxious weed and 

other invasive non-native vegetation, and 

create fire and fuel breaks to reduce this 

risk of catastrophic wildfire and its spread. 

These beneficial effects would help to 

offset some of the adverse effects to 

livestock from other reasonably 

foreseeable future actions in the CESA. 

Mitigation: Riparian Treatments 

Monitoring and Mitigation: 1) Prior to 

implementation of a treatment, the BLM 

will review the current livestock grazing 

management and resource conditions, 

such as the season of use and Proper 

Functioning Condition rating, and 

determine if changes in the current terms 

and conditions of the grazing permit will 

be required to maintain the long-term 

success of the proposed treatment. 

Changes to the permitted use will be 

completed through the issuance of 

subsequent grazing decisions in 

accordance with 43 CFR §§ 4110.3, 

4130.3-3, and 4160.2). To ensure 

treatment success, the following 

modifications may be made to the Terms 

and Conditions of the grazing permit: a) 

Timing and Duration of Grazing: The 

season of use may shifted to avoid hot 

season grazing (July – September) or the 

Mitigation: See Alternative A. Mitigation: See Alternative A. Mitigation: See Alternative A. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-65 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

duration of grazing may be shortened to 

give the riparian vegetation time to 

recover; b) Average stubble height of at 

least 4 to 6 inches will be maintained for 

herbaceous riparian vegetation with 

consideration for habitat. If stubble height 

limits are reached, the permittee will have 

5 days to move livestock to the next 

pasture in the rotation or from the 

allotment entirely; c) Streambank 

alteration rates would be set to a level 

appropriate to the particular stream in 

accordance with Guidelines for 

Establishing Allowable Levels of 

Streambank Alteration (Cowley 2002). 

Based on the characteristics of the streams 

and the presence of Lahontan cutthroat 

trout, the streambank alteration rates 

would range from 10 to 20 percent. If 

designated streambank alteration rates are 

reached, the permittee will have 5 days to 

move livestock to the next pasture in the 

rotation or from the allotment entirely; d) 

Utilization rates will not exceed 35 

percent for woody species. If utilization 

rates are reached, the permittee will have 5 

days to move livestock to the next pasture 

in the rotation or from the allotment 

entirely (Wyman et al. 2006); and e) 

Existing non-functioning water 

developments and fences may be required 

to be repaired prior to implementation of 

the treatment if contributing to 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-66 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

unacceptable use patterns by livestock. 3) 

Season of use may be modified to exclude 

hot season grazing from July 1 to 

September 30 annually. 

Aspen Treatments Monitoring and 

Mitigation: 1) Temporary fences may be

used to exclude wildlife and livestock 

grazing within the treatment area until the 

following criteria are met, and then they 

will be removed: a) A mean sucker height 

of 7 feet with a minimum of 10,000 stems 

per acre within the treatment area (Kay 

2002). 2) To ensure proposed treatment 

success, the following stipulations may be 

added to the Terms and Conditions of the 

grazing permit: a) The season of use may 

be shifted to late season (beginning of 

September; Jones 2010); b) If the season 

of use is not shifted to late season, then 

utilization of terminal leader browse on 

branches and suckers will be less than or 

equal to 20 percent. If utilization rates are 

reached, the permittee will have 5 days to 

move livestock to the next pasture in the 

rotation or from the allotment entirely; and 

c) Existing non-functioning water 

developments and fences may be required 

to be repaired prior to implementation of 

the treatment if contributing to 

unacceptable use patterns by livestock. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-67 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Pinyon-juniper and Sagebrush Treatments 

Monitoring and Mitigation: 1) Prior to 

implementation of any seeding treatment, 

the BLM will ensure proper livestock 

management. 2) If changes to the 

permitted use are necessary, those changes 

will be completed through the issuance of 

subsequent grazing decisions in 

accordance with 43 CFR §§ 4110.3, 

4130.3-3, and 4160. 3) To ensure 

treatment success, the following 

modifications may be made to the Terms 

and Conditions of the grazing permit: a) 

Timing and Duration of Grazing: The 

season of use may be shifted or the 

duration of grazing may be shortened to 

give the vegetation time to recover from 

grazing; b) In mountain big sagebrush 

communities, utilization rates will not 

exceed 45 percent for upland herbaceous 

species and 35 percent for upland shrub 

species. If utilization rates are reached, the 

permittee will have 5 days to move 

livestock to the next pasture in the rotation 

or from the allotment entirely as outlined 

in Range Management, Principles and 

Practices (Holechek et al. 1998); c) In 

Wyoming and basin big sagebrush 

communities, utilization rates will not 

exceed 35 percent for upland herbaceous 

species and 35 percent for upland shrub 

species. If utilization rates are reached, the 

permittee will have 5 days to move 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-68 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

livestock to the next pasture in the rotation 

or from the allotment entirely as outlined 

in Holechek et al. (1998); d) In black 

sagebrush communities, utilization rates 

will not exceed 45 percent for upland 

herbaceous species and 35 percent for 

upland shrub species. If utilization rates 

are reached, the permittee will have 5 days 

to move livestock to the next pasture in 

the rotation or from the allotment entirely 

as outlined in Holechek et al. (1998); and 

e) Existing non-functioning water 

developments and fences may be required 

to be repaired prior to implementation of 

the treatment if contributing to 

unacceptable use patterns by livestock. 4) 

Season of grazing use may be modified to 

provide growing season deferment and 

dormant season grazing. 

SUMMARY OF EFFECTS ON VISUAL RESOURCES

Direct and Indirect Effects: In the shortterm, removal of vegetation would affect 

the visual qualities of treatment sites by 

creating hard-edged openings and other 

vegetation-free areas that provide a 

noticeable visual contrast to the 

surrounding areas. Treatments could 

create visually distinct areas of discolored 

vegetation, which could contrast markedly 

from surrounding areas of healthy 

vegetation. Impacts would last for the 

longest amount of time in pinyon-juniper 

stands where large trees and shrubs are 

Direct and Indirect Effects: Without the 

use of fire, there would be no localized 

deterioration of air quality and reduced 

visibility caused by smoke, no blackened 

appearance of treated areas and blackened 

stumps and snags that would create a color 

contrast, and no spread of noxious weeds 

and other invasive non-native vegetation 

in burned areas. However, long-term 

improvements in pinyon-juniper stand 

health, replacement of pinyon-juniper 

stands with sagebrush, forbs, and grasses, 

and removal of encroaching pinyonDirect and Indirect Effects: By not 

being able to use fire and mechanical 

equipment, there would be no adverse 

visual effects associated with burned 

vegetation; creating openings in pinyonjuniper stands from removal of vegetation; 

creating long linear features for fire and 

fuel breaks; or causing surface disturbance 

from disking/tilling/harrowing to restore 

areas invaded by cheatgrass. The BLM 

would also leave less dead plant material 

on the ground to turn brown. Under 

Alternative C, the BLM would not be able 

Direct and Indirect Effects: There would 

be no direct effects to visual resources 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. This alternative would also do 

little to return the 3 Bars ecosystem to its 

Potential Natural Community and restore 

Proper Functioning Condition to wetlands 

and riparian zones, to the benefit of visual 

resources on the project area. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-69 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

removed. Long-term, treatments would 

result in plant communities that are 

dominated by native species. Nativedominated communities tend to be more 

diverse, and thus more visually appealing,

than plant communities that have been 

overtaken by the surrounding monoculture 

(such as pinyon-juniper encroaching on 

riparian zones). Treatments that reduce the 

risk of wildfire should reduce the visual 

impacts associated with large expanses of 

burned vegetation. Efforts to restore 

native, fire-resilient vegetation would 

make these areas more visually appealing, 

and would reduce the risk of future 

wildfires. 

juniper using prescribed fire and wildland 

fire for resource benefit, and the resultant 

improvement in the visual qualities of the 

landscape, would not occur over several 

thousand acres annually. Without the use 

of fire to reduce hazardous fuel loads, 

Alternative B could pose a greater longterm risk for wildfire due to the 

accumulation of fuels. The BLM would 

not be able to promote more fire resilient 

and diverse habitat on the 3 Bars Project 

area. An increase in wildfire risk under 

Alternative B than under Alternative A 

could lead to a long-term reduction in the 

visual qualities of the landscape. Although 

short-term impacts to visual resources 

would be less under this alternative than 

Alternative A, there would be less longterm improvement in the scenic quality of 

the 3 Bars Project area under Alternative 

B than under Alternative A. 

to conduct stream engineering and 

restoration to improve native riparian 

habitat, except on a limited basis on only a 

few stream miles; control noxious weeds 

and other invasive non-native vegetation, 

except on very small areas where this 

vegetation can be hand pulled or 

controlled using hand tools; reseed and 

replant restoration sites, except for small 

areas where shrubs and other vegetation 

would be planted by hand; or create fire 

and fuel breaks to reduce the risk of 

wildfire spread. The BLM would only be 

able conduct hazardous fuels treatments 

and remove downed woody material from 

treatments on a limited acreage. Thus, the 

risk of catastrophic wildfire, and its effects 

on the visual landscape, would be greater 

under Alternative C than under the other 

action alternatives. Overall, there would 

be less improvement in the visual quality 

of the 3 Bars Project area under this 

alternatives than under Alternatives A and 

B. 

Cumulative Effects: Past and present 

actions discussed above for soil resources 

have affected visual resources within the 

CESA. In addition, the Mount Hope 

Project would disturb about 8,300 acres. 

There would be a moderate to strong 

contrast in form, line, and color between 

the existing landscape and the postmining landscape associated with the 

Cumulative Effects: Under Alternative 

B, less effort would be spent by the BLM 

on treatments to reduce wildfire risk and 

its impacts on visual resources. By not 

using fire, there would be no visual effects 

associated with fire on several thousand 

acres annually within the 3 Bars Project 

area. This includes the effects of smoke, 

dead and dying vegetation, and a charred 

Cumulative Effects: Adverse, short-term 

effects to scenic resources, primarily 

vegetation, associated with the use of fire 

and mechanized equipment would not 

occur under Alternative C. Fire and 

mechanized equipment could be used in 

other portions of the CESA to improve 

habitat, remove hazardous fuels, and 

reduce the risk of wildfire under current 

Cumulative Effects: There would be no 

cumulative effects on visual resources 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. As discussed above under soil 

resources, existing and future 

authorizations would improve ecosystem 

functionality on a limited acreage, to the 

benefit of visual resources. Based on 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-70 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Mount Hope Project. Most of the area 

encompassed by the mine project is 

Visual Resource Management (VRM)

Class IV; however, the changes in the 

landscape would conform to VRM 

objectives. Proposed hazardous fuels 

reduction and habitat improvement 

treatments would occur on about 127,000 

acres for the 3 Bars Project, and on about 

15,000 acres in other portions of the 

CESA under current and future 

authorizations, or collectively on about 5 

percent of the CESA. Treatments would

help to offset some of the adverse effects 

to visual resources from other reasonably 

foreseeable future actions in the CESA, 

and to a greater extent than would occur 

under the other alternatives. 

landscape. However, the use of fire could 

occur on a few hundred acres annually 

outside the 3 Bars Project treatment areas. 

Hazardous fuels reduction and habitat 

improvement projects could occur on 

about 63,000 acres within the 3 Bars 

Project area, and on an additional 15,000 

acres within the CESA, or only about 3 

percent of the acreage within the CESA. 

Still, there would be a long-term net 

benefit from BLM treatments that would 

help to offset some of the adverse effects 

to visual resources from other reasonably 

foreseeable future actions, but not to the 

extent as would occur under Alternative 

A. 

and future authorizations. By not being 

able to use mechanical methods, disking, 

plowing, shredding, and mulching would 

not occur that would cause a visual 

contrast with untreated areas. The BLM, 

however, would not be able to use fire and 

mechanical methods to restore riparian, 

aspen, pinyon-juniper, and sagebrush 

habitats, restore areas dominated by 

cheatgrass and other noxious weeds and 

invasive non-native vegetation, or restore 

degraded stream channels and riparian 

zones, to the detriment of the scenery on 

the 3 Bars Project area. The BLM would 

also be less able to reduce hazardous fuels 

and construct fire and fuel breaks, and 

reduce the risk of catastrophic wildfire and 

its effects on the scenery. Hazardous fuels 

reduction and habitat improvement 

projects could occur on about 32,000 acres 

within the 3 Bars Project area, and on an 

additional 15,000 acres within the CESA, 

or only about 2 percent of the acreage 

within the CESA. There would be a longterm net benefit from BLM treatments that 

would help to offset some of the adverse 

effects to visual resources from other 

reasonably foreseeable future actions, but 

not to the extent as would occur under 

Alternatives A and B. 

historic treatments in the 3 Bars Project 

area, only about 1,500 acres would be 

treated annually in the CESA. Thus, the 

BLM would not move rangelands toward 

their Potential Natural Community or 

restore Proper Functioning Condition in 

wetlands and riparian zones. The trend 

toward large-sized fires of moderate to 

high severity in sagebrush and large standreplacing fires in pinyon-juniper would 

likely increase. As a result, visual resource 

conditions would likely continue to 

deteriorate within the CESA. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON LAND USE AND ACCESS

Direct and Indirect Effects: Adverse Direct and Indirect Effects: Because fire Direct and Indirect Effects: Because fire Direct and Indirect Effects: There would 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-71 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

effects to land use include short-term 

access limitations to land uses and current 

land use authorizations. Treatments that 

reduce the risk of future catastrophic 

wildfire through fuels reduction would 

reduce the risk of loss of life, property, 

constructed facilities on public land, and 

resources on the 3 Bars Project area. 

Treatments would not result in long-term, 

substantial conflicts with existing land 

uses, changes in land use designations, or 

reduction in opportunities for rights-ofway authorizations and development 

activities. Additionally, there would not be 

a substantial reduction in opportunities for 

land tenure adjustments. The BLM would 

have the ability to issue new 

authorizations needed to implement 

treatments, including restricting access to 

an area and closing treatment areas to 

livestock and humans for periods of time 

needed to ensure treatment success. 

would not be available to reduce 

hazardous fuel loads and improve habitat, 

Alternative B may pose a greater longterm risk for wildfire than Alternative A 

due to the accumulation of fuels that could 

lead to loss of life and property. Without 

the use of prescribed fire, treatments could 

take longer, especially those needed to 

thin and remove Phase II and III pinyonjuniper stands, and the public may be 

restricted from accessing treatment sites 

for longer periods than if fire could be 

used. There could be temporary access 

restrictions from treatments, but 

treatments would not preclude future land 

use authorizations within the project area, 

and would not conflict with county and 

BLM land use objectives. 

and mechanical methods would not be 

available to reduce hazardous fuel loads 

and improve habitat, Alternative C would 

pose a greater long-term risk for wildfire 

than the other action alternatives due to 

the accumulation of fuels that could lead 

to loss of life and property. Without the 

use of fire and mechanical methods, 

treatments would take longer, especially 

those needed to thin and remove Phase II 

and III pinyon-juniper stands, restore 

lands dominated by cheatgrass and other 

noxious weeds and other invasive nonnative vegetation, or to restore stream 

channels. Thus, the public may be 

restricted from accessing treatment sites 

for longer periods than if fire and 

mechanical methods could be used. There 

could be temporary access restrictions 

from treatments. Treatments would not 

preclude future land use authorizations 

within the project area, and would not 

conflict with county and BLM land use 

objectives. 

be no direct effects to land use and access 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. The BLM would not take 

actions to reduce wildfire risk, so there 

would be no short-term access restrictions. 

Cumulative Effects: Permanent features 

or exclusion areas associated with the 

Mount Hope Project and future land 

development actions, in combination with 

3 Bars Project activities, could impact 

future rights-of-way authorizations, 

development activities, and land tenure 

adjustments, and conflict with Eureka 

County and BLM land use objectives. 

Cumulative Effects: By not using fire on 

the 3 Bars Project area, there would be no 

land access restrictions associated with use 

of prescribed fire and wildland fire for 

resource benefit on several thousand acres 

annually within the 3 Bars Project area. 

However, by not conducting fire 

treatments to reduce the risk of wildfire, 

the potential for wildfire to adversely 

Cumulative Effects: By not being able to 

use mechanical methods and fire, the 

BLM would treat fewer acres to reduce 

hazardous fuels, create fire and fuel 

breaks, remove downed wood and slash, 

control noxious weeds and other invasive 

non-native vegetation, and improve 

vegetation health and condition to make it 

more resilient to wildfire. Thus, the 

Cumulative Effects: There would be no 

cumulative effects on land use and access 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. The BLM could take actions 

under existing and future authorizations to 

benefit ecosystem health, as discussed 

above under Soil Resources, but only on 

about 1,500 acres annually. 3 Bars Project 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-72 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

These effects would be greatest under 

Alternative A. Wildfires could adversely 

affect life and property, access, and 

resource use, on or near the 3 Bars Project 

area. The BLM is proposing to treat about 

127,000 acres on the 3 Bars Project area, 

and about 15,000 acres elsewhere in the 

CESA under current and reasonably 

foreseeable future authorizations to restore 

ecosystem health. 3 Bars Project 

treatments, and potential short-term access 

restrictions, could occur on about 17 

percent of the CESA under Alternative A. 

There would be no permanent features or 

exclusion areas associated with 3 Bars 

Project actions. 

affect life and property, access, and 

resource use on or near the 3 Bars Project 

area would be greater than under

Alternative A. 3 Bars Project treatments, 

and potential short-term access 

restrictions, would occur on about 78,000 

acres, or about 8 percent of the CESA 

under Alternative B. There would be no 

permanent features or exclusion areas 

associated with 3 Bars Project actions. 

potential for wildfire to adversely affect 

life and property, access, and resource use, 

on or near the 3 Bars Project area, would 

be greater than under Alternatives A and 

B. 3 Bars Project treatments, and potential 

short-term access restrictions, would occur 

on about 47,000 acres, or 4 percent of the 

CESA under Alternative C. There would 

be no permanent features or exclusion 

areas associated with project actions. 

treatments, and potential short-term access 

restrictions, would occur on about 2 

percent of the CESA under Alternative D. 

There would be no permanent features or 

exclusion areas associated with 3 Bars 

Project actions. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON RECREATION

Direct and Indirect Effects: There would 

be some short-term scenic impacts, as well 

as distractions to users (e.g. , noise from 

machinery), from treatments. Some areas 

would be off-limits to recreational

activities as a result of treatments, for 

periods ranging from a few hours to days, 

or even 1 full growing season or longer, 

depending on the treatment. There could 

be temporary displacement of wildlife for 

both consumptive (e.g., hunting, fishing) 

and non-consumptive (e.g., wildlife 

viewing, photography) users. Users of the 

Pony Express National Historic Trail 

could potentially be impacted by treatment 

Direct and Indirect Effects: Because the 

BLM would not be able to use fire, there 

would be none of the adverse effects 

associated with this treatment type. 

However, with greater reliance on 

mechanical methods, there may be greater 

disturbance to the public from the use of 

mechanical equipment than would occur 

under Alternative A. There would be 

fewer gains in wildlife forage production 

outside of riparian zones, and greater risk 

of habitat loss from catastrophic wildfire, 

under this alternative than under 

Alternative A. Some treatments to 

improve historic pinyon-juniper 

Direct and Indirect Effects: The 

consequences of not using fire under 

Alternative C would be the same as those 

discussed under Alternative B. Effects to 

visitors from noise and disturbance 

associated with mechanical treatment 

equipment would not occur under this 

alternative. By not being able to use 

mechanical equipment, however, there 

would be less improvement in vegetation 

and water quantity and quality, and more 

risk of catastrophic wildfire, than under 

Alternatives A and B. Under Alternative 

C, the BLM would not substantially 

improve the native vegetation community 

Direct and Indirect Effects: There would 

be no direct or indirect effects on 

recreation from 3 Bars Project treatments 

as no treatments would be authorized 

under this alternative. Thus, long-term

loss of recreational opportunities and 

deterioration in the visitor experience 

would be greatest under Alternative D. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-73 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

activity and noise during implementation 

of the treatments and the visual aspects of 

the recreational experience of the trail may 

be affected in the short-term until 

vegetation recovers to the point where it 

no longer appears that it has been 

manipulated. Long-term, improved fish 

and game habitat and populations should 

provide additional and/or improved 

hunting and fishing opportunities. 

Improved habitat should enhance the 

overall scenic quality of the area, while 

removal of noxious weeds and invasive 

non-native vegetation would reduce the 

likelihood of visitors being harmed or 

inconvenienced by these plants, and could 

influence the visitor experience. Riparian 

projects would be beneficial to anglers if 

they lead to improved fish populations. 

Prescribed burns would require the closure 

of burn areas to visitors during burn 

activities. People recreating in nearby 

areas would be able to see and perhaps 

smell smoke. The potential for smoke 

inhalation could result in some health risks 

to these users, A reduction in wildfire risk, 

however, should lead to fewer temporary 

closures to protect human safety (i.e., 

fewer public access constraints from 

fires). As a result of thinning and removal 

treatments, the number of pinyon pine and 

juniper trees within woodland products 

harvest areas would be reduced. 

communities would occur, which could 

benefit future pine nut harvest in these 

areas long-term, but the acreage benefiting 

from these treatments would be 

substantially less than under Alternative 

A. 

nor stop the loss of important ecosystem 

components. As a result, the visitor use 

experience could decline long-term. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-74 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Cumulative Effects: In general, while 

there are locally important recreation 

resources in the CESA, the types of 

dispersed recreation resources available in 

the area are not of regional or national 

significance except for the Pony Express 

National Historic Trail, which has been 

Congressionally designated as a 

recreational resource. Recreational use 

within the CESA is likely to increase 

proportionally to changes in the regional 

population. To reduce the risk of 

catastrophic wildfire and to restore the 

health and resiliency of native vegetation, 

the BLM would treat up to 127,000 acres 

to reduce hazardous fuels. The BLM also 

proposes to treat hazardous fuels on an 

additional 15,000 acres under current and 

reasonably foreseeable future 

authorizations in high to very high fire risk 

areas within other portions of the CESA. 

Recreational access to treatment areas 

could be restricted during the treatment 

period, and it is likely that the treated area 

would have few recreation values for 

several years after treatments. Over time, 

this reduction in fuels, however, would 

allow for more natural forage within the 

analysis area, benefiting game populations 

and hunting opportunities and improving

the health of pinyon-juniper stands, which 

could benefit nut production. In addition, 

treatments would reduce the risk of 

Cumulative Effects: By not using fire, 

the amount of area disturbed by treatments 

would generally be smaller, and have less 

impact on fish and wildlife resources and 

scenery, than other treatment methods. 

However, fewer acres would also be 

treated to restore landscape health and 

habitat for fish and game, and reduce the 

risk of catastrophic wildfire, and would 

not likely offset the increased potential for 

more extensive and intense wildfires to 

occur in place of controlled burns on the 3 

Bars Project area. About 63,000 acres of 

vegetation, and 31 miles of stream, would 

be disturbed from the 3 Bars Project, or 

only about 2 percent of the CESA. 

Treatments would result in localized 

effects and would not substantially alter 

the availability of dispersed recreation 

opportunities in the CESA or larger 

region. Still, there would be a long-term 

net benefit from BLM treatments that 

would help to offset some of the adverse 

effects to recreation resources from other 

reasonably foreseeable future actions. 

Actions would provide more recreation 

opportunities for a growing population, 

but not to the extent as would occur under 

Alternative A. 

Cumulative Effects: By not being able to 

use fire and mechanical methods there 

would be less disturbance to public from 

treatments compared to Alternatives A 

and B. Without the use of fire and 

mechanical methods, however, the BLM 

would do little to improve ecosystem 

health. The risk of wildfire and its effects 

on recreation would likely increase, while 

there would be few benefits to fish and 

game, under this alternative compared to 

Alternatives A and B. About 32,000 acres 

of vegetation, and 8 miles of stream, 

would be disturbed from the 3 Bars 

Project, or only about 1 percent of the 

CESA. Treatments would result in 

localized effects and would not 

substantially alter the availability of 

dispersed recreation opportunities in the 

CESA or larger region. Still, there would 

be a minor long-term net benefit from 

BLM treatments that would help to offset 

some of the adverse effects to recreational 

resources from other reasonably 

foreseeable future actions. Actions would 

provide more recreational opportunities 

for a growing population, but not to the 

extent as would occur under Alternatives 

A and B. 

Cumulative Effects: There would be no 

cumulative effects on recreation from 3 

Bars Project treatments as no treatments 

would be authorized under this alternative. 

The BLM could take actions under 

existing and future authorizations to 

benefit ecosystem health, as discussed 

above under Soil Resources, but only on 

about 1,500 acres annually. Thus, benefits 

to the recreating public would be 

substantially less under this alternative 

than under the action alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-75 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

catastrophic wildfire, which would benefit 

native plant communities and fish and 

game within the CESA. 3 Bars Project 

treatments would occur on only about 5 

percent of the CESA. Treatments would 

result in localized effects and would not 

substantially alter the availability of 

dispersed recreation opportunities in the 

CESA or larger region. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON WILDERNESS STUDY AREAS AND OTHER SPECIAL MANAGEMENT AREAS

Direct and Indirect Effects: Treatments 

within the Roberts Mountains and 

Simpson Park WSAs could temporarily 

impair the wilderness characteristics of 

solitude, naturalness, and primitive and 

unconfined recreation within and adjacent 

to these areas. The overall effect of 

treatments on the WSAs would depend on 

whether the end condition of the treatment 

site (considering both long-term benefits 

and short-term effects) was an 

improvement in wilderness characteristics. 

In many cases (e.g., an eradication of a 

small population of an incipient pest, a 

prescribed fire that mimicked historical 

fire), communities in the treatment area 

would quickly recover, and the overall 

effect would be positive. Manual 

treatments would be the least obtrusive 

method to use in WSAs and the most 

appropriate. Manual treatment methods 

Direct and Indirect Effects: The BLM 

anticipates treating about half as many 

acres (about 200 acres) within WSAs 

under Alternative B as under Alternative 

A. Without the use of fire, there would be 

no localized deterioration of air quality 

and reduced visibility caused by smoke, 

no disturbance, and no blackened 

appearance that could affect the 

naturalness of treatment areas. As noted 

under Alternative A, though, only a few 

acres, if any, would be treated using fire in 

WSAs so the adverse and beneficial 

effects of not using fire would be 

negligible under this alternative. As noted 

under Alternative A, users of the Pony 

Express National Historic Trail may detect 

activity and noise during project 

implementation and the effects of the 

treatments may be visible from the trail in 

the short-term until the vegetation no 

Direct and Indirect Effects: Under 

Alternative C, the BLM would only be 

able to use manual and classical biological 

control methods to treat vegetation. Fire 

and mechanical treatments would seldom 

be used under Alternatives A and B, so the 

cumulative effects associated with WSA 

treatments among the alternatives would 

show few differences. As noted under 

Alternative A, users of the Pony Express 

National Historic Trail may detect activity 

and noise during project implementation 

and the effects of the treatments may be 

visible from the trail in the short-term until 

the vegetation no longer shows signs of 

manipulation. 

Direct and Indirect Effects: There would 

be no direct or indirect effects on WSAs 

and the Pony Express National Historic 

Trail from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. The BLM could take actions 

under existing and future authorizations to 

benefit ecosystem health, as discussed 

above under Soil Resources, but on only 

about 1,500 acres annually. Little, if any, 

acreage would be treated within WSAs. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-76 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

are typically focused on small areas, 

which would have localized impacts on 

naturalness, solitude, and primitive and 

unconfined recreation. Although an 

appropriate buffer would be applied to 

minimize impacts to the Pony Express 

National Historic Trail, users of the trail 

may still detect activity and noise during 

project implementation and the effects of 

the treatments may be visible from the 

trail in the short-term until the vegetation 

no longer shows signs of manipulation. 

longer shows signs of manipulation. 

Cumulative Effects: Historic livestock 

grazing practices, wild horse use, and 

other natural- and human-caused factors

have led to impacts to riparian and aspen 

habitat, establishment and spread of 

noxious weeds and other invasive nonnative vegetation, and the expansion of 

pinyon-juniper beyond its historical ranges 

in portions of the WSAs. To reduce 

wildfire risk and improve ecosystem 

health, approximately 127,000 acres 

would be treated annually on the 3 Bars 

Project area, and an additional 15,000 

acres could be treated under current and 

future authorizations within the CESA, or 

about 16 percent of the CESA, but only on 

about 1 percent of WSAs. Although the 

acreage treated within WSAs would be 

small, treatments elsewhere in the CESA 

would help to reduce hazardous fuels and 

improve ecosystem health, and reduce the 

Cumulative Effects: Because fire would 

be used sparingly within WSAs under 

Alternative A, its lack of use under 

Alternative B would be insignificant. 

Without being able to use fire on other 

portions of the CESA, the BLM would be 

less successful in reducing the risk of 

catastrophic wildfire within the CESA, 

and would not likely offset the increased 

potential for more extensive and intense 

wildfires to occur in place of controlled 

burns on the 3 Bars Project area compared 

to Alternative A. As demonstrated by 

wildfires in 1999, wildfires can have 

substantial effects on WSAs and could 

also affect the scenery on and near the 

Pony Express National Historic Trail. 

Cumulative Effects: Adverse, short-term 

effects to wilderness characteristics, 

primarily solitude and visual qualities, 

associated with the use of fire and 

mechanized equipment would not occur 

under Alternative C. However, fire and 

mechanical treatments would seldom be 

used in WSAs under Alternatives A and 

B, so the cumulative effects associated 

with WSA treatments among the 

alternatives would show few differences. 

The BLM would treat only about 10 acres 

annually in the WSAs, and about 47,000 

acres within the remainder of the CESA, 

or about 4 percent of the CESA under 

Alternative C. The risk of wildfire and its 

adverse impacts on WSAs and lands near 

the Pony Express National Historic Trail 

would likely be greater on the 3 Bars 

Project area than under Alternatives A and 

Cumulative Effects: There would be no 

cumulative effects on WSAs or the Pony 

Express National Historic Trail from 3 

Bars Project treatments as no treatments 

would be authorized under this alternative. 

The BLM could take actions under 

existing and future authorizations to 

benefit ecosystem health, as discussed 

above under Soil Resources, but only on 

about 1,500 acres annually. Thus, benefits 

to the WSAs and the Pony Express 

National Historic Trail would be less 

under this alternative than under the action 

alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

potential for wildfire that could have 

substantial adverse affects on WSAs and 

lands on and near to the Pony Express

National Historic Trail. 

B. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON CULTURAL RESOURCES

Direct and Indirect Effects: Manual 

methods would result in general surface 

disturbance that could disrupt the spatial 

context of archaeological constituents, 

mulching with organic materials would 

compromise radiometric dating, and the 

use of hard-edged tools could damage 

artifacts. There is also the potential for 

unauthorized collection of artifacts by 

workers. The use of a track hoe or back 

hoe for stream channel restoration, and 

mechanical treatments on upland sites, 

could damage surface and subsurface 

cultural resources if the sites are not 

avoided. Mechanical treatments could also 

result in surface and shallow subsurface 

disturbance that would likely introduce 

organic materials to lower soil layers, 

thereby contaminating any surface or 

Direct and Indirect Effects: Mechanical 

and fire treatments have the greatest 

potential for harming cultural resources. 

Prescribed fire and wildland fire for 

resource benefits would not be used on 

several thousand acres annually, as they 

would under Alternative A. Fire has the 

potential to cause inadvertent effects to 

cultural sites. Under Alternative B, the 

BLM would be unable to restore fire as an 

integral part of ecosystem restoration. It is 

unlikely that the BLM would be able to 

slow the spread of noxious weeds and 

other invasive non-native vegetation, 

including cheatgrass. Cheatgrass is a 

major contributor to providing fuel for 

wildfire. It is unlikely that the trend 

toward large-sized fires of moderate to 

high severity in sagebrush and large standDirect and Indirect Effects: Given that 

mechanical and fire treatments, and to a 

lesser extent biological treatments using 

livestock, have the greatest potential to 

harm cultural sites, these risks would be 

eliminated under this alternative. 

However, large numbers of workers and 

their vehicles would be needed to 

accomplish proposed treatments under this 

alternative. Vehicle miles traveled would 

likely be greatest under this alternative 

and vehicles could crush cultural 

materials. Increased number of workers 

could increase the potential for looting. 

Downed trees and slash material from 

treatments would be difficult to remove 

without mechanical equipment or pile 

burning. Some downed wood and slash 

could be sold, used for biomass, or made 

Direct and Indirect Effects: There would 

be no direct or indirect effects on cultural 

resources from 3 Bars Project treatments 

as no treatments would be authorized 

under this alternative. The long-term 

threat to historic resources from wildfire 

would be greatest under Alternative D. 

shallow subsurface cultural resources. 

Archaeological materials may be 

replacing fires in pinyon-juniper would 

slow or reverse in the long-term, which 

available to the public as firewood, but the 

demand for this wood is unknown. The 

3 Bars Project Final EIS 2-77 October 2016

 ALTERNATIVES
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-78 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

damaged, destroyed, or remain essentially 

unaffected by prescribed fire. Wooden 

structures or wooden parts of stone 

structures (such as those within the 

Roberts Creek Unit) are very susceptible 

to fire. Long-term, stabilization and 

restoration of riparian systems would 

reduce streambank erosion and ensure that 

cultural and paleontological resources 

buried near streams remained intact. 

Uncontrolled wildfire, similar to 

prescribed fire, has the potential to 

significantly impact cultural resources. By 

improving ecosystem health and resiliency 

and reducing hazardous fuels, the risk of 

an uncontrolled catastrophic wildfire that 

could adversely affect historic properties 

would be reduced under this alternative. 

would continue to be a threat to historic 

properties and this threat would be greater 

under Alternative B than under 

Alternative A. 

number of miles of fire and fuel breaks 

created under this alternative would be 

substantially less than for Alternatives A 

and B as the BLM would not be able to 

use mechanical equipment to create fire 

and fuel breaks. Under Alternative C, it is 

unlikely the trend toward large-sized fires 

of moderate to high severity in sagebrush 

and large stand-replacing fires in pinyonjuniper would slow or reverse long-term, 

and wildfire would continue to be a threat 

to historic properties. 

Cumulative Effects: Past and present 

actions discussed above for Soil 

Resources have affected cultural resources 

within the CESA. In addition, the Mount 

Hope Project would disturb about 8,300 

acres, which includes 80 prehistoric and 

142 historic sites, and an additional 352 

sites within the larger area of potential 

effects, which includes a portion of the 3 

Bars Project area. Implementation of the 

Mount Hope Project would result in 

adverse impacts to 83 eligible sites, and 

these impacts would be considered 

significant. Under the 3 Bars Project and 

previous and reasonably foreseeable future

Cumulative Effects: Although use of fire 

would not occur within the 3 Bars Project 

area, the use of fire could occur on several 

hundred acres annually in the remainder of 

the CESA. By not using fire to reduce 

hazardous fuels and improve vegetation 

resiliency to fire, there would be a greater 

potential for more extensive and intense 

wildfires to occur in place of controlled 

burns on the 3 Bars Project area under this 

alternative compared to Alternative A. 

Because 3 Bars Project actions would 

affect only about 6,350 acres annually, or 

1 percent of the CESA, and treatment 

areas would be surveyed prior to treatment 

Cumulative Effects: Adverse, short-term 

effects to cultural resources associated 

with the use of fire and mechanized 

equipment would not occur under 

Alternative C. However, fire and 

mechanized equipment could be used on 

about 1,500 acres annually on other 

portions of the CESA and outside of 3 

Bars Project areas to improve habitat, 

remove hazardous fuels, and reduce the 

risk of wildfire, and could affect cultural 

resources in those areas. Because 3 Bars 

Project actions would affect only about 

3,200 acres annually (less than 0. 5 

percent of the CESA), and the BLM 

Cumulative Effects: There would be no 

cumulative effects on cultural resources 

from 3 Bars Project treatments as no 

treatments would be authorized under this 

alternative. The BLM could take actions 

under existing and future authorizations to 

benefit ecosystem health, as discussed 

above under Soil Resources, but only on 

about 1,500 acres annually. Thus, benefits 

to cultural resources would be less under 

this alternative than under the action 

alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-79 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

authorizations, the BLM would treat about 

142,000 acres within the CESA, totaling 

about 11 percent of the CESA. The BLM 

would conduct surveys prior to treatments 

to determine whether there are additional 

cultural sites on these areas which could 

be impacted by treatment actions. Existing 

and newly found sites would be mitigated 

in accordance with the 2012

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 3 Bars Ecosystem and 

Landscape Restoration Project, Eureka 

County, Nevada. The Agreement was 

signed on September 5, 2012. Long-term, 

the 3 Bars Project and other restoration 

treatments should result in a landscape 

that is more fire resilient and similar to the 

Potential Natural Community. These 

activities would help to reduce the 

potential for streambank erosion and 

catastrophic wildfire and potential loss of 

cultural materials. 

to avoid or reduce impacts to cultural 

sites, there would be a negligible 

cumulative effect to cultural resources 

from 3 Bars Project actions. 

would conduct pre-treatment surveys for 

cultural resources to reduce the potential 

for effects to eligible sites, effects to 

cultural resources within the CESA would 

be negligible. 

Mitigation: 1) Consult with local Tribes 

in accordance with Stipulation III (A) of 

the 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 

Mitigation: See Alternative A. Mitigation: See Alternative A. Mitigation: See Alternative A. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-80 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

Compliance for the 3Bars Ecosystem and 

Landscape Restoration Project, Eureka 

County, Nevada (Appendix B). 2) For 

each phase of the undertaking, the BLM 

shall evaluate cultural resources for

National Register of Historic Properties 

(NRHP) eligibility, and consult with local 

Tribes or tribal members regarding areas 

of cultural or traditional religious 

importance, and consult with the State 

Historic Preservation Office and local 

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 

historic properties, i.e., those resources 

determined eligible for inclusion in the 

NRHP, in accordance with Stipulation 

III(C) of the Programmatic Agreement. 4) 

Monitor treatment implementation 

according to the protocols outlined in 

Stipulation VII of the Programmatic 

Agreement, to insure that there are no 

inadvertent impacts to plant and wildlife 

of importance to traditional lifeways. 5) 

Human remains and burial items are 

sacred to the local Native American tribes. 

Therefore, the BLM shall provide training 

to all BLM and contract personnel to 

insure compliance with the 

Archaeological Resource Protection Act 

of 1979 (16 USC § 470), as amended, and 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-81 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

insure that the remains and associated 

grave goods are treated with respect and 

are handled according to the provisions. 

SUMMARY OF EFFECTS ON NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES

Direct and Indirect Effects: Treatment 

activities that remove vegetation or alter 

the distribution, health, and welfare of 

plants and animals used by Native peoples 

would have the greatest potential to harm 

natural resources with associated 

traditional values. Manual treatment is 

highly selective and would have less of an 

effect on plants with traditional lifeway 

values than other treatment methods. 

Concerns have been expressed by local 

tribes regarding traditional pine nut 

harvesting in general and the removal of 

pinyon pine. Some seed-bearing trees 

would be destroyed or removed by 

mechanical or hand treatments and fire, 

and prescribed and wildland fires would 

require the construction of fuel breaks, 

which could also compromise plant 

species of importance to Native American 

lifeways. Fire may top-kill some plants 

used by Native Americans, but fire has

been shown to enhance their long-term 

health and development. Treatments to 

enhance riparian vegetation and increase 

the number of miles of BLM-administered 

streams that are classified as “Proper 

Functioning,” would provide good habitat 

for fish that are harvested by Native 

Direct and Indirect Effects: Because the 

BLM would not be able to use fire, there 

would be none of the adverse or beneficial 

impacts associated with this treatment 

method. In particular, there would be no 

harm to or loss of native vegetation or fish 

and wildlife habitat from prescribed fire 

and wildland fire for resource benefit. 

There would also be no risk of a 

prescribed fire spreading beyond treatment 

boundaries and impacting native plants 

and fauna of interest to the Native 

American community, which could be the 

case under Alternative A. The few native 

plants and wildlife that are found in dense 

stands of pinyon-juniper may not 

experience habitat loss under this 

alternative. By not using fire, risks to nontarget vegetation, including plants used by 

local tribes, from treatments would be 

negligible. Long-term, however, native 

vegetation and fish and game species 

would experience fewer of the benefits 

associated both with creating openings in 

dense pinyon-juniper habitat and creating 

a mosaic of pinyon-juniper and sagebrush 

habitat. Because fire would not be 

available to reduce hazardous fuel loads, 

Alternative B may pose a greater longDirect and Indirect Effects: Most of the 

treatments under this alternative would be 

to thin and remove pinyon-juniper using 

chainsaws where it is encroaching into 

riparian, aspen, and sagebrush habitats. 

There would be fewer direct impacts to 

plants and animals used by Native 

Americans from treatments under this 

alternative than the other alternatives, 

because adverse impacts, such as harm to,

or death of, plants and wildlife, and noise 

and other disturbance, would be much less 

with manual methods than with the other 

methods. Manual treatments would be 

small in scale and mostly targeted to 

pinyon-juniper stands. Under Alternative 

C, riparian restoration treatments would 

primarily be limited to manual treatments 

(placing logs and rocks in streams to slow 

water flows; using temporary exclosure

fencing to exclude livestock, wild horses, 

and other wild ungulates; and stimulating 

aspen regeneration), which would help to 

create wet meadows and enhance riparian 

vegetation and fish and wildlife habitat. 

Under Alternative C, the BLM would not 

substantially improve the native 

vegetation community nor stop the loss of 

important ecosystem components, 

Direct and Indirect Effects: There would 

be no direct or indirect effects on Native 

American traditional/cultural values, 

practices, and resources from 3 Bars 

Project treatments as no treatments would 

be authorized under this alternative. Under 

Alternative D, the BLM would not 

improve the native vegetation community 

nor stop the loss of important ecosystem 

components, including native vegetation 

and fish and wildlife habitat. As a result, 

Native American traditional/cultural 

values, practices, and resources would not 

see benefits under this alternative. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-82 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

peoples. Because water is scarce on the 3 

Bars Project area, stream and riparian 

restoration projects would improve water 

availability for fish and wildlife. 

Improvements in habitat quality would 

increase the carrying capacity of the 

landscape and allow it to support larger 

and healthier wildlife populations. 

Treatments that remove hazardous fuels 

from public lands would be expected to 

benefit the health of plant and animal 

communities in which natural fire cycles 

have been altered, and to improve 

accessibility for tribal cultural practices. 

term risk for wildfire due to the 

accumulation of fuels. Under Alternative 

B, Native American traditional/cultural 

values, practices, and resources would 

benefit from treatments, but not to the 

extent that would occur under Alternative 

A. 

including native vegetation and fish and 

wildlife habitat. As a result, the health and 

abundance of Native American 

traditional/cultural resources would be 

expected to decline from current levels. 

Cumulative Effects: Historic livestock 

grazing practices, wild horse 

overpopulation, land uses, and wildfire 

have contributed to impacts to vegetation 

and loss of fish and wildlife used by 

Native Americans on Roberts Mountains

and elsewhere in the CESA. Of most 

interest to local tribes would be the 

removal of vegetation that is used by the

tribes for traditional purposes, and the 

harvest of fish and game on public lands 

within the CESA. Approximately 142,000 

acres could be treated on the 3 Bars 

Project area and elsewhere in the CESA (4 

percent of the CESA) under existing or 

reasonably foreseeable authorizations to 

reduce hazardous fuels and restore 

ecosystem health. Most of these 

treatments would occur within pinyonCumulative Effects: By not using fire to 

reduce hazardous fuels and improve 

vegetation resiliency to fire, there would 

be greater potential for more extensive and 

intense wildfires to occur in place of 

controlled burns on the 3 Bars Project area 

under this alternative compared to 

Alternative A. This could lead to loss of 

vegetation and fish and wildlife habitat of 

importance to local tribes. 3 Bars Project 

actions would only affect about 63,500 

acres, or 2 percent of the CESA. These 

effects would be less than for Alternative 

A, but greater than for Alternative C. 

Cumulative Effects: By not being able to 

use mechanical methods and fire to reduce 

hazardous fuels, improve vegetation 

resiliency to fire, create fire and fuel 

breaks, and remove downed wood and 

slash, the risk of wildfire and its impacts 

on Native American traditional/cultural 

values, practices, and resources would 

likely increase on the 3 Bars Project area, 

to the potential detriment of vegetation, 

and fish and wildlife and their habitats, 

within the CESA. About 3,200 acres 

would be treated annually in the 3 Bars 

Project area and another 1,500 acres

annually in other portions of the CESA to 

reduce hazardous fuels and to improve 

ecosystem health, or only about 1 percent 

of the CESA. There should be negligible 

cumulative effects to these resources from 

Cumulative Effects: There would be no 

cumulative effects on Native American 

traditional/cultural values, practices, and 

resources from 3 Bars Project treatments 

as no treatments would be authorized 

under this alternative. The BLM could 

take actions under existing and future 

authorizations to benefit ecosystem health, 

as discussed above under Soil Resources, 

but only on about 1,500 acres annually. 

Thus, benefits to Native American 

traditional/cultural values, practices, and 

resources would be negligible and least 

among the alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-83 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

juniper and sagebrush treatment areas, 

including on the Roberts Mountains and 

Sulphur Spring Range, areas with 

ethnographic significance to the Western 

Shoshone. Treatments would have shortterm effects on vegetation and wildlife 

habitat and displace game species. The 

BLM would consult with local tribes, and 

treatment areas would be surveyed prior to 

treatment, to avoid or reduce impacts to 

Native American traditional/cultural 

values, practices, and resources. Thus, 

there should be negligible cumulative 

effects to these resources from 3 Bars 

Project actions. Within a few years 

conditions within treatment areas should 

improve vegetation and fish and wildlife 

habitat. The beneficial effects of 

treatments would be greatest under 

Alternative A. 

3 Bars Project actions and effects would 

be less than under Alternatives A and B. 

Mitigation: See Mitigation under 

Summary of Effects on Cultural 

Resources. 

Mitigation: See Alternative A. Mitigation: See Alternative A. Mitigation: See Alternative A. 

SUMMARY OF EFFECTS ON SOCIAL AND ECONOMIC VALUES AND ENVIRONMENTAL JUSTICE

Direct and Indirect Effects: Because the 

3 Bars Project area is rural and largely 

undeveloped, potential adverse social 

effects related to restoration would be 

indirect and largely intangible, and would 

most likely affect general degrees of 

satisfaction or dissatisfaction of 

individuals, families, and various 

stakeholders. There could be short-term 

Direct and Indirect Effects: The cost per 

acre of treatment would be greater under 

Alternative B than under Alternative A. 

This reflects, in part, the higher 

expenditures associated with manual and 

mechanical treatments, which generally 

cost about 2 times or more to implement 

than do fire treatments. Such outlays could 

increase the annual level of expenditures 

Direct and Indirect Effects: The cost 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 

to implement than do fire and mechanical 

treatments. Due to the reduction in acres 

Direct and Indirect Effects: There would 

be no direct or indirect effects on social 

and economic values from 3 Bars Project 

treatments as no treatments would be 

authorized under this alternative. 

Treatments to improve 3 Bars ecosystem 

health, and increase or improve the 

amount and quality of commercial and 

casual uses of public lands, improve or 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-84 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

reductions in authorized grazing levels 

and subsequent loss or reduction of ranch 

income as a result of grazing restrictions 

and increases in the required amount of 

livestock management. The BLM would 

experience short-term, and possibly longterm, reductions in annual grazing fees as 

a result of reductions in the level of 

authorized grazing use during and 

following treatments. Social effects on 

ranchers, outfitters, individual 

recreationists, some business owners, and 

others would manifest themselves in terms 

of concerns for social and economic wellbeing, increased satisfaction or 

dissatisfaction with public lands 

management by the Mount Lewis Field 

Office, and quality of life in general. The 

project would generate a short-term 

temporary local economic stimulus 

associated with BLM and contractor 

efforts and jobs. Locally, these benefits 

would accrue primarily to residents and 

businesses in southern Eureka County. 

Pinyon-juniper trees with potential for use 

as fence posts or for firewood could be 

gathered up and offered for sale to the 

public, providing additional benefits to 

residents, local businesses, and 

landowners, including farmers and 

ranchers. Restoration treatments would 

reduce the risk of wildfire and improve 

ecosystem health. The reduction in 

and the associated short-term employment 

and income and business revenue benefits 

associated with landscape restoration. 

Grazing permittees would experience 

short-term reductions in income in 

conjunction with the proposed treatments, 

particularly with pinyon-juniper 

treatments. Temporary and long-term 

social effects under Alternative B would 

be similar to those for Alternative A, 

although some individuals and stakeholder 

groups would be more or less satisfied by 

the preclusion of use of fire as a treatment 

method. 

treated, the temporary reductions in 

grazing use associated with treatments 

would be lower, and the potential for other 

reductions due to declining rangeland 

health would persist. Over the long-term, 

treatments would do little to slow the 

declines in rangeland health and promote a 

stabilization of future grazing levels and 

support for rural lifestyles. Treatments 

would do little to improve habitat for fish 

and wildlife, conditions of woodlands to 

the benefit of pine nut production and 

other woodland products, and aesthetic 

qualities of the landscape for the 

recreational and commercial resource 

users. 

maintain market and non-market values of 

public land resources, and reduce the cost 

of operations on public lands, would not 

occur under this alternative. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-85 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

wildfire would benefit nearby private 

property owners and facilities constructed 

on public land, including facilities for 

mining and infrastructure, reducing the 

risk of property damage and interference 

with operations. 

Cumulative Effects: Agriculture, land 

development, and mineral, oil, gas, and 

hydrothermal exploration and 

development could affect lands within the 

CESA in the reasonably foreseeable 

future, including land sales, new 

croplands, roads, and rights-of-way for 

power and telephone lines. These actions 

would provide economic benefits to the 

local community, but would also result in 

loss of fish and wildlife habitat, and 

possibly recreational opportunities. The 

Mount Hope Project would directly 

disturb approximately 8,300 acres over the 

long-term and another 6,000 acres would 

be fenced to exclude the public and 

livestock. The proposed mine project 

would have economic costs and benefits. 

Economic costs would include the loss of 

32 AUMs in perpetuity due to 

construction of the mine pit. In addition, 

another 781 AUMs would be lost for 

approximately 70 years due to the mine 

project. Annual mine payroll is projected 

to be $33.4 million at full production, 

about half of which is projected to accrue 

to Eureka County residents. The increase 

Cumulative Effects: The BLM would 

conduct treatments on approximately 

63,000 acres on the 3 Bars Project area, 

and about another 15,000 acres on other 

portions of the CESA, or collectively 

about 4 percent of the CESA, to reduce 

hazardous fuels and improve fish and 

wildlife habitat. The types of risks and 

benefits to social and economic resources 

under Alternative B would be about half 

those for Alternative A within the CESA. 

3 Bars Project and other BLM actions 

within the CESA would have negligible 

effect on the social and economic 

conditions within the CESA. The growth 

in economic activity, and stakeholder 

perceptions and concerns regarding 

various issues related to rangeland health, 

including grazing use, and the allocation 

of forage for wildlife, wild horses, and 

grazing, would generally be less under 

Alternative B than under Alternative A. 

Cumulative Effects: The BLM would 

conduct treatments on approximately 

32,000 acres on the 3 Bars Project area, 

and on about 15,000 acres under existing 

and reasonably foreseeable future actions 

on other portions of the CESA, or 

collectively about 2 percent of the CESA, 

to reduce hazardous fuels and improve 

fish and wildlife habitat. The types of risks 

and benefits to social and economic 

resources under Alternative C would be 

about one-fourth those for Alternative A 

within the CESA. 3 Bars Project and other 

BLM actions within the CESA would 

have negligible effect on the social and 

economic conditions within the CESA. 

The growth in economic activity, and 

stakeholder perceptions and concerns 

regarding various issues related to 

rangeland health, including grazing use, 

the allocation of forage for wildlife, wild 

horses, and grazing, would generally be 

less under Alternative C than under 

Alternatives A and B. 

Cumulative Effects: There would be no 

cumulative effects on social and economic 

values from 3 Bars Project treatments as 

no treatments would be authorized under 

this alternative. The BLM could take 

actions under existing and future 

authorizations to benefit ecosystem health, 

as discussed above under Soil Resources, 

but only on about 1,500 acres annually. 

Thus, benefits to social and economic 

values would be negligible and least 

among the alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-86 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

in income would be equal to about 28 

percent of the income realized by local 

residents in 2008. 3 Bars Project and other 

BLM actions within the CESA would 

have little effect on the social and 

economic conditions within the CESA. 

The growth in economic activity, and 

stakeholder perceptions and concerns 

regarding various issues related to 

rangeland health, including grazing use, 

and the allocation of forage for wildlife, 

wild horses, and grazing, would generally 

be greatest under Alternative A. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 

SUMMARY OF EFFECTS ON HUMAN HEALTH AND SAFETY

Direct and Indirect Effects: The greatest 

health and safety risks associated with 

treatments would be to workers 

conducting the treatments, rather than to 

the public. These risks include injuries 

associated with use of heavy equipment, 

contact with sharp cutting blades, 

exposure to rocks and other flying debris, 

loss of control of equipment, high noise 

levels, vehicle exhaust, and smoke 

inhalation. Fires can affect public safety 

by reducing visibility and create 

hazardous driving conditions on nearby 

roads. Long-term, treatments would help 

reduce the risks to human health from 

wildfire smoke and fire. 

Direct and Indirect Effects: The human 

health and safety risks associated with 

exposure to smoke from prescribed fire 

would not be present under this 

alternative. The acreage of land treated 

using mechanical methods, and the 

associated level of risk to worker safety 

associated with this treatment method, 

would be similar or somewhat greater to 

that under Alternative A. The 

effectiveness of treatments at reducing 

catastrophic wildfire potential would 

likely be less than under Alternative A. 

While mechanical treatments can be used 

to remove fuels, in some instances a 

combination of treatments (mechanical 

plus fire) might produce better results. 

Therefore, wildfire risk reduction and 

Direct and Indirect Effects: Workers and

the public would not be at risk for 

exposure to smoke, or for accidents 

associated with operation of heavy 

equipment. Risks associated with manual 

methods and classical biological control 

would be minimal. Out of all the action 

alternatives, short-term health and safety 

risks associated with project treatments 

would be lowest under Alternative C. 

However the long-term health and safety 

benefits associated with reducing 

catastrophic wildfire risk would be lower

under Alternative C than under the other 

action alternatives because the least 

amount of hazardous fuel removal would 

occur. 

Direct and Indirect Effects: There would 

be no direct effects on human health and 

safety from 3 Bars Project treatments as 

no treatments would be authorized under 

this alternative. The BLM could take 

actions under existing and future 

authorizations to benefit ecosystem health, 

as discussed above under Soil Resources, 

but only on about 1,500 acres annually.

The BLM would not reduce the risk of 

large-scale wildfire that could be 

detrimental to human health and safety. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-87 October 2016

 ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

associated health and safety benefits 

would likely be less under this alternative 

than under Alternative A. 

Cumulative Effects: Agriculture, mining, 

land development, utilities construction 

and operation, and other land uses have 

associated occupational and public health 

and safety risks during the construction 

phase, and some would have associated 

risks during the operational phase. 

Members of the public who visit or drive 

through the 3 Bars Project area may also 

visit or drive through areas where other 

projects are occurring. Additionally, 

workers who implement the BLM’s 3 

Bars treatment projects may live in the 

vicinity of other projects, may visit or 

drive through areas where other projects 

are occurring, or may be hired to 

implement other projects that have been 

identified within the CESA. Therefore, it 

is likely that both workers and members of 

the public who would potentially be 

exposed to 3 Bars project treatments 

would also be exposed to human health 

and safety risks associated with other 

reasonably foreseeable future actions, 

resulting in cumulative health and safety 

risks. The BLM would treat about 142,000 

acres (127,000 on the 3 Bars Project area, 

and 15,000 on other areas within the 

CESA), or about 8 percent of the CESA, 

to restore natural fire regimes and 

Cumulative Effects: Because fire would 

not be used on the project area, risks 

associated with exposure to fire and 

smoke would not contribute to cumulative 

health effects. Hazardous fuels reduction 

and habitat improvement projects could 

occur on about 63,000 acres within the 3 

Bars Project area, and on up to 15,000 

acres within the CESA, or about 4 percent 

of acreage within the CESA. The 

cumulative risks to workers from these 

treatments could be greater from manual 

and mechanical methods than from fire 

treatments. Over the long-term, 

cumulative effects to health and safety 

associated with wildfire would be greater 

than under Alternative A, since the 

acreage treated for fuels reduction would 

be less and treatments would likely not be 

as effective. 

Cumulative Effects: Adverse, short-term 

effects to human health and safety with 

the use of fire and mechanized equipment 

would not occur under Alternative C. 

About 47,000 acres would be treated in 

the CESA to reduce hazardous fuels, of 

which about 32,000 acres would be treated 

on the 3 Bars Project area. This would be 

less than 2 percent of the land within the 

CESA and within the 3 Bars Project area. 

Under Alternative C, the acreage treated 

would be less than under Alternatives A

and B, and only manual and classical 

biological would be used. Therefore, 

short-term cumulative health and safety 

risks would likely be lower under 

Alternative C than under the other action 

alternatives. Over the long-term, 

cumulative effects to human health and 

safety associated with wildfire would be 

greater than under the other action 

alternatives, as the least amount of 

hazardous fuel removal would occur under 

Alternative C. 

Cumulative Effects: There would be no 

cumulative effects on human health and 

safety from 3 Bars Project treatments as 

no treatments would be authorized under 

this alternative. Thus, benefits to human 

health and safety would be negligible and 

least among the alternatives. 
TABLE 2-2 (Cont.) 

Summary and Comparison of Effects on Resources by Alternative

3 Bars Project Final EIS 2-88 October 2016

ALTERNATIVES

Alternative A (Preferred 

Alternative/All Available Methods)

Alternative B

(No Fire Use)

Alternative C 

(Minimal Land Disturbance)

Alternative D 

(No Action Alternative)

encourage the growth of native vegetation 

that is more resilient to wildfire, reducing 

the risk of wildfire. If plant community 

structure, species composition, and 

disturbance regimes return to near 

historical ranges, then disturbances should 

have effects that would be less severe, and 

result in less wildfire danger and risks to 

the public, than at present. 

Mitigation: None. Mitigation: None. Mitigation: None. Mitigation: None. 
3 Bars Project Final EIS 3-i October 2016

 CHAPTER 3 

AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES 
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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE OF CONTENTS 

Page 

3.1 Introduction .....................................................................................................................................................3-1

3.2 Summary of Major Changes between the Draft and Final EIS .....................................................................3-1

3.3 How the Effects of the Alternatives Were Evaluated ....................................................................................3-4

3.3.1 Direct and Indirect Effects .................................................................................................................3-4

3.3.2 Cumulative Effects .............................................................................................................................3-5

3.3.3 Unavoidable Adverse Commitments .............................................................................................. 3-20

3.3.4 Irreversible and Irretrievable Commitments ................................................................................... 3-21

3.3.5 Resource Protection Measures Considered in the Effects Analysis ............................................... 3-21

3.3.6 Incomplete and Unavailable Information ....................................................................................... 3-21

3.4 General Setting............................................................................................................................................. 3-22

3.4.1 Project Area ..................................................................................................................................... 3-22

3.4.2 Ecoregions ....................................................................................................................................... 3-22

3.5 Meteorology and Climate Change ............................................................................................................... 3-27

3.5.1 Regulatory Framework .................................................................................................................... 3-27

3.5.2 Affected Environment ..................................................................................................................... 3-27

3.5.3 Environmental Consequences ......................................................................................................... 3-31

3.6 Air Quality ................................................................................................................................................... 3-33

3.6.1 Regulatory Framework .................................................................................................................... 3-33

3.6.2 Affected Environment ..................................................................................................................... 3-37

3.6.3 Environmental Consequences ......................................................................................................... 3-38

3.6.4 Mitigation ........................................................................................................................................ 3-48

3.7 Geology and Minerals ................................................................................................................................ 3-49

3.7.1 Regulatory Framework .................................................................................................................... 3-49

3.7.2 Affected Environment ..................................................................................................................... 3-50

3.7.3 Environmental Consequences ......................................................................................................... 3-55

3.7.4 Mitigation ....................................................................................................................................... 3-58

3.8 Paleontological Resources .......................................................................................................................... 3-58

3.8.1 Regulatory Framework .................................................................................................................... 3-58

3.8.2 Affected Environment ..................................................................................................................... 3-60

3.8.3 Environmental Consequences ......................................................................................................... 3-60

3.8.4 Mitigation ....................................................................................................................................... 3-65

3.9 Soil Resources .............................................................................................................................................. 3-65

3.9.1 Regulatory Framework .................................................................................................................... 3-65

3.9.2 Affected Environment ..................................................................................................................... 3-65

3.9.3 Environmental Consequences ......................................................................................................... 3-81

3.9.4 Mitigation ........................................................................................................................................ 3-94

3.10 Water Resources ......................................................................................................................................... 3-94

3.10.1 Regulatory Framework .................................................................................................................... 3-94

3.10.2 Affected Environment ..................................................................................................................... 3-95

3.10.3 Environmental Consequences ....................................................................................................... 3-112

3.10.4 Mitigation ...................................................................................................................................... 3-129

3 Bars Project Final EIS 3-iii October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-iv October 2016

3.11 Wetlands, Floodplains, and Riparian Zones.............................................................................................. 3-129

3.11.1 Regulatory Framework .................................................................................................................. 3-129

3.11.2 Affected Environment ................................................................................................................... 3-131

3.11.3 Environmental Consequences ....................................................................................................... 3-133

3.11.4 Mitigation ...................................................................................................................................... 3-146

3.12 Native and Non-invasive Vegetation Resources ...................................................................................... 3-147

3.12.1 Regulatory Framework .................................................................................................................. 3-147

3.12.2 Affected Environment ................................................................................................................... 3-148

3.12.3 Environmental Consequences ....................................................................................................... 3-206

3.12.4 Mitigation ...................................................................................................................................... 3-224

3.13 Noxious Weeds and other Invasive Non-native Vegetation ..................................................................... 3-224

3.13.1 Regulatory Framework .................................................................................................................. 3-224

3.13.2 Affected Environment ................................................................................................................... 3-226

3.13.3 Environmental Consequences ....................................................................................................... 3-228

3.13.4 Mitigation ...................................................................................................................................... 3-238

3.14 Wildland Fire and Fire Management......................................................................................................... 3-238

3.14.1 Regulatory Framework .................................................................................................................. 3-239

3.14.2 Affected Environment ................................................................................................................... 3-241

3.14.3 Environmental Consequences ....................................................................................................... 3-252

3.14.4 Mitigation ....................................................................................................................................... 3-262

3.15 Fish and Other Aquatic Resources ........................................................................................................... 3-262

3.15.1 Regulatory Framework .................................................................................................................. 3-262

3.15.2 Affected Environment ................................................................................................................... 3-263

3.15.3 Environmental Consequences ....................................................................................................... 3-270

3.15.4 Mitigation ....................................................................................................................................... 3-284

3.16 Wildlife Resources ..................................................................................................................................... 3-285

3.16.1 Regulatory Framework .................................................................................................................. 3-285

3.16.2 Affected Environment ................................................................................................................... 3-287

3.16.3 Environmental Consequences ....................................................................................................... 3-308

3.16.4 Mitigation ....................................................................................................................................... 3-327

3.17 Wild Horses ................................................................................................................................................ 3-327

3.17.1 Regulatory Framework .................................................................................................................. 3-327

3.17.2 Affected Environment ................................................................................................................... 3-327

3.17.3 Environmental Consequences ....................................................................................................... 3-334

3.17.4 Mitigation ....................................................................................................................................... 3-345

3.18 Livestock Grazing ...................................................................................................................................... 3-345

3.18.1 Regulatory Framework .................................................................................................................. 3-345

3.18.2 Affected Environment ................................................................................................................... 3-346

3.18.3 Environmental Consequences ....................................................................................................... 3-352

3.18.4 Mitigation ....................................................................................................................................... 3-364

3.19 Visual Resources ........................................................................................................................................ 3-366

3.19.1 Regulatory Framework .................................................................................................................. 3-366

3.19.2 Affected Environment ................................................................................................................... 3-366

3.19.3 Environmental Consequences....................................................................................................... 3-373
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-v October 2016

3.19.4 Mitigation ..................................................................................................................................... 3-388

3.20 Land Use and Access ................................................................................................................................. 3-388

3.20.1 Regulatory Framework .................................................................................................................. 3-388

3.20.2 Affected Environment ................................................................................................................... 3-389

3.20.3 Environmental Consequences ....................................................................................................... 3-403

3.20.4 Mitigation ..................................................................................................................................... 3-407

3.21 Recreation .................................................................................................................................................. 3-407

3.21.1 Regulatory Framework .................................................................................................................. 3-407

3.21.2 Affected Environment ................................................................................................................... 3-408

3.21.3 Environmental Consequences ....................................................................................................... 3-412

3.21.4 Mitigation ...................................................................................................................................... 3-422

3.22 Wilderness Study Areas, Special Management Areas, and Lands with Wilderness Character .............. 3-423

3.22.1 Regulatory Framework .................................................................................................................. 3-423

3.22.2 Affected Environment ................................................................................................................... 3-424

3.22.3 Environmental Consequences ....................................................................................................... 3-426

3.22.4 Mitigation ...................................................................................................................................... 3-433

3.23 Cultural Resources ..................................................................................................................................... 3-433

3.23.1 Regulatory Framework .................................................................................................................. 3-433

3.23.2 Affected Environment ................................................................................................................... 3-433

3.23.3 Environmental Consequences ....................................................................................................... 3-447

3.23.4 Mitigation ...................................................................................................................................... 3-457

3.24 Native American Traditional/Cultural Values, Practices, and Resources ................................................ 3-457

3.24.1 Regulatory Framework .................................................................................................................. 3-457

3.24.2 Affected Environment ................................................................................................................... 3-459

3.24.3 Environmental Consequences ....................................................................................................... 3-465

3.24.4 Mitigation ..................................................................................................................................... 3-478

3.25 Social and Economic Values and Environmental Justice ........................................................................ 3-478

3.25.1 Regulatory Framework .................................................................................................................. 3-478

3.25.2 Affected Environment ................................................................................................................... 3-478

3.25.3 Environmental Consequences ....................................................................................................... 3-492

3.25.4 Mitigation ...................................................................................................................................... 3-502

3.26 Human Health and Safety .......................................................................................................................... 3-502

3.26.1 Regulatory Framework .................................................................................................................. 3-502

3.26.2 Affected Environment ................................................................................................................... 3-503

3.26.3 Environmental Consequences ....................................................................................................... 3-507

3.26.4 Mitigation ...................................................................................................................................... 3-516

 

`
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-vi October 2016

List of Tables 

3-1 Elements Associated with Supplemental Authorities and Rationale for Detailed Analysis for the Proposed 

Action and other Alternatives ............................................................................................................................ 3-2 

3-2 Resources or Uses other than the Elements Associated with Supplemental Authorities and Rationale for 

Detailed Analysis for the Proposed Action and other Alternatives .................................................................. 3-3 

3-3 Monthly Climate Summary for Eureka, Nevada (1888 through 2012). ........................................................ 3-29

3-4 National and Nevada Ambient Air Quality Standards ................................................................................... 3-34

3-5 State and National Ambient Air Quality Standards Compliance Analysis for Manual Treatments ............. 3-41

3-6 State and National Ambient Air Quality Standards Compliance Analysis for Mechanical Treatments....... 3-42

3-7 State and National Ambient Air Quality Standards Compliance Analysis for Prescribed Fire Treatments . 3-42

3-8 State and National Ambient Air Quality Standards Compliance Analysis for Biological Treatments ......... 3-44

3-9 Potential Fossil Yield Classification ............................................................................................................... 3-59

3-10 Project Area Soil Limitations .......................................................................................................................... 3-69

3-11 Project Area Topsoil Organic Matter Content ................................................................................................ 3-76

3-12 Soil Textures in the Project Area .................................................................................................................... 3-76

3-13 Soil Suitabilities for Vegetation Treatment ................................................................................................... 3-78

3-14 Nevada Hydrographic Areas included in the Water Resources Assessment ................................................. 3-96

3-15 Perennial and Intermittent/Ephemeral Streams in the Project Area ............................................................. 3-100 

3-16 Flow Summary from U.S. Geological Survey Monitoring Stations ............................................................ 3-102

3-17 Site-specific Stream Investigations ............................................................................................................... 3-102 

3-18 Flow Measurements at Springs ..................................................................................................................... 3-107

3-19 2009 Estimated Annual Groundwater Budget for Individual Basins ........................................................... 3-110 

3-20 Percent of Watershed Basin within Treatment Areas ................................................................................... 3-118

3-21 Perennial Stream Miles within Treatment Areas .......................................................................................... 3-118

3-22 Current and Expected Vegetation Types within the 3 Bars Project Area .................................................... 3-150

3-23 Ecological Sites for Grassland Community .................................................................................................. 3-155

3-24 Ecological Sites for Big Sagebrush Community .......................................................................................... 3-156
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-vii October 2016

3-25 Ecological Sites for Low Sagebrush Community......................................................................................... 3-161

3-26 Ecological Sites for Black Sagebrush Community....................................................................................... 3-162

3-27 Ecological Sites for Greasewood Community .............................................................................................. 3-164

3-28 Ecological Sites for Salt Desert Scrub Community ...................................................................................... 3-165

3-29 Ecological Sites for Mountain Mahogany .................................................................................................... 3-167

3-30 Ecological Sites for Pinyon-juniper Community .......................................................................................... 3-169

3-31 Pinyon-juniper Classification Schemes ........................................................................................................ 3-179

3-32 Flynn/Parman Allotment KMAs ................................................................................................................... 3-184

3-33 Roberts Mountain Allotment KMAs ............................................................................................................ 3-186

3-34 JD Allotment KMAs ..................................................................................................................................... 3-190

3-35 Three Bars Allotment KMAs ........................................................................................................................ 3-194

3-36 Romano Allotment KMAs ............................................................................................................................ 3-199

3-37 Lucky C Allotment KMAs ............................................................................................................................ 3-201

3-38 Special Status Plant Species That may Occur in the 3 Bars Project Area ................................................... 3-203

3-39 Noxious Weeds in the 3 Bars Project Area................................................................................................... 3-228

3-40 Fire History on the 3 Bars Project Area ........................................................................................................ 3-246

3-41 Fire Regime Descriptions (Historical Fire Regimes) ................................................................................... 3-246

3-42 Fire Regime Condition Class Descriptions ................................................................................................... 3-247

3-43 Habitat Characteristics of Birch, Pete Hanson, and Willow Creeks ............................................................ 3-264

3-44 Summary of Lahontan Cutthroat Trout Surveys in Birch, Pete Hanson, and Willow Creeks .................... 3-268

3-45 Special Status Species Known or with Potential to Occur in the 3 Bars Project Area ................................ 3-297

3-46 Herd Management Areas ............................................................................................................................... 3-330

3-47 Allotments within Herd Management Areas ................................................................................................ 3-333 

3-48 Surface Disturbance by HMA for Management Types ................................................................................ 3-336 

3-49 Grazing Allotments within the 3 Bars Ecosystem ........................................................................................ 3-348 

3-50 Allotment Grazing Management System and Category ............................................................................... 3-348
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-viii October 2016

3-51 Rangeland Improvements by Allotment ....................................................................................................... 3-350

3-52 Acreage Affected by Treatment Types for each Allotment under Alternative A ........................................ 3-355 

3-53 Visual Resource Project Area Inventory and Visual Resource Management Classes Summary ............... 3-372 

3-54 Landscape Scenery Impacts .......................................................................................................................... 3-376

3-55 Distance Zones and Project Visibility ........................................................................................................... 3-376

3-56 Impacts to Viewers ........................................................................................................................................ 3-376

3-57 Visual Resource Project Area Inventory and Visual Resource Management Classes for Cumulative Effects 

Analysis.......................................................................................................................................................... 3-384

3-58 Land Ownership within the Project Area and Eureka County ..................................................................... 3-391

3-59 Existing Land Use Authorizations in the Project Area ................................................................................. 3-391

3-60 2011 Harvest by Hunt Unit and Group ......................................................................................................... 3-411

3-61 Annual Average Fishing Use in the Study Area (1980-2010) ..................................................................... 3-411

3-62 Summary of Documented Resources ............................................................................................................ 3-443

3-63 Summary of Document Prehistoric Cultural Sites ........................................................................................ 3-444

3-64 Summary of Documented Historic-era Cultural Sites .................................................................................. 3-445

3-65 Minority Population and the Incidence of Poverty in Eureka County, 2010 ............................................... 3-480

3-66 Eureka County Population, Selected Years, 2000-2011............................................................................... 3-481

3-67 Eureka County Labor Force, Unemployed, and Unemployment Rate, Selected Years .............................. 3-482

3-68 Eureka County Personal Income by Place of Residence, Selected Years.................................................... 3-483

3-69 Per Capital Personal Income, Eureka County, Nevada, and the United States............................................ 3-483

3-70 Farm Income and Expenses, Eureka County, 2007-2010 ............................................................................ 3-487

3-71 Eureka County Budget Summary, Fiscal Years 2007-2011......................................................................... 3-490

3-72 Eureka County, Assessed Value, Fiscal Years 2005/2006 through 2010/2011 ........................................... 3-490

3-73 Estimated Treatment Costs per Acre............................................................................................................. 3-496

3-74 Leading Causes of Death in Nevada and Eureka County, 2000 to 2008 ..................................................... 3-504

4-1 List of Preparers of the 3 Bars EIS .................................................................................................................... 4-5 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-ix October 2016

List of Figures 

3-1 Cumulative Effects Study Areas ........................................................................................................................3-7 

3-2 Cumulative Impacts from Grazing, Agriculture, and Forest Product Activities ........................................... 3-10

3-3 Cumulative Impacts from Wildland Fires, Fuels Management, and Reseeding ........................................... 3-14

3-4 Cumulative Impacts from Recreation and Wilderness ................................................................................... 3-15

3-5 Cumulative Impacts from Utilities and Infrastructure .................................................................................... 3-17

3-6 Cumulative Impacts from Mining Operations and Oil and Gas Production .................................................. 3-19

3-7 Study Area ....................................................................................................................................................... 3-23

3-8 Ecoregions for the 3 Bars Project Area ........................................................................................................... 3-25

3-9 Geologic Formations ....................................................................................................................................... 3-51

3-10 Mineral Resources ........................................................................................................................................... 3-53

3-11 Oil and Gas Resources .................................................................................................................................... 3-54

3-12 Soil Orders....................................................................................................................................................... 3-67

3-13 Compaction Prone Soils .................................................................................................................................. 3-68

3-14 Soil Erosion Potential from Water .................................................................................................................. 3-70

3-15 Soil Erosion Potential from Wind ................................................................................................................... 3-71

3-16 Organic Matter within Surface Soils ............................................................................................................... 3-72

3-17 Soil Surface Texture ........................................................................................................................................ 3-73

3-18 Soils with Low Revegetation Potential ........................................................................................................... 3-75

3-19 Fire Damage Susceptibility ............................................................................................................................. 3-77

3-20 Mechanical Treatment Suitability (Shredder) ................................................................................................ 3-79

3-21 Site Degradation Susceptibility ....................................................................................................................... 3-80

3-22 Streams, Lakes, Ponds, and Wetlands ............................................................................................................ 3-99

3-23 Water Developments and Water Uses .......................................................................................................... 3-106

3-24 Deteriorating Riverine/Wetland Plant Communities .................................................................................... 3-134
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-x October 2016

3-25 Current Vegetation Communities ................................................................................................................. 3-151

3-26 Major Vegetation Communities in the 3 Bars Project Area based on Ecological Site Data ....................... 3-152 

3-27 Pinyon-juniper Phase Classes ........................................................................................................................ 3-180

3-28 Current Rangeland Conditions ...................................................................................................................... 3-181

3-29 Range Allotments and Key Management Areas ........................................................................................... 3-183

3-30 Forest Products (Private Fuelwood, Pine Nuts, Christmas Trees, and Seed Harvest) ................................. 3-205

3-31 Prime Farmlands ............................................................................................................................................ 3-209

3-32 Cheatgrass and other Weeds.......................................................................................................................... 3-229

3-33 Fire History and Occurrence ......................................................................................................................... 3-242

3-34 Natural Fire Regimes ..................................................................................................................................... 3-243

3-35 Current Fire Regime Condition Class ........................................................................................................... 3-244

3-36 Current Risk of Catastrophic Fire and Threat to Resource Values .............................................................. 3-245

3-37 Snail Observations ......................................................................................................................................... 3-266

3-38 Lahontan Cutthroat Trout Habitat ................................................................................................................. 3-269

3-39 Mule Deer Habitat ......................................................................................................................................... 3-294 

3-40 Areas with Degraded Habitat Conditions ..................................................................................................... 3-295 

3-41 Pronghorn Habitat .......................................................................................................................................... 3-296 

3-42 Greater Sage-grouse Habitat ......................................................................................................................... 3-301 

3-43 Wild Horse Management Areas and Habitat Improvement Areas ............................................................... 3-329 

3-44 Areas of Moderate to Severe Use and Treatment Areas .............................................................................. 3-347

3-45 Visual Resource Inventory Scenic Quality Rating ....................................................................................... 3-368

3-46 Visual Resource Inventory Sensitivity Level Rating .................................................................................... 3-369 

3-47 Visual Resource Inventory Visual Distance Zone ........................................................................................ 3-370

3-48 Visual Resource Inventory Class .................................................................................................................. 3-371 

3-49 Visual Resource Management Class ............................................................................................................. 3-374 

3-50 Land Ownership and Land-use Authorizations ............................................................................................ 3-390
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-xi October 2016

3-51 Cultural Resource Inventories ....................................................................................................................... 3-410

3-52 Eureka County Alfalfa Production 1995-2011............................................................................................. 3-486

3-53 Eureka County Livestock Product 1995-2011.............................................................................................. 3-486
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-xii October 2016

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-1 October 2016

CHAPTER 3 

AFFECTED ENVIRONMENT AND 

ENVIRONMENTAL CONSEQUENCES 

3.1 Introduction 

This chapter describes the natural, cultural, and social environment of public lands in the 3 Bars Project area that 

would be affected by the alternatives under consideration. These descriptions are followed by an examination of how 

vegetation treatment and other activities may affect these natural, cultural, and social resources. The focus of the 

analysis is on the alternative proposals for treating public lands within the 3 Bars ecosystem. The analysis is useful in 

understanding the consequences of the proposed action and alternatives. 

Supplemental authorities that are subject to requirements specified by statute or executive order must be considered in 

all BLM environmental documents. The 17 elements associated with the supplemental authorities listed in the BLM 

Instruction Memorandum NV-2009-030 (USDOI BLM 2009c) are listed in Table 3-1. The table lists the elements 

and their status in the project area as well as the rationale used to determine whether an element present in the project 

area would be affected by the proposed action or any of the alternatives. Supplemental authorities that may be 

affected by the proposed action or any of the alternatives are discussed in this chapter under each element. Those 

elements listed under the supplemental authorities that do not occur in the project area and would not be affected are 

not discussed further in this EIS. The elimination of non-relevant issues follows CEQ policy, as stated at 40 CFR § 

1500.4.

In addition to the elements listed under supplemental authorities, the BLM considers other resources and uses that 

occur on public lands and the effects on these resources and uses that may result from the implementation of the 

proposed action or any of the alternatives. Other resources or uses of the human environment that have been 

considered for this EIS are listed in Table 3-2. 

3.2 Summary of Major Changes between the Draft and Final 

EIS

Several major changes were 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. These changes (and Section where change was made) are as follows: 

1. Text revised throughout Chapter 3 to reflect changes to the restoration treatments and methods that were 

identified in Section 2.2. 

2. Added a discussion of the need to reduce effects of livestock, wild horses, and other wild ungulates on 

vegetation in response to greater stress being placed upon vegetation due to climate change (Section 3.5.2.2). 

3. Added a discussion of the role of using prescribed fire to reduce forest carbon emissions and improve longterm carbon sequestration (Section 3.5.3.2.2). 
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-2 October 2016

TABLE 3-1 

Elements Associated with Supplemental Authorities and Rationale 

for Detailed Analysis for the Proposed Action and other Alternatives 

Supplemental Authority Element 

(Authority) Not Present Present/Not 

Affected

Present/May be 

Affected Reference Section

Air Quality  3.6

Areas of Critical Environmental 

Concern  3.22

Cultural Resources  3.23

Environmental Justice  3.25

Farm Lands (Prime and Unique)  3.12

Fish Habitat  3.15

Floodplains  3.11

Forests and Rangelands (Healthy 

Forest Restoration Act only)  3.12

Human Health and Safety  3.26

Migratory Birds  3.16

Native American Religious Concerns  3.24

Threatened or Endangered Species  3.12, 3.15, 3.16

Wastes (Hazardous and Solid) 

Water Quality  3.10

Wetlands and Riparian Zones  3.11

Wild and Scenic Rivers 

Wilderness 

Lands with Wilderness Character 

4. Added a discussion of the effects of dioxins on human health and the amount of dioxins produced by 

prescribed fire, wildland fire for resource benefit, and wildfire (Section 3.6.3.3.1). 

5. Additional discussion of biological soil crusts, their functions, and their use as indicators of ecological health 

(Section 3.9.2.2.8). 

6. The BLM has decided not to use chaining on the 3 Bars Project area based on comments from the public on 

the Draft EIS. Removed discussion of chaining and chaining susceptibility in Soil Resources section (Section 

3.9.2.3.3) and effects of chaining throughout the document. 

7. Added list of key issues of concern for soil resources that were considered during evaluation of the 

Environmental Consequences (Section 3.9.3.1). 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-3 October 2016

TABLE 3-2 

Resources or Uses other than the Elements Associated with Supplemental Authorities 

and Rationale for Detailed Analysis for the Proposed Action and Other Alternatives 

Resources or Uses Present/Not 

Affected

Present/May be 

Affected Reference Section

Forest/Woodland Products  3.12

Geology and Minerals  3.7

Historic Trails  3, 21, 3.22, 3.23

Land Use and Access  3.20

Noxious Weeds and other 

Invasive Non-native 

Vegetation

 3.13

Paleontology  3.8

Recreation  3.21

Socioeconomic Values  3.25

Soil Resources  3.9

Transportation 

Vegetation  3.12, 3.13

Visual Resources  3.19

Water Resources  3.10

Wilderness Study Areas  3.22

Wild Horses  3.17

Wildlife  3.16

8. Added a discussion of the effects of mechanical treatments on biological soil crusts in treatment areas 

(Section 3.9.3.3.2). 

9. Included information on pinyon-juniper fire cycles and factors that may have contributed to the expansion 

and contraction of pinyon-juniper stands, including climate, livestock grazing, fire prevention, and 

woodcutting (Section 3.12.2.2.9). 

10. Provided additional information on the history of woodcutting in the 3 Bars Project area (Section 3.12.2.6), 

11. The BLM would only seed with native plant species, except as follows: Non-native seedings may be used 1) 

to create fuel breaks, 2) in areas that have previously burned and are beyond use of Emergency Stabilization 

and Rehabilitation techniques, 3) to create green strips; and 4) for soil stabilization in low precipitation zones. 

(Section 3.12.3.3). 

12. Provided additional information on natural fire regimes and fire risk (Section 3.14.2.3). 

13. Provided updated information on the status of cheatgrass infestations resulting from the Red Hills hazardous 

fuels reduction project (Section 3.14.3.3.2). 
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-4 October 2016

14. The BLM would not conduct sagebrush thinning or other sagebrush control projects on sagebrush treatment 

areas, or on Greater sage-grouse breeding and winter habitats. References to thinning and burning of 

sagebrush to control sagebrush have been deleted in the Final EIS. (Section 3.16.3.3). 

15. Corrected statement in Section 3.21.3.3.1 to note that the Pony Express National Historic Trail is a 

recreational resource of national significance. 

16. No fire treatments would be conducted in Wilderness Study Areas (Section 3.22.3.3.3).

3.3 How the Effects of the Alternatives Were Evaluated 

Within each resource area, applicable direct and indirect effects of treatments are evaluated. Cumulative effects, 

unavoidable adverse commitments, and resource commitments that are lost or cannot be reversed are also evaluated 

for all treatment activities in the EIS. These effects are defined as follows: 

 Direct effects – Those effects that are caused by the action and occur at the same time and in the same 

general location as the action. 

 Indirect effects – Those effects that occur at a different time or in a different location than the action to which 

the effects are related. 

 Cumulative effects – Those effects on the environment that result from the incremental impact of the action 

when added to the other past, present, and reasonably foreseeable future actions regardless of what agency 

(federal or non-federal) or person undertakes such other actions. Cumulative effects can result from 

individually minor but collectively significant actions taking place over a period of time. 

 Unavoidable adverse commitments – Those effects that could occur as a result of implementing any of the 

action alternatives. Some of these effects would be short-term, while others would be long-term. 

 Irreversible commitments – Those commitments that cannot be reversed, except perhaps in the extreme longterm. This term applies primarily to the effects of use of nonrenewable resources, such as minerals or cultural 

resources, or to factors, such as soil productivity, that are renewable only over long periods of time. 

 Irretrievable commitments – Those commitments that are lost for a period of time. For example, timber 

production is lost while an area is mined. The production lost is irretrievable, but the action is not 

irreversible. If the site is reclaimed, it is possible to resume timber production. 

This chapter should be read together with Chapter 1 (Proposed Action and Purpose and Need), which explains why 

the BLM is proposing to conduct treatments, and Chapter 2 (Alternatives), which explains the alternative proposals 

the BLM is considering to restore the health and functionality of the 3 Bars ecosystem. The analyses of the affected 

environment and environmental consequences in this chapter build upon and relate to information presented in these 

earlier chapters to describe which resources may be impacted and how and where impacts might occur. 

3.3.1 Direct and Indirect Effects 

To the extent practicable, existing environmental analyses were used in analyzing impacts associated with the 

proposed action and alternatives. Within each resource area, applicable direct and indirect effects are evaluated. Key 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-5 October 2016

factors considered in the analysis include treatment methods and their risks, acreage treated, effectiveness of SOPs, 

and mitigation measures. 

This EIS focuses on treatments that the Mount Lewis Field Office proposes to conduct during the life of the project. 

For analysis purposes, however, it was assumed that projects would occur within a 10 to 15 year period. It is expected 

that similar types of treatments would occur after this period that would still be covered by the analysis in this EIS. 

The analysis in this EIS builds upon analyses in earlier EISs, Environmental Assessments, and environmental reports, 

including the 17-States PEIS and PER, Mount Hope Project Final Environmental Impact Statement (Mount Hope 

Project EIS), and AECC (USDOI BLM 2007b, c, 2009a, 2012b). 

Information from the 17-States PER was used to assess the effects on the environment from 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 (USDOI BLM 2007c). Risk is defined as the 

likelihood that an effect (injury, disease, death, or environmental damage) may result from a specific set of 

circumstances (USDOI BLM 2007b). 

3.3.2 Cumulative Effects 

The NEPA and its implementing guidelines require an assessment of the proposed project and other projects that have 

occurred in the past, are occurring in the present, or are likely to occur in the future, which together may have 

cumulative impacts that go beyond the impacts of the proposed project itself. According to 40 CFR §§1508.7 and 

1508.25[a][2]) (CEQ 2012): 

“Cumulative impact is the impact on the environment which results from the incremental impact of 

the action when added to the other past, present, and reasonably foreseeable future actions regardless 

of what agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts 

can result from individually minor but collectively significant actions taking place over a period of 

time. In addition, to determine the scope of Environmental Impact Statements, agencies shall 

consider cumulative actions, which when viewed with other proposed actions have cumulatively 

significant impacts and should therefore be discussed in the same impact statement.”

The purpose of the cumulative effects analysis is to determine if the effects of BLM vegetation treatments have the 

potential to interact or accumulate over time and space, either through repetition or when combined with other effects, 

and under what circumstances and to what degree they might accumulate.

3.3.2.1 Structure of the Cumulative Effects Analysis 

For this EIS, the analysis of cumulative impacts is a four-step process that follows guidance provided in Considering 

Cumulative Effects under the National Environmental Policy Act (CEQ 1997): 

 Specify the class of actions for which effects are to be analyzed. 

 Designate the appropriate time and space domain in which the relevant actions occur. 

 Identify and characterize the set of receptors to be assessed. 

 Determine the magnitude of effects on the receptors and whether those effects are accumulating. 
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-6 October 2016

3.3.2.2 Class of Actions to be Analyzed 

This analysis addresses site-specific and local-scale trends and issues that require integrated management across 

landscapes. It also addresses trends and changes in the social and economic needs of people. Restoration treatment 

methods used by the BLM are considered in the analysis. These include manual, mechanical, and biological control 

methods, and the use of fire, as identified in Chapter 2 (Alternatives). 

For this EIS, potential cumulative effects include those that were assessed for all land ownerships, including lands 

administered by other federal agencies and non-federal lands, particularly effects to air quality, aquatic and terrestrial 

species, and subsistence resources. The analysis and disclosure of cumulative effects alerts decision-makers and the 

public to the context within which effects are occurring, and to the environmental implications of the interactions of 

known and likely management activities. 

3.3.2.3 Appropriate Temporal and Spatial Domain 

3.3.2.3.1 Temporal Domain 

The analysis period covered by the cumulative effects analysis begins in 2015 and continues through 2040. The 

timeline outlined in this EIS (about 10 to 15 years) is based on when treatments would occur, and the time needed to 

realize the results of the treatments in terms of meeting management objectives and desired vegetative conditions 

(about 10 years). The timeline is also based on the difficulty of predicting advances in technology, approved treatment 

practices, and the types and amounts of vegetation treatments needed, very far into the future. Thus, a reasonable 

analysis period, and one on which most of the cumulative effects analysis is focused, is 25 years into the future. In 

accordance with CEQ guidance on June 24, 2005 (CEQ 2005), past actions associated with the 3 Bars ecosystem are 

addressed through their current aggregate effects and have not been provided as a list of individual projects. A brief 

discussion of past and present actions in the vicinity of the 3 Bars Project area is provided in Section 3.3.2.3.3; a more 

detailed discussion can be found in Section 4.3 of the Mount Hope Project EIS (USDOI BLM 2012b).

3.3.2.3.2 Spatial Domain 

For some resources and uses, the project area may be where the effect can be felt (known as the “footprint”), but for 

others, the footprint may extend well beyond that space. For example, air quality effects to humans can extend miles 

beyond the footprint of the proposed action. The spatial domain, or cumulative effects study area (CESA), for past, 

present, and reasonably foreseeable future activities for each resource is identified under the discussion of the analysis 

area for each resource, and is shown in Figure 3-1. The rationale used to develop the spatial domain is also provided 

under the descriptions of the resources that follow. 

For the purposes of this analysis, non-federal lands include land owned and/or managed by individuals, corporations, 

Native American tribes, states, counties, or other agencies. The BLM does not have the authority to regulate any 

activities or their timing on lands other than those the BLM administers. However, when an action takes place on 

public land, it may cause direct or indirect effects on non-federal lands. For example, a wildfire that begins on public 

land may burn to adjacent private land, or noxious weeds and other invasive non-native vegetation infestations that 

begin on public land may infest adjacent private land. 

This EIS also considers the likely effects on public lands from reasonably foreseeable actions occurring on nonfederal lands. For example, agricultural use of non-federal lands may potentially have direct impacts on terrestrial 

wildlife species that move between federal and non-federal lands during the year or during their life cycle. The role of 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-1

Cumulative Effects Study Areas

3 Bars Ecosystem and

Landscape Restoration Project

Elko

Battle

Mountain

Austin Eureka

Nye County

Elko

County

Humboldt

County

White Pine

County

Lander

County

Eureka

County

Pershing

County

82

305

766

1

228

227

306

379

844

18

376

11

789

2

892

225

8

229

278

50

80

0 2 4 6 8 10 20

Miles

0 2 4 6 8 10 20Kilometers

Legend

Air Quality CESA

Cultural CESA

(5 mi. buffer)

Grazing Allotment CESA

Herd Management

Area CESA

Native American CESA

Socioeconomic CESA

Water Resources, Wildfire,

Soils, and Vegetation CESA

Visual Resources and

Recreation CESA

(15 mi. buffer)

Wildlife CESA

(10 mi. buffer)

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012d, 2013b.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/30/13)
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-8 October 2016

the management of non-federal lands was considered in the analysis on these species and their associated ecosystems. 

Localized actions on non-federal lands often affect local environmental conditions on nearby federal lands and may 

also affect federal management decisions. 

3.3.2.3.3 Past, Present, and Reasonably Foreseeable Future Actions 

Numerous past and present actions on and near the 3 Bars Project area have contributed to existing conditions on the 

3 Bars Project area. These include actions by entities with an interest in vegetation management, including nearby 

federal land management agencies, the State of Nevada, Eureka County and other local governments, and private 

landowners including ranchers and farmers, and private developers. Past and present actions considered in the 

cumulative effects analysis include noxious weeds and other invasive non-native vegetation treatments and the use of 

herbicides; grazing, agriculture, and the use and harvest of woodland products; utility infrastructure and distribution 

networks; wildfires, fuels management, and reseeding; habitat stabilization and rehabilitation; livestock and wild 

horse management activities; recreation; land development; mineral development and exploration; and oil, gas, and 

geothermal leasing and development. 

In addition, the BLM identified reasonably foreseeable future actions that could affect conditions on the 3 Bars 

Project area and that should be addressed in the cumulative effects analysis. These projects and activities have the 

potential to impact the environmental resources of concern within all or portions of the various CESAs. The following 

summarizes past, present, and reasonably foreseeable future actions that have or could occur in one or more of the 3 

Bars Project CESAs. 

Grazing and Grazing Management, Range Improvement, and Allotment Management 

Past land uses on lands in the CESA and throughout the western U.S. have resulted in changes in the vegetation 

community from its historic ecological site characteristics. Much of the change that has occurred within the 3 Bars 

ecosystem has been attributed to historic livestock grazing and other land disturbances that have led to the 

establishment and spread of noxious weeds and other invasive non-native vegetation, and expansion of pinyon-juniper 

woodland beyond historic ranges. Livestock often congregate near streams, springs, and wetlands and have impacted 

riparian habitat and forage, and have influenced stream channels and their ability to function properly. Humans have 

also been a major factor in influencing vegetation, including actions that have altered fire regimes and caused the 

spread of noxious weeds and other invasive non-native vegetation. 

Livestock grazing has been, and continues to be, a dominant land use in Eureka County and the adjoining portions of 

Elko, Lander, White Pine, and Nye Counties. Multiple grazing allotments have been permitted and administered by 

the BLM during the past half century. The carrying capacity of these allotments has been adjusted over the years in 

response to mineral development, drought, wildfires, and rangeland condition. 

Surface water sources that support livestock grazing and agriculture within the CESAs include reservoirs, perennial 

creeks, springs, and seeps. Improved water sources include developed springs, stock wells, stock ponds, water 

pipelines, and troughs. Cow-calf pairs, heifers, steers, bulls, and sheep graze on residual forage in alfalfa fields, 

irrigated pastures, and rangeland within Eureka County and the adjoining portions of Elko, Lander, White Pine, and 

Nye Counties. In addition, a substantial amount of four-strand wire fencing has been constructed within the CESAs. 

Past and present range and habitat improvement projects have resulted in changes to vegetation communities. The 

actual acreage for this has not been quantified; however, some of these projects are range improvements that include 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-9 October 2016

fences, cattle guards, noxious weeds and other invasive non-native vegetation control, water troughs, spring 

improvements, wells, reservoirs, windmills and tanks, and pipelines. 

Open range livestock operations are expected to continue on public lands within the CESA at management levels that 

have been established through allotment-specific grazing decisions. Fenced feeding operations occur on fenced 

private lands within the CESAs and are expected to continue as well (Figure 3-2). Short-term (typically 2 to 4 years) 

temporary suspensions to Animal Unit Months (AUMs) would be expected in response to broadcast prescribed fires 

and the resultant temporary loss of forage, to allow for vegetation establishment and stabilization. The BLM would 

continue to monitor resource conditions to ensure proper livestock management and the long-term success of 

treatments. Any changes to the permitted use would be completed through the issuance of subsequent grazing 

decisions in accordance with 43 CFR §§ 4110.3, 4130.3-3, and 4160.

Range improvement projects are also proposed as part of ongoing livestock management programs at the BLM Mount 

Lewis Field Office and could include: 

 allotment/pasture fences, exclosure fences, and drift fence construction 

 seeding and seeding maintenance 

 vegetation manipulation 

 noxious weeds and other invasive non-native vegetation population control 

 fence relocation 

 water hauls 

 maintenance of wells and troughs 

 spring developments 

In order to ensure long-term success, restoration projects would not be implemented until proper grazing management 

is in place, as discussed in Section 3.18.4. This would occur through agreements or decisions subsequent to the 3 Bars 

Project ROD. The BLM would work with permittees on a permit-by-permit basis to address any changes in livestock 

management due to treatment implementation. In all instances, appropriate changes in livestock management through 

agreements or decisions would be finalized prior to project implementation. 

The BLM would also manage livestock to meet Greater sage-grouse habitat objectives, in accordance with current 

policy and guidance. 

Noxious Weeds and other Invasive Non-native Vegetation 

Noxious weeds and other invasive non-native vegetation are found on the 3 Bars Project area and adjacent lands 

(Figure 3-2). The BLM uses an integrated vegetation management approach to prevent, control, or contain noxious 

weeds and other invasive non-native vegetation, using, but not limited to, manual, mechanical, biological, fire, and 

chemical methods. In an integrated vegetation management program, each management option is considered and/or 

used in combination with another, recognizing that no one management option is a stand-alone option and that each 

has its strengths and weaknesses. No individual method will eradicate undesirable vegetation in a single treatment; 

multiple treatments may be required. The effects of these treatment methods were analyzed for 17 western states, 

including Nevada, in the 17-States PEIS and PER (USDOI BLM 2007b, c). 
Figure 3-2

Cumulative Impacts from

Grazing, Agriculture, and

Forest Product Activities

3 Bars Ecosystem and

Landscape Restoration Project

Eureka

Elko

County

White

Pine

County

Lander

County

Eureka

County

82

892

8

379

278

50

Trail

Canyon Seed

Harvest Area

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Range Improvements

Cattle Guard

Corral

Gate

Reservoir

Spring

Stock Tank/Trough/Waterhaul

Windmill/Well

Other Water Development

Fence

Noxious Weed Treatments

Canada thistle

Musk thistle

Perennial pepperweed

Russian knapweed

Scotch thistle

Tamarisk

Whitetop/Hoary cress

Allotment Boundaries

Irrigated Cropland

Range Improvement Treatment

Commercial Pine Nut Sale Area

Private Fuelwood and

Christmas Tree Harvest Area

Seed Harvest Area

Grazing Allotment CESA

Herd Management Area CESA

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USGS 2004; AECOM 2011a; BLM 2012d,e, 2013b,c,d,e.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/30/13)

Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-11 October 2016

The BLM treats about 250 acres of noxious weeds and other invasive non-native vegetation annually on the 3 Bars 

Project area using herbicides. Key species targeted for treatments include cheatgrass, hoary cress, musk and Scotch 

thistles, and Russian knapweed. Treatments within the CESAs are also conducted by the Diamond Valley Weed 

Control District and by private landowners. The BLM and other landowners within the CESA would continue 

noxious weeds and other invasive non-native vegetation inventory, treatment, and monitoring. 

Historically, the BLM has used ground-based methods, including hand-held sprayers, truck mounted sprayers, and allterrain vehicles 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. Most treatments in the future 

would also be conducted using ground-based methods. 

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 (2,4-

dichlorophenoxyacetic acid), clopyralid, chlorsulfuron, dicamba, glyphosate, imazapic, imazapyr, metsulfuron 

methyl, picloram, tebuthiuron, and triclopyr. 

During 2011, only five herbicide active ingredients were used on the 3 Bars Project area—2,4-D, glyphosate, 

imazapyr, metsulfuron methyl, and picloram. Imazapyr was used as a stand-alone herbicide, while 2,4-D was tank 

mixed with metsulfuron methyl and with picloram, and glyphosate and metsulfuron methyl were tank mixed together. 

About 80 percent of treatments involved the use of 2,4-D in a tank mix with metsulfuron methyl. Specific herbicide 

characteristics and approved use areas are discussed in the 17-State PEIS (USDOI BLM 2007b:2-9 to 2-16). 

The BLM has applied herbicides aerially in the past to treat noxious weeds and other invasive non-native vegetation, 

and may use helicopters or fixed-wing aircraft to apply herbicides in the future. Should aerial spraying occur in the 

future, the BLM anticipates only using 2,4-D, glyphosate, imazapic, imazapyr, and metsulfuron methyl, all of which 

are labeled for this specific application method. Operation of helicopters is more expensive than operation of fixedwing aircraft, but helicopters are more maneuverable and more effective in areas with irregular terrain. Helicopters are 

also more effective for treating targeted vegetation in areas with multiple vegetation types. 

Ground-based herbicide treatments would continue as the primary treatment method in riparian areas, while aerial 

herbicide applications would primarily occur in larger, more expansive areas to treat cheatgrass. However, treatments 

could occur anywhere in the CESA where Nevada-listed noxious weeds and other invasive non-native vegetation are 

found. 

Irrigated Crops and Irrigation Facilities on Private Lands 

Approximately 24,357 acres are under irrigation in Diamond Valley, and 280 acres were under irrigation in Kobeh 

Valley in 2011. Agricultural development in Pine Valley was approximately 5,100 acres in 2007 (USDOI BLM 

2012b). 

Irrigation facilities and irrigation of crops are only permitted on private lands, with the exception of ditches that 

require a right-of-way. Continued agricultural activities in Diamond Valley, Kobeh Valley, and Pine Valley are 

reasonably expected to occur in the form of flood and pivot irrigation (USDOI BLM 2012b). Irrigated croplands 

near the 3 Bars Project area are shown on Figure 3-2.
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-12 October 2016

Woodland Products 

Private fuelwood, Christmas tree, and pine nut harvest areas are found within the CESAs (Figure 3-2). Commercial 

pine nut harvesting occurs under permits issued by the Mount Lewis Field Office. Yearly commercial pine nut 

harvesting is very sporadic, based on the tree production of cones and nuts. Other woodland product harvesting 

activities include the commercial and personal cutting of pinyon pine and Utah juniper for firewood, the personal 

cutting of pinyon pine for Christmas trees, the greenwood cutting of primarily juniper for fence posts, and commercial 

and personal harvesting of pine nuts (USDOI BLM 2012b).

Personal use of woodland products would occur in the future in the CESAs. Public and tribal pine nut and woodland 

products harvesting would continue based on the trees’ production of cones and nuts. Commercial firewood and pine 

nut harvesting could occur on the Sulphur Spring Range, Roberts Mountains, and Whistler Mountains in the 3 Bars 

Project area, and on the Fish Creek Range in Eureka County. 

Wild Horse Management Activities 

Wild horse gathers to achieve the Appropriate Management Level (AML) were conducted in the Roberts Mountain 

Herd Management Area (HMA) in 1987, 1995, 2001, and 2008. Drought-stressed wild horses were gathered from the 

Whistler Mountain HMA in 2001, in conjunction with the Roberts Mountain gather. The Whistler Mountain HMA 

was gathered with the Roberts Mountain HMA in 2008. The Kobeh Valley area outside the Fish Creek HMA was 

gathered in 1994 and 2008. The Rocky Hills HMA was gathered in 1997, 1999, 2009, and 2010, and fertility control 

was implemented during the last two gathers. 

The objectives of BLM wild horse gathers has been to remove wild horses from outside of designated HMA 

boundaries, achieve and maintain the established AMLs, and in recent years, treat and/or re-treat mares for fertility 

control to reduce population growth rates. During gathers, the BLM does not remove all wild horses within an HMA. 

Either a portion of the population remains uncaptured or the BLM selects wild horses to release back to the range. 

This helps to achieve the low range of the AML and allows the population to increase for about 3 to 4 years before 

another gather would be required. To date, approximately 1,200 wild horses have been removed from the Roberts 

Mountain Complex, which includes the Roberts Mountain, Whistler Mountain, and Fish Creek North HMAs, and 650

wild horses from the Rocky Hills HMA. 

Future wild horse management activities within these HMAs could include AML reviews and adjustments, 

adjustments to HMA boundaries, fence removal, enhancement of existing water sources and development of new 

water sources, and implementation of range improvement projects. Methods used to control wild horse populations 

would primarily involve gathers to remove excess animals to control populations, and fertility control through 

injections of immunocontraceptives. These activities would help to maintain herd numbers near sustainable levels and 

to distribute wild horses more evenly across the rangeland. The BLM is also guided by the Nevada Northeastern 

Great Basin Resource Advisory Council to promote healthy rangelands through implementation of standards and 

guidelines for maintaining healthy wild horse herds on HMAs. 

Fuels Management and Habitat Improvement Projects 

The BLM is conducting ongoing, previously authorized, and fuels treatments on approximately 17,378 acres in the 

CESA. These include: Eureka-South Diamond Valley Wildland Urban Interface Treatments (2,087 total acres, 247 

acres still to be treated; USDOI BLM 2003a, 2006); Red Hills (3,671 total acres, 859 acres still to be treated; USDOI 

BLM 2005a); Sulphur Spring Hazardous Fuels Reduction Treatments (8,620 total acres, 6,420 acres still to be treated; 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-13 October 2016

USDOI BLM 2009d); Tonkin (1,000 total acres, 650 acres still to be treated; USDOI BLM 2005b); and Roberts 

Mountains Habitat Enhancement Project (2,000 total acres, 500 still to be treated; USDOI BLM 2007d). Of the 8,676 

acres still to be treated, about 8,021 acres would be treated using manual and mechanical methods, and 655 acres 

would be treated using prescribed fire. In addition, the BLM would seed or plant many of the acres after treatment to 

restore native vegetation, and would continue to monitor past treatments, and treat as necessary, to mitigate any 

noxious weeds and other invasive non-native vegetation that may establish in treatment areas and to ensure that 

treatments meet established goals. 

In addition to these projects, the BLM would continue to conduct projects to slow the spread of noxious weeds and 

other invasive non-native vegetation, and restore lands degraded by wildfire, which are allowed under previously 

approved authorizations. If the No Action Alternative (Alternative D) is selected, it is likely that the BLM would 

authorize additional treatments within the 3 Bars ecosystem to meet the goals in the Shoshone-Eureka RMP, 

including hazardous fuels reduction, stream restoration, and fish and wildlife habitat improvement projects. These 

projects may be similar to those proposed under the action alternatives, but under Alternative D, these projects would 

have to be analyzed individually under separate NEPA analyses. These projects would likely be similar to those 

described in the previous paragraph, but would be smaller in size and would take longer to implement than would be 

the case for treatments under the action alternatives. It is estimated that the BLM would conduct about 1,500 acres of 

treatments annually under current and future authorizations under the No Action Alternative, not including treatments 

that would be conducted as part of rehabilitation of lands burned by wildfires. 

While the acreage burned by wildfires in a given year is sporadic and highly variable, since 1985 wildfires have 

burned an average of 4,200 acres annually within the 3 Bars Project area and an average of 6,900 acres annually 

within watersheds that are wholly or partially within the CESAs, and several large fires have occurred within the 

CESA since 1985 (Figure 3-3). The BLM and local fire districts would continue to conduct fire suppression activities 

when wildfires occur within the CESAs. The scale and scope of those activities would be proportional to the size of 

the wildfire and its proximity to structures. 

Recreation 

Dispersed recreation opportunities include sightseeing, pleasure driving, rock collecting, photography, winter sports, 

off-highway vehicle use, mountain biking, picnicking, camping, fishing, hunting, hiking, and Pony Express Trail rerides. This wide range of opportunities is possible because virtually all of the public lands in the CESAs are accessible 

to the public and offer a variety of settings suitable for different recreational activities. Numerous roads provide 

access to off-highway vehicle users within the CESA (Figure 3-4). Recreational use within the CESA is likely to

increase proportionally to changes in population, with dispersed outdoor recreational activities being the predominant 

type of recreation.

Utilities and Infrastructure 

Past utility and distribution actions include the development of roads, powerlines, and telecommunications, as well as 

public water supply and wastewater systems. Roads have been developed by the federal government and the State of 

Nevada (U.S. Highway 50, State Route 278, and State Route 892), Eureka County and adjoining counties, the BLM, 

and the Forest Service. The town of Eureka is in southeastern Eureka County. Individual ranches and farms comprise 

the remainder of the inhabited areas in southern Eureka County and the surrounding counties of Lander, Nye, White 

Pine, and Elko.
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-3

Cumulative Impacts from

Wildland Fires, Fuels

Management, and Reseeding

3 Bars Ecosystem and

Landscape Restoration Project

Sulphur

Spring

Red

Hills

Eureka

WUI

NW Diamond

Valley WUI

Diamond

Valley WUI

Tonkin

Eureka

Elko

County

White

Pine

County

Lander

County Eureka

County

82

8

379

892

278

50

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Fire Starts (1985 - 2008)

Large Fire Perimeter

(1985 - 2012)

Fuels Reduction Unit

Fire and Fuels CESA

Fire Reseeding

Fire Defense System Assessment

Shrub/Grass

Sagebrush/Pinyon-juniper

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012d,f,g, 2013f.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-4

Cumulative Impacts from

Recreation and Wilderness

3 Bars Ecosystem and

Landscape Restoration Project

S I M P S O N P A R K M O U N T A I N S

Roberts Creek

Willow Creek

Pete Hanson Creek

Birch Creek

Eureka

Elko

County

White

Pine

County

Lander

County

Eureka

County

82

379

306

892

278

50

ROBERTS

MOUNTAIN

SIMPSON

PARK

Tonkin Spring

Tonkin

Reservoir

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10Kilometers

Legend

Travel Route Accessible to:

All Vehicles

High Clearance Vehicles

4 Wheel Drive Vehicles

All-terrain Vehicles (ATV)

Spring

Reservoir

Fishing Stream

Wilderness Study Area

Visual and Recreation CESA

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: U.S. Census 2009, 2010a,b, 2011da BLM 2012d,g; USGS 2012a.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-16 October 2016

Three general types of roads have been developed within Eureka County and the adjoining counties—paved roads, 

gravel surface roads, and dirt roads. There are two major travel routes within the CESAs—U.S. Highway 50 and State 

Route 278. 

Development of additional roads is probable; however, most of these roads may be unauthorized dirt roads created 

during motorized recreational use of public lands in the CESAs, and paved or unpaved roads associated with 

development in or near the town of Eureka. It is reasonable to expect that traffic would increase in volume on the two 

major travel routes (U.S. Highway 50 and State Route 278) in the CESAs, as well as on the other county roads in 

proportion to an expected increase in economic activity and population growth, although no estimate was made on the 

miles of new roads and railroads and acres of disturbance in the reasonably foreseeable future (Figure 3-5). 

Two major transmission powerlines are in Eureka County, distributing power in the State of Nevada as part of the 

power grid. One is the Falcon-Gonder line that travels from north of Beowawe, Nevada, through the project area to 

U.S. Highway 50 and then east to Ely, Nevada. The other main transmission line is an east-west line that parallels 

U.S. Highway 50. In addition, there are power distribution lines in Diamond Valley and the town of Eureka and to 

most of the remote ranches and mining operations within the CESA boundaries. 

The town of Eureka and the Devils Gate General Improvement District in Diamond Valley have a community water 

supply system, which is supplied primarily from ground water wells in Diamond Valley, as well as springs in the 

Pinto Summit area (USDOI BLM 2012b).

The town of Eureka is planning to expand beyond its current limits of development and will require additional 

infrastructure to support the needs of the community. The need for new transmission lines within this portion of the 

Nevada is not anticipated, however, as existing rights-of ways can accommodate additional transmission line 

development and it is reasonable to expect that additional utility distribution and telephone lines would be 

constructed. 

Mineral Development and Exploration 

There are ten historic mining districts that occur within the geology and minerals CESA in Eureka County—Alpha, 

Antelope, Diamond, Eureka, Fish Creek, Lone Mountain, Mineral Hill, Mount Hope, Roberts, and Union. The Alpha 

District is in the Sulphur Spring Range. The Antelope District is on the western flank of Roberts Mountains. The 

Diamond District is north of the town of Eureka on the west flank of the Diamond Mountains. The Eureka District, is 

in the vicinity of the town of Eureka. The Fish Creek District is southwest of the town of Eureka in the Fish Creek 

Range. The Lone Mountain District is on the north flank of Lone Mountain in Kobeh Valley. The Mineral Hill 

District is on the northwest flank of the Sulphur Spring Range. The Mount Hope District is on the southeast flank of 

Mount Hope and is where the Mount Hope Project is being constructed. The Roberts District is on the west flank of 

the Simpson Park Mountains. The Union District is on the north flank of the Sulphur Spring Range. Surface 

disturbance associated with these operations has not been quantified, however, it is likely in the range of several 

hundred to a few thousand acres. 

From the mid-1960s to the present, mineral resource development within the CESA has principally been 

gold production from four mining operations: Gold Bar, Windfall, Tonkin Springs, and Ruby Hill. The Gold Bar 

Mine is found in the Antelope District in the southern Roberts Mountains and closed in the 1990s. The Ruby Hill 

Mine is active and is in the Eureka District. The Windfall-Rustler and Lookout Mountain (Ratto Canyon) mines are in 
Figure 3-5

Cumulative Impacts from

Utilities and Infrastructure

3 Bars Ecosystem and

Landscape Restoration Project

Elko

Battle Mountain

Austin Eureka

Nye County

Elko

County

Humboldt

County

White Pine

County

Lander

County

Eureka

County

Pershing

County

82

305

766

1

228

227

306

379

844

18

376

789 11

2

892

225

8

229

278

50

80

0 2 4 6 8 10 20

Miles

0 2 4 6 8 10 20Kilometers

Legend

CESA Maximum

Extent

Agriculture

Airport

Communication Site

Drill Pad

Dump

Exclusion Area

Fire Station

Historical Site

Material Site

Monitoring Site

Monument

Non-Energy Facility

Power Facilities

Pump Station

Range Improvement

Recreation Site

Right of Way

Stream Gaging

Station

Study Plot

Trespass

Water Pumping

Plant

Well

Undefined

Railroad

Interstate Hwy

U.S. Hwy

State Hwy

Other Road

Fence

Irrigation Facilities

Pipeline

Telephone Line

Transmission Line

Irrigated Crop

Land Exchange

Land Treatment Area

Lease

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: U.S. Census 2009, 2010a,b, 2011a; BLM 2012c,d.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/30/13)

Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-18 October 2016

the southern portion of the Eureka District and exploration is ongoing. The Tonkin Springs Mine is currently in 

closure. 

Activities associated with mining, exploration, and extraction would continue to occur in the CESA and would be 

likely to occur in the 3 Bars Project area (Figure 3-6). There are no active mines within the 3 Bars Project area, 

although the 8,318 acre Mount Hope Project is within the 3 Bars Project boundary. A portion of the mine site was 

cleared in 2013, but no dates have been set for completion of construction. Although much of the Mount Hope Project 

site was cleared in 2013, it is uncertain when construction and operation of the mine would occur. McEwen Mining 

recently purchased the Gold Bar facilities from U.S. Gold Corporation and is conducting baseline work in anticipation 

of reinitiating mining on the property. Exploration is also occurring in the Red Hills area and at the north end of 

Rocky Hills. The Gibellini vanadium mine, south of the town of Eureka, has submitted a Plan of Operations to the 

BLM and preparation of an EIS has begun. There are about 385 acres of sand and gravel materials sites within the 

Mining Operations and Geothermal, Oil, and Gas CESA. Of these, about 55 acres are within the 3 Bars Project area. 

 Oil, Gas, and Geothermal Leasing and Development

There are oil and gas leases throughout the CESAs (Figure 3-6). Four oil fields have been developed in Pine Valley. 

These oil fields are in Eureka County and are administered by the BLM Elko District. 

There are two geothermal projects within the Mining Operations and Geothermal, Oil, and Gas CESA. The 

McGinness Hills geothermal project is in Grass Valley, Lander County, and is west of the 3 Bars Project area. The 

Beowawe geothermal project is in Whirlwind Valley, northern Eureka County, and is north of the 3 Bars Project area. 

Both projects are in operation. As energy demands increase and advancements in exploration and drilling technology 

lead to development of previously unexplored resources, oil, natural gas, and geothermal leasing and exploration are 

likely to increase. Increased economic incentive may also lead to an increase in exploration and development as oil 

prices rise, although no exploration or development permit applications for projects in the CESAs have recently been 

submitted to the BLM. There would be additional disturbance associated with oil and gas and geothermal exploration 

and development as projects are proposed. 

All future proposed actions within the CESAs would be analyzed when a lessee submits plans for the action. The 

BLM would have the ability to limit discretionary activities on public lands, such as oil, natural gas, and geothermal 

leasing, because of the potential for listing of the Greater sage-grouse as threatened or endangered under the 

Endangered Species Act, and possibility that leasing actions could adversely impact Greater sage-grouse. 

Land Development 

The town of Eureka comprises approximately 880 acres. The majority of the town area lies along U.S. Highway 50. 

In addition, approximately 700 acres have been identified for residential or commercial development in the Diamond 

Valley area. The town of Eureka and the Diamond Valley community consist of roads, residences, commercial and 

public buildings, powerlines, fences, and other related development. 

There has been little industrial activity within the CESAs except for mineral development activities discussed above. 

There are also cement batch plants in the town of Eureka and Diamond Valley (USDOI BLM 2012b). 

Approximately 23,000 acres within Diamond Valley and within the project area have been identified for disposal in 

the Shoshone-Eureka RMP. Public land sales are considered possible under reasonably foreseeable future actions. The 

BLM is evaluating a proposed 150-acre land sale associated with the Ruby Hill Mine. Other potential land sales could 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-6

Cumulative Impacts from

Mining Operations and

Oil and Gas Production 

3 Bars Ecosystem and

Landscape Restoration Project

Mount Hope

Molybdenum

Mine Project

Gold Quarry Mine

Expansion Project

Rossi Mine Expansion

Hollister

Underground Gold and

Silver Mine Project

Arturo Open Pit

Gold Mine Project

Independence

Mountains Poverty

Peak

Tuscarora

Rock Creek

Potosi

Gold Circle

Beaver

Coal

Mine

Wells

Dutch

Flat

Ivanhoe

Merrimac

Bootstrap

Lynn Izenhood Swales

Mountain Elko

Golconda

Iron Point

Halleck

Gold

Run

Maggie

Creek

Buffalo

Mountain

Warm

Creek

Carlin

North Battle

Mountain

Battle

Mountain

Black

Diablo

Iron Hat

Argenta

(nonmetallic)

Tobin and

Sonoma

Range

Buffalo

Valley Huntington Creek Argenta (Elko)

(metallic)

Beowawe Railroad Safford

Lee (Elko)

Ruby Valley

Bateman

Canyon

Lewis Hilltop Robinson

Mountain

Gilbert

Canyon

McCoy

Delker

Bullion

Valley

View ModarelliFrenchie

Creek

Mount

Tobin

Mud

Springs

Corral Larrabee Creek Harrison

Pass

Pine

Valley

Mountain

Springs

Cave Creek

Buckhorn

Cortez

Jersey Union

(Eureka Elko)

Warm

Springs

(Lander) Mineral

Hill

Carico

Lake Chase

Diamond

Marsh

Huntington Creek

(Eureka White Pine)

Bald

Mountain

Alpha

Butte

Valley

Steiner

Canyon

Antelope

(Eureka)

Roberts

Wild Horse

(Churchill

Lander)

Callaghan

Ranch

Iowa

Canyon Mount

Hope

Ravenswood

Diamond

New Pass Lone Mountain

(Eureka)

Skookum

Reese

River Newark

Eureka

Illipah

Fish Creek

Pancake

Pinto

Birch

Creek

Big Creek

Spencer

Hot Springs

White Pine

Kingston

Gibellini

Washington

(Nye Lander)

Millett Segura Ranch Northumberland

Jackson

Spalding

Marsh

Elko

Battle Mountain

Austin

Eureka

Nye County

Elko

County

Humboldt

County

White Pine

County

Lander

County

Eureka

County

Pershing

County

82

305

1

228

227

306

379

844

18

376

789 11

2

892

225

8

229

278

50

80

0 2 4 6 8 10 20

Miles

0 2 4 6 8 10 20Kilometers

Legend

Oil and Gas Wells through 2006

Active Production Well

Abandoned Well with Evidence

of Oil and/or Gas Encountered

while Drilling

Abandoned Well with No

Evidence of Oil or Gas

Encountered while Drilling

Geothermal Lease

Mineral Resources

Precious Metals

Base Metals

Sand and Gravel

Mining District

CESA Maximum Extent

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: Tingley, J.V. 1998; Garside and Hess 2007; BLM 2011c, 2012d; USGS 2012a.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/10/13)
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-20 October 2016

include lands associated with community development or specific resource development projects. Any future land 

sales that were not within disposal areas identified in the Shoshone-Eureka RMP would be subject to congressional 

requirements in the implementing legislation. Public lands converted to private ownership would be subject to all 

applicable state environmental laws. 

If a land sale involved community development land, there would likely be a future change in use from wildlife 

habitat to residential or commercial development. If a land sale involved an ongoing resource development project, 

current resource activities would likely continue into the future with possible expansion. After the resource activity 

has been completed, the land could be restored to uses such as livestock grazing and wildlife habitat, which would be 

the use if the land remained under BLM management, or could be converted to other uses. Long-term use of 

privatized land would be subject to any covenants agreed to at the time of sale. Information on areas identified for 

disposal can be found in the 1986 Shoshone-Eureka Resource Area ROD (USDOI BLM 1986a:5) on the BLM Battle 

Mountain District Office website at URL: 

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

3.3.2.4 Set of Receptors to be Assessed 

The set of receptors assessed in the cumulative effects analysis are the natural, cultural, and social resources discussed 

in this chapter. 

3.3.2.5 Magnitude of Effects and whether Those Effects are Accumulating 

The potential extent of the total cumulative effects (e.g., number of animals and habitat affected), and how long the 

effects might last (e.g., population recovery time) are estimated to determine the magnitude of effects that could 

accumulate for each resource. Where possible, the assessment of effects on a resource is based on quantitative 

analysis (e.g., acres affected by treatment activity). However, many effects are difficult to quantify (e.g., animal 

behaviors; human perceptions) and a qualitative assessment of effects is made. 

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. The analysis also assumes that the BLM would determine the need for the action 

based on past monitoring, and that additional monitoring would occur after the project to ascertain if effects are still 

accumulating or if the treatment has been effective in achieving the resource objective. 

3.3.3 Unavoidable Adverse Commitments 

Unavoidable adverse commitments are those commitments that could occur as a result of implementing any of the 

action alternatives. Some of these effects would be short-term, while others would be long-term. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-21 October 2016

3.3.4 Irreversible and Irretrievable Commitments 

Irreversible commitments are those commitments that cannot be reversed, except perhaps in the extreme long-term. 

This term applies primarily to the effects of use of nonrenewable resources, such as minerals or cultural resources, or 

to factors, such as soil productivity, that are renewable only over long periods of time. 

Irretrievable commitments are those commitments that are lost for a period of time. For example, timber 

production is lost while an area is mined. The production lost is irretrievable, but the action is not irreversible. If 

the site is reclaimed, it is possible to resume timber production. 

3.3.5 Resource Protection Measures Considered in the Effects Analysis 

The impacts assessment assumes that SOPs, monitoring measures, and mitigation developed by the BLM for the 

alternatives would be adopted to protect environmental and socioeconomic resources on public lands (Appendix C). 

In addition, a number of federal, state, local, and tribal resource management and monitoring programs have been 

established to protect environmental resources and, in cases where there is existing environmental impairment, to 

effect restoration. The assessment of cumulative impacts recognizes the existence of these programs and assumes that 

the mandate under which each program was established will continue. The effects analysis assumes that these 

programs effectively avoid or mitigate the environmental impacts that they are designed to address. The programs are 

discussed in the sections that follow. 

3.3.6 Incomplete and Unavailable Information 

This EIS discusses the baseline environment that exists today, and impacts from treatments that the Mount Lewis 

Field Office proposes to conduct during life of the project. It is assumed that baseline conditions would change little 

during the expected life of this EIS (about 10 to 15 years). Still, treatments could occur during the life of this EIS that 

are substantially different from those evaluated in this EIS. If so, the Mount Lewis Field Office would conduct 

additional NEPA analysis to assess those projects’ effects. 

The analysis of impacts of the treatments in this EIS is based on the best and most recent information available. As is 

always the case when developing management direction for a wide range of resources, not all information that might 

be desired is available. The CEQ regulations provide direction on how to proceed with the preparation of an EIS when 

information is incomplete or unavailable: 

“If the information relevant to reasonably foreseeable significant adverse impacts cannot be 

obtained because the overall costs of obtaining it are exorbitant or the means to obtain it are not 

known, the agency shall include within the environmental impact statement: 1) a statement that 

such information is incomplete or unavailable; 2) a statement of the relevance of the incomplete 

or unavailable information to evaluating reasonably foreseeable significant adverse impacts on 

the human environment; 3) a summary of existing credible scientific evidence which is relevant 

to evaluating the reasonably foreseeable significant adverse impacts on the human environment; 

and 4) the agency’s evaluation of such impacts based upon theoretical approaches or research 

methods generally accepted in the scientific community. For the purposes of this section, 

“reasonably foreseeable” includes “impacts which have catastrophic consequences, even if their 

probability of occurrence is low, provided that the analysis of the impacts is supported by 
HOW THE EFFECTS OF THE ALTERNATIVES WERE EVALUATED 

3 Bars Project Final EIS 3-22 October 2016

credible scientific evidence, is not based on pure conjecture, and is within the rule of reason” 

(40 CFR § 1502.22b). 

For this EIS, the primary effect of unavailable information is the inability to quantify certain impacts. Where 

quantification was not possible, impacts have been described in qualitative terms. A summary of existing credible 

scientific evidence that is relevant to evaluating the reasonably foreseeable adverse impacts on the human and 

socioeconomic environment and supports the BLM’s evaluation of such impacts has been included in Chapter 3, in 

the appendices that accompany this EIS, and in supporting documents that were prepared for this EIS. 

There are also uncertainties associated with the assessment process used to determine the effects from the use of the 

treatment methods. Our knowledge of risks to the environment from treatment methods continually evolves. Our 

knowledge is, and always will be, incomplete regarding many aspects of terrestrial and aquatic species; ecology of the 

lands administered by the BLM; the economy; society; the types of vegetative threats the Field Office will face in 

future years; funding; and changes in government policy. To reduce the level of uncertainty, the best available 

information was used, and it was assumed that future treatment actions, funding, and government policies, as they 

apply to BLM-administered lands, would be similar to actions and policies that have occurred in recent years. Should 

these conditions change and as the best available science emerges such that assumptions made in this EIS are no 

longer valid, the Mount Lewis Field Office would conduct additional NEPA analysis to better understand risks from 

their treatments. 

3.4 General Setting 

3.4.1 Project Area 

The 3 Bars Project area is in northern Eureka County, Nevada (Figure 3-7). The project area spans about 750,000 

acres and includes three major mountain ranges (Roberts Mountains, Simpson Park Mountains, and the Sulphur 

Spring Range). 

The project area is located in the central portion of the Basin and Range physiographic province. Within the project 

area, surface elevations range from approximately 10,100 feet above mean sea level (amsl) at the peak of Roberts 

Mountains in the middle of the project area, to approximately 5,450 feet amsl along Pine Creek at the northern edge 

of the project area. Other high elevation areas within the project include the Simpson Park Mountains (ranging 

generally from 7,600 to 8,200 feet amsl) along the western part of the project area, and Table Mountain and the 

Sulphur Spring Range (the latter ranging generally from 7,400 to 7,800 feet amsl) in the northeast. Lower elevations 

are approximately 6,070 feet amsl along U.S. Highway 50; approximately 5,830 feet amsl in Diamond Valley, 

approximately 5,640 feet amsl in the northwest corner of the project area, and approximately 5,480 feet amsl along 

Henderson Creek in Garden Valley in the northern part of the project area. Block faulting in the area has resulted in 

generally north-south trending mountain ranges. Structural deformation has resulted in a series of valleys separated by 

mountain ranges. The three valleys of interest that are within the ecosystem are Diamond, Kobeh, and Pine Valleys 

(Figure 3-7). 

3.4.2 Ecoregions 

There are nine ecoregions within the project area (Figure 3-8; Bryce et al. 2003). Ecoregions are geographic areas 

that are delineated and defined by similar climatic conditions, geomorphology, and soils (Bailey 1997, 2002 cited in

USDOI BLM 2007c). Since these factors are relatively constant over time and strongly influence the ecology of 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-7

Study Area

3 Bars Ecosystem and

Landscape Restoration Project

L O N E

M T N

W H I S T L E R

M T N S I M P S O N P A R K M O U N T A I N S

S U L F E R S P R I N G S R A N G E

C O R T E Z M O U N T A I N S

S H O S H O N E R A N G E

F I S H C R E E K

M O U N T A I N S

T O I Y A B E 

R A N G E

D I A M O N D M O U N T A I N S

R U B Y M O U N T A I N S

S H E L L C R E E K R A N G E

M O U N T

H O P E

M O U N T

T E N A B O

T A B L E P I N E V A L L E Y

M T N G A R D E N

V A L L E Y

D I A M O N D V A L L E Y

K O B E H V A L L E Y

Nye County

Elko

County

Humboldt

County

White Pine

County

Lander

County

Eureka

County

Pershing

County

Battle

Mountain

Gold

Acres

Austin Eureka

LITTLE HUMBOLDT

RIVER

CHINA

MOUNTAIN

RED

SPRING

CEDAR

RIDGE TOBIN

RANGE

AUGUSTA

MOUNTAINS

ROBERTS

MOUNTAIN

SIMPSON

PARK

221

304

18

82

535

225

230

227

226

376

379

51

306

21

228

722

229

789

278

305

50

50

80

80

0 2 4 6 8 10 20

Miles

0 2 4 6 8 10 20Kilometers

Legend

Interstate Highway

U.S. Highway

State Highway

Major Road

City or Town

CESA Maximum Extent

Wilderness Study Area

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012d,g.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
GENERAL SETTING 

3 Bars Project Final EIS 3-24 October 2016

vegetative communities, ecoregions may have similar potentials and responses to disturbance (Clarke and Bryce 

1997, Jensen et al. 1997). Ecoregions, therefore, provide a useful framework for organizing, interpreting, and 

predicting changes to vegetation following management treatments. These ecoregions are discussed below.

Several ecological sites occur within each respective ecoregion. Finer scale descriptions of the soils, vegetation, and 

associated plant community dynamics can be obtained from the ecological site descriptions for the ecological sites 

correlated to specific soils within the project area. A list of the dominant ecological sites can be found in Section 

3.12.2.2 based on ecological site descriptions. 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. 

3.4.2.1 Lahontan and Tonopah Playas 

The nearly level and often barren Lahontan and Tonopah Playas ecoregion contains mud flats, alkali flats, and 

intermittent saline lakes, such as the Black Rock Desert, Carson Sink, and Sarcobatus Flat. Marshes, remnant lakes, 

and playas are all that remain of Pleistocene Lake Lahontan, which was once the size of Lake Erie. Playas occur at the 

lowest elevations in the Lahontan Basin and represent the terminus or “sink” of rivers flowing east off the Sierra 

Nevada. They fill with seasonal runoff from surrounding mountain ranges during winter, providing habitat for 

migratory birds. Black greasewood or four-winged saltbush may grow around the perimeter in the transition to the salt 

shrub community, where they often stabilize areas of low sand dunes. This ecoregion has very limited grazing 

potential. Windblown salt dust from exposed playas may affect upland soils and vegetation. The Lahontan and 

Tonopah Playas ecoregion is important as wildlife habitat and for some recreational and military uses. 

3.4.2.2 Carbonate Sagebrush Valleys 

The basins and semi-arid uplands of the Carbonate Sagebrush Valleys ecoregion surround the carbonate ranges of 

eastern Nevada. Like the ranges, the Carbonate Sagebrush Valleys ecoregion is also largely underlain by limestone or 

dolomite. The combination of summer moisture and a limestone or dolomite substrate affects regional vegetation, 

particularly in terms of species dominance and elevational distribution. The substrate favors shrubs, such as black 

sagebrush and winterfat, which can tolerate shallow soil. Even in alluvial soils, root growth may be limited by a hard 

pan or caliche layer formed by carbonates leaching through the soil and accumulating. As a result, shrub cover is 

sparse in contrast to other sagebrush-covered ecoregions in Nevada, including the Central Nevada High Valleys 

ecoregion. The grass understory grades from a dominance of cool season grasses, such as bluebunch wheatgrass, in 

the north, to warm season grasses, such as blue grama (an indicator of summer rainfall), in the south. 

3.4.2.3 Carbonate Woodland Zone 

In the Carbonate Woodland Zone ecoregion the singleleaf pinyon pine and Utah juniper woodland canopy overtops 

and spans the existing sagebrush and mountain brush communities. The pinyon-juniper woodland has a broader 

elevational range in the carbonate areas of eastern Nevada than elsewhere in the region, even extending onto the 

floors of the higher basins, partially because of greater summer precipitation. Both pinyon and juniper decline north of 

this ecoregion. Historically, miners cut pinyon and juniper for mine timbers and charcoal. Since the beginning of fire 

suppression early in the last century, pinyon-juniper woodland has increased in density and expanded into lower 

sagebrush zones. The woodland understory is diverse due to the influence of carbonate substrates and summer 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-8

Ecoregions of the

3 Bars Project Area

3 Bars Ecosystem and

Landscape Restoration Project

13a

13h 13p

13q

13s

13t

13t

13z

13z

13b

13r

13r

13r

13s

13s

13p

13p

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

13 Central Basin and Range

13a Salt Deserts

13b Shadscale-dominated

 Saline Basins

13h Lahontan and

 Tonopah Playas

13p Carbonate Sagebrush

 Valleys

13q Carbonate Woodland

 Zone

13r Central Nevada

 High Valleys

13s Central Nevada Mid-slope

 Woodland and Brushland

13t Central Nevada

 Bald Mountains

13z Upper Lahontan Basin

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USEPA 2012a.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/30/13)
GENERAL SETTING 

3 Bars Project Final EIS 3-26 October 2016

rainfall. There are more springs and streams in this ecoregion than in western non-carbonate woodlands (e.g., Central 

Nevada Mid-Slope Woodland and Brushland ecoregion) because the carbonate substrate is soluble and porous, 

allowing rapid infiltration. 

3.4.2.4 Central Nevada High Valleys 

The Central Nevada High Valleys ecoregion contains sagebrush-covered rolling valleys that are generally over 5,000 

feet amsl in elevation. Alluvial fans spilling from surrounding mountain ranges fill the valleys, often leaving little 

intervening flat ground. Wyoming big sagebrush and associated grasses are common on the flatter areas, and black 

sagebrush dominates on the volcanic hills and alluvial fans. This ecoregion tends to have a lower species diversity

than many other sagebrush-dominated ecoregions (including the Carbonate Sagebrush Valleys ecoregion) because of 

its aridity and its isolation from more species-rich areas. Saline playas may occur on available flats. Less shadscale 

and fewer associated shrubs surround these playas compared to other lower, more arid ecoregions to the west. Valleys 

with permanent water support endemic fish species, such as the Monitor Valley speckled dace. 

3.4.2.5 Central Nevada Mid-slope Woodland and Brushland 

The Central Nevada Mid-slope Woodland and Brushland ecoregion at 6,500 to 8,000 feet amsl is analogous in 

altitudinal range to other woodland areas in Nevada. However, continuous woodland is not as prevalent on the 

mountains of central Nevada as in other woodland ecoregions. Pinyon–juniper grows only sparsely through the shrub 

layer due to the combined effects of past fire, logging, and local climate factors, including lack of summer rain and 

the pattern of winter cold air inversions. Where extensive woodlands do exist, understory diversity tends to be very 

low, especially in closed canopy areas. Areas of black and Wyoming big sagebrush grade upward into mountain big 

sagebrush and curl-leaf mountain mahogany, which straddles the transition between this mid-elevation brushland and 

the mountain brush zone of the higher Central Nevada Bald Mountains ecoregion. 

3.4.2.6 Central Nevada Bald Mountains 

The Central Nevada Bald Mountains ecoregion is dry and mostly treeless. Although they rise only a hundred miles 

east of the Sierra Nevada, they lack Sierra Nevada species because of the dry conditions. These barren-looking 

mountains are covered instead by dense mountain brush that is dominated by mountain big sagebrush, western 

serviceberry, snowberry, and low sagebrush. In moister microsites, scattered groves of curl-leaf mountain mahogany 

and aspen grow above the shrub layer. A few scattered limber pines grow on ranges that exceed 10,000 feet amsl. The 

Toiyabe Range, which is a few miles to the east of the project area, is high enough to have an alpine zone, but it lacks 

a suitable substrate to retain snowmelt moisture. The isolation of these “sky islands” has led to the evolution of many 

rare and endemic plant species. 

3.4.2.7 Upper Lahontan Basin 

The Upper Lahontan Basin ecoregion lies outside of the rain shadow cast by the Sierra Nevada and records somewhat 

higher rainfall and cooler temperatures than other portions of the Lahontan Basin. It is characterized by the shadscale 

and greasewood plant community, with Thurber’s needlegrass common in the understory. This ecoregion has a 

shorter growing season than the rest of the Lahontan Basin. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-27 October 2016

3.4.2.8 Salt Deserts 

The Salt Deserts ecoregion is composed of nearly level playas, salt flats, mud flats, and saline lakes. These features 

are characteristic of those in the Bonneville Basin; they have a higher salt content than the Lahontan and Tonopah 

Playas. Water levels and salinity fluctuate from year to year; during dry periods salt encrustation and wind erosion 

occur. Vegetation is mostly absent although scattered salt-tolerant plants, such as pickleweed, iodine bush, black 

greasewood, and inland saltgrass, occur. Soils are not arable, and there is very limited grazing potential. The salt 

deserts provide wildlife habitat, and serve some recreational, military, and industrial uses. 

3.4.2.9 Shadscale-dominated Saline Basins 

The Shadscale-dominated Saline Basins ecoregion is arid, internally drained, and gently sloping to nearly flat. These 

basins are higher in elevation and colder in winter than the Lahontan Salt Shrub Basin to the west. Light-colored soils 

with high salt and alkali content occur and are dry for extended periods. The saltbush vegetation common to 

Shadscale-dominated Saline Basins Ecoregion has a higher tolerance for extremes in temperature, aridity, and salinity 

than big sagebrush, which dominates the Sagebrush Basins and Slopes ecoregion at somewhat higher elevations. The 

basins in Nevada, in contrast to those in Utah, are more constricted in area and more influenced by nearby carbonate 

mountain ranges, which provide water by percolation through the limestone substrate to valley springs. Isolated valley 

drainages support endemic fish, such as the Newark Valley tui chub. 

3.5 Meteorology and Climate Change 

3.5.1 Regulatory Framework 

On October 30, 2009, the USEPA published a rule for the mandatory reporting of greenhouse gases (40 CFR § 98) 

from large greenhouse gas emissions sources in the U.S. Implementation of 40 CFR § 98 is referred to as the 

Greenhouse Gas Reporting Program. 40 CFR § 98 applies to direct greenhouse gas emitters, fossil fuel suppliers, and 

industrial gas suppliers. This comprehensive, nationwide emissions data will provide a better understanding of where 

greenhouse gases are coming from and will guide development of the policies and programs to reduce emissions. The 

publicly available data will allow greenhouse gas emitters to track their own emissions and compare them to similar 

facilities, and aid in identifying cost effective opportunities to reduce emissions in the future. In general, the threshold 

for reporting is 25,000 metric tons or more of carbon dioxide (CO2) equivalent per year. Reporting is at the facility 

level, except for certain suppliers of fossil fuels and industrial greenhouse gases. An estimated 85 to 90 percent of the 

total U.S. greenhouse gas emissions from approximately 10,000 facilities are covered by this final rule. Most small 

businesses and mining operations would fall below the 25,000 metric ton threshold and are not required to report 

greenhouse gas emissions to the USEPA. 

3.5.2 Affected Environment 

3.5.2.1 Meteorology 

Limited meteorological data have been collected in the 3 Bars Project area. Baseline meteorological conditions 

representative of the project area were assessed using data from nearby monitoring stations in north-central Nevada. 

Meteorological data from the Elko, Nevada airport, 70 miles north of the project area, was utilized for climate 

characterization. The Elko monitoring station measures ambient temperature, wind speed, wind direction, and 
METEOROLOGY AND CLIMATE CHANGE 

3 Bars Project Final EIS 3-28 October 2016

precipitation at an elevation of approximately 5,080 feet amsl. Meteorological data from the Mercury-Desert Rock 

monitoring station was also used because the Nevada Bureau of Air Pollution Control (Nevada BAPC) determined 

that the meteorological data at that site are most representative for the project area. 

Local climatic factors include the occurrence of cold air inversions during winter and scarce summer rain. Average 

maximum temperatures are 86 degrees Fahrenheit (°F) in July, while average minimum temperatures are 17 °F in 

January. 

Mean annual precipitation varies directly with elevation, ranging from approximately 8 inches per year in the lower 

valley floors, up to approximately 18 inches per year at the highest elevations in the Roberts Mountains (USDA 

Natural Resources Conservation Service 1998). Most of the study area receives between 10 and 16 inches of 

precipitation in an average year. Nearby long-term regional climate stations are at Eureka (station elevation 6,540 feet 

amsl) and at a USDA site to the north in Diamond Valley (station elevation 5,970 feet amsl). For the Eureka station, 

averages are indicated in Table 3-3 (Western Regional Climate Center 2012). 

The precipitation climate in the project area is classified as arid, with elevations below 6,500 amsl feet receiving the 

least amount of precipitation (5 to 9 inches per year), while the mountainous areas are significantly wetter, receiving 

11 to over 16 inches of precipitation annually (Western Regional Climate Center 2012). An arid climate is 

characterized by low rainfall, low humidity, clear skies, and relatively large annual and diurnal temperature ranges. 

Net evaporation exceeds precipitation in the project area. 

Most precipitation accumulates as snow on the mountain ranges. During the spring snowmelt period, water flows 

from the mountain ranges into the basin fill deposits. As water flows from areas of bedrock outcrop in the mountains 

toward the valley, it rapidly infiltrates into the basin fill deposits along the range fronts. Thus, most recharge into the 

basin fill deposits occurs along the margins of the valleys or at higher elevations and not in the central portion of the 

valleys. However, some streams may flow into the central valley during times of high runoff, causing water to 

accumulate in the playas (Western Regional Climate Center 2012). 

The BLM operated 3 flow-recording stations and 20 bulk precipitation collection stations in the Coils Creek 

watershed, a 50-square mile area in the northwestern part of Kobeh Valley, from 1963 to 1980 (Houng-Ming et al. 

1983 cited in USDOI BLM 2012b). The average annual precipitation was 11.4 inches during the period, but they did 

not find an increase in precipitation with altitude, which is uncommon in the Great Basin, where orographic lift 

effects usually produce a well-defined elevation-to-precipitation relationship. Orographic lift occurs when an air mass 

is forced from a low elevation to a higher elevation as it moves over rising terrain, and often generates clouds and 

precipitation. The precipitation data from the Coils Creek watershed may indicate unusual storm tracks, a lack of 

orographic lift effect, or potentially a data problem that cannot be resolved with existing information (Montgomery 

and Associates 2010). 

3.5.2.2 Climate Change 

Ongoing scientific research has identified the potential impacts of man-made greenhouse gas emissions and changes 

in biological carbon sequestration due to land management activities on global climate. Through complex interactions 

on a regional and global scale, these greenhouse gas emissions cause a net warming effect of the atmosphere, 

primarily by decreasing the amount of heat energy radiated by the earth back into space. Although greenhouse gas 

levels have varied for millennia, recent industrialization and burning of fossil fuels have caused carbon dioxide (CO2 ; 

a greenhouse gas) concentrations to increase dramatically, and are likely to contribute to overall global climatic 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-29 October 2016

changes. The Intergovernmental Panel on Climate Change (2007) concluded that “warming of the climate system is 

unequivocal” and “most of the observed increase in globally average temperatures since the mid-20th century is very 

likely due to the observed increase in anthropogenic greenhouse gas concentrations.”

Several activities contribute to the phenomena of climate change, including emissions of greenhouse gasses 

(especially CO2 and methane) from fossil fuel development, large wildfires, and activities using combustion engines; 

changes to the natural carbon cycle; and changes to radiative forces and reflectivity from the earth’s surface (albedo). 

It is important to note that greenhouse gasses would have a sustained climatic impact over different temporal scales. 

For example, recent emissions of CO2 can influence climate for more than 100 years (Intergovernmental Panel on 

Climate Change 2007). 

Global mean surface temperatures have increased nearly 1.8 °F from 1890 to 2006. Models indicate that average 

temperature changes are likely to be greater in the Northern Hemisphere. Northern latitudes (above 24° North) have 

exhibited temperature increases of nearly 2.1 °F since 1900, with nearly a 1.8 °F increase since 1970. Without 

additional meteorological monitoring systems, it is difficult to determine the spatial and temporal variability and 

change of climatic conditions, but increasing concentrations of greenhouse gasses are likely to accelerate the rate of 

climate change. 

TABLE 3-3 

Monthly Climate Summary for Eureka, Nevada (1888 through 2012) 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

Precipitation 

(inches) 1.07 1.05 1.34 1.34 1.42 0.84 0.68 0.78 0.77 0.89 0.78 0.89 11.85

Total Snowfall

(inches) 9.4 9.8 10.2 7.0 3.7 0.4 0.1 0.0 0.6 2.4 6.1 9.4 59.0

Average 

Maximum 

Temperature 

(°F)

38.3 41.2 48.3 57.0 66.0 77.2 86.4 84.3 74.9 63.3 48.8 39.7 60.4

Average 

Minimum 

Temperature 

(°F)

17.1 19.2 23.9 28.9 36.4 44.1 52.9 52.0 43.7 34.6 24.5 18.3 33.0

Source: Western Regional Climate Center (2012). 

In 2001, the Intergovernmental Panel on Climate Change indicated that by the year 2100 global average surface 

temperatures would increase 2.5 to 10.4 °F above 1990 levels. The National Academy of Sciences (2010) agreed with 

these findings, but also has indicated there are uncertainties regarding how climate change may affect different 

regions. Computer model predictions indicate that increases in temperature would not be equally distributed, but are 

likely to be accentuated at higher latitudes. Warming during the winter months is expected to be greater than during 

the summer, and increases in daily minimum temperatures are more likely than increases in daily maximum 

temperatures. Increases in temperatures would increase water vapor in the atmosphere and reduce soil moisture, 

which would increase generalized drought conditions and enhance heavy storm events. Although large-scale spatial 

shifts in precipitation distribution may occur, these changes are more uncertain and difficult to predict. 
METEOROLOGY AND CLIMATE CHANGE 

3 Bars Project Final EIS 3-30 October 2016

Karl et al. (2009) assessed the effects of global climate change impacts in the U.S. They noted that the average 

temperature in the Southwestern U.S. has increased about 1.5 °F compared to the 1960-1979 baseline, and is 

predicted to increase 4 to 10 °F above the historical baseline by the end of the century. Although the Southwest 

experiences frequent droughts, recent warming in the Southwest is among the most rapid in the nation. This is causing 

declines in spring snowpack and water in some areas in the Southwest has become limited. Climate change is 

projected to cause substantial reductions in rain and snowfall in the spring months, when precipitation is most needed 

to fill reservoirs. Despite the greater likelihood of drought, however, the incidence of flooding is expected to increase 

as the precipitation rate exceeds the infiltration rate, with a trend toward both more frequent extremely dry and 

extremely wet winters. With warmer temperatures, more precipitation will fall as rain than as snowfall. The increase 

in rain on snow events will also cause rapid runoff and flooding. 

Because of temperature increases, pinyon-juniper woodlands in portions of the Southwest are dying off, and area 

burned by wildfires is expected to increase. However, where fire is limited by the availability of fine fuels, such as 

occurs in the 3 Bars Project area, fire frequency is expected to decrease. Temperature increase is projected to increase 

the amount of grassland acreage, and acreage dominated by invasive vegetation, such as red brome, that do well in 

high temperatures (Karl et al. 2009). There is concern that as climate change places greater stress upon vegetation, 

soil, water, and other resources on public lands, that it will be necessary to reduce the effects of other stressors, 

including livestock, wild horses, and other ungulates by reducing their numbers or spreading out their use in areas 

where they are abundant (Reisner 2010, Beschta et al. 2013). At the least, it will require that the BLM monitor the 

effects of livestock and other ungulates on the health of public lands, including the 3 Bars Project area, as the climate 

warms. 

Climate change is predicted to increase water temperature in most regions including the arid Southwest (Meyer et al. 

1999). The effect of increased water temperature on aquatic habitat and species could include changes in water quality 

(e.g., dissolved oxygen) and biological conditions such as direct mortality from acute temperature stress, sublethal 

stress on physiological functions, and shifts in species distributions. In North America, the Intergovernmental Panel 

on Climate Change predicted that coldwater fisheries would likely be adversely affected, warmwater fish species 

generally would be positively affected, and cool water fisheries would have a mixture of positive and negative 

changes in terms of habitat conditions and species distribution and diversity. In general, climatic warming would 

result in a general shift in species distributions northward, with extinctions of cool-water species at lower altitudes and 

range expansion of warmwater and cool-water species into higher altitudes (Meyer et al. 1999). 

As a means of assessing the vulnerability of species to climate change, NatureServe initiated a collaborative effort to 

develop a Climate Change Vulnerability Index (Young et al. 2009). The Index was applied to a selection of test 

species in Nevada, where it will be used to modify the State Wildlife Action Plan by incorporating climate change 

species information. Based on this initial case study (Young et al. 2009) and subsequent analyses by the Nevada 

Natural Heritage Program (2011), vulnerability index ratings for aquatic species provide some indication of potential 

effects of climate change in Nevada. The index score was moderately vulnerable for Lahontan cutthroat trout, a 

federally listed threatened species under the Endangered Species Act that is found on the 3 Bars Project area. The 

analysis also predicted that the abundance and/or range extent of this species within the geographical area assessed 

likely would decrease by 2050. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-31 October 2016

3.5.3 Environmental Consequences 

3.5.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, a number of concerns specific to meteorology and climate were

identified and are discussed in the previous section and this section. These include: 

 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, 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 the 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. 

3.5.3.2 Direct and Indirect Effects 

3.5.3.2.1 Direct and Indirect Effects Common to All Action Alternatives 

The combustion of fossil fuels would release CO2 to the atmosphere. The use of chainsaws, and vehicles to transport 

workers, would be the primary sources of CO2 emissions common to all alternatives. These emissions would have a 

negligible effect on global climate change. Treatments would help to improve ecosystem health and reduce the risk of 

wildfire and associated smoke emissions, to the benefit of the global climate. 

3.5.3.2.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Prescribed fire and wildland fire for resource benefit, and use of equipment for mechanical treatments and to transport 

workers, would be the primary sources of CO2 emissions. ENSR (2005a) modeled annual CO2 emissions for BLM 

vegetation treatments for the 17-States PEIS and PER (USDOI BLM 2007b, c). Based on modeling done for Nevada, 

the acreage treated on the 3 Bars Project area would comprise about 4 percent of acres treated by the BLM annually in 

Nevada and would contribute about 19,115 tons of CO2 to the atmosphere annually. The actual amount of emissions 

could vary from estimates from modeling based on differences in the acres and types of vegetation treated under each 

method. However, in the context of CO2 emissions from BLM treatments in Nevada, and from other sources of 

CO2 emissions in the region, CO2 emissions for the 3 Bars Project would be negligible. 

Based on 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 CO2 emissions than wildfires of the same size. The Association for Fire Ecology 

and others (2013) noted that prescribed fires can be used to reduce the risk of wildfire and help to promote a stable 
METEOROLOGY AND CLIMATE CHANGE 

3 Bars Project Final EIS 3-32 October 2016

and resilient ecosystem and long-term carbon sequestration. Treatments to improve the health and resiliency of native 

vegetation, thin and remove pinyon-juniper, create fire and fuel breaks, and control cheatgrass and other noxious 

weeds and other invasive non-native vegetation should help to reduce the occurrence and spread of wildfire and 

associated CO2 emissions from wildfire smoke. 

3.5.3.2.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, the BLM would not use prescribed fire and wildland fire for resource benefit and thus CO2 

emissions from those sources would not occur under this alternative. Mechanical treatments contribute negligible 

amounts of CO2 emissions. Based on modeling, the 3 Bars Project would contribute about 5,600 tons of CO2 to the 

atmosphere annually under Alternative B. The actual amount of emissions could vary from estimates from modeling 

based on differences in the acres and types of vegetation treated under each method. Because prescribed fire and 

wildland fire for resource benefit would not be used under this alternative to thin and remove pinyon-juniper and 

improve the health and resiliency of native vegetation, the occurrence of wildfire and associated smoke production 

may be greater under this alternative than under Alternative A. 

3.5.3.2.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

The BLM would only use manual and classical biological treatments under Alternative C. Based on modeling, these 

methods would contribute only about 2 tons of CO2 emissions annually. Because these treatments would do little to 

improve ecosystem health and reduce wildfire risk, smoke emissions from wildfire would likely be greater under this 

alternative than under Alternatives A and B. 

3.5.3.2.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct CO2 emissions under this alternative as no treatments would be authorized. The BLM would 

not create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of 

noxious weeds and other invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the 

ecosystem; or reduce the risk of a large-scale wildfire. Thus, the 3 Bars Project area would be subject to large-scale 

wildfires with potentially uncontrolled dense smoke emissions. Carbon dioxide emissions from wildfires would likely 

be greater under Alternative D than under the action alternatives. 

3.5.3.3 Cumulative Effects 

The effects of changing climate on future fire regimes and CO2 emissions are difficult to predict, not only due to 

uncertainties associated with future climate, but because of interactive effects between climate change, biological 

factors, and vegetation treatment activities, and politics. 

Cumulative impacts to climate change could result from CO2 emissions from a number of sources within the CESA 

that are associated with reasonably foreseeable land development and utility and infrastructure projects. Mechanical 

equipment would be used during construction of utility and infrastructure projects, and construction workers and users 

of the facilities would travel by vehicle to project sites. Wildfires will continue to be the primary contributors to 

CO2 emissions in the CESA. Technology, however, will continue to play an important role in reducing CO2 emissions 

from engine operations. Increasing carbon storage and reducing the amount of CO2 released to the atmosphere can 

also be achieved by reducing the rate of logging and by preserving older trees (DellaSala 2009). 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-33 October 2016

3.5.3.4 Significance of the Effects under the Alternatives 

A significant effect on climate is not likely to be caused by BLM restoration activities. Treatments that improve 

ecosystem health and reduce hazardous fuels buildup, thereby reducing the risk of wildfire, should provide long-term 

benefits to local and regional air quality and climate (USDOI BLM 2007c:4-9). Nationally, there were about 7,385 

million tons of greenhouse gas emissions in 2011 (USEPA 2012b). The Mount Hope Project would be a contributor 

to greenhouse gases, and based on modeling, would emit up to approximately 604,000 tons per year of greenhouse 

gases, or approximately 0.00008 percent of the national annual emissions. Other developments in the CESA would 

contribute negligible amounts of greenhouse gases. The 3 Bars Project would contribute about 0.000003 percent to 

the national annual greenhouse gas emissions under Alternative A, and even less under the other alternatives. 

3.6 Air Quality 

Air quality is defined by the concentration of various pollutants and their interactions in the atmosphere. Pollution 

effects on receptors have been used to establish a definition of air quality. Measurement of pollutants in the 

3

atmosphere is expressed in units of parts per million (ppm) or μg/m . Both long-term climatic factors and short-term 

weather fluctuations are considered part of the air quality resource because they control dispersion and affect 

concentrations. Physical effects of air quality depend on the characteristics of the receptors and the type, amount, and 

duration of exposure. Air quality standards specify acceptable upper limits of pollutant concentrations and duration of 

exposure. Air pollutant concentrations within the standards generally are not considered to be detrimental to public 

health and welfare (USEPA 2012). 

3.6.1 Regulatory Framework 

Ambient air quality and the emission of air pollutants are regulated under both federal and state laws and regulations. 

Regulations potentially applicable to the proposed action and alternatives include the following: Federal Clean Air 

Act (Clean Air Act) and National Ambient Air Quality Standards (NAAQS), Nevada AAQS, Prevention of 

Significant Deterioration (PSD), New Source Performance Standards, Federal Operating Permit Program (Title V), 

and State of Nevada air quality regulations (Nevada Administrative Code 445B). 

3.6.1.1 Federal Clean Air Act and National Ambient Air Quality Standards 

The Clean Air Act and the subsequent Clean Air Act amendments of 1990 require the USEPA to identify NAAQS to 

protect the public health and welfare. The Clean Air Act and amendments establish NAAQS for seven pollutants, 

known as “criteria” pollutants because the ambient standards set for these pollutants satisfy “criteria” specified in the 

Clean Air Act. The criteria pollutants regulated by the Clean Air Act and their applicable NAAQS set by the USEPA 

are listed in Table 3-4. The list of criteria pollutants is amended by the USEPA as needed to protect public health and 

welfare. The most recent revisions include amendments to standards for the following pollutants (dates represent 

publication in the Federal Register): particulate matter less than 2.5 micrometers in aerodynamic diameter (PM2.5) and 

particulate matter less than ten micrometers in aerodynamic diameter (PM10; October 2006), ozone (O3; March 2008), 

lead (Pb; November 2008), nitrogen dioxide (NO2; February 2010), and sulfur dioxide (SO2; June 2010). 
AIR QUALITY 

3 Bars Project Final EIS 3-34 October 2016

TABLE 3-4 

National and Nevada Ambient Air Quality Standards 

Pollutant Averaging 

Time Nevada Standards1 National Standards1

Primary Secondary

Ozone (O3)

1-Hour 235 235 235

8-Hour NA 157 157

Carbon monoxide (CO) 1-Hour 40,500 40,000 40,000

CO less than 5,000 feet amsl 8-Hour 10,500 10,000 10,000 CO at or greater than 5,000 feet amsl 8-Hour 7,000

Sulfur dioxide (SO2)

1-Hour NA 197 NA

3-Hour 1,300 N/A 1,300

24-Hour 365 NA NA

Annual Average 80 NA NA

Nitrogen dioxide (NO2)

1-Hour2 NA 189 NA

Annual Average 100 100 100

Particulate matter with aerodynamic 

diameter of 10 microns or less (PM10)

24-Hour 150 150 150

Annual Average 50 NA NA

Particulate matter with aerodynamic 

diameter of 2.5 microns or less (PM2.5)

24-Hour 35 35 35

Annual Average 12 12 12

1

 Micrograms per cubic meter (μg/m3).

2 To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitoring site within an 

area must not exceed 189 μg/m3 (0.100 parts per million [ppm]). 

N/A = Not applicable. 

Sources: Nevada Division of Environmental Protection (2012) and USEPA (2012b).

3.6.1.2 Nevada State Ambient Air Quality Standards 

The Nevada Administrative Code 445B.22097 includes AAQS for the State of Nevada (Table 3-4). The Nevada 

AAQS are generally identical to the NAAQS, with the exception of the following: 

 Nevada has not formally adopted the 8-hour O3 standard adopted by the USEPA in 2008. 

 Nevada has not formally adopted the recently promulgated 1-hour NAAQS standards for NO2 and SO2. 

 Nevada retains the state standard for PM10 (annual arithmetic mean) where the comparable NAAQS standard 

was revoked by the USEPA in 2006. 

 Nevada has not formally adopted the 24-hour and annual NAAQS standards for PM2.5 promulgated by 

USEPA in 2006. 

 Nevada has an additional state standard for carbon monoxide (CO) in areas with an elevation in excess of 

5,000 feet amsl. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-35 October 2016

3.6.1.3 Attainment and Non-attainment Areas and Prevention of Significant 

Deterioration 

Pursuant to the Clean Air Act, the USEPA has developed classifications for distinct geographic regions known as air 

quality management areas. Under these classifications, for each federal criteria pollutant, each air basin (or portion of 

an air quality management area [AQMA or “planning area”]) is classified as “in attainment” if the AQMA has 

“attained” compliance with (i.e., not exceeded) the adopted NAAQS for that pollutant; is classified as “nonattainment” if the levels of ambient air pollution exceed the NAAQS for that pollutant; or is classified as 

“maintenance” if the monitored pollutants have fallen from non-attainment levels to attainment levels. Air quality 

management areas for which sufficient ambient monitoring data are not available are designated as “attainment 

unclassifiable” for those particular pollutants until actual monitoring data support formal “attainment” or “nonattainment” classification. 

In addition to the designations relative to attainment of conformance with the NAAQS, the Clean Air Act requires the 

USEPA to place each planning area within the U.S. into one of three PSD classes, which are designed to limit the 

deterioration of air quality when it is “better than” the NAAQS. “Class I” is the most restrictive air quality category 

and was created by Congress to prevent further deterioration of air quality in National Parks and Wilderness Areas of 

a given size which were in existence prior to 1977, or those additional areas that have since been designated Class I 

under federal regulations (40 CFR § 52.21). All remaining areas outside of the designated Class I boundaries were 

designated Class II planning areas, which allow a relatively greater deterioration of air quality. For future redesignation purposes, Congress defined as Class III any existing Class II area for which a state may desire to promote 

a higher level of industrial development (and emissions growth). Thus, Class III areas are allowed to have the greatest 

amount of pollutant increase of the three area classes while still achieving the NAAQS. There have been no Class III 

re-designations to date. Regardless of the class of the planning area, the air quality cannot exceed the NAAQS. The 

nearest Class I planning area to the project, the Jarbridge Wilderness Area, is approximately 130 miles northeast of 

the project area. There are no Class I airsheds within 60 miles of the project area. 

Federal PSD applicability regulations limit the maximum allowable increase in ambient particulate matter in a Class I 

3 3

planning area, resulting from a major or minor stationary source, to 4 μg/m (annual geometric mean) and 8 μg /m

3

(24-hour average). For Class II planning areas, the maximum allowable increase is 17 μg/m (annual geometric mean) 

3

and 30 μg/ m (24-hour average). Specific types of facilities that emit, or have the potential to emit, 100 tons per year 

(tpy) or more of PM10 or other criteria air pollutants, or any facility that emits, or has the potential to emit, 250 tpy or 

more of PM10 or other criteria air pollutants, is considered a major stationary source. A stationary source that emits 

less than 100 tpy of criteria pollutants and less than 10 tpy of individual hazardous air pollutants, and less than 25 tpy 

of hazardous air pollutants in the aggregate, would be considered a minor source. The proposed 3 Bars Project would 

be classified as a minor source. 

Fugitive emissions are not included as part of the calculation to determine if a proposed source is a major source of 

emissions for PSD purposes. Permit applicants for proposed major stationary sources or major modification to a 

source are required to notify federal land managers of Class I planning areas within 60 miles of the new or modified 

major stationary source. There are no Class I planning areas within 60 miles of the project area. Air pollutant emission 

sources under the proposed action and alternatives, including from prescribed burning, are minor stationary sources 

that are not subject to PSD regulatory requirements. 
AIR QUALITY 

3 Bars Project Final EIS 3-36 October 2016

Since the proposed 3 Bars Project would not be a PSD source, there is no air quality permit requirement to assess 

impacts to Class I areas; however, Class I areas are protected by federal land managers who manage air quality related 

values (AQRVs) such as visibility and atmospheric deposition. Though not a regulatory program under PSD, federal 

land managers review the issuance of a PSD permit for any impacts that exceed guideline thresholds for visibility, 

atmospheric deposition, and changes in the acid neutralizing capacity of sensitive lakes. The federal land managers 

consider a source greater than 30 miles from a Class I area to have negligible impacts with respect to Class I AQRVs 

if the total SO2, nitrous oxides (NOx), PM10, and sulfuric acid (H2SO4) annual emissions (in tons per year, based on 

24-hour maximum allowable emissions), divided by the distance (in kilometers [km]) from the Class I area (Q/D), is 

10 or less. In general, the Federal Land Managers’ Air Quality Related Values Work Group recommends that an 

applicant apply the Q/D test for proposed sources greater than 50 km (30 miles) from a Class I area to determine 

whether or not any further AQRV analysis is necessary (USDA Forest Service et al. 2010). Federal agencies would 

not request any further Class I AQRV impact analyses from sources with a Q/D ratio that is 10 or less. 

3.6.1.4 Nevada Air Quality Operating Permit 

The Clean Air Act delegates primary responsibility for air pollution control to state governments, which in turn often 

delegate this responsibility to local or regional organizations. The State Implementation Plan was originally the 

mechanism by which a state set emission limits and allocated pollution control responsibility to meet the NAAQS. 

The function of a State Implementation Plan broadened after passage of the Clean Air Act and now includes the 

implementation of specific technology based emission standards, permitting of sources, collection of fees, 

coordination of air quality planning, and PSD of air quality within regional planning areas and statewide. Section 176 

of the Clean Air Act, as amended, requires that federal agencies must not engage in, approve, or support in any way 

any action that does not conform to a State Implementation Plan for the purpose of attaining ambient air quality 

standards. 

The Nevada Bureau of Air Pollution Control (BAPC) is the agency in the State of Nevada with the responsibility for 

implementing a State Implementation Plan (excluding Washoe and Clark Counties, which have their own State 

Implementation Plans). Included in a State Implementation Plan are the State of Nevada air quality permit programs 

(Nevada Administrative Code 445B.001 through 445B.3485, inclusive) and the Nevada State AAQS (Table 3-4). In 

addition to establishing the Nevada State AAQS, the Nevada BAPC is responsible for permit and enforcement 

activities throughout the State of Nevada (except in Clark and Washoe Counties). 

The 3 Bars Project is in Eureka County, Nevada. The applicable permitting authority for the county is the Nevada 

BAPC. Before any construction of a potential source of air pollution can occur, an air quality operating permit 

application must be submitted to the Nevada BAPC in order to obtain an Air Quality Operating Permit. 

3.6.1.5 Burn Management 

The Battle Mountain District Fire Management Plan (Fire Management Plan) was approved in 2004 and provides 

program guidance based on the Land-use Plan Amendment for Fire Management for the Shoshone-Eureka RMP

(USDOI BLM 2004a). Fire management in the 3 Bars Project area is discussed in more detail in Section 3.14, 

Wildland Fire. 

The Eureka County Master Plan discusses air quality and makes these recommendations regarding air quality within 

the County (Eureka County 2010). These include: 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-37 October 2016

 Prevent significant deterioration of the superior air quality found in Eureka County. 

 Review best management practices as necessary to assure applicability and compliance. 

3.6.2 Affected Environment 

3.6.2.1 Study Methods and Study Area 

No air quality data have been collected in the 3 Bars Project area. Baseline air quality conditions representative of the 

project area were assessed using data from nearby monitoring stations in north-central Nevada. Meteorological data 

from the Elko, Nevada, airport (WBO262573), 70 miles north of the project area, were used for climate 

characterization (Figure 3-1). Upper air meteorological data from the Mercury-Desert Rock monitoring station, about 

200 miles south of the project area, were used for air dispersion modeling. The Mercury-Desert Rock monitoring 

station was used because the Nevada BAPC determined that the meteorological data at that site are most 

representative for the project area. 

The study area for direct and indirect impacts to air quality is the 3 Bars Project area and local airshed. The 

cumulative effects study area includes the Hydrologic Unit Code 10 watersheds that are all or partially included in the 

3 Bars Project area. 

3.6.2.2 Air Quality 

The air quality within the study area is typical of the largely undeveloped regions of the western U.S. For the purposes 

of statewide regulatory planning, the area has been designated as in attainment for all pollutants that have an AAQS. 

Important sources of air pollutants in the area include several precious metals mines that are sources for PM10 and 

PM2.5. No areas in Nevada are currently designated as nonattainment of the PM2.5 standard. There is a lack of 

sufficient data to develop a comprehensive emissions inventory for PM2.5 from mine sources; nevertheless, an 

acceptable approach for assessing PM2.5 emissions from fugitive dust sources is to use a percentage of the PM10

emissions. 

Three important meteorological factors influence the dispersion of pollutants in the atmosphere—mixing height, wind 

(speed and direction), and stability. Mixing height is the height above ground within which rising warm air from the 

surface would mix by convection and turbulence. Local atmospheric conditions, terrain configuration, and pollutant 

source location determine dilution of pollutants in this mixed layer. Mixing heights vary diurnally, with the passage of 

weather systems, and with season. For the study area, the mean annual morning mixing height is estimated to be 

approximately 1,000 feet amsl; however, during the winter months the mean morning mixing height is approximately 

80 feet above ground (Holzworth 1972). The mean annual afternoon mixing height exceeds 7,400 feet amsl. 

Wind speed has an important effect on area ventilation and the dilution of pollutants. Light winds, in conjunction with 

large source emissions, may lead to an accumulation of pollutants that can stagnate or move slowly to downwind 

areas. During stable conditions, downwind usually means down valley or toward lower elevations. Climate data from 

Elko indicate that the potential for air pollution episodes to last 5 or more days is nearly zero (Holzworth 1972). A 

potential air pollution episode is defined as a period of time with wind speeds less than 4 miles per hour and mixing 

heights less than 3,300 feet amsl. 
AIR QUALITY 

3 Bars Project Final EIS 3-38 October 2016

Morning atmospheric conditions tend to be stable because of the rapid cooling of the layers of air nearest the ground. 

Afternoon conditions, especially during the warmer months, tend to be neutral to unstable because of the rapid heating 

of the surface under clear skies. During the winter, periods of stable afternoon conditions may persist for several days 

in the absence of the synoptic (continental scale) storm systems that can generate higher winds with more turbulence 

and mixing. A high frequency of inversions at lower elevations during the winter can be attributed to the nighttime 

cooling and sinking air flowing from higher elevations to the low-lying areas in the basins. Although winter 

inversions are generally not very deep, they tend to be more stable because of reduced surface heating (Holzworth 

1972). 

Because of the typically dry atmosphere, bright sunny days and clear nights frequently occur. This in turn allows 

rapid heating of the ground surface during daylight hours and rapid cooling at night. Since heated air rises, and cooled 

air sinks, winds tend to blow uphill during the daytime and down slope at night. This upslope and down slope cycle 

generally occurs in all the geographical features, including mountain range slopes and river courses. The volume of 

air affected depends on the area of the feature; the larger the horizontal extent of the feature, the greater the volume of 

air that moves in the cycle. The complexity of terrain features causes complex movements in the cyclic air patterns, 

with thin layers of moving air embedded within the larger scale motions. The lower level, thermally driven winds also 

are embedded within larger-scale upper wind (synoptic) systems. Synoptic winds in the region are predominantly 

west to east, characterized by daily weather variations that enhance or diminish the boundary layer winds, and 

significantly channeled by regional and local topography (Western Regional Climate Center 2012).

3.6.3 Environmental Consequences 

3.6.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, one commenter asked that the current air quality be assessed and 

the impacts to air from multiple or overlapping treatments be assessed. 

3.6.3.2 Significance Criteria 

Impacts to air quality would be considered significant if BLM actions resulted in a: 

 Violation of any regulatory requirement of the Nevada BAPC. 

 Violation of any state or federal ambient air quality standard. 

 Substantial contribution to an existing or projected air quality violation. 

 Exposure of sensitive receptors to substantial pollutant concentrations. 

A substantial contribution to an existing or projected air quality violation could occur if the contribution of projectrelated pollutants results in a violation of the NAAQS, or if the pollutant is among the top percentage contributors to 

the ambient concentrations of pollutants from multiple sources. 

Sensitive receptors include hospitals, schools, daycare facilities, elderly housing, and convalescent facilities. These 

are areas where the occupants are more susceptible to the adverse effects of exposure to toxic chemicals, pesticides, 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-39 October 2016

and other pollutants. Extra care must be taken when dealing with contaminants and pollutants in close proximity to 

areas recognized as sensitive receptors (USEPA 2012c).

3.6.3.3 Direct and Indirect Effects 

3.6.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Effects 

Air quality would be affected by vegetation treatment activities, including dust and combustion engine exhaust from 

manual treatments. However, effects would be small in scale, temporary, and quickly dispersed throughout the 

treatment area. Provided SOPs are followed, and site-specific plans are developed and reviewed before a treatment 

activity occurs, federal, state, and local air quality regulations would not be violated. 

Primary sources of PM10 and PM2.5 emissions include road dust from unpaved roads and wind erosion on disturbed 

land. Emissions also include engine exhaust, tire and brake wear, and fugitive dust generated from travel on paved 

roads. These emissions would have an incremental but insignificant impact on the air quality in the vicinity of roads 

throughout the project area. 

Treatment methods would have minor air quality impacts that would be temporary, transitory, and limited to the 

immediate vicinity of the specific activity. Combustion of diesel in transport trucks and mobile equipment, such as 

loaders, dozers, pickups, etc., would produce emissions of CO, NO2, SO2, PM10, PM2.5, and O3 (from volatile 

organic compound emissions). Hazardous air pollutant emissions would result from the combustion of hydrocarbon 

fuels, and the handling and use of various chemicals. Diesel fuel combustion emissions contain a number of 

hazardous air pollutants including benzene, toluene, ethylbenzene, and xylene. 

The USEPA’s guideline air quality California Puff (CALPUFF) air pollutant dispersion model (referenced in 

Appendix W of 40 CFR § 51) was used to provide example predictions of potential particulate matter (total 

suspended particles, PM10, and PM2.5) impacts that could result from five vegetation management methods at 

receptors located between approximately 1 and 100 km (0.6 and 62 miles) from the assumed center of the modeled 

treatment areas. The nearest receptors were placed 0.5 km (0.3 miles) from the edge of the modeled treatment area 

in each case. Both 24-hour and annual impacts were predicted. CALPUFF “lite” version 5.5 was selected because 

of its ability to screen potential air quality impacts within, as well as beyond, 50 km (31 miles) and its ability to 

simulate plume trajectory over several hours of transport based on limited meteorological data. In Nevada, sources 

that were modeled included fire, unpaved roads used by transportation and ignition vehicles, and fugitive dust 

occurring from pre/post-treatment fuel-break blading (ENSR 2005b). 

This modeling is consistent with general modeling practices described in 40 CFR § 51, Appendix W, and with 

CALPUFF screening procedures outlined by the USEPA. The maximum potential impacts found through modeling 

for each treatment method are summarized here and more details concerning the modeling are available in the 17-

States PEIS and PER (USDOI BLM 2007b, c), and ENSR (2005b). 

Beneficial Effects 

Carefully planned and implemented restoration treatments that reduce hazardous fuel accumulations can reduce the 

risk of wildfire and smoke effects. Manual methods would be an important treatment option in Phase I and Phase II 
AIR QUALITY 

3 Bars Project Final EIS 3-40 October 2016

pinyon-juniper stands or near sensitive areas where the use of other treatment methods is limited. Restoration of 

vegetation in areas that currently consists of bare ground would help to reduce dust emissions. 

Prescribed fire and wildland fire for resource benefit would release dioxins, which are a by-product of biomass 

combustion from wildfire and prescribed fire (Gullett and Touati 2003). Dioxins are highly toxic and can cause 

reproductive and developmental problems, damage the immune system, interfere with hormones and also cause 

cancer. More than 90 percent of human exposure is through food, mainly meat and dairy products, fish and 

shellfish (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. In fact, in the past 

few years, forest fires probably emitted nearly as much dioxin to the environment as did all USEPA-quantified 

sources combined. Dioxin emissions from industrial sources have declined steadily over the past several decades. As 

emissions from these sources are further curtailed through regulation and technology, wildfires should continue to be 

viewed as a major source of dioxins to the environment. 

3.6.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Adverse Effects 

For the 17-States PEIS and PER, the BLM modeled concentration estimates of particulate matter for typical, but 

hypothetical (“example”) emission scenarios for each of the treatment methods at six representative locations 

throughout the western United States (ENSR 2005a, b, USDOI BLM 2007c:4-9). Winnemucca, Nevada, is the closest 

modeling location to the 3 Bars Project area. 

For analysis of air quality impacts in the 17-States PER, it was assumed for manual treatments that the BLM would 

treat up to 5 acres per day using chainsaws or other hand-held equipment, and would drive to and from the work 

site. Table 3-5 shows the modeling results for manual treatments. Total suspended particles, PM10, and PM2.5, from 

manual treatments on the 3 Bars Project area would be negligible and would not exceed ambient air quality 

standards. 

It was assumed that mechanical treatments consisted of 50 acres of mowing and 6 acres of brush blading and piling 

each day. For prescribed fire, it was assumed that 700 acres were treated each day on 6 separate days with prescribed 

fire, that the fire began at 9 a.m. and was extinguished at 6 p.m., and that the fuel combustion rate was 50 percent. All 

treatment scenarios assume that workers and their equipment are transported to the site each day (ENSR 2005b). 

Tables 3-6 and 3-7 show the modeling results for mechanical and prescribed fire treatments based on assumptions 

used in modeling. Modeling indicates that no proposed treatment method would result in significant air quality 

impacts. Total concentrations of particulates are virtually unchanged from background levels, and all project-related 

3

24-hour and annual particulate impacts are less than 1 μg/m . The acreage treated daily for the 3 Bars Project would 

be substantially less than the acreage used to model impacts to air quality from treatment methods. Thus, adverse 

effects on air quality from riparian treatments would be substantially less than those reported in Tables 3-5 to 3-7 and 

would be negligible. 

Fire treatments could expose bare soil and could lead to particulate matter impacts due to wind-blown dust. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Beneficial Effects 

Restoration of riparian, wetland, and spring habitats in areas that currently consist of bare ground would help to 

reduce dust emissions. Fire treatments would be used on only a few acres annually, if at all, and would help to reduce 

hazardous fuels and restore natural fire regimes in riparian zones. Carefully planned and implemented prescribed fire 

should produce far less smoke impact to air quality than uncontrolled wildfires. The BLM would use burn models to 

determine when to burn during periods with good air dispersion (USDOI BLM 2007c:4-10). 

TABLE 3-5

State and National Ambient Air Quality Standards Compliance Analysis for Manual Treatments

3 Bars Project Final EIS 3-41 October 2016

Pollutant Averaging 

Period

CALPUFF Lite 

Concentration 

(μg/m3)

12

Background 

Concentration

(μg/m3) 2

Total 

Concentration 

(μg/m3)

AAQS 

Standard 

(μg/m3) 3

Total Suspended 

Particles

24-hour 

Annual

3.583E-02 

1.007E-04

40

11

40.04

11.00

150

50

PM10

24-hour 

Annual

3.32E-02

9.16E-05

30

8

30.03

8.00

150

50

PM2.5

24-hour 

Annual

3.25E-02

8.92E-05

30

8

30.03

8.00

35

12

1 Values given using exponential notation. For example, 3.58E-02 = 0.0358. 

2 PM10 concentrations are also conservatively used as background concentrations for PM2.5. 

3 There are no Nevada AAQS for total suspended particles or for annual PM10. Values based on 0.33 of 24-hour standard. 

PM10 =Particulate matter with aerodynamic diameter of 10 microns or less. 

PM2.5 =Particulate matter with aerodynamic diameter of 2.5 microns or less. 

μg/m3= Micrograms per cubic meter.

AAQS = Ambient Air Quality Standards. 

Source: ENSR (2005b).

Aspen Treatments 

Adverse Effects 

Modeling indicates that no proposed treatment method for any project groups would result in significant air quality 

impacts. Total concentrations of particulates would be virtually unchanged from background levels, and all project3

related 24-hour and annual particulate impacts would be less than 1 μg/m . Only about 15 acres would be treated 

annually to restore aspen habitat under the proposed action. The acreage treated daily would be substantially less than 

the acreage used to model impacts to air quality from treatment methods. Thus, adverse effects on air quality from 

aspen treatments would be substantially less than those reported in Tables 3-5 to 3-7 and would be negligible. 

Beneficial Effects 

Creating and enhancing fuel breaks in pinyon-juniper stands would break up of the continuity of fuels and moderate 

fire behavior, and reduce the potential for catastrophic wildfire and the associated smoke impacts. Restoration of 

aspen and other vegetation in areas that currently consists of bare ground would help to reduce dust emissions. 
AIR QUALITY 

3 Bars Project Final EIS 3-42 October 2016

TABLE 3-6 

State and National Ambient Air Quality Standards Compliance Analysis for Mechanical Treatments 

Pollutant Averaging 

Period

CALPUFF Lite 

Concentration 

(μg/m3) 1

Background 

Concentration

(μg/m3) 2

Total 

Concentration 

(μg/m3)

AAQS 

Standard 

(μg/m3) 3

Total Suspended 

Particles

24-hour 

Annual

3.53E-02

9.69E-05

40

11

40.04

11.00

150

50

PM10

24-hour 

Annual

1.40E-02

3.84E-05

30

8

30.01

8.00

150

50

PM2.5

24-hour 

Annual

9.68E-03

2.65E-05

30

8

30.01

8.00

35

12

1, 2, 3 See Table 3-5.

PM10 =Particulate matter with aerodynamic diameter of 10 microns or less. 

PM2.5 =Particulate matter with aerodynamic diameter of 2.5 microns or less. 

μg/m3= Micrograms per cubic meter.

AAQS = Ambient Air Quality Standards. 

Source: ENSR (2005b). 

TABLE 3-7 

State and National Ambient Air Quality Standards Compliance Analysis for Prescribed Fire Treatments 

Pollutant Averaging 

Period

CALPUFF Lite 

Concentration 

(μg/m3) 1

Background 

Concentration

(μg/m3) 2

Total 

Concentration 

(μg/m3)

AAQS 

Standard 

(μg/m3) 3

Total Suspended 

Particles

24-hour 

Annual

3.19E-01

8.85E-04

40

11

40.32

11.00

150

50

PM10

24-hour 

Annual

3.19E-01

8.86E-04

30

8

30.32

8.00

150

50

PM2.5

24-hour 

Annual

2.91E-01

8.08E-04

30

8

30.29

8.00

35

12

1, 2, 3 See Table 3-5.

PM10 =Particulate matter with aerodynamic diameter of 10 microns or less. 

PM2.5 = Particulate matter with aerodynamic diameter of 2.5 microns or less. 

μg/m3= Micrograms per cubic meter.

AAQS = Ambient Air Quality Standards. 

Source: ENSR (2005b). 

Pinyon-juniper Treatments 

Adverse Effects 

Prescribed fire treatments in pinyon-juniper treatment units could total several thousand acres annually, while 

wildland fire for resource benefit treatments on the Sulphur Spring Wildfire Management Unit could be used on up to 

1,000 acres per treatment and up to 2,000 acres annually. Nonetheless, the adverse impacts from individual prescribed 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-43 October 2016

fire treatments would be similar to those modeled (700 acres per day, 4,200 total acres per treatment) and shown in

Table 3-7. 

Modeling indicates that no proposed treatment method would result in significant air quality impacts. Total 

concentrations of particulates would be virtually unchanged from background levels, and all project-related 24-hour 

3

and annual particulate impacts would be less than 1 μg/m . Although many acres would be treated under pinyonjuniper treatments, the acreage treated daily should still be less than the acreage used to model impacts to air quality 

from treatment methods. Thus, adverse effects on air quality from pinyon-juniper treatments would likely be less than 

those reported in Tables 3-5 to 3-7 and would be negligible. Fire treatments could expose bare soil and could lead to 

particulate matter impacts due to wind-blown dust. 

Beneficial Effects 

Manual, mechanical, and fire treatments in pinyon-juniper treatment areas would provide several benefits. Creating 

and enhancing fuel breaks in pinyon-juniper stands would break up of the continuity of fuels and moderate fire 

behavior, and reduce the potential for catastrophic wildfire and the associated smoke impacts. Thinning and removal 

of pinyon-juniper in Phase II and III stands should encourage revegetation of bare ground in these stands and reduce 

dust emissions. 

In general, wildfire impacts on air quality would likely be greater than emissions from prescribed burning. Alternative 

A would have greater long-term benefits than the other alternatives since the proposed treatments are intended to 

minimize uncontrolled wildfires and reduce the potential for widespread wildfires in future years, with much less 

potential for widespread dense smoke from these fires to affect nearby receptors. Unlike wildfire, the impacts of 

smoke from prescribed fire are managed. Where smoke impacts from prescribed fire are of concern, fuel 

accumulations can be reduced through manual or mechanical treatments prior to, or instead of, prescribed burning. 

Smoke impacts can also be reduced through scheduling burning for times when the wind is blowing away from 

smoke-sensitive areas and during good dispersion conditions. Scheduling prescribed burns before new fuels 

accumulate can reduce the amount of emissions produced. Fire managers can also reduce the amount of area burned, 

increase the combustion efficiency of a burn, and increase the plume height in order to reduce smoke impacts to air 

quality (USDOI BLM 2007c:4-10). 

The 17-States PER did not analyze the long-term effects on air quality from implementing a vegetation treatment 

management program similar to that proposed under Alternative A. However, an analysis of a similar vegetation 

management program in the Interior Columbia Basin showed that effects from wildfire on air quality and visibility 

could be significantly greater in magnitude than effects from prescribed burning and other treatment methods. As 

discussed in the 17-States PER, and as shown in the Interior Columbia Basin study, particulate matter emissions 

associated with prescribed burning and other treatment methods, when considered alone, should not cause widespread 

regional-scale exceedances of NAAQS. The same would not be true for wildfires. Thus, vegetation treatment actions 

that improve ecosystem health and reduce hazardous fuels buildup, thereby reducing the risk of wildfire, should 

provide long-term benefits to local and regional air quality (USDOI BLM 2007c:4-10). 

Sagebrush Treatments 

Adverse Effects 

Modeling indicates that manual, mechanical, and prescribed fire treatments proposed for sagebrush areas would not 

result in significant air quality impacts. Total concentrations of particulates would be virtually unchanged from 
AIR QUALITY 

3 Bars Project Final EIS 3-44 October 2016

background levels, and all project-related 24-hour and annual particulate impacts would be less than 1 μg/m (Tabl 3 es 

3-5 to 3-7). Adverse effects on air quality from sagebrush habitat treatments would likely be less than those reported 

in Tables 3-5 to 3-7 and would be negligible. 

The BLM may use livestock to control cheatgrass and other non-native vegetation and to increase the effectiveness of 

other treatment methods. Livestock can reduce cheatgrass dominance and can be used to remove some cheatgrass 

before the unit is treated using other methods and seeded. For air quality modeling, it was assumed that vegetation 

could be treated using goats or insects (ENSR 2005b). It was also assumed that 10 acres would be treated per day 

using goats, over a 30-day period, while 100 acres per day would be treated using a hand release of insects. Travel to 

and from the worksite by workers was assumed under both scenarios. Modeled impacts from biological treatment are 

listed in Table 3-8. Adverse effects on air quality from sagebrush habitat treatments would likely be less than those 

reported in Table 3-8 and would be negligible. 

Beneficial Effects 

At sites dominated by herbaceous or invasive species, such as West Simpson Park Unit, up to 50 percent of the area 

could be treated with mechanical methods, and herbicides under existing authorizations. The West Simpson Unit 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 and smoke production. 

TABLE 3-8 

State and National Ambient Air Quality Standards Compliance Analysis for Biological Treatments 

Pollutant Averaging 

Period

CALPUFF Lite 

Concentration 

(μg/m3) 1

Background 

Concentration

(μg/m3) 2

Total 

Concentration 

(μg/m3)

AAQS 

Standard 

(μg/m3) 3

Total Suspended 

Particles

24-hour 

Annual

7.93E-03 

6.01E-05

40

11

40.01

11.00

150

50

PM10

24-hour 

Annual

1.86E-03 

1.42E-05

30

8

30.00

8.00

150

50

PM2.5

24-hour 

Annual

2.59E-04 

1.98E-06

30

8

30.00

8.00

35

12

1, 2, 3 See Table 3-5.

PM10 =Particulate matter with aerodynamic diameter of 10 microns or less. 

PM2.5 =Particulate matter with aerodynamic diameter of 2.5 microns or less. 

μg/m3= Micrograms per cubic meter.

AAQS = Ambient Air Quality Standards. 

Source: ENSR (2005b). 

3.6.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, the BLM would treat approximately half as many acres as under Alternative A, and would not 

be able to use prescribed fire or wildland fire for resource benefit. This alternative would have fewer particulate 

emissions and no smoke emissions compared to Alternative A. Modeling indicates that treatments would not result in 

significant air quality impacts. Total concentrations of particulates would be virtually unchanged from background 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-45 October 2016

3

levels, and all project-related 24-hour and annual particulate impacts would be less than 1 μg/m . Adverse effects on 

air quality from treatments would likely be less than those reported in Tables 3-5 to 3-8 and would be negligible. 

As about half as many acres would be treated annually to reduce hazardous fuels under this alternative than under 

Alternative A. There would be more wildfire risk and resultant smoke impacts could be greater under this alternative 

than Alternative A long-term, since wildfires would generate more smoke than a prescribed burn. It is unlikely that 

the BLM would be able to slow the spread of large infestations of noxious weeds and other invasive non-native 

vegetation, including cheatgrass, using manual, mechanical, and biological control methods, which would contribute 

to greater risk for a large-scale wildfire. 

Under Alternative B, the BLM would treat fewer acres and conduct fewer treatments in areas with high risk for 

catastrophic fire than under Alternative A due to the reduction in methods available and increase in costs and time 

from using manual and mechanical methods. The BLM would be less able to slow pinyon-juniper encroachment and 

the densification and deterioration in tree health, slow the spread of noxious weeds and other invasive non-native 

vegetation, and decrease the fire cycle over much of the 3 Bars Project area. Thus, wildfire smoke production and 

impacts to air quality would be greater under this alternative than under Alternative A. 

3.6.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would treat approximately one-fourth as many acres as under Alternative A, and 

would not be able to use mechanical methods, prescribed fire, or wildland fire for resource benefit. This alternative 

would result in fewer particulate emissions than Alternatives A and B, and modeling indicates that treatments would 

not result in significant air quality impacts. Total concentrations of particulates would be virtually unchanged from 

3

background levels, and all project-related 24-hour and annual particulate impacts would be less than 1 μg/m . Adverse 

effects on air quality from treatments would likely be less than those reported in Tables 3-5 to 3-8 and would be 

negligible. 

In addition to the effects discussed under Alternative B, the BLM would not be able to use mechanical methods to 

slow pinyon-juniper encroachment, create fire and fuel breaks, thin pinyon-juniper, remove downed wood and slash, 

and remove noxious weeds and other invasive/non-native vegetation. Only about 500 to 1,000 acres would be treated 

annually to reduce hazardous fuels, so it is unlikely the trend toward large-sized fires of moderate to high severity in 

sagebrush and large stand-replacing fires in pinyon-juniper would slow or reverse long-term. Thus, there would be 

more wildfire risk and resultant smoke impacts under Alternative C than under Alternatives A and B. Because of the 

heightened risk of wildfire, adverse effects to air quality would be greater under this alternative than under 

Alternatives A and B. 

3.6.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct or indirect impacts to air quality under this alternative as no treatments would be authorized. 

The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; 

slow the spread of noxious weeds and other invasive non-native vegetation, especially cheatgrass; restore fire as an 

integral part of the ecosystem; or reduce the risk of a large-scale wildfire. Thus, the 3 Bars Project area would be 

subject to large scale wildfires with potentially uncontrolled dense smoke emissions from these fires and air quality 

impacts from wildfires would likely be greater under Alternative D than under the action alternatives. 
AIR QUALITY 

3 Bars Project Final EIS 3-46 October 2016

3.6.3.4 Cumulative Effects 

The CESA for air quality is approximately 1,524,879 acres and generally follows the boundary developed for soil, 

water, and vegetation resources (all or portions of Hydrologic Unit Code 10 watersheds within the 3 Bars Project 

area), but also includes additional area to the northwest of the 3 Bars Project area (Figure 3-1). This boundary was 

developed by BLM fire management staff and is based on their observations of where smoke from prescribed and 

wildland fires on the project area drifts, their interactions with federal and state agencies responsible for air quality, 

and their knowledge of dominant weather patterns in the project area. Approximately 92 percent of the CESA is 

administered by the BLM, 6 percent is privately owned, and 2 percent is administered by the Forest Service. 

3.6.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Cumulative impacts to air quality could result from the emissions from a number of sources within the CESA that are 

associated with reasonably foreseeable land development and utility and infrastructure projects. Mechanical 

equipment would be used during construction of utility and infrastructure projects, and construction workers and users 

of the facilities would travel by vehicle to project sites. Technology, however, will continue to play an important role 

in reducing air emissions from engine operations. 

The BLM could continue use ground-based herbicide applications to remove noxious weeds and other invasive nonnative vegetation, and aerial-based application methods to remove cheatgrass, and would restore burned areas under 

the Burned Area Emergency Stabilization and Rehabilitation program, under existing authorizations on about 1,000 

acres annually. These treatments would contribute particulate matter and chemicals associated with the herbicides to 

the atmosphere, but these effects on air quality would be localized and negligible. These treatments would help to 

reduce hazardous fuels, slow the spread of noxious weeds and other invasive non-native vegetation, and reduce 

surface runoff and erosion associated with burn sites on a few hundred acres annually. 

Population growth in Eureka County would lead to additional land development, and construction and use of 

businesses, homes, and related infrastructure and associated production of pollutants. Air quality impacts could result 

from generation of fugitive dust and from the burning of fossil fuels. Some of these emissions would be localized and 

subject to air quality permits. 

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 resuspension of road dust, wind 

erosion of exposed dirt surfaces, and activities related to the processing of ore materials. Combustion of diesel in 

haul trucks and mobile equipment, such as loaders, dozers, etc., the combustion of propane in processing units such 

as boilers, and the combustion of fuel oil or diesel in units such as the roaster, can produce elevated ambient levels 

of CO, NO2, SO2, PM10, PM2.5, and O3 (from volatile organic compound emissions). Modeling done for the Mount 

Hope Project and Ruby Hill Mine showed that these emissions, however, would not exceed the Nevada State 

AAQS or national AAQS, even with the addition of the background values. 

Short-term adverse and long-term beneficial effects from 3 Bars Project treatments would accumulate with those 

outside the project area. Fuels reduction and habitat improvement projects would occur on about 1 percent of the 

CESA annually (about 12,700 acres within the 3 Bars Project area, and about 1,500 acres within the remainder of the 

CESA) to reduce hazardous fuels and restore ecosystem health. Treatments would impact air quality, as discussed 

under direct and indirect effects, but the effects on air quality would be negligible. Treatments should help to reduce 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-47 October 2016

the risk of wildfire. Based on long-term averages, approximately 6,900 acres would burn annually from wildfires in 

the CESA. In general, air quality impacts from wildfires would be greater than air quality impacts from prescribed fire 

on a per acre basis. 

3.6.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on air quality would be 

similar to those described under Alternative A. Under Alternative B, the BLM would treat approximately 6,300 acres 

annually within the 3 Bars Project area, and the short-term adverse and long-term beneficial effects from 3 Bars 

Project treatments would accumulate with those from treatments (about 1,500 acres annually) elsewhere in the CESA. 

The amount of pollutants generated under Alternative B would be less than half those generated under Alternative A, 

due to fewer acres being treated and lack of use of prescribed fire and wildland fire for resource benefit. Pollutants 

generated from 3 Bars Project treatments would be low in the context of emissions from other sources in the CESA, 

and cumulatively would not result in an exceedance of Nevada AAQS or national AAQS. Treatments would help to 

reduce the risk of wildfire within the CESA, and resultant smoke emissions, but not to extent as would occur under 

Alternative A. 

3.6.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on air quality would be 

similar to those described under Alternative A. Under Alternative C, the BLM would treat about 3,200 acres annually 

on the 3 Bars Project area, and another 1,500 acres on other public lands within the CESA. Because of the limited 

number of acres treated, and lack of use of mechanical equipment and fire, particulate and other air emissions would 

be less under this alternative than under the other action alternatives. Pollutants generated from 3 Bars Project 

treatments would be negligible in the context of emissions from other sources in the CESA, and cumulatively would 

not result in an exceedance of Nevada AAQS or national AAQS. Treatments would help to reduce the risk of wildfire 

within the CESA, and resultant smoke emissions, but not to extent as would occur under Alternatives A and B. 

3.6.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on air quality would be 

similar to those described under Alternative A. There would be no cumulative effects to air quality from this 

alternative as no treatments would be authorized under this alternative. This alternative would not reduce the risk of 

wildfire, thus air quality effects from wildfire within the CESA would likely be highest under this alternative. 

3.6.3.5 Unavoidable Adverse Effects 

Use of prescribed fires would result in smoke emissions that contain particulates and gaseous constituents (i.e., 

PM10, PM2.5, CO, and hazardous air pollutants). Emissions of PM10 and PM2.5, and gaseous materials, would be 

generated by numerous processes as a result of the proposed action, including the re-suspension of road dust, wind 

erosion of exposed dirt surfaces, and activities related to the treatment methods. Combustion of diesel in trucks and 

mobile equipment, such as loaders, dozers, pickups, etc., can produce emissions of CO, NO2, SO2, PM10, PM2.5, 

and O3 (from volatile organic compound emissions). These activities are inherent to the operational activities and 

would be ongoing throughout the life of the 3 Bars Project. 
AIR QUALITY 

3 Bars Project Final EIS 3-48 October 2016

3.6.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

Vegetation treatments would cause short-term degradation of air quality, with most degradation associated with fire 

use. As discussed earlier, much of the focus of treatments is on restoring ecosystem function including natural fire 

regimes and reducing the incidence and severity of wildfires. In general, wildfire impacts on air quality would likely 

be greater than emissions from prescribed burning, since techniques to minimize emissions would be implemented 

during prescribed burns and smoke management plans would permit prescribed fires only when meteorological 

conditions are favorable to smoke dispersion. 

In addition, state smoke management meteorologists would consider the cumulative effects of emissions from other 

sources (such as road dust, other federal, state, and local vegetation management activities, and agricultural dust and 

burning) during the development of daily smoke management instructions. State smoke management program 

managers would also consider these sources during development of smoke management plans submitted for approval 

(as a component of the state smoke implementation plan) to the USEPA (USDOI BLM 2007b:4-246). 

3.6.3.7 Irreversible and Irretrievable Commitment of Resources 

Air quality would be affected by all treatment methods, with fire use contributing the most to degradation of air 

quality. These effects would occur only during the period of the treatment activity and there would be no irreversible 

or irretrievable effects on air quality. 

3.6.3.8 Significance of the Effects under the Alternatives 

There would be negligible direct, indirect, and cumulative effects to air quality from 3 Bars Project actions under all 

alternatives. The treatment methods under each action alternative would not result in significant direct, indirect, or 

cumulative impacts on air quality in the 3 Bars Project area or CESA since: 

 There would be no violation of any regulatory requirement of the Nevada BAPC. 

 No state or federal AAQS would be violated. 

 Treatments would not contribute substantially to an existing or projected air quality violation. 

 No sensitive receptors would be exposed to substantial pollutant concentrations. 

3.6.4 Mitigation 

No mitigation measures are proposed for air quality. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-49 October 2016

3.7 Geology and Minerals 

3.7.1 Regulatory Framework 

3.7.1.1 Geological Resources 

Regulations pertaining to geological resources are concerned with either the preservation of unique geological 

features or with designing structures or infrastructure to mitigate geological hazards such as earthquakes and 

landslides. Unique geological features are protected as National Natural Landmarks. The National Registry of Natural 

Landmarks (16 USC §§ 461 to 467) set up the National Natural Landmarks program in 1962, which is administered 

under the Historic Sites Act of 1935. 

3.7.1.2 Mineral Resources 

Most of the mineral estate in the 3 Bars Project area is administered by the federal government. Publicly owned 

minerals are available for exploration, development, and production, while subject to existing regulations, standard 

terms and conditions, and stipulations. Federally administered minerals in the public domain are classified into 

specific categories and these categories only apply to minerals in the federal mineral estate. These categories are 

locatable, leasable, and salable 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 

(American Geological Institute1997). The BLM has been charged by the U.S. Congress with the management of 

activities on public lands under the General Mining Law of 1872. 

A mining claim gives the holder the right to mine on federal land, while a patent gives the holder outright ownership 

of mineral-rich land that belongs to the federal government. An individual or company must first possess a claim 

before applying for a patent. The Mining Law of 1872 and amendments have provided a process for the filing of 

mining claims and assessment of fees to facilitate the exploration and development of valuable minerals as described 

above. Ultimately, claims could be patentable whereby the government would assign title of the claim to an individual 

or entity and the claim becomes private land. However, since 1994, the BLM has not been able to accept patent 

applications under a moratorium instituted by various acts of Congress. 

Leasable minerals are those minerals that are leased to individuals for exploration and development. The leasable 

minerals have been subdivided into two classes, fluids 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. These minerals are associated with the following laws: the Mineral 

Leasing Act of 1920, as amended and supplemented; the Mineral Leasing Act for Acquired Lands of 1947, as 

amended; and the Geothermal Steam Act of 1970, as amended (American Geological Institute 1997). Leasable 

minerals are acquired by applying to the federal government for a lease to explore and develop the 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. These are sold by contract with the federal government. These 
GEOLOGY AND MINERALS 

3 Bars Project Final EIS 3-50 October 2016

minerals are regulated under the Mineral Material Act of July 23, 1947, as amended, and the Surface Use and 

Occupancy Act of July 23, 1955 (American Geological Institute 1997). 

3.7.2 Affected Environment 

3.7.2.1 Study Methods and Study Area 

Information on the geology and mineral resources of the 3 Bars Project area was derived from maps and publications 

by the Nevada Bureau of Mines and Geology, the USDOI USGS, and Mount Hope Project EIS and references cited 

therein (USDOI BLM 2012b). The study area for direct, indirect, and cumulative effects to geology and minerals is 

the 3 Bars Project area. 

3.7.2.2 Geology 

The following is a general description of the geology of the study area. A more detailed description is in the Mount 

Hope Final Project EIS (USDOI BLM 2012b). 

The study area is located along the leading edge of the Roberts Mountains thrust. The Roberts Mountains thrust was 

formed when a mix of sedimentary and volcanic rock (the “Western” assemblage) was thrust on top of similarly aged 

carbonate rocks (the “Eastern” assemblage) about 340 to 370 million years ago, during the Devonian-Mississippian 

Antler orogeny, or process of mountain building (Roberts et al. 1967). The Western assemblage includes the Vinini 

and Valmy formations, which are largely composed of mudstones, cherts, sandy limestones, sandstones, and 

conglomerates and are exposed on the Roberts Mountains and the Simpson Park Mountains (Figure 3-9). The 

Western assemblage also contains minor amounts of limestone and andesitic volcanic rocks. 

Eastern assemblage rocks, including the Silurian Lone Mountain Dolomite and Devonian Nevada Formation, are 

exposed along the eastern side of the Sulphur Spring Range and in the Fish Creek Range on the southeastern corner of 

the study area (Roberts et al. 1967). The Eastern assemblage in Eureka County is composed of Cambrian to 

Ordovician rocks that were originally deposited in a shallow water shelf, and consist primarily of limestone, dolomite, 

and lesser amounts shale and quartzite. 

During the Antler orogeny, an elongate foreland basin formed at the toe of the mass of rock that had been moved. 

This basin was filled with a post-orogenic coarse clastic (rocks that are derived from fragments of other rocks due to 

erosion and weathering and then the rock fragments are transported and deposited to form new rocks; this is a class of 

sedimentary rocks) “Overlap” assemblage representing detritus eroded off the Antler highlands. Intermittent orogenic 

movement during the late Paleozoic and Mesozoic resulted in folding and thrust faulting of the Overlap assemblage 

and underlying formations. 

In addition to the Paleozoic rocks that belong to the assemblages described above, Tertiary volcanic and intrusive 

rocks are present. The volcanic rocks are exposed in the Simpson Park Mountains and Roberts Mountains and are 

composed of flows and tuffs. Igneous intrusive rocks are associated with the Mount Hope igneous complex (Roberts 

et al. 1967, USDOI BLM 2012b). 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-9

Geologic Formations

3 Bars Ecosystem and

Landscape Restoration Project

K O B E H

V A L L E Y

M O N I T O R

V A L L E Y

L O N E

M T N

W H I S T L E R

M T N S I M P S O N P A R K M O U N T A I N S

G R A S S V A L L E Y

P I N E V A L L E Y

R O B E R T S

M O U N T A I N S

S U L F U R S P R I N G S R A N G E

D E N A Y V A L L E Y

D I A M O N D

V A L L E Y

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Cu

Dd

Dd

Dd

Deu

Deu

Dn

Dn

Dn

Dn

Dn

Dn

Dn

Dn Dn

Dn

Dwu

ir

ir

Oe

Oh

Oh

Op

Op

Ov

Ov

Ov

Ov

Ov

Ov

Ov

Ov

Ova Pg

Pg

Pg

Qal

Qal

Qf

Qoa

Qoa

Qoa

QTsu

QTsu

QTsu

Sl

Sl

Sl

SOwu

Sr

Tvu

Tvu

Tvu

Tvu

Tvu

Cu

Dd

Dd

Dd

Dd

Deu

Dn

Dn Dn

Dn

Dn

Dn

Dn

Dn

Dn

Dn

Dn

Dn

Dn Dn

Dn

ir

ir

ir

ir

Oh

Ov

Ov

Ov

Ov

Ov

Ov

Ov

Ov

Pg

Pg

Pg?

Qal

Qal

Qal

Qal

Qal

Qal

Qal

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

Qoa

QTsu

QTsu

QTsu QTsu

Qvu

Sl

Sl Sl

Sl

SOwu

Sr

Sr

Sr

Tg

Tg

Tg

Tg

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

Tvu

0 1 2 3 4 5 10

Miles

Kilometers

Roberts Mountains Thrust

Qal-Alluvium

Qa-Valley Alluvium and Stream Deposits

Qf-Alluvial Fan Deposits

Qs-Sinter Deposits

Qoa-Older Alluvium

Qvu-Volcanic Rocks, Undivided

QTsu-Sedimentary Deposits, Undivided

Tg-Gravels

Tvu-Volcanic Rocks, Undivided

ir-Intrusive Rocks

Kn-Newark Canyon Formation

Pg-Garden Valley Formation

Mu-Sedimentary Rocks, Undivided

Dd-Devils Gate Limestone

Dwu-Sedimentary Rocks, Undivided

Deu-Sedimentary Rocks, Undivided

Dn-Nevada Formation

DSwu-Sedimentary Rocks, Undivided

Sl-Lone Mountain Dolomite

Sr-Roberts Mountains Formation

SOwu-Sedimentary Rocks, Undivided

Oh-Hanson Creek Formation

Ova-Valmy Formation

Ov-Vinini Formation

Oe-Eureka Quartzite

Ou-Sedimentary Rocks, Undivided

Op-Pogonip Group

Cu-Sedimentary Rocks, Undivided

Undetermined

3 Bars Project Area

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)

0 1 2 3 4 5 10

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: Roberts et al. 1967.
GEOLOGY AND MINERALS 

3 Bars Project Final EIS 3-52 October 2016

3.7.2.3 Minerals 

3.7.2.3.1 Locatable Minerals 

The most important locatable mineral commodities in the study area are precious and base metal resources including 

antimony, gold, lead, manganese, mercury, molybdenum, nickel, silver, vanadium, and zinc (Roberts et al. 1967). The 

Eureka-Battle Mountain trend crosses the study area from northwest to southeast and mines within the trend produced 

over 100,000 ounces of gold in 2009 (Price et al. 2010). 

Major mines in Eureka County include the Betze-Post Mine (Barrick Goldstrike Mines, Inc.), Eastern Nevada 

Operations (Newmont Mining Corporation), and the Ruby Hill Mine (Barrick Gold Corp.), which have produced a 

total of 81,382 ounces of gold and 43,276 ounces of silver through 2010 (Driesner and Coyner 2011). The Mount 

Hope Project is under construction, and there are several historical mining districts within the study area including the 

Roberts, Antelope, Lone Mountain, and Mount Hope Districts (Figure 3-10; Roberts et al. 1967). 

A Record of Decision for the Mount Hope Project was issued in 2012 and construction for the project began in 2013. 

The Project is currently on hold and no date has been set for resumption of construction activities (USDOI BLM 

2012b). Molybdenum was discovered at the site through exploratory drilling in the 1970s and 1980s (General Moly 

2012) and the deposit is estimated to have 1.3 billion pounds of molybdenum reserves.

3.7.2.3.2 Leasable Minerals 

Oil and Gas 

A few oil and gas test holes have been drilled in the study area, but no commercial production has been established 

(Figure 3-11; Garside and Hess 2011). Pine Valley is considered an area of high petroleum potential and a small 

portion of the southern part of the valley extends into the project area. 

Geothermal

Geothermal energy is a potential leasable mineral resource in the study area. Geothermal energy is used for power 

generation at Beowawe, Nevada, in northern Eureka County, and at the McGinness Hills geothermal project in Grass 

Valley, Lander County, and west of the 3 Bars Project area. The likelihood of geothermal development on the 3 Bars 

Project area is low (Zehner et al. 2009).

3.7.2.3.3 Saleable Minerals 

Alluvial fan deposits along the mountain fronts in Eureka County provide a large potential source of sand and gravel 

(Lumos and Associates 2007). There are about 24 saleable minerals sites covering about 55 acres within the 3 Bars 

Project area. Annual production is about 100,000 tons of material. 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-10

Mineral Resources

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Union

Cortez

Alpha

Antelope

Roberts

Mount

Hope

Lone

Mountain

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Mineral Resources

Precious Metals

Base Metals

Mining District

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: Lumos & Associates 2007.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-11

Oil and Gas Resources

(through 2006)

3 Bars Ecosystem and

Landscape Restoration Project

Silver State

Federal No. 33-18

27-011-05208

Willow Wash

Federal No. 42-24

27-011-05225

East Henderson

Creek No. 1

27-011-05228

North Kobeh Valley

Federal No. 13-10

27-011-05242

Lone Mountain

No. 15-1

27-011-05243

Jackpot

Federal No. 1

27-011-05249

Table Mountain

No. F-11X-6G

27-011-05253

Alpha Strat

No. 1

27-011-05290

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Abandoned Well with Evidence of Oil

and/or Gas Encountered while Drilling

Abandoned Well with No Evidence of

Oil or Gas Encountered while Drilling

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: Garside & Hess 2007.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.7.3 Environmental Consequences 

3.7.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, key issues of concern for geology and minerals are the potential 

for restoration treatments to interfere with existing or proposed mineral extraction operations and the ability to access 

the underlying minerals. 

3.7.3.2 Significance Criteria 

Effects to geology or minerals would be considered significant if BLM actions resulted in a prolonged or permanent 

restriction on use of, or access to, mineral resources.

3.7.3.3 Direct and Indirect Effects 

3.7.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

There is potential that restoration treatments could affect or be effected by mineral exploration and development, as an 

area could be restored and later affected by mineral exploration or development that could cause the loss of restoration 

benefits; or restoration treatments could interfere with staking and maintenance of mineral claims. Conflicts (and 

subsequent potential effects) between mineral exploration and development and land restoration would be minimized 

by the implementation of General Standard Operating Procedure 4 (Appendix C), whereby the location of mineral 

claims and other mineral activity would be determined prior to the start of treatments. By reviewing the Legacy 

Rehost (LR) 2000 database, the BLM would be able to identify areas with current and possibly future mineral 

activity, such as current fluid minerals leases. The presence of mining claims or fluid mineral leases would not 

preclude restoration work, but these sites would require more coordination with affected interests. 

Restoration treatments would not be expected to interfere with current ongoing mineral extraction operations. 

However, areas disturbed by ongoing mineral development (leach pads, waste rock dumps, roads, and mine facilities) 

would be precluded from treatment, as restoration of these areas would be handled under federal mining laws and 

Nevada State regulations. Eventual reclamation of these areas would be consistent with BLM land management goals 

and objectives. 

3.7.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

The use of minerals would be greater for riparian treatments than for other treatment types. Gravel and crushed rock 

resources would be needed for streambank restoration and grade stabilization. This effect on local gravel and rock 

resources would be negligible as valley fill deposits provide an abundance of gravel and rock resources, but the BLM 

may have to develop pits near Roberts Mountains and other treatment areas to provide mineral resources. Riparian 

treatments would have little effect on mineral access or potential for conflict with mineral exploration and 

development because of the limited extent of the riparian treatment areas. 

3 Bars Project Final EIS 3-55 October 2016
GEOLOGY AND MINERALS 

Aspen Treatments 

Aspen treatments would have no effect on mineral use because aspen treatments do not involve the use of gravel or 

crushed rock. Aspen treatments would have little effect on mineral access or potential for conflict with mineral 

exploration and development because of the limited extent of the aspen treatment areas. 

Pinyon-juniper Treatments

Pinyon-juniper treatments would have no effect on mineral use because pinyon-juniper treatments would not involve 

the use of gravel or crushed rock. Pinyon-juniper treatments could affect mineral access and contribute to potential 

conflicts with mineral exploration and development because of the large area being treated to control pinyon-juniper 

and the potential for treatment areas to overlap with future mineral resource development areas. 

Sagebrush Treatments

Sagebrush treatments would have no effect on mineral use because sagebrush treatments would not involve the use of 

gravel or crushed rock. Sagebrush treatments would have little effect on mineral access or potential conflicts for 

conflict with mineral exploration and development because of the limited area being treated and the limited potential 

for treatment areas to overlap with mineral resource areas. 

3.7.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Direct and indirect effects to local gravel and rock resources under Alternative B would be similar to those for 

Alternative A. Potential conflicts over access to and use of mineral resources would be about 50 percent less under 

this alternative than under Alternative A. 

3.7.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Direct and indirect effects to local gravel and rock resources under Alternative C would be about one-fourth those for 

Alternative A. Potential conflicts over access to and use of mineral resources would one-fourth that of Alternative A. 

3.7.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to geology and minerals from this alternative as no treatments would be authorized 

under this alternative. 

3.7.3.4 Cumulative Effects 

The CESA for geology and mineral resources is the 3 Bars Project area (Figure 3-1). 

3.7.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Alternative A would have a negligible contribution to the cumulative effects on mineral resources. About 12,700 

acres would be treated annually on the 3 Bars Project area, and another 1,500 acres annually on other public lands 

within the CESA, to restore riparian, aspen, pinyon-juniper, and sagebrush habitat and reduce hazardous fuels. 

Approximately 31 miles of stream would be restored, and restoration activities would require gravel and crushed rock. 

However, in the context of road and other land development and mining within the CESA, gravel and crushed rock 

3 Bars Project Final EIS 3-56 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

needs for the 3 Bars Project would be negligible. Potential conflicts over access to and use of mineral resources would 

also be negligible. 

3.7.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on geology and mineral 

resources would be similar to those described under Alternative A. Alternative B would have a negligible contribution 

to the cumulative effects on mineral resources. About 6,300 acres would be treated annually on the 3 Bars Project 

area, and another 1,500 acres annually on other public lands within the CESA, to restore habitat and reduce hazardous 

fuels. Approximately 31 miles of stream would be restored, and restoration activities would require gravel and 

crushed rock. However, in the context of road and other land development and mining within the CESA, gravel and 

crushed rock needs for the 3 Bars Project would be negligible. Potential conflicts over access to and use of mineral 

resources would also be negligible. 

3.7.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on geology and mineral 

resources would be similar to those described under Alternative A. Alternative C would have a negligible contribution 

to the cumulative effects on mineral resources. About 3,200 acres would be treated annually on the 3 Bars Project 

area, and another 1,500 acres annually on other public lands within the CESA, to restore habitat and reduce hazardous 

fuels. Only about 8 miles of stream would be restored, one-fourth the miles of stream restored under Alternatives A 

and B. In the context of road and other land development and mining within the CESA, gravel and crushed rock needs 

for the 3 Bars Project would be negligible, as less than 1 percent of the CESA would be affected annually. Potential 

conflicts over access to and use of mineral resources would be negligible. 

3.7.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on geology and mineral 

resources would be similar to those described under Alternative A. There would be no cumulative impacts to geology 

and mineral resources from this alternative as no treatments would be authorized under this alternative. 

3.7.3.5 Unavoidable Adverse Effects 

There would be a loss of gravel and rock from mine quarries for stream bioengineering activities under Alternatives 

A, B, and C. 

3.7.3.6 Relationship between Local Short-term Uses and Long-term Productivity 

There would be a long-term loss of mineral resources from quarries to provide gravel and rock resources for stream 

bioengineering. However, these resources would have a long-term benefit to riparian and stream habitat. 

3.7.3.7 Irreversible and Irretrievable Commitment of Resources 

There would be no irreversible or irretrievable commitment of geological or mineral resources. Gravel and rock used 

for stream bioengineering would be moved from one location (mine quarry) to another (stream), but not lost. 

3 Bars Project Final EIS 3-57 October 2016
GEOLOGY AND MINERALS 

3.7.3.8 Significance of the Effects under the Alternatives 

There would be negligible direct, indirect, and cumulative effects to geology or mineral resources from the 

alternatives and these effects would not be significant. Demand for gravel and crushed stone to support mining 

activities in the CESA would far exceed the amounts of material that would be needed for 3 Bars Project treatments. 

None of the alternatives are expected to result in a prolonged or permanent restriction on use of or access to mineral 

resources within the 3 Bars Project area or CESA. 

3.7.4 Mitigation 

No mitigation measures are proposed for geology or minerals. 

3.8 Paleontological Resources 

3.8.1 Regulatory Framework 

Federal legislative protection for paleontological resources stems from the Antiquities Act of 1906 (Public Law-59-

209; 16 USC § 431 et seq; 34 Statute 225), which calls for protection of historic and prehistoric structures and other 

objects of historic or scientific interests on federally administered lands. Federal protection for scientifically important 

paleontological resources applies to construction or other related project impacts that occur on federally administered 

lands. 

The Paleontological Resource Protection Act of 2009 (Public Law 111-011) requires the Secretaries of the 

Department of Interior and Department of Agriculture to manage and protect paleontological resources on federal 

land using scientific principles and expertise. The Act includes specific provisions addressing management of these 

resources by the BLM and other federal agencies. 

The BLM manages paleontological resources under a number of other federal laws including the Federal Land Policy 

and Management Act (Sections 310 and 302[b]), which directs the BLM to manage public lands to protect the 

quality of scientific and other values; 43 CFR § 8365:1-5, which prohibits the willful disturbance, removal, and 

destruction of scientific resources or natural objects; 43 CFR § 3622, which regulates the amount of petrified wood 

that can be collected for personal noncommercial purposes without a permit; and 43 CFR § 3809.420 (b)(8), which 

stipulates that a mining operator “shall not knowingly disturb, alter, injure, or destroy any scientifically important 

paleontological remains or any historical or archaeological site, structure, building or object on federal lands.”

The BLM has adopted the Potential Fossil Yield Classification (PFYC) system to identify and classify fossil resources 

on federal lands (Table 3-9; USDOI BLM 2007e). Paleontological resources are closely tied to the geologic units 

(i.e., formations, members, or beds) that contain them. The probability of finding paleontological resources can be 

broadly predicted from the geologic units present at or near the surface. Therefore, geologic mapping can be used for 

assessing the potential for the occurrence of paleontological resources. 

The PFYC system is a way of classifying geologic units based on the relative abundance of vertebrate or scientifically 

significant fossils (plants, vertebrates, and invertebrates) and their sensitivity to adverse impacts. A higher class 

number indicates higher potential for presence. The PFYC system is not intended to be applied to specific 

paleontological localities or small areas within units. Although significant localities may occasionally occur in a 

3 Bars Project Final EIS 3-58 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

geologic unit, a few widely scattered important fossils or localities do not necessarily indicate a higher class. Instead, 

the relative abundance of significant localities is intended to be the major determinant for the class assignment. 

The PFYC system is meant to provide baseline guidance for predicting, assessing, and mitigating paleontological 

resources. The classification should be considered at an intermediate point in the analysis, and should be used to assist 

in determining the need for further mitigation assessment or actions. The BLM intends for the PFYC System to be 

used as a guideline rather than as a rigorous definition. 

TABLE 3-9 

Potential Fossil Yield Classification

Class Description Basis

1

Igneous and metamorphic (tuffs 

are excluded from this category) 

geologic units or units representing 

heavily disturbed preservation 

environments that are not likely to 

contain recognizable fossil 

remains. 

 Fossils of any kind known not to occur except in the rarest of 

circumstances. 

 Igneous or metamorphic origin. 

 Landslides and glacial deposits. 

2

Sedimentary geologic units that 

are not likely to contain vertebrate 

fossils or scientifically significant 

invertebrate fossils. 

 Vertebrate fossils known to occur very rarely or not at all. 

 Age greater than Devonian. 

 Age younger than 10,000 years before present. 

 Deep marine origin. 

 Aeolian origin. 

 Diagenetic alteration. 

3

Fossiliferous sedimentary geologic 

units where fossil content varies in 

significance, abundance, and 

predictable occurrence. Also 

sedimentary units of unknown 

fossil potential.

 Units with sporadic known occurrences of vertebrate fossils. 

 Vertebrate fossils and significant invertebrate fossils known to 

occur inconsistently, and predictability known to be low. 

 Poorly studied and/or poorly documented. Potential yield cannot 

be assigned without ground reconnaissance. 

4

Class 4 geologic units are Class 5 

units (see below) that have 

lowered risks of human-caused 

adverse impacts and/or lowered 

risk of natural degradation. 

 Significant soil/vegetative cover; outcrop is not likely to be 

impacted. 

 Areas of any exposed outcrop are smaller than 2 contiguous 

acres. 

 Outcrop forms cliffs of sufficient height and slope that most is 

out of reach by normal means. 

 Other characteristics that lower the vulnerability of both known 

and unidentified fossil localities.

5

Highly fossiliferous geologic units 

that regularly and predictably 

produce invertebrate fossils and/or 

scientifically significant 

invertebrate fossils, and that are at 

risk of natural degradation and/or 

human-caused adverse impacts.

 Vertebrate fossils and/or scientifically significant invertebrate 

fossils are known and documented to occur consistently, 

predictably, and/or abundantly. 

 Unit is exposed and little or no soil/vegetative cover. 

 Outcrop areas are extensive and discontinuous areas are larger 

than 2 contiguous acres. 

 Outcrop erodes readily and may form badlands. 

 Easy access to extensive outcrop in remote areas. 

 Other characteristics that increase the sensitivity of both known 

and unidentified fossil localities. 

Sources: USDOI BLM (2007e, 2008c).

3 Bars Project Final EIS 3-59 October 2016
PALEONTOLOGICAL RESOURCES 

In addition to the statutes and regulations previously listed, fossils on public lands are managed through the use of 

internal BLM guidance and manuals. Included among these are BLM Manual 8270, Paleontological Resource 

Management, and BLM Handbook H-8270-1, General Procedural Guidance for Paleontological Resource 

Management (USDOI BLM 2008c, d).

3.8.2 Affected Environment 

3.8.2.1 Study Methods and Study Area 

Information on the paleontological resources of the 3 Bars Project area was derived from maps and publications by 

the Nevada Bureau of Mines and Geology and USGS (2012a), and the Mount Hope Project EIS and references cited 

therein (USDOI BLM 2012b). 

The study area for direct, indirect, and cumulative effects to paleontological resources is the 3 Bars Project area 

(Figure 3-1). 

3.8.2.2 Fossil Potential in the Study Area 

No paleontological resources of critical scientific or educational value are known to occur within the 3 Bars Project 

area. Paleontological resources have been identified in several mountain ranges in the study area (Lumos and 

Associates 2007, USDOI BLM 2012b). At Roberts Mountains and Lone Mountain, the paleontological resources are 

associated with Ordovician rocks where the fossil assemblages provide evidence of mass extinctions. The Simpson 

Park Mountains and Roberts Mountains have yielded marine vertebrate fossils from Devonian rocks. The fossilbearing formations have not been classified according to the PFYC system. 

At Roberts Mountains, paleontological resources have been found near Vinini Creek, Pete Hanson Creek, and 

Cottonwood Canyon, and are significant for their invertebrate fossil resources because they have yielded numerous 

new species. Johnson (1962 cited in USDOI BLM 2012b) reported a previously unrecorded species of brachiopod, 

leading to the designation of a new Middle Devonian zone from rocks in the Roberts Mountains. Ausich (1978 

cited in USDOI BLM 2012b) reported a new species of Pisocrinus from the Roberts Mountains which expanded 

the known range for this type of Silurian crinoid. Stone and Berdan (1984), based on investigations of the Late 

Silurian strata of the Roberts Mountains, identified 3 new genera and 18 new species of ostracodes. 

3.8.3 Environmental Consequences 

3.8.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, no key issues of concern were identified for paleontological 

resources. However, the BLM is obligated by statute to protect paleontological resources on federal lands from 

damage by activities initiated or approved of by the BLM. 

3.8.3.2 Significance Criteria 

The loss or destruction of scientifically important or valuable paleontological resources would constitute a significant 

impact. 

3 Bars Project Final EIS 3-60 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.8.3.3 Direct and Indirect Effects 

3.8.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Paleontological resources are most valuable when they are found in place and undisturbed. Even if fossils are present 

“in float,” on the soil surface or as part of soil horizons, if they are not found in their original stratigraphic position in 

the sedimentary layers they are less valuable scientifically. 

Restoration treatments should have little or no impact on paleontological resources. Scientifically valuable fossils that 

may be present in the study area would be in bedrock outcrops and should not be affected. Indirect adverse effects to 

paleontological resources could occur through unauthorized collecting by workers at easily accessible outcrops. 

3.8.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Mechanical treatments involving the use of heavy equipment, and any treatment method that has the potential to 

disturb more than surficial layers (disturbance greater than 6 to 8 inches deep), or has the potential to disturb bedrock, 

have the greatest possibility of causing impacts to paleontological resources. Equipment with treads (i.e., bulldozers 

with grousers) could damage fossil specimens found near the soil surface, but such action would not have as much 

impact as disturbance of fossils that are contained in bedrock and outcrop. If the disturbance is shallow, and not on 

exposed bedrock, the potential for loss or damage of fossils would be minimal. However, soil excavation and removal 

would only occur on a few acres annually within riparian zones, and mostly in areas that have likely been disturbed in 

the past by stream channelization and movement, so impacts to fossils from riparian zone treatments should be 

negligible. 

The effects of fire on fossil resources have been studied by the USDOI National Park Service. A study was conducted 

in the Badlands National Park, South Dakota, where the effects of elevated temperatures on fossils were studied in 

controlled burns and under laboratory conditions (Benton and Reardon 2006). They found that moderate fire 

conditions appear to have “minimal impact on fossil resources” unless the specimens are in direct contact with 

burning fuel. It was found that high intensity fire conditions could have an effect on fossils even if there is no contact 

with burning fuel. Fossils exposed to low intensity fire conditions showed no alteration while fossils exposed to 

higher temperatures exhibited discoloration and fracturing. Since the most valuable fossil resources are still entrained 

in outcrops where there is less likelihood for fuel, and only a few acres of riparian habitat would be burned annually, 

the risk of impacts to fossil resources from prescribed fire on the 3 Bars Project area would be negligible. 

Aspen Treatments

Mechanical treatments would generally involve the manipulation of vegetation above the soil surface. Aspen 

treatments presents a lesser risk of potential effects to fossils than riparian treatments, because mechanical treatments 

would not disturb the soil as deeply as would stream restoration treatments. 

Pinyon-juniper Treatments 

Manual treatments would primarily occur in Phase I and II woodland stands (see Section 3.12.2, Native and Noninvasive Vegetation Resources, for a discussion of pinyon-juniper phase classes) found at lower elevations and would 

be unlikely to disturb fossils. 

3 Bars Project Final EIS 3-61 October 2016
PALEONTOLOGICAL RESOURCES 

Because the BLM proposes to use prescribed fire primarily in Phase III stands that are often found at higher 

elevations, it is possible that fires would come into contact with rock outcrops that might contain fossils. These 

include treatments in the Atlas, Frazier Unit, Henderson Corridor, Gable Corridor, and Vinini Corridor units, which 

are on Roberts Mountains where fossils have been found. Paleontological resources have been found near Vinini 

Creek, Pete Hanson Creek, and Cottonwood Canyon. Rock outcrops are also associated with old-growth pinyonjuniper and limber pine, but the BLM would not conduct fire treatments in old-growth areas. 

Sagebrush Treatments 

The BLM proposes to use mechanical and biological control methods and prescribed fire to treat noxious weeds and 

other invasive, non-native vegetation on the Rocky Hills and West Simpson Park units. No fossils have been 

identified in these units, and if present, would be found below the soil surface and should not be affected by treatment 

methods, including discing, tilling, and seeding, and use of livestock. 

3.8.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The effects to paleontological resources under Alternative B would be less than for Alternative A. Approximately 

6,350 acres would be treated annually, half as many as would be treated under Alternative A, and the BLM would not 

be able to use prescribed fire or wildland fire for resource benefit. Thus, there would be no risks to fossils from the 

use of fire, or from the equipment used to conduct these treatments. The BLM would conduct stream bioengineering 

on approximately 31 miles under this alternative; risks to fossils from stream treatments would be similar to those for 

Alternative A. Instead of using fire to treat Phase II and III pinyon-juniper, the BLM would rely on manual and 

mechanical methods to remove hazardous fuels and break up the continuity of fuels. 

3.8.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

The effects to paleontological resources under Alternative C would be less than for the other action alternatives. Only 

about 3,200 acres would be treated annually, one-fourth that of Alternative A, and only using manual and classical 

biological control methods. Both of these methods would have little or no ground disturbance, and would not be done 

near rock outcrops. The BLM would conduct about 8 miles of riparian restoration, but the area of disturbance would 

be very small and the BLM would not be able to use mechanical equipment to restore stream habitat. 

3.8.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to paleontological resources under Alternative D as no treatments would be 

authorized under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to 

promote healthy, diverse stands; slow the spread of noxious weeds and other invasive non-native vegetation, 

especially cheatgrass; restore fire as an integral part of the ecosystem; or reduce the risk of a large-scale wildfire. As a 

result, there may be loss of soil and other land degradation that could affect paleontological resources found close to 

the ground surface, but this risk would be negligible. 

3.8.3.4 Cumulative Effects 

The CESA for paleontological resources is the same as for geology and minerals and is the 3 Bars Project area 

(Figure 3-1). 

3 Bars Project Final EIS 3-62 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.8.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Cumulative effects to paleontological resources would result from surface disturbance related to industrial 

developments, unauthorized collection, and natural erosion processes in the CESA. Utilities and infrastructure and 

land development activities in fossil-bearing formations could impact, expose, damage, or destroy paleontological 

resources, although these activities would be unlikely on the 3 Bars Project area. These projects would require large 

amounts of sand, gravel, and crushed rock, however, and these materials could contain fossils. 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and aerial-based application methods to remove cheatgrass, and would restore burned areas 

under the Burned Area Emergency Stabilization and Rehabilitation program, under existing authorizations. These 

treatments should have no direct effect on paleontological resources, which would be found in rock outcrops or buried 

in the soil. These treatments would help to reduce hazardous fuels, slow the spread of noxious weeds and other 

invasive non-native vegetation, and reduce surface runoff and erosion associated with burn sites, potentially to the 

benefit of paleontological resources. 

The BLM would conduct hazardous fuels and habitat restoration treatments on about 1,500 acres annually under 

existing authorizations, and likely on additional acreage under future authorizations, within the CESA. The effects 

of these treatments on paleontological resources would be similar to those for 3 Bars Project treatments and should 

be negligible. 

The 8,300 acre Mount Hope Project is in the southeastern portion of the 3 Bars Project area. There are no known 

fossil-bearing rocks associated with the Mount Hope Project, and most geologic units associated with the mine site 

have low probability of having fossils (USDOI BLM 2012b:3-268). Disturbance activities occurring in non-fossilbearing geologic formations would not impact or affect paleontological resources. 

Surface disturbance from drilling of wells and construction of infrastructure for oil, gas, or geothermal development 

could impact fossil resources. The primary impact to paleontological resources would result from the excavation of 

material for construction of facilities. Extraction of gravel materials could impact paleontological resources. If a 

pipeline was constructed and placed underground, there could be impacts to subsurface fossil resources. Overall, 

disturbance from development would have a very low probability of impacting paleontological resources. 

In the context of other land-disturbing activities in the CESA, effects from the 3 Bars Project would be negligible, as 

less than 2 percent of the surface area (about 12,700 acres) would be disturbed annually from 3 Bars Project actions. 

Thus, the cumulative effects from project actions in the context with disturbances from other activities within the 

CESA should be negligible. 

3.8.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on paleontological 

resources would be similar to those described under Alternative A. The cumulative risks to paleontological resources 

under Alternative B would be less than for Alternative A, as only about half as many acres would be treated on the 3 

Bars Project area and fire treatments would not be allowed under this alternative. Approximately 6,300 acres would 

be treated annually on the 3 Bars Project area to improve habitat and reduce hazardous fuels, or about 1 percent of the 

CESA. Thus, the cumulative effects from project actions in the context with disturbances from other activities within 

the CESA should be negligible. 

3 Bars Project Final EIS 3-63 October 2016
PALEONTOLOGICAL RESOURCES 

3.8.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on paleontological 

resources would be similar to those described under Alternative A. The cumulative risks to paleontological resources 

under this alternative would be the least for the action alternatives. Approximately 3,200 acres would be treated 

annually on the 3 Bars Project area, or about 0.5 percent of the CESA. Only manual and classical biological control 

methods would be used, and these methods would have negligible effect on fossils. Stream bioengineering would 

occur on only about 8 miles of stream during the life of the project, one-fourth the mileage treated under Alternative 

A. 

3.8.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on paleontological 

resources would be similar to those described under Alternative A. There would be no cumulative impacts to 

paleontological resources as no treatments would be authorized under this alternative. This alternative would not 

reduce the risk of wildfire or loss of soil due to erosion, thus there could be effects to fossils if wildfires occur in rock 

outcrops, or fossils are lost due to erosion. 

3.8.3.5 Unavoidable Adverse Effects 

The loss of paleontological resources has the potential to be adverse, especially if it results in the loss of scientifically 

important fossils. However, if surveys and inventories are conducted in areas where ground-disturbing activities are 

proposed to occur, the likelihood of adverse impacts would be greatly reduced and any impacts that did occur would 

be minimal. 

3.8.3.6 Relationship between Local Short-term Uses and Long-term Productivity

Because paleontological resources are nonrenewable, there is no difference between short-term and long-term 

impacts. The resource cannot recover from some types of adverse impacts. Once disturbed, the materials and 

information associated with paleontological deposits may be permanently compromised. Any destruction of 

paleontological sites, especially those determined to have particular scientific value, would represent long-term losses. 

Furthermore, once paleontological deposits were disturbed and exposed, natural erosion could accelerate the 

destruction of fossils, and exposed fossils would be vulnerable to unauthorized collecting and digging. Any 

discoveries of paleontological resources as a result of surveys required prior to treatment would enhance long-term 

knowledge of the area and these resources (USDOI BLM 2007b). 

3.8.3.7 Irreversible and Irretrievable Commitment of Resources 

Because paleontological resources are nonrenewable, any impacts would render the resource disturbance irreversible 

and the integrity of the resource irretrievable. 

3.8.3.8 Significance of the Effects under the Alternatives 

None of the alternatives would be expected to result in the loss or destruction of scientifically important or valuable 

paleontological resources within the CESA or 3 Bars Project treatment areas. Thus, none of the direct, indirect, or 

cumulative impacts from the alternatives would create a significant impact within the CESA or 3 Bars Project area. 

3 Bars Project Final EIS 3-64 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.8.4 Mitigation 

No mitigation measures for paleontological resources are recommended. According to Instructional Memorandum 

2009-011 Guidelines for Assessment and Mitigation of Potential Impacts to Paleontological Resources (USDOI BLM 

2008e), “If the proposed project will not disturb potentially fossil-yielding bedrock or alluvium, no additional work is 

necessary... Examples of such projects include noxious weed spraying, mechanical brush treatment, geophysical 

exploration, or surface disturbing activities such as road construction when the fossil resource is expected to be buried 

well below project compression or excavation depth or when surface fossil resources would be left undamaged.” 

3.9 Soil Resources 

3.9.1 Regulatory Framework 

There are no federal or state laws or regulations specific to soil. State and federal agencies, however, have identified 

best management practices (BMPs) to limit the effects of soil erosion on the aquatic environment, including water 

quality. The USEPA guidelines define BMPs as “methods, measures, or practices to prevent or reduce water 

pollution, including but not limited to, structural and non-structural controls, operation and maintenance procedures, 

and scheduling and distribution of activities. Usually BMPs are applied as a system of practices rather than a single 

practice. Best management practices are selected on the basis of site-specific conditions that reflect natural 

background conditions and political, social, economic, and technical feasibility.”

The BLM Nevada Northeastern Great Basin Resource Advisory Council, as chartered by the USDOI to promote 

healthy rangelands, has developed Standards and Guidelines for grazing administration on about 16.2 million acres of 

public lands in Nevada. Included in the Standards and Guidelines is Standard 1 – Upland Sites. This Standard states 

that “upland soils exhibit infiltration and permeability rates that are appropriate to soil type, climate and land form.” 

Indicators include canopy and ground cover, including litter, live vegetation, and rock, appropriate to the potential of 

the site. Livestock grazing management and wild horse and burro population levels are appropriate when in 

combination with other multiple uses they maintain or promote upland vegetation and other organisms and provide 

for infiltration and permeability rates, soil moisture storage, and soil stability appropriate to the ecological site with 

management units (USDOI 2007b).

3.9.1.1 Nevada Best Management Practices 

The use of BMPs in Nevada is addressed in the Handbook of Best Management Practices (Nevada Division of 

Environmental Protection and Nevada Division of Conservation Districts 1994). Nevada Administrative Code 

445A.306 defines “Best Practices” as “measures, methods of operation, or practice that are reasonably designed to 

prevent, eliminate, or reduce water pollution from diffuse sources and that are consistent with the best practices in the 

particular field under the conditions applicable. This term is intended to be equivalent to the term ‘best management 

practices’ as used in federal statutes and regulations.”

3.9.2 Affected Environment 

3.9.2.1 Study Methods and Study Area 

Information on major land resource areas and soil characteristics was obtained from the Land Resource Regions and 

Major Land Resource Areas (MLRAs) of the United States, the Caribbean, and the Pacific Basin (USDA Natural 

3 Bars Project Final EIS 3-65 October 2016
SOIL RESOURCES 

Resources Conservation Service 2006), while information on soil characteristics was obtained from the Soil Survey 

Geographic Database (USDA Natural Resources Conservation Service 2012). The Mount Hope Project EIS, and 

references cited therein, was also consulted (USDOI BLM 2012b). 

The study area for direct and indirect effects to soil resources is the 3 Bars Project area. The cumulative effects study 

area for soil resources is the Hydrologic Unit Code 10 watersheds wholly or partially within the project area (Figure 

3-1). 

3.9.2.2 Soils Characteristics on the Project Area 

3.9.2.2.1 Soil Orders 

Soil resources in the project area formed in major land resource area 28B, the Central Nevada Basin and Range. The 

dominant soil orders in this major land resource area are Aridisols, Entisols, Inceptisols, and Mollisols (Figure 3-12). 

Aridisols form in an arid or semi-arid climate and are well developed soils that have a very low concentration of 

organic matter. In co

Entisols are consider

ntrast, Mollisols are fertile soils with high organic matter and a nutrient-enriched, thick surface. 

ed recent soils that lack soil development because erosion or deposition rates occur faster than 

the rate of soil development. Inceptisols are generally young mineral soils, but have had more time to develop profile 

characteristics than Entisols. The soils in this major land resource area generally are well drained, loamy or loamyskeletal, and range from shallow to very deep (USDA Natural Resources Conservation Service 2006). 

3.9.2.2.2 Soil Physical Properties 

Soil physical characteristics, such as the susceptibility to erosion and the potential for revegetation, are important to 

consider when planning for vegetation treatment activities and stabilization of disturbed areas. These hazards or 

limitations for use are a function of many physical and chemical characteristics of each soil, in combination with the 

climate and vegetation. Table 3-10 summarizes some important soil characteristics to be considered when evaluating 

the effects of vegetation treatment activities. 

3.9.2.2.3 Soil Compaction 

Soil compaction occurs when soil particles are pressed together and the pore spaces between them are reduced and 

bulk density is increased. Moist, fine textured soils are most susceptible to severe compaction. Approximately 19 

percent of the soils in the project area are compaction prone (Figure 3-13). 

3.9.2.2.4 Soil Erodibility Hazard 

Water erosion is the detachment and movement of soil by water. Natural erosion rates depend on inherent soil 

properties, slope, soil cover, and climate. 

Soil erodibility hazard potential has been assessed for both water driven and wind driven causes of erosion on each 

soil unit within the project area. Erodibility ratings are based on analyzing the dominant conditions of the surface 

layer of each soil within a soil unit. Water driven causes have been qualified based on the USDA Natural Resources 

Conservation Service K factor. The erosion K factor indicates the susceptibility of a soil to sheet and rill erosion by 

water, based primarily on the percentage of silt, sand, organic matter, and rock fragments within the soil unit and on 

soil structure and saturated hydraulic conductivity. Values of K range from 0.02 to 0.64. Soils with higher K values 

are more erodible than soils with lower K values. A small percentage of the soils within the project area 

3 Bars Project Final EIS 3-66 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-12

Soil Order

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Soil Order

Aridisols

Entisols

Inceptisols

Mollisols

Not Rated

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 10/02/13)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-13

Compaction Prone Soils

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Compaction Prone Soils

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

(approximately 15 percent) have a “severe” soil erodibility hazard rating for water-caused erosion. These soils are on 

steep slopes (Figure 3-14, Table 3-10).

Wind erosion is the physical wearing of the earth’s surface by wind. Wind erosion removes and redistributes soil. 

Small blowout areas may be associated with adjacent areas of deposition at the base of plants or behind obstacles, 

such as rocks, shrubs, fence rows, and roadbanks (Soil Quality Institute 2001). Wind driven erodibility interpretations 

are based on USDA Natural Resources Conservation Service wind erodibility group ratings. Wind erodibility group 

ratings range from 1 to 8 with values of 1 and 2 considered “severe,” and thus considered a limitation within the 

project area. The wind erodibility group value is closely correlated to the texture of the surface layer, the size and 

durability of surface clods, rock fragments, and organic matter, and the calcareous reaction potential of the soil. Soil 

moisture and frozen soil layers also influence wind erodibility group ratings. Wind erodible soils are not prevalent in 

the project area. A small percentage of the soils within the 3 Bars Project area (less than 1 percent) have a “severe” 

soil erodibility hazard rating for wind-caused erosion (Figure 3-15). These soils are in the southeastern portion of the 

project area. 

TABLE 3-10

Project Area Soil Limitations 

Limitation Acres Percent of Project Area

Compaction Prone 141,484 19

Low Revegetation Potential 51,321 7

Wind Erodible 1,043 <1

Water Erodible 109,139 15

Shallow to Bedrock 490,311 65

Droughty 156,905 21

Source: USDA Natural Resources Conservation Service (2012). 

3.9.2.2.5 Soil Productivity and Quality 

Site productivity is primarily a measure of vegetation success. Productivity varies with vegetation community, but 

more importantly, with land management objectives as they relate to the establishment of desirable or productive 

vegetation types. In contrast, soil quality is an inherent soil resource characteristic involving aeration, permeability, 

texture, salinity and alkalinity, microbial populations, fertility, and other physical and chemical characteristics that are 

accepted as beneficial to overall plant growth and establishment. Topsoil thickness and organic matter content 

influence water and nutrient holding capacity and improve soil structure and soil quality. Topsoils in the project area 

have organic matter contents that range from 0 to 5 percent, as shown in Table 3-11 and Figure 3-16. 

3.9.2.2.6 Soil Textures 

Surface soil textures in the project area range from silty clay to loamy very fine sand. Rock fragments such as gravel, 

cobbles, and stones are common in surface soils within the project area. The soils in the mountainous central part of 

the project area are typically very stony to very gravelly loams found on 8 to 50 percent slopes intermixed with rocky 

outcrops. These soils are shallow to moderately deep over lithic and paralithic bedrock and derive from residuum and 

colluvium from mixed igneous, metamorphic, and volcanic rocks. Soils found in the hilly terrain surrounding Mount 

Hope are on slopes ranging from 4 to 30 percent and are derived from volcanic rocks and limestone. Table 3-12 and 

Figure 3-17 provide information on the surface soil textures within the project area. 

3 Bars Project Final EIS 3-69 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-14

Soil Erosion Potential

from Water

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Soil Erosion Potential from Water

Severe Water Erosion

Moderate Water Erosion

Low Water Erosion

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-15

Soil Erosion Potential

from Wind

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Soil Erosion Potential from Wind

Severe Wind Erosion

Moderate Wind Erosion

Low Wind Erosion

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-16

Organic Matter within

Surface Soils

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Organic Matter within

Surface Soils

< 1%

1 - 3%

3 - 5%

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-17

Soil Surface Texture

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

1:400,000

Legend

Soil Surface Texture

Fine Texture

Medium Texture

Coarse Texture

Not Rated

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
SOIL RESOURCES 

3.9.2.2.7 Low Revegetation Potential 

Soils with low revegetation potential have chemical characteristics such as high salts, sodium, or pH that may limit 

plant growth. Saline soils affect plant uptake of water and sodic soils (soils with high levels of sodium) often have 

drainage limitations. In addition, the success of stabilization and restoration efforts in these areas may be limited 

unless additional treatments and practices are employed to offset the adverse physical and chemical characteristics of 

the soils. Approximately 7 percent of soils in the project area are characterized as having low revegetation potential 

(Figure 3-18).

3.9.2.2.8 Biological Soil Crusts 

Biological soil crusts are also referred to as microbiotic, cryptogamic, cryptobiotic, and microphytic crusts. The 

names are all meant to indicate common features of the organisms that compose the crusts. Biological soil crusts are 

formed by living organisms and their by-products, creating a crust of soil particles bound together by organic 

materials. Chemical and physical crusts are inorganic features, such as a salt crusts or platy surface crusts. Biological 

soil crusts are commonly found in semiarid and arid environments throughout the world. Areas in the United States 

where crusts are a prominent feature of the landscape include the Great Basin (USDA Natural Resources 

Conservation Service 1997).

Biological soil crusts function as living mulch by retaining soil moisture and discouraging annual weed growth. They 

reduce wind and water erosion, fix atmospheric nitrogen, and contribute to soil organic matter. Structurally, biological 

soil crusts are a rough, uneven carpet or skin of low stature (1 to10 centimeters in height). Below ground, lichen and 

moss rhizines, fungal hyphae, and cyanobacterial filaments form a matrix that binds soil particles together. 

Horizontally, biological soil crusts occupy the nutrient-poor zones between vegetation clumps in many types of 

aridland vegetation. Compositionally, biological soil crusts are diverse. In many arid and semi-arid communities there 

are often many more species associated with the biological soil crust at a given site than there are vascular plants. 

Biological soil crusts can also be used as indicators of ecological health. In addition, they act as indicators of abiotic 

factors, such as the presence of calcareous soils. Most crustal organisms are biologically active during the cool 

seasons when the soil surface is moist. In contrast, vascular plants are active in spring and summer when air 

temperatures are above freezing. Unlike vascular plants, crustal organisms, particularly lichens, are not greatly 

influenced by short-term climatic conditions. This makes them ideal indicators of long-term environmental factors 

(USDOI BLM and USDOI USGS 2001and references cited therein). 

3.9.2.3 Vegetation Treatment Soil Suitability 

3.9.2.3.1 Fire Damage Susceptibility 

Wildfire is a naturally occurring event that has helped maintain ecosystem function in wildlands. Wildland fire can be 

caused by natural ignition, such as a lightning strike, or by man-caused ignition, and is used for a resource benefit. 

Buildup of excess fuel loads can result in high severity fires that damage the soils in the burn area. Prescribed burning 

is a restoration practice that is primarily designed to help return the natural fire cycle to the landscape. 

3 Bars Project Final EIS 3-74 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-18

Revegetation Potential

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Revegetation Potential

Low Potential

Moderate Potential

High Potential

Not Rated

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
SOIL RESOURCES 

TABLE 3-11

Project Area Topsoil Organic Matter Content 

Percent Organic Matter Acres Percent of Project Area

<1 121,740 16

1-1.9 396,013 53

2-3.9 213,342 28

>4 18,714 2

Source: USDA Natural Resources Conservation Service (2012). 

Vulnerability to fire damage ratings are used to assess the risks that a fire will create a water repellant (hydrophobic) 

soil layer, volatilize essential soil nutrients, destroy soil biological activity, and cause soil and water erosion on a 

burned site. Vulnerability to fire damage ratings are directly related to burn severity (e.g., a low to moderate severity 

burn will not result in water repellant layer formation). Table 3-13 and Figure 3-19 provide vulnerability to fire 

damage ratings for the 3 Bars Project area (USDA Natural Resources Conservation Service 2012). Sandy soils are 

more susceptible to formation of a water repellant layer than are fine textured soils. High rock fragment content 

increases the rate of heat transfer into the soil. Steep slopes increase the vulnerability to water erosion. 

TABLE 3-12

Soil Textures in the Project Area 

Surface Texture Acres Surface Texture Acres

Cobbly Loam 46,483 Silt Loam 66,405

Extremely Cobbly Loam 3 Silty Clay 317

Extremely Stony Loam 10,389 Silty Clay Loam 2,298

Fine Sandy Loam 19,655 Stony Loam 40,686

Gravelly Fine Sandy Loam 13,842 Very Cobbly Clay Loam 255

Gravelly Loam 119,273 Very Cobbly Loam 94

Gravelly Sandy Loam 15,949 Very Fine Sandy Loam 4,451

Gravelly Silt Loam 183 Very Gravelly Loam 75,154

Loam 138,274 Very Stony Loam 87,785

Loamy Very Fine Sand 1,043 No Data 5,307

Sandy Loam 101,965 Total 749,810

Source: USDA Natural Resources Conservation Service (2012). 

Vulnerability to formation of hydrophobic (water repellant) layers varies by vegetation type. For example, pinyonjuniper vegetation types are more susceptible to hydrophobicity than shrubland or grassland vegetation types. Hot, dry 

south slopes are more susceptible to fire damage than cool northern slopes. 

The vulnerability to fire damage rating should be used in conjunction with the rangeland seeding rating or the 

opportunity for restoration rating depending upon whether seeding or natural regeneration will be utilized on the site. 

3 Bars Project Final EIS 3-76 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-19

Fire Damage Susceptibility

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Fire Damage Susceptibility

Highly Susceptible

Moderately Susceptible

Slightly Susceptible

Not Rated

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 08/14/13)
SOIL RESOURCES 

TABLE 3-13

Soil Suitabilities for Vegetation Treatment (acres) 

Suitability or Susceptibility Fire Damage 

Susceptibility

Shredder 

Susceptibility

Site Degradation 

Susceptibility

Poorly Suited/Highly Susceptible 78,786 109,545 112,900

Moderately Suited/ Susceptible 444,257 210,470 426,103

Well Suited/Slightly Susceptible 225,446 428,474 209,487

Not Rated 1,321 1,321 1,321

 Source: USDA Natural Resources Conservation Service (2012). 

3.9.2.3.2 Shredder Susceptibility 

Shredder mechanical treatment is commonly practiced, sometimes in combination with seeding, for rangeland 

restoration. This type of treatment is often implemented in sagebrush, mountain shrub, and pinyon-juniper vegetation 

types to reduce the size and composition of dense brush and trees up to 15 to 18 inches diameter at breast height. The 

treatment objective of creating a mulch layer can include reducing hazardous fuel loads, increasing forage for 

livestock and wildlife, increasing infiltration, and reducing runoff and erosion (USDA Natural Resources 

Conservation Service 2012). 

Shredder mechanical treatment suitability ratings represent the relative physical limitations of soil factors upon use of 

shredder implements suitable for treatment of rangeland sites. This rating should be used in conjunction with the 

rangeland seeding rating or the opportunity for restoration rating depending upon whether seeding or natural 

regeneration will be utilized on the site. Table 3-13 and Figure 3-20 show shredder suitability ratings for the 3 Bars 

Project area. 

3.9.2.3.3 Site Degradation Susceptibility

Vulnerability to degradation is a function of resistance to degradation. Resistance to degradation of a rangeland or 

woodland site is a measure of its ability to function without change throughout a disturbance. The magnitude of 

decline in the capacity to function determines the degree of resistance to change. Resistance to degradation thus could 

be described as an area’s buffering capacity (USDA Natural Resources Conservation Service 2012). 

The vulnerability to site degradation suitability ratings represent the relative risk of water and wind erosion, 

salinization, sodification, organic matter, and nutrient depletion and/or redistribution, and loss of adequate rooting 

depth necessary to maintain desired plant communities. This rating should be used with the objective to protect 

vulnerable sites from the type of degradation that would result in accelerated erosion, reduction in water and air 

quality, invasion by annual grasses or noxious weeds and other invasive, non-native vegetation, and other large scale 

potential natural plant community conversions. When degradation of soil and natural plant community characteristics 

goes beyond the threshold for the ecological site, the ecological site characteristics cannot be restored without 

artificial restoration efforts. Table 3-13 and Figure 3-21 show the site degradation susceptibility ratings for the 3 Bars 

Project area (USDA Natural Resources Conservation Service 2012). 

3 Bars Project Final EIS 3-78 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-20

Mechanical Treatment Suitability

(Shredder)

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Mechanical Treatment Suitability

(Shredder)

Poorly Suited

Moderately Suited

Well Suited

Not Rated

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-21

Site Degradation Susceptibility

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Site Degradation Susceptibility

Highly Susceptible

Moderately Susceptible

Slightly Susceptible

Not Rated

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.9.3 Environmental Consequences 

One of the goals of the 3 Bars Project is to improve soil quality and productivity and reduce soil erosion, especially in 

riparian zones. Restoration treatments would potentially affect soils by altering their physical, chemical, and/or 

biological properties. Physical changes could include the loss of soil through erosion or changes in soil structure, 

porosity, or organic matter content. Fire and other treatments would potentially alter nutrient availability and soil pH. 

Some vegetation treatments might also alter the abundance and types of soil organisms that contribute to overall soil 

quality, including mycorrhizae (USDOI BLM 2007c:4-11). These consequences are expected to be short-term. Over 

the long-term, treatments that remove noxious weeds and other invasive non-native vegetation, reduce fuels, and 

restore native plants should enhance soil quality on the 3 Bars Project area. 

3.9.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Several issues related to soil resources were identified during public scoping. These are: 

 Concern that the recent Nevada Soil Survey information does not accurately reflect the historical occurrence 

of forest vegetation, and is strongly biased towards shrub-grass sites as soil surveys were based on what was 

present during the past few decades. 

 Concern that the current soils information is being used as a justification for massive deforestation and 

sagebrush killing and does not accurately reflect ecological conditions, either historic or current. 

 Concern that the soils information ignores the role of historic mining, agency treatment, and other 

deforestation. 

 Concern that because sagebrush is seral to pinyon and juniper, the presence of sagebrush in some areas at the 

time of the soil surveys may likely have been the result of past deforestation or BLM treatments. 

 Request basic information be provided regarding soil stability, erosion hazard, and wind and water erosion 

risks related to lands in the EIS area in order to understand likely sedimentation into streams, site soil 

stability post-treatment, likelihood of increased gullying, and other factors. 

 Concern that the actions proposed would bring about widespread microbiotic crust loss and soil erosion from 

wind and water. 

3.9.3.2 Significance Criteria 

Impacts to soil would be considered significant if BLM actions resulted in: 

 Accelerated erosion that would likely exceed annual soil loss tolerances. 

 Loss of topsoil, soil quality, or productivity that would limit revegetation success. 

 Accelerated erosion from watershed slopes, leading to increased sedimentation or turbidity in streams or 

ponds, or to other instabilities along stream corridors. 

3 Bars Project Final EIS 3-81 October 2016
SOIL RESOURCES 

3.9.3.3 Direct and Indirect Effects 

3.9.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Effects 

Restoration treatments could result in increased rates of erosion and reduced water infiltration, leading to reduced soil 

productivity. Erosion results when unstable soils are displaced under the forces of gravity, wind, or water. Although 

erosion is a natural process, it can increase markedly when vegetation is cleared (Bonneville Power Administration 

2000). Unnaturally high erosion rates could occur as a result of soil disturbance during the restoration treatment, or 

from the resultant vegetation removal and associated decrease in soil stability. The effects of loss of plant cover and 

organic matter on soil erosion would be greatest for treatments in areas with soils having severe water and wind 

erosion hazards as shown in Figures 3-14 and 3-15. 

Soils that are highly prone to water erosion would likely undergo accelerated erosion for a period during and after 

treatments. These areas are indicated on Figure 3-14. Erosion risk would be greatest for treatment areas on steep 

slopes, or where soils have clay, poor structural aggregation, or low organic content, and includes most riparian 

treatment areas. Treatments on these soils, particularly during wet periods, would encourage adverse impacts from 

soil erosion and sedimentation. 

Removal of vegetation on public lands would influence the amount of water infiltrating into the soil in some areas. 

Removal of vegetation could increase surface runoff, reducing the amount of water that might infiltrate into the soil. 

However, vegetation removal would also eliminate the loss of water to the soil from water being captured by the plant 

canopy or lost through evapotranspiration. 

Soil compaction associated with some vegetation treatment methods could reduce infiltration and soil productivity by 

eliminating pore spaces used for water storage and air exchange. Where highly compactable soils occur, noticeable 

compaction impacts would likely occur from vehicle traffic and equipment operations. These areas are indicated on 

Figure 3-13. Compaction could impede infiltration and accelerate runoff and erosion. Soil compaction may also 

result from manual construction of fences and spring exclosures, although disturbance areas would be small. Soil 

compaction risk would be greatest during wet or muddy conditions, such as during spring runoff, during rainstorms, 

and for a day or so after storm events. 

Vegetation treatments can alter the chemistry of the soil. Treatment methods that reduce organic matter cover can 

reduce the productivity of soils by reducing carbon and other nutrient inputs, and by reducing the moisture-holding 

capacity. Erosion can result in the transport of organic matter and nutrients off site. Soils with little organic matter to 

begin with (e.g., most Aridisols) are more susceptible to losses of organic matter. Removing nitrogen-fixing plants, 

such as legumes, can reduce soil nitrogen, and removing logs and other plant material can deprive soils of nutrients 

provided by decaying material. Removing vegetation can also reduce evapotranspiration, allowing more water to 

leach soluble nutrients from the soil (USDOI BLM 2007c:4-12). 

Laborers and vehicles accessing the site could disturb topsoil and/or surface organic matter; however, the extent of 

this disturbance should be limited. Coarse-textured soils and steep slopes would be the most fragile, and extensive 

areas of disturbance could result in increased erosion rates. There is the potential for some contamination of the soil 

from petroleum products used in hand-held power equipment or from transport vehicles, but these effects would be 

localized. 

3 Bars Project Final EIS 3-82 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Beneficial Impacts 

Although treatments would have short-term adverse 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. In particular, efforts to restore stream functionality, reduce noxious weeds and 

other invasive non-native vegetation spread, and reduce wildfire risk would benefit soils. The time necessary to 

accomplish these beneficial results would vary between treatments and from site to site, but would likely be on the 

order of years to decades after treatment. Based on soil characteristics, site revegetation potential is moderate to high 

for 3 Bars Project treatment sites (Figure 3-18).

Vegetation treatments that reduce or eliminate noxious weeds and other invasive non-native vegetation could be 

beneficial to soil quality. Beneficial impacts to soil stability and quality would ultimately result from revegetation 

treatments, due to the overall improvement in nutrient cycling, structural aggregation, reduction of erosion and 

sedimentation, accumulation of topsoil and organic matter, and enhanced infiltration. 

If these treatments were to result in increased native plant cover on sites degraded by noxious weeds and other 

invasive non-native vegetation, soil quality would begin to rebound. Sites with a large component of noxious weeds 

and other invasive non-native vegetation may be at a higher risk for erosion than sites that support native vegetation. 

Invasive plants can increase the potential for wind or water erosion by altering the fire frequency or producing 

chemicals that directly affect soil quality or organisms. These negative effects include increased sediment deposition 

and erosion, and alterations in soil nutrient cycling. In areas where pinyon-juniper has invaded, studies show that when 

tree dominance is reduced and herbaceous cover is increased, runoff and soil erosion decrease on sites with relatively 

fine-textured soils. Leaving tree debris on the ground after mechanical treatments can intercept runoff and increase 

infiltration, increase soil moisture by reducing evapotranspiration and evaporative loss of soil water, and promote 

nutrient cycling (Tausch et al. 2009).

Restoration treatments would benefit soil quality and productivity by reducing the risk of wildfire. Wildfires generally 

occur when soils are driest, resulting in hot soil temperatures, loss of nutrients, consumption of soil organic matter, 

and reduction of soil aggregation, infiltration, and aeration (Erickson and White 2008). Catastrophic, stand-replacing 

wildfires in pinyon-juniper woodlands can cause the loss of 75 to 100 percent of the soil organic matter (Neary et al. 

1999). Given the ability of an unplanned, uncontrolled, severe wildfire to cover a large geographic area, the 

detrimental effects of wildfire on soil quality have the potential to be high. Thus, vegetation management that reduces 

this risk would be beneficial to soil resources on public lands. Lower intensity prescribed fires would help avoid these 

conditions. This would be especially important on moderate and steep slopes, where uncontrolled catastrophic 

wildfires fires could cause severe erosion impacts. 

Removal of noxious weeds and other invasive non-native vegetation should improve soil function and increase both 

soil biodiversity and soil moisture. Many noxious weeds and other invasive non-native vegetation have relatively 

sparse canopies, which allow for greater evaporation from the exposed soil than dense vegetative cover. Sites infested 

with noxious weeds and other invasive non-native vegetation often experience more extreme soil temperatures that 

can alter soil moisture regimes. Removal of noxious weeds and other invasive non-native vegetation and 

reestablishment of native vegetation should slow runoff and evaporation and moderate soil temperatures (USDOI 

BLM 2007c:4-23). 

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SOIL RESOURCES 

3.9.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Accelerated erosion and sediment yields could occur under Alternative A, primarily from pinyon-juniper and 

sagebrush treatments. About 4,000 of the acres treated annually would occur in areas that are susceptible to wind or 

water erosion, or would be compaction prone, while about 10,000 of the acres treated annually could occur in areas 

that are susceptible to damage from fire treatments. 

Over time, the risks of water and wind erosion should be reduced from current levels. Soil fertility would improve 

over time for most treatments. Treatment activities that move pinyon-juniper woodlands and rangelands toward 

historical ranges of variability would provide favorable conditions for soil functions and processes that contribute to 

long-term soil productivity at a broad scale (USDOI BLM 2007c:4-18). 

Riparian Treatments 

The following discussion focuses on the effects of riparian treatments on soil. A discussion of stream processes, and 

how proposed stream engineering treatments would affect stream morphology and functionality, including processes 

related to soil erosion and deposition, is in Section 3.11.3 under Wetland, Floodplain, and Riparian Zones. 

Adverse Effects 

Locally, riparian conditions could be adversely affected if treatments resulted in accelerated soil erosion or deposition 

occurred near water bodies. These effects would occur along streams or other riparian zones if soils on nearby slopes 

were exposed and subjected to greater transport capacities from raindrop splash or overland flow. 

Treatment work at several streams, ponds, and springs, including projects associated with the Black Spring Unit, 

Garden Spring Unit, Henderson above Vinini Confluence Unit, and Frazier Creek Unit groups, would involve using 

heavy equipment to reconstruct streams and improve riparian habitat. Because of the spatial scale of constructionrelated disturbance associated with channel modification projects, the risk of unanticipated impacts can be very high. 

This is particularly true when projects do not meet restoration objectives, are not constructed as planned, or are 

designed with inadequate knowledge of watershed processes, disturbance regimes, or altered watershed conditions. 

Poorly designed channel modification projects can result in unexpected channel erosion in adjacent reaches, 

aggradation or degradation of the channel bed, or other impacts to habitat and processes due to changes in channel 

slope, bed elevation, and sediment transport capacity. Furthermore, the dynamic nature of hydraulic forces, and the 

uncertainties inherent in design and analysis, may result in inadvertent impacts from channel modification even when 

properly designed (Saldi-Caromile et al. 2004). 

The use of heavy equipment can result in soil compaction, particularly in areas of moist soils. Compaction by vehicles 

and other heavy equipment can reduce the porosity of soils, thus limiting water infiltration and increasing surface 

water runoff and erosion. Soil disturbance during stream restoration could increase erosion and degrade riparian 

habitat, especially when the treatment is performed on hillslopes. Erosion can be a problem on slopes greater than 20 

percent. About 21 percent of riparian treatment acreage has moderate to high soil water erosion potential, 8 percent 

has moderate to high wind erosion potential, and 27 percent is compaction prone. 

The treatment areas most prone to compaction and severe water erosion include the McClusky Creek and Indian 

Creek Headwaters North units. The McClusky Creek Unit in particular has a combination of severe water erosion risk 

and compaction-prone soils. For those streams identified for Lahontan cutthroat trout habitat improvement, streams 

most prone to severe water erosion would include portions of streams within the Vinini Creek and Roberts Creek 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

units. Compaction prone soils exist at the upper Henderson Creek, Vinini Creek, and Willow Creek units. The Vinini 

Creek and Willow Creek units in particular have a combination of severe water erosion risk and compaction-prone 

soils, although mechanical equipment would not be used within Willow Creek. Wind erosion hazard is also a 

moderate risk for adverse impacts in the Lower Henderson Creek Unit. Treatment by mechanical methods during dry 

months can minimize the effects of erosion on riparian zones. 

Prescribed fire would not be used as a primary treatment on riparian areas; however, pile burning could be used to 

dispose of activity fuels. It is unlikely that livestock would be used to treat cheatgrass in riparian areas, although 

classical biological control could be used to treat noxious weeds and other invasive, non-native vegetation on riparian 

areas. 

Beneficial Effects 

Stream restoration efforts would help reconnect the streams with their floodplains, and help stream systems dissipate 

energy associated with high water flow, filter sediment, capture bedload, aid in floodplain development, improve 

floodwater retention and groundwater recharge, restore desirable soil moisture regimes, and provide suitable 

conditions for riparian plants to develop root masses that stabilize streambanks against erosion. Stream bioengineering 

and stabilization efforts using manual and mechanical methods would reduce soil erosion and episodes of bank 

failure. 

The BLM would manually remove pinyon-juniper that is encroaching into riparian zones. Pinyon-juniper is not a 

riparian species and does not hold soil as well as native riparian species. Pinyon-juniper would be cut into logs or 

mulched. Vegetation that is uprooted, shredded, mowed, or otherwise altered and scattered on the surface would 

improve soil cover and organic matter. Scattered vegetative debris could temporarily provide greater soil stability than 

before treatment. Noelle (2012) observed that slash did not affect runoff but sediment yield was significantly reduced 

in pinyon-juniper stands where slash was used to slow runoff on steep slopes. 

Stream degradation in the 3 Bars Project area can be attributed to historic livestock, wild horse, and other wild 

ungulate soil disturbance in addition to other natural and human-caused factors, and this disturbance has led to soil 

erosion (USDOI BLM 1999a, 2004b, 2007f, 2008f, 2009e). To reduce these impacts, the BLM could use existing 

permanent fencing or small, temporary exclosures to temporarily exclude livestock, wild horses, and other wild 

ungulates from treatment areas to reduce soil disturbance and allow native vegetation to recover. 

Aspen Treatments 

Adverse Effects 

Mechanical treatments could lead to soil erosion, as 57 percent of aspen management acreage has moderate to high 

soil water erosion potential and 14 percent is compaction prone; none of the aspen management treatments areas have 

potential for wind erosion. 

Beneficial Effects 

The BLM would remove pinyon-juniper trees to slow pinyon-juniper encroachment into aspen stands, and to create 

fire and fuel breaks. Only about 10 acres of pinyon-juniper would be treated annually near aspen stands. Creation of 

fire and fuel breaks would slow or stop the spread of a wildfire, to the benefit of soil, as discussed earlier. 

3 Bars Project Final EIS 3-85 October 2016
SOIL RESOURCES 

Pinyon-juniper Treatments 

Adverse Effects 

Pinyon-juniper treatment areas are generally on moderate to steep hillslopes that are prone to erosion. Where trees are 

in dense stands, removal of these trees could lead to water and wind erosion as vegetative ground cover is mostly 

absent from these stands. These effects of vegetation loss would lessen as forbs and grasses improve ground cover, 

and soil loss could also be mitigated by leaving downed wood and slash on the ground as mulch. 

Manual treatments using chainsaws would have few effects on soil as there would be little soil disturbance. The 

effects of mechanical treatments on soil would depend on the following: 1) the amount of soil exposed during the 

treatment; 2) the effect of ground disturbance on soil properties; and 3) the site conditions, especially slope and 

patterns of precipitation. 

Mechanical treatments would affect soils by removing vegetation and by disturbing or removing topsoil. Because 

plant and litter cover protect the soil, and roots hold the soil in place, removal of plant materials exposes soil. Exposed 

soils are vulnerable to increased water and wind erosion and reduced water-holding capacity. Overall, about 37 

percent of pinyon-juniper management acreage has moderate to high water erosion potential, 16 percent has moderate 

to high wind erosion potential, and 32 percent is compaction prone. Of those areas where mechanical treatments could 

occur, about 18 percent of the treatment acreage is poorly suited for shredding. 

Although most of the mechanical treatments would not directly disturb the soil, the use of heavy equipment on 

treatment sites could result in increased soil compaction, and heavy equipment can shear and rut wet soils. 

Compaction by vehicles and other heavy machinery can reduce soil pores and limit water infiltration, soil aeration, 

and root penetration. Approximately 21 percent of treatment acres are prone to soil compaction. 

Mechanical treatments could disrupt biological soil crusts. Crusts are sensitive to compaction by vehicles and other 

heavy equipment. The removal or destruction of biological soil crusts could adversely affect soil quality by increasing 

susceptibility to erosion, reducing nitrogen inputs, reducing infiltration, and potentially encouraging weed 

establishment (USDOI BLM 2007c:4-15). 

The BLM would use manual and mechanical treatments to thin pinyon-juniper and create fuel breaks on up to 1,400 

acres on the Lone Mountain area. Most trees would be thinned using chainsaws, while fire breaks would be created 

using manual and mechanical methods, such as shredding. These methods have minimal impact on the soil layer, and 

soils on Lone Mountain are not prone to compaction. Approximately 60 acres have water erosion hazard, and 400 

acres have moderate wind erosion hazard. 

The BLM would thin and remove pinyon-juniper and create fuel breaks in several drainages on Roberts Mountains.

Treatment units include the Atlas, Birch, Frazier, Gable, Henderson, Upper Pete Hanson, Upper Roberts, and Vinini 

units. Approximately one-third of the proposed treatment acres are on soils that are susceptible to compacting, and the 

resulting adverse impacts to soil from erosion, runoff, sedimentation, and degraded soil quality would be of concern 

for this treatment group. In addition, approximately 17 percent of these areas has severe water erosion hazard. Nearly 

80 percent of these areas has moderate or high fire damage susceptibility, while 26 percent is poorly suited for 

shredding. Thus, mechanical treatments may be preferable to fire treatments if there is concern about soil damage and 

loss. 

3 Bars Project Final EIS 3-86 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

On the Three Bars Ranch, Cottonwood/Meadow Canyon, Dry Canyon, Lower Pete Hanson, Tonkin North, Tonkin 

South, Whistler, and Sulphur Spring Wildfire Management units, soil compaction risk occurs on about 15 percent of 

the treatment areas, and the resulting accelerated erosion, runoff, sedimentation, and degraded soil quality would be a 

minor adverse impact within this treatment group. Approximately 21 percent of the treatment area has severe water 

erosion hazard due to slopes and inherent soil conditions. About 70 percent of the area has moderate or high fire 

damage susceptibility, while 18 percent of the area is poorly suited for shredding. Thus, shredding treatments may be 

preferable to prescribed fire treatments if there is concern about soil damage and loss. Approximately 30 percent of 

the Sulphur Spring Wildfire Management Unit is at risk for water erosion, while 90 percent of the unit has moderate 

or high fire damage susceptibility. 

Potential adverse impacts from prescribed fires in pinyon-juniper treatment areas include greater vulnerability to 

accelerated erosion, loss of organic matter, temporarily reduced microbial populations, and the potential formation of 

water-repellent surface layers (Ice et al. 2004). Barger et al. (2012) found that prescribed fire in pinyon-juniper stands 

led to a 11- to 32-fold increase in wind erosion compared to shredded and control sites. He recommended that 

shredding should be preferred over prescribed fire where possible. Rau et al. (2005) observed that water repellency in 

pinyon-juniper forests varies by elevation and spatial variability in surface and soil organic matter associated with the 

vegetation. Spring burning in pinyon-juniper may cause a decrease in infiltration if coarse mineral particles are greater 

than 40 percent. They also noted that fall burning may lead to greater development of water repellency because fuel 

and soil moisture are typically lower in the fall. 

Biological soil crusts are generally killed by hot ground fires; however, lightly scorched biological crusts may still 

function to reduce erosion (USDOI BLM and USDOI USGS 2001). Extensive and severe wildfires often destroy 

biological crusts and leave the bare soil unprotected, whereas small, less intense prescribed burns may leave some 

biological soil crusts intact and functioning. Biological soil crusts provide little fuel to carry a fire through the 

interspaces, thus acting as a refugia to slow the spread of fire and decrease its intensity (Rosentreter 1986). Over 80 

percent of pinyon-juniper treatment areas is prone to fire damage that can create a water repellant soil layer, volatilize 

essential soil nutrients, destroy soil biological activity, and cause soil and water erosion on a burned site. Conducting 

prescribed burns when soils are not extremely dry, or during cooler times of the year, could reduce fire effects to soils 

and biological soil crusts. 

Beneficial Effects 

Restoration treatments that move woodlands toward historical ranges of variability would provide favorable 

conditions for soil functions and processes that contribute to long-term soil productivity at a broad scale (USDOI 

BLM 2007c:4-18). Erosion and sedimentation processes in pinyon-juniper stands would be reduced long-term by 

vegetation treatments. In a review by Wilcox and Davenport (1995), they found that as pinyon-juniper increases in 

density, the understory cover decreases. Hastings et al. (2003) observed accelerated erosion in areas where pinyonjuniper was encroaching into native woodlands and displacing native vegetation. Pierson et al. (2007) noted that 

juniper-dominated hillslopes had significantly lower ground cover and produced rapid runoff from rainfall events that 

was up to 15 times greater than on sites that were not dominated by juniper. They noted that cutting juniper stimulated 

herbaceous recovery, improved infiltration capacity, and protected the soil surface from rainfall events. Lossing 

(2012) observed that interception by pinyon-juniper reduced the amount of rainfall reaching the soil beneath the tree 

canopy by 44 percent. Mechanical treatments that ultimately result in improved plant cover and diversity can improve 

habitat for soil organisms and reduce the risk of soil erosion. Soil organic matter content, nutrient cycling, topsoil 

formation, and greater structural aggregation would increase following treatments. Soil fertility, aeration, and 

3 Bars Project Final EIS 3-87 October 2016
SOIL RESOURCES 

infiltration should also improve over time. The length of time for these effects to occur is likely to be on the order of 

years to decades, but improving trends may become noticeable after a few years (USDOI BLM 2007c:4-18). 

Chipping and shredding of vegetation can result in all or most of the organic material remaining on site. The 

application of large quantities of fresh, woody organic material to the soil surface can provide protection to the soil in 

the form of mulch. It is well documented that mulch results in attenuated soil temperatures, improved water 

infiltration, increased soil moisture retention, and reduced sediment yield. 

Several beneficial effects to soils would result from prescribed fires. These include increases in plant nutrient 

availability, and long-term enhancement of organic matter and microbial populations under desirable plant 

communities. 

Sagebrush Treatments 

Adverse Effects 

Mechanical treatments would be limited to overseeding and planting with native sagebrush and perennial grass 

species within intact sagebrush communities, and to treating noxious weeds and other invasive non-native vegetation. 

In areas where mechanical treatments could occur, water and wind erosion is of concern at several treatment units. 

Overall, about 24 percent of sagebrush treatment acreage has moderate to high soil erosion potential, 75 percent has 

moderate to high wind erosion potential, and 39 percent is compaction prone. The BLM would overseed with native 

species within intact sagebrush communities, on the Alpha, Coils Creek, Kobeh East, Nichols, Roberts Mountain 

Pasture, and South Simpson units; approximately 60 percent of sagebrush treatment areas for this group have wind 

erosion hazards. Seeding and planting in these areas should result in little loss of soil due to wind erosion. The BLM 

would seed and plant and remove Phase I and II pinyon-juniper on the Table Mountain, Three Corners, and Whistler 

Sage units. Phase I pinyon-juniper would be removed using chainsaws, and chainsaws would also be the preferred 

method for removing pinyon-juniper in Phase II stands. 

Most (84 percent) of the West Simpson Park Unit is susceptible to severe water erosion, and the Rocky Hills Unit has 

moderate risk of wind erosion (63 percent of potential treatment area). Use of equipment in these units could 

contribute to soil loss and reduced water infiltration, and some soils may not be well suited for use of shredding. 

As noted above, mechanical treatments could disrupt biological soil crusts and result in conditions that favor the 

spread of cheatgrass. Deines et al. (2007) found that lichen-dominated soil crusts inhibited germination and root 

penetration by cheatgrass. However, invasions of noxious weeds and other invasive non-native vegetation into 

perennial plant communities can pose a long-term threat to biological soil crusts, as the crust-dominated interspace 

between the perennial plants is often heavily invaded (USDOI BLM and USDOI USGS 2001, Reisner et al. 2013). 

Fire could be used on sagebrush treatment areas to remove cheatgrass and other non-native vegetation (crested 

wheatgrass and forage kochia) on the Rocky Hills and West Simpson Park units. About half of the acreage on the 

Rocky Hills and West Simpson Park units is moderately to highly susceptible to fire damage. 

Discing would be used to control non-native vegetation, while drill and broadcast seeding would be used to revegetate 

treatment sites. These methods could improve soil porosity and aerate the root zone in clayey or compacted soils, but 

may degrade soil structure and reduce permeability to air and water on more fragile soil surfaces. This could promote 

soil erosion. Similar impacts could occur from harrowing and dragging, but generally would be less severe because of 

the shallower nature of these techniques. Treatments would likely destroy any existing biological soil crusts in the 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

treatment area, which could reduce infiltration, accelerate erosion, and degrade soil microbiological properties 

(USDOI BLM 2007c:4-15). 

The BLM could use livestock, in combination with mechanical treatments, to control cheatgrass on all units, and 

cheatgrass, forage kochia, and crested wheatgrass on the Rocky Hills and Table Mountain Units. The action of animal 

hooves could cause some disturbance, shearing, and compaction of soil, increasing its susceptibility to both water and 

wind erosion. Severe compaction often reduces the availability of water and air to plant roots, sometimes reducing 

plant vitality. Domestic animals could damage biological soil crusts at treatment sites through physical disruption, 

resulting in reduced species richness and lichen/moss cover (Belnap et al. 2001). Biological soil crusts, however, are 

not likely to be well developed in areas dominated by non-native vegetation. 

Beneficial Effects 

Treatments that thin the sagebrush canopy and promote the development of understory vegetation would help to 

stabilize soils and reduce the risk of wind and water erosion. 

Sites with a large component of noxious weeds and other invasive non-native vegetation may be at a higher risk for 

erosion than sites that support native vegetation. Units with a large component of cheatgrass (fine fuels) may 

experience faster moving wildfires, which would adversely affect soils. Reestablishment of native vegetation on 

treatment sites would stabilize the fire cycle and lend to improved soil stability and productivity. 

3.9.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Adverse effects to soil would generally be the same as described for Alternative A. Excluding prescribed fire and 

wildland fire for resource benefit would avoid the increases in runoff and erosion common to burned areas. Reduced 

soil infiltration, due to resinous sealing after intense burning, and loss of soil microorganisms would not occur as a 

result of prescribed burns. 

The BLM would primarily be limited to mechanical methods (discing and seeding/planting) and using livestock to 

control cheatgrass over large areas. These methods could result in more soil disturbance and soil compaction than the 

use of fire. The West Simpson Park Unit is on rugged terrain, and use of mechanical equipment to control cheatgrass 

would be difficult and erosion potential from treatments would be great. The BLM would not be able to conduct 

prescribed burns to open up woodland stands to promote understory development and improve infiltration. The BLM 

also would not be able to use fire to remove hazardous fuels in Phase II and III pinyon-juniper stands. Thus, many of 

the beneficial, long-term effects of treatments on soils discussed under Alternative A would not be realized under 

Alternative B. 

3.9.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

The BLM anticipates treating about one-fourth as many acres under Alternative C as under Alternative A. Because 

the BLM would be unable to use mechanical methods, and prescribed fire and wildland fire for resource benefit, 

adverse impacts and benefits to soil would be similar to those described under Effects Common to All Alternatives. 

The risk of localized compaction and short-term accelerated erosion would be less under Alternative C than the other 

alternatives, as there would be little ground disturbance under Alternative C. By not being able to use mechanical 

methods, there would be less risk of soil compaction and erosion from these treatments, and less risk for soil 

disturbance that could lead to noxious weeds and other invasive non-native vegetation infestations. However, the 

BLM would not be able to use mechanical equipment to thin and remove pinyon-juniper and create mulch to promote 

3 Bars Project Final EIS 3-89 October 2016
SOIL RESOURCES 

understory development, improve soil fertility, reduce soil erosion, and increase infiltration. The BLM also would 

also not be able to use equipment to reduce hazardous fuels, create fire and fuel breaks, and pile and slash burn to 

remove downed wood and slash, increasing the risk of wildfire and its impacts on soil. Thus, many of the beneficial, 

long-term effects of treatments on soils discussed under Alternatives A and B would not be realized under Alternative 

C.

3.9.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to soil resources from this alternative as no treatments would be authorized under 

this alternative. The BLM, however, would not create fire and fuel breaks; thin and remove pinyon-juniper to promote 

healthy, diverse stands; slow the spread of noxious weeds and other invasive non-native vegetation, especially 

cheatgrass; restore fire as an integral part of the ecosystem; or reduce the risk of a large-scale wildfire. Thus, longterm loss of soil and soil productivity due to erosion, stream channel instability, pinyon-juniper encroachment, and 

wildfire would be greatest under Alternative D. 

3.9.3.4 Cumulative Effects 

The CESA for soil resources is approximately 1,841,700 million acres and includes those watersheds at the 

Hydrologic Unit Code 10 level that are all or partially within the 3 Bars Project area (Figure 3-1). Approximately 92 

percent of the area is administered by the BLM, 6 percent is privately owned, and 2 percent is administered by the 

Forest Service. Past and present actions that have influenced soil resources in the 3 Bars ecosystem are discussed in 

Section 3.3.2.3.3.

3.9.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Historic overgrazing, introduction of cheatgrass, large wildfires, and other natural and human-caused factors have 

contributed to the deviation of the plant communities from the Potential Natural Communities across the 3-Bars 

ecosystem. The Potential Natural Community is the plant community that would become established if all 

successional sequences were completed without interference by humans under current environmental conditions. 

Potential Natural Communities can include naturalized non-native species. 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 help these ecosystems recover their functionality 

and return to their Potential Natural Community. 

The BLM would continue wild horse management activities including AML reviews and adjustments, adjustments to 

HMA boundaries, wild horse gathers and fertility treatments to control wild horse populations, fence removal, 

enhancement of existing water sources and development of new water sources, and implementation of range 

improvement projects. These activities would better distribute wild horses across the range and reduce localized 

adverse effects to soils. The measures that the BLM would take to minimize livestock impacts to treatment areas are 

discussed in more detail in Section 3.18.4, and in Appendix C.

Land, utility, infrastructure, mineral, and other development, and oil, gas, and hydrothermal geothermal exploration 

and development, could affect about 10,000 acres in the reasonably foreseeable future, including about 8,335 acres of 

surface disturbance associated with the Mount Hope Project. Although disturbance areas would be reclaimed using 

soil removed from the site and stockpiled for later use, soil productivity may be less after reclamation. Land sales in 

Diamond Valley and Kobeh Valley associated with the Mount Hope Project, agriculture, ranching, and other land 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

development interests, and for rights-of-ways for power and telephone lines, could lead to loss of soil if land sales 

lead to a use of that land, such as undeveloped land being converted to a housing development. Impacts to soil 

resources would be similar to those described under direct and indirect effects, and would include compaction, 

removal, stockpiling, denudation, and alteration of runoff. Although many past actions were not subject to 

reclamation, most current and reasonably foreseeable activities would be subject to reclamation, especially those 

regulated by federal, state, or local agencies. 

The BLM would continue to conduct ground- and aerial-based herbicide application treatments to control noxious 

weeds and other invasive non-native vegetation. Although initial vegetation treatments using herbicides could 

indirectly lead to minor short-term soil erosion from the lack of rooting weedy plants, in the long-term those 

treatments would allow for deeper-rooting native plants to stabilize soils, enhance soil fertility, and reduce the risk of 

wildfire. Five herbicides are typically used on the 3 Bars Project area—2,4-D, glyphosate, imazapyr, metsulfuron 

methyl, and picloram. For the 3 Bars Project, it is likely that the BLM would also use imazapic to treat cheatgrass. 

Based on an assessment of risks to soil from the use of herbicides, there is potential for glyphosate and metsulfuron 

methyl to be transported by wind and water in areas with moderate to high risk of wind or water erosion. There should 

be few risks to soil organisms and soil productivity from use of these herbicides, however, as most of these herbicides 

degrade quickly (USDOI BLM 2007c:4-18).

Hazardous fuels reduction, habitat improvement, and invasive species control projects would occur on approximately 

142,000 acres (127,000 acres for the 3 Bars Project and 15,000 acres for other hazardous fuels projects in the CESA), 

or about 8 percent of the CESA during the life of the project. Loss of vegetation and soil disturbance associated with 

the use of treatment equipment could cause some short-term loss of soil functions, processes, and productivity on 

nearly all treated land. However, these treatments would help to reduce the risk of wildfire within the CESA, a major 

contributor to loss of soil functions and processes. In addition, the BLM would conduct stream bioengineering and 

plantings along about 31 miles of stream to restore surface water systems to Proper Functioning Condition to improve 

riparian habitat and reduce soil erosion. 

Although 3 Bars Project treatments would have short-term adverse effects on soil resources, soil functions and 

processes on about 127,000 acres should improve long-term as discussed under the direct and indirect effects of the 

alternatives. These benefits, along with those associated with hazardous fuels and habitat improvement projects 

elsewhere in the CESA (about 15,000 acres), would be greater under Alternative A than the other alternatives and 

would help to offset adverse effects to soils occurring elsewhere in the CESA from reasonably foreseeable future 

actions. 

3.9.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on soil would be similar to 

those described under Alternative A. The BLM anticipates treating about half as many acres under Alternative B as 

under Alternative A, and less effort would be spent by the BLM on treatments to reduce wildfire risk and loss of soil 

from erosion, including use of fire to restore natural fire regimes. 

Adverse effects to soil would generally be the same as described for Alternative A. However, by not using prescribed 

fire and wildland fire for resource benefit, there would be no risk to soil from fire treatments, including soil erosion, 

hydrophobicity, and loss of soil productivity, or increase in spread of noxious weeds and other invasive non-native 

vegetation. 

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SOIL RESOURCES 

The BLM would be limited to manual and mechanical methods and use of livestock to control noxious weeds and 

other invasive non-native vegetation on several thousand acres annually. These methods could result in more soil 

disturbance than the use of fire. By relying on manual, mechanical, and biological control methods, the BLM would 

be unable to use reduce hazardous fuels over large acreages, including dense stands of Phase II and III pinyon-juniper, 

and remove large amounts of downed woody material from treatment areas. Thus, the risk of wildfire and its effects 

on soil would be greater under this alternative than under Alternative A. 

Although 3 Bars Project treatments would have short-term adverse effects on soil resources, soil productivity on about 

63,500 acres should improve long-term, as discussed under the direct and indirect effects of the alternatives. Although 

these actions would benefit soils on the project area, and would help to offset adverse effects to soils occurring 

elsewhere in the CESA from reasonably foreseeable future actions, benefits to soils would not be as great as those that 

would occur under Alternative A. 

3.9.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on soil would be similar to 

those described under Alternative A. Under Alternative C, the BLM would treat about 3,200 acres annually within the 

3 Bars Project area, and about another 1,500 acres annually in the remainder of the CESA. Because of the limited 

number of acres treated, and lack of use of mechanical equipment and fire for 3 Bars Project treatments, short-term 

effects associated with the use of mechanical equipment and fire, including soil compaction, erosion, and disturbance, 

would not occur within the project area. 

By not being able to use mechanical methods and fire, however, the BLM would have limited ability to reduce 

hazardous fuels, create fire and fuel breaks, thin and remove pinyon-juniper and sagebrush to promote understory 

development, enhance stream habitat and channel stability and functions in the riparian zone, shred vegetation to 

create mulch to help reduce soil water erosion and improve water infiltration, and remove downed wood in the 3 Bars 

Project area. Thus, there would be more soil erosion, less improvement in soil productivity, less water infiltration, and 

greater risk of wildfire and its impacts on soil within the CESA than would occur under the other action alternatives. 

Actions taken under this alternative would help to offset adverse effects to soils occurring elsewhere in the CESA 

from reasonably foreseeable future actions, but not to the extent that would occur under the other action alternatives. 

3.9.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on soil would be similar to 

those described under Alternative A. There would be no cumulative impacts to soil resources from this alternative as 

no treatments would be authorized under this alternative. The BLM could conduct stream bioengineering treatments; 

create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of 

noxious weeds and other invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the 

ecosystem; and reduce the risk of a large-scale wildfire, but on a very limited acreage. Thus, loss of soil and soil 

productivity due to erosion, stream channel instability, spread of noxious weeds and other invasive and non-native 

vegetation, pinyon-juniper encroachment, and wildfire would continue on the 3 Bars Project area and would likely be 

greatest under this alternative. Treatments under Alternative D would do little to offset adverse effects to soils 

occurring from other reasonably foreseeable future actions within the CESA. 

3 Bars Project Final EIS 3-92 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.9.3.5 Unavoidable Adverse Effects 

Regardless of the method used to remove vegetation, restoration treatments could potentially result in adverse shortterm impacts to soil through increased erosion and reduced water infiltration, leading to loss of soil and reduced soil 

productivity. The degree of these effects would vary by treatment method (greater risk with mechanical and fire 

treatments), treatment type (greater risk with stream restoration in riparian zones), and soil risk category (greater risk 

in areas prone to water or wind erosion, or soil compaction), and if downed vegetation was left on the ground as 

mulch. To reduce this level of variability as much as possible, past treatment successes and failures would be 

evaluated and used to guide future treatment actions to ensure treatment success. 

Vegetation treatments could disturb biological soil crusts, potentially reducing soil quality and ecosystem 

productivity. The extent of impacts to biological soil crusts would be dependent on the intensity and kind of 

disturbance and the amount of area covered. The duration of the effects would vary, but recovery of biological soil 

crusts typically takes much longer than the recovery of vascular vegetation (USDOI BLM 2007b:4-243). 

3.9.3.6 Relationship between Local Short-term Uses and Maintenance and Enhancement 

of Long-term Productivity 

Although treatments would have short-term effects on soil condition and productivity, it is predicted that the soil 

disturbance associated with restoration activities would have less impact and be less severe than soil erosion caused 

by wildfire and encroachment by noxious weeds and other invasive non-native vegetation. Furthermore, monitoring 

and evaluation, integrated with an adaptive management approach, would allow the BLM to adjust treatments to 

reduce soil disturbance to levels that meet management objectives. 

Studies in woodland and rangeland environments indicate that landscapes that resemble conditions within historical 

ranges of variability provide favorable conditions for soil functions and processes that contribute to long-term 

sustainability of soil productivity. Restoration activities that move landscapes toward historical ranges of variability 

would provide favorable conditions for soil functions and processes, and contribute to long-term soil productivity 

levels at a broad scale (USDOI BLM 2007b:4-247). 

3.9.3.7 Irreversible and Irretrievable Commitment of Resources 

Disturbance activities associated with proposed treatments could result in soil erosion and loss of soil and soil 

productivity. This loss of soil and soil productivity would be irretrievable in the disturbance area, although the soil 

could be available for use at some other location. This commitment of resources could extend over many years, 

depending on treatment methods and site-specific conditions, until soil quality attributes improved either through 

amendments or natural processes. However, a benefit of increasing the amount of acres treated would be to slow the 

loss of soil and soil productivity due to noxious weeds and other invasive non-native vegetation and wildfire, and to 

restore soil structure and function on degraded sites as part of a larger goal to restore native ecosystem processes. As a 

result of these actions, soil productivity in disturbed areas should reestablish over time (USDOI BLM 2007b:4-251). 

3.9.3.8 Significance of the Effects under the Alternatives 

Under all alternatives, there would be a short-term (less than 5 years) increase in soil erosion from 3 Bars Project and 

other CESA habitat improvement and hazardous fuels reduction treatments, primarily those where the soil is disturbed 

by mechanical or fire treatments, or by large-scale removal of non-native vegetation using herbicides. This increase in 

3 Bars Project Final EIS 3-93 October 2016
SOIL RESOURCES 

erosion could lead to increased sedimentation or turbidity in streams or ponds. These impacts from soil erosion would 

accrue with soil erosion and loss of soil associated with other land disturbance activities in the CESA. These losses of 

soil due to erosion and its impacts to water quality in streams and ponds in the CESA would be offset by long-term 

benefits from: 1) stream restoration projects that promote stream stability and riparian vegetation development; 2) 

improvements in vegetation in areas where thinning pinyon-juniper and sagebrush promotes understory development; 

3) removal and control on noxious weeds and other invasive non-native vegetation; 4) revegetation of treatment sites 

with native vegetation; and 5) hazardous fuels treatments that reduce the risk of a catastrophic wildfire, including 

prescribed burning and use of wildland fire for resource benefit, and the creation of fire and fuel breaks. 

It is possible that prescribed fire and wildland fire for resource benefit treatments could result in erosion that could 

exceed annual soil loss tolerances, and in the loss of topsoil, soil quality, or productivity that could limit revegetation 

success. Based on monitoring done by the BLM at fire treatment sites, loss of soil is low when sites are revegetated 

and noxious weeds and other invasive non-native vegetation is removed from treatment sites (USDOI BLM 2007c:4-

18). There is also the potential that large-scale non-native control treatments using mechanical equipment could result 

in loss of vegetation and soil over large areas. However, the BLM would use SOPs to minimize this risk, including 

discing on contour, avoiding treatments on steep slopes, and restricting livestock access to treatment sites. Based on 

monitoring, loss of soil would be greater in areas burned by wildfire, as these areas can be large, are often in remote 

areas, and can be difficult to revegetate (Erickson and White 2008). Thus, BLM treatments that reduce the risk of 

wildfire should help to slow soil loss and loss of soil quality and productivity in the project area. 

There should be an overall improvement in soil quality and productivity from treatments under all alternatives. 

Although the risks and benefits to soil from 3 Bars Project treatments would be greatest under Alternative A, proper 

adaptive management should greatly reduce risks by identifying and addressing treatment issues as they arise. 3 Bars 

Project treatments would not result in a long-term (greater than 5 years) significant increase in soil erosion, water 

quality degradation from soil erosion, loss of topsoil, or loss of soil quality or productivity in the 3 Bars Project area 

or CESA. 

3.9.4 Mitigation 

Soil resources would benefit from mitigation and monitoring measures identified in Section 3.18.4 (Livestock 

Grazing Mitigation). No mitigation or monitoring measures are recommended specifically for soil resources. 

3.10 Water Resources 

3.10.1 Regulatory Framework 

Major regulations and agency policies guiding water resources management include: 

 Clean Water Act Section 303 – Water Quality Standards and Implementation Plans. This requires each state 

to review, establish, and revise water quality standards for all surface waters within the state. Designated 

beneficial uses are assigned to surface waters. 

 Clean Water Act Section 404 – Permits for Dredged or Fill Material. This regulates activities in wetlands and 

waters of the U.S. Subsequent court decisions and regional guidelines apply. 

3 Bars Project Final EIS 3-94 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 Safe Drinking Water Act – 40 CFR Chapter 1, Subchapter D, Part 142 (National Primary Drinking Water 

Regulations) and Part 143 (National Secondary Drinking Water Standards). 

 Title 40 Nevada Revised Statutes, Chapter 445A – State of Nevada water controls (authority for waterbody 

designated uses and water quality criteria). 

 Title 48, Nevada Revised Statutes – State of Nevada water use administration. 

 Nevada Administrative Code Chapter 445A.070 through 445A.2234, “Water Pollution Control” including 

beneficial use categories, water quality classes, and associated water quality criteria and standards 

promulgated from the Clean Water Act and Nevada Revised Statutes listed above. 

Additional important policies and procedures involving water resources for the project area include water rights and 

water quality programs administered in the Nevada Division of Water Resources and Nevada Division of 

Environmental Protection; Memoranda of Understanding between the BLM and other state or federal agencies; and 

BLM policies developed under the Rangeland Health Standards promulgated under 43 CFR § 4180.2. The Federal 

Land Policy and Management Act, BLM Handbook H-4180-1 (Rangeland Health Standards; USDOI BLM 2001), 

and BLM Manual H-1601-1 (Land Use Planning Handbook; USDOI BLM 2005c), describe the agency goals and 

management approaches for water resources and riparian zones.

3.10.2 Affected Environment 

3.10.2.1 Study Methods and Study Area 

Information sources consulted for water resources include data, maps, and publications from the Nevada Division of 

Water Resources, USGS, a Montgomery and Associates (2010) report entitled Hydrogeology and Numerical Flow 

Modeling, and the Mount Hope Project EIS and references cited therein (USDOI BLM 2012b). 

The study area for direct and indirect effects to water resources lies within the 3 Bars Project area. The study area for 

cumulative effects to water resources is the Hydrologic Unit Code 10 watersheds wholly or partially within the project 

area (Figure 3-1). This area includes parts of the drainages and groundwater basins as defined by the Nevada Division 

of Water Resources and identified in Table 3-14. 

3.10.2.2 Hydrologic Setting 

3.10.2.2.1 Overview 

Most precipitation accumulates as snow on the mountain ranges. The highest elevations consist of moderately to 

steeply sloping mountains and ridges such as the Roberts Mountains. Rock outcrops are common at elevations above 

about 8,000 feet amsl and contribute to the increased extent of impervious areas there. Moderate to high gradient 

headwater streams occur at these elevations, mainly supplied by cold springs and snowmelt. In this zone, riffle 

sections in the streams generally have cobbly substrates (Bryce et al. 2003). 

3 Bars Project Final EIS 3-95 October 2016
WATER RESOURCES 

TABLE 3-14

Nevada Hydrographic Areas Included in the Water Resources Assessment 

Hydrographic 

Area Basin Number Basin Area (acres) Area within Project Boundary (acres)

Approximate Percentage 

of Basin Area within 3 

Bars Project Area

Pine Valley 053 640,588 269,482 42

Grass Valley 138 379,846 59,174 16

Kobeh Valley 139 551,961 341,495 61

Diamond Valley 153 477,506 79,659 17

Total 2,049,901 749,810 36

Source: Nevada Division of Water Resources (2012). 

Most of the annual runoff within the project area is derived from snowmelt. In the spring months, typically April 

through June, snowmelt produces runoff, which often results in the highest seasonal flows in the high mountain 

drainages. Occasionally, spring season rainfall coincides with the snowmelt, resulting in extremely high runoff. 

While there is potential for heavy thunderstorm events in mid- to late summer, spawned by moisture from the 

desert southwest, the hot, dry weather at this time of year, typically combined with little or no rain and high 

evaporation rates, generally produces the lowest flows of the year (USDOI BLM 2012b).

During the spring snowmelt period, water flows from the mountain ranges into nearby basins. As water flows from 

the mountains towards the valleys, it infiltrates into basin fill deposits along the range fronts. Thus, recharge into the 

basin fill deposits occurs along the margins of the valleys (or at higher elevations), and, except during times of high 

runoff, not in the central portion of the valleys. 

Soils at mid-elevations are commonly rocky and shallow, promoting runoff. Perennial or intermittent moderategradient streams occur at middle elevations, and are supplied by snowmelt and springs. Broad alluvial fans and flatter 

saline playa deposits commonly accumulate in the extensive lower-elevation terrain. Eroded gullies are generally 

more common at lower elevations, and permanent lakes are uncommon to absent. In general, the lower elevation 

streams are relatively low-gradient, with substrates consisting of finer sediments (Bryce et al. 2003). 

3.10.2.2.2 Basin Hydrology 

Of the major basins in the study area, only Pine Valley drains outward to a larger surface water system (the Humboldt 

River). Kobeh Valley drains to Diamond Valley. The remaining three basins (Diamond, Grass, and Antelope basins) 

are closed, with no external surface drainage. 

Kobeh Valley is a large basin with a drainage area of approximately 870 square miles. This basin is bounded on the 

north by the Roberts Mountains, on the west by the Simpson Park Mountains, on the east by Whistler Mountain, and 

on the south by the Monitor Range and Monitor and Antelope Valleys. Elevations on the basin floor range from 6,400 

feet amsl on the west side of the basin to around 6,000 feet amsl on the east side at Devils Gate, an erosional gap that 

allows surface water from Kobeh Valley to enter Diamond Valley. Surface water also occasionally flows into the 

southern part of Kobeh Valley via the main ephemeral drainages in Antelope Valley (Antelope Wash) and the 

northern part of Monitor Valley (Stoneberger Creek). Ephemeral streams bring mountain-front runoff from the north, 

east, and south, and converge in the vicinity of U.S. Highway 50. This water is sufficiently close to the surface to 

allow for the development of an extensive area of phreatophytes, which are deep-rooted plants that obtain water from 

3 Bars Project Final EIS 3-96 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

a permanent ground supply or from the water table. Springs in Kobeh Valley are found mainly within the mountains 

that border the valley, while wells are found throughout the basin (USDOI BLM 2012b).

Diamond Valley has a drainage area of approximately 750 square miles and is bounded on the west by the Sulphur 

Spring Range and Whistler Mountain, on the north by Diamond Hills, on the east by the Diamond Mountains, and on 

the south by the Fish Creek Range. The valley floor of Diamond Valley ranges in elevation from 6,200 feet amsl to 

5,770 feet amsl at the playa found in the north end of the valley. Surficial drainage is from the bounding mountain 

ranges to the central axis of the valley and then northward to the playa. Diamond Valley is a closed basin and an 

extensive playa occupies the northern end of the valley, where all shallow groundwater flow converges. Agricultural 

irrigation and withdrawals of groundwater for municipal water supply occur in the southern part of the valley, north of 

Eureka, Nevada. Shallow alluvial groundwater in this area is recharged by mountain-front runoff from the major 

drainages near Eureka. Many springs are found within Diamond Valley at the north end, where groundwater flow 

converges and the water table in the shallow alluvial aquifer approaches the surface (USDOI BLM 2012b). 

Pine Valley is north of Kobeh Valley and west of Diamond Valley. This basin is bounded on the south by Roberts 

Mountains, on the west by the Sulphur Spring Range, and on the north and west by the Cortez Mountains. The basin 

occupies approximately 1,000 square miles and drains northward to the Humboldt River. Basin floor elevations range 

from 5,800 feet amsl at the south end near Henderson Creek to 4,840 feet amsl at the north end. The Garden Valley 

sub-basin occupies the southeastern part of Pine Valley and is a separate basin between the Roberts Mountains and 

the Sulphur Spring Range. Drainage in this sub-basin converges on Henderson Creek and flows into Pine Valley. 

Springs in Pine Valley are mostly in the bounding mountain ranges, with local areas of springs in the basin along 

major drainages. Wells are found at the north end of Pine Valley in the area where ephemeral drainages from the 

mountains converge. There are a few wells in the Garden Valley sub-basin near Henderson Creek (USDOI BLM 

2012b). 

Grass Valley is west of Kobeh Valley and is a closed hydrographic basin bounded on the east by the Simpson Park 

Mountains and on the west by the Toiyabe Range. The Cortez Mountains bound the valley to the north (Everett and 

Rush 1966). The valley consists of two sub-basins that are interconnected, a smaller basin at the southwest end of the 

valley that is east of Mount Callaghan and the main part of Grass Valley. The lowest elevation in the valley is 5,611 

feet amsl in the playa that occupies the northern part of the basin. The highest point is Mount Callaghan in the 

Toiyabe Range at 10,187 feet amsl. The basin has internal drainage only and groundwater is recharged by mountainfront runoff. Springs are found mainly in the smaller sub-basin at the southwest end of Grass Valley and along the 

mountain fronts where the basin alluvium contacts the bedrock of the bounding mountain ranges. All water in the 

basin flows toward the playa in the northern part of the basin and groundwater comes sufficiently close to the surface 

in the vicinity of the playa to allow for the development of an extensive area of phreatophytes. Limited irrigation and 

farming of alfalfa are found south of the playa (USDOI BLM 2012b). 

Antelope Valley, although not a part of the hydrologic study area, is located south of Kobeh Valley and south of 

Diamond Valley. It is part of the regional groundwater flow system. This basin occupies 450 square miles and drains 

into Kobeh Valley. Groundwater in Antelope Valley also flows north into Kobeh Valley through the same gap as the 

surface water drainages. Elevations in Antelope Valley range from 6,800 feet amsl on the south end to around 6,075 

feet amsl at the gap between Antelope Valley and Kobeh Valley (USDOI BLM 2012b).

Kobeh Valley, Diamond Valley, and Antelope Valley are part of the Diamond Valley Regional Flow System as 

described by Harrill et al. (1988 cited in USDOI BLM 2012b). Basins that are part of this flow system are internally 

connected by ephemeral streams and subsurface groundwater flow through the alluvial basin aquifers and the bedrock 

3 Bars Project Final EIS 3-97 October 2016
WATER RESOURCES 

carbonate aquifers (Tumbusch and Plume 2006). Diamond Valley is the terminus of this flow system and the water 

resources at the south end of Diamond Valley have been developed for use in agricultural irrigation, mining in the 

Eureka area, and for municipal water supply for Eureka. Pine Valley, the Garden Valley sub-basin connected to Pine 

Valley, and Grass Valley are part of the Humboldt Regional Flow System (Harrill et al. 1988 cited in USDOI BLM 

2012b), where surface and groundwater flows northward to the Humboldt River system. 

3.10.2.3 Surface Water Resources 

3.10.2.3.1 Streams and Creeks - Overview 

Numerous perennial, intermittent, and ephemeral streams occur within the project area (Table 3-15). In general, 

perennial segments have their source in the mountains and, although they do respond to snowmelt and rainfall 

events, much of their flow is provided by groundwater discharge that occurs as spring flow. Perennial flow only 

occurs in a relatively few isolated stream reaches (Figure 3-22). Stream flows in the 3 Bars Project area primarily 

occur as intermittent flows from isolated springs, as short-term seasonal runoff from snowmelt or winter storms, or 

1

as ephemeral flow from intense but infrequent thunderstorms. Numerous drainages leave the mountain fronts and 

cross over alluvial fans, where flows typically dissipate. When water does reach the valley floor during larger runoff 

events, the water is soon taken up by evapotranspiration and seepage into valley-floor sediments. Channels become 

poorly defined as they near the flatter portion of the basins and runoff infiltrates into permeable alluvial fan material 

(USDOI BLM 2012b).

Major perennial stream reaches include parts of Henderson Creek, McClusky Creek, Pete Hanson Creek, Roberts 

Creek, Vinini Creek, and Willow Creek. Additional, shorter perennial reaches occur on Birch Creek, Kelley Creek, 

Ferguson Creek, and in scattered locations on other streams throughout the project area. 

The USDOI USGS (2012c) is monitoring streamflow at several locations within the project area (Table 3-16). 

Although monitoring only began in 2011, it is apparent that daily surface flows vary widely. The maximum flow 

months generally occur in spring, and the smallest flows are usually in late summer. Tonkin Spring has the steadiest 

flow of the stations in the USGS monitoring program. 

In addition to USGS monitoring, stream studies were carried out for the Mount Hope Project EIS (JBR 2009, USDOI 

BLM 2012b). The results of these investigations, which were conducted in the Pine Valley basin draining the northern 

and eastern Roberts Mountains, are summarized in Table 3-17. These investigations included the upper portions of 

Birch Creek, Henderson Creek, Pete Hanson Creek, and Vinini Creek. All measurements and samples were collected 

within the mountainous portions of the streams. They were conducted in a short time frame in late March and early 

April, 2009. Based on the amount of snowpack and occurrence of bare ground during the investigation, it was evident 

that some snowmelt and spring run-off had occurred prior to the initial sampling period. The air temperature was 

typically above freezing during the days, and snowmelt and runoff were observed (JBR 2009). 

 

1

 The USGS does not distinguish between intermittent and ephemeral streams. The majority of streams classified as intermittent on the 3 

Bars Project area do not have seasonal water, but only have water occasionally and would be classified as ephemeral. 

3 Bars Project Final EIS 3-98 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-22

Streams, Lakes, Ponds,

and Wetlands

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander CountyEureka

County

Pine Valley

Basin # 053

Diamond Valley

Basin # 153

Grass Valley

Basin # 138

Kobeh Valley

Basin # 139

B irch Creek

Dry Creek

Ferguson Cr eek

Horse Creek

Coils Creek

Niel Creek

R utabaga Creek

Denay C reek

Roberts Creek

McC lu s ky Creek

Roberts Creek

Wil ol wCree k

Henderson Creek

Vin ini Creek

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Spring

Moist Site

Perennial Stream

Intermittent Stream

Canal/Ditch

Lake or Pond

Playa

Freshwater Emergent

Wetland

Freshwater Forested/

Shrub Wetland

Hydrographic Basin

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012g, USFWS 2012, NDOW 2012a, NDWR 2012, USGS 2012b.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
WATER RESOURCES 

TABLE 3-15

Perennial and Intermittent/Ephemeral Streams in the Project Area 

3 Bars Project Final EIS 3-100 October 2016

Basin 

Number Basin Name Stream Name

Perennial 

Stream 

Miles

Intermittent/ 

Ephemeral

Stream Miles1

Canal/ 

Ditch

Total 

Miles

053 Pine Valley

Birch Creek 1.50 5.07 6.57

Denay Creek 2.22 22.61 24.83

Dry Creek 8.38 8.38

Frazier Creek 5.86 5.86

Garden Pass Creek 0.98 0.98

Geyser Creek 7.33 7.33

Grouse Creek 2.30 2.30

Henderson Creek 18.34 11.28 29.62

Horse Creek 9.08 9.08

Indian Creek 8.68 8.68

Kelley Creek 2.20 0.68 2.88

Niel Creek 5.21 5.21

North Fork Pete Hanson Creek 1.71 0.69 2.40

Pete Hanson Creek 6.07 12.84 18.91

Pine Creek 12.84 12.84

Vinini Creek 9.51 9.51

Willow Creek 6.74 6.31 13.05

Unnamed Creeks 7.85 728.76 1.87 738.48

138 Grass Valley

Coils Creek 0.94 0.94

Indian Creek 0.01 0.01

McClusky Creek 7.12 3.26 10.38

Pine Creek 0.04 0.04

Unnamed Creeks 5.09 138.46 143.55

139 Kobeh Valley

Coils Creek 35.62 35.62

Cottonwood Creek 4.42 2.45 6.87

Ferguson Creek 5.09 4.53 9.62

Horse Creek 4.56 4.56

Jackass Creek 2.96 2.96

North Branch Horse Creek 0.89 0.89

North Fork Horse Creek 2.42 2.42

Roberts Creek 8.38 15.31 23.69

Rutabaga Creek 12.79 12.79

Slough Creek 7.78 7.78

South Fork Horse Creek 1.64 1.64

Stoneberger Creek 5.67 5.67

U’ans-in-dame Creek 15.14 15.14

Underwood Creek 11.06 11.06

Willow Creek 0.27 0.27

Unnamed Creeks 9.22 1,015.89 1.33 1,026.44
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-15 (Cont.) 

Perennial and Intermittent/Ephemeral Streams in the Project Area 

Basin 

Number Basin Name Stream Name

Perennial 

Stream 

Miles

Intermittent/ 

Ephemeral

Stream Miles1

Total 

Miles

153 Diamond 

Valley

Garden Pass Creek 6.01 6.01

Slough Creek 0.57 0.57

Tyrone Creek 4.57 4.57

Unnamed Creeks 0.11 192.53 192.64

Totals 95.57 2,334.27 3.20 2,433.14

1

 The USGS does not distinguish between intermittent and ephemeral streams. The majority of streams classified as intermittent on the 3 

Bars Project area do not have seasonal water, but only have water occasionally and would be classified as ephemeral.

Sources: JBR (2009), Montgomery and Associates (2010 cited in USDOI BLM 2012b), and USDOI USGS (2012b).

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). 

3.10.2.3.2 Streams and Creek Flows by Basin

The following describes stream and creek flows by basins within the 3 Bars Project area. This information is based on 

studies for the Mount Hope Project EIS, and references cited therein (USDOI BLM 2012b). Major perennial stream 

reaches occur within the Pine Valley (56.1 miles), Grass Valley (12.2 miles), Kobeh Valley (27.1 miles), and 

Diamond Valley (0.11 mile) watersheds. In addition, approximately 2,334 miles of intermittent/ephemeral stream 

reaches have been identified in the project area. 

Kobeh Valley 

In Kobeh Valley, surface drainage is directed generally from the mountains to the central valley floor and then 

eastward toward Devils Gate, where flow occasionally passes into Diamond Valley via Slough Creek (Figure 3-22,

Table 3-15). Surface water occasionally flows into the southern part of Kobeh Valley via the main ephemeral 

drainages in Antelope Valley (Antelope Wash) and the northern part of Monitor Valley (Stoneberger Creek). The 

Stoneberger Creek drainage enters the southwestern side of Kobeh Valley from Monitor Valley and crosses southern 

Kobeh Valley in a west to east direction through Bean Flat. Antelope Wash enters Kobeh Valley from the south at a 

point where several ephemeral drainages join on the southeastern side of Kobeh Valley to form Slough Creek. Slough 

Creek, also ephemeral, drains east through Devils Gate into southern Diamond Valley. Channel geomorphology and a 

lack of vegetation scour indicate that outflow through Devils Gate is a rare occurrence related to low frequency, high 

runoff events. 

The two main internal drainages within Kobeh Valley are Coils Creek in the western part of the valley, which drains 

the east side of the Simpson Park Mountains and the western side of the Roberts Mountains, and Roberts Creek, 

which drains the central and southeastern part of the Roberts Mountains. Rutabaga Creek lies between these two 

drainages and drains the southern part of the Roberts Mountains. 

3 Bars Project Final EIS 3-101 October 2016
WATER RESOURCES 

Roberts Creek is perennial from the headwaters of its middle and east fork tributaries to near the base of the mountain. 

A segment of the Cottonwood Canyon drainage, on the southwest side of the Roberts Mountains, is also identified as 

containing perennial flow upstream of its confluence with the Coils Creek drainage. The only other identified 

perennial stream reaches in Kobeh Valley are Snow Water Canyon and Ferguson Creek on the east side of the 

Simpson Park Mountains, as well as Ackerman Creek, Basin Creek, Coils Creek, Dry Canyon, Dry Creek, Kelly 

Creek, Jackass Creek, and Meadow Canyon. A small segment of U’ans-in-dame Creek to the east-northeast of Lone 

Mountain has also been classified by the USGS as perennial. However, other investigations indicate that based on 

2010 field observations, a review of Landsat images, and the USDA’s National Agricultural Imaging Program aerial 

photography, it is now believed that this stream segment is not perennial (Montgomery and Associates 2010, USDOI 

USGS 2012c). 

TABLE 3-16

Flow Summary from U.S. Geological Survey Monitoring Stations 

3 Bars Project Final EIS 3-102 October 2016

Waterbody

USGS 

Station 

Number

Monitored 

Location 

(Latitude / 

Longitude)

Monitoring 

Period

Average 

Recorded 

Flow (cfs)

Maximum 

Recorded 

Flow (cfs) 

Minimum 

Recorded 

Flow (cfs)

Maximum 

Monthly 

Average 

Flow (cfs)

Minimum 

Monthly 

Average 

Flow (cfs)

Coils Creek 

above Horse 

Creek

10245960 39° 46’ 11” 

116° 27’ 52”

1/12/2011 to 

9/30/2011 11.0 64 (1/17/2011)

0

(many) 24 (Apr) 0.01 (Aug)

Henderson 

Creek below 

Vinini Creek

10322535 39° 52’ 08” 

116° 10’ 01”

1/11/2011 to 

6/2/2012 8.1 19 (5/23/2011)

0

(many) 14 (May) 0.02 (Sep)

Pete Hanson 

Creek above 

Henderson 

Creek

10322555 39° 53’ 25” 

116° 22’ 42”

5/5/2011 to 

6/2/2012 9.7 17 (6/15/2011)

0

(4/2012) 12 (Jun) 0.84 (Sep)

Roberts 

Creek 10245970 39° 47’ 23” 116° 18’ 03”

6/4/2011 to 

6/2/2012 2.8 11(6/2012)

0.18 

(1/2012) 8.9 (Jun) 0.68 (Aug)

Tonkin 

Spring above 

Denay Creek

10322510 39° 54’ 17” 

116° 24’ 45”

8/26/2010 to 

6/2/2012 1.7 2.4(9/2011)

1.0 

(1/2011)

2.0 (May, 

Aug) 1.2 (Jan)

cfs = cubic feet per second. 

Source: USDOI USGS (2012c).

TABLE 3-17

Site-specific Stream Investigations 

Stream Measurement 

Date

Range in Channel 

Widths

(feet)

Flow Range

(gpm)

Flow Range

(cfs)

Birch Creek March 22-26, 2009 2.7 to 3.9 64 to 274 0.14 to 0.61

Pete Hanson Creek March 3-27, 2009 0.9 to 5.7 269 to 614 0.60 to 1.37

Vinini Creek March 25, 2009 1.3 to 3.8 15 to 269 0.03 to 0.60

Henderson Creek April 7, 2009 2.2 to 2.5 269 to 359 0.60 to 0.80

gpm = gallons per minute. 

cfs = cubic feet per second. 

Source: JBR (2009). 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Stream discharge measurements were taken along the course of Roberts Creek in 2007 (Montgomery and Associates 

2010). Measurements made during August 2007 on the tributaries of Roberts Creek indicated that most of the flow 

originated from the east fork, at 108 gallons per minute (gpm; 0.24 cubic feet per second [cfs]), which received its 

flow from springs along the west and south to southeast flanks of the Roberts Mountains. The west and middle forks 

of Roberts Creek contributed little flow at that time, with the west fork being dry, and the middle fork discharge 

estimated at 4.5 gpm (0.01 cfs; Montgomery and Associates 2010). Measured discharge below the confluence of the 

three forks of Roberts Creek consistently decreased with distance downstream, indicating that Roberts Creek loses 

water over most of its length. These stream losses are assumed to result in recharge to the local alluvial and carbonate 

aquifer systems. Flow loss due to evaporation and transpiration from riparian vegetation adjacent to the stream bed 

may also be a contributing factor to the consistent downstream decrease in flow. 

Coils Creek is interpreted by Rush and Everett (1964) to be the principal tributary to Slough Creek. They reported a 

flow of approximately 3,600 gpm (8 cfs) in May 1964 at a location in Section 27, Township 22 North, Range 49 East, 

in the west-central portion of the project area. Intermittent reaches of upper Coils Creek are mainly fed by spring flow 

and are used for irrigation purposes. More recent estimates of flows in Coils Creek are presented in Table 3-16. 

In August 2007, Montgomery and Associates (2010) measured a flow of 9 gpm (0.02 cfs) in Rutabaga Creek on the 

southern flanks of the Roberts Mountains. Along the east slope of the Simpson Park Mountains, on the west side of 

Kobeh Valley, no surface flow was observed by Montgomery and Associates (2010) in Snow Water Canyon during 

June and December 2007, and April 2008. No surface flow was observed in Ackerman Canyon in April 2008, but a 

flow of 27 gpm (0.06 cfs) was observed in May 2008. An estimated surface flow of less than 112 gpm (0.25 cfs) was 

observed in Ferguson Creek in May, but not in August 2007. No surface flow was observed in Dry Canyon in June 

2007. At the stream gauge on Roberts Creek, flows were 561 and 1,872 gpm (1.25 and 4.17 cfs) during April and 

May 2008, respectively. 

Reported flows in Willow Creek and Dagget Creek, which drain the north end of the Monitor Range in southern 

Kobeh Valley, were approximately 450 and 670 gpm (1 and 1.5 cfs), respectively, in May 1964 (Robinson et al. 

1967). No other drainages within the Kobeh Valley basin have recorded stream flows. 

Pine Valley

The main streams in Pine Valley are in the Horse Creek, Denay Creek, Henderson Creek, and Pine Creek drainages 

(Figure 3-22, Table 3-15). Pine Creek is the principal stream in the valley and is a tributary to the Humboldt River. 

Eakin (1961 cited in USDOI BLM 2012b) reported that the flow in Pine Creek is maintained primarily by the 

discharge from hot springs. 

Numerous headwater tributaries to Pine Creek form on the east- and southeast-facing slopes of the Cortez Mountains 

(Horse Creek drainage) and the northern part of the Simpson Park Mountains (Denay Creek drainage); on the north to 

northwest flanks of the Roberts Mountains (Pete Hanson Creek, Neil Creek, Kelly Creek, Birch Creek, Willow Creek, 

and Dry Creek); and on the northeast side of the Roberts Mountains in the Garden Valley subbasin (Henderson Creek, 

Vinini Creek, and Frazier Creek). Perennial streamflow segments have only been identified on portions of Denay 

Creek, Pete Hanson Creek, Willow Creek, Vinini Creek, and Henderson Creek (USDOI BLM 1997 cited in USDOI 

BLM 2012b). 

Isolated reaches in the Horse Creek drainage of Pine Valley were reported to have flows ranging from 9 to 58 gpm 

(0.02 to 0.13 cfs) during August 2005 before surface flows were lost to infiltration or evapotranspiration (USDOI 

3 Bars Project Final EIS 3-103 October 2016
WATER RESOURCES 

BLM 2008g). The Denay Creek drainage arises from headwater springs in Red Canyon on the north slope of the 

Roberts Mountains, and is fed lower down in the drainage by perennial discharge from Tonkin Spring (Table 3-16). 

Denay Creek discharges into Tonkin Springs Reservoir, a small surface-water impoundment, approximately 1 mile 

downstream of Tonkin Spring. Between August 2007 and September 2009, Montgomery and Associates (2010) 

measured the discharge from Tonkin Spring during all months of the year, and the range of observed flows was from 

525 to 1,086 gpm (1.17 to 2.42 cfs). This is generally within the range reported by the USDOI USGS (2012c; Table 

3-16). This provides an estimate of the flows in Denay Creek just downstream of Tonkin Spring. Further east, along 

the north side of the Roberts Mountains, no flow was reported in Pete Hanson Creek during August 2007, but a flow 

of 1,023 gpm (2.28 cfs) was reported in June 2009. Also, Willow Creek was observed to have flows of 31 and 9 gpm 

(0.07 and 0.02 cfs) in August and October 2007, respectively (Montgomery and Associates 2010). 

As part of the baseline characterization investigations for the proposed Mount Hope Project, three surface water 

monitoring stations were established on Henderson Creek in 2006, allowing two distinct reaches of the creek to be 

studied (Table 3-17). The upper monitoring station is approximately one-half mile southeast and downgradient of 

Spring 585 at an elevation of approximately 7,177 feet amsl. SRK (2008) reported that the creek flow is perennial at 

the upper monitoring station, with the flow is sustained by discharge from local springs and seeps. The middle 

monitoring station is approximately 2 miles downgradient of the upper station and is approximately 50 feet below the 

confluence of the north and south forks of Henderson Creek at an elevation of approximately 6,688 feet amsl. The 

creek flow at this location is also thought to be perennial and fed by springs and seeps in the upper part of the 

watershed. The stream channel morphology at the middle monitoring station is described as being substantially 

incised, with arroyo-like features. The lower monitoring station is approximately 2.5 miles downgradient of the 

middle station and is roughly 60 feet west of State Route 278 at an elevation of approximately 6,446 feet amsl. SRK 

characterized the lower reach as being perennial, but noted that the actual flowing locations of the creek near the 

lower monitoring station vary on a seasonal basis, such that the established sampling-point location was observed to 

be dry in the third and fourth quarters of 2006 and the first quarter of 2007. 

During site visits in May 2006 and 2007, SRK (2008) recorded maximum flow rates of approximately 400, 3,180, and 

2,600 gpm (0.9, 7.1, and 5.8 cfs) at the upper, middle, and lower monitoring stations, respectively, on Henderson 

Creek. Subsequent monitoring events recorded smaller flow rates, ranging from 45 to 112 gpm (0.1 to 0.25 cfs), at the 

upper and middle monitoring stations and no flow at the lower station. 

Stream flow measurements were also made on Henderson and Vinini Creeks, north of Mount Hope in the Garden 

Valley subbasin of Pine Valley (Montgomery and Associates 2010). During August and October 2007, Vinini Creek 

was observed to be dry, whereas in May 2008 and June 2009 flows of 3,110 and 950 gpm (6.93 and 2.12 cfs), 

respectively, were recorded. Henderson Creek was measured in August 2007 at the confluence of its north and south 

fork tributaries. No stream flow was observed from the north fork at that time, whereas discharge from the south fork 

was reported to be 27 gpm (0.06 cfs). Other flow measurements in Henderson Creek were 36 gpm (0.08 cfs) in 

December 2007 and 135 gpm (0.3 cfs) in May 2008. Henderson Creek contained observable flow in a reach 

approximately 2.3 miles long before losing all of its surface flow to infiltration and evapotranspiration (Montgomery 

and Associates 2010 cited in USDOI BLM 2012b).

Diamond Valley

Harrill (1968 cited in USDOI BLM 2012b) described the existence of only a few perennial streams in Diamond 

Valley, all of which are on the east side of the valley on the western slopes of the Diamond Mountains (Figure 3-22, 

Table 3-15). This area is outside the 3 Bars Project area, but within the CESA. Cottonwood and Simpson Creeks 

3 Bars Project Final EIS 3-104 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

were mentioned as the two most prominent perennial streams, and the only ones that supported ranching operations in 

the 1960s. The only intermittent streams in Diamond Valley with a significant volume of seasonal runoff are also in 

the Diamond Mountains. The rest of the streams in Diamond Valley are intermittent or ephemeral and were reported 

to have only minor flows. 

Between May of 1965 and October of 1966, reported stream flows in 11 drainages within the CESA along the 

western side of the Diamond Mountains ranged from zero flow to a maximum of 785 gpm (1.75 cfs) in Cottonwood 

Creek on one occasion; all other observed flows during that time period were less than 287 gpm (0.64 cfs; Harrill 

1968 cited in USDOI BLM 2012b). No flow was observed during March and June of 1966 in Garden Pass Creek, an 

ephemeral creek on the western side of Diamond Valley that originates at the topographic divide between Pine and 

Diamond Valleys, and an unnamed drainage on the eastern slopes of the Sulphur Spring Range in the northern part of 

Diamond Valley was also reported to be dry in April and October of 1966 (Harrill 1968 cited in USDOI BLM 2012b). 

Peak flow measurements made by the USGS in Garden Pass Creek between 1965 and 1981 ranged from 314 to over 

290,000 gpm (0.7 to 650 cfs). 

3.10.2.3.3 Springs 

Approximately 334 springs occur within or immediately adjacent to the project area, including 141 known sites in 

Pine Valley, 131 in Kobeh Valley, 49 in Grass Valley, and 13 in Diamond Valley (Figure 3-22). Most springs are in 

mountainous parts of the project area, although some occur on alluvial fans or in valley floor positions. At any 

specific site, spring flows are either perennial (flowing year-round) or intermittent (flowing part of the year), 

depending on historic precipitation and geologic factors that govern the groundwater source of the spring. Some 

general flow characteristics are indicated in Table 3-18 for springs where data are available. A substantial range in 

flows is apparent. Additional geologic aspects of spring origins and characteristics are discussed in the groundwater 

section. 

3.10.2.3.4 Other Surface Water Features

There are no naturally occurring lakes or ponds within the project area. However, range water improvements, 

windmills, reservoirs, and improved springs occur throughout the project area (Figure 3-23). Agricultural water uses 

for irrigation and stock watering occur in Garden Valley and along the western edge of Diamond Valley. Other 

surface water impoundments that intermittently or perennially contain water include the following: 1) Tonkin 

Reservoir on upper Denay Creek, JD Ranch reservoirs on lower Henderson Creek and Pete Hanson Creek, and the 

Alpha Ranch impoundments of Henderson Creek and Chimney Springs in Pine Valley; 2) the Roberts Creek Ranch 

impoundment on Roberts Creek in Kobeh Valley; 3) the Shipley Hot Spring pond and the Flynn Ranch springs water 

impoundments in Diamond Valley; and 4) several small reservoirs on the upper Antelope Wash and its tributaries 

near the Segura Ranch in Antelope Valley. There may be other, smaller man-made impoundments in various 

drainages and downgradient of certain springs within the project area that were not located in the field or identified on 

maps or aerial photographs. 

Saline flats or playas exist where streams empty or ground water discharges into areas with no outflow. Temporary 

ponding occurs in such areas after snowmelt or prolonged rainfall, but the accumulated water typically soon 

evaporates. 

3 Bars Project Final EIS 3-105 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-23

Water Developments

and Water Uses

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Pine Valley

Basin # 053

Diamond Valley

Basin # 153

Grass Valley

Basin # 138

Kobeh Valley

Basin # 139

Vin ini Creek

Henderson Creek

McC lu s ky Creek

Roberts Creek

Wil ol wCree k

Roberts

Creek

Reservoir

JD Reservoir

Denay

Pond

Tonkin

Reservoir

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Water Developments

and Water Uses

Spring

Windmill/Well

Reservoir

Stock Tank, Trough,

or Waterhaul

Irrigated Crop

Perennial Stream

Lake or Pond

Playa

Hydrographic Basin

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012c,g; NDWR 2012; USGS 2012b.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-18

Flow Measurements at Springs 

Spring Associated Drainage Flow (gpm) Flow (cfs) Measurement Date

Tonkin Spring Denay Creek 449 to 1,077 1.0 to 2.4 Continuous

BC-1 Upper Birch Creek 78 0.17 03/22/2009

PH-2 Upper Pete Hanson Creek 10 0.02 03/27/2009

PH-7 Upper Pete Hanson Creek 2 0.004 03/27/2009

PH-7A Upper Pete Hanson Creek 8 0.018 03/27/2009

PH-8 Upper Pete Hanson Creek 0 0 03/23/2009

PH-14 Upper Pete Hanson Creek 1 0.002 03/23/2009

PH-15 Upper Pete Hanson Creek 0 0 03/23/2009

HC-10A Upper Henderson Creek 1 0.002 03/28/2009

gpm = gallons per minute. 

cfs = cubic feet per second. 

Source: JBR (2009) and USDOI USGS (2012b).

3.10.2.4 Surface Water Quality 

Beneficial uses of surface water in the project area include livestock watering, irrigation, aquatic life support, 

recreation with either contact or noncontact with water, municipal supply, and wildlife propagation (Nevada 

Administrative Code 445A). 

The Nevada Water Pollution Control Law provides the State of Nevada the authority to maintain water quality for 

public use, wildlife, industry, agriculture, and the economic development of the site. The Nevada Division of 

Environmental Protection defines waters of the state to include surface water courses, waterways, drainage systems, 

and underground water. The Nevada Water Pollution Control Law also gives the State Environmental Commission 

authority to require controls on diffuse sources of pollutants, if these sources have the potential to degrade the quality 

of the waters of the state. The USEPA has also granted Nevada authority to enforce drinking water standards 

established under the Safe Drinking Water Act. 

The State of Nevada classifies surface water bodies into four classes—A, B, C, and D. Each class has associated water 

quality standards. Class A waters include waters or portions of waters in areas of little human habitation, and no 

industrial development or intensive agriculture, and where the watershed is relatively undisturbed by human activity. 

The beneficial uses of Class A waters are municipal or domestic supply, or both, with treatment by disinfection only, 

aquatic life, propagation of wildlife, irrigation, watering of livestock, recreation including contact with the water, and 

recreation not involving contact with the water. Class B waters include waters or portions of waters that are on areas 

of light or moderate human habitation, little industrial development, light-to-moderate agricultural development, and 

where the watershed is only moderately influenced by human activity (USDOI BLM 2012b). 

The beneficial uses of Class B waters are municipal or domestic supply, or both, with treatment by disinfection and 

filtration only, irrigation, watering of livestock, aquatic life and propagation of wildlife, recreation involving contact 

with the water, recreation not involving contact with the water, and industrial supply. Class C waters include waters or 

portions of waters that are on areas of moderate to urban human habitation, where industrial development is present in 

moderate amounts, where agricultural practices are intensive, and where the watershed is considerably altered by 

human activity (USDOI BLM 2012b). 

3 Bars Project Final EIS 3-107 October 2016
WATER RESOURCES 

The beneficial uses of Class C waters are municipal or domestic supply, or both, following complete treatment, 

irrigation, watering of livestock, aquatic life, propagation of wildlife, recreation involving contact with the water, 

recreation not involving contact with the water, and industrial supply. Class D waters include waters or portions of 

waters in areas of urban development, are highly industrialized or intensively used for agriculture, or a combination of 

these, and where effluent sources include a multiplicity of waste discharges from the highly altered watershed. The 

beneficial uses of Class D waters are recreation not involving contact with the water, aquatic life, propagation of 

wildlife, irrigation, watering of livestock, and industrial supply, except for food processing purposes (USDOI BLM 

2012b). 

Roberts Creek and its tributaries are Class A water bodies from the headwaters to the reservoir and Class B water 

bodies below the reservoir. Denay Creek and its tributaries from the headwaters to Tonkin Reservoir and the 

Reservoir itself are Class A water bodies. Denay Creek below Tonkin Reservoir is a Class B water body. J.D. ponds 

are Class C water bodies. These water bodies have aquatic life, livestock, recreation, irrigation, and other beneficial 

uses. All other perennial streams in the vicinity of the project area are unclassified (USDOI BLM 2012b). 

The Nevada Division of Environmental Protection requires compliance with National Pollution Discharge 

Elimination System permits related to discharge to waters of the U.S., including discharges of stormwater runoff. The 

Nevada Division of Environmental Protection requires that discharges into subsurface waters be controlled if the 

potential for contamination of groundwater supplies exist. 

Surface water quality has been investigated through more intensive sampling at several locations within the Roberts 

Mountains by the USGS and JBR from 2009 to 2011 (JBR 2009, USDOI USGS 2012c). No water quality 

assessments are known to have occurred outside the Roberts Mountains. Results indicate generally good to excellent 

water quality in drainages within the Roberts Mountains. The waters are a calcium/magnesium bicarbonate type, with 

pH ranging generally between 7.8 to 8.6 standard units. Some pH values are slightly higher. Hardness ranges between 

approximately 200 to 300 milligrams per liter (mg/L) as calcium carbonate. In Birch Creek and Vinini Creek, the 

electrical conductivities are somewhat elevated (on the order of 6,500 micromhos per centimeter), indicating higher 

levels of dissolved salts. Elsewhere, conductivity values were moderate to low (200 to 400 microSiemens per 

centimeter). At springs such as PH-14 on Pete Hanson Creek, HC-10 on Henderson Creek, and Tonkin Spring above 

Denay Creek, somewhat greater concentrations of magnesium occurred in comparison to other locations. Dissolved 

oxygen concentrations were moderate in the USGS samples (6.6 to 8.1 mg/L). The lower dissolved oxygen values 

(below 7 mg/L) occurred with warmer water temperatures during June 2011 (USDOI USGS 2012c). 

It is anticipated that water quality from these upgradient streams and springs would generally decline with increasing 

distance from the mountain headwaters. As the streams traverse lower-elevation alluvial fans and valley deposits, 

remaining flows are likely to have increased salinity and sediment concentrations. 

3.10.2.5 Groundwater Resources 

3.10.2.5.1 General Hydrogeologic Setting 

The mountains that border the basins consist of complexly faulted and folded Paleozoic sedimentary rocks, with 

widespread occurrences of Jurassic, Cretaceous, and Tertiary intrusive and volcanic rocks. Carbonate rocks dominate 

the Sulphur Spring Range and Roberts Mountains, as well as the mountains bordering Eureka, Nevada. Siliceous 

clastic rocks are found in the Diamond Mountains along the east side of Diamond Valley. Tertiary intrusive and 

volcanic rocks are predominant in most of the other mountain ranges. The approximate axis of the Northern Nevada 

3 Bars Project Final EIS 3-108 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Rift extends from Eureka northeastward through the Roberts Mountains and northeast into Grass Valley (Ponce and 

Glen 2002 cited in USDOI BLM 2012b). 

The basin fill deposits consist of middle Tertiary through Quaternary sedimentary rocks and unconsolidated to 

partially consolidated alluvial, fluvial, and lacustrine sediments. Ash-flow and air-fall tuffs are interbedded with the 

sediments. Coarse alluvial sediments found along the mountain fronts grade basinward into finer alluvial fan, fluvial, 

and lacustrine sediments. Pliocene and Pleistocene lakes formed in many of the valleys during a period of wetter 

climate in the Great Basin. Pine Valley, Kobeh Valley, Grass Valley, and Diamond Valley contained extensive lakes 

during the Pliocene and early Pleistocene. Remnants of these pluvial lakes are elevated terrace deposits and a thick 

sequence of clay, silt, freshwater limestone, and evaporites that underlie the shallow alluvial sediments of the basins. 

3.10.2.5.2 Groundwater Hydrology of Kobeh Valley 

The Kobeh Valley basin is a roughly equidimensional basin. Descriptions of the valley have been taken from Rush 

and Everett (1964) and USDOI BLM (2012b). Geologically, Kobeh Valley consists of basin-fill alluvium within the 

main part of the basin and alluvial fan sediments along the mountain fronts surrounding the basin. 

Montgomery and Associates (2010) completed a water balance study for Kobeh Valley basin during 2009. This is 

presented in Table 3-19 along with their estimates for the 2009 water balance for Antelope, Diamond, and Pine 

Valley basins. The total outflow for the Kobeh Valley basin for 2009 was 20,800 acre-feet/year and exceeded the 

inflow of 18,000 acre-feet/year (Montgomery and Associates 2010 cited in USDOI BLM 2012b). By this water 

balance estimate, Kobeh Valley basin is losing water from storage due to groundwater pumpage and water levels in 

the valley should begin to decline. This may eventually affect the growth of phreatophytes. 

3.10.2.5.3 Groundwater Hydrology of Diamond Valley 

Diamond Valley is an elongate basin oriented approximately north–south. The north end of the valley is occupied by 

an extensive playa. The south end of the basin near Eureka is used for agricultural irrigation. The valley-fill sediments 

consist of at least 7,845 feet amsl of interbedded gravels, silts, clays, evaporates, Pleistocene lake-bed sediments, and 

volcanic tuffs. 

Groundwater flow in the Diamond Valley basin has been noticeably altered by extensive agricultural irrigation in the 

southern part of the valley. Prior to the onset of intensive irrigation, groundwater in the Diamond Valley basin flowed 

from south to north and terminated in the playa at the north end of the basin. Eakin (1962 cited in USDOI BLM 

2012b) completed a groundwater appraisal of the Diamond Valley basin and showed that water elevations in the 

southern part of the valley were around 5,870 feet amsl and those in the northern part near the playa were around 

5,770 feet amsl. Water elevations in 2005 were around 5,800 feet amsl in the southern part of the basin. Irrigation 

pumping has created a groundwater depression that has concentrated groundwater flow into the southern part of the 

basin. Consequently, groundwater no longer flows into the playa area in the northern part of the basin from the south. 

Agricultural irrigation in the southern part of the basin has resulted in subsidence of the basin sediments. 

Eakin (1962 cited in USDOI BLM 2012b) completed a preliminary water balance for the Diamond Valley basin. He 

estimated that groundwater recharge was around 16,000 acre-feet/year and that groundwater discharge was about 

23,000 acre-feet/year. Evapotranspiration from natural vegetation was estimated at 14,100 acre-feet/year and water 

loss from meadow and pasture grass was estimated at 8,900 acre-feet/year. Pumpage from irrigation wells was around 

5,000 acre-feet/year and the wells were screened in the upper 200 feet of the basin fill with well yields in the range of 

1,000 to 2,500 gpm. Montgomery and Associates (2010 cited in USDOI BLM 2012b) estimated the water balance for 

3 Bars Project Final EIS 3-109 October 2016
WATER RESOURCES 

the Diamond Valley basin. Their values are considerably different from those of Eakin (1962 cited in USDOI BLM 

2012b), with precipitation recharge at 21,400 acre-feet/year and 8,900 acre-feet/year of groundwater inflow from Pine 

and Kobeh valley basins. Their evapotranspiration loss was 14,700 acre-feet/year and groundwater pumpage was 

55,800 acre-feet/year with groundwater inflow from Pine Valley and Kobeh Valley basins. 

With irrigation pumpage resulting in a groundwater sink in the southern part of the Diamond Valley basin and 

accompanying basin sediment subsidence, the playa at the north end of the valley no longer receives groundwater 

flow from the southern part of the valley. Prior to agricultural development of Diamond Valley, the playa at the north 

end of the valley was the terminus of the Diamond Valley regional groundwater flow system. Now, the groundwater 

sink created by irrigation pumpage is the terminus of the flow system. Without groundwater flow from the southern 

part of the valley, the playa at the north end of Diamond Valley can be expected to become progressively dryer, 

resulting in a change in vegetation types and a reduction in phreatophytes surrounding the playa.

TABLE 3-19 

2009 Estimated Annual Groundwater Budget for Individual Basins

Budget Component Antelope 

Valley Diamond Valley Kobeh Valley Pine Valley1

Groundwater Inflow (acre-feet per year) 

Precipitation Recharge 4,100 21,400 13,200 34,900 

Subsurface Inflow 0 

7,800 (5,800 from 

Pine Valley and 

2,000 from Kobeh 

Valley) 

4,800 (1,600 from Monitor 

Valley, 2,700 from 

Antelope Valley, and 500 

from Pine Valley) 

0 

Total Inflow 4,100 29,200 18,000 34,900 

Groundwater Outflow (acre-feet per year) 

Evapotranspiration 1,400 14,700 15,900 17,100

Net Groundwater 

Pumping Negligible 55,800 2,900 negligible 

Subsurface Outflow

2,700 (to 

Kobeh 

Valley)

0 2,000 (to Diamond Valley) 

17,600 (5,800 to Diamond 

Valley, 500 to Kobeh 

Valley, and 11,300 to 

northern Pine Valley) 

Total Outflow 4,100 70,500 20,800 34,700 

Inflow (Outflow) 0 (41,300) (2,800) 200 

1

 Within Hydrologic Unit Code 10 watersheds on/within 3 Bars Project area. 

Source: Montgomery and Associates (2010) cited in USDOI BLM (2012b:3-55 to 3-56). 

3.10.2.5.4 Groundwater Hydrogeology of Pine Valley 

Pine Valley is an elongate basin, 55 miles long by 30 miles wide, northwest of Diamond Valley and north of Kobeh 

Valley. The principal drainage is Pine Creek and this drainage flows into the Humboldt River, placing Pine Valley in 

the Humboldt River Flow System. Garden Valley is a sub-basin of Pine Valley and is along the southeastern part of 

the basin, adjacent to Mount Hope. Henderson Creek drains Garden Valley and flows into Pine Creek. Most of the 

drainages that feed into Pine Creek originate in the Cortez Mountains or the Roberts Mountains. 

3 Bars Project Final EIS 3-110 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

The Pine Valley basin is characterized by shallow groundwater levels in the valley-fill alluvial aquifer. Groundwater 

elevations in the basin alluvial aquifer are around 5,800 feet amsl at the southern end of the valley and around 4,800 

feet amsl near the northern end of the basin where Pine Creek flows into the Humboldt River. The hydrology of Pine 

Valley is characterized by shallow groundwater levels in the valley-fill alluvial aquifer (Eakin 1961 cited in USDOI 

BLM 2012b). Depth to groundwater, in the valley fill along Pine Creek, ranges from 0 to 10 feet below ground 

surface. Pine Creek is fed by groundwater baseflow on a year-round basis and by mountain-front runoff during the 

spring snowmelt in the bordering mountains, especially the Cortez Range and the Roberts Mountains. Eakin (1961 

cited in USDOI BLM 2012b) estimated the recharge to Pine Valley at 46,000 acre-feet/year with discharge by 

evapotranspiration from natural vegetation and pasture grass at 24,000 acre-feet/year. Pine Creek discharges from 30 

acre-feet/year during low flow periods to 2,100 acre-feet/year during high flow periods (Eakin 1961 cited in USDOI 

BLM 2012b). Montgomery and Associates (2010 cited in USDOI BLM 2012b) estimated the precipitation recharge 

for 2009 to be 34,900 acre-feet/year for the southern two-thirds of the basin (the area within the project area). Their 

water balance estimate had 17,100 acre-feet/year of evapotranspiration loss and 17,600 acre-feet/year of subsurface 

groundwater outflow to Diamond Valley (5,800 acre-feet/year), Kobeh Valley (500 acre-feet/year), and the northern 

one-third of Pine Valley (11,300 acre-feet/year). Montgomery and Associates (2010 cited in USDOI BLM 2012b) did 

not discuss groundwater baseflow to the Pine Creek basin and the discharge of this groundwater eventually to the 

Humboldt River. 

3.10.2.5.5 Groundwater Hydrology of Grass Valley 

Grass Valley is a closed hydrographic basin that has not received much study. Everett and Rush (1966 cited in 

USDOI BLM 2012b) described the general features of the basin hydrology. The Grass Valley basin is topographically 

and hydrologically closed and consists of two interconnected basins. The smaller basin is in the southwest corner of 

Grass Valley and is adjacent to Mt. Callaghan and fed by Current Creek and Skull Creek. This smaller basin contains 

abundant springs and drains through a gap in the bounding mountain ranges into the main part of the Grass Valley 

basin. The main basin of Grass Valley is elongate in a north-south direction and fed by ephemeral streams draining 

the Toiyabe Range that bounds the west side of the valley. Springs are found along both the east and west sides of 

Grass Valley near the contact between the alluvial fans that form the margins of the basin and the bounding bedrock 

of the fault-block ranges that border the basin. The Grass Valley basin is dominated by a large playa and the 

surrounding area phreatophytes that tap the shallow groundwater of the basin. 

Groundwater recharge in the valley was estimated to be around 13,000 acre-feet/year. This is approximately balanced 

by evapotranspiration from the phreatophytes and groundwater pumpage. Estimated total precipitation for Grass 

Valley is around 29,000 acre-feet/year and approximately 45 percent of this precipitation recharges groundwater. This 

is balanced by evapotranspiration from the phreatophytes estimated at 12,000 acre-feet/year and by both limited 

groundwater pumpage (about 200 acre-feet/year) and consumption of groundwater by alfalfa grown south of the playa 

in the central part of the valley (Everett and Rush 1966 cited in USDOI BLM 2012b). 

3.10.2.5.6 Basin Groundwater Quality

Groundwater quality in all the basins is similar and generally suitable for irrigation and stock watering. For most 

basins, the groundwater is dominated by calcium-sodium bicarbonate or sodium-calcium bicarbonate with the total 

dissolved solids generally below 1,000 mg/L and often below 500 mg/L. Water quality is best in the alluvial fans near 

the mountain fronts and becomes more saline near the valley centers. For valleys with playas, the water quality can 

become quite saline, with the total dissolved solids exceeding 1,000 mg/L and the groundwater near the playas being 

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WATER RESOURCES 

dominated by calcium sulfate. Chloride can be locally elevated near the playas. Shallow groundwater near the basins 

centers is generally more saline than groundwater in the alluvial fans near the mountain fronts. 

Grass Valley has calcium bicarbonate dominated groundwater, with a total dissolved solids in the range of 300 to 500 

mg/L (Everett and Rush 1966). Sulfate ranges up to 116 mg/L. Near the playas, groundwater in Grass Valley becomes 

saline with the total dissolved solids ranging up to 1,800 mg/L (Cohen 1964). Groundwater quality is suitable for 

irrigation, except beneath the playa area. Surrounding the playa and in the area of the phreatophytes, groundwater is 

dominated by sodium-calcium bicarbonate with a total dissolved solids in the range of 300 to 500 mg/L, sulfate 

ranging from 40 to 120 mg/L, and chloride less than 25 mg/L. In the area of the playa, the groundwater quality 

becomes saline due to evaporation in the playa. There are 23 wells of record and the deepest well is only 327 feet 

below ground surface. Water levels in the wells are generally within 50 feet of the surface (Everett and Rush 1966 

cited in USDOI BLM 2012b).

Big Smoky Valley has groundwater that increases in total dissolved solids with depth (Handman and Kilroy 1997). 

The total dissolved solids ranged from a low around 65 mg/L up to 600 mg/L for groundwater in the alluvium away 

from the playas. Near the playas, total dissolved solids can reach 9,000 mg/L and the groundwater becomes 

dominated by calcium sulfate. 

Diamond Valley is divided into two valleys (Eakin 1962 cited in USDOI BLM 2012b). The lower or southern part of 

the valley has good groundwater used for irrigation that is dominated by calcium bicarbonate, with total dissolved 

solids generally below 500 mg/L. The northern part of the valley is dominated by a playa and the groundwater 

becomes quite saline and dominated by calcium sulfate. 

Monitor, Antelope, and Kobeh Valleys have groundwater dominated by calcium bicarbonate and the total dissolved 

solids are below 500 mg/L. Near the centers of the basins and especially near playas, the groundwater quality 

becomes more saline and the total dissolved solids exceed 1,000 mg/L (Rush and Everett 1964). 

3.10.3 Environmental Consequences 

3.10.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, the following issues were identified for water resources: 

 How will water rights be addressed? 

 How will treatments maintain or improve water quality? 

 How will treatments protect surface and groundwater resources from degradation by fuel or oil spills and 

other human activities in the 3 Bars ecosystem that could result in the pollution of water resources? 

 How will treatments maintain or improve watershed and streams/riparian zone conditions? 

 How will treatments reduce the threat of knickpoints and/or headcuts, which indicate vertical instability and 

are a point source for accelerated erosion? 

 Will pinyon-juniper treatments help to lessen water demands (through decreased evapotranspiration and 

sublimation), and increase the amount of water that infiltrates into the ground and discharges to seeps and 

springs? 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 Will treatments remove stock ponds that have inhibited sediment transport conditions locally, stored 

sediment, and caused channel incision downstream? 

 Will treatments improve bank stability? 

 Will treatments benefit deep-rooted perennial upland herbaceous species that have declined due to decreasing 

infiltration rates and increasing run-off and surface erosion? 

 What kinds of water developments are being considered for the planning area, and what are the projected 

water flow production rates and availability to wild horses, wildlife, and livestock? 

 How will treatments reduce the impacts of wildfires on groundwater and surface water resources? 

 Would there be effects on local aquifers from the removal of pinyon-juniper and from mining and other 

projects in the CESA? 

3.10.3.2 Significance Criteria 

Impacts to water resources would be considered significant if BLM actions resulted in: 

 Release of contaminants such as sediment, fuels, or lubricants into perennial or intermittent streams or 

springs, creating a change of water quality that often or regularly exceeds the applicable Nevada Division of 

Environmental Protection water quality standards specified in Nevada Administrative Code 445A for 

existing uses such as aquatic life, irrigation, livestock watering, or propagation of wildlife. 

 Prevention of access, consumptive use, or long-term diversion of surface water that adversely affects 

recognized water rights holders. This would include flows and seasons of use where existing beneficial water 

uses, as defined by the Nevada Division of Water Resources, may be affected. 

 Accelerated erosion occurs from watershed slopes and leads to increased sedimentation in streams or ponds, 

or to other uncontrolled stream channel and bank instabilities (including conditions that foster aggradation 

and lateral migration, bank erosion or piping, or channel degradation through scour or collapse at knickpoints 

or headcuts). 

 Lower groundwater levels due to decreased water recharge. For groundwater levels, the water level decline 

would need to be greater than seasonal fluctuations in water levels and persist for several years or more to be 

statistically verifiable. 

3.10.3.3 Direct and Indirect Effects 

3.10.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Much of the focus of restoration treatments would be on maintaining connections between streams and floodplains, 

increasing infiltration, decreasing overland flow, reducing discharge velocity, and encouraging riparian plant 

establishment. Numerous streams lack characteristics necessary for properly functioning riparian habitats. Invasive 

plant species, hazardous fuels buildup, pinyon-juniper encroachment, disturbance by historic livestock use, wild 

horses, and other wild ungulates, and climatic conditions are factors that have degraded riparian function on the 3 

Bars Project area. 

3 Bars Project Final EIS 3-113 October 2016
WATER RESOURCES 

Groundwater in the 3 Bars ecosystem is an important component of riparian and wetland ecosystem health because it 

provides baseflow to streams, springs, and seeps that are an important source of water in riparian and wetland areas. 

Improvement of ecosystem health in riparian zones and increasing stream flows are expressed goals for the 3 Bars 

Project area (USDOI BLM 2009a:50). When functioning properly, streams, springs, seeps, and associated floodplains 

and wetlands absorb snowmelt and stormwater runoff, extend flows further into the year, and attenuate flood 

discharges. 

Water Access 

There could be short-term access restrictions to water along portions of streams, or at developed or undeveloped 

springs, to promote site restoration and establishment of native vegetation. Access to surface water sources could be 

temporarily interrupted through road closures, fencing, or other factors. However, the BLM would not completely 

block access to water for livestock, wild horses, and wildlife and access to water resources would be ensured to meet 

the needs of those species in accordance with Nevada Water Law and to ensure that existing water rights are satisfied 

and unimpaired. 

Hillslope Erosion and Runoff 

Removal of vegetation and disturbance of the soil could lead to increased water runoff and soil erosion. Interception 

and infiltration of rainfall and snowmelt would decrease as a result of overstory vegetation removal, formation of 

water resistant soil surfaces, or soil compaction. These effects could be minimized through the application of mulch 

and/or other erosion controls. After restoration with desirable vegetation, the erosive effects of snowmelt and rainfall 

would decrease, surface retention and infiltration would increase, and runoff and erosion conditions would improve. 

Streambed or Bank Instability 

Treatments could lead to short-term degradation of streambeds and streambanks due to removal of undesirable 

vegetation, and from in-channel earthwork. Adverse effects could include initiating or increasing the occurrence and 

migration rate of knickpoints, headcuts, or bank caving and lateral migration, with the largest expected effect being an 

increase in sedimentation. Restoration at treatment sites, stabilization practices along streams, and post-project 

monitoring and maintenance would reduce the severity and duration of these impacts. Long-term, treatments would 

ultimately improve stream function. 

Surface Water Quantity 

Restoration treatments would affect surface water quantity. Removal of vegetation could lead to increased runoff, and 

decreased infiltration, groundwater recharge, stream flow, and flow duration. Reductions in baseflows (groundwater 

contributions to streams) may result from increased surface runoff and reduced infiltration and groundwater recharge. 

Revegetation may increase evapotranspiration demands on springs and perennial or intermittent streams at some sites. 

Some treatments may increase demands by phreatophytic vegetation and reduce water flows at or near treatment sites. 

These effects may contribute to increased episodes of little or no flow in ephemeral streams. Use of water from 

nearby sources to extinguish wildfires could reduce the quantity of surface water resources, particularly during dry 

seasons (USDOI BLM 2007c:4-22). 

Several studies have shown that removal of pinyon-juniper that is encroaching into riparian habitat can improve 

stream flow. DeBoodt (2008) found that in areas where all junipers were cut from a watershed, late season spring 

flow, days of recorded ground flow, and late season soil moisture increased compared to pre-treatment conditions. As 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

a result, flows may endure longer into the summer months at some springs and perennial or intermittent streams 

where dense, deep-rooted pinyon-juniper or other stands are treated. The lengths of perennial or intermittent stream 

reaches may also increase. These benefits would be more likely in Phase II and III pinyon-juniper stands, or in the 

mountains or on upstream reaches of mountain-front alluvial fan channels. 

Pierson et al. (2013) found that 2 years post fire, erosion remained 20-fold greater on burned than unburned pinyonjuniper woodland plots, but concentrated flow erosion from the intercanopy was reduced by growth of forbs and 

grasses in the understory. Their study suggested that burning may amplify runoff and erosion immediately post fire, 

but that activities that stimulate vegetation productivity may provide long-term reduction of soil loss, especially when 

compared to untreated areas with pinyon-juniper. Burning of Phase II and III woodlands enhanced herbaceous cover, 

decreased bare ground connectivity, improved infiltration, and reduced concentrated flow erosion within the 

intercanopy over the first 2 years following the fire. Short-term improvements in infiltration and erosion suggested

that tree removal by burning may create a restoration pathway for woodland-encroached sagebrush steppe habitat, but 

that improvements may take 3 or more years to take effect, depending on the rate of vegetation and ground cover 

recruitment. In contrast, Pierson et al. (2013) observed that simply placing cut-downed trees into the unburned 

intercanopy had minimal immediate impact on infiltration and soil loss. 

If slash and other downed woody material from treatments are used as mulch, this material should slow runoff and 

sedimentation, and infiltration and soil moisture would likely increase. Mulch would also help to capture sediments 

and decrease peak flows. As treated areas revegetate, there should be long-term benefits to stream flow and soil 

moisture. 

Surface Water Quality 

The water quality of perennial and intermittent streams could decrease in the short-term after treatments, due to runoff 

and erosion from loss of vegetative cover and soil disturbance. Some treatments could occur on soils that are 

susceptible to water and wind erosion (see Figures 3-14 and 3-15). However, by retaining downed woody material in 

treatment areas, these effects can be minimized or avoided. 

If streamside vegetation is removed, the loss of shade could result in higher water temperatures and lower dissolved 

oxygen, to the detriment of fish and other aquatic organisms (USDOI BLM 2007c:4-22). Removal of vegetation and 

an increase in erosion and sedimentation could result in an increase in salts in receiving water bodies. Birch Creek and 

Vinini Creek have elevated electrical conductivities, indicating higher levels of dissolved salts. However, other 

streams on Roberts Mountains have lower conductivity values, so the potential for adverse salinity effects varies 

across the project area. 

There is potential for fuel and lubricants used for equipment and transport vehicles to spill into water bodies. The 

BLM would minimize this risk by refueling and servicing equipment away from water bodies, and minimizing 

equipment use in aquatic bodies, where feasible. 

The removal of hazardous fuels from public lands would result in a long-term benefit to surface water quality by 

reducing the risk of a future high-severity wildfire on the treatment site. A high-severity wildfire that removes 

excessive plants and litter could subsequently increase surface soil erosion and cause soil mass failures and debris 

flow, resulting in short-term increases in stream flows. In addition, fire retardants could affect water quality. Fire 

retardants that are used most extensively for emergency suppression contain nitrogen and phosphorus that could cause 

nutrient enrichment of surface waters. When mixed with water and exposed to ultraviolet radiation, some fire 

3 Bars Project Final EIS 3-115 October 2016
WATER RESOURCES 

retardants break down into hydrogen cyanide, an extremely toxic substance (Fresquez et al. 2002 cited in USDOI 

BLM 2012b). 

Over the long-term, vegetation treatments that move the 3 Bars ecosystem toward historical ranges of variability, with 

a preponderance of native plant communities in natural mosaic patterns and relatively uninterrupted disturbance 

regimes, would provide favorable conditions for surface water quality by reducing the incidence of soil erosion and 

sedimentation. 

Groundwater Quantity and Recharge 

As discussed above, studies by DeBoodt (2008), and Pierson et al. (2013) showed that the removal of vegetation 

could increase surface water runoff and reduce infiltration in treatment areas in the short-term, to the detriment of 

local-area groundwater recharge and availability. Some water may be retained in the system due to reduced 

evapotranspiration and, on a basin-wide scale, groundwater recharge would increase. Long-term, treatments may 

improve groundwater availability as native vegetation re-establishes on treatment sites, which would reduce runoff 

and increase infiltration. These effects would be most noticeable in Phase II and III pinyon-juniper stands where there 

is little understory. Baseflow to streams may also increase due to increased infiltration of precipitation and an increase 

in recharge to shallow groundwater. The increase in baseflow may be temporary unless long groundwater flow paths 

are involved. 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 (USDOI BLM 2007c:4-21). 

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 water consumptive nature of the replacement 

species. Steep slopes with tight or compact soils would have a greater tendency to show increased runoff after 

removal of a water consumptive species. This increased runoff would be temporary and would decline once the 

replacement species has established. However, the increased runoff would cause a reduction in infiltration and thus a 

potential reduction in recharge to shallow aquifers. Mulching treated areas with chopped vegetation would mitigate 

for these effects by slowing runoff and enhancing infiltration. Areas with frequent or intense precipitation would be 

expected to show a greater potential for increased infiltration after removal of a water consumptive species. Similarly, 

if the replacement species has a high capacity for soil water retention and consumption, then the benefits of removal 

of the less desirable species would be only temporary. 

Groundwater Quality 

Improvements in groundwater quality from vegetation treatments are more difficult to quantify, primarily due to the 

lack of long-term groundwater quality data needed to statistically defend an improvement in water quality. If 

vegetation treatments reduce nutrient uptake by plants, either by removing plants or replacing one species with 

another that requires less or different nutrients, then soluble nutrients like nitrogen may enter streams via groundwater 

baseflow from shallow aquifers due to dissolution of these nutrients by infiltrating precipitation (USDOI BLM 

2007c:4-21). In areas with high salt levels in soils, a change in plant species may result in increased flushing of salts 

to groundwater. Nutrients sorbed onto soil particles, such as phosphorous, may be carried to streams in runoff. 

Groundwater quality may be affected, at least temporarily, by an influx of nutrients that would otherwise have been 

consumed by the vegetation that has been removed. Conversely, since runoff beneath pinyon-juniper has been shown 

to far exceed that of non-pinyon-juniper terrain, removing pinyon-juniper, placing mulch, and allowing native 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

vegetation to stabilize the soil could decrease runoff and the associated erosion which carries sediment loads and 

increases total dissolved salts and other pollutants in the runoff. 

3.10.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

The BLM has identified about 3,885 acres of riparian zone treatments. Most of the riparian treatments would be in the 

Kobeh Valley and Pine Valley watersheds. Treatment acres comprise only a small portion of the watershed basins 

within the project area and only 3 percent of all project treatment acreage (Table 3-20). The BLM would restore 

about 31 miles of perennial streams, 17 miles of intermittent streams, and 40 springs that are within the riparian 

treatment zone (Table 3-21). Manual and mechanical methods would be used for treatments, and it is possible that 

livestock could be used to remove cheatgrass in the riparian zone. 

Riparian area treatments would focus on restoring stream and habitat functionality in areas where the stream channel 

morphology, and the plant species composition within the riparian zone, has been compromised by past actions. 

Because of the loss of structural integrity in compromised channels, stream velocities have increased over historic 

levels, nutrient-rich sediment is not being delivered to riparian vegetation, and there is less groundwater recharge 

within the floodplains. Near-stream groundwater levels have also dropped as a result of stream incision. 

The following discussion focuses on the effects of riparian treatments on water resources. A discussion of stream 

processes, and how proposed stream engineering treatments would affect stream morphology and functionality, 

including processes related to water quantity and quality, is in Section 3.11.3 under Wetland, Floodplain, and Riparian 

Zone Resources. 

Adverse Effects 

Because riparian treatments would, by definition, be conducted close to surface water features, of all of the treatment 

types they would have the most potential to have adverse and beneficial impacts on water resources. Avoidance of 

these impacts would be particularly critical for occupied and potential Lahontan cutthroat trout streams, stream 

segments on the Roberts Mountains, such as Roberts Creek, and those tributaries that have Class A stream standards.

Degraded stream systems on the 3 Bars Project area reflect degraded conditions in their contributing watersheds. 

These conditions tend to increase the magnitude and frequency of high flows after precipitation events, increase 

sediment inputs into stream systems, and diminish the streams’ ability to resist degradation. The annual hydrograph, 

as differentiated from the storm event flow response described above, is also changed. High spring runoff flows often 

increase, while seasonal low flows (baseflows) decline or cease. Direct alterations include channel straightening, 

dredging, widening, narrowing, levee construction, floodplain fill, and riparian zone modification. Indirect activities 

include those that alter the principal processes that create and maintain stream channel conditions. Tree harvest, road 

building, and grazing also influence the supply and transport of water, sediment, energy (light and heat), nutrients, 

solutes, and organic matter (ranging from woody material to leaf litter; Saldi-Caromile 2004). Stream restoration 

treatments could further degrade conditions within the stream until it stabilizes. Channel restoration and vegetation 

removal and planting may temporarily increase erosion in treated areas. 

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WATER RESOURCES 

TABLE 3-20

Percent of Watershed Basin within Treatment Areas 

Basin Name Basin 

Acres Riparian Aspen Pinyonjuniper Sagebrush

Diamond Valley 477,506 <0.1 0 6.8 1.4

Grass Valley 379,846 <0.1 0 0 2.2

Kobeh Valley 551,961 0.2 <0.1 8.9 8.1

Pine Valley 640,588 0.3 <0.1 7.8 8.0

Source: Nevada Division of Water Resources (2012). 

TABLE 3-21

Perennial Stream Miles within Treatment Areas 

Stream Name Miles by Treatment Type

Aspen Pinyon-juniper Riparian Sagebrush

Birch Creek 0.6 1.5 0 0

Denay Creek 0 0.1 0 0

Henderson Creek 0 1.8 5.6 4.6

McClusky Creek 0 0 3.3 0

Pete Hanson Creek 1.2 1.4 0 0

Roberts Creek 0 3.2 5.4 0

Vinini Creek 0.3 0 5.2 1.3

Willow Creek 0 0 5.0 0

Unnamed 1.7 5.7 6.7 0.5

Total Miles 3.8 13.7 31.2 6.4

Treatments on units of the Black Spring and Garden Spring groups, as well as those streams identified for Lahontan 

cutthroat trout habitat improvements, would involve using heavy equipment such as bulldozers and backhoes to 

reconstruct streams and improve riparian habitat. The soil disturbance associated with machinery used to remove 

vegetation and reconstruct streams, such as digging, plowing, or scraping, and from wheels and tracks of machinery, 

would increase the likelihood of soil and plant material being carried into streams by surface runoff. In addition, the 

compaction of soil by heavy equipment would increase the likelihood of surface runoff by reducing the soil’s 

infiltration capacity. However, leaving debris in place after treatments would limit these negative effects on 

infiltration rates and stream sedimentation (USDOI BLM 2007c:4-23). No mechanical equipment would be used 

within Willow Creek whenever possible. 

Manual and mechanical methods could be used on units of the Garden Spring Group to remove pinyon-juniper. 

Chainsaw hand thinning is the preferred method for tree cutting in riparian treatment units. Because manual 

treatments would occur over small areas, and would involve little soil disturbance or vegetation removal, the effects 

on water resources would be minimal. Manual treatment seldom results in exposed soil, and plant materials would 

remain in the treatment areas, minimizing the risks of sedimentation and alteration to water flow (USDOI BLM 

2007c:4-23). 

3 Bars Project Final EIS 3-118 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Beneficial Effects 

The primary objective of riparian management is to restore degraded streams to Proper Functioning Condition to 

benefit riparian habitat, riparian-dependent wildlife, and Lahontan cutthroat trout and other aquatic species. A proper 

functioning riparian zone has the necessary physical and structural components to dissipate stream energy associated 

with high water flows, as well as conditions that support a diverse and healthy population of fish and other aquatic 

organisms. 

Stream bioengineering treatments that include improvements to stream channel morphology and plantings should 

reduce the occurrence of high flow events and allow higher flows to be distributed across the floodplain rather than 

focused in the channel. Where flows are restricted to narrow channels, the increase in energy confined within the 

channel has resulted in stream degradation. By creating conditions that slow water flow, and creating associated 

floodplains and wet meadows, the energy associated with water flow would be dissipated, reducing the potential for 

future channel degradation. In-channel work and road mitigation projects would provide additional benefits. Grade 

control structures would reduce incision rates and in some cases, reverse it through aggradation (one rock dam series). 

Post vanes and baffles would induce meanders and help restore natural sinuosity and slow discharge velocity. Road 

mitigation, such as rolling dips, berms, swales, and spill pads, would help move water off of roads and into the 

riparian and wetland areas. These structures may be installed in conjunction with stream bioengineering to improve 

and expand riparian habitat.

Hydrologic functions would improve over the long-term due to stream restoration, including stabilization or reduction 

of drainageway erosion features such as knickpoints, headcuts, gullies, and bank caving. Hydrologic functions would 

improve as a result of reconnecting hydrologic pathways and improvements in infiltration due to overland flow. 

Pinyon-juniper removal from riparian zones and adjacent upland areas may benefit hydrologic functions as well, by 

generating some minor improvement in water flow in treated streams. Greater infiltration and interception of 

precipitation from improvement in riparian vegetation would help increase groundwater recharge and attenuate runoff 

peaks. Local increases in flow durations and flowing reaches could occur at some streams and springs (Tague et al. 

2008). Incised channels and channel straightening from roads have caused water levels to drop along many proposed 

treatment streams, causing nearby areas to dry out. By creating conditions that reduce channel incision, reduce surface 

runoff, and increase infiltration, the deep-rooted herbaceous species that are being lost in many riparian zones should 

benefit from these actions. In turn, as these species become reestablished, they should help to stabilize soils and 

improve water quality.

Treatments to remove pinyon-juniper from riparian treatment units and in nearby upland areas where pinyon-juniper 

is encroaching into riparian and sagebrush habitat may increase groundwater recharge. Longleaf pinyon pine and Utah 

juniper are not riparian species, and are not as effective as native vegetation in stabilizing soil near streams. 

Encroaching pinyon-juniper in Phase II and III stands has led to the loss of understory vegetation through shading, 

which has resulted in increased runoff and higher-than-normal flows in streams and accelerated the erosion of natural 

stream meander bends. Since sinuosity and slope are inversely proportional, the streambeds have begun incising to 

compensate for the increased flow rates, resulting in the lowering of the streambed and water table. By removing trees 

and leaving treatment slash and other woody debris on the ground as mulch, and allowing understory vegetation to reestablish, surface runoff rates and peak stream flows should lessen, less sediment would be transported to streams, 

and more water should infiltrate into the soil and recharge the groundwater (Lossing 2012, Noelle 2012). 

Exclosure fencing using existing permanent fencing or small, temporary exclosures would control access to treatment 

sites by livestock, wild horses, and other wild ungulates and allow treatment areas to revegetate. Livestock, wild 

3 Bars Project Final EIS 3-119 October 2016
WATER RESOURCES 

horses, and other wild ungulates can affect surface runoff through trampling, soil disturbance, and soil compaction. 

Past studies found that runoff from a heavily grazed watershed was 1.4 times that of a moderately grazed watershed, 

and 9 times greater than that of lightly grazed watershed. In some cases, however, light grazing may actually improve 

soil infiltration by breaking up physical crusts on the soil (USDOI BLM 2007c:4-24). Small breaks would be 

provided in the fencing, as needed, to ensure that animals have access to water in the vicinity of treatments. 

Aspen Treatments 

Aspen treatment areas overlap with approximately 4 miles of perennial streams, 55 miles of intermittent/ephemeral 

streams, and 35 springs. Efforts to stimulate aspen suckering and sucker survival would cause short-term soil 

disturbance and erosion, but as aspen stands improve, treatment actions should stabilize soils and improve hydrologic 

functions to the benefit of water resources. The BLM would remove pinyon-juniper and other non-riparian trees near 

aspen stands. Although it is unlikely that these treatments would enhance water yields, except perhaps at RM-A2 and 

RM-A10 along upper Roberts Creek and Upper Pete Hanson Creek, respectively, they would help to enhance fire 

breaks. Efforts to reduce the risk of catastrophic wildfires would reduce the potential for excessive loss of plant and 

litter cover and the potential for soil erosion and mass failures that would cause a decrease in water quality. 

Pinyon-juniper Treatments 

Treatments that reduce the abundance of pinyon-juniper near water bodies, promote the development of native forbs, 

grasses, and shrubs, and reduce the risk of fire spread in pinyon-juniper stands would provide the most benefits to 

surface and groundwater resources. Pinyon-juniper treatments would overlap with approximately 14 miles of 

perennial streams, 464 miles of intermittent/ephemeral streams, and 63 springs. 

Adverse Effects 

Impacts to water quantity and quality could be greater for pinyon-juniper treatment areas than for other treatment 

types because of the large acreage treated, and because pinyon-juniper treatment areas are generally on moderate to 

steep hillslopes that are prone to water erosion. In addition, where trees are in dense stands, removal of these trees 

could lead to short-term water and wind erosion as vegetative ground cover is mostly absent from these areas. Thurow 

and Hester (2012) found that runoff and erosion were greater from manual, mechanical, and fire treatments in pinyon 

treatment areas than untreated areas, and that it could take up to 10 years to return to normal levels, especially for 

mechanical treatments that disturb the soil. They noted that fire can increase the water repellency of soils, and 

increase runoff and erosion and loss of soil nutrients from the site until the burned site is revegetated. They also noted 

that studies have shown that burning can significantly reduce the infiltration rate and increase erosion due to loss of 

vegetation. These effects lessen as sites are revegetated. 

Pierson et al. (2013) found that burning may amplify runoff and erosion immediately post fire, but that activities that 

stimulate vegetation productivity may provide long-term reduction of soil loss, especially when compared to 

untreated areas with pinyon-juniper. Burning of Phase II and III woodlands enhanced herbaceous cover, decreased 

bare ground connectivity, improved infiltration, and reduced concentrated flow erosion within the intercanopy over 

the first 2 years following the fire. Short-term improvements in infiltration and erosion suggested that tree removal by 

burning may create a restoration pathway for woodland-encroached sagebrush steppe habitat, but that improvements 

may take 3 or more years to take effect, depending on the rate of vegetation and ground cover recruitment. 

Several thousand acres could be burned each year using prescribed fire and wildland fire for resource benefit. The 

potential effects of fire on water resources would depend largely on the severity and size of the fire, with a low 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

severity burn being less likely to degrade water quality and quantity than a severe burn, and a small fire affecting a 

smaller surface area than a large fire. In addition, the closer the fire is to a water body, the more likely it would be to 

affect water quality. The BLM would use fire and fuel breaks to limit the spread of fire. Most fire treatments would 

occur along the western slopes of the Roberts Mountains, and at the Whistler and Sulphur Spring Wildfire 

Management units. 

Prescribed fire could be used on several pinyon-juniper treatment areas, while wildland fire for resource benefit would 

be used on the Sulphur Spring Wildfire Management Unit. The BLM would also thin and remove pinyon-juniper and 

create fire breaks. Approximately one-third of the proposed treatment acres are on soils that are susceptible to 

compacting, and the resulting adverse impacts from erosion, runoff, sedimentation, and degraded soil quality would 

be of concern for this treatment group. In addition, approximately 17 percent of treatment acreages has severe water 

erosion hazard. Nearly 80 percent of the acreage associated with the Atlas, Birch, Frazier, Gable, Henderson, Upper 

Pete Hanson, Upper Roberts, and Vinini units has moderate or high fire damage susceptibility, while about 70 percent 

of acreage of the Three Bars Ranch, Cottonwood/Meadow Canyon, Dry Canyon, Lower Pete Hanson, Tonkin North, 

Tonkin South, and Whistler units, and Sulphur Spring Wildfire Management Unit, has moderate to high fire damage 

susceptibility. Thus, mechanical treatments may be preferable to fire treatments if there is concern about soil damage 

and loss. If fire is used, effort would be made to burn during the cooler periods of the year and to keep fire intensity 

low.

Beneficial Effects 

Historical fire suppression has affected water quality and quantity on the 3 Bars Project area, as fire suppression is 

partly responsible for the spread of pinyon-juniper woodlands. The spread of Utah juniper and increase in the density 

of juniper stands has led to conditions that favored a decrease in soil infiltration and increase in peak discharges, 

especially in areas where dense pinyon-juniper cover has resulted in a lack of understory vegetation. 

An important objective of pinyon-juniper treatments is to remove encroaching pinyon-juniper to restore the natural 

hydrologic regime. Treatments should lead to a long-term decrease in runoff, and an increase in infiltration, which 

should help to reduce the short-term intensity of stream flows during high rainfall events to the benefit of stream 

function and stability. 

Hydrologic functions may ultimately improve along some perennial and intermittent streams and springs within the 

pinyon-juniper treatment areas. Petersen and Stringham (2008) found that water infiltration decreased as juniper 

canopy cover increased due to the loss of herbaceous and shrub vegetation. Depth of water was also lowest in plots 

dominated by juniper. Pierson et al. (2008) and Thurow and Hester (2012) found that runoff and erosion are greater 

from interspace areas than vegetated areas within pinyon-juniper woodlands. Lossing (2012) observed that removal of 

pinyon-juniper resulted in a 40 percent increase in the amount of rainfall reaching the soil surface compared to 

untreated stands. Thus, removal of trees should increase runoff, but could also increase infiltration. 

Noelle (2012) observed that by leaving slash and other woody debris on the ground, sediment yield was significantly 

reduced. It is unlikely that additional water yields (flow durations and volumes) would be widespread, but they may 

occur at some treatment sites where dense pinyon-juniper stands occur along streams or near springs. As discussed 

earlier, removal of pinyon-juniper that is encroaching into riparian habitat can improve stream flow. These benefits 

would be more likely in Phase II and III pinyon-juniper stands, in the mountains, or on upstream reaches of mountainfront alluvial fan channels (DeBoodt 2008). However, Ffolliott and Gottfried (2012:15), in their literature review of 

hydrologic processes in pinyon-juniper woodlands, came to the conclusion “that the potential for increasing 

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WATER RESOURCES 

streamflow volumes by converting tree overstories to an herbaceous cover is poor.” They attributed this to the fact 

that there are few opportunities to reduce evapotranspiration losses in areas with little rainfall where pinyon-juniper is 

typically found. The low amount of annual precipitation also has little influence on soil moisture. 

Treatments along riparian corridors, including the Atlas, Birch, Frazier, Henderson, Upper Pete Hanson, Upper 

Roberts Creek, and Vinini units, may result in some streamflow increases and water quality improvements, while 

improvements to the understory should reduce soil erosion and impacts to water quality long-term. These treatment 

areas are within and along the flanks of the Roberts Mountains. Removal of pinyon-juniper from these areas can be 

expected to improve infiltration and recharge to shallow groundwater along and near stream areas. The degree of 

improvement would depend on the depth to groundwater and the nature of the bedrock hosting the shallow aquifer. 

Thurow and Hester (2012) found that runoff and erosion were greater from manual and mechanical treatments when 

slash was removed than allowed to remain on the ground. 

At the 3 Bars Project hazardous fuels reduction treatment units, including Cottonwood/Meadow Canyon, Dry 

Canyon, Lower Pete Hanson, Sulphur Spring Wildfire Management, and Tonkin units, some flow increases may 

occur at springs or along streams due to treatments. Hydrologic and wetland functions may improve at the base of 

alluvial fans and along the valley axis in the upper Coils Creek drainage, near Meadow Canyon, and in the western 

part of the Three Bars Ranch treatment area. The Sulphur Spring Wildfire Management and Whistler units are along 

the western side of Diamond Valley and are in recharge areas for the shallow alluvial aquifer in Diamond Valley. 

Removal of pinyon-juniper could lead to an increase in groundwater recharge in Diamond Valley. 

Efforts to reduce the risk of catastrophic wildfires through reduction of hazardous fuels and creation of fire and fuel 

breaks would reduce the potential for excessive loss of plant and litter cover and the potential for soil erosion and soil 

mass failures that cause a decrease in water quality. Fire use and other treatments that restore natural fire regimes and 

ecosystem processes would reduce the effects of fire suppression and benefit water resources and quality. 

Sagebrush Treatments 

Adverse Effects 

Approximately 5 miles of perennial stream are associated with riparian management projects within the larger 

sagebrush treatment area (Lower Henderson 1 and 3, and Lower Vinini Creek units). Only 1.3 miles of perennial 

stream habitat are associated exclusively with sagebrush treatment projects—Table Mountain (Henderson and Vinini 

Creeks), and West Simpson Park (unnamed) units. Approximately 400 acres of treatments are associated with 

intermittent/ephemeral streams. Water erosion risk is low for most sagebrush treatment areas, except at West Simpson 

Park, where most (84 percent) of the treatment area would be susceptible to severe water erosion, and at the Three 

Corners Unit, where 27 percent of unit has severe or moderate risk of water erosion. 

If livestock are used as a method of biological treatment to control cheatgrass, crested wheatgrass, and forage kochia, 

the action of their hooves would cause some disturbance, shearing, and compaction of soil, increasing its 

susceptibility to both water and wind erosion. Severe compaction often reduces the availability of water and air to the 

roots, sometimes reducing plant vitality (Belsky 2000). 

 Beneficial Effects 

Seedings and plantings to promote sagebrush development in areas where sagebrush should occur based on ecological 

site description reference, desired state, or management objective, would help to stabilize soils and reduce the risk of 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

wind and water erosion. Removal of pinyon-juniper from sagebrush treatment areas could improve water flows and 

groundwater recharge. 

Mechanical treatments could improve infiltration in clayey or compacted soils. Henderson Creek is found within the 

Table Mountain area. Seeding and planting, and pinyon-juniper thinning, in this area may improve hydrologic 

functions along the creek, particularly by improving runoff conditions and reducing accelerated erosion and related 

suspended sediment and turbidity. 

For some treatment areas, pinyon-juniper removal could improve groundwater recharge by limiting the amount of 

water lost through plant evapotranspiration. In this case, base flows, which are dependent on the quantity of 

groundwater discharge, would increase. These changes could be very minor or short-lived if areas were revegetated 

quickly. 

Under some circumstances, vegetation removal could result in the reduction of groundwater discharge and baseflow 

as a function of reduced infiltration rates. Reduced infiltration rates result in more surface runoff reaching streams and 

lakes immediately after a rain event, thus increasing the velocity, frequency, and magnitude of peak stream flows. 

These changes in water quantity could alter the physical characteristics of stream channels and affect the speed of 

water movement. Any changes would last until the site was revegetated. Stream restoration projects adjacent to 

sagebrush treatment areas that improve stream function and restore riparian communities, however, should mitigate 

the short-term increase in runoff from these sites. 

Non-native vegetation, specifically cheatgrass, on the 3 Bars Project area is associated with the occurrence of 

wildfires, which in turn have detrimental effects on water quality. Use of manual, mechanical, and biological control 

methods and fire use can benefit water quantity and quality if noxious weed and other invasive non-native vegetation 

removal reduces the risk of catastrophic wildfire. 

3.10.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Of the approximately 6,350 acres that would be treated annually under Alternative B, about 2,000 acres would be 

treated in areas that have moderate to high water erosion potential, or about half that of Alternative A. Because 

prescribed fire and wildland fire for resource benefit would not be allowed under Alternative B, there would be no 

risks to water resources from fire use. Excluding prescribed burns would avoid the increases in runoff and erosion 

common to burned areas. Reduced soil infiltration, due to resinous sealing after intense burning that can occur in high 

fire susceptibility risk areas, would not occur as a result of prescribed burns. This may not be particularly beneficial, 

however, if more extensive and intense wildfires occur in place of controlled burns. 

By not being able to use prescribed fire, the BLM would be limited to mechanical and biological control treatments to 

slow pinyon-juniper encroachment, thin pinyon-juniper to promote understory vegetation, and control noxious weeds 

and other invasive non-native vegetation. In addition, mechanical methods could result in more soil disturbance than 

the use of fire, which could lead to water degradation in areas with high water erosion risk. The West Simpson Park 

Unit is on rugged terrain, and use of mechanical equipment to control cheatgrass would be difficult and erosion 

potential from treatments in this area would be great. If not controlled, large infestations of cheatgrass and other 

noxious weeds and other invasive non-native vegetation could result in frequent wildfires that would degrade water 

quality. 

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WATER RESOURCES 

3.10.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would only be able to use manual and classical biological control methods to treat 

vegetation and would only treat about one-fourth as many acres as would be treated under Alternative A. 

The risk of localized soil compaction and short-term accelerated erosion from treatments, and its contribution to water 

quality degradation, would be less under Alternative C than the other alternatives, as there would be little ground 

disturbance 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 impacts on soil would be greater under this alternative than the 

other action alternatives. In addition, fewer acres would be treated to improve stream function and capability, and to 

remove pinyon-juniper and improve key sagebrush habitat, and benefits to surface and groundwater availability and 

quality from treatments under Alternative C would be less than under Alternatives A and B. 

3.10.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to soil resources from this alternative as no treatments would be authorized under 

this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, 

diverse stands; slow the spread of noxious weeds and other invasive non-native vegetation, especially cheatgrass; 

restore fire as an integral part of the ecosystem; or reduce the risk of a large-scale wildfire. The processes that create 

knickpoints, headcuts, and unstable streambanks would remain active, there would be few benefits to deep-rooted 

vegetation near streams, and there would be little improvement in stream flows. Thus, the health of the landscape 

would continue to deteriorate, and water quality and quantity would also deteriorate due to loss of soil due to erosion, 

stream channel instability, pinyon-juniper encroachment, and wildfire. These long-term effects would be greatest 

under Alternative D. 

3.10.3.4 Cumulative Effects 

The CESA for water resources is approximately 1,841,700 million acres and includes those watersheds at the 

Hydrologic Unit Code 10 level that are all or partially within the 3 Bars Project area (Figure 3-1). Approximately 92 

percent of the area is administered by the BLM, 6 percent is privately owned, and 2 percent is administered by the 

Forest Service. Past and present actions that have influenced water resources in the 3 Bars ecosystem are discussed in 

Section 3.3.2.3.3.

3.10.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

The use of temporary fencing to protect treatment areas within the CESA, should benefit water resources. The 

measures that the BLM would take to minimize livestock and wild horse impacts to treatment areas are discussed in 

more detail in Section 3.18.4 (Livestock Grazing Mitigation), and in Appendix C. 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds, and aerial-based 

application methods to remove cheatgrass, and would restore burned areas under the Burned Area Emergency 

Stabilization and Rehabilitation program, under existing authorizations on about 1,000 acres annually. These 

treatments could have short-term effects on water quality, primarily through ground disturbance and erosion 

associated with use of mechanical equipment, or if herbicides were accidentally spilled into a water body, but these 

risks would be negligible. Treatments would help to reduce hazardous fuels, slow the spread of noxious weeds and 

other invasive non-native vegetation, and reduce surface runoff and erosion associated with burn sites on about 1,000 

acres annually, to the benefit of water resources. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Five herbicides are typically used on the 3 Bars Project area—2,4-D, glyphosate, imazapyr, metsulfuron methyl, and 

picloram. For the 3 Bars Project, it is likely that the BLM would also use imazapic to treat cheatgrass. Based on an

assessment of risks from the use of herbicides, there is potential for glyphosate and metsulfuron methyl to be 

transported by wind and water in areas with moderate to high risk of wind or water erosion. Several herbicides are 

known groundwater contaminants (USDOI BLM 2007b:4-29 to 4-34). The BLM would minimize the risk of 

contamination of water bodies from herbicides by using appropriate buffer zones for herbicides not labeled for aquatic 

use based on risk assessment guidance, with minimum widths of 100 feet for aerial, 25 feet for vehicle, and 10 feet for 

hand spray applications. 

Land development, mineral development, and oil, gas, and hydrothermal exploration and development would disturb 

soil, which would lead to soil erosion and water quality impacts and use of groundwater for public and industrial uses. 

Land development and development of natural resources would involve the use of equipment and drilling wells, 

which could result in spills of hydrocarbons and other hazardous materials. This, in turn, could impact surface water 

and groundwater. For example, a recent oil spill at the Blackburn oil well in Pine Valley impacted over 3 acres 

(USDOI BLM 2012b:4-47). 

Modeling suggests that there could be a significant impact to groundwater levels near the Mount Hope Project due to 

mining and other activities in the CESA, and that it may be 100 years or more before groundwater levels have 

recovered to their pre-mining levels (USDOI BLM 2012b:4-48 to 4-50). Mining activities within the CESA may also 

create significant adverse impacts to surface water resources including 2 perennial stream segments (Roberts Creek 

and Henderson Creek) and 22 springs, mainly by altering drainage features, by dewatering springs or stream 

segments, and by water quality impacts from disturbed area runoff or escapes from processing facilities. Most of these 

impacts from mining activities would be avoided or reduced through state and federal mining regulations and related 

compliance programs. However, modeling done for the Mount Hope Project found that agriculture, mining, and oil 

and gas development could lead to substantial water quantity and quality issues in the CESA (USDOI BLM 2012b:3-

74 to 3-112).

Hazardous fuels reduction, habitat improvement, and noxious weeds and other invasive non-native species control 

projects would occur on approximately 142,000 acres (127,000 for the 3 Bars Project and 15,000 acres for other 

hazardous fuels projects in the CESA), or 8 percent of the CESA (about 1 percent of the CESA annually). These 

treatments would lead to short-term increases in soil erosion and surface water runoff, but would have long-term 

benefits to water quality and possibly to water flows. The disturbance effects resulting from restoration activities are 

predicted to have less impact and be less severe than effects and erosion caused by catastrophic wildfire, which could 

occur on about 6,900 acres annually. In addition, a reduction in the spread of noxious weeds and other invasive nonnative vegetation is expected to help reduce soil erosion, especially in areas that are prone to water erosion. Overall, 3 

Bars Project actions would have a minor contribution to water resources effects occurring within the CESA under 

Alternative A. 

3.10.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on water resources would 

be similar to those described under Alternative A. The BLM anticipates treating about half as many acres under 

Alternative B as under Alternative A, and less effort would be spent by the BLM on treatments to reduce wildfire risk 

and loss of soil from erosion, including use of fire to restore natural fire regimes. 

3 Bars Project Final EIS 3-125 October 2016
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3 Bars Project Final EIS 3-126 October 2016

Adverse effects to water resources would generally be the same as described for Alternative A. However, by not using 

fire, there would be no risks to water quality from fire on several thousand acres annually within the 3 Bars Project 

area. 

The BLM would be limited to discing and plowing and using livestock to control non-native vegetation on several 

thousand acres annually. These methods could result in more soil disturbance and soil erosion that could impact water 

quality, than the use of fire. The West Simpson Park Unit is on rugged terrain, and use of mechanical equipment to 

control cheatgrass would be difficult and erosion potential from treatments would be great. 

Under Alternative B, annual hazardous fuels reduction and habitat improvement projects could occur on about 6,300 

acres within the 3 Bars Project area, and on an additional 1,500 acres within the CESA under current or reasonably 

foreseeable future authorizations, or less than 1 percent of acreage within the CESA. Because of the large acreage 

treated, water quantity and quality should improve within the 3 Bars Project area and CESA, although not to the 

extent as would occur under Alternative A. 

3.10.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on water resources would 

be similar to those described under Alternative A. Under Alternative C, the BLM would treat about 3,200 acres 

annually within the 3 Bars Project area. Adverse, short-term effects to water resources associated with the use of 

prescribed fire and wildland fire for resource benefit and mechanized equipment would not occur under Alternative C. 

However, fire use, herbicides, and mechanized equipment would be used in other portions of the CESA. These 

treatments in other portions of the CESA would affect about 1,500 acres annually. 3 Bars Project restoration 

treatments would have short-term adverse and long-term beneficial effects on water resources, but these effects would 

be negligible (0.2 percent of acreage within the CESA on an annual basis) in the context of the acreage within the 

CESA and other types of activities that have effects on water resources, such as the Mount Hope Project and 

irrigation. By not being able to use mechanical methods to thin and remove pinyon-juniper and sagebrush to 

encourage development of the understory, create fire and fuel breaks, use seeding/planting to improve habitat, and 

remove slash and other downed woody debris and reduce hazardous fuels, however, the risk of wildfire and its 

impacts on water resources would likely increase on the 3 Bars Project area. Because of the acreage treated, water 

quantity and quality would improve within the 3 Bars Project area and provide a minor benefit to water resources 

within the CESA, although not to the extent as would occur under Alternatives A and B. 

3.10.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on water resources would 

be similar to those described under Alternative A. There would be no cumulative impacts to water resources from this 

alternative as no treatments would be authorized under this alternative. The BLM could conduct stream 

bioengineering treatments; create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse 

stands; slow the spread of noxious weeds and other invasive non-native vegetation, especially cheatgrass; restore fire 

as an integral part of the ecosystem; and reduce the risk of a large-scale wildfire, but on a very limited acreage. Thus, 

factors that contribute to reduction in water quantity and degradation of water quality would remain, including soil 

erosion, stream channel instability, spread of noxious weeds and other invasive non-native vegetation, pinyon-juniper 

encroachment, and wildfire, and would likely be greatest under this alternative. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.10.3.5 Unavoidable Adverse Effects 

An increase in soil erosion and surface water runoff could result from restoration treatments, which could lead to 

streambank erosion and sedimentation. Rates of runoff would be influenced by precipitation rates, soil types, and 

proximity to the treated area. All vegetation removal activities could disturb the soil and reduce the amount of 

vegetation binding to soil, potentially causing erosion and increased sedimentation. The removal of vegetation would 

decrease the amount of rainfall captured by plants, detritus, and soil, potentially leading to increased stormwater 

flows, runoff velocity, and sedimentation. 

3.10.3.6 Relationship between Local Short-term Uses and Maintenance and Enhancement 

of Long-term Productivity 

Over the short-term (several months or a few years), access for some users to surface water features within treatment 

areas would be restricted. The BLM would investigate the status of any water right associated with an affected water 

feature to determine whether, and to what extent, it could implement the proposed treatment, and if any mitigation 

was needed and the effectiveness of the mitigation. This would be an adverse impact to existing water rights holders 

and beneficial uses. The BLM would offset those impacts to existing water rights holders. 

Treatment of vegetation would cause a short-term increase in soil erosion and surface water runoff. Successful control 

of noxious weeds and other invasive non-native plants, however, would lead to improved conditions in watersheds 

over the long-term, with the greatest improvement likely to occur in degraded watersheds. The eventual growth of 

desirable vegetation in treated areas would moderate water temperatures, buffer the input of sediment from runoff, 

and promote streambank stability. Ongoing efforts by the BLM to enhance vegetation would also help to increase the 

acreage of watersheds that are functioning properly. Improvement of watersheds and water flows and quality would 

benefit Lahontan cutthroat trout and other aquatic organisms that depend upon aquatic habitats for their survival. 

Vegetation treatments that reduce hazardous fuels would benefit ecosystems by reducing the chances of a large, 

uncontrolled wildfire, which could destroy a large amount of high quality habitat and potentially lead to erosion, 

especially if followed by heavy rainfall. Hazardous fuels reduction would also decrease the likelihood that wildfire 

suppression activities would occur in or near aquatic habitats (USDOI BLM 2007b:4-247). 

3.10.3.7 Irreversible and Irretrievable Commitment of Resources 

An accidental fuel spill or uncontrolled wildland fire could cause damage to water bodies and the ability to use water 

resources in the affected area could be lost for a short period of time. However, these impacts would be highly 

unlikely and could be reversed if restoration treatments are successful. Other treatments should not result in 

irreversible or irretrievable commitments of water resources. 

Under all alternatives, there could be a short-term (less than 5 years) increase in soil erosion from 3 Bars Project 

treatments, primarily those where the soil is disturbed by mechanical or fire treatments. This increase in erosion could 

lead to increased sedimentation or turbidity in streams or ponds. These impacts from soil erosion would accrue with 

soil erosion and loss of soil associated with other land disturbance activities in the CESA. These losses of soil due to 

erosion and its impacts to water quality in streams and ponds in the 3 Bars Project area would be offset by long-term 

benefits from: 1) stream restoration projects that promote stream stability and riparian vegetation development; 2) 

improvements in vegetation in areas where thinning pinyon-juniper promotes understory development; 3) removal 

and control of noxious weeds and other invasive non-native vegetation and revegetation of treatment sites with native 

3 Bars Project Final EIS 3-127 October 2016
WATER RESOURCES 

vegetation; and 4) hazardous fuels reduction treatments that reduce the risk of a catastrophic wildfire, including 

prescribed burning and use of wildland fire for resource benefit, and the creation of fire and fuel breaks. 

It is possible that prescribed fire and wildland fire for resource benefit treatments could result in erosion that could 

adversely affect water quality. However, the BLM would use SOPs to minimize this risk, including discing on 

contour and avoiding treatments on steep slopes. Loss of soil and its effects on water quality could be greater in areas 

burned by wildfire, as these areas can be large, are often in remote areas, and can be difficult to revegetate. Thus, 

BLM treatments that reduce the risk of a wildfire should help to slow soil erosion and improve water quality. 

3.10.3.8 Significance of the Effects under the Alternatives 

Under all alternatives, there could be short-term releases of sediments and fuels and lubricants from equipment into 

water bodies from actions within the CESA. The BLM would prevent or minimize the movement of fuels and 

lubricants into water bodies by fueling and servicing equipment off-site or away from streams. Although multiple 

treatments could occur on some treatment units or sites, especially those where prescribed fire and wildland fire for 

resource benefit are used (e.g., fire treatment followed by mechanical treatment to control non-native species and 

seeding), treatments would likely occur only once or twice a year. By retaining buffers between treatment areas and 

water bodies where feasible, and following other SOPs that protect water quality, it is unlikely that there would be a 

change in water quality that would often or regularly exceed Nevada water quality standards. 

The BLM could, but is not likely to, divert water while reconstructing streams, and use water to manage prescribed 

fires and wildland fires for resource benefit. The BLM also may prevent access by livestock, wild horses, and other 

wild ungulates to treatment sites near water in riparian and aspen treatment areas until these areas were restored and 

able to accommodate use by these animals. It is anticipated that access restrictions would be in place for a minimum 

of 2 growing seasons or until vegetation establishment criteria are met. If access to treatment areas is restricted, the 

BLM would work with the affected permittee(s) to ensure livestock, wild horses, and other wild ungulates access 

water. Thus, there should be no significant long-term diversion, access restriction, or consumptive use of surface 

water that substantially reduces water availability and the uses recognized by Nevada Department of Water Resources 

in the CESA under all alternatives. This would include flows and seasons of use in springs or streams where existing 

beneficial water uses, as defined by Nevada Division of Environmental Protection and recorded by Nevada 

Department of Water Resources, may be affected. 

Nearly all 3 Bars Project restoration treatments would cause short-term erosion that leads to increased sedimentation 

in streams or ponds. These risks would be greatest in restoration areas with moderate to severe water or wind erosion 

potential, or where soils are susceptible to fire degradation. Treatments that disturb the soil or remove large amounts 

of vegetation, including the use of mechanical treatments such as discing and plowing, and prescribed fire and 

wildland fire for resource benefit, could also lead to short-term erosion and sedimentation. Long-term, restoration 

treatments would lead to conditions that should reduce the risk of erosion, including revegetation of treatment sites 

with native vegetation and treatments to stimulate growth of the understory. Treatments that reduce the risk of 

wildfire, including hazardous fuels treatments, control of noxious weeds and other invasive non-native vegetation, and 

create fire and fuel breaks would reduce the risk of erosion resulting from wildfire and its effects on water quality. 

Thus, none of the alternatives would result in a significant long-term (greater than 5 years) accelerated erosion from 

watershed slopes or increased sedimentation in streams or ponds. 

None of the treatments proposed under the alternatives should lead to significant uncontrolled stream channel and 

bank instabilities. However, stream channel improvements are not proposed under Alternative D, and only about 8 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

miles of degraded streams would be treated under Alternative C. Thus, it is likely that the number of miles of streams 

with stream and bank channel instability within the 3 Bars Project Area and CESA would continue to increase under 

Alternative D, while there would be little improvement in stream and bank channel stability under Alternative C. 

As discussed in the Mount Hope Project EIS, mining, agriculture, and other activities in the CESA are predicted to 

have a significant impacts to surface and groundwater quantity, including 2 perennial stream segments and 22 springs 

(USDOI BLM 2012b:4-48 to 4-50); these impacts could last 100 years or more. Tomitigate these impacts, the BLM 

identified several mitigation measures, including installation of new wells or deepening of existing wells, 

development of existing water sources, including springs, and fencing to protect water sources (USDOI BLM 

2012b:19-22). Short-term, 3 Bars Project restoration treatments also could contribute to localized, minor declines in 

groundwater levels, especially in large-scale fire treatment areas. However, these declines would likely not exceed 

seasonal fluctuations in water levels. Long-term, 3 Bars Project treatments should result in improved surface water 

flows and groundwater recharge. Thus, the effects of 3 Bars Project treatments would not, by themselves, result in a 

significant cumulative effect to water resources. 

3.10.4 Mitigation 

Water resources would benefit from mitigation measures identified in Section 3.18.4 (Livestock Grazing Mitigation). 

No mitigation or monitoring measures are recommended specifically for water resources. 

3.11 Wetlands, Floodplains, and Riparian Zones 

3.11.1 Regulatory Framework 

This section discusses the laws and regulations that apply to wetlands, floodplains, and riparian zones potentially 

affected by the 3 Bars Project. These resources are considered valuable natural resources that provide habitat for a 

variety of dependent plant and wildlife species. 

3.11.1.1 Definition of Wetlands 

Wetlands are defined by the U.S. Army Corps of Engineers (USACE) and USEPA in 33 CFR § 328.3 and 40 CFR § 

230.3 as those areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient 

to support, and under normal conditions do support, a prevalence of vegetation typically adapted for life in saturated 

soil conditions. Wetlands generally include swamps, marshes, bogs, wet meadows, and similar areas. 

The USACE’s Wetland Delineation Manual defines a three parameter approach to delineating jurisdictional wetlands. 

In order for an area to be considered a jurisdictional wetland it must support each of the three wetland parameters: 

hydric soils, wetland vegetation, and wetland hydrology (USACE 1987). 

Hydric soils are defined as “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.” Wetland 

(hydrophytic) 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. The Wetland Delineation Manual requires that, in most cases, more 

than 50 percent of the dominant vegetation include species that meet the wetland plant technical criteria. Wetland 

hydrology, although the driving force for wetland formation, is the most obscure attribute to define. Wetland 

3 Bars Project Final EIS 3-129 October 2016
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

hydrology encompasses all hydrologic characteristics of areas that are periodically inundated or have soil saturated to 

the surface at some time during the growing season (USACE 1987). 

3.11.1.2 Definition of a Riparian Zone 

BLM Manual 1737, Riparian-Wetland Area Management, defines a riparian zone as a form of wetland transition 

between permanently saturated wetlands and upland areas (USDOI BLM 1992a). These areas exhibit vegetation or 

physical characteristics reflective of permanent surface or subsurface water influence. Lands along, adjacent to, or 

contiguous with perennially and intermittently flowing rivers and streams, glacial potholes, and the shores of lakes 

and reservoirs with stable water levels are typical riparian zones. Excluded are such sites as ephemeral streams or 

washes that do not exhibit the presence of vegetation dependent upon free water in the soil. 

3.11.1.3 Definition of a Floodplain 

The geomorphic floodplain is that 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. When flood energy is dissipated, floodwater velocity is reduced 

and sediments begin to settle out. All of this happens best when the active riparian floodplain is properly vegetated 

with riparian grasses, sedges, shrubs, and trees. The root masses of these plants anchor them into the floodplain and 

hold the sediments in place. The above ground parts of these riparian plants help to physically disrupt and retard the 

energy of floodwater and to trap and stabilize sediments. 

3.11.1.4 Sections 401 and 404 of the Clean Water Act 

The USACE regulates the discharge of dredged or fill material into waters of the U.S. under Section 404 of the Clean 

Water Act. Section 404 prohibits the discharge of dredged or fill material into waters of the United States, (including 

wetlands) without a permit from the USACE. The regulations and policies of the USACE mandate that the filling of 

wetlands be avoided unless it can be demonstrated that no practicable alternatives (to filling wetlands) exist. 

Section 401 of the Clean Water Act requires that an applicant applying for a USACE permit for the discharge of 

dredge or fill material must also obtain a water-quality certificate from the appropriate state agency that states that 

their activity is consistent with the state’s water quality standards and criteria. The conditions in the certificate are 

incorporated into the USACE permit. Section 401 certifications are issued by the Nevada Division of Environmental 

Protection. 

3.11.1.5 Executive Orders 

Two Executive Orders apply to wetlands and floodplains: 

 Executive Order 11990, Protection of Wetlands – agencies are to minimize destruction, loss, or degradation 

of wetlands, and enhance and preserve the natural and beneficial values of wetlands; and 

 Executive Order 11988, Floodplain Management – addresses activities in floodplains and management of 

multiple resources comprising floodplain values. 

3 Bars Project Final EIS 3-130 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.11.2 Affected Environment 

3.11.2.1 Study Methods and Analysis Area 

Study methods employed in the preparation of this section include review of baseline information, a reconnaissancelevel site visit, project-specific vegetation mapping, and agency coordination. Several sources were reviewed in the 

preparation of this section, including USGS topographic and USFWS National Wetland Inventory maps; aerial 

photographs; and technical documents including the Falcon to Gonder EIS (EDAW 2001), AECC (USDOI BLM 

2009a), and Mount Hope Project EIS and references cited therein (USDOI BLM 2012b); discussions with BLM 

resource specialists; Geographic Information System shapefiles provided by BLM resource specialists for spring 

inventories and riparian monitoring; and site-specific studies conducted on the 3 Bars Project area. 

The analysis area for direct and indirect effects to wetlands, floodplains, and riparian zones lies within the 3 Bars 

Project area. The analysis area for cumulative impacts to wetlands, floodplains, and riparian zones includes the 

Hydrologic Unit Code 10 watersheds wholly, or partially within, the project area (Figure 3-1). This area includes 

parts of the drainages and groundwater basins as defined by the Nevada Department of Water Resources and 

identified in Figure 3-22. 

3.11.2.2 Wetlands 

No formal delineation of wetlands has been done for the project area. Based on the USFWS National Wetlands 

Inventory, approximately 2,363 acres of wetlands are found on the project area (USDOI USFWS 2012). Wetlands in 

the 3 Bars Project area include saline flats or playas, and wetlands associated with surface water features, including 

stream channels and reservoirs Wet meadows on the project area are dominated by hydrophytes such as Nebraska 

sedge, spikerush, alkali bluegrass, foxtail barley, clustered field sedge, and Baltic rush. 

3.11.2.3 Riparian Zones 

Approximately 96 miles of perennial stream are on the project area. These include Denay Creek, Henderson Creek, 

McClusky Creek, Roberts Creek, and Vinini Creek (Figure 3-22). There are also 2,334 miles of 

intermittent/ephemeral streams. The USGS does not distinguish between intermittent and ephemeral streams within 

the project area. The majority of streams classified as intermittent on the 3 Bars Project area do not have seasonal 

water, but only have water occasionally and would be classified as ephemeral. These streams may have associated 

riparian habitat. Riparian zones in the project area have vegetation dominated by wild rose, narrow-leaf willow, 

narrow-leaf cottonwood, redosier dogwood, and water birch. Aspen characterizes some of the mountainous riparian 

zones. 

3.11.2.4 Floodplains 

Federal Emergency Management Agency (FEMA)-designated Zone A flood hazard areas, which would be flooded 

during a 100-year, 24-hour runoff event, have been delineated in low-lying areas in the northern, eastern, and southern 

parts of the project area. Based on historical maps, the major Zone A delineations occur along Pine Creek, Henderson 

Creek, and lower Pete Hanson Creek in the northern part of the project area. All of the lower-elevation areas along 

Slough Creek, Coils Creek, and lower Roberts Creek are within floodplains (FEMA 2013). These zones range from 

approximately one-eighth to one-quarter mile wide along the individual streams, and coalesce to form broad flood 

3 Bars Project Final EIS 3-131 October 2016
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

zones up to 2 or 3 miles wide along the valley floors. No FEMA flood hazard Zone A delineations occur in the central 

or western part of the project area. 

3.11.2.5 Proper Functioning Condition Surveys 

Proper Functioning Condition surveys have been conducted by the BLM for wetlands and riparian zones on the 

project area. A wetland area or riparian zone is considered to be in Proper Functioning Condition when adequate 

vegetation, landform, or large woody debris are present to: 

 dissipate stream energy associated with high water flows, thereby reducing erosion and improving water 

quality; 

 filter sediment, capture bedload, and aid in floodplain development; 

 improve floodwater retention and groundwater recharge; 

 develop root masses that help to 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. 

If a wetland or riparian zone is not in Proper Functioning Condition, it is placed into one of three other categories 

(BLM 1998a):

 Functional-at-risk – Riparian or wetland areas are in functional condition, but an existing soil, water, or 

vegetation attribute makes them susceptible to degradation. 

 Nonfunctional – Riparian or wetland areas clearly are not providing adequate vegetation, landform, or large 

woody debris to dissipate stream energy associated with high flows, and thus are not reducing erosion, 

improving water quality, or meeting other goals mentioned above. 

 Unknown – Riparian or wetland areas where managers lack sufficient information to make any form of 

determination. 

Functional-at risk areas may be placed into other sub-categories, depending on whether an upward trend toward 

attaining, or a downward trend away from, Proper Functioning Condition can be determined. 

Proper Functioning Condition ratings for the 3 Bars ecosystem for those streams and wetlands that have been rated 

are: 

 Proper Functioning Condition - 47 miles of stream and 58 acres of wetlands. 

 Functioning-at-risk with upward trend - 35 miles and 13 acres. 

 Functioning-at-risk with trend not apparent - 34 miles and 29 acres. 

 Functioning-at-risk with downward trend - 37 miles and 61 acres. 

 Nonfunctional - 26 miles and 6 acres.

3 Bars Project Final EIS 3-132 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Factors contributing to degraded conditions include headcuts and knickpoints within deeply incised channels that are 

lowering the water table and drying out nearby wet meadows and riparian areas; altered runoff and infiltration 

regimes; bank shearing and terracing; channel erosion; poor sinuosity, width/depth ratio, and gradient along the 

stream reach; roads impacting stream flow; degradation by livestock and wild horses; frost heaving; lack of streamfloodplain connections; insufficient type or amount of vegetation to protect streambanks and slow discharge velocity; 

and noxious weeds and other invasive non-native vegetation (USDOI BLM 2009a, b).

A number of riparian and wetland areas on the Roberts Mountains are not at Proper Functioning Condition or have 

functioning-at-risk conditions with actively upward trends (Figure 3-24). Similar areas are more widely scattered in 

the Simpson Park Mountains. Pinyon-juniper expansion and/or encroachment are occurring in the Pete Hanson Creek 

and Birch Creek areas on the northern Roberts Mountains. Parts of Indian Creek and Indian Springs, a complex of 

sites in the northwestern part of the project area, and several sites in the Vinini and Henderson Creek drainages, are 

the major areas at Proper Functioning Condition. Other streams and springs are generally in a Functioning-at-risk 

condition; many have no observable trend, or are in a downward trend. 

3.11.3 Environmental Consequences 

3.11.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Key issues of concern that pertain to wetlands, floodplains, and riparian zones were identified in the AECC and 

during scoping. These issues include: 

 Concerns about the impacts of the various treatments on wetlands and riparian zones.

 Impacts of livestock on wetlands and riparian zones.

 The potential that desertification is making riparian zones less resilient. 

 Questions about hot season use of riparian and wetland areas for grazing. 

 Recommendations that the BLM remove wild horses, cut trees, and construct enclosures in meadow areas. 

 Streams, springs, and meadows are functioning at less than the Proper Functioning Condition. 

3.11.3.2 Significance Criteria 

Impacts to wetlands, floodplains, and riparian zones would be considered significant if BLM actions resulted in one or 

more of the following: 

 The destruction, loss, or long-term (greater than 10 years) degradation of wetlands, floodplains, or riparian 

zones. 

 A long-term reduction in the flood-attenuation functions of floodplains.

3 Bars Project Final EIS 3-133 October 2016
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-24

Proper Functioning Condition

Rating

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander CountyEureka

County

Pine Valley

Basin # 053

Diamond Valley

Basin # 153

Grass Valley

Basin # 138

Kobeh Valley

Basin # 139

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Proper Functioning Condition Rating

Proper Functioning Condition

Functioning-at-risk with Upward Trend

Functioning-at-risk with Trend Not Apparent

Functioning-at-risk with Downward Trend

Non-functioning

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: NDWR 2012, BLM 2013h.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-135 October 2016

 A long-term reduction in the functions of wetlands or riparian zones, a long-term reduction of the acreage of 

riparian and wetland areas in Proper Functioning Condition, or a downgrade of Functioning-at-risk riparian 

or wetland areas to a downward trend or to nonfunctional. 

3.11.3.3 Direct and Indirect Effects 

3.11.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Restoration treatments would focus on stabilizing streambanks and channels, reducing erosion, improving water 

flows, restoring native fire resilient vegetation, reconnecting streams with their floodplains, and restoring natural 

channel dimension, pattern, and profile. Wetland, floodplain, and riparian zone treatments have effects in common 

with Soil Resources (Section 3.9), Water Resources (Section 3.10), Native and Non-invasive Vegetation Resources 

(Section 3.12), Fish and other Aquatic Organisms Resources (Section 3.15), and Wildlife Resources (Section 3.16). 

Thus, adverse and beneficial effects associated with those resources, primarily those for Riparian Treatments and 

Aspen Treatments, would also apply to wetland, floodplain, and riparian zone resources and the reader is encouraged 

to also review those sections. 

Adverse Effects 

Various treatments under the alternatives have the potential to adversely affect nearby wetlands, floodplains, and 

riparian zones. Adverse effects associated with vegetation removal in wetlands and riparian zones were discussed in 

the 17-States PER (USDOI BLM 2007c:4-28 to 4-29). Removal of vegetation and soil disturbance associated with 

treatments could lead to increased soil erosion and surface water runoff, which could lead to channel alterations and 

sedimentation in wetlands and riparian zones. Removal of vegetation could also decrease the amount of rainfall 

captured by plants, detritus, and soil, potentially leading to increased stormwater flows and runoff velocity in streams 

and indirectly affecting wetlands and riparian zones. Increased light and disturbance tend to favor early successional 

species, including noxious weeds and other invasive non-native vegetation. By leaving slash and other downed woody 

debris from treatments on the ground as mulch, runoff and erosion would be slowed and more water would infiltrate 

into the ground. 

One important function of wetlands and floodplains is to dissipate the energies associated with flood events, thereby 

reducing erosion, capturing nutrient rich sediment, and improving water quality. Increased stormwater runoff can 

scour wetlands and floodplains and modify their morphology. Removal of vegetation may decrease resistance to 

overland flow. It would also decrease canopy interception of precipitation and evapotranspiration, which would 

increase the amount of free water. As a result, both increased runoff and increased infiltration would likely result. 

Siltation could reduce water quality and the amount of oxygen available to aquatic organisms. Siltation could also 

reduce the acreage of wetland and riparian habitat. Impacts associated with loss of vegetation would be short-term, as 

vegetation would soon return to treated areas. 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. 

Beneficial Effects 

Vegetation treatments would be used, to varying degrees, to help restore targeted wetlands and riparian zones to 

Proper Functioning Condition and to increase stream flows. Treatments would include stream bioengineering, 

structures such as deflectors and weirs, road and culvert modifications, removal of pinyon-juniper from aspen stands 
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

and historical riparian zones, hand planting of native species, and use of temporary and existing permanent fencing to 

restrict livestock, wild horse, and other wild ungulate access to treatment areas. These treatments, which would be 

designed specifically to improve the functions of targeted wetland and riparian zones, would be expected to have a 

beneficial effect on these areas. Excluding livestock, wild horses, and other wild ungulates from treatment areas using 

fencing would reduce soil disturbance in treatment areas and allow native vegetation to recover. 

Removal of pinyon-juniper may improve water flows in streams and water yields at spring sources and in nearsurface aquifers. Hand planting native species would benefit wetland and riparian zones by providing additional 

vegetation that would help prevent erosion, protect streambanks, and provide habitat for wildlife. 

3.11.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Approximately 63 miles of streams have been identified as Functioning-at-risk with no trend or a downward trend, or 

Nonfunctioning. Riparian zone treatments would focus on restoring stream and habitat functionality in those streams 

where both the morphology and structural integrity of the stream channel, plant species composition, soil structure, or 

other conditions within the riparian zone have been compromised by past actions. The BLM proposes to restore 

streams by removing, or reducing the effects of, causative factors that have led to stream degradation, and 

implementing bioengineering, streambank stabilization, and other methods that utilize structures which manipulate 

stream power to meander degraded and incised water courses in ways that restore stream functionality. 

Adverse Effects 

Manual treatments proposed for riparian zones would generate a relatively small amount of ground disturbance. 

Treatments include placement of rocks, gravel, logs, and other bioengineered structures in streams to manipulate 

water flow, and plantings along the streambank. Some associated erosion and sedimentation into aquatic habitats 

would occur over the short-term, as degraded channels are induced to evolve back towards a stable dimension, 

pattern, and profile. Additionally, if noxious weeds and other invasive non-native vegetation are present on treatment 

sites, or brought to the site by workers or their equipment, they could increase as a result of disturbance. 

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). Adverse effects would 

likely be associated with soil disturbance, vegetation removal, and any potential release of petroleum products from 

vehicles into aquatic systems. Use of heavy equipment in or near wetlands and riparian zones is likely to cause ground 

disturbance that could lead to a temporary increase in erosion. The use of heavy equipment can also result in soil 

compaction, particularly in areas of moist soils, which can increase surface runoff from the treated areas, reduce soil 

porosity, and limit water infiltration. Spills resulting from fueling, equipment maintenance, and operation could 

adversely affect water quality and the health of wetland or riparian zones. These effects would be minimized through 

the use of SOPs, including maintaining a 300-feet buffer between the fueling area and water bodies (Appendix C). 

For Frazier Creek Group units, all pinyon-juniper within 200 feet of riparian zones or within historic floodplains 

would be removed, except on south or west facing slopes lacking shrubs or herbaceous vegetation. This could cause 

short-term soil disturbance and erosion and increase surface water flows until ground cover re-established. Use of 

mulch and other erosion controls on treatment sites would reduce these effects. 

3 Bars Project Final EIS 3-136 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Many riparian treatment areas are within, or in close proximity to, aspen, pinyon-juniper, or sagebrush treatment areas 

as discussed below. Treatments in upland areas, especially those on hillslopes and involving the thinning or removal 

of pinyon-juniper, have the potential to adversely affect downslope riparian habitat. For example, removal of pinyonjuniper or other vegetation on nearby upland habitat could cause a short-term increase in surface water flows and soil 

erosion, leading to increased flows and sedimentation in streams. This could occur if a large precipitation event occurs 

before mulch is applied, and could generate erosion and sedimentation that could affect wetland, floodplain, and 

riparian habitats. By using slash and other woody debris from treatments as mulch, or having a vegetated buffer 

between upland treatment areas and water bodies, these effects to streams and other water bodies from upland 

treatments should be greatly reduced. 

Beneficial Effects 

It is expected that all of the proposed treatments in wetlands, floodplains, and riparian zones would have long-term 

beneficial effects on wetland and riparian habitats by restoring the natural processes that lead to Proper Functioning 

Conditions. 

Efforts to restore optimal channel dimension, pattern, and profile would help to improve surface water quality, 

attenuate peak runoff, capture sediment, increase groundwater recharge and base flow, expand riparian acreage, and 

support healthy, soil stabilizing, riparian vegetation. By restoring streams to stable channel types, reducing runoff, and 

increasing infiltration, water should stay on the land longer to the benefit of deep-rooted riparian/wetland vegetation, 

resulting in expanded riparian zones and more stable streams. Stream incision, which can be caused by a loss of 

stream sinuosity associated with increased runoff and/or decreased soil stabilizing vegetation, has caused groundwater 

to drain to the lower stream level along many proposed treatment streams, causing nearby areas to dry out. By 

creating conditions that reduce channel incision, induce sinuosity and bank storage, and reduce surface runoff and 

increase infiltration, deep-rooted herbaceous species that are being lost in many riparian zones should benefit. 

The BLM would remove pinyon-juniper that is encroaching into riparian zones. Treatments to remove pinyon-juniper 

from riparian management units may increase water yield and groundwater recharge, to the benefit of wetland 

vegetation, fish and other aquatic species, and wildlife (DeBoodt 2008). Pinyon and juniper are not riparian species, 

and are not as effective as native vegetation in stabilizing soil. If field investigations indicate that it would be 

beneficial to the system, logs and other woody debris would be placed into streams to slow water flows, induce 

meandering, and create wetland and riparian habitat. Pinyon-juniper that are cut down could also be removed from the 

site for firewood, fence posts, and other uses. 

Many riparian treatment areas are within or in close proximity to upland treatment areas. Although treatments upslope 

from riparian zones could have short-term adverse effects on stream flows and water quality, long-term, these 

treatments should be beneficial. Studies have shown that runoff from sites dominated by pinyon-juniper is up to 15 

percent greater than from sites without pinyon-juniper and that removal of pinyon-juniper that is encroaching into 

riparian habitat can improve streamflow. DeBoodt (2008) found that in areas where all junipers were cut from a 

watershed, late season spring flow, days of recorded ground flow, and late season soil moisture increased compared to 

pretreatment conditions. 

Surface water runoff may increase short-term from removal of vegetation, especially encroaching pinyon-juniper in 

Phase II and III stands, because there is often minimal ground cover and shrub vegetation below pinyon-juniper trees, 

and less rainfall would be intercepted by foliage after tree removal (Lossing 2012). As ground cover and low shrubs 

re-establish on treatment sites, however, surface runoff and peak discharge should decrease, and infiltration should 

3 Bars Project Final EIS 3-137 October 2016
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

increase, to the benefit of riparian and wetland habitat downslope. As a result, flows may last longer into the summer 

months at some springs and in perennial or intermittent streams where dense, deep-rooted pinyon-juniper or other 

stands are treated. By reducing the magnitude of peak discharges, the chances of stream restoration treatments 

succeeding due to moderating water flows would greatly increase. 

Because riparian treatment success in part depends upon successful completion of treatments upslope, the BLM 

would attempt to conduct treatments at similar times for treatment areas in close proximity to ensure that treatment 

impacts occur at about the same time, rather than over many years, and to ensure that treatments are integrated 

cohesively. For example, slash and other woody debris from pinyon-juniper treatments upslope from a riparian 

treatment area could be used as mulch to slow runoff on the pinyon-juniper treatment area, but also to provide logs 

and other woody debris for use in or near streams. 

Prescribed fire and wildland fire for resource benefit would be used to slow pinyon-juniper encroachment, which 

would decrease runoff and evapotranspiration and increase infiltration and shallow subsurface recharge. This would 

help to increase base streamflows, expand riparian extents, and decrease the damaging effects of high peak 

discharges. Other beneficial effects include decreasing hazardous fuels, triggering germination of certain native plant 

species, stimulating growth of new vegetation, and creating wildlife habitat. Fire may also increase the levels of 

certain nutrients utilized by plants by raising soil pH and burning woody material. Finally, trees near streams that are 

removed by fire would become standing wood that would ultimately become large woody debris in stream channels, 

which could provide important habitat for fish (USDOI BLM 2007c:4-31). It is expected that appropriately planned 

prescribed fires would be of low intensity and unlikely to carry in the damp soils and vegetation of wetlands. Over the 

long-term, with the planned control of noxious weeds and other invasive non-native vegetation, replanting as needed, 

and better grazing management, it is expected that native species would return and potentially increase in abundance 

in wetlands and riparian zones. 

Treatments that reduce hazardous fuels and create fire and fuel breaks would benefit wetlands and riparian zones by 

reducing the potential for catastrophic wildfires and resultant loss of high quality wetland and riparian habitat. 

Hazardous fuels reduction would also decrease the likelihood that wildfire suppression activities would be needed in 

or near aquatic habitats. 

The BLM would use protective fencing, but not other treatments, to restore riparian habitats at Denay Pond, Lone 

Spring, and Treasure Well. The BLM would provide a water gap within the fencing to allow livestock to access a 

portion of these perennial water sources. 

Aspen Treatments 

Adverse Effects 

The RM-A7, RM-A2, and RM-A5 aspen treatment units are partially or wholly within the larger Upper Henderson, 

Roberts Creek, and Upper Vinini Creek riparian units, respectively. Where projects overlap, riparian projects are 

typically limited to stream channel work, removal of nearby upland vegetation, plantings, and fencing, whereas aspen 

projects include pinyon-juniper removal, fencing, and disturbance to stimulate aspen suckering. In the areas of 

overlap, riparian zones and associated wetland areas may be subject to multiple project disturbances although the 

BLM would try to minimize multiple treatment disturbance by conducting treatments within the same general area at 

the about the same time. 

3 Bars Project Final EIS 3-138 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Beneficial Effects 

Aspen treatment projects would be expected to benefit riparian habitats by encouraging the growth of aspen 

communities. Aspen contributes to the stability of streams and provides shade and important wildlife habitat for a 

wide diversity of species (Shepperd and Mata 2005; see also Section 3.16). Therefore, riparian functions would be 

improved by aspen treatment projects. 

Actions that stimulate or enhance aspen suckering and sucker survival should improve the health of aspen stands, and, 

longer-term, reduce the amount of dead and decaying vegetation in these stands that could provide fuel for a wildfire. 

The BLM also proposes to remove pinyon-juniper trees near aspen stands to create or enhance fire and fuel breaks to 

control wildfire spread. Prescribed fire could be used in aspen stands for pile burning. 

Use of existing permanent fencing or small, temporary exclosure fencing would benefit areas with aspen sprouts that 

are heavily grazed. This should benefit aspen, as past studies have shown that aspen stands that are protected from 

herbivory successfully regenerate and form multi-aged stands without fire or other disturbance. It is believed that 

ungulate herbivory is the main reason that aspen has declined in central Nevada and on the 3 Bars Project area (Kay 

2001, 2002, 2003), although Jones (2010) found that livestock herbivory on aspen could be reduced by using early 

season grazing and providing mineral supplements in areas with aspens. The BLM typically protects treated stands 

until the stand density is 1,500 stems per acre and sapling reach at least 7 feet in height. Typically, objectives are met 

in 3 to 5 years as a result of exclusion. 

Pinyon-juniper Treatments 

Approximately 938 acres of riparian treatments and 53 acres of aspen treatments could occur within a larger pinyonjuniper treatment project boundary, and could be affected by treatment actions within the larger area. These include 

about 535 acres (Roberts Creek Unit) associated with Upper Roberts Creek Unit, 235 acres (Roberts Creek Unit) 

associated with the Atlas Unit, and 118 acres (Frazier Creek, Upper Henderson, RM-A7, and RM-A9 units) 

associated with the Frazier and Vinini Corridor units. Pinyon-juniper treatments could also occur near riparian 

habitats that have not been targeted for improvements under riparian enhancement projects. 

Adverse Effects 

Widespread removal of pinyon-juniper stands could result in substantial ground disturbance, which, if a large 

precipitation event occurs before mulch is applied, could generate erosion and sedimentation that could affects 

wetland, floodplain, and riparian habitats. Where mulching and shredding are used as mechanical treatment, the 

material left on the site would cover bare, exposed soil to help encourage infiltration, capture sediment, and reduce 

runoff. 

Beneficial Effects 

It is expected that over the long-term, restoration of historic vegetation communities would benefit wetlands, 

floodplains, and riparian zones and lead to increased biodiversity in these areas. As discussed under Riparian 

Treatments, thinning and removal of pinyon-juniper and re-establishment of low-growing herbaceous and shrub 

cover, especially in Phase II and III stands, should reduce surface runoff and increase water infiltration. This would 

help to reduce peak flows, and associated channel incision and streambank instability, and increase base flows, which 

would provide water to streams for longer periods of time and better water quality, to the benefit of riparian and 

aquatic vegetation. 

3 Bars Project Final EIS 3-139 October 2016
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

Thinning pinyon-juniper to improve sagebrush habitat and creating fuel breaks would encourage riparian growth and 

reduce the risk of wildfire in riparian zones within the Atlas, Frazier, Upper Roberts Creek, and Vinini units. 

Additionally, pinyon-juniper treatments, including thinning, removal of dead and diseased vegetation, and creation of

fire and fuel breaks, would reduce the risk of catastrophic wildfire. Catastrophic wildfire could burn through large 

sections of riparian and wetland communities, killing vegetation and minimizing the functions of these areas, 

including water retention and streambank stability, which in turn could affect wetlands and riparian zones within the 

burn area. 

Sagebrush Treatments 

Approximately 522 acres of riparian treatments could occur within the larger sagebrush treatment project boundaries, 

and could be affected by treatment actions within the larger area. These include approximately 363 acres associated 

with the Lower Henderson 1 and 3 units and 134 acres associated with the Lower Vinini Creek Unit, which are within 

the Table Mountain Unit. 

Sagebrush treatments could also occur near riparian habitats that have not been targeted for improvements under 

riparian enhancement projects. Only a few areas of perennial streams and seeps/springs are found within proposed 

sagebrush treatment areas. The Rocky Hills Unit includes two springs that are targeted for treatment under riparian 

enhancement projects. The West Simpson Park Unit includes seven seeps/springs and a small stretch of perennial 

stream. The Three Corners Unit includes seven seeps/springs. The Table Mountain Unit includes two large stretches 

of Henderson Creek, which are also targeted for treatment under riparian enhancement projects. The Roberts 

Mountain Pasture Unit includes one spring that is targeted for treatment under the Mud Spring Unit riparian 

enhancement project. No perennial streams (indicating riparian zones) or springs/seeps have been mapped in any of 

the remaining proposed sagebrush project areas. Therefore, sagebrush treatments in the Alpha, Coils Creek, Kobeh 

East, Nichols, South Simpson, and Whistler Sage units should not impact wetlands and riparian zones, although it is 

possible that unmapped wetlands, seeps, or springs occur in these areas. 

Adverse Effects 

In the sagebrush treatment areas that include riparian zones and wetlands, adverse effects from the various treatment 

methods could potentially occur. Prescribed fire could be used on hundreds of acres annually to control non-native 

vegetation, including cheatgrass, the West Simpson Park Unit. Prescribed fire over large acreages could result in loss 

of organic material on a site, exposing mineral soil, and sometimes forming hydrophobic soil layers that would slow 

water infiltration. About half of the acreage on the West Simpson Park Unit is moderately to highly susceptible to fire 

damage, however, the likelihood of a prescribed fire removing substantial amounts of organic material and causing 

formation of a hydrophobic layer is low in areas dominated by cheatgrass because of the limited amount of vegetation 

on the site. 

Affected areas would primarily occur in units, where livestock could be used to remove cheatgrass and other nonnative vegetation. Direct effects could include alteration of stream channel/wetland morphology and loss of native 

wetland or riparian vegetation. The action of animal hooves would cause some disturbance, shearing, and compaction 

of soil, increasing its susceptibility to both water and wind erosion. Severe compaction often reduces the availability 

of water and air to the roots and plant vitality. Biomass, vigor of native plants, and species diversity could all be 

reduced. The degree of effect would be dependent on the timing, duration, and intensity of grazing. 

3 Bars Project Final EIS 3-140 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Beneficial Effects 

Successful control of noxious weeds and other invasive non-native plants in wetlands and riparian zones associated 

with sagebrush treatments would lead to improved conditions in these habitats over the long-term. Treatments that 

promote the development of understory vegetation, and plantings on or near riparian management areas, would 

improve riparian habitat and water quality and nearby upland habitat. 

Most of the riparian management acreage associated with sagebrush habitat is found on the Table Mountain Unit. 

Treatments in this unit would focus on removal of encroaching pinyon-juniper. Improvement in understory vegetation 

cover would reduce the risk of erosion and sedimentation in nearby streams, while removal of pinyon-juniper could 

improve water flows and availability in streams. Sites with a large component of noxious weeds and other invasive 

non-native plants may be at a higher risk for erosion than sites that support native vegetation. 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 the risk of 

catastrophic fire. 

3.11.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

About half as many acres would be treated under Alternative B as under Alternative A, primarily due to the higher 

costs associated with manual and mechanical treatments. Nearly all wetland, riparian, and aspen habitat and stream 

channel restoration could be done using manual and mechanical methods. Thus, acreage and miles of wetland, 

riparian, aspen, and stream channel restoration work done under Alternative B would be similar to that done under 

Alternative A. Under this alternative, the BLM would likely be able to restore a similar amount of Non-functioning 

and Functioning-at-risk wetlands and riparian zones to Proper Functioning Condition as under Alternative A. 

Without use of prescribed fire and wildland fire for resource benefit, the effectiveness of some treatments could be 

reduced, but for many treatments there would be no differences in the outcome between alternatives. Fire treatments 

could lead to a short-term increase in erosion and stream sedimentation, and the spread of noxious weeds and other 

invasive non-native vegetation. These risks would not occur under this alternative, but the inability to use fire could 

reduce the effectiveness of pinyon-juniper removal in some areas. The inability to use fire may result in less 

improvement in water flows in streams due to fewer acres of pinyon-juniper removal, fewer long-term benefits to 

wetlands and riparian zones from development of more fire resilient vegetation after use of prescribed fire, and greater 

risk of catastrophic wildfire, under Alternative B than under Alternative A. The BLM would be less likely to reduce 

hazardous fuels and burn piles of slash, which would increase the risk of catastrophic wildfire under this alternative 

compared to Alternative A. The BLM would also have less success under Alternative B than Alternative A in slowing 

pinyon-juniper encroachment into riparian and other habitats, slowing the spread of noxious weeds and other invasive 

non-native vegetation, restoring fire as an integral part of the ecosystem, developing fire and fuel breaks, and reducing 

the risk of catastrophic wildfire. 

3.11.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would treat about a fourth as much acreage as would be treated under Alternative A. 

As a result, effects to wetlands and riparian zones from treatments would be much lower than under Alternatives A 

and B. By not being able to use mechanical treatments, there would be no risk of sedimentation into streams and 

wetlands from erosion caused by mechanical treatments. 

3 Bars Project Final EIS 3-141 October 2016
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

Wetland and riparian restoration treatments would largely consist of hand installation of fencing, hand replanting, and 

removal of pinyon-juniper with chainsaws. The BLM would be unable to use mechanical methods to address 

headcuts and stream incision through grade stabilization structures and streambank bioengineering. It would also be 

more difficult for the BLM to transport and place logs and woody debris from felled pinyon-juniper into streams, 

remove slash that could pose a fire risk, restore fire as an integral part of the ecosystem, develop fire and fuel breaks, 

and reduce the risk of catastrophic wildfire. 

While an improvement in wetland and riparian function would be expected across all treated areas, the level of 

improvement would likely be less than under Alternatives A and B, and it is possible that some areas would not be 

restored to Proper Functioning Condition with only manual methods. Benefits associated with improvements to 

upland community types would be less than under Alternatives A and B, since a much smaller portion of the project 

area would be treated, and the reduction in wildfire risk would also likely be lower. 

3.11.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to wetlands, floodplains, or riparian zones as no treatments would be authorized 

under this alternative. The BLM would not conduct stream bioengineering treatments; create fire and fuel breaks; thin 

and remove pinyon-juniper to promote healthy, diverse stands; treat large-scale infestations of noxious weeds and 

other invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the ecosystem; or reduce 

the risk of a large-scale wildfire. The processes that create knickpoints, headcuts, and unstable streambanks would 

remain active, there would be few benefits to deep-rooted vegetation near streams, and there would be little 

improvement in stream flows. Thus, the health of wetlands, floodplains, and riparian zones would continue to 

deteriorate and few improvements would be seen in water quality and quantity in these areas. Because degraded 

channel morphology is a primary factor causing stream habitats to not function properly, Non-functioning and 

Functioning-at-risk wetlands and riparian zones would persist in the 3 Bars Project area. 

3.11.3.4 Cumulative Effects 

The CESA for wetland, floodplain, and riparian zone resources is approximately 1,841,698 acres and includes those 

watersheds at the Hydrologic Unit Code 10 level that are all or partially within the 3 Bars Project area (Figure 3-1). 

Approximately 92 percent of the area is administered by the BLM, 6 percent is privately owned, and 2 percent is 

administered by the Forest Service. There are approximately 77,629 acres of wetlands (2,363 acres on the 3 Bars 

Project area and 75,266 acres on other portions of the CESA; most of the non-3 Bars wetland acreage is associated 

with a large playa that is usually dry but has soils typical of wetlands), 5,271 miles of perennial and 

intermittent/ephemeral streams (2,433 miles within the 3 Bars Project area, 2,728 miles within other portions of the 

CESA), and 1,116 springs and seeps (334 within the3 Bars Project area, 782 within other portions of the CESA) 

within the CESA. Past and present actions that have influenced wetland, floodplain, and riparian zone activity in the 3 

Bars ecosystem are discussed in Section 3.3.2.3.3. 

3.11.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Past land uses in the CESA have resulted in the degradation of wetlands, riparian zones, and floodplains and reduced 

their functions. In particular, the BLM has indicated that roads, historic grazing regimes, and pinyon-juniper 

encroachment have negatively affected riparian and wetland functions and values, water quantity and timing, and 

water quality (USDOI BLM 2009a). 

3 Bars Project Final EIS 3-142 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

The BLM would continue ongoing management reviews to ensure proper livestock management and the long-term 

success of the proposed treatments. 

Proposed 3 Bars Project treatments would help to reduce land disturbance and restore degraded habitats, and 

discourage establishment and expansion of noxious weeds and other invasive non-native vegetation, especially on 

riparian and aspen habitats. The BLM also proposes to install small scale, temporary exclosure fencing to limit 

livestock, wild horse, and other wild ungulate access to treatment areas, although water gaps would be incorporated 

into fencing along streams to allow these animals to access water. These actions should help to improve water quality 

in affected streams, restore streams to Proper Functioning Condition, and improve riparian habitat. The measures that 

the BLM would take to minimize livestock and wild horse impacts to treatment areas are discussed in more detail in 

Section 3.18.4 (Livestock Grazing Mitigation), and in Appendix C. 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and aerial-based application methods to remove cheatgrass, and would restore burned areas 

under the Burned Area Emergency Stabilization and Rehabilitation program, under existing authorizations on about 

1,000 acres annually. These treatments should not have a direct effect on wetlands, floodplains, and riparian zones 

unless they cause erosion, or there is an accidental spill of an herbicide into a water body. These treatments would 

help to reduce hazardous fuels, slow the spread of noxious weeds and other invasive non-native vegetation, and 

reduce surface runoff and erosion associated with burn sites, potentially to the benefit of wetlands, floodplains, and 

riparian zones. Herbicides could be transported in runoff to water bodies and effect wetland, floodplain, and riparian 

vegetation, but the BLM would use buffers between water bodies and treatment areas and/or carefully select the 

timing of applications and types of herbicide to minimize or avoid these risks. 

Land development, mineral development, and oil, gas, and hydrothermal exploration and development could affect 

about 15,500 acres in the reasonably foreseeable future, including about 8,335 acres of disturbance associated with the 

Mount Hope Project. These projects could disturb wetlands, riparian zones, and floodplains on a small portion of this 

land through soil disturbance, water diversion, pumping of groundwater, filling, and removal of vegetation. 

As discussed in the Mount Hope Project EIS under Wetland and Riparian Zones (USDOI BLM 2012b: Section 3-11), 

and in this EIS under Water Resources (Section 3.10), there is concern that pumping of water for future livestock and 

domestic uses, mining, and agriculture 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. 

Catastrophic wildfire can affect wetlands by causing extensive burns, which may potentially include wetland and 

riparian vegetation, particularly during drought conditions when soils and vegetation are dry. About 140,000 acres 

could burn within the CESA over the next 20 years, based on acreage burned since 1985. While large fire events have 

been sporadic within the CESA since 1985, on average 6,900 acres have burned annually. The wide-scale removal of 

riparian and wetland vegetation by fire would be expected to return affected areas to early-successional conditions, 

and could reduce structural diversity of wetland and riparian habitats. Wide-scale removal of vegetation would also 

result in increased sedimentation into wetlands and riparian zones. 

Hazardous fuels reduction, habitat improvement, and noxious weeds and other invasive non-native vegetation 

management projects on the 3 Bars Project and other areas within the CESA would occur on approximately 142,000

acres (127,000 for the 3 Bars Project and on 15,000 acres for other hazardous fuels projects in the CESA), or about 8 

3 Bars Project Final EIS 3-143 October 2016
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

percent of the CESA. These treatments would lead to short-term increases in soil erosion and surface water runoff, but 

long-term benefits to water quality and possibly water flows. Pinyon-juniper removal within riparian zones could lead 

to increased water flows, and allow native vegetation to re-establish along streambanks. Long-term, 3 Bars Project 

actions should make a substantial contribution toward improving wetland, floodplain, and riparian zone conditions 

within the CESA and help to offset adverse effects to these resources from other reasonably foreseeable future actions 

under Alternative A. 

3.11.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, 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. However, by not using fire on the 3 Bars 

Project area, there would be no effects to wetland and stream water quantity and quality from fire on several thousand 

acres annually within the CESA. 

The BLM would be limited to manual and mechanical methods such as use of chainsaws and discing and plowing, 

and using livestock to control noxious weeds and other invasive non-native vegetation on several hundred acres 

annually within the CESA. These methods could result in more soil disturbance and erosion and inherent water 

quality issues than would the use of fire. The West Simpson Park Unit is on rugged terrain, and use of mechanical 

equipment to control cheatgrass would be difficult and erosion potential from treatments would be great. 

The BLM would conduct hazardous fuels reduction and habitat improvement projects using manual and mechanical 

methods on about 63,000 acres within the 3 Bars Project area, and on about 15,000 acres in other portions of the 

CESA, or about 4 percent of acreage within the CESA. Wetland, stream and floodplain habitat should improve within 

the 3 Bars Project area and within the CESA, although not to the extent as would occur under Alternative A. 

3.11.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

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. 

3.11.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, 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. There would be no cumulative impacts to 

wetlands, floodplains, or riparian zones as no treatments would be authorized under this alternative. The BLM could 

conduct stream bioengineering treatments; create fire and fuel breaks; thin and remove pinyon-juniper to promote 

3 Bars Project Final EIS 3-144 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

healthy, diverse stands; slow the spread of noxious weeds and other invasive non-native vegetation, especially 

cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildland fire under 

existing and future authorizations, but only on about 1,500 acres annually under current and reasonably foreseeable 

future authorizations. Given the low acreage of habitat treated annually, and because factors causing streams and 

wetlands to not function properly would remain, including soil erosion, stream channel instability, spread of noxious 

weeds and other invasive non-native vegetation, pinyon-juniper encroachment, and wildfire, improvement to wetland, 

floodplain, and riparian functions within the CESA would be least under this alternative. 

3.11.3.5 Unavoidable Adverse Effects 

An increase in soil erosion and surface water runoff could result from vegetation removal, and could lead to channel 

erosion and sedimentation in wetlands, floodplains, and riparian zones (Ott 2000). The rate of runoff would be 

influenced by the precipitation rate, soil type, and proximity to the treated area. All vegetation removal activities 

could disturb the soil and reduce the amount of vegetation binding to the soil, potentially causing erosion and 

increased sedimentation to wetlands, floodplains, and riparian zones, although the use of mulching could minimize 

these effects. 

The removal of vegetation would decrease the amount of rainfall captured by plants, detritus, and soil, potentially 

leading to increased stormwater flows and runoff velocity in wetland and riparian zones. Increased stormwater runoff 

can scour streams, modify their morphology, and affect the distribution and abundance of aquatic organisms within 

the area. Siltation of wetlands could reduce water quality and the amount of oxygen available to aquatic organisms. In 

addition, siltation could reduce the acreage of wetland and riparian habitat (USDOI BLM 2007c:4-243). 

3.11.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

Removal of vegetation could cause a short-term increase in soil erosion and surface water runoff, which could impact 

wetlands, floodplains, and riparian zones. Successful control of noxious weeds and other invasive non-native plants in 

these areas, however, would lead to improved conditions in these habitats over the long-term. The eventual growth of 

desirable vegetation in treated areas would moderate water temperatures, buffer the input of sediment from runoff, 

and promote channel stability in riparian zones. Project activities would also enhance the acreage of streamside 

wetlands by reconnecting streams to their floodplains. Ongoing efforts by the BLM to restore wetlands, floodplains, 

and riparian zones would enhance the function of treated areas in the project area, and would help increase the miles 

of streams and acres of wetlands that would be classified by the BLM as Proper Functioning. Improvement of 

riparian, floodplain, and wetland habitat would also benefit Lahontan cutthroat trout and other species of concern, 

such as Greater sage-grouse, which depend on these habitats for their survival. 

3.11.3.7 Irreversible and Irretrievable Commitment of Resources 

There would be no irreversible or irretrievable commitment of wetland, floodplain, or riparian resources. Although 

there would be short-term impacts to these resources from the proposed project treatments, these impacts would not 

be irretrievable and would be reversed if restoration treatments were successful (USDOI BLM 2007c:4-251). 

3 Bars Project Final EIS 3-145 October 2016
WETLANDS, FLOODPLAINS, AND RIPARIAN ZONES 

3.11.3.8 Significance of the Effects under the Alternatives 

Based on the significance criteria presented in Section 3.11.3.2, it is not expected that direct, indirect, or cumulative 

effects from the 3 Bars Project would result in a significant adverse cumulative effect to wetlands, floodplains, or 

riparian zones under any of the alternatives. 

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), the BLM would 

maintain vegetated buffers between the treatment area and wetlands. If noxious weeds or other invasive non-native 

vegetation were removed from wetlands, the affected area would be replanted or reseeded to encourage recovery of 

native species. Some degree of wetland degradation would be possible as a result of land development, and 

sedimentation, reduced vegetative cover, and physical disturbance associated with hazardous fuels and habitat 

restoration treatments within the CESA. However, these effects would be short-term in duration, and wetlands would 

eventually recover to their original or an improved condition. 

Removal of vegetation within floodplains could minimize the flood attenuation functions of floodplains, as there may 

be increased overland flow to streams and increased risk of flooding. However, these effects would only last until the 

treatment sites recover, or are restored through reseeding or replanting. Maintaining vegetated buffers between 

treatment areas and water bodies would help to preserve some flood attenuation functions of floodplains. 

The majority of stream restoration treatments would be done in streams with little to no stream-floodplain 

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. 

None of the actions under the alternatives would result in a long-term reduction in the functions of wetlands or 

riparian zones, a long-term reduction in the acreage of riparian and wetland areas in Proper Functioning Condition, or 

a downgrading of Functional-at-risk riparian or wetland areas to a negative trend or Nonfunctional. Removal of 

vegetation in these areas, or nearby upland areas, could temporarily reduce certain functions, including the ability to 

dissipate overland flow, improve floodwater retention and groundwater recharge, stabilize streambanks against 

cutting actions, and provide habitat for a diversity of wildlife. All of these functions factor into the Proper Functioning 

Condition of a wetland or riparian zone. These adverse effects would be short-term, and over the long-term, the 

affected areas would return to their original or improved functioning condition. 

3.11.4 Mitigation 

Wetlands, floodplains, and riparian zones would benefit from mitigation identified in Section 3.18.4 (Livestock 

Grazing Mitigation). No mitigation or monitoring measures are recommended specifically for wetlands, floodplains, 

and riparian zones. 

3 Bars Project Final EIS 3-146 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.12 Native and Non-invasive Vegetation Resources 

3.12.1 Regulatory Framework 

3.12.1.1 Special Status Species 

The Endangered Species Act of 1973 provides for conserving federally listed endangered and threatened plant 

species, and plant species proposed for federal listing. The Act also requires that federal agencies consult with the 

USFWS to ensure that any actions they authorize, fund, or carry out are not likely to jeopardize the continued survival 

of a listed species or result in the adverse modification or destruction of its critical habitat. Critical habitat is a specific 

area or type of area that is considered to be essential for the survival of a species, as designated by the USFWS under 

the Act.

In addition to administering conservation programs for listed species and species proposed for listing under the Act, 

the BLM also administers programs for sensitive species under guidance from Manual 6840, Special Status Species 

Management (USDOI BLM 2008h). BLM Special Status Species are federal candidate species for listing as 

threatened or endangered under the provisions of the Act, and those designated by the Director or individual State 

Directors as BLM sensitive. Conservation of BLM sensitive species means the use of programs, plans, and 

management practices to minimize or eliminate threats affecting the overall condition of the species, and/or improve 

the condition of the species’ habitat.

3.12.1.2 Federal Laws 

Federal laws pertaining to noxious weeds and other invasive non-native vegetation include the Lacey Act as amended 

(18 USC § 42), the Carson-Foley Act of 1968 (Public Law 90-583), the Federal Noxious Weed Act of 1974, as 

amended by the Food, Agriculture, Conservation, and Trade Act of 1990 (Section 1453, “Management of Undesirable 

Plants on Federal Lands,” USC §2801 et seq.), the Federal Plant Pest Act (7 USC § 150aa et seq.), and the Plant 

Protection Act of 2000 (7 USC § 7701 et seq.), as amended by the Noxious Weed Control and Eradication Act of 

2004 (Public Law 108-412). 

3.12.1.3 BLM Guidance and Regulations 

BLM Handbook H-1740, Integrated Vegetation Management (USDOI BLM 2008b) provides guidance on the 

management of vegetation on public lands and discusses the use of treatment methods for ensuring management 

success. 

3.12.1.4 Resource Advisory Council Guidance 

The BLM Nevada Northeastern Great Basin Resource Advisory Council, as chartered by the USDOI to promote 

healthy rangelands, has developed Standards and Guidelines for grazing administration on about 16.2 million acres of 

public lands in Nevada. Included in the Standards and Guidelines are guidelines for vegetation management. These 

include guidelines to control noxious weeds and other invasive non-native vegetation, including cheatgrass; limit 

grazing in salt desert plant communities to very early season or dormant season; create and maintain a diversity of 

sagebrush age and cover classes; maintain healthy stands of pinyon-juniper and ensure a combination of stand stages; 

and use native vegetation to reclaim sites (USDOI §2007b).

3 Bars Project Final EIS 3-147 October 2016
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.1.5 Woodlands 

The Federal Land Policy and Management Act of 1976 and BLM Manual 5000-1, Forest Management Public 

Domain (USDOI BLM 1991b), include requirements for planning and implementing forestry and woodland projects. 

Additionally, 43 CFR §5400 regulates the sale of forest products harvested from public lands. 

3.12.1.6 Prime Farmlands 

Prime farmland, as defined by 7 CFR § 657.5 “is land that has the best combination of physical and chemical 

characteristics for producing food, feed, forage, fiber, and oilseed crops and that is available for these uses. It has the 

combination of soil properties, growing season, and moisture supply needed to produce sustained high yields of crops 

in an economic manner if it is treated and managed according to acceptable farming methods. In general, prime 

farmland has an adequate and dependable water supply from precipitation or irrigation, a favorable temperature and 

growing season, an acceptable level of acidity or alkalinity, an acceptable content of salt or sodium, and few or no 

rocks. Its soils are permeable to water and air. Prime farmland is not excessively eroded or saturated with water for 

long periods of time, and it either does not flood frequently during the growing season or is protected from flooding” 

(USDA Natural Resources Conservation Service 2000). 

3.12.2 Affected Environment 

3.12.2.1 Study Methods and Analysis Area 

Several sources were reviewed in the preparation of this section, including USGS topographic and USFWS National 

Wetland Inventory maps; aerial photographs; USDA Natural Resources Conservation Service (2012) soil survey for 

Eureka County; documents prepared for nearby projects, including the Falcon to Gonder EIS (EDAW 2001), AECC 

(USDOI BLM 2009a), and Mount Hope Project EIS and references cited therein (USDOI BLM 2012b); BLM Special 

Status Species list and Nevada Heritage Program Special Status Plant Species database; range allotment studies 

conducted by the BLM; discussions with BLM resource specialists; Geographic Information System shapefiles 

provided by BLM resource specialists for spring inventories and riparian monitoring; site-specific studies conducted 

on the 3 Bars Project area; and site visits. 

In 2010 and 2011, two studies were conducted to obtain additional information on rangeland and woodland health on 

the 3 Bars ecosystem. Based on these studies, two reports were prepared: 1) a 3 Bars Ecosystem and Landscape 

Restoration Project Pinyon-juniper Assessment that provided the results from an assessment of pinyon-juniper stands 

within the 3 Bars ecosystem (AECOM 2011a); and 2) a Landscape Restoration Project Rangeland Health Report that 

provided the results of a 2010 to 2011 evaluation of rangeland health on approximately 532,000 acres within the 3 

Bars ecosystem (Eastern Nevada Landscape Coalition and AECOM 2012). In addition, the BLM has conducted 

rangeland health studies on much of the remaining portions of the 3 Bars Project area that were not evaluated during 

2010 and 2011 studies.

The soil surveys for Eureka, Lander, and White Pine Counties (USDA Natural Resources Conservation Service 

2012), vegetation mapping done by the BLM, and vegetation surveys done for this project by the Mount Lewis Field 

Office and its consultants (AECOM 2011a, b, Eastern Nevada Landscape Coalition and AECOM 2012), were used to 

describe the vegetation on the 3 Bars Project area. Grassland included wildfire burn areas in the northern Simpson 

Park Mountains (1999 Trail Canyon Fire Area) and the 2012 Frazier Fire wildfire, and historic crested wheatgrass 

3 Bars Project Final EIS 3-148 October 2016
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

seedings. The pinyon-juniper vegetation type was based on those areas having Phase II and III pinyon-juniper stands 

(see Section 3.12.2.2.8 for a discussion of pinyon-juniper phases). 

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 BLM Special Status Species list was reviewed to determine which special status plant species could occur in the 

project area. In addition, Geographic Information System shapefiles of previously documented special-status plant 

occurrences were obtained from the Nevada Natural Heritage Program. The Nevada Natural Heritage Program 

maintains a database on the general location and status of Nevada’s sensitive plants, animals, and natural biological 

communities. The Nevada Native Plant Society list of plant species of concern was also reviewed. The Nevada Native 

Plant Society is a non-profit organization that functions in an advisory capacity to state and federal agencies regarding 

Nevada native plants and their distributions. The Nevada Native Plant Society has created six categorical designations 

of plants to identify their respective concern for these species. These designations do not afford legal status or 

protection for the species, but the lists produced by Nevada Native Plant Society are utilized by agencies in their 

planning processes for activities that may impact the species or habitat. 

Surveys conducted in support of the Mount Hope Project EIS were reviewed for information on special status plant 

species. Focused surveys for special status plant species were conducted on the majority of the Mount Hope Project 

area by SRK during June, 2005, and during the bloom period in 2006 (SRK 2007a). These surveys targeted Beatley 

buckwheat, an imperiled species, least phacelia, a BLM sensitive species, and windloving buckwheat, a BLM Special 

Status Species. In addition, spring areas with potential habitat for least phacelia in the project area were visited 

quarterly during water sampling activities (SRK 2007a). Field surveys were conducted in the well field, powerline, 

and transmission line areas in mid-July and August 2007 (SRK 2007b). A special status plant survey in the Kobeh 

Valley portion of the project area was conducted in July 2008 (Great Basin Ecology 2008 cited in USDOI BLM 

2012b), and the USFWS (USDOI USFWS1993) has conducted surveys for Monte Neva paintbrush, a state critically 

endangered species, on portions of the 3 Bars Project area. 

The study area for direct, indirect, and cumulative impacts to native and non-invasive vegetation, including 

woodlands, is the 3 Bars Project area. The CESA for cumulative impacts to native and non-invasive vegetation 

includes the Hydrologic Unit Code 10 watersheds wholly, or partially within, the project area (Figure 3-1). 

3 Bars Project Final EIS 3-149 October 2016
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.2.2 Vegetation Communities 

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 3-25, Table 3-22). Information on noxious weeds and other invasive and nonnative vegetation, including cheatgrass, is provided in Section 3.13. 

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 3-26 and Table 3-22

show the location and extent of major expected vegetation communities, based on ecological site description, in the 

project area. 

Each of the major vegetation communities shown in Figures 3-25 and 3-26 is briefly described below, followed by a 

discussion of the ecological health of these communities in the project area, as determined by rangeland health 

assessments conducted by Eastern Nevada Landscape Coalition and AECOM (2012), pinyon-juniper mapping 

(AECOM 2011a), and discussions with BLM resource specialists. 

TABLE 3-22

Current and Expected Vegetation Types within the 3 Bars Project Area 

3 Bars Project Final EIS 3-150 October 2016

Vegetation Community

Actual1 Expected2 Difference between Actual 

Acres Percent Acres Percent and Expected Vegetation

Big Sagebrush 345,372 46.1 354,082 47.2 -8,709

Greasewood 31,642 4.2 32,392 4.3 -750

Low Sagebrush 23,228 3.1 28,914 3.9 -5,686

Black Sagebrush 62,109 8.2 77,148 10.3 -15,039

Mountain Mahogany 4,275 0.6 13,730 1.8 -9,455

Grassland3 52,146 7.0 4,433 0.6 47,713

Pinyon-juniper4 190,357 25.4 209,176 27.9 -18,819

Pits, Playas, and Water 378 0.1 384 0.1 -6

Salt Desert Scrub 28,061 3.7 29,552 3.9 -1,491

Non-native Vegetation 12,242 1.6 0 0.0 12,242

Total 749,810 100.0 749,810 100.0 0

1 Actual acres are derived by what vegetation was present when vegetation surveys were completed. 

2 Expected acres are derived from ESDs. 

3

 Grassland is defined as those areas comprised of native, fire-induced, and man-made grass cover. 

4

 Pinyon-juniper vegetation type is based on those areas having Phase II and III pinyon-juniper stands (see Section 3.12.2.2.8 

for a discussion of pinyon-juniper phases). 

Sources: AECOM (2011a, b), USDA Natural Resources Conservation Service (2012).
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-25

Current Vegetation Communities

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Vegetation Community

Big Sagebrushd

Black Sagebrushd

Low Sagebrushd

Greasewoodd

Invasive Speciesa,c

Mountain Mahoganyd

*Grasslanda,b,d

+Pinyon-juniperc

Salt Desert Scrubd

Pits, Playas, or Waterd

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: aUSGS 2004; bBLM 2012g;cAECOM 2011a,b; dUSDA NRCS 2012.

*Grassland is comprised of native, fire induced, and man-made grass cover. +

Pinyon-juniper represents phase 2/3 successional stages only.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-26

Major Vegetation Communities in

the 3 Bars Project Area based

on Ecological Site Data

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Vegetation Community

Big Sagebrush

Black Sagebrush

Low Sagebrush

Greasewood

Mountain Mahogany

Native Grassland

Pinyon-juniper

Salt Desert Scrub

Pits, Playas, or Water

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.12.2.2.1 Grassland 

Grasslands occur throughout the Great Basin on dry plains and mesas. On the 3 Bars Project area, this community 

occurs between 5,500 and 6,200 feet amsl. These grasslands occur in lowland and upland areas, and may occupy 

swales, playas, mesa tops, plateaus, alluvial flats, and plains, but sites are typically dry. According to the USDA 

Natural Resources Conservation Service (2012) ecological site data, native grassland dominated by alkali sacaton is 

expected to cover about 4,433 acres, or 0.6 percent of the 3 Bars Project area. Other associated species may include 

alkali cordgrass, Indian ricegrass, three-awn grasses, blue grama grass, needle-and-thread, and Muhly grass. The 

community may also include scattered shrubs and dwarf-shrubs sagebrush, saltbush, blackbrush, species of joint fir or 

Mormon tea, snakeweed, and winterfat. 

The grassland community is comprised of three ecological sites. Characteristics of these sites are shown in Table 3-

23. Semi-desert native grassland typically occurs on well-drained sandy or loamy-textured soils derived from 

sedimentary parent materials, but soil types are quite variable and may include fine-textured soils derived from 

igneous and metamorphic rocks. 

Grassland in the project area suffers from a lack of diversity, and some areas have been taken over by cheatgrass. 

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. 

3.12.2.2.2 Big Sagebrush 

The big sagebrush vegetation type is present on alluvial fans, hillsides, and ephemeral drainages. This vegetation type 

occurs at elevations between 5,500 and 10,000 feet amsl on the 3 Bars Project area. Approximately 407,481 acres, or 

54.3 percent, of big sagebrush is found on the project area. According to the ecological site description, big sagebrush 

communities should cover about 354,082 acres, or 47.2 percent of the 3 Bars Project area. The dominant overstory 

vegetation, depending on the location, is either basin big sagebrush, Wyoming big sagebrush, or mountain big 

sagebrush. Understory species commonly associated with big sagebrush communities includes basin wildrye, 

Thurber’s needlegrass, greenstem paperflower, bluebunch wheatgrass, mountain brome, Letterman’s needlegrass, 

Indian ricegrass, and needle-and-thread (USDA Natural Resources Conservation Service 2012). Other species may 

include bottlebrush squirreltail, rabbitbrush, Sandberg bluegrass, lupine, rabbitbrush, winterfat, and antelope 

bitterbrush. 

The Wyoming big sagebrush type is a prevalent vegetation type in the project area, and generally dominates the lower 

to mid-elevation zones in Kobeh Valley. Based on the USDA Natural Resources Conservation Service (2012) soil 

surveys, the rangeland health assessment conducted in support of the project, other rangeland health data from the 

BLM, and ecological site descriptions for upland vegetation communities, big sagebrush communities in the 3 Bars 

Project area show low grass production. While some desirable forbs and grasses occur, they only amount to a low 

percentage of overall vegetation. The dominant shrub, Wyoming big sagebrush, is appropriate for the site, but 

production is often low (Eastern Nevada Landscape Coalition and AECOM 2012). For most ecological sites in this 

type, grass species have the potential to comprise over 50 percent of vegetative composition, with shrubs being at or 

below 50 percent of the total composition. On several sites, primary grasses, including bluebunch wheatgrass and 

needle-and-thread, are absent. 

3 Bars Project Final EIS 3-153 October 2016
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

The big sagebrush community is comprised of 11 ecological sites. Characteristics of these sites are shown in Table 3-

24. The decline in abundance and health of the sagebrush community is a major concern within the 3 Bars ecosystem. 

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. 

 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, although Bukowski and Baker 

(2013) suggest that historical sagebrush landscapes were dominated by large, contiguous areas of sagebrush, 

and that variation in sagebrush density was a common source of patchiness. 

 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 pinyonjuniper woodland.

3.12.2.2.3 Low Sagebrush 

The low sagebrush community is dominated by low sagebrush. Common understory species are bluebunch 

wheatgrass and Idaho fescue (USDA Natural Resources Conservation Service 2012). Other overstory species 

commonly found in this community include Nevada ephedra and rabbitbrush, while dominant understory species 

include squirreltail and cheatgrass. On the 3 Bars Project area, low sagebrush occurs on the alluvial fans, hillslopes, 

and bottom areas at lower to mid-elevations (6,000 to 8,800 feet amsl). The low sagebrush community covers about 

23,228 acres, or 3.1 percent of the project area. According to the ecological site description, low sagebrush 

communities should cover about 28,914 acres, or 3.9 percent of the 3 Bars project area. 

The low sagebrush community is comprised of three ecological sites. Characteristics of these sites are shown in Table 

3-25. Issues associated with health of the low sagebrush community are similar to those discussed above for big 

sagebrush, however low sagebrush is much less widespread in the project area. 

3.12.2.2.4 Black Sagebrush 

The black sagebrush community is dominated by black sagebrush. Common understory species are bluebunch 

wheatgrass, Indian ricegrass, and needle-and-thread. In the 3 Bars Project area, black sagebrush occurs on summits 

and slideslopes of lower piedmont slopes and low hills on all exposures, alluvial fans, hillsides, and bottom areas at 

low to mid-elevations (5,000 to 6,500 feet amsl). The black sagebrush community covers about 62,109 acres, or 8.2 

percent of the project area. According to the ecological site description, black sagebrush communities should cover 

about 77,148 acres, or 10.3 percent of the 3 Bars project area. 

The black sagebrush community is comprised of three ecological sites. Characteristics of these sites are shown in 

Table 3-26. Issues associated with health of the black sagebrush community include a lack of an understory of native 

3 Bars Project Final EIS 3-154 October 2016
Ec

C

Alkal

alkali

Sand

alkali

Tufted

Alkali

alkali 

TABLE 3-23

Ecological Sites for Grassland Community 

ological Site 

ommunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

i sacaton-

 cordgrass

berg bluegrass-

 sacaton

R024XY043NV Wet meadow 6 

to 8 inches

The plant community is dominated by 

alkali bluegrass, alkali sacaton, Baltic 

rush, and inland saltgrass. Potential 

vegetative composition is about 85

percent grasses and 15 percent forbs.

Where management results in abusive grazing use by 

livestock or horses, woody plants often increase, 

especially rabbitbrush species. Inland saltgrass and 

Baltic rush increase and may eventually dominate the

site. Foxtail barley, annual mustards, and other 

undesirable forbs and grasses are species likely to 

invade this site.

 hairgrass R025XY005NV Wet meadow The plant community is dominated by 

tufted hairgrass. Nevada bluegrass, 

alpine timothy, Sierra clover, and 

meadow sedges are important plants 

associated with this site.

Where management results in chronic, repetitive, 

multi-year improper grazing, tufted hairgrass 

composition is reduced with foxtail barley, rushes, 

sedges, and forbs such as wild iris, cinquefoil, and 

yarrow increasing on the site. Willows and roses 

often increase in the overstory. Redtop, Kentucky 

bluegrass, thistles, and quackgrass are species likely 

to invade this site. Where stream channels become 

entrenched, the water table is lowered and a more 

drought tolerant plant community occurs. Vegetation 

includes cattail, bulrush, spike rush, reedgrass, and 

water-loving sedge. 

 sacatoncordgrassR028BY002NV Saline meadow The plant community is dominated by 

alkali sacaton. Alkali cordgrass, alkali 

bluegrass, and sedges are important 

associated plant species. Potential 

vegetative composition is about 85

percent grasses and grass-likes, 10

percent forbs, and 5 percent shrubs.

As ecological condition declines, inland saltgrass 

and Baltic rush increase as alkali sacaton and alkali 

bluegrass decrease. Where severe stream 

entrenchment occurs, the potential for this site is lost 

due to change in soil moisture balance. Typically, 

this site is succeeded by the plant community 

characterized in the Saline Bottom (028BY004NV) 

site description following severe stream down 

cutting.

3 Bars Project Final EIS 3-155 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 
Ec

C

Wyom

sagebr

needle

Wyom

sagebr

wildry

TABLE 3-24

Ecological Sites for Big Sagebrush Community 

ological Site 

ommunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

ing big 

ush/Thurber’s 

grass

R024XY005NV Loamy 8 to 10 

inches

The plant community is dominated 

by Thurber’s needlegrass and 

Wyoming big sagebrush. Potential 

vegetative composition is about 55

percent grasses, 5 percent forbs, and 

40 percent shrubs.

Where management results in chronic, repetitive, 

multi-year improper grazing by livestock or horses, 

Thurber’s needlegrass composition declines and is 

replaced by bluegrasses and bottlebrush squirreltail 

as the dominant understory grasses. Cheatgrass and 

other annuals will often dominate the understory as 

Wyoming big sagebrush and Douglas’ rabbitbrush 

increase in the overstory with degraded ecological 

condition. Where site degradation has been fireinduced, broom snakeweed and rabbitbrush often 

dominate the site. Repeated burning of the plant 

community at intervals less than 10 to 15 years 

results in complete site dominance by annuals 

(primarily cheatgrass and tansy mustard) and the 

near total absence of woody plants, including 

sagebrush.

ing big 

ush/basin 

e

R024XY006NV Dry floodplain The plant community is dominated 

by basin wildrye. Basin big 

sagebrush and black greasewood are 

other important species associated 

with this site. Potential vegetative 

composition is about 70 percent

grasses, 5 percent forbs, and 25

percent shrubs.

Where management results in chronic, repetitive, 

multi-year improper grazing by livestock or horses, 

basin wildrye is replaced by woody plants. Rubber 

rabbitbrush, black greasewood, and basin big 

sagebrush increase as ecological condition declines. 

Russian thistle and cheatgrass are species likely to 

invade this site.

3 Bars Project Final EIS 3-156 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Ecol

Co

Big sage

bluebun

Thurber

Wyomi

sagebru

wheatgr

needlegr

Wyomi

sagebru

sagebru

ricegras

TABLE 3-24 (Cont.) 

Ecological Sites for Big Sagebrush Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

brush/ 

ch wheatgrass-

’s needlegrass

R025XY014NV Loamy 10 to 12 

inches

The plant community is dominated 

by bluebunch wheatgrass, Thurber’s

needlegrass, and big sagebrush.

Potential vegetative composition is 

about 65 percent grasses, 10 percent

forbs, and 25 percent shrubs.

Where management results in chronic, repetitive, 

multi-year improper grazing, big sagebrush and 

Douglas’ rabbitbrush become dominant with 

increases of bottlebrush squirreltail and Sandberg 

bluegrass in the understory. Cheatgrass and annual 

mustards are plants likely to invade this site.

ng big 

sh/bluebunch 

ass-Thurber’s 

ass

R025XY019NV Loamy 8 to 10 

inches

The plant community is dominated 

by Thurber’s needlegrass, bluebunch

wheatgrass, and Wyoming big

sagebrush. Potential vegetative 

composition is about 65 percent

grasses, 5 percent forbs, and 30

percent shrubs.

As ecological condition declines, big sagebrush 

and rabbitbrush become dominant with an increase 

of Sandberg’s bluegrass, bottlebrush squirreltail, 

phlox, and other and mat-forming forbs in the 

understory. Cheatgrass, halogeton, Russian thistle,

and annual mustards are species likely to invade 

this site. Utah juniper will invade this site where it

occurs adjacent to these woodland areas.

ng big 

sh-black 

sh/Indian 

s

R025XY025NV Chalky knoll The plant community is dominated 

by Indian ricegrass, Wyoming big

sagebrush, and black sagebrush.

Shrubs dominate the aspect of the 

site. Antelope bitterbrush, spiny 

hopsage, and bottlebrush squirreltail 

are other important species associated 

with this site. Potential vegetative 

composition is about 40 percent

grasses, 10 percent forbs, and 50

percent shrubs.

As ecological condition declines, rabbitbrush and 

littleleaf horsebrush increase in density while 

Indian ricegrass and other perennial grasses are 

reduced in the understory. Cheatgrass, annual 

mustards, Russian thistle, halogeton, and Utah 

juniper are species likely to invade this site.

3 Bars Project Final EIS 3-157 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 
Ecol

Co

Basin bi

basin wi

Big 

sagebru

needlegr

paperflo

TABLE 3-24 (Cont.) 

Ecological Sites for Big Sagebrush Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

g sagebrush/ 

ldrye

R028BY003NV Loamy bottom 

10 to 14 inches

The plant community is dominated 

by basin wildrye. Potential vegetative 

composition is about 85 percent

grasses, 5 percent forbs, and 10

percent shrubs.

As ecological condition declines, basin big 

sagebrush and rabbitbrush increase within the plant 

community as basin wildrye and Nevada bluegrass 

decrease. With continued site degradation, rubber 

rabbitbrush becomes the dominant plant. Species 

most likely to invade this site are cheatgrass, annual 

mustards, and thistle.

sh/Thurber’s 

ass-greenstem 

wer

R028BY007NV Loamy 10 to 12 

inches

The plant community is dominated 

by Thurber’s needlegrass, bluebunch

Wheatgrass, and big sagebrush.

Potential vegetative composition is

about 65 percent grasses, 10 percent

forbs, and 25 percent shrubs and 

trees.

Where management results in chronic, repetitive, 

multi-year improper grazing, big sagebrush, 

rabbitbrush, bottlebrush squirreltail, and Sandberg 

bluegrass increase, while Thurber’s needlegrass, 

bluebunch wheatgrass, and other desirable forage 

species decrease. Cheatgrass readily invades this 

site following disturbances. Singleleaf pinyon and 

Utah juniper invade this site where it occurs 

adjacent to pinyon-juniper woodlands. When 

pinyon-juniper occupy this site, they compete with 

other species for available light, moisture, and 

nutrients. If pinyon-juniper canopies are allowed to 

close, they can eliminate all understory vegetation.

3 Bars Project Final EIS 3-158 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
E

Wyo

sageb

ricegr

thread

Moun

sageb

wildr

Moun

sageb

brome

needl

TABLE 3-24 (Cont.) 

Ecological Sites for Big Sagebrush Community 

cological Site 

Community Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

ming big 

rush/Indian 

ass-needle-andR028BY010NV Loamy 8 to 10 

inches

The plant community is dominated 

by Wyoming big sagebrush, Indian 

ricegrass, and needle-and-thread.

Potential vegetative composition is 

about 50 percent grasses, 5 percent

forbs, and 45 percent shrubs and 

trees.

As ecological condition declines, Wyoming big 

sagebrush and Douglas’ rabbitbrush increase, while 

Indian ricegrass and needle-and-thread decrease. 

Various annual species are likely to invade this 

site. Utah juniper readily invades this site where it 

occurs adjacent to this woodland. When Utah 

juniper occupies this site it competes with other 

species for available light, moisture, and nutrients. 

If Utah juniper canopies are allowed to close, they 

can eliminate all understory vegetation.

tain big 

rush/basin 

ye

R028BY024NV Loamy bottom 

14+ inches

The plant community is dominated 

by basin wildrye. Potential vegetative 

composition is about 85 percent

grasses, 5 percent forbs, and 10 

percent shrubs.

As ecological condition declines, mountain big 

sagebrush and rabbitbrush increase within the plant 

community as basin wildrye, slender wheatgrass, 

and Nevada bluegrass decrease. With continued site 

degradation, rubber rabbitbrush may become the 

dominant plant. Species most likely to invade this 

site are cheatgrass, annual mustards, and thistle.

tain big 

rush/mountain 

-Letterman’s 

egrass

R028BY029NV Loamy 16+ 

inches

The plant community is dominated 

by mountain brome and Letterman’s

needlegrass. The visual aspect is

dominated by mountain big 

sagebrush in association with a 

variety of mountain browse shrubs.

As ecological condition declines, mountain big 

sagebrush and snowberry become dominant, while 

mountain brome and Letterman’s needlegrass 

decrease.

3 Bars Project Final EIS 3-159 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 
Ecol

Co

Mountai

sagebrus

wheatgra

TABLE 3-24 (Cont.) 

Ecological Sites for Big Sagebrush Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

n big 

h/bluebunch 

ss

R028BY030NV Loamy 12 to 16 

inches

The plant community is dominated 

by bluebunch wheatgrass and 

mountain big sagebrush. Potential 

vegetative composition is about 55

percent grasses, 10 percent forbs, and 

35 percent shrubs and trees.

As ecological condition declines, rabbitbrush and 

big sagebrush become more prevalent and may 

eventually dominate the site as condition further 

declines. Shallow-rooted bluegrasses, bottlebrush 

squirreltail, and arrowleaf balsamroot increase in 

the understory as condition deteriorates. Cheatgrass 

is the species likely to invade this site. Singleleaf 

pinyon and Utah juniper readily invade this site. In 

the absence of natural fire, pinyon-juniper will 

increase on this site and may eventually dominate 

the plant community.

3 Bars Project Final EIS 3-160 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Ecol

Co

Low sa

Idaho f

bluebu

wheatg

Low sa

greenst

paperfl

Thurbe

needle

Low sa

black s

bluebu

wheatg

TABLE 3-25

Ecological Sites for Low Sagebrush Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

gebrush/ 

escuench 

rass

R025XY017NV Claypan 12 to 

16 inches

The plant community is dominated 

by Idaho fescue, bluebunch 

wheatgrass, and low sagebrush. 

Potential vegetative composition is 

about 60 percent grasses, 15 percent

forbs, and 25 percent shrubs.

As ecological condition declines, dwarf sagebrush 

species and Douglas’ rabbitbrush become dominant with 

increases of bottlebrush squirreltail, Sandberg bluegrass, 

and mat forming forbs in the understory. Cheatgrass is 

the species most likely to invade this site.

gebrush/ 

em 

owerr’s 

grass

R028BY037NV Claypan 12 to 

14 inches

The plant community is dominated 

by bluebunch wheatgrass, Thurber’s 

or western needlegrass, and low

sagebrush. Potential vegetative 

composition is about 50 percent 

grasses, 10 percent forbs, and 40 

percent shrubs and trees.

As ecological condition declines, rabbitbrush and low 

sagebrush become dominant with increases of 

bottlebrush squirreltail and Sandberg bluegrass.

Singleleaf pinyon and Utah juniper invade this site 

where it occurs adjacent to these woodlands. When 

juniper and pinyon occupy this site, they compete with 

other species for available light, moisture and

nutrients. If pinyon-juniper canopies are allowed to 

close, they can eliminate all understory vegetation.

gebrushagebrush/

nch 

rass

R028BY038NV Mountain ridge 

14+ inches

The plant community is dominated 

by bluebunch wheatgrass, 

muttongrass, and low or black 

sagebrush. Black sagebrush is 

typically restricted to the ridge crest 

areas where soil depth is most 

limiting. Potential vegetative 

composition is about 45 percent

grasses, 10 percent forbs, and 45

percent shrubs.

As ecological condition declines, low sagebrush, black 

sagebrush, and Douglas’ rabbitbrush become dominant 

with increases of Sandberg bluegrass and phlox in the 

understory. Phlox, goldenweed, and other mat-forming 

forbs are usually the dominant herbaceous species on 

sites in lower condition. Cheatgrass is the species most 

likely to invade this site.

3 Bars Pr

1

2oject Final EIS 3-161 

3October 2016 

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Ecol

Co

Black 

sagebru

ricegras

and-thr

Black 

sagebru

ricegras

and-thr

Black 

sagebru

wheatg

TABLE 3-26

Ecological Sites for Black Sagebrush Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

sh/Indian 

s/needleead

R028BY011NV Shallow 

calcareous 

loam 8 to 10 

inches

The plant community is 

dominated by black sagebrush, 

Indian ricegrass, and needleand-thread. Potential vegetative 

composition is about 50 percent

grasses, 5 percent forbs, and 45

percent shrubs.

As ecological condition declines, black sagebrush, 

rabbitbrush, and shadscale increase, while perennial grasses, 

palatable shrubs, and forbs decrease. Cheatgrass and 

halogeton are species likely to invade on this site. Rodent 

activity is typically evidenced by small patches dominated 

by spiny hopsage. Utah juniper readily invades this site 

where it occurs adjacent to these woodlands. When Utah 

juniper occupies this site, it competes with other species for 

available light, moisture, and nutrients. If tree canopies are

allowed to close, they can eliminate all understory 

vegetation.

sh/Indian

s/needleead

R028BY016NV Shallow 

calcareous 

slope 8 to 10 

inches

The plant community is 

dominated by black sagebrush, 

Indian ricegrass, and needleand-thread. Potential vegetative 

composition is about 40 percent 

grasses, 5 percent forbs, and 55

percent shrubs and trees.

As ecological condition declines, black sagebrush, small 

rabbitbrush, and shadscale increase, while perennial grasses 

and forbs are reduced in the understory. Cheatgrass, Russian 

thistle, and halogeton are species likely to invade this site. 

Utah juniper readily invades this site where it occurs 

adjacent to these woodlands. When Utah juniper occupies 

this site, it competes with other species for available light, 

moisture, and nutrients. If the juniper canopy is allowed to 

close, it can eliminate all understory vegetation.

sh/bluebunch 

rass

R028BY027NV Shallow 

calcareous 

slope 14+ 

inches

The plant community is 

dominated by bluebunch 

wheatgrass and black sagebrush.

Potential vegetative composition 

is about 65 percent grasses, 10

percent forbs, and 25 percent

shrubs.

Black sagebrush and rabbitbrush will increase, while 

bluebunch wheatgrass and other desirable grasses will 

decrease, with excessive use by cattle and horses. With 

excessive use by sheep, black sagebrush, muttongrass, and 

forbs decrease as bluebunch wheatgrass initially increases.

3 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES

Bars Pr

4oject Final EIS 

53-162 October 2016 

6
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

bunchgrasses, and those that support any bunchgrasses typically only support one species, lack of an understory of 

native perennial forbs, and pinyon-juniper expansion (USDA Natural Resources Conservation Service 2012). 

3.12.2.2.5 Greasewood 

Black greasewood scrub dominates the southern end of the Kobeh Valley at elevations ranging from 5,500 to 6,200 

feet amsl. The northern portion of the project area also supports stands of greasewood in low-lying areas. The 

characteristic overstory shrub is black greasewood. Greasewood is considered a phreatophyte (i.e., a plant that sends 

its roots into the water table and depends on a constant supply of groundwater). Common understory grasses in 

greasewood communities include alkali sacaton, salt grass, and basin wildrye. The greasewood community covers 

about 31,642 acres, or 4.2 percent of the project area. According to the ecological site description, greasewood is 

expected to cover about 32,392 acres, or 4.3 percent of the project area (USDA Natural Resources Conservation 

Service 2012). Because greasewood occurs on extremely alkaline substrates, which are generally less suitable for 

other competing vegetation types, the actual distribution of greasewood in the project area is very similar to what 

would be expected for its ecological site. The project does not include specific proposed management actions for 

greasewood communities. 

The greasewood community is comprised of four ecological sites. Characteristics of these sites are shown in Table 3-

27. Cheatgrass invasion is the primary issue affecting the greasewood community. 

3.12.2.2.6 Salt Desert Scrub 

Salt desert scrub vegetation typically occurs in saline areas along drainages, margins of lake beds and marshes, and on 

flats and basins. In the 3 Bars Project area, this community occurs at elevations between 5,500 and 6,200 feet amsl. 

The salt desert scrub community covers about 28,061 acres, or 3.7 percent of the project area. According to the 

ecological site description, salt desert scrub dominated by shadscale is expected to cover about 29,552 acres, or 3.9 

percent of the 3 Bars Project area (USDA Natural Resources Conservation Service 2012). Other species present in 

this community include Indian ricegrass, squirreltail, bud sagebrush, iodine bush, halogeton, spiny hopsage, salt grass, 

and rock willow. The overall composition for sites with this vegetation type shows that they often have low grass 

production. The dominant grass species, such as bottlebrush squirreltail and Indian ricegrass, are often absent from the 

sites (Eastern Nevada Landscape Coalition and AECOM 2012). However, this community is relatively limited on the 

3 Bars Project area, and no management actions specific to salt desert scrub are proposed. 

The salt desert scrub community is comprised of four ecological sites. Characteristics of these sites are shown in 

Table 3-28. 

3.12.2.2.7 Quaking Aspen 

Since European settlement, the occurrence of aspen in the American West has declined from nearly 10 million acres 

to 4 million acres (about a 60 percent decline). Eighty percent of remaining aspen stands are being invaded by native 

conifers. In a study of 100 aspen stands in southeastern Oregon, northeastern California, and northwestern Nevada, 12 

percent of the aspen stands were completely replaced by western juniper. These stands were identified as previously 

being dominated by aspen based on the high density of dead aspen logs in the understory. In addition, post-settlement 

western juniper was the dominant tree species in 23 percent of the stands and common to co-dominant in 42 percent 

of the aspen stands (Miller et al. 2005). 

3 Bars Project Final EIS 3-163 October 2016 
Ecol

Co

Grease

wildrye

Grease

wildrye

Grease

wildrye

sacaton 

Grease

sacaton

TABLE 3-27

Ecological Sites for Greasewood Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

wood/basin R024XY007NV Saline bottom The plant community is dominated by 

basin wildrye. Black greasewood is 

the dominant shrub. Potential 

vegetative composition is about 70

percent grasses, 5 percent forbs, and 

25 percent shrubs.

Where management results in excessive grazing use 

by livestock, rabbitbrush and black greasewood 

increase and become the dominant vegetation in 

lower condition classes. Inland saltgrass increases as 

condition declines and usually dominates the 

understory during low ecological conditions. 

wood/basin 

-saltgrass

R024XY011NV Sodic flat 6 to 8 

inches

The plant community is dominated by 

black greasewood. Potential

vegetative composition is about 25

percent grasses, 5 percent forbs, and 

70 percent shrubs.

Herbaceous understory is reduced or eliminated and 

the site becomes a nearly pure stand of black 

greasewood. Halogeton, fivehook bassia, and annual 

mustards are species likely to invade this site.

wood/basin 

-alkali 

R028BY004NV Saline bottom The plant community is dominated by 

basin wildrye and alkali sacaton. 

Potential vegetative composition is 

about 80 percent grasses and grasslike plants, 5 percent forbs, and 15

percent shrubs.

As ecological condition declines, black greasewood 

and rubber rabbitbrush increase, while basin wildrye 

and alkali sacaton decrease. With further site 

degradation, rubber rabbitbrush typically becomes the 

dominant species.

wood/alkali 

-saltgrass

R028BY020NV Sodic flat 5 to 8 

inches

The plant community is dominated by 

black greasewood, alkali sacaton, and 

inland saltgrass. Vegetation on this site 

is normally restricted to coppice 

mound areas that are surrounded by 

playa-like depressions or nearly level, 

usually barren, interspaces. Potential 

vegetative composition is about 15

percent grasses, 5 percent forbs, and 80

percent shrubs.

As ecological condition declines, the herbaceous 

understory is reduced or eliminated and the site 

becomes a community of halophytic shrubs 

dominated by black greasewood. Halogeton and 

annual mustards are species likely to invade this site.

3 Bars Project Final EIS 3-164 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Eco

C

Shads

bud sa

squirre

ricegra

Shads

rock w

squirre

Winter

ricegra

Shads

Indian

squirre

o

c

c

c

TABLE 3-28

Ecological Sites for Salt Desert Scrub Community 

logical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

ale saltbushgebrush/ 

ltail-Indian 

ss

R024XY002NV Loamy 5 to 

8 inches

The plant community is dominated 

by shadscale, bud sagebrush, and 

Indian ricegrass. Potential 

vegetative composition is about 25

percent grasses, 5 percent forbs, 

and 70 percent shrubs.

Where management results in chronic, repetitive, multi-year 

improper grazing by livestock or horses, shadscale increases 

in density while Indian ricegrass and bud sagebrush 

composition is reduced. With further site degradation, 

shadscale may become dominant to the extent of a nearly pure 

stand. Cheatgrass, halogeton, and tansy mustard are likely to 

invade this site.

ale saltbushillow/ 

ltail

R024XY003NV Sodic 

terrace 6 to 

8 inches

The plant community is dominated 

by shadscale and black 

greasewood. Potential vegetative 

composition is about 10 percent

grasses, 5 percent forbs, and 85

percent shrubs.

Where management results in chronic, repetitive, multi-year 

improper grazing by livestock or horses, black greasewood 

and seepweed increase in density as perennial grass species 

decline. Russian thistle, annual mustards, and halogeton are 

species likely to invade disturbed areas on this site.

fat/Indian 

ss

R028BY013NV Silty 8 to 10 

inches

The plant community is dominated 

by winterfat and Indian ricegrass. 

Potential vegetative composition is 

about 30 percent grasses, 5 percent

forbs, and 65 percent shrubs.

As ecological condition declines, bottlebrush squirreltail and 

shadscale increase as winterfat and Indian ricegrass decrease. 

With further site deterioration, cheatgrass, halogeton and 

annual mustards invade the interspace areas between shrub 

species. On heavily disturbed sites, these annual species, 

particularly halogeton, become dominant. Soils of this site are 

easily eroded and gullies often form, interrupting the overland 

flow patterns. 

ale saltbush/ 

ricegrassltail

R028BY017NV Loamy 5 to 

8 inches

The plant community is dominated 

by Indian ricegrass, bottlebrush

squirreltail, and shadscale. 

Potential vegetative composition is 

about 30 percent grasses, 5 percent

forbs, and 65 percent shrubs

As ecological condition declines, shadscale increases in 

density, while Indian ricegrass, bottlebrush squirreltail, and 

bud sagebrush compositions are reduced. With further site 

degradation, shadscale may become dominant to the extent of 

a nearly pure stand. Cheatgrass, halogeton, and tansy mustard 

are species likely to invade this site.

3 Bars P

1roject Final EIS 

23-165 October 2016 

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

Quaking aspen occurs in isolated stands in riparian habitats within the project area and is found in deep to very deep 

soils (see Figure 3-25). The aspen community covers about 533 acres, or 0.1 percent of the 3 Bars Project area 

(USDOI USGS 2004, USDOI BLM 2010d, USDA Natural Resources Conservation Service 2012). Aspen 

communities have the highest biodiversity of any upland forest type in the Intermountain West, supplying important 

wildlife forage, cover, and breeding sites (Finch and Ruggiero 1993). 

Aspen are clonal, relying on root sprouting to reproduce and spread. They are also fire-adapted, and require periodic 

disturbance such as fire to stimulate root suckering and reduce competition from conifers (Bartos and Mueggler 1979, 

1981, Bartos et al. 1991, 1994, Shepperd 1993, Shepperd and Smith 1993; all in Kay 2001). Successful aspen seeding 

is rare; according to Kay (2001) there hasn’t been suitable climatic condition for aspen seedling success for thousands 

of years. Because aspen trees are short-lived, ongoing regeneration is important for the long-term persistence of aspen 

stands. 

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 is one of the 

primary goals of the 3 Bars Project. 

3.12.2.2.8 Mountain Mahogany Woodland 

Curl-leaf mountain mahogany woodlands occur in hills and mountain ranges of the intermountain basins. This 

vegetation type occurs on rocky outcrops or escarpments and forms small- to large-patch stands in woodland areas. 

Most stands occur as shrublands on ridges and steep rimrock slopes, but may also occur as small trees in steppe areas. 

The mountain mahogany woodland community covers about 4,275 acres, or 0.6 percent, of the project area. 

According to the USDA Natural Resources Conservation Service (2012) ecological site description, mountain 

mahogany woodland is expected to cover about 13,730 acres, or 1.8 percent of the 3 Bars Project area. Elevations 

range from 6,800 to 9,800 feet amsl. Curl-leaf mountain mahogany, mountain big sagebrush, greenstem paperflower, 

and Thurber’s needlegrass are characteristic species of this vegetation community. Other associated species may 

include antelope bitterbrush, manzanita, gooseberry, or snowberry. Scattered junipers or pines may also occur. Curlleaf mountain mahogany is a slow-growing, drought-tolerant species that generally does not resprout after burning 

and needs the protection from fire that rocky sites provide. In some instances, mountain mahogany is being impacted 

by pinyon-juniper encroachment or infilling, making this species more susceptible to impacts from fire. Mountain 

mahogany stands in the project area appear to be in fairly healthy condition, and the only management activities 

specifically targeting mountain mahogany communities would be the removal of dead trees and limbing of trees to 

improve stand health. The mountain mahogany community is comprised of two ecological sites. Characteristics of 

these sites are shown in Table 3-29. 

3.12.2.2.9 Pinyon-juniper Woodland 

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. According to the ecological site description for this 

3 Bars Project Final EIS 3-166 October 2016 
Ecolo

Com

Curl-leaf 

mahogan

big sageb

greenste

paperflo

Thurber’

needlegra

Curl-leaf 

mahogan

big sageb

greenste

paperflo

needlegra

TABLE 3-29

Ecological Sites for Mountain Mahogany Community 

gical Site 

munity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

mountain 

y/mountain 

rush/ 

m 

wers 

ss

R028BY042NV Mahogany 

thicket

The plant community is dominated by curl-leaf 

mountain mahogany, but trees such as singleleaf 

pinyon pine, Utah juniper, white fir, and limber 

pine may occur sporadically in the overstory 

canopy. Mountain big sagebrush and snowberry 

are the principal understory shrubs. Bluebunch 

wheatgrass and Thurber’s needlegrass are the most 

prevalent understory grasses. Total overstory 

canopy cover exceeds 45 percent. Understory 

vegetation comprises less than 10 percent of the 

total site production. Potential vegetative 

composition for the understory is about 55 percent

grasses, 10 percent forbs, and 35 percent shrubs. 

The overstory of curl-leaf mountain mahogany is 

about 85 percent of the total site production.

As ecological condition declines, the 

understory grasses and forbs are reduced 

as mountain big sagebrush and 

snowberry increase. Heavy utilization by 

livestock and/or wildlife will cause the

reproduction and overall production of 

curl-leaf mountain mahogany to be 

severely impacted. Cheatgrass is the 

species most likely to invade this site.

mountain 

y/mountain 

rush/ 

m 

werss

R028BY043NV Calcareous 

mahogany 

savanna

The plant community is dominated by curl-leaf 

mountain mahogany. Mountain big sagebrush is 

the principal understory shrub. Bluebunch 

wheatgrass, western needlegrass, Columbia 

needlegrass, and Letterman's needlegrass are the 

most prevalent understory grasses. Total overstory 

canopy cover is less than 50 percent. Understory 

vegetation comprises about 20 percent of the total 

site production. Potential vegetative composition 

for the understory is about 55 percent grasses, 10

percent forbs, and 35 percent shrubs. Overstory 

trees and tree-like shrub composition is about 80

percent of the total site production.

As ecological condition declines, 

understory grasses and forbs are reduced 

as mountain big sagebrush and Douglas’

rabbitbrush increase. Heavy utilization 

by livestock and wildlife will result in 

most of the foliage of the mountain 

mahogany growing above the reach of 

browsing animals and will severely limit 

production. Cheatgrass is the species 

most likely to invade this site.

3 Bars Project Final EIS 3-167 October 2016 

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

association, the potential natural vegetation includes Thurber’s needlegrass, bluebunch wheatgrass, black sagebrush, 

Mountain big sagebrush, Indian ricegrass, and greenstem paperflower (Eastern Nevada Landscape Coalition and 

AECOM 2012, USDOI BLM 2012b). Other shrubs present include antelope bitterbrush and rabbitbrush. Additional 

grasses include Sandberg bluegrass, bottlebrush squirreltail, Idaho fescue, and basin wildrye. 

The pinyon-juniper community is comprised of nine ecological sites. Characteristics of these sites are shown in Table 

3-30. 

Based on the project-specific mapping, pinyon-juniper woodlands cover approximately 190,357 acres, or 25.4 percent 

of the project area. These include areas with Phase II and III stands (see below for a description of phases), but not 

Phase I stands. According to the ecological site description, this vegetation type would be expected to be present on 

approximately 209,176 acres or 27.9 percent of the project area. The difference (approximately 18,819 acres) shows 

that Phase II and III 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 3.12.2.6), 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. However, if Phase I stands are also considered, there are about 118,000 more acres with 

pinyon-juniper 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. 

One resource management focus of the 3 Bars project is the overall distribution and structure of pinyon-juniper 

woodlands within the project area. In the Great Basin, pinyon-juniper has expanded outside of their historical range, 

and the density of trees has increased in older stands. Since the advent of fire suppression, there has been a migration 

of pinyon-juniper into sagebrush steppe communities. Sagebrush on much of the 3 Bars Project area has also been 

replaced with pinyon-juniper woodlands (USDOI BLM 2009a, 2012b, AECOM 2011a, Eastern Nevada Landscape 

Coalition and AECOM 2012). Many of these indicators have been observed in Phase III (or late successional) pinyonjuniper woodlands, which generally have a high density of trees and buildup of fuels. 

Romme et al. (2009), however, noted that pinyon-juniper typically experience long fire rotations of 400 years or more 

and because fires were never frequent, fire exclusion cannot be the principal mechanism responsible for infill in 

persistent woodlands. Miller and Rose (1999) and Romme et al. (2009) suggested that infilling of previously existing 

pinyon-juniper woodlands and expansion of pinyon-juniper into former grasslands and shublands may also reflect 

increased grazing pressure since the mid- 1800s, and normal fluctuations associated with climate that have occurred 

over thousands of years, including rising CO2 levels that have occurred during the past 100 years and wet climatic 

conditions from 1870 to 1915. Still, Romme et al. note that fire exclusion since the mid-1800s, coincident with the 

onset of livestock grazing, are likely the primary causes of pinyon-juniper infill and expansion into former grasslands 

and savannahs. In addition, infilling and expansion in the 3 Bars Project area likely reflect the recovery of preexisting 

woodlands following severe woodcutting that occurred around Eureka during the late 1800s for production of 

charcoal (see Section 3.12.2.6; Zeier 1987). 

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. 

Generally, areas of potential expansion are areas in which pinyon-juniper woodlands have not historically been 

present. These areas are targeted by the BLM for treatments to restore historical community types. Phase III 

3 Bars Project Final EIS 3-168 October 2016 
Ec

C

Single

Utah 

junipe

sagebr

blueb

wheat

Thurb

needle

TABLE 3-30

Ecological Sites for Pinyon-juniper Community 

ological Site 

ommunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

leaf pinyonr/mountain big 

ush/ 

unch 

grasser’s 

grass

F024XY049NV Not applicable An overstory canopy cover of 20 to 35 percent is 

assumed to be representative of tree dominance on 

this site in the pristine environment. Wildfire is 

recognized as a natural disturbance that influenced 

the structure and composition of the climax 

vegetation of this woodland site. This site is 

dominated by singleleaf pinyon pine and Utah 

juniper. Mountain big sagebrush is the principal 

understory shrub. Bluebunch wheatgrass, Indian 

ricegrass, and Thurber’s needlegrass are the most 

prevalent understory grasses. Overstory tree canopy 

composition is about 50 to 70 percent Utah juniper 

and about 30 to 50 percent singleleaf pinyon pine. 

Understory vegetative composition is about 60 

percent grasses, 10 percent forbs, and 30 percent

shrubs and young trees when the average overstory 

canopy is medium (20 to 35 percent). Average 

understory production ranges from 300 to 700 

pounds per acre with a medium canopy cover. 

Understory production includes the total annual 

production of all species within 4.5 feet of the 

ground surface.

Not applicable.

3 Bars Project Final EIS 3-169 October 2016 

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Ec

Utah 

singl

Wyo

sageb

needl

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

ological Site 

Community Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

junipereleaf pinyon/ 

ming big 

rush/Thurber’s 

egrass

F024XY050NV Not applicable An overstory canopy of 20 to 35 percent is assumed 

to be representative of tree dominance on this site in 

the pristine environment. Wildfire is recognized as a 

natural disturbance that strongly influenced the 

structure and composition of the climax vegetation 

of this woodland site. This site is dominated by Utah 

juniper and singleleaf pinyon pine. Wyoming big 

sagebrush is the principal understory shrub. 

Thurber’s needlegrass, bluebunch wheatgrass, and 

bluegrasses are the most prevalent understory 

grasses. Overstory tree canopy composition is about 

60 to 80 percent Utah juniper and about 20 to 40

percent singleleaf pinyon. Understory vegetative 

composition is about 50 percent grasses, 10 percent

forbs, and 40 percent shrubs and young trees when 

the average overstory canopy is medium (20 to 35

percent). Average understory production ranges 

from 200 to 500 pounds per acre with a medium 

canopy cover. Understory production includes the 

total annual production of all species within 4.5 feet 

of the ground surface.

Not applicable.

3 Bars Project Final EIS 3-170 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Ecol

Co

Singlele

Utah ju

sagebru

needleg

bluebun

wheatgr

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

af pinyonniper/black 

sh/Thurber’s 

rassch 

ass

F024XY051NV Not applicable An overstory canopy of 20 to 35 percent is assumed 

to be representative of tree dominance on this site in 

the pristine environment. Wildfire is recognized as a 

natural disturbance that strongly influenced the 

structure and composition of the climax vegetation 

of this woodland site. This site is dominated by 

singleleaf pinyon pine and Utah juniper. Black 

sagebrush is the principal understory shrub. 

Bluebunch wheatgrass, bluegrass, Thurber’s 

needlegrass, and Indian ricegrass are the most 

prevalent understory grasses. Overstory tree canopy 

composition is about 50 to 70 percent Utah juniper 

and about 30 to 50 percent singleleaf pinyon. 

Understory vegetative composition is about 35

percent grasses, 15 percent forbs, and 50 percent

shrubs and young trees when the average overstory 

canopy is medium (20 to 35 percent). Average 

understory production ranges from 250 to 500 

pounds per acre with a medium canopy cover. 

Understory production includes the total annual 

production of all species within 4.5 feet of the 

ground surface.

Not applicable.

3 Bars Project Final EIS 3-171 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Ecolo

Co

Singlel

Utah ju

sagebru

mounta

sagebru

Thurbe

needleg

bluebu

wheatg

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

gical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

eaf pinyonniper/black 

sh/

in big 

sh/ 

r’s 

rassnch 

rass

F024XY051NV/ 

F024XY049NV

Not applicable An overstory canopy of 20 to 35 percent is assumed to 

be representative of tree dominance on this site in the 

pristine environment. Wildfire is recognized as a 

natural disturbance that strongly influenced the 

structure and composition of the climax vegetation of 

this woodland site. This site is dominated by singleleaf 

pinyon pine and Utah juniper. Black sagebrush is the 

principal understory shrub. Bluebunch wheatgrass, 

bluegrass, Thurber’s needlegrass, and Indian ricegrass 

are the most prevalent understory grasses. Overstory 

tree canopy composition is about 50 to 70 percent Utah 

juniper and about 30 to 50 percent singleleaf pinyon. 

Understory vegetative composition is about 35 percent

grasses, 15 percent forbs, and 50 percent shrubs and 

young trees when the average overstory canopy is 

medium (20 to 35 percent). Average understory 

production ranges from 250 to 500 pounds per acre 

with a medium canopy cover. Understory production 

includes the total annual production of all species 

within 4.5 feet of the ground surface.

Not applicable.

3 Bars Project Final EIS 3-172 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Ecol

Co

Utah j

Wyom

sagebr

bluebu

wheat

Thurb

needle

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

uniper/ 

ing big 

ush/

nch 

grasser’s 

grass

F025XY059NV Not applicable This site is dominated by Utah juniper. Wyoming 

big sagebrush is the principal understory shrub. 

Bluebunch wheatgrass, Thurber’s needlegrass, 

Indian ricegrass, and bluegrasses are the most 

prevalent understory grasses. Phlox and milkvetch 

are common understory forbs. Overstory tree canopy 

composition is 100 percent Utah juniper. An 

overstory canopy cover of 20 to 35 percent is 

assumed to be representative of tree dominance on 

this site in the pristine environment. Wildfire is 

recognized as a natural disturbance that strongly 

influenced the structure and composition of the 

climax vegetation of this woodland site. Understory 

vegetative composition is about 50 percent grasses, 

20 percent forbs, and 30 percent shrubs and young 

trees when the average overstory canopy is medium 

(20 to 35 percent). Average understory production 

ranges from 200 to 500 pounds per acre with a 

medium canopy cover. Understory production 

includes the total annual production of all species 

within 4.5 feet of the ground surface.

Not applicable.

3 Bars Project Final EIS 3-173 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Ecolo

Com

Singlele

Utah jun

sagebru

bluebun

wheatgr

ricegras

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

gical Site 

munity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

af pinyoniper/black 

sh/

ch 

ass-Indian 

s

F028BY060NV Not applicable An overstory canopy of 20 to 35 percent is assumed 

to be representative of tree dominance on this site in 

the pristine environment. Wildfire is recognized as 

a natural disturbance that strongly influenced the 

structure and composition of the climax vegetation 

of this woodland site. This site is dominated by 

singleleaf pinyon pine and Utah juniper. Black 

sagebrush is the principal understory shrub. 

Bluebunch wheatgrass, bluegrass, Thurber’s

needlegrass, and Indian ricegrass are the most 

prevalent understory grasses. Overstory tree canopy 

composition is about 50 to 70 percent Utah juniper 

and about 30 to 50 percent singleleaf pinyon. 

Understory vegetative composition is about 35

percent grasses, 15 percent forbs, and 50 percent

shrubs and young trees when the average overstory 

canopy is medium (20 to 35 percent). Average 

understory production ranges from 250 to 500 

pounds per acre with a medium canopy cover. 

Understory production includes the total annual 

production of all species within 4.5 feet of the 

ground surface.

Not applicable.

3 Bars Project Final EIS 3-174 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Ecol

Co

Singlel

Utah j

Wyom

sagebr

bluebu

wheat

ricegra

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

eaf pinyonuniper/ 

ing big 

ush/

nch 

grass-Indian 

ss

F028BY061NV Not applicable An overstory canopy of 20 to 35 percent is assumed 

to be representative of tree dominance on this site in 

the pristine environment. Wildfire is recognized as a 

natural disturbance that strongly influences the 

structure and composition of the climax vegetation of 

this woodland site. This site is dominated by Utah 

juniper and singleleaf pinyon pine. Wyoming big 

sagebrush is the principal understory shrub. 

Bluebunch wheatgrass and Thurber’s needlegrass are 

the most prevalent understory grasses. Overstory tree 

canopy composition is about 50 to 70 percent Utah 

juniper and about 30 to 50 percent singleleaf pinyon. 

Understory vegetative composition is about 50

percent grasses, 10 percent forbs, and 40 percent

shrubs and young trees when the average overstory 

canopy is medium (20 to 35 percent). Average 

understory production ranges from 200 to 500 

pounds per acre with a medium canopy cover. 

Understory production includes the total annual 

production of all species within 4.5 feet of the 

ground surface.

Not applicable.

3 Bars Project Final EIS 3-175 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Eco

C

Singl

Utah 

junip

big sa

blueb

wheat

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

logical Site 

ommunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

eleaf pinyoner/mountain 

gebrush/ 

unch 

grass

F028BY062NV Not applicable This site is dominated by singleleaf pinyon and Utah 

juniper. An overstory canopy of 20 to 35 percent is 

assumed to be representative of tree dominance on 

this site in the pristine environment. Mountain big 

sagebrush is the principal understory shrub. 

Bluebunch wheatgrass, Indian ricegrass, and 

Thurber’s needlegrass are the most prevalent 

understory grasses. Overstory tree canopy 

composition is about 50 to 70 percent Utah juniper 

and about 30 to 50 percent singleleaf pinyon. 

Understory vegetative composition is about 60

percent grasses, 10 percent forbs, and 30 percent

shrubs and young trees when the average overstory 

canopy is medium (20 to 35 percent). Average 

understory production ranges from 300 to 700 

pounds per acre with a medium canopy cover. 

Understory production includes the total annual 

production of all species within 4.5 feet of the 

ground surface.

Not applicable.

3 Bars Project Final EIS 3-176 October 2016

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Ecol

Co

Singlel

Utah j

mount

sagebr

bluebu

wheatg

Thurbe

needle

greenst

paperfl

TABLE 3-30 (Cont.) 

Ecological Sites for Pinyon-juniper Community 

ogical Site 

mmunity Site Descriptor Soil Type Potential Native Vegetation Plant Community Dynamics

eaf pinyonuniper/ 

ain big 

ush/ 

nch 

rassr’s 

grassem 

ower

R028BY007NV/

F024XY049NV

Loamy 10 to 12 

inches

The understory plant community is dominated by 

Thurber’s needlegrass, bluebunch wheatgrass, and 

big sagebrush. Potential vegetative composition is

about 65 percent grasses, 10 percent forbs, and 25

percent shrubs and trees. An overstory canopy of 20 

to 35 percent is assumed to be representative of tree 

dominance on this site in the pristine environment. 

Wildfire is recognized as a natural disturbance that 

strongly influenced the structure and composition of 

the climax vegetation of this woodland site. This site 

is dominated by singleleaf pinyon and Utah juniper. 

Black sagebrush is the principal understory shrub. 

Bluebunch wheatgrass, bluegrass, Thurber’s 

needlegrass, and Indian ricegrass are the most 

prevalent understory grasses. Overstory tree canopy 

composition is about 50 to 70 percent Utah juniper 

and about 30 to 50 percent singleleaf pinyon. 

Understory vegetative composition is about 35

percent grasses, 15 percent forbs, and 50 percent

shrubs and young trees when the average overstory 

canopy is medium (20 to 35 percent). Average 

understory production ranges from 250 to 500 

pounds per acre with a medium canopy cover. 

Understory production includes the total annual 

production of all species within 4.5 feet of the 

ground surface.

Where management results in chronic, 

repetitive, multi-year improper grazing, 

big sagebrush, rabbitbrush, bottlebrush 

squirreltail, and Sandberg's bluegrass 

increase, while Thurber needlegrass, 

bluebunch wheatgrass, and other 

desirable forage species decrease. 

Cheatgrass readily invades this site 

following disturbances. Singleleaf 

pinyon pine and Utah juniper invade this 

site where it occurs adjacent to pinyonjuniper woodlands. When pinyon and 

juniper occupy this site they compete 

with other species for available light, 

moisture, and nutrients. If pinyonjuniper canopies are allowed to close, 

they can eliminate all understory 

vegetation.

3 Bars Project Final EIS 3-177 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

woodlands have the greatest tree density, and the greatest amount of canopy fuels, which puts them at increased risk 

for loss from high intensity wildfires (Tausch 1999 cited in Miller et al. 2008). According to Miller et al. (2008), 

however, treatments in Phase I and II expansion woodlands to halt their succession to Phase III woodlands may be 

more successful and cost-effective than treatments in Phase III woodlands. Figure 3-27 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. Areas of recent pinyon-juniper 

expansion seem to be most prevalent at the lowest elevations, where topography is gentle (AECOM 2011a). 

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; 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 3.12.2.6, much of the older pinyon-juniper was 

harvested to make charcoal for the mining industry in the mid-1800s. 

The following indicators of decline in the health of pinyon-juniper woodlands have been observed within the project 

area: 

 Lack of understory species diversity, and absence or decline in associated woodland species (e.g., aspen, 

bitterbrush, and curl-leaf mountain mahogany). 

 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. 

 Decreased tree vigor and pine nut production. 

 Increased pathogen infestations resulting in greater than 20 percent ongoing mortality within a given stand. 

 Stand conditions in excess of 400 steams per acre in several watersheds. Expansion onto adjacent range 

sites and encroachment into the interspaces within woodland sites including important wildlife and Greater 

sage-grouse habitats. 

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. 

3.12.2.3 Allotment Vegetation and Monitoring Studies 

Rangeland systems common to the 3 Bars ecosystem consist of shrublands with a bunchgrass understory (Eastern 

Nevada Landscape Coalition and AECOM 2012). Overall, the area is experiencing issues with invasive annual grass 

species (mainly cheatgrass) that are altering the fire regime, as discussed in Section 3.13 (Noxious Weeds and other 

Invasive Non-native 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. 

3 Bars Project Final EIS 3-178 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-31 

Pinyon-juniper Classification Schemes 

Classification Description

Historical Based System1

Persistent Woodlands

Vary from sparse stands of small trees growing in poor substrates to relatively 

dense stands of large trees on productive sites. However, by definition they 

are communities in which pinyon pine and/or juniper are dominant species 

(historically and currently).

Pinyon-juniper Savannas

Predominantly found on gentle upland and transitional valley locations, 

where soil conditions favor grasses (or other grass-like plants), but can 

support at least some tree cover.

Areas of Potential Expansion Occur when pinyon pine and juniper expand into new areas where they were 

not found historically.

Transitional Phases of Woodland Succession System2

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.

1

 Romme et al. (2007). 

2

 Miller et al. (2008).

Rangeland health studies were conducted in six allotments between December 2010 and September 2011 (Figure 3-

28). Seventy Key Management Areas (KMAs) within these allotments were assessed for their ecological status. These 

areas were selected because they met the following criteria: 

 representative of larger areas of interest; 

 contained within a single ecological site and plant community; 

 contain key species; and 

 capable of responding to management action that would be indicative of a response on a larger scale. 

The results of these studies were discussed in the Final 3 Bars Ecosystem and Landscape Restoration Project 

Rangeland Health Report (Eastern Nevada Landscape Coalition and AECOM 2012). This report provides an 

overview assessment of rangeland health in the 3 Bars ecosystem as well as a more detailed analysis of six allotments 

that span the project area from the northern to southern extent. The analysis focused on the assessment of individual 

KMAs within each allotment, and was extrapolated to the entire allotment. Within these KMAs, three parameters 

were used to measure overall rangeland health—production, desired dominant species, and Potential Natural 

Community for grass, forb, and shrub species. 

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. The Potential Natural 

Community is a measurement of plant composition, not to be confused with production. A site could be experiencing 

3 Bars Project Final EIS 3-179 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-27

Pinyon-juniper 

Phase Classes

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Pinyon-juniper Succession

Phase I

Phase II

Phase III

Pinyon-juniper Old Growth

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: AECOM 2011a. 

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-28

Range Allotments and

Key Management Areas

3 Bars Ecosystem and

Landscape Restoration Project

PRIVATE

SHANNON

STATION

WILLOWS

RANCH WILLOWS

RANCH

DRY

CREEK

278

50

Eureka

Elko County

Eureka County

Lander CountyEureka County

NORTH

DIAMOND

FLYNN/

PARMAN

JD

GRASS

VALLEY

ROBERTS

MOUNTAIN ROMANO

THREE

BARS

SANTA FE/

FERGUSON

LUCKY C

DRY

CREEK

DC-02

WR-02

DC-08

WR-03 SF-03

SF-02 LC-04

SF-01 LC-09 SF-04

LC-06

LC-07

SF-10 SF-05 RO-02

RM-02 RM020 TB-24 LC-05

SF-07 TB-08 RM-25

RM-08

TB-07 RM-26

RO-03 RM-17

SF-08 RM-01

RO-11 RO-04

RM-07

TB-20

SF-09

TB-21

RM-03

RO-12

TB-02 TB-10 RO-06 TB-03

GV-26

RM-14

TB-01 TB-22

TB-06 TB-09 RM-27

GV-25 RM-18 TB-04 JD-12

RM-13 RO-08 TB-05

TB-19 RM-22 RO-07 JD-07 JD-13

GV-07 RM-16

ND-01 GV-06 RM-20

RM-21

GV-23 GV-22

JD-06

GV-21 JD-04 JD-03

GV-20

ND-04

GV-04 JD-05

JD-04

GV-19 ND-03

RM-11

JD-02

RM-19 RM-23

GV-09 GV-18 RM-09

GV-08 JD-10 JD-05 RM-15

GV-10

JD-08 JD-09

JD-01

ND-02 GV-17 JD-02 JD-11

ND-05

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Key Management Area

Fence

Allotment Boundary

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012h, 2013i.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

high production, but have low Potential Natural Community, if it is only producing a single grass, forb, or shrub 

species. 

One of the objectives of the 3 Bars Project is to restore the functionality of the plant communities within the project 

area. 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. 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). After management objectives 

have been developed, one specific plant community may be identified as the desired plant community. 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 3-29 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 of the KMAs. 

3.12.2.3.1 Flynn/Parman Allotment 

The Flynn/Parman Allotment consists of terrain ranging from moderately sloping hills to low mountains. Vegetation 

in the lower elevations includes big sagebrush with an understory of Sandberg’s bluegrass, bottlebrush squirreltail, 

and Indian ricegrass. Mid-elevation vegetation includes pinyon-juniper and big sagebrush with an understory of 

bottlebrush squirreltail, Nevada bluegrass, and western wheatgrass. The vegetation at upper elevations includes 

pinyon-juniper with understories of bluebunch wheatgrass, basin wildrye, Thurber’s needlegrass, and antelope 

bitterbrush. Five wildfires have occurred in this allotment since 1994, ranging from 61 to 3,275 acres, and have 

resulted in some of the area being infested with cheatgrass (see Section 3.13, Noxious Weeds and other Invasive Nonnative Vegetation). Four of these fire sites were re-seeded with a mixture of native and non-native species. 

3.12.2.3.2 Roberts Mountain Allotment 

The Roberts Mountain Allotment consists of terrain ranging from level valleys to high mountains. The vegetation in 

the valleys includes big sagebrush with an understory of Sandberg’s bluegrass, bottlebrush squirreltail, and Indian 

ricegrass. Vegetation at mid-elevations includes pinyon-juniper, big sagebrush, and low sagebrush with an understory 

of bottlebrush squirreltail, Thurber’s needlegrass, and Nevada bluegrass. Vegetation at upper elevations includes 

pinyon-juniper, mountain mahogany, willow, aspen, big sagebrush, and low sagebrush with an understory of 

bottlebrush squirreltail, Thurber’s needlegrass, and Nevada bluegrass. Since 1954, five vegetation treatments have 

been applied; they include three crested wheatgrass seedings between 1954 and 1956 totaling 8,425 acres, an 

herbicide treatment application in 1965 totaling 2,111 acres, and pinyon-juniper thinnings in 2008 and 2009 totaling 

1,660 acres. Additionally, a fire burned 627 acres in 2006. 

3.12.2.3.3 JD Allotment 

The JD Allotment consists of terrain ranging from flats and rolling hills to high mountains. Several seeps, springs, and 

streams are found in the mid- to upper elevations, supporting willow and aspen stands. Vegetation in the lower 

3 Bars Project Final EIS 3-182 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-29

Current Rangeland Conditions

3 Bars Ecosystem and

Landscape Restoration Project

PRIVATE

SHANNON

STATION

WILLOWS

RANCH WILLOWS

RANCH

DRY

CREEK

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

NORTH

DIAMOND

FLYNN/

PARMAN

JD

GRASS

VALLEY

ROBERTS

MOUNTAIN

ROMANO

THREE

BARS

SANTA FE/

FERGUSON

LUCKY C

DRY

CREEK

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Successional Status

Early (0-25%)

Mid (25-50%)

Late (51-76%)

Not Available

Allotment Boundary

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012g, ENLC and AECOM 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Allot

Fly

Par

TABLE 3-32 

Flynn/Parman Allotment Key Management Areas 

ment

KMA 

Number

Grass 

Composition (%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

nn/ 

man

FJ1 50 27 5 60 45 12

This site is rated as early seral primarily due to a lack of 

desired perennial grass and shrubs. The primary and secondary 

perennial grass species are absent from the site. The dominant 

perennial grass found on the site is Sandberg’s bluegrass; while 

desirable, it should not be the dominant perennial grass species 

for this site, based on the Ecological Site Description (ESD). 

Production of forbs is above the Potential Natural Community 

(PNC) for the site, with the dominant species being arrowleaf 

balsamroot. 

FJ2 50 25 5 60 45 13

This site was recently disturbed by a wildfire, and is rated as 

early seral primarily due the lack of desired shrubs and 

perennial grasses. The dominant shrub species are missing 

from the site, and many of the desired perennial grasses are 

present, but are well below PNC. Production for forbs is well 

above PNC, however the dominant forb species, spiny phlox, 

is an undesirable forage species. 

FP1 50 56 5 39 45 5

This site is rated as early seral, primarily due to a lack of 

desired shrubs. The dominant shrub species, Wyoming big 

sagebrush, is on the site but is not abundant. Production of 

forbs is above PNC; however, the dominant forb species, spiny 

phlox, is an undesirable forb species. It is important to note 

that this site has a much larger juniper component than is 

represented by the production study. The ESD for this site 

states that juniper readily invades this type of site where it is 

adjacent to woodlands, and when juniper occupies this site, it 

competes for other species for nutrients and available light. 

Where juniper canopies are allowed to close, juniper can cause

the elimination of understory vegetation. 

3 Bars Project Final EIS 3-184 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Allotm

Flyn

Parma

TABLE 3-32 (Cont.) 

Flynn/Parman Allotment Key Management Areas 

ent

KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

n/

n

FP2 50 58 5 38 45 <1

This site has been disturbed by a wildfire, and is rated as 

early seral primarily due the lack of desired shrubs and 

perennial grasses. The dominant shrub species are missing 

from the site, as well as the primary and secondary grasses. 

Production of forbs is above PNC, however, the dominant 

forb species, spiny phlox, is an undesirable forage species. 

FP3 55 29 10 64 35 5

This site appears to have been disturbed, although the cause 

of the disturbance is uncertain. It is rated as early seral 

primarily due to the lack of desired shrubs and perennial 

grasses. The dominant shrub species are missing from the 

site, and many of the desired perennial grasses are missing or 

present but below PNC. Production of forbs is above PNC,

however, the dominant forb species, spiny phlox, is an 

undesirable forage species. 

FP4 65 73 10 19 25 <1

This site has been disturbed by a wildfire, and is rated as 

early seral primarily due the lack of desired shrubs, perennial 

grasses, and forbs. The dominant shrub species are missing 

from the site. In addition, the site is missing some desired 

perennial grasses. Production of forbs is above PNC,

however, the dominant forb species, spiny phlox, is an 

undesirable forage species

3 Bars Project Final EIS 3-185 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Allotm

Robe

Mount

TABLE 3-33

Roberts Mountain Allotment Key Management Areas 

ent KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

rts 

ain

RM7 65 14 10 8 25 78

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The primary and 

secondary perennial grass species are absent from the site. 

The dominant perennial grass found on the site is crested 

wheatgrass. While desirable, it should not be the dominant 

perennial grass species for this site, based on the ESD. 

Production of forbs is below PNC for the site. 

RM9 65 17 10 26 25 57

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The primary and

secondary perennial grass species are absent from the site. 

The dominant perennial grass found on the site is crested 

wheatgrass. While desirable, it should not be the dominant 

perennial grass species for this site, based on the ESD. No 

desirable forbs are found at the site. 

RM11 50 31 5 2 45 67

This site is rated as late seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses found on the site are squirreltail and Sandberg’s

bluegrass; while desirable, they should not be the dominant 

perennial grass species for this site, based on the ESD. 

Several desirable forbs are found at the site, but production of 

these plants is low. 

RM14 55 7 10 23 35 70

This site is rated as late seral primarily due to the lack of a 

desired perennial grasses. The dominant perennial grasses 

listed on the ESD (with the exception of bluebunch 

wheatgrass) are found on the site, but production is low. In 

addition, the site is lacking its secondary shrub, antelope 

bitterbrush. 

3 Bars Project Final EIS 3-186 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Allot

Rob

Mou

TABLE 3-33 (Cont.) 

Roberts Mountain Allotment Key Management Areas 

ment KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

erts 

ntain

RM18 45 9 10 60 45 30

This site is rated as late seral primarily due to the lack of 

desired perennial grasses. The dominant perennial grasses 

listed on the ESD (with the exception of bluebunch 

wheatgrass and pine needlegrass) are found on the site, but 

production is extremely low. 

RM19 50 10 5 4 45 86

This site is rated as late seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD (with the exception of needle-andthread) are found on the site, but production is low. Desirable 

perennial forbs are found at the site, but production is low.

RM20 50 4 5 19 45 77

This site is rated as late seral primarily due to the lack of 

desired perennial grass and forbs. The dominant perennial 

grasses listed on the ESD are absent from the site. Several 

other desirable perennial forbs (milkvetch, hawksbeard, and 

long leaf phlox) are found on the site, but production is low.

RM21 50 7 5 12 45 81

This site is rated as late seral primarily due to the lack of 

desired perennial grasses. The dominant perennial grasses 

listed on the ESD (with the exception of needle-and-thread) 

are found on the site, but production is low. 

RM22 50 7 5 4 45 89

This site is rated as late seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are not on the site, only two 

perennial forbs are found the site, and production is low.

RM23 50 7 5 <1 45 83

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD (with the exception of Thurber’s 

needlegrass) are found on the site, but production is low. The 

site is lacking in desirable perennial forbs. 

3 Bars Project Final EIS 3-187 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Allot

Rob

Mou

TABLE 3-33 (Cont.) 

Roberts Mountain Allotment Key Management Areas 

ment KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

erts 

ntain

RM25 50 3 5 1 45 96

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD (with the exception of needle-andthread) are found on the site, but production is low. Only one 

perennial forb is found on the site, and production is low.

RM26 50 28 5 7 45 64 This site is rated as PNC primarily due to the presence of 

desirable perennial grasses and forbs.

RM27 50 9 5 24 45 67

This site is rated as late seral primarily due to the lack of 

desired perennial grasses. The dominant perennial grasses 

listed on the ESD (with the exception of needle-and-thread) 

are found on the site, but production is low. 

RM108 65 21 10 5 25 74

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are not found on the site. Crested 

wheatgrass dominates the site. Several perennial forbs are 

found on the site, but production is low. 

RM208 50 1 5 1 45 98

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. Only one 

perennial forb was found on the site, and production is low. 

RM308 60 6 10 2 30 92

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. Perennial 

forbs are on the site, but production is low. 

3 Bars Project Final EIS 3-188 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

elevations includes Wyoming big sagebrush, shadscale, and budsage with an understory of Sandberg’s bluegrass and 

bottlebrush squirreltail. Vegetation in the higher elevations consists of pinyon-juniper, low sagebrush, and some 

mountain mahogany with an understory of Sandberg’s bluegrass, bottlebrush squirreltail, Thurber’s needlegrass, and 

bluebunch wheatgrass. Since 1961, nine seedings, eight wildfires, two mechanical treatments, and one herbicide 

treatment application have occurred, as follows: 

Seedings (11,133 acres) 

1961 = 888 acres of crested wheatgrass 

1964 = 1,692 acres of crested wheatgrass 

1966 = 698 acres of crested wheatgrass 

1985 = 1,383 acres of crested wheatgrass 

1994 = 1,642 acres of native and non-native species 

1995 = 838 acres of native and non-native species 

1996 = 385 acres of native and non-native species 

1999 = 2,250 acres of crested wheatgrass 

2000 = 1,357 acres of native and non-native species 

Fires (34,581 acres) 

JD Fire 1985 = 1,128 acres 

Simpson Fire 1994 = 1,663 acres (reburned in the 1999 Trail Canyon Fire) 

Mud Fire 1996 = 385 acres (reburned in the 1999 Trail Canyon Fire) 

Trail Canyon Fire 1999 = 17,694 acres 

Tonkin Fire 2000 = 1,357 acres 

Tonkin Fire 2006 = 72 acres 

JD Fire 2006 = 210 acres 

Frazier Fire 2012 = 12,072 acres 

Chaining after the Trail Canyon re-seeding 1999 = 17,744 acres 

Chemical and mechanical treatment applications 

Ester 2,4-D aerial spray 1966 = 1,796 acres 

Chaining after the Trail Canyon re-seeding 1999 = 17,744 acres 

Hand thinning of pinyon-juniper 2008 = 2,209 acres 

3.12.2.3.4 Three Bars Allotment 

The Three Bars Allotment consists of terrain ranging from valley bottoms to high mountains. Vegetation in the lower 

elevations includes Wyoming big sagebrush with an understory of Sandberg’s bluegrass, bottlebrush squirreltail, and 

Indian ricegrass. Vegetation in the higher elevations consists of pinyon-juniper, Wyoming big sagebrush, mountain 

big sagebrush, and black sagebrush with an understory of bottlebrush squirreltail, Thurber’s needlegrass, Indian 

ricegrass, Great Basin wildrye, Idaho fescue, and Nevada bluegrass. Two fires have occurred within the Three Bars 

Allotment; the Trail Canyon Fire in 1999 that burned 3,490 acres, and the HaHa Fire in 2005 that burned 24 acres. 

The following six allotments (Dry Creek, Grass Valley, North Diamond, Santa Fe/Ferguson, Shannon Station, and 

Willows Ranch) were not part of the Final 3 Bars Ecosystem and Landscape Restoration Project Rangeland Health 

3 Bars Project Final EIS 3-189 October 2016 
Allo

TABLE 3-34

JD Allotment Key Management Areas 

tment KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

JD

JD1 55 6 5 18 40 41

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. No perennial 

forbs are found on the site.

JD2 25 3 5 15 70 82

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. No perennial 

forbs are found on the site.

JD3 50 <1 5 0 45 100

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. 

JD4 65 63 5 0 30 37

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. Crested 

wheatgrass is the dominant grass. No perennial forbs are on the 

site. 

JD5 55 54 5 <1 40 63

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. No perennial 

forbs were found on the site. 

JD6 50 10 5 0 45 90

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. No perennial 

forbs were found on the site. 

JD7 65 9 10 82 25 9

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and shrubs. The dominant perennial 

grasses listed on the ESD are lacking on the site. Shrubs are on 

the site, but production is low. 

3 Bars Project Final EIS 3-190 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Allotm

JD

TABLE 3-34 (Cont.) 

JD Allotment Key Management Areas 

ent KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

JD8 40 30 10 <1 50 70

This site is rated as late seral primarily due to the lack of the 

production of desired perennial grasses and shrubs. Grass 

production is lower than desired, but several desirable species 

are present. No desirable forbs are on the site. 

JD9 65 94 5 5 30 0

This site is rated as early seral primarily due to the lack of 

desired perennial grasses, forbs, and shrubs. The dominant 

perennial grasses listed on the ESD are lacking on the site. No 

perennial forbs are on the site. The dominant grass is crested 

wheatgrass, which is a non-native seeded species.

JD10 50 15 5 0 45 85

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site. Perennial forbs 

were found on the site during nested frequency studies, but not 

during production studies. 

JD11 25 12 5 13 70 73

This site is rated as late seral primarily due to the lack of 

production of desired perennial grasses and shrubs. The 

dominant perennial grasses listed on the ESD are on the site but 

production is low. No perennial forbs were found on the site. 

Only one shrub, shadscale saltbush, was found during the 

production studies.

JD12 55 44 10 41 35 15

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and shrubs. Perennial grass production 

is low, and one of the dominant perennial grasses listed on the 

ESD is lacking on the site. Several desirable perennial forbs are 

found on the site. Shrub production is low, and antelope 

bitterbrush was not found on the site. 

3 Bars Project Final EIS 3-191 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Allo

TABLE 3-34 (Cont.) 

JD Allotment Key Management Areas 

tment KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

JD

JD13 55 17 10 67 35 16

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and low shrub production. The 

dominant perennial grasses listed on the ESD are lacking on the 

site, and the perennial grasses that are present have low 

production. A variety of desirable shrubs are on the site, but 

production is low. 

JD14 50 32 5 24 45 44

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The dominant perennial 

grasses listed on the ESD are lacking on the site, and only one 

perennial forb was found on the site. 

JD15 55 48 5 22 40 30

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and low shrub production. The 

dominant perennial grasses listed on the ESD are lacking on the 

site. Shrub production is low and the secondary shrub was not 

found on the site. 

JD16 65 58 10 29 25 13

This site is rated as early seral primarily due to the lack of 

desired perennial grass, forb, and shrub production. The 

dominant perennial grasses listed on the ESD are lacking on the 

site. Perennial forbs are found on the site, but production is low.

Shrub production is low, and the secondary shrub was not found

on the site. 

JD17 40 69 5 0 55 29

This site is rated as early seral primarily due to the low 

production of desired perennial grasses and shrubs. Needle-andthread, one of the dominant perennial grasses listed on the ESD,

is lacking on the site. No perennial forbs were detected during 

production. Shrub production is low. 

3 Bars Project Final EIS 3-192 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
TABLE 3-34 (Cont.) 

JD Allotment Key Management Areas 

Allotment KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

JD

JD18 55 52 10 15 35 33

This site is rated as early seral primarily due to the low 

production of desired perennial grasses, forbs, and shrubs. The 

dominant perennial grasses listed on the ESD are lacking on the 

site. Production of forbs is low, despite the presence of several 

desirable species. The secondary shrub was not found on the 

site, and mountain big sagebrush has low production.

JD19 65 21 10 21 25 58

This site is rated as early seral primarily due to the low 

production of desired perennial grasses, forbs, and shrubs. The 

dominant perennial grasses listed on the ESD are lacking on the 

site. Production for forbs is high, and includes several desirable 

species. No desirable shrubs are present. 

3 Bars Project Final EIS 3-193 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Allot

Thr

Ba

TABLE 3-35

Three Bars Allotment Key Management Areas 

ment KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

ee 

rs

BI2 65 21 10 15 25 64

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The primary perennial 

grass species is absent from the site. The desirable grasses 

present are only found in small amounts. Production of forbs 

and shrubs is above PNC. 

TB1 50 24 10 10 40 66

This site is rated as early seral primarily due to the lack of 

desired perennial grasses. The primary and secondary perennial 

grass species are absent from the site. The desirable grasses 

present are only found in small amounts. Production of forbs is 

below PNC and the production of shrubs is above PNC. 

TB2 65 37 10 37 25 26

This site is rated as early seral primarily due to the lack of 

desired perennial grasses. The primary and secondary perennial 

grass species are absent from the site. Many of the perennial 

grasses found on the site have low production. Production of 

forbs and shrubs is above PNC. 

TB3 65 6 10 79 25 15

This site is rated as early seral primarily due to the low 

production of desired perennial grasses and shrubs. The 

primary and secondary perennial grass species are absent from 

the site. Desirable shrub composition is below PNC. 

TB4 55 15 10 82 35 3

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and shrubs. The primary and 

secondary perennial grass species are absent from the site. The 

desirable grasses present are only found in small amounts. 

Production of shrubs is below PNC. 

3 Bars Project Final EIS 3-194 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Allotm

Thre

Bars

TABLE 3-35 (Cont.)

Three Bars Allotment Key Management Areas 

ent KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

e 

TB6 50 51 10 8 40 41

This site is rated as early seral primarily due to the lack of 

desired perennial grasses. The primary and secondary perennial 

grass species are absent from the site. Bluegrass and squirreltail 

are the dominant grasses on the site, and while they are 

desirable grasses, they should not be the dominant grasses for 

this site. The desirable grasses present are only found in small 

amounts. Production of forbs and shrubs is close to PNC. 

TB7 50 50 5 1 45 49

This site is rated as early seral primarily due to the lack of 

desired perennial grasses and forbs. The primary and secondary 

perennial grass species are absent from the site. The primary 

grass on the site is Sandberg’s bluegrass and while desirable, it 

should not be the dominant grass species for this site. In 

addition, the site lacks the desired production for forbs and 

Wyoming big sagebrush. 

TB8 50 <1 5 0 45 100

This site is rated as mid-seral primarily due to the lack of 

desired perennial grasses and forbs. The primary and secondary 

perennial grass species are absent from the site. Only one grass, 

squirreltail, is on the site, and it has very low production. Shrub 

production is above PNC. 

TB9 45 43 10 41 45 16

This site is rated as late seral primarily due to the amount of 

production of the perennial grasses and forbs. However, this 

site is lacking the primary and secondary perennial grass 

species. The dominant grass species is bluegrass, and while 

desirable, it should not be the dominant grass on the site. 

Sagebrush production is also low on this site. 

3 Bars Project Final EIS 3-195 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Allotm

Thre

Bar

TABLE 3-35 (Cont.) 

Three Bars Allotment Key Management Areas 

ent KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

e 

s

TB10 45 43 10 16 45 41

This site is rated as late seral primarily due to the production of 

the perennial grasses, forbs, and shrubs. 

TB19 45 35 10 57 45 8

This site is rated as mid-seral primarily due to the amount of 

production of perennial grasses and forbs. However, this site is 

lacking the primary and secondary perennial grass species. The 

dominant grass species is bluegrass, and while desirable, it 

should not be the dominant grass on the site. Sagebrush 

production was not observed on this site. 

TB20 65 22 10 46 25 32

This site is rated as early seral primarily due to the lack of 

production of the perennial grasses and variety of forbs and 

shrubs. The primary and secondary perennial grass species 

were not found on the site. The main forb species found on the 

site was spiny phlox, and while desirable, it should not be the 

dominate forb on the site. The secondary shrub, antelope 

bitterbrush, is absent from the site. 

TB21 65 39 10 39 25 22

This site is rated as early seral primarily due to the lack of 

perennial grasses and variety forbs. This site is lacking the 

primary grass species listed on the ESD for the site. The only 

forb observed on the site was spiny phlox; it should not be the 

dominant forb species. Antelope bitterbrush, the secondary 

shrub, was not found on the site. 

TB22 65 56 10 37 25 7

This site is rated as mid-seral primarily due to the amount of 

production of the perennial grasses and shrubs. However, this 

site is lacking the secondary perennial grass species listed on 

the ESD. Shrub production was found to be low on this site and 

the secondary shrub was not detected. 

3 Bars Project Final EIS 3-196 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Allot

Thre

Bar

TABLE 3-35 (Cont.) 

Three Bars Allotment Key Management Areas 

ment KMA 

Number

Grass Composition 

(%)

Forb Composition 

(%)

Shrub Composition 

(%) Major Concerns

Desired Actual Desired Actual Desired Actual

e 

s

TB24 50 36 5 13 45 51

This site is rated as early seral primarily due to the lack of 

production of the perennial grasses. The primary grass is 

present in only a small amount, and the secondary grass is not 

found on the site. The dominant grass species was bluegrass, 

and while desirable, it should not be the dominant grass on the 

site.

3 Bars Project Final EIS 3-197 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.2.3.5 Romano Allotment 

The Romano Allotment consists of terrain ranging from valley bottoms to low mountains. Vegetation in the lower 

elevations includes Wyoming big sagebrush with an understory of Sandberg’s bluegrass, bottlebrush squirreltail, and 

Indian ricegrass. Vegetation in the mid-range elevations consists of pinyon-juniper and Wyoming big sagebrush with 

an understory of bottlebrush squirreltail, Nevada bluegrass, and western wheatgrass. Vegetation at higher elevations 

consists of pinyon-juniper with an understory of bluebunch wheatgrass, basin wildrye, Thurber’s needlegrass, and 

antelope bitterbrush. There are scattered occurrences of cheatgrass within the Romano Allotment (see Section 3.13, 

Noxious Weeds and other Invasive Non-native Vegetation). 

3.12.2.3.6 Lucky C Allotment 

The Lucky C Allotment consists of terrain ranging from valley bottoms to low mountains. Vegetation on the lower 

elevations includes black greasewood with an understory of basin wildrye and inland saltgrass. Vegetation at midrange elevations consists of Wyoming big sagebrush and basin big sagebrush with an understory of needle-and-thread 

grass and Indian ricegrass. Vegetation at higher elevations consists of black sagebrush with an understory of Indian 

ricegrass and needle-and-thread grass. Pinyon-juniper is found on Lone Mountain. 

The following six allotments (Dry Creek, Grass Valley, North Diamond, Santa Fe/Ferguson, Shannon Station, and 

Willows Ranch) were not part of the Final 3 Bars Ecosystem and Landscape Restoration Project Rangeland Health 

Report (Eastern Nevada Landscape Coalition and AECOM 2012). Health assessments and evaluations have been 

conducted by the BLM, with the exception of the Santa Fe/Ferguson allotment, and the results follow. 

3.12.2.3.7 Dry Creek Allotment 

The Potential Natural Communities for the Dry Creek Allotment consist of Wyoming big sagebrush with an 

understory of Indian ricegrass and needle-and-thread grass at the lower elevations; black sagebrush with an understory 

of Indian ricegrass and needle-and-thread grass at the mid-elevations; and low sagebrush with an understory of 

Thurber’s needlegrass and bluebunch wheatgrass and Utah juniper and singleleaf pinyon pine communities in the 

upper elevations. 

3.12.2.3.8 Grass Valley Allotment 

The Potential Natural Communities for the Grass Valley Allotment in the lower elevations consist of alkali sacaton, 

saltgrass, alkali bluegrass, basin wildrye, and black greasewood in the poorly drained areas and Wyoming big 

sagebrush, shadscale, and budsage, with an understory of Indian ricegrass, bottlebrush squirreltail, and bluegrass on 

the alluvial fans. The mid-elevation Potential Natural Communities consist of pinyon-juniper, curl-leaf mountain 

mahogany, black sagebrush, mountain big sagebrush, and low sagebrush with an understory of bluebunch wheatgrass, 

Idaho fescue, Thurber’s needlegrass, bottlebrush squirreltail, Nevada bluegrass, and basin wildrye. The higher 

elevation Potential Natural Communities consist of mountain big sagebrush, snowberry, serviceberry, and low 

sagebrush with an understory of mountain brome, Thurber’s needlegrass, basin wildrye, Idaho fescue, and bluegrass.

Portions of the Grass Valley Allotment were burned in the 1999 Trail Canyon Fire and are now dominated by 

cheatgrass. 

3 Bars Project Final EIS 3-198 October 2016 
Allot

Rom

TABLE 3-36

Romano Allotment Key Management Areas 

ment KMA 

Number

Grass Composition (%) Forb Composition (%) Shrub Composition (%) Major Concerns Desired Actual Desired Actual Desired Actual

ano

RO2 50 33 5 13 45 50

This site is rated as mid-seral primarily due to the lack 

of production of the perennial grasses. Both the 

primary and secondary grasses are present, but only in 

small amounts. The dominant grass species is 

bluegrass, and while desirable, it should not be the 

dominant grass on the site.

RO3 55 58 10 9 35 33

This site is rated as mid-seral primarily due to the lack 

of variety of perennial grasses and shrubs and the low 

production of forbs. The secondary grass (Indian 

ricegrass) was not found on the site and the site is 

dominated by needle-and-thread. Only one perennial 

forb was detected in measurable amounts. The site 

was also missing its secondary shrub (four-wing 

saltbush). 

RO4A 50 52 5 2 45 35

This site is rated as early seral primarily due to the 

lack of production of native perennial grasses and 

forbs. The primary grass (Indian ricegrass) was not 

detected on the site, and the secondary grass was only 

present in a small amount. Only one perennial forb 

(milkvetch) was found and only in trace amounts.

RO4B 50 100 5 0 45 0

This site is rated as early seral due to the lack of 

production of the native perennial grasses, forbs, and 

shrubs. The only species found on the site was a nonnative seeded species, crested wheatgrass. 

RO6 30 4 5 36 65 60

This site is rated as mid-seral primarily due to the lack 

of production of the perennial grasses, forbs, and 

shrubs. Perennial grass production is low, and no 

perennial forbs were found on the site. The dominant

shrub, shadscale saltbush, is low. 

3 Bars Project Final EIS 3-199 October 2016 

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
Allo

Ro

TABLE 3-36 (Cont.) 

Romano Allotment Key Management Areas 

tment KMA 

Number

Grass Composition (%) Forb Composition (%) Shrub Composition (%) Major Concerns Desired Actual Desired Actual Desired Actual

mano

RO7 50 37 5 24 45 39

This site is rated as early seral primarily due to the 

lack of production of the perennial grasses, forbs, and 

shrubs. The primary grass was found in only trace 

amounts and the secondary grass was absent from the 

site. Several perennial forbs were found on the site, 

but forb production is dominated by bur buttercup, an 

undesirable annual forb. Shrub production is below 

PNC.

RO8 50 42 5 0 45 58

This site is rated as early seral primarily due to the 

lack of production of perennial grasses. The primary 

grass is present in small amounts, but the secondary 

grass was not found. The dominant grass species is 

bluegrass, and while desirable, it should not be the 

dominant grass on the site. No perennial forbs were 

found.

RO11 55 16 10 46 35 37

This site is rated as mid-seral primarily due to the lack 

of production of the perennial grasses. Both the 

primary and secondary grasses are present, but only in 

small amounts. The dominant grass species is 

bluegrass, and while desirable, it should not be the 

dominant grass on the site.

RO12 65 49 10 36 25 15

This site is rated as early seral primarily due to the 

lack of production of the perennial grasses and shrubs. 

Both the primary and secondary grasses were not 

found. The dominant grass species is bluegrass, and 

while desirable, it should not be the dominant grass on 

the site. Big sagebrush production is below PNC, and 

the secondary shrub, antelope bitterbrush, was not 

detected. 

3 Bars Project Final EIS 3-200 October 2016 

NATIVE AND NON-INVASIVE VEGETATION RESOURCES
Allo

Lu

TABLE 3-37

Lucky C Allotment Key Management Areas 

tment KMA 

Number

Grass Composition 

(%) Forb Composition (%) Shrub Composition (%) Major Concerns

Desired Actual Desired Actual Desired Actual

cky C

LC4 35 40 5 0 60 60

This site is rated as early seral primarily due to the 

lack of production of the perennial grasses, forbs, 

and shrubs. The species composition is acceptable 

for this site type, but the actual production is low. 

LC5 55 79 10 8 35 13

This site is rated as mid-seral primarily due to the 

lack of production of the perennial forbs and shrubs. 

Only one perennial forb was detected. Shrub 

production is below PNC, and the secondary shrub, 

fourwing saltbush, was not detected. 

LC6 50 33 5 23 45 44

This site is rated as early seral primarily due to the 

lack of production of the perennial grasses and 

shrubs. The species composition is acceptable for 

this site type, however actual production is low. 

LC7 50 21 5 30 45 49

This site is rated as early seral primarily due to the 

lack of production of the perennial grasses and 

shrubs. The species composition is acceptable for 

this site type, however actual production is low. 

LC9 50 28 5 45 45 27

This site is rated as early seral primarily due to the 

lack of production of the perennial grasses and 

shrubs. The species composition is acceptable for 

this site type. 

3 Bars Project Final EIS 3-201 October 2016 

 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.2.3.9 North Diamond Allotment 

The Potential Natural Communities for the North Diamond Allotment in the lower elevations consist of alkali 

sacaton, saltgrass, and alkali bluegrass in the poorly drained areas and big sagebrush with an understory of Indian 

ricegrass, bottlebrush squirreltail, and bluegrass in the remainder of the lower elevations. Mid-elevation Potential 

Natural Communities consist of pinyon-juniper communities and the Potential Natural Communities in the higher 

elevations have mountain big sagebrush, antelope bitterbrush, snowberry, serviceberry, and curl-leaf mountain 

mahogany with an understory of bluebunch wheatgrass, various needlegrass species, Indian ricegrass, and bottlebrush 

squirreltail. 

3.12.2.3.10 Santa Fe/Ferguson Allotment 

The Potential Natural Communities for the Santa Fe/Ferguson Allotment consist of Wyoming big sagebrush with an 

understory of Indian ricegrass and needle-and-thread grass, and salt desert scrub dominated by shadscale, Indian 

ricegrass, and squirreltail, and greasewood with alkali sacaton and salt grass at the lower elevations. Black sagebrush, 

with an understory of Indian ricegrass and needle-and-thread grass, is found at the mid-elevations. 

3.12.2.3.11 Shannon Station Allotment

The Potential Natural Communities for the Shannon Station Allotment in the lower elevations consist of alkali 

sacaton, saltgrass, and alkali bluegrass in the poorly drained areas and big sagebrush with an understory of Indian 

ricegrass, bottlebrush squirreltail, and bluegrass in the remainder of the lower elevations. Mid-elevation Potential 

Natural Communities consist of pinyon-juniper communities and the Potential Natural Communities in the higher 

elevations consist of mountain big sagebrush, antelope bitterbrush, snowberry, serviceberry, and curl-leaf mountain 

mahogany with an understory of bluebunch wheatgrass, various needlegrass species, Indian ricegrass, and bottlebrush 

squirreltail. 

3.12.2.3.12 Willows Ranch Allotment 

The Potential Natural Communities for the Willows Ranch Allotment consist of Wyoming big sagebrush with an 

understory of Indian ricegrass and needle-and-thread grass, salt desert scrub dominated by shadscale, Indian ricegrass, 

and squirreltail, greasewood with alkali sacaton and salt grass, and grassland dominated by alkali sacaton, alkali 

cordgrass, Indian ricegrass and three-awn grasses at the lower elevations. Black sagebrush, with an understory of 

Indian ricegrass and needle-and-thread grass, are found at the mid-elevations. 

3.12.2.4 Special Status Plant Species 

No focused special status plant surveys were conducted in support of this project. The BLM Special Status Species 

list for the Battle Mountain District includes 40 plant species that have the potential to occur in the District. A 

USFWS species list (USDOI USFWS 2011) by county was reviewed in support of this analysis. No federally listed 

plants are known to occur in Eureka County and none are expected to occur on the project area. In addition, the BLM 

obtained data from the Nevada Natural Heritage Program (2012) on special status species occurrence on the 3 Bars 

Project area. Information on plant species that may occur within the 3 Bars Project area is provided in Table 3-38. 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 

3 Bars Project Final EIS 3-202 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

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 

community. The only known location with this habitat type within the 3 Bars Project area is Hot Springs Hill north of 

U.S. Highway 50 in the Santa Fe Ferguson Allotment. Of the low elevational riparian treatment areas in Kobeh 

Valley, including Lone Mountain Spring, Mud Spring, and Treasure Well, none have the appropriate characteristics 

for the Monte Neva paintbrush. The USFWS has conducted surveys in the general area of Hot Spring Hill, including 

the three spring areas, and found no evidence of Monte Neva paintbrush (Morefield 1993). 

None of these special status plant species have been found within proposed 3 Bars treatment areas, although one 

mapped occurrence of Beatley buckwheat is within approximately 1,300 feet of the proposed Upper Vinini Creek 

riparian treatment area. Although not mapped within proposed project areas, sensitive species could still occur in 

these areas, since surveys for these species have not been conducted for the 3 Bars project. None of these species were 

found during any of the focused Mount Hope Project special status species plant surveys. 

TABLE 3-38

Special Status Plant Species that may Occur on the 3 Bars Project Area 

3 Bars Project Final EIS 3-203 October 2016 

Common Name Scientific Name Habitat Status1

Beatley buckwheat Eriogonum beatleyae Rock outcrops BLM Sensitive 

and NNHP S2

Lahontan beardtongue Penstemon palmeri var. 

macranthus

Moist washes, roadsides, and 

canyon floors

BLM Sensitive 

and NNHP S2

Least phacelia Phacelia minutissima

Wetlands (including riparian 

zones, aspen stands, and 

sagebrush swales)

BLM Sensitive 

and NNHP S2

Monte Neva paintbrush Castilleja salsuginosa Wetlands and travertine hot 

spring mounds

Nevada 

Critically 

Endangered 

and NNHP S1

Nevada willowherb Epilobium nevadense Pinyon-juniper slopes with 

limestone outcrops or talus

BLM Sensitive 

and NNHP S2

One-leaflet Torrey milkvetch Astragalus calycosus var. 

monophyllidius Sagebrush NNHP S2

1

 Nevada Natural Heritage Program (NNHP) S1 = critically imperiled and especially vulnerable to extinction or extirpation due to 

extreme rarity, imminent threats, or other factors (state rank indicator); NNHP S2 = Imperiled due to rarity or other demonstrable 

factors (state rank indicator). 

Sources: Nevada Natural Heritage Program (2001, 2010, 2012), USDOI BLM (2012b).
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.2.5 Special Woodland Products 

The BLM allows the harvest of Christmas trees and fuel wood from any location within the 3 Bars Project area. For 

commercial users, the BLM would issue a permit for the harvest of Christmas trees or fuel wood and would assign the 

user to a specific area where pinyon-juniper occurs. The public and commercial users may harvest pine nuts and 

native seeds within designated harvest areas, as identified in the Shoshone-Eureka RMP, by permit. The locations of 

allowable harvest areas are shown in Figure 3-30.

3.12.2.5.1 Woodland Products 

Harvested fuel wood includes deadwood (dead branches or wood) and greenwood (living branches or wood). Juniper 

trees are commonly harvested for use as fence posts. The public may harvest fuel wood (green or dead), posts, or 

Christmas trees anywhere on public lands within the 3 Bars Project area, except WSAs, while commercial harvest is 

handled on a case-by-case basis and requires site-specific NEPA documentation and a permit from the Mount Lewis 

Field Office. Juniper posts and other types of greenwood must be harvested within designated harvest units. Species 

approved for commercial and personal harvest include singleleaf pinyon pine and Utah juniper, with permits for a 

limited amount of curl-leaf mountain mahogany also available. The vast majority of woodland product harvest is 

wood cutting by private individuals. 

Commercial wood harvest permits are fairly uncommon in the 3 Bars Project area. Based on data from 1996 through 

2011, the Battle Mountain District issued only 11 commercial harvest permits for cutting within Eureka County. 

During this same period, only one permit for commercial harvest for posts was issued. 

3.12.2.5.2 Christmas Trees 

The public may harvest Christmas trees from most unrestricted public land through permit, while commercial harvest 

is handled on a site-specific basis with site-specific NEPA documentation and requires a permit from the Mount 

Lewis Field Office. The most common species allowed for harvest are singleleaf pinyon pine and Utah juniper. 

Between 1997 and 2010, the Battle Mountain District issued permits to cut between 114 and 402 Christmas trees 

annually. In most years, between 100 and 200 trees were cut within the District. 

3.12.2.5.3 Pine Nuts 

Pine nuts, which are produced by singleleaf pinyon pines, are collected for personal use and commercial purposes. 

Families may collect up to 25 pounds of pine nuts per year without a permit; a permit is required for collection of 

additional nuts. All woodland areas within the 3 Bars Project area are open to the public for harvest of pine nuts 

(Figure 3-30). 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. The amount of commercial pine nut harvest is variable from year to year, 

depending on the yearly crop. The BLM does not have information about harvest of pine nuts by individuals, as a 

permit is not required. Based on data from 1996 through 2011, permits for commercial pine nut harvest were issued in 

fiscal years 1998, 1999, and 2010. A total of six permits were issued for Eureka County over this period. 

3 Bars Project Final EIS 3-204 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-30

Forest Products

(Private Fuelwood, Pine Nuts,

Christmas Trees, and Seed Harvest)

3 Bars Ecosystem and

Landscape Restoration Project

North Simpson

Park Pine

Nut Area

Roberts

Mountain

Pine Nut Area

Whistler/Sulfur

Spring Pine

Nut Area

Whistler/Sulfur

Spring Pine

Nut Area

278

ROBERTS

MOUNTAIN

SIMPSON

PARK

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Trail

Canyon Seed

Harvest Area

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Private Fuelwood and

Christmas Tree Harvest Area

Seed Harvest Area

Commercial Pine Nut Sale Area

Wilderness Study Area

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: AECOM 2011a; BLM 2012i, 2013d,e.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.2.5.4 Seed Harvest 

Commercial harvesters collect seed from plants within the 3 Bars Project area. The project area contains one 

designated harvest unit for commercial seed harvest, Trail Canyon, which is approximately 14,200 acres. Seed harvest 

typically occurs in the late summer to early fall months. The most commonly harvested seeds are from big sagebrush, 

shadscale, four-wing saltbush, Indian ricegrass, and forage kochia. The highest level of demand for native seed 

typically follows catastrophic wildfires in the region, when seed is needed for stabilization and/or restoration of 

impacted areas. 

3.12.2.6 Historic Use of Pinyon-juniper Woodlands 

The production of charcoal and cordwood was one of the area’s most significant industries, and it resulted in 

substantial changes to the environment as it existed before 1850. The furnaces of the Eureka Mining District and 

other mines within the area required tremendous quantities of charcoal. In addition, cordwood and lumber were 

needed for other purposes such as construction. Pinyon-juniper cordwood was also used for fuel by the Eureka & 

Palisade Railroad until 1890, when the railroad switched to coal. Within the 3 Bars Project area, cordwood for the 

Eureka & Palisade Railroad was cut into 4-foot lengths and delivered by contractors to stations along the route 

(Zeier 1985). By far the largest 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. These operations included the 

vast majority of the 3 Bars Project area. 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. From our estimates of wood 

yield, 4,000 to 5,000 acres of woodland had to be cut annually to supply the mills. By 1874 the mountain slopes 

around Eureka were denuded of pinyon and juniper for a radius of twenty miles. By 1878 the average hauling distance 

from (charcoal) pit to smelter was 35 miles. 

Based on a review by Lanner and Frazier (2011), by 1878 the pinyon-juniper forest around Eureka Had been denuded 

to a distance of 50 miles, an area that includes the Roberts Mountains, Simpson Creek Mountains, and Sulphur 

Mountains. By 1887, woodcutters were cutting second-growth timber that was not over 5 inches in diameter. These 

reports indicate that pinyon-juniper woodlands near Eureka and on the 3 Bars Project area were widespread, 

continuous, and dense; there were no comments on scattered-tree savannahs in the area. 

3.12.3 Environmental Consequences 

3.12.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Key issues of concern pertaining to native and non-invasive vegetation types were identified in the AECC and during 

scoping. These include the following: 

 Plant communities that are below their Potential Natural Community and desired vigor. 

 Decline of aspen, mountain mahogany, and other important plant community components resulting from a 

failure of these species to regenerate or establish in historic or new habitats. 

 The need to assess the success of rehabilitation projects after treatments. 

 Too much loss of forested vegetation, based on the BLM’s interpretation of what desired conditions are. 

3 Bars Project Final EIS 3-206 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 Reference is made to “phase class” and “fire regime condition,” but very little discussion was given to 

ecological condition classes within the concept of the range of natural variability, or the place of oldgrowth/persistent pinyon-juniper on the landscape. 

 Loss of mature and old-growth pinyon-juniper in the project area. 

 Reducing stand density and distribution of Utah juniper to benefit pinyon pine. 

 The potential for mechanical disturbance and injury to pinyon pines to promote insects and pathogens. 

 Concerns regarding alteration of the sagebrush and pinyon-juniper communities, as these are suffering from 

past and ongoing disturbances. 

 Concerns regarding the recovery and viability of listed, rare, and imperiled species found on the 3 Bars 

Project area, including special-status plant species. 

 The potential for treatments to cause invasion of weedy species into woodlands, or juniper expansion. 

 Concern regarding the use of exotics, such as crested wheatgrass, to restore burned areas. 

 The need for scientific justification for the desired conditions for woodlands. 

 Concerns about the use of fire in native plant communities and success of past fire management activities. 

 Concern that the typical response to fire is to place a fence, which is often permanent, around the perimeter 

of a burned area. 

 Describe the success of past fire management activities. 

3.12.3.2 Significance Criteria 

The following would have a significant adverse effect on native and non-invasive vegetation: 

 Take of a federally listed plant species or increased mortality of a proposed or candidate plant species. 

 Local extirpation of a rare or sensitive species not currently listed under the Endangered Species Act. 

 Long-term loss or degradation of a unique or high quality plant community. 

 A measurable long-term reduction in diversity within a high quality plant community. 

 An overall decline in woodland health. 

 A reduction in aspen regeneration or recruitment. 

 A long-term reduction in the amount of special woodland products such that harvest of these resources 

would be limited or precluded. 

 A long-term loss of access to woodland resources. 

Analysis for vegetation communities was conducted by overlaying Geographic Information System shapefiles of the 

proposed treatment areas with the baseline data for vegetation types derived from project specific mapping or from 

the ecological site data (USDA Natural Resources Conservation Service 2012) as described above. Temporary and 

permanent impacts were identified and compared to the thresholds established above. 

3 Bars Project Final EIS 3-207 October 2016
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.3.3 Direct and Indirect Effects 

3.12.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Effects 

Vegetation removal treatments can create conditions that result in a temporary loss of some desirable or more mature 

vegetation through inadvertent removal of non-target vegetation. Removal of target and non-target vegetation could 

also cause soil disturbance that favors the introduction and spread of noxious weeds and other invasive non-native 

vegetation, to the detriment of native species. The BLM would implement vegetation treatments to thin and remove 

pinyon-juniper. Removal of pinyon-juniper could reduce the amount of pine nuts, wood, and other woodland products 

available for commercial and individual harvest. Thinning and removal of pinyon-juniper also would result in dead 

wood and slash material that, if not removed, mulched, or burned, could provide fuel for a wildfire. 

The locations of prime farmlands within the 3 Bars Project area are shown on Figure 3-31. There are no prime 

farmlands on BLM-administered land within the treatment areas because the BLM does not allow for irrigation on 

public land. Aspen treatments should not impact prime farmland because only a small area would be treated. Pinyonjuniper treatments could affect the prime farmland along Coils Creek from pinyon-juniper treatments in Dry Canyon 

and Cottonwood/Meadow Creek. Prime farmland along Denay Creek could be affected by the Tonkin North and 

South Units pinyon-juniper treatments. Prime farmland could also be affected by the Henderson 1 and Roberts Creek 

units riparian treatments, the Vinini Corridor, Upper Roberts, and Atlas Units pinyon-juniper treatments, and Table 

Mountain Unit sagebrush treatment. Effects of the treatments, if any, would primarily be related to short-term erosion 

and its effects on water quality that could result from upland and riparian zone treatments. 

Beneficial Effects 

All proposed treatments or combinations of treatments are designed to enhance native plant (re)establishment, and 

therefore would be expected to have a beneficial impact on native vegetation by increasing the extent of native plant 

communities in the project area. Treatments that benefit native plant communities could potentially provide habitat 

that is more suitable for rare and sensitive plant species. Treatments would result in improved health and vigor of 

riparian, aspen, and sagebrush communities. As treatments restore the functionality of the ecosystem, the system 

would become more resistant to invasion by noxious weeds and other invasive non-native vegetation, drought, and 

wildfire. As the health of the system improves, native species would make greater contributions to the health and 

recovery of the system and serve as an important seed source for areas adjacent to treatment sites. Over time, this 

would allow the 3 Bars Project area to recover from past disturbances. 

The degree of the benefit provided by project treatments would depend on how effective the treatment is at 

controlling the target species and/or enhancing desired vegetation. In some cases, a combination of methods (such as 

mechanical methods to remove the species followed by fire to reduce the seedbank) may be required to effectively 

control the target species and manage native vegetation over the long-term. Small, temporary exclosure fencing may 

also be required, to protect native plant communities until desirable vegetation has established. Therefore, while some 

benefit is expected under all the treatments, the level of benefit is expected to vary by alternative, as some methods 

are more effective than others, and some of the alternatives allow for application of a wider variety of tools and for 

treatment of much larger areas. More discussion of the effectiveness of the various treatment methods is provided in 

the 17-States PER (USDOI BLM 2007c:2-12 to 2-19). 

3 Bars Project Final EIS 3-208 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-31

Farmland Classification

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Farmland Classification

Prime Farmland if Irrigated

Prime Farmland if Irrigated

and Reclaimed of Excess

Salts and Sodium

Farmland of Statewide Importance

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: USDA NRCS 2012.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

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 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. In pinyon-juniper habitats, 

wildfires tend to kill all pinyon pines and junipers that are burned, regardless of size (Romme et al. 2007). Pinyonjuniper sites that are dominated by trees have a large component of canopy fuels and reduced ground fuels as a result 

of a reduced shrub layer. This fuel distribution promotes infrequent, high intensity fires over more frequent and 

moderate fires (Miller et al. 2008). The reduced risk would benefit Phase III woodlands with a dominance of canopy 

fuels, many of which occur on soil types that historically supported pinyon-juniper and may have a component of old 

growth pinyon-juniper. A large fire would be expected to result in loss of sagebrush and pinyon-juniper woodlands 

over a large geographic area, potentially including old-growth trees and persistent woodland stands. Reduced 

catastrophic wildfire risk would also benefit woodland products associated with pinyon-juniper communities. 

Reduced densities of trees could lead to improved health of treated stands by reducing competition, promoting 

regeneration, and decreasing the risk of infestation by pathogens and insects (Marcus et al. 2011). High tree densities 

appear to contribute to pinyon Ips and mistletoe, which may be the result of resource limitation and close proximity of 

trees, although site condition may be the most important factor (Greenwood 2006). Additionally, treatments that 

target pinyon-junipers infested with pathogens and pests in the North and South Tonkin units would help improve the 

health of these stands. 

Thinning pinyon-juniper woodlands would be expected to benefit pine nut production by reducing the spacing 

between trees. Space between trees allows the crowns of pinyon pines to develop fully, which typically results in 

more pine nut production (USDOI BLM and Colorado Wood Utilization and Marketing Program 2008). Additionally, 

fuels reduction treatments would decrease the risk of a wildfire burning pinyon pines that bear harvestable pine nuts. 

Long-term, treatments should benefit nearby prime farmlands by reducing upslope erosion and risk of a severe 

wildfire. 

3.12.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Adverse Effects 

Project activities have the potential to disturb vegetation at treatment sites, and therefore could result in the temporary 

loss of riparian and wetland vegetation. Mechanical treatments typically result in widespread soil disturbance in 

treated areas, as discussed in Section 3.9.3 of this EIS and in the 17-States PER (USDOI BLM 2007c:2-14). 

Machinery used in mechanical treatments could result in inadvertent removal of native vegetation. The risks for loss 

and damage to riparian and wetland vegetation would be greatest in project groups with the largest acreage and that 

employ the most extensive mechanical treatments (project groups that include streambank earthwork as well as 

pinyon-juniper removal—Frazier Creek Group and Garden Spring Group). To minimize these effects, chainsaw 

thinning would be the preferred method for cut pinyon-juniper in riparian treatment areas. For the Denay Pond group, 

the disturbance associated with mechanical treatments would be minimal, since only fence installation would occur. 

3 Bars Project Final EIS 3-210 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Riparian treatments are proposed to occur in areas identified as harvest units for Christmas trees, greenwood, and pine 

nuts. Within riparian treatment areas, only pinyon-juniper removal would be expected to affect woodland products. 

Pinyon-juniper removal would occur over a very small portion (less than 1 percent) of designated harvest areas for 

Christmas trees, pine nuts, and green wood (shown in Figure 3-30). These treatments would affect a fraction of a 

percent of the total woodland products harvest acreage within the 3 Bars Project area, and would not constitute a 

measurable reduction in special woodland products available for harvest. 

Ground-disturbing activities could impact special status plant species, if any are present in the proposed riparian 

treatment areas. No federally listed plant species are known or likely to occur in treatment areas, but several BLM 

Special Status Species could potentially occur in wetland and riparian zones within the project area. BLM policy 

requires the Mount Lewis Field Office to survey treatment sites for listed and other special status species prior to 

conducting ground-disturbing activities. Pre-treatment surveys would allow the BLM to avoid or minimize impacts to 

these species when implementing project treatments. 

Beneficial Effects 

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. 

Pinyon-juniper would be removed from the riparian zone for treatment areas within the Frazier Creek and Garden 

Spring groups using manual and mechanical methods and prescribed fire. The total treatment area involving pinyonjuniper removal would be approximately 2,682 acres, although removal of pinyon-juniper would not occur over this 

entire area. Treatments would target pinyon-juniper where it is encroaching into sagebrush habitat along riparian 

zones (Phase I - 769 acres and Phase II – 524 acres), but riparian management treatments would also occur along 

streams in areas dominated by Phase III pinyon-juniper (296 acres). Treatments targeting pinyon-juniper would result 

in the loss of these woodland species. However, these treatments would benefit riparian vegetation. 

Removal of pinyon-juniper in Phase II and III stands could provide trees for greenwood cutting. Use of fire and 

mechanical methods to thin and remove pinyon-juniper in Phase II and III stands should improve riparian zone health 

and functionality. 

Aspen Treatments 

Adverse Effects 

The effects associated with manual treatments would be low in aspen treatment areas, since a minimal amount of soil 

disturbance would occur. Standard Operating Procedures would be implemented to prevent the spread and 

establishment of noxious weeds and other invasive non-native vegetation, and slash would be left onsite to promote 

seedling and sapling establishment and to promote infiltration. There could be loss of non-target vegetation. 

As noted by Kay (2003), while fire usually has a beneficial effect on aspen by stimulating root suckering and killing 

invading conifers, the condition and trend of aspen in north central Nevada, in general, is not related to the absence of 

fire. 

3 Bars Project Final EIS 3-211 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

Ground-disturbing activities could impact special status plant species, if any are present in the proposed aspen 

treatment areas. No federally listed plant species are known or likely to occur in the project area, but several BLM 

Special Status species could potentially occur within aspen treatment units within the project area. BLM policy 

requires the Mount Lewis Field Office to survey treatment sites for listed and other special status species prior to 

conducting ground disturbing activities. Pre-treatment surveys would allow the BLM to avoid or minimize impacts to 

these species when implementing project treatments. 

Beneficial Effects 

Mechanical methods would promote aspen suckering through hormonal stimulation. Treatment of aspen stands with 

mechanical treatment is expected to enhance the rejuvenation of existing stands and would result in an expansion of 

the total area occupied by aspen stands and increased vigor of stands in comparison to current conditions. In some 

cases, mechanical methods would be used to remove pinyon-juniper to reduce competition for resources. Cutting trees 

and ripping the root mass stimulates sprouting, which is a much more reliable and cost-effective method of 

regenerating aspen than planting seedlings or encouraging natural reseeding. 

Removal of pinyon-juniper trees in aspen stands has the potential to result in damage or disturbance to existing aspen. 

However, aspen are known to respond well to disturbance, which stimulates suckering and treatment/cutting of 

mature trees is part of proposed treatments in some projects, such as RMA-5, JD A-1, and TB-A. 

Removal of conifers would allow sunlight to reach the woodland floor and warm the soil, thereby stimulating aspen 

sprouting, and could also create conditions that allow aspen to expand into surrounding areas. In mixed aspen-conifer 

stands, mechanical treatments may be an effective means of regenerating aspen, by providing hormonal stimulation 

and reducing competition (Sheppard 2008). 

Protective fencing that reduces herbivory would benefit areas that contain aspen sprouts. Studies have suggested that 

the downward trend in aspen communities in north-central Nevada, including the 3 Bars Project area, is not related to 

climatic variation, fire suppression, woodland succession, or browsing by mule deer, but is related to past and present 

levels of livestock grazing (Kay 2002, 2003). Fencing the aspen stand would protect aspen sprouts, thus allowing the 

aspen stand to regenerate and form multi-aged stands without using fire or other disturbance. 

Pinyon-juniper Treatments 

Adverse Effects 

Potential adverse effects associated with manual treatments in pinyon-juniper habitats are discussed in the 17-States 

PER (USDOI BLM 2007c:4-49). These treatments could result in small amounts of trampling or accidental removal 

of non-target plants. Additionally, there would be minor risks associated with spills of oil and fuels from hand-held 

equipment. The overall effects to native communities would be minimal and short-term in duration. Use of manual 

methods would allow the BLM to avoid old-growth trees during treatments, and would cause minimal soil 

disturbance and associated risks for establishment and spread of noxious weeds and other non-native invasive species. 

However, increased light availability on the site and shading of desirable understory plants by heavy slash could 

provide conditions that favor invasive species (Tausch et al. 2009). Slash piles could lead to the infestation of healthy 

trees by Ips beetles if placed too close to the base of trees (Marcus et al. 2011). Additionally, the understory response 

following treatments may be delayed by several years, and slash left behind on site would have the potential to 

increase fuel loads and create a fire hazard for a minimum of 2 years (Tausch et al. 2009). Chainsaw cutting in juniper 

woodlands has been correlated with increased shrub and grass cover, which may include at least an initial increased 

3 Bars Project Final EIS 3-212 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

cover of cheatgrass on sites where a seed source for this species is present (Miller et al. 2005). Fire risks associated 

with slash would be mitigated to some degree by associated programs to use felled trees for posts, mulch, or other 

uses, and following manual treatments with pile and slash burning. 

Potential adverse effects associated with mechanical treatments are discussed briefly in the 17-States PER (USDOI 

BLM 2007c:4-47). Most pinyon-juniper would be removed using mechanical methods and prescribed fire and 

wildland fire for resource benefit. Mechanical treatments are often used to reduce tree dominance in Phase II and III 

woodlands, but could also be used with chainsaws in Phase I stands if the equipment does not harm the sagebrush 

community. However, mechanical treatments may stimulate understory shrub vegetation, to the detriment of forbs 

and grasses (see review in Jones et al. 2012), and making seedbed preparation and sowing difficult when the site 

requires revegetation (Tausch et al. 2009). In some cases, non-native species might be used in order to prevent 

cheatgrass establishment and spread. Mechanical treatments can result in substantial soil disturbance that favors 

noxious weeds and other invasive non-native species, as discussed for riparian treatments, or less desirable native 

species (Jones et al. 2012). However, when mechanical treatments are applied in combination with seeding, the 

associated soil disturbance can increase the establishment and success of seeded species (Miller et al. 2005). Heavy 

equipment could also impact desirable understory vegetation (Tausch et al. 2009) including special status species, and 

contribute to soil erosion and compaction (Miller et al. 2005). While mechanical treatments can be used on stands of 

trees, they can also be used on individual trees, allowing old-growth trees to be avoided. Generation of slash and 

associated fire risks would be similar to those discussed for manual treatments, although more slash is likely to be 

generated using mechanical methods. Large amounts of slash in late Phase II and Phase III stands and could create a 

fire hazard for a minimum of 2 years and could limit the mobility of domestic and wild large herbivores (Tausch et al. 

2009). In some areas, the creation of fire and fuel breaks could also lead to noxious weeds and other invasive nonnative vegetation establishment and spread. 

Mechanical treatments such as shredding generally increase herbaceous biomass, but this improvement in forb and 

grass cover may disappear after about 25 years as pinyon-juniper reestablishes on the site (Tausch and Hood 2007). 

Lanner and Frazier (2011) suggested that it may be futile to remove pinyon-juniper from the landscape, given their 

recovery from deforestation during the mining area. Use of mechanical equipment can also be limited by terrain 

(Miller et al. 2005), and as discussed under Soil Resources (Section 3.9), much of the area targeted for pinyon-juniper 

management is not suitable for shredding because of steep slopes and other factors. Shredding 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, shredding would likely be used on a limited basis in the 3 Bars Project area. 

The BLM would utilize fire as one means of removing and thinning pinyon-juniper from treatment sites, especially on 

areas with steep slopes or where stand replacement is desired. Prescribed fire could be used as a treatment tool in 

nearly all of the proposed treatment areas. Prescribed fire could be used on several thousand acres annually, although 

prescribed fires and wildland fire for resource benefit use would generally be limited to less than 1,000 acres at any 

one time. In addition, the BLM would utilize wildland fire for resource benefit in the Sulphur Spring Wildfire 

Management Unit. In this unit, the BLM would allow a wildfire to burn in areas where natural fire would benefit 

multiple resources and fuel loads exceed 2 tons per acre in shrublands and 10 tons per acre in pinyon-juniper 

woodlands, with individual fire size not to exceed 1,000 acres. The general effects of fire on pinyon-juniper 

woodlands are discussed in the 17-States PER (USDOI BLM 2007c:4-37 to 4-40). These include a short-term 

decrease in desirable vegetation and increase in noxious weeds and other invasive non-native vegetation. 

3 Bars Project Final EIS 3-213 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

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, 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). In addition, Bauer and 

Weisberg (2009) noted that there is little ecological justification for reintroducing fire to areas of persistent (historic) 

woodland, at least within the context of restoring natural fire regimes, because these areas may not have experienced 

the effects of fire exclusion. This may be especially true given that these areas were likely deforested during the 

mining era in the late 1800s. 

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. 

Treatments in the Sulphur Spring Wildfire Management Unit would restore fire as an integral part of the ecosystem 

and improve plant species diversity. By reducing fuel accumulations and creating canopy openings in the pinyonjuniper, sagebrush and other shrub species and forbs and grasses should increase. Re-introduction of fire is preferred 

to non-fire treatments for habitat restoration, where feasible. Although wildland fire for resource benefit would have a 

substantial impact on wildlife and their habitat in both the short and long-term, controlling pinyon-juniper without 

the re-introduction of periodic fire (such as cutting western juniper trees), despite providing ecological and 

hydrologic benefits, may not result in full restoration. The underlying proximate cause of pinyon-juniper 

expansion, the absence of periodic fire, would remain. Eventually, especially if pinyon-juniper is nearby, and if 

other conditions remain the same, the site would be invaded again and pinyon-juniper problems would re-emerge 

(Kerr and Salvo 2007).

Regardless of the cause of the fires in pinyon-juniper habitat, 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. 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, completed through a separate process. The BLM may also use small, 

temporary exclosure 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 (USDOI BLM 2009d, e, 

2010e, f, g, h, i, j, 2011e, f).

3 Bars Project Final EIS 3-214 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

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 non-native 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 2012g). 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 3.13.3.3). 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 and 

mixed-aged stands of pinyon-juniper. 

Vegetation succession after fire would also vary depending on the canopy cover and site conditions. While regrowth 

of native understory species is rapid and vigorous when the canopy cover is relatively open, poorer native regrowth 

would be expected on sites with fewer understory plants and a depleted seed bank. On these sites, reseeding and/or a 

combination of treatment types would be necessary. 

Pinyon-juniper enhancement projects would occur within designated harvest units for woodland products. There is a 

large degree of overlap between harvest units and pinyon-juniper treatment areas. Trees would be removed from these 

areas, although not over the entire area. As a result of thinning treatments, the number of pinyon-juniper trees within 

harvest areas would be reduced, although woodland products would still be available over portions of treatment areas. 

Treatments would affect approximately 26 percent of the total designated woodland products harvest area. Removal 

of pinyon pines and juniper from these areas would eliminate or limit the ability to harvest woodland products there. 

Ground-disturbing activities could impact special status plant species, if any are present in the proposed pinyonjuniper treatment areas. No federally listed plant species are known or likely to occur in the project area, but several 

BLM Sensitive Species could potentially occur within pinyon-juniper treatment units within the project area (Table 

3-38). BLM policy requires the Mount Lewis Field Office to survey treatment sites for listed and other special status 

species prior to ground-disturbing activities. Pre-treatment surveys would allow the BLM to avoid or minimize 

impacts to these species when implementing project treatments. 

Beneficial Effects 

Selective cutting by the BLM or public (greenwood cutting) using chainsaws would remove trees throughout the 

designated units with minimal effects on other vegetation. Some debris would be left on-site following selective 

cutting treatments. In dense stands, large amounts of debris would be piled and burned on-site. Burning piles on-site 

would remove the large volumes of fuel from the site, reducing the threat of a large-scale stand replacing fire. 

Mechanical treatments, such as mulching and shredding, would be done on tree-dominated sites that have sufficient 

desired understory vegetation. The advantages of mechanical removal of trees include flexibility in timing of the 

treatment application and the ability to precisely control treatment boundaries or targeted trees. For example, oldgrowth trees can be better protected if manual or mechanical methods are used than if fire is used (Tausch et al. 2009). 

Residual woody vegetation would be left on-site and would consist of slash/wood chips created from shredders. 

Wood chips scattered across the site would allow for increased infiltration and water retention and decreased soil 

erosion. When compared to the bare soils under closed canopy woodlands, shredding treatments would increase water 

retention, infiltration, seedling protection, and establishment. The decomposition of woody plant material should also 

improve soil nutrient content that could enhance seedling recruitment and establishment and the long-term viability of 

the grass and shrub community, as well as provide protection to the soil resource (Brockway et al. 2002, USDOI 

BLM 2012g).

3 Bars Project Final EIS 3-215 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

This treatment method would alter vegetation communities on the site and would favor grasses and forbs over shrubs 

and trees. Reduced competition and ground disturbance may allow native seed banks to aid in the reestablishment of 

native species. Areas to be treated with this method would consist of tree dominated areas with little desired 

understory vegetation. 

While pinyon-juniper can be controlled without the use of prescribed fire or wildland fire for resource benefit, nonfire 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. 

Treatments to reduce hazardous fuels, increase canopy spacing among pinyon-juniper, remove diseased trees, remove 

encroaching pinyon-juniper, and create fire and fuel breaks would help to reduce wildfire risk to the benefit of native 

vegetation. Monitoring at the Red Hills hazardous fuels reduction site has shown that the risk of wildfire was reduced 

from a “very high to extreme” risk to “low” risk at 35 monitoring sites, and “low to moderate” risk at 5 sites, after 3 

years. A variety of desirable forbs, grasses, and shrubs were observed re-colonizing treatment areas, and fuel breaks 

were still viable (USDOI BLM 2008i). 

The BLM would restore fire as an integral part of the ecosystem, improve species diversity, and reduce hazardous 

fuels on the Sulphur Spring Wildfire Management Unit by using wildland fire for resource benefit. The BLM would 

allow fire to burn on about 20 to 40 percent of the area, but generally burns would be limited to small acreages to 

create a mosaic of habitats and to create fuel breaks. By keeping burned areas small, the risk of a cheatgrass 

infestation would be much less. Several wildfires have occurred in this area in recent years due to dense fuel 

accumulations and pinyon-juniper 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 cover should increase, a more natural fire 

regime would be restored in the area, and the risk of future wildfires would be diminished. Both prescribed fire and

wildland fire for resource benefit could be used year-round, although prescribed fire treatments tend to be conducted 

during fall through spring and outside of the migratory bird breeding season. 

A large amount of downed logs and woody debris would result from pinyon-juniper management and could be used 

for firewood. By thinning and removing pinyon-juniper, competition among remaining trees for water and other 

resources would decline, stand health would improve through reduced competition, and the remaining pinyon pines 

should be able to produce more nuts. 

Sagebrush Treatments 

Of the treatments in pinyon-juniper-dominated communities, about 75 percent would occur in Phase I stands. 

Therefore, the vast majority of project treatments would occur in areas that support, or have supported, sagebrush, and 

areas where pinyon-juniper encroachment into the sagebrush community is occurring. The BLM would treat up to 50 

percent of the unit in units dominated by non-native vegetation in an effort to restore native species in areas of historic 

3 Bars Project Final EIS 3-216 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

importance to Greater sage-grouse. The BLM would only use native species when overseeding sagebrush 

communities. 

Adverse Effects 

Projects to reduce non-native vegetation dominance (Rocky Hills Unit), 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. 

Other sagebrush projects (Table Mountain, Three Corners, and Whistler Sage units) would involve removal of Phase I 

and II pinyon pine and juniper from sagebrush habitats. These treatments would have an adverse effect on pinyonjuniper woodlands by reducing the overall cover of this habitat type. The goal of most of these treatments would be to 

restore sagebrush habitat in areas where sagebrush should occur based on ecological site description reference, 

desired state, or management objective. The long-term result of the treatments would be a reduction in pinyon-juniper 

and an increase in sagebrush. However, if the treatments do not continue indefinitely, it is likely that over time, 

pinyon-juniper would once again expand into sagebrush habitats. 

Manual and mechanical treatments would have the potential to disturb sagebrush habitats, with potential impacts 

similar to those discussed for other community types. Ground disturbance associated with mechanical treatments 

would occur in all of the sagebrush project areas. These treatments could potentially result in trampling and 

inadvertent removal of non-target plants, as well as soil disturbance that could favor the establishment and spread of 

cheatgrass and other noxious weeds and other invasive non-native vegetation. The greatest risk for adverse effects 

would occur where the largest ground areas are disturbed, and where weed seeds are already present. 

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 nonnative 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 sagebrush 

habitat. The proposed treatments would affect a relatively small portion (5 percent) of the total designated woodland 

product harvest area. This reduction in woodland product species would continue for as long as the BLM continued 

treatments to slow or reverse the encroachment of pinyon-juniper into sagebrush. 

Ground-disturbing activities could impact special status plant species, if any are present in the proposed sagebrush 

treatment areas. No federally listed plant species are known or likely to occur in the project area, but several BLM 

Sensitive Species could potentially occur within sagebrush treatment units within the project area (Table 3-38). BLM 

policy requires the Mount Lewis Field Office to survey treatment sites for listed and other special status species prior 

to ground disturbing activities. Pre-treatment surveys would allow the BLM to avoid or minimize impacts to these 

species when implementing project treatments. 

3 Bars Project Final EIS 3-217 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

Beneficial Effects 

The purpose of mechanical treatments would be to remove pinyon-juniper and noxious weeds and other invasive nonnative vegetation, and for seeding and planting. The BLM would minimize soil disturbance as much as possible to 

reduce the potential for noxious weed and other invasive non-native vegetation establishment. 

Pinyon-juniper removal projects at the Table Mountain, Three Corners, and Whistler Sage units would likely have a 

beneficial effect on sagebrush habitats. Woodland encroachment into sagebrush communities can reduce the structural 

complexity of these communities, decrease the seed bank, and reduce fuels and the role of fire, such that tree 

recruitment is favored, and increase surface runoff and erosion (Miller et al. 2005 cited in Pierson et al. 2008). 

Therefore, removal of trees from these habitats would likely improve the quality of sagebrush habitats. 

Prescribed fire, along with broadcast seeding, could be used in the West Simpson Park Unit to control cheatgrass. Fire 

use would be followed by broadcast seeding, drill seeding, or hand plantings in an effort to re-establish native shrub 

and herbaceous species within an historic Greater sage-grouse area. 

A limited amount of downed logs and woody debris would result from sagebrush treatments and could be used for 

firewood. Down trees could be made available for commercial woodcutting and other forest products use, although it 

is unlikely that these uses would occur on the project area. 

3.12.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Under this alternative, the total acreage treated would be approximately half that of Alternative A. Effects to native 

plants and natural plant communities from mechanical methods would be similar to those under Alternative A, as 

similar amounts of mechanical treatments would likely be used. 

Given that fire would not be used under this alternative, treatment programs might not be as effective as under 

Alternative A. Phase I and II pinyon-juniper woodlands would be targeted for treatments. Treatment programs would 

not include fire or a combination of fire and other methods, and they might not be as effective at meeting project 

objectives as under Alternative A. It would be difficult for the BLM to conduct pinyon-juniper and noxious weeds 

and other invasive non-native vegetation treatments on hillslopes, or over large acreages, using mechanical methods, 

where fire use treatments would be effective. Loss of pinyon-juniper and associated increase in sagebrush would be 

less than under Alternative A, as less acreage would be treated. The acreage of persistent woodlands and sagebrush 

habitats benefiting from treatments would be less than under Alternative A. Since treatment of Phase III woodlands 

would be minimal, these areas, which have the greatest risk for loss from high intensity fires, would remain at a high 

risk under this alternative. 

More acres would be available for commercial and individual harvest of woodland products under Alternative B than 

under Alternative A. Some treatments to improve historic pinyon-juniper communities would occur, which could 

benefit future pine nut harvest in these areas, but the acreage benefiting from these treatments would be substantially 

lower than under Alternative A. Additionally the risk that a wildfire would burn large areas of woodland products 

would be greater under this alternative than under Alternative A. 

Under Alternative B, it is unlikely that the BLM restore fire as an integral part of the ecosystem and reduce extreme, 

very high, and high wildfire risks to moderate risk or less. As a result, it is likely that the amount of area meeting 

Potential Natural Community objectives would be less than would occur under Alternative A. 

3 Bars Project Final EIS 3-218 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.12.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Given that fire, mechanical methods, and livestock grazing would not be used under this alternative, the BLM would 

have the fewest options for its treatment programs, and these programs would likely not be as effective as under the 

other alternatives. The BLM would be unable to combine treatment methods for optimal control of certain species and 

for enhancement of native plant communities. Additionally, removal of fuel hazards would be least under this action 

alternative, and the risk of catastrophic wildfire would be greatest. Because this alternative is the most limited in terms 

of the tools available for large scale restoration, it is the least likely of the action alternatives to help attain larger 

ecosystem restoration goals for the 3 Bars Project area. 

Under this alternative, only manual methods would be used to treat vegetation. Pinyon-juniper would be removed 

using chainsaws. Risks to non-target vegetation from treatments would be least under this alternative. Phase I 

woodlands and a limited acreage of Phase II woodlands would be targeted for treatments. As all treatments would be 

manual, their effectiveness would likely be lower than under the other alternatives. Additionally, the BLM would not 

be able to slash and pile burn following treatments to reduce the short-term fire hazard, although programs to use 

felled trees for posts, mulch, and other forest products uses would help minimize the fire risk. Loss of pinyon-juniper 

and the associated increase in sagebrush would be less than under Alternatives A and B. The acreage of persistent 

woodlands and sagebrush habitats also benefiting from treatments would be less than under Alternatives A and B. 

Since Phase III woodlands likely would not be treated, these areas, which have the greatest risk for loss from high 

intensity fires, would remain at a high risk under this alternative. 

Acres available for commercial and individual harvest of woodland products would be greater than under Alternatives 

A and B, based on the amount of area treated. Treatments to improve historic pinyon-juniper habitats would be 

limited under this alternative. The risk that a wildfire would burn large areas of woodland products available for 

harvest would be greater than under Alternatives A and B. Long-term benefits to woodland products would be less 

under this alternative than under Alternatives A and B. 

As under Alternative C, it is unlikely that the BLM would restore fire as an integral part of the ecosystem; or reduce 

extreme, very high, and high wildfire risks to moderate risk or less or be able to increase the presence of native shrubs 

and herbaceous species in areas dominated by crested wheatgrass and forage kochia. In addition, the BLM would 

make little or no contribution toward developing fire and fuel breaks or reducing the risk of a large-scale wildfire 

under Alternative C. As a result, it is likely that the amount of area meeting Potential Natural Community objectives 

would be less than would occur under Alternatives A and B. 

3.12.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct impacts to native and non-invasive vegetation from 3 Bars Project treatments as no 

treatments would be authorized under this alternative. Under this alternative, the BLM would not create fire and fuel 

breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; treat large-scale infestations of noxious 

weeds and other invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the 

ecosystem; or reduce the risk of a large-scale wildfire. Threats to ecosystem health under this alternative would 

include the continued decline of ecosystem health due to further decline in native understory species in the upland 

plant communities: further expansion of pinyon-juniper woodland into other communities, including sagebrush, 

riparian, and aspen habitats; and the continued increase of the risk for catastrophic wildfire as a result of high fuel 

loads. Given the low acreage treated annually (about 1,500 acres), there would be little or no improvement in the 

amount of acreage in Proper Functioning Condition. 

3 Bars Project Final EIS 3-219 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.3.4 Cumulative Effects 

The CESA for native and non-invasive vegetation resources is approximately 1,841,698 million acres and includes 

those watersheds at the Hydrologic Unit Code 10 level that are all or partially within the 3 Bars Project area (Figure 

3-1). Past and present actions that have influenced native and non-invasive vegetation activity in the 3 Bars ecosystem 

are discussed in Section 3.3.2.3.3.

3.12.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

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. 

In the short-term, small, temporary exclosure fences may change the distribution of grazing by livestock, wild horses, 

and some wildlife. As distribution patterns change, utilization would also change. Wildlife and wild horse utilization 

would decrease in treatment areas while temporary exclosure fences are in place, but would increase in other areas. 

Once the temporary exclosure fences are removed, wild horses and wildlife may be attracted to the treatment areas 

resulting in potentially higher use of the area than before. Temporary exclosure fences would exclude livestock, 

although AUMs may be temporarily suspended to prevent overuse in other areas. 

According to utilization data, about 6 percent of the 3 Bars Project area is experiencing moderate to severe forage 

utilization (see Section 3.18.3). However, about 35 percent of proposed riparian zone treatment areas, 25 percent of 

pinyon-juniper treatment areas, and 48 percent of sagebrush treatment areas are experiencing moderate to severe 

forage utilization. In addition, about 1,600 acres within the Simpson Park Northeast Unit are experiencing moderate to 

severe forage utilization, although only about 150 acres would be treated within this unit. 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and aerial-based application methods to remove cheatgrass, and would restore burned areas 

under the Burned Area Emergency Stabilization and Rehabilitation program, under existing authorizations on about 

1,000 acres annually. These treatments could have a short-term adverse effect on non-target vegetation. These 

treatments would have long-term beneficial effects by helping to reduce hazardous fuels, improve native vegetation, 

slow the spread of noxious weeds and other invasive non-native vegetation, and reduce surface runoff and erosion 

associated with burn sites.

All of the formulations of herbicide active ingredients would have the potential to adversely affect non-target 

vegetation under one or more exposure scenarios. The assessment completed for the 17-States PEIS found that the 

most likely mode of impact to non-target plants is via spray drift, particularly for aerial applications, and accidental 

exposure scenarios, such as a spill (USDOI BLM 2007b:4-44). 

Land development, mineral development, and oil, gas, and hydrothermal exploration and development could affect 

about 15,000 acres in the CESA in the reasonably foreseeable future, including about 8,335 acres of disturbance 

associated with the Mount Hope Project, and from materials sites, roads, and rights-of-way for roads, pipelines, and 

power and telephone lines. Although some of the disturbance areas from these projects would be reclaimed, these 

activities would lead to long-term losses in native plant communities in the affected areas. No federally listed plant 

3 Bars Project Final EIS 3-220 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

species are known or likely to occur in the CESA, but several BLM Sensitive Species occur within the CESA and 

could be impacted by reasonably foreseeable future actions under Alternative A. 

An estimated 140,000 acres would be burned by wildfire within the CESA within the next 20 years, based on wildfire 

incidence since 1985. Wildfire could cause the wide-scale removal of vegetation in the CESA. Wildfires that are not 

reseeded would return to early-successional conditions and would be left to recover naturally. In the absence of 

invasive species, the site may successfully revegetate if perennial grasses survive the fire, otherwise it would be 

necessary to reseed and control the invasive species with herbicide treatments to rehabilitate the site. Areas with intact 

plant communities would be more resilient to wildfire and may retain functionality of ecosystem processes. Areas 

with degraded plant communities may benefit from wildfire and the subsequent reseeding and herbicide treatments to 

restore functionality of ecosystem processes. 

Short-term, there would be loss of vegetation, particularly pinyon-juniper and non-native vegetation, and there could 

be an increase in noxious weeds and other invasive non-native vegetation. Long-term, these treatments should result 

in vegetation that is more fire resilient, more abundant, and similar to the Potential Natural Community. Hazardous 

fuels and other habitat improvement treatments would occur on about 127,000 acres within the 3 Bars Project area, 

and on an additional 15,000 acres within other portions of the CESA under existing and future authorizations, or 

about 8 percent of the CESA. Noxious weed and other non-native vegetation treatments would remove vegetation that 

contributes to short return-interval fires and the loss of native vegetation. These treatments would help to reduce the 

risk of wildfire within the CESA. In addition, the BLM would conduct stream bioengineering and plantings on about 

31 miles of stream to slow stream flow and create pools and wet meadows, to improve wetland and riparian 

vegetation and water flows and quality. Overall, there would be a net beneficial accumulation of effects from BLM 

treatments and treated areas would move toward their Potential Natural Community. These benefits would be greatest 

under Alternative A. 

3.12.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on vegetation would be 

similar to those described under Alternative A. Under Alternative B, the inability to use prescribed and wildland fire 

for resource benefit would restrict BLM’s ability to reduce wildfire risk, restore natural fire regimes, and influence 

vegetation communities on a large scale within the 3 Bars Project area. Prescribed fire would be limited to a few 

hundred acres annually in other portions of the CESA outside the 3 Bars Project treatment area based on previous 

authorizations. 

Short-term, there would be disturbance to and loss of vegetation, particularly pinyon-juniper and non-native 

vegetation, and there could be an increase in noxious weeds and other invasive non-native vegetation. Long-term, 

these treatments should result in vegetation that is more fire resilient, more abundant, and similar to the Potential 

Natural Community. Hazardous fuels and other habitat improvement treatments would occur on about 63,000 acres 

within the 3 Bars Project area, and on an additional 15,000 acres within other portions of the CESA under existing 

and future authorizations, or about 4 percent of the CESA. These treatments would help to reduce the risk of wildfire 

within the CESA. Overall, there would be a net beneficial accumulation of effects from BLM treatments and treated 

areas would move toward their Potential Natural Community. However, because the BLM would treat fewer acres, 

and would not be able to use fire, benefits to vegetation would be less under Alternative B than under Alternative A. 

3 Bars Project Final EIS 3-221 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on native and noninvasive vegetation would be similar to those described under Alternative A. Under Alternative C, the BLM would 

only be able to use manual and classical biological control methods to treat vegetation. As a result, the BLM 

anticipates treating about one-fourth as many acres under Alternative C as under Alternative A. These methods would 

cause little vegetation and soil disturbance and would also give the BLM greater control on the types and amount of 

vegetation that are removed. 

By not being able to use mechanical methods and fire to improve the health and resiliency of native vegetation, 

reduce hazardous fuels, create fire and fuel breaks, and remove downed wood and slash, the risk of wildfire and its 

impacts on vegetation would likely increase on the 3 Bars Project area. 

Hazardous fuels reduction and habitat improvement projects could occur on about 32,000 acres within the 3 Bars 

Project area. Fire and mechanized equipment could be used on about 15,000 acres in other portions of the CESA to 

improve native vegetation, remove hazardous fuels, and reduce the risk of wildfire. Collectively, about 3 percent of 

the CESA would be treated by the BLM. 

There would still be a net benefit from BLM treatments and treated areas would move toward their Potential Natural 

Community on portions of the project area. Because the BLM would not be able to use fire and mechanical treatments 

and fewer acres would be treated, however benefits to vegetation under Alternative C would be less than under 

Alternatives A and B. 

3.12.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on native and noninvasive vegetation would be similar to those described under Alternative A. There would be no cumulative impacts 

to native and non-invasive vegetation from 3 Bars Project treatments as no treatments would be authorized under this 

alternative. The BLM could create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse 

stands; slow the spread of noxious weeds and other invasive non-native vegetation using ground-based methods, 

especially cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildfire 

under current and reasonably foreseeable future authorized actions, but on a very limited acreage. Thus, factors that 

contribute to loss of native and non-invasive vegetation health and resiliency would remain, including spread of 

noxious weeds and other invasive non-native vegetation, pinyon-juniper encroachment, and wildfire, and would likely 

be greatest under this alternative. Under this alternative, the BLM would do little to move plant communities toward 

their Potential Natural Community. 

3.12.3.5 Unavoidable Adverse Effects 

The proposed vegetation treatments would cause unavoidable short-term disturbances to native and non-invasive 

vegetation communities by removing both target and non-target vegetation. In some cases, treatments would return all 

or a portion of the treated area to an early successional stage by freeing up resources such as light and nutrients. These 

adverse effects would be temporary and would consist of short-term losses of native vegetation and associated habitat 

values. The vegetation treatments would also have unavoidable adverse effects to pinyon-juniper habitats and 

woodland products harvest areas by substantially reducing the acreage of pinyon-juniper within the project area. 

3 Bars Project Final EIS 3-222 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

These adverse effects are a goal of the treatment program, and are intended to be long-term; in the absence of 

treatments, pinyon-juniper habitats would continue to expand.

3.12.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

The proposed vegetation treatments would have short-term adverse impacts to existing vegetation, including native 

trees, shrubs, forbs, and grasses, as these could be removed during treatments. Treatments that remove or control 

noxious weeds and other invasive non-native vegetation could provide immediate benefits to native species, such as 

increased access to water and nutrients and enhanced vigor from reduced competition with invasive species. 

Treatments that remove hazardous fuels from public lands would be expected to benefit the long-term health of plant 

communities in which natural fire cycles have been altered. The suppression of fire results in the buildup of dead plant 

materials (e.g., litter and dead woody materials), and often increases the density of flammable living fuels on a site. 

Treatments that restore and maintain fire-adapted ecosystems, and increase ecosystem functionality, through the 

appropriate use of mechanical thinning, use of wildland fire for resource benefit or prescribed fire, and other 

vegetation treatment methods, would decrease the effects of future wildfires on plant communities and improve 

ecosystem resilience and sustainability. Over the long-term, treatments should also reduce the incidence and severity 

of wildfires across the project area. 

Treatments that control populations of non-native species on public lands would be expected to benefit native plant 

communities over the long-term by aiding in the reestablishment of native species. The degree of benefit would 

depend on the success of these treatments over both the short-and long-term. Some treatments are very successful at 

removing noxious weeds and other invasive non-native vegetation over the short-term, but are not successful at 

promoting the establishment of native species in their place. In such cases, seeding and planting of native plant 

species would be beneficial. Plant communities that have declined substantially in geographic extent from historical 

to current periods (e.g., big sagebrush and bunchgrasses) would increase. Treatments would also manipulate the 

vegetation in the project area to more closely resemble the Potential Natural Communities and to counteract the 

invasion of sagebrush-steppe and other habitats by pinyon-juniper woodland. 

Short-term uses are also discussed in other sections of this EIS, including the potential loss of fish and wildlife habitat, 

increase in noxious weeds and other invasive non-native vegetation, loss of rangeland for livestock and wild horse 

use, and loss of public use of lands for recreation, as a result of treatments to restore vegetation and other resources, 

reduce hazardous fuels, and reduce the risk of wildfire. Long-term, treatments to reduce the risk of wildfire and 

restore habitat should enhance the resilience and health of the landscape and land productivity, and reduce the risk of 

future wildfire and resultant loss of natural and social resources. As discussed above, short-term uses and 

enhancement of long-term productivity would generally be in proportion to acres treated and methods used by the 

BLM. 

3.12.3.7 Irreversible and Irretrievable Commitment of Resources 

Loss of native vegetation and plant productivity as a result of treatments would persist only until vegetation was 

reestablished, usually within several growing seasons. Loss of pinyon-juniper communities would last for as long as 

treatments continue, and would not be irreversible and irretrievable. 

3 Bars Project Final EIS 3-223 October 2016 
NATIVE AND NON-INVASIVE VEGETATION RESOURCES 

3.12.3.8 Significance of the Effects under the Alternatives 

Based on the significance criteria presented in Section 3.12.3.2 it is not expected that any of the proposed alternatives 

would have a significant direct, indirect, or cumulative adverse effect on native and non-invasive vegetation, provided 

the BLM adheres to the SOPs referenced in Appendix C, and provided that treatments are effective at accomplishing 

their intended outcome. 

Because no federally listed, proposed, or candidate plant species are known or likely to occur within the proposed 

treatment areas within the CESA, take or increased mortality of these species should not occur. Several rare or 

sensitive species not currently listed under ESA are known to occur in the 3 Bars project area or nearby. None are 

known to occur within the proposed treatment areas, although populations could occur in these areas. Pre-treatment 

surveys for rare plants would identify whether these species are present and allow the BLM to design treatment 

programs to avoid or minimize effects to these species. Should these species be present, it is possible that limited 

mortality could occur, but local extirpation of these species would not occur as a result of project activities. 

None of the action alternatives would result in a long-term loss or degradation of a unique or high quality plant 

community, a measurable reduction in diversity within a high quality plant community, or an overall decline in 

woodland health. As discussed throughout this section, while there could be some short-term impacts to native 

communities as a result of implementing treatments, over the long-term the proposed treatments would help sustain 

and improve unique and high quality plant communities (sagebrush, historic pinyon-juniper, aspen). Woodland health 

in treated stands should improve over the long-term, and aspen regeneration and recruitment should increase. 

While all of the action alternatives would result in a long-term reduction in the amount of special woodland products 

available for harvest, the designated harvest areas within the Battle Mountain District are very large, and would still 

provide suitable access to and availability of pinyon-juniper woodlands used for commercial and individual harvest. 

3.12.4 Mitigation 

Native and non-invasive vegetation resources would benefit from mitigation and monitoring measures identified in 

Section 3.18.4 (Livestock Grazing Mitigation). No mitigation or monitoring measures are recommended specifically 

for native and non-invasive vegetation resources. 

3.13 Noxious Weeds and other Invasive Non-native Vegetation 

3.13.1 Regulatory Framework 

3.13.1.1 Executive Order 13112

Executive Order 13112, Invasive Species (February 3, 1999), instructs federal agencies to prevent introductions of 

non-native invasive species, control their spread in a cost-effective and environmentally sound manner, and minimize 

the economic, ecological, and human health impacts that invasive species cause. The Invasive Species Council, made 

up of federal agencies and departments, oversees and facilitates implantation of the Executive Order. The Executive 

Order also instructs the Secretary of the Interior to establish an advisory committee comprised of local, state, tribal, 

and regional stakeholders. 

3 Bars Project Final EIS 3-224 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.13.1.2 Federal Laws 

Federal laws pertaining to noxious and invasive weeds include the Lacey Act as amended (18 USC § 42), the CarsonFoley Act of 1968 (Public Law 90-583), the Federal Noxious Weed Act of 1974, as amended by the Food, 

Agriculture, Conservation, and Trade Act of 1990 (Section 1453, Management of Undesirable Plants on Federal 

Lands; 7 USC § 2814 et seq.), the Federal Plant Pest Act (7 USC § 150aa et seq.), and the Plant Protection Act of 

2000 (7 USC § 7701 et seq.), as amended by the Noxious Weed Control and Eradication Act of 2004 (Public Law 

108-412). 

3.13.1.3 Nevada Laws 

Chapter 555 of the Nevada Revised Statute pertains to noxious weeds. The Nevada Department of Agriculture is 

responsible for jurisdiction, management, and enforcement of this state law. The law mandates that plants on 

Nevada’s noxious weed list be controlled on both private and public lands. The law also calls for the establishment of 

county weed control districts, which are responsible for control and eradication of noxious weeds. The Diamond 

Valley Weed District coordinates weed control efforts on public and private lands in Eureka County. The Nevada 

state noxious weed list can be found at URL: http://agri.nv.gov/Plant/Noxious_Weeds/Noxious_Weed_List/. 

3.13.1.4 BLM Guidance and Regulations 

BLM Manual 9015, Integrated Weed Management, provides policy relating to the management and coordination of 

noxious weeds and other invasive non-native vegetation activities (USDOI BLM 1992b). The policy requires that 

ground-disturbing projects and projects that alter plant communities be assessed to determine the risk of introducing 

or spreading noxious weeds and other invasive non-native vegetation. If the risk is moderate or higher, a management 

program must be established. 

Two documents identify broad objectives for management of vegetation on BLM-administered lands—Partners 

against Weeds: An Action Plan for the Bureau of Land Management (USDOI BLM 1996), and Pulling Together: 

National Strategy for Invasive Plan Management (USDOI BLM 1998b). Treatment activities at the local level are 

guided by the goals, standards, and objectives of land use plans developed for each BLM field office. The BLM’s 

noxious weeds and other invasive non-native vegetation control program has three performance measures: inventory, 

treatment, and post-treatment effectiveness monitoring. BLM funding is associated with achievement of performance 

measure targets. 

BLM Handbook H-1740, Integrated Vegetation Management (USDOI BLM 2008b), and the BLM Battle Mountain 

District’s Integrated Weed Management Plan Mt. Lewis Field Office and Tonopah Field Office (USDOI BLM 2009b) 

direct management of noxious weeds and other invasive non-native plant species within the 3 Bars Project area. The 

District’s weed management plan is most concerned with State of Nevada noxious weeds and invasive annual grasses 

found on or with the potential to spread into the jurisdictional boundaries of the Battle Mountain District. 

3 Bars Project Final EIS 3-225 October 2016 
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION 

3.13.2 Affected Environment 

3.13.2.1 Study Methods and Analysis Area 

3.13.2.1.1 Study Methods 

Information about the presence and distribution of noxious weeds and other invasive non-native vegetation was 

obtained from past noxious weeds and other invasive non-native vegetation inventory, treatment, and monitoring data, 

background documents, aerial photographs, visual surveys for cheatgrass conducted during late fall and winter 2009-

2010, and rangeland health studies conducted during fall 2010 and summer 2011. 

The Mount Lewis Field Office has conducted noxious weed surveys over much of the 3 Bars Project area. These 

surveys are concentrated in areas that have been disturbed by human factors, sensitive natural areas, high-risk areas 

(e.g., riparian and wetland areas), high resource value habitat (e.g., for Greater sage-grouse), disturbed areas (e.g., 

roadsides and rangelands), and heavy public use areas (e.g., recreation sites). Noxious weeds and other invasive nonnative vegetation inventory, treatment, monitoring, mapping, and reporting are conducted by Mount Lewis Field 

Office resource specialists and community partners, including Eureka County, Diamond Valley Weed District, and 

through Bootstraps, a University of Nevada-Reno Cooperative Extension program developed specifically to conduct 

noxious weed treatments and inventory throughout the Battle Mountain District (USDOI BLM 2011g).

Rangeland health studies conducted by the BLM and Eastern Nevada Landscape Coalition (Eastern Nevada 

Landscape Coalition and AECOM 2012), included observations of noxious weeds and other invasive non-native 

vegetation within representative portions of the project area. Data collected during the studies included information 

about species composition and dominance within the sampling plots, including presence of canopy gaps, which 

provides some indication of the potential for invasion of the area by invasive species. 

A cheatgrass assessment for the project identified areas of cheatgrass establishment and propagation, as well as areas 

at risk for new cheatgrass establishment, particularly fire scars. During field surveys conducted in late fall 2009, much 

of the project area was surveyed for cheatgrass monocultures by ecologists conducting other project-related fieldwork. 

Ecologists looked for and identified large cheatgrass infestations, and mapped their locations using Global Positioning 

System technology. Aerial photographs and BLM burn data were reviewed to delineate areas of apparent dense 

cheatgrass coverage on recent burn areas (post 1984), which are considered areas with a high potential for infestation 

by cheatgrass monocultures. In February 2010, areas of cheatgrass monoculture potential were surveyed for 

cheatgrass presence. Recent burn areas were also identified during these surveys. The mapping from these surveys 

was used to develop cheatgrass coverage polygons for the project area. The results were presented in the 3 Bars 

Ecosystem and Landscape Restoration Project Cheatgrass Assessment (AECOM 2011b). 

3.13.2.1.2 Study Area 

The study area for direct and indirect effects to noxious weeds and other invasive non-native vegetation is the 3 Bars 

Project area. The CESA for cumulative impacts to noxious weeds and other invasive non-native vegetation includes 

the Hydrologic Unit Code 10 watersheds wholly, or partially within, the project area (Figure 3-1). 

3.13.2.2 Noxious Weeds and other Invasive Non-native Vegetation 

The Battle Mountain District’s noxious weed suppression efforts are concentrated on Russian knapweed, saltcedar 

(tamarisk), perennial pepperweed (tall white top), hoary cress, various thistle species, and on non-native annual 

3 Bars Project Final EIS 3-226 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

grasses (USDOI BLM 2009b). Elongated mustard, which is not currently listed by the State of Nevada as a noxious 

weed, is also of concern, as it is listed as a noxious weed in surrounding states and is found within Eureka County. 

The 3 Bars Project area is being closely watched for potential establishment and spread of this species. 

3.13.2.2.1 Noxious Weeds 

Coverage of noxious weed infestations in the 3 Bars Project area is approximately 12,242 acres, or 1.6 percent of the 

project area. Noxious weeds and non-native annual grasses occur sporadically, particularly infesting wildfire burn 

scars and other disturbance areas. Noxious weeds are concentrated around areas of high soil disturbance, including 

roadsides, and areas of soil/water disturbance associated with riparian resources. Areas with the greatest concentration 

of noxious weeds include the Henderson Creek area, Roberts Creek area, Ferguson Creek, and Gable and Willow 

Canyons. The most prevalent noxious weeds in the 3 Bars Project area are musk thistle and hoary cress. 

As stated in the BLM Battle Mountain District’s Integrated Weed Management Plan Mt. Lewis Field Office and 

Tonopah Field Office (USDOI BLM 2009b), the following areas are associated with noxious weeds and non-native 

invasive species on public lands in the Battle Mountain District. 

 Along rights-of-way and improved dirt roads - hoary cress, Russian knapweed, and halogeton. 

 Heavily trampled/disturbed rangeland - hoary cress, Russian/spotted knapweed, various thistles, salt cedar, 

and halogeton. 

 Along waterways/flood zones – perennial pepperweed, salt cedar, hoary cress, and various thistles. 

 Wildfire burn scars - cheatgrass, red brome, hoary cress, and various thistles. 

 Open range - cheatgrass, medusahead rye, and red brome. 

 Recreation/industrial - puncture vine and hoary cress. 

Table 3-39 provides a summary of the noxious weeds that are known to occur within the 3 Bars Project area, and the 

recommended control methods for these species. 

3.13.2.2.2 Cheatgrass Monocultures 

Because cheatgrass is so widespread and established on rangeland 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 3-32. Mapped areas include relatively 

large cheatgrass monocultures in 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. 

3 Bars Project Final EIS 3-227 October 2016 
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION 

TABLE 3-39

Noxious Weeds on the 3 Bars Project Area 

Species Typical Habitat Control method

Black henbane

Open sites with well-drained soils. 

Roadsides, waste areas, field 

borders, and pastures.

Mechanical or manual methods prior to seed 

production; burning dry mature plants; and chemical 

control by using metsulfuron methyl or picloram.

Canada thistle

Wide range of environmental and 

soil conditions. Rangeland, 

pastures, waste areas, roadsides, 

and along waterways.

Repeated mechanical/manual methods prior to seed 

production; biological control; chemical control by 

using 2,4-D, clopyralid, dicamba, glyphosate, or

picloram.

Hoary cress

Disturbed alkaline soils. Pastures, 

fields, roadsides, rangelands, waste 

areas, and along waterways.

Manual removal; chemical control by using 2,4-D, 

chlorsulfuron, or metsulfuron methyl.

Not effective: Mechanical control.

Musk thistle Roadsides, pastures and waste 

areas.

Manual or mechanical methods after bolting but prior 

to flowering; biological control; chemical control by 

using 2,4-D, clopyralid, dicamba, chlorsulfuron, 

metsulfuron methyl, or picloram. 

Perennial pepperweed 

Moist sites. Floodplains, pastures, 

meadows, hay fields, and along 

waterways.

Chemical control by using 2,4-D, chlorsulfuron, 

glyphosate, imazapic, or metsulfuron methyl.

Not effective: Mechanical or prescribed fire treatments.

Russian knapweed 

Broad range of sites. Rangeland, 

waste areas, roadsides, and along 

waterways.

Chemical control by using chlorsulfuron, clopyralid, or 

glyphosate.

Not effective: Mechanical methods.

Saltcedar Edges of waterways, lakes, and 

ponds.

Mechanical/manual control or prescribed fire combined 

with chemical application; biological control; chemical 

control by imazapyr, glyphosate, or triclopyr.

Scotch thistle Pastures, rangelands, roadsides, 

and waste areas.

Mechanical or manual methods prior to flowering; 

chemical control by using 2,4-D, chlorsulfuron, 

clopyralid, dicamba, metsulfuron methyl, or picloram.

Source: University of Nevada Cooperative Extension (2010). 

3.13.3 Environmental Consequences 

3.13.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Key issues of concern pertaining to noxious weeds and other invasive non-native vegetation were identified in the 

AECC and during scoping. These include the following: 

 The potential for the return of invasive species (primarily cheatgrass) following treatments. 

 The potential for disturbance associated with vegetation treatments to increase the abundance of invasive 

species, or result in the establishment of new invasive species populations. 

 The role of livestock grazing and climate change on noxious weeds and other invasive non-native vegetation 

invasion. 

 The potential for treatments to cause invasion of noxious weeds and other invasive non-native vegetation into 

woodlands, or juniper expansion. 

3 Bars Project Final EIS 3-228 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-32

Cheatgrass and Other Weeds

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Black Henbane

Cheatgrass

Hoary cress

Musk thistle

Perennial pepperweed

Russian knapweed

Scotch thistle

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2010k, 2012g; AECOM 2011b. 

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION 

 Avoid the use of prescribed fire and burn only in areas not at risk of exotic species invasion. 

 Concern regarding the use of exotics, such as crested wheatgrass, to restore burned areas. 

 Concern that the typical response to fire is to place a fence, which is often permanent, around the perimeter 

of a burned area. 

 Who or what is threatened by the woody vegetation that is termed hazardous fuels, and is cheatgrass a 

hazardous fuel? 

 Concerns about the use of herbicides in native plant communities. 

3.13.3.2 Significance Criteria 

The following would have a significant adverse effect on vegetation: 

 At the end of 10 years, an introduction of noxious weeds and other invasive non-native vegetation into a 

relatively weed free treatment area at a moderate or high ecological risk, relative to baseline levels. 

 At the end of 10 years, an expansion of noxious weeds and other invasive non-native vegetation within and 

outside of the treatment areas into a relatively weed free area at moderate or high ecological risk, relative to 

baseline levels. 

3.13.3.3 Direct and Indirect Effects 

3.13.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Effects 

Vegetation removal treatments can create conditions that favor early successional species and also result in a 

temporary loss of more mature vegetation. Most noxious weeds are early successional species that benefit from light 

and disturbance (Baker 1986). All treatments that cause disturbance or remove plants from an area could lead to a 

competitive advantage for many noxious weeds and other invasive non-native vegetation, particularly if a seed source 

is present on the site. There is also some potential for noxious weeds and other invasive non-native vegetation seeds 

to be transported onto treatment sites on workers’ shoes and clothing, with the plant materials used in rehabilitation 

projects, and on vehicles. It is expected that manual treatments would have a low potential for increasing noxious 

weeds and other invasive non-native vegetation coverage, given the minimal amounts of disturbance. To minimize 

these effects, the BLM would follow SOPs to prevent the inadvertent introduction and spread of noxious weeds and 

other invasive non-native vegetation, and monitor areas where soil is disturbed and where noxious weeds and other 

invasive non-native vegetation are inventoried or treated. The BLM would also inspect plant materials prior to 

planting to ensure that they are weed-free, and would identify and plant appropriate seed mixtures and plants suitable 

for specific habitats. It is assumed that the risks associated with manual treatments would be similar for all project 

groups. 

Beneficial Effects 

All treatments, or combinations of treatments, designed to control noxious weeds and other invasive non-native 

species would be expected to have a beneficial impact by reducing populations of these species. The reduction of fuel 

loads would decrease the risk of severe or repeat wildfires, thereby reducing the risk of spread of cheatgrass and other 

3 Bars Project Final EIS 3-230 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

noxious weeds and other fire-dependent invasive non-native species. By removing these species, overall ecosystem 

health and functionality would improve, and by restoring rangeland health native species would be better able to 

compete with noxious weeds and other invasive non-native species. 

3.13.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Adverse Effects 

Some of the proposed projects could promote the establishment and spread of noxious weeds and other invasive nonnative vegetation. Machinery used in mechanical treatments can result in inadvertent removal of native vegetation, 

and has the potential to spread seeds of noxious weeds and other invasive non-native vegetation. Furthermore, soil 

disturbance stimulates germination of noxious weeds and other invasive non-native vegetation seeds by providing 

physical cues that competing vegetation is absent (Cornell University Weed Ecology and Management Laboratory, no 

date). Additionally, vehicles and other mechanical equipment can damage or crush existing desirable riparian and 

wetland vegetation or bring propagules of non-native species into treatment areas and create sites for noxious weeds 

and other invasive non-native vegetation establishment (BLM 2007c:4-45). The risks for loss and damage to existing 

riparian and wetland vegetation and spread of noxious weeds and other invasive non-native vegetation would be 

greatest in project groups with the largest acreage and that employ the most extensive mechanical treatments (project 

groups that include streambank earthwork as well as pinyon-juniper removal (Garden Spring Group and Frazier Creek 

Group). For the Denay Pond group, the disturbance associated with mechanical treatments would be minimal, since 

only fence installation would occur. 

Beneficial Effects 

Successful control of invasive plants in riparian zones using manual and mechanical methods would lead to improved 

conditions in these habitats over the long-term. The eventual growth of desirable vegetation in treated areas would 

moderate water temperature, buffer the input of sediment from runoff, and promote bank stability in riparian zones. 

Efforts by the BLM to enhance wetland and riparian vegetation would also help to increase the number of miles of 

stream and acres of wetlands that are in Proper Functioning Condition. 

Aspen Treatments 

Adverse Effects 

The risks of introduction and spread of noxious weeds and other invasive non-native vegetation through manual and 

mechanical methods would be similar to those described for riparian zones. At all aspen treatment areas, the risks 

associated with manual treatments would be low, since a minimal amount of soil disturbance would occur, SOPs 

would be implemented to prevent the establishment and spread of noxious weeds and other invasive non-native 

vegetation, and woody debris would be left onsite to promote seedling and sapling establishment. 

Treatment activities that cause soil disturbance and create open conditions, including mechanical methods and fire, 

could facilitate noxious weeds and other invasive non-native vegetation establishment and spread. These include 

project areas where pinyon-junipers would be removed (JD-A4 group and RM-A2 group). In areas where the 

mechanical treatments are limited to cutting aspen or ripping root masses, less disturbance would be expected given 

the targeted nature of these treatments. 

3 Bars Project Final EIS 3-231 October 2016 
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION 

Beneficial Effects 

While noxious weeds and other invasive non-native vegetation control is not identified as part of the treatment design 

for these sites, the BLM could use manual and mechanical methods to treat noxious weeds and other invasive nonnative vegetation that are present on aspen treatment areas. By directly targeting noxious weeds and other invasive 

non-native vegetation in the course of completing other proposed treatments, the proposed project would have a 

beneficial effect on native plant communities. 

Pinyon-juniper Treatments 

Adverse Effects 

Manual and mechanical treatments could cause soil disturbance that leads to the establishment and spread of noxious 

weeds and other invasive non-native vegetation, as increased light availability in the site and shading of desirable 

understory plants by heavy slash could provide conditions that favor invasive species (Tausch et al. 2009). Chainsaw 

cutting in juniper woodlands has been correlated with increased shrub and grass cover, which may include at least an 

initial increased cover of cheatgrass on sites where a seed source for this species is present (Miller et al. 2005). Fire 

risks associated with slash would be mitigated to some degree by associated programs to use felled trees for posts, 

mulch, or other forest products uses, and following manual treatments with pile and slash burning. In some areas, the 

creation of fire and fuel breaks could also lead to noxious weeds and other invasive non-native vegetation 

establishment and spread. 

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 non-native annual grasses and forbs 

would be the first to establish after a fire. Without other treatments, such as the use of herbicides, non-native annual 

grasses and forbs may dominate the site (USDOI BLM 2012g). 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 and mixed-aged stands of pinyon-juniper. 

Cheatgrass could potentially increase in dominance following a fire. Over time, the presence of cheatgrass in an area 

can increase the frequency of fire, potentially altering the successional trajectory, such that the understory never 

progresses from annual grass to perennial grass and shrub/grass mix, and the community never returns to a perennial 

grass or woodland stage (Miller and Tausch 2001, Ansley and Rasmussen 2005). Therefore, 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. Increased dominance of cheatgrass is particularly a concern for the 

Sulphur Spring Wildfire Management Unit, where wildfires would be allowed to burn for resource benefit, and where 

cheatgrass is already present, including a large monoculture (see Figure 3-32). However, the BLM would take into 

account the potential for cheatgrass to respond to fire when managing wildland fires in this area. The BLM would also 

take into account the live fuel moisture conditions, weather conditions and trends, whether the fire would meet 

management objectives, and the fire return interval (i.e., if an area has recently burned, it would not be allowed to 

burn again until it is within the range of the normal fire return interval). Fires would be suppressed during periods of 

low fuel moisture, or in areas with large populations of cheatgrass. Since cheatgrass is present throughout the Sulphur 

Spring Wildfire Management Unit, the potential for cheatgrass spread as a result of treatments exists. Rehabilitation 

3 Bars Project Final EIS 3-232 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

following the treatment would be conducted in areas where native communities are unlikely to regrow after a fire. 

Additionally, all sites are monitored for at least 3 years to assess whether further action is needed. 

Beneficial Effects 

The predominant noxious weeds and other invasive non-native vegetation infestations in pinyon-juniper treatment 

areas are cheatgrass, musk thistle, and black henbane. Treatments directed at these and other weeds during the course 

of completing proposed pinyon-juniper enhancement projects would be expected to have a beneficial effect on 

ecosystem health. 

The BLM would restore fire as an integral part of the ecosystem, improve species diversity, and reduce hazardous 

fuels on the Sulphur Spring Wildfire Management Unit by using wildland fire for resource benefit. The BLM would 

allow fire to burn on about 20 to 40 percent of the area, but generally burns would be limited to small acreages to 

create a mosaic of habitats and to create fuel breaks. By keeping burned areas small, the risk of a cheatgrass 

infestation is much less. 

Sagebrush Treatments 

Adverse Effects 

Treatments to reduce herbaceous dominance (Rocky Hills Unit) 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 treatments 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, the long-term result of the project would be to 

minimize the herbaceous component and increase the sagebrush component. 

Manual and mechanical treatments would have the potential to disturb sagebrush habitats, with potential impacts 

similar to those discussed for other community types. Ground disturbance associated with mechanical treatments 

could occur on all of the sagebrush project areas. These treatments could potentially result in trampling and 

inadvertent removal of non-target plants, as well as soil disturbance that could favor the establishment and spread of 

cheatgrass and other noxious weeds and other invasive non-native vegetation. The greatest risk for adverse effects 

would occur where the largest ground areas are disturbed, and where noxious weeds and other invasive non-native 

vegetation seeds are already present. 

Biological control has been identified for use to remove cheatgrass, crested wheatgrass, and forage kochia. 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 

treatment areas since these species are already present in the areas. Using SOPs to prevent noxious weeds and other 

invasive non-native vegetation spread, monitoring, and follow-up treatments would help to minimize these risks. 

3 Bars Project Final EIS 3-233 October 2016 
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION 

Beneficial Effects 

Prescribed fire and broadcast seeding could be used on the West Simpson Unit to control cheatgrass. Livestock could 

be used to biologically control cheatgrass. In all areas where the BLM would employ the use of livestock as a 

biological control, other control methods would also be used to restore ecologically functioning sagebrush habitat. 

These could include mechanical treatments such as discing and seeding. These efforts to reduce cheatgrass cover 

would have a beneficial outcome in these areas. 

The Rocky Hills Unit was replanted with non-native crested wheatgrass and forage kochia after the 1999 Trail fire. 

Crested wheatgrass can establish with minimal seedbed preparation, can survive periods of drought, and can compete 

with weedy species (Davies et al. 2010). This species, however, is a prolific seed producer that can dominate a site 

and exclude native vegetation, including the native bunchgrasses and big sagebrush that offer better wildlife value 

(Monson 2002, Braun 2006). Forage kochia was originally introduced into the U.S. to compete with halogeton. It has 

since been shown to compete well against other aggressive, exotic annual noxious weeds and other invasive nonnative vegetation such as cheatgrass, Russian thistle, and medusahead rye. Plantings of forage kochia can decrease 

densities of annual weeds, thus decreasing fire intervals of degraded rangelands while providing valuable forage to 

livestock and forage and cover for wildlife (Tilley et al. 2006). 

Projects that target non-native vegetation, including cheatgrass, crested wheatgrass, and forage kochia would be 

beneficial for native vegetation, as they would help to restore native sagebrush communities in these areas that are 

currently dominated by a non-native species. Competition from these non-native species has limited sagebrush 

expansion in previously burned areas. The BLM proposes to restore areas seeded with crested wheatgrass and forage 

kochia to native vegetation. Non-native vegetation would be treated in strips. As treated strips are restored with native 

vegetation, additional strips would be treated. Pehrson and Sowell (2011) studied methods to eliminate crested 

wheatgrass and establish sagebrush. They found that no technique eliminated crested wheatgrass in a single 

application. Grazing and fire had no long-term impacts on crested wheatgrass. Mechanical treatments, such as 

plowing, discing, and cultivating reduced and eradicated crested wheatgrass, but invasive grasses followed treatments 

and made it difficult to establish native seeded species. 

In some areas dominated by cheatgrass, the BLM may initiate a phased succession approach to restoration that 

includes treating the area with various methods, including mechanical treatments and prescribed fire, and then 

planting the area with crested wheatgrass and forage kochia to compete directly with remaining cheatgrass. Once 

these species have stabilized the site, the BLM would begin to convert the site back to native vegetation. 

3.13.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Given that fire would not be used under this alternative, treatment programs might not be as effective as under 

Alternative A. Because only mechanical and manual methods would be used, it would be difficult for the BLM to 

conduct hazardous fuels reduction, and noxious weeds and other invasive non-native vegetation treatments on steep 

hillslopes or over large acreages. The BLM would not be able to use fire to remove the mat of dead vegetation in 

cheatgrass-dominated areas, or to promote the health and resiliency of native vegetation. Thus, the wildfire risk would 

be greater under this alternative than under Alternative A, as would the potential for establishment and spread of 

noxious weeds and other invasive non-native vegetation. 

3 Bars Project Final EIS 3-234 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.13.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Given that fire and mechanical methods would not be used under this alternative, the BLM would have the fewest 

options for its treatment programs, and these programs would likely not be as effective as under the other action 

alternatives. The BLM would be unable to combine treatment methods for optimal control of cheatgrass and other 

noxious weeds and other invasive non-native vegetation. Because this alternative is the most limited in terms of the 

tools available for large scale restoration, it is the least likely of the action alternatives to help attain larger ecosystem 

restoration goals for the 3 Bars Project area. 

Because only manual methods would be used, it is unlikely that the BLM would slow the spread of noxious weeds 

and other invasive non-native vegetation, including cheatgrass; restore fire as an integral part of the ecosystem; and 

reduce extreme, very high, and high wildfire risks to moderate risk or less. Thus, wildfire risk would be greater under 

this alternative than under Alternatives A and B, as would the potential for establishment and spread of noxious weeds 

and other invasive non-native vegetation. 

3.13.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to noxious weeds and other invasive non-native vegetation from 3 Bars Project 

treatments as no treatments would be authorized under this alternative. Under this alternative, the BLM would not 

create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; treat large-scale 

infestations of noxious weeds and other invasive non-native vegetation, especially cheatgrass; restore fire as an 

integral part of the ecosystem; or reduce the risk of a large-scale wildfire. Threats to ecosystem health under this 

alternative would be associated with the ongoing expansion of noxious weeds and other invasive non-native 

vegetation; continued decline of ecosystem health due to further decline in native understory species in the upland 

plant communities; further expansion of pinyon-juniper woodland into other communities, including sagebrush, 

riparian, and aspen habitats; and the continued increase of the risk for catastrophic wildfire as a result of high fuel 

loads. Given the low acreage treated annually, there would be little or no improvement in reducing the amount of 

acreage infested with noxious weeds and other invasive non-native vegetation. 

3.13.3.4 Cumulative Effects 

The CESA for noxious weeds and other invasive non-native vegetation is approximately 1,841,698 million acres and 

includes those watersheds at the Hydrologic Unit Code 10 level that are all or partially within the 3 Bars Project area 

(Figure 3-1). Past and present actions that have influenced noxious weeds and other invasive non-native vegetation 

activity in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.13.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

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. 

In the short-term, small, temporary exclusion fences may change the distribution of grazing by livestock, wild horses, 

and some wildlife. As distribution patterns change, utilization would also change. Utilization would decrease in 

treatment areas while temporary exclusion fences are in place, but would increase in other areas. Once the temporary 

3 Bars Project Final EIS 3-235 October 2016 
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION 

exclusion fences are removed, animals may be attracted to the treatment areas resulting in potentially higher use of the 

area than before. Temporary exclusion fences would exclude livestock, although AUMs may be temporarily 

suspended to prevent overuse in other areas. 

The BLM would continue using ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and aerial-based application methods to remove cheatgrass, and would restore burned areas 

under the Burned Area Emergency Stabilization and Rehabilitation program, under existing authorizations. These 

treatments would help to reduce hazardous fuels, slow the spread of noxious weeds and other invasive non-native 

vegetation, and reduce surface runoff and erosion associated with burn sites on about 1,000 acres annually. The active 

ingredients in herbicide formulations could adversely affect non-target vegetation under one or more exposure 

scenarios, particularly for aerial applications, and accidental exposure scenarios such as a spill (USDOI BLM 

2007b:4-47). 

Agriculture, land development, mineral development, and oil, gas, and hydrothermal exploration and development 

could affect about 10,000 acres in the reasonably foreseeable future, including about 8,335 acres of disturbance 

associated with the Mount Hope Project. Although some of the disturbance from these projects would be reclaimed, 

these activities would lead to long-term losses in native plant communities in the affected areas, and entail disturbance 

that could facilitate the establishment and spread of noxious weeds and other invasive non-native vegetation. 

Since 1985, approximately 7,000 acres have burned annually in the CESA, although the acreage burned annually is 

quite variable. It is projected that an additional 140,000 acres could be burned in the CESA during the next 20 years. 

A wildfire would cause the wide-scale removal of vegetation in the CESA, and would also lead to the spread of 

noxious weeds and other invasive non-native vegetation. 

Hazardous fuels reduction, habitat improvement, and noxious weed and other invasive non-native vegetation control 

projects would occur on up to 142,000 acres (127,000 for the 3 Bars Project and 15,000 acres for other hazardous 

fuels projects in the CESA), or 8 percent of the CESA. As discussed under direct and indirect effects, these treatments 

would lead to short-term increases in noxious weeds and other invasive non-native vegetation. 

Long-term, these treatments should result in a reduction of noxious weeds and other invasive non-native vegetation 

and return of native and non-invasive vegetation that is more fire resilient, more abundant, and similar to the Potential 

Natural Community. These treatments would also help to reduce the risk of wildfire within the CESA, which often 

leads to the establishment and spread of noxious weeds and other invasive non-native vegetation. 

3 Bars Project treatments would affect less than 1 percent of the CESA annually, and these effects should be 

beneficial long-term. Thus, there would be a negligible short-term accumulation of adverse effects and minor longterm accumulation of benefits from 3 Bars Project actions combined with effects from other treatments. 

3.13.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on noxious weeds and 

other invasive non-native vegetation would be similar to those described under Alternative A. The BLM would treat 

about half as many acres under Alternative B as under Alternative A, and less effort would be spent by the BLM on 

treatments to reduce wildfire risk and its impacts on vegetation, including the use of fire to restore natural fire 

regimes. 

3 Bars Project Final EIS 3-236 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

The use of mechanical treatments would give the BLM greater latitude to control various types of vegetation 

compared to fire treatments, but efforts to control cheatgrass and other noxious weeds and other invasive non-native 

vegetation would be difficult on steep slopes and over large acreages. Hazardous fuels reduction and habitat 

improvement projects could occur on about 63,000 acres within the 3 Bars Project area, and on about 15,000 acres 

within other portions of the CESA, or about 4 percent of the acreage within the CESA. Thus, the BLM would be less 

successful in controlling noxious weeds and other invasive non-native vegetation on the project area and in the CESA 

under Alternative B than under Alternative A. 

3.13.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on noxious weeds and 

other invasive non-native vegetation would be similar to those described under Alternative A. Under Alternative C, 

the BLM anticipates treating about one-fourth as many acres as under Alternative A. Adverse, short-term effects to 

vegetation associated with the use of fire and mechanized equipment would not occur under Alternative C. 

By not being able to use mechanical methods, such as mowing, chopping, tilling, discing, harrowing, and drill 

seeding, the BLM would do little to reduce hazardous fuels, create fire and fuel breaks, treat areas with noxious weeds 

and other invasive non-native vegetation, or remove downed wood and slash. Thus, the risk of wildfire and spread of 

noxious weeds and other invasive non-native vegetation would remain high on the 3 Bars Project area and within the 

CESA. Only about 32,000 acres, or about 2 percent of the CESA, would be treated within the CESA. These 

treatments would benefit the 3 Bars ecosystem, but not to the extent as under Alternatives A and B.

3.13.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on noxious weeds and 

other invasive non-native vegetation would be similar to those described under Alternative A. There would be no 

cumulative impacts to noxious weeds and other invasive non-native vegetation from 3 Bars Project treatments from 

this alternative as no treatments would be authorized under this alternative. The BLM could create fire and fuel 

breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and 

other invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the ecosystem; and 

reduce the risk of a large-scale wildfire under current and reasonably foreseeable future authorized actions, but on a 

very limited acreage. Thus, factors that contribute to the spread of noxious weeds and other invasive non-native 

vegetation would remain, and would likely be greatest under this alternative. 

3.13.3.5 Unavoidable Adverse Effects 

The proposed vegetation treatments would cause unavoidable short-term disturbances to plant communities by 

removing both target and non-target vegetation. In some cases, treatments would return all or a portion of the treated 

area to an early successional stage by freeing up resources such as light and nutrients. These adverse effects would be 

temporary and would consist of short-term losses of native vegetation and associated habitat values.

3.13.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

The proposed vegetation treatments would have short-term adverse impacts on non-target vegetation, including native 

trees, shrubs, forbs, and grasses, as these could inadvertently be removed during treatments. Treatments that remove 

3 Bars Project Final EIS 3-237 October 2016 
NOXIOUS WEEDS AND OTHER INVASIVE NON-NATIVE VEGETATION 

or control noxious weeds and other invasive non-native vegetation could provide immediate benefits to native species, 

such as increased access to water and nutrients and enhanced vigor from reduced competition with invasive species. 

Over the long-term, treatments should also reduce the incidence and severity of wildfire across the project area. 

Treatments that control populations of noxious weeds and invasive and non-native species on public lands would be 

expected to benefit native plant communities over the long-term by aiding in the reestablishment of native species. 

The degree of benefit would depend on the success of these treatments over both the short- and long-term. Some 

treatments are very successful at removing noxious weeds and other invasive non-native vegetation over the shortterm, but are not successful at promoting the establishment of native species in their place. In such cases, seeding and 

planting of native plant species would be beneficial. 

3.13.3.7 Irreversible and Irretrievable Commitment of Resources 

Loss of native vegetation and plant productivity as a result of treatments would persist only until vegetation was 

reestablished, usually within several growing seasons. 

3.13.3.8 Significance of the Effects under the Alternatives 

While treatments would result in short-term increases in populations of noxious weeds and other invasive non-native 

species such as cheatgrass, post-treatment control and rehabilitation are expected to slow the spread of noxious weeds 

and other invasive non-native vegetation. Under Alternative C, mechanical methods would not be used to target 

noxious weeds and other invasive non-native vegetation and vegetation control might be more difficult, although 

manual methods of weed control could still be used successfully, particularly if the treatment area is relatively small. 

Under Alternative A, the spread of cheatgrass following prescribed or wildland fire for resource benefit is of 

particular concern. Additionally, SOPs would require the BLM to address the potential proliferation of cheatgrass 

when planning burns or assessing rehabilitation needs post-burn. Since the significance criteria allow 10 years to 

control noxious weeds and other invasive non-native vegetation that are introduced as a result of treatments, 

additional monitoring beyond 3 years would be required to ensure that no further control is required beyond the 

standard 3-year monitoring period. 

3.13.4 Mitigation 

Noxious weed and other invasive and non-native vegetation control would benefit from mitigation measures 

identified in Section 3.18.4 (Livestock Grazing Mitigation). No mitigation or monitoring measures are recommended 

specifically for noxious weed and other invasive non-native vegetation control. 

3.14 Wildland Fire and Fire Management 

Species diversity within a plant community depends on species composition, the adaptive traits of plants, the timing 

of fire, and the nature of fire as it moves through the community. The spatial arrangement of fuels and individual 

plants can be important to survival, particularly where fuels are unevenly distributed. Concentrations of live or dead 

fuels can generate high fire intensities and severities on relatively small sites, which can enhance or reduce diversity 

depending on the community. The areas within and surrounding the 3 Bars ecosystem are of high value to the Mount 

Lewis Field Office. The area has a high occurrence of wildfires with large fire potential in many places as 

demonstrated by past fire history and deviation from historic fire regimes. The Battle Mountain District provides 

aggressive initial attack for all fires within this area. 

3 Bars Project Final EIS 3-238 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.14.1 Regulatory Framework 

The Battle Mountain District Fire Management Program is guided by the policies expressed in national policy 

documents and referenced in Chapter 1. District policy documents include the Approved Resource Management Plan 

Amendment for Fire Management with Environmental Assessment and Decision Record Shoshone-Eureka Planning 

Area (Shoshone-Eureka Fire Land Use Plan Amendment; USDOI BLM 2002); and the 2004 Battle Mountain District 

Fire Management Plan (Fire Management Plan; USDOI BLM 2004a).

In addition, fire management guidance is provided by the following BLM documents:

BLM Manual 1740, Renewable Resource Improvements and Treatments (USDOI BLM 2008j), and BLM Manual 

Handbook H-1740-1, Renewable Resource Improvement and Treatment Guidelines and Procedures (USDOI BLM 

2007g), provide guidance and procedures for management and treatment of renewable resources, including utilization 

of management prescribed fire and emergency fire rehabilitation. 

BLM Handbook 1742, Burned Area Emergency Stabilization and Rehabilitation (USDOI BLM 2007h), provides 

guidance for emergency fire rehabilitation including measures to prevent accelerated soil erosion and establishment of 

noxious and invasive plant species, and post fire management of restoration areas. 

BLM Manual 9212, Fire Prevention, is consistent with Departmental policy (910 Department Memorandum 1.4), and 

it is the BLM’s policy that:

 Prevention of catastrophic wildfires is a high priority. Commitment to an effective wildland fire prevention 

program is expected at all levels within the Bureau. 

 The wildfire prevention program shall be designed to minimize losses from fire consistent with resource 

objectives identified in RMPs.

 Wildfire prevention shall stress the analysis of risks, hazards and values and the development of specific 

educational, engineering, enforcement and administrative prevention actions. 

 Wildfire prevention activities shall be coordinated with all federal, state, county, and municipal agencies. 

 Each state and district office shall provide coordination, guidance, and assistance to achieve an aggressive 

wildfire prevention program and shall maintain and update as required a Wildfire Prevention Plan integrated 

with the Fire Management planning process. 

 Wildfire Prevention Program funding shall be consistent with the identified needs as determined through a 

prevention analysis that is approved as an operational plan of the Fire Management Plan (BLM 9212-1). 

 The BLM shall emphasize the use of hazardous fuel reduction techniques as part of the wildfire prevention 

program. 

BLM Manual 9214, Prescribed Fire Management, and BLM Handbook H-9214-1, Prescribed Fire Handbook, 

describe the authority and policy for prescribed fire use on public lands administered by the BLM. It is BLM policy 

that: 

 The role of fire and its potential use will be considered in establishing the management strategy for all 

ecosystems. 

3 Bars Project Final EIS 3-239 October 2016 
WILDLAND FIRE AND FIRE MANAGEMENT 

 Prescribed fires may be initiated by planned or unplanned (unscheduled) ignition. 

 All prescribed fire (including hazard reduction) projects will support one or more approved land management 

objective(s) derived from the Bureau’s land management planning process.

 The planning and execution of the prescribed fire will be funded by the benefiting program(s). 

 Each prescribed fire project will have an approved Prescribed Fire Plan completed before ignition. 

 Each prescribed fire will be managed and executed in conformance with the approved plan by qualified 

personnel. The term qualified will include experience, training, and physical fitness for key positions. 

 Prescribed fire projects will comply with federal, state and local regulations and standards, including air 

quality and smoke management programs. 

 Pre-burn, burn, and post-burn fuel and weather measurement(s) will be taken on all prescribed fire projects 

for planning purposes, prescription, compliance, and project evaluation. It may not be necessary to take postburn weather measurements on fuel reduction projects. 

 Pre-burn and post-burn monitoring will be conducted to determine whether resource and fire objectives are 

achieved, unless where previous documented experience is adequate to predict post-burn results. 

The Eureka County Master Plan discusses fire management and makes these recommendations regarding burning 

within the County (Eureka County 2010): 

 Prevent significant deterioration of the superior air quality found in Eureka County. 

 Manage smoke from prescribed burns through techniques of smoke avoidance, dilution, and emission 

reduction, and limit unnecessary emissions from existing and new point and nonpoint sources through 

development and implementation of best management practices. 

 Engage federal land management agencies in burn planning. 

 Conduct prescribed burning at the maximum rate allowed by Clean Air Act and State regulations. 

 Maintain records of both acreage and tonnage burned and compare to allowable values. 

 Review burn plans for compliance with best management practices for point source emissions. 

 Review burn calculations and plans to assure that air quality maximums are not exceeded. 

 Evaluate whether prescribed burning plan conforms to the requirements and guidelines for air quality and 

smoke management being developed by the State of Idaho. 

 Review best management practices as necessary to assure applicability and compliance. 

 Conduct an annual review of the backlog of prescribed burns, pending applications, and requests for 

additional prescribed burns to incorporate them into the following year annual plan.

For wildfires, Eureka County supports the right for local citizens to protect their property from fires originating on 

state and federal lands. The County advocates active fire management on federal lands, including, where appropriate 

and in consultation with grazing permit holders, adjacent landowners, local volunteer fire fighters and Eureka County, 

a let-burn policy. The County is opposed to arbitrary and inequitable restriction of post-fire land use for recreation and 

3 Bars Project Final EIS 3-240 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

livestock grazing. The County insists that all post-fire land use restrictions be adequately justified and based on peerreviewed science (Eureka County 2010). 

3.14.2 Affected Environment 

3.14.2.1 Study Methods and Study Area 

The following documents were important sources of information for this assessment:17-States PER (USDOI BLM 

2007c); Wildland Fire in Ecosystems Effects of Fire on Flora (USDA Forest Service 2000); Proceedings of the 

Invasive Species Workshop: The Role of Fire in the Control and Spread of Invasive Species (Tall Timbers Research 

Station 2001); Shoshone-Eureka Fire Land Use Plan Amendment (USDOI BLM 2002); Fire Management Plan 

(USDOI BLM 2004a); Wildland Fire in Ecosystems: Fire and Non-native Invasive Plants (Zouhar et al. 2008); and 

AECC (USDOI BLM 2009a). Information about the occurrence of wildland fires was obtained from historic records 

maintained by the Battle Mountain District Office, field surveys, and discussions with District fire management staff. 

The study area for direct and indirect effects to resources affected by fire management activities lies within the 3 Bars 

Project area. The cumulative effects study area includes the Hydrologic Unit Code 10 watersheds within, or partially 

within, the project area (Figure 3-1). 

3.14.2.2 Fire Incidence in the 3 Bars Project Area 

Since 1985, about nine fires have occurred annually within the project area, burning about 4,225 acres annually and 

about 520 acres per fire. The number of fires and acres burned was higher in the mid- to late-1990s than during the 

past decade (Figure 3-33, Table 3-40).

3.14.2.3 Fire Regimes and Fire Condition Classes in the 3 Bars Project Area 

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 et al. 

(2002) and interpreted for fire and fuels management by Hann and Bunnell (2001). Fire regimes are based on a 

number of factors including frequency, intensity, size, pattern, season, and severity. Individual fires can vary greatly 

in severity, and the specific effects and risks caused by a fire will depend on the specifics of its fire regime. As shown 

in Table 3-41, the BLM has identified five fire regimes, three of which occur in the 3 Bars Project Area. 

An FRCC is a classification of the amount of departure from the natural regime. The BLM has identified three 

FRCCs, as described in Table 3-42. Based on FRCCs, the BLM determines where to use fire and other treatment 

methods to restore public lands to their natural fire regime. For the 3 Bars Project, treatments are focused on FRCC II 

and III areas. 

Fire risk is different than FRCC. Fire risk involves several factors, including ignition sources, fuels topography, and 

weather, while FRCC is a classification of the amount of departure from the natural regime (Hann and Bunnell 2001). 

As discussed earlier, current fire regimes have deviated substantially from historical regimes, as shown in Figures 3-

34 and 3-35, and Tables 3-41 and 3-42. Nearly 80 percent of lands on the project area were historically in Fire 

Regime IV, while nearly 90 percent of acreage is now within FRCC II. This has led to moderate to extreme risks for a 

catastrophic fire on the project area (Figure 3-36; USDOI BLM 2009a).

3 Bars Project Final EIS 3-241 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-33

Fire History and Occurence

3 Bars Ecosystem and

Landscape Restoration Project

Tonkin (1998)

Tonkin (2001)

Tonkin (2002)

Alpha (2002)

Tonkin (2003)

Alpha (2004)

Moonshine (1985)

Hope Mtn

(1998)

S Table Mtn

(1999)

3 Bar (1999)

Spring (2003)

Middle (2005)

Table Mtn 2

(1988)

Dugout (1996)

Rye Patch

(1999)

Table Mtn (1985)

278

50

Eureka

Elko County

Eureka County

Lander CountyEureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Fire Starts (1985 - 2008)

0 - 10 ac.

10 - 100 ac.

100 - 1,000 ac.

> 1,000 ac.

Large Fire Perimeter

(1985 - 2012)

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012f,g.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-34

Natural Fire Regimes

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Reese River/

Grass Valley

NV 060-18

Three Bars

NV 060-15

Roberts

NV 060-17

Big Smoky

NV 060-13

Eureka/

Diamond Valley

NV 060-21

Eureka/

Diamond Valley

NV 060-21

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Natural Fire Regimes

Fire Regime Group III

Fire Regime Group V

Fire Regime Group IV

Barren

Sparsely Vegetated

Indeterminate Fire

Regime Characteristics

Fire Management Unit

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012g.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-35

Current Fire Regime

Condition Classes

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Reese River/

Grass Valley

NV 060-18

Three Bars

NV 060-15

Roberts

NV 060-17

Big Smoky

NV 060-13

Eureka/

Diamond Valley

NV 060-21

Eureka/

Diamond Valley

NV 060-21

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Current Fire Regime

Condition Classes

Condition Class 1

Condition Class 2

Condition Class 3

Agriculture

Barren

Sparsely Vegetated

Fire Management Unit

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012g.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-36

Current Risk of Catastrophic Fire

and Threat to Resource Values

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Pete Hanson

Creek SRA

Tonkin

Mine SRA

Elko County

Eureka County

Lander County

Eureka County

Reese River/

Grass Valley

NV 060-18

Three Bars

NV 060-15

Roberts

NV 060-17

Big Smoky

NV 060-13

Eureka/

Diamond Valley

NV 060-21

Eureka/

Diamond Valley

NV 060-21

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Fire Risk

Low to Moderate

Moderate

Moderate to High

High

High to Very High

Very High

Very High to Extreme

Extreme

Current Identified

"Strategic Areas"

Site/Risk Assessment

Strategic Areas -

Ongoing Assessments

Fire Management Unit

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source:BLM 2009a,f, 2012g.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
WILDLAND FIRE AND FIRE MANAGEMENT 

TABLE 3-40

Fire History on the 3 Bars Project Area 

Year Number of Fires Total Acres 

Burned

Year Number of Fires Total Acres 

Burned

1985 9 18,164 1999 16 74,164

1986 4 12 2000 11 1,396

1987 1 0 2001 14 10

1988 4 652 2002 12 6

1989 7 0 2003 15 31

1990 10 0 2004 6 2

1991 5 1 2005 21 227

1992 8 10 2006 8 909

1993 2 0 2007 7 52

1994 13 2,074 2008 7 172

1995 12 329 2009 0 0

1996 10 2,009 2010 1 1,208

1997 4 2 2011 4 71

1998 8 2,540 2012 1 12,073

TABLE 3-41

Fire Regime Descriptions (Historical Fire Regimes)

Estimated from LANDFIRE database. 

3 Bars Project Final EIS 3-246 October 2016 

Group Frequency Severity Severity Description Number of Acres 

in Project Area

I 0 – 35 years Low/mixed

Generally low-severity fires replacing less 

than 25 percent of the dominant overstory 

vegetation; can include mixed-severity fires 

that replace up to 75 percent of the 

overstory. 

0

II 0 – 35 years Replacement

High-severity fires replacing greater than 75

percent of the dominant overstory 

vegetation. 

0

III 35 – 200 years Mixed/low Generally mixed-severity; can also include 

low-severity fires. 102,000

IV 35 – 200 years Replacement High-severity fires. 576,750

V 200+ years Replacement/any 

severity

Generally replacement-severity; can include 

any severity type in this frequency range. 71,250
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-42 

Fire Regime Condition Class Descriptions 

Condition 

Class Fire Regime

Risk of Losing Key 

Ecosystem 

Components

Vegetation 

Attributes

Acres in 3 

Bars Project 

Area

I Fire regimes are within historical 

range.

Risk of losing key 

ecosystem 

components is low.

Vegetation attributes 

are intact and function 

within an historical 

range.

45,000

II

Fire regimes on the land have been 

moderately altered from historical 

ranges. Fire return intervals have 

increased or decreased from 

historical frequencies by 1 or more 

return intervals, resulting in 

moderate changes to:

 The size, frequency, intensity, or 

severity of fires; or

 Landscape patterns.

There exists a 

moderate risk of 

losing key ecosystem 

components from fire.

Vegetation attributes 

have been moderately 

altered from the 

historical range of 

attributes.

625,000

III

Fire regimes on the land have been 

significantly altered from historical 

ranges. Fire return intervals have 

increased or decreased from 

historical frequencies by multiple 

return intervals, resulting in dramatic 

changes to:

 The size, frequency, intensity, or 

severity of fires; or

 Landscape patterns.

There exists a high 

risk of losing key 

ecosystem 

components from fire.

Vegetation attributes 

have been 

significantly altered 

from the historical 

range of attributes.

52,500

Estimated from LANDFIRE database. 

3.14.2.4 Resource Management Plan Amendments for Fire Management 

In 2002, the BLM prepared an amendment to the Shoshone-Eureka RMP in order to address fire management. Under 

the Shoshone-Eureka Fire Land Use Plan Amendment Decision Record, the BLM decided to improve fire 

management within the planning area by restoring fire as an integral part of the ecosystem, improving the diversity of 

vegetation, and reducing fire fuel hazards. This would be accomplished through the use of prescribed fire and fire use 

for resource benefit, and by using mechanical treatments such as green strips, shaded fuel breaks, and tree thinning to 

reduce wildfire fuel hazards. By taking these actions, it was expected that the size and severity of future wildfires 

would be reduced (USDOI BLM 2002:1, 9). This amendment was developed in response to the 1999 wildfire season, 

when 279,990 acres burned within the Battle Mountain District, substantially more acres than the average of 5,900 

acres that burned annually during the previous 10 years. 

3 Bars Project Final EIS 3-247 October 2016 
WILDLAND FIRE AND FIRE MANAGEMENT 

3 Bars Project Final EIS 3-248 October 2016 

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. In Category C areas, prescribed fire use tends to be site-specific and is designed to 

accomplish protection or improvement goals, and the desired future condition is a healthy ecosystem characterized by 

a good distribution and proportion of successional stages that would occur over time under a natural fire regime. The 

remainder of the 3 Bars Project area was categorized as Category B. Under this category, unplanned fire is likely to 

cause negative effects, but these effects may be mitigated through fuels management. Prescribed fire has limited use 

and mechanical treatments are normally preferred (USDOI BLM 2002:10, 12). 

3.14.2.5 Fire Management Plan 

The purpose of the 2004 Fire Management Plan is to identify and integrate all wildland fire management guidance, 

direction, and activities required to implement national fire policy, the National Fire Plan, the Healthy Forest 

Restoration Act, and the Healthy Forest Initiative. The Fire Management Plan also reflects and integrates fire 

management direction from the Shoshone-Eureka RMP, and the Shoshone-Eureka Fire Land Use Plan Amendment. 

Management direction allows for fire to be restored as an integral part of the ecosystem to meet resource management 

objectives on BLM-administered lands. The Fire Management Plan identifies and directs fire strategies to provide for 

firefighter safety, the protection of human life, and the safeguarding of private property through aggressive fire 

protection, reduction of hazardous fuels, and restoration of fire-damaged ecosystems. 

Fire Management Plan Objectives 

The Fire Management Plan identifies numerous objectives for managing fires in the project area. These include: 

 Protection of human life, safety of wildland firefighters, and protection of human safety and health.

 Protection of private property and natural and cultural resources, including preventing the destruction of 

cultural properties from suppression actions.

 Protection of communities and associated infrastructure.

 Providing for vegetative and ecological diversity.

 Protection of important wildlife habitat from devastating wildland fire effects.

 Protection of all fisheries, including existing and historical Lahontan cutthroat trout habitats.

 Protection of HMA foaling areas during foaling seasons.

 Providing for vegetative and ecological diversity.

 Protection of important raptor nesting habitat. 

 Protection of riparian zones from devastating wildland fire effects.

 Restoring fire as an integral part of the ecosystem.

 Using mechanical treatments to reduce wildfire fuel hazards. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-249 October 2016 

 Fire is considered a natural and desirable element in WSAs. Interim guidance directs BLM to rely on 

methods least damaging to wilderness values, and to limit surface disturbance to the protection of life and 

private property. All WSAs are managed as Visual Resource Management Class I areas.

 Rehabilitation and restoration of all wildfires 300 acres or larger.

In addition, the Fire Management Plan identifies several objectives for managing prescribed fires in the project area. 

These are: 

 Utilize prescribed fire to mitigate hazardous fuels to acceptable levels. 

 Utilize prescribed fire to promote resource management to maintain the natural component of the ecosystem 

and restore fire as an integral part of the ecosystem. 

 Utilize wildland fire for resource benefit to maintain important habitat and restore fire as an integral part of 

the ecosystem as approved by site-specific activity level document. 

 Restore pinyon pine and juniper woodland density and coverage to the approximate values found under 

natural fire return intervals. 

3.14.2.6 Fire Management Units 

As discussed in the Fire Management Plan, the BLM has divided the Battle Mountain District into Fire Management 

Units (FMUs). A FMU is a specific land management area that is defined by fire management objectives, 

management constraints, topographic features, access, values to be protected, political boundaries, fuel types, and/or 

major fire regime groups. The Battle Mountain FMUs are scaled to best define predominate fire management 

objectives, physical characteristics, resource values, and fire planning attributes, including for lands within the 3 Bars 

Project area (USDOI BLM 2004a).

The 3 Bars Project area is part of five FMUs—Big Smoky (NV-060-13), Three Bars (NV-060-15), Roberts (NV-060-

17), Reese River/Grass Valley (NV-060-18), and Eureka/Diamond Valley (NV-060-21; Figure 3-35). The following 

summarizes information from the 2004 Fire Management Plan. 

3.14.2.6.1 Big Smoky (NV-060-13)

The Big Smoky FMU lies between the Toiyabe Mountain Range to the west, and the Toquima Mountain Range to the 

east. The FMU is 407,715 acres, of which 96 percent of acres are administered by the BLM; 19,758 acres are within 

the project area. Most of the vegetation is salt-desert shrub, but some sagebrush pockets exist. During 1980 to 2003, 

the average wildfire size was less than an acre and nearly all wildfires were started by lighting, with a few fires started 

by humans. 

Wildfires typically occur during May through October. Temperatures during the fire season typically range from the 

mid-80s to the upper 90s °F with relative humidity typically in the teens or single digits. Summer thunderstorms bring 

frequent lightning and can bring brief, heavy rains. Occasionally, dry or isolated thunderstorms plague the District 

with multiple ignitions. 

Fire is an uncommon component of salt-desert shrub ecosystems as is abundant fine fuel loadings. Wind-driven fires 

in the sagebrush can advance with high rates of spread and can cover vast distances quickly. Fires in the salt-desert 

shrub vary in intensity and are highly dependent on the presence of fine fuels. The presence of cheatgrass can 
WILDLAND FIRE AND FIRE MANAGEMENT 

dramatically shorten fire return intervals in all vegetative communities and cause fires to spread very quickly, but very 

little cheatgrass has been seen in this FMU. Live fuel moisture, pathogens, relative humidity, wind, and slope will 

greatly influence fire behavior in these desert fuel types. 

The salt-desert scrub communities are Fire Regime IV and FRCC I. The sagebrush/grass communities are Fire 

Regime II and FRCC II. 

 

3.14.2.6.2 Three Bars (NV-060-15)

The Three Bars FMU is in Lander and Eureka Counties and is 880,852 acres; approximately 618,601 acres are within 

the project area. The FMU is bound on the west by Grass Valley, on the south by the U.S. Highway 50, on the east by 

Diamond Valley, and on the north by the District Boundary. U.S. Highway 50 and State Highway 278 provide the 

primary access to this FMU. Over 97 percent of this FMU is administered by the BLM. The unit is rated as having 

high value habitat, with over 85 percent of vegetation comprised of pinyon-juniper and sagebrush. During 1980 to 

2003, the average wildfire size was about 300 acres and nearly all wildfires were started by lighting, with a few fires 

started by humans. 

Wildland fires typically occur during May through September. Maximum temperatures for this FMU rarely exceed 

100 °F during this period. Frequent lightning storms bring moderate amounts of precipitation occur throughout the 

summer.

Fire behavior differs in the three fuel types found in this FMU. Fires in sagebrush, which is the dominant fuel type, 

historically were medium sized and of mixed severity. Recent sagebrush fires in this FMU have been medium-sized 

fires but of high severity. Fires in pinyon-juniper stands are characterized by either single tree/small group fires or 

large, stand-replacing events. Salt-desert shrub fires typically only burn under severe conditions (i.e., high wind, low 

relative humidity, and with abundant fine fuel loading). Fire is a relatively uncommon component of salt-desert shrub 

fuel types. Living vegetation fuel moisture, pathogens, relative humidity, fine fuels, wind, and slope will greatly 

influence fire behavior in these fuel types. Fires in the sagebrush and salt-desert shrub types are generally easier to 

suppress than fires in the pinyon-juniper type. 

The pinyon-juniper and sagebrush types are in Fire Regime II and FRCC II. 

3.14.2.6.3 Roberts (NV-060-17)

The Roberts FMU consists of 39,192 acres in the Roberts Mountains of Eureka County, and these acres are within the 

project area. State Highway 278 and the Alpha Road provide the primary access to this FMU. One hundred percent of 

this FMU is administered by the BLM. The unit is rated as Special Management Area, with vegetation comprised 

mostly of pinyon-juniper, mountain shrub, and sagebrush. During 1980 to 2003, the average wildfire size was about 3 

acres and nearly all wildfires were started by lighting. 

Wildfires typically occur during May through September. Maximum temperatures for this FMU rarely exceed 100 °F 

during this period. Frequent lightning storms bring moderate amounts of precipitation during the summer.

Fire behavior differs in two main fuel types. Fires in the pinyon-juniper type are characterized by either single 

tree/small group fires or large stand replacing events. Fires in the sagebrush type are historically characterized by 

medium-sized fires of mixed severity. Lately, the trend has been medium- to large-sized fires of moderate to high 

severity. Living vegetation fuel moisture, pathogens, relative humidity, fine fuels, wind, and slope will greatly 

3 Bars Project Final EIS 3-250 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-251 October 2016 

influence fire behavior in these fuel types. Fires in sagebrush are generally easier to suppress than fires in the pinyonjuniper type.

The pinyon-juniper type and sagebrush type are in Fire Regime II and FRCC II. 

3.14.2.6.4 Reese River/Grass Valley (NV-060-18)

The Reese River/Grass Valley FMU lies in the northern portion of the District and is 843,149 acres; only a portion of 

the FMU is in the project area (40,501 acres). The portion of the FMU in the project area is bordered by U.S. 

Highway 50 on the south and the Dry Hills and the Cortez Mountains on the east. This FMU in the project area is 

administered by the BLM. Much of the unit contains cheatgrass. Fires are often quite large (greater than 1,000 acres) 

and are started by lighting and human causes. 

Wildfires typically occur during May through October. Wind driven fires in the sagebrush can advance with high 

rates of spread and can cover vast distances quickly. Fires in the salt-desert shrub vary in intensity and are highly 

dependent on the presence of fine fuels. Fire is an uncommon component of salt-desert shrub ecosystems as are 

abundant fine fuel loadings. Areas where cheatgrass have invaded are at the highest risk for fire. The presence of 

cheatgrass can dramatically shorten fire return intervals in all vegetative communities and cause fires to spread very 

quickly. Living vegetation fuel moisture, pathogens, relative humidity, wind, and slope will greatly influence fire 

behavior in these fuel types. 

The vast majority of the FMU occurs in valley locations. In these areas, diurnal winds and temperatures can vary 

greatly. These areas can experience 180-degree changes in slope and valley winds. Additionally, these locations are 

prone to intense heating (heat sinks) during the day and rapid cooling at night. Generally cool air flows to the lowest 

elevations at night, which are typically the valley locations. The mountains and valleys are aligned southwest to 

northeast, which is in concert with the typical prevailing wind direction. This FMU has a history of having large 

wildfires, most recently, the wildfires of 1999. The 1999 Antelope fire burned nearly 100,000 acres. Thunderstorms 

have been responsible for erratic and rapid fire spread during past fire events. 

The sagebrush type is in Fire Regime II and FRCC III, and the salt-desert shrub communities are in Fire Regime IV 

and FRCC III. 

3.14.2.6.5 Eureka/Diamond Valley (NV-060-21)

The Eureka-Diamond Valley FMU is 243,330 acres in Eureka County in the southern end of Diamond Valley; 30,573 

acres are within the project area. The FMU is bound on the east by the Diamond Mountain Range, on the west by the 

Mountain Boy Range, on the north by Alkali Flat, and the south by the Fish Creek Range. U.S. Highway 50 and State 

Route 278 provide the primary access to this FMU. Seventy-nine percent of this FMU is administered by the BLM, 

while 20 percent is privately owned. The unit is rated as Wildland Urban Interface, with 74 percent of vegetation 

comprised of pinyon-juniper, mountain shrub, and sagebrush, and 20 percent not having significant vegetation. 

During 1980 to 2003, the average wildfire size was about 500 acres and most wildfires were started by lighting. 

Wildfires typically occur May through September. Maximum temperatures for this FMU rarely exceed 90 °F during 

the same period. Frequent lightning storms bring moderate to heavy amounts of precipitation during the summer. 

Fires in the pinyon-juniper type are characterized by either single tree/small group fires or large stand replacing events. 

Fires in the sagebrush type are historically characterized by medium-sized fires of mixed severity. Living vegetation 
WILDLAND FIRE AND FIRE MANAGEMENT 

fuel moisture, pathogens, relative humidity, fine fuels, wind, and slope will greatly influence fire behavior in both of 

these fuel types. Diamond Valley is a heat sink for this FMU and could significantly alter fire behavior.

The pinyon-juniper type and sagebrush types are in Fire Regime II and FRCC II. 

3.14.3 Environmental Consequences 

3.14.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

The following fire management issues were identified by the public during scoping: 

 Concern that the BLM thinks it can impose fire and other treatments to restore the historical ranges of fire 

occurrence and achieve an artificially desired future condition. 

 Fuels reduction should only occur in the wildland-urban interface or where there is a threat of significant 

wildfire. 

 Assess whether seeding crested wheatgrass, grazing, and high stocking rates may result in more extensive 

and larger acreage fires. 

 The BLM should develop a methodology to prioritize any treatments of hazardous fuels. 

 The BLM needs to provide a full accounting of all fuels/fire/habitat projects conducted by the District in the 

past 10 years. 

3.14.3.2 Significance Criteria 

Impacts from the alternatives would be considered significant if they caused 1) a change from a lower FRCC to a 

higher FRCC (e.g., from FRCC I to FRCC II or FRCC II to FRCC III), 2) an increase in risk of loss of life or property 

from wildland fire, or 3) an increase in the risk of a catastrophic wildfire. 

3.14.3.3 Direct and Indirect Effects 

3.14.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Effects 

In general, proposed treatments would have few adverse impacts on wildfire risk. It is possible that the use of vehicles 

to transport workers to the treatment site, or use of chainsaws or other gas-powered equipment could cause a spark 

that results in a wildfire. Vehicles could also transport noxious weeds and other invasive non-native vegetation seeds 

and vegetative parts from a treatment site to other 3 Bars Project areas, resulting in noxious weeds and other invasive 

non-native vegetation spread and increased risk of wildfire. However, these risks would be minor as transport vehicles 

would contain fire extinguishers and other fire suppression equipment and would generally remain on roads. If slash 

or other woody material from woodland treatments were not disposed of properly, they could serve as an ignition 

source for a wildfire. To reduce this risk, felled trees would be disposed of by using trees for posts or as mulch, by 

selling trees for commercial use, by placing logs in streams to slow water flow, or by burning piles or slash. 

3 Bars Project Final EIS 3-252 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Beneficial Effects 

Treatments that remove hazardous fuels from public lands would be expected to benefit the health of plant 

communities in which natural fire cycles have been altered. Fire suppression leads to the buildup of unhealthy and 

dead plant materials (e.g., litter and dead woody materials), and often increases the density of flammable living fuels 

on a site (e.g., dead branches on living shrubs or live plants, especially during dry periods) that can lead to crown fires 

(Cochrane et al. 2012). The resultant fires burn hotter, spread more quickly, and consume more plant materials than 

historical wildfires that occurred under conditions of lower fuel loading. In addition, human-caused wildland fires 

occur with greater frequency than they historically did, resulting in altered plant community structure. Treatments that 

restore and maintain fire-adapted ecosystems, through the appropriate use of mechanical thinning, fire use, and other 

vegetation treatment methods, would decrease the effects from fire to communities and improve ecosystem resilience 

and sustainability (USDOI BLM 2007c:4-53). 

Creating and maintaining fire and fuel breaks would be a common objective of many of the treatments proposed on 

the 3 Bars ecosystem. This includes creating green strips and shaded fuel breaks to compartmentalize wildland fire 

and reduce the risk of a catastrophic wildfire. The BLM would use existing barriers/breaks to halt fire spread to the 

extent practicable, and use thinnings and plantings adjacent to barriers/breaks to enhance their effectiveness. Fire and 

fuel breaks would be created or enhanced under all alternatives, and would primarily be created using manual and 

mechanical methods. 

3.14.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Under Alternative A, the BLM would meet FMU objectives under the Fire Management Plan (USDOI BLM 2004a). 

The BLM would be able to reduce hazardous fuels, and create fire and fuel breaks to slow the spread of a wildfire. 

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. 

Riparian Treatments 

Adverse Effects 

Prescribed fire treatments could jump fire boundaries and burn a larger area than planned. In addition, seeding may be 

needed, and livestock would need to be kept off of treated areas for at least 2 growing seasons after a prescribed fire, 

to promote the development of native forage and give forage ample time to recover (USDOI BLM 2007c:4-96). 

Beneficial Effects 

Riparian treatments would help to reduce the risk of wildfire by reducing hazardous fuels and restoring natural fire 

regimes in riparian zones. Manual and mechanical treatments would help restore and enhance riparian function, and 

improve the ability of streams and associated riparian, wetland, and floodplain habitat to serve as a fuel break. At 

Hash Spring and several other springs, and at project sites where Lahontan cutthroat trout habitat improvements 

would occur, the BLM would improve riparian habitat by removing pinyon-juniper using manual and mechanical 

methods or prescribed fire. Most pinyon-juniper removal would occur adjacent to roads or other fire breaks, or to 

create or enhance fuel breaks adjacent to riparian zones. Fuel and fire breaks would help to control the spread of 

wildfires. 

3 Bars Project Final EIS 3-253 October 2016 
WILDLAND FIRE AND FIRE MANAGEMENT 

Aspen Treatments 

Some slash from pinyon-juniper treatments would be left in place to promote aspen suckering and seedling 

establishment, or to act as deadfall to limit livestock, wild horse, and other wild ungulate movement onto treatment 

areas. This woody material could provide fuel for a wildfire until it decomposes. However, this risk would be 

minimized by gathering up excess material and selling it to the public, or pile/slash burning the material. 

Actions that stimulate or enhance aspen suckering and sucker survival should improve the health of aspen stands, and, 

long-term, reduce the amount of dead and decaying vegetation in these stands that could provide fuel for a wildfire. 

Pinyon-juniper Treatments 

Adverse Effects 

On the Lone Mountain area of Kobeh Valley, trees would be thinned primarily by using chainsaws. Downed trees and 

other woody material could serve as fuel for a wildfire. Slash from chainsaw treatments in late Phase II and Phase III 

woodlands can create a fire hazard for at least 2 years, and may open sites for introduction of invasive plant species 

(Tausch et al. 2009). Woody material from shredding treatments can also contribute to available fuels and often 

creates favorable conditions for noxious weeds and other invasive non-native species (Gottfried and Overby 2011). 

On the Atlas, Frazier, and several other units, pinyon-juniper would be removed using manual and mechanical 

treatments. If not disposed of properly, uprooted and downed trees and slash could provide fuels for a wildfire and 

serve as a conduit for carrying a wildfire between valley and mountain areas. To reduce this risk, felled trees would be 

used for posts or mulch, sold for forest products use, placed in streams to slow water flow, or burned in piles or as 

slash. 

Fire treatments could expose bare soil and allow noxious weeds and other invasive non-native vegetation, such as 

cheatgrass, to establish and spread. The BLM has conducted monitoring at prescribed fire treatment areas, and has 

found that noxious weeds and other invasive non-native vegetation may be found at treatment sites post-burn. At the 

Red Hills site, for example, very low to low densities of cheatgrass were seen at about half of the monitoring stations 

1 year after the burn, especially in areas of high-severity burning (USDOI BLM 2008i). As of 2013, cheatgrass is still 

present in the Red Hills project, but its coverage is very spotty across the landscape both in where it occurs and how 

much occurs. No monitoring of the site was done in 2013, but monitoring is scheduled for 2014 (Lewis 2014). 

Beneficial Effects 

Manual, mechanical, and fire treatments in pinyon-juniper management areas would provide several benefits. 

Creating and enhancing fuel breaks in pinyon-juniper stands would break up the continuity of fuel, moderate fire 

behavior, and reduce the risk of loss of habitat and other resources from a catastrophic wildfire. 

The BLM would place downed logs into streams to slow water flow. Logs should help to expand the size of streams 

where gradients are more gradual, and these stream features could also serve as fuel breaks to slow the spread of 

wildfire. 

On the Cottonwood/Meadow Canyon, Dry Canyon, Three Bars Ranch, Tonkin North, and Whistler units, the focus of 

treatments would be on hazardous fuels reduction using manual and mechanical methods and prescribed fire. Much of 

the west slope of Roberts Mountains has not experienced a large-scale wildfire in over 100 years. These units have 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

been identified as having high to very high risk of catastrophic wildfire, or in the case of the Tonkin North 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). 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). 

Monitoring at the Red Hills hazardous fuels reduction project, which included prescribed fire and mechanical 

treatments, showed that treatments helped to reduce hazardous fuels and wildfire risk. The risk of wildfire was 

reduced from a “very high to extreme” risk to “low” risk at 35 monitoring sites, and “low to moderate” risk at 5 sites. 

The FRCC Rating was II before the burn, and was “low II” after the burn. A variety of desirable forbs, grasses, and 

shrubs were observed re-colonizing treatment areas, and fuel breaks were still viable (USDOI BLM 2008i). 

Pathogens and pests, including mistletoe, have led to unhealthy pinyon-juniper stands in the Tonkin North and South 

units and a build-up of hazardous fuels. The BLM proposes to remove up to half of the trees using manual and 

mechanical means and prescribed fire. These projects would enhance the health and resilience of pinyon-juniper 

woodlands and reduce the amount of hazardous fuels and wildfire risk. In recent years, the BLM has conducted 

hazardous fuels reduction treatments in the Tonkin Springs area using chainsaws, bull-hogs, and feller-bunchers, and 

created fuel breaks using a rotary mower (USDOI BLM 2005b).

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 pinyon-juniper 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 cover should 

increase, a more natural fire regime would be restored in the area, and the risk of future wildfires would be 

diminished. 

Regardless of the cause of the fires in pinyon-juniper habitat, 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 (USDOI BLM 2011e). To ensure 

vegetation restoration success, the BLM may exclude livestock access to the area through grazing closure decisions, 

competed through a separate process. The BLM may also use small, temporary exclusion 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 (USDOI BLM 2009a, d, 2010e, f, g, h, i, j, 2011e, f).

The BLM would carefully monitor prescribed fire treatment sites to ensure that cheatgrass and other invasive nonnative vegetation does not become established on these areas. In general, burns at lower elevations are more likely to 

have noxious weeds and other invasive non-native vegetation issues than treatments at higher elevations. Monitoring 

for the Red Hills hazardous fuels reduction project 1 year after prescribed fire and mechanical treatments showed 

evidence of cheatgrass in areas where severe burning occurred, but no cheatgrass or other noxious weeds and other 

invasive non-native vegetation in areas where burning was less severe (USDOI BLM 2008i). As of 2013, cheatgrass 

is still present in the Red Hills project, but its coverage is very spotty across the landscape both in where it occurs and 

how much occurs 5 years after treatment. No monitoring of the site was done in 2013, but monitoring is scheduled for 

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WILDLAND FIRE AND FIRE MANAGEMENT 

2014 (Lewis 2014). Cheatgrass and other noxious weeds and other invasive non-native vegetation can be controlled 

on wildland fire sites using herbicides, but it may take several years before this vegetation is brought under control 

(USDOI BLM 2011e, f).

Sagebrush Treatments 

Adverse Effects 

Where trees or sagebrush are left on the ground as slash, or piled, the potential for this material to serve as fuel for a 

wildfire exists. Pinyon-juniper trees would be disposed of by using trees for posts or mulch, selling trees, or placing 

them in streams. Treatments of noxious weeds and other invasive non-native vegetation would result in dead 

vegetation that could provide fuel for a hazardous wildfire until the site was restored using native vegetation or 

crested wheatgrass or forage kochia. 

Beneficial Effects 

At sites dominated by herbaceous or invasive species, such as the Rocky Hills and West Simpson Park units, the units 

could be treated using mechanical methods. 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 the Rocky Hills Unit, and the unit has 

little sagebrush habitat. The BLM would use mechanical methods (discing and broadcast/drill seeding) to reduce 

herbaceous vegetation and promote the establishment of a native sagebrush community. The BLM may also use 

prescribed fire and biological control (livestock grazing) to also remove cheatgrass prior to seeding at the West 

Simpson Park Unit. 

3.14.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The risk of treatments causing a wildfire that spreads beyond treatment boundaries would be less under this 

alternative than Alternative A. Miles traveled by vehicles, the number of acres treated using manual and mechanical 

equipment, the amount of downed trees and slash material created, and the miles of fire and fuel breaks created would 

be similar between this alternative and Alternative A. Because the BLM would not use prescribed fire to treat 

vegetation under this alternative, there would be no risk of a prescribed fire spreading beyond treatment boundaries. 

Without the use of prescribed fire and wildland fire for resource benefit, the BLM would be less likely to 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 than under Alternative A. About 8 percent of the 3 Bars Project area would be 

treated under this alternative. About 1,000 to 2,000 acres would be treated annually to reduce hazardous fuels, and the 

FRCC would be reduced on about 7,500 to 15,000 acres over the next 10 to 15 years. It is unlikely the trend toward 

large-sized fires of moderate to high severity in sagebrush and large stand-replacing fires in pinyon-juniper would 

slow or reverse in the long-term, however, and the BLM would still need an aggressive wildland fire prevention and 

control program for the long-term. 

Treatments would help to meet some of the FMU objectives under the Fire Management Plan (USDOI BLM 2004a), 

but not to the same extent as they would under Alternative A. Manual and mechanical treatments would help to 

reduce hazardous fuels, protect and improve fish and wildlife habitat, and create fire and fuel breaks to slow the 

spread of a wildfire. Prescribed fire and fire for resource benefit are identified as important treatment options under 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

the Fire Management Plan for all FMUs, except the Big Smoky FMU, but would be unavailable to the BLM as a 

management tool under this alternative. 

3.14.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

This alternative focuses on the use of treatments that would have minimal ground disturbance. Recovery of vegetation 

through this more passive management approach is expected to take longer than under active management, where 

treatments such as seeding with native species, establishing intermediate vegetation to control erosion, and use of fire 

to reduce hazardous fuels, would be expected to promote faster recovery. 

Under this alternative, there would be no wildland fire risks associated with the use of prescribed fire. The BLM 

would not use mechanical equipment (other than vehicles to transport work crews to treatment sites), so there would 

be no risk of a wildland fire being started by tractors, mowers, and other mechanical treatment equipment. However, 

workers would still use chainsaws and other hand-held power equipment that could cause a spark and start a wildland 

fire. Large numbers of workers and their vehicles would be needed to accomplish proposed treatments under this 

alternative. Vehicle miles traveled would likely be greatest under this alternative. Downed trees and slash material 

from treatments would be difficult to remove without mechanical equipment or pile/slash burning. 

The number of miles of fire and fuel breaks created under this alternative would be less than under Alternatives A and 

B, as the BLM would not be able to use mechanical equipment, such as bulldozers, mowers, and mulchers, and 

prescribed fire to create fire and fuel breaks. 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. 

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. 

The BLM would not meet FMU objectives under the Fire Management Plan (USDOI BLM 2004a). Manual 

treatments could be used to create a few miles of fuel breaks to slow the spread of a wildfire. Although the BLM 

could treat acreage using manual methods as proposed for each FMU, the BLM would not be able to conduct fire 

treatments as recommended in the Fire Management Plan to reduce hazardous fuels and the risk of a catastrophic 

wildfire in FMUs. 

3.14.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to wildland fire from 3 Bars Project treatments as no treatments would be authorized 

under this alternative. Under this alternative, the BLM would not meet the fire use purposes to 1) restore fire as an 

integral part of the ecosystem, 2) reduce the risk of a large-scale wildfire, 3) reduce extreme, very high, and high 

wildfire risks to moderate risk or less, and 4) develop fuel breaks within treatment and adjacent areas. Threats to 

ecosystem health that could lead to catastrophic wildfire under this alternative would be associated with the ongoing 

expansion of noxious weeds and other invasive non-native vegetation; continued decline of ecosystem health due to 

further decline in native understory species in the upland plant communities; further expansion of pinyon-juniper 

woodland into other communities, including sagebrush, riparian, and aspen habitats; and an increase of fuel loads. 

There would be no improvement in the FRCC on the 3 Bars Project area and the BLM would not meet FMU 

objectives.

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WILDLAND FIRE AND FIRE MANAGEMENT 

3.14.3.4 Cumulative Effects 

The CESA for wildland fire is approximately 1.84 million acres and includes those watersheds at the Hydrologic Unit 

Code 10 level that are all or partially within the 3 Bars Project area (Figure 3-1). Approximately 92 percent of the 

area is administered by the BLM, 6 percent is privately owned, and 2 percent is administered by the Forest Service. 

Past and present actions that have influenced wildland fire activity in the 3 Bars ecosystem are discussed in Section 

3.3.2.3.3.

3.14.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

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. 

In the short-term, small, temporary fences may change the distribution of grazing by livestock, wild horses, and 

wildlife. As distribution patterns change, utilization would also change. Utilization would decrease in treatment areas 

while temporary exclusion fences are in place, but would increase in other areas. Once the temporary exclusion fences 

are removed, animals may be attracted to the treatment areas resulting in potentially higher use of the area than 

before. Temporary exclusion fences would exclude livestock, although AUMs may be temporarily suspended to 

prevent overuse in other areas. 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and aerial-based application methods to remove cheatgrass, and would restore burned areas 

under the Burned Area Emergency Stabilization and Rehabilitation program, under existing authorizations on about 

1,000 acres annually. These treatments could have a short-term adverse effect on non-target vegetation. These 

treatments would have long-term beneficial effects by helping to reduce hazardous fuels, improving native vegetation, 

slowing the spread of noxious weeds and other invasive non-native vegetation, and reducing surface runoff and 

erosion associated with burn sites on about 1,000 acres annually. 

As discussed earlier, the BLM conducts fuel treatment projects under the direction of the Fire Management Plan. In 

addition to those areas identified under the proposed action, the BLM also proposes to treat hazardous fuels on an 

additional 8,300 acres in high to very high fire risk areas on and near the 3 Bars Project area. These include treatments 

in pinyon-juniper and sagebrush habitat using prescribed fire and manual and mechanical methods to remove pinyonjuniper, enhance wildlife habitat, and create fuel breaks. 

Recreational use of the 3 Bars Project area increases the risk of a wildland fire due to accidental or intentional ignition 

of vegetation from a campfire, cigarette, hot vehicle muffler, or other human-caused ignition source. In addition, 

recreational users can spread noxious weeds and other invasive non-native vegetation that attaches to vehicles or to 

clothing or shoes, and can later cause new noxious weeds and other invasive non-native vegetation infestations and 

provide fuels for a wildland fire. 

Land, mineral, oil, gas, geothermal, and other development would cause land disturbance and the spread of noxious 

weeds and other invasive non-native vegetation within the 3 Bars Project and nearby areas. Development would lead 

to additional human activity in the area, and increase the potential for a human-caused wildland fire. The BLM and 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

other fire-fighting agencies would have to contribute labor and equipment to protect developments from loss of 

human life and property from wildfire, instead of allowing these areas to burn naturally. 

Hazardous fuels treatments would occur on about 142,000 acres (9 percent) of lands within the CESA. Although this 

would still be a small portion of lands within the CESA, treatments would be targeted toward public lands with high 

to very high wildfire risk. Given that over 90 percent of acres impacted by future actions are focused on hazardous 

fuels reduction and resource management, treatments would reduce wildfire risk long-term. At fire management 

treatment levels projected to occur in the CESA during the next 25 years under Alternative A, the BLM should meet 

the FMU objectives for most FMUs (USDOI BLM 2004a). The FRCC on about 142,000 acres would improve over 

the next 25 years. 

3.14.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on wildfire would be 

similar to those described under Alternative A. The BLM anticipates treating about half as many acres under 

Alternative B as under Alternative A. Because the BLM would not use fire to treat vegetation on the 3 Bars Project 

area, the risk of a prescribed fire spreading beyond treatment boundaries would be less under this alternative than 

under Alternative A. However, the BLM would less able to restore fire as an integral part of the ecosystem; reduce the 

risk of a large-scale wildland fire; slow the spread of noxious weeds and other invasive and non-native vegetation; or 

reduce extreme, very high, and high wildfire risks to moderate risk or less under this alternative than under 

Alternative A on the 3 Bars Project area. 

About 78,000 acres of vegetation would be treated to reduce hazardous fuels and improve rangeland health within the 

CESA, or about 4 percent of the CESA. This would include about 63,000 acres treated annually by the BLM on the 3 

Bars Project area, and about 15,000 acres treated by the BLM on other areas within the CESA. Acres treated to reduce 

the FRCC under this alternative would be half that of Alternative A, and it is also less likely that the BLM would meet 

FMU objectives under the Fire Management Plan under this alternative than under Alternative A on the 3 Bars Project 

area. 

3.14.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on wildland fire would be 

similar to those described under Alternative A. The BLM anticipates treating about one-fourth as many acres under 

Alternative C as under Alternative A, mostly due to the higher costs associated with manual and classical biological 

control methods. The risk of treatments causing a wildland fire would be slightly less under this alternative than 

Alternative A. Because the BLM would not use fire to treat vegetation on the 3 Bars Project area, the risk of a 

prescribed fire spreading beyond treatment boundaries would also be less under this alternative than Alternatives A 

and B. 

By not being able to use mechanical methods, such as mowing, chopping, tilling, discing, harrowing, and drill 

seeding, however, the BLM would do little to reduce hazardous fuels, create fire and fuel breaks, treat areas with 

noxious weeds and other invasive non-native vegetation, or remove downed wood and slash. Under Alternative C, the 

BLM would conduct fire management treatments on only about 2 percent of the CESA. This would include about 

32,000 acres treated by the BLM to reduce hazardous fuels and wildfire risk on the 3 Bars Project area, and about 

15,000 acres treated by the BLM elsewhere within the CESA. Only one-fourth as many acres would be treated to 

reduce the FRCC under this alternative as under Alternative A. It is also less likely that the BLM would meet FMU 

3 Bars Project Final EIS 3-259 October 2016 
WILDLAND FIRE AND FIRE MANAGEMENT 

objectives under the Fire Management Plan under this alternative than under Alternatives A and B on the 3 Bars 

Project area. 

3.14.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on wildland fire would be 

similar to those described under Alternative A. There would be no cumulative effects on wildfire from 3 Bars Project 

treatments as no treatments would be authorized under this alternative. The BLM could create fire and fuel breaks; 

thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and other 

invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the ecosystem; and reduce the 

risk of a large-scale wildfire, but on only about 1,500 acres annually under existing and reasonably foreseeable future 

authorizations. 

Hazardous fuel levels would likely increase, and only a limited number of miles of fuel and fire breaks would be 

constructed under this alternative compared to the action alternatives. The trend toward large-sized fires of moderate 

to high severity in sagebrush, and large stand-replacing fires in pinyon-juniper, would likely increase. The BLM 

would do little to reduce the FRCC, and it is also less likely that the BLM would meet FMU objectives under the Fire 

Management Plan under this alternative than under the action alternatives on the 3 Bars Project area. Given the large 

number of utilities and infrastructure, mineral, oil, gas, geothermal, and other land developments that are reasonably 

foreseeable in the CESA, the need for an aggressive wildland fire prevention and control program to protect natural 

resources and public health and infrastructure could increase from current levels. 

3.14.3.5 Unavoidable Adverse Effects 

There is a risk, albeit small, of treatments causing a wildland fire. Although the BLM would implement SOPs to 

reduce this risk to near nil, it cannot be totally ignored. These risks include the potential for vehicles and manual and 

mechanical equipment to accidentally ignite a wildland fire. A prescribed fire or wildland fire for resource benefit 

could expand beyond treatment boundaries and become a wildland fire that could adversely impact natural and social 

resources. Treatments would result in the production of downed trees and other woody material that could become 

hazardous fuels. Workers and their vehicles could transport noxious weeds and other invasive non-native vegetation 

outside the treatment area, and this vegetation could become a hazardous fuel. Noxious weeds and other invasive nonnative vegetation could also establish and spread in areas treated using prescribed fire and wildland fire for resource 

benefit. 

3.14.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

As discussed throughout this EIS, all restoration treatments would likely result in short-term uses and adverse effects, 

but if treatments are even modestly successful they would benefit land productivity long-term; wildland fire 

management treatments are no exception. Short-term uses have been discussed in other sections of this EIS, including 

the potential loss of vegetation, loss of use of woodland products, loss of fish and wildlife habitat, increase in noxious 

weeds and other invasive non-native vegetation, loss of rangeland for livestock and wild horse use, and loss of public 

use of lands for recreation, as a result of treatments to restore vegetation and other resources, reduce hazardous fuels, 

and reduce the risk of wildfire. Long-term, treatments to reduce the risk of wildfire should enhance the resilience and 

health of the landscape and land productivity, and reduce the risk of future wildfire and resultant loss of natural and 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

social resources. As discussed above, short-term uses and enhancement of long-term productivity would generally be 

in proportion to acres treated and methods used by the BLM. 

3.14.3.7 Irreversible and Irretrievable Commitment of Resources 

Fire management actions could result in an irretrievable loss of resources if they are lost for a period of time and 

cannot be replaced without reclamation. For example, prescribed fire could be used to treat unhealthy pinyon-juniper. 

If the burn is severe enough, native vegetation could be lost and replaced by cheatgrass. However, the site could be 

reclaimed with seedings and plantings of native vegetation. The fact that the BLM is proposing to restore a degraded 

landscape in the 3 Bars Project area suggests that the landscape is resilient, and that natural and man-made causes that 

have led to resource losses that can be corrected and retrieved over time. 

Prescribed fire and wildland fire for resource benefit, and possibly manual and mechanical methods, used for 

hazardous fuels reduction and to reduce wildland fire risk could result in the loss of old-growth pinyon-juniper stands 

that could be considered by some to be irreversible, because it would take several hundred years before old growth 

stands would again occur on the site. 

3.14.3.8 Significance of the Effects under the Alternatives 

Treatment actions under all of the alternatives would not lead to a significant increase in wildland fire risk on the 3 

Bars Project area and CESA. Treatments would help maintain or reduce the FRCC in treatment areas, reduce the risk 

of loss of life or property from wildland fire, and reduce the risk of a catastrophic fire. However, the alternatives 

would differ substantially in the magnitude of improvements, and whether restoration actions taken under an 

alternative would be effective in lowering overall wildland fire risks within the 3 Bars ecosystem. 

Substantially more acres within the CESA would be treated under Alternative A than the other alternatives, and over 

the next 10 to 15 years about 17 percent of the acreage on the 3 Bars Project area would be treated under this 

alternative. Thus, the potential for meaningful improvement in the landscape is greatest under this alternative. Under 

Alternative A, the potential for loss of life or property from wildland fire on the 3 Bars Project area would probably 

remain little changed from current conditions over the short-term, but should decrease long-term as fire return 

intervals in pinyon-juniper stands return to more natural cycles, hazardous fuels levels decrease, fire and fuel breaks 

are installed, and the landscape becomes more fire resilient. Although the change in overall FRCC would be slow, 

long-term it is likely that there would be a general shift in acreage from a higher FRCC to a lower one. It is also 

assumed that the risks of a catastrophic wildfire would decrease as resource conditions improve within the CESA due 

to fire management and other treatments under Alternative A. 

Under Alternative B, the BLM would be limited to the use of manual, mechanical, and biological control methods and 

would treat about half as many acres (about 7,800 acres annually) within the CESA compared to Alternative A. Under 

this alternative, the potential for loss of life or property from wildland fire on the 3 Bars Project area would probably 

remain little changed from current conditions. The BLM would not be able to use prescribed fire and fire for resource 

benefit or herbicides to reduce hazardous fuels, but would be able to compartmentalize and slow the spread of 

wildland fire using manual and mechanical treatments to create fire and fuel breaks. Because fire would not be 

available to the BLM to help to restore nature fire cycles on the 3 Bars ecosystem, the ability of the BLM to improve 

ecosystem health and resiliency and reduce hazardous fuels would be limited. 

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WILDLAND FIRE AND FIRE MANAGEMENT 

Under Alternative C, the BLM would be limited to use of manual and classical biological control methods and would 

treat only about one-fourth the acreage treated under Alternative A. Treatments would primarily focus on riparian and 

aspen restoration and removal of pinyon-juniper in Phase I and II woodlands, and creation of fire and fuel breaks. 

Little hazardous fuels reduction or noxious weed and other invasive non-native vegetation control would occur, and 

fire and fuel break treatments would be limited to areas adjacent to roads and streams. The BLM would have limited 

ability to reduce the risk of a catastrophic fire and to control its spread, and risks of loss of life or property from 

wildfire within the CESA would likely increase long-term. Prescribed fire and fire for resource benefit would not be 

available to the BLM to help to restore nature fire cycles over portions of the 3 Bars ecosystem, and mechanical 

treatments would not be available for use to control or eliminate noxious weeds and other invasive non-native 

vegetation, create fire and fuel breaks, thin and remove pinyon-juniper that is encroaching into sagebrush habitat or is 

unhealthy, and to reseed disturbed areas. Thus, the ability of the BLM to improve ecosystem health and resiliency and 

reduce hazardous fuels would be more limited under Alternative C than under the other action alternatives. 

3.14.4 Mitigation 

No mitigation measures are proposed for wildland fire risk.

3.15 Fish and Other Aquatic Resources 

3.15.1 Regulatory Framework 

Several laws protect fish and other aquatic resources and their habitats. The Sikes Act of 1974 authorizes the USDOI 

to plan, develop, maintain, and coordinate programs with state agencies for the conservation and rehabilitation of 

wildlife, fish, and game on public lands. The Fish and Wildlife Conservation Act of 1980 encourages federal agencies 

to conserve and promote the conservation of non-game fish and wildlife species and their habitats. 

3.15.1.1 Endangered Species Act 

In accordance with Section 7 of the Endangered Species Act, federal agencies must “insure that any action authorized, 

funded, or carried out by such agency is not likely to jeopardize the continued existence of any listed species or result 

in the destruction or adverse modification of critical habitat of such species.” The purpose of the Act is to provide a 

means for conserving the ecosystems upon which threatened and endangered species depend, and to provide a 

program for protecting these species. The Act defines an endangered species as a species that is in danger of 

extinction throughout all or a major portion of its range. A threatened species is defined as any species that is likely to 

become an endangered species within the foreseeable future throughout all or a major portion of its range. This Act 

also addresses species that have been proposed for listing as either threatened or endangered, but for which a final 

determination has not been made. Critical habitat is a specific area or type of area that is considered to be essential for 

the survival of a species, as designated by the USFWS under the Endangered Species Act. The Lahontan cutthroat 

trout is the only federally listed (threatened) species that occurs on the 3 Bars Project area. 

3.15.1.2 Special Status Species 

BLM Sensitive Species are defined as those plant and animal species for which population viability is a concern, as 

evidenced by: 1) significant current or predicted downward trend in population numbers or density, or 2) a significant 

current or predicted downward trend in habitat capability that would reduce the species’ existing distribution. These 

species are protected under provisions of the Endangered Species Act or under the Nevada BLM sensitive status 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

(BLM Manual 6840, Special Status Species Management; USDOI BLM 2008h). In addition, there is a Nevada State 

Protected Animal List (Nevada Administrative Code 501.100 - 503.104) that the BLM has incorporated, in part, into 

the sensitive species list. No BLM sensitive aquatic species are known to occur within the project area. 

3.15.1.3 BLM and Nevada Department of Wildlife Memorandum of Understanding 

Wildlife and fish resources and their habitat on public lands are managed cooperatively by the BLM and NDOW 

under a Memorandum of Understanding as established in 1971. The Memorandum of Understanding describes the 

BLM’s commitment to manage wildlife and fisheries resource habitat, and the NDOW’s role in managing 

populations. The ecological definition of a population is a group of organisms of one species that interbreed and live 

in the same place at the same time. The BLM meets its obligations by managing public lands to protect and enhance 

food, shelter, and breeding areas for wild animals. The NDOW assures healthy wildlife numbers through a variety of 

management tools including wildlife and fisheries stocking programs, hunting and fishing regulations, land purchases 

for fish and wildlife management, cooperative enhancement projects, and other activities. 

3.15.1.4 Nevada Department of Wildlife Programs 

The NDOW is the state agency responsible for the restoration and management of fish and wildlife resources within 

the state. The NDOW administers state fish and wildlife management and protection programs as set forth in Nevada 

Revised Statute Chapter 501, Wildlife Administration and Enforcement, and Nevada Administrative Code § 503, 

Hunting, Fishing and Trapping; Miscellaneous Protective Measures. Nevada Revised Statute § 501.110 defines the 

various categories of fish and wildlife in Nevada, including protected categories. Nevada Administrative Code §§ 

503.010-503.080, 503.110, and 503.140 list the fish and wildlife species currently placed in the state’s various legal 

categories, including protected species, game species, and pest species. 

3.15.2 Affected Environment 

3.15.2.1 Study Methods and Study Area 

Aquatic biological resources within the project area include fish and aquatic invertebrates and their habitat. 

Descriptions of fish and other aquatic resources were based on published and unpublished information regarding the 

types of aquatic habitat and their associated species or groups found in the 3 Bars Project area. Data sources used to 

identify habitat and aquatic species occurrences include the Mount Hope Project EIS and references cited therein 

(USDOI BLM 2012b), NDOW reports on fish populations and Lahontan cutthroat trout, the species management plan 

for the Lahontan cutthroat trout (Elliot 2004), and published reports of snails (SRK 2010). In addition, BLM and 

NDOW staff were contacted for information on fish and other aquatic resources on the 3 Bars Project area. 

The study area for direct and indirect effects to aquatic biological resources includes streams, springs, and wetlands 

within the project area. The CESA for cumulative impacts to aquatic biological resources includes the Hydrologic 

Unit Code 10 watersheds wholly, or partially within, the project area, as shown in Figure 3-1. 

3.15.2.2 Aquatic Habitat 

The types of aquatic habitat that occur with the analysis area include perennial, intermittent, and ephemeral streams, 

springs, and wetlands. Perennial waterbodies contain water continuously during an average water year. Intermittent 

waterbodies contain water or flow on a sporadic or periodic basis, while ephemeral waterbodies contain water on a 

3 Bars Project Final EIS 3-263 October 2016 
FISH AND OTHER AQUATIC RESOURCES 

short-term basis after precipitation events. The majority of the streams within the project area are 

2

intermittent/ephemeral. In terms of stream lengths, the Pine Valley Basin contains the greatest number of miles of 

streams with perennial reaches. These streams include Birch, Denay, Henderson, Kelley, North Fork Pete Hansen, 

Pete Hansen, Vinini, and Willow Creeks (Figure 3-22). Of these streams, Henderson and Vinini Creeks contain the 

most perennial lengths, with 18.3 and 9.5 miles, respectively. Roberts Creek, with 8.4 miles, is the only stream in the 

Kobeh Valley Basin that contains perennial reaches. McClusky Creek (7.1 miles of perennial stream length) is the 

only perennial stream in the Grass Valley Basin that is within the 3 Bars Project area. Springs and wet areas are 

scattered throughout the project area. The majority of springs are found at higher elevations in the Simpson Park 

Range, on Roberts Mountains, and in the Sulphur Spring Range. 

Aquatic habitat surveys were conducted in Birch and Pete Hanson Creeks as part of fish surveys in July 2009, and in 

2011 in Willow Creek. These streams were selected for study due to the presence of Lahontan cutthroat trout, a 

federally listed threatened species under the Endangered Species Act. Based on the Habitat Condition Index, NDOW 

rated the stream reaches from poor to good in Birch and Pete Hanson Creeks, and fair to excellent in Willow Creek 

(NDOW 2009a, Starr 2011). The overall Habitat Condition Index rating was good in Birch and Willow Creeks and 

fair in Pete Hansen Creek. The Habitat Condition Index rating involved evaluating six parameters in the field, 

including pool abundance, pool structure, substrate stability, bank cover, soil stability, and bank vegetation stability. 

Downcutting of the stream channel exists in portions of Willow Creek (Starr 2011), but the downcut sections were not 

part of the Willow Creek habitat survey sites. Habitat information for these streams is provided in Table 3-43. 

TABLE 3-43 

Habitat Characteristics of Birch, Pete Hanson, and Willow Creeks

Stream Discharge 

(cfs)2

Average 

Depth 

(feet)

Average 

Width 

(feet)

Substrate (%) Bank Vegetative Cover (%)

Gravel Rubble Trees Shrubs Grasses/Forbs

Birch Creek 1.0-4.3 0.4 4.4 18 38 47 31 22

Pete Hanson

Creek

1.0-4.3 0.4 4.4 44 28 19 36 45

Willow Creek 0.1-1.3 0.2 2.5 53 28 6 31 61

Cfs = cubic feet per second.

Source: NDOW (2009a), Starr (2011). 

Stream assessments were conducted in Birch and Pete Hanson Creeks in 2001 for the purpose of evaluating the 

stream’s ability to dissipate energy, protect banks, and minimize erosion (USDOI BLM 2012b, 2014). The streams’ 

functioning condition was rated in qualitative terms using information about channel morphology, hydrology, soil, 

and vegetative parameters. Of the 5.4 miles of Birch Creek that were surveyed, conditions were rated as Proper 

Functioning Condition for 0.7 mile and Functional-at-risk Downward Trend for 0.4 mile. The remaining 4.3 miles 

 

2

 The USGS does not distinguish between intermittent and ephemeral streams. The majority of streams classified as intermittent on the 3 

Bars Project area do not have seasonal water, but only have water occasionally and would be classified as ephemeral. 

3 Bars Project Final EIS 3-264 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

were classified as an intermittent stream. Assessment results for 9.5 miles of Pete Hanson Creek were Proper 

Functioning Condition (5.3 miles), Functional-at-risk Upward (1.6 miles) Functional-at-risk Trend Not Apparent (1.3 

miles) and Intermittent (1.3 miles). Assessment results for 5.8 miles of Willow Creek were Proper Functioning 

Condition (1.4 miles), Functional-at-risk Upward (1.6 miles), Functional-at-risk Trend Not Apparent (0.8 mile), and 

Non-functional (2.0 miles). Stream evaluations also were completed for other streams within the 3 Bars Project area. 

Several stream reaches did not meet the Proper Functioning Condition or Functional-at-risk Upward Trend including 

perennial streams such as Henderson, Vinini, Roberts, and McClusky Creeks. The NDOW conducted aquatic habitat 

surveys of Birch Creek and Pete Hanson Creek in 2009, and Willow Creek in 2011. Streambank stability, bank 

alteration, and erosion evaluations were completed for these streams in July 2010. The survey indicated that 73 

percent of surveyed reaches had stable streambanks while 16 percent had active bank erosion, in Birch Creek. Similar 

results were observed in Pete Hanson Creek, where 74 percent of reaches surveyed had stable banks, while active 

bank erosion was observed on 15 percent of reaches. Bank alteration from livestock was estimated at 3 percent of the 

surveyed reach in Birch Creek and 4 percent of the surveyed reach in Pete Hanson Creek. Stable streambanks were 

found along 78 percent of surveyed reaches for Willow Creek (USDOI BLM 2014). 

Based on public scoping comments, habitat conditions could be improved in project study area perennial streams that 

contain fish. The public recommended removal of fish barriers consisting of culvert and a large headcut on lower 

Roberts Creek, and habitat improvements on Birch, Pete Hanson, Vinini, Henderson, Roberts, and McClusky Creeks. 

3.15.2.3 Aquatic Species 

3.15.2.3.1 Invertebrates 

Permanent and temporary waterbodies provide habitat for aquatic invertebrates. These aquatic organisms are 

indicators of water quality conditions and they serve important roles in the dynamics of the aquatic food web. Based 

on surveys in Birch Creek, the most abundant invertebrate groups included mayflies (Ephemeroptera), caddiflies 

(Trichoptera), stoneflies (Plecoptera), flies (Diptera), beetles (Coleoptera), and leeches (Hirudinea; USDOI BLM 

2012b). These same groups, as well as snails (Gastropoda) and true bugs (Hemiptera), were common in Pete Hanson 

Creek. Invertebrate groups collected in Willow Creek included mayflies, stoneflies, and beetles (Starr 2011). 

Invertebrates were considered to be abundant at all sites sampled in Willow Creek. 

Five major invertebrate groups typically are present in all types of springs including nematodes, aquatic worms 

(Oligochaeta), water mites (Acari), caddisflies, and chironomid midges. Several groups such as flatworms and 

stoneflies are present only in springs with permanent water sources. 

A regional springsnail survey was conducted in selected springs within Antelope, Diamond, Huntington, Kobeh, 

Little Smokey, and Pine Valleys in 2007 by SRK (2010). Approximately 40 of the surveyed springs are within the 3 

Bars Project area. Six of these springs contained snails, although species were not identified (Figure 3-37). Snails also 

were observed at two sites within unnamed streams in Pine Valley. Some of these snails could be springsnails. This 

group of mollusks is considered important because of their restricted distribution and native origin. The BLM 

considers springsnails to be a sensitive group and manages public lands to protect these species and their habitats. 

3 Bars Project Final EIS 3-265 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-37

Snail Observations

3 Bars Ecosystem and

Landscape Restoration Project

KV015

PV018

PV023

PV032

PV033

PV034

PV035

PV036

278

50

Pine Valley

Basin # 053

Diamond Valley

Basin # 153

Grass Valley

Basin # 138

Kobeh Valley

Basin # 139

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Snail Observation

Hydrographic Basin

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: SRK 2010.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.15.2.3.2 Lahontan Cutthroat Trout 

Fish surveys in the project study area have focused on the occurrence of Lahontan cutthroat trout. The Lahontan 

cutthroat trout is an inland subspecies of cutthroat trout (family Salmonidae). The species may be either riverine or 

lacustrine and is endemic to the Lahontan Basin of northeast California, southeast Oregon, and northern Nevada. 

The range for Lahontan cutthroat trout in Nevada includes the Truckee, Carson, Walker, Quinn, and Humboldt 

River Basins, the Honey and Coyote Lake Basins, and Black Rock Desert Basin. Riverine, or stream-dwelling, 

Lahontan cutthroat trout usually live less than 5 years and may reach 10 to 15 inches in length. Females mature at 3 

to 4 years of age and males at 2 to 3 years of age (Coffin and Cowan 1995). As with all cutthroat trout, the 

Lahontan cutthroat trout is an obligate riverine spawner. Spawning occurs from April to July, depending on stream 

discharge, elevation, and water temperature. Most remaining populations of Lahontan cutthroat trout in Nevada 

occupy higher elevation, low-order streams (Dunham et al. 1999). Spawning and nursery habitat is characterized by 

cool-water pools in close proximity to instream cover, velocity breaks, well-vegetated and stable streambanks, and 

relatively silt-free rocky substrate in riffle-run areas (Coffin and Cowan 1995). This species spawns in riffles over 

gravel substrate when water temperatures are between 41 to 60  ̊F. Intermittent tributaries are sometimes used as 

spawning sites during high-water years. Fry may develop in the tributary stream until flushed into the mainstream 

during high runoff (Coffin 1981 cited in USDOI BLM 2012b, Trotter 1987). 

General characteristics of riverine cutthroat trout habitat include a relatively stable flow regime, a 1:1 pool to riffle 

ratio, well-vegetated stable streambanks, instream cover exceeding 25 percent, and relatively silt-free riffle-run 

areas. Cutthroat trout waters generally have a stable summer temperature regime with less than 39  ̊F fluctuation in 

water temperature and maximum water temperatures less than 72  ̊F (Hickman and Raleigh 1982). Lahontan 

cutthroat trout may have a higher thermal tolerance than other cutthroat trout and can tolerate temperatures 

exceeding 80  ̊F for short periods of time and 57 to 63  ̊F fluctuations of temperature (Ausich 1983, and Dickerson 

and Vinyard 1999 cited in USDOI BLM 2012b). Beaver ponds may provide thermal refuge for trout in the summer 

and winter. Habitat requirements may vary somewhat with life stage and season (Coffin and Cowan 1995). 

Lahontan cutthroat trout primarily feed on terrestrial and aquatic invertebrates, although larger fish may be fisheating. 

The decline of the Lahontan cutthroat trout has been primarily attributed to the loss and degradation of habitat. 

Agricultural and municipal uses of water from streams or lakes have reduced or altered the stream discharge in this 

species’ range. Grazing has altered the physical characteristics of stream channels and increased the sediment loads 

in many Lahontan cutthroat trout streams. Mining, urban development, logging, road construction, and dam 

building have also been associated with changes in stream channel morphology and water quality (Coffin and 

Cowan 1995, NDOW 2004). 

The Lahontan cutthroat trout competes with non-native trout species that were historically stocked for recreational 

fishing opportunities. Dunham and Vinyard (1996 cited in USDOI BLM 2012b) found that the distribution of 

Lahontan cutthroat trout can be truncated when brook trout are present, although they noted that the results were 

variable. Furthermore, Lahontan cutthroat trout have hybridized with non-native rainbow trout in many areas (Coffin 

and Cowan 1995, NDOW 2004). 

Lahontan cutthroat trout conservation efforts are ongoing and involve fish transplants, population and habitat surveys, 

genetic evaluations, habitat improvement projects, grazing management, use of riparian fencing, and creation of 

fishery management plans for several basins. The objective of these management efforts is the protection or 

3 Bars Project Final EIS 3-267 October 2016 
FISH AND OTHER AQUATIC RESOURCES 

restoration of habitats that sustain viable self-sustaining populations of this species. A self-sustaining population is 

defined as having been established 5 or more years and having three or more age classes (Coffin and Cowan 1995). 

Lahontan cutthroat trout populations occur in three streams within the project study area—Birch, Pete Hanson, and 

Willow Creeks. The headwater areas of Birch and Pete Hanson Creeks originate at elevations of approximately 8,200 

and 7,200 feet amsl, respectively. Genetic analyses have determined that pure strains (i.e., fish with unmixed lineage 

over many generations) exist 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 2013a). 

Surveys in 2009 indicated that Lahontan cutthroat trout occupy approximately 1.9 miles in Birch Creek and 3.5 miles 

in Pete Hanson Creek (Figure 3-38). Population estimates during the 2009 surveys were 116 fish/mile in Birch Creek 

and 445 fish/mile in Pete Hanson Creek (NDOW 2009a). Comparison of 2009 Lahontan cutthroat trout densities with 

previous survey results indicated that population levels in Birch Creek are stable, while the Pete Hanson population 

estimates are more variable (Table 3-44). Lahontan cutthroat trout were surveyed in Willow Creek in September 

2011 (Starr 2011). The estimated density for this species was 106 fish/mile in the lower portion of the creek. The fish 

collected in Willow Creek were considered healthy and representative of at least three different Lahontan cutthroat 

trout age classes. Lahontan cutthroat trout occupies approximately 0.5 mile in the middle portion of Willow Creek. In 

addition to occupied habitat in these perennial and intermittent streams, potential habitat has been identified by the 

NDOW surveys (Figure 3-38). Potential recovery streams for Lahontan cutthroat trout within the project area include 

Henderson and Vinini Creeks (Coffin and Cowan 1995); these streams have 15.6 miles of potential habitat (7 and 8.6 

miles respectively). 

TABLE 3-44

Summary of Lahontan Cutthroat Trout Surveys in Birch, Pete Hanson, and Willow Creeks

Stream Survey Years

1998 2003 2009 2011

Birch Creek

 Miles Occupied 1.5 1.5 1.9 NS

 LCT/Stream Mile 153 198 116 NS

Pete Hanson Creek

 Miles Occupied 3.5 3.5 3.5 NS

 LCT/Stream Mile 382 823 445 NS

Willow Creek

 Miles Occupied NS NS NS 0.5

 LCT/Stream Mile NS NS NS 106

NS = Not surveyed. 

LCT = Lahontan cutthroat trout. 

Source: NDOW (2009a), Starr (2011). 

Management direction for Lahontan cutthroat trout is provided in the Lahontan Cutthroat Trout Species Management 

Plan for the Upper Humboldt River Drainage Basin (Elliott 2004), and the Lahontan Cutthroat Trout Recovery Plan

(Coffin and Cowan 1995). A portion of the project area falls within the Humboldt River basin, which supports the 

greatest number of riverine populations. Management objectives for this species focus on the protection and 

3 Bars Project Final EIS 3-268 October 2016 
Area

of

Detail

Elko

Eureka

White Pine

Eureka

LanderEureka

278

50

Figure 3-38

Lahontan Cutthroat Trout (LCT)

Habitat

3 Bars Ecosystem and

Landscape Restoration Project

278

Robe rts Creek

Garden PassCreek

Fra zier C reek

Geyser Creek

Tyrone Creek

Vinini Creek

Indian Creek

Niel Creek

Pete Hanson

Cre ek

Birch

Creek

Rutabaga Creek

Henderson Creek

Willow

Creek

Denay C reek

Kelley Cre ek

0 1 2 3

Miles

0 1 2 3 4Kilometers

Legend

LCT Populated Creek

LCT Potential Habitat

Less than Optimal

Conditions for LCT

Perennial Stream Reach

Intermittent Stream Reach

Canal/Ditch

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2009f, 2012j; JBR 2009; NDOW 2012b; USGS 2012b.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
FISH AND OTHER AQUATIC RESOURCES 

restoration of habitats that sustain viable self-sustaining populations. Threats to Lahontan cutthroat trout include 

habitat fragmentation due to physical and biological conditions, alteration of stream discharge, water quality 

degradation, and introduction of non-native fish species (Coffin and Cowan 2005, USDOI USFWS 2010). 

3.15.2.3.3 Other Fish 

Other fish species are also likely to occur in study area streams, based on historic occurrences. Speckled dace, redside 

shiner, Tahoe sucker, mountain sucker, and Lahontan tui chub have been reported in the Pine Creek Drainage (Elliott 

2013b). Speckled dace also are known to occur in Coils Creek. Two additional streams, Roberts and McClusky 

Creeks, contain sport fish species including brook, brown, and rainbow trout (Petersen 2012). McClusky Creek has 

been stocked with brook trout, and Roberts Creek with rainbow trout (Elliott 2013b).

3.15.3 Environmental Consequences 

3.15.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, the following issues were identified for aquatic biological 

resources: 

 Habitat conditions for Lahontan cutthroat trout are less than optimal. 

 Limiting factors for Lahontan cutthroat trout include insufficient residual pool depth and cemented substrate. 

 There has been a decline in fisheries habitat complexity. 

 Address the need for habitat improvements in occupied Lahontan cutthroat trout streams (Birch, Pete 

Hanson, and Willow Creeks), Lahontan cutthroat trout recovery streams (Vinini and Henderson Creeks), and 

sport fish streams (Roberts and McClusky). 

 Increase public awareness of Lahontan cutthroat trout in Willow Creek. 

 Consider historical and current population trends for Lahontan cutthroat trout in the 3 Bars Project area to 

determine recovery status. 

 Identify known and potential conflicts with Lahontan cutthroat trout and livestock and wild horses and 

mitigation measures that could be implemented to minimize effects from these conflicts. 

 Concern regarding historical trout numbers in some drainages within the 3 Bars project study area. 

 Concern regarding fish barriers consisting of culverts and a headcut on Lower Roberts Creek. 

 Evaluate and consider the effect of wildland fire on special status species. 

3.15.3.2 Significance Criteria 

Impacts to aquatic biological resources would be considered significant if the BLM actions resulted in the following: 

 Action results in long-term (greater than 3 years in duration) alteration or loss of habitat in streams or springs 

containing Lahontan cutthroat trout (current populations or recovery sites), or other aquatic species. 

3 Bars Project Final EIS 3-270 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 Action causes long-term (greater than 3 years in duration) loss of riparian vegetation from prescribed fire 

treatment or surface disturbance activities in streams or springs containing Lahontan cutthroat trout (current 

populations or recovery sites), or other aquatic species. 

 Action results in water quality effects and potential toxicity conditions involving spills or chemical use that 

last more than 1 month in streams or springs containing Lahontan cutthroat trout (current populations or 

recovery sites), or other aquatic species. 

 Action causes a flow reduction lasting more than 1 month in streams containing Lahontan cutthroat trout 

(current populations or recovery sites), or other aquatic species. 

 Action causes permanent barriers to fish movement in streams containing Lahontan cutthroat trout (current 

populations or recovery sites), or other aquatic species. 

The following assumptions were used in the impact analysis for aquatic biological resources: 

 Surface disturbance activities within approximately 0.25 mile and upgradient of perennial streams could 

result in sediment or contaminant input to the streams. 

 Flow reductions of greater than 5 percent of baseline conditions on a continual basis could result in an 

adverse effect on aquatic habitat for Lahontan cutthroat or other trout, or native fish species. 

3.15.3.3 Direct and Indirect Effects 

3.15.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Habitat Alteration 

Proposed treatments would disturb aquatic habitat if equipment or vehicles enter streams or other waterbodies. The 

magnitude of the effect would vary depending on the area of disturbance and the duration of the activity. Instream 

disturbance would alter bottom substrates and possibly change the types of fish cover such as cobble, vegetation, or 

woody debris in the affected area, and the substrate alteration could adversely affect fish spawning habitat. Habitat 

alteration could affect Lahontan cutthroat trout, since restoration treatments are proposed for streams occupied by this 

species including Birch, Pete Hanson, and Willow Creeks. Final aspects of restoration treatment in Lahontan cutthroat 

trout occupied streams would be determined through BLM consultation with the USFWS and with input from 

NDOW. These treatments would be designed in a manner that would minimize direct effects to Lahontan cutthroat 

trout. The USFWS, and to some extent NDOW, would determine what level of impact would be acceptable. 

The outcome of the restoration would ultimately benefit Lahontan cutthroat trout populations by expanding suitable 

habitat as a result of increased stream connectivity. Stream enhancements could involve the creation or expansion of 

pool habitat, improvements in the riffle to pool ratio, and the addition of instream cover for fish. Stream 

enhancements would also benefit other fish and macroinvertebrate species that inhabit the treated streams. 

Small, temporary exclosure fencing and revegetation treatments would result in benefits to aquatic species. Small, 

temporary exclosure fencing would restrict access to treated areas by livestock, wild horses, and other wild ungulates. 

This action would exclude livestock, wild horses, and other wild ungulates from riparian treatment areas, resulting in 

reduced bank erosion and improved riparian vegetation cover. After treatment activities are completed, treated sites 

may be replanted. The addition of vegetation and riparian cover would be beneficial to water quality by reducing 

3 Bars Project Final EIS 3-271 October 2016 
FISH AND OTHER AQUATIC RESOURCES 

erosion in the drainage. In addition, the BLM would place logs and other woody debris from felled pinyon-juniper 

into streams to slow water flow and create fish habitat. 

Vegetation Modification 

Treatment activities would affect riparian vegetation through disturbance by vehicles or equipment. Removal of 

noxious weeds and other invasive non-native plant species would cause a short-term loss of riparian vegetation, which 

could adversely affect aquatic habitat and ecological requirements for aquatic species, and cause a temporary increase 

in bank erosion. 

Proposed treatments would have beneficial effects on riparian vegetation depending on the activity. 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. 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 (USDOI BLM 2007b:4-76). 

Water Quality 

Proposed treatments would result in short-term adverse effects on water quality. Surface disturbing activities within or 

near streams and springs could cause short-term increased sediment input. The extent of the area affected by sediment 

would depend on soil composition and the characteristics of the receiving stream or standing waterbody (e.g., flow 

conditions, channel or waterbody morphology, presence of aquatic vegetation, and gradient). Streams with firm 

substrates consisting of sand, gravel, or cobble would exhibit lower levels of sedimentation compared to soft 

substrates such as silt. Typically, the extent of downstream movement of sediment is less during low flow conditions 

and more extensive during high flow conditions. However, the suspended sediment levels would be more diluted 

under high flow conditions due to the higher water volumes. 

Increases in sediment entering a stream could adversely affect fish health and stream quality. Suspended sediment can 

affect physiological functions such as oxygen uptake for aquatic species. Depending on the sediment level and 

sensitivity of the species, effects can range from reduced health to mortality (Waters 1995). Increased sediment levels 

can bury invertebrates and early life stages of fish. Sedimentation can affect fish habitat by covering spawning and 

rearing areas, thereby reducing the survival of fish embryos and juvenile fish. Excessive sedimentation also can fill in 

pool habitats. Pool habitats provide important fish cover due to depth and overwintering habitat. 

Vehicles and equipment used within or adjacent to streams and waterbodies could also pose a risk to aquatic biota 

from fuel spills or lubricant leaks. If fuel reached a waterbody, aquatic species could be exposed to toxic conditions. 

Impacts could include direct mortality or reduced health of aquatic organisms. The magnitude of a potential spill 

would depend on the flow conditions, channel or waterbody morphology, and gradient, and the response time and 

effectiveness of containment and cleanup operations. To reduce these risks, refueling activities would not be allowed 

within 300 feet of a stream. 

3 Bars Project Final EIS 3-272 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Long-term, treatments that restore channel morphology and stream function, remove noxious weeds and other 

invasive non-native vegetation, improve the health and resiliency of riparian vegetation, and reduce the risk of 

catastrophic wildfire would benefit water quality and aquatic organisms. 

Water Use 

Stream water could be used during restoration projects and for prescribed fire control and could result in temporary 

reductions in stream flows or water levels in ponds. The BLM occasionally withdraws water from streams or ponds 

during wildfire events as an emergency measure for fire suppression. The BLM works closely with resource advisors 

to make sure this option is authorized and does not impact other key resources including aquatic species. Water 

withdrawal would consider the presence of Lahontan cutthroat trout and game fish species and their habitats when 

selecting water sources. Flow regime is considered the primary determinant regarding the structure and function of 

aquatic and riparian ecosystems for streams and rivers (Poff et al. 2010). Based on a literature review by Poff and 

Zimmerman (2010), fish was the only aquatic biological group to consistently respond negatively to reductions in 

flow magnitude. Flow or water level reductions could adversely affect fish by decreasing the amount of aquatic 

habitat and affect critical life events such as spawning, early life development, growth, physiological functions, and 

competition (Bradford and Heinonen 2008, Poff and Zimmerman 2010). 

The response of macroinvertebrate communities to reduced flow has been the subject of recent literature reviews by 

Dewson et al. (2007) and Poff and Zimmerman (2010). Based on a review of studies involving relatively large flow 

reductions (approximately 60 to 100 percent compared to base flow conditions), results showed that 

macroinvertebrate abundance and diversity declined in most cases due to reduced habitat diversity, loss of food 

sources, and changes in competition and predation. Increased water temperature and sedimentation and altered 

attached algae assemblages also can contribute to changes in aquatic community composition and taxonomic richness. 

3.15.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Riparian area treatments would focus on restoring stream and habitat functionality in areas where both the 

morphology and structural integrity of the stream channel, and the plant species composition within the riparian zone, 

have been compromised by past actions. Examples of compromised stream channel integrity include: 1) areas where 

the channel is eroded and incised; 2) areas where there is a sharp break in the slope of the channel due to erosion 

(knickpoint or headcut); and 3) areas where the channel has been diverted from its historic watercourse due to road 

construction or other factors. Because of loss of structural integrity in compromised channels, stream velocities have 

increased over historic levels, nutrient-rich sediment is not being delivered to riparian vegetation, and there is less 

groundwater recharge within the floodplains, to the detriment of fish and other aquatic organisms. 

Treatments would primarily occur in upper and lower Henderson Creek (8.9 miles of perennial stream), Roberts 

Creek (7.6 miles), upper and lower Vinini Creek (5.9 miles), and Willow Creek (4.3 miles). Willow Creek supports 

Lahontan cutthroat trout along 0.5 mile of occupied perennial stream habitat, while Henderson and Vinini and 

unnamed creeks have known or potential Lahontan cutthroat trout habitat, including approximately 9.3 miles of 

potential perennial habitat and 3.6 miles of potential intermittent habitat. None of the springs are known to contain 

snails or springsnails. 

3 Bars Project Final EIS 3-273 October 2016 
FISH AND OTHER AQUATIC RESOURCES 

Adverse Effects 

Riparian vegetation removal could adversely affect ecological functions of riparian vegetation on a short-term basis, 

although the affected area would represent a relatively minor portion of the overall riparian zone. Streamside 

vegetation removal could decrease the amount of woody debris deposited in the stream, although the BLM proposes 

to place down logs and other wood from felled pinyon-juniper into streams to improve stream habitat. 

The adverse effects of mechanical treatments on water quality would be expected to be localized and of short-term in 

duration, with water quality returning to pre-disturbance conditions within several days or weeks after treatment is 

completed. Adverse effects for all proposed riparian zone projects could result from soil disturbance and erosion, and 

the spill of fuel or lubricants into water bodies. Habitat alteration or loss at a particular site would be considered 

relatively minor in relation to the overall habitat in the stream, especially since treatments would be focused on 

degraded stream habitat. Instream disturbance would occur in Lahontan cutthroat trout occupied (Willow Creek) or 

recovery (Henderson and Vinini Creeks) streams, and game fish streams (Roberts and McClusky Creeks), as part of 

habitat enhancement. The BLM would consult with the USFWS and NDOW regarding designing treatments in a 

manner that would minimize direct effects to Lahontan cutthroat trout. This approach would avoid significant impacts 

to Lahontan cutthroat trout. 

The adverse effects of mechanical treatments on water quality would be expected to be short-term in duration, with 

water quality returning to pre-disturbance conditions within several days or weeks after treatment is completed. 

Adverse effects for all proposed riparian zone projects could result from soil disturbance and erosion, and the spill of 

fuel or lubricants into water bodies. Habitat alteration or loss at a particular site would be considered relatively minor 

in relation to the overall habitat in the stream. Riparian treatments would be localized and targeted for areas that are 

generally degraded in terms of riparian vegetation quality or characterized by the absence or limited number of 

riparian species. The BLM would consult with the USFWS and NDOW regarding designing treatments in a manner 

that would minimize direct effects to Lahontan cutthroat trout. This approach would avoid significant impacts to 

Lahontan cutthroat trout. Treatment methods used in Birch and Willow Creeks within the Roberts Mountains WSA 

would have to meet non-impairment criteria for WSAs, but would not include the use of vehicles or building of new 

roads. 

Beneficial Effects 

The BLM’s highest priority is to use vegetation treatments to restore high priority subbasins within key watersheds to 

benefit fish and other aquatic organisms. Over the short-term, adverse effects to aquatic organisms from vegetation 

treatment activities proposed by the BLM could occur, but treatments would lead to improved conditions for aquatic 

species over the long-term. The eventual growth of desirable vegetation in treated areas would moderate water 

temperatures, buffer the input of sediments from runoff, promote bank stability, and contribute woody debris to 

aquatic bodies. Ongoing efforts by the BLM to enhance riparian vegetation would also help to increase the number of 

miles of BLM-administered streams that are classified as Proper Functioning Condition. 

Removing invasive vegetation such as pinyon-juniper could increase streamflow, while replacing noxious weeds and 

other invasive non-native species with native vegetation would stabilize streambanks and moderate streamflows. 

Furthermore, replacing noxious weeds and other invasive non-native vegetation with shrubs and trees would also 

increase the amount of woody debris in water bodies that can be used as habitat by fish (USDOI BLM 2007c:4-69). 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

The beneficial effects of riparian treatments would include aquatic habitat enhancements. Various treatment methods 

would be used to improve issues involving headcuts and stream incisions. The treatment activities would include 

streambank bioengineering, grade stabilization, and vegetation plantings to initiate stream restoration. These treatment 

activities would enhance pool and riffle habitat by increasing depths and providing additional in-stream structure by 

adding cobble and boulder substrates and woody debris. After restoration is completed, aquatic habitat would occur

on a more consistent basis as a result of increased stability of the channel banks and substrates. The habitat 

improvements also would be beneficial to macroinvertebrates by stabilizing bottom substrates and creating a diverse 

composition of substrate types. Macroinvertebrates represent an important food source for fish species. As a result of 

the stream restoration activities, habitat for Lahontan cutthroat trout (in both occupied and recovery streams) and 

game fish species would be improved in terms of functionality and structure. Habitat improvements in the Lahontan 

cutthroat trout recovery streams may assist in the reintroduction of this species into habitats that were used 

historically, which would meet the goals and objectives of the Lahontan Cutthroat Trout Recovery Plan (Coffin and 

Cowan 1995). In addition, wet meadows and stream reaches could be created under this treatment, which would 

provide additional aquatic habitat for fish and invertebrates. 

Vegetation treatments to thin or remove pinyon-juniper from within floodplains and near streams would help to create 

fire breaks and would benefit aquatic animals by reducing the risk that a large, uncontrolled wildfire would destroy a 

large amount of high quality aquatic habitat. Fire can adversely affect aquatic organisms by degrading water quality 

and raising water temperature (USDOI BLM 2007c:4-70). 

After restoration, treatment areas may be excluded using small, temporary exclosure fencing to ensure that restored 

sites and plantings are not damaged by livestock, wild horse, and other wild ungulates. Also, fencing would be used to 

protect riparian habitat at Denay Pond, Lone Spring, and Treasure Well. 

Aspen Treatments 

Adverse Effects 

Potential adverse impacts to fish and other aquatic resources from the three aspen treatments associated with stream 

habitat would be similar to those for riparian treatments. However, only about 15 acres of aspen would be treated 

annually under the proposed action, and only 4 miles of stream are associated with aspen treatments. Aspen 

treatments would occur in areas that are occupied, or could be occupied, by Lahontan cutthroat trout. Treatments 

could result in erosion that could adversely impact nearby stream habitat and aquatic resources, including game and 

non-game fish. 

Beneficial Effects 

Restoration of aspen stands could benefit fish and other aquatic species, primarily through an improvement in water 

quality. Pinyon-juniper would be removed to reduce competition between aspens and pinyon-junipers for space and 

nutrients, and may occur near roads to improve their effectiveness as fuel breaks. Fuel breaks would help to slow the 

spread of wildfire, reducing the chances that a large, uncontrolled wildfire would destroy a large amount of high 

quality aquatic habitat. Downed trees and other large woody material from felled trees could be placed in streams as a 

source of woody debris for fish. The additional woody debris would provide improvements in the quantity and quality 

of fish cover and an additional source of organic material to the stream. The BLM would remove or burn slash and 

downed wood if there is the potential for the material to increase the risk of wildfire. 

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FISH AND OTHER AQUATIC RESOURCES 

If small, temporary exclosure fencing is installed near streams, it would benefit aquatic habitat and species by 

restricting livestock, wild horses, and other wild ungulates from entering the stream. This would reduce the amount of 

direct alteration of aquatic habitat and minimize erosion. Fencing would also help to ensure that aspen restoration 

treatments are successful. 

Pinyon-juniper Treatments 

Adverse Effects 

Approximately 5 miles of stream are associated with riparian management projects that occur within the larger 

pinyon-juniper management area. Seven miles of perennial stream treatments are associated exclusively with pinyonjuniper management projects, including the Birch Creek, Upper Pete Hanson, Tonkin South, Upper Roberts Creek, 

and Vinini treatment units. These pinyon-juniper project areas also overlap with Lahontan cutthroat trout and other 

fish habitat—Atlas (Roberts Creek), Birch Creek (Birch Creek), Lower Pete Hanson (Pete Hanson Creek), Pete 

Hanson (Pete Hanson Creek), and Vinini Unit (Henderson Creek). Habitat alteration could occur near streams that 

provide known or potential Lahontan cutthroat trout habitat (Birch, Pete Hanson, and Henderson Creeks). 

The types of impacts to these perennial and intermittent streams would be similar to those discussed earlier, including 

increased sediment loads into streams, spill of fuel or lubricants into streams, and flow reduction due to use of water 

for fire control. Approximately 30 percent of the treatment area for these units has moderate to high water erosion 

risk, and mechanical treatments could cause soil disturbance that could lead to erosion and sedimentation of streams. 

The effects of treatments on water quality would be short-term, with water quality returning to pre-disturbance 

conditions within several days or weeks after treatment is completed. However, this risk is negligible in areas where 

pinyon-juniper are felled using chainsaws, or pinyon-juniper are shredded, as the resultant woody debris would help 

to protect the soil. If large amounts of woody debris are left on the ground, however, it could provide fuel for a 

wildfire. 

Fire treatment could result in increased turbidity in streams due to runoff from burn areas. Sediment input could 

adversely affect stream substrate composition due to increased silt deposition. The magnitude of sediment input 

would depend on gradient in the burned portion of the drainage area and the extent of vegetation growth between the 

burn area and the receiving streams. Densely vegetated areas could capture and reduce the sediment input to streams. 

Standard operating procedures would reduce the sediment input to downgradient streams, but would not eliminate all 

sediment input into drainages. Sediment input could adversely affect aquatic habitat and the health of fish and 

invertebrate species. 

High severity fires tend to burn much of the organic material on a site, exposing mineral soil, and sometimes creating 

hydrophobic soil layers. This hydrophobic condition increases the rate of water runoff and erosion. Nearly all of the 

treatment acreage associated with treatment units near perennial streams has soils with a moderate to high risk of fire 

degradation. The BLM would reduce this risk by conducting low severity prescribed burns. It is unlikely that burning 

would be conducted along streams with Lahontan cutthroat trout due to the potential for adverse impacts to stream 

water quality and loss of vegetative cover adjacent to streams. The BLM would consult with the USFWS before 

conducting treatments near streams occupied by Lahontan cutthroat trout. 

Water may be needed for fire control. If water sources include perennial streams or springs connected to surface flow, 

temporary flow reductions could occur in streams. The magnitude of the effect would depend on the water volume 

and timing of the withdrawal. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Beneficial Effects 

The removal of pinyon-juniper vegetation in riparian zones could increase stream flows and improve aquatic habitat 

as a result of reduced water uptake by vegetation. Manual, mechanical, and fire treatments in pinyon-juniper 

management areas would improve aquatic habitat by placing woody debris at strategic locations to expand the size of 

the streams and result in the creation or expansion of pool habitats. These treatments would benefit Lahontan 

cutthroat trout habitat in Birch, Pete Hanson, and Willow Creeks. Habitat improvements near Henderson Creek could 

assist in the recovery of Lahontan cutthroat trout. The stream structures (i.e., logs and pools) could also serve as fuel 

breaks to slow the spread of wildland fire and reduce fire effects on aquatic habitat and species. 

Prescribed fire treatments could benefit aquatic species by reducing hazardous fuel loads, and therefore the risk of a 

destructive high-intensity wildfire. In many cases, pre-treatment fuels reductions (e.g., thinning and pile burning) 

would be necessary to reduce the severity of prescribed burns near or within riparian zones (USDOI BLM 2007b:4-

70). Removal of pinyon-juniper and shredding of sagebrush to create fuel breaks would help to contain and limit the 

spread of wildfire, to the benefit of aquatic resources. 

Sagebrush Treatments 

Adverse Effects 

Four streams (Birch, Henderson, Pete Hanson, and Vinini Creeks) provide potential Lahontan cutthroat trout, with 1.6 

miles of potential perennial and 4.4 miles of intermittent habitat within sagebrush treatment areas. However, there is 

no occupied Lahontan cutthroat trout habitat in the sagebrush treatment areas. None of the springs are known to 

contain snails or springsnails. 

Most of the sagebrush projects (Alpha, Kobeh East, Nichols, Roberts Mountain Pasture, South Simpson, Three 

Corners, and Whistler Sage) overlap with intermittent/ephemeral, but not perennial streams. Potential habitat and 

water quality effects in these streams would mainly affect invertebrate communities, but fish could also be present 

during spring runoff. 

Approximately 5 miles of perennial stream are associated with riparian management projects within the larger 

sagebrush management area (Lower Henderson 1 and 3, and Lower Vinini Creek units). Only 1.3 miles of perennial 

stream habitat are associated exclusively with sagebrush management projects—Table Mountain (Henderson and 

Vinini Creeks), and West Simpson Park (unnamed) units. Lahontan cutthroat trout potential habitat occurs in 

Henderson and Vinini Creeks, while native fish (speckled dace) have been reported in Coils Creek. Manual and 

mechanical treatments could result in increased water runoff and erosion, and spills of fuels and lubricants, to the 

possible detriment of water quality and aquatic habitat. 

Fire treatments on the West Simpson Park Unit to remove non-native vegetation could result in increased turbidity in 

streams due to runoff from burned areas. Adverse effects on stream habitat and aquatic species would vary depending 

on the precipitation conditions. Under average and dry year precipitation conditions, measured effects of prescribed 

fire would be relatively small or undetectable (Clifton et al. 2006). If large storm events occur within the first few 

years after prescribed fire, erosion could be substantial. 

Livestock grazing could be used for short periods to remove undesirable vegetation before using other treatment 

methods. 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 

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FISH AND OTHER AQUATIC RESOURCES 

movement of undesirable vegetation into uninfested areas in livestock feces (USDOI BLM 2009b). Livestock could 

also degrade vegetation and soils, and deposit fecal material in or near streams, which would adversely affect water 

quality and habitat for aquatic species. Livestock grazing also could directly alter aquatic habitat if animals have 

access to the stream channels. 

Beneficial Effects 

The beneficial effects of sagebrush treatments would include improvements in aquatic and riparian habitats and a 

reduction in wildfire risk. Grade stabilization structures, streambank bioengineering, removal/reconstruction of water 

development, and vegetation planting to initiate stream restoration would be used at the Henderson 1 and 2 units and 

Lower Vinini Unit that are within sagebrush treatment units and would benefit aquatic species and habitat. Trees that 

are removed as part of this treatment could be placed in streams to expand the stream width and help create or expand 

pool habitats. The woody structures also would provide additional in-stream cover for fish and organic material to the 

stream environment. 

The BLM would use mowers and shredders to create fuel breaks. A decreased risk of wildfire would benefit aquatic 

habitat and species by reducing the occurrence of catastrophic wildfires and the associated adverse effects on habitat 

and species. 

3.15.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, the number of acres of riparian treatments (4,000 acres) and miles of stream improved to restore 

channel morphology and function (31 miles) would be similar to Alternative A. 

Because the BLM would have to rely more on mechanical treatments to reduce hazardous fuels and improve 

woodland health, improve the health of aspen stands, and control non-native vegetation, short-term soil disturbance 

and erosion would be similar to that under Alternative A, even though fewer acres would be treated. However, firerelated effects on water quality and aquatic habitat would not occur under Alternative B. Although this would be 

beneficial to fish in the short-term, in the long-term there would be a higher risk of wildfire as a result of buildup of 

hazardous fuel materials that could have been removed through the use of prescribed fire and wildland fire for 

resource benefit. Fire would also not be used to improve woodland health and for stand replacement treatments in 

Phase II and III pinyon-juniper stands. These stands would be highly susceptible to a wildfire. Adverse effects on 

aquatic habitat and species could result from wildfires near perennial streams and springs. 

Under Alternative B, the BLM would be able to demonstrate that it is restoring landscapes and addressing multiple 

resource issues. The BLM would also make gains toward meeting Proper Functioning Condition objectives on several 

streams in the project area. Treatment benefits to fish and other aquatic organisms under Alternative B would be less 

than under Alternative A, but not substantially less, as fire would be used sparingly to improve habitat for fish under 

Alternative A. However, risks to fish from wildfire would be greater under this alternative than for Alternative A. 

3.15.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under this alternative, the BLM would only treat vegetation using manual and classical biological control methods. 

Overall, only about one-fourth as many total acres, acres of wetland, floodplain, and riparian habitat, and miles of 

stream restoration would be treated under Alternative C as compared to Alternative A. Short-term soil disturbance 

and erosion would occur in watersheds as a result of manual and classical biological treatments, but effects would be 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

substantially less under this alternative than under the other action alternatives because fewer acres would be treated, 

and because manual and biological treatments cause less soil disturbance compared to mechanical and fire treatments. 

The BLM would have limited success in restoring channel morphology and function in degraded streams to benefit 

Lahontan cutthroat trout and other aquatic organisms. The BLM would be able to hand place rocks, logs, and other 

materials in streams to slow water flows, and may be able to make minor changes to the stream morphology using 

hand tools, but these improvements would be minor. 

Pinyon-juniper would be removed using chainsaws. Phase I woodlands and a limited acreage of Phase II woodlands 

would be targeted for treatments. Most treatments would occur near streams and roads to promote their use as fire 

breaks, to the benefit of aquatic resources. However, the BLM would not be able to conduct fire treatments to reduce 

hazardous fuels, or use mechanical equipment to create fire and fuel breaks, and thus the risks of wildfire and its 

effects on fish and other aquatic resources would be greater under this alternative than under the other action 

alternatives.

Under Alternative C, the BLM would do little to slow the spread of noxious weeds and other invasive non-native 

vegetation, including cheatgrass, or protect fish and wildlife habitat from devastating wildfire effects. Thus, benefits 

to fish and other aquatic organisms under Alternative C would be less than under Alternatives A and B. Although the 

BLM would make some gains toward meeting Proper Functioning Condition objectives on several streams in the 

project area, these gains would be less than under Alternatives A and B. 

3.15.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to fish or other aquatic resources from 3 Bars Project treatments as no treatments 

would be authorized under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyonjuniper to promote healthy, diverse stands; reconstruct stream channels and improve riparian habitat; thin and/or 

remove pinyon-juniper and sagebrush to encourage understory development; restore fire as an integral part of the 

ecosystem; or reduce the risk of a large-scale wildfire to the benefit of fish and other aquatic resources and their 

habitats. Alternative D poses the greatest threat to Lahontan cutthroat trout, through long-term habitat loss and 

degradation. 

3.15.3.4 Cumulative Effects 

The CESA for fish and other aquatic resources is approximately 1,841,698 acres and includes those watersheds at the 

Hydrologic Unit Code 10 level that are all or partially within the 3 Bars Project area (Figure 3-1). Approximately 92 

percent of the area is administered by the BLM, 6 percent is privately owned, and 2 percent is administered by the 

Forest Service. Past and present actions that have influenced fish and other aquatic resources in the 3 Bars ecosystem 

are discussed in Section 3.3.2.3.3.

3.15.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

As discussed in Section 3.3.2.3.3, historic livestock grazing use has contributed to soil erosion and water quality 

degradation, especially in riparian zones and near streams occupied, or potentially occupied, by Lahontan cutthroat 

trout and other fish. This degradation in habitat is a major reason why the BLM is conducting stream channel and 

habitat restoration along 31 miles of streams. The BLM also proposes to install small, temporary exclosure fencing to 

exclude livestock, wild horse, and other wild ungulate access to riparian zone and aspen treatment areas. These 

actions should help to improve water quality in affected streams. 

3 Bars Project Final EIS 3-279 October 2016 
FISH AND OTHER AQUATIC RESOURCES 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and aerial-based application methods to remove cheatgrass, and would restore burned areas 

under the Burned Area Emergency Stabilization and Rehabilitation program, under existing authorizations on about 

1,000 acres annually. The BLM primarily uses 2,4-D, glyphosate, imazapyr,, metsulfuron methyl, and picloram on the 

3 Bars Project area, and could use imazapic on the area in the future. These herbicides have negligible to low risks to 

fish and other aquatic resources, except under accidental spill situations, which would be unlikely (USDOI BLM 

2007b:4-80).These treatments could have a short-term adverse effect on non-target vegetation. These treatments 

would have long-term beneficial effects by helping to reduce hazardous fuels, improve native vegetation, slow the 

spread of noxious weeds and other invasive non-native vegetation, and reduce surface runoff and erosion associated 

with burn sites to the benefit of fish and other aquatic resources. 

Recreation activities, primarily off-road vehicle travel, could impact stream habitat. Approximately 496 miles of road 

are within 500 feet of streams within the CESA. Approximately 16 miles of road are within 500 feet of perennial 

streams including Birch, Denay, Henderson, Pete Hanson, Vinini, and Willow Creeks. Approximately 11 miles of 

known or potential Lahontan cutthroat trout habitat occurs near roads. In addition, 76 miles of off-highway vehicle 

routes are within 500 feet of streams. Of those, approximately 11 miles of off-highway vehicle routes are within 500 

feet of the same perennial streams that are near roads. Two miles of streams within 500 feet of off-highway vehicle 

routes contain known or potential Lahontan cutthroat trout habitat. Unpaved roads and off-highway vehicle routes 

near streams could contribute runoff and sediment to streams. Fishermen may also harvest Lahontan cutthroat trout 

and other game fish. 

As discussed in the Mount Hope Project EIS, there is concern that water withdrawals for future livestock and 

domestic uses, mine projects, and agricultural activities could reduce surface water flows in streams associated with 

the Diamond Mountains, Diamond Valley, Roberts Mountain, Kobeh Valley, and Pine Valley. Water drawdown 

could adversely impact habitat used by Lahontan cutthroat trout, and could also impact habitat for other aquatic 

organisms and potential habitat for Lahontan cutthroat trout on Henderson Creek (USDOI BLM 2012b:4-48 to 4-50). 

If deemed necessary by the BLM based on water monitoring, the Mount Hope Project proponent would augment 

water flows at several springs and at Henderson and Roberts Creeks (USDOI BLM 2012b:3-93 to 3-105). 

Future mining activities within the CESA may create adverse impacts to surface water resources, mainly by altering 

drainage features, by dewatering springs or stream segments, and by water quality impacts from runoff from disturbed 

areas or escapes from processing facilities. Most of these potential impacts from mining activities would be avoided 

or reduced through state and federal mining regulations and related compliance programs. 

Surface water features within the CESA generally resemble those within the project area, consisting mainly of 

streams, springs, ponds, and playas in various conditions. In some locations, notably along Henderson and Pine 

Creeks and near the town of Eureka, irrigation return flows may have poorer water quality than rangeland streams and 

springs. These areas are not used by Lahontan cutthroat trout, but could be used by other fish and aquatic resources. 

Land development, mineral development, and oil, gas, and geothermal exploration and development could affect 

about 10,000 acres in the reasonably foreseeable future, including about 8,335 acres of disturbance associated with the 

Mount Hope Project, and acreage associated with potential land sales (although it is unlikely that all of this land 

would be developed), roads, and rights-of-way for power and telephone lines. These projects would disturb soil, and 

could lead to soil erosion and water quality impacts in streams used by game fish and other aquatic resources. Land 

development and development of natural resources would involve the use of equipment and drilling of wells that 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

could result in hydrocarbon and other spills of hazardous materials that could impact surface water and groundwater; 

a recent oil spill at the Blackburn oil well in Pine Valley impacted over 3 acres (USDOI BLM 2012b:4-47). 

Hazardous fuels reduction, habitat improvement, and noxious weed and other invasive non-native vegetation control 

projects would occur on up to approximately 142,000 acres (about 127,000 for the 3 Bars Project and about 15,000 

acres for other hazardous fuels projects in the CESA), or 8 percent of the CESA. As discussed under direct and 

indirect effects, these treatments would lead to short-term increases in soil erosion and surface water runoff, but longterm benefits to water quality and possibly water flows to the benefit of fish and other aquatic organisms. Fire 

treatments could cause the development of hydrophobic soils, increasing surface water runoff. Soils over much of the 

CESA are susceptible to fire degradation. The disturbance effects resulting from restoration activities are predicted to 

have less impact and be less severe than fire effects and erosion caused by wildfire. Based on historic numbers, 

approximately 140,000 acres could burn during the next 20 years within the CESA. 

3 Bars Project treatments would have short-term adverse effects on about 4,000 acres of riparian habitat, 9 miles of 

occupied Lahontan cutthroat trout streams, and 68 miles of potential Lahontan cutthroat trout streams. In addition, 

treatments under Alternative A could affect aquatic organisms found in about 1,000 miles of perennial and 

intermittent/ephemeral streams on the 3 Bars Project area. Adverse effects from treatments would generally be shortterm, while benefits would be long-term and would accumulate with fish and other aquatic resources habitat effects 

that occur on other portions of the CESA. Because stream restoration and enhancement treatments on the 3 Bars 

Project area under Alternative A would affect less than 0.2 percent of the acreage on the CESA, these effects would 

be negligible. About 17 percent of the 3 Bars Project Area and 8 percent of the CESA would be treated to reduce 

hazardous fuels, and slow the trend toward large-sized fires of moderate to high severity in sagebrush and large standreplacing fires in pinyon-juniper. A reduction in wildfire risk on the CESA would benefit aquatic organisms, and 

would be greatest under Alternative A. 

3.15.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on fish and other aquatic 

resources would be similar to those described under Alternative A. Acres and types of wetland and riparian habitat 

treated under this alternative would be similar to Alternative B. However, less effort would be spent by the BLM on 

treatments to reduce wildfire risk and its associated impacts to aquatic habitat from soil erosion, including use of fire 

to restore natural fire regimes. 

Adverse effects to fish and other aquatic resources would generally be the same as described for Alternative A. 

However, by not using fire, there would be no risks to fish and other aquatic resources or their habitats from fire on up 

to several thousand acres annually within the 3 Bars Project area. However, the use of fire could occur on several 

hundred acres annually on other portions of the CESA. 

Because of the large number of acres treated, water quantity and quality should improve within the 3 Bars Project area 

and provide a benefit to fish and other aquatic resources within the CESA, although not to the extent as would occur 

under Alternative A. 

Under Alternative B, restoration projects would occur along about 31 miles of streams, including about 9 miles of 

streams occupied by Lahontan cutthroat trout, and on about 2,000 acres of wetland and riparian habitat. Hazardous 

fuels reduction and habitat improvement projects could occur on about 63,000 acres within the 3 Bars Project area, 

and on an additional 15,000 acres within the CESA, or about 4 percent of the acreage within the CESA. The trend 

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FISH AND OTHER AQUATIC RESOURCES 

toward large-sized wildfires of moderate to high severity in sagebrush and large stand-replacing fires in pinyonjuniper should slow, but treatments to reduce this risk on the CESA would be less under Alternative B than under 

Alternative A. 

3.15.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on fish and other aquatic 

resources would be similar to those described under Alternative A. Adverse, short-term effects to fish and other 

aquatic resources associated with the use of fire and mechanized equipment would not occur under Alternative C. 

However, fire use and mechanized equipment would be used on other portions of the CESA to improve habitat, 

remove hazardous fuels, and reduce the risk of wildfire. Treatments in the CESA would affect about 47,000 acres, or 

about 2 percent of the CESA; less than 0.2 percent of acreage on the CESA would be affected annually. 3 Bars 

Project restoration treatments would have short-term adverse and long-term beneficial effects on fish and other 

aquatic resources, but these effects would be negligible in the context of the acreage within the CESA and other types 

of activities that have effects on water resources, such as the Mount Hope Project. By not being able to use 

mechanical methods and fire to reduce hazardous fuels, treat vegetation to make it more fire resilient, create fire and 

fuel breaks, and remove downed wood and slash, however, the risk of wildfire and its impacts on water resources 

would likely increase on the 3 Bars Project area, to the potential detriment of fish and other resources that depend 

upon water in the CESA. 

3.15.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on fish and other aquatic 

resources would be similar to those described under Alternative A. There would be no cumulative effects on fish and 

other aquatic organisms from 3 Bars Project treatments as no treatments would be authorized under this alternative. 

The BLM could create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow 

the spread of noxious weeds and other invasive non-native vegetation using ground-based and aerial application 

methods of herbicides, especially cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a 

large-scale wildfire under current and reasonably foreseeable future authorized actions, but on a very limited acreage. 

Based on historic treatments in the 3 Bars Project area, only about 1,500 acres would be treated annually in the CESA 

to reduce hazardous fuel levels and improve ecosystem health. Hazardous fuel levels would likely increase, and only a 

limited number of miles of fuel and fire breaks would be constructed under this alternative compared to the action 

alternatives. The BLM would conduct stream bioengineering and riparian habitat enhancements on a limited acreage 

and these projects would have to be authorized through separate decisions. Stream channels and riparian habitat 

would likely remain degraded and contribute to water quality concerns. Thus, riparian habitat used by Lahontan 

cutthroat trout and other aquatic organisms would remain degraded and contribute to water quality concerns. The 

trend toward large-sized fires of moderate to high severity in sagebrush, and large stand-replacing fires in pinyonjuniper, would likely increase. Of note, large regional wildfires have contributed to runoff, erosion, and water quality 

issues within the CESA, particularly outside treatment areas in the eastern mountainous parts of Grass Valley and 

Pine Valley. It is likely that wildfire incidence and severity would remain high under Alternative D. These effects 

would be detrimental to fish and other aquatic organisms. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.15.3.5 Unavoidable Adverse Effects 

Unavoidable adverse effects on aquatic biological resources include treatments that disturb soil and increase 

sedimentation, which could result in short-term adverse effects on water quality and aquatic species. In addition, 

removal of pinyon-juniper in riparian treatment areas could reduce stream shading, which could increase stream 

temperatures and adversely affect aquatic species. These adverse impacts generally would be short-term in duration 

(several months to several years), and would be addressed by resource protection measures implemented during and 

after the project treatment activities. 

3.15.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

As discussed under direct and indirect effects, treatments could lead to short-term habitat loss, and possibly loss of 

aquatic organisms, due to removal of vegetation and erosion. Long-term, control of aquatic and riparian vegetation 

would improve habitat quality for fish and other aquatic resources, improve hydrologic function, and reduce soil 

erosion. Vegetation treatments that reduce hazardous fuels would benefit aquatic organisms by reducing the chances 

of a large, uncontrolled wildfire, which could result in the destruction of a large amount of high quality wetland and 

riparian habitat, especially if followed by heavy rainfall. Hazardous fuels reduction would also decrease the likelihood 

that wildfire suppression activities would occur in or near aquatic habitats. Treatments that restore natural fire regimes 

and native vegetation near streams should ensure a steady supply of large woody debris that would provide habitat for 

aquatic organisms in the long-term (USDOI BLM 2007b:4-248). 

3.15.3.7 Irreversible and Irretrievable Commitment of Resources 

Loss of control over a prescribed fire could also harm aquatic habitat and cause mortality or injury to aquatic 

organisms. Treatments would likely result in short-term habitat degradation and some reduction in populations of fish 

and other aquatic organisms. These effects, however, would be reversible, as habitats would improve and aquatic 

organism populations would likely increase as a result (USDOI BLM 2007b:4-252). 

3.15.3.8 Significance of the Effects under the Alternatives 

3 Bars Project restoration treatments and other actions in the CESA should not have a significant adverse impact on 

fish and other aquatic resources. One of the goals of the 3 Bars Project is to improve habitat for Lahontan cutthroat 

trout and other fish and wildlife by restoring stream and habitat functionality through in-channel activities such as recontouring and installing grade-control structures and plantings. Treatments could occur on several miles of streams 

annually and could lead to short-term stream channel instability and degradation. The BLM would also remove 

encroaching pinyon-juniper and noxious weeds and other invasive non-native vegetation on about 3,900 acres of 

riparian habitat, and revegetate treatment areas with native vegetation. The BLM would work with the USFWS and 

NDOW to ensure that treatments would not result in a long-term (greater than 3 year in duration) alteration or loss of 

habitat in streams or springs containing Lahontan cutthroat trout (current populations or recovery sites). The BLM 

also may exclude livestock, wild horse, and other wild ungulate access to treated areas until site-specific treatment 

goals and objectives were met. These treatments are expected to improve stream habitat within 2 to 3 years. Stream 

restoration is not planned on other portions of the CESA, but could occur in the future should funding become 

available. 

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FISH AND OTHER AQUATIC RESOURCES 

Nearly all 3 Bars Project restoration treatments would cause short-term erosion that leads to increased sedimentation 

in streams or ponds that could harm aquatic species, and which could last for several years. These risks would be 

greatest in restoration areas with moderate to severe water or wind erosion potential, or where soils are susceptible to 

fire degradation. Treatments that disturb the soil or remove large amounts of vegetation, including use of mechanical 

treatments such as discing and plowing, and prescribed fire and wildland fire for resource benefit, would also lead to 

short-term erosion and sedimentation. Long-term, restoration treatments would lead to conditions that should reduce 

the risk of erosion, including revegetation of treatment sites with native vegetation and conducting treatments to 

stimulate growth of the understory. Treatments that reduce the risk of wildfire, including hazardous fuels treatments, 

control non-native vegetation, and create fire and fuel breaks would also reduce the risk of fire-associated erosion and 

its effects on water quality. Thus, none of the alternatives would result in a significant long-term (greater than 3 years) 

increase in erosion and the associated increased sedimentation in streams or ponds. 

Under all alternatives, there is potential for short-term releases of fuels and lubricants from equipment into water 

bodies that could affect Lahontan cutthroat trout or other aquatic species, although this risk would be negligible. The 

BLM would prevent or minimize the movement of fuels and lubricants into water bodies by fueling and servicing 

equipment off-site at least 300 feet from streams. Operators would also carry absorbent material and other spill cleanup materials to use should a spill occur in a water body. By retaining buffers between treatment areas and water 

bodies where feasible, and following other SOPs that protect water quality, it is unlikely that there would be a change 

in water quality that would often or regularly exceed Nevada water quality standards. 

Treatments under all alternatives would not cause a flow reduction lasting more than 1 month in streams containing 

Lahontan cutthroat trout (current populations or recovery sites), or other aquatic species. The BLM could divert water 

while reconstructing streams. The BLM may exclude livestock, wild horse, and other wild ungulate from treatment 

sites near water in riparian and aspen treatment areas until these areas were restored and able to accommodate use by 

these animals. It is anticipated that access restrictions would be 2 to 3 years. If access is restricted, the BLM would 

work with affected permittee(s) to ensure access to water. Thus, there should be no significant long-term diversion, or 

access restriction that substantially reduces water availability and the uses recognized by Nevada Department of 

Water Resources in the analysis area or immediately adjacent to it under all alternatives. This would include flows 

and seasons of use in springs or streams where existing beneficial water uses, as defined by Nevada Division of 

Environmental Protection and recorded by Nevada Department of Water Resources, may be affected. 

Poorly designed, installed, or maintained culverts have impacted stream flows and fish movement on several streams 

on the 3 Bars Project area (AECOM 2010). The BLM would work to replace these culverts, and would ensure that 

any future culverts used in stream reconstruction would not cause permanent barriers to fish movement in streams. 

3.15.4 Mitigation 

The following mitigation measures would be implemented to reduce or avoid impacts to fish and other aquatic 

biological resources: 

1. If instream disturbance is required as part of treatment, activities would be scheduled to avoid spawning 

periods of game fish species or Lahontan cutthroat trout. The measure would be effective in protecting 

spawning periods of game or special status fish species. 

2. If water is required for fire control, perennial streams with game or special status species or springs with 

connections to these perennial streams would not be used as water sources. This measure would be effective 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

in avoiding flow reductions in streams with important aquatic species by restricting their use as water sources 

for fire control. 

3. The BLM would consult with the 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. The measure would be effective in protecting stream habitat for Lahontan cutthroat trout. 

In addition, fish and other aquatic resources would benefit from mitigation measures identified in Section 3.18.4 

(Livestock Grazing Mitigation). 

3.16 Wildlife Resources 

3.16.1 Regulatory Framework 

3.16.1.1 Endangered Species Act 

In accordance with Section 7 of the Endangered Species Act, federal agencies must “insure that any action authorized, 

funded, or carried out by such agency is not likely to jeopardize the continued existence of any listed species or result 

in the destruction or adverse modification of critical habitat of such species.” The purpose of the Act is to provide a 

means for conserving the ecosystems upon which threatened and endangered species depend, and to provide a 

program for protecting these species. The Act defines an endangered species as a species that is in danger of 

extinction throughout all or a major portion of its range. A threatened species is defined as any species that is likely to 

become an endangered species within the foreseeable future throughout all or a major portion of its range. This Act 

also addresses species that have been proposed for listing as either threatened or endangered, but for which a final 

determination has not been made. These so-called “candidate” species are those for which the USFWS has sufficient 

information on their biological status and threats to propose them as endangered or threatened under the Act, but for 

which development of a proposed listing regulation is precluded by other, higher priority listing activities. Critical 

habitat is a specific area or type of area that is considered to be essential for the survival of a species, as designated by 

the USFWS under the Act. The yellow-billed cuckoo is the only federally listed wildlife species on the 3 Bars 

ecosystem; the Columbia spotted frog is a candidate for listing; and the Greater sage-grouse is a special status species. 

3.16.1.2 BLM Special Status Species 

BLM Special Status Species are defined as those plant and animal species for which population viability is a concern, 

as evidenced by a significant current or predicted downward trend in population numbers or density, or a significant 

current or predicted downward trend in habitat capability that would reduce the species’ existing distribution. These 

animals are protected under provisions of the Act or under BLM Manual 6840, Special Status Species Management 

(USDOI BLM 2008h). In addition, there is a Nevada State Protected Animal List (Nevada Administrative Code §§ 

501.100 - 503.104) that BLM has incorporated, in part, into the Special Status Species list. The Greater sage-grouse is 

protected under the September 2015 Nevada and Northeastern California Greater Sage-Grouse Approved Resource 

Management Plan Amendment and Record of Decision (ARMPA). 

3.16.1.3 BLM and Nevada Department of Wildlife Memorandum of Understanding 

Wildlife and fish resources and their habitat on public lands are managed cooperatively by the BLM and NDOW 

under a Memorandum of Understanding as established in 1971. The Memorandum of Understanding describes the 

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WILDLIFE RESOURCES 

BLM’s commitment to manage wildlife and fisheries resource habitat, and the NDOW’s role in managing 

populations. The BLM meets its obligations by managing public lands to protect and enhance food, shelter, and 

breeding areas for wild animals. The NDOW assures healthy wildlife numbers through a variety of management tools 

including wildlife and fisheries stocking programs, hunting and fishing regulations, land purchases for wildlife 

management, cooperative enhancement projects, and other activities. 

3.16.1.4 Nevada Department of Wildlife Programs

The NDOW is responsible for the restoration and management of fish and wildlife resources within the state. The 

NDOW administers state wildlife management and protection programs as set forth in Nevada Revised Statutes 

Chapter 501, Wildlife Administration and Enforcement, and Nevada Administrative Code Chapter 503, Hunting, 

Fishing and Trapping; Miscellaneous Protective Measures. Nevada Revised Statute § 501.110 defines the various 

categories of wildlife in Nevada, including protected categories. Nevada Administrative Code §§ 503.010 to 503.080, 

503.110, and 503.140 list the wildlife species currently placed in the state’s various legal categories, including 

protected species, game species, and pest species. 

3.16.1.5 Migratory Bird Treaty Act and Migratory Bird Conservation Act 

Migratory birds, with the exception of native resident game birds, are protected under the provisions of the Migratory 

Bird Treaty Act of 1918. Under this act, nests with eggs or the young of migratory birds may not be harmed, nor may 

any migratory birds be killed. Measures to prevent bird mortality must be incorporated into the project’s design.

The Migratory Bird Conservation Act of 1929, as amended, makes it unlawful to directly or indirectly harm migratory 

birds. If the USFWS determines that migratory birds could be harmed by BLM vegetation treatment actions, the two 

agencies would develop a site-specific assessment and mitigation to prevent harm to these birds. 

Per the BLM Nevada Wildlife Surveys protocol, the BLM is required to conduct migratory bird surveys in and 

adjacent to (within 100 meters; 328 feet) a project area prior to disturbance. These surveys are adequate for up to 14 

days. Additional surveys must be conducted after 14 days have elapsed if the project has not been implemented 

(USDOI BLM 2013j). 

3.16.1.6 Bald and Golden Eagle Protection Act 

The Bald and Golden Eagle Protection Act (16 USC § 668) applies primarily to taking, hunting, and trading activities 

that involve any bald or golden eagle. The Act prohibits the direct or indirect take of an eagle, eagle part or product, 

nest, or egg. The term “take” includes “pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest, or 

disturb.” Disturb is defined as to “agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, 

based on the best scientific information available: 1) injury to an eagle, or 2) a decrease in its productivity, by 

substantially interfering with normal breeding, feeding, or sheltering behavior, or 3) nest abandonment, by 

substantially interfering with normal breeding, feeding, or sheltering behavior.” Golden eagles are protected by the 

Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act, both of which prohibit take. Prior to 

conducting a treatment, the BLM would survey for eagles as per guidance in the BLM Nevada Wildlife Surveys 

protocol (USDOI BLM 2013j).

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.16.1.7 Other Regulations 

The Sikes Act is federal legislation that authorizes the USDOI to plan, develop, maintain, and coordinate programs 

with state agencies for the conservation and rehabilitation of wildlife, fish, and game on public lands. The Fish and 

Wildlife Conservation Act of 1980 encourages federal agencies to conserve and promote the conservation of nongame fish and wildlife species and their habitats. 

3.16.2 Affected Environment 

3.16.2.1 Study Methods and Analysis Area 

The NDOW provided a list of wildlife species that have been observed within the project area, or which NDOW 

biologists believe have a strong potential to occur within the project area, based on knowledge of the species’ habitat 

preference and conditions. BLM biologists reviewed these lists prior to their incorporation into this document. The 

NDOW Wildlife Action Plan and the NDOW Draft Nevada Wildlife Action Plan Public Review provided information 

about key habitats and the species that depend on them, including species descriptions, range maps, and habitat needs 

(Wildlife Action Plan Team 2006, 2012). The Revised Nevada Bat Conservation Plan provided in-depth analysis of 

Nevada’s bat species, habitat and conservation needs, and distribution (Bradley et al. 2006). The Nevada 

Comprehensive Bird Conservation Plan was used as a supplemental resource for information about bird life history 

and habitats, especially for those species not covered in either the 2006 or 2012 Wildlife Action Plans (Great Basin 

Bird Observatory 2010). 

Several previous studies in or near the project area provided useful reference and analysis relevant to the proposed 

project. The most significant of these was the Mount Hope Project EIS (USDOI BLM 2012b). The Mount Hope 

Project is in the southeast corner of the 3 Bars Project area, and the study area for some aspects of the Mount Hope 

EIS included much the 3 Bars Project area. Finally, numerous Geographic Information System data files for wildlife 

species presence and seasonal habitat range were consulted in conjunction with the above referenced documents. 

The project area for analysis of direct and indirect effects to wildlife resources is the 3 Bars Project area. The 

cumulative effects analysis area includes the 3 Bars Project area, and areas within 10 miles of the project area 

boundary, as shown in Figure 3-1. 

3.16.2.2 Wildlife Habitat 

Important wildlife habitat in the area includes big sagebrush (mountain, basin, and Wyoming big sagebrush), low 

sagebrush, pinyon-juniper woodlands, aspen, riparian, and salt desert scrub vegetation types. The components of these 

habitats are described in Section 3.12, Native and Non-native Vegetation Resources, while wetland, floodplain, and 

riparian habitats within the project area are described in Section 3.11, Wetlands, Floodplains, and Riparian Zones. 

3.16.2.2.1 Sagebrush 

Sagebrush communities in Nevada provide habitat for approximately 100 bird species and 70 mammal species, 

including at least 28 rodent species (Braun et al. 1976). Big sagebrush provides important habitat for many sagebrush 

obligate and facultative wildlife species. “Obligate” species are those that live only within a particular habitat type, 

while “facultative” species prefer a particular habitat, but are not restricted to it. Sagebrush lizard, Greater sagegrouse, sage thrasher, sage sparrow, Brewer’s sparrow, sagebrush vole, pygmy rabbit, and pronghorn antelope are 

sagebrush obligate species (Paige and Ritter 1999, Knick et al. 2003). Low sagebrush areas provide seasonal habitat 

3 Bars Project Final EIS 3-287 October 2016 
WILDLIFE RESOURCES 

for some species and year-round habitat for smaller animal species. Sagebrush provides important nesting and 

foraging habitat, and protection from predators and from the weather. The deep, often sandy or loose soils are easy to 

dig, and burrowing and denning species are common. Sagebrush range in good condition typically supports a lush 

undergrowth of bunchgrasses and forbs. This highly productive understory is critical to the needs of wildlife species, 

including sagebrush vole and several species of shrew that depend on the productivity of the grass component for both 

prey production and cover (Wildlife Action Plan Team 2012). 

Wildfire, spread of noxious weeds and other invasive non-native species, and pinyon-juniper encroachment are major 

threats to sagebrush habitat and associated wildlife (Connelly et al. 2004). The decline in sagebrush habitat in the 

western U.S. has resulted in the Greater sage-grouse being petitioned for listing as threatened or endangered, and 

shrubland birds are declining faster than any other group of species in North America (Knick et al. 2003). The 

Brewer’s sparrow population has declined by over 50 percent since 1966, and the loggerhead shrike population 

continues to decline across its range (Wildlife Action Plan Team 2012). 

3.16.2.2.2 Pinyon- juniper Woodland 

Pinyon-juniper woodlands provide a variety of sheltering functions for wildlife that range from hiding cover to 

cavities and nest sites for birds, bats, and small mammals. Numerous wildlife species frequent pinyon-juniper habitats 

in the western United States. At least 70 species of birds and 48 species of mammals have been associated with these 

woodlands (Gottfried et al. 1995). Over the past 150 years, pinyon-juniper has expanded into sagebrush, riparian, and 

aspen habitats, to the detriment of species that use these habitats. Ironically, despite the increase in amount of pinyonjuniper habitat on the landscape, resident seed and fruit eating bird species such as pinyon jay, western scrub jay, and 

mountain chickadee are undergoing substantial population declines in the pinyon-juniper biome, while migratory 

insectivore populations are little changed (Sauer et al. 2008 cited in Great Basin Bird Observatory 2011). 

The pinyon-juniper woodlands provide important thermal protection for wildlife during winter, and shelter from the 

intense sun during the summer. For birds and bats in particular, pinyon-juniper woodlands provide structure for 

nesting and roosting and locations for foraging that would otherwise be missing from the mid-elevation cold desert. 

The pinyon nut crop is an important food source for a number of species, including pinyon jay and a variety of small 

mammals. The juniper berry crop is also an important food resource for birds and small mammals (Wildlife Action 

Plan Team 2012). Pinyon-juniper at different successional stages offers different benefits for different species, and 

pinyon-juniper communities can range from open stands with a diverse understory of shrubs and grasses to closed 

woodlands with little understory vegetation. Open pinyon-juniper/big sagebrush/bunchgrass stands are midsuccessional and characterized by herbaceous, shrub, and tree layers, and often host a high diversity of wildlife 

species. As western juniper dominance increases, structural diversity declines. Old growth stands also differ 

structurally from post-settlement woodlands, including having a greater density of cavities, which benefits cavity 

nesting species (Miller et al. 2005).

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.16.2.2.3 Aspen and Riparian 

Wildlife use riparian zones disproportionately more than any other type of habitat in the Great Basin (see review in 

Thomas et al. 1979, Wildlife Action Plan Team 2012). Riparian habitat in the Great Basin supports a rich diversity of 

wildlife, including more than one-half of the bird species that breed regularly in the Great Basin (Wildlife Habitat 

Council 2005). Riparian areas provide important habitat for numerous wildlife species on the 3 Bars Project area, but 

several species, including northern leopard frog, Lewis’ woodpecker, northern goshawk, mountain quail, willow 

flycatcher, Cassin’s finch, montane shrew, and numerous species of bats preferentially use riparian zones (USDOI 

BLM 2003b, Wildlife Action Plan Team 2012). 

Biological diversity is higher in aspen stands than in any other upland forest type in the West (Finch and Ruggiero 

1993 cited in Kay 2003). Numerous wildlife species use aspen areas and aspen stands typically have high bird 

abundance and richness, but several species, including Lewis’ woodpecker, northern goshawk, Cassin’s finch, 

mountain quail, mule deer, and numerous species of bats preferentially use aspen habitats on the 3 Bars Project area 

(Wildlife Action Plan Team 2012). Aspen are found on scattered tracts on the 3 Bars Project area, but their future is 

uncertain. Studies in California, Oregon, and Nevada have shown that 12 percent of aspen stands have been 

completely replaced by pinyon-juniper, and pinyon-juniper was dominant or co-dominant on another 65 percent of 

stands (Kerr and Salvo 2007). Studies in Nevada and on the 3 Bars Project area have shown that unless protected by 

fencing, aspen stands are degraded by livestock. In areas where aspens were protected from grazing, they successfully 

regenerated and formed multi-aged stands. Aspen have also declined from fire suppression, but even if burned, will 

not regenerate if ungulate herbivory is excessive (Kay 2001, 2003, USDOI BLM 2010d). 

Aspen communities are particularly important to cavity nesting species in Nevada because stems attain sizes over 10 

inches diameter at breast height and the wood is soft and easy to excavate. Because large diameter aspen occur more 

frequently in riparian aspen stands, these areas tend to be preferred by cavity nesting species. In addition to cavities 

and peeling bark, mature aspen communities provide larger diameter trees utilized by wildlife as forage substrate or 

nesting. For example, northern goshawks can live in and utilize high-elevation shrub-steppe habitats because stringers 

of large-diameter aspen trees with closed canopies in the riparian zones will support their nesting needs. Birds and 

small mammals utilize mid-story structure and herbaceous/shrub understory of aspen communities for forage, nesting, 

and protective cover. Downed trees in aspen habitat can create slow moving water conditions favorable to Columbia 

spotted frog, a federal candidate species and BLM Special Status Species. 

3.16.2.2.4 Salt Desert Scrub 

The intermountain cold desert shrub, including salt desert scrub, is the most important habitat in Nevada for several 

BLM Special Status Species, including pale kangaroo mouse and loggerhead shrike. The shrub habitat provides 

nesting structure and protection from predators and the weather. This habitat is important to loggerhead shrike, which 

can attain high breeding densities in valley bottoms where individual shrubs can be quite large and provide good 

cover and nest protection. Soils tend to be loose and either sandy or gravelly and are often easy to dig, providing 

important denning and burrowing habitat. Small and medium mammals including rabbits, jackrabbits, and various 

rodents that forage in the brush serve as prey for raptors. Washes provide unique habitat for certain terrestrial species 

including amphibians. By retaining higher soil moisture than surrounding upland areas, they can serve as enhanced 

movement and migration pathways for these species and facilitate their distribution across the landscape, perhaps 

serving an important role in amphibian metapopulation maintenance. As a result of the limited water availability 

associated with salt desert scrub, the habitat is used seasonally by larger animals and provides a lower abundance of 

smaller animals than found in the more mesic plant communities (Wildlife Action Plan Team 2012). 

3 Bars Project Final EIS 3-289 October 2016 
WILDLIFE RESOURCES 

3.16.2.3 Wildlife Species 

Wildlife species and habitats occurring in the project area are typical of the central Basin and Range region, and are 

relatively abundant within and adjacent to the project area. Wildlife species that are not special status species are 

discussed below; a discussion of special status species, such as those listed as federally threatened or endangered, or 

BLM Special Status Species, follows. These discussions only address a portion of the wildlife species that occur 

within the 3 Bars Project area, and focus on those species where the BLM has the most information. 

3.16.2.3.1 Reptiles and Amphibians 

Records for amphibian occurrence within the project study area are lacking. Based on amphibian records in areas 

adjacent to the project study area, species occurrence could include the Great Basin spadefoot toad, western toad, 

northern leopard frog, and Columbia spotted frog (Petersen 2012). The Columbia spotted frog is discussed under 

BLM Special Status Species. 

Potential habitat for amphibians within the project study area includes springs, wet areas, and streams. Many of the 

toad species, such as Great Basin spadefoot, utilize terrestrial habitats throughout most of the year, but they move to 

aquatic habitats for breeding in the spring or early summer. 

The northern leopard frog was petitioned for listing, but the status review and 12-month finding concluded that listing 

the western population is not warranted at this time (USDOI USFWS 2011). Habitat for northern leopard frog 

typically includes springs and wet areas. Breeding typically occurs in the spring or early summer for leopard frogs. 

There are a variety of snakes and lizards that are known either to occur or have the potential to occur within the 

project area, in almost every habitat type. Likely species include rubber boa and ringneck snake, which can occupy a 

variety of grassland and woodland habitats including aspen woodlands, and often occur near riparian zones. The 

greater short-horned lizard also uses a variety of habitats including sagebrush, and open pinyon-juniper woodlands, 

and prefers areas where substrate is stony, sandy, or firm, but usually where there is some fine loose soil. Desert 

horned lizard and long-nosed leopard lizard tend to prefer arid shrublands, and may occur in the project area, and the 

great basin rattlesnake is likely to occur in the broken rocks and brush habitats within the project area. Other reptiles 

known or likely to occur in the project area include coachwhip, common sagebrush lizard, great basin collared lizard, 

western fence lizard, long-nosed snake, and striped whipsnake (NDOW 2008a, 2009b, Wildlife Action Plan Team 

2012).

3.16.2.3.2 Birds 

Waterfowl 

Waterfowl and wading birds occur in shallow lakes, marshes, grassy meadows, and wetlands. These birds may use the 

project area for breeding, as a wintering ground, as year-round habitat, or during migration. Snow geese, tundra 

swans, and other waterfowl overwinter within the project area, while mallards and Canada geese overwinter and breed 

here. Great blue heron forage in shallow water and marshy areas year-round, while populations of American bittern, 

black-crowned night heron, and sora use these habitat areas during the breeding season. Other species of waterfowl, 

including several species of teal as well as egret, rails, and coots, are known to occur in the project area. Migratory 

and breeding populations of sandhill crane use the wet meadows, riparian zones, and agricultural lands for foraging, 

and often congregate in large numbers in eastern Nevada, including all of Eureka County (Wildlife Action Plan Team 

2006, 2012, Great Basin Bird Observatory 2010, Cornell Lab of Ornithology 2011). 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Doves and Quail 

Mourning dove and chukar partridge are small game birds that occur on the project area. Mourning doves primarily 

inhabit open country, areas with scattered trees, and woodland edges, and forage for seeds on the ground. They are 

frequently found along unimproved roads where they obtain gravel for food digestion, or near springs and artificial 

sources of water (Cornell Lab of Ornithology 2011, USDOI BLM 2012b). Mourning doves are a year-round resident 

in Nevada (Otis et al. 2008). Chukar partridge were introduced to Nevada in the 1940s and are now widely 

distributed. Optimum habitat for chukar partridge consists of steep rugged canyons with numerous talus slopes and 

rocky outcrops; the species typically inhabits rock outcrops and ledges adjoining grassy and sagebrush hillsides. 

Chukar partridge eat a variety of leafy green food, weed seeds, fruits, berries, insects, and beetles. Chukar partridge 

are common in the Roberts Mountains, Whistler Mountain, and Sulphur Spring Range. Occupation of seasonal habitat 

varies with moisture and snow levels. The birds typically move to lower elevations and south-facing slopes during 

heavy snow events, and concentrate around water sources during the summer months (USDOI BLM 2012b).

Raptors 

A variety of raptors are known to use the project area for roosting, nesting, and/or hunting. Golden eagle, northern 

harrier, prairie falcon, Cooper’s hawk, ferruginous hawk, red-tailed hawk, Swainson’s hawk, sharp-shinned hawk, 

American kestrel, and western burrowing owl have been known to nest in the area. Nesting data since 2006 indicates 

active use of the area by prairie falcons, and kestrels. Northern goshawk, a BLM Special Status Species, occurs in 

riparian habitat in the Roberts Mountains area. There are also numerous historic nesting records for ferruginous hawk, 

another BLM Special Status Species, within open habitat areas of the 3 Bars project area, including a site in the 

southeastern section of the project area that has been used within the past 10 years, Flammulated owls may occur in 

woodland areas in the north-central part of the project area. Additional raptors sighted in the area include merlin and 

rough-legged hawk (Wildlife Action Plan Team 2006 and 2012, NDOW 2009c, 2010a, USDOI BLM 2012b). 

Migratory Birds 

Neo-tropical migrant birds are bird species that migrate from the temperate portions of the continent to winter in the 

tropics of North and South America. Neo-tropical migrants are most commonly associated with habitats having a 

strong vertical component of woody shrubs and trees. A number of migratory birds that breed in North America and 

winter in the neotropical region of South America also breed in the project area and vicinity. 

Species commonly occurring in pinyon-juniper habitats and that are known to occur or have the potential to occur in 

the project area include the pinyon jay, western bluebird, Virginia’s warbler, black-throated gray warbler, and Scott’s 

oriole. Sage thrasher, Brewer’s sparrow, and sage sparrow use sagebrush habitats within the project area, while 

loggerhead shrike and green-tailed towhee also have potential to occur in the sagebrush habitats in the project area. 

Gray flycatcher is known to occur within the project area and may use pinyon-juniper, tall sagebrush, or riparian 

habitats (Great Basin Bird Observatory 2010, USDOI BLM 2012b, Wildlife Action Plan Team 2012). Other 

migratory species known to occur within the project area include common nighthawk, common raven, mountain 

bluebird, black-throated sparrow, lark sparrow, and western meadowlark. 

3 Bars Project Final EIS 3-291 October 2016 
WILDLIFE RESOURCES 

3.16.2.3.3 Mammals 

Large Game 

Mule deer use a variety of vegetation types and habitats seasonally within the project area in their pursuit of forage, 

thermal cover, and escape cover for seasonal needs. Vegetation important for mule deer includes serviceberry, 

snowberry, mountain mahogany, sagebrush, aspen, cottonwood, willow, chokecherry, wild rose, singleleaf pinyon 

pine, Utah juniper, eriogonum, arrowleaf balsamroot, penstemon, phlox, sorrel, hawksbeard, lupine, and numerous 

forbs. Riparian vegetation along streams, meadow areas, and aspen stands are important fawn-rearing areas (USDOI 

BLM 2007g). Six mule deer herds have all or a portion of their range within the project area, including the Sulphur 

Spring herd, Whistler herd, Fish Creek herd, Roberts Mountain herd, Simpson Park herd, and Cortez Mountains herd 

(Figure 3-39). Mule deer habitat is concentrated primarily in the eastern half of the project area, including the Roberts 

Mountains area, and in the Simpson Park area. 

Habitat for mule deer over much of the 3 Bars Project Area is in decline, and proposed treatments are designed to 

slow or reverse this trend (Figure 3-40). Factors contributing to this decline include pinyon-juniper encroachment 

into shrublands, decadent and unhealthy pinyon-juniper stands, high levels of hazardous fuels that could lead to a 

catastrophic wildfire and loss of deer habitat, livestock grazing, noxious weeds and other invasive non-native 

vegetation, and human-related disturbance. 

The mule deer population in NDOW hunt units 141 through 145 has been stable to slightly increasing from 2009 to 

2011, with a December 2011 population estimate of nearly 1,500 animals (NDOW 2012b, c). The Roberts Mountains 

deer are migratory in nature. Mule deer leave Roberts Mountains in October or November and migrate south into the 

Mountain Boy and Fish Creek Ranges south of U.S. Highway 50. The migration pattern includes moving south from 

Roberts Creek Ranch to Lone Mountain and from Henderson Summit along Whistler Mountain to Devils Gate 

(USDOI BLM 2012b).

Pronghorn antelope occupy the lowlands and the foothills of the project area and are mostly absent from the Roberts 

Mountains area (Figure 3-41; NDOW 2008b). Pronghorn numbers have increased throughout the area in recent 

years, partially in response to vegetation changes resulting from past range fires. Wyoming big sagebrush habitat is 

particularly important to pronghorn (Tsukamoto 2003). Important vegetation species for pronghorn include low sage, 

black sage, serviceberry, shadscale, winterfat, rabbitbrush, greasewood, ricegrass, needlegrasses, lupine, spurge, 

balsamroot, several eriogonum species, scarlet globe-mallow, phlox, locoweed, and other perennial forbs. Ten 

antelope herds have all or a portion of their range within the project area. The 2006 population estimate for the 

NDOW hunt units was 450 animals, up from 240 in 2002, and population growth was observed in 2011 (NDOW 

2012b). The pronghorn antelope population in Kobeh Valley is low and variable with most of the antelope 

observed in the southern part of the valley near Lone Mountain and U.S. Highway 50 (USDOI BLM 2012b).

Habitat for pronghorn antelope over much of the 3 Bars Project Area is in decline, and proposed treatments are 

designed to slow or reverse this trend (Figure 3-41). Factors contributing to this decline include pinyon-juniper 

encroachment into shrublands, high levels of hazardous fuels that could lead to a catastrophic wildfire and loss of 

pronghorn antelope habitat, livestock grazing, noxious weeds and other invasive non-native vegetation that displace 

native forbs and grasses, dense stands of Wyoming big sagebrush, and human-related disturbance. 

Bighorn sheep occur in mesic to dry grasslands or shrub-steppe in mountains, foothills, or river canyons, in areas with 

access to steep, rugged terrain for escape from predators. While historic populations of bighorn sheep were in most 

3 Bars Project Final EIS 3-292 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

mountain ranges within Nevada, there are no known bighorn sheep populations with the 3 Bars Project area. The most 

recent NDOW sighting for bighorn sheep in the project area was in 1983, on the east side of the Roberts Mountains 

(NDOW 2008a, 2010b). Potential habitat for bighorn sheep exists in the Roberts Mountains area, the Whistler Range, 

Lone Mountain, the Simpson Park Mountains, and the Cortez Mountains (NDOW 2010b). 

Other Mammals 

Cougars are found primarily in the mountainous portions of the 3 Bars Project area, and bobcats have been seen 

throughout the 3 Bars Project area, including near Table Mountain in the Sulphur Spring Range, along Vinini 

Creek on the Roberts Mountains, and in the central area south of Roberts Mountains. Coyotes occupy almost all 

habitat types and have been observed in the southern part of the project area (NDOW 2012d). One of the most 

diverse groups represented in the project area is rodents, with species of chipmunks, mice, ground squirrels, 

jumping mice, kangaroo rats, and voles present throughout. Members of the rabbit family, including pygmy 

rabbit, black-tailed jackrabbit, and mountain cottontail, also occur in the project area (USDOI BLM 2012b). Pika 

could be found on Roberts Mountains. 

The Revised Nevada Bat Conservation Plan and NDOW data show several records for bat occurrences within the 

project area. Bats inhabit or utilize many niches across the 3 Bars landscape. These include caves, abandoned mines, 

cliffs, springs, riparian, aspen, pinyon-juniper, subalpine coniferous forest, and desert shrub habitats. The only 

documented bat occurrences in the project area are for long-eared myotis, which has been recorded on the eastern 

edge of the project area and in the Roberts Mountains. Townsend’s big-eared bat and western small footed myotis 

may occur on the southeastern edge of the project area (Bradley et al. 2006, NDOW 2008a). Bat species are discussed 

in greater detail in the Special Status Species section. 

3.16.2.3.4 Special Status Species 

The following discussion of BLM Special Status Species is based on two lists: the BLM’s Special Status Species list 

for the Battle Mountain District, and the NDOW list of species known to occur within the 3 Bars Project area or that 

NDOW biologists believe have the potential to occur within the project area, based on habitat needs and habitat 

conditions (NDOW 2012d). The lists were cross-referenced with each other to obtain a list of Special Status Species 

known to occur or with potential to occur within the 3 Bars Project area. NDOW Geographic Information System data 

were used to verify whether there are current or historic occurrences of a species within the project area, but because 

absence of a Geographic Information System record does not necessarily indicate that the species is absent, only that 

no record has been made of its presence in a particular location, the following section considers all BLM Special 

Status Species suspected or known to occur within the 3 Bars Project area. 

Table 3-45 lists the special status species within the Project Area. Of these, the yellow-billed cuckoo is the only 

species federally listed as threatened or endangered; and the Columbia spotted frog is a federal candidate species. 

3 Bars Project Final EIS 3-293 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-39

Mule Deer Habitat

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Mule Deer Habitat

Summer Range

Crucial Summer Range

Winter Range

Crucial Winter Range

Transition Range

Year-round Range

Agricultural Lands/

Unique Habitat

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: NDOW 2009d.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-40

Areas with Degraded

Habitat Conditions

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Degraded Habitat

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2009a.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-41

Pronghorn Habitat

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Pronghorn Habitat

Summer Range

Winter Range

Crucial Winter Range

Year-round Range

Crucial Year-round Range

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: NDOW 2008b.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-297 October 2016 

Amphibians 

Columbia Spotted Frog

Columbia spotted frogs are closely associated with clear, slow-moving or ponded surface waters, with little shade, and 

relatively constant water temperatures. Breeding and egg-laying occurs in waters with floating vegetation and larger 

ponds such as oxbows, lakes, stock ponds, and beaver-created ponds; in some areas, this species is critically tied to 

beaver ponds. Adults are opportunistic feeders, and eat insects, mollusks, crustaceans, and spiders. Tadpoles eat 

decomposed plants and live green algae. 

Columbia spotted frogs occur in three geographically separated subpopulations in the Jarbidge and Independence 

Mountains, the Ruby Mountains, and in the Toiyabe Mountains. There are no recorded occurrences in the project 

area. 

TABLE 3-45 

Special Status Species Known or with Potential to Occur on the 3 Bars Project Area 

Common Name/Group Scientific Name Status Habitat

REPTILES AND AMPHIBIANS

Columbia spotted frog Rana luteiventris Federal Candidate

Clear, open, slow moving or still 

water with consistent 

temperature.

BIRDS

Bald eagle Haliaetus leucocephalus BLM Sensitive Large conifers for roosting.

Black rosy-finch Leucosticte atrata BLM Sensitive

Barren, rocky, or grassy areas 

and cliffs among glaciers or 

above timberline.

Brewer’s sparrow Spizella breweri BLM Sensitive Sagebrush and large openings in 

pinyon-juniper.

Ferruginous hawk Buteo regalis BLM Sensitive

Pinyon-juniper edges, sagebrush, 

and other open areas and wooded 

edges.

Golden eagle Aquila chrysaetos BLM Sensitive Open or sparsely wooded habitats 

in mountainous areas.

Greater sage-grouse Centrocercus urophasianus BLM Sensitive Sagebrush.

Lewis’ woodpecker Melanerpes lewis BLM Sensitive Aspen and riparian.

Loggerhead shrike Lanius ludovicianus BLM Sensitive Desert scrub, especially creosote 

bush. Nests in sagebrush. 

Northern goshawk Accipiter gentilis BLM Sensitive Aspen and riparian.

Peregrine falcon Falco perigrinus BLM Sensitive Desert scrub, including sage and 

steppe habitat near cliffs. 

Pinyon jay Gymnorhinus cyanocephalus BLM Sensitive Pinyon-juniper.

Sage thrasher Oreoscoptes montanus BLM Sensitive Sagebrush.

Swainson’s hawk Buteo swainsoni BLM Sensitive Wooded riparian near sage and 

brushland.
WILDLIFE RESOURCES 

TABLE 3-45 (Cont.) 

Special Status Species Known or with Potential to Occur in the 3 Bars Project Area 

Common Name/Group Scientific Name Status Habitat

BIRDS (Cont.)

Western burrowing owl Athene cunicularia BLM Sensitive Sagebrush.

Yellow-billed cuckoo Coccyzus americanus Threatened

Riparian obligate and dense 

riparian cottonwood-willow 

stands.

MAMMALS 

California myotis Myotis californicus BLM Sensitive Desert to forest.

Dark kangaroo mouse Microdipodops 

megacephalus BLM Sensitive Sagebrush.

Fringed myotis Myotis thysanodes BLM Sensitive Desert to forest.

Hoary myotis Lasiurus cinereus BLM Sensitive

Forests/woodlands, including 

pinyon-juniper and forested 

riparian zones.

Little brown bat Myotis lucifugus BLM Sensitive Associated with coniferous forest 

with a nearby water source.

Long-eared myotis Myotis evotis BLM Sensitive Coniferous forests.

Long-legged myotis Myotis volans BLM Sensitive

Pinyon-juniper woodland and 

montane coniferous forests. May 

use shrub habitat including 

sagebrush. 

Pygmy rabbit Brachylagus idahoensis BLM Sensitive Sagebrush.

Silver-haired bat Lasionycteris noctivagans BLM Sensitive

Forests and wooded areas near 

water, including pinyon-juniper 

forests and wooded riparian 

corridors.

Townsend’s big-eared bat Corynorhinus townsendii BLM Sensitive

Caves and mines in a variety of 

habitats, including pinyon-juniper 

and mahogany woodlands. 

Western pipistrelle Parastrelluss hesperus BLM Sensitive

Desert habitats including 

sagebrush, and occasionally in 

pinyon-juniper habitat with rock 

outcrops and canyons.

Western small-footed 

myotis Myotis ciliolabrum BLM Sensitive

Various, including grasslands, 

shrubland, coniferous forest, and 

urban settings.

Sources: Bradley et al. (2006), Great Basin Bird Observatory (2010), and Wildlife Action Plan Team (2012). 

Birds 

Greater Sage-grouse 

Greater sage-grouse are largely dependent on sagebrush for nesting and brood rearing and feed almost exclusively on 

sagebrush leaves during the winter. Greater sage-grouse are known to occur in foothills, plains, and mountain slopes 

where sagebrush meadows and aspen are in close proximity. A dense sagebrush overstory and an herbaceous 

3 Bars Project Final EIS 3-298 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

understory of grasses are important to provide shade and security, and both new herbaceous growth and residual cover 

are important in the understory. 

Greater sage-grouse have specific habitat requirements to carry out their life cycle functions. Early spring habitats or 

breeding sites called “leks” are usually situated on ridge tops or grassy areas surrounded by a substantial brush and 

herbaceous component (USDOI BLM 2012b). Leks have less herbaceous and shrub cover than the surrounding areas. 

In early spring, males gather in leks where they strut to attract females. Nests are located in thick cover in sagebrush 

habitat and consist of a shallow depression on the ground. Habitat for brood-rearing in early spring is critical to brood 

survival. Important habitat components for brood rearing include a sagebrush overstory, an herbaceous understory, 

and the presence of plentiful insects, especially wasps, bees, ants and beetles, which provide a high-protein diet for 

broods. Insects are especially important in the diet of newly hatched broods. Over the fall, birds shift from consuming 

large amounts of forbs to eating mostly sagebrush. Access to sagebrush for food and cover in winter is critical to their 

survival. 

Greater sage-grouse habitat is found over most of the 3 Bars Project area. The distribution of Greater sage-grouse on 

the project area is closely tied to the sagebrush ecosystem that provides nesting, brood-rearing, and fall/winter cover 

as well as forage throughout the year. Summer habitat consists of sagebrush mixed with areas of wet meadows, 

riparian, and irrigated agricultural fields. Fall habitat consists of a mosaic of low-growing sagebrush and Wyoming 

big sagebrush. Winter habitat is contingent on the severity of winter weather, topography, and vegetative cover, but 

access to sagebrush for food and cover in winter is critical to Greater sage-grouse survival. 

Late spring habitat and nesting sites are in thick cover in sagebrush habitat beneath sagebrush or other shrubs. 

Individual Greater sage-grouse move seasonally between habitat types throughout the year (USDOI BLM 2012b). 

With the exception of a few of the higher elevation areas, all of the 3 Bars project area is within the summer 

distribution range for Greater sage-grouse. Nearly all of the foothills and lowland areas are within the winter range of 

the species, and Kobeh Valley and Denay Valley are within nesting range. 

The NDOW defines lek status as active, inactive, historic, or unknown. An active lek is defined as a lek that had two 

or more birds present during at least one of three or more surveys in a given breeding season. For a strutting ground to 

attain this status, it must also have had two or more birds present during at least 2 years in a 5-year period. An inactive 

lek is a lek that has been surveyed three or more times during one breeding season with no birds detected during the 

surveys and no sign observed on the lek. If a lek is only surveyed once during a breeding season and was surveyed 

under adequate conditions and no birds were observed at the location during the current and the previous year and no 

sign was observed at the lek, then an inactive status can be applied to the lek. An unknown lek is a lek that may not 

have had birds present during the last survey, but could be considered viable due to the presence of sign at the lek. 

This designation could be especially useful when weather conditions or observer arrival at a lek could be considered 

unsuitable to observe strutting behavior. The presence of a single strutting male would invoke the classification of the 

lek as unknown. A lek that was active in the previous year, but was inadequately sampled (as stated above) in the 

current year with no birds observed could also be classified as unknown. An historic lek is a lek that has not had bird 

activity for 20 years or more and has been checked according to protocol at least intermittently. Another means of 

classifying a lek as historic is to photograph a lek location and determine if the habitat is suitable for normal courtship 

displays. For example, if a lek location lies in a monotypic stand of sagebrush that is 3 to 4 feet tall, then conditions 

are no longer suitable for leking activity. 

The BLM and Forest Service have developed a National Greater Sage-Grouse Planning Strategy for identifying 

important Greater sage-grouse habitat. Currently, agencies are utilizing habitat classifications addressed in the 

3 Bars Project Final EIS 3-299 October 2016 
WILDLIFE RESOURCES 

ARMPA to guide land use decisions— Priority Habitat Management Areas (PHMA), General Habitat Management 

Areas (GHMA) and Other Habitat Management Areas (OHMA). Priority Habitat Management Areas and General 

Habitat Management Areas indicate where land-use changes could result in an expected negative impact to sagegrouse population health and are shown on Figure 3-42 for the 3 Bars Project area. These classifications are a 

conglomeration of NDOW Greater seasonal sage-grouse data. 

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 consists 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. 

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. 

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. 

The Greater sage-grouse population trends are tracked based on the number of males per lek (Sage- and Columbian 

Sharp-Tailed Grouse Technical Committee 2008). Individual Greater sage-grouse counts can vary year to year and 

approximately 10 years of data are required to establish population trends. Populations in Eureka County showed a 25 

percent increase between 2011 and 2012, but are only 55 percent of the highest recorded levels in 1986. The peak 

male attendance at ten comparable leks surveyed in 2012 was 259, for an average of 25.9 males per lek. In 2011, 207 

males were counted for an average of 20.7 males per lek. The average in 2006 was 41 males, which is the highest 

average since the 1986 average of 47 males. In addition to trend counts there were additional leks monitored by the 

NDOW, BLM, and University of Nevada-Reno graduate students in 2012. The 18 leks monitored in 2012 had 346 

males in attendance for an average of 19.2 males per lek. In 2011, these same leks had 307 males yielding an average 

of 17.1 males per lek for a 12 percent increase from 2011 to 2012. Within the 3 Bars project area, there were 21 active 

leks surveyed in 2012; 339 males were counted, for an average of 16.1 males per lek. An additional 27 leks have a 

status of unknown, and there are 10 historic lek sites (Figure 3-42; Podborny 2012). 

Habitat for Greater sage-grouse over much of the 3 Bars Project Area is in decline, and proposed treatments are 

designed to slow or reverse this trend (Figure 3-40). The most significant threats to Greater sage-grouse in Nevada 

are natural system modifications due to wildfire and the subsequent loss of habitat as well as impacts of invasive 

species (cheatgrass) and pinyon-juniper encroachment. Other threats include habitat fragmentation and disturbance, 

particularly roads and utility service lines as a result of both renewable and non-renewable energy resources, and 

degradation caused by overgrazing, mining, and recreational activities. 

3 Bars Project Final EIS 3-300 October 2016 
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No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012f,k.

Figure 3-42

Greater Sage-grouse

Leks and Habitat

3 Bars Ecosystem and

Landscape Restoration Project

Source: BLM 2012f,k.

o

Legend

Greater Sage-grouse

Leks and Habitat

¥[ Active Lek

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Priority Habitat Management Area

Other Habitat Management Area

General Habitat Management Area

Non-Habitat

Pinyon-juniper Treatment Area

Sage Treatment Area

Aspen Treatment Area

Riparian Treatment Area

3 Bars Project Area

0 1 2 3 4 5 10

Miles

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 03/15/16)

0 1 2 3 4 5 10

Kilometers
WILDLIFE RESOURCES 

Bald Eagles 

Bald eagles are found throughout Nevada as part of the species winter range and are known to occur within the 

project area, with most occurrences along the northeastern edge of the project area boundary. Bald eagles roost 

preferentially in large conifers or other sheltered sites in winter and typically select the larger, more accessible trees. 

There are no known bald eagle nesting sites within the project area (NDOW 2009c).

Golden Eagle 

Golden eagles are found throughout Nevada and the project area. Golden eagles are generally found in a variety of 

open to semi-open landscapes, especially in hilly or mountainous regions, and avoid heavily forested areas. This 

species typically nests on rock ledge on cliffs or occasionally in large trees. Pairs may have several nests, and may use 

the same nest in consecutive years or shift to using an alternate nest in different years. Nests have been recently found 

in the project area (USDOI BLM 2012b). Golden eagles feed mainly on small mammals (e.g., rabbits, marmots, 

ground squirrels), although they are opportunistic and may also eat insects, snakes, birds, young deer or pronghorn 

antelope, and carrion.

Northern Goshawk 

Northern goshawks breed and winter throughout the state. Northern goshawks rely on open sagebrush adjacent to 

riparian and aspen stands for foraging, and aspens are a key habitat feature. Nests are generally constructed in the 

largest trees in dense, large tracts of mature or old growth aspen stands with high canopy closure (60 to 95 percent) 

and sparse ground cover, near the bottom of moderate slopes, and near water or dry openings. Prey items include tree 

squirrels, ground squirrels, rabbits, and various bird species, depending on availability. Within the project area, 

northern goshawks are known from aspen and riparian habitat in the west-central Roberts Mountains (NDOW 2009c). 

Peregrine Falcon 

Peregrine falcons use various open environments including steppe, over open water, and desert shrub habitats 

including sagebrush, usually in close association with suitable nesting cliffs. They can also be found in mountainous, 

open forested regions, and human population centers. Peregrine falcons often nest on ledges or in holes on rocky cliff 

faces, commonly in sites sheltered by an overhang. There is an historic NDOW record for peregrine falcons in the 

Roberts Mountains (NDOW 2009c). Peregrine falcons feed primarily on birds, ranging in size from medium 

songbirds up to small waterfowl. They may also hunt small mammals, such as bats, or lizards, fishes, and insects. 

Swainson’s Hawk 

Swainson’s hawks are a spring and summer resident of Nevada, including the project area. Open riparian woodlands, 

including aspen woodlands, with significant expanses of pasture, agricultural fields, wet meadow, or open shrublands 

with grass cover in the immediate vicinity, provide an ideal landscape for the Swainson’s hawk. The preferred nesting 

site is in large riparian trees. Small mammals are typical prey (Great Basin Bird Observatory 2010). 

Ferruginous Hawk 

Ferruginous hawks are year-round and breeding residents in central Nevada, including the 3 Bars Project area. Habitat 

includes open country, sagebrush, saltbush-greasewood shrubland, and the periphery of pinyon-juniper and other 

woodland and desert communities. In Nevada, ferruginous hawks nest primarily in live juniper trees. Mammals are 

3 Bars Project Final EIS 3-302 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

the primary prey during the breeding season, although birds, amphibians, reptiles, and insects are also taken. 

Ferruginous hawk sightings in the 3 Bars Project area have occurred around the perimeter of the project area in 

relatively level, open terrain. There are over 50 records for nesting sites within the project area, although only one of 

these, in the southeastern corner of the project area, has been observed active within the past 10 years (NDOW 

2009c). Small mammals are the primary prey during the breeding season, although birds, amphibians, reptiles, and 

insects also are taken. 

Western Burrowing Owl 

Western burrowing owls are mostly migratory in northern Nevada, although some individuals may overwinter. 

Preferred habitat is characterized by short vegetation and the presence of fresh small mammal burrows, indicating an 

abundance of the deer mice and meadow voles that are preferred food. Western burrowing owls typically nest and 

roost in burrows abandoned by grounds squirrels, badgers, fox, and tortoise, although they occasionally excavate fresh 

burrows (Wildlife Action Plan Team 2006). 

Within the project area, there are records for western burrowing owl from the open lands surrounding the Roberts 

Mountains. The most recent record is for two owls sighted at a burrow in 2006, in the southwestern quadrant of the 

project area. (NDOW 2009c). 

Yellow-billed Cuckoo

The yellow-billed cuckoo is listed as threatened, under the Endangered Species Act. Historically, the species was 

found state-wide areas of large, contiguous, densely wooded cottonwood-willow riparian habitat. The species nests in 

willows and forages for large insects, its primary food source, in cottonwood trees. The last sighting of yellow-billed 

cuckoo in or near the project area was in 1976, just outside of the southeast corner of the project area boundary 

(Nevada Natural Heritage Program 2006). 

Lewis’ Woodpecker

Lewis’ woodpeckers are a year-round resident within the project area. Important habitat features include an open tree 

canopy, a brushy understory with ground cover, dead trees for nest cavities, dead or downed woody debris, perching 

sites, and abundant insects. In Nevada, this species is most strongly associated with deciduous riparian woodlands 

dominated by aspen or cottonwood (Great Basin Bird Observatory 2010). The species is a weak excavator, and as 

such it is dependent on dead trees, and tends to nest in existing tree cavities. Key habitat factors include the presence 

of large, partly decayed snags, an open forest structure for aerial foraging, and a well-developed shrub or native 

herbaceous layer that promotes healthy populations of flying insects. 

Lewis’ woodpeckers feed on insects including ants, beetles, flies, grasshoppers, tent caterpillars, and mayflies during 

the summer, and ripe fruit and nuts in the fall and winter. Unlike other woodpeckers, Lewis’ woodpeckers do not bore 

for insects, but will catch them in flight, glean insects from tree branches or trunks, and forage on the ground. Lewis’

woodpeckers are suspected, but not documented, within the project area (Great Basin Bird Observatory 2010). 

Loggerhead Shrike 

Loggerhead shrikes are a year-round resident throughout the state. This species breeds in open country with scattered 

trees and shrubs, savanna, desert scrub, and, occasionally in open woodlands. Loggerhead shrikes often perch on 

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WILDLIFE RESOURCES 

poles, wires, or fence posts and suitable hunting perches are an important part of the habitat. Nesting habitat includes 

shrubs and small trees, including cholla cactus and sagebrush. 

Loggerhead shrike feed primarily on large insects, small birds, lizards, frogs, and rodents, and will occasionally 

scavenge. While there are no records for loggerhead shrike within the project area, there are occurrence records near 

the southeastern edge of the project area. 

Sage Thrasher 

Sage thrashers occupy the Great Basin region of Nevada including the project area. Sage thrashers breed and forage in 

sagebrush, juniper, mountain mahogany, and aspen communities, and have a preference for patchy habitat with 

adequate shrub cover. The species occasionally nests on the ground but more typically nests in low shrubs, typically 

sagebrush. Sage thrashers feed on a wide variety of insects, including grasshoppers, beetles, weevils, ants, and bees, 

as well as fruits and berries. There are extant sage thrasher records for the southeastern corner of the project area 

(Great Basin Bird Observatory 2010).

Black Rosy-finch 

Black rosy-finches winter in central Nevada, including the project area (Ellsworth 2013). This species uses barren, 

rocky, or grassy areas and cliffs among glaciers or beyond timberline as habitat. During migration and winter this 

species also occurs in open fields, cultivated lands, brushy areas, and around human habitation. Black rosy-finches 

usually nest in rock crevices or in holes in cliffs above snow fields, although it may nest in old abandoned buildings, 

mine shafts, or other protected sites. The black rosy-finch forages on the ground for seeds. In the spring, it gleans 

wind-blown insects from the snow, and later in the season it may glean insects from vegetation or may chase flying 

insects and catch them in the air. 

Brewer’s Sparrow

Brewer’s sparrows breed in northern Nevada, including the project area, but does not overwinter in the project area. 

The species is strongly associated with healthy sagebrush habitats, and prefers areas with patchy cover by scattered 

tall shrubs and short grasses. Brewer’s sparrows can be found to lesser extent in mountain mahogany and rabbitbrush 

habitats, bunchgrass grasslands with shrubs, bitterbrush, ceanothus, and manzanita, and in large openings in pinyonjuniper stands. Sagebrush is the preferred nesting habitat. 

Brewer’s sparrows are primarily a ground forager. During the summer they eat a variety of insects, and in the fall and 

winter transitions to a diet of seeds. Brewer’s sparrow nest in sagebrush throughout the 3 Bars Project area (Ellsworth 

2013). 

Pinyon Jay 

Pinyon jays are a year-round resident anywhere in Nevada where pinyon pine occurs, including appropriate habitats 

in the project area. Pinyon jays have a strong preference for pinyon-juniper woodlands, and occur less frequently in 

pine habitats. During the non-breeding season, this species may also occur in scrub oak and sagebrush. Pinyon jays 

nest in shrubs or trees when adequate numbers of pine seeds are available. The pinyon jay diet consists of pinyon nuts 

and other pine seeds, berries, small seeds, and grain, as well as insects including beetles, grasshoppers, caterpillars, 

and ants. Pinyon jays may also eat bird eggs and hatchlings. Pinyon jays have been observed on Roberts Mountains 

and Sulphur Spring Range (Ellsworth 2013). 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Mammals 

Dark Kangaroo Mouse 

The dark kangaroo mouse inhabits stabilized dunes and other sandy soils in valley bottoms and alluvial fans 

dominated by big sagebrush, rabbitbrush, and horsebrush. These nocturnal rodents typically occur in sandy habitats 

below the elevation where pinyon-juniper occur and above elevations where greasewood and saltbush predominate. 

Although restricted to sand, it displays a broad tolerance for soils with varying amounts of gravel. Seeds are the 

primary food source although it will also eat some insects. It does not appear to use free-standing water and probably 

gets moisture from its food sources. It is believed to store food in seed caches within the burrow system. 

There is one extant record for dark kangaroo mouse within the project area. This record is from 2005, in the southeast 

Kobeh Valley near Whistler Mountain (NDOW 2008a). The potential range of the species includes appropriate 

habitat throughout the project area. 

Pygmy Rabbit 

The pygmy rabbit is a diminutive native species that is found primarily on plains dominated by big sagebrush and on 

alluvial fans where plants occur in tall, dense clumps. Deep, loose soils are required for burrow excavation, although 

they will occasionally occupy burrows dug by other animals in harder soils. Big sagebrush is the primary food and 

may comprise up to 99 percent of food taken in winter and 51 percent in the summer. Wheatgrass and bluegrass are 

highly preferred foods in the summer. Cheatgrass invasion is detrimental to pygmy rabbits. Shrub cover is necessary 

for protection during dispersal and cheatgrass monocultures may provide a barrier to dispersal. Pinyon-juniper 

encroachment decreases understory species and, in turn, decreases suitable pygmy rabbit habitat. Pygmy rabbits spend 

the majority of their lives within 40 feet of their burrows (Utah Division of Wildlife Resources 2003), although 

occasionally males will venture more than 2 miles during the breeding season (Katzner and Parker 1998). 

Pygmy rabbits are found in several locations in the project area, including along the east side of the Kobeh Valley, 

several locations along riparian systems in the central and southern portion of Roberts Mountains, and in the Parks 

Mountains north of Cottonwood Canyon. Surveys conducted in the southeast portion of the project area as part of the 

Mount Hope Project EIS found 19 burrows and 10 pygmy rabbits. The majority of the sightings and burrows were 

along the old railroad grade to the west of and paralleling State Route 278, and numerous sightings and burrow 

complexes were also along the alluvial fan east of Mount Hope Spring (NDOW 2009c, e, USDOI BLM 2012b). 

California Myotis 

The California myotis is found throughout Nevada, primarily at elevations below 6,000 feet amsl. The species is 

somewhat of a habitat generalist, and is found in habitats ranging from desert scrub to forested areas. This bat roosts 

in crevices, including those found in mines, caves, buildings, rocks, hollow trees, and under bark. California myotis 

forages in the open for a variety of small insects such as moths, flies, and beetles. Most records for the species are 

from southern Nevada, but the species has the potential to occur in the project area (NDOW 2008a). 

Fringed Myotis 

The fringed myotis is found throughout central and southern Nevada in a wide range of appropriate habitat, from low 

desert scrub to high elevation coniferous forests, including white fir forests and pinyon-juniper woodlands. This 

species roosts in mines, caves, trees, and buildings, and may also use rock crevices, tree hollows, and rock crevices in 

3 Bars Project Final EIS 3-305 October 2016 
WILDLIFE RESOURCES 

cliff faces. Nurseries and hibernacula are generally mines or caves. Foraging occurs in and among vegetation, with 

some gleaning activity. In some areas, there is evidence that fringed myotis use forest edges as well as areas above the 

forest canopy for foraging. The fringed myotis eats a variety of insects but seems to preferentially select beetles. 

There are no records for fringed myotis within the project area (NDOW 2008a). 

Hoary Bat 

The hoary bat is a tree-roosting species, found primarily in forested/woodland upland habitats such as pinyon-juniper 

and conifers, as well as in gallery forest riparian zones. Hoary bats day roost 10 to 18 feet above ground in trees that 

offer good protective leaf cover, but that are open below to facilitate flying in and out of the roost. Hoary bats may 

migrate for the winter or hibernate on tree trunks, in a tree cavity, or in a squirrel’s nest. Food items include a variety 

of insects but moths, dragonflies, and beetles feature prominently. Foraging is generally over the tree canopy. In the 

open, rapid descending arcs are exhibited. Hoary bats will follow watercourses for foraging and drinking. The nearest 

records for hoary bat are southwest of the project area although their range includes the project area (NDOW 2008a).

Little Brown Bat 

The little brown bat is found primarily at higher elevations, and is often associated with coniferous forest and with 

larger bodies of water or rivers. Often, roost sites are associated with these aquatic features. Little brown bats have 

adapted to using human-made structures for resting and maternity sites, but will also use caves, hollow trees, and rock 

outcrops. These bats feed heavily on aquatic insects such as caddisflies, midges, and mayflies, although a variety of 

other terrestrial insects may be eaten. Foraging occurs in open areas among vegetation, along water margins, and 

sometimes a few feet above the water surface. 

In the eastern U.S., little brown bats suffer from white-nose syndrome, with over 5 percent mortality in some areas, 

Should the disease spread to the west, white nose syndrome would be a significant threat to the overall viability of the 

species. Little brown bat is more common in the northern part of Nevada. There are no records for little brown bat in 

the project area (NDOW 2008a).

Long-eared Myotis 

The long-eared myotis is usually associated with coniferous forests. Individuals roost under exfoliating tree bark, and 

in hollow trees, and occasionally in caves, mines, cliff crevices, sink-holes, and rocky outcrops on the ground. It is 

often described as a hovering gleaner that feeds by eating prey off foliage, tree trunks, rocks, and from the ground. 

The species is found throughout the state and its range includes the project area; there are species records for longeared myotis in the Roberts Mountains (NDOW 2008a). 

Long-legged Myotis 

The long-legged myotis is found in pinyon-juniper woodland and montane coniferous forest habitats, and is 

occasionally found in salt desert scrub, blackbrush, mountain shrub, and sagebrush habitats. This species roosts 

primarily in hollow trees, particularly large-diameter snags or live trees with lightning scars, and may use rock 

crevices, caves, mines, and buildings when available. Long-legged myotis feeds primarily on moths, but also feeds on 

beetles, flies, and termites. 

The species is found throughout the state and its range includes the project area. There are no species records for longlegged myotis in the project area (NDOW 2008a).

3 Bars Project Final EIS 3-306 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Silver-haired Bat 

The silver-haired bat is a forest-associated species and is more commonly found in mature forests. These bats are 

found primarily at higher latitudes and altitudes in coniferous and mixed deciduous and coniferous forests/woodlands 

of pinyon-juniper, limber pine, aspen, cottonwood, and, willow. These bats forage for a wide variety of insects above 

the forest canopy or along wooded edges, roadsides, and the edges of streams and waterbodies. Moths appear to be a 

major portion of their diet. Loss of foraging habitat in riparian zones is a threat. 

The species is found throughout the state and its range includes the project area. There are no species records for 

silver-haired bats in the project area (NDOW 2008a).

Townsend’s Big-eared Bat 

The Townsend’s big-eared bat roosts in mines, caves, and cave-like spaces in pinyon, curl-leaf mountain mahogany, 

blackbrush, sagebrush, salt desert scrub, agricultural, and occasionally urban habitats. Foraging associations include 

the edge of habitats along streams that are adjacent to and within a variety of wooded habitats. Townsend’s big-eared 

bats are moth specialists, with nearly all of their diet consisting of moths. 

The species’ range includes the entire state including the project area. The nearest records to the project area for 

Townsend’s big-eared bat are immediately north and northwest of the project area and southeast of the project area 

(NDOW 2008a).

Western Pipistrelle 

The western pipistrelle can be found in Sonoran desert habitats of blackbrush, creosote, salt desert shrub, and 

sagebrush, with occasional occurrence in pinyon-juniper woodlands, usually in association with rock features such as 

granite boulders and canyons. The species typically roosts in rock crevices, but may use mines, or, less frequently, 

buildings and vegetation. Food includes small moths, leafhoppers, mosquitoes, and flying ants. Foraging occurs in the 

open. 

The species is found throughout most of the state, primarily in the southern and western portions. The species has the 

potential to occur in the project area although there are no records for western pipistrelle in the project area (NDOW 

2008a).

Western Small-footed Myotis 

The western small-footed myotis is found in a variety of habitats including desert scrub, grasslands, sagebrush steppe, 

blackbrush, greasewood, pinyon-juniper woodlands, pine-fir forests, agricultural, and urban areas. This species is a 

crevice rooster and uses mines, caves, buildings, rock crevices, hollow trees, and exfoliating bark on trees. Western 

small-footed myotis forages early in the evening on a variety of insects including small moths, flies, ants, and beetles 

that occur in open areas. 

The species is found throughout Nevada except for the far southeastern corner of the state. The species has been 

observed near the southeast corner of the project area (NDOW 2008a).

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WILDLIFE RESOURCES 

3.16.3 Environmental Consequences 

3.16.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, a number of concerns specific to wildlife and 3 Bars ecosystem 

restoration were identified and are discussed in this section. These include: 

 Reduction in the amount of key wildlife habitat because of degraded range conditions due to past rangeland 

management practices and past range disturbances. 

 Project actions could have large-scale effects ranging from increased sedimentation of streams to major 

fragmentation of pinyon jay, Virginia’s warbler, Greater sage-grouse, Brewer’s sparrow, and other sensitive 

species’ habitat.

 Encroachment and expansion of pinyon-juniper into important habitat for Greater sage-grouse or other 

wildlife species. 

 Proposed treatments in pinyon pine woodlands and any resulting impacts to pine nuts could impact several 

species of birds and mammals, including pinyon jay and mule deer. 

 There is a need to thin pinyon-juniper along drainages to improve water flows in streams and to open up 

corridors for animal movement on the south and east side of drainages. 

 There is a need to assess treatment impacts on wildlife species that are dependent on old growth pinyonjuniper as well as on other species that may nest in the area or migrate through it. 

 There is a need to assess how sagebrush treatments would impact habitat for pygmy rabbit, sage sparrow, and 

other sagebrush species. 

 The potential to fragment remaining patches of sagebrush by mowing and chopping could hasten the decline 

of the Greater sage-grouse population. 

 That all factors affecting Greater sage-grouse (including predators and hunters) be considered, not just loss of 

habitat. 

 Need to address movements of Greater sage-grouse hens with broods from valley nesting and early brood 

rearing sites to upper elevation sagebrush and riparian communities on Roberts Mountains. 

 Thinning of the pinyon-juniper woodlands along creek bottoms may be beneficial to the survival of Greater 

sage-grouse. 

 The effects of invasion of undesirable plant species into Greater sage-grouse and other wildlife habitats. 

 The high, very high, or extreme risk of catastrophic wildfire in important Greater sage-grouse habitats. 

 Fences can cause avian mortality from collisions, including significant Greater sage-grouse mortality, and 

can serve as perches for predators or observation posts for the brown-headed cowbird. 

 Proper size, shape, and design of vegetation treatments to create an edge effect would be critical in the 

success of the project for wildlife. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 Whether Greater sage-grouse, pygmy rabbit, pinyon jay, loggerhead shrike, and other species in the 3 Bars 

ecosystem are present at levels that provide viable populations in the short-, mid-, and long-term, especially 

under continued livestock degradation of habitats, utility corridor developments, mining and energy 

developments, and the spread of cheatgrass and noxious weeds and other invasive non-native vegetation that 

would be promoted by the various vegetation and woodland removal plans the BLM may be contemplating. 

 Whether there is an opportunity for the reintroduction of bighorn sheep into the 3 Bars ecosystem if domestic 

sheep operations voluntarily relinquish their permits, a change of livestock occurs, or further research is 

conducted into bighorn sheep diseases. 

3.16.3.2 Significance Criteria 

Impacts to wildlife would be considered significant if BLM actions resulted in: 

 A substantial, long-term (greater than 10 years) reduction in the quantity or quality of habitat critical to the 

survival of local populations of common wildlife species. 

 Injury or mortality to common wildlife species, such that species populations would not recover within 5 

years. 

 Mortality to a listed species or species proposed for listing that could result in a “take” under the Endangered 

Species Act. 

 A reduction in the population, habitat, or viability of a species of concern or sensitive species that would 

result in a trend toward endangerment or the need for federal listing. 

 Any loss of birds, eggs, or nesting habitat critical to migratory birds under the Migratory Bird Treaty Act, in 

the project area. 

3.16.3.3 Direct and Indirect Effects 

3.16.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Impacts 

Adverse effects to wildlife common to all treatments include injury and loss of life, noise and other disruptions 

associated with treatment applications, and temporary and long-term habitat effects. 

The use of vehicles and treatment equipment for restoration poses a risk of injury or death by crushing animals or 

their nests or roosts, and vehicle weight may collapse burrows or compact soils. Soil compaction may also make 

burrow or den excavation difficult. Fuel spills could have negative effects to wildlife species on land if fuel is 

ingested, and could negatively impact water quality. The likelihood of such an impact is negligible, though, as 

refueling would generally occur off-site or away from treatment areas. 

Hand-held manual equipment, including chainsaws, mechanical equipment, and transport vehicles create noise that 

can disturb animals and cause them to flee or alter their behavior or habitat use. Most researchers agree that noise can 

affect an animal’s physiology and behavior, and if it becomes a chronic stress, noise can be injurious to an animal’s 

energy budget, reproductive success, and long-term survival (Radle 2007). The loudness of normal conversation is 

about 65 decibels, while the loudness of a chainsaw is about 110 decibels. These effects would be short-term and 

3 Bars Project Final EIS 3-309 October 2016 
WILDLIFE RESOURCES 

occur within a relatively small area, however, and would not likely to have much effect on the long-term health and 

habitat use of wildlife in the treatment area. 

Over the short-term, treatments could make habitats less suitable for some wildlife species, requiring displaced 

wildlife to find suitable habitat elsewhere. If these habitats were already near or at capacity in the number of wildlife 

they could support, displaced animals might perish or suffer lower productivity. In many cases, the treatments would 

return all or a portion of the treated area to an early successional stage, favoring early successional wildlife species. In 

areas where fire suppression has historically occurred, vegetation treatments could benefit native plant communities 

by mimicking a natural disturbance component that has been missing from these communities. Treatments would also 

restore native vegetation in areas where noxious weeds and other invasive non-native vegetation have displaced native 

plant species. Wildlife that occurred historically in these areas would likely increase in numbers, while species that 

have adapted to the disturbed conditions, such as chukar partridge, would decline (USDOI BLM 2007c:4-75). 

Species that are mobile or that are not dependent on a specific habitat type can relocate during treatment activities and 

adapt to a new environment. Species that require very specific habitat conditions or that cannot relocate easily may be 

more vulnerable to impacts. Treatments that cover a large area have more potential to affect species, because there 

may be less opportunity for an animal in the interior of a treatment area to vacate, and because the number of 

individual animals affected is likely to be greater for a large area (USDOI BLM 2007c:4-74). 

Small, temporary exclosure fencing would be used to protect treatment sites. Although fencing would benefit wildlife 

habitat, it can also modify wildlife movements and wildlife may collide with fences. Stevens (2011) found that sagegrouse collisions with fences were fairly common in Idaho, especially in areas near leks. 

Beneficial Impacts 

Proposed treatments would occur across the 3 Bars Project landscape, would target areas with declining habitat 

quantity and quality, and would facilitate wildlife movement across the landscape. There has been a loss of habitat 

diversity and complexity due to pinyon-juniper encroachment into riparian, woodland, and sagebrush habitats, and 

decrease in the abundance and diversity of animals that can be supported in areas with pinyon-juniper encroachment. 

Loss of habitat at the landscape level would be addressed by reducing levels of pinyon-juniper encroachment into 

other habitats, reducing the spread of noxious weeds and other invasive non-native vegetation, and reducing the risk 

of catastrophic wildfire. Treatments that slow or reverse pinyon-juniper encroachment and promote the development 

of native vegetation would improve habitat structure and species composition (USDOI BLM 2007c:4-85). 

Cheatgrass and other noxious weeds and other invasive non-native plants provide few wildlife benefits, often occur in 

monocultures across the landscape, and alter wildfire cycles to the detriment of native vegetation and wildlife. By 

slowing or reversing the spread and occurrence of noxious weeds and other invasive non-native vegetation on the 

landscape, greater numbers and types of wildlife would be supported by the area, and risks to special status species 

and other species found in low numbers in treated ecosystems would be reduced. 

Treatments that reduce hazardous fuel loads, slow the spread of pinyon-juniper, reduce woodland densities, reduce the 

incidence of disease within pinyon-juniper communities, reduce the spread of noxious weeds and other invasive nonnative vegetation, and create fuel and fire breaks would reduce the risk of catastrophic wildfire harming wildlife or 

their habitat (Connelly 2013). Fire and fuel breaks would be designed in collaboration with NDOW to minimize the 

loss of sagebrush in key habitats. Treatments aimed at restoring natural fire cycles would improve vegetation 

resilience and increase plant diversity across the landscape, to the benefit of wildlife (USDOI BLM 2007c:4-85). 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Improvements in habitat quality would increase the carrying capacity of the landscape and allow it to support larger 

and healthier wildlife populations. In particular, treatments would benefit mule deer, pronghorn antelope, and Greater 

sage-grouse by removing pinyon-juniper that reduces habitat quality or thinning vegetation (pinyon-juniper) to allow 

more desirable vegetation, such as forbs and grasses, to better compete and thrive. Thinning and removing pinyonjuniper would also benefit local and seasonal movements of wildlife, including mule deer and Greater sage-grouse. 

The BLM would not thin or remove sagebrush in Greater sage-grouse wintering and breeding areas, as recommended 

by Connelly (2013). Removing pinyon-juniper could benefit Greater sage-grouse because they are thought to avoid 

trees and other tall vegetation during migration and local movements. Because water is scarce on the 3 Bars Project 

area, the BLM would implement stream and riparian restoration projects to improve water availability for wildlife. In 

addition, slash piles left from thinning pinyon-juniper would be used provide microhabitat and cover for reptiles, 

rabbits and other small mammals, and songbirds. 

Wildfire, spread of invasive plants, and other factors have caused habitat fragmentation and the loss of connectivity 

between blocks of habitat, especially in lower elevation riparian zones, woodlands, and sagebrush. Fragmentation has 

isolated some animal populations and reduced the ability of populations to disperse across the landscape by increasing 

the distance that wildlife must travel between suitable habitat patches. Treatments that restore native vegetation in 

disturbed areas should reduce fragmentation and restore connectivity among blocks of similar habitat, allowing 

wildlife to move more easily across the landscape (USDOI BLM 2007c:4-85). 

3.16.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Because of the increase in the amount of habitat treated, both short-term impacts and long-term benefits to wildlife 

would be greatest under this alternative. Species would benefit through the slowing of pinyon-juniper encroachment; 

removal of crested wheatgrass, forage kochia, and cheatgrass; creation of a matrix of habitat types; reseeding and 

replanting of native shrubs, forbs, and grasses to restore habitat; a reduction in the threat of a catastrophic wildfire; 

and increase in edge habitat. Species that would benefit from edge habitat would include Greater sage-grouse that 

might forage in meadows and near streams, but seek shrub cover for shelter; raptors that perch in pinyon-juniper trees 

but forage in adjacent grassland and sagebrush habitats; and mule deer that forage in meadows, but seek shelter and 

thermal cover in adjacent pinyon-juniper woodlands.

Riparian Treatments 

Adverse Effects 

Treatment activities may result in a permanent or temporary loss of cover along riparian zones, potentially exposing 

animals to predators and causing the loss of thermal cover during temperature extremes. Loss of wooded areas 

adjacent to streams may make the habitat unsuitable for species that prefer wooded riparian zones. 

Treatment work at several streams, ponds, wells, and springs would involve using heavy equipment to reconstruct 

streams and improve riparian habitat. Heavy equipment and placement of rock and other structures in streams pose a 

risk of injury or death by crushing animals or their breeding sites; amphibians would be most susceptible to harm or 

injury from use of heavy equipment near streams. If not done properly, stream reconstruction could worsen stream 

channel morphology, alter water depths and flows, and cause the loss of additional riparian habitat. Changes in water 

availability and flow rates would be especially harmful to amphibians that lay their eggs in water and require 

relatively stable water conditions for their eggs and hatchlets. Loss of riparian vegetation would contribute to 

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WILDLIFE RESOURCES 

sedimentation via increased runoff and erosion, affecting in-stream habitat for aquatic species including amphibians 

that forage, breed, or hide in stream gravel or spaces between stones (Pilliod et al. 2003). 

Manual and mechanical methods would be used at Hash Spring and several other springs, as well as at sites where 

Lahontan cutthroat trout habitat improvements are planned. About half of the pinyon-juniper treatments would occur 

in Phase I stands, and the remaining treatments would be split nearly evenly between Phase II and III stands. Most of 

the Phase II and III treatments would occur along Roberts Creek. This would reduce the amount of habitat available to 

pinyon-juniper dependent species, including pinyon jay, gray flycatcher, juniper titmouse, Bewick’s wrens, blue-gray 

gnatcatchers, black-throated gray warblers, and ferruginous hawks (Miller et al. 2005). Removal of Phase III trees and 

decayed and malformed trees could eliminate habit for cavity-nesting birds, such as woodpeckers and owls, and 

nesting and roosting habitat for small mammals, such as bats, squirrels, and mice. Removal of pinyon-juniper, 

particularly large trees, would also reduce the capacity of woodlands to intercept snow and provide snow-intercept 

thermal cover during winter (Hunter 1990 cited in USDOI BLM 2007c). Loss of winter cover may negatively affect 

mule deer that use pinyon-juniper areas during the winter (Miller et al. 2005). Fire and fuel breaks could serve as a 

barrier to small mammal and amphibian movement. 

Small, temporary exclosure fences erected at riparian treatment sites could have an adverse effect on some small 

mammals, birds, and reptile populations because fences may provide perches for raptors and ravens that predate on 

small mammals such as mice, bats, and squirrels. Fences could also provide scanning perches for brown-headed 

cowbirds, thereby helping them to locate and parasitize bird nests and small mammals, such as bats, squirrels, and 

mice. 

Beneficial Effects 

Riparian treatments are designed to enhance water quality and quantity for wildlife, while also promoting improved 

habitat conditions that lead to higher quality forage and cover. Approximately 85 percent of riparian treatment acreage 

is within mule deer summer or winter range habitat, while over 80 percent of the riparian treatment acreage is within 

the summer or winter range for Greater sage-grouse (Figures 3-39 and 3-42; NDOW 2008a, 2009d). Proposed 

treatments would focus on restoring degraded riparian habitat, including restoring about 1,250 acres of mule deer 

habitat, 177 acres of pronghorn antelope habitat, and 2,093 acres of Greater sage-grouse PHMA. 

A key feature of healthy riparian habitat is a high diversity of microhabitats. However, riparian habitat systems on the 

3 Bars Project area have been altered through actions such as stream channelization, construction of water diversions 

for livestock, construction of roads, introduction of noxious weeds and other invasive non-native vegetation, and 

pinyon-juniper encroachment. For many wildlife species, these alterations often mean a loss of habitat (Tsukamoto 

1983, Wasley 2004, Wildlife Action Plan Team 2012). 

Manual and mechanical treatments are often more effective than other treatment methods, especially in sensitive 

areas, such as wetland and riparian habitat, or near habitats of plant and animal species of concern, where greater 

control over treatment effects is required or effects to non-target species are a concern (USDOI BLM 2007c:4-88). 

Stream restoration using manual and mechanical methods would reduce stream erosion and episodes of bank failure, 

improving both water quality and stream access for wildlife, while fencing and plantings would improve cover, 

shoreline stability, and wildlife habitat value. Treatments in riparian zones would create wet meadows and 

meandering streams and reduce water loss associated with stream downcutting; this would benefit amphibians and 

provide improved forage and habitat for birds and mammals. Riparian zones in rangelands typically produce more 

edge habitat in a small area than other habitat types. Mule deer spend a disproportionate amount of time in riparian 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

habitats, including use as fawning habitat (Thomas et al. 1979), and would see an increase in habitat area and quality 

as a result of treatments. Riparian zones also produce large quantities of insects, which in turn provide food for 

wildlife, including Greater sage-grouse and bats. 

Reducing the cover of pinyon-juniper on up to 900 acres in riparian treatment areas could improve water flows, allow 

more desirable riparian, woodland, and sage-brush vegetation to thrive, and open up movement corridors for Greater 

sage-grouse and other wildlife (see review in Miller et al. 2005:35). Use of felled trees in streams to slow water would 

create pools that provide breeding habitat for amphibians and open-water drinking areas for bats and other wildlife. 

By mulching or piling trees, cover and thermal habitat would be created that would provide protection and warmth to 

amphibians, reptiles, birds, and small mammals. Removal of pinyon-juniper should also improve flows in nearby 

creeks as water uptake by trees is lessened. For example, DeBoodt (2008) found that in areas where all juniper were 

cut from a watershed in Oregon, that late season spring flow, days of recorded ground flow, and late season soil 

moisture increased compared to pretreatment conditions. 

Greater sage-grouse would benefit from riparian treatments that remove pinyon-juniper within those corridors used by 

sage-grouse for seasonal movements, and improve habitat quality within brood-rearing areas. Pinyon-juniper 

treatments within riparian corridors on the Roberts Mountains would be particularly beneficial because dense 

woodlands likely contribute to a high mortality rate for female Greater sage-grouse and their young as they move 

from nest sites in the surrounding valleys to higher elevation meadows. It is likely that the removal of pinyon-juniper 

and regeneration of a riparian and shrub community would facilitate movements and improve Greater sage-grouse 

survival. Wet meadow and other riparian restoration treatments would increase the availability of insects and other 

food items needed by Greater sage-grouse chicks and adults. Forbs and insects comprise the bulk of Greater sagegrouse chick diets until they are about 12 weeks old (Crawford et al. 2004), and are important to Greater sage-grouse 

chick survival (Drut et al. 1994). Atamian et al. (2010) found that Greater sage-grouse and their broods preferred 

higher elevation, moist sites with riparian shrubs or sagebrush during late brood rearing, and lack of this habitat could 

be a limiting factor for Greater sage-grouse chick survival (Drut et al. 1994). 

Aspen Treatments 

Adverse Effects 

The primary impact to wildlife from treatments would be from noise, which could cause wildlife to leave the 

treatment area for a short period of time. There is concern that noise and other disturbance could cause wildlife, 

including northern goshawk, to abandon nests, however treatment areas would be surveyed for nesting birds prior to 

treatment and if nests are found, treatments would be delayed until young have fledged. 

There also would be loss of pinyon-juniper habitat where trees are felled to slow pinyon-juniper encroachment into 

aspen stands, and to create fire and fuel breaks. About 10 acres of pinyon-juniper would be treated annually near 

aspen stands. Effects to wildlife and their habitat from pinyon-juniper removal would be similar to those described 

under Riparian Management. 

Beneficial Effects 

Aspen treatments would benefit a variety of wildlife. All of the aspen treatment sites are within mule deer summer or 

winter range, and 60 percent of the sites are within pronghorn summer or winter range (Figures 3-39 and 3-41;

NDOW 2008b, 2009d). Of the 151 acres of proposed aspen treatments, about 146 acres are within areas where the 

3 Bars Project Final EIS 3-313 October 2016 
WILDLIFE RESOURCES 

BLM has determined that mule deer habitat is degraded and 88 acres are within degraded pronghorn antelope habitat; 

treatments could improve habitat conditions for these species (Figure 3-40). Lewis’ woodpeckers, northern 

goshawks, and several species of bats are special status species that have been observed using aspen habitats on the 3 

Bars Project area. Northern goshawk preferentially use mature aspen communities for nesting, foraging, and roosting, 

and Lewis’s woodpecker and several species of bats use cavities and peeling bark in aspen stands (Wildlife Action 

Plan Team 2012). Northern goshawk use mature aspen almost exclusively for nesting in the Great Basin (Wildlife 

Action Plan Team 2012), and their apparent decline in Nevada has been attributed to the loss of mature aspen stands 

that provide structural support for goshawk nests (Great Basin Bird Observatory 2010). DeByle (1985) noted that 

stimulation of suckering substantially increased the number of shrub-nesting birds associated with the stand. 

Aspen areas provide important habitat for a variety of wildlife, and are being lost to pinyon-juniper encroachment. 

Mule deer use stream corridors within aspen habitat for fawning and as movement corridors, and treatments would 

improve both mule deer access and habitat quality. About half of the cavity-nesting birds in the western U.S nest in 

aspen stands (DeByle 1985). Bird species richness and diversity in sagebrush communities are strongly and positively 

correlated with the presence of nearby aspen stands, while encroachment of pinyon-juniper into aspen stands 

negatively impacts bird species diversity and richness. Manual and manual treatments to remove encroaching pinyonjuniper would help to ensure the long-term health and longevity of aspen and other woodlands by removing 

competing pinyon-juniper and encouraging aspen stand regeneration via seeds and suckering. 

The BLM would remove pinyon-juniper within 200 feet of aspen stands to improve their effectiveness as fire breaks. 

Fire breaks would help to protect mature aspen stands from fire and slow or compartmentalize wildland fire, to the 

benefit of wildlife and their habitat. Protective fencing in aspen stands would help to slow or reverse the loss of aspen 

habitat. 

Pinyon-juniper Treatments 

Adverse Effects 

Treatments proposed by the BLM that remove or reduce pinyon-juniper habitat could adversely impact wildlife that 

use these woodlands. The types and magnitude of adverse effects would differ according to the pinyon-juniper phase 

that treatments are conducted in. In general, adverse effects to wildlife habitat would be less in Phase I than Phase II

or III woodlands. Adverse effects from Phase I treatments to wildlife habitat would primarily be related to loss of 

woodland edge habitat. For example, ferruginous hawks use pinyon-juniper/sagebrush/grassland edge habitat for 

nesting and foraging. Treatments in Phase I woodlands would not impact species that use the understory vegetation 

because chainsaws would be the primary treatment tool. Phase I treatments would not target old growth pinyonjuniper, so bats and birds that use old growth stands would not be impacted. Chainsaw thinning in Phase I stands 

would cause only a slight increase of fuels and wildfire risk. Treatments in Phase II and III habitat would open up 

pinyon-juniper woodland to stimulate understory vegetation to the benefit of some species, but would also remove old 

trees that provide winter cover and trees with rough bark used by roosting bats. 

Over 70 species of birds nest in pinyon-juniper, and removal of pinyon-juniper could adversely impact migratory 

birds that use pinyon-juniper, including gray flycatcher, juniper titmouse, Bewick’s wrens, and black-throated gray 

warbler (Miller et al. 2005). Populations of several of these species are in decline despite the increase in pinyonjuniper on the landscape. These species generally favor stands that have an open canopy with a significant shrub 

understory, and the interface between pinyon-juniper and sagebrush; densely wooded interior locations and Phase III 

stands are generally bird poor (Noson 2002 cited in Miller et al. 2005, Great Basin Bird Observatory 2011). 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Pinyon-juniper stands provide important winter habitat for wildlife. In Oregon, higher winter bird densities occur in 

open juniper woodlands than in any other plant community (Miller 2001). Mule deer are also an important 

inhabitant. Dense stands of pinyon-juniper provide habitat for mule deer during severe winter weather because of the 

reduced snow cover and increased thermal cover in these areas. Bats favor old growth trees that have rough bark and 

crevasses. Removal of pinyon-juniper in Phase II and III stands could mean a loss of this wildlife benefit. Pinyonjuniper woodlands also provide habitat structure that would be lost if woodlands were converted to grasslands (Maser 

and Gashwiler 1978). 

Downed trees and other woody material left on the ground from thinnings and tree removal could serve as fuel for a 

wildfire. Slash from shredding and other treatments in late Phase II and Phase III woodlands can create a fire hazard 

for at least 2 years, and may leave sites vulnerable to the introduction of invasive plant species (Tausch et al. 2009, 

Gottfried and Overby 2011). Slash piles can aid in the establishment of new vegetation or seedlings and pose a longterm benefit for wildlife species that prefer more herbaceous and shrub cover. A delayed understory response to 

treatments is common, and it may be several years before a treated site regains full habitat value (Tausch et al. 2009). 

In the interim, the treated area may run the risk of noxious weeds and other invasive non-native vegetation 

colonization and associated decline in habitat value for wildlife species, or be at higher risk of erosion and associated 

declines in aquatic habitat quality if streams are nearby. 

The BLM does not plan to conduct burns in Phase I stands, but would conduct stand-replacement burns that could 

treat several thousand acres annually in Phase II and III stands. As noted earlier, about 60 percent of treatments would 

occur in Phase II and III stands. These burns could have adverse and beneficial effects on pinyon jays and other 

wildlife. Prescribed fires would open up pinyon-juniper stands and stimulate the growth of native forbs and grasses. 

However, given that prescribed fire burns would be less selective in controlling vegetation than manual or mechanical 

methods, and several thousand acres (but no more than 70 percent of the area) per treatment area could be burned 

annually, there could be a loss of mountain and Wyoming big sagebrush and other shrubs that are desirable for 

pronghorn antelope and mule deer. Numerous studies have shown that it can take decades for Wyoming big 

sagebrush to recover from fire, and that sage-grouse avoid burn areas (Sage- and Columbian Sharp-tailed Grouse 

Technical Committee 2008). Treated areas must then be reseeded to ensure that burned areas do not become infested 

with noxious weeds and other invasive non-native vegetation, to the detriment of wildlife. It is likely that large, older 

pinyon-juniper trees that provide juniper berries and pinyon nuts for pinyon jay and mule deer would also be lost 

(Balda and Masters 1980). Removal of mature and decadent and diseased trees would eliminate habitat used by 

cavity-nesting birds, roosting bats, and small mammals. In addition, large burns create more homogenous conditions 

that are less favored by wildlife, and remove thermal and hiding cover needed by mule deer (USDOI BLM 1991c). 

The large size of a treatment area may make it difficult for animals to flee during disturbance, especially fire, and may 

increase fire mortality. Species that are small or not very mobile may find it difficult to relocate into new, appropriate 

habitat in the wake of treatment activities, if the treated area is not immediately suitable for use. Greater sage-grouse 

chicks and roosting bats would likely not be able to escape fire. To minimize or avoid loss to Greater sage-grouse 

chicks, the BLM would not conduct treatments in brood-rearing areas, including the Atlas, Frazier, Gable, Henderson, 

Upper Roberts, and Vinini units, between May 15 and September 15 or as current policy dictates, including field 

verifications by BLM-approved biologists.Additional guidelines in Appendix C, Standard Operating Procedures, will 

also be followed. 

Wildland fires for resource benefit in the Sulphur Spring Wildfire Management Unit would be allowed during the 

summer, and could be more intense than prescribed fires and could lead to noxious weeds and other invasive non3 Bars Project Final EIS 3-315 October 2016 
WILDLIFE RESOURCES 

native vegetation problems. At a minimum, it could take longer for native forbs and grasses to establish on sites 

burned by wildland for resource benefit than on sites burned with prescribed fire because wildfires tend to burn hotter 

and are more intense. Because of the large treatment area and the inability to anticipate when or where a wildfire 

would occur, there would be limited opportunities to control which areas burn in order to minimize the loss of 

Wyoming sagebrush or other more desirable vegetation, to survey for sensitive species, or to mitigate for impacts to 

sensitive wildlife species within the time frames described in the SOPs (Appendix C). Large-scale fires could also 

increase habitat fragmentation, to the detriment of birds including Brewer’s sparrow, pinyon jay, and Virginia’s 

warbler, and to less mobile species, such as reptiles and small mammals. Use of bulldozers and other firefighting 

equipment, and possibly aerial retardants, to protect private property could disturb wildlife and their habitats and 

cause harm or injury to less mobile species. 

Beneficial Effects 

Although one of the primary objectives of pinyon-juniper management is to improve woodland health and reduce the 

risk of high-intensity crown fires in dense woodland stands, treatments would also benefit wildlife by 1) removing 

pinyon-juniper to develop and enhance movement corridors for Greater sage-grouse; 2) removing pinyon-junipers to 

slow encroachment into Greater sage-grouse leking and nesting areas; 3) removing and thinning pinyon-juniper to 

break up the continuity of fuels and reduce the risk of catastrophic wildfire; and 4) improving wildlife habitat on the 

Sulphur Spring Wildfire Management Unit using wildland fire for resource benefit. 

Most land managers target Phase I and II stands, which are often the most valuable to pinyon-juniper dwelling birds. 

Approximately 40 percent of treatments would be in Phase I stands and primarily involve the use of chainsaws to 

remove scattered trees. The BLM proposes to treat Phase II and III stands by opening up the canopy to stimulate 

growth in the shrub and herbaceous layers, and to reduce wildfire risk. About 40 percent of treatments would be in 

Phase II, and 20 percent in Phase III stands, using mostly mechanical methods, prescribed fire, and wildland fire for 

resource benefit (Sulphur Spring Wildfire Management Unit). While Phase I treatments may benefit Greater sagegrouse habitat, there may also be limited benefit to resident bird species that favor pinyon-juniper/sagebrush 

woodland edge habitat. By targeting Phase II and III stands, however, the BLM may enhance habitat for some 

pinyon-juniper dwelling species by opening up dense pinyon-juniper stands and creating more edge habitat (Great 

Basin Bird Observatory 2011). 

As observed throughout the Great Basin, as pinyon-juniper cover has increased, the cover of shrubs and herbaceous 

understory species has declined, to the detriment of wildlife (Willis and Miller 1999 cited in Miller et al. 2005). The 

overall goal is to manage pinyon-juniper for wildlife by restoring the balance between pinyon-juniper and 

understory plants such as shrubs, grasses, and forbs (Miller 2001). All of the pinyon-juniper treatment sites are 

within mule deer summer or winter range, 60 percent of sites are within pronghorn summer or winter range, while 

about half of the treatment area is within Greater sage-grouse PHMA (see Figures 3-39, 3-41, and 3-42; NDOW

2008b, 2009d). 

Manual and mechanical treatments would be used to control the encroachment of pinyon and juniper into sagebrush, 

riparian, and aspen sites. The most common method to remove pinyon-juniper is with chainsaws. These treatments 

would generally occur in Phase I stands. With chainsaws, pinyon-juniper can be removed or thinned, while still 

retaining some patches for wildlife. Chainsaws offer flexibility in the timing of application and the ability to precisely 

control treatment boundaries or target specific trees, including selective cutting of diseased trees or leaving habitat 

trees. Some cut trees, slash, or chips would be left on site to control erosion, aid in seedling establishment, and 

provide wildlife habitat (Tausch et al. 2009). Miller et al. (1999) found that avian species diversity was greater on 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

plots where juniper was removed and slash remained than on closed woodlands. Pronghorn antelope and mule deer 

benefit from mechanical treatments by foraging on strips of grasses and forbs that would be created for fuel breaks. 

Much of the focus of treatments would be on thinning or removing pinyon-juniper to benefit Greater sage-grouse and 

other wildlife using mechanical methods in Phase II and III stands. This would improve food and cover for small 

mammals by increasing shrub and herbaceous recruitment and seed production. Opening up dense stands of pinyonjuniper benefits edge species, ground-feeding and ground-nesting birds, and small mammals. Openings of 250 acres 

or less and created by mechanical means benefit deer, small mammals, and birds. Studies have shown that breeding 

bird densities increase as pinyon-juniper stands are opened up and treatments that create patches of treated and 

untreated pinyon and juniper promote species diversity (Scott and Boeker 1977, O’Meara et al. 1981, Payne and 

Bryant 1998). In addition to removing downed trees, the BLM would place larger wood into streams to slow water 

flow and provide habitat for amphibians and other wildlife. 

In pinyon-juniper woodlands, female cone production declines as woods close in and the competition between trees 

increases; thinning or removing Utah juniper using manual and mechanical methods should enhance cone and seed 

production and improve food and cover for small mammals by increasing shrub and herbaceous recruitment and seed 

production. Juniper cones are consumed by deer mice, golden-mantled ground squirrel, Lewis’ woodpecker, scrub 

jay, mountain bluebird, and cedar waxwing, and the berries are the primary winter food for American robin and 

Townsend’s solitaire. Mule deer, mountain cottontail, and coyote also consume juniper cones, and woodrats, 

cottontail, black-tailed jackrabbit, and porcupine forage on juniper foliage at certain times of the year. There are 

reports of twice as many species and up to a 60 percent increase in deer mice, piñon mice, and Ord’s kangaroo rat in 

thinned versus unthinned pinyon-juniper stands, and small mammal numbers generally increase when pinyon-juniper 

is thinned or completely cut, as long as slash remains (Miller et al. 2007). 

Treatments on the Atlas, Frazier, Gable, Henderson, Upper Roberts, and Vinini units would help to open up Greater 

sage-grouse travel corridors between lower elevation winter and leking habitats and upper elevation nesting and 

brood-rearing habitats, by removing pinyon-juniper that are encroaching into these drainages. Treatments would also 

provide forage for Greater sage-grouse and other wildlife by promoting development of native grasses, forbs, and 

shrubs through removal of pinyon-juniper. Several studies have shown that Greater sage-grouse avoid pinyon-juniper 

stands and that the number of Greater sage-grouse using an area increases after pinyon-juniper removal (see review in 

USDOI USFWS 2008:60-61). In general, adult survival is high, but is offset by low juvenile survival (Crawford et al. 

2004). Removal and thinning of pinyon-juniper in drainages should improve brood survivorship during movements 

from between breeding areas in the valleys and brood-rearing areas on Roberts Mountains, while these treatments in 

conjunction with riparian treatments should improve brood habitat and survivorship. Treatments could also benefit 

pinyon jays by opening up closed-canopy woodlands, while protecting old-growth pinyon-juniper habitat, and should 

ensure that roosting habitat is maintained for bats. 

The Atlas and Henderson units provide habitat for pygmy rabbits. Pygmy rabbits forage primarily on sagebrush, so 

treatments that remove pinyon-juniper and stimulate the growth of sagebrush and herbaceous vegetation would 

benefit pygmy rabbits long-term. Pinyon-juniper encroachment has adversely impacted pygmy rabbit populations 

(Grayson 2006), and has shifted pygmy rabbit habitat to lower elevation in the western U.S. (Larrucea and Brussard 

2008). Although pygmy rabbits would use areas with limited pinyon-juniper cover, stands with 40 percent or greater 

cover provide only marginal habitat for pygmy rabbits (Miller et al. 2005). Treatments to promote development of 

sagebrush, other shrubs, and herbaceous species would benefit pygmy rabbits. 

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WILDLIFE RESOURCES 

Prescribed fire, in addition to manual and mechanical treatments, would be used to enhance habitats. Fire almost 

always reduces pinyon-juniper canopy or density, but is most effective when used in conjunction with mechanical 

treatments, that first reduce juniper competition and increase herbaceous growth that fuels the fire (Ansley and 

Rasmussen 2005). 

The BLM would reduce hazardous fuels on up to 10,000 acres annually on the Cottonwood/Meadow Canyon, Dry 

Canyon, Three Bars Ranch, Tonkin North, and Whistler units. Proposed treatment areas provide important year-round 

habitat for Greater sage-grouse and pronghorn antelope, and crucial summer range for mule deer. In addition to 

reducing hazardous fuels and risk of loss of wildlife and their habitat from a catastrophic wildfire, treatments would 

improve shrub and herbaceous diversity, improve wildlife habitat, and improve hydrologic function. Treatments 

would kill most of the pinyon-juniper overstory and set back plant development and succession, and would increase 

forage for wildlife. When conditions are favorable for a stand-replacing fire, burning kills most of the pinyon-juniper 

overstory and increases plant diversity and patchiness. While loss of pinyon-juniper can reduce thermal and hiding 

cover for ungulates, an increase in plant species diversity after fire can benefit deer as well as ground-nesting birds 

(Lyon et al. 2000a, b). 

In 2010 and 2011, the BLM mapped pinyon-juniper phases and areas with old-growth trees on the 3 Bars Project 

Area (AECOM 2011a). There are several old-growth pinyon-juniper stands on Roberts Mountains; these stands 

would be left untreated. Protection of old-growth pinyon-juniper favors wildlife species that preferentially use pinyonjuniper old-growth. Old-growth juniper have more cavities than young trees, and offer significant habitat benefit to 

cavity nesting species including red-breasted nuthatch, mountain bluebird, mountain chickadee, and northern flicker 

(Miller et al. 2005). Bushy-tailed woodrat is also common in old-growth pinyon-juniper, where it nests in cavities. 

Sagebrush Treatments

Adverse Effects 

Livestock could be used to remove cheatgrass. Livestock can directly harm wildlife by trampling on animals or their 

nests, and grazing can alter grassland structure, to the detriment of birds and small mammals (Wiens and Dyer 1975). 

Given that grazing would be limited to areas dominated by cheatgrass, which has low habitat value for wildlife, these 

risks to wildlife would be low. 

In several treatment areas, the BLM would plant sagebrush seedlings and reseed with native grasses and forbs to 

encourage establishment of sagebrush and herbaceous vegetation near historic leks (Rocky Hills Unit), and to restore 

areas degraded by cheatgrass (West Simpson Park Unit, and Table Mountain Unit). The BLM would use native seeds 

and plants whenever possible, but could also use non-native grasses such as crested wheatgrass and forage kochia. 

Crested wheatgrass and forage kochia have limited value for most wildlife, including Greater sage-grouse. However, 

they do provide forage for livestock, wild horses, and other wild ungulates, help to stabilize soils and reduce erosion 

in areas burned by wildfire, and exclude cheatgrass. Non-native seedings would only be used 1) in areas that have 

previously burned and are beyond use of Emergency Stabilization and Rehabilitation techniques, 2) to create green 

strips; and 3) for soil stabilization in low precipitation zones. 

Beneficial Effects 

The 3 Bars Project area provides important habitat for Greater sage-grouse, mule deer, pronghorn antelope, and other 

wildlife. Approximately 98 percent of proposed treatment acres are within pronghorn antelope summer or winter 

3 Bars Project Final EIS 3-318 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

range, 65 percent are within summer or winter range for Greater sage-grouse, and 55 percent are within mule deer 

summer or winter range (see Figures 3-39, 3-41, and 3-42; NDOW 2008b, 2009d, 2012d, e). 

An estimated 50 percent of the original sagebrush habitat in the Great Basin has been lost in the past century, with 

increasing occurrence of wildfire being a major contributor to this loss (Sage- and Columbian Sharp-tailed Grouse 

Technical Committee 2009). Loss and degradation of sagebrush habitat has also occurred on the 3 Bars Project area, 

and proposed treatments would focus on restoring sagebrush habitat. Over 85 percent of the acres treated would occur 

where the BLM has determined that pronghorn antelope habitat is declining, nearly half of the acres treated would 

occur where Greater sage-grouse habitat is declining, and 45 percent of the acres treated would occur where mule deer 

habitat is declining (Figure 3-40).

Pinyon-juniper treatments to enhance sagebrush habitat would benefit sage obligate species, including Greater sagegrouse, sage sparrow, Brewer’s sparrow, sage thrasher, pygmy rabbit, sagebrush vole, pronghorn antelope, and 

sagebrush lizard. Several shrub-steppe birds show population decreases when pinyon-juniper density and total area of 

cover increase. Sage thrasher in particular is very sensitive to pinyon-juniper encroachment into sagebrush, and one 

study found a 90 percent decline in a population with a 6 percent increase in pinyon-juniper cover. Brewer’s sparrow 

and vesper sparrow are also sensitive to pinyon-juniper encroachment (Miller et al. 2005). Removing or thinning 

pinyon-juniper creates openings for raptors to use while hunting. Ferruginous hawks prefer more open country, 

sagebrush, and the periphery of pinyon-juniper and sagebrush. They nest in pinyon-juniper trees (Wildlife Action 

Plan Team 2012). Thus, treatments to create mosaic of pinyon-juniper and sagebrush habitat on the Whistler Unit, and 

to restore sagebrush on the Rocky Hills Unit, should benefit ferruginous hawks by making it easier for hawks to find 

prey, while creating new sagebrush habitat for prey species. 

Removing pinyon-juniper from sagebrush habitat improves fawning habitat for mule deer, and improves browse 

resources (Wasley 2004). It also benefits pronghorn antelope, which preferentially use open, shrub-steppe 

communities (such as sagebrush) rather than stands with scattered trees or woodlands (Tsukamoto 2003, Wasley 

2004). Pinyon-juniper encroachment has also impacted pygmy rabbit populations (Grayson 2006), especially when 

pinyon-juniper cover exceeds 40 percent. Pinyon-juniper removal projects on the Three Corners and Whistler Sage 

units could benefit pygmy rabbits, although treatments would occur in Phase I stands where pinyon-juniper cover is 

less than 40 percent. Because pinyon-juniper can uptake large amounts of water, removal of pinyon-juniper may also 

improve water supply and flow in creeks, which would benefit wildlife. 

Chainsaws would be used to thin and remove pinyon-juniper in Phase I stands that have encroached into sagebrush 

habitat. The effects to wildlife and their habitat from pinyon-juniper removal and thinning in Phase I stands are 

discussed under Pinyon-juniper Treatments. 

Several leks were found on the Rocky Hills Unit before the 1999 Trail Canyon Fire. West Simpson Park, which 

provides mule deer winter range, was also burned by the 1999 Trail Fire and is now dominated by cheatgrass. Table 

Mountain has been burned by several wildfires in the past few decades. It also has cheatgrass, and provides only 

marginal habitat for Greater sage-grouse, although several leks are nearby. Plowing and discing, and prescribed fire, 

could be used to reduce the reproduction of cheatgrass and crested wheatgrass. Treatments that break the firecheatgrass-fire cycle and risk of future wildfire on treated and nearby sagebrush habitat, should improve wildlife 

habitat by increasing the cover of native shrubs, grasses, and forbs that provide better habitat value for wildlife, and 

possibly encourage Greater sage-grouse to again nest in these units. 

3 Bars Project Final EIS 3-319 October 2016 
WILDLIFE RESOURCES 

The BLM may use livestock and pathogens to control cheatgrass and other non-native vegetation, as livestock can 

reduce cheatgrass dominance, while a naturally-occurring pathogens such as Ustilago bullata can cause head smut in 

cheatgrass (Pellant 2002). The BLM may use livestock to remove some cheatgrass before other treatments. These 

treatments would be used to restore degraded rangeland that provides few wildlife benefits. Noxious weeds and other 

invasive non-native vegetation can hinder pygmy rabbit movement and increases a predators’ ability to detect the 

rabbits. Treatments to control noxious weeds and other invasive non-native vegetation at West Simpson Park could 

encourage nearby pygmy rabbits to use this unit. 

3.16.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The types and magnitude of effects for manual, mechanical, and biological control treatments would be similar 

between Alternatives A and B. Because the BLM would not be able to use fire, there would be no harm to or loss of 

wildlife from prescribed fire and wildland fire for resource benefit. The few wildlife that use dense stands of pinyonjuniper would not experience habitat loss under this alternative, and may even see habitat gains as more pinyonjuniper habitat shows Phase II or III characteristics. 

Acres and types of wetland and riparian habitat and miles of streams treated would be similar to Alternative A. 

However, less effort would be spent by the BLM on slowing pinyon-juniper encroachment into sagebrush and 

riparian communities; reducing the amount of Phase II and III pinyon-juniper treated using stand-replacement fires; 

restoring habitat where sagebrush should occur based on ecological site description reference, desired state, or 

management objective; and reducing the acres of priority habitat treated to improve species diversity, especially 

through cheatgrass control. 

Because fire would not be available to reduce hazardous fuel loads, Alternative B may pose a greater long-term risk 

for wildfire due to the accumulation of fuels. The BLM would also be less able to promote more fire resilient and 

diverse habitat on the 3 Bars Project area. 

The inability to use prescribed fire and wildland fire for resource benefit would probably have few short-term adverse 

effects. Long-term, however, mule deer, Greater sage-grouse, migratory birds, and other wildlife would experience 

fewer of the benefits associated both with creating openings in dense pinyon-juniper habitat and with creating a 

mosaic of pinyon-juniper and sagebrush habitat. Prescribed fire to treat non-native vegetation on the West Simpson 

Park Unit also would not be available under this alternative. 

3.16.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would only be able to use manual and classical biological control methods to treat 

vegetation. The BLM has not identified areas where it would use classical biological control, but if nematodes, 

insects, or fungi are used on the 3 Bars Project area, treatments would generally be small in size and effects would be 

localized, or if used on cheatgrass, could cover large areas of habitat that are little used by wildlife. Thus, the effects 

on wildlife from classical biological control would be minor and primarily restricted to those species using vegetation 

treated by these methods. The BLM would not be able to use livestock to remove cheatgrass under Alternative C nor 

to reduce the competitiveness of exotic species such as crested wheatgrass and forage kochia on the Rocky Hills Unit.

Most of the treatments under this alternative would be to thin and remove pinyon-juniper using chainsaws where it is 

encroaching into riparian, aspen, and sagebrush habitats. There would be fewer direct impacts to wildlife from 

treatments under this alternative than the other alternatives, because adverse impacts, such as harm to or death of 

wildlife, and noise and other disturbances, would be much less with manual methods than the other methods. Since 

3 Bars Project Final EIS 3-320 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

fewer acres would be treated, there would be fewer benefits to wildlife under this alternative than under Alternatives 

A and B. Manual treatments would be small in scale and mostly targeted to pinyon-juniper stands. Benefits to special 

status species and migratory birds would primarily be limited to those species that use the pinyon-juniper and 

sagebrush interface, while Greater sage-grouse, pygmy rabbit, and other sagebrush dependent wildlife would see few 

benefits. 

3.16.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to wildlife resources from 3 Bars Project treatments as no treatments would be 

authorized under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to 

promote healthy, diverse stands; thin or remove pinyon-juniper and sagebrush to encourage understory development; 

restore fire as an integral part of the ecosystem; or reduce the risk of a large-scale wildland fire to the benefit of 

wildlife and their habitats. Because no habitat would be restored, Alternative D also poses the greatest threat to special 

status species, including migratory birds, through long-term habitat loss and degradation. Species at greatest risk from 

habitat degradation are Greater sage-grouse, pygmy rabbit, northern goshawk, cavity nesting birds, and migratory 

birds through densification of pinyon-juniper and sagebrush, loss of aspen habitat, and pinyon-juniper encroachment. 

3.16.3.4 Cumulative Effects 

The wildlife CESA is approximately 1,883,729 acres and extends 10 miles beyond the 3 Bars Project area (Figure 3-

1). Approximately 92 percent of the area is administered by the BLM, 6 percent is privately owned, and 2 percent is 

administered by the Forest Service. Past and present actions that have influenced wildlife resources in the 3 Bars 

ecosystem are discussed in Section 3.3.2.3.3.

3.16.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

The BLM would continue ongoing management reviews to ensure proper livestock management and long-term 

success. Modifications will be made through a separate process from the 3 Bars Project. 

The BLM may install small, temporary exclosure fencing to exclude livestock, wild horse, and other wild ungulate

access to riparian and aspen treatment areas. These actions should help to improve water quality in affected streams, 

restore streams to Proper Functioning Condition, and improve riparian habitat to the benefit of amphibians, Greater 

sage-grouse, and other wildlife. 

The BLM would continue to manage livestock to meet Greater sage-grouse habitat objectives. These objectives 

include having suitable sagebrush cover and utilization levels to ensure that adequate habitat would be available for 

Greater sage-grouse during all life stages (see further discussion in Section 3.3.2.3.3; USDOI BLM 2013c).

The BLM would continue to treat noxious weeds and other invasive non-native vegetation in areas with known 

infestations, including areas burned by wildfire or prescribed fire, and in new areas under the Early Detection and 

Rapid Response program. Noxious weeds and other invasive non-native vegetation would typically be found in newly 

burned or disturbed areas, along roads, near mining and energy developments, and in areas where livestock and wild 

horses congregate. These treatments would benefit wildlife and their habitats, except for those few species that use 

cheatgrass and other noxious and invasive species. Cheatgrass is usually most prevalent in areas that have been 

burned by wildfire. 

3 Bars Project Final EIS 3-321 October 2016 
WILDLIFE RESOURCES 

Five herbicides are typically used on the 3 Bars Project area—2,4-D, glyphosate, imazapyr, metsulfuron methyl, and 

picloram. For the 3 Bars Project, it is likely that the BLM would also use imazapic to treat cheatgrass. Based on 

analysis done for the 17-States PEIS, formulations of 2,4-D could have moderate to high risks, while risks from the 

other herbicides to wildlife would have low to negligible risks to wildlife. A detailed analysis of the risks to wildlife 

and their habitat from the use of herbicides is provided in the 17-States PEIS (USDOI BLM 2007b:4-96). 

Recreational use of the 3 Bars Project area would adversely impact wildlife by disturbing animals and possibly from 

fuel or other petroleum product spills from recreation vehicles that could impact drinking water. Wildlife could be 

injured or killed by recreational vehicles, or from illegal hunting. Visitor use of the CESA would result in increased 

risk of a wildland fire due to accidental or intentional ignition of vegetation from a campfire, cigarette, hot vehicle 

muffler, or other human-caused ignition source. Recreational users can spread noxious weeds and other invasive nonnative vegetation that attaches itself to vehicles or to clothing or shoes, and can later cause new noxious weeds and 

other invasive non-native vegetation infestations and degrade wildlife habitat. Garbage and other debris left behind by 

recreational users could be ingested by wildlife and harm or kill animals, or attract ravens and other scavengers. As 

the local population increases, there would be increased hunting pressure on Greater sage-grouse and other wildlife. 

However, there are no studies that have demonstrated that regulated hunting is the cause of the decline of Greater 

sage-grouse in recent time (Connelly et al. 2004). Pine nut harvesting would cause a loss of pine nuts as food for 

wildlife. 

Utility and infrastructure projects could kill, injure, or disturb wildlife, causing habitat loss and fragmentation, and 

possibly altering wildlife migration patterns and movements. Wildlife can strike fences and be injured or killed and be 

killed by vehicles on roads, and powerlines and communication sites may be used as perches by raptors, to the 

detriment of their prey. During a 10-year study of the effects of the Falcon-Gonder transmission line, which is in the 

eastern portion of the 3 Bars Project area, researchers found that counts of common ravens along the transmission 

corridor, and raven-associated disturbances of Greater sage-grouse leks, increased substantially during the 10-year 

period after construction of the transmission line. However, researchers did not find a meaningful impact of the 

transmission line on Greater sage-grouse nest survival (Collopy and Lammers 2005, Nonne et al. 2011).

Several studies have shown that mining and energy development can have a substantial impact on Greater sagegrouse habitat use and breeding success, and because of their large footprints, can fragment habitat (Braun et al. 2002, 

Lyon and Anderson 2003, Hollaran and Anderson 2004, Braun 2006, Great Basin Bird Observatory 2011; also see 

review in USDOI USFWS 2008), although habitat loss and fragmentation can be reduced over time as developments 

are reclaimed. 

Construction and operation of the Mount Hope Project would directly affect wildlife habitat through removal of 

vegetation, primarily in the big sagebrush vegetation community. Approximately 8,318 acres of wildlife habitat 

would be directly removed. Upon completion, approximately 7,656 acres would be reclaimed by revegetating 

disturbed areas with shrubs, forbs, and grasses (USDOI BLM 2012b). The mine project would also cause death and 

injury to wildlife, disturb wildlife, and fragment wildlife habitat. Mule deer, Greater sage-grouse, and other wildlife 

migrations and movements would be impacted by the mine project. Mule deer migrate along routes from Pine 

Valley south around the Roberts Mountains into Kobeh Valley and Diamond Valley and could be affected by the 

Mount Hope Project. 

Core breeding, brood-rearing, and wintering habitat for Greater sage-grouse is within the mine project area. The 

mine project could impact the movement of Greater sage-grouse between Kobeh Valley and Roberts Mountains.

Other impacts to Greater sage-grouse from the mine project include increased raptor or scavenger predation from 

3 Bars Project Final EIS 3-322 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

elevated equipment and power poles; visual encroachment or interruptions created by elevated equipment, power 

poles, vehicular travel and dust; interruption of “bird foot traffic” created by above-ground pipes, extended 

elevated berms, or other linear features that may block passage; noise created by pumps, vehicles, and equipment; 

collision with fences and other structures; and unreclaimed surface disturbance resulting in habitat loss (USDOI

BLM 2012b).

The mine project waste rock stockpile would be constructed over burrows and areas where pygmy rabbits have 

been sighted. In addition, the mine project access road and growth media stockpiles may also cover burrows and 

areas where pygmy rabbits have been sighted. These impacts would be limited to selected burrows and a limited 

number of individuals may be extirpated; these impacts are not expected to result in a population-level effect that 

would affect the potential listing of the species under the Endangered Species Act. The BLM has calculated that 

approximately 475 acres of pygmy rabbit habitat would be disturbed by the mine project. Of those 475 acres, 211 

acres are occupied by pygmy rabbits and 264 acres are considered potential pygmy rabbit habitat. 

One commenter during public scoping asked about the potential for reintroduction of Rocky Mountain bighorn sheep 

into the 3 Bars Project area. The NDOW does have plans to reintroduce bighorn sheep into the Cortez Range, which 

is immediately northwest of the 3 Bars Project area. These plans have been met with some resistance from local 

ranching interests, and the plan is currently on hold. There are no plans to reintroduce bighorn sheep on Roberts 

Mountains, as permittees are authorized to graze sheep on the mountain. Should sheep permits be retired or changed 

to cattle permits in the future, it is possible that NDOW could reintroduce bighorn sheep on Roberts Mountains (Foree 

2012). 

It is estimated that approximately 140,000 acres would be burned by wildfires over the next 20 years, and in some 

years wildfires may burn substantial acreage, based on acreage burned since 1985 in the CESA. About 75,000 acres 

burned in the 3 Bars Project area, and nearly 56,000 acres within remaining areas of the CESA, in 1999. In addition to 

concerns about how wildland fires may result in establishment and spread of noxious weeds and other invasive nonnative vegetation, such as cheatgrass, there is concern that as wildland fire intervals increase, the likelihood of 

vegetation reaching late successional stages would be reduced, to the detriment of species that favor late successional 

habitat, such as sage thrasher and gray flycatcher (Great Basin Bird Observatory 2010). 

In addition to treatments under the proposed action, the BLM also proposes to treat hazardous fuels on approximately 

1,500 acres annually in high to very high fire risk areas on and near the 3 Bars Project area and within the CESA. 

These include treatments of pinyon-juniper and sagebrush using prescribed fire and manual and mechanical methods, 

to remove pinyon-juniper, enhance wildlife habitat, and create fuel breaks. In addition to improving wildlife habitat 

by creating a mosaic of habitats and opening up pinyon-juniper stands to promote development of shrubs, grasses, and 

forbs to the benefit of Greater sage-grouse and other wildlife, these treatments would also reduce the risk of wildfire 

and loss of wildlife habitat. 

Under Alternative A, adverse effects from treatments would generally be short-term, while benefits would be longterm and would accumulate with wildlife habitat effects that occur on other portions of the CESA. Proposed BLM 

restoration projects would have short-term adverse and long-term beneficial effects on about 142,000 acres of wildlife 

habitat within the CESA during the life of the project. About 17 percent of the 3 Bars Project Area and 8 percent of 

the CESA would be treated to reduce hazardous fuels and improve ecosystem health and resiliency. Habitat 

improvement and a reduction in wildfire risk on the CESA would benefit wildlife and help offset some of the adverse 

effects to wildlife from other reasonably foreseeable future actions in the CESA, and would be greatest under 

Alternative A. 

3 Bars Project Final EIS 3-323 October 2016 
WILDLIFE RESOURCES 

3.16.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on wildlife resources 

would be similar to those described under Alternative A. The BLM anticipates treating about half as many acres 

(63,500) on the 3 Bars Project area under Alternative B than under Alternative A. The types and magnitude of adverse 

impacts to wildlife from prescribed fire treatments, including loss of life and injury, loss of habitat, and habitat 

fragmentation, would not occur within the 3 Bars Project area, but could occur on several hundred acres annually 

within other portions of the CESA under current and reasonably foreseeable future authorization. Long-term benefits 

from prescribed fire and wildland fire for resource benefit, including improving pinyon-juniper health, stimulating 

aspen suckering, creating a mosaic of habitat, slowing pinyon-juniper encroachment, making vegetation more fire 

resilient, creating openings in pinyon-juniper habitat to promote shrub, forb, and grass development, and reducing the 

risk of catastrophic wildfire, would occur on only a few hundred acres annually under this alternative, under previous 

and reasonably foreseeable future authorizations, and would provide few benefits for wildlife. 

Adverse and beneficial effects of 3 Bars Project treatments on wildlife resources would accumulate with those from 

other actions in the CESA. About 8 percent of the 3 Bars Project Area and 4 percent of the CESA would be treated to 

reduce hazardous fuels and improve ecosystem health and resiliency. The trend toward large-sized wildfires of 

moderate to high severity in sagebrush and large stand-replacing wildfires in pinyon-juniper should remain near 

current levels. Treatments to reduce this risk on the CESA would benefit wildlife and their habitats, but not to the 

extent as would occur under Alternative A. 

3.16.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on wildlife resources 

would be similar to those described under Alternative A. Because mechanical treatments would not be used, the BLM 

would not be able to use this method to stimulate aspen suckering on about 450 acres. The BLM would be less able to 

reduce the risk of pinyon-juniper encroachment into aspen stands, and thin and remove pinyon-juniper to create and 

enhance fire and fuel breaks to reduce the risk of wildfire destroying aspens. 

There would be no risk of injury or death to wildlife from use of mechcanical equipment. The BLM would have less 

success in opening up pinyon-juniper to promote development of shrubs, grasses and forbs; reducing hazardous fuels; 

removing cheatgrass and other non-native species; creating a mosaic of habitats; creating fire and fuel breaks; 

restoring stream habitat; and reseeding and replanting vegetation to restore wildlife habitat compared to Alternatives 

A and B. The BLM would be able to use mechanical methods on several hundred acres annually for other projects in 

the CESA under Alternative C under current and reasonably foreseeable future authorizations, but the total amount of 

acreage treated using mechanical methods would be about 90 percent less than under Alternative A. 

Under Alternative C, proposed restoration projects would have adverse and beneficial effects to about 47,000 acres of 

wildlife habitat within the CESA during the life of the project. Treatments would primarily restore pinyon-juniper and 

sagebrush habitat through thinnings and removal of pinyon-juniper. Wildfire risk to wildlife and their habitats would 

increase in the CESA. Wildlife species diversity and numbers, and habitat quality, would show little improvement 

under Alternative C, primarily because only about 2 percent of the CESA would be treated to improve wildlife 

habitat, and the BLM would be limited in the types of treatments it could conduct to reduce the risk of wildfire and 

improve wildlife habitat. 

3 Bars Project Final EIS 3-324 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.16.3.4.4 Cumulative Effects under Alternative D (No Action Alternative)

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on wildlife resources 

would be similar to those described under Alternative A. There would be no cumulative effects on wildlife resources 

from 3 Bars Project treatments as no treatments would be authorized under this alternative. The BLM could create fire 

and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds 

and other invasive non-native vegetation using ground-based and aerial application methods of herbicides, especially 

cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildland fire under 

current and reasonably foreseeable future authorized actions, but on a very limited acreage. 

Based on historic treatments in the 3 Bars Project area, only about 1,500 acres would be treated annually in the CESA 

to reduce hazardous fuel levels and improve ecosystem health. Hazardous fuel levels would likely increase, and only a 

limited number of miles of fuel and fire breaks would be constructed under this alternative compared to the action 

alternatives. The BLM would conduct stream bioengineering and riparian habitat enhancements only on a limited 

acreage and these projects would have to be authorized through separate decisions. Thus, stream channels and riparian 

habitat would remain degraded and contribute to water quality concerns. The trend toward large-sized wildfires of 

moderate to high severity in sagebrush and large stand-replacing wildfires in pinyon-juniper would likely increase. 

3.16.3.5 Unavoidable Adverse Effects 

The proposed vegetation treatments could kill or harm wildlife, and cause unavoidable short-term adverse impacts to 

wildlife habitat and wildlife habitat use. The extent of these disturbances would vary by the extent and type of 

treatment. In general, greatest risks would be associated with the use of prescribed fire and wildland fire for resource 

benefit. These effects would be of special concern when they impact BLM Special Status Species, including Greater 

sage-grouse, pygmy rabbit, raptors, and bats. 

3.16.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

All treatments would have short-term adverse impacts to wildlife and their habitats. Treatments that improve habitat 

would provide long-term benefits to wildlife. Treatments that remove hazardous fuels from public lands and reduce 

the risk of a large, catastrophic wildfire would reduce the potential for future death and injury of wildlife and lead to 

improved habitat. Treatments that slow pinyon-juniper encroachment and control populations of noxious weeds and 

other invasive non-native species on public lands would be expected to benefit most wildlife over the long-term by 

aiding in the reestablishment of native vegetation and restoring wildlife habitat to near historical conditions. 

3.16.3.7 Irreversible and Irretrievable Commitment of Resources 

Wildlife habitat lost as a result of treatments would be irretrievable until native plant communities were reestablished, 

usually within several growing seasons. Treatments that improve rangeland and woodland ecosystem health, 

including removal of noxious weeds and other invasive non-native vegetation, slowing of pinyon-juniper 

encroachment, and enhancement of riparian, aspen, and sagebrush habitat, would translate into benefits for wildlife. 

3 Bars Project Final EIS 3-325 October 2016 
WILDLIFE RESOURCES 

3.16.3.8 Significance of the Effects under the Alternatives 

Under all alternatives, there would be a short-term (less than 10 years) loss of habitat due to proposed treatments, in 

particular pinyon-juniper, and cheatgrass and other noxious weeds and other invasive non-native species. However, 

pinyon-juniper is common throughout Nevada and the western U.S., and cheatgrass is an invasive weed with few 

wildlife values. Treatments would improve habitat on much of the 3 Bars Project area and CESA. Thus, there would 

be no significant direct, indirect, or cumulative long-term impacts to the quantity or quality of habitat critical to the 

survival of local populations from 3 Bars Project treatments within the 3 Bars Project area or CESA. 

Under all alternatives, there would be injury or mortality to common wildlife species, primarily from use of 

prescribed fire and wildland fire for resource benefit, and from mechanical treatments. Less mobile species, such as 

amphibians, reptiles, and small mammals, would be most susceptible. Injury or mortality to wildlife would be in 

proportion to acres treated (greatest risk under Alternative A) and treatment methods (least risk under Alternative C). 

BLM Special Status Species, whose populations would be at most risk of not recovering in 5 years, are either mobile, 

could retreat to burrows, or use aquatic habitats to avoid fire and most mechanical treatments. Thus, populations of 

species that could be impacted by treatments should recover within 5 years, or should not suffer losses that would 

affect population viability. Thus, there would be no significant direct, indirect, or cumulative long-term impacts to 

local wildlife populations from 3 Bars Project treatments within the 3 Bars Project area or CESA. 

The yellow-billed cuckoo is listed as threatened, under the Endangered Species Act on the CESA, however, the last 

sighting of yellow-billed cuckoo in or near the project area was in 1976, just outside of the southeast corner of the 

project area boundary. Thus, proposed treatments on the 3 Bars Project area or CESA would not result in the “take” of 

a listed species, or species proposed for listing. 

Under all alternatives, there could be a short-term reduction in the population, habitat, or viability of a species of 

concern or sensitive species. However, these losses would not result in a trend toward endangerment or the need for 

federal listing. Species of greatest concern are the Greater sage-grouse, northern goshawk, pygmy rabbit, and several 

species of bats. Under all alternatives, the BLM would conduct treatments that would restore habitat for these species. 

The BLM would remove pinyon-juniper in Phase II and III stands, potentially to the detriment of bats that roost under 

the bark of these trees. However, pinyon-juniper is common in Nevada, the BLM would protect old-growth pinyonjuniper and conduct most treatments outside the period when bats would be using trees for roosts, and bats use other 

habitats for roosting and breeding in addition to pinyon-juniper. Thus bat populations should not be imperiled from 

treatments in the CESA. The BLM would avoid treatments near pygmy rabbit burrows, where feasible, on the 3 Bars 

Project area. In addition, most of the treatments on the 3 Bars Project area and CESA would benefit the sagebrush 

habitat used by Greater sage-grouse, pygmy rabbit, and other wildlife. The BLM would also improve aspen habitat to 

benefit northern goshawk. Thus, there should be a long-term gain in habitat value to species of concern on the CESA. 

Under all alternatives, there could be a loss of birds, eggs, or nesting habitat critical to birds protected under the 

Migratory Bird Treaty Act, and should this loss occur, it could be significant. As discussed in Appendix C, the BLM 

would conduct nest surveys prior to any surface-disturbing activities that would occur during the avian breeding 

season. If nests are found within the treatment area, or if other evidence of nesting is observed, treatment activities 

may be postponed until after the completion of nesting; a protective buffer 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. The BLM will also avoid raptor and Greater sage-grouse nesting areas. 

However, there is no guarantee that all nests would be found, and it is possible that migratory birds or their nests or 

3 Bars Project Final EIS 3-326 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

young could be impacted by resource and other development in the CESA. The BLM would work with the USFWS 

to minimize or mitigate these losses. 

3.16.4 Mitigation 

Wildlife resources would benefit from mitigation measures identified in Section 3.18.4 (Livestock Grazing 

Mitigation). No mitigation or monitoring measures have been identified specifically for wildlife resources. 

3.17 Wild Horses 

3.17.1 Regulatory Framework 

Management of wild horses and burros on BLM-administrated land is regulated under the Wild Free-Roaming Horses 

and Burros Act of 1971 and the multiple use objectives of the Federal Land Policy and Management Act. There are 

wild horses, but no wild burros, on the 3 Bars Project area. The Act requires that wild horse and burro populations be

managed at levels that allow for the preservation and maintenance of a thriving natural ecological balance. Methods 

used to control wild horse and burro populations primarily involve gathers to remove excess animals, and fertility 

control through injections of immunocontraceptives to reduce population growth rates. The BLM is also guided by 

the Nevada Northeastern Great Basin Resource Advisory Council to promote healthy rangelands through 

implementation of standards and guidelines for maintaining healthy wild horse and burro herds on HMAs (USDOI 

2007b). These include managing wild horses in HMAs based on the capability of the HMA to provide suitable feed, 

water, cover, and living space, and control of population levels to ensure the long-term health of wild horse 

populations. 

3.17.2 Affected Environment 

3.17.2.1 Study Methods and Study Area 

BLM wild horse gather reports, monitoring data, and inventories were used to assess conditions of wild horses and 

their associated HMAs, including overall herd health, population compared to AML, and available water sources. The 

2007 Roberts Mountain Complex Wild Horse Gather Environmental Assessment, the Roberts Mountain Complex 

Final Gather and Removal Report of January 2008, the 2008 Roberts Mountain HMA Genetic Report, the 2008 

Callaghan Complex Wild Horse Gather Environmental Assessment, the Callaghan Complex Gather Report of 

February 2009, and the Callaghan Complex Genetic Report of 2009 provided much of the information for this 

assessment (USDOI BLM 2007h, 2008k, l, 2009g, h). The Wild Horses and Burros Management Handbook H-4700-

1 (USDOI BLM 2010l) was also consulted for information on wild horse management. 

The study area for the assessment of direct and indirect impacts to wild horses includes the HMAs within the 3 Bars 

Project area as shown on Figure 3-43. Herd Management Areas are for long-term management of wild horses and 

are designated “Special Management Areas” on public lands. Establishment of HMAs must take into consideration 

the AML for the herd, the habitat requirements of the animals, and the relationships with other uses of public land. 

The objective of the management of wild horses is to limit the animals’ distribution to Herd Areas, which are areas 

of public lands identified as being habitat used by wild horses at the time of the passage of the Wild Free-Roaming 

Horses and Burros Act (43 CFR § 47000-5[d]). A herd is defined as one or more stallions and his mares and foals. 

3 Bars Project Final EIS 3-327 October 2016 
WILD HORSES 

The CESA area for assessment of cumulative effects includes all of the HMAs that are contained within or partially 

overlap the 3 Bars Project area boundary. 

3.17.2.2 General Herd and Herd Management Area Characteristics 

3

The 3 Bars Project area contains four HMAs—Fish Creek North , Rocky Hills, Roberts Mountain, and Whistler 

Mountain, totaling 246,536 acres. The HMAs are grouped into two different complexes. The Callaghan Complex 

consists of the Rocky Hills HMA and others not overlapped by the project area. The Roberts Mountain Complex 

contains the Roberts Mountain, Whistler Mountain, and Fish Creek North HMAs. Highway 50 divides Fish Creek 

North from Fish Creek South and precludes movement of the wild horses in the northern portion with the portion of 

the HMA south of U.S. Highway 50. As a result, the northern portion of the Fish Creek HMA is managed as a 

Complex with the Roberts Mountain and Whistler Mountain HMAs. Also included in this Complex is the Kobeh 

Valley Herd Area which is not currently designated as an HMA. The Kobeh Valley Herd Area surrounds the Fish 

Creek North HMA and wild horses pass through the Herd Area between the HMAs. 

Limited year-round water sources, coupled with wild horse overpopulation, have resulted in wild horse concentrations 

in portions of the Roberts Mountain and Rocky Hills HMAs. Herd populations frequently exceed the desired AML 

due to inadequate gather frequency. As a result of populations over the AML, and limited forage and water during 

drought years, wild horse body scores declined and emergency gathers were required in portions of the Roberts 

Mountain Complex in 2001 and 2008. Permanent and temporary fences throughout the Rocky Hills and Roberts 

Mountain HMA hinder free-roaming abilities of wild horses in these HMAs. 

Sampling of both the Rocky Hills and the Roberts Mountain Complex for genetic health indicates that the genetic 

variability of wild horses in these herds is high due to the population sizes and mixing between herds. The history of 

these herds is traced back to the early settlers of the area and the saddle horses used for ranch work. Some of the 

horses within the Rocky Hills HMA share traits with those of curly horses introduced into Nevada in the mid-1800s.

The BLM is required to maintain an inventory of wild horses or burros on public lands. Inventories are typically 

conducted using aircraft, and mostly by helicopter. A systematic grid is flown of the HMA using experienced 

observers. A direct count is obtained along with other monitoring data such as wild horse distribution, animal health, 

resource condition, and availability. Inventories are conducted every 2 to 3 years. During years when an inventory is 

not conducted, the Mount Lewis Field Office uses an average rate of increase derived from historical herd growth 

across the District, which is 17.5 to 19 percent annually, although the herd growth can fluctuate from year to year and 

among HMAs. 

 

3

 The Fish Creek HMA exists on both the north and south sides of U.S. Highway 50, and is crossed by two rights-of-way fences. The 

portion of the HMA north of U. S. Highway 50 is referred to as Fish Creek North, though the HMA name has not yet been officially 

changed. 

3 Bars Project Final EIS 3-328 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-43

Wild Horse Herd Management Areas

and Habitat Improvement Areas

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Rocky

Hills

Whistler

Mountain

Roberts

Mountain

Fish

Creek

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Wild Horse Herd

Management Area

Areas Where Habitat

Improvement is Needed

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2010m, 2012g.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
WILD HORSES 

3.17.2.3 Individual HMA Characteristics 

Table 3-46 displays the HMAs that are within the project area, their approximate size, the established AML, and the 

estimated 2013 population following the spring 2013 foaling season. The most recent inventory for the Roberts 

Mountain Complex was completed in November 2012, with Rocky Hills completed in conjunction with the 

4 Callaghan Complex in August 2012 . 

3.17.2.3.1 Rocky Hills HMA 

The Rocky Hills HMA is 50 miles southwest of Carlin, Nevada, in Eureka County. It is approximately 15 miles east 

to west and 13 miles north to south. The elevation ranges from 5,500 to 8,100 feet amsl. In 1999, the Trail Canyon 

Fire burned approximately 50 percent of the Rocky Hills HMA and forced a gather that resulted in the removal of 98 

percent of the wild horse population. Three years later, 74 horses were released into the HMA, most over 9 years of 

age. The most recent gather in this HMA occurred in 2011 as part of the Callaghan and New Pass/Ravenswood 

Complex gather (USDOI BLM 2010n). The Rocky Hills HMA (in conjunction with the Callaghan Complex) has 

been part of a program to reduce population growth through limited removals and the application of fertility control 

since 2008. The objective is to return to these areas every few years to gather wild horses, re-treat the females with 

fertility control and remove only a few animals (primarily young animals), and release most of the population back to 

the range. During the most recent inventory in August 2012, it was noted that the population consisted of 

approximately 7 percent foals, which was markedly lower than untreated populations exhibiting composition of foals 

ranging from 16 to 20 percent. 

TABLE 3-46 

Herd Management Areas 

HMA Acreage Appropriate Management 

Levels

2014 Population 

(estimated)

Rocky Hills 83,997 86-143 130

Fish Creek North1 19,300 6-10 6

Roberts Mountain 99,992 150 443

Whistler Mountain 43,247 14-24 20

1

 The portion of the Fish Creek HMA north of U.S. Highway 50 is shown in the table. The entire HMA, which extends south of U.S. 

Highway 50, exceeds 252,000 acres. 

The Rocky Hills HMA wild horses are large horses and display a variety of colorations including paint, buckskin, 

grulla, appaloosa, roan, and dun. Horses may reach 16 hands (a hand is 4 inches) or taller, and may reflect some draft 

 

4

 Annual average rate of increase used to compute the 2013 estimated population for Roberts Mountain Complex is 19 percent. The 

annual rate of increase used for Rocky Hills for 2013 was 12 percent. Fertility control applications are being used on the Rocky Hills 

HMA to reduce foaling rates. 

3 Bars Project Final EIS 3-330 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

horse traits such as heavy muscling and large bone structure. The wild horses in the Rocky Hills HMA are 

descendants of the saddle horses raised by the Demale Family at the JD Ranch prior to the passage of the Wild FreeRoaming Horses and Burros Act, and may include Morgan, Saddlebred, Quarterhorse, Thoroughbred, Appaloosa, and 

heavier draft breeds. 

Wild horses within the Rocky Hills HMA have generally exhibited good health and body condition, and no issues 

with disease or genetic defects are known. Sex ratios and age structures are expected to be within normal ranges for 

wild horse herds. 

The southern portion of the HMA tends to be under-utilized, with horses congregating in the northeastern portion. 

This is likely due to areas of thick pinyon-juniper cover and fencing that precludes wild horse access to water sources 

and movement in the southern portion of the HMA. Perennial streams, which may not flow year-round within the 

HMA, provide variable amounts of water to wild horses. Other intermittent or ephemeral drainages may provide 

water during periods of spring run-off or during wet years. Many areas in the northern three-quarters of the HMA 

have been identified as lacking or having poor water availability and quality. 

3.17.2.3.2 Fish Creek North HMA 

The Fish Creek HMA is west of Eureka, Nevada. Approximately 92 percent of the HMA is south of U.S. Highway 50 

and is cut off from the north portion by highway rights-of-way fences that preclude wild horse movement. The north 

portion of the Fish Creek HMA, referred to as the Fish Creek North HMA, was once part of the Kobeh Herd Area of 

which portions were designated as a part of the Fish Creek HMA and the Whistler Mountain HMA. The Fish Creek 

North HMA is associated with the Roberts Mountain Complex. The portion south of U.S. Highway 50 is not 

associated with the 3-Bars project and is not discussed further. The Fish Creek North HMA is approximately 6 miles 

from east to west and 5 miles from north to south. The elevation ranges from approximately 6,030 to 7,900 feet amsl. 

The habitat consists of pinyon-juniper, black sagebrush, Wyoming big sagebrush, and sodic bottom vegetation types 

that are not highly productive. Horses from this HMA were last gathered with the Roberts Mountain Complex gather 

in 2008. 

Wild horses make intermittent use of the Fish Creek North HMA, moving through Kobeh Valley and between the 

Roberts Mountain, Whistler Mountain, and Fish Creek North HMAs. Despite fences, wild horses have found places 

to cross into the Roberts Mountain HMA (USDOI BLM 2007h). It is suspected that the Whistler Mountain and Fish 

Creek North herds travel into the Roberts Mountain HMA for water and to seek higher elevations in the summer 

months, and Whistler Mountain and Fish Creek North HMAs during winter months when deeper snow covers higher 

elevations. Due to the proximity of the HMA to the Roberts Mountain and Whistler Mountain HMAs, and 

documented movement of these horses, wild horses most closely resemble the horses within the Roberts Mountain 

HMA. 

3.17.2.3.3 Roberts Mountain HMA 

The Roberts Mountain HMA is 30 miles northwest of Eureka, Nevada, and west of Highway 278. It is approximately 

10 miles east to west and 17 miles north to south. The elevation ranges from 5,500 to 7,500 feet amsl (USDOI BLM 

2008l). In January 2008, a gather was conducted and 308 wild horses were removed, leaving 118 to 123 in the HMA. 

The 2014 population estimate was 443 horses, or about 293 horses above the established AML. 

Perennial streams, which may not flow year-round within the HMA, provide variable amounts of water to wild 

horses. Other intermittent or ephemeral drainages may provide water during periods of spring run-off or during wet 

3 Bars Project Final EIS 3-331 October 2016 
WILD HORSES 

years. Few water sources exist in the southern and southwestern portion of the HMA. Forage in the low elevations 

that provides important winter range is also limited and is in a degraded state. As a result, concentrations of wild 

horses have been documented in portions of the HMA near available water sources, especially when the population 

exceeds the established AML. Additionally, wild horses move into higher elevations and into areas outside of the 

HMA to access water and forage. Wild horses are generally familiar with the location of fences and gates and are able 

to move within and outside of the HMA through gates and around drift fences (USDOI BLM 2007h). A large portion 

of the population exists outside of the HMA where use by wild horses has not been allocated. During the most recent 

inventory in November 2012, 56 percent of the wild horses were observed outside of the HMA boundary. 

Wild horses of the Roberts Mountain HMA are known to have desirable traits. Size of the horses is typically larger 

than other wild horses, averaging 15 hands. Conformation of the animals is very good, with well-muscled shoulders 

and hindquarters typical of working stock ancestry. The wild horses include desirable colors including palomino, 

buckskin, and roan in addition to traditional colors of bay, brown, sorrel, and black. Health and body condition 

scoring of the Roberts Mountain HMA wild horses is typically adequate; however during drought or periods of 

overpopulation, forage in the lower elevation winter range becomes limited in relation to that needed to support a 

healthy population. This has resulted in emergency conditions in the past, specifically during the 2008 winter gather.

3.17.2.3.4 Whistler Mountain HMA 

The Whistler Mountain HMA is 10 miles northwest of Eureka, Nevada, and west of Highway 278. It is approximately 

7 miles from east to west and 16 miles from north to south. The elevation ranges from 5,900 to 8,225 feet amsl. This 

HMA was gathered with the Roberts Mountain Complex in 2008. 

Intermittent and ephemeral channels provide negligible amounts of water, and areas in the central portion of the HMA 

lack or have poor water quality and availability. The western portion of the HMA has been under-utilized by wild 

horses in the past, partially due to lack of water sources. Wild horses commonly move from the Whistler Mountain 

HMA into the Roberts Mountain HMA or Kobeh Valley Herd Area. Lone Mountain Spring and Treasure Well in the 

Kobeh Valley (outside of the Whistler Mountain HMA boundary), are frequently utilized by wild horses from the 

Whistler Mountain and Fish Creek North HMAs. 

No fences separate the Fish Creek North and Whistler Mountain HMAs, and horses move freely between them. 

Despite allotment boundary fences, wild horses have found places to cross into the Roberts Mountain HMA. It is 

suspected that the Whistler Mountain and Fish Creek North herds travel into the Roberts Mountain HMA for water 

and to seek higher elevations in the summer months, and use the lower elevations of Whistler Mountain HMA and 

Kobeh Valley during the winter months (USDOI BLM 2007h).

3.17.2.4 Conflicts among Wild Horses, Livestock, and Wildlife 

Herd Management Areas within the project area overlap with grazing allotments (Table 3-47). The allocation of 

forage vegetation has to be adequate to support livestock, wild horses, and wildlife in a sustainable manner, otherwise 

forage for livestock, wild horses, and wildlife becomes degraded, as has occurred over much of the project area 

(Figure 3-29). Typically, horses are treated very similar to livestock in terms of calculating AUMs, and dietary 

overlap between wild horses and cattle is very similar. Forage vegetation and water resources are also shared with 

wildlife. 

3 Bars Project Final EIS 3-332 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.17.2.5 Population Management and Control 

Wild horses have relatively few natural predators, which allow their population rates to grow at an average rate of 18 

to 25 percent per year (USDOI USGS 2012d). When unchecked, this rate of increase is greater than the rangeland can 

provide for and will begin to negatively affect the health of wild horses as well as wildlife. The Wild Free-Roaming 

Horses and Burros Act requires that wild horse and burro populations be managed at levels that allow for the 

preservation and maintenance of a thriving natural ecological balance. Current methods used to control wild horse 

populations include gathers and removals, adoption, and an immunocontraceptive (fertility control). Additional 

Population Growth Suppressants that could become available in the future include gelding of stallions or spay of a 

select number of mares, or implementation of improved fertility control formulations or methods. Any future gathers 

to implement Population Growth Suppressants would be documented through appropriate NEPA analysis. 

TABLE 3-47 

Allotments within Herd Management Areas 

Herd Management 

Area Allotment Acreages Percent of HMA

Percent of 

Allotment in HMA

Percent of Forage Allotted 

to Wild Horses (estimated)

Rocky Hills Grass Valley 33,321 40 12 11

JD 50,676 60 36 10-17

Fish Creek North Lucky C 19,300 100 17 17

Roberts Mountain

Roberts 

Mountain 63,995 64 39 10

Three Bars 35,997 36 45

Whistler Mountain Lucky C 12,109 28 11 17

Romano 31,138 72 41 8

USDOI BLM (2007h, 2010m).

Several contraceptive methods have been explored since 1990, but most have proven to be ineffective. One method 

that has been effective is the injection of an immunocontraceptive known as Porcine Zona Pelludica, which is injected 

into mares during horse gathers. Porcine Zona Pelludica is a desirable method of fertility control for the following 

reasons (USDOI USGS 2012d):

 effects passively wear off and normal fertility can resume in 3 to 4 years; 

 there is no harm if injected into mares that are already pregnant; 

 research suggests that Porcine Zona Pelludica does not affect ovarian function or hormonal health; 

 life span seems to increase (5 to 10 years) with improved health of treated mares, apparently due to the 

absence of stresses from pregnancy and lactation; and 

 Porcine Zona Pelludica may be 90 percent effective in blocking fertility in mares for up to 3 years. 

3 Bars Project Final EIS 3-333 October 2016 
WILD HORSES 

3.17.3 Environmental Consequences 

3.17.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on information in the AECC and public scoping comments, the following concerns regarding wild horses were 

identified and are discussed in the effects analysis. 

 Competition among wild horses, livestock, and wildlife for forage and water. 

 Poor health scores recorded during horse gathers. 

 Effects of project actions in and around foaling areas during the foaling season. 

 Appropriate development of water sources to help disperse wild horses. 

 The effect wild horses would have on project reclamation areas and the ability to achieve the desired goals. 

 Injury or death of wild horses due to project activities. 

3.17.3.2 Significance Criteria 

Impacts to wild horses would be considered significant if BLM actions resulted in: 

 Loss of habitat, forage, or water that results in adverse effects to the overall health of wild horses for more 

than 3 years after treatments. 

 Interference with the historical distribution and movement patterns of wild horses within the affected HMAs. 

3.17.3.3 Direct and Indirect Effects 

3.17.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Restoration activities could have short-term effects on wild horses by exposing them to treatments that could harm 

their health, interfere with their movements, cause changes in vegetation that could alter the carrying capacity of the 

HMAs, or limit their access to water, which could ultimately affect their genetic health. Long-term, vegetation 

management activities would improve the amount and quality of forage, and potentially increasing the carrying 

capacity of the HMAs. Refer to Appendix C which describes the Standard Operating Procedures that would be 

followed in order to minimize impacts to wild horses during treatment efforts. 

Adverse Effects 

Forage Vegetation 

Most treatment methods would result in a temporary loss of forage for wild horses. Even when vegetation is not 

physically damaged or removed, treated areas may require a minimum of 2 growing seasons of rest before they would 

be available to grazing animals and electric or other temporary fencing may be used to exclude wild horses from 

treatment areas, if necessary. The 2 year closure would be for areas where seeding or planting occurs. During this 

period, horses would have to utilize other portions of the HMA, which could increase competition with livestock and 

3 Bars Project Final EIS 3-334 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

wildlife for forage. Only temporary electric fencing would be used within HMAs to protect treatment areas. No 

barbed wire fencing would be used in HMAs except for small, temporary riparian or aspen exclosures. 

Movement Patterns 

Under the proposed action, the BLM could use small, temporary (usually less than 3 years) exclosure fencing to 

protect treatments in riparian and aspen management units. Temporary fencing generally would not impact wild 

horses if there is reliable water outside of the exclosure or a water gap, and interference with the movement patterns 

of wild horses would be negligible due to the small size of the exclosures. Temporary electric fencing could be used 

to protect treatment areas in sagebrush and pinyon-juniper areas for up to 2 years following treatment. Electric fencing 

may be used during critical times of the year, or year-round if necessary. No barbed wire fence would be constructed, 

except perhaps for small riparian or aspen exclosures. The treatment activities within the HMAs may cause 

disturbance to wild horses, causing them to move to other locations within the HMAs. As a result, there could be 

temporary changes to movement and distribution patterns in the HMA. Normal movement patterns would be expected 

to return once treatment activity is complete. Movement patterns are also influenced by population size, and other 

environmental conditions. 

Beneficial Effects 

With increased abundance of perennial desirable forage species, the overall quality of wild horse habitat would 

increase. Forage resources would be more abundant throughout the year, including during the winter months. Healthy, 

perennial forage species are better able to withstand drought, and would provide more abundant forage during 

drought. It is anticipated that treatments would reduce the risk of wildfire and resultant loss of habitat for wild horses, 

and move riparian vegetation communities closer to their Proper Functioning Condition and Potential Natural 

Community. Improved habitat would result in improved health of wild horses through heavier body weights, larger 

and healthier foals, and increased ability to survive during harsh winters and drought. 

Forage Vegetation 

Treatments that improve the quality and abundance of native forbs and grasses and reduce the cover of noxious weeds 

and other invasive non-native vegetation would benefit wild horses by increasing the acreage available for grazing 

and the quantity and quality of forage. Treatments that reduce the risk of future catastrophic wildfire through fuels 

reduction and construction of fire and fuel breaks would also benefit wild horses, as wildfires would cause the loss of 

forage and could lead to infestations of noxious weeds and other invasive non-native vegetation in burned areas. 

Health 

Treatments that improve habitat quantity and quality for wild horses should result in healthier horses, reduce the need 

for emergency removals, increase movement patterns, and maintain and improve genetic diversity, while preserving 

wild horse historic traits long-term. 

Water Resources 

Riparian treatments of springs and streams should help several streams achieve Proper Functioning Condition in the 

long-term and improve water flows and quality. Reduced stream velocities would improve riparian vegetation health, 

groundwater recharge, and water quality. Streams would be stabilized and more resilient. Removal of pinyon-juniper 

near streams could increase stream flows. Treatments to reduce hazardous fuels, remove noxious weeds and other 

3 Bars Project Final EIS 3-335 October 2016 
WILD HORSES 

non-native vegetation, and restore native, fire resilient vegetation would reduce the risk of wildfire and its adverse 

impacts on water quantity and quality and peak flows. 

3.17.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Under Alternative A, the BLM would make substantial gains in improving forage and water quantity and quality, 

which would help to distribute wild horses more evenly over the 3 Bars Project area, and would improve the health of 

these animals. 

Riparian Treatments 

About 286 acres of riparian treatments would occur within HMAs, with most treatments in the Rocky Hills HMA 

(Table 3-48). Table 3-48 includes acres within the HMA boundaries and does not include acres of treatment outside 

of HMAs. 

TABLE 3-48 

Surface Disturbance by Herd Management Area for Treatment Types 

HMA Name

Management Type (acres) Total

Riparian Aspen Pinyon-juniper Sagebrush

Fish Creek North 0 0 1,359 1 1,360

Roberts Mountain 25 0 18,572 4,352 22,950

Rocky Hills 229 0 5,611 9,175 15,014

Whistler Mountain 32 0 18,879 1,421 20,332

Total 286 0 44,421 14,949 59,656

Adverse Effects 

Manual and mechanical treatments could temporarily reduce the amount of forage on the treatment site, and wild 

horses could experience short-term disturbances associated with mechanical noise and the presence of humans. 

However, since animals could leave the area during treatments, effects would be minor (USDOI BLM 2007c:4-100). 

Noise and other disturbances may require wild horses to find other water sources to avoid treatment activities. This 

could cause an increased use of other water sources and increased competition between other wild horses, livestock, 

and wildlife. These effects are expected to be temporary with normal use patterns resuming once treatments are 

completed. 

Small, temporary exclosure fencing could be used to exclude wild horses from riparian treatment sites, although water 

gaps in the fencing would allow wild horses to access water within portions of the treatment area. The BLM would 

also use exclosure fencing at Denay Pond to prevent wild horses from entering most of this area and allow the site to 

restore naturally. A gap would be provided in the fencing to allow wild horses and livestock to access a small portion 

of the pond. 

Beneficial Effects 

By stabilizing channels, revegetating treatment sites, and creating appropriate access to water sources, the BLM 

would reduce erosion and return riparian systems to a Proper Functioning Condition for the benefit of wild horses. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Through these treatments, water quality, quantity, and duration would be improved within HMAs, with water 

availability improved during times of drought, including at Cadet Spring, which is an important water source for wild 

horses. 

In areas where pinyon-juniper is removed, stream flows could increase due to reduced water uptake by pinyonjuniper; this would be beneficial to wild horses, especially during drought conditions. Downed trees could be cut into 

logs and logs placed into streams, slowing water flow and creating pools for use by wild horses. 

Aspen Treatments 

Treatments are proposed in the Simpson Park Northeast Unit, which is part of the Rocky Hills HMA. However, 

treatment areas have not been identified pending surveys in the unit, and thus treatment acreage is not included in 

Table 3-48. Adverse and beneficial effects from manual and mechanical treatment methods, and from the use of 

small, temporary exclosure fencing would be similar to those discussed under Effects Common to All Alternatives, 

and under Riparian Treatments. 

Pinyon-juniper Treatments 

About half (44,421 acres) of the pinyon-juniper treatment acres would be within HMAs (Table 3-48). Manual and 

mechanical methods and prescribed fire would be used to treat vegetation on all treatment areas within the Roberts 

Mountain, Rocky Hills, and Whistler Mountain HMAs; only manual and mechanical methods would be used within 

the Fish Creek North HMA. 

Adverse Effects 

Manual and mechanical treatments could temporarily reduce the amount of forage on the treatment site, and wild 

horses could experience short-term disturbances associated with mechanical noise and the presence of humans. 

Prescribed fire could reduce the ability of the treatment area to support wild horses by removing native forbs and 

grasses, leading to the spread of noxious weeds and other invasive non-native vegetation and loss of forage (USDOI 

BLM 2007c:4-100). Wild horses are accustomed to migrating in search of food and shelter in response to climatic 

variation and natural disturbances that alter food supplies, however, the amount of area treated annually would 

comprise only a small portion of the HMAs. 

Treatments could result in increased sediment loads into streams. The effects of treatments on water quality, and 

possibly on wild horse use, would be short-term in duration, with water quality returning to pre-disturbance 

conditions within several days or weeks after treatment is completed. 

Beneficial Effects 

Wild horses would benefit from treatments that encourage the growth of the native forbs and grasses. Treatments 

would also help to move the associated ecological sites toward their Potential Natural Community, since most of the 

acreage within the HMAs is early- to mid-seral status. If the forage amount was increased within a given HMA, wild 

horses would likely be better distributed within the HMA (USDOI BLM 2007c:4-101). Treatments could also 

improve winter forage and year-round access to water, and the ability of wild horses to move throughout the HMAs, 

which should result in improved genetic health. 

3 Bars Project Final EIS 3-337 October 2016 
WILD HORSES 

The BLM proposes to remove pinyon-juniper in several drainages on Roberts Mountains that serve as travel corridors 

for Greater sage-grouse. By removing pinyon-juniper in these drainages and encouraging the establishment of grasses 

and forbs, the BLM would also provide forage for wild horses in these areas, and may assist wild horse movements 

between valley and mountain use areas. 

Treatments that remove hazardous fuels and create fire and fuel breaks would also benefit wild horses by opening up 

additional habitat and foraging areas, as well as protecting habitat from future loss by reducing the risk of a largescale catastrophic wildfire. The expected outcome is that a larger number of acres within HMAs would be utilized by 

wild horses, providing improved foraging and travel ways over the current conditions. 

Sagebrush Treatments 

About half of sagebrush treatments would occur within HMAs (Table 3-48). Over 90 percent of sagebrush treatment 

projects within HMAs would occur on the Rocky Hills (Rocky Hills Unit) and Roberts Mountains (Coils Creek, 

Nichols, and Roberts Mountain Pasture units) HMAs. 

Adverse Effects 

The types of adverse effects from manual and mechanical treatment methods would be similar to those discussed 

under Effects Common to All Alternatives, and under Pinyon-juniper Treatments. These include short-term loss of 

forage and effects on wild horses from noise and disturbance. The sagebrush treatment area overlaps with 6 miles of 

perennial streams and 16 springs (Figure 3-22; Table 3-15). Treatments near these streams and springs could impact 

water quality and flows and the BLM may exclude wild horses from portions of streams using small, temporary 

exclosure fencing. 

The BLM would plant sagebrush seedlings and reseed with native grasses and forbs to encourage the establishment of 

sagebrush and herbaceous vegetation that would provide forage for wild horses. The BLM would use native seeds and 

plants whenever possible, but could also use non-native grasses such as crested wheatgrass. Crested wheatgrass 

provides forage for livestock and wild horses, especially during winter (Ogle 2006). However, the BLM could remove 

crested wheatgrass and forage kochia at the Rocky Hills Unit to enhance sagebrush cover, to the potential detriment of 

wild horses. While only up to 50 percent of the unit would be treated, crested wheatgrass provides more forage for 

wild horses than does native vegetation. 

Beneficial Effects 

Encroachment of pinyon-juniper and spread of noxious weeds and other invasive non-native vegetation are also 

factors contributing to the degraded condition of sagebrush habitats. By thinning pinyon-juniper, removing noxious 

weeds and other invasive non-native vegetation, and seeding and planting with native vegetation, perennial forbs and 

grasses would be able to achieve proper abundance, and distribution, and provide greater quantity and quality forage 

vegetation for wild horses. These improvements should help to facilitate wild horse movement and better distribute 

wild horses throughout the HMAs. 

Sagebrush treatments would increase the understory cover of grasses and forbs that provide forage for wild horses. 

Manual and mechanical treatments could result in increased water runoff and erosion, to the possible detriment of 

water quality and aquatic habitat. Long-term, treatments should improve water flows and water quality to the benefit 

of wild horses. Treatments that reduce the risk of future catastrophic wildfire through fuels reduction, including 

removal of noxious weeds and other invasive non-native vegetation, would benefit wild horses. Uncontrolled, high 

3 Bars Project Final EIS 3-338 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

intensity wildfires can damage large tracts of rangeland, reducing its suitability for grazing Treatments that restore 

and maintain fire-adapted ecosystems, such as the appropriate use of mechanical thinning and fire, and creation of 

fuel breaks, would decrease the effects from wildfire to rangeland plant communities and improve ecosystem 

resilience and sustainability. 

3.17.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The types and magnitude of effects for manual, mechanical, and biological control treatments would be similar 

between Alternatives A and B. Because the BLM would not use fire, therefore, there would be none of the adverse 

effects associated with prescribed fire and wildland fire for resource benefit. In particular, prescribed fire would not 

contribute to degradation of wild horse habitat that could result from soil erosion, loss of forage, and spread of 

noxious weeds and other invasive non-native vegetation in burned areas. However, with greater reliance on 

mechanical methods, there may be greater disturbance to wild horses from use of mechanical equipment than would 

occur under Alternative A. 

Acres and types of wetland and riparian habitat treated would be similar to Alternative A, and the BLM could use 

small, temporary exclosure fencing to protect treatment areas. However, fewer acres would be treated to slow pinyonjuniper encroachment into sagebrush and riparian communities, and fewer acres where sagebrush should occur based 

on ecological site description reference, desired state, or management objective would be restored. Thus, there would 

be fewer gains in habitat improvement and forage production outside of riparian zones. 

Because fire would not be available to reduce hazardous fuel loads, Alternative B may pose a greater long-term risk 

for catastrophic wildfire due to the accumulation of fuels. The BLM would be limited in promoting more fire resilient 

and diverse vegetation on the 3 Bars Project area. Prescribed fire would not be used to remove downed wood and 

other hazardous fuels associated with thinning and removal of pinyon-juniper, thus increasing the risk of wildfire in 

pinyon-juniper treatment areas. These effects would not be beneficial to wild horses. 

3.17.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would use manual and classical biological control methods to treat vegetation, and 

would treat about one-fourth as many acres as would occur under Alternative A. The types and magnitude of effects 

for manual treatments would be similar to those for the other alternatives. The consequences of not using fire under 

Alternative C would be the same as those discussed under Alternative B. 

The BLM has not identified areas where it would use classical biological control, but if nematodes, insects, or fungi 

are used on the 3 Bars Project area, treatments would generally be small in size and effects would be localized, or if 

used on cheatgrass, could cover large areas of habitat that are little used by wild horses. Thus, the effects on wild 

horses from biological control would be minor and primarily restricted to those species using vegetation treated by 

these methods. The BLM would not use livestock to remove cheatgrass or reduce competition from crested 

wheatgrass and forage kochia under Alternative C. 

Most of the treatments under this alternative would be to thin and remove pinyon-juniper using chainsaws where it is 

encroaching into riparian, aspen, and sagebrush habitats. Noise and other disturbance would be less with manual 

methods than the other methods. Manual and biological control methods result in less land disturbance than 

mechanical methods and as a result, short-term adverse effects to water quality from soil erosion, and loss of nontarget vegetation, would be least under this alternative. 

3 Bars Project Final EIS 3-339 October 2016 
WILD HORSES 

Without the use of mechanical equipment, the BLM would not conduct stream engineering and restoration, except on 

a limited basis on only a few stream miles. Fewer acres of noxious weeds and other invasive non-native vegetation 

would be controlled and fewer acres of pinyon-juniper thinning and removal would be conducted to promote 

understory development, except on very small areas where this vegetation can be hand pulled or controlled using hand 

tools. Reseeding and replanting of restoration sites would be limited to small areas where shrubs and other vegetation 

would be planted by hand; and fire and fuel breaks to reduce the risk of fire spread would only be created near 

existing roads or aspen stands, or along a few miles of stream. There would be little reduction in the risk of a 

catastrophic wildfire. 

Under Alternative C, the BLM would not substantially improve the native vegetation community nor stop the loss of 

important ecosystem components. Wild horse movements and distribution, and availability and quality of forage and 

water, would be less under this alternative than the other action alternatives. These effects would be most noticeable 

during drought periods, harsh winters, or during periods of overpopulation. Thus, there would be negligible 

improvement in wild horse genetic diversity. 

3.17.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to wild horses from 3 Bars Project treatments as no treatments would be authorized 

under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to promote 

healthy, diverse stands; or restore fire as an integral part of the ecosystem. Without treatments to reduce fuel loading 

or to control cheatgrass establishment and spread, the risk of catastrophic wildfires would continue to increase. Such 

fires could potentially lead to a catastrophic loss of wild horse habitat and create additional opportunities for invasive 

species to invade newly burned areas. The BLM would not conduct stream engineering and riparian habitat 

enhancement, and thus would do little to improve water availability and quality for wild horses. Thus, this alternative 

would do little to return the 3 Bars ecosystem to its Potential Natural Community and improve the genetic health of 

wild horses. 

3.17.3.4 Cumulative Effects 

The CESA for wild horses is approximately 320,579 acres and includes the area encompassed by all of the HMAs 

that are contained within and partially overlap the 3 Bars Project area boundary (Figure 3-1). Approximately 98 

percent of the CESA is administered by the BLM and 2 percent is privately owned. Past and present actions that have 

influenced wild horses in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.17.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Historic overgrazing and other natural- and human-caused factors have contributed to an increase in wildfire 

occurrence and intensity and to a decrease in native plant diversity, specifically in the understory of the sagebrush 

community. This has caused many sagebrush habitats to be far below their Potential Natural Community. These 

actions have led to the decrease of native forage to the detriment of wild horses, livestock, and wildlife. In addition, 

livestock congregation and concentrated use by overpopulations of wild horses near streams, springs, and wetlands, 

have contributed to the degradation of riparian habitat and forage and their ability to function properly. 

The BLM would continue ongoing management reviews to ensure proper livestock management and the long-term 

success of the proposed treatments. Long-term, wild horse management activities would continue which includes wild 

3 Bars Project Final EIS 3-340 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

horse gathers, AML reviews and adjustments, removal of excess animals, and implementation of fertility control and 

other population growth suppressants 

These management methods would help to reduce land disturbance and restore degraded habitats, and discourage 

establishment and expansion of noxious weeds and other invasive non-native vegetation, to the benefit of wild horses. 

The BLM may also install small, temporary exclosure fencing to limit livestock and wild horse access to treatment 

areas, although water gaps may be incorporated into fencing along streams to allow livestock, wild horses, and 

wildlife to access water. These actions should help to improve water quality in affected streams, restore streams to 

Proper Functioning Condition, and improve riparian habitat. 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and may use aerial-based herbicide applications to remove cheatgrass. The BLM would also 

use herbicides and other treatment methods to restore burned areas under the Burned Area Emergency Stabilization 

and Rehabilitation program, under existing authorizations. These treatments would occur on about 1,000 acres 

annually and would improve rangeland health and resiliency, improve forage and water for wild horses, move 

vegetation communities in areas that have been disturbed by past natural and human-caused action toward their 

Potential Natural Communities, and reduce the risk of catastrophic wildfire. 

Five herbicides are typically 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 on the project area in the future. These 

herbicides, along with 13 other herbicides that could be used by the BLM, generally have negligible to low risks to 

wild horses at typical and maximum application rates. A more detailed discussion of the effects of herbicides on wild 

horses is in the 17-States PEIS (USDOI BLM 2007b:4-143). 

Land development, mineral development, and oil, gas, and hydrothermal exploration and development could affect 

about 15,000 acres in the CESA in the reasonably foreseeable future, including about 14,200 acres of disturbance 

associated with the Mount Hope Project, and acreage associated with potential land sales (although it is unlikely that 

all of this land would be developed), materials sites, roads, and rights-of-way for roads, pipelines, and power and 

telephone lines. 

The Mount Hope Project would have an impact on wild horses in the CESA, as discussed in the Mount Hope Project 

EIS (USDOI BLM 2012b:4-438 to 4-443). A perimeter fence would be constructed around the mine site to minimize 

direct impacts to wild horses from mining activities, including collisions with equipment. This fence would directly 

remove approximately 14,200 acres of wild horse habitat. The fenced area includes approximately 13,998 acres of 

designated HMAs, including portions of the Roberts Mountain HMA and the Whistler Mountain HMA. Roberts 

Mountain HMA wild horses would be excluded from about 7,836 acres, while Whistler Mountain HMA wild horses 

would be excluded from about 6,162 acres, as a result of the construction of the boundary fence. Project-related 

surface disturbance could also result in limiting wild horse access to developed and natural water sources in the 

mining area, and direct impacts could occur as a result of vehicular collisions along mine access roads. 

Mine-related activities would result in direct impacts to the movement patterns of wild horses. The perimeter fence 

would exclude wild horses during mine operation and reclamation for approximately 70 years. Construction of the 

fence would result in wild horses moving to other parts of the HMA and potentially increasing the use of forage and 

water resources that may be already limited. 

3 Bars Project Final EIS 3-341 October 2016 
WILD HORSES 

Noise disturbance, human presence, and increased vehicular traffic would be continuous for approximately 44 years 

during the mine project. Sudden loud noises, such as blasts, could cause wild horses to disperse in directions away 

from the sound. This behavior could send wild horses into unfamiliar terrain. Some wild horses may avoid the area 

while others may tolerate the noise and continue foraging and breeding activities in the vicinity of the mine. 

Distribution changes could result in concentrations of wild horses using vegetation resources in certain areas and 

increased utilization levels. For example, increased human disturbance and unavailable land in the Whistler 

Mountain HMA and east portion of the Roberts Mountain HMA could result in the population shifting to the west 

portion of the Roberts Mountain HMA, resulting in larger numbers of wild horses using smaller land areas. As a 

result, upland forage species could be heavily utilized. Some impacts could occur to wild horses during the peak 

foaling season if widespread human activity disturbs the population. As a result, new foals could be orphaned or 

abandoned. 

In addition to the loss of vegetation associated with the Mount Hope Project, of particular concern is the potential 

drawdown of groundwater near the proposed Mount Hope Project. The mine project could have an impact on 

groundwater resources and could result in diminished surface water flows on Roberts Mountains, to the detriment of 

wild horses (USDOI BLM 2012b:3-438 to 3-439). In addition, the mine’s perimeter fence would prohibit wild horse 

access to natural watering sources and forage. 

As part of mitigation for the mine project, staff with the Mount Hope Project worked with the BLM to identify 

alternative water sources. Six locations within the Whistler Mountain and Roberts Mountain HMAs have been 

identified for development as water sources for wild horses and could also be used by wildlife and livestock. These 

sites consist of existing stock wells that are not currently functioning or do not have pumps or troughs and two new 

sources tapped from production wells associated with the Mount Hope Project. These sources would provide water 

where it has not been available previously, or where availability has been limited (USDOI BLM 2012b:3-439). 

These measures would help to offset potential impacts to wild horse movement, distribution, and habitat loss by 

providing additional water sources and improving habitat that has been underused in the past. 

Upon mine closure and reclamation, the perimeter fence would be removed. The reclaimed land should have more 

grass and forb forage and less mature shrub forage than presently occurs. However, there would be no other actions 

taken to provide alternative forage for wild horses during the 70 year development, operation, and reclamation 

period. 

Catastrophic wildfire can burn extensive acreage, particularly during drought conditions when soil and vegetation are 

dry. An estimated 85,000 acres would burn in the CESA during the next 20 years. To reduce this risk, hazardous fuels 

reduction, habitat improvement, and noxious weeds and other invasive non-native vegetation control projects would 

occur on about 66,000 acres within the HMAs, or about 26 percent of HMAs within the CESA (about 3 percent of the 

CESA annually). Treatments include stream channel restoration, removal of encroaching pinyon-juniper, thinning and 

removal of pinyon-juniper to stimulate development of grasses and forbs and reduce tree density, and creation of fire 

and fuel breaks. 

Although the cumulative effects of human disturbance, mining and other development, and wildfire in the CESA 

would impact wild horse forage and water quality and quantity, continued management to improve forage and water 

quantity and quality, livestock adjustments, wild horse gathers, and reduction of hazardous fuels would help offset 

these effects, and improve wild horse habitat quantity and quality. Treatments also would improve the physical and 

genetic health of wild horse populations long-term, and lead to a better distribution of wild horses across the HMAs 

3 Bars Project Final EIS 3-342 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

within the CESA. Long-term benefits from treatments would be greater under this alternative than the other 

alternatives. 

3.17.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on wild horses would be 

similar to those described under Alternative A. Under Alternative B, the BLM anticipates treating about half as many 

acres as under Alternative A. Fewer acres would be treated to reduce wildfire risk and its impacts on wild horse 

forage and water quality, including use of prescribed fire and wildland fire for resource benefit to restore natural fire 

regimes. 

Adverse effects to vegetation within the CESA would generally be the same as described for Alternative A. However, 

by not using fire on the 3 Bars Project area, there would be no risks to vegetation and wild horse forage from fire on 

several thousand acres annually within the CESA. However, long-term benefits that could be derived from prescribed 

fire and wildland fire for resource benefit would not occur under this alternative, including improving pinyon-juniper 

health, creating a mosaic of habitats, slowing pinyon-juniper encroachment, making vegetation more fire resilient, 

creating openings in pinyon-juniper to promote shrub, forb, and grass development, and reducing the risk of 

catastrophic wildfire to benefit wild horse habitat. 

Hazardous fuels reduction and habitat improvement projects and other land uses would occur on about 37,000 acres 

within HMAs, or about 18 percent of HMA acreage within the CESA (1 percent annually). Short-term adverse and 

long-term beneficial effects from 3 Bars Project treatments would accumulate with those outside the project area, but 

not to the same extent as would occur with Alternative A. Restoration treatments would benefit vegetation long-term, 

and should help to offset affects from land-use actions that are detrimental to vegetation. Thus, there would be minor 

short-term adverse effects, and long-term beneficial effects, from 3 Bars Project actions. Although 3 Bars Project 

treatments would improve the physical and genetic health of wild horses and help to better distribute wild horses 

across the 3 Bars Project area, these benefits would be less than for Alternative A, particularly in light of the 

cumulative impacts to wild horse habitat loss that could be realized from implementation of the Mount Hope Project. 

3.17.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on wild horses would be 

similar to those described under Alternative A. Under Alternative C, the BLM would only use manual and classical 

biological control methods to treat vegetation. As a result, the BLM anticipates treating about one-fourth as many 

acres under this alternative than under Alternative A. 

Adverse, short-term effects to vegetation associated with the use of fire and mechanized equipment would not occur 

under Alternative C. The risk of wildfire and its impacts on the water and vegetation used by wild horses would likely 

increase on the 3 Bars Project area under this alternative. The BLM would not be able to use mechanical methods and 

fire to reduce hazardous fuels, create fuel breaks, thin and remove pinyon-juniper to promote more fire resilient 

vegetation, and remove downed wood and slash. 

Under current and future authorizations, fire and mechanized equipment would be used on about 7,500 acres within 

other portions of the HMAs in the CESA to improve habitat, remove hazardous fuels, and reduce the risk of wildfire. 

Thus, restoration treatments would impact about 22,000 acres within HMAs, or about 9 percent of the HMAs in the 

CESA; less than 1 percent of the acreage on the CESA would be affected annually. These treatments would help to 

3 Bars Project Final EIS 3-343 October 2016 
WILD HORSES 

restore plant communities back to their Potential Natural Community and would improve the physical and genetic 

health of wild horses, but not to the extent that would occur under Alternatives A and B. 

3.17.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on wild horses would be 

similar to those described under Alternative A. There would be no cumulative effects on wild horses from 3 Bars 

Project treatments as no treatments would be authorized under this alternative. The BLM could create fire and fuel 

breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and 

other invasive non-native vegetation using ground-based and aerial application methods of herbicides, especially 

cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildfire under current 

and reasonably foreseeable future authorized actions, but on a very limited acreage. 

Based on historic treatments in the 3 Bars Project area, only about 1,500 acres would be treated annually in the CESA 

to reduce hazardous fuel levels and improve ecosystem health, and only about a third of these treatments would occur 

in HMAs. Hazardous fuel levels would likely increase, and only a limited number of miles of fuel and fire breaks 

would be constructed under this alternative compared to the action alternatives. The BLM would restore little riparian 

habitat. Thus, water quality would remain degraded and water availability could be limiting, especially during 

droughts, for wild horses. The trend toward large-sized wildfires of moderate to high severity in sagebrush and large 

stand-replacing wildfires in pinyon-juniper would likely increase. There would be few benefits to wild horse habitat, 

and their physical and genetic health, and comprehensive improvement to habitat components or movement patterns 

would not occur in the long-term. 

3.17.3.5 Unavoidable Adverse Effects 

The proposed restoration treatments would disturb wild horses and alter wild horse movements and habitat use, and 

cause the short-term loss of forage used by wild horses. 

3.17.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

The proposed treatments would affect the availability and quality of vegetation and water. These impacts would begin 

to disappear within 1 to 2 growing seasons after treatment. Because only a small percentage of HMAs would be 

treated annually, effects would be isolated, minor, and short-term. 

All treatments that successfully reduce the cover of noxious weeds and other invasive non-native vegetation, thin 

pinyon-juniper to encourage growth of understory vegetation, and restore native vegetation on grazed lands would 

benefit wild horses by increasing the number of acres available for foraging and the quality of forage and resilience of 

vegetation to drought and harsh winters. Horses would also benefit from riparian treatments to increase water flows 

and improve water quality. 

Treatments that reduce the risk of future catastrophic wildfire through fuels reduction would also benefit wild horses. 

Uncontrolled, high intensity wildfires can remove forage from large tracts of rangeland, reducing its suitability for 

wild horses. Treatments that restore and maintain fire-adapted ecosystems through the appropriate use of mechanical 

thinning, fire, and other vegetation treatment methods would decrease the effects of wildfire on rangeland plant 

communities and improve ecosystem resilience and sustainability. 

3 Bars Project Final EIS 3-344 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.17.3.7 Irreversible and Irretrievable Commitment of Resources 

3 Bars Project treatments are not expected to result in an irreversible or irretrievable commitment of resources for 

wild horses. 

3.17.3.8 Significance of the Effects under the Alternatives 

None of the treatments under all alternatives should result in a significant long-term (greater than 5 years) loss of 

critical habitat, forage, or water that results in adverse direct, indirect, or cumulative effects to the overall health of 

wild horses, or interference with the normal distribution and movement patterns of wild horses within the affected 

HMAs. As discussed above, BLM treatments could have short-term effects on resources needed by wild horses, but 

would occur on less than 3 percent of the CESA annually. Small, temporary exclosure fencing associated with this 

and other projects would exclude wild horse access to portions of the CESA, but most of the area that is fenced would 

be the 14,000 acres of sagebrush and other habitat associated with the Mount Hope Project. Under all alternatives 

there would be long-term improvements in forage and water resources from BLM restoration treatments, the BLM 

would continue to provide wild horses access to water in or near riparian zones, and small, temporary exclosure 

fencing would be removed as soon as treatment sites are satisfactorily restored. 

3.17.4 Mitigation 

Wild horses would benefit from mitigation measures identified in Section 3.18.4 (Livestock Grazing Mitigation). No 

mitigation or monitoring measures have been identified specifically for wild horses. 

3.18 Livestock Grazing 

3.18.1 Regulatory Framework 

The 3 Bars Project area is utilized by livestock on 12 grazing allotments administered by the BLM under the Taylor 

Grazing Act of 1934, as amended, the Federal Land Policy Management Act of 1976, as amended by the 

Public Rangelands Improvement Act of 1978 Grazing Regulations, and Public Land Orders. The BLM revised 

their grazing regulations in 1995 in order to ensure that livestock grazing practices are conducted in a manner that 

sustains or improves the ecological health of public rangelands. The revised regulations led to the development of the 

Northeastern Great Basin Area Standards and Guidelines (Standards and Guidelines), which established standards of 

rangeland health and livestock grazing. The intention of the Standards and Guidelines is to create a balance between 

sustainable development and multiple use while progressing towards desired rangeland conditions. The standards 

developed to achieve these conditions are as follows (USDOI 2007b):

Standard 1. Upland Sites: Upland soils exhibit infiltration and permeability rates that are appropriate to soil type, 

climate, and land form. 

Standard 2. Riparian and Wetland Sites: Riparian and wetland areas exhibit a properly functioning condition and 

achieve state water quality criteria. 

Standard 3. Habitat: Habitats exhibit a healthy, productive, and diverse population of native and/or desirable plant 

species, appropriate to the site characteristics, to provide suitable feed, water, cover and living space for 

3 Bars Project Final EIS 3-345 October 2016 
LIVESTOCK GRAZING 

animal species and maintain ecological processes. Habitat conditions meet the life cycle requirements of 

threatened and endangered species. 

Standard 4. Cultural Resources: Land use plans would recognize cultural resources within the context of multiple use. 

Standard 5. Healthy Wild Horse and Burro Populations: Wild horses and burros exhibit characteristics of a healthy, 

productive, and diverse population. Age structure and sex ratios are appropriate to maintain the long-term 

viability of the population as a distinct group. Herd management areas are able to provide suitable feed, 

water, cover and living space for wild horses and burros and maintain historic patterns of habitat use. 

3.18.2 Affected Environment 

3.18.2.1 Study Methods and Study Area 

Allotment acreage, AUMs, and livestock information (number, type, and season of use), were provided by the BLM. 

The study area for assessment of direct and indirect impacts to livestock and rangeland conditions is the 3 Bars 

Project area. The CESA for assessment of cumulative effects includes any allotment or portion of an allotment that 

is within the 3 Bars Project area. 

3.18.2.2 Grazing Allotments 

The 3 Bars Project area is made up of 12 grazing allotments on BLM-administered land (Figure 3-44). Table 3-49

lists the allotments, total acreage, active AUMs, average acres per AUM, type of livestock, and season of use on the 3 

Bars Project area. One AUM is the amount of forage required by an animal unit (AU) for 1 month, or the tenure of 

one AU for a 1-month period. If one AU grazes on an area of rangeland for 6 months, that tenure is equal to 6 AUs 

for 1 month or 6 AUMs. In general, the number of animal units, multiplied by the number of months they are on 

the range, equals the number of AUMs used (Ruyle and Ogden 1993). An AU is a standardized unit of measurement 

for range livestock that is equivalent to one mature cow and a calf up to 6 months, one horse, five sheep, or five 

goats, all over 6 months of age. 

3.18.2.3 Grazing Management Systems 

Grazing management systems determine how long livestock are allowed to graze in a given pasture or area. Improper 

livestock management can lead to the overuse of areas that are more desirable to livestock (near water sources, 

riparian zones, preferred vegetation types, etc.) and cause impacts. The use of various grazing rotation systems can 

achieve a more even use of rangelands and ensure a healthier rangeland with an increased ability to produce quality 

forage. Factors that are typically considered when developing a grazing rotation management system include grazing 

intensity, frequency, season of use, plant vigor and timing of growth, re-growth, seed production, and soil 

susceptibility to compaction. Fencing, salt and mineral supplements and artificial water sources can all be used to 

encourage livestock to utilize different areas or pastures. Table 3-50 presents the management system for each 

grazing allotment within the project area. A description of grazing management systems follows (Wyman et al. 2006). 

Rotation System - Scheduled movement of grazing animals from one pasture to another. 

Rest-rotation System - Any grazing system that provides for the rotation of rest among pastures. The period of rest 

can be for a full year or more, or a portion of the growing season. The time and length of rest generally changes each 

successive year. 

3 Bars Project Final EIS 3-346 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-44

Range Use and Treatment Areas

3 Bars Ecosystem and

Landscape Restoration Project

PRIVATE

SHANNON

STATION

WILLOWS

RANCH WILLOWS

RANCH

DRY

CREEK

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

NORTH

DIAMOND

FLYNN/

PARMAN

GRASS JD

VALLEY

ROBERTS

MOUNTAIN

ROMANO

THREE

BARS

SANTA FE/

FERGUSON LUCKY C

DRY

CREEK

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Moderate to Severe

Range Use

Allotment Boundary

3 Bars Project Area

Pinyon-juniper

Treatment Area

Sage Treatment Area

Aspen Treatment Area

Riparian Treatment Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2011g, 2013i.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
LIVESTOCK GRAZING 

3 Bars Project Final EIS 3-348 October 2016 

TABLE 3-49

Grazing Allotments within the 3 Bars Ecosystem

Allotment Name -

Number

3 Bars 

Project1 All Lands2

Total 

Acres

Total 

Acres

Active 

AUMs

Average 

Acres/AUM Livestock Type Season of Use

Three Bars - 00064 76,893 76,893 5,840 13 Cattle and Sheep 3/1-2/28

Dry Creek -10036 24,403 94,580 5,702 26 Cattle and Horse 3/1-1/31

Flynn/Parman - 10039 28,841 28,841 1,357 22 Cattle 3/15-11/30

Grass Valley - 10006 74,469 268,149 17,700 16 Cattle and Horse 1/1-1/31, 3/1-11/30

JD - 10041 140,749 140,740 7,921 12 Cattle 5/1-1/31

Lucky C - 10043 62,082 113,844 3,051 28 Cattle 4/15-2/28

North Diamond - 10034 22,846 76,950 3,579 22 Cattle 5/1-1/31

Roberts Mountain -

10046 164,079 164,079 9,624 16 Cattle and Sheep 1/1-12/31

Romano - 10047 47,829 75,847 2,887 26 Cattle 5/1-12/31

Santa Fe/Ferguson -

10049 76,514 83,480 5,202 16 Cattle and Sheep 3/1-12/1

Shannon Station - 10051 4,173 31,518 2,520 10 Cattle 4/1-2/28

Willows Ranch - 00062 10,678 51,421 3,621 18 Cattle 5/1-1/14

1

 Data reflect only the portion of the allotments on public land and do not include private lands within the 3 Bars Project area. 

2 Includes public and private lands within the 3 Bars Project area, and lands outside the project area. 

TABLE 3-50 

Allotment Grazing Management System and Category 

Allotment Management System Number of 

Pastures

Management 

Category

3 Bars - 00064 Rest Rotation System 5 Improve

Dry Creek -10036 Rotation System 10 Improve

Flynn/Parman - 10039 Rest Rotation System 3 Improve

Grass Valley - 10006 Rotation System 24 Improve

JD - 10041 Rotation System 8 Maintain

Lucky C - 10043 Rotation System 4 Custodial

North Diamond - 10034 Rotation System 7 Custodial

Roberts Mountain - 10046 Rest Rotation System 19 Improve

Romano - 10047 Rotation System 10 Improve

Santa Fe/Ferguson - 10049 Voluntary Rotation System 1 Improve

Shannon Station - 10051 Rest Rotation System 8 Improve

Willow Ranch - 00062 Rest Rotation System 9 Maintain
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Voluntary Rotation System - Movement of grazing animals in which the permittee volunteers to a more 

conservative grazing management approach that is given in the grazing management plan. This approach is 

developed in cooperation with the BLM to provide benefits to the permittee and to resources managed by the 

BLM. 

3.18.2.4 Grazing Management Categories 

In allotments where use areas have not been established, there may not be a requirement for the cattle to move 

through the allotment according to specific dates. It is up to the permittee to voluntarily rotate their cattle through the 

allotment in order to maintain appropriate distribution and utilization rates. Criteria used to assign each of these 

management approaches are as follows: 

Improve - Allotments generally have the potential for increasing resource production or conditions, but are not 

producing at that potential. There may be conflicts or controversy involving resource conditions and uses, but there 

are realistic opportunities to improve resource conditions. 

Maintain - Allotments are in satisfactory resource condition and are producing near their potential under existing 

management strategies. There are little or no known resource use conflicts or controversies. 

Custodial - Allotments usually consist of relatively small acreages or parcels of public land. Acreages often 

intermingled with larger amounts of non-federal lands. There should be no known resource conflicts involving use 

or resource conditions. Typically, opportunities for positive economic returns from public investments are limited 

on these lands. 

3.18.2.5 Range Improvements 

The range improvements constructed within the project area include fencing, corrals, gates, cattle guards, and water 

improvement/supply projects. Table 3-51 summarizes the improvements that occur in the affected allotments within 

the 3 Bars project area. 

3.18.2.6 Allotment Evaluation Status 

Rangeland health studies were conducted on six allotments between December 2010 and September 2011. As 

discussed in Section 3.12.2.3, Seventy KMAs within these allotments were assessed for their ecological status. These 

areas were selected because they met the following criteria: 

 representative of larger areas of interest; 

 contained within a single ecological site and plant community; 

 contain key species; and 

 capable of responding to management action that would be indicative of a response on a larger scale. 

3 Bars Project Final EIS 3-349 October 2016 
LIVESTOCK GRAZING 

TABLE 3-51 

Rangeland Improvements by Allotment 

Allotment Cattle 

Guard

Fencing 

(miles) Corral Gate Spring Man-made Water Supply1

Dry Creek 1 25 4

Flynn/Parman 37

Grass Valley 4 126 1 4 36 8

JD 6 143 4 4 4 4

Lucky C 29

North Diamond 42

Roberts Mountain 2 159

Romano 14

Santa Fe / Ferguson 50 2 3

Shannon Station <1

Three Bars 6 67 13 1

Willows Ranch 21 1

1

 Includes reservoir, stock tank, and troughs. 

The results of these studies were released in the Final 3 Bars Ecosystem and Landscape Restoration Project 

Rangeland Health Report (Eastern Nevada Landscape Coalition and AECOM 2012) and are summarized below. The 

analysis focused on the assessment of individual KMAs within each allotment and the condition of the KMA was 

extrapolated to the area within an allotment for which it represents. Within these KMAs, three parameters were used 

to measure overall rangeland health—production, desired dominant species, and Potential Natural Community for 

grass, forb, and shrub species. This EIS provides an overview assessment of rangeland health in the 3 Bars ecosystem 

as well as a more detailed analysis of six allotments that span the project area from the northern to southern extent. 

Current rangeland conditions are shown in Figure 3-44, and are in part based on this assessment and show that about 

6 percent of the 3 Bars Project area has moderate to severe range use. 

3.18.2.6.1 Flynn/Parman Allotment 

The current grazing decision for the Flynn/Parman/Jiggs allotments was made on September 21, 1993. Approximately 

28,841 acres of the allotment within the 3 Bars Project area are administered by the BLM. Six KMAs were studied 

within this allotment (Table 3-32). FP2 and FJ2 are within burn areas, the remaining four are not. Grass production 

and the desired dominant species were low or absent on five sites. Shrub production was low on five sites and the 

presence of desired dominant species was low or absent on five sites. 

3.18.2.6.2 Roberts Mountain Allotment 

The current grazing decision for the Roberts Mountain Allotment was made on October 20, 1994. Approximately 

164,079 acres of the allotment are within the 3 Bars Project area and administered by the BLM. Sixteen KMAs were 

studied within this allotment (Table 3-33). RM9 and RM108 are within crested wheatgrass seeding areas and RM11 

is within an herbicide treatment area. Grass production and/or Potential Natural Community were low in every KMA. 

3 Bars Project Final EIS 3-350 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.18.2.6.3 JD Allotment 

The current grazing decision for the JD Allotment was made on September 24, 1994. Nineteen KMAs were studied 

within this allotment (Table 3-34). JD2, JD9, JD10, and JD15 are in burned areas. JD4 and JD5 are in the Willow 

Creek and Gabel Canyon seeding areas (1961 and 1964, respectively). The allotment has low grass production and 

lacks desired dominant grass species. Several areas lack desired dominant forb or shrub species. 

3.18.2.6.4 Three Bars Allotment 

The current grazing decision for the Three Bars Allotment was made on October 20, 1994. Approximately 76,893

acres of the allotment are within the 3 Bars Project area and administered by the BLM. Fifteen KMAs were studied 

within this allotment (Table 3-35). Key Management Area TB19 is within the Trail Canyon Fire burn area. The 

allotment has low grass production and desired dominant species are low or absent. Some areas are below the 

Potential Natural Community for forbs and shrubs and lack the desired dominant species. 

3.18.2.6.5 Romano Allotment 

The current grazing decision for the Romano Allotment was made on September 27, 2004. Approximately 50 percent 

of the allotment (47,829 acres) is within the 3 Bars Project area and administered by the BLM. Nine KMAs were 

studied within the project area (Table 3-36). Within this area, four seeding efforts have occurred. KMA RO7 and 

RO4B are within seeding areas. The allotment has low grass production and desired dominant species are low or 

absent. Several areas lack the desired forb species. 

3.18.2.6.6 Lucky C Allotment 

The current grazing decision for the Lucky C Allotment was made on September 27, 2004. Approximately 55 percent 

(62,082 acres) of the allotment is within the 3 Bars Project area and administered by the BLM. Of that portion, 1,078 

acres are private land. Five KMAs were studied (Table 3-37). All are on the portion of the allotment that is within the 

3 Bars Project area and administered by the BLM. Overall, the allotment has low grass production and various KMAs 

were rated low to absent for forb or shrub species. 

3.18.2.6.7 Dry Creek Allotment 

The grazing permit renewal for the Dry Creek Allotment was made on October 10, 2007. Approximately 24,403 acres 

of the allotment are within the 3 Bars Project area and administered by the BLM. Upland vegetation field 

observations indicate that appropriate perennial grass understory is lacking at all elevations. In the lower elevations, 

the perennial grass understory is typically limited to Sandberg’s bluegrass. 

3.18.2.6.8 Grass Valley Allotment 

The current grazing decision for the Grass Valley Allotment was made on June 21, 2002. Approximately 74,469 acres 

of the allotment is within the 3 Bars Project area and administered by the BLM. Field surveys conducted in 1998 

indicated that overall production of perennial grasses was below the site potential. Shadscale production was below 

site potential on the majority of sites surveyed. Additionally, Wyoming big sagebrush was experiencing die-off and 

cheatgrass was present to varying degrees in the lower- and mid-elevation ranges. A portion of the Grass Valley 

Allotment burned in the 1999 Trail Canyon Fire and some burn areas are infested with cheatgrass. 

3 Bars Project Final EIS 3-351 October 2016 
LIVESTOCK GRAZING 

3.18.2.6.9 North Diamond Allotment 

The current grazing decision for the North Diamond Allotment was made on January 5, 2000. Approximately 22,846 

acres of the allotment are within the 3 Bars Project area and administered by the BLM. Surveys conducted in 1998 

found that over 80 percent of the desired dominant grass species were below the Potential Natural Communities for 

the site, however, they were present on three of the five sites surveyed. These species included Indian ricegrass, 

needle-and-thread, bluebunch wheatgrass, and basin wildrye. On one area, 100 percent of the antelope bitterbrush was 

mature or decadent and there was no recruitment. Additionally, cheatgrass was prevalent in the lower elevation 

understory. 

3.18.2.6.10 Santa Fe/Ferguson Allotment 

The current grazing decision for the Santa Fe/Ferguson Allotment was implemented by the Shoshone-Eureka RMP on 

November 6, 1987 and the Shoshone-Eureka Rangeland Program Summary in 1988. Approximately 76,514 acres of 

the allotment are within the 3 Bars Project area and administered by the BLM. This allotment has not been evaluated 

by the BLM. 

3.18.2.6.11 Shannon Station Allotment

The current grazing decision for the Shannon Station and Spanish Gulch Allotment was made on January 5, 2000. 

Approximately 4,173 acres of the allotment are within the 3 Bars Project area and administered by the BLM. Surveys 

conducted in 1998 indicated that desired dominant grass species were present at six of nine sites surveyed. These 

species included Indian ricegrass, needle-and-thread, and bluebunch wheatgrass. Cheatgrass comprised approximately 

25 percent of the understory community. 

3.18.2.6.12 Willow Ranch Allotment 

The current grazing decision for the Willow Ranch Allotment was made on May 18, 1994. Approximately 10,678 

acres of the allotment are within the 3 Bars Project area and administered by the BLM. An allotment evaluation hasn’t 

been conducted for the Willow Ranch Allotment since 1994. At that time, it was determined that overgrazing was 

compromising the health of the allotment. The Final Multiple Use Decision that followed the evaluation reduced the 

permitted AUMs by 1,749 to 3,621. 

3.18.3 Environmental Consequences 

3.18.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on information in the AECC and public scoping comments, the following concerns regarding livestock grazing 

and rangeland conditions were identified and are discussed in this impact analysis: 

 Impacts on ranching operations as a result of livestock exclusion areas. 

 Effects of livestock on project reclamation areas and the ability to achieve desired goals. 

3.18.3.2 Significance Criteria 

Impacts to livestock would be considered significant if BLM actions resulted in: 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 Long-term (greater than 10 years) change in forage availability that measurably affects livestock grazing. 

 Long-term (greater than 5 years) change in access to water that measurably affects livestock grazing. 

3.18.3.3 Direct and Indirect Effects 

3.18.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Vegetation management activities could affect livestock by exposing them to treatments that could harm their health, 

interfere with their movements, cause changes in vegetation that could positively or negatively alter the carrying 

capacity of the allotments, or limit their access to water. Alternately, vegetation management activities could improve 

the amount and quality of forage, potentially increasing the carrying capacity of the allotments. 

Adverse Effects 

Forage Vegetation 

Some treatment methods could result in a temporary loss of forage available to livestock. Even when vegetation is not 

physically damaged or removed, treatment areas could require a minimum of 2 growing seasons of rest if they are 

reseeded or replanted before they would be available to livestock (see Section 3.18.4 for mitigation measures related 

to livestock closures). This period could be extended if the project area experiences prolonged drought conditions. 

During this period, ranch operators would have to utilize other portions of the affected allotments. This could have the 

potential to temporarily reduce the number of livestock that an allotment could carry or necessitate providing salt and 

mineral supplements. 

Health 

It is possible that small, temporary exclusion fencing around treatment areas could cause injury to livestock if they run 

into the fence or try to breach the fence. Livestock could be excluded from treatment areas during the treatment to 

reduce risk of harm from prescribed fire and other treatments. 

Movement Patterns

Under the proposed action, the BLM could use small, temporary exclosure fencing to protect treatments in riparian 

and aspen management units. Temporary fencing generally does not harm livestock if there is reliable water outside 

of the exclosure or if gaps are created in the exclosure to allow livestock to access portions of the water source. 

Temporary exclosure fencing could interfere with livestock use of treatment areas and could interfere with the 

movement patterns of livestock. Treatment areas could be closed to livestock for at least 2 growing seasons after 

treatment. 

Water Resources 

Stream treatments would result in short-term water quality degradation from soil erosion and sedimentation of 

streams. Small, temporary exclosure fencing could be used to exclude livestock from riparian treatment areas for at 

least 2 growing seasons to allow treatment areas to stabilize and to encourage growth of native vegetation. The BLM 

would work with the affected permittee(s) to ensure water is available for livestock.

 

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Beneficial Effects 

Forage Vegetation 

Treatments that successfully improve the quality and abundance of native forbs and grasses, and reduce the cover of 

noxious weeds and other invasive non-native vegetation on rangelands, would benefit livestock. In addition, some 

noxious weeds are poisonous to livestock. The success of noxious weeds and other invasive non-native vegetation 

removal would determine the level of benefit of the treatments over the long-term. Treatments that reduce the risk of 

future catastrophic wildfire through fuels reduction and construction of fire and fuel breaks would also benefit 

livestock. Wildfires would result in the loss of forage and could lead to infestations of noxious weeds and other 

invasive non-native vegetation in burned areas. 

Health and Movement Patterns 

Treatments that improve woodland, rangeland, and riparian health, productivity, and functionality would benefit 

livestock. Risks to livestock health and movement from small, temporary exclosure fencing could be reduced by 

removing temporary fencing from treatment areas as soon as areas have stabilized and native vegetation has 

reestablished on the site. 

Water Resources 

The Grass Valley, JD, Lucky C, Roberts Mountain, and Romano allotments could all receive riparian treatments. 

Riparian treatments should help several streams achieve Proper Functioning Condition and improve water flows and 

quality to the benefit of livestock. Removal of pinyon-juniper near streams could increase stream flows. Treatments to 

reduce hazardous fuels, remove noxious weeds and other invasive non-native vegetation, and restore native, fire 

resilient vegetation, would reduce the risk of wildfire and its adverse impacts on forage and water quality and quantity 

to the benefit of livestock. 

3.18.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

The BLM has identified about 3,885 acres of riparian zone treatments. Of these, about 2,731 acres of treatment would 

occur on the Roberts Mountain Allotment, 547 acres on the JD Allotment, and 319 acres on the Grass Valley 

Allotment (Table 3-52). Adverse effects from manual treatments would be similar to those discussed under Effects 

Common to All Alternatives. Use of mechanical treatments could negatively affect plants by compacting soils, 

creating bare ground, and uprooting desirable species, and could temporarily reduce the amount of forage on the 

treatment site. 

Small, temporary exclosure fencing could be used to exclude livestock from riparian treatment sites for a minimum of 

2 growing seasons to allow riparian conditions to stabilize. The BLM would work with the affected permittee(s) to 

ensure water is available for livestock. 

Beneficial Effects 

Beneficial effects from manual treatments and fencing would be similar to those discussed under Effects Common to 

All Alternatives. 

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All treatments would help to improve riparian habitat and forage and drinking water for livestock. Treatments would 

also reduce the risk of future catastrophic wildfire through removal of pinyon-juniper and creation of fire and fuel 

breaks to the benefit of livestock. Because of these actions, it is anticipated that riparian vegetation communities 

would move closer to the Potential Natural Community. 

TABLE 3-52 

Acreage Affected by Treatment Types for each Allotment under Alternative A 

Allotment Name

Treatment Type Total

Riparian Aspen Pinyon-juniper Sagebrush

Acres Acres Acres Acres Acres

Three Bars 0 0 10,909 996 11,905

Dry Creek 0 0 0 0 0

Flynn/Parman 0 0 5,361 1,538 6,899

Grass Valley 319 0 0 7,435 7,754

JD 547 62 10,009 6,091 16,709

Lucky C 4 0 8,624 1,519 10,147

North Diamond 0 0 7,157 0 7,157

Roberts 

Mountain 2,731 77 30,153 9,699 42,660

Romano 32 0 16,394 1,341 17,767

Santa 

Fe/Ferguson 8 8 0 2,680 2,696

Shannon Station 0 0 2,880 16 2,896

Willow Ranch 0 0 0 0 0

Total 3,641 147 91,487 31,315 126,590

In areas where pinyon-juniper is removed, stream flows could increase due to reduced water uptake and capture of 

rainfall by pinyon-juniper. This would be beneficial to livestock, especially during drought conditions. Downed trees 

could be cut into logs and logs placed into streams, slowing water flow and creating pools for use by livestock. 

Stream channel restoration, removal of pinyon-juniper, and removal of noxious weeds and other invasive non-native 

vegetation would allow riparian zones to function as fire breaks, helping to reduce the risk of wildfire to riparian 

zones and loss of forage and degradation of water quality, all of which would benefit livestock. 

Aspen Treatments 

Adverse and beneficial effects from manual and mechanical fire treatment methods, and from the use of small, 

temporary exclosure fencing, would be similar to those discussed under Effects Common to All Alternatives, and 

under Riparian Treatments. Treatments would occur in the JD, Roberts Mountain, and Santa/Fe Ferguson allotments. 

Pinyon-juniper would be removed near aspen stands and nearby roads. These clearings would function as fire breaks, 

helping to reduce the risk of wildfire to aspen and nearby habitats and degradation of water quality and loss of forage 

to the benefit of livestock. 

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Pinyon-juniper Treatments 

Treatments would occur on most allotments, with largest treatment acreages on the Roberts Mountain, Romano, JD, 

and Three Bars allotments (Table 3-52).

Adverse Effects 

Effects from manual and mechanical treatments could be associated with loss of forage and disturbance. About 57 

percent of treatments where the objective is to improve sagebrush habitat by thinning pinyon-juniper, and 37 percent 

of the treatments where the objective is to reduce hazardous fuels, would occur in Phase I stands. For the entire 3 Bars 

Project area, about 40 percent of treatments would be in Phase I stands. These treatments would have minimal impact 

on livestock as there would be little loss of forage that is of value to livestock, and disturbance would be localized. 

The remainder of treatments would occur in Phase II and III stands. Livestock use pinyon-juniper for shelter and 

cover, but generally avoid Phase III stands because of the limited forage and dense cover of pinyon-juniper. Several 

thousand acres could be treated annually in Phase II and III stands, primarily by using prescribed fire. Prescribed fire 

could reduce the suitability of the treatment site to support livestock by removing native forbs and grasses. Fires could 

also lead to the spread of noxious weeds and other invasive non-native vegetation and loss of forage (USDOI BLM 

2007c:4-100). Treatment areas would be closed to livestock for a minimum of 2 growing seasons. Based on past 

monitoring of prescribed fire treatment sites on the 3 Bars Project area, native vegetation should recover within a few 

years and establishment and spread of noxious weeds and other invasive non-native vegetation should be minimal 

(USDOI BLM 2011e, f).

Thirteen miles of perennial stream treatments are associated with pinyon-juniper management projects. Treatments 

could result in increased sediment loads into streams. The effects of treatments on water quality, and possibly on 

livestock use, would be short-term in duration, with water quality returning to pre-disturbance conditions within 

several days or weeks after treatment is completed. 

Beneficial Effects 

Manual and mechanical treatments would improve forage availability and quality for livestock. In pinyon-juniper 

treatment areas, livestock would benefit from the thinning and burning of pinyon-juniper, as these treatments would 

encourage growth of the native forbs and grasses favored by livestock and help to move the associated ecological sites 

toward their Potential Natural Community. 

The BLM proposes to remove pinyon-juniper in several drainages on Roberts Mountains that serve as travel corridors 

for Greater sage-grouse. By removing pinyon-juniper in these drainages and encouraging the establishment of grasses 

and forbs, the BLM would provide forage for livestock in areas once dominated by pinyon-juniper, and may facilitate 

livestock movements between valley and mountain use areas. Removal of pinyon-juniper near streams and springs 

could lead to increased flows and improved water supply for livestock. 

In many cases, prescribed fire would benefit livestock by reducing the cover of shrub and tree species, such as 

pinyon-juniper, which can form dense stands that preclude the establishment of desirable forage species and create 

physical obstructions to forage. The effect of fire on forage would vary by site. Prescribed burning conducted during 

the dormant season, under moist conditions, would be likely to stimulate forage production (e.g., through increasing 

soil temperature and nutrient availability) and favor perennial grasses with greater palatability (USDOI BLM 

2007c:4-96). 

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Treatments that reduce the risk of future catastrophic wildfire through fuels reduction would also benefit livestock. 

Uncontrolled, high intensity wildfires can damage large tracts of rangeland, reducing its suitability for livestock 

grazing. Treatments that restore and maintain fire-adapted ecosystems, such as the appropriate use of mechanical 

thinning and fire, would decrease the effects of wildfire on rangeland plant communities and improve ecosystem 

resilience and sustainability (USDOI BLM 2007c:4-96). Manual and mechanical treatments would also be used to 

create many miles of fire and fuel breaks in all management types to help minimize wildfire effects and limit the 

spread of wildfire. 

Sagebrush Treatments 

About two-thirds of treatments would occur in the Roberts Mountain, Grass Valley, and JD allotments (Table 3-52). 

Sagebrush communities over most of the area are not meeting their Potential Natural Community objectives primarily 

due to an inadequate perennial grass and forb understory. 

The BLM would thin pinyon-juniper in sagebrush communities on the Table Mountain (Roberts Mountain 

Allotment), Three Corners (JD and Roberts Mountain allotments), and Whistler Sage (Romano Allotment) units. 

These treatments would remove encroaching pinyon-juniper and promote sagebrush development. 

The BLM would conduct treatments to remove non-native vegetation, including cheatgrass, crested wheatgrass, and 

forage kochia, using all treatment methods. Rocky Hills Unit treatments would be associated with the Grass Valley 

(5,477 acres) and JD (3,698 acres) allotments. Whistler Sage treatments would mostly be associated with the Romano 

Allotment; a few acres would be associated with the Shannon Station Allotment. All but about 5 of the 1,958 acres of 

treatments associated with West Simpson Park would be on the Grass Valley Allotment. 

Adverse Effects 

Effects from manual and mechanical treatments would be associated with loss of forage and disturbance. On the 

Rocky Hills Unit, the BLM would remove crested wheatgrass and forage kochia and re-seed or re-plant the area with 

sagebrush. This would result in the loss of forage for livestock, and may require that the BLM temporarily suspend 

AUMs during the treatment. 

Beneficial Effects 

By thinning pinyon-juniper, and removing non-native vegetation and seeding and planting with native vegetation, 

perennial forbs and grasses would be able to achieve proper abundance, distribution, and diversity and ecological sites 

would begin moving towards their Potential Natural Community. This would improve overall rangeland health and 

provide greater quantity and quality forage vegetation for livestock. 

Approximately 5 miles of perennial stream are associated with riparian management projects that occur within the 

larger sagebrush management area (Lower Henderson 1 and 3 and Lower Vinini Creek units). These treatments 

would improve water availability and quality for livestock; treatments in riparian zones are discussed under Riparian 

Treatments. Another 1.3 miles of perennial stream habitat are associated exclusively with sagebrush management 

projects—Rocky Hills (Coils Creek) and West Simpson Park (unnamed) units. The primary treatment objectives for 

these units are to thin pinyon-juniper to promote understory development, using manual and mechanical methods, and 

to remove non-native vegetation. Manual and mechanical treatments would help to improve water flows and water 

quality to the benefit of livestock. 

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Noxious weeds and other invasive non-native vegetation infestations can greatly reduce the land’s carrying capacity 

for livestock, which tend to avoid noxious weeds and other invasive non-native vegetation that have low palatability 

as a result of defenses such as spines and/or distasteful compounds (e.g., thistles; Olson 1999). Grazing can help to 

manage invasive plants (i.e. cheatgrass), but would have to be used in combination with other methods, such as 

discing and plowing, to control noxious weeds and other invasive non-native vegetation and to return vegetation to a 

more desirable composition. 

In some treatment areas, the BLM would plant sagebrush seedlings and reseed with native grasses and forbs to 

encourage the establishment of sagebrush and herbaceous vegetation that would provide forage for livestock. The 

BLM would use native seeds and plants whenever possible, but could also use non-native plants such as crested 

wheatgrass and forage kochia. Crested wheatgrass provides forage for livestock, especially during winter (Ogle 2006). 

Non-native plantings would be limited to those areas where there is cheatgrass dominance, and where the site could 

be restored in the future with native vegetation. 

Treatments that reduce the risk of future catastrophic wildfire through fuels reduction, including removal of noxious 

weeds and other invasive non-native vegetation, would benefit livestock. Uncontrolled, high intensity wildfires can 

damage large tracts of rangeland, reducing its suitability for grazing. Manual and mechanical treatments would be 

used to create many miles of fire and fuel breaks in all management types to help minimize wildfire effects and limit 

the spread of wildfire. 

3.18.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, the BLM would not be able to use prescribed fire or wildland fire for resource benefit. As a 

result, the BLM anticipates treating about half as many acres under Alternative B as under Alternative A. The types 

and magnitude of effects for manual, mechanical, and biological control treatments would be similar between 

Alternatives A and B. Because the BLM would not be able to use fire, there would be none of the adverse effects 

associated with fire. In particular, there would be no loss of forage, degradation of water quality from soil erosion, and 

spread of noxious weeds and other invasive non-native vegetation in burned areas. By not using fire, permittees 

would likely have more flexibility in managing their herds as treatment areas would generally be smaller. Many 

treatments would take longer to complete, such as those where pinyon-juniper and noxious weeds and other invasive 

non-native species are controlled using mechanical or manual treatments instead of fire, or where stream channel and 

riparian habitat restoration are proposed. 

The BLM would closely coordinate activities with permittees, and permittees may have to adjust their livestock 

stocking levels or pasture use. Because some treatments may take longer to complete, such as those where invasive 

species are controlled using mechanical treatments, the time that permittees would have to adjust their grazing plans 

could be longer than under Alternative A. 

Acres and types of wetland and riparian habitat treated would be similar to Alternative A, and the BLM could use 

small, temporary exclosure fencing to protect treatment areas. However, less effort would be spent by the BLM on 

slowing pinyon-juniper encroachment into sagebrush and riparian communities, reducing the amount of Phase II and 

III pinyon-juniper treated, reducing the amount of habitat restored where sagebrush should occur based on ecological 

site descriptions, desired state, or management objective, and reducing the acres of habitat treated to improve species 

diversity, especially through cheatgrass control. Thus, there would be fewer gains in forage production outside of 

riparian zones, and greater risk of habitat loss from catastrophic wildfire, under this alternative than under Alternative 

A.

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Because fire would not be available to reduce hazardous fuel loads, Alternative B may pose a greater long-term risk 

for wildfire due to the accumulation of fuels. The BLM would not be able to promote more fire resilient and diverse 

habitat on the 3 Bars Project area. 

Under Alternative B, the BLM would improve forage and water quantity and quality and the health and resiliency of 

vegetation. The BLM would also make substantial gains in improving forage and water quantity and quality in 

riparian zones. The BLM would only treat a limited acreage to control noxious weeds and other invasive non-native 

vegetation, and reduce the risk of catastrophic wildfire. Thus, overall benefits to livestock from treatment actions 

would be less under this alternative than under Alternative A. 

3.18.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would only be able to use manual and classical biological control methods to treat 

vegetation. As a result, the BLM anticipates treating about one-fourth the acreage that would be treated under 

Alternative A. The types and magnitude of effects for manual treatments would be similar to those for the other action 

alternatives. The consequences of not using fire under Alternative C would be the same as those discussed under 

Alternative B. 

Under Alternative C, many treatments would take longer to complete, such as those where pinyon-juniper and 

noxious weeds and other invasive non-native species are controlled using manual treatments instead of fire and 

mechanical methods, or where stream channel and riparian habitat restoration are proposed. Thus, the time that 

permittees would have to adjust their grazing plans could be longer than under Alternative A. 

Although fewer acres would be treated under Alternative C than under Alternatives A and B, the BLM would still 

have to closely coordinate activities with permittees and permittees may have to adjust their livestock stocking levels 

or pasture use. The BLM has not identified areas where it would use classical biological control, but if nematodes, 

insects, or fungi are used on the 3 Bars Project area, treatments would generally be small in size and effects would be 

localized, or if used on cheatgrass, could cover large areas of habitat. The BLM would not be able to use livestock to 

remove cheatgrass under Alternative C. 

Most of the treatments under this alternative would be to thin and remove pinyon-juniper using chainsaws where it is 

encroaching into riparian, aspen, and sagebrush habitats. Noise and other disturbance would be less with manual 

methods than the other methods. Because land disturbance would be greater using mechanical methods and fire than it 

would be with manual and classical biological control methods, adverse effects to livestock drinking water quality 

from soil erosion, and loss of non-target vegetation, would be less under this alternative than under Alternatives A and 

B.

By not being able to use mechanical equipment, however, the BLM would also not be able to conduct stream 

engineering and restoration, except on a limited basis on only a few stream miles; control noxious weeds and other 

invasive non-native vegetation, except on very small areas where this vegetation can be hand pulled or controlled 

using hand tools; reseed and replant restoration sites, except for small areas where shrubs and other vegetation would 

be planted by hand; remove vegetation to stimulate production of desirable forbs and grasses; or create fire and fuel 

breaks to reduce the risk of fire spread, except near existing roads or aspen stands, or along a few miles of stream. As 

a result, there would be less improvement in forage and water quantity and quality, and more risk of catastrophic 

wildfire than under the other action alternatives. Overall benefits to livestock from treatment actions would be less 

under this alternative than under Alternatives A and B. By not using fire and mechanical methods, however, 

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LIVESTOCK GRAZING 

permittees would likely have more flexibility in management of their herds as treatment areas would generally be 

smaller under this alternative than under Alternatives A and B. 

3.18.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to livestock from 3 Bars Project treatments as no treatments would be authorized 

under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to promote 

healthy, diverse stands; thin and remove pinyon-juniper to promote growth of forbs and grasses; or restore fire as an 

integral part of the ecosystem. Without treatments to reduce fuel loading or to control cheatgrass establishment and 

spread, the risk of catastrophic wildfires would continue to increase and such fires could potentially lead to a 

catastrophic loss of livestock forage and create additional opportunities for noxious weeds and other invasive nonnative species to invade newly burned areas. The BLM would not conduct stream engineering and riparian habitat 

enhancement, and thus would do little to improve water availability and quality for livestock. Thus, this alternative 

would do little to return the 3 Bars ecosystem to its Potential Natural Community and improve rangeland conditions 

for livestock. 

3.18.3.4 Cumulative Effects 

The CESA for livestock and rangeland management is approximately 1,312,942 acres and includes the area 

encompassed by all of the allotments that are contained within or partially overlap the 3 Bars Project area boundary 

(Figure 3-1)). Approximately 94 percent of the area is administered by the BLM and 6 percent is privately owned. 

Past and present actions that have influenced livestock in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.18.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

According to utilization data, about 6 percent of the 3 Bars Project area is experiencing moderate to severe forage 

utilization (see Section 3.18.2.3). However, about 35 percent of proposed riparian zone treatment areas, 25 percent of 

pinyon-juniper treatment areas, and 48 percent of sagebrush treatment areas are experiencing moderate to severe 

forage utilization. About 1,600 acres within the Simpson Park Northeast Unit are experiencing moderate to severe 

forage utilization, although only about 150 acres would be treated within this unit. In addition, livestock often 

congregate near streams, springs, and wetlands, impacting riparian habitat, forage, and stream channels and their 

ability to function properly. 

The BLM would continue ongoing management reviews to ensure proper livestock management and long-term 

success of the treatments. If changes in the current terms and conditions of the grazing permit are required, they 

would be implemented through a separate process in accordance the grazing regulations. 

The BLM would also continue to conduct wild horse gathers, conduct AML reviews and adjustments, remove excess 

animals and use fertility control, and implement habitat projects. 

The BLM may install small, temporary exclosure fencing to exclude livestock and wild horses from treatment areas, 

although water gaps may be incorporated into fencing along streams to allow access to water. These actions should 

help to improve water quality in affected streams, restore streams to Proper Functioning Condition, and improve 

riparian habitat. 

Land development, mineral development, and oil, gas, and hydrothermal exploration and development could affect 

about 15,000 acres in the CESA in the reasonably foreseeable future, including the Mount Hope Project, and acreage 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

associated with potential land sales (although it is unlikely that all of this land would be developed), materials sites, 

roads, and rights-of-way for roads, pipelines, and power and telephone lines. Disturbance associated with these 

activities could alter livestock behavior and habitat use, and loss of native plant communities in the affected areas 

could reduce forage for livestock and facilitate the establishment and spread of noxious weeds and other invasive nonnative vegetation. 

A total of 32 AUMs in the Romano and Roberts Mountain allotments would be lost in perpetuity as a result of the 

734-acre Mount Hope Project open pit. In addition, 490 AUMs in the Roberts Mountain Allotment, and 291 AUMs in 

the Romano Allotment, would be lost for approximately 70 years as a result of an exclusionary perimeter fence that 

would enclose 14,206 acres of the Mount Hope Project. The loss of AUMs represents 5 percent of the active grazing 

preference in the Roberts Mountain Allotment and 10 percent of the active grazing preference in the Romano 

Allotment. 

As described in the Mount Hope Project EIS, when an area of BLM-administered land is devoted to a single public 

purpose, such as mineral production, AUMs are adjusted to reflect the area withdrawn from multiple uses. These 

AUMs are lost until such time that mining has ceased and reclamation has been successfully completed. At that time, 

the area would be evaluated to determine if the AUMs can be returned (USDOI BLM 2012b:3-421 to 3-422). 

In addition to the loss of access to forage for the Mount Hope Project, mine project activities could result in direct 

impacts to the movement patterns of livestock. Noise disturbance, human presence, and increased vehicular traffic 

would be continuous for approximately 44 years during implementation and execution of the mine project. Sudden 

loud noises, such as blasts, could cause livestock to disperse in directions away from the sound. 

Of particular concern is the potential drawdown of groundwater near the proposed Mount Hope Project and its effects 

on forage, particularly phreatophytes, and on water resources on Roberts Mountains and in the Kobeh Valley. The 

mine project could have a significant impact on groundwater resources and could result in diminished surface water 

flows on Roberts Mountains, to the detriment of livestock grazing (USDOI BLM 2012b:3-423 to 3-424). 

As part of mitigation for the mine project, the mine proponent worked with the BLM to develop alternative water 

sources. Six locations have been identified in coordination with the BLM and would be developed as water sources 

for wild horses and could also be used by wildlife and livestock in areas historically used by wild horses. These sites 

consist of existing stock wells that are not currently functioning or do not have pumps or troughs and two new sources 

tapped from Mount Hope Project production wells. These sources would provide water where it has not been 

available previously or where availability has been limited (USDOI BLM 2012b:3-439). The mine proponent would 

reclaim disturbed areas during and after mining, and remove the fence after reclamation is completed. The reclaimed 

land would have more grass and forb forage and less shrub and pinyon-juniper cover than presently occurs. The BLM 

would also monitor vegetation conditions in areas that could be impacted by lower groundwater levels, and conduct 

seeding, with possible grazing closures, to minimize the loss of forage (USDOI BLM 2012b:3-424). The BLM felt 

that these actions would mitigate impacts from the mine project to less than significant. There would be no actions 

taken to provide alternative forage for livestock during the 70 year development, operation, and reclamation period. 

Although herbicides are not proposed for use as part of the 3 Bars Project, the BLM could use herbicides applied 

aerially and using ground-based methods under existing authorizations. Thus, there could be risks to livestock in the 

CESA from being accidentally sprayed, or ingesting, herbicides that could adversely impact livestock health, although 

only a few hundred acres would be treated annually. Given the amount of acreage treated, noxious weeds and other 

invasive non-native vegetation would continue to spread to the detriment of livestock forage. Five herbicides are 

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LIVESTOCK GRAZING 

typically used on the 3 Bars Project area—2,4-D, glyphosate, imazapyr, metsulfuron methyl, and picloram. The BLM 

may also use imazapic to treat cheatgrass on the project area in the future. These herbicides, along with 12 other 

herbicides that could be used by the BLM, generally have negligible to low risks to livestock at typical and maximum 

application rates. A more detailed discussion of the effects of herbicides on livestock is in the 17-States PEIS (USDOI 

BLM 2007b:4-125). 

Catastrophic wildfire can burn extensive vegetation, particularly during drought conditions when soil and vegetation 

are dry. Treatments should reduce the incidence and severity of wildfires. An estimated 84,000 acres would burn 

within the 3 Bars Project area within the next 20 years, and would result in loss of livestock forage and degradation of 

water quality. 

The BLM would treat about 127,000 acres in the 3 Bars Project area, and an additional 15,000 acres under existing 

and reasonably foreseeable future authorizations, over the next 10 to 15 years within the CESA, or about 11 percent of 

the CESA. Short-term, there would be disturbance to and loss of vegetation, particularly pinyon-juniper, and there 

could be an increase in noxious weeds and other invasive non-native vegetation, from treatments. 

Long-term, these treatments should result in vegetation that is healthier, more fire resilient, abundant, and diverse, and 

similar to the Potential Natural Community. The BLM would conduct stream bioengineering and plantings on about 

31 miles of stream to slow stream flow and create pools and wet meadows, and to improve wetland and riparian 

vegetation and water flows and quality. In addition, the BLM would thin and remove pinyon-juniper and noxious 

weed and other invasive non-native vegetation, and create fire and fuel breaks to reduce the risk of catastrophic 

wildfire and its spread. These beneficial effects would help to offset some of the adverse effects to livestock from 

other reasonably foreseeable future actions in the CESA. 

3.18.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on livestock would be 

similar to those described under Alternative A. Under Alternative B, less effort would be spent by the BLM on 

treatments to reduce wildfire risk and its impacts on livestock forage and water quality, including use of fire to restore 

natural fire regimes, within the 3 Bars Project area. However, by not using fire on the 3 Bars Project area, there would 

be no risks to vegetation from fire on several thousand acres annually within the 3 Bars Project area. However, fire 

could be used on other portions of the CESA outside the 3 Bars Project treatment areas.

Under this alternative, the BLM would be limited to hand pulling, discing, plowing, seeding, and using livestock to 

control noxious weeds and other invasive non-native vegetation on several hundred acres annually on the 3 Bars 

Project area. These methods could result in soil disturbance, but would also give the BLM some control over the types 

and amount of vegetation that are removed. The West Simpson Park Unit is on rugged terrain, and use of mechanical 

equipment to control cheatgrass would be difficult on this unit. 

Hazardous fuels reduction and habitat improvement projects could occur on about 63,000 acres within the 3 Bars 

Project area, and on an additional 15,000 acres within the CESA, or about 6 percent of the CESA. Overall, there 

would be a net beneficial accumulation of effects from BLM treatments long-term that would help to offset adverse 

effects to livestock from other reasonably foreseeable future actions, but not to the same extent as would occur under 

Alternative A. 

3 Bars Project Final EIS 3-362 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.18.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on livestock would be 

similar to those described under Alternative A. Under Alternative C, the BLM would only be able to use manual and 

classical biological control methods to treat vegetation, and would treat only a fourth of the acreage that could be 

treated under Alternative A, within the 3 Bars Project area. However, fire and mechanized equipment would be used 

in other portions of the CESA to improve habitat, remove hazardous fuels, and reduce the risk of wildfire. 

By not being able to use mechanical methods, fire, and livestock to reduce hazardous fuels, create fire and fuel breaks, 

and remove downed wood and slash, the risk of wildfire and its impacts on vegetation and water used by livestock 

would likely increase on the 3 Bars Project area. 

Hazardous fuels reduction and habitat improvement projects would occur on about 32,000 acres within the 3 Bars 

Project area, and on an additional 15,000 acres within the CESA, or about 4 percent of the acreage within the CESA. 

Overall, there would be a net beneficial accumulation of effects from BLM treatments long-term that would help to 

offset adverse effects to livestock from other reasonably foreseeable future actions, but not to the extent as would 

occur under Alternatives A and B. 

3.18.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on livestock would be 

similar to those described under Alternative A. There would be no cumulative effects on livestock from 3 Bars Project 

treatments as no treatments would be authorized under this alternative. The BLM could create fire and fuel breaks; 

thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and other 

invasive non-native vegetation using ground-based and aerial herbicide application methods; restore fire as an integral 

part of the ecosystem; and reduce the risk of a large-scale wildfire under current and reasonably foreseeable future 

authorized actions, but on a limited acreage through existing and subsequent separate decisions. 

Based on historic treatments in the 3 Bars Project area, only about 1,500 acres would be treated annually in the CESA 

to reduce hazardous fuel levels and improve ecosystem health. Hazardous fuel levels would likely increase, and only a 

limited number of miles of fuel and fire breaks would be constructed under this alternative compared to the action 

alternatives. The BLM would conduct stream bioengineering and riparian habitat enhancements on only a limited 

area. Thus, water quality would remain degraded and water availability could be limited, especially during droughts, 

for livestock. The trend toward large-sized wildfires of moderate to high severity in sagebrush and large standreplacing wildfires in pinyon-juniper would likely increase. BLM treatments would help to offset some of the effects 

to livestock from non-3 Bars Project actions, but not to the same extent as would occur under the action alternatives. 

3.18.3.5 Unavoidable Adverse Effects 

The proposed treatments could temporarily affect non-target vegetation that might provide forage, shelter, or other life 

requisites for livestock. 

3.18.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity

The proposed vegetation treatments would affect the availability and palatability of vegetation over the short-term. 

These impacts would begin to disappear within 1 to 2 growing seasons after treatment. 

3 Bars Project Final EIS 3-363 October 2016 
LIVESTOCK GRAZING 

All treatments that successfully reduce the cover of noxious weeds and other invasive non-native vegetation and 

restore native vegetation would benefit livestock by increasing the quality of forage. In addition, treatments would 

remove some noxious weeds (e.g., tansy ragwort, houndstongue, Russian knapweed, and common St. Johnswort) that 

are harmful to livestock. The success of noxious weeds and other invasive non-native vegetation removal, and 

restoration of native habitats, would determine the level of benefit of the treatments over the long-term. 

Treatments that reduce the risk of future catastrophic wildfire through fuels reduction would also benefit livestock. 

Uncontrolled, high intensity wildfires can remove forage from large tracts of rangeland, reducing its suitability for 

livestock in the short-term. Treatments that restore and maintain fire-adapted ecosystems through the appropriate use 

of mechanical thinning, fire, and other vegetation treatment methods would decrease the effects of wildfire on 

rangeland plant communities and improve ecosystem resilience and sustainability (USDOI BLM 2007b:4-249). 

3.18.3.7 Irreversible and Irretrievable Commitment of Resources

Loss in vegetation function and quality from treatments would have a short-term impact on livestock productivity. 

Although some livestock could be displaced from public lands, forage could be found elsewhere, although possibly at 

a higher cost. As rangelands improved, their ability to support livestock use levels at or near current levels should also 

improve. Although this impact would represent an irreversible loss of the individual animal, the impacts to the 

livestock operation and industry would be reversible (USDOI BLM 2007b:4-252). 

3.18.3.8 Significance of the Effects under the Alternatives

None of the 3 Bars Project alternatives should result in significant direct or indirect long-term loss of habitat, forage, 

or water, and these effects would not result in a significant cumulative effect. Treatments would have short-term 

effects on these forage and water resources needed by livestock. However, there would be long-term improvement in 

forage and water resources under all alternatives from the treatments. 

3.18.4 Mitigation

According to utilization data, 33 percent of proposed treatment occur within areas experiencing moderate to severe 

forage utilization. Those areas are discussed in Section 3.18.3. Utilization data were collected on the Flynn Parman, 

Roberts Mountain, JD, Three Bars, Romano, and Lucky C allotments during October to December 2010 and May to 

July 2011, encompassing about 71 percent of the 3 Bars Project area. Data for other allotments, however, were 

collected during the 1990’s and early 2000’s, so current forage utilization may differ from past forage utilization, 

especially for areas that have not been surveyed for several decades. In addition, forage utilization accounts for both 

livestock and wild horse use. 

In order to ensure treatment success and prior to treatment implementation, monitoring would be conducted to 

determine if proper livestock management is in place. If modification to the terms and conditions of a grazing permit 

are required, they would be implemented through a decision process separate from the 3 Bars Project and in 

accordance with the grazing regulations. Additionally, if the BLM determines that wild horses are over AML within 

seeding treatments, AML will be achieved prior to project implementation. Since treatments may be conducted 

several years from now, the BLM would not only use rangeland health data collected to date, but would also evaluate 

rangeland conditions at the time of treatment. 

3 Bars Project Final EIS 3-364 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.18.4.1 Potential Changes to Grazing Permits Prior to Treatment Implementation 

1. The season of use may be modified to avoid hot season grazing (July – September). 

2. The duration of grazing may be shortened to allow the riparian vegetation time to recover. 

3. Average stubble height of at least 4 inches will be maintained for herbaceous riparian vegetation. If 

stubble height limits are reached, the permittee will have 5 days to move livestock to the next pasture in 

the rotation or from the allotment entirely. 

4. Streambank alteration rates would be set to a level appropriate to the particular stream in accordance 

with Guidelines for Establishing Allowable Levels of Streambank Alteration (Cowley 2002). Based on 

the characteristics of the streams and the presence of Lahontan cutthroat trout, the streambank alteration 

rates would range from 10 to 20 percent. If designated streambank alteration rates are reached, the 

permittee will have 5 days to move livestock to the next pasture in the rotation or from the allotment 

entirely. 

5. Utilization of woody species will not exceed 35 percent. If utilization rates are reached, the permittee 

will have 5 days to move livestock to the next pasture in the rotation or from the allotment entirely 

(Wyman et al. 2006). 

6. Existing non-functioning water developments and fences may be required to be repaired if contributing 

to unacceptable use patterns by livestock.

7. Temporary fences may be constructed to exclude grazing within the treatment area for a minimum of 

two growing seasons or until treatment objectives are obtained. Additionally, livestock closure may be 

required for the fenced area(s) or other treatment areas. If a livestock closure is required, it would be 

implemented through a decision process separate from the 3 Bars Project and in accordance with the 

grazing regulations. 

8. The season of use within aspen treatments may be shifted to late season (beginning of September; Jones 

2010). 

9. Utilization of terminal leader browse on aspen branches and suckers will be less than or equal to 20 

percent. If utilization rates are reached, the permittee will have 5 days to move livestock to the next 

pasture in the rotation or from the allotment entirely. 

10. For mountain big sagebrush communities, utilization will not exceed 45 percent on upland herbaceous 

species and 35 percent on upland shrub species. If utilization rates are reached, the permittee will have 5 

days to move livestock to the next pasture in the rotation or from the allotment entirely as outlined in 

Range Management, Principles and Practices (Holechek et al. 1998). 

11. For Wyoming and basin big sagebrush communities, utilization will not exceed 35 percent on upland 

herbaceous species and 35 percent on upland shrub species. If utilization rates are reached, the permittee 

will have 5 days to move livestock to the next pasture in the rotation or from the allotment entirely as 

outlined in Holechek et al. (1998). 

3 Bars Project Final EIS 3-365 October 2016 
LIVESTOCK GRAZING 

12. For black sagebrush communities, utilization will not exceed 45 percent on upland herbaceous species 

and 35 percent on upland shrub species. If utilization rates are reached, the permittee will have 5 days to 

move livestock to the next pasture in the rotation or from the allotment entirely as outlined in Holechek 

et al. (1998). 

3.19 Visual Resources 

3.19.1 Regulatory Framework 

Scenic quality is the measure of the visual appeal of a unit of land. Section 102 (a) of the Federal Land Policy and 

Management Act (1976), states that “...the public lands are to be managed in a manner that will protect the quality of 

scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archeological 

values.” Section 103(c) identifies “scenic values” as one of the resources for which public land should be managed. 

Section 201(a) states that “the Secretary shall prepare and maintain on a continuing basis an inventory of all public 

lands and their resources and other values (including scenic values)...” Section 505(a) requires that “each ROW

[rights-of-way] shall contain terms and conditions which will...minimize damage to the scenic and esthetic values...”

Section 101 (b) of the NEPA requires that measures be taken to ensure that aesthetically pleasing surroundings be 

retained for all Americans. Under the Federal Land Policy and Management Act, the BLM developed a standard 

visual assessment methodology, known as the Visual Resource Management (VRM) system, to inventory and 

manage scenic values on lands under its jurisdiction. Guidelines for applying the VRM system on BLM lands are 

described in the BLM Manual 8400, Visual Resource Management (USDOI BLM 1984b) and BLM Handbook H8410-1 Visual Resource Inventory (USDOI BLM 1986b).

3.19.2 Affected Environment 

Visual resources consist of land, water, vegetation, wildlife, and other natural or built features visible to recreation 

visitors, adjacent landowners, and travelers on public lands. In addition, roads, streams, and trails pass through a 

variety of characteristic landscapes where natural attractions can be seen and where cultural modifications are 

apparent. Of particular importance to visual resources in this region is the visual appeal (health and spatial diversity) 

of streams and ponds, and riparian, wetland, aspen, and sagebrush landscapes. 

3.19.2.1 Study Methods and Study Area 

The assessment of visual resources on the project area was based on a 2011 visual resource inventory (VRI) 

conducted for the Battle Mountain District, including the 3 Bars Project area (OTAK 2011). A follow-up site visit was 

made to the 3 Bars Project area to confirm OTAKS’s (2011) findings. 

The analysis area for the assessment of direct and indirect effects to visual resources is the 3 Bars Project area, 

while the CESA includes the 3 Bars Project area and the BLM visual resource management background distance 

zone (15 miles; Figure 3-1).

3.19.2.2 Visual Resource Inventory and Management 

The characteristic landscape of the project area is contained within a variety of landforms in the central Great Basin of 

the Basin and Range physiographic province. Visual resources within the project area are influenced by topographic, 

3 Bars Project Final EIS 3-366 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

vegetative, geologic, hydrologic, and land use characteristics. The topography ranges from relatively flat terrain and 

low rolling or flat-topped and cone-shaped hills to steep mountain ranges. Vegetation is comprised of grasses, 

greasewood, rabbitbrush, and sagebrush at lower elevations, and trees and shrubs including aspen, mountain 

mahogany, limber pine, and pinyon-juniper at higher elevations. Vegetation patterns affect color, form, line, and 

contrast, which shape the basis for the analysis of visual resources in the project area. Land use in the area is 

predominantly grazing and recreation. There is little surface water in the area except for a few perennial and 

intermittent streams and a few small ponds. The excellent air quality in the region promotes expansive views. The 

success and appeal of recreational activities such as hiking, collecting, photography, wildlife viewing, and picnicking 

are dependent on the settings and scenic views. 

The BLM identifies and evaluates visual resource values through the VRI system (USDOI BLM 1986b). Visual 

resource inventory classes are based on scenic quality, sensitivity level, and distance zone criteria and indicate the 

overall value of landscapes. A VRI was conducted to determine the visual values of the Battle Mountain District, 

including the 3 Bars Project area. The components of a VRI include scenic quality evaluation, sensitivity level 

analysis, visibility, and distance zones. 

For the scenic quality evaluation, lands are rated as Class A (19 points or more), Class B (12 to 18 points), or Class C 

(11 points or less). Lands are rated using seven key factors: landforms, vegetation, water, color, influence of adjacent 

scenery, scarcity and cultural modifications. Approximately 37 percent of the 3 Bars Project area is rated as Class A, 

and includes the mountainous areas of the project area, and 60 percent as Class B (Table 3-53). Figure 3-45

illustrates the scenic quality classifications in the project area. 

The sensitivity level analysis measures public concern for visual resources. Lands are assigned high, medium, or low 

sensitivity levels based on consideration of the following factors: types of users, amount of use, public interest, 

adjacent land uses, special areas, and other factors. Approximately 45 percent of the 3 Bars Project area is rated High, 

and includes much of the southern half of the project area, 30 percent is rated Moderate, and 22 percent is rated Low 

(Table 3-53). Figure 3-46 illustrates the sensitivity levels for the sensitivity level rating units in the project area. 

Distance zones are delineated to subdivide the landscape based on relative visibility from travel routes, use areas, or 

vantage points. The three distance zones include: 

 Foreground-middleground Zone: this is the area visible within 3 to 5 miles of the viewing location. 

 Background Zone: this is the visible area beyond the foreground-middleground zone, but usually within 15 

miles of the viewing location. 

 Seldom Seen Zone: These are areas that are rarely visible within the foreground-middleground or 

background zones. 

Approximately 88 percent of the 3 Bars Project area is visible in the foreground-middleground, and 9 percent is 

seldom seen (Table 3-53; Figure 3-47). Seldom seen areas include much of Roberts Mountains, and portions of West 

Simpson Park and Sulphur Spring Range. 

The scenic quality evaluation, sensitivity level analysis, and delineation of distance zones are combined to develop 

VRI classes (Figure 3-48), which represent the relative value of the visual resources. Classes I and II are the most 

valued, Class III represents a moderate value, and Class IV represents the least value. Approximately 64 percent of 

the 3 Bars Project area is rated Class II and includes most mountainous areas, and the flatter portions of the southern 

3 Bars Project Final EIS 3-367 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-45

Visual Resource Inventory

Scenic Quality Rating

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Visual Resource Inventory

Scenic Quality Rating

Class A

Class B

Not Inventoried

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: OTAK 2011.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-46

Visual Resource Inventory

Sensitivity Level Rating

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Visual Resource Inventory

Sensitivity Level Rating

High

Moderate

Low

Not Inventoried

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: OTAK 2011.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-47

Visual Resource Inventory

Visual Distance Zones

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Visual Resource Inventory

Visual Distance Zones

Foreground-Middleground

Seldom Seen

Not Inventoried

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: OTAK 2011.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-48

Visual Resource Inventory Classes

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Visual Resource Inventory Classes

Class II

Class III

Class IV

Not Inventoried

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: OTAK 2011.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
VISUAL RESOURCES 

TABLE 3-53

Visual Resource Project Area Inventory and Visual Resource Management Classes Summary 

Scenic Quality Evaluation

BLM - Class A BLM - Class B BLM - Class C Not Inventoried Total

279,601

37%1

449,395

60%

190

0%

20,624

3% 749,810

Sensitivity Level Analysis

High Medium Low Not Inventoried Total

337,294

45%

227,753

30%

164,138

22%

20,624

3% 749,810

Distance Zones

ForegroundMiddleground Background Seldom Seen Not Inventoried Total

660,709

88%

0

0%

68,447

9%

20,624

3% 749,810

Visual Resource Inventory Classes

VRI Class I VRI Class II VRI Class III VRI Class IV Not Inventoried Total

0

0%

478,105

64%

78,868

11%

172,213

23%

20,624

3% 749,810

Visual Resource Management Classes

VRM Class I VRM Class II VRM Class III VRM Class IV Not Inventoried Total

30,073

4%

24,331

3%

45,319

6%

650,086

87%

0

0% 749,810

1

 Percent of acres within 3 Bars Project area. 

half of the project area, 11 percent is rated Class III, and 23 percent is rated Class IV; there are no Class I areas on the 

project area (Table 3-53).

Visual resource inventory classes are informational in nature and provide the baseline data for considering visual 

values in the RMP process. Visual resource inventory classes do not establish management direction and are not used 

as a basis for constraining or encouraging surface-disturbing activities. 

The VRM system is used by the BLM to manage visual resources on public land. Visual resource management 

objectives are established in RMPs in conformance with land use allocations (USDOI BLM 1984). These areaspecific objectives provide the standards for planning, designing, and evaluating future management activities. BLM 

policy requires that all BLM land be inventoried for scenic values and be assigned a VRM Class during the land use 

planning process. These VRM classes are part of the land use plan decisions for a particular office and set the 

management standards for visual resources that activity level plans must subsequently meet. 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. Based on this process, the BLM 

designates lands into one of four VRM classes with the following objectives: 

3 Bars Project Final EIS 3-372 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 VRM Class I – The objective of this class is to preserve the existing character of the landscape. This class 

provides for natural ecological changes; however, it does not preclude very limited management activity. The 

level of change to the characteristic landscape should be very low and must not attract attention. 

 VRM Class II – The objective of this class is to retain the existing character of the landscape. The level of 

change to the characteristic landscape should be low. Management activities may be seen, but should not 

attract the attention of the casual observer. Any changes must repeat the basic (design) elements of form, 

line, color, and texture found in the predominant natural features of the characteristic landscape. 

 VRM Class III – The objective of this class is to partially retain the existing character of the landscape. The 

level of change to the characteristic landscape should be moderate. Management activities may attract 

attention, but should not dominate the view of the casual observer. Changes should repeat the basic elements 

found in the predominant natural features of the characteristic landscape. 

 VRM Class IV – The objective of this class is to provide for management activities, which require major 

modification of the existing character of the landscape. The level of change to the characteristic landscape 

can be high. These management activities may dominate the view and be the major focus of viewer attention. 

However, every attempt should be made to minimize the impact of these activities through careful location, 

minimal disturbance, and repeating the basic (design) elements. 

The assignment of VRM classes is based on the management decisions made in the RMP process, which must take 

into consideration the value of visual resources and management priorities for land uses (Figure 3-49). Based on 

these decisions, approximately 4 percent of the 3 Bars Project area is rated VRM Class I, and includes portions of 

Roberts Mountains and Simpson Park Mountains, 3 percent is rated Class II, 6 percent is rated Class III, and 87 

percent is rated Class IV. During the RMP process, inventory class boundaries can be adjusted as necessary to reflect 

resource allocation decisions made in the RMP. 

Table 3-53 summarizes the acreages and percent of the project area categorized into each VRI component, the 

resulting VRI classes, and the VRM classes. 

3.19.3 Environmental Consequences 

3.19.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

The only visual resources scoping comment indicated concern that the current VRM classes in the Shoshone-Eureka 

(USDOI BLM 1986a) may be outdated. The RMP is being updated and this analysis for the 3 Bars Project area is 

based on the VRI conducted by OTAK (2011) for the updated Battle Mountain District RMP. 

3.19.3.2 Significance Criteria 

Impacts to visual resources would be considered significant if BLM actions resulted in the following: 

 Strong visual contrast in the immediate foreground view from a designated recreation site, historic trail, or 

residence in the long-term (greater than 10 years). 

3 Bars Project Final EIS 3-373 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-49

Visual Resource

Management Classes

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Visual Resource

Management Classes

Class I

Class II

Class III

Class IV

3 Bars Project Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012l.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

 Non-compliance with VRM objectives in the long-term (greater than 3 years for VRM objectives Classes I 

and II and greater than 10 years for Classes III and IV). 

3.19.3.3 Direct and Indirect Effects 

3.19.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Vegetation treatment activities have the potential to disturb the surface features of the landscape and impact scenic 

values in the short-term (less than 3 years) and long-term (greater than 10 years). The proposed vegetation treatments 

would affect visual resources if they changed the scenic quality of the landscape, diminished the experience of 

viewers with a high level of concern for scenery, or did not meet agency management objectives. In general, 

treatments would have short-term negative effects and long-term positive effects on visual resources.

Public sensitivity to changes in the landscape character of the area would vary relative to the level of visibility and 

distance from viewer activity, and viewer concern. Distance zones and impacts to viewers are listed in Tables 3-54 to 

3-56, respectively. The BLM’s VRM policy states that the extent of visual impact and compliance with management 

objectives must be evaluated at the project level using the visual contrast rating process. 

A Contrast Rating System, as described in BLM Manual Handbook H- 8431-1, Visual Resource Contrast Rating

(USDOI BLM 1986c), provides a systematic means to evaluate the approved VRM objectives, and to identify 

mitigation measures to minimize adverse visual impacts. The Contrast Rating System is designed to compare the 

respective features of the existing characteristic landscape with a proposed project and to identify those parts that are 

not in conformance. These features include the basic design elements of form, line, color, and texture that characterize 

the landscape. Modifications to a landscape that repeat the natural landscape’s basic elements are said to be in 

harmony with their surroundings, while those that differ may be visually displeasing. The information generated is 

used to determine the amount of visual contrast created and whether the VRM objective for the area would be met, 

and to develop additional mitigation measures necessary to meet the VRM objective. 

This process compares the amount of contrast to the form, line, color, and texture of the characteristic landscape of an 

area as a result of a surface-disturbing activity. The effects of vegetation treatments on the visual quality of the 

landscape would be most notable to travelers, sightseers, and residents situated in the immediate foreground (0.0 to 2 

miles) for the first year to approximately 3 years following treatment. Visual impacts over the short- and long-term 

from vegetative treatments would occur from projects that 1) reduce the scenic quality rating of the treatment site, 2) 

result in degradation of high-sensitivity visual resources, or 3) are not in compliance with BLM management 

objectives. 

Adverse Effects 

In the short-term, removal of vegetation would affect the visual qualities of treatment sites by creating hard-edged 

openings and other vegetation-free areas that provide a noticeable visual contrast to the surrounding areas. In the 

short-term, treatments could create visually distinct areas of discolored vegetation (i.e., areas where treatments have 

killed vegetation), which could contrast markedly from surrounding areas of healthy vegetation. The degree of these 

effects would depend on the amount of area treated, the appearance of the surrounding vegetation and the vegetation 

being removed, the type of treatment method used, and the season of treatment. The greater the area and nearness to 

viewers of the vegetation treatment, the greater the visual impacts are likely to be. The effects of treatments that occur 

over a large portion of the landscape are more likely to be observed by people than the effects of small-scale 

treatments (USDOI BLM 2007c:4-112). 

3 Bars Project Final EIS 3-375 October 2016 
VISUAL RESOURCES 

TABLE 3-54 

Landscape Scenery Impacts

Scenic Quality

Project Visual Contrast

Strong Moderate Weak

Class A High High Moderate

Class B High Moderate Low

Class C Moderate Low Low

TABLE 3-55 

Distance Zones and Project Visibility 

Distances Project

Immediate Foreground 0 – 2 Miles

Foreground-Middleground 2 – 5 Miles

Background 5 – 15 Miles

Seldom Seen Greater Than 15 Miles

TABLE 3-56 

Impacts to Viewers 

Project Visibility

Project Visual Impacts

High Sensitivity Moderate Sensitivity Low Sensitivity

0 – 2 Miles High Moderate Low

2 –5 Miles Moderate Moderate Low

5 – 15 Miles Moderate Low Low

Greater Than 15 Miles 

or Seldom Seen

Low Low Low

Color contrasts caused by vegetation removal would be most apparent in areas dominated by homogenous patterns of 

vegetation and by large plants, such as conifer trees. The visual impacts would be heightened if the treatment also 

prevented the manifestation of seasonal changes in vegetation, such as spring flowers or fall color. The contrast 

between a cleared area and the surrounding vegetation would be less in sagebrush, where low-growing shrubs, and 

browns, grays, and earth tones dominate the landscape than in areas with pinyon-juniper. In addition, the brown colors 

associated with vegetation treatments would be least noticeable during the late fall and the winter, when they would 

blend more naturally with surrounding colors, than in the spring and summer, when the green colors of new growth 

are more likely to be present (USDOI BLM 2007c:4-112). 

There would be negligible to weak short-term visual contrasts to the landscape as a result of manual treatments. 

Treatment limited to small areas (exclosure fencing, removal of small groups of trees) would be much less noticeable 

3 Bars Project Final EIS 3-376 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

than the alterations caused by other treatment methods. In other cases, such as the removal of vegetation with 

chainsaws over many acres, the visual effects would be negative, though minor, and would last until downed trees 

were removed by wood gatherers, pile burned, or concealed through revegetation. 

Beneficial Effects 

Effects to visual resources would begin to disappear within 1 to 2 growing seasons after treatment. The regrowth of 

vegetation on the site would eliminate much of the stark appearance of a cleared area, and the area would develop a 

more natural appearance. 

Impacts would last for the longest amount of time in pinyon-juniper stands where large trees and shrubs are removed. 

Treatments that aim to rehabilitate degraded ecosystems, if successful, would result in plant communities that are 

dominated by native species. Native-dominated communities tend to be more diverse, and thus, more visually 

appealing than plant communities that have been overtaken by the surrounding monoculture (such as pinyon-juniper 

encroaching on riparian zones). Treatments that reduce the risk of wildfire should reduce the visual impacts associated 

with large expanses of burned vegetation. Additionally, the BLM would work to mitigate the edge effect of treatments 

by “feathering” treatments in to adjacent vegetation communities and designing treatments in a mosaic pattern.

3.19.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

The majority of riparian zone treatment areas are rated Class A for their scenic qualities, have High sensitivity to the 

public, and are in the foreground-middleground zone. Approximately 75 percent of treatment areas are VRM Class III 

or IV, where moderate to substantial modification of the landscape is acceptable. The remaining 25 percent of the 

proposed treatment areas includes 9 acres of Roberts Creek, which are VRM Class I, where the objective is to 

preserve the existing character of the site, and 444 acres of VRM Class II at Roberts Creek, Vinini Creek, and Willow 

Creek, where a low level of change in the landscape character is acceptable. The three Class I/II areas are part of the 

Roberts Creek Unit group. 

Adverse Effects 

Riparian zone treatments along Roberts, Vinini, and Willow Creeks would result in a low level of change, and 

portions of these streams that are rated VRM Class I or II may not be treated. For example, the Roberts Creek Unit is 

1,390 acres, but only 9 acres are VRM Class I; 486 acres are Class II, where a low level of change is acceptable. 

Nearly all of the Willow and Upper Willow Creek units are VRM Class II. Stream channel restoration would be 

limited to about 250 acres and a mile or two of stream annually. Use of manual and mechanical treatments to 

reconstruct streams and clear vegetation would be likely to remove large quantities of vegetation from a treatment 

site, leaving dead plant material on the ground to turn brown, and expose much soil. 

Although treatment activities could be seen, they would probably not attract the attention of the casual observer as 

they are in somewhat secluded drainages, and would be conducted to retain or restore the natural character of the 

landscape. 

3 Bars Project Final EIS 3-377 October 2016 
VISUAL RESOURCES 

Beneficial Effects 

Riparian management treatments would focus on restoring streams that have been degraded and on slowing pinyonjuniper encroachment into riparian zones. Mechanical methods would result in strong short-term visual contrasts of 

form, line, color, and texture until the treatment site is revegetated. For all treatment methods, effects to visual 

resources would begin to disappear within 1 to 2 growing seasons after treatment. The regrowth of vegetation on the 

site would eliminate much of the stark appearance of a cleared area, and the area would develop a more natural 

appearance. Non-fire treatments can be used to avoid the visual effects associated with smoke and to integrate treated 

and untreated areas into a more visually appealing mosaic of vegetation types. Effects would last for the longest 

amount of time in woodlands and other areas where large trees and shrubs were removed. 

Over the long-term, vegetation treatments would likely improve visual resources on public lands. Treatments that aim 

to rehabilitate degraded ecosystems, if successful, would result in plant communities that are dominated by native 

species. Native-dominated communities tend to be more visually appealing than areas that have been overtaken by 

noxious weeds and other invasive non-native vegetation, or that have been invaded by pinyon-juniper. These 

treatment benefits could be more noticeable in the riparian zone, as many of the treatment streams have been 

substantially degraded and are not meeting Proper Functioning Condition. 

Treatments that restore native fire regimes, vegetation, and ecosystem processes would reduce the spread of noxious 

weeds and other invasive non-native vegetation that is less visually appealing than native vegetation. Noxious weeds 

and other invasive non-native vegetation removal, stream channel restoration, and the removal of encroaching pinyonjuniper would help to limit the spread of wildfire by enabling riparian zones to function as fuel breaks. 

Aspen Treatments 

The scenic quality evaluation showed that all aspen treatment units were rated Class A. The visual effects to resources 

from treatments would be High on all treatment units. However, only about one-third of the treatment units would be 

visible in the foreground-middleground (JD-A1, JD-A4, RM-A7, and RM-A9); the remaining areas would seldom be 

seen. Based on these assessments, all riparian management units are rated Class II. 

About 40 percent of treatment acreage is rated VRM Class I, and includes the JD-A4, RM-A2, RM-A10, and SFF-A1

units. About 20 percent of acres are rated VRM Class II (JD-A1 and RM-A2), while the remaining acres are VRM 

Class IV, including 2 acres of RM-A2. At the JD-A4, RM-A2, and RM-A10 units, manual and mechanical methods 

would be used to remove pinyon-juniper trees encroaching into aspen habitats. For JD-A1, treatments would focus on 

treating aspen to stimulate stand suckering using mechanical and manual methods, while at SFF-A1 the BLM would 

erect small, temporary exclosure fencing around an aspen stand to promote sucker survival. Exclosure fencing could 

also be used at other sites to protect treated aspen stands from grazing. 

Only about 5 acres of treatments would be visible to the public annually, thus effects of aspen treatments on the visual 

resources of the 3 Bars Project area would be negligible. 

Pinyon-juniper Treatments 

The scenic quality evaluation found that about 65 percent of treatment areas were rated Class A, and 35 percent as 

Class B. Treatment units where over 90 percent of the area was Class A included Birch Creek, Cottonwood/Meadow 

Canyon, Dry Canyon, Lone Mountain, Upper Pete Hanson, Tonkin North, and Tonkin South units. 

3 Bars Project Final EIS 3-378 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Public concern for adverse visual effects to resources would be Low on about 6 percent of treatment areas, but about 

47 percent each for Moderate and High. Treatment units where most acreage (over 75 percent) was rated High are the 

Atlas, Birch Creek, Upper Pete Hanson, Three Bars Ranch, Tonkin South, and Upper Roberts Creek units. 

Nearly 90 percent of treatment areas would be visible in the foreground-middleground, while the remaining areas 

would be seldom seen. Only the Upper Pete Hanson and Upper Roberts Creek units would be relatively difficult to 

see by the public. 

Despite the relatively high resource ratings given above, over 90 percent of the pinyon-juniper management area was 

rated as VRM Class IV, where substantial modification of the landscape is appropriate, while 2 percent of treatment 

acres were rated Class III, and 7 percent as Class II. Units with more than 100 acres rated as Class II were the Atlas, 

Gable, Lower Pete Hanson, Upper Pete Hanson, Upper Roberts Creek, and Whistler units, although these acres were 

only a small portion of the overall treatment acres except for Lower Pete Hanson and Upper Roberts, where VRM 

Class II lands comprised over 75 percent of the treatment unit. Only 346 acres were rated VRM Class I, and these 

were at the Birch Creek, Upper Pete Hanson, and a small portion (20 acres) of Upper Roberts Creek units. 

Adverse Effects 

Most visual resource concerns would be focused on the Birch Creek, Upper Pete Hanson, and Upper Roberts Creek 

units, since most of their acreage is rated VRM Class I or II. Treatments on the Upper Pete Hanson and Upper 

Roberts Creek units, however, would be relatively difficult for the public to see. The BLM proposes to improve 

sagebrush habitat by thinning pinyon-juniper to promote sagebrush growth, and create fuel breaks to reduce the 

damage from a wildfire. Manual and mechanical methods and prescribed fire would be used on Upper Roberts Creek, 

while only chainsaws would be used on the Birch Creek and Upper Pete Hanson units because treatment areas are in 

the Roberts Mountains WSA. The effects of manual treatments are discussed under Effects Common to All 

Alternatives. 

Most of the pinyon-juniper on the Upper Roberts Creek Unit would be removed from Phase I stands. Because these 

trees have encroached into sagebrush habitat, and are widely-spaced throughout the area, removal of these trees would 

restore the visual character associated with sagebrush habitat and would have a minor visual effect. Limited 

management is allowed in VRM Class I areas, and management activities should not attract the attention of the casual 

observer in VRM Class II areas. The Birch Creek and Upper Pete Hanson units are small (less than 300 acres each) 

and manual treatments would be used to remove pinyon-juniper in all phases. If trees are removed from dense stands, 

there could be more visual contrast with remaining areas, but this effect would be minor because only about 20 acres 

would be treated annually in each unit and the BLM would manage pinyon-juniper stands to create a mosaic of 

habitat for wildlife. 

Prescribed fire could be used on the Upper Roberts Creek Unit. Although smoke would be visible to the public on the 

Upper Roberts Creek Unit, charred vegetation from burning would be difficult for the public to see as this unit is 

relatively isolated and not visible from the foreground-middleground. 

The objective of VRM Classes I and II is to retain the existing character of the landscape. Although treatments for 

these three units would be limited in scope and extent, they would alter the existing characters of the landscape. 

However, treatments would help remove encroaching pinyon-juniper and return the sites to their more historic 

condition. 

3 Bars Project Final EIS 3-379 October 2016 
VISUAL RESOURCES 

Beneficial Effects 

Beneficial treatment effects on visual resources would be similar to those discussed under Effects Common to All 

Alternatives, and under Riparian Treatments. Treatments in VRM Class I and II areas would help to slow pinyonjuniper encroachment into sagebrush habitat and restore more natural conditions to these areas. Treatments on Birch 

Creek and Upper Peter Hanson would help to retain the visual characteristics associated with the Roberts Mountains 

WSA. 

Treatments on other pinyon-juniper management units would also benefit visual resources on the 3 Bars Project area. 

Treatments that restore degraded ecosystems would result in plant communities that are dominated by native species 

and are more visually appealing. Prescribed fire would help to remove dead and diseased pinyon-juniper that is 

unattractive; reduce hazardous fuels and the risk of catastrophic wildfire; and restore native fire regimes, vegetation, 

and ecosystem processes. The use of prescribed fire would allow the BLM to limit the size and duration of fires in 

areas of high public use to minimize visual contrasts between burned and unburned vegetation and effects of smoke, 

and to conduct fires during the cooler times of the year when visitation by the public would be less. By using all 

treatment methods to reduce hazardous fuels, create fire and fuel breaks, remove noxious weeds and other invasive 

non-native vegetation, and promote more resilient vegetation, the BLM would reduce the risk of wildfire and its 

inherent impacts on the scenery. 

Sagebrush Treatments 

Mechanical methods have the potential to scarify the landscape and leave bare soil and dead vegetation that contrast 

with the surrounding colors. The effects of mechanical treatments on visual resources would be temporary, and would 

only last until the re-establishment of vegetation on the treatment site, typically 1 or 2 growing seasons (USDOI BLM 

2007c:4-113). 

The scenic quality evaluation found that about 15 percent of treatment areas were rated as Class A, while the 

remainder were rated Class B. On the Three Corners and West Simpson Park units, over 95 percent of the acreage is 

rated Class A. 

Public concern for adverse visual effects to resources would be High on about 20 percent of the sagebrush treatment 

area, Moderate on 35 percent of the area, and Low on 45 percent of the area. On the Coils Creek, Nichols, Roberts 

Mountain Pasture, and Three Corners units, more than 80 percent of the treatment acres were rated High. 

Based on the visibility of sites, all but about 1,000 acres would be visible in the foreground-middleground. Only the 

Three Corners Unit would be seldom seen by the public. None of the sagebrush treatment acreage was rated VRM 

Class I, and less than 1 percent was rated VRM Class II. Over 90 percent of the acreage is VRM Class IV, while 8 

percent is Class III. Class II acreage is found at the Alpha and Three Corners units. 

Adverse Effects 

Concerns regarding effects from sagebrush management would be greatest for the Alpha, Coils Creek, Nichols, 

Roberts Mountain Pasture, Three Corners, and West Simpson Park units. The Alpha, Coils Creek, Nichols, and 

Roberts Mountain Pasture units are part of the Alpha Unit treatment group. The effects of manual and mechanical 

treatments on relatively flat terrain, such as for these sagebrush communities, would have less effect on visual 

resources than treatments on steeper terrain, such as pinyon-juniper woodlands, which would be more visible on the 

3 Bars Project Final EIS 3-380 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-381 October 2016 

landscape. The effects of manual and mechanical treatments on visual resources would be temporary, and would only 

last until the reestablishment of vegetation on the treatment site, typically 1 or 2 growing seasons. 

On the Three Corners Unit, the BLM would thin pinyon-juniper and seed and plant to increase the percent 

composition of native grasses, forbs, and shrubs to 50 to 75 percent of the Potential Natural Community. The Three 

Corners Unit is found in an area that is seldom seen by the public. 

The BLM would treat cheatgrass on south-facing slopes to promote the establishment of sagebrush on the West 

Simpson Park Unit. Portions of this unit have been burned by wildfire in recent years. The BLM would use all 

methods to control cheatgrass, including pre-treatments using prescribed fire, livestock, and discing. About 1,963 

acres, or half of the unit, could be treated over the life of the project. The greater the area of vegetation treatment, the 

greater the visual effect is likely to be. Large treatments alter a larger portion of the landscape than small treatments, 

and the effects are more likely to be observed by people. However, the West Simpson Park Unit consists of degraded 

lands of low to moderate scenic quality, resulting in a smaller visual effect from treatment and likely an improvement 

in the scenic quality of the land over the long-term. 

Beneficial Effects 

Beneficial effects from manual, mechanical, and fire treatments are discussed under Effects Common to All 

Alternatives and Pinyon-juniper Treatments. 

In general, treatments on the West Simpson Park Unit would have long-term positive effects on visual resources. 

Areas dominated by non-native vegetation have been impacted by past wildfires and are some of the more degraded 

areas on the 3 Bars Project area. They are also vulnerable to future wildfires. Thus, efforts to restore native, fire 

resilient vegetation would make these areas more visually appealing, and would reduce the risk of future wildfires. 

The controlled use of domestic animals to contain undesirable vegetation may create a short-term visual impact 

associated with trampling and consumption of vegetation. These impacts would be dealt with on a case-by-case basis 

and mitigated as appropriate at the project level. The visual effects caused by the containment of domestic animals 

would be short-term in nature and would create a positive visual effect with the regrowth of desirable vegetation in a 

healthy, productive condition. 

3.19.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The types and magnitude of effects for manual, mechanical, and biological control treatments would be similar 

between Alternatives A and B. Treatments conducted under Alternative B would have short-term adverse and longterm beneficial impacts on the scenic qualities of the landscape on about 2,500 to 3,500 acres annually on lands with a 

Scenic Quality rating of A and Sensitivity Level Rating of High. Of the estimated 6,350 acres treated annually under 

Alternative B, about 5,500 acres could occur where treatments occur would be visible to the public. The BLM may 

have to modify management objectives on about 20 acres of VRM Class I, and 35 acres in VRM Class II treatment 

units annually, as these areas could be visible to the casual observer. 

Without the use of fire, there would be no localized deterioration of air quality and reduced visibility caused by 

smoke, no blackened appearance of treated areas and blackened stumps and snags that would create a color contrast, 

and no spread of noxious weeds and other invasive non-native vegetation in burned areas. However, long-term 

improvements in pinyon-juniper stand health, replacement of pinyon-juniper stands with sagebrush, forbs, and 

grasses, and removal of encroaching pinyon-juniper using prescribed fire and wildland fire for resource benefit, and 
VISUAL RESOURCES 

3 Bars Project Final EIS 3-382 October 2016 

the resultant improvement in the visual qualities of the landscape, would not occur over several thousand acres 

annually. 

Without the use of fire to reduce hazardous fuel loads, Alternative B could pose a greater long-term risk for wildfire 

due to the accumulation of fuels. The BLM would not be able to promote more fire resilient and diverse habitat on the 

3 Bars Project area. The BLM would also not be able to use prescribed fire to remove downed wood and other 

hazardous fuels associated with thinning and removal of pinyon-juniper, thus increasing the risk of wildfire in pinyonjuniper treatment areas. An increase in wildfire risk compared to Alternative A could lead to a long-term reduction in 

the visual qualities of the landscape. 

The BLM could use classical biological control, such as the use of nematodes, insects, and fungi to control non-native 

vegetation, but would more likely use cattle and goats. The use of domestic animals to contain undesirable vegetation 

would cause minimal effects to visual resources. The sight of domestic animals should not cause any adverse effects, 

as livestock are found over most of the 3 Bars Project area. 

Under Alternative B, the BLM would be able to slow, but probably not reverse, habitat degradation on the 3 Bars 

Project area. Treatments would occur across the landscape and most projects would benefit multiple resources, but 

large-scale fire and herbicide treatments would not occur under this alternative. Although short-term impacts to visual 

resources would be less under this alternative than Alternative A, there would be less long-term improvement in the 

scenic quality of the 3 Bars Project area under Alternative B compared to Alternative A. 

3.19.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Treatments conducted under Alternative C would have short-term adverse and long-term beneficial impacts on the 

scenic qualities of the landscape on about 1,500 to 2,000 acres annually of lands with a Scenic Quality Rating of A 

and Sensitivity Level Rating of High. Of the estimated 3,250 treated annually under Alternative C, about 3,000 acres 

would be visible to the public. The BLM may have to modify management objectives on about 10 acres of VRM 

Class I and 15 acres in VRM Class II treatment lands annually, as these areas could be visible to the casual observer. 

By not being able to use mechanical equipment, there would be no adverse visual effects associated with stream 

channel restoration disturbance, creating openings in pinyon-juniper stands from removal of vegetation, creating long 

linear features for fire and fuel breaks, or causing surface disturbance from discing/tilling/harrowing to restore areas 

invaded by cheatgrass. The BLM would also leave less dead plant material on the ground to turn brown. 

The BLM has not identified areas where it would use classical biological control, but if nematodes, insects, or fungi 

are used on the 3 Bars Project area, they would cause some visual alterations to the landscape. Plants attacked by 

these agents often show visual symptoms of disease or parasitism, which are often regarded as visually unappealing. 

However, these changes would only be noticeable upon close examination of the site. The overall appearance of the 

treatment area would likely remain relatively unchanged. Because these agents kill target species gradually, the 

effects would be less visibly distinct than treatments that kill a large area of vegetation all at once (USDOI BLM 

2007c:4-113). 

Under Alternative C, the BLM would not be able to conduct stream engineering and restoration to improve native 

riparian habitat, except on a limited basis on only a few stream miles; control noxious weeds and other invasive nonnative vegetation, except on very small areas where this vegetation can be hand pulled or controlled using hand tools; 

reseed and replant restoration sites, except for small areas where shrubs and other vegetation would be planted by 

hand; or create fire and fuel breaks to reduce the risk of wildfire spread, except near existing roads or aspen stands, or 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-383 October 2016 

along a few miles of stream. The BLM would only be able conduct hazardous fuels treatments and remove downed 

woody material from treatments on a limited acreage using manual and classical biological control treatments. Thus, 

the risk of catastrophic wildfire, and its effects on the visual landscape, would be greater under Alternative C than the 

other action alternatives. 

Under Alternative C, the BLM would not substantially improve the native vegetation community nor stop the loss of 

important ecosystem components. As a result, there would be less improvement in the visual quality of the 3 Bars 

Project area under this alternative than under Alternatives A and B. 

3.19.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to visual resources from 3 Bars Project treatments as no treatments would be 

authorized under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to 

promote healthy, diverse stands; use fencing to protect treatment areas; or restore fire as an integral part of the 

ecosystem. Without treatments to reduce fuel loading or to control cheatgrass establishment and spread, the risk of 

catastrophic wildfires would continue to increase. The BLM would not conduct stream engineering and riparian 

habitat enhancement, and thus would do little to improve visual qualities within riparian zones. This alternative would 

also do little to return the 3 Bars ecosystem to its Potential Natural Community and restore Proper Functioning 

Condition to wetlands and riparian zones, to the benefit of visual resources on the project area. 

3.19.3.4 Cumulative Effects 

The CESA for visual resources is approximately 2,599,851 acres and includes the 3 Bars Project area and the BLM 

visual resource management background distance zone (15 miles; Figure 3-1). Approximately 94 percent of the 

area is administered by the BLM and 6 percent is privately owned. Past and present actions that have influenced 

visual resources in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

Table 3-57 summarizes the acreages and percent of the cumulative effects analysis area categorized into each VRI 

component, the resulting VRI classes, and the VRM classes. 

3.19.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

As demonstrated by rangeland health studies conducted for the 3 Bars Project, historic livestock grazing and other 

natural and human-caused factors have resulted in rangelands dominated by early- to mid-seral vegetation, indicating 

a need to improve the health and resiliency of native vegetation and move rangelands closer to their Potential Natural 

Community. In addition, livestock and wild horses often congregate near streams, springs, and wetlands, causing 

impacts to riparian habitat, forage, and stream channels and their ability to function properly. 

To improve forage and water resources, the BLM would continue ongoing management reviews to ensure proper 

livestock management and the long-term success of the proposed treatments. Any required modifications to grazing 

permits would be completed through a decision process separate from the 3 Bars Project and in accordance with the 

grazing regulations. 

The BLM would also continue to conduct wild horse gathers, AML reviews and adjustments, remove excess animals 

and use fertility control, improve water developments, and implement habitat projects. These management actions 

would help to improve visual resources on the 3 Bars Project area. 
VISUAL RESOURCES 

TABLE 3-57 

Visual Resource Project Area Inventory and Visual Resource Management Classes 

Summary for Cumulative Effects Study Area 

Scenic Quality Evaluation

BLM - Class A BLM - Class B BLM - Class C Not Inventoried Total

836,5621

32%2

1,107,651

43%

443,199

17%

212,438

8% 2,599,851

Sensitivity Level Analysis

High Medium Low Not Inventoried Total

867,129

33%

681,443

26%

838,841

32%

212,438

8% 2,599,851

Distance Zones

ForegroundMiddleground Background Seldom Seen Not Inventoried Total

1,766,368

68%

71,917

3%

549,127

21%

212,438

8% 2,599,851

Visual Resource Inventory Classes

VRI Class I VRI Class II VRI Class III VRI Class IV Not Inventoried Total

0 1,254,385

48%

167,253

6%

965,775

37%

212,438

8% 2,599,851

Visual Resource Management Classes

VRM Class I VRM Class II VRM Class III VRM Class IV Not Inventoried Total

64,545

2%

40,426

2%

334,999

13%

2,058,732

79%

101,150

4% 2,599,851

1 Acres. 

2

 Percent of acres within CESA. 

The BLM would continue to use ground-based herbicide applications to remove noxious weeds and other invasive 

non-native vegetation, and aerial-based herbicide applications to remove cheatgrass, and would also use herbicides to 

restore burned areas under the Burned Area Emergency Stabilization and Rehabilitation program, under existing 

authorizations on about 1,000 acres annually. The BLM could use aerial applications to control cheatgrass on several 

hundred acres annually on the West Simpson Park Unit. Portions of this unit have been burned by wildfire in recent 

years. About half of the unit could be treated over the life of the project. In general, herbicide treatments would have 

short-term negative effects and long-term positive effects on visual resources. The greater the area of vegetation 

treatment, the greater the visual effect is likely to be. Large treatments alter a larger portion of the landscape than 

small treatments, and the effects are more likely to be observed by people. However, the units consists of degraded 

lands of low to moderate scenic quality, resulting in a smaller visual effect from treatment and likely an improvement 

in the scenic quality of the land over the long-term. 

Land development, mineral development, and oil, gas, and hydrothermal exploration and development could affect 

about 10,000 acres in the CESA in the reasonably foreseeable future, including the Mount Hope Project and acreage 

associated with potential land sales (although it is unlikely that all of this land would be developed), materials sites 

and other mineral development, roads, and rights-of-ways for roads, pipelines, and power and telephone lines. 

3 Bars Project Final EIS 3-384 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

The Mount Hope Project would disturb about 8,300 acres. There would be a moderate to strong contrast in form, 

line, and color between the existing landscape and the post-mining landscape associated with the Mount Hope 

Project. Most of the area encompassed by the mine project is VRM Class IV and the changes in the landscape 

would conform to VRM objectives. Visual contrast would be reduced by reclamation practices, which would 

consist of recontouring and revegetating the waste rock and tailings storage facilities; recontouring and 

revegetating exploration roads; removing all buildings, structures, and equipment brought to the site; and 

recontouring and revegetating all building sites. Following successful reclamation, the visual contrast from the 

Mount Hope Project would be slightly reduced. Over the long-term, the vegetation used to restore the mine site 

would begin to blend with the color and texture of the existing natural landscape. However, the mine pit would still 

be visible to the public after mine reclamation and its visual impact on the landscape would be significant (USDOI 

BLM 2012b:3-327 to 3-328). 

Catastrophic wildfire can burn extensive areas of vegetation. Based on acreage burned by wildfires since 1985, an 

estimated 140,000 acres would be burned by wildfires in the CESA during the next 20 years, and would result in a 

blackened landscape. 

Proposed hazardous fuels reduction and habitat improvement treatments would occur on about 127,000 for the 3 Bars 

Project, and on about 15,000 acres in other portions of the CESA under current and reasonably foreseeable future 

authorizations, or collectively about 5 percent of the CESA. Proposed treatments would move vegetation 

communities in areas that have been disturbed by past natural and human-caused action in the CESA toward their 

Potential Natural Communities. As discussed under direct and indirect effects, proposed vegetation treatments would 

have a short-term affect on visual resources by changing the scenic quality of the landscape. Long-term, the 3 Bars 

Project should result in vegetation that is more fire resilient, diverse, and similar to the Potential Natural Community. 

Hazardous fuels treatments would remove vegetation that contributes to short return-interval fires and loss of native 

vegetation. These treatments would help to reduce the risk of wildfire within the CESA. In addition, the BLM would 

conduct stream bioengineering and plantings on about 31 miles of stream to slow stream flow and create pools and 

wet meadows to improve wetland and riparian vegetation. These activities would help to make the landscape more 

visually appealing. In the long-term, benefits to visual resources from treatments would help to offset some of the 

adverse effects to visual resources from other reasonably foreseeable future projects in the CESA, and to a greater 

extent than would occur under the other alternatives. 

3.19.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on visual resources would 

be similar to those described under Alternative A. Under Alternative B, less effort would be spent by the BLM on 

treatments to reduce wildfire risk and its impacts on visual resources. By not using fire on the 3 Bars Project area, 

there would be no visual effects associated with fire on several thousand acres annually within the 3 Bars Project area. 

These include the effects of smoke, dead and dying vegetation, and a charred landscape. However, the use of fire and 

could occur on a few hundred acres annually outside the 3 Bars Project treatment areas. 

The BLM would be limited to hand pulling, discing, plowing, seeding, and using livestock to control noxious weeds 

and other invasive non-native vegetation on several hundred acres annually on the 3 Bars Project area. These methods 

could result in more soil disturbance and erosion than would occur from the use of fire, but would also give the BLM 

greater control on the types and amount of vegetation that is removed and types of visual impacts from treatments. 

The West Simpson Park Unit is on rugged terrain, and use of mechanical equipment to control cheatgrass on this unit 

would be difficult. This area is predominantly Scenic Quality Class A, and visible to the public. 

3 Bars Project Final EIS 3-385 October 2016 
VISUAL RESOURCES 

Hazardous fuels reduction and habitat improvement projects could occur on about 63,000 acres within the 3 Bars 

Project area, and on an additional 15,000 acres within the CESA, or about 3 percent of the acreage within the CESA. 

BLM treatments would help to offset some of the adverse effects to visual resources from other reasonably 

foreseeable future actions, but not to the extent as would occur under Alternative A. 

3.19.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on visual resources would 

be similar to those described under Alternative A. Adverse, short-term effects to scenic resources, primarily 

vegetation, associated with the use of fire and mechanized equipment would not occur under Alternative C; fire and 

mechanized equipment could be used in other portions of the CESA to improve habitat, remove hazardous fuels, and 

reduce the risk of wildfire under current and reasonably foreseeable future authorizations. 

By not being able to use mechanical methods, less pinyon-juniper removal, discing, plowing, shredding, and 

mulching that would cause a visual contrast with untreated areas would occur under this alternative compared to 

Alternatives A and B. The BLM, however, would be less able to create fire and fuel breaks, remove diseased and 

dying pinyon-juniper, thin decadent sagebrush, restore areas dominated by cheatgrass and other noxious weeds and 

other invasive non-native vegetation, or restore degraded stream channels and riparian zones under this alternative 

than under Alternative A and B, to the detriment of the scenery on the 3 Bars Project area. The BLM would also be 

less able to reduce hazardous fuels and construct fire and fuel breaks, and reduce the risk of catastrophic wildfire and 

its effects on the scenery under Alternative C than under Alternatives A and B. 

Hazardous fuels reduction and habitat improvement projects could occur on about 32,000 acres within the 3 Bars 

Project area, and on an additional 15,000 acres within the CESA, or only about 2 percent of the acreage within the 

CESA. There would be a long-term net benefit from BLM treatments that would help to offset some of the adverse 

effects to visual resources from other reasonably foreseeable future actions, but not to the extent as would occur under 

Alternatives A and B. 

3.19.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on visual resources would 

be similar to those described under Alternative A. There would be no cumulative effects on visual resources from 3 

Bars Project treatments as no treatments would be authorized under this alternative. The BLM could create fire and 

fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and 

other invasive non-native vegetation using ground-based and aerial application methods of herbicides, especially 

cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildfire under current 

and reasonably foreseeable future authorized actions, but on a very limited acreage. 

Based on historic treatments in the 3 Bars Project area, only about 1,500 acres would be treated annually in the CESA 

to reduce hazardous fuel levels and improve ecosystem health. Hazardous fuel levels would likely increase, and only a 

limited number of miles of fuel and fire breaks would be constructed under this alternative compared to the action 

alternatives. The BLM would conduct stream bioengineering and riparian habitat enhancements on only a few miles 

of streams. Thus, the BLM would do little to move rangelands toward their Potential Natural Community or restore 

Proper Functioning Condition in wetlands and riparian zones. The trend toward large-sized fires of moderate to high 

severity in sagebrush and large stand-replacing fires in pinyon-juniper would likely increase. As a result, visual 

resource conditions would likely continue to deteriorate within the CESA. 

3 Bars Project Final EIS 3-386 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.19.3.5 Unavoidable Adverse Effects 

Over the short-term, vegetation treatments would kill or harm vegetation in the treated area, resulting in a more open, 

browned or blackened landscape until new plants grow. While these effects are unavoidable, they are considered 

short-term impacts, as the vegetation would recover and lead to improved natural conditions. Treatment areas would 

vary in terms of their visual appeal prior to treatment and their distance from human activity, as well as in terms of the 

resulting public sensitivity to the pre- and post-treatment visual character of the area. The effects of vegetation 

treatments on the visual quality of the landscape would be most noticeable to travelers, sightseers, and residents for 

the first one to several years following treatment, particularly near major roads or residential areas (USDOI BLM 

2007c:4-245). The proposed vegetation treatments would not cause unavoidable adverse effects to visual resources 

over the long-term. 

3.19.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

The proposed vegetation treatments would affect visual resources by changing the scenic quality of the landscape. 

Over the short-term, impacts to visual resources from all treatment methods would begin to disappear within 1 to 2 

growing seasons. The regrowth of vegetation on the site would eliminate much of the stark appearance of cleared 

areas, and the site would develop a more natural appearance. Impacts would last for the longest amount of time in 

woodlands and other areas where large trees and shrubs were removed. 

Over the long-term, vegetation treatments would likely improve visual resources on public lands. Treatments that aim 

to rehabilitate degraded ecosystems, if successful, would result in plant communities dominated by native species. 

Native-dominated communities tend to be more visually appealing and productive than areas that have been 

overtaken by noxious weeds and other invasive non-native vegetation (e.g., areas supporting a cheatgrass 

monoculture), or that have been invaded by woody species (e.g., sagebrush experiencing encroachment by pinyonjuniper; USDOI BLM 2007c:4-250). 

3.19.3.7 Irreversible and Irretrievable Commitment of Resources 

There would be no irreversible or irretrievable commitment of visual resources. Although there would be short-term 

impacts to visual resources from vegetation treatments, loss of visual resources would not be irretrievable and could 

be reversed if restoration treatments were successful. 

3.19.3.8 Significance of the Effects under the Alternatives 

3 Bars Project treatments could contribute to scenic degradation in the short-term, but this would be negligible in the 

context of other adverse impacts to visual resources in the CESA and would be in conformance with VRM objectives. 

By themselves, none of the 3 Bars Project treatments under all alternatives should result in a significant change in 

Class A scenery from Class A to Class B or to Class C in the long-term (greater than 10 years), strong visual contrast 

in the immediate foreground view from a designated recreation site, historic trail, or residence in the long-term 

(greater than 10 years), or non-compliance with VRM objectives in the long-term (greater than 10 years) within the 3 

Bars Project area and CESA. 

3 Bars Project Final EIS 3-387 October 2016 
LAND USE AND ACCESS 

3.19.4 Mitigation 

No mitigation measures are proposed for visual resources. 

3.20 Land Use and Access 

3.20.1 Regulatory Framework 

Federal and local planning documents were reviewed to gain an understanding of the regulatory guidelines in effect 

within the 3 Bars Project area. The Shoshone-Eureka RMP provides a regulatory framework that applies to land use 

and authorizations on the 3 Bars Project area. The Eureka County Master Plan, although not a regulatory document, 

also provides policy recommendations for land use within the 3 Bars Project area. 

The Federal Land Policy and Management Act of 1976 was implemented to establish public land policy and 

guidelines for its administration; to provide for the management, protection, development, and enhancement of 

public lands; and for other purposes (USDOI BLM 1976). Several sections within the Act deal with land use 

actions, including sections devoted to land use planning, land acquisition, and land disposition; authorizations to 

grant rights-of-ways; and other administrative actions. 

The BLM Land Use Planning Handbook (H-1601-1) provides guidance to employees for implementing the BLM 

land use planning requirements established by Sections 201 and 202 of the Federal Land Policy and Management 

Act of 1976 (USDOI BLM 2005c). Land use plans and planning decisions are the basis for every on-the-ground 

action the BLM undertakes. Land use plans include both RMPs and management framework plans. 

Land use plans ensure that the public lands are managed in accordance with the intent of Congress as stated in the 

Federal Land Policy and Management Act, under the principles of multiple use and sustained yield. As required by 

the Federal Land Policy and Management Act and BLM policy, the public lands must be managed in a manner that 

protects the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, 

and archaeological values; that, where appropriate, will preserve and protect certain public lands in their natural 

condition; that will provide food and habitat for fish and wildlife and domestic animals; that will provide for 

outdoor recreation and human occupancy and use; and that recognizes the Nation’s need for domestic sources of 

minerals, food, timber, and fiber from the public lands by encouraging collaboration and public participation 

throughout the planning process. 

The Land Use Planning Handbook provides guidance for preparing, revising, amending, and maintaining land use 

plans. This handbook also provides guidance for developing subsequent implementation (activity-level and projectspecific) plans and decisions. The BLM 2800 Manual/Handbook/Instructional Memorandum Series provides policy 

and program direction for issuing, administering, assigning, amending, renewing, and terminating rights-of-way 

grants under the Federal Land Policy and Management Act and other related authorities in an environmentally, 

socially, and economically sound manner. The Manual/Handbook/Instructional Memorandum series also provides 

instructions to the program managers for right-of-way policy and program management (USDOI BLM 2008m). 

The Natural Resources and Federal or State Land Use Element of the Eureka County Master Plan (Natural Resource 

and Land Use Plan) provides policy for natural resource management and land use on federal and state administered 

lands in Eureka County (Eureka County 2010). The Natural Resource and Land Use Plan was expanded in response 

3 Bars Project Final EIS 3-388 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

to the passing of Senate Bill 40. Senate Bill 40 is intended to give Nevada localities an opportunity to address federal 

land use management issues directly. 

The Natural Resource and Land Use Plan provides land management objectives and describes how the County and 

the BLM and other land managers can work cooperatively to manage natural resources of interest. Topics covered in 

the Natural Resource and Land Use Plan include soil, vegetation, and watersheds; forage and livestock grazing; water 

quality, riparian areas, and aquatic habitats; wildlife and wildlife habitat; land tenure; minerals; cultural, historical, 

and paleontological resources; hunting, fishing, and outdoor recreation; WSAs; air quality; and law enforcement. 

3.20.2 Affected Environment 

3.20.2.1 Study Methods and Study Area 

Existing land use plans, such as the Shoshone-Eureka RMP and Eureka County Master Plan, as well BLM Mount 

Lewis Field Office data, were reviewed to determine land ownership and land uses. Land authorizations and rights-ofway from BLM field office data were also reviewed and summarized. Lastly, the Mount Lewis Field Office provided 

tables that showed land ownership and land use authorizations. 

The study area for the assessment of direct, indirect, and cumulative effects for land use is the 3 Bars Project area 

(Figure 3-1). 

3.20.2.2 Land Ownership and Use 

The federal government is the dominant landowner within Eureka County and the project area, followed by private 

landowners. Federal lands within the project area are administered by the BLM. There are no U.S. Forest Service, 

state, or county-owned lands within the project area. Figure 3-50 and Tables 3-58 and 3-59 detail land ownership as 

well as land use authorizations within the project area. 

Mining and livestock grazing are the two primary land uses within the project area. As described in the Eureka 

Natural Resources and Land Use Plan, open space agricultural consisting of designated grazing allotments is the 

single greatest land use within Eureka County (2010). Open space agricultural often consists of ranching with 

dispersed livestock grazing on non-irrigated rangelands. Section 3.18 contains more information about livestock 

grazing within the project area. There are no active mines within the project area, but there are six active mines within 

30-miles. In addition, the 8,300-acre Mount Hope Project is under construction and is in the southwestern portion of 

the project area. The Ruby Hill Mine, operated by Homestake Mining Company of California, a subsidiary of Barrick 

Gold Corporation, is the closest active mine to the project area, and is 4 miles southeast of the project boundary, near 

the town of Eureka. In addition, there are approximately 1,227 abandoned mine sites within the project area. These 

abandoned sites include mine shafts and quarries. Eureka County has not adopted a zoning ordinance. 

There are two WSAs within the project area, Roberts Mountains WSA and Simpson Park WSA (Figure 3-7). 

Information on WSAs is included in Section 3.22. The nearest town is Eureka, located just southeast of the junction of 

U.S. 50 and State Route 278 and approximately 7 miles from the southeast corner of the project area. 

3 Bars Project Final EIS 3-389 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-50

Land Ownership and

Land-use Authorizations

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Communication Site

Dump

Monitoring Site

Monument

Power Facilities

Range Improvement

Recreation Site

Stream Gaging Station

Study Plot

Water Pumping Plant

Road

Fence

Pipeline

Telephone Line

Transmission Line

Irrigated Crop

Land Exchange

Land Treatment Area

Material Site

Land Owner

Bureau of Land Management

Private

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2013l.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-58

Land Ownership within the 3 Bars Project Area and Eureka County 

3 Bars Project Final EIS 3-391 October 2016 

Land Ownership Within the Project Area Acreage Percent

Bureau of Land Management 729,246 97

Private 20,564 3

Total 749,810 100

Land Ownership Within Eureka County Acreage Percent

Bureau of Land Management 1,969,762 74

U.S. Forest Service 142,923 5

Private Ownership 554,506 21

Eureka County 1041 <0.1

State of Nevada 19 <0.1

Total 2,668,251 100

TABLE 3-59

Land Use Authorizations in the Project Area

Authorization Type Serial Number Total Width (feet)

Cattle Guard NVN-000053 NA

Cattle Guard NVN-000101 NA

Cattle Guard NVN-000160 NA

Cattle Guard NVN-003514 NA

Cattle Guard NVN-003515 NA

Cattle Guard NVN-003539 NA

Cattle Guard NVN-004057 NA

Cattle Guard NVN-004060 NA

Cattle Guard NVN-004153 NA

Cattle Guard NVN-004155 NA

Cattle Guard NVN-004275 NA

Cattle Guard NVN-004307 NA

Cattle Guard NVN-004340 NA

Cattle Guard NVN-004694 NA

Cattle Guard NVN-004695 NA

Cattle Guard NVN-004737 NA

Cattle Guard NVN-004741 NA

Cattle Guard NVN-004743 NA

Cattle Guard NVN-004768 NA

Cattle Guard NVN-004775 NA

Cattle Guard NVN-004891 NA

Cattle Guard NVN-005005 NA

Cattle Guard NVN-005258 NA

Cattle Guard NVN-062509 NA
LAND USE AND ACCESS 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-392 October 2016 

Authorization Type Serial Number Total Width (feet)

Cattle Guard NVN-064776 NA

Cattle Guard NA NA

Cattle Guard NA NA

Cattle Guard NA NA

Cattle Guard NA NA

Cattle Guard NA NA

Cattle Guard NA NA

Communication Site NVN-004049 NA

Communication Site NVN-051602 NA

Corral NVN-000671 NA

Corral NVN-000760 NA

Corral NVN-000772 NA

Corral NVN-004223 NA

Corral NVN-040415 NA

Dump NVN-048468 NA

Dump NVN-048603 NA

Emergency Stabilization and Rehabilitation NVN-004842 NA

Emergency Stabilization and Rehabilitation NVN-059210 NA

Emergency Stabilization and Rehabilitation NVN-595086 NA

Emergency Stabilization and Rehabilitation NVN-595089 NA

Emergency Stabilization and Rehabilitation NVN-595090 NA

Emergency Stabilization and Rehabilitation NVN-595091 NA

Emergency Stabilization and Rehabilitation NVN-595096 NA

Emergency Stabilization and Rehabilitation NVN-595106 NA

Emergency Stabilization and Rehabilitation NVN-595139 NA

Emergency Stabilization and Rehabilitation NVN-595210 NA

Emergency Stabilization and Rehabilitation NVN-595211 NA

Emergency Stabilization and Rehabilitation NVN-595212 NA

Emergency Stabilization and Rehabilitation NVN-595215 NA

Emergency Stabilization and Rehabilitation NVR-004841 NA

Fence NVN-000016 NA

Fence NVN-000166 NA

Fence NVN-000485 NA

Fence NVN-004410 NA

Fence NVR-590004 NA

Fence NVR-590015 NA

Fence NVR-590016 NA

Fence NVR-590021 NA

Fence NVR-590025 NA

Fence NVR-590039 NA
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-393 October 2016 

Authorization Type Serial Number Total Width (feet)

Fence NVR-590050 NA

Fence NVR-590053 NA

Fence NVR-590059 NA

Fence NVR-590064 NA

Fence NVR-590065 NA

Fence NVR-590072 NA

Fence NVR-590082 NA

Fence NVR-590083 NA

Fence NVR-590085 NA

Fence NVR-590092 NA

Fence NVR-590101 NA

Fence NVR-590123 NA

Fence NVR-590160 NA

Fence NVR-590166 NA

Fence NVR-590167 NA

Fence NVR-590180 NA

Fence NVR-590187 NA

Fence NVR-590195 NA

Fence NVR-590203 NA

Fence NVR-590243 NA

Fence NVR-590310 NA

Fence NVR-590362 NA

Fence NVR-590364 NA

Fence NVR-590366 NA

Fence NVR-590384 NA

Fence NVR-590443 NA

Fence NVR-590444 NA

Fence NVR-590471 NA

Fence NVR-590482 NA

Fence NVR-590487 NA

Fence NVR-590501 NA

Fence NVR-590521 NA

Fence NVR-590533 NA

Fence NVR-590556 NA

Fence NVR-590628 NA

Fence NVR-590629 NA

Fence NVR-590736 NA

Fence NVR-590739 NA

Fence NVR-590741 NA

Fence NVR-590749 NA

Fence NVR-590753 NA
LAND USE AND ACCESS 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-394 October 2016 

Authorization Type Serial Number Total Width (feet)

Fence NVR-590754 NA

Fence NVR-590756 NA

Fence NVR-590757 NA

Fence NVR-590758 NA

Fence NVR-590759 NA

Fence NVR-590761 NA

Fence NVR-590764 NA

Fence NVR-590771 NA

Fence NVR-590772 NA

Fence NVR-590779 NA

Fence NVR-591510 NA

Fence NVR-593514 NA

Fence NVR-593516 NA

Fence NVR-593539 NA

Fence NVR-593794 NA

Fence NVR-594057 NA

Fence NVR-594060 NA

Fence NVR-594126 NA

Fence NVR-594136 NA

Fence NVR-594150 NA

Fence NVR-594153 NA

Fence NVR-594155 NA

Fence NVR-594197 NA

Fence NVR-594220 NA

Fence NVR-594224 NA

Fence NVR-594225 NA

Fence NVR-594266 NA

Fence NVR-594267 NA

Fence NVR-594275 NA

Fence NVR-594443 NA

Fence NVR-594561 NA

Fence NVR-594693 NA

Fence NVR-594714 NA

Fence NVR-594715 NA

Fence NVR-594730 NA

Fence NVR-594740 NA

Fence NVR-594742 NA

Fence NVR-594759 NA

Fence NVR-594760 NA

Fence NVR-593794 NA

Fence NVR-594762 NA
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-395 October 2016 

Authorization Type Serial Number Total Width (feet)

Fence NVR-594763 NA

Fence NVR-594767 NA

Fence NVR-594769 NA

Fence NVR-594777 NA

Fence NVR-594779 NA

Fence NVR-594838 NA

Fence NVR-594839 NA

Fence NVR-594840 NA

Fence NVR-594849 NA

Fence NVR-594853 NA

Fence NVR-594855 NA

Fence NVR-594881 NA

Fence NVR-594883 NA

Fence NVR-594885 NA

Fence NVR-594890 NA

Fence NVR-594917 NA

Fence NVR-594987 NA

Fence NVR-594994 NA

Fence NVR-595078 NA

Fence NVR-595105 NA

Fence NVR-595120 NA

Fence NVR-595121 NA

Fence NVR-595123 NA

Fence NVR-595127 NA

Fence NVR-595129 NA

Fence NVR-595205 NA

Fence NVR-595234 NA

Fence NVR-595258 NA

Fence NVR-595277 NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA
LAND USE AND ACCESS 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-396 October 2016 

Authorization Type Serial Number Total Width (feet)

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-397 October 2016 

Authorization Type Serial Number Total Width (feet)

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Fence NA NA

Irrigated Crop NVN-020395 NA

Irrigated Crop NVN-048415 NA

Irrigated Crop NVN-048443 NA

Land Treatment Area NVN-000175 NA

Land Treatment Area NVN-000281 NA

Land Treatment Area NVN-000322 NA

Land Treatment Area NVN-590002 NA

Land Treatment Area NVN-590008 NA

Land Treatment Area NVN-590019 NA

Land Treatment Area NVN-590023 NA

Land Treatment Area NVN-590044 NA

Land Treatment Area NVN-590060 NA

Land Treatment Area NVN-590114 NA

Land Treatment Area NVN-590158 NA

Land Treatment Area NVN-590190 NA

Land Treatment Area NVN-590346 NA

Land Treatment Area NVN-590368 NA

Land Treatment Area NVN-590455 NA

Land Treatment Area NVN-590456 NA

Land Treatment Area NVN-590457 NA

Land Treatment Area NVN-590491 NA

Land Treatment Area NVN-590534 NA

Land Treatment Area NVN-594729 NA
LAND USE AND ACCESS 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-398 October 2016 

Authorization Type Serial Number Total Width (feet)

Land Treatment Area NVN-594856 NA

Land Treatment Area NVN-595188 NA

Land Treatment Area NVR-000182 NA

Land Treatment Area NVR-590357 NA

Land Treatment Area NVR-590359 NA

Land Treatment Area NVR-590360 NA

Land Treatment Area NA NA

Land Treatment Area NA NA

Land Treatment Area NA NA

Land Treatment Area NA NA

Land Treatment Area NA NA

Local Neighborhood Road, Rural Road, City 

Street

NVN-052399 NA

Local Neighborhood Road, Rural Road, City 

Street

NVN-052540 NA

Local Neighborhood Road, Rural Road, City 

Street NVN-060918 NA

Material Site NVN-001472 NA

Material Site NVN-001473 NA

Material Site NVN-001962 NA

Material Site NVN-002186 NA

Material Site NVN-002187 NA

Material Site NVN-003420 NA

Material Site NVN-022487 NA

Material Site NVN-022489 NA

Material Site NVN-022492 NA

Material Site NVN-022499 NA

Material Site NVN-023080 NA

Material Site NVN-023082 NA

Material Site NVN-030013 NA

Material Site NVN-035593 NA

Material Site NVN-035595 NA

Material Site NVN-042799 NA

Material Site NVN-051858 NA

Material Site NVN-059954 NA

Material Site NVN-292803 NA

Monitoring Site NVN-089351 NA

Other Road NVN-000005 NA

Other Road NVN-000006 NA

Other Road NVN-000009 NA

Other Road NVN-036707 60
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-399 October 2016 

Authorization Type Serial Number Total Width (feet)

Other Road NVN-042812 400

Other Road NVN-048798 NA

Other Road NVN-052540 NA

Other Road NVN-053379 NA

Other Road NVN-053976 40

Other Road NVN-078526 NA

Other Road NA NA

Pipeline NVN-000087 NA

Pipeline NVN-000176 NA

Pipeline NVN-000239 NA

Pipeline NVN-000245 NA

Pipeline NVN-000326 NA

Pipeline NVN-003545 NA

Pipeline NVN-004046 NA

Pipeline NVN-004093 NA

Pipeline NVN-035075 NA

Pipeline NVN-036566 NA

Pipeline NVN-064738 NA

Pipeline NVN-064805 NA

Pipeline NVN-064806 NA

Pipeline NVR-000107 NA

Pipeline NVR-000741 NA

Plate Tectonic Study NA NA

Private Road for Service Vehicles (logging, oil 

fields, ranches, etc.)

NVN-052540 NA

Recreation Site NVN-002474 NA

Reservoir NVN-000067 NA

Reservoir NVN-000086 NA

Reservoir NVN-000145 NA

Reservoir NVN-000184 NA

Reservoir NVN-004059 NA

Reservoir NVN-005264 NA

Reservoir NVN-048417 NA

Reservoir NVN-053667 660

Reservoir NA NA

Secondary Road NVCC-022478 NA

Secondary Road NVN-001471 400

Secondary Road NVN-003794 NA

Secondary Road NVN-042812 400

Secondary Road NVN-043007 400

Secondary Road NVN-048798 NA
LAND USE AND ACCESS 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-400 October 2016 

Authorization Type Serial Number Total Width (feet)

Secondary Road NVN-060918 NA

Spring NVN-000081 NA

Spring NVN-000083 NA

Spring NVN-000110 NA

Spring NVN-000143 NA

Spring NVN-000235 NA

Spring NVN-000350 NA

Spring NVN-000402 NA

Spring NVN-000403 NA

Spring NVN-000423 NA

Spring NVN-000425 NA

Spring NVN-000432 NA

Spring NVN-000451 NA

Spring NVN-000474 NA

Spring NVN-000492 NA

Spring NVN-000511 NA

Spring NVN-000532 NA

Spring NVN-000548 NA

Spring NVN-000584 NA

Spring NVN-000585 NA

Spring NVN-000586 NA

Spring NVN-000611 NA

Spring NVN-000612 NA

Spring NVN-000613 NA

Spring NVN-000614 NA

Spring NVN-000615 NA

Spring NVN-000616 NA

Spring NVN-000618 NA

Spring NVN-000619 NA

Spring NVN-000620 NA

Spring NVN-000621 NA

Spring NVN-000622 NA

Spring NVN-000737 NA

Spring NVN-000738 NA

Spring NVN-000740 NA

Spring NVN-000755 NA

Spring NVN-003505 NA

Spring NVN-003506 NA

Spring NVN-003507 NA

Spring NVN-003509 NA

Spring NVN-003510 NA
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-401 October 2016 

Authorization Type Serial Number Total Width (feet)

Spring NVN-003513 NA

Spring NVN-003542 NA

Spring NVN-003543 NA

Spring NVN-003544 NA

Spring NVN-004094 NA

Spring NVN-004181 NA

Spring NVN-004248 NA

Spring NVN-040748 NA

Spring NA NA

Spring NA NA

Spring NA NA

Stock Tank NVN-048472 NA

Stream Gaging Station NVN-088802 NA

Study Plot NVN-004436 NA

Study Plot NVN-004443 NA

Study Plot NVN-004561 NA

Study Plot NVN-004730 NA

Study Plot NVN-004760 NA

Study Plot NVN-004777 NA

Study Plot NVN-004779 NA

Study Plot NVN-004849 NA

Study Plot NVN-004881 NA

Study Plot NVN-004883 NA

Study Plot NVN-004885 NA

Study Plot NVN-004917 NA

Study Plot NVR-004136 NA

Study Plot NVR-064714 NA

Study Plot NVR-064715 NA

Substation NVN-060092 NA

Telephone Line NVN-005253 NA

Telephone Line NVN-007318 20

Telephone Line NVN-051022 15

Telephone Line NVN-056120 10

Telephone Line NVN-058497 NA

Transmission Line NVN-005638 NA

Transmission Line NVN-012655 25

Transmission Line NVN-042324 NA

Transmission Line NVN-047781 NA

Transmission Line NVN-048321 30

Transmission Line NVN-060092 NA

Transmission Line NVN-063162 NA
LAND USE AND ACCESS 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

3 Bars Project Final EIS 3-402 October 2016 

Authorization Type Serial Number Total Width (feet)

Transmission Line NVN-088978 45

Trough NVN-000176 NA

Trough NVN-000212 NA

Trough NA NA

Trough NA NA

Trough NA NA

Trough NA NA

Trough NA NA

Trough NA NA

Trough NA NA

Trough NA NA

Trough NA NA

Trough NA NA

US Mineral Monument NVN-001758 NA

US Mineral Monument NVN-001762 NA

US Mineral Monument NVN-001763 NA

US Mineral Monument NA NA

US Mineral Monument NA NA

US Mineral Monument NA NA

Water Pumping Plant NVN-000490 NA

Well - Other NVN-000069 NA

Well - Other NVN-000307 NA

Well - Other NVN-000479 NA

Well - Other NVN-000480 NA

Well - Other NVN-000543 NA

Well - Other NVN-000598 NA

Well - Other NVN-004050 NA

Well - Other NVN-004120 NA

Well - Other NVN-004156 NA

Well - Other NVN-004339 NA

Well - Other NVN-040116 NA

Well - Other NVN-040117 NA

Well - Other NVN-040118 NA

Well - Other NVN-040119 NA

Well - Other NVN-040120 NA

Well - Other NVN-040121 NA

Well - Other NVN-040122 NA

Well - Other NA NA

Well - Other NA NA

Windmill NVN-000040 NA

Windmill NVN-000617 NA
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-59 (Cont.) 

Land Use Authorizations in the Project Area

Authorization Type Serial Number Total Width (feet)

Windmill NVN-000653 NA

Windmill NVN-000765 NA

Windmill NVN-004745 NA

Windmill NA NA

Windmill NA NA

Withdrawal Class Reserves NA NA

Withdrawal Class Reserves NA NA

1 Source: USDOI BLM (2012a, 2013k).

NA = Not applicable. 

3.20.3 Environmental Consequences 

3.20.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, two concerns specific to land use and 3 Bars ecosystem 

restoration were identified and are discussed in this section. These are: 

 Encourage the BLM to work to balance the requirements and demands of multiple users of the land, 

consistent with federal multiple-use policies. 

 Ensure the EIS considers the objectives of Eureka County’s plans and policies. 

3.20.3.2 Significance Criteria 

Impacts to land use would be considered significant if BLM actions resulted in: 

 Substantial conflict with existing land uses, including current land use authorizations. 

 Substantial change in land use designations. 

 Substantial reduction in opportunity for right-of-way authorizations and development activities. 

 Substantial reduction in the opportunity for land tenure adjustments. 

3.20.3.3 Direct and Indirect Effects 

3.20.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse effects to land use common to all alternatives include the use of treatments that may result in short-term 

access limitations to land uses and current land use authorizations within the analysis area. 

Treatments that reduce the risk of future catastrophic wildfire through fuels reduction would reduce the risk of loss of 

life, property, constructed facilities on public land, and resources on the 3 Bars Project area. Collaboration with the 

3 Bars Project Final EIS 3-403 October 2016 
LAND USE AND ACCESS 

affected holders of a right-of-way or other authorizations and any landowners within the vicinity of the project area 

would be of utmost importance when implementing fire treatments. Open communication between the affected parties 

would limit possible negative impacts to right-of-way, other authorized development on public land, livestock, and 

ranch, farm, or other private properties and values (USDOI BLM 2009a). 

Treatments would not result in long-term, substantial conflicts with existing land uses, changes in land use 

designations, or reductions in opportunity for right-of-way authorizations and development activities. Additionally, 

there would not be a substantial reduction in the opportunity for land tenure adjustments. 

 3.20.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

There are 45 land use authorizations within the riparian treatment areas, including a corral, Emergency Stabilization 

and Rehabilitation areas, fences, irrigated crops, land treatment areas, roads, a pipeline, a recreation site, a reservoir, 

spring improvements, a stream gauging station, study plots, a telephone line, and a transmission line. 

Treatments could temporarily limit access to land use authorizations in localized areas. Due to the lack of permanent 

features, exclusion areas, or designations, riparian treatments should not preclude future rights-of-way authorizations, 

development activities, or land tenure adjustments. 

Aspen Treatments 

There are 26 land use authorizations within the aspen treatment areas, including Emergency Stabilization and 

Rehabilitation areas, fences, a land treatment area, roads, a pipeline, and spring improvements. Should a land use 

authorization occur within a treatment area, there could be short-term exclusion from use during treatment and posttreatment restoration. 

Due to the lack of permanent features, exclusion areas, or designations, aspen treatments should not preclude future 

right-of-way authorizations, development activities, or land tenure adjustments. 

Pinyon-juniper Treatments 

There are 134 land use authorizations that are within pinyon-juniper treatment units, including study plots and roads, 

material sites, cattle guards, pipelines, corrals, Emergency Stabilization and Rehabilitation areas, fences, land 

treatment areas, reservoirs, spring improvements, a recreation site, a withdrawal area, a stream gauging station, 

powerlines, a trough, a water pumping plant, a well, and a windmill. Access restrictions may preclude access to 

mineral, rights-of-way, and land use authorizations during treatment and post-treatment restoration, but this 

preclusion would be temporary and would constitute a negligible impact. 

Sagebrush Treatments 

There are 83 land use authorizations within the sagebrush treatment areas, including a study plot and roads, material 

sites, cattle guards, pipelines, a withdrawal area, a stream gauging station, powerlines, Emergency Stabilization and 

Rehabilitation areas, fences, cropland, land treatment areas, a reservoir, spring improvements, a telephone line, a 

waterhaul, wells, and windmills. Fencing and other exclusion methods associated with this treatment area may 

preclude access to mineral resources, rights-of-way, and land use authorizations during treatment and post-treatment 

restoration, but this restriction would be temporary and would constitute a negligible impact. 

3 Bars Project Final EIS 3-404 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Due to the lack of permanent features, exclusion areas, or designations, sagebrush treatments should not preclude 

future right-of-way authorizations, development activities, or land tenure adjustments. 

3.20.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Because fire would not be available to reduce hazardous fuel loads and improve habitat, Alternative B may pose a 

greater long-term risk for wildfire than Alternative A due to the accumulation of fuels that could lead to loss of life 

and property. Without the use of prescribed fire, treatments could take longer, especially those needed to thin and 

remove Phase II and III pinyon-juniper stands, and the public may be restricted from accessing treatment sites for 

longer periods than if fire could be used. 

There could be temporary access restrictions from treatments, but treatments would not preclude future land use 

authorizations within the project area, and would not conflict with county and BLM land use objectives. Because up 

to 6,350 acres could be treated annually, the BLM would have to closely coordinate activities with landowners within 

the project area and the public to ensure that landowner property and the public are not harmed by treatments. 

3.20.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Because fire and mechanical methods would not be available to reduce hazardous fuel loads and improve habitat, 

Alternative C would pose a greater long-term risk for wildfire than Alternatives A and B due to the accumulation of 

fuels that could lead to loss of life and property. Without the use of fire and mechanical methods, treatments would 

take longer, especially those needed to thin and remove Phase II and III pinyon-juniper stands, restore lands 

dominated by cheatgrass and other noxious weeds and other invasive non-native vegetation, or to restore stream 

channels. Thus, the public may be restricted from accessing treatment sites for longer periods than if fire and 

mechanical methods were used. 

There could be temporary access restrictions from treatments. Treatments would not preclude future land use 

authorizations within the project area, and would not conflict with county and BLM land use objectives. Because 

about 3,250 acres could be treated annually, the BLM would have to closely coordinate activities with landowners 

within the project area and the public to ensure that landowner property and the public are not harmed by treatments. 

3.20.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects to land use and access from 3 Bars Project treatments as no treatments would be 

authorized under this alternative. The BLM would not take actions to reduce wildfire risk, so there would be no shortterm access restrictions. 

3.20.3.4 Cumulative Effects 

The CESA for land uses is the 3 Bars Project area (Figure 3-1). Past and present actions that have influenced land use 

and access in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.20.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Permanent features or exclusion areas associated with the Mount Hope Project and future land development actions, 

in combination with 3 Bars Project activities, could impact future right-of-way authorizations, development activities, 

and land tenure adjustments, and conflict with Eureka County and BLM land use objectives. These effects would be 

greatest under Alternative A. 

3 Bars Project Final EIS 3-405 October 2016 
LAND USE AND ACCESS 

Catastrophic wildfire can cause extensive burns in vegetation, particularly during drought conditions when soils and 

vegetation are dry. Treatments should reduce the incidence and severity of wildfires. Based on past acreage burned by 

wildfire, an estimated 84,000 acres would burn in the CESA during the next 20 years. Wildfires could adversely 

affect life and property, access, and resource use, on or near the 3 Bars Project area. 

The BLM is proposing to treat about 127,000 acres on the 3 Bars Project area, and about 15,000 acres under current 

and future authorizations, to restore ecosystem health. 3 Bars Project treatments, and potential short-term access 

restrictions, could occur on about 17 percent of the CESA under Alternative A. There would be no permanent features 

or exclusion areas associated with 3 Bars Project actions. 

3.20.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on land use and access 

would be similar to those described under Alternative A. By not using fire on the 3 Bars Project area, there would be 

no land access restrictions associated with use of prescribed fire and wildland fire for resource benefit on several 

thousand acres annually within the 3 Bars Project area. However, by not conducting fire treatments to reduce the risk 

of wildfire, the potential for wildfire to adversely affect life and property, access, and resource use on or near the 3 

Bars Project area would be greater than under Alternative A. 

3 Bars Project treatments and potential short-term access restrictions would occur on about 63,000 acres, or about 8 

percent of the CESA under Alternative B. There would be no permanent features or exclusion areas associated with 3 

Bars Project actions. 

3.20.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on land use and access 

would be similar to those described under Alternative A. Under Alternative C, less effort would be spent by the BLM 

on treatments to conduct hazardous fuels and habitat improvement projects to reduce wildfire risk and improve the 

health and resiliency of the vegetation than would occur under Alternatives A and B. By not being able to use 

mechanical methods and fire, the BLM would treat fewer acres to reduce hazardous fuels, create fire and fuel breaks, 

remove downed wood and slash, control noxious weeds and other invasive non-native vegetation, and improve 

vegetation health and condition to make it more resilient to wildfire. Thus, the potential for wildfire to adversely 

affect life and property, access, and resource use on nor near the 3 Bars Project area would be greater than under 

Alternatives A and B. 

3 Bars Project treatments, and potential short-term access restrictions, would occur on about 32,000 acres, or 4 

percent of the CESA under Alternative C. There would be no permanent features or exclusion areas associated with 3 

Bars Project actions. 

3.20.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on land use and access 

would be similar to those described under Alternative A. Under Alternative D, there would be no cumulative effects 

on land use and access from 3 Bars Project treatments as no treatments would be authorized under this alternative. 

The BLM could create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow 

the spread of noxious weeds and other invasive non-native vegetation using ground-based and aerial application 

methods of herbicides, especially cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a 

3 Bars Project Final EIS 3-406 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

large-scale wildfire under current and reasonably foreseeable future authorized actions, but on a very limited acreage 

(about 1,500 acres annually), under existing and likely future authorizations. Any future authorizations would undergo 

environmental review before authorization. There would be potential short-term access restrictions on about 0.2 

percent of the CESA under Alternative D. 

3.20.3.5 Unavoidable Adverse Effects 

There could be temporary access restrictions from treatments. Treatments would not preclude future land use 

authorizations on the project area, and would not conflict with BLM land use objectives. The BLM would closely 

coordinate activities with landowners on the project area and the public to ensure that they are not harmed by 

treatments. 

3.20.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

There could be temporary access restrictions from treatments. Treatments that reduce the risk of future catastrophic 

wildfire through fuels reduction, however, would improve ecosystem resilience and sustainability and reduce the risk 

of life and property and public resources on or near the 3 Bars Project area from catastrophic wildfire. 

3.20.3.7 Irreversible and Irretrievable Commitment of Resources 

There would be no irreversible or irretrievable commitment of resources associated with land use and access. 

3.20.3.8 Significance of the Effects under the Alternatives 

Impacts to land use and access from actions under all the alternatives, including the construction and operation of the 

Mount Hope Project and other oil, gas, geothermal, and other potential development projects within the CESA, would 

not be significant. Under the Federal Land Policy and Management Act, public lands are managed for multiple 

resources, including livestock grazing, recreation and other public uses, and mining and other resource development. 

As noted in the Shoshone-Eureka RMP ROD, livestock grazing, mineral development, land disposal, and utility 

corridor designations are authorized on lands within the CESA. Thus, the 3 Bars Project and other reasonably 

foreseeable future actions within the CESA 1) would not conflict with existing land uses and current land use 

authorizations; 2) would not cause a substantial change in land use designations; 3) would not cause a substantial 

reduction in opportunity for rights-of-way authorizations and development activities; and 4) would not cause a 

substantial reduction in the opportunity for land tenure adjustments. 

3.20.4 Mitigation 

No mitigation measures are recommended for land use and access. 

3.21 Recreation 

3.21.1 Regulatory Framework 

The BLM’s Shoshone-Eureka RMP provides the primary regulatory framework for management of recreational

opportunities within the project area since nearly all lands within the area are administered by the BLM (USDOI 

3 Bars Project Final EIS 3-407 October 2016 
RECREATION 

BLM 1987a). The Battle Mountain District Office is in the process of updating its RMP, and the updated RMP will 

combine the Shoshone-Eureka and Tonopah planning areas. BLM lands within the project area are managed “to 

encourage safe, public access and recreational use of public lands while ensuring protection of important resource 

values.” 

There are two WSAs in the study area, Roberts Mountains WSA and Simpson Park WSA. These WSAs are discussed 

in more detail in Section 3.22, Wilderness Study Areas and other Special Management Areas. There are no Special 

Recreation Management Areas designated within the project area. 

All BLM lands and recreational uses are managed as Extensive Recreation Management Areas. Extensive Recreation 

Management Areas are areas where management consists primarily of providing basic information and access. 

Dispersed recreation occurs in Extensive Recreation Management Areas, and visitors have the freedom of recreational 

choice with minimal regulatory constraints. Significant public recreational issues or management concerns are limited 

in these areas, and nominal management suffices (USDOI BLM 2007c:3-72). The Shoshone-Eureka RMP indicates 

that the BLM should “provide dispersed recreational opportunities” (with minimal facilities to support such activities 

and protect sensitive resources) within Extensive Recreation Management Areas. 

In addition to recreational guidance provided in the BLM RMP, BLM Manual 6280, Management of National Scenic 

and Historic Trails and Trails under Study or Recommended as Suitable for Congressional Designation, provides 

guidance on management of the Pony Express National Historic Trail, and both Eureka County and the Nevada 

Statewide Comprehensive Outdoor Recreation Plan provides information, recommendations, and guidance related to 

the provision and management of statewide recreational opportunities (Eureka County 2010, Nevada Division of State 

Parks 2010, USDOI BLM 2012m). 

3.21.2 Affected Environment 

3.21.2.1 Study Methods and Study Area 

Sources of recreational-related information used in this EIS include federal, state, and local land management plans 

(with recreational elements), visitor and activity-specific use estimates, published literature and studies, including the 

Mount Hope Project EIS (USDOI BLM 2012b), and personal communications with BLM staff. The proposed action 

and alternatives were then compared to these existing conditions to determine the potential for and expected severity 

of conflict with existing and planned recreational uses of the project area. 

The study area for the assessment of direct and indirect effects for recreation is the 3 Bars Project area. The 

cumulative effects study area extends 15 miles from the project area boundary (Figure 3-1). 

3.21.2.2 Recreation Activities and Use Levels 

From October 2009 through September 2011, the BLM estimated that recreational use in the Mount Lewis Field 

Office planning area accounted for approximately 229,000 visitor days, of which dispersed use accounted for about 

164,000 days (72 percent; USDOI BLM 2012m). Developed recreation generally occurs at constructed and/or 

specifically designated recreational sites and areas, while dispersed recreational use occurs away from these 

constructed/designated recreational sites and areas. It is unknown how much of this use occurred within the study 

area, though BLM staff describe project area use levels as low (around 100 visitors on a typical day across the study 

area, though the number of visitors can frequently be much lower and occasionally higher), and typical of more 

3 Bars Project Final EIS 3-408 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

remote, rural areas. While most of this use is likely from locals, a portion is also from visitors from other parts of the 

state, as well as from out-of-state visitors. 

The most common recreational activities in the project area include hunting, fishing, wildlife viewing, off-highway 

vehicle use, horseback riding, sightseeing, mountain biking, hiking, and rock collecting (USDOI BLM 2012m, o). 

This range of recreational opportunities is possible because most BLM lands within the project area are open and 

accessible to public use via roads and trails. In most cases, activity-specific use estimates are not available for the 

study area. 

There are a variety of hunting opportunities within the study area and region. Common species hunted include mule 

deer, pronghorn antelope, mountain lion, rabbits, Greater sage-grouse, chukar partridge, quail, mourning dove, and 

waterfowl. Big game hunt statistics for desert bighorn sheep, pronghorn antelope, and mule deer for the hunt units that 

are within or that overlap the analysis area are shown in Table 3-60. The hunt unit statistics reflect the average 

number of animals harvested in each unit. This is a result of the statistics being divided by multiple hunt unit 

groups provided in the NDOW harvest data. In addition, 172 elk hunting tags were issued and 72 elk were killed in 

2011, for hunt units 161, 162, 164, 171, and 173 combined (NDOW 2012f).

Fishing use within the 3 Bars Project area occurs primarily along Pete Hanson Creek, Birch Creek, Roberts Creek, 

and in the Tonkin Reservoir. The Roberts Creek Reservoir and Vinini Creek are no longer fishable and JD Ponds and 

Denay Creek are on private lands with restricted access. These creeks and other water bodies have trout and other 

sport fisheries that are popular with locals and visitors. Table 3-61 displays annual average use estimates for creeks 

and water bodies in the study area (NDOW 2012f).

There are very few special recreational permits given out by the Mount Lewis Field Office for recreational activities 

within the project area. While the BLM permits occasional hunting related outfitting/guiding services that may occur 

in the project area, the primary annual permit is for XP Rides to conduct an organized ride on the Pony Express 

National Historic Trail (Figure 3-51). This annual event, typically conducted in June, involves re-riding the entire, 

multi-state length of the Pony Express National Historic Trail. Additionally, there is informal recreational use of the 

Pony Express National Historic Trail through visits by individual users or small groups (Kreutzer 2013). 

3.21.2.3 Recreation Management and Use Areas 

BLM lands without special designations within the project area are currently managed as an Extensive Recreation 

Management Area. Dispersed types of recreation are the predominate uses within the project area, as well as the 

surrounding rural region. Since dispersed uses tend to require minimal constructed or developed facilities, there are 

few developed or designated recreational sites within the project area. There is an existing network of roads and trails 

that provide access to dispersed recreational opportunities throughout the study area (USDOI BLM 2012m, o).

Roberts Mountains are one of the primary recreational destinations within the project area. The Roberts Mountains 

have several creeks (Roberts, Pete Hanson, and Tonkin Springs) that are popular fishing spots for both locals and 

visitors. Other recreational opportunities in the Roberts Mountains include hiking, camping, wildlife viewing, and 

hunting. This area and its diverse opportunities serve as an important local recreational asset given the proximity of 

the Roberts Mountains to nearby towns in Eureka County and the existing network of access roads and trails 

throughout the study area (USDOI BLM 2012m, o).

3 Bars Project Final EIS 3-409 October 2016 
Battle

Mountain

District

Project Area

Mount

Lewis

Field

Office

Elko Battle

Mountain

Reno

Las

Vegas

Figure 3-51

Cultural Resource Inventory

3 Bars Ecosystem and

Landscape Restoration Project

278

50

Eureka

Elko County

Eureka County

Lander County

Eureka County

Pony Express Trail

0 1 2 3 4 5 10

Miles

0 1 2 3 4 5 10

Kilometers

Legend

Pony Express Trail

Cultural Resource

Inventory

3 Bars Project Area

Pinyon-juniper

Treatment Area

Sage Treatment Area

Aspen Treatment Area

Riparian Treatment Area

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or completeness of these data for individual or aggregate use with other data.

Original data were compiled from various sources. This information may not meet National Map Accuracy Standards.

This product was developed through digital means and may be updated without notice.

Source: BLM 2012g.

United States Department of the Interior

Bureau of Land Management

Mount Lewis Field Office

50 Bastian Rd.

Battle Mountain, NV 89820

(Prepared by MLFO - 09/08/14)
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

TABLE 3-60 

2011 Harvest by Hunt Unit and Group

Desert Bighorn Sheet Pronghorn Antelope Mule Deer

Hunt 

Unit / 

Group

Tags Number 

Killed

Percent 

Success

Hunt 

Unit / 

Group

Tags Number 

Killed

Percent 

Success

Hunt Unit / 

Group Tags Number Killed

Percent 

Success

161 11 9 82 065

41 24 59

065 58 43 74

162-163 4 4 100 142 141 69

144 142 19

141

151 105 70

143 34

143 144 90

151 145 26

152 Management 

Area 14 554 238 43

154 151 77

155 152 70

131

76 52 68

154 41

145 155 47

163 Management 

Area 15 548 235 43

164 161 97

161 27 24 89 162 73

162 163 26

164 10

Management 

Area 16 501 206 41

Source: NDOW (2012f).

TABLE 3-61 

Annual Average Fishing Use in the Study Area (1980-2010)

Creek/Water Body Annual Average Number of 

Anglers (minimum/maximum)

Annual Average Angler Days 

(minimum/maximum)

Roberts Creek 42 (0 / 106) 126 (0 / 606)

Roberts Creek Reservoir 3 (0 / 71) 3 (0 / 71)

Pete Hanson Creek 4 (0 / 30) 7 (0 /60)

Vinini Creek 1 (0 / 20) 1 (0 / 20)

JD Ponds 10 (0 / 56) 24 (0 / 184)

Denay Creek 3 (0 / 46) 7 (0 / 184)

Tonkin Reservoir 90 (11 / 463) 220 (11 / 1,246)

Source: NDOW (2012g).

The Pony Express National Historic Trail crosses the project area (Figure 3-51). This national trail follows the 

historic route used by the Pony Express and links St. Joseph, Missouri, to Sacramento, California. While the Pony 

Express was only in operation for 18 months (April 1860 through October 1861), it has come to represent the Old 

West in each of the eight states (California, Colorado, Kansas, Missouri, Nebraska, Nevada, Utah, and Wyoming) it 

passes through. The section of the trail that passes through the project area is part of the Overland Canyon to Simpson 

Park Station High Potential Segment of the Pony Express National Historic Trail. The National Trails System Act 

defines a High Potential Segment as “those segments of a trail which would afford high quality recreational

experience in a portion of the route having greater than average scenic values or affording an opportunity to 

vicariously share the experience of the original users of a historic route.” The BLM has direct management 

3 Bars Project Final EIS 3-411 October 2016 
RECREATION 

responsibility and authority for the trail within its jurisdictional boundaries, and the USDOI National Park Service is 

the trailwide administrator for programmatic, planning, and co-ordination purposes (USDOI National Park Service 

1999, 2012, Kreutzer 2013). 

3.21.3 Environmental Consequences 

3.21.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on information in the AECC and public scoping comments the following concerns regarding recreation were 

identified and are discussed in this impact analysis. 

 Off-highway vehicle use could damage and/or jeopardize completed restoration work. 

 Treatments could promote additional off-highway vehicle use and new routes. 

 If recreational opportunities are lost as a result of restoration efforts, there could be associated impacts to the 

local and regional economy. 

 Roads and livestock facilities near roads are contributors to fire. 

These and other recreational-related issues (e.g., access, visitor experiences, etc.) were considered during the 

evaluation of consequences that could reasonably be anticipated under the proposed restoration effort. 

3.21.3.2 Significance Criteria 

The proposed action and alternatives were assessed within the existing recreation management frameworks that guide 

recreational opportunities in the 3 Bars ecosystem and vicinity, including the Shoshone-Eureka RMP, Eureka County, 

Nevada Division of State Parks, and other relevant plans. For purposes of this assessment, the proposed action and 

alternatives are considered to have a significant effect on recreation if they meet one or more of the following 

significance criteria: 

1. The action conflicts with formally established recreation and other appropriate public uses (i.e., would the 

action limit and/or restrict existing and/or future recreation and public use?). 

2. The action substantially degrades or reduces the quantity or quality of the area available for existing or 

future recreational opportunities (i.e., would the action degrade visitor satisfaction with and/or overall 

quality of the recreational experience?). 

3. The action results in the permanent damage or impairment of a unique, nationally significant recreational

resource (i.e., would the action result in the loss of a recreational resource of regional and/or national 

importance?). 

Impacts to historic trails would be considered significant if the proposed action or alternatives resulted in any of the 

following: 

1. Changes to the landscape adjacent to an historic trail that cannot be mitigated to a BLM Class II VRM

objective, as outline in BLM Instructional Memorandum NV-2004-004. 

2. Permanent or long-term limitation of use of an identified portion of a national historic trail. 

3 Bars Project Final EIS 3-412 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.21.3.3 Direct and Indirect Effects 

3.21.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

In general, the potentially affected lands in the 3 Bars ecosystem do not offer unique recreational opportunities 

(WSAs are addressed separately in Section 3.22). The Pony Express National Historic Trail is the only recreational

resource of national significance within the 3 Bars Project area. However, these lands do play an important role in the 

local provision of recreational opportunities, with a focus on dispersed uses (e.g., off-highway vehicle use, hunting, 

fishing, wildlife observation, etc.). As such, the restoration actions proposed under each of the alternatives would not 

affect developed or other areas of highly concentrated recreational use. Instead, the proposed actions would primarily 

influence undeveloped recreational opportunities and the users of those areas. Given the size of the 3 Bars Project area 

(about 750,000 acres) and relatively low levels of use (about 100 visitors on a typical day), the proposed restoration 

treatments would affect only a small number of visitors. 

The 3 Bars ecosystem area is managed as an Extensive Recreation Management Area and open to multiple types of 

dispersed recreational activities. Per the proposed restoration actions, recreation and specifically off-highway vehicle 

use, would continue to be allowed throughout the 3 Bars Project area, although periodic closures of specific areas are 

anticipated to help the restoration effort and minimize human health risks. Under all treatment methods, the size of 

closed areas and duration of the temporary closures would be the most pronounced and potentially significant effects 

on recreation. 

Adverse Effects 

There would be some short-term scenic degradation, as well as distractions to users (e.g., noise from machinery), 

from treatments. Some areas would be off-limits to recreational activities as a result of treatments, for periods ranging 

from a few hours to days, or even 1 full growing season or longer, depending on the treatment. In most cases, 

recreationists would be able to find alternative sites offering the same amenities, although a lessened experience could 

result from more concentrated use in these alternative sites. 

In the short-term (less than 3 years) general recreational impacts would be negative and include the following: 

 Temporary closure and loss of recreational uses of dispersed areas during treatment implementation. 

 Disturbance from workers, equipment, and/or movement of people and equipment associated with 

treatments. 

 Temporary displacement of wildlife for both consumptive (e.g., hunting, fishing, etc.) and non-consumptive 

(e.g., wildlife viewing, photography, etc.) users. 

The temporary closure of specific areas would be the most direct effect on recreation during the implementation of 

treatments proposed under each of the alternatives. Visitors would be restricted from accessing the treatment areas 

during implementation and possibly during post-implementation. This would generally degrade the visitor experience 

(in particular for those visitors who intended to visit an area closed for treatment), and displace visitors to other 

dispersed use areas within the 3 Bars ecosystem and/or other regional areas. 

In addition to displacing visitors, the proposed treatments could also temporarily displace wildlife. However, this 

could increase the availability of wildlife in adjacent areas that do not have access or public use restrictions. While 

both visitors and wildlife could be displaced during the proposed treatments, there could also be more wildlife-related 

3 Bars Project Final EIS 3-413 October 2016 
RECREATION 

opportunities in areas not affected by closures (e.g., a higher density of game animals in non-treatment areas). So, 

while temporary displacement of visitors and wildlife could be considered a negative effect, there could also be a 

related beneficial impact to wildlife-dependent recreational opportunities and experiences in nearby areas not affected 

by the treatments. 

Recreational users of the Pony Express National Historic Trail could potentially be impacted by treatment activity and 

noise during implementation of the treatments and the visual aspects of the recreational experience of the trail may be 

affected in the short-term until vegetation recovers to the point where it no longer appears that it has been 

manipulated. 

Beneficial Effects 

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 other invasive non-native vegetation. 

 A reduction in the risk of a large-scale, catastrophic wildfire. 

Improved habitat and associated wildlife and a reduction in noxious weeds and other invasive non-native vegetation 

should contribute to an enhanced recreational experience in the 3 Bars ecosystem. Improved fish and game habitat 

and populations should provide additional and/or improved hunting and fishing opportunities. Improved habitat 

should enhance the overall scenic quality of the area, while removal of noxious weeds and other invasive non-native 

vegetation would reduce the likelihood of visitors being harmed or inconvenienced by these plants, and could 

influence the visitor experience. Additionally, a reduction in wildfire risk should lead to fewer temporary closures to 

protect human safety (i.e., fewer public access constraints from fires). 

3.21.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Adverse Effects 

Short-term effects would generally be negative, and include temporary closures or lack of access to fishing sites, 

visitor displacement (to other fishing sites), and potential degradation in the visitor experience, both from the 

temporary closures and visual disturbances associated with the various treatment methods. 

While temporary closures would be likely during manual treatments, this type of treatment would result in the fewest 

impacts to recreation. Since manual treatments tend to be most feasible on smaller-scales, only small areas would be 

subject to temporary recreation and public use closures. During manual treatments, there could be some distractions 

from additional staff and equipment, though given the scale of these efforts, these distractions would not likely overly 

degrade scenic quality. 

Mechanical treatments would be used to restore stream channel functionality. Activities at treatment sites could 

distract visitors, and large equipment used to restore stream channels could be heard for several miles. Direct habitat 

3 Bars Project Final EIS 3-414 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

alteration or loss of habitat could occur in Lahontan cutthroat trout and other game fish streams (Birch, Pete Hanson, 

and Willow Creeks) and cause reduced fishing opportunities for fishermen. 

Small, temporary exclosure fencing could be used to exclude livestock, wild horses, and other wild ungulates from 

riparian zone treatment areas for a minimum of 2 growing seasons. Although visitors could likely scale fences to 

access treatment sites, if desired, fences could discourage recreational use of the area. 

Beneficial Effects 

Treatments would improve the aesthetic and visual qualities of recreational areas for hikers, birdwatchers, and other 

public land users; reduce the risk of recreationists coming into contact with noxious weeds and other invasive nonnative vegetation; increase the abundance and quality of plants harvested from public lands; and improve habitat for 

fish and wildlife sought after by fishermen and hunters. 

Given the location of proposed riparian treatments along stream corridors and along other waterbodies, in particular in 

several areas that are popular for fishing, the effects of riparian projects on recreation would likely be more 

pronounced for anglers compared to other visitors. The enhancements to riparian zones and game fish habitat would 

also improve the recreational experience (e.g., cohesive visual landscape, healthier fish populations and potential 

catch rates, etc.). 

Removal of pinyon-juniper in the riparian zone for all treatments groups, except the Black Spring and Denay Pond 

groups, would enhance its capabilities to function as a fire or fuel break. These treatments would reduce the spread of 

future wildfires on public lands used for recreation. As a result, recreationists would be provided with safer 

conditions, and there would be less of a chance that a wildfire would destroy a large acreage of lands used for 

recreation. Severe wildfires are capable of causing damage to recreational resources over large areas that subsequently 

require long periods of time for recovery. In addition, treatments that reduce the risk of wildfire would reduce the 

likelihood of recreationists being displaced from their favorite hunting, fishing, and camping sites by wildfires. 

Aspen Treatments 

Aspen treatments could result in wildlife habitat enhancements that have the potential to beneficially influence the 

recreational experience in the long-term in these areas. Aspen stands are unique, and quite beautiful in the fall when 

the leaves change colors, and efforts to preserve and enhance these stands would benefit sightseers. 

Most pinyon-juniper removal would occur near roads to promote development of fire breaks near aspen stands. Fire 

breaks would help to protect aspen stands, and other woodland and rangeland habitat from wildfire. Protection of 3 

Bars Project resources would be beneficial to users of these resources, and reduce the amount of area that would be 

closed to recreational users due to emergency stabilization and rehabilitation of burned areas. 

Pinyon-juniper Treatments 

Adverse Effects 

Pinyon-juniper treatment projects would affect off-highway vehicle use, hunting, and other dispersed uses that occur 

in the 3 Bars ecosystem. Additionally, several of the pinyon-juniper treatment projects are proposed along creeks that 

provide fishing opportunities. Anglers who use these creeks would be affected by the treatments. In the short-term, 

3 Bars Project Final EIS 3-415 October 2016 
RECREATION 

temporary closures, distractions and changes in the scenic integrity of the landscape, and degradation of the 

experience would negatively affect recreational users. 

Recreationists likely would not be excluded from Phase I areas where pinyon-juniper removal is primarily done using 

manual methods, especially if the treatments do not result in substantial soil disturbance and reseeding is not 

necessary. Low-intensity treatments such as thinning would generally be less restrictive to recreational uses than 

treatments such as discing. People recreating in nearby areas would be able to hear the motorized equipment and 

could be exposed to some exhaust smells, but these effects would last only as long as the treatment itself. After the 

completion of treatments, vegetation would be absent from large portions of the landscape and bare soil would be 

exposed, making the site less desirable for recreation. The use of heavy machinery would disrupt the treatment area, 

breaking limbs and disturbing soil. It is also likely that some large debris would be left behind, creating obstacles for 

certain types of recreational uses (USDOI BLM 2007c:4-120). 

Prescribed burns would require the closure of burn areas to visitors during burn activities. People recreating in nearby 

areas would be able to see and perhaps smell smoke. The potential for smoke inhalation could result in some health 

risks to these users (see Section 3.26, Human Health and Safety), depending on their vicinity and position (i.e., 

upwind or downwind) in relation to the fire. Because smoke impairs visibility, views of the landscape could be 

blocked during burning. These effects would reduce the recreational experience, but would typically last only as long 

as the burn treatment itself. After a fire, the burned area would appear blackened, and some residual vegetation would 

be charred, making the area undesirable for most recreational uses for a period of 1 or more years. Four-wheel drive 

vehicles and other off-highway vehicles could be excluded from areas treated with fire to minimize damage to these 

sites while they revegetate. Low impact uses such as camping and hiking would generally not be restricted, but it is 

likely that burned areas would be avoided by users engaging in these types of activities. Visitation to a prescribed 

burn area would decline drastically or cease altogether in the short-term (USDOI BLM 2007c:4-120). 

As a result of thinning and removal treatments, the number of pinyon pine and juniper trees within woodland products 

harvest areas would be reduced. Treatments would affect approximately 26 percent of the total designated woodland 

products harvest area, including Christmas tree, green wood, and commercial and public pine nut harvest areas. 

Removal of pinyon pines and juniper from these areas would eliminate or limit the ability to harvest woodland 

products there, although most of the project area would not be affected. 

Beneficial Effects 

Pinyon-juniper treatments would improve woodland health, productivity, and functionality; slow the expansion of 

pinyon-juniper into sagebrush and riparian plant communities; increase pine nut production; and reduce the risk of 

catastrophic wildfire, to the benefit of recreational users. Treatments could also lead to increased forage for wildlife, 

and water for fish, and increase the capacity of the land to support game fish and wildlife and increased hunting and 

fishing opportunities. However, these gains may not be realized for a decade or more, or until treated areas have fully 

recovered. 

The BLM allows firewood and Christmas tree harvesting, greenwood cutting, and pine nut gathering on the 3 Bars 

Project area, and would continue to do so in the future in treatment and non-treatment areas. The BLM would also 

allow the public to cut live pinyon-juniper trees in areas where pinyon-juniper trees are tightly spaced and harming the 

growth of herbaceous vegetation and sagebrush, in order to help slow pinyon-juniper encroachment into riparian, 

aspen, and sagebrush habitats. These actions would promote recreation, by promoting a healthier woodland and 

rangeland that in turn would promote woodland recreational activities, healthy populations of fish and game, and an 

3 Bars Project Final EIS 3-416 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

enhanced scenic quality. By thinning and removing pinyon-juniper, competition among remaining trees for water and 

other resources would decline, and the remaining pinyon pines should be able to produce more nuts for use by the 

public. Downed logs would also be placed in streams to benefit game fish habitat. 

Fuels reduction treatments would reduce the severity of future wildfires on public lands used for recreation. As a 

result, recreationists would be provided with safer conditions, and there would be less of a chance that a wildfire 

would destroy a large acreage of lands used for recreation. Wildfires are capable of causing damage to recreational 

resources over large areas that subsequently require long periods of time for recovery. In addition, treatments that 

reduce the risk of wildfire would reduce the likelihood of recreationists being displaced from their favorite hunting, 

fishing, and camping sites by wildfires (USDOI BLM 2007c:4-122). 

Sagebrush Treatments 

Adverse Effects 

Recreationists likely would not be excluded from areas such as those in the Alpha Unit group and Table Mountain 1 

and Three Corners units, where Phase I and Phase II pinyon-juniper would be thinned to promote forb, grass, and 

sagebrush development using manual and mechanical equipment. 

Prescribed fire, along with other treatment methods, could be used to manage noxious weeds and other invasive nonnative vegetation on the West Simpson Park Unit. Recreationists would be excluded from prescribed fire areas during 

the burn, but would be allowed into the burn area when the BLM deems it is safe for re-entry. Treatment sites would 

be posted to inform the public of any access restrictions. During treatments, there would be some scenic degradation 

and distractions to users (noise from machinery and crews), but given the small amount of area treated annually, these 

effects should be minor. 

Biological control has been identified for use on the 3 Bars Project area. Grazing may be used to maintain firebreaks 

and to help reduce wildfire risk in this area. Grazing can contribute to the spread of noxious weeds and other invasive 

non-native vegetation through preferential grazing of native vegetation over weeds, and by movement of noxious 

weeds and other invasive non-native vegetation into uninfested areas in livestock feces (USDOI BLM 2009b). The 

spread of noxious weeds and other invasive non-native vegetation could degrade recreational resources on the 3 Bars 

Project area. 

Much of the focus of treatments on sagebrush treatment units to improve habitat for fish and game species of 

importance to sportsmen. Manual and mechanical treatments could result in increased water runoff and erosion, and 

spills of fuels and lubricants, to the possible detriment of game fish populations in these creeks. 

Beneficial Effects 

Treatments that restore native vegetation and natural fire regimes and ecosystem processes would be beneficial to 

recreationists. Treatments would 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 after by fishermen and hunters and the recreational experience through 

improved scenery and increased populations of fish and game species. 

Over 85 percent of the acres treated would occur where the BLM has determined that pronghorn antelope habitat is 

declining, nearly 65 percent of acres treated would occur where Greater sage-grouse habitat is declining, and 45 

3 Bars Project Final EIS 3-417 October 2016 
RECREATION 

percent of the acres treated would occur where mule deer habitat is declining. Manual and mechanical treatments 

would create a grass-shrub mosaic favored by Greater sage-grouse, pronghorn antelope, mule deer, and other wildlife 

that could be harvested by hunters. 

Removal of pinyon-juniper through thinning, and seeding and planting, should enhance the visitor experience. By 

removing pinyon-juniper to promote the reestablishment of grasses, forbs, and sagebrush, habitat for wildlife and 

game species would improve (Lauer and Peek 1976, Willms et al. 1981, Payne and Bryant 1998). 

Efforts to restore areas dominated by non-native vegetation would make these areas more visually appealing and 

better suited for fish and wildlife, and would reduce the risk of future wildfires, all of which benefit the recreationist. 

3.21.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The types and magnitude of effects for manual, mechanical, and biological control treatments would be similar 

between Alternatives A and B. Because the BLM would not be able to use fire, however, there would be none of the 

adverse effects associated with this treatment type. In particular, there would be no harm to recreationists from 

prescribed fire and wildland fire for resource benefit. However, with greater reliance on mechanical methods, there 

may be greater disturbance to the public from the use of mechanical equipment than would occur under Alternative A. 

Acres and types of wetland and riparian habitat treated would be similar to Alternative A, and the BLM would use 

small, temporary exclosure fencing to protect treatment areas. However, the BLM would not use fire to slow pinyonjuniper encroachment into sagebrush and riparian communities, or treat Phase II and III pinyon-juniper to improve 

woodland health and reduce hazardous fuels. Thus, there would be fewer gains in wildlife forage production outside 

of riparian zones, and greater risk of habitat loss from catastrophic wildfire, under this alternative than under 

Alternative A, to the detriment of recreational resources and the public. 

Some treatments to improve historic pinyon-juniper communities would occur, which could benefit future pine nut 

harvest in these areas long-term, but the acreage benefiting from these treatments would be substantially less than 

under Alternative A. 

3.21.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would only be able to use manual and classical biological control methods to treat 

vegetation. The consequences of not using fire under Alternative C would be the same as those discussed under 

Alternative B. 

Effects to visitors from noise and disturbance associated with mechanical treatment equipment would not occur under 

this alternative. By not being able to use mechanical equipment, however, the BLM would also not be able to conduct 

stream engineering and restoration, except on a limited basis on only a few stream miles; control noxious weeds and 

other invasive non-native vegetation, except on very small areas where this vegetation can be hand pulled or 

controlled using hand tools; reseed and replant restoration sites, except for small areas where shrubs and other 

vegetation would be planted by hand; or create fire and fuel breaks to reduce the risk of fire spread, except near 

existing roads or aspen stands, or along a few miles of stream. As a result, there would be less improvement in 

vegetation and water quantity and quality, and more risk of catastrophic wildfire, than under Alternatives A and B, to 

the detriment of the recreational user. 

3 Bars Project Final EIS 3-418 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

The BLM has not identified areas where it would use classical biological control on the 3 Bars Project area. The use 

of biological control agents would have few effects on recreational areas and visitors to public lands since they would 

be used on a limited number of acres and to specifically control undesirable species without disturbing desirable 

vegetation or the land. During the release of biological control agents, there would be some workers present that could 

cause a minor distraction to visitors in the area. 

Under Alternative C, the BLM would not substantially improve the native vegetation community nor stop the loss of 

important ecosystem components. As a result, the visitor use experience could decline long-term. 

3.21.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct or indirect effects on recreation from 3 Bars Project treatments as no treatments would be 

authorized under this alternative. Thus, long-term loss of recreational opportunities and deterioration in the visitor 

experience would be greatest under Alternative D. 

3.21.3.4 Cumulative Effects 

The CESA for recreation is approximately 2,599,851 acres and includes the 3 Bars Project area and the BLM visual 

resource management background distance zone (15 miles; Figure 3-1). This area was selected based on the 

anticipated increase in population and corresponding demand for recreational opportunities by residents in the project 

vicinity (e.g., Eureka, Battle Mountain, etc.), as well as the location of other nearby recreational resources (e.g., 

Hickison Petroglyph Recreation Site). Approximately 94 percent of the area is administered by the BLM and 6 

percent is privately owned. Past and present actions that have influenced land use and access in the 3 Bars ecosystem 

are discussed in Section 3.3.2.3.3.

3.21.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

In general, while there are locally important recreational resources in the CESA, the types of dispersed recreational

resources available in the area are not of regional or national significance except the Pony Express National Historic 

Trail, which has been Congressionally designated as a recreational resource. Recreational use within the CESA is thus 

likely to increase proportionally to changes in the regional population. As recreational use increases over time, there 

tends to be an inevitable increase in public demand for recreational opportunities and a corresponding increase in 

expectations about the quality of the recreational experience. The cumulative effects from the proposed 3 Bars 

Project, as well as past, present, and reasonably foreseeable future actions are considered within this context of 

increasing population and recreational demand, including potential changes in recreational resources and experiences. 

The BLM would continue ongoing management reviews to ensure proper livestock management and long-term 

success of treatments. The BLM would also continue to conduct wild horse gathers, AML reviews and adjustments, 

remove excess animals and use fertility control, improve water developments, and implement habitat projects. Efforts 

to better distribute livestock and wild horses across the rangeland should provide for a more natural visitor experience 

and reduce the potential for livestock/wild horse/visitor conflicts. 

The BLM could apply herbicides using ground-based methods under existing authorizations. These treatments would 

be small and have few visitor impacts. The BLM could also use aerial herbicide applications to control cheatgrass on 

several hundred or more acres annually on the West Simpson Park Unit. There could be short-term visitor access 

restrictions in treatment areas. However, the units consist of degraded lands of low recreational value. 

3 Bars Project Final EIS 3-419 October 2016 
RECREATION 

The population within southern Eureka County is projected to increase by 50 percent during construction and 

operation of the Mount Hope Project. With an increase in population in the CESA due to population growth, and 

employment opportunities such as the Mount Hope Project, the number of recreational users in the CESA should 

increase. Recreational users in the 3 Bars analysis area can spread noxious weeds and other invasive non-native 

vegetation that attaches itself to vehicles or to clothing or shoes, and can later cause new noxious weeds and other 

invasive non-native vegetation infestations, possibly impacting other land uses within the CESA. 

Land, mineral, oil, gas, geothermal, and other development would increase levels of land disturbance and spread of 

noxious weeds and other invasive non-native vegetation within the 3 Bars Project and nearby areas. Development 

would lead to additional human activity in the area, and possible degradation of other land uses within the analysis 

area. Past mining activities associated with the Atlas Gold Bar Mine degraded rangeland resources on about 1,300 

acres within the CESA. The proposed Mount Hope Project would disturb about 8,300 acres, and fencing would be 

used to restrict public access on an additional 6,000 acres. As noted in the Mount Hope Project EIS, mining could 

substantially alter the groundwater level near the mine pit, causing a drawdown in water that could affect surface 

water flows, groundwater levels, and vegetation on Roberts Mountains and in Kobeh Valley and Diamond Valley, to 

the detriment of native vegetation and fish and wildlife habitat (USDOI BLM 2012b:3-74 to 3-90). In addition, 

removal of Mount Hope would have an impact on the historic setting of the Pony Express National Historic Trail. The 

mountain is visible for miles and its removal will alter the character of the trail and the ability of recreationists to 

experience the trail as it existed in 1860-61. In addition, access would be virtually eliminated for a segment of the trail 

that passes within the mine boundary. The 3 Bars Project would not significantly add to this impact since none of the 

proposed treatments would further limit access to any portion of the trail within the 3 Bars Project Area. These effects 

could degrade the recreational experience within the CESA. 

Catastrophic wildfire can burn extensive areas of vegetation. Based on acreage burned by wildfires since 1985, an 

estimated 140,000 acres would be burned by wildfires in the CESA during the next 20 years. To reduce the risk of 

catastrophic wildfire and to restore the health and resiliency of native vegetation, the BLM would treat up to 127,000 

acres to reduce hazardous fuels. The BLM also proposes to treat hazardous fuels on an additional 15,000 acres under 

current authorizations in high to very high fire risk areas within the CESA. Recreational access to treatment areas 

could be restricted during the treatment period, and it is likely that the treated area would have few recreational

values, for several years after treatments. Over time, this reduction in fuels, however, would allow for more natural 

forage within the project area, benefiting game populations and hunting opportunities, and improve the health of 

pinyon-juniper stands, which could benefit nut production. In addition, treatments would reduce the risk of 

catastrophic wildfire, which would benefit native plant communities and fish and game. 

3 Bars Project treatments would occur on only about 5 percent of the CESA. Treatments would result in localized 

effects and would not substantially alter the availability of dispersed recreational opportunities in the CESA or larger 

region. However, by nature, many types of dispersed uses (e.g., off-highway vehicle use, hunting, wildlife viewing, 

etc.) require large tracts of undeveloped or little used natural areas. Actions that permanently alter and fragment the 

landscape (e.g., energy development, mining, land development, etc.), as well as similar unforeseen future actions, 

could eventually affect both the availability of dispersed use opportunities and experiences. 

3.21.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on recreation would be 

similar to those described under Alternative A. By not using fire, the amount of area disturbed by treatments would 

generally be smaller, and have less impact on fish and wildlife resources, and scenery, than other treatment methods. 

3 Bars Project Final EIS 3-420 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

However, fewer acres would also be treated to restore landscape health and habitat for fish and game, and reduce the 

risk of catastrophic wildfire, and would not likely offset the increased potential for more extensive and intense 

wildfires to occur in place of controlled burns on the 3 Bars Project area. 

About 63,000 acres of vegetation and 31 miles of stream would be disturbed from the 3 Bars Project, or only about 2 

percent of the CESA. Treatments would result in localized effects and would not substantially alter the availability of 

dispersed recreational opportunities in the CESA or larger region. Still, there would be a long-term net benefit from 

BLM treatments that would help to offset some of the adverse effects to recreational resources from other reasonably 

foreseeable future actions. Actions would provide more recreational opportunities for a growing population, but not to 

the extent as would occur under Alternative A. 

3.21.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on recreation would be 

similar to those described under Alternative A. By not being able to use mechanical methods there would be less 

disturbance to public from treatments compared to Alternatives A and B. Without mechanical methods, however, the 

BLM would be less able to reduce hazardous fuels, remove noxious weeds and other invasive non-native vegetation, 

thin and remove vegetation to encourage understory development, create fire and fuel breaks, and remove downed 

wood and slash. The risk of wildfire and its effects on recreation would likely increase, while there would be few 

benefits to fish and game, under this alternative compared to Alternatives A and B. 

About 32,000 acres of vegetation and 8 miles of stream would be disturbed from the 3 Bars Project, or only about 1 

percent of the CESA. Treatments would result in localized effects and would not substantially alter the availability of 

dispersed recreational opportunities in the CESA or larger region. Still, there would be a minor long-term net benefit 

from BLM treatments that would help to offset some of the adverse effects to recreational resources from other 

reasonably foreseeable future actions. Actions would provide more recreational opportunities for a growing 

population, but not to the extent as would occur under Alternatives A and B. 

3.21.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on recreation would be 

similar to those described under Alternative A. There would be no cumulative effects on recreation from 3 Bars 

Project treatments as no treatments would be authorized under this alternative. The BLM could create fire and fuel 

breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and 

other invasive non-native vegetation using ground-based and aerial application methods of herbicides, especially 

cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildfire under current 

and reasonably foreseeable future authorized actions, but on a very limited acreage (about 1,500 acres annually; less 

than 0.1 percent of the CESA). Thus, benefits to the recreating public would be substantially less under this 

alternative than under the action alternatives. 

3.21.3.5 Unavoidable Adverse Effects 

There would be some scenic degradation, as well as distractions to users (e.g., noise from machinery), from 

treatments. In addition, there would be some human health risks to recreationists associated with exposure to smoke 

from fire. Finally, some areas would be off-limits to recreational activities as a result of treatments. These effects 

would be localized and short-term. 

3 Bars Project Final EIS 3-421 October 2016 
RECREATION 

3.21.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

There would be some scenic degradation, as well as distractions to users (e.g., noise from machinery), from 

treatments. These effects would be localized and short-term. Treatments that restore native vegetation and natural fire 

regimes and other ecosystem processes would be beneficial to recreationists. Treatments would improve the aesthetic 

and visual qualities of recreational 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 

fishermen and hunters. These benefits would be long-term and improve the productivity of land resources and their 

ability to provide recreational values (USDOI BLM 2007c:4-250). 

3.21.3.7 Irreversible and Irretrievable Commitment of Resources 

There would be no irreversible or irretrievable commitment of recreational resources. Although there would be shortterm impacts to recreational resources from vegetation treatments, these impacts would not be irretrievable and could 

be reversed if restoration treatments were successful. 

3.21.3.8 Significance of the Effects under the Alternatives 

Under all the alternatives, direct and indirect effects of 3 Bars Project treatments, along with effects from other actions 

within the CESA, would not have a significant permanent conflict with formally established recreation and other 

appropriate public uses over the long-term. Public access to the Mount Hope Project would be limited until the mine 

was reclaimed, and there may be access restrictions in other areas with resource development. As discussed in the 

Mount Hope Project EIS and ROD, few permanent restrictions are anticipated from the mine project (USDOI BLM 

2012b:4-81) and there would be no permanent access restrictions associated with the 3 Bars Project. 

Under all the alternatives, direct and indirect effects of 3 Bars Project treatments would not result in long-term 

changes to the landscape adjacent to the Pony Express National Historic Trail that cannot be mitigated to a BLM 

Class II Visual Resource Management objective, as outline in BLM Instructional Memorandum NV-2004-004, or in 

permanent or long-term limitation of use of an identified portion of the trail. The BLM would follow guidance in 

BLM Manual 6280, Management of National Scenic and Historic Trails and Trails under Study or Recommended as 

Suitable for Congressional Designation, to ensure proper management of the Pony Express National Historic Trail 

(USDOI BLM 2012n). 

In the long-term, actions that would occur within the CESA would not significantly degrade or reduce the quantity 

or quality of the area that is available for existing or future recreational opportunities. 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 

(USDOI BLM 2012b:4-81). 

3.21.4 Mitigation 

No mitigation measures are recommended for recreation. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.22 Wilderness Study Areas, Special Management Areas, and 

Lands with Wilderness Character 

3.22.1 Regulatory Framework 

The BLM manages certain lands under its jurisdiction that possess unique and important historical, anthropological, 

ecological, biological, geological, and paleontological features. These features include undisturbed wilderness tracts, 

critical habitat, natural environments, open spaces, scenic landscapes, historic locations, cultural landmarks, and 

paleontological-rich regions. Special management is administered with the intent to preserve, protect, and evaluate 

these significant components of our national heritage. Most special areas are either designated by an Act of Congress 

or by Presidential Proclamation, or are created under BLM administrative procedures. 

The National Landscape Conservation System is the primary management framework for these specially designated 

lands. The National Landscape Conservation System was created in June 2000 by the BLM to bring into a single 

system some of the agency’s premier areas. National Landscape Conservation System designations include National 

Monuments, National Conservation Areas, Designated Wilderness and WSAs, National Scenic and Historic Trails, 

and Wild, Scenic, and Recreational Rivers (USDOI BLM 2007c:3-70). 

The only lands within the National Landscape Conservation System that are on the 3 Bars Project area are the Roberts 

Mountains WSA and a portion of the Simpson Park WSA, and the Pony Express National Historical Trail. 

Wilderness Study Areas 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. BLM Manual 6330, Management of BLM Wilderness Study Areas, guides management decisions made 

for specific areas of public lands under wilderness review by Congress (USDOI BLM 2012p). The policy applies to 

the following: 1) WSAs identified by the wilderness review required by Section 603 of the Federal Land Policy and 

Management Act; 2) WSAs established by Congress; and 3) WSAs identified through the land use planning process 

in Section 202 of Federal Land Policy and Management Act. The purpose of the manual is to prevent impairment of 

the wilderness values, described in Section 2(c) of the Wilderness Act of 1964 (Public Law 88/577). The manual 

allows for actions that clearly benefit a WSA by protecting or enhancing these characteristics even if they are 

impairing, though they must still be carried out in the manner that is least disturbing to the site. Wilderness Study 

Areas are managed under the manual until such time as Congress makes a determination regarding wilderness 

designation; the manual would apply to the WSAs in the project area. 

The Eureka County Natural Resource and Land Use Plan is an executable policy for natural resource management 

and land use on federal- and state-administered lands in Eureka County (Eureka County 2010). The Natural Resource 

and Land Use Plan was expanded in response to the passing of Nevada Senate Bill 40. Senate Bill 40 is intended to 

give Nevada localities an opportunity to address federal land use management issues directly. This bill requires that 

“A Plan or statement of policy must be approved by the governing bodies of the county and cities affected by it, and 

by the governor before it is put into effect.”

As stated in the Natural Resources and Land Use Plan, a goal pertaining to Wilderness Areas, WSAs, and other 

special management areas is to “Seek immediate Congressional designation action on all WSAs and other restrictive 

land classifications based on Eureka County policy to release these areas for multiple use management and in the 

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WILDERNESS STUDY AREAS AND OTHER SPECIAL MANAGEMENT AREAS 

interim prevent, minimize or mitigate impairment or degradation of such areas to the extent that Congressional actions 

are not pre-empted.” Similarly, an objective is to “Develop comprehensive guidance to Congress seeking release of 

all WSAs deemed by the Department of Interior to be unsuitable for wilderness designation to multiple use 

management.” 

Approximately 41 miles of the Pony Express National Historical Trail are within the 3 Bars Project area. This national 

trail follows the historic route used by the Pony Express and links St. Joseph, Missouri, to Sacramento, California. 

While the Pony Express was only in operation for 18 months (April 1860 through October 1861), it has come to 

represent the Old West in each of the eight states (California, Colorado, Kansas, Missouri, Nebraska, Nevada, Utah, 

and Wyoming) it passes through. The section of the trail that passes through the project area is part of the Overland 

Canyon to Simpson Park Station High Potential Segment of the Pony Express National Historic Trail. The National 

Trails System Act defines a High Potential Segment as “those segments of a trail which would afford high quality 

recreation experience in a portion of the route having greater than average scenic values or affording an opportunity to 

vicariously share the experience of the original users of a historic route.” The BLM has direct management 

responsibility and authority for the trail within its jurisdictional boundaries, and the USDOI National Park Service is 

the trailwide administrator for programmatic, planning, and co-ordination purposes (USDOI National Park Service 

1999, 2012, Kreutzer 2013). 

In 2009 as part of a National Historic Trail feasibility study under Omnibus Public Land Management Act, Congress 

identified the Central Overland Trail as a potential National Historic Trail. This trail would occur within the 3 Bars 

Project area. The National Park Service is currently studying the feasibility, suitability, and desirability of adding this 

and other routes to the existing California National Historic Trail. The Central Overland Trail largely corresponds to 

the Pony Express National Historic Trail, but the two trails do vary in places, mostly over short distances. 

3.22.2 Affected Environment 

3.22.2.1 Study Methods and Study Area 

Land use plans such as the Shoshone-Eureka RMP, Eureka County Natural Resources and Land Use Plan, and Mount 

Hope Project EIS, and online BLM sources were reviewed to determine wilderness and special management areas 

within the project area. 

The study area for the assessment of direct and indirect effects is the 3 Bars Project area, while the cumulative 

effects study area is the 3 Bars Project area and that portion of the Simpson Park WSA that is outside of the project 

area (Figure 3-1). 

3.22.2.2 Special Management Areas 

There are no National Monuments, National Conservation Areas, Designated Wilderness Areas, or Wild, Scenic, and 

Recreational Rivers on the 3 Bars Project area. The Pony Express National Historic Trail is within the 3 Bars Project 

area. The route of the Pony Express National Historic Trail crosses the southern portion of the 3 Bars Project area, 

and three stations and one water source known to have been used by the Pony Express are within or immediately 

adjacent to the project boundary. From east to west, these are located at Sulphur Spring, Roberts Creek, Goodwin, and 

Grubbs Well. Additional stops in the project vicinity are Diamond Springs (Diamond City), on the east side of 

Diamond Valley, and Dry Creek, situated at the base of the Simpson Park Range. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

In the 1999 Comprehensive Management Plan/EIS developed for the Pony Express, California, Oregon, and Mormon 

Pioneer national historic trails, the National Park Service identified the route from the mouth of Overland Canyon at 

Huntington Valley (Eureka County) to Simpson Park Station, northeast of Austin (Lander County), as a high potential 

segment of the National Historic Trail. This segment crosses the project area. BLM Manual 6280, Management of 

National Scenic and Historic Trails and Trails under Study or Recommended as Suitable for Congressional 

Designation, which guides management of national historic trails crossing BLM jurisdiction, requires NEPA analyses 

of “the extent to which the proposed action would affect the Federal Protection Components, including high-potential 

historic sites or high-potential route segments located on public land” (USDOI BLM 2012n). No high potential 

historic sites are identified along the Overland Canyon to Simpson Park Station High Potential Segment (Kreutzer 

2013). 

There are two WSAs within the project area, Roberts Mountains WSA and Simpson Park WSA (Figure 3-7). Roberts 

Mountains WSA is wholly contained within the project area, while Simpson Park WSA is partially contained within 

the project area. The Roberts Mountains WSA includes 15,090 acres of public land and consists of rugged 

mountainous areas and contains three prominent peaks. Vegetation includes willow, cottonwood, aspen, birch, and 

dogwood. Mountain mahogany trees and limber pine are found in isolated stands on the barren rock ridges The 

Roberts Mountains WSA is generally in a natural state, provides an outstanding opportunity for solitude, and offers 

opportunities for primitive and unconfined recreation such as cross-country skiing, horseback riding, rock hounding, 

hiking, and hunting. About 487 people use the Roberts Mountains WSA annually (USDOI BLM 2012b:3-471). 

Roberts Mountains are the type locality (the geologic point of first recognition) of the Roberts Mountains Thrust, 

which is a major geologic structure in western North America. The area has been referred to as “the Window of the 

World” because of the unique view it gives of the complex geologic structure of the region and has been studied by 

professional geologists and students from across the nation because of its rare qualities and geologic importance 

(USDOI BLM 2012b).

The Simpson Park WSA includes 49,119 acres of public land and 147 acres of privately owned in-holdings; 14,872 

acres of public lands and 22 acres of private in-holdings are within the 3 Bars Project area. The WSA consists of 

mountainous country with scattered stands of aspen and mountain mahogany. The Simpson Park WSA is generally in 

a natural state, provides limited to good opportunities for solitude, and offers outstanding opportunities for hiking, 

horseback riding, and hunting. About 150 people use the Simpson Park WSA annually (USDOI BLM 2012b:3-476). 

3.22.2.3 Lands with Wilderness Character 

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, thefore Lands with Wilderness Character 

are “not present, not effected” 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. 

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WILDERNESS STUDY AREAS AND OTHER SPECIAL MANAGEMENT AREAS 

3.22.3 Environmental Consequences 

3.22.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Based on the AECC and public scoping comments, one concern specific to WSAs and other Special Management 

Areas and 3 Bars ecosystem restoration wasidentified and is discussed in this section. This concern was that the 

expanded ease of livestock movement in cleared country may shift and intensify livestock use on adjacent wilderness 

lands, which could impair their naturalness characteristics. 

3.22.3.2 Significance Criteria 

Impacts to WSAs would be considered significant if BLM actions resulted in nonconformance with BLM Manual 

6330, Management of BLM Wilderness Study Areas (USDOI BLM 2012p).

Impacts to historic trails would be considered significant if the Proposed Action or alternatives result in any of the 

following: 

 Long-term changes to the landscape adjacent to a historic trail that cannot be mitigated to a BLM Class II 

VRM objective, as outlined in BLM Instructional Memorandum NV-2004-004.

 Permanent or long-term limitation of use of an identified portion of a national historic trail. 

3.22.3.3 Direct and Indirect Effects 

3.22.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

The BLM proposes to restore up to 393 acres on the Roberts Mountains WSA and 8 acres on the Simpson Park WSA, 

or less than 1 percent of the acreage in WSAs on the 3 Bars Project area. The BLM may also treat additional aspen 

habitat in the Simpson Park WSA in the future after site-specific aspen inventories are completed. 

Treatments within the Roberts Mountains and Simpson Park WSAs could temporarily impair the wilderness 

characteristics of solitude, naturalness, and primitive and unconfined recreation within and adjacent to these areas. 

The overall effect of treatments on the WSAs would depend on whether the end condition of the treatment site 

(considering both long-term benefits and short-term effects) was an improvement in wilderness characteristics. In 

many cases (e.g., an eradication of a small population of an incipient pest, a prescribed fire that mimicked historical 

fire), communities in the treatment area would quickly recover, and the overall effect would be positive. 

Manual treatments would be the least obtrusive method to use in WSAs and the most appropriate. Manual treatment 

methods are typically focused on small areas, which would have localized impacts on naturalness, solitude, and 

primitive and unconfined recreation. Manual treatment methods would also result in fewer effects on naturalness from 

short-term effects from mechanized equipment and intrusions, noise, and other disturbances. 

It is possible that treatment activity would be visible or audible to visitors on the WSAs or Pony Express National 

Historic Trail during the treatment period, but such activity would not significantly adversely affect the visitor’s 

recreational/historical experience. In addition, the treatment would not adversely affect the historical character and 

scenic value of the trail landscape, or any artifacts or National Register-eligible historic properties associated with the 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Pony Express National Historic Trail. It is possible that treatment sites could be accessed using roads that overlie the 

trail, but access would not occur via the historic trail. The BLM cultural resources specialist would evaluate each 

proposed treatment at the time of implementation and, in coordination with the National Park Service as appropriate, 

would make a recommendation to the authorized officer for an appropriate buffer width around the trail based on the 

type of treatment to be used, the integrity of the potentially affected trail segment, and other factors as necessary. 

3.22.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Under the proposed action, the BLM would treat up to 9 acres along Roberts Creek within the Roberts Mountains 

WSA. There would be no riparian treatments within the Simpson Park WSA or on or near the Pony Express National 

Historic Trail. 

Adverse Effects 

Mechanical treatments within WSAs are allowed for the enhancement of wilderness characteristics in accordance 

with BLM Manual 6330. Thinning and removal of vegetation are allowed in WSAs where prescribed fire in the WSA 

will inevitably cause unacceptable risks to life, property, or natural resources outside the WSA; or where natural 

successional processes have been disrupted by past human activity to the extent that intervention is necessary in order 

to return the ecosystem to a condition where natural processes can function; or where non-native species have altered 

the fire regime so that wildfires pose an undue risk to the native ecosystem. 

Treatment methods would result in ground disturbance, noise, and other disturbances that may temporarily degrade 

the naturalness of the treatment area, and opportunities for solitude and primitive and unconfined recreation within the 

area. These effects would occur on a small area (up to 9 acres) over a short period of time (a few months) and would 

temporarily result in a negligible adverse effect. 

Beneficial Effects 

Beneficial effects would include enhancing the naturalness and primitive and unconfined recreation of the WSAs after 

restoration was completed. In WSAs, treatments would only be allowed in order to improve the natural condition of 

these areas. Although stream enhancement could result in substantial ground disturbance on up to 9 acres, treatments 

would restore native vegetation within the riparian zone and improve stream habitat for Lahontan cutthroat trout and 

game fish. The reduction of hazardous fuels and noxious weeds and other invasive non-native vegetation on lands 

adjacent to or near wilderness and special areas would provide long-term benefits by reducing the likelihood that 

noxious weeds and other invasive non-native vegetation would spread onto these unique areas, or that a catastrophic 

wildfire would burn through them and degrade their unique qualities. 

Aspen Treatments 

The BLM has identified approximately 62 acres within the Roberts Mountains WSA for aspen treatments. The BLM 

may also treat additional aspen habitat in the Simpson Park WSA in the future after site-specific aspen inventories are 

completed. No aspen treatments would be or near the Pony Express National Historic Trail. Aspen treatments would 

focus on improving the health of aspen stands by removing pinyon-juniper to reduce tree competition at JD-A4 (23 

acres), RM-A2 (11 acres), and RM-A10 (28 acres) within the Roberts Mountains WSA, and constructing small, 

3 Bars Project Final EIS 3-427 October 2016 
WILDERNESS STUDY AREAS AND OTHER SPECIAL MANAGEMENT AREAS 

temporary exclosure fencing to promote aspen sucker survival at SFF-A1 (8 acres) within the Simpson Park WSA; 

exclosure fencing could also be used to protect treatment sites within the Roberts Mountains WSA. 

Adverse Effects 

Treatment methods would result in short-term ground disturbance, noise, and other disturbances that may temporarily 

degrade the naturalness of the treatment area, and opportunities for solitude and primitive and unconfined recreation 

within the area. Felling of pinyon-juniper and construction of small, temporary exclosure fencing would impact the 

visual qualities of the treatment area. These effects would be lessened by chipping or removing downed pinyonjunipers and using downed logs to create stream habitat, and removing fencing once aspen stands are restored. 

Beneficial Effects 

Removal of pinyon-juniper trees in aspen stands has the potential to damage or disturb aspen. However, aspen 

respond well to disturbance, which stimulates suckering. Removal of conifers would allow sunlight to reach the 

woodland floor and warm the soil, thereby stimulating aspen sprouting, and could also create conditions that allow 

aspen to expand onto surrounding areas and restore the naturalness of the treatment area. Removal of encroaching 

pinyon-juniper near roads would enable roads near aspen stands to function as fire breaks, and would help to limit the 

spread of wildfire, to the benefit of the WSAs. 

Small, temporary exclosure fencing and ensuring proper livestock management would benefit areas that contain 

aspen. Fencing should have substantial benefit for aspen, as past studies have observed that aspen stands that are 

protected from grazing successfully regenerate and form multi-aged stands without using fire or other disturbance 

(Kay 2001, 2002, 2003). Thus, these actions would benefit the natural qualities of the treatment area. 

Pinyon-juniper Treatments 

The BLM has identified approximately 323 acres within the Roberts Mountains WSA for pinyon-juniper treatments. 

Treatments would occur on the Birch Creek (175 acres), Upper Pete Hanson (126 acres), and Upper Roberts Creek 

(21 acres) units. The Henderson, Three Bars Ranch, and Sulphur Spring Wildfire Management units overlap the Pony 

Express National Historic Trail. However, the BLM cultural resources specialist would evaluate each proposed 

treatment at the time of implementation and, in coordination with the National Park Service as appropriate, would 

make a recommendation to the authorized officer for an appropriate buffer width around the trail based on the type of 

treatment to be used, the integrity of the potentially affected trail segment, and other factors as necessary. 

Adverse Effects 

Treatment methods would result in short-term ground disturbance, noise, and other disturbances that may temporarily 

degrade the naturalness of the treatment area and opportunities for solitude and primitive and unconfined recreation 

within the area. Most of the pinyon-juniper on the Upper Roberts Creek and Upper Pete Hanson units would be 

removed from Phase I stands using chainsaws. Because these trees have encroached into sagebrush habitat, and are 

widely-spaced throughout the area, removal of these trees would restore the natural characters associated with 

sagebrush habitat and would have a minor visual effect. Manual treatments would be the least obtrusive method for 

use in the Roberts Mountains WSA. Because this method of vegetation removal is very selective, damage to nontarget vegetation would be minimized. Although an appropriate buffer would be applied to minimize impacts to the 

Pony Express National Historic Trail, users of the trail may still detect activity and noise during project 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

implementation and the effects of the treatments may be visible from the trail until the vegetation no longer shows 

signs of treatment. 

Beneficial Effects 

Removal of pinyon-juniper on the Birch Creek, Upper Pete Hanson, and Upper Roberts Creek units would encourage 

shrub and riparian vegetation growth and restore the natural condition of these units. All but 3 acres within these units 

are rated “High” for their scenic qualities. Treatments would maintain or improve the wilderness qualities of an area 

without causing effects that are incompatible with established wilderness principles. 

The creation of fuel breaks on or near the Roberts Mountains WSA would provide long-term benefits by reducing the 

likelihood that a catastrophic wildfire would burn through the WSA and degrade its unique qualities. 

Sagebrush Treatments 

No sagebrush treatments are proposed for WSAs. The Roberts Mountain Pasture and Coils Creek units overlap the 

Pony Express National Historic Trail. The BLM cultural resources specialist would evaluate each proposed treatment 

at the time of implementation and, in coordination with the National Park Service as appropriate, would make a 

recommendation to the authorized officer for an appropriate buffer width around the trail based on the type of 

treatment to be used, the integrity of the potentially affected trail segment, and other factors as necessary. Although an 

appropriate buffer would be applied to minimize impacts to the Pony Express National Historic Trail, users of the trail 

may still detect activity and noise during project implementation and the effects of the treatments may be visible from 

the trail until the vegetation no longer shows signs of treatment. 

3.22.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The BLM anticipates treating about half as many acres (about 200 acres) within WSAs under Alternative B as under 

Alternative A. The types and magnitude of effects for manual and mechanical treatments within WSAs would be 

similar between Alternatives B and A. Because the BLM would not be able to use fire, there would be none of the 

adverse effects to the wilderness experience associated with the use of fire. Without the use of fire, there would be no 

localized deterioration of air quality and reduced visibility caused by smoke, no disturbance, and no blackened 

appearance that could affect the naturalness of treatment areas. As noted under Alternative A, no fire treatments 

would be conducted in WSAs for any of the alternatives. 

3.22.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, the BLM would only be able to use manual and classical biological control methods to treat 

vegetation. The types and magnitude of effects for manual treatments would be similar to those for the other 

alternatives, although the BLM would likely treat substantially fewer acres in WSAs under this alternative than under 

Alternatives A and B. 

3.22.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct or indirect effects on WSAs and the Pony Express Trail from 3 Bars Project treatments as 

no treatments would be authorized under this alternative. The BLM, however, would not create fire and fuel breaks; 

thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and other 

invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the ecosystem; or reduce the 

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WILDERNESS STUDY AREAS AND OTHER SPECIAL MANAGEMENT AREAS 

risk of a large-scale wildfire, which could have adverse effects on WSAs and the Pony Express Trail. Long-term, 

there would be less chance of improvement of WSAs under this alternative than under the action alternatives. 

3.22.3.4 Cumulative Effects 

The CESA for WSAs is approximately 784,182 acres and includes the 3 Bars Project area and that portion of the 

Simpson Park WSA that is outside the 3 Bars Project boundary (Figure 3-1). Approximately 97 percent of the 

CESA is administered by the BLM and 3 percent is privately owned. Past and present actions that have influenced 

land use and access in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.22.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Historic livestock grazing and wild horse use have led to the degradation of riparian and aspen habitat, establishment 

and spread of noxious weeds and other invasive non-native vegetation, and expansion of pinyon-juniper beyond its 

historical ranges in portions of the WSAs. To improve forage and water resources, the BLM would continue ongoing 

management reviews to ensure proper livestock management and long-term success of treatments. 

The BLM would also continue to conduct wild horse gathers, AML reviews and adjustments, remove excess animals 

and use fertility control, improve water developments, and implement habitat projects. There are no HMAs that 

overlap with WSAs, but wild horses do move onto the Roberts Mountains during the summer and use the Roberts 

Mountains WSA. Efforts to distribute wild horses more evenly across the rangeland should help to reduce grazing 

pressure on the Roberts Mountain WSA. However, the Mount Hope Project would exclude wild horses from about 

14,000 acres for up to 70 years, and as a result wild horses may spend more time in the Roberts Mountains WSA in 

search of food and water. The BLM would provide alternate water sources for wild horses in Kobeh Valley (USDOI 

BLM 2012b:3-439). By developing additional water sources, wild horses would be able to use foraging areas that are 

currently underutilized in Kobeh Valley. 

The BLM would treat noxious weeds and other invasive non-native vegetation within WSAs under existing 

authorizations. New infestations would typically be found in newly burned or disturbed areas, and in areas where 

livestock and wild horses congregate. Treating infestations while they are small and reducing the amount of area 

covered by existing large infestations, would result in fewer effects on the WSAs. 

The population within southern Eureka County is predicted to increase by 50 percent during construction and 

operation of the Mount Hope Project. With an increase in population and employment opportunities, the number of 

users of WSAs should increase. Users could spread noxious weeds and other invasive non-native vegetation that 

attaches itself to clothing or shoes. 

The Mount Hope Project would disturb about 8,300 acres, but would have no direct impact on WSAs, although it 

will be visible from the WSAs. Potential indirect impacts to the Roberts Mountains WSA could occur if 

groundwater pumping activities decrease the flows in Roberts Creek or other streams associated with the Roberts 

Mountains WSA). Removal of Mount Hope would have an impact on the historic setting of the Pony Express 

National Historic Trail. The mountain is visible for miles and its removal would alter the character of the trail and the 

ability of recreationists to experience the trail as it existed in 1860-61. In addition, access would be virtually 

eliminated for a segment of the trail that passes within the mine boundary. The 3 Bars Project would not significantly 

add to this impact since none of the proposed treatments would further limit access to any portion of the trail within 

the 3 Bars Project Area. These effects could degrade the recreational experience within the CESA. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Wildfire has been relatively uncommon on the Roberts Mountains, but the 106,479-acre Trail Fire in 1999, and 

several other fires that have burned tens to hundreds of acres, have occurred on or near the Simpson Park WSA (see 

Figure 3-33). An estimated 84,000 acres could burn from wildfires during the next 20 years, based on wildfire 

occurrence since 1985. 

To reduce wildfire risk and improve ecosystem health, approximately 127,000 acres would be treated on the 3 Bars 

Project area, and an additional 15,000 acres could be treated under current and future authorizations within the CESA, 

or about 16 percent of the CESA, but only on about 1 percent of WSAs. Although the acreage treated within WSAs 

would be minor, treatments elsewhere in the CESA would help to reduce hazardous fuels and improve ecosystem 

health, and reduce the potential for catastrophic wildfire that could have substantial adverse effects on WSAs and 

lands adjacent to the Pony Express Trail. 

3.22.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on WSAs and the Pony 

Express Trail would be similar to those described under Alternative A. Fire would not be used on WSAs under any of 

the alternatives. However, fire could not be used under this alternative on about 78,000 acres elsewhere in the CESA 

under the 3 Bars Project and current and reasonably foreseeable future authorizations, or about 8 percent of the 

CESA. Without being able to use of fire on other portions of the CESA, the BLM would be less successful in 

reducing the risk of catastrophic wildfire within the CESA, and would not likely offset the increased potential for 

more extensive and intense wildfires to occur in place of controlled burns on the 3 Bars Project area compared to 

Alternative A. As demonstrated by wildfires in 1999, wildfires can have substantial effects on WSAs and could also 

affect the scenery near the Pony Express Trail. 

3.22.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on WSAs and the Pony 

Express Trail would be similar to those described under Alternative A. Adverse, short-term effects to wilderness 

characteristics, primarily solitude and visual qualities, associated with the use of fire and mechanized equipment 

would not occur under Alternative C. However, fire and mechanical treatments would be little used under 

Alternatives A and B, so the cumulative effects associated with WSA treatments among the action alternatives would 

show few differences. 

The BLM would treat only about 10 acres annually in the WSAs, and about 33,000 acres within the remainder of the 

CESA, or about 4 percent of the CESA. By not being able to use mechanical methods, fire, and livestock to reduce 

hazardous fuels, create fire and fuel breaks, stimulate development of understory vegetation, and remove downed 

wood and slash, however, the risk of wildfire and its adverse impacts on WSAs and lands near the Pony Express Trail 

would likely be greater on the CESA under Alternative C than under Alternatives A and B. 

3.22.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on WSAs and the Pony 

Express Trail would be similar to those described under Alternative A. There would be no cumulative effects on 

WSAs or the Pony Express Trail from 3 Bars Project treatments as no treatments would be authorized under this 

alternative. The BLM could create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse 

stands; slow the spread of noxious weeds and other invasive non-native vegetation using ground-based and aerial 

application methods of herbicides, especially cheatgrass; restore fire as an integral part of the ecosystem; and reduce 

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WILDERNESS STUDY AREAS AND OTHER SPECIAL MANAGEMENT AREAS 

the risk of a large-scale wildfire under current and reasonably foreseeable future authorized actions, but on a very 

limited acreage (about 1,500 acres annually). Thus, benefits to the WSAs and the Pony Express Trail would be less 

under this alternative than under the action alternatives. 

3.22.3.5 Unavoidable Adverse Effects 

Use of manual and mechanical treatments could potentially cause the loss of non-target native vegetation. 

3.22.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

Impacts to resources within WSAs would begin to disappear within 1 to 2 growing seasons after treatment, regardless 

of the treatment method. The regrowth of vegetation on the site would eliminate much of the stark appearance of 

cleared areas, and the site would develop a more natural appearance. The longest lasting impacts would occur in 

woodlands and other areas where large trees and shrubs are removed. Benefits to plants and animals in terms of 

ecosystem function and improved forage and cover would occur as the treated area recovered. 

Over the long-term, vegetation treatments would likely improve resources on WSAs. Treatments that aim to 

rehabilitate degraded ecosystems would result in plant communities that are dominated by native species (see Section 

3.12, Native and Non-invasive Vegetation Resources, for more information). Native-dominated communities often 

provide better habitat for fish and wildlife, including species of concern, than communities dominated by noxious 

weeds and other invasive non-native vegetation. 

3.22.3.7 Irreversible and Irretrievable Commitment of Resources 

There would be no irreversible or irretrievable commitment of resources. Although there would be short-term impacts 

to wilderness and special area resources from vegetation treatments, impacts would not be irretrievable and could be 

reversed if restoration treatments are successful. 

3.22.3.8 Significance of the Effects under the Alternatives 

There would be negligible to minor impacts to solitude and other wilderness opportunities from 3 Bars Project 

treatments under all alternatives, but these actions would affect less than 0.1 percent of WSAs annually, and would 

last only a few years. The BLM would ensure that treatment actions conform to guidance in BLM Manual 6330, 

Management of BLM Wilderness Study Areas (USDOI BLM 2012p). 

Under all the alternatives, direct and indirect effects of 3 Bars Project treatments would not result in long-term 

changes to the landscape adjacent to the Pony Express National Historic Trail that cannot be mitigated to a BLM 

Class II Visual Resource Management objective, as outlined in BLM Instructional Memorandum NV-2004-004, or in 

permanent or long-term limitation of use of an identified portion of the trail. Treatments would also not permanently 

th impact the solitude and scenic value of the trail or the ability of visitors to vicariously share the 19 century Pony 

Express experience. The BLM would follow guidance in BLM Manual 6280, Management of National Scenic and 

Historic Trails and Trails under Study or Recommended as Suitable for Congressional Designation, to ensure proper 

management of the Pony Express National Historic Trail (USDOI BLM 2012n). 

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3 Bars Project Final EIS 3-433 October 2016 

3.22.4 Mitigation 

No mitigation measures for WSAs are recommended. 

3.23 Cultural Resources 

The following discussion provides an overview of the cultural resources that have been identified and can be expected 

to be found on the 3 Bars Project area. A cultural resource is any defined location of past human activity, occupation, 

or use, identifiable through field investigation, historical documentation, or oral histories. Cultural resources include 

prehistoric, historic, ethnohistoric, or architectural sites, structures, places, objects, and artifacts (USDOI BLM 

1999b). Cultural resources in the 3 Bars Project area are divided into three groups: prehistoric archaeological 

resources, historic archaeological and architectural resources (discussed in this section), and Traditional Cultural 

Properties, which are discussed in Section 3.24, Native American Traditional/Cultural Values, Practices, and 

Resources. Historic properties are those historic or prehistoric cultural resources that, through consultation with the 

Nevada State Historic Preservation Officer and Advisory Council on Historic Preservation, have been determined to 

be eligible for inclusion in the National Register of Historic Places (NRHP). 

3.23.1 Regulatory Framework 

There are several laws and acts that pertain to the protection of historic and cultural resources and the rights of Native 

American tribes. The Historic Sites Act of 1935 provides for the preservation of historic American sites, buildings, 

objects, and antiquities of national significance. The National Historic Preservation Act of 1966 (16 USC § 470 et 

seq.) requires federal agencies to take into account the potential effects of their actions on properties that are listed or 

are eligible for listing on the NRHP, and to consult with State Historic Preservation Officers, Native American tribes, 

and local governments regarding the effects of federal actions on historic properties. The Archeological Resources 

Protection Act of 1979 prohibits the excavation, removal, damage, or other alteration or defacement of archaeological 

resources on federal or Native American lands without a permit. The American Indian Religious Freedom Act of 

1978 (Public Law 95-341) requires federal land managers to include consultation with traditional Native American 

religious leaders in their management plans. The Native American Graves Protection and Repatriation Act of 1990 

recognizes the property rights of Native Americans in certain cultural items, including Native American human 

remains and sacred objects. 

Executive Order 13084, Consultation and Coordination with Indian Tribal Governments, directs federal agencies to 

respect tribal self-government and sovereignty, tribal rights, and tribal responsibilities whenever they formulate 

policies that “significantly or uniquely affect Indian tribal governments.”

3.23.2 Affected Environment 

3.23.2.1 Study Methods and Study Area 

Mount Lewis Field Office databases consisting of Geographic Information System shapefiles and a Microsoft Access 

database with information about cultural resources, studies, and investigations that have been conducted within and in 

the vicinity of the 3 Bars Project area were reviewed. These were supplemented with information from the Nevada 

Cultural Resources Information System. These baseline data provided the framework for determining the types of 

cultural resources that are found within the project area, and an assessment of impacts that may result from 

implementation of the project alternatives. These data were also used to prepare a Cultural Context 3 Bars Ecosystem 
CULTURAL RESOURCES 

and Landscape Restoration Project report that described the cultural resources and cultural setting of the 3 Bars 

project area (AECOM 2012). 

The study area for the assessment of direct and indirect effects for cultural resources is the 3 Bars project area. The 

cumulative effects study area for cultural resources includes the project area and a 5-mile buffer around the project 

area (Figure 3-1). 

3.23.2.2 Cultural Setting 

The 3 Bars Project area and its vicinity are known to contain numerous traces of past human activity ranging from 

early Native American sites and artifacts to the remains of early trails and transportation and communication routes 

(including the route of the Pony Express), mining, charcoal production, and ranching and agriculture. Such materials 

can be found at many locations on the landscape and represent the traces of human activities that in some cases extend 

as far back as 10,000 to 8,000 years before the present (BP). 

3.23.2.2.1 Prehistory 

The project area is in central Nevada within the western area of the Great Basin, as defined by Elston (1986). The 

most pertinent cultural chronology of this portion of the western Great Basin can be derived from data resulting from 

excavations conducted at the Gatecliff Shelter (Thomas 1983a). Additional information has been provided by 

d’Azevedo (1986), Jennings (1986), Janetski and Madsen (1990), Grayson (1993), Madsen and Rhode (1994), Beck 

and Jones (1997 cited in Beck 1999), Kelly (1997), Madsen and Simms (1998), and Beck (1999). Additional 

information from surveys conducted within the Reese River and Monitor Valleys by Thomas and Bettinger (1976) 

and Thomas (1983b, 1988) are also relevant. Within the broader context defined by the Early, Middle, and Late 

Archaic Periods, five chronological phases have been defined by Thomas (1983b): Clipper Gap (5500–4500 BP), 

Devils Gate (4550–3550 BP), Reveille (3550 BP–1300 BP), Underdown (1300–600 BP), and Yankee Blade (600 

BP–historic). Elston (1986) postulates a Grass Valley Phase (circa [ca.] 10,000–8000 BP) for the Paleoarchaic Period 

and a hiatus in occupation between 8000 and 5500 BP. These phases are summarized below. 

Paleoarchaic Period (ca. 10,000–8000 BP) 

Paleoarchaic (or “Pre-Archaic”) sites dating to as early as 11,000 years BP are known from eastern Nevada such as 

those documented at the Ely Airport (BLM Report CRR 8111 [NV 040] 2005-1512), Sunshine Well (Jones et al. 

1996), and Giroux Wash (Stoner et al. 2000). One of the main characteristics distinguishing Paleoarchaic sites from 

other prehistoric cultural manifestations is the presence of fluted implements such as Clovis and Folsom projectile 

points and distinctive nonfluted Plano projectile point forms, crescent-shaped implements, choppers, gravers, 

punches, and an assemblage of steep-edged scrapers, which are primarily unifacial. Paleoarchaic assemblages are 

most often found in surface contexts associated with late Pleistocene and early Holocene pluvial lake and lacustrine 

environments of the region; therefore, researchers have concluded that they are the remains of a settlement pattern 

geared toward the exploitation of marsh and lake-edge resources in valley floors or in riparian corridors (Elston et al. 

1981, Elston 1982, Madsen 1982, Davis and Rusco 1987, Beck and Jones 1988 cited in Beck 1999). 

Although Thomas (1982a) postulated a lack of occupation before 8000 BP in the central Great Basin, Elston (1986) 

indicated that the Pre-Archaic period is marked by the Grass Valley Phase between ca. 10,000 and 8000 BP as 

indicated by the presence of Western Stemmed series and fluted points. The Western Stemmed series is represented 

by leaf-shaped, Lake Mohave stemmed, and lanceolate projectile points, usually found in surface contexts. Associated 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

constituents consist of flake tools, thick triangular scrapers, bifacially flaked knife-choppers, and steep-sided hafted 

scrapers. 

Early Archaic Period (8000–5000 BP) 

At the end of the Paleoarchaic Period, shifting land-use patterns, subsistence systems, and the emergence of a wide 

variety of implement types marked the beginning of the Archaic Period (Bryan 1979, Elston et al. 1979, Aikens and 

Madsen 1986, Jennings 1986, Jones et al. 1996). Site locations from the earlier years of the Archaic Period suggest 

continued adaptations to lakeshore environments (Madsen 1982, Jones et al. 1996, Stoner et al. 2000), although the 

variety of implements and types of materials used appears to have increased. Projectile point styles consisted of 

Stemmed, Pinto, and Lake Mojave types. The people of the Early Archaic Period seem to have inhabited a much 

more diverse landscape with a more flexible subsistence system than the Paleoarchaic peoples who preceded them. 

They utilized not only valley floors and lake margins, but cave sites and upland areas as well. 

Elston (1986) suggested a hiatus in occupation within central Nevada between 8000 and 5500 BP. Thomas (1982a) 

indicated that the later portion of the Early Archaic is represented by the Clipper Gap Phase (ca. 5500–4500 BP), 

which is characterized by artifacts similar to those used during the Pre-Archaic. Based on observations from Monitor 

Valley, this period also appears to be characterized by large, wide, concave-base projectile points called “Triple T.” 

Limited assemblages of artifacts from this time period suggest that the area was sparsely inhabited, possibly by small 

groups. 

Middle Archaic Period (5000–1300 BP)

As during the earlier portion of the Archaic Period, remains of larger game tend to be found in archaeological 

contexts during the Middle Archaic Period, which is divided into the Devils Gate Phase (ca. 4500–3500 BP) and the 

later Reveille Phase (ca. 3500–1300 BP). The Middle Archaic Period is marked by the presence of large side-notched 

Gatecliff and Elko series projectile points, which slowly replaced the earlier Pinto and stemmed point forms. The use 

and exploitation of upland environments intensified during this time period, possibly in association with the 

exploitation of pinyon pine, which is postulated to have been introduced in the area around 6000 BP (Thomas 

1982a:164). 

Evidence from Gatecliff Shelter (Thomas 1983a) and Mount Jefferson (Thomas 1982b) indicates that the hunting of 

large game remained a dominant subsistence activity, as interpreted from the large numbers of Elko-style projectile 

points. However, more intense exploitation of a broad range of resources, possibly resulting from increased 

population, may have caused an increase in the presence of seed processing equipment. Incised stones are present in 

the Monitor Valley assemblages, and the appearance of exotic obsidian and marine shell beads suggests the presence 

of regional exchange (Thomas 1983a). 

Divergence from the Middle and Late Archaic patterns is seen in the emergence in Utah and extreme eastern Nevada 

of the Fremont “cultures” during the Fremont/Parowan Period, ca. 1600 BP (Marwitt 1986). However, the degree of 

influence of the Fremont cultures with peoples in central Nevada is uncertain. 

Late Archaic Period (1300 BP–Contact)

The Late Archaic Period is represented by the Underdown Phase (ca. 1300–600 BP) and the Yankee Blade Phase 

(600 BP–historic). This period is marked by important technological changes, which included the introduction of bow 

and arrow technology, as indicated by the presence of small corner-notched and basally notched projectile points 

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CULTURAL RESOURCES 

designated as part of the Rosegate series (Thomas 1981a). Because of the association of basally notched points with 

Fremont cultures, Thomas (1997) suggested that these artifacts may indicate a Fremont influence. During this time 

period occupation appears to be less intense, as marked by a decrease in overall numbers of artifacts and the 

production of bifaces at Gatecliff Shelter (Thomas 1983a). 

The Yankee Blade Phase shows a marked divergence from earlier patterns. Projectile points from this phase are small 

Desert side-notched and Cottonwood series. Other than at the Alta Toquima residence sites (Thomas 1982b), these 

point forms are rarer in the Monitor Valley than the earlier Eastgate basally notched, Rose Spring corner-notched, and 

Elko forms. Resource exploitation intensified during this phase, with an increased focus on seeds, including pinyon 

pine. The discovery of more permanent habitation sites at higher altitudes indicates that groups became more 

sedentary, and that residences became established at locations that had served as temporary hunting camps during the 

preceding periods (Elston 1986). There is an increase in the size of houses and settlements. In the case of the Western 

Shoshone, large settlements appear in valley floors during the ethnohistoric (contact) period. 

As noted above, a shift from the Middle and Late Archaic patterns is seen in the emergence of the Fremont “cultures” 

described by Marwitt (1986). No evidence of extensive use of the project area exists; however, southeast of the 

project area, Fremont style ceramics have been found near Cabin Spring, approximately 30 miles south of the project 

area (Russell 2004).

Small villages, ceramics, and some reliance on horticulture characterized the Parowan Fremont culture. As rainfall 

(necessary for agriculture) became more unpredictable, the Fremont may have abandoned agriculture in favor of a 

hunting-gathering adaptive strategy in the pinyon-juniper woodlands of western Utah and eastern Nevada, with a 

terminal date of ca. 650 BP (Wilde and Soper 1999:7). Another scenario proposed by Wilde and Soper (1999:7), 

based on evidence from Janetski (1994) and Madsen and Simms (1998), suggested that competition from foragers 

also may have been a factor in the shift to a more hunter-gatherer strategy. 

It is also during this period that some see the arrival of Newe (Numic speakers and ancestral Shoshone). This period is 

marked by the presence of brownware ceramics, twined and coiled basketry, and small side-notched (Desert sidenotched) projectile points. This is contrary to ethnographic accounts and oral tradition that indicate that the Western 

Shoshone have inhabited the region for a much greater period of time. The timing of the arrival of the Newe and the 

area from which they moved is widely debated (see Madsen and Rhode 1994), but current evidence suggests that they 

may have arrived ca. 1000 BP. 

3.23.2.2.2 Historic Setting 

The beginning of the historic-era in the Eureka County region is determined using rather arbitrary temporal and 

cultural markers. Although contact between European and American traders, trappers and explorers and the 

ethnographic Shoshone had been taking place since at least the early decades of the 19th century, sustained contact 

between Native and Euro-American populations did not occur until the 1850s and 1860s (Bailey 1966, James 1981). 

As the population of Euro-American settlers and entrepreneurs increased in the Eureka County region, particularly 

following the Ruby Valley Treaty in 1863, several predominant economic patterns and themes of historical 

development emerged during the middle of the 19th century. The themes of particular relevance to Eureka County in 

general, and the 3 Bars Project area specifically, consist of early exploration, transportation and communication, early 

settlement, mining, charcoal production, and ranching and agriculture. Each of these topics is discussed below. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.23.2.2.3 Early Exploration 

The earliest recorded routes through Nevada were those made by fur trappers, and traders. American trapper Jedediah 

Smith, representing the Rocky Mountain Fur Company, struck out from the Great Salt Lake to Los Angeles in the 

summer of 1826, a journey that took him south along the Colorado River, then to the Mojave Valley, and finally into 

California (Elliot 1987, McBride 2002:2-4). In 1826, Peter Skene Ogden of the British-owned Hudson’s Bay 

Company passed through northeastern Nevada in a prelude to his later exploration of the Humboldt River in 1828. In 

search of beaver hides, Ogden and his men left the Columbia River basin and traveled southeast until they discovered 

an “unknown” river, later named the Humboldt River, near Winnemucca. This route later became the main emigration 

corridor across Nevada (McBride 2002:2). 

As the fur trading business declined, the U.S. government started taking an active interest in the West and began 

sponsoring explorations of the area. From 1843 through 1845, John C. Fremont, a lieutenant in the Army 

Topographical Corps, led several expeditions into Nevada as part of this government-sponsored program of 

exploration. During the expeditions, Fremont recognized that the area had interior drainage and understood its 

physiographical features, and thus named it the Great Basin (McBride 2002:7). In 1845, his route continued through 

the Diamond Mountains and through Diamond and Kobeh Valleys, a path that would have bisected the current project 

area. 

In 1859, James Simpson, who had previously explored the area, led an expedition through central Nevada, from 

Camp Floyd, Utah, to Genoa, Nevada. Simpson noted that this route was not suitable for a railroad but would work 

well for wagons (Welch 1979:6, Vlasich 1981:228, McBride 2002:10–11). This route was later called the Central 

Route (also known as the Central Overland Trail and Egan-Simpson Wagon Route). 

3.23.2.2.4 Transportation and Communication 

As with virtually every other economic endeavor in Nevada, industries dealing with transportation and 

communication activities were established, at least initially, in reaction to the booming California and later Nevada 

mining industry in the middle 1800s. Emigrant and shipping routes were established early on for settlers and 

California-bound gold miners, but in large part these were intended only to provide passage through the state, and not 

to bring or support settlers. As Nevada’s mining industry boomed, the state became a destination for travelers to the 

West.

3.23.2.2.5 Early Mail Delivery 

Beginning in 1855, Major Howard Egan of the Mormon Battalion first traversed a route through central Nevada; 3 

years later he surveyed the route for Major George Chorpenning. In 1859, this route was quickly adopted by 

Chorpenning’s mail line, which used mules. Informally known as the “Jack-ass Mail,” the operation was first 

established along the Humboldt River (Goetzmann 1966:293 cited in Bowers and Muessig 1982). By December 

1859, Chorpenning had built several stations along the new route (Godfrey 1994). It is not known whether stations 

had been established within the project area. At the same time, Russell, Majors, and Waddell, owners of the Central 

Overland California & Pikes Peak Express Company (COC&PP Express Company), had been actively soliciting the 

U.S. Congress for the establishment of a 10-day mail service by pony express between Sacramento, California, and 

St. Joseph, Missouri, while at the same time laying out and establishing stations along the same route used by 

Chorpenning (Townley 1986:7–8, Godfrey 1994). In the wake of cash flow problems, Chorpenning’s mail contract 

was terminated in May 1860, and was promptly awarded to the COC&PP Express Company. Russell, Majors, and 

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Waddell hoped that by demonstrating “that the central route offered the best opportunity for mail or stage...the firm 

could inherit the (proposed route of the) Pacific Railroad” (Townley 1986:8). This new subsidiary venture, more 

commonly known as the Pony Express Mail Service, began in April 1860. 

Although short-lived (1860–1861), the Pony Express demonstrated the importance of a central route, which became 

even more important after the seizure of Butterfield’s southern route by the Confederate army in January 1861 

(Townley 1986:13). Although it was replaced by the telegraph just 18 months after it began, during its brief existence 

the Pony Express helped to deliver important information during a time of civil unrest. 

The route of the Pony Express crosses the southern portion of the 3 Bars Project area, and three stations and one water 

source known to have been used by the Pony Express are within or immediately adjacent to the project boundary. 

From east to west, these are located at Sulphur Spring, Roberts Creek, Goodwin, and Grubbs Well. Additional stops 

in the project vicinity are Diamond Springs (Diamond City), on the east side of Diamond Valley, and Dry Creek, 

situated at the base of the Simpson Park Range. 

3.23.2.2.6 Overland Stage 

After the disbandment of the Pony Express, competition for government mail and passenger service contracts over the 

central route ensued between the COC&PP Express Company and Butterfield’s Overland Mail Company. As a 

compromise, Congress awarded the COC&PP Express Company the eastern portion of the route from the Missouri 

River to Salt Lake City, where post and passengers were transferred to the Overland Mail Company (Overland Stage), 

which completed the first run to San Francisco on July 18, 1861 (Townley 1986:13, Hafen 2004 [1926]).

By the spring of 1862, the COC&PP Express Company had become financially stressed as a result of difficulties 

encountered with the management of the eastern end of the route, and its finances were in the hands of the courts. 

Finally, as a result of heavy indebtedness, the company was sold to Ben Holladay and the name was changed to the 

Overland Stage (Hafen 2004 [1926]:227–232). 

A map of the Overland Stage and Pony Express routes across Nevada (Townley 1986:10–11) indicates that the 

Overland Stage followed the same route as the Pony Express through the project area. Within the project area, stations 

were located at Sulphur Spring, Roberts Creek, and Grubbs Well, with a watering stop at Goodwin. 

In the latter part of 1866, Holladay disposed of his entire overland mail holdings, which included the Holladay 

Overland Mail and Express Company, the Overland Mail Company, and the Pioneer Stage Company. These were all 

absorbed by Wells, Fargo and Company, which had been founded in 1852 by Henry Wells, William G. Fargo, John 

Livingston, D. N. Barney, and others to conduct an express and banking business (Hafen 2004 [1926]:232–235). 

As the Transcontinental Railroad neared completion, mail and coach service decreased, and even the Overland 

Telegraph was rerouted along the railroad, following the joining of the Central Pacific and Union Pacific railroads in 

May 1869. After the completion of the railroad, the central route for mail and passenger service was soon abandoned, 

with only interconnecting service between railheads remaining. 

3.23.2.2.7 Transcontinental Telegraph 

The telegraph line basically followed the route of the Overland Stage. Like the stage, its existence along the central 

route was short lived. Upon completion of the Transcontinental Railroad, the telegraph was quickly rerouted along the 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

Central Pacific Railroad. Service to southern Eureka County was provided by a line from Palisade along the Eureka 

and Palisade Railroad (E&PRR) to Eureka with additional service to mining camps surrounding Eureka. 

3.23.2.2.8 Eureka and Palisade Railroad 

With the completion of the Transcontinental Railroad through northern Eureka County, overland transportation took a 

dramatic turn. The largely isolated nature of central and eastern Nevada was rapidly coming to an end, and new 

markets for the industrial and agricultural/ranch products of the region soon emerged. At first wagon roads connected 

the area to the railroad. Later the E&PRR linked Palisade (a stop along the Central Pacific) and southern Eureka 

County, providing easy transportation to other population centers such as Salt Lake City. 

As with most transportation development in the 19th century, the E&PRR was established in response to the 

development of mining. Upon establishment of the town of Eureka in 1870 and the development of mining, the 

lucrative, high-yielding lead and silver ore was transported by a fast wagon freight operation to the recently 

established Central Pacific railhead at Palisade (Paher 1970:181). 

In 1874, a consortium of Isaac Requa, D.O. Mills, William Sharon, Thomas Bell, and Edgar Mills, who represented 

the Bank of California, the Virginia and Truckee Railroad, and various Comstock mining operations, took over the 

railroad (Myrick 1992:90). During the next 10 years the railroad was extremely prosperous, with connecting freight 

service to Belmont, Hamilton, Austin, Ward, and Pioche, Nevada, and plans were made to expand the line south. In 

the late 1880s mining began to fail in the Eureka area (Myrick 1992:107). Mark Requa, the son of Isaac, made a 

valiant effort to acquire additional business from other mines in the area, including the profitable copper mines near 

Ely, and at one point even contemplated extending the route east over four mountain ranges. A brief boom period 

occurred in 1905, however this short period of prosperity suffered a major blow in 1910 when major floods caused 

extensive damage to the line. In 1921, George Whittle purchased and reorganized the operation under the name of the 

Eureka-Nevada Railway Company. The line, operated under the leadership of John E. Sexton, made three runs per 

week. However, revenues began to decline in 1927 as a result of competition from growing highway traffic, and the 

railroad made its last run in September of 1938 (Myrick 1992:111). 

Two sidings and two stations were located within the 3 Bars Project area. The sidings, Cedar and Oak, were used 

from 1934 to 1938 (Hall 1994). Pine Station is located just outside of Alpha. The Summit Station was a water stop 

located at the top of Garden Pass Summit. 

3.23.2.2.9 Highway Development 

As the 20th century progressed, railroads remained the primary means of moving people and goods within and 

through Nevada, but the automobile was fast becoming a major player on the transportation scene. However, in 1914, 

only 262 miles of Nevada’s 12,812 miles of roadway were paved, and Nevada had a long way to go to provide for the 

automobile. An exception was the establishment in 1913 of the Lincoln Highway, which was one of America’s first 

transcontinental automobile routes, beginning in Times Square in New York City and ending at the Palace of the 

Legion of Honor in San Francisco (USDOI National Park Service 2004). 

The early route of the Lincoln Highway was determined primarily by the geography of Utah, where the Great Salt 

Lake Desert blocked the way west from Salt Lake City and limited funds were available for construction of a raised 

roadway across the barren salt flats. Because of this, the early route was routed around the south end of the desert to 

Ely, then on to Eureka. However, the popularity of this route began to decline after 1919. The final blow to the route 

through Eureka County was in 1927, when the Lincoln Highway Association abandoned the route through Ely and 

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Eureka for the Wendover Road. As a result, Nevada built an 80-mile route south to link up with the Lincoln Highway 

south of County Road 18 north of Ely. By the time the route was completed in 1930, the more direct Victory Highway 

(U.S. Highway 40) along the Humboldt River Valley had been improved sufficiently to capture most of the traffic 

traveling across the Great Basin. 

3.23.2.2.10 Early Settlement 

Early settlement within and in the vicinity of the 3 Bars Project was limited to scattered ranches consisting of Denay, 

Pennsylvania (currently known as the McClusky Ranch), Grubb Meadows Ranch (currently known as the 3 Bar 

Ranch), and the Addinton Ranch. Of these early ranches, the 3 Bar and McClusky Ranches were established and are 

still in the western portion of the project area. The initial operations of these early ranches were geared primarily 

toward trapping mustangs and driving them to California (Wooley 1999). 

3.23.2.2.11 Mining 

The economic and social development of central Nevada during the 19th century was more closely associated with 

the emergence of the mining industry than with any other activity. In fact, the existence of Nevada as an independent 

state is primarily the result of the wealth of the Comstock Lode, which helped convince the U.S. Congress and 

President Abraham Lincoln to create this new territory from the western section of Utah in 1861. After the Civil War, 

and throughout the latter decades of the 19th century, mining continued to be the single most important economic 

endeavor throughout the state, although the boom-and-bust cycles intrinsic to the industry kept the population of 

much of Nevada at a very low level until the early 20th century (Hulse 1990). 

Roberts and Montgomery (1967) depict five mining districts—Alpha, Lone Mountain, Mount Hope, Antelope, and 

Roberts—within the project area, and another six to the north and southeast. Several smaller areas of mining activity 

also existed historically; all are discussed below. Those in the project area vicinity include the Cortez/Mill Canyon, 

Buckhorn, Mineral Hill, and Union Districts to the north and the Eureka and Fish Creek Districts to the south. 

Although mining is represented within the project area, historically it does not compare in size and scope to 

operations at Eureka and Ruby Hill south and southeast of the 3 Bars Project area, and the Mineral Hill and Cortez 

Districts north of the project area. 

3.23.2.2.12 Charcoal Production 

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. 

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3.23.2.2.13 Ranching and Agriculture 

Given the region’s generally arid climate and landscape, traditional crop farming was never a major industry in 

Eureka and surrounding counties, and growing fruits and vegetables never expanded much beyond small-scale local 

operations. Early settlers in the area were actively engaged in rounding up mustangs, an endeavor that continued into 

the 20th century. However, cattle and sheep ranching proved to be highly profitable endeavors, especially during the 

boom periods of the mining industry, when tens of thousands of hungry miners flooded the region during the middle 

and latter decades of the 19th century. 

Ranching 

Cattle and sheep grazing have long been the mainstays of the agricultural industry in central Nevada. However, they 

occur within a marginal environment where severe weather conditions, particularly in the winter, and rangeland 

vegetation that can only support a few head per acre limit the scope and degree to which grazing can be supported 

(Bowers and Muessig 1982:77). The first domestic cattle documented as having at least passed through eastern 

Nevada came with the Bartelson-Bidwell party in 1841, but as an industry, cattle ranching did not develop in central 

Nevada until after the Civil War. By the mid-1860s, stockmen were driving thousands of head into the region (Mack 

and Sawyer 1965 cited in James 1981; Patterson 1965). However, as with mining in Eureka and surrounding counties, 

cattle-raising went through its own boom-and-bust cycles. 

The first sheep to enter Nevada followed the Old Spanish Trail from New Mexico through southern Nevada into 

California. This drive, consisting of 25,000 head, was organized by Miguel Otero, a rich landowner whose son would 

later become the governor of New Mexico, and Jose Luna, one of the richest sheep owners in the state. The second 

sheep drive was organized by “Uncle Dick” Wootton, with 9,000 head that took a northerly route along the Humboldt 

River in 1852 (Georgetta 1972:7-15). 

Beginning in the 1870s, Scandinavian, Irish, and Scottish immigrants became engaged in the raising of sheep, which 

greatly intensified in the 1890s with the arrival of the Basque, who had moved from California following a period of 

drought. Because of their competition for grazing land, cattle ranches sought to control sheep grazing through the 

creation of grazing laws (Creel 1964). The fact that sheep cropped the land so closely caused former ranges to lose 

their plant growth, thereby rendering areas useless for cattle grazing (James 1981:258–260). It was not until 1934 with 

the passage of the Taylor Grazing Act that the management problem was adequately addressed. In 1946, the BLM 

was organized from the Grazing Service and General Land Office (Clawson 1950:100). Sheep grazing within the 3 

Bars Project area specifically was conducted by the Damele Brothers (Georgetta 1972:442). 

Agriculture 

Because of the limited availability of water, the remoteness of the area, and harsh winter conditions, agriculture has 

always been conducted on a limited basis in most areas of Nevada, including Eureka County, and even then has 

primarily been geared toward serving local markets such as mining camps and towns. Bowers and Muessig (1982) 

provide numerous examples from the Reese River area, the Monitor and Big Smoky Valleys, and the current project 

area of crops that met local demands, alleviating the high cost of importing fruits and vegetables from California, 

Utah, or the valleys of western Nevada. In 1879-1880, the Eureka County Assessor reported production of onions, 

cabbage, corn, potatoes, carrots, parsnips, tomatoes, beets, and turnips (Nevada Surveyor General and State Land 

Register 1880:34–35 cited in Bowers and Muessig 1982:78). However, this trend in the production of local vegetables 

decreased during the 1880s as the first mining boom came to an end (Hardman and Mason 1949:24 cited in Bowers 

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CULTURAL RESOURCES 

and Muessig 1982:78–79). Hardman and Mason (1949:24) indicated that as the early boom period in mining declined, 

so did the acreage used in the production of fruits and vegetables. They attribute this to the lack of irrigation, the 

remoteness of the area, and the high cost of transportation to markets outside of the area. 

Wild Horse Industry 

The trapping of wild horses has been a continuing industry since settlers began arriving in the 1850s, and at first met 

the large demand for horses in California during the Gold Rush. Those who were engaged in the capture of mustangs 

became known as mustangers. 

In the late 1890s it was estimated that 80,000 wild horses roamed in eastern Nevada within the area encompassed by 

White Pine, Lander, Elko, Nye, and Eureka Counties (Amaral 1976:20). Shortly thereafter, there was a large demand 

for horses from the Quartermaster Remount Service. Established in 1908 to procure horses for military transportation, 

the service procured approximately 571,000 horses during World War I. Agents from the Quartermaster Remount 

Service were stationed in Austin, Battle Mountain, and Elko, as well as other Nevada locations. 

After World War I, the demand for horses for use as pet food increased, and large numbers were captured and shipped 

via rail to the East Coast for processing. Horse meat originally canned for pet food was also known to have been 

consumed by humans during the Great Depression. After World War II, the pet food industry continued to expand to 

the point that the wild horse population was decimated. Finally, in 1971 legislation was passed that ended both the 

legal and the unregulated roundup of wild horses. Since then the BLM has developed a program of range management 

that is designed to keep the population of wild horses in check. 

3.23.2.3 Documented Cultural Resources 

3.23.2.3.1 Previous Studies and Surveys 

A total of 345 cultural resource investigations have been conducted within the vicinity of the project area. With the 

exception of linear cultural resource surveys, these investigations have primarily been focused within the Roberts and 

Simpson Park Mountains, and constitute approximately 16 percent (121,845 acres) of the project area (Figure 3-51). 

Cultural remains have been found at many locations on the landscape and demonstrate that people—indigenous 

peoples followed by European-Americans—have resided in the 3 Bars Project region for at least 8,000 years. A 

detailed summary of the documented resources by theme is presented in Cultural Context 3 Bars Ecosystem and 

Landscape Restoration Project (AECOM 2012). 

Within the 3 Bars Project area, investigations have resulted in the documentation of 1,109 resources, 354 of which are 

isolated finds. The remaining 755 cultural resource sites, summarized in Table 3-62, have varying characteristics and 

have been subjected to various levels of significance assessment; approximately 36 percent of the sites have not been 

evaluated for NRHP eligibility. 

 536 sites reflect early Native American sites and artifacts, including 7 resources that appear to represent 

ethnohistoric usage including 6 with prehistoric and historic components. 

 219 sites reflect historic-era land use. These sites consist of the remains of early trails, transportation routes, 

and communication systems and reminders of historic-era mining and related charcoal production and 

ranching and sheepherding activities. 

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 52 sites contain evidence of both prehistoric and historic-era land uses. 

3.23.2.3.2 Documented Prehistoric Sites, Features, and Artifacts 

The area is known to contain evidence of activities that occurred from the Early Archaic Period through the more 

recent Native American (Western Shoshone) period. Resources identified by prehistoric temporal periods are 

summarized in Table 3-63. The resources are discussed by temporal period; numerous cultural sites contain the 

remains of prehistoric occupations that span multiple periods of time over several temporal periods. 

Early Archaic 

Based on the presence of Pinto and stemmed projectile points, seven Early Archaic sites or site components have been 

identified within the project area. With the exception of 26EU1272, which is just north of U.S. Highway 50, all are 

within or immediately north of Roberts Mountains. Two of these sites have not been evaluated for eligibility for 

listing in the NRHP, three have been recommended as not eligible, and two appear eligible for inclusion in the NRHP. 

TABLE 3-62 

Summary of Documented Resources 

Site Type Eligible Sites Not-Eligible Sites Unevaluated Sites Total 

Prehistoric 85 240 152 477

Prehistoric/Historic 27 8 17 52

Total Prehistoric Sites 112 248 169 529

Ethnohistoric/Prehistoric 4 0 0 4 

Ethnohistoric/Historic 2 0 0 2 

Ethnohistoric 0 0 1 1 

Total Ethnohistoric Sites 6 0 1 7 

Historic 76 54 89 219

Grand Totals 194 302 259 755

Middle Archaic 

Of the sites that can be associated with a particular prehistoric period, the majority (116) contain Middle Archaic 

markers, Elko and Gatecliff style projectile points. Given the large number of sites dating to this time period, it 

appears that this time frame shows a large increase in the intensity of prehistoric land use during the Middle Archaic, 

and most likely an associated increase in population. Almost half of these resources (51) have been recommended as 

eligible for inclusion in the NRHP, 37 appear not to be eligible, and 28 are unevaluated. With the exception of five 

sites located in the southern portion of the project area, north of U.S. Highway 50, the remaining sites are distributed 

along the upper fans and higher elevations within Roberts Mountains and the southern end of the Simpson Park 

Mountains. Three of these sites also contain Early Archaic components, indicating some reuse of locations from the 

earlier time period. The vast majority of the 116 sites (97 sites) consist entirely of lithics, 11 sites also contain ground 

stone, 6 appear to represent at least short-term habitation based on the presence of fire-cracked-rock and/or hearth 

features, and lithics with rock circles are present at two sites. 

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Late Archaic 

A total of 54 Late Archaic sites defined by the presence of Rose Spring and Eastgate style projectile points have been 

defined primarily within the Roberts Mountains area, although a small number are also located north of U.S. Highway 

50 in the southern portion of the project area. More than half of these sites (28) also contain Middle Archaic 

components, indicating reuse of locations from the earlier period, and the remaining 26 sites represent expansion of 

land uses and the assumed increase in the intensity of resource procurement. The majority of these sites (27 sites) 

appear eligible for listing in the NRHP, 9 are unevaluated, and 18 have been recommended as not eligible. 

TABLE 3-63 

Summary of Documented Prehistoric Cultural Sites 

Site Type Eligible Not Eligible Not Evaluated Total 

Early Archaic 2 3 2 7 

Middle Archaic 51 37 28 116

Late Archaic 27 18 9 54

Numic Occupation 7 11 14 32

Unknown Prehistoric 39 192 118 349

Totals 126 261 171 5581 

1

 Multiple occupations/time periods are represented at 34 sites. 

Numic Occupation 

Numic occupation, implied from the presence of desert series projectile points and/or brownware ceramics, is present 

at 32 locations. With the exception of site 26EU353, which is at the southern end of the project area, these sites tend 

to be located within the pinyon-juniper zone of Roberts Mountains. Seven of these sites have been recommended as 

eligible for listing in the NRHP, 11 as not eligible, and 14 have not been evaluated. Reuse of locations from the 

Middle Archaic Period and/or earlier part of the Late Archaic Period is documented at 14 of these 32 sites. As with 

sites from the Middle and Early portions of the Late Archaic Period, 19 of these sites consist of lithic materials only. 

Complex constituents, including hearths (suggesting campsites), are located at three sites; three resources contain 

lithics and ground stone, seven contain brownware ceramics, and one site has an associated rock ring. 

Unknown Prehistoric 

A total of 353 prehistoric sites or site components lacking temporal markers that would place them within a specific 

time frame have been identified and documented. The majority (328) contain only flaked stone. Five of these sites 

appear to be opportunistic quarry locations, and eight sites possess flaked and ground stone artifacts. The remaining 

24 sites consist of hunting blinds (4 sites), rock rings or flaked stone with rock ring features (7 sites), lithics and 

burned bone and/or hearth features (5 sites), lithics and bedrock mortars (1 site), and one complex rock shelter site 

with flaked stone, fire-cracked rock, and ground stone. Approximately one-third (118) of these sites have not been 

evaluated, more than half (192) have been recommended as not eligible for listing in the NRHP, 39 resources have 

been recommended as eligible, with the evaluation pending additional assessment at 4 of these sites. This resource 

type is primarily clustered within the Roberts Mountains area. 

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3.23.2.3.3 Documented Historic-era Sites and Features 

Historic-era enterprises in the region have also left their marks on the landscape, such as the routes of the Pony 

Express, Overland Stage and Transcontinental Telegraph, and the E&PRR, and various mining ventures and 

associated charcoal production, and ranching operations, some of which date to early settlement of the region (Table 

3-64). A review of these and other important developments provides a cultural background against which to define the 

context for the historic-era events that shaped the natural environment into the mosaic that exists today. Cultural 

resource sites that reflect early exploration have not been identified within the project area. 

 

TABLE 3-64 

Summary of Documented Historic-era Cultural Sites 

Unevaluated/Incomplete 

Site Type Eligible Not Eligible Total Evaluations 

Pony Express/Overland Stage/Telegraph Route 0 0 7

1

7 

Transportation 6 7 2 15

Communication 2 0 2 4 

Early Settlement/Ranching 2 0 12 14

Mining 5 12 1 18

Charcoal Production 81 4 28 113

Ranching and Agriculture 5 6 8 19

Unassociated Historic Sites 0 39 40 79

Totals 101 68 100 2692 

1

 The Pony Express National Historic Trail is considered nationally significant and only segments are 

unevaluated/incomplete. 

2

 Includes 50 sites with prehistoric or ethnohistoric components. 

3.23.2.3.4 Summary of Identified Resources - Transportation and Communication 

This theme is represented by the routes of the Pony Express, Overland Stage, Lincoln Highway/Austin-to-Eureka 

Stage, Transcontinental Telegraph, and the E&PRR, and historic roads, telegraph and telephone alignments. Seven 

resources associated with the Pony Express/Overland Stage and Transcontinental Telegraph route have been 

documented in the southern portion of the project area, and all are classified as unevaluated. The route of the Austinto-Eureka Stage and Lincoln Highway is immediately north and south of U.S. Highway 50, and has been 

recommended as not eligible for listing in the NRHP. Three of the four historic road segments are situated on the 

southwest flank of Roberts Mountains and are also listed as not eligible. An alignment of the Old State Route 21 is 

near the northern boundary of the project area and is listed as eligible. 

As part of the mitigation to offset indirect visual impacts and direct impacts on the remains of the E&PRR resulting 

from construction of the Falcon transmission line project, Summit Envirosolutions, Inc., documented nearly the entire 

length of the E&PRR (McQueen et al. 2009). Within the project area the route is represented by the railroad line, 

3 Bars Project Final EIS 3-445 October 2016 
CULTURAL RESOURCES 

workcamps with historic refuse, an historic structure, and the remains of Chimney’s (Alpha) Station, Summit Station, 

and Deep Wells Station. The historic structure and Chimney’s Station have not been evaluated, the Deep Wells site 

has been recommended as not eligible for listing in the NRHP, and the remaining elements of the route have been 

recommended as contributing elements. Four additional resources include the remains of telegraph and telephone 

lines, one of which is unevaluated, and one is the remains of the McClusky Peak toll station line, which along the 

western project area boundary and has not been evaluated for eligibility. The other two resources include the remains 

of the telephone line extending to the Three Bars Ranch, which has been recommended as eligible for listing; the 

remaining site consists of three unevaluated segments of a telegraph line that parallels the west side of Tonkin Road 

near the northern end of the project area. Although no remains of the transcontinental telegraph have been 

documented, the route most likely paralleled the route of the Pony Express/Overland Stage. 

3.23.2.3.5 Summary of Documented Resources - Early Settlement/Ranching 

The archaeological manifestations of early settlement are represented by signs of early ranching within the project 

area and consist of 14 resources. Ten sites documented in the project area reflect named early 

settlements/ranches—the Sadler, Tonkin, and Willow Creek ranches, Walti Hot Springs, Bartine Ranch, Indian 

Ranch, and Peretti’s, Ferguson, Andrew Louck, and Isaacs ranches. In addition, the remains of four other unnamed 

resources appear to be the remains of early ranches/settlements. With the exceptions of the dugout with historic 

refuse and Andrew Louck’s Ranch, which have been recommended as eligible for inclusion in the NRHP, the 

remaining ranches or remains of ranches have not been evaluated.

3.23.2.3.6 Summary of Documented Resources - Mining 

A review of the previously documented sites indicates that the remains of 18 mines or mining-associated cultural 

resources have been documented within the project area. These resources are somewhat clustered in the vicinity of 

Mount Hope, with the remainder consisting of one on the southwest flank of Roberts Mountains, one in the Simpson 

Park Mountains, and another at Lone Mountain. Mines and mining camps, including the remains of the Mount Hope 

and Keystone Mines, represent ten of the documented resources. The Mount Hope Project and another resource 

consisting of adits and tailings have been recommended as not eligible for listing in the NRHP; the remaining sites are 

unevaluated. 

The remaining eight sites consist of prospect pits, refuse deposits (one of which appears to be associated with a 

Chinese occupation), cairns, a quarry, and a trail. With the exception of the trail that has not been evaluated and the 

quarry and Chinese occupation site, which have been recommended as eligible, all of the remaining mining resources 

have been recommended as not eligible for inclusion in the NRHP. 

3.23.2.3.7 Summary of Identified Resources - Charcoal Production 

Consisting of 113 resources, the remains of charcoal production are well represented in the 3 Bars Project area. The 

majority of these resources are in the southern Roberts Mountains, and the remaining sites are scattered in the uplands 

throughout the northern half of the project area. With the exception of seven resources consisting of associated refuse, 

a road, a logging skid trail, and piles of ax-cut wood, all of these documented resources contain the remains of 

charcoal platforms, and 26 sites appear to be the remains of camps. The majority of the sites (81 sites) appear eligible 

for inclusion in the NRHP, 28 have either not been or are only partially evaluated, and 4 sites remain unevaluated. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

A treatment plan was developed and implemented to mitigate adverse effects on 13 historic properties located within 

the Gold Bar II Mine Project, which were determined by the Nevada State Office of Historic Preservation to be 

contributing elements to the Roberts Mountains Carbonari District, part of the Eureka Charcoal District. This 

treatment plan consisted of detailed documentation of 31 charcoal platforms, 9 distinct habitation loci, and 1 trash 

dump (Reno et al. 1994:i–ii). 

3.23.2.3.8 Summary of Cultural Resources - Ranching and Agriculture 

Although ranching, sheepherding, and the wild horse industry are represented by documented cultural resources 

within the project area, resources specifically associated with agriculture have not been identified. As mentioned 

above, “Early Settlement” is represented by the ranches or the remains of early ranching settlements at 14 locations. 

The remaining 15 ranching-related resources consist of fences and rock walls (4 sites), ranching-related refuse (3 

sites), 2 roads, and 6 miscellaneous ranching-related features (e.g., depressions, corrals, a well, a sheep camp, and log 

troughs). Five of these sites have been recommended as not eligible for listing in the NRHP and the remaining ten 

either have been recommended as not eligible (six) or have not been evaluated (four). 

Two sites with aspen tree carvings associated with Basque sheepherding have been documented within the project 

area. Both sites are located within the Simpson Park Mountains in the western portion of the project area, and have 

been recommended as not eligible for listing in the NRHP. 

Two horse traps or blinds have been documented within the project area. One, located on the northwest flank of 

Roberts Mountains, appears eligible for listing in the NRHP; the other, in Pine Valley, has not been evaluated. 

3.23.2.3.9 Summary of Cultural Resources - Unassociated Historic Sites 

A total of 79 documented historic cultural resources sites are lacking the data necessary to determine their 

association with historic-era themes. The majority (65) of these 79 sites consists of historic-era refuse; none of 

these sites have been recommended as eligible for listing in the NRHP, 29 appear not eligible, and 36 are 

unevaluated. The remaining 14 resources consist of features such as spring improvements, wagon parts, a fence, a 

boundary line, a historic campsite, rock walls, logging isolates, a rock shelter with stacked rocks, a log building, 

rock rings, a schoolhouse, a stone dam, a structure of unknown function, and wooden poles. With the exception of 

the log building, schoolhouse, wooden poles, and the unknown structure that have not been evaluated (four sites), 

the remaining ten sites have been recommended as not eligible for listing in the NRHP. 

3.23.3 Environmental Consequences 

3.23.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Several issues of concern have been identified by the BLM in the AECC and through scoping. These would not be 

addressed directly by the restoration treatments, but could be dealt with indirectly through surveys and studies 

conducted on treatment areas prior to treatment. These are: 

 Site management is currently “piecemeal,” resulting in fracturing of the historic landscape and loss of 

integrity of cultural resources. 

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CULTURAL RESOURCES 

 Approximately 84 percent of the 3 Bars ecosystem has not been inventoried for the presence of prehistoric 

and historic-era resources that may be eligible for inclusion in the NRHP or which may be contributing 

elements to a historic cultural landscape. 

 A large number of previously identified cultural resources have not been evaluated for inclusion in the 

NRHP. 

 The physical, historic remnants of the Pony Express Trail have not been fully inventoried or evaluated to 

identify related segments or sites that may eligible for the NRHP. 

3.23.3.2 Significance Criteria 

Federal historic preservation legislation provides a legal environment for the documentation, evaluation, and 

protection of archaeological and historic sites that may be affected by federal undertakings, by private undertakings 

operating under federal license, or on federally managed lands. The significance criterion used to evaluate the impacts 

of the alternatives on cultural resources is whether any action would adversely affect historic properties unevaluated 

or eligible for inclusion in the NRHP. 

The NRHP eligibility of cultural resources is determined by applying the criteria outlined in 36 CFR § 60.4 (see 

Regulatory Background Section 3.23.1). In addition to having eligibility related to one of the four criteria, a cultural 

resource must also retain sufficient physical integrity to convey its importance. The National Register has defined 

seven elements of integrity—Location, Design, Setting, Materials, Workmanship, Feeling, and Association. 

For the 3 Bars Project, the NRHP eligibility criteria were further refined into research domains for prehistoric and 

historic-era sites. Five research themes were defined for the prehistoric period resources and consisted of 

Paleoenvironment, Geomorphology and Chronology, Lithic Technology, Settlement and Subsistence, and External 

Relations and Exchange (AECOM 2012). For historic-era properties, the themes consist of Early Exploration, 

Transportation and Communication, Early Settlement, Mining and Associated Charcoal Production, and Ranching 

and Agriculture. 

Impacts to cultural resources were assessed in light of the degree to which the project may adversely affect cultural 

resources eligible for listing in the NRHP, or unevaluated resources that may potentially be eligible for listing. Under 

36 CFR Part 800 (regulations for implementing the National Historic Preservation Act), “An adverse effect is found 

when an undertaking may alter, directly or indirectly, any of the characteristics of a historic property that qualify the 

property for inclusion in the National Register in a manner that would diminish the integrity of the property’s 

location, design, setting, materials, workmanship, feeling, or association.” Adverse effects can include physical 

disturbance or alteration of a property or its setting, visual, atmospheric, and auditory intrusions, removal of a 

building or structure from its historic location, and deterioration through neglect. Any adverse effect identified under 

the National Historic Preservation Act criteria is also considered to be a significant adverse impact under NEPA. 

3.23.3.3 Direct and Indirect Effects 

3.23.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Effects 

Historically, there have been potential direct conflicts between land restoration treatments and archaeological/cultural 

resources, and specific impacts to known and undiscovered cultural resources can be severe. For example, surface3 Bars Project Final EIS 3-448 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

disturbing activities may destroy spatial context as well as damage or destroy individual artifacts, features, and 

structures. Cultural properties consisting only of surface manifestations could be destroyed or severely affected during 

surface-disturbing activities. 

Beneficial Effects 

Stabilization and restoration of riparian systems would reduce streambank erosion and would ensure that buried 

cultural and paleontological resources adjacent to streams remained intact. Surveys would be conducted to identify 

the locations of cultural and traditional resources prior to treatment activities to ensure that these resources would be 

protected. 

3.23.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments

Cultural resource investigations have been conducted on the Black Spring, Indian Creek Headwaters Middle, Mud 

Spring, Garden Spring, Roberts Mountain Spring, Trail Spring, Lower Henderson 1, Vinini Creek, Upper Vinini 

Creek, Upper Willow, Roberts Creek, Willow Creek, Denay Pond, Lone Spring, and Treasure Well units. Fifteen 

investigations have resulted in the identification of 23 cultural sites. Seventeen sites have either been determined 

eligible for inclusion in the NRHP or have not been evaluated for NRHP eligibility. The remaining six sites have been 

determined not eligible for NRHP listing. 

Adverse Effects 

Manual methods would result in general surface disturbance that could disrupt the spatial context of archaeological 

constituents, mulching with organic materials would compromise radiometric dating, and the use of hard-edged tools 

could damage artifacts. There is also the potential for unauthorized collection of artifacts by workers. Although the 

removal of vegetation has the potential to expose archaeological components, and thereby increase the possibility of 

vandalism and/or unauthorized collection of artifacts, monitoring during project implementation would significantly 

reduce the risk of unauthorized collection. Cultural inventories conducted in accordance with the 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 3 Bars Ecosystem and 

Landscape Restoration Project, Eureka County, Nevada (Programmatic Agreement) would result in the identification 

of historic properties, thereby allowing avoidance (see Appendix B). Because inventory and site assessment would be 

conducted prior to project implementation and all eligible or unevaluated resources would be avoided, there would be 

no direct adverse effects to cultural resources. 

Use of chainsaws to remove pinyon-juniper should have little or no effect on cultural resources. Because of the 

limited scope and small size of the acreage that would be treated with manual methods, however, manual methods 

may do little to reduce the potential for wildfires that could result in severe impacts to cultural resources either from 

the fire, fire suppression activities, or the indirect effects associated with the increased potential for erosion as a result 

of catastrophic wildfire, and which have the potential to more significantly compromise the integrity of archaeological 

deposits. 

The use of a track hoe or back hoe for stream channel restoration would result in surface and shallow subsurface 

disturbances that would likely introduce organic materials to lower soil layers, thereby contaminating any surface or 

shallow subsurface cultural resource sites that contain early historic or prehistoric datable organics, such as charcoal, 

3 Bars Project Final EIS 3-449 October 2016 
CULTURAL RESOURCES 

wood, or preserved plant materials. Surface and shallow subsurface impacts would also include horizontal and 

vertical displacement of the upper portion of soils where archaeological resources could be contained, potentially 

compromising depositional context and integrity, and damaging or destroying artifacts (USDOI BLM 2007c:4-107). 

Beneficial Effects 

Stabilization and restoration of riparian systems would reduce streambank erosion and ensure that cultural and 

paleontological resources buried near streams remained intact. Uncontrolled wildfire has the potential to significantly 

impact cultural resources, and the reduction of fuels that would contribute to such events is one of the goals of the 3 

Bars Project. Stream channel restoration and removal of pinyon-juniper and noxious weeds and other invasive nonnative vegetation from riparian zones would improve stream functionality and encourage the growth of fire-resilient 

vegetation, which would enhance the ability of the riparian zone to function as a fuel break. 

Aspen Treatments 

An inventory conducted at RM-A2 documented a site with historic features and prehistoric flaked stone that has been 

recommended as eligible for inclusion in the NRHP. 

A Class III cultural resource inventory would be conducted prior to treatment to reduce the potential for treatments to

adversely affect historic properties. Inventory, assessments of NRHP eligibility, and avoidance of adverse effects are 

outlined in the stipulations of the Programmatic Agreement prepared for the 3 Bars Project, and would meet the 

requirements of Section 106. Improvement in the health of aspen stands, and removal of pinyon-juniper near aspen 

stands to create fire breaks, would help to reduce the risk of wildfire spread. These treatments, however, would do 

little to reduce the long-term risk to archaeological and other cultural resources from wildfire as few acres would be 

treated annually in aspen stands. 

Pinyon-juniper Treatments 

Twelve cultural resources investigations have been conducted within portions of the Atlas, Cottonwood/Meadow 

Canyons, Dry Canyon, Gable Corridor, Henderson Corridor, Sulphur Spring Wildfire Management, Three Bars 

Ranch, Tonkin North and South, Upper Roberts Creek, Vinini Corridor, and Whistler units. These resulted in the 

documentation of 189 cultural sites, of which 71 were recommended and/or determined to be not eligible for inclusion 

in the NRHP, 71 were determined eligible, and 47 were unevaluated. Dominant cultural resources include prehistoric 

open lithic scatters and historic resources associated with charcoal production. Historic-era resources represent all 

themes including the built environment consisting of historic structures and ranches. A segment of the Pony Express 

Trail is within the Henderson Corridor Unit. 

Adverse Effects 

The types of adverse effects from manual, mechanical, and prescribed fire treatment methods, and from the use of 

small, temporary exclosure fencing, would be similar to those discussed under Effects Common to All Alternatives, 

and under Riparian Treatments. The greatest risks to cultural resources would be from mechanical and fire treatments. 

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. 

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

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. 

Stumps that smolder and burn have the potential to affect nearby buried materials. Heavy duff, surface logs, and roots 

that smolder and burn have the potential to expose subsurface materials to heat over a period of time, and hence have 

the potential to affect cultural materials. Fires that burn hot and fast through a site may have less of an effect on 

certain types of cultural materials than fires that smolder in the duff, or than logs that burn for a period of time 

(USDOI BLM 2007c:4-104). Fire can cause physical damage to sites from snags/trees falling on them, and can 

indirectly lead to loss of archaeological data due to increased damage from rain, changes in drainage patterns, soil 

erosion, and flooding (USDOI BLM 2007c:4-107). 

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, 

cultural resource specialists could work with fire managers to determine the predicted temperature and duration of a 

fire through an area, and possibly to modify burn plans to minimize effects to cultural resources. The emergency 

nature of wildfires can lessen management’s ability to prioritize conservation of cultural resources. 

Protecting cultural resources during fire would begin with fire management planning. During planning, the BLM 

would define vulnerable cultural resources by classes of site-types and specific sites, identify appropriate protection 

measures for them, and identify appropriate management responses with regard to cultural resources in the event of 

fire. Consultation with State Historic Preservation Office, Tribes, and other appropriate entities should be part of the 

project planning process, especially when designing fire-specific protocols for identification and protection of 

potentially affected cultural resources (USDOI BLM 2007c:4-105). 

Beneficial Effects 

Cultural inventories conducted in accordance with the Programmatic Agreement established for this project would 

result in the identification and avoidance of historic properties. This assessment would also include determination of 

eligibility of a portion of the Pony Express route mentioned above. The Pony Express route is Congressionally 

designated as a National Historic Trail, thus it is anticipated that the NRHP assessment may include consultation and 

concurrence with the National Park Service. Because inventory and site assessment would be conducted prior to 

project implementation and all resources would be avoided, there would be no direct adverse effects to cultural 

resources. Although the removal of vegetation has the potential to expose archaeological components, and could 

thereby increase the possibility of vandalism and/or unauthorized collection of artifacts, monitoring during project 

implementation would significantly reduce the risk of unauthorized collection. 

Given the large number of acres that would be subject to treatment, together these methods would significantly reduce 

hazardous fuels and the risk of an uncontrolled catastrophic wildfire that could adversely affect historic properties. 

Therefore, pinyon-juniper treatments would result in significant long-term benefits and protection of cultural 

resources from catastrophic wildfire. 

3 Bars Project Final EIS 3-451 October 2016 
CULTURAL RESOURCES 

Sagebrush Treatments 

Eleven investigations have been conducted on portions of the Alpha, Coils Creek, Kobeh East, Nichols, Roberts 

Mountain Pasture, Rocky Hills, South Simpson, Table Mountain, Three Corners, West Simpson Park, and Whistler 

Sage units. These studies have documented 27 cultural sites, of which 5 have been determined not eligible, 3 have 

been determined eligible, and 19, including a portion of the Pony Express route, have not been evaluated for NRHP 

eligibility. Two of the eligible sites are components of the E&PRR, which has been completely documented. These 

sites would require mitigation if it is not possible to avoid them during project implementation. 

Adverse Effects 

Manual and mechanical treatments could be used in all areas and the potential for adverse effects would be the same 

as Effects Common to All Alternatives and effects from pinyon-juniper treatments. 

Livestock could to be used on the 3 Bars Project area to remove cheatgrass. While grazing animals could displace and 

damage artifacts and generally compromise the integrity of surface archaeological deposits, use of livestock would be 

limited to small treatment areas and would most likely not affect historic properties. 

Beneficial Effects 

Adherence to the stipulations outlined in the Programmatic Agreement would ensure that historic properties are not 

subject to adverse effects. The greatest inadvertent threat to cultural resources would be associated with uncontrolled 

wildfire, and these effects have the potential to be severe. However, treatments would reduce fuel loads and fuel 

breaks would aid in protecting historic properties from uncontrolled catastrophic wildfire, resulting in long-term 

beneficial effects. 

3.23.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

Mechanical and fire treatments have the greatest potential for harming cultural resources. The number of acres treated 

using manual and mechanical equipment would be similar to that under Alternative A. Prescribed fire and wildland 

fire for resource benefit would not be used on several thousand acres annually, as they would under Alternative A. 

Fire has the potential to cause inadvertent effects to cultural sites. By removing fire under this alternative, these risks 

would be substantially less under Alternative B than under Alternative A. 

Under Alternative B, the BLM would be unable to restore fire as an integral part of the ecosystem. It is unlikely that 

the BLM would be able to slow the spread of noxious weeds and other invasive non-native vegetation, including 

cheatgrass. Cheatgrass is a major contributor to providing fuel for wildfire. It is unlikely the trend toward large-sized 

fires of moderate to high severity in sagebrush and large stand-replacing fires in pinyon-juniper would slow or reverse 

in the long-term, which would continue to be a threat to historic properties. 

3.23.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Given that mechanical and fire treatments, and to a lesser extent biological treatments using livestock, have the 

greatest potential to harm cultural sites, these risks would be eliminated under this alternative. However, large 

numbers of workers and their vehicles would be needed to accomplish proposed treatments under this alternative. 

Vehicle miles traveled would likely be greatest under this alternative and vehicles could crush cultural materials. 

Increased numbers of workers could increase the potential for looting. Downed trees and slash material from 

3 Bars Project Final EIS 3-452 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

treatments would be difficult to remove without mechanical equipment or pile burning. Some downed wood and slash 

could be sold or made available to the public as firewood. 

The number of miles of fire and fuel breaks created under this alternative would be substantially less than under 

Alternatives A and B as the BLM would not be able to use mechanical equipment, such as bulldozers, mowers, and 

mulchers, and prescribed fire to create fire and fuel breaks. 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. 

Under Alternative C, it is unlikely the trend toward large-sized fires of moderate to high severity in sagebrush and 

large stand-replacing fires in pinyon-juniper would slow or reverse long-term, and wildfire would continue to be a 

threat to historic properties. 

3.23.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects on cultural resources from 3 Bars Project treatments as no treatments would be 

authorized under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper to 

promote healthy, diverse stands; slow the spread of noxious weeds and other invasive non-native vegetation, 

especially cheatgrass; restore fire as an integral part of the ecosystem; or reduce the risk of a large-scale wildfire. 

Thus, long-term threat to historic resources from wildfire would be greatest under Alternative D. 

3.23.3.4 Cumulative Effects 

The CESA for cultural resources is approximately 1,267,997 acres and includes the 3 Bars Project area and a 5-mile 

buffer around the 3 Bars Project area that encompasses the viewshed of the Pony Express Trail and Eureka Palisade 

Stage lines that traverse the entire project area (Figure 3-1). Approximately 94 percent of the area is administered by 

the BLM, 5 percent is privately owned, and 1 percent is administered by the U.S. Forest Service. Past and present 

actions that have influenced land use and access in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.23.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

The BLM would treat noxious weeds and other invasive non-native vegetation under existing authorizations. New 

infestations would typically be found in newly burned or disturbed areas, and in areas where livestock and wild horses 

congregate. Treating infestations while they are small and reducing the amount of area covered by existing large 

infestations, would result in few effects, if any, to historic resources. There could be some risk associated with discing 

soil to remove cheatgrass, and possibly drill seeding, but these risks would be negligible. Surveys would be conducted 

prior to treatments to determine whether there are additional cultural sites in these areas which could be impacted by 

treatment actions. Existing and newly-found sites would be mitigated in accordance with the Programmatic 

Agreement before restoration work begins. 

Road and utility construction, land development, and mineral, oil, gas, and geothermal leasing and development 

projects could affect cultural resources, but their impacts to these resources would be evaluated based on plans 

submitted by the developer or lessee. Cultural resources surveys completed for the Mount Hope Project documented 

242 cultural sites within the mine project footprint, including 80 prehistoric and 142 historic sites, and an additional 

352 sites within the larger area of potential effects, which includes a portion of the 3 Bars Project area. 

Implementation of the Mount Hope Project would result in adverse impacts to 83 eligible sites. Under the 

Programmatic Agreement developed between the mine proponent and State Historic Preservation Office, the 

proponent would develop, and submit to the BLM for approval, a treatment plan to address the potential direct 

3 Bars Project Final EIS 3-453 October 2016 
CULTURAL RESOURCES 

impacts to the 83 officially eligible sites. The proponent would implement the treatment plan prior to any surface 

disturbance of eligible sites within the area of direct impacts. All adverse effects under the National Historic 

Preservation Act and direct and indirect impacts under the NEPA to known eligible properties identified within the 

project area, and properties discovered during construction activities, would be mitigated in accordance with the 

Programmatic Agreement and the treatment plan prepared for the project (USDOI BLM 2012b:3-604). The BLM 

concluded that mine activities would not significantly impact cultural areas outside of the mine footprint (USDOI 

BLM 2012b:4-605). There would also be cumulative short-term visual effects from the Mount Hope Project, but 

these effects would be somewhat offset by improvement to the visual landscape from the 3 Bars Project. 

Since 1985, wildfires have burned an average of about 7,000 acres annually within the CESA. Assuming a similar 

rate in the future, about 140,000 acres would burn from wildfires during the next 20 years. In addition to the 127,000 

acres treated on the 3 Bars Project area to reduce hazardous fuels and improve ecosystem health, an additional 15,000 

acres could be treated under current and reasonably foreseeable future authorizations within the CESA, totaling about 

11 percent of the CESA. The BLM would conduct surveys prior to treatments to determine whether there are 

additional cultural sites in these areas that could be impacted by treatment actions and existing and newly-found sites 

would be mitigated in accordance with the Programmatic Agreement before hazardous fuel treatment work begins. 

There could be adverse effects to eligible historic properties from fuels and other vegetation treatments within the 

CESA. Physical effects to eligible historic properties would be avoided where possible, but visual effects from 

treatments may not be fully avoided. Long-term, the 3 Bars Project and other restoration treatments should result in a 

landscape that is more fire resilient and similar to the Potential Natural Community. Noxious weeds and other 

invasive non-native vegetation treatments would remove vegetation that contributes to short return-interval fires and 

loss of native vegetation and could cause adverse effects to eligible historic sites. In addition, the BLM would conduct 

stream bioengineering and plantings on about 31 miles of stream to slow stream flow and create pools and wet 

meadows, and remove encroaching pinyon-juniper to improve wetland and riparian vegetation. These activities would 

help to reduce the potential for streambank erosion and potential loss of cultural materials. 

3.23.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on cultural resources 

would be similar to those described under Alternative A. Adverse effects to cultural resources within the CESA would 

generally be the same as described for Alternative A. Although use of fire would not occur within the 3 Bars Project 

area, the use of fire could occur on several hundred acres annually in the remainder of the CESA. By not using fire to 

reduce hazardous fuels and improve vegetation resiliency to fire, there would be greater potential for more extensive 

and intense wildfires to occur in place of controlled burns on the 3 Bars Project area under this alternative as 

compared to Alternative A. 

Because 3 Bars Project actions would affect only about 6,350 acres annually, or 1 percent of the CESA, and treatment 

areas would be surveyed prior to treatment to avoid or reduce impacts to cultural sites, there would be a negligible 

cumulative effects to cultural resources from 3 Bars Project actions. These effects would be less than under

Alternative A, but greater than under Alternative C. 

3.23.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on cultural resources 

would be similar to those described under Alternative A. Adverse, short-term effects to cultural resources associated 

3 Bars Project Final EIS 3-454 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-455 October 2016 

with the use of fire and mechanized equipment would not occur under Alternative C. However, fire and mechanized 

equipment could be used on about 1,500 acres annually in other portions of the CESA and outside of 3 Bars Project 

areas to improve habitat, remove hazardous fuels, and reduce the risk of wildfire, and could affect cultural resources 

in those areas. 

Because 3 Bars Project actions would affect only about 3,200 acres annually (less than 0.5 percent of the CESA), and 

the BLM would conduct pre-treatment surveys for cultural resources to reduce the potential for effects to eligible 

sites, effects to cultural resources within the CESA would be negligible. 

3.23.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on cultural resources 

would be similar to those described under Alternative A. There would be no cumulative effects on cultural resources 

from 3 Bars Project treatments as no treatments would be authorized under this alternative. The BLM could create fire 

and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds 

and other invasive non-native vegetation using ground-based and aerial application methods of herbicides, especially 

cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildfire under current 

and reasonably foreseeable future authorized actions, but on a very limited acreage (about 1,500 acres annually; less 

than 0.1 percent of the CESA). Thus, adverse effects and benefits to cultural resources would be less under this 

alternative than under the action alternatives. 

3.23.3.5 Unavoidable Adverse Effects 

Because cultural resources are nonrenewable and their locations are for the most part unknown, project-related 

treatments have the potential to adversely impact historic properties, including those eligible for inclusion in the 

NRHP. Surveys, inventories, assessments of affect, and treatments designed to mitigate adverse effects conducted 

prior to project implementation would result in avoidance, which is the mitigation measure preferred by the BLM, or 

some other treatment (e.g., data recovery), that would reduce adverse effects. These measures, however, may only 

reduce cumulative effects. In addition, adoption of an unanticipated discovery plan would effectively mitigate effects 

either through avoidance or data recovery. While implementation of archaeological excavation as part of a data 

recovery plan could result in the partial or total destruction of the site, the recovered data would effectively mitigate 

for this destruction. Therefore, project implementation under all four alternatives would not result in unavoidable 

adverse effects under NEPA.

3.23.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

Any destruction of cultural resources that are eligible for inclusion in the NRHP would represent long-term loss of 

data. In the event that avoidance of archaeological resources is not feasible, other mitigation measures may include 

archaeological data recovery carried out under an approved treatment and data recovery plan. Such a plan could result 

in the partial or total destruction of the site. However, any investigations of cultural resources made during inventories 

or investigations required prior to restoration treatments would enhance the knowledge of the historic-era and 

prehistory of the region and serve to effectively mitigate any adverse effects (USDOI BLM 2007c:4-249). 

Due to the build-up of fuels, historic properties within the 3 Bars Project could be compromised either directly or 

indirectly by catastrophic wildfire. For example, the loss of vegetation would expose archaeological sites to an 
CULTURAL RESOURCES 

increased risk from erosion, or direct effects could compromise the vertical and horizontal integrity of historic-era and 

prehistoric archaeological sites, and obsidian hydration rims for prehistoric resources, thereby limiting the ability to 

place prehistoric site constituents within a relative chronology. Catastrophic wildfire would also result in substantial 

damage or complete destruction of wooden buildings and structures that have been determined to be eligible for 

NRHP listing. 

3.23.3.7 Irreversible and Irretrievable Commitment of Resources 

Cultural resources are nonrenewable, so any impacts that may result from treatments would be irreversible, and the 

integrity of the affected resource would be irretrievable. Therefore, impacts to near surface archaeological sites from 

treatments could result in partial or complete destruction of the resource, and such loss of scientific data would be 

irreversible and irretrievable. Although archaeological investigations carried out under an approved treatment and 

data recovery plan could result in partial or complete destruction of the site, the recovered scientific data would 

effectively mitigate for this destruction. These investigations carried out prior to vegetation treatments would enhance 

and fill gaps in the body of knowledge as it relates to the history and prehistory of the region, and would serve to 

effectively mitigate further potential effects of activities in the area (USDOI BLM 2007c:4-249). 

3.23.3.8 Significance of the Effects under the Alternatives 

The significance criterion used to evaluate the impacts of the alternatives on cultural resources is whether any action 

would adversely affect historic properties eligible or unevaluated for inclusion in the NRHP. The Mount Hope Project 

could have direct and indirect impacts to 83 NRHP-eligible sites. Direct and indirect impacts to known eligible 

properties within the area of potential effects would be mitigated in accordance with the programmatic agreement and 

treatment plan developed cooperatively by the Mount Hope Project proponent, BLM, and State Historic Preservation 

Office. Any previously unknown eligible properties that may be discovered during construction activities would be 

mitigated in accordance with the Programmatic Agreement. 

For 3 Bars Project treatments, most ground-based equipment would disturb only the upper few inches of soil and in 

most cases would be confined to previously disturbed areas such as roadways, trails, and rights-of-ways. Cultural 

resources on the surface should be discovered during pretreatment surveys. All treatment methods could cause 

indirect loss of cultural resources as a result of erosion and soil disturbance, but these effects should be minimal. 

Potential effects would be further reduced because the BLM has inventoried, or would conduct inventories for, 

cultural resources in treatment areas to lessen the chance that they would be inadvertently impacted by BLM 

vegetation restoration treatments. Thus, there should be a negligible cumulative loss of cultural resources on public 

lands due to herbicide and other vegetation treatment methods under all alternatives.

The BLM and State Historic Preservation Office have entered into a Programmatic Agreement that outlines the 

stipulations that will be followed to insure compliance with Section 106 of the National Historic Preservation Act for 

each phase of the 3 Bars Project. According to the Programmatic Agreement, all treatments shall be conducted in a 

manner consistent with the BLM and State Historic Preservation Office protocol. The BLM, in consultation with the 

State Historic Preservation Office, shall ensure that effects to historic properties are avoided through design, or 

redesign, or by other means in a manner consistent with the BLM and State Historic Preservation Office protocol. 

When avoidance is not feasible, the BLM, in consultation with the State Historic Preservation Office, Native 

American tribes, and interested persons, shall develop, or ensure that an appropriate treatment plan is designed to 

lessen or mitigate project-related effects to historic properties. For properties eligible under criteria (a) through (c) (36 

CFR § 60.4), mitigation, other than data recovery, may be considered in the treatment plan (for example, Historic 

3 Bars Project Final EIS 3-456 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-457 October 2016 

American Buildings Survey/Historic American Engineering Survey recordation, oral history, historic markers, 

exhibits, interpretive brochures or publications, etc.). Where appropriate, treatment plans shall include provisions 

(content and number of copies) for a publication intended for dissemination to the general public. When data recovery 

is required as a condition of approval, the BLM, in consultation with the State Historic Preservation Office, shall 

develop, or ensure development of a data recovery plan that is consistent with the Secretary of the Interior’s Standards 

and Guidelines for Archaeology and Historic Preservation (48 CFR § 44716-37) and Treatment of Historic 

Properties: A Handbook (Advisory Council on Historic Preservation 1980). By following the Programmatic 

Agreement, the BLM would ensure that there are no significant direct, indirect, or cumulative effects to cultural 

resources under all alternatives from 3 Bars Project actions. 

3.23.4 Mitigation 

Under all alternatives, the BLM shall implement the following measures in accordance with the Programmatic 

Agreement prepared for the 3 Bars Project. 

 Consult with local Tribes in accordance with Stipulation III (A) of the 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 (Appendix B).

 For each phase of the undertaking, the BLM shall evaluate cultural resources for NRHP eligibility, and 

consult with local Tribes or tribal members regarding areas of cultural or traditional religious importance, 

and consult with the State Historic Preservation Office and local Tribes regarding the NRHP determinations 

per Stipulation III(B) of the Programmatic Agreement. 

 Develop and implement appropriate treatment measures to mitigate adverse effects to historic properties, i.e., 

those resources determined eligible for inclusion in the NRHP, in accordance with Stipulation III(C) of the 

Programmatic Agreement. 

 Monitor treatment implementation according to the protocols outlined in Stipulation VII of the Programmatic 

Agreement, to insure that there are no inadvertent impacts to plant and wildlife of importance to traditional 

lifeways. 

 Human remains and burial items are sacred to the local Native American tribes. Therefore, the BLM shall 

provide training to all BLM and contract personnel to insure compliance with the Archaeological Resource 

Protection Act of 1979 (16 USC § 470), as amended, and insure that the remains and associated grave goods 

are treated with respect and are handled according to the provisions. 

3.24 Native American Traditional/Cultural Values, Practices, and 

Resources 

3.24.1 Regulatory Framework 

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. 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

3 Bars Project Final EIS 3-458 October 2016 

The BLM formally 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. 

Laws and Orders that require agency consultation with tribes include the: 

 National Environmental Protection Act 

 National Historic Preservation Act as amended 

 American Indian Religious Freedom Act 

 Native American Graves Protection and Repatriation Act 

 Archaeological Resource Protection Act 

 Executive Order 13007, Indian Sacred Sites 

 Executive Order 13175, Consultation and Coordination with Indian Tribal Governments 

 Secretarial Order 3317, Consultation with Indian Tribes 

The NEPA requires federal agencies to consult with tribes to identify a proposed action’s potential to conflict with a 

tribe’s use of the environment for cultural, religious, and economic purposes, and to work with tribes to seek 

alternatives that would resolve the potential conflicts. 

When the National Historic Preservation Act was amended in 1992, Section 101(d)(6)(a) was added stating that 

“properties of traditional religious and cultural importance to an Indian tribe or Native Hawaiian organization may be 

determined to be eligible for inclusion in the National Register.” 

The American Indian Religious Freedom Act was passed in 1978 to establish a policy of federal protection for 

traditional Native American religious freedoms and required a review of agency programs in consultation with Native 

American religious leaders. Consultation efforts have been directed at identifying the concerns of Native American 

religious practitioners when considering agency actions. This law requires consultation with the practitioner of the 

native religion, not political leaders or academicians. 

The Native American Graves Repatriation Act requires consultation between federal agencies and tribes to determine 

affiliation and disposition of the specific kinds of “cultural items” defined in the Act, which include Native American 

human remains, funerary objects, sacred objects, and objects of cultural patrimony. The Act also provides for 

inadvertent discoveries. The lead agency must also consult with any affected tribe before issuing a permit to excavate 

or remove remains and associated funerary objects from public land. 

The Archaeological Resource Protection Act provides felony-level penalties for the unauthorized excavation, 

removal, damage, alteration, defacement, or the attempted unauthorized removal, damage, alteration, or defacement 

of any archaeological resource, more than 100 years of age, found on public lands or Native American lands. The Act 

also prohibits the sale, purchase, exchange, transportation, receipt, or offering of any archaeological resource obtained 

from public lands or Native American lands in violation of any provision, or local law. 

Executive Order 13007 requires federal agencies to consult with tribes to determine whether proposed land 

management actions would restrict practitioners’ access to and ceremonial use of Native American sacred sites on 

federal lands, or adversely affect the physical integrity of Native American sacred sites on federal lands. If such 

impacts could occur, the agency must then seek alternatives that would resolve potential conflicts. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-459 October 2016 

For the 3 Bars Project the BLM and the Nevada State Historic Preservation Officer have signed a Programmatic 

Agreement that outlines the protocols to be completed as part of Section 106 compliance including Native American 

consultation, and procedures that will be used to assess both unanticipated discoveries and impacts that may occur 

during project implementation (Appendix B). Seven tribes—the Battle Mountain Band Council, Duckwater 

Shoshone Tribe, Elko Band Council, Ely Shoshone Tribe, South Fork Band Council, Te-Moak Tribe of Western 

Shoshone, and the Yomba Shoshone Tribe—are concurring parties to this agreement. 

3.24.2 Affected Environment 

3.24.2.1 Study Methods and Study Area 

Information on Native American traditional values is based on the following ethnographic assessments produced for 

the 3 Bars Project and other projects within and near the project area. 

 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 (Rucks 2000). 

 Background Ethnographic Study for Cortez Joint Venture. Prepared for JBR Environmental, Reno Nevada 

(Rusco 2000). 

 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 (Rucks 2011). 

 Northern Paiute and Western Shoshone Land Use in Northern Nevada: A Class I Ethnographic/ 

Ethnohistoric Overview. Cultural Resource Series No. 12. U.S. Bureau of Land Management, Nevada State 

Office, Reno, Nevada (Bengston 2003). 

 Ethnographic for Pediment Project. Report prepared by Summit Envirosolutions, Carson City, Nevada 

(Rucks 2003). 

 Mount Tenabo Properties of Cultural and Religious Importance Determinations of Eligibility to the National 

Register of Historic Places. BLM Report No. 6-2352-1 (Dixon and McGonagle 2004). 

 An Ethnographic Study Completed for the Cortez Gold Mines Pediment Project. Report prepared by Summit 

Envirosolutions, Inc., Carson City, Nevada (Rucks 2004). 

 Ethnographic Assessment for the Newe (Western Shoshone): Proposed Ruby Pipeline Project in Nevada. 

Report prepared by Bengston Consulting, Inc., Sparks, Nevada (Bengston 2010). 

 3 Bars Ecosystem and Land Restoration Project: Native American Contacts Review. Report prepared by 

Bengston Consulting, Inc., Sparks, Nevada (Bengston Consulting 2012).

Information presented in the following sections is based on the results of the ethnographic assessments and the 

ongoing government-to-government consultation process with interested tribes. BLM consultation to date includes 

ongoing engagement with the seven tribal entities that have expressed interest in the 3 Bars Project. These are the 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

3 Bars Project Final EIS 3-460 October 2016 

Duckwater Shoshone Tribe, the South Fork Band Council, the Elko Band Council, the Te-Moak Tribe of Western 

Shoshone, the Battle Mountain Band Council, the Yomba Shoshone Tribe, and the Ely Shoshone Tribe. In addition, 

the 3 Bars Project is discussed during regularly scheduled meetings designed to inform the tribes of the project status. 

The analysis area for the assessment of direct and indirect effects for Native American Traditional/Cultural Values, 

Practices, and Resources is the 3 Bars Project area. The analysis area for cumulative effects also includes traditional 

tribal rounds on or adjacent to the 3 Bars Project area, as shown on Figure 3-1. 

3.24.2.2 Ethnography 

The 3 Bars Project is situated within the traditional homeland of native peoples referred to as the Western Shoshone 

(Newe), who inhabit a region extending from Death Valley in California through the mountainous terrain of central 

Nevada, and into northwestern Utah and southern Idaho (Thomas et al. 1986:262–264, Sewall 1999). However, the 

limits of Western Shoshone territory, like those of many early Native American groups, tended to be somewhat 

variable over time (Kroeber 1925, Driver 1937, Malouf 1950 [1940], Steward 1970 [1938], and Grosscup 1977 cited 

in Thomas et al. 1986:262). 

3.24.2.2.1 Social and Political Organization 

According to Steward, the Western Shoshone social structure and practices could best be characterized as 

“quantitative simplicity” in that the Western Shoshone lacked many of the cultural institutions often typical of the 

majority of Native American groups. These included an absence of significant and clearly defined linguistic 

differences between them and neighboring groups, a lack of gender- or age-based societies, or political organization 

beyond the local village level. Although inferring a certain degree of environmental determinism, Steward posited that 

the Western Shoshone social system was “...the inevitable response to areas of meager resources, low population 

density, and an annual cycle of nomadism” (Steward 1970 [1938]:115).

Relatively little appears to be known regarding ethnographic-period groups residing specifically within the 3 Bars 

Project area. Rucks (2004:3) suggested that this general paucity of information may have resulted because Julian 

Steward (one of the primary sources of early ethnographic data on the Western Shoshone) avoided some portions of 

the project area and vicinity because of heavy historic-era mining. One exception consists of the Pasiatekkaa. Steward 

stated that their home district—the Diamond, Pine Creek, and Little Smoky Valleys—was not particularly fertile 

except at the base of Roberts Mountains and Sulphur Spring Range where various seeds, root vegetables, and 

especially pinyon nuts were harvested (Steward 1970 [1938]:141–144). Steward documented village sites or groups 

of encampments, including Bauwiyoi, Tupagandϋ, and To:dzanadϋ that were at the base of the mountains, where 

water was more abundant than on the valley floors. Steward (1970 [1938]:142) noted that most of the information 

gathered regarding subsistence activities and the social and political structure was derived from the inhabitants of 

To:dzanadϋ; however, it can be inferred that they were applicable to the other village groups situated at Pine Creek 

north of Roberts Mountains and in the Diamond Valley. 

3.24.2.2.2 Kinship and Marriage 

For the Western Shoshone, kinship terms and status reflect a fundamental division of labor, with men mostly hunting 

and women almost exclusively gathering floral foodstuffs or smaller animals. Consequently, marriage was a critical 

economic institution just as much as it was an emotional or spiritual one. In this system, particularly successful 

hunters could take more than one wife, although the oldest sisters were typically married off first. Bride prices or 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-461 October 2016 

dowries, although common among many Western Shoshone groups, were quite uncommon or unknown altogether 

among those peoples residing east of the Humboldt River and west of the Reese River Valley. Marriages typically 

resulted in strong family bonds; the highest level of Western Shoshone social and political structure was the 

immediate family or small family groups, and armed conflict was a rare occurrence (Steward 1941:311, Cappannari 

1960 cited in Thomas et al. 1986:277). 

Although Western Shoshone marriage practices (an important mechanism for regional and intergroup contact and 

interactions) have been well documented for many regions within their traditional territory, the Kobeh and Diamond 

Valleys within and adjacent to the 3 Bars Project area have not been subjected to the kind of intensive ethnographic 

observations and research characteristic of other regions. Regardless, marriage customs (and other social practices) in 

the project area were likely similar to those in better-studied areas such as the Reese River, Big Smoky, Spring, 

Snake, and Little Smoky Valleys, where most marriages were contracted with a “frequency relative to the distance 

separating groups” (Steward 1970 [1938]). Population density also appears to have played a role in very specific 

marriage and group interaction practices during the ethnographic period. Although marriages between related kin 

were prohibited among the Western Shoshone, marriage between cross cousins and “pseudo cross cousins” (mother’s 

brother’s stepchildren or father’s sister’s stepchildren) was practiced in the nearby Big Smoky and Little Smoky 

Valley regions (Steward 1970 [1938]). Marriage between cross cousins (a closer familiar relationship) was practiced 

in the Steptoe, Ruby Valley, and Elko regions (Delacorte et al. 1992:24). Eggan (1980 cited in Delacorte et al. 

1992:24) noted that cross cousin marriage increased bonds within groups while reducing ties with outside 

populations. Eggan posits this was a consequence of the ecologically rich setting of places like the Ruby Valley, 

where there was little need to go outside the local group for marriage purposes, thereby strengthening local bonds and 

deemphasizing ties with distant groups. 

3.24.2.2.3 Group Social Interaction 

In the most arid regions of Western Shoshone territory with the least prolific and predictable resources, social groups 

were residentially mobile and the kinship system functioned more as a social network and communication system 

than as an economic foundation. However, with subsistence being potentially tenuous in such areas as Death Valley, 

this networking served the critical function of a communication system broadcasting the locations and value of 

resource patches in a marginal environment. Conversely, Eggan (1980:177 cited in Thomas et al. 1986:278) noted 

that the unpredictability of resources, particularly in arid regions, resulted in the development of pronounced 

intergroup sharing restrictions, with women essentially “owning” critical seed harvests. This was especially manifest 

in winter camps, where the women were responsible for the general welfare of the immediate family but there was no 

obligation to share often scarce resources with the larger group. 

In the more ecologically diverse and resource-rich landscapes of the Western Shoshone territory, social practices 

tended to differ from those expressed in areas such as Death Valley, Panamint, or Little Smoky Valley situated just 

southeast of the project area. In the well-watered settings such as those found in the Reese River, Spring, Snake, 

Antelope, and Ruby Valleys, vast stands of pinyon pine, dense patches of seed-bearing grasses and other plants, and 

plentiful large game promoted greater social and residential stability and higher population densities than in the more 

arid regions. In these resource-rich areas, there was less need for the social systems employed in marginal settings to 

provide networks for monitoring ecological conditions and sharing information about the location and quality of 

resources (Thomas et al. 1986:279). Groups inhabiting these areas developed social systems designed to increase 

local group integrity, with a marriage alliance system increasing broader community bonds. In effect, as dense and 

varied resources allowed for more residential stability, the social system correspondingly shifted away from the 
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3 Bars Project Final EIS 3-462 October 2016 

immediate family level and toward structures that encouraged and increased the more generalized and widespread 

group integration. 

3.24.2.2.4 Subsistence and Resource Management 

Research conducted by Steward (1941, 1943, 1970 [1938]), Fowler (1977, 1982 cited in Fowler 1986), and Thomas 

(1981b, 1983a) forms the core of what is presently known regarding the Western Shoshone subsistence economy. A 

great deal of variation in this economic structure existed within the Western Shoshone territory during ethnographic 

times; however, common resources, procurement methods, and preparation techniques link the widespread Western 

Shoshone groups. 

The labor often invested in sustaining specific floral and faunal resources clearly indicates that certain areas were 

subject to repeated visits over long periods of time. Rights to those maintained resources essentially resulted in a 

claim of control, although not necessarily “ownership” in the present-day sense of the word. Rucks’ (2004) 

informants agreed that these rights to particular gathering areas and campsites were recognized by outside groups 

based on evidence of management and consistent use. 

As with their exploitation of many important foodstuffs on their lands, the Western Shoshone attached a certain 

degree of spirituality to their procurement. 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. 

The BLM has met with the Western Shoshone on several occasions during the past 3 years to better understand their 

concerns. The results of these meetings are summarized in the 3 Bars Ecosystem and Land Restoration Project: 

Native American Contacts Review (Bengston Consulting 2012). Based on these discussions, several plant and animal 

species of importance to local tribes were identified. Specific plants and their ethnographic use are: 

 Basin wildrye – food source 

 Bunchgrass (Indian ricegrass) – food source 

 Camas (Yomba) – food source 

 Large sage – purifying, medicinal tea, and the manufacture of wooden implements and textiles 

 Mint – food source 

 Mormon (Indian) tea – medicinal tea 

 Mountain mahogany – medicinal, wooden implements, and fuel 

 Pinyon pine – food source 

 Utah juniper - medicinal 
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3 Bars Project Final EIS 3-463 October 2016 

 Watercress – food source 

 Wild onion – food source 

 Willow – basket weaving 

In addition, the tribes use fish, sage-grouse, jackrabbit, pygmy rabbit, pronghorn antelope, mule deer, and other 

wildlife for food. 

3.24.2.2.5 Ethnobotanical and Ethnoecological Perspective 

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, such as when a tribal member 

enlisted in the U.S. armed forces is going overseas or off to war (George 2000:38). 

George (2000:39) also noted that her Western Shoshone (Duckwater Reservation) consultants universally expressed 

disapproval of commercial pinyon nut pickers. To many Western Shoshone maintaining traditional cultural norms, 

commercial pickers are seen as greedy intruders who strip trees bare of their cones and take an important traditional 

food source away from their people with no consideration of the ecological or cultural implications of their actions. 

Comparable situations have developed in Western Shoshone territory where, for strictly commercial purposes, nonnative harvesting has nearly eliminated bear grass, an important traditional basketry material. 

As part of the Mount Hope ethnographic assessment (Bengston 2007), three culturally significant areas within the 3 

Bars project area were identified. These are Kobeh Valley, Roberts Mountains, and the Sulphur Spring Range. Tribal 

representatives indicated that the northern side of Mount Hope was a favored pine nut gathering area (Bengston 

Consulting 2012:23). During the current study, tribal representatives stated that Roberts Mountains was and still is 

used for hunting and plant gathering, and that there are Newe who went into the mountains to offer prayers. A tribal 

elder from Duck Valley mentioned that two types of minerals, abe (a white chalk used in ceremonies) and a red 

mineral, are still collected in the Roberts Mountains, but did not state the specific location. 

3.24.2.2.6 Hunting 

Important faunal species taken by the Western Shoshone included bighorn sheep and pronghorn antelope. Bighorn 

sheep were hunted during both the winter season and also during the warmer months, when their diurnal movements 

could be easily tracked, and were sometimes procured through the use of permanent hunting blinds or with dogs 

assisting in their pursuit (Muir 1894:322, Lowie 1924:195, Steward 1941:220–221 cited in Thomas et al. 1986:267). 

During the winter months, bighorn sheep hunting shifted to higher elevations, with hunters hiding behind previously 

constructed rock walls, cairns, and blinds. These were particularly common alongside canyons that served to guide 

the sheep into restricted areas where the kill would be easier. Generally, bighorn sheep procurement among the 

Western Shoshone was an individual pursuit, with a single hunter typically taking one sheep at a time. However, 

Steward (1970 [1938]:148) documented communal sheep hunts in the Ruby Valley that were the only ones of their 

kind among the Western Shoshone. 

Pronghorn antelope, although hunted individually as well, were typically procured through the use of large communal 

drives. Steward (1970 [1938]) and Bengston (2003:Figure 2.5) noted that antelope drives occurred in the Diamond 

Valley just north of Eureka and in the general vicinity of two winter villages, one at the eastern edge of the Sulphur 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

3 Bars Project Final EIS 3-464 October 2016 

Spring Range and another just south of present-day Eureka (Egan 1917:240 cited in Thomas et al. 1986:267, Steward 

1970 [1938]:33). 

Rabbits, another important species procured for their meat and skins, were also hunted primarily through the use of 

communal drives. Just like the antelope hunts, fall rabbit hunts, conducted following the pinyon harvest and in 

conjunction with the fall festival (Steward 1970 [1938]:105), were significant social occasions, attracting families 

from a broad geographic area. Rabbit drives certainly occurred with some regularity throughout the project area, 

although Steward (1970 [1938]) and Bengston (2003:Figure 2.3) noted one such site in the southern Diamond Valley 

just north of the town of Eureka. As with the pronghorn antelope hunts, rabbit drives were also accompanied by those 

with recognized shamanistic abilities. In addition to bighorn sheep, pronghorn antelope, and rabbits, a wide variety of 

other animal species were also hunted, trapped, or otherwise captured for food, fur, feathers, or other materials. 

3.24.2.2.7 Spirituality and World View 

According to Miller (1983), three basic principles constitute the foundation of the Western Shoshone world view and 

are largely common to indigenous cultures throughout the world. The first and foremost, referred to by the Western 

Shoshone (and their Northern Paiute neighbors) as the puha, perceives an all-compassing and ever-present life force 

or consciousness that animates virtually everything in the universe—rocks, plants, animals, water, people—and is 

characterized by Miller (1983:73 cited in Rucks 2004:22) as “...life-force energy...not static or concrete, but rather 

kinetic, always moving and flowing through the cosmos, underpinning all facets of the universe...” The second 

principle is that of the intimate relationship between people and land in which they reside. The third, like the second, 

is derived from the puha, and relates to the personalized nature of spiritual experience and its integration into 

everyday life. 

Western Shoshone spiritual tradition holds that puha permeates the world and has been in existence since the “mythage” when animals were people before the Shoshone became human (Deaver 1993 cited in Rucks 2004:24, Rucks 

2004:22). Western Shoshone creation myths state that in the beginning the earth was covered with water, but during 

the “drying time” when the floodwaters receded, the first people moved down-slope from Mount Tenabo to live near 

the numerous springs found at lower elevations. They were told by the Creator “Anything that comes into the world 

after the drying up of the water will be your relative” (Tom Austin as told to Lowie [1924] cited in Rucks 2004:24). 

This particularly illustrates the second foundational principle of the Western Shoshone world view—that of the 

intimate relationship between the Western Shoshone people and their land. 

According to Miller (1983:337 cited in Rucks 2004:22), although puha is universally present, it is concentrated in 

certain landscape features and natural objects, moving in “web-like currents linked to mountain peaks and water 

sources.” Such places are known to and accessed by traditional medical practitioners who engage the power through 

various means for healing and encouraging various natural phenomena. 

3.24.2.3 Documented Ethnographic Sites and Traditional Cultural Properties 

Seven ethnohistoric resources dating to the protohistoric/ethnographic period have been identified thus far within the 

project area. The first ethnohistoric site consists of unevaluated stocked logs that could be the remains of a Shoshone 

structure located in Sheep Corral Canyon, near the western boundary of the project area. The remaining six sites have 

been recommended eligible for inclusion in the NHRP, and consist of another possible structure located slightly north 

of Sheep Corral Canyon, two resources in the vicinity of Indian Ranch that appear to be a temporary Shoshone 
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3 Bars Project Final EIS 3-465 October 2016 

woodcutters’ camps, another camp that may have been associated with ranching, a camp possibly associated with 

charcoal manufacturing, and two camps associated with springs on the north flank of Roberts Mountains. 

Although no Traditional Cultural Properties are situated directly within the project area, the Mount Tenabo 

Traditional Cultural Property is immediately adjacent to the northwestern corner of the project boundary. 

3.24.2.4 Native American Consultation 

The BLM continues to engage the seven tribal entities that have expressed interest in the 3 Bars Project. The 3 Bars 

Project is discussed during regularly scheduled project status meetings with the tribes, and the tribal entities were 

consulting parties during the preparation of 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 3 Bars Ecosystem and Landscape Restoration Project, Eureka County, Nevada

for the 3 Bars Project (Appendix B). 

3.24.3 Environmental Consequences 

3.24.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Key issues of concern pertaining to Native American traditional/cultural values, practices, and resources were 

identified in the AECC and during scoping. These are: 

 Decline in distribution and abundance of traditional, edible, and medicinal plants. 

 Decreased pine nut production and tree vigor. 

 Decline in wild game species. 

3.24.3.2 Significance Criteria 

The American Indian Religious Freedom Act, as amended, and Executive Order 13007 (Sections 3.6.1.1 and 3.6.1.2) 

apply to sites used for religious ceremonies and/or documented sacred sites. These statutes do not specify criteria for 

determining whether a project would affect such places, however for the purposes of analysis in this EIS, sites used 

for religious ceremonies as referred to in the American Indian Religious Freedom Act and sacred sites referred to in 

Executive Order 13007, a project effect is considered significant if it restricts access to such sites, in some way 

impedes the exercise of ceremonies at such sites, or affects the physical integrity of such sites. In addition, effects on 

Traditional Cultural Properties that are eligible for listing in the NRHP because of their traditional religious or cultural 

values would be assessed for impacts under 36 CFR § 800.9 of Section 106 of the National Historic Preservation Act. 

Implementation of vegetation management practices may result in impacts to traditional plant resources or ceremonial 

sites. For example, the treatment could result negative health effects or destruction to traditional edible or ceremonial 

plants and prescribed or wildland fire may destroy traditional edible plants and/or basket weaving materials. A site 

would be considered susceptible to a significant effect under one (or more) of the following project-related situations: 

 Access is reduced or lost (Executive Order 13007). 

 Physical destruction or disturbance (Executive Order 13007 and National Historic Preservation Act). 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

 Alteration of setting (American Indian Religious Freedom Act and National Historic Preservation Act). 

 Introduction of visual, noise, or atmospheric elements that are out of character with the religious ceremonies 

or that compromise the sacred values (American Indian Religious Freedom Act, Executive Order 13007, and 

National Historic Preservation Act). 

3.24.3.3 Direct and Indirect Effects 

3.24.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Historically, there have been direct conflicts between vegetation treatments and resources that are of importance in 

maintaining Native people’s lifeways and/or spiritual values. The following discussion of the various vegetation 

treatment options and effects on resources that may be of importance in maintaining Native people’s lifeways is 

adapted from the 17-States PER (USDOI BLM 2007c). This section also includes effects unique to the 3 Bars project 

that have been identified through scoping, consultation between the BLM and the seven tribes, and ethnographic 

studies conducted by Bengston Consulting for this project and others listed above in Section 3.24.2.1. In addition, the 

reader is encouraged to read the Native and Non-invasive Vegetation Resources (Section 3.12), Fish and other 

Aquatic Resources (Section 3.15), Wildlife Resources (Section 3.16), and Human Health (Section 3.26) sections of 

this EIS for more information on resources and issues of interest to local tribes. 

Adverse Effects 

Treatment activities that remove vegetation or alter the distribution, health, and welfare of plants and animals used by 

Native peoples would have the greatest potential to harm natural resources with associated traditional values. During 

treatments, the BLM would have limited ability to avoid plants identified by Native peoples as being important in 

traditional subsistence, religious, or other cultural practices. 

Beneficial Effects 

Treatments to enhance riparian vegetation and increase the number of miles of BLM-administered streams that are 

classified as “Proper Functioning” would provide good habitat for fish that are harvested by Native peoples. 

Improvements in habitat quality would increase the carrying capacity of the landscape and allow it to support larger 

and healthier wildlife populations. In particular, treatments would benefit mule deer, pronghorn antelope, and Greater 

sage-grouse by removing vegetation (pinyon-juniper) that is degrading habitat or thinning vegetation (pinyon-juniper 

and sagebrush) to allow more desirable vegetation, such as forbs and grasses, to better compete and thrive. Thinning 

and removing vegetation would also benefit local and seasonal movement of wildlife, including mule deer and 

Greater sage-grouse. Because water is scarce on the 3 Bars Project area, the BLM would implement stream and 

riparian restoration projects to improve water availability for fish and wildlife. 

Treatments that remove hazardous fuels from public lands would be expected to benefit the health of plant and animal 

communities in which natural fire cycles have been altered, and to improve accessibility for tribal cultural practices. 

Treatments that control populations of non-native species on public lands would be expected to aid in the 

reestablishment of native plant species. Treatments to control non-native species would benefit game species and 

plants used for traditional/cultural values and practices, including species associated with shrubland habitats (e.g., 

Greater sage-grouse, sharp-tailed grouse, quail), where most treatments would occur (USDOI BLM 2007c:4-109). 

3 Bars Project Final EIS 3-466 October 2016 
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3 Bars Project Final EIS 3-467 October 2016 

3.24.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Adverse Effects 

Mechanical methods consisting of a track-hoe, backhoe, and dump trucks have the potential to affect a broad range of 

plant resources, some of which may be of importance to Native peoples. There could be short-term loss of fish habitat 

and fish resources during stream reconstruction. As opposed to mechanical methods, manual treatment is highly 

selective and would have less of an effect on plants with traditional/cultural practices and values such as willow, basin 

wildrye, mint, watercress, wild onions, and bunchgrass that can be found in riparian zones. 

Riparian treatments are proposed to occur in areas identified as harvest units for Christmas trees, greenwood, and pine 

nuts. Within riparian treatment areas, only pinyon-juniper removal would be expected to affect woodland products. 

Pinyon-juniper removal would occur over a very small portion of designated harvest areas for Christmas trees, pine 

nuts, and greenwood. These treatments would affect a small percentage of the total woodland products harvest 

acreage within the 3 Bars Project area, and would not constitute a measurable reduction in special woodland products 

available for harvest. 

The use of small, temporary exclosure fencing to protect treatment sites could limit Native American access to fish 

and wildlife harvest areas. 

Beneficial Effects 

Treatment activities would include streambank bioengineering, grade stabilization, and vegetation plantings to initiate 

stream restoration on up to 31 miles of stream. The habitat improvements would be beneficial to macroinvertebrates, 

which represent an important food source for fish species, and to Lahontan cutthroat trout (occupied and recovery 

streams) and game fish species used by local tribes. Habitat improvements in the Lahontan cutthroat trout recovery 

streams may assist in the reintroduction of this species into habitats that were used historically. 

Riparian treatments would enhance water quality and quantity for wildlife used by the tribes, while also promoting 

improved habitat conditions that would lead to higher quality forage and cover. Approximately 85 percent of riparian 

treatment acreage is within mule deer summer or winter range habitat, while over 80 percent of the riparian treatment 

acreage is within the summer or winter range for Greater sage-grouse. Proposed treatments would help to restore 

degraded riparian habitat, including about 1,250 acres of mule deer habitat, 177 acres of pronghorn antelope habitat, 

and 1,300 acres of Greater sage-grouse habitat that are degraded due to pinyon-juniper encroachment. 

Encroachment of non-native plant species, and displacement of native plant species that serve as important sources of 

food, reduces the suitability of the habitat for these wildlife species (USDOI BLM 2007b:4-119). Removal of noxious 

weeds and other invasive non-native vegetation would also promote streambank stability and allow native species to 

recolonize degraded areas and provide fish and wildlife habitat. 

Vegetation treatments that reduce hazardous fuels and create fire breaks would benefit Native American resources by 

reducing the chances that a large, uncontrolled wildfire would destroy a large amount of high quality vegetation and 

fish and wildlife and their habitats. The restoration of natural fire regimes and native ecosystems would have longterm benefits associated with increasing the presence and abundance of native plant, fish and wildlife resources 

important to maintaining Native American traditional lifeways. 
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3 Bars Project Final EIS 3-468 October 2016 

Aspen Treatments 

Plant species of interest to Native Americans within aspen management units would be similar to those found within 

riparian treatment zones. Adverse and beneficial effects would be the same as Effects Common to All Alternatives 

and for Riparian Treatments. The initial acreage of aspen identified for treatment is low (151 acres over 10 years). 

Therefore, potential loss of Native American traditional resources initially would be localized to very small areas in 

the Roberts Mountain, JD, 3 Bars, and Santa Fe allotments. In later years, a similar acreage could be treated in the 

Simpson Park East and Northeast areas. 

Pinyon-juniper Treatments 

With the exception of Sulphur Spring Wildfire Management Unit, Whistler, Lone Mountain, and Tonkin North and 

South units, all of the proposed treatment units are within the Roberts Mountains. As stated in the Riparian 

Treatments section, ethnographic documentation indicates that the Roberts Mountains have been identified by Native 

American consultants as an important hunting and plant gathering area, particularly for pinyon pine nuts. Pinyon nuts 

played a significant role in the subsistence, resource management, seasonal migration patterns, spiritual practices, and 

world view of the Western Shoshone. Other ethnographic plant species identified by Bengston Consulting (2012) that 

may be found within pinyon-juniper woodlands consist of large sagebrush, basin wild rye, Indian ricegrass, and 

possibly Mormon tea and wild onions. Historically, the base of the Roberts Mountains was important for the Western 

Shoshone because of the abundance of root vegetables and seeds, especially pinyon pine, that were harvested there. 

These resources were also abundant at the base of the Sulphur Spring Range, where the BLM proposes to use 

wildland fire for resource benefit to manage pinyon-juniper. These environments also provide habitat for various 

species of wildlife that are important to Native Americans, including pygmy rabbit and Greater sage-grouse. 

Adverse Effects 

Because of ground disturbance associated with the use of mechanical treatments and the effects associated with 

prescribed and wildland fire for resource benefit, the potential inadvertent and short-term adverse effects to traditional 

plant and fish and wildlife resources would be similar to the Effects Common to All Alternatives and Riparian 

Treatments. 

Dense stands of pinyon-juniper provide habitat for mule deer during severe winter weather because of the reduced 

snow cover and increased thermal cover in these areas. Removal of pinyon-juniper in Phase II and III stands could 

mean a loss of this wildlife benefit. Pinyon-juniper woodlands also provide habitat structure that would be lost if 

woodlands were converted to grasslands (Maser and Gashwiler 1978). 

Treatments would reduce fuel loads, and fuel breaks to be constructed around old-growth pinyon-juniper woodlands 

would reduce the risk from catastrophic wildfire. For example, treatment areas on the west slope of the Roberts 

Mountains have not experienced a large-scale wildfire in over 100 years. As a result, these units have a high to very 

high or very high to extreme risk for a catastrophic wildfire. 

The BLM does not plan to conduct burns in Phase I stands, but would conduct stand-replacement burns that could 

cover several thousand acres annually in Phase II and III pinyon-juniper stands. About 60 percent of treatments would 

occur in Phase II and III stands. Prescribed fires would open up pinyon-juniper stands and stimulate the growth of 

native forbs and grasses to benefit wildlife, but there could also be a minor loss of Wyoming big sagebrush and of 

other shrubs desirable for Greater sage-grouse, pronghorn antelope, and mule deer hunted by Native Americans. It is 

likely that large, older pinyon-juniper trees that provide juniper berries and pinyon nuts for mule deer and other 
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3 Bars Project Final EIS 3-469 October 2016 

wildlife would also be lost. Fire may top-kill some plants used by Native Americans, including Basin wild rye, camas, 

Indian ricegrass, and Mormon tea, but fire has been shown to enhance their long-term health and development 

(Howard 1993, Tirmenstein 1999, Anderson 2002, 2004). 

Concerns have been expressed by local tribes regarding traditional pine nut harvesting in general and the removal 

of pinyon pine. Some seed bearing trees would be destroyed or removed by mechanical or hand treatments and fire, 

and prescribed and wildland fires would require the construction of fuel breaks, which could also compromise plant 

species of importance to Native American lifeways. Treatments would affect approximately 26 percent of the total 

designated woodland products harvest area, including 28 percent of the pine nut harvest area. Removal of pinyon 

pines and juniper from these areas would eliminate or limit the ability to harvest woodland products there, although a 

large portion of the project area would not be affected. Additionally, other nearby areas in the Battle Mountain 

District, which make up a substantial portion of the annual harvest area, would not be affected by treatments under the 

3 Bars Project. 

Beneficial Effects 

A key project goal is to increase the distribution and abundance of traditional, edible, and medicinal plants by 

improving the relative abundance of desirable plant species in previously identified locations (obtained through 

Native American consultation). This would include sustaining the regeneration and recruitment of desirable species 

such as aspen, bitterbrush, and curl-leaf mountain mahogany. Although the majority of pinyon-juniper management is 

focused on hazardous fuels reduction, treatments associated with the Atlas Unit group would involve removal of 

pinyon-juniper to encourage shrub and riparian species growth. Plants used by local tribes that could benefit from 

these treatments include basin wildrye, Indian ricegrass, Mormon tea, and sagebrush. 

Manual, mechanical, and fire treatments in pinyon-juniper management areas would improve aquatic habitat by 

increasing stream flows and using downed logs and other wood in streams to create pools and other fish habitat. 

These treatments would benefit Lahontan cutthroat trout and game fish habitat in Birch, Pete Hanson, and Willow 

Creeks. 

Treatments would help to improve big game habitat, especially in areas with degraded habitat. All of the pinyonjuniper treatment sites are within mule deer summer or winter range, 60 percent of sites are within pronghorn summer 

or winter range, while nearly 95 percent of the treatment area is within the summer or winter range for Greater sagegrouse. Over 70 percent of acres targeted for treatment occur where the BLM has determined that mule deer or 

Greater sage-grouse habitat is declining, and nearly 60 percent of the treated acreage would be in areas where 

pronghorn antelope habitat is declining. 

Treatments in the Atlas, Frazier, Gable, Henderson, Upper Roberts, and Vinini units would primarily benefit Greater 

sage-grouse, but would also open up pathways in drainages, and provide forage for other wildlife by promoting 

development of native grasses, forbs, and shrubs through removal of pinyon-juniper. These areas also provide 

important year-round habitat for pronghorn antelope and crucial summer range for mule deer. 

Pinyon-juniper encroachment has adversely impacted pygmy rabbit populations (Grayson 2006). Although pygmy 

rabbits will use areas with limited pinyon-juniper cover, stands with 40 percent or greater cover provide only marginal 

habitat for pygmy rabbits (USDOI BLM 2003c). The Atlas and Henderson units provide habitat for pygmy rabbits. 

Pygmy rabbits forage primarily on sagebrush, so treatments that remove pinyon-juniper and stimulate the growth of 

shrubs and herbaceous vegetation would benefit pygmy rabbits in the long-term. 
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3 Bars Project Final EIS 3-470 October 2016 

A large amount of downed logs and woody debris would result from pinyon-juniper management and could be used 

for firewood. By thinning and removing pinyon-juniper, competition among remaining trees for water and other 

resources would decline, and the remaining pinyon pines should be able to produce more nuts. 

Although there is the low potential for short-term adverse effects to traditional use resources and Native American 

health, the restoration of natural fire regimes and native ecosystems would have long-term benefits to the presence 

and abundance of native plant, fish, and wildlife resources important to maintaining traditional lifeways. 

Sagebrush Treatments 

Adverse Effects 

Because of ground disturbance associated with the use of manual and mechanical treatments, the potential inadvertent 

and short-term adverse effects to traditional plant and terrestrial resources would be similar to the Effects Common to 

All Alternatives and Pinyon-juniper Treatments. The BLM would use manual and mechanical treatments to seed and 

plant sagebrush and perennial grasses within sagebrush communities, and control noxious weeds and other invasive 

non-native vegetation. Kobeh Valley was identified by Bengston (2007) as a culturally significant area within the 3 

Bars Project area. 

Prescribed fire could be used to remove cheatgrass and other non-native vegetation on the West Simpson Park Unit. 

As it is unlikely that plants favored by local tribes would be found in areas dominated by non-native vegetation, the 

effects of prescribed fire on traditional plant and terrestrial resources should be negligible. 

Only 1.3 miles of perennial stream habitat are associated exclusively with sagebrush management projects—Rocky 

Hills (Coils Creek), Table Mountain (Henderson and Vinini Creeks), and West Simpson Park (unnamed streams) 

units. Lahontan cutthroat trout occurs in Henderson and Vinini Creeks, while native fish (speckled dace) have been 

reported in Coils Creek. Manual and mechanical treatments could result in increased water runoff and erosion, and 

spills of fuels and lubricants, to the possible detriment of water quality and aquatic habitat. 

Beneficial Effects 

Treatments should lead to improved and increased sagebrush habitat and sagebrush resiliency to fire, and open up the 

sagebrush canopy to slow wildfire spread and promote the development of an herbaceous understory including those 

plant species mentioned above and of importance to Native American traditional lifeways. In intact sagebrush 

communities, only 20 percent of the area would be treated and the BLM would create a mosaic of sagebrush and 

herbaceous vegetation that would retard the spread of wildfire and provide habitat for Greater sage-grouse, another 

traditionally important species identified in consultation with the Native American community (Bengston Consulting 

2012). While there is the potential for short-term adverse effects, the long-term benefits associated with the planting 

of native perennial vegetation and improved Greater sage-grouse habitat would result in substantial long-term benefits 

by restoring native sagebrush habitat. 

The beneficial effects of sagebrush treatments would include improvements in aquatic and riparian habitats and a 

reduction in wildfire risk. Trees that are removed as part of this treatment could be placed in streams to expand the 

stream width and help create or expand pool habitats. The woody structures also would provide additional instream 

cover for game fish and organic material to the stream environment. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-471 October 2016 

The primary focus of 3 Bars Project sagebrush treatments is to improve habitat for nesting Greater sage-grouse. 

Approximately 98 percent of proposed treatment acres are within pronghorn antelope summer or winter range, 65 

percent are within summer or winter range for Greater sage-grouse, and 55 percent are within mule deer summer or 

winter range. Loss and degradation of sagebrush habitat has occurred on the 3 Bars Project area, and proposed 

treatments would focus on restoring sagebrush habitat. Over 85 percent of the acres treated would occur where the 

BLM has determined that pronghorn antelope habitat is declining, nearly 65 percent of acres treated would occur 

where Greater sage-grouse habitat is declining, and 45 percent of the acres treated would occur where mule deer 

habitat is declining. These include treatments on the Rocky Hills and West Simpson Park units, where the BLM 

would control non-native vegetation to encourage sagebrush development in areas with active or historic Greater 

sage-grouse leks. 

Pinyon-juniper encroachment has impacted pygmy rabbit populations (Grayson 2006), especially where pinyonjuniper cover exceeds 40 percent. Pinyon-juniper removal projects at the Three Corners and Whistler Sage units could 

benefit pygmy rabbits, although treatments would occur in Phase I stands, where pinyon-juniper cover is less than 40 

percent. 

3.24.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The types and magnitude of effects for manual, mechanical, and biological control treatments would be similar 

between Alternatives A and B. Because the BLM would not be able to use fire, however, there would be none of the 

adverse or beneficial impacts associated with this treatment method. In particular, there would be no harm to or loss 

of native vegetation or fish and wildlife habitat from prescribed fire and wildland fire for resource benefit. There 

would also be no risk of a prescribed fire spreading beyond treatment boundaries and impacting native plants and 

fauna of interest to the Native American community, which could be the case under Alternative A. The few native 

plants and wildlife that are found in dense stands of pinyon-juniper may not experience habitat loss under this 

alternative. 

Acres and types of wetland and riparian habitat and miles of stream restored would be similar to Alternative A. 

However, less effort would be spent by the BLM on slowing pinyon-juniper encroachment into sagebrush and 

riparian communities, removing Phase II and III pinyon-juniper, restoring historic sagebrush habitat, and controlling 

noxious weeds and other invasive non-native vegetation that is adversely impacting native vegetation and fish and 

wildlife habitat. 

Under Alternative B, the BLM would be limited to manual and mechanical methods for removing noxious weeds and 

other invasive non-native vegetation and replanting and reseeding to promote the growth of native forbs and grasses. 

However, the West Simpson Park Unit is on rugged terrain, and use of mechanical equipment to control cheatgrass 

would be difficult on this unit. 

The inability to use prescribed fire and wildland fire for resource benefit would probably have few short-term effects. 

By not using fire, risks to non-target vegetation, including plants used by local tribes, from treatments would be 

negligible. Long-term, however, native vegetation and fish and game species would experience fewer of the benefits 

associated both with creating openings in dense pinyon-juniper habitat and creating a mosaic of pinyon-juniper and 

sagebrush habitat. 

Under Alternative B, riparian restoration treatments would primarily be limited to manual treatments (placing logs 

and rocks in streams to slow water flows, using small, temporary exclosure fencing to exclude livestock, wild horses, 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

and other wild ungulates, and stimulating aspen regeneration) that would help to create wet meadows and enhance 

riparian vegetation and fish and wildlife habitat. Because fire would not be available to reduce hazardous fuel loads, 

Alternative B may pose a greater long-term risk for wildfire due to the accumulation of fuels. Without the use of 

prescribed fire and wildland fire for resource benefit, the BLM would be unable to restore fire as an integral part of 

the ecosystem. It is unlikely that the trend toward large-sized fires of moderate to high severity in sagebrush and large 

stand-replacing fires in pinyon-juniper would slow or reverse in the long-term, and catastrophic wildfire would 

continue to be a threat to traditional pine nut gathering locations, and plants such as basin wild rye and Indian 

ricegrass that are found in sagebrush and pinyon-juniper habitats. 

Under Alternative B, Native American traditional/cultural values, practices, and resources would benefit from 

treatments, but not to the extent that would occur under Alternative A. 

3.24.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

The types and magnitude of effects for manual treatments on Native American resources would be similar to those for 

the other alternatives. The BLM has not identified areas where it would use classical biological control, but if 

nematodes, insects, or fungi are used on the 3 Bars Project area, treatments would generally be small in size and 

effects would be localized, or if used on cheatgrass, could cover large areas of habitat that support little native 

vegetation or wildlife. Thus, the effects on Native American resources from classical biological control would be 

minor and primarily restricted to those species using vegetation treated by these methods. 

Most of the treatments under this alternative would be to thin and remove pinyon-juniper using chainsaws where it is 

encroaching into riparian, aspen, and sagebrush habitats. There would be fewer direct impacts to plants and animals 

used by Native Americans from treatments under this alternative than the other alternatives, because adverse impacts, 

such as harm to or death of plants and wildlife, and noise and other disturbance, would be much less with manual 

methods than with the other methods. Since fewer acres would be treated, however, there would be fewer benefits to 

Native American resources under this alternative than under Alternatives A and B. Manual treatments would be small 

in scale and mostly targeted to pinyon-juniper stands. By not being able to use mechanical equipment, the BLM 

would have limited capabilities to benefit Native American resources by: 

 Conducting stream bioengineering and restoration, except on a limited basis on only a few stream miles, to 

benefit Lahontan cutthroat trout, other game fish, Greater sage-grouse, and native riparian vegetation. 

 Controlling noxious weeds and other invasive non-native vegetation, except on very small areas where this 

vegetation can be hand pulled or controlled using hand tools, to benefit native vegetation and wildlife, 

including Greater sage-grouse, pygmy rabbit, pronghorn antelope, and mule deer. 

 Reseeding and replanting restoration sites, except for small areas where shrubs and other vegetation would be 

planted by hand, to the benefit of a variety of Native American resources. 

 Creating fire and fuel breaks to reduce the risk of fire spread, except near existing roads or aspen stands, or 

along a few miles of stream, and using manual methods to reduce hazardous fuels and wildfire risk. 

Under Alternative C, the BLM would not substantially improve the native vegetation community nor stop the loss of 

important ecosystem components, including native vegetation and fish and wildlife habitat. As a result, the health and 

abundance of Native American traditional/cultural resources would be expected to decline from current levels. 

3 Bars Project Final EIS 3-472 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3.24.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct or indirect effects on Native American traditional/cultural values, practices, and resources 

from 3 Bars Project treatments as no treatments would be authorized under this alternative. The BLM would not 

create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of 

noxious weeds and other invasive non-native vegetation, especially cheatgrass; restore fire as an integral part of the 

ecosystem; or reduce the risk of a large-scale wildfire that could be detrimental to Native American resources. Under 

Alternative D, the BLM would not improve the native vegetation community nor stop the loss of important ecosystem 

components, including native vegetation and fish and wildlife habitat. As a result, Native American 

traditional/cultural values, practices, and resources would not see benefits under this alternative. 

3.24.3.4 Cumulative Effects 

The CESA for Native American traditional/cultural values, practices, and resources is approximately 3,202,529 acres 

and includes the 3 Bars Project area and an area of north-central Nevada that encompasses the Kobeh Valley on the 

south, the Tuscarora Mountains on the north, the Shoshone Range on the west, and the Pinon Range on the east, based 

on consultation with local tribes for the Mount Hope Project and other projects in the region (USDOI BLM 2012b:4-

9; Figure 3-1). Approximately 72 percent of the area is administered by the BLM, 27 percent is privately owned, and 

less than 1 percent is administered by the USDOI Bureau of Reclamation. Past and present actions that have 

influenced land use and access in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3. 

3.24.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Historic livestock grazing practices and wild horse overpopulation have contributed to the degradation of riparian and 

aspen habitat, establishment and spread of noxious weeds and other invasive non-native vegetation, and the expansion 

of pinyon-juniper beyond its historical ranges, to the detriment of fish and wildlife used by Native Americans on 

Roberts Mountains and elsewhere in the CESA. To improve forage and water resources, the BLM would continue 

ongoing management reviews to ensure proper livestock management and long-term treatment success. 

The BLM would also continue to conduct wild horse gathers, AML reviews and adjustments, remove excess animals 

and use fertility control, improve water developments, and implement habitat projects. A small portion of the Roberts 

Mountain HMA is on Roberts Mountains, and wild horses use portions of Roberts Mountains that are outside of the 

HMA, especially when the wild horse population exceeds the AML. Efforts to distribute wild horses more evenly 

across the rangeland should help to reduce grazing pressure on Roberts Mountains. However, the Mount Hope Project 

would exclude wild horses from about 14,000 acres for up to 70 years, and as a result wild horses may spend more 

time in the Roberts Mountains in search of food and water, potentially to the detriment of vegetation used by Native 

Americans. 

The BLM would treat noxious weeds and other invasive non-native vegetation on about 1,000 acres annually within 

the CESA. New infestations would typically be found in newly burned or disturbed areas, and in areas where 

livestock and wild horses congregate. These areas provide poor habitat for plants and animals used by local tribes. 

Tribal members could be impacted by herbicides, through indirect contact or consumption of treated foliage, but the 

BLM would post treatment areas and notify the tribes and public of proposed herbicide treatments to avoid or 

minimize impacts to human health. The risks to Native Americans are discussed in more detail in the 17-States PEIS 

(USDOI BLM 2007c: 4-149). Restoration of these areas using a combination of methods should help to restore these 

3 Bars Project Final EIS 3-473 October 2016 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

lands back toward their Potential Natural Community (primarily sagebrush). As treatment areas recover, native game, 

including Greater sage-grouse, mule deer, pronghorn antelope, and pygmy rabbit, should return to these areas. 

Public and private lands are used for a variety of recreation uses. Of most interest to local tribes would be the removal 

of vegetation that is used by tribes for traditional purposes, and the harvest of fish and game on public lands within the 

CESA. Recreational activities such as off-road travel could disturb native game and adversely affect Native American 

traditional practices. Use of public lands within the CESA is expected to increase due to normal population growth 

and from an influx of workers needed to support the Mount Hope Project and other reasonably foreseeable future 

projects. 

Agriculture, land development, and mineral, oil, gas, and hydrothermal exploration and development could affect 

about 15,000 acres in the reasonably foreseeable future, including acreage associated with potential land sales 

(although it is unlikely that all of this land would be developed), new croplands, roads, and rights-of-way for power 

and telephone lines. These actions would affect traditional/cultural resources and values and would be of concern if 

they occurred on Roberts Mountains or on the Sulphur Spring Range, or in Kobeh Valley, three culturally significant 

areas within the 3 Bars Project area (Bengston 2007). In particular, there could be loss of vegetation used by local 

tribes, and of fish and wildlife and their habitats that are important to local tribes. 

Approximately 8,300 acres would be disturbed by the Mount Hope Project, and another 6,000 acres fenced to exclude 

the public. Thus, about 14,000 acres used by large and small game would be made unavailable for use by local tribes 

for hunting. In addition, the mine could affect groundwater levels in the vicinity of the mine, potentially impacting 

vegetation on the Kobeh and Diamond Valleys, and affecting surface water flows on Roberts Mountains; these are 

culturally important areas to the Western Shoshone (Bengston 2007). These effects could last 70 years or more, and 

could impact plant, fish, and wildlife resources of importance to local tribes (USDOI BLM 2012b:4-69). The mine 

project would impact less than 1 percent of pinyon pines in the CESA. The mine site would be reclaimed, but habitat 

for big game and pygmy rabbit may be inaccessible or unavailable for 40 years or more. The mine proponent, BLM, 

and State Historic Preservation Office have developed a Programmatic Agreement to address many of these 

concerns. 

The buildup of hazardous fuels and the spread of noxious weeds and other invasive non-native vegetation have 

increased both the risk of wildfire and the displacement of plants and animals that are important to Native peoples for 

maintaining their traditional/cultural practices and values. Although fire is being reintroduced to undeveloped areas in 

the West that were historically burned by Native peoples to maintain early successional plant species and improve 

habitat for game species, natural disturbance regimes have not been restored over much of the West. Encroachment 

by non-native species into natural ecosystems continues, to the detriment of many native species of importance to 

Native peoples. 

Since 1985, wildfires have burned about 15,000 acres annually in the CESA, although the acreage burned annually 

can be quite variable. The risks to Native American traditional/cultural values from wildfire are much greater than for 

prescribed fires, as wildfires tend to be hotter and burn larger areas. Wildfires kill vegetation, and harm or displace the 

native fish and wildlife used by local tribes. In addition, it is often difficult to restore burned lands, due to their remote 

location and uneven terrain, and noxious weeds and other invasive non-native vegetation often out-compete and 

displace native vegetation, to the long-term detriment of resources used by Native Americans. Treatments that remove 

hazardous fuels, including decadent and diseased pinyon-juniper and cheatgrass and other non-native vegetation, and 

construction of fire and fuel breaks, would be expected to reduce the risk of catastrophic wildfire, to the benefit of 

Native American resources. 

3 Bars Project Final EIS 3-474 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

In addition to the approximately 127,000 acres that could be treated on the 3 Bars Project area to reduce hazardous 

fuels and restore ecosystem health, the BLM also proposes to treat hazardous fuels and improve habitat on an 

additional 15,000 acres under current or reasonably foreseeable future authorizations in high to very high fire risk 

areas, or collectively on about 4 percent of lands within the CESA. Most of these treatments would occur within 

pinyon-juniper and sagebrush management areas, including on Roberts Mountains and Sulphur Spring Range, areas 

with ethnographic significance to the Western Shoshone. As discussed under direct and indirect effects, hazardous 

fuel treatments could adversely impact traditional/cultural resources and values within the CESA, including singleleaf 

pinyon pines and Utah juniper that are used for their seeds and berries. Treatments could also impact fish and game 

resources, including mule deer, pronghorn antelope, and pygmy rabbit, which are used for food by local tribes. As 

discussed under Native and Non-invasive Vegetation Resources (Section 3.12) and Wildlife Resources (Section 3.16), 

treatments would have short-term effects on vegetation and wildlife habitat and displace game species, but within a 

few years conditions within treatment areas should improve and provide improved vegetation and fish and wildlife 

habitat. The beneficial effects of treatments would be greatest under Alternative A. 

3.24.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

Under Alternative B, effects from non-3 Bars Project reasonably foreseeable future actions on Native American 

traditional/cultural values, practices, or resources would be similar to those described under Alternative A. Under 

Alternative B, less effort would be spent by the BLM on treatments to reduce wildfire risk and its impacts on 

vegetation and fish and game habitat, including use of fire to restore natural fire regimes. 

Adverse effects to Native American traditional/cultural values, practices, and resources within the CESA would 

generally be the same as described for Alternative A. By not using fire on the 3 Bars Project area, however there 

would be no risks to vegetation from fire on up to several thousand acres annually within the project area. Fire could 

be used on a few hundred acres annually outside the 3 Bars Project area. 

By not using fire to reduce hazardous fuels and improve vegetation resiliency to fire, there would be greater potential 

for more extensive and intense wildfires to occur in place of controlled burns on the 3 Bars Project area under this 

alternative compared to Alternative A. This could lead to loss of vegetation and fish and wildlife habitat of 

importance to local tribes. 3 Bars Project actions would only affect about 63,500 acres, or 2 percent of the CESA. The 

BLM would consult with local tribes, and treatment areas would be surveyed, prior to treatment to avoid or reduce 

impacts to Native American traditional/cultural values, practices, and resources. Thus, there should be negligible 

cumulative effects to these resources from 3 Bars Project actions. These effects would be less than under Alternative 

A, but greater than under Alternative C. 

3.24.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under Alternative C, effects from non-3 Bars Project reasonably foreseeable future actions on Native American 

traditional/cultural values, practices, or resources would be similar to those described under Alternative A. Adverse, 

short-term effects to vegetation associated with the use of fire and mechanized equipment would not occur under 

Alternative C. However, fire and mechanized equipment would be used in other portions of the CESA to improve 

habitat, remove hazardous fuels, and reduce the risk of wildfire. 

By not being able to use mechanical methods and fire to reduce hazardous fuels, improve vegetation resiliency to fire, 

create fire and fuel breaks, and remove downed wood and slash, however, the risk of wildfire and its impacts on 

3 Bars Project Final EIS 3-475 October 2016 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

Native American traditional/cultural values, practices, or resources would likely increase on the 3 Bars Project area, to 

the potential detriment of vegetation and fish and wildlife and their habitats within the CESA. 

About 32,000 acres would be treated on the 3 Bars Project area, and another 15,000 acres in other portions of the 

CESA, to reduce hazardous fuels and to improve ecosystem health, or only about 1 percent of the CESA. The BLM 

would consult with local tribes, and treatment areas would be surveyed, prior to treatment to avoid or reduce impacts 

to Native American traditional/cultural values, practices, and resources. Thus, there should be negligible cumulative 

effects to these resources from 3 Bars Project actions and effects would be less than under Alternatives A and B. 

3.24.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on Native American 

traditional/cultural values, practices, or resources would be similar to those described under Alternative A. There 

would be no cumulative effects on Native American traditional/cultural values, practices, and resources from 3 Bars 

Project treatments as no treatments would be authorized under this alternative. The BLM could create fire and fuel 

breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the spread of noxious weeds and 

other invasive non-native vegetation using ground-based and aerial application methods of herbicides, especially 

cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a large-scale wildfire under current 

and reasonably foreseeable future authorized actions, but on a very limited acreage (about 1,500 acres annually; or 

about 0.03 percent of the CESA annually). Thus, benefits to Native American traditional/cultural values, practices, 

and resources would be negligible and least among the alternatives. 

3.24.3.5 Unavoidable Adverse Effects 

Unavoidable adverse effects could occur through inadvertent actions such as accidental removal of culturally 

significant plant species during mechanical methods or loss of important game habitat from burning. Treatments 

could also discourage or prohibit Native peoples from using these areas. However, all of these impacts would be 

short-term and would be far outweighed by the beneficial effects associated with long-term effects resulting from 

treatments that result in an increase in the abundance and diversity of native plant, wildlife, and aquatic resources. 

3.24.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

Vegetation treatments under all alternatives could have short-term impacts on vegetation used for traditional lifeways. 

Manual treatment methods have the least potential to impact plant species of importance to Native American 

traditional/cultural values, practices, or resources. These methods would be used to thin pinyon groves and, while 

there could be a short-term adverse effect from treatments, there would be a long-term benefit in pine nut harvesting 

associated with increased production; this would far outweigh the short-term effects. Biological treatments would 

have the least impact on short-term use, while prescribed and wildland fire and mechanical treatments have the 

potential to have the greatest effect on short-term use. Fire treatments could displace Native peoples from traditional 

use areas until the area is safe to reenter, or desirable vegetation was reestablished. However, the long-term restoration 

of native plant communities and natural ecosystem processes that benefit traditional plant and animal resources should 

compensate for the short-term losses in use and access. 

3 Bars Project Final EIS 3-476 October 2016 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-477 October 2016 

3.24.3.7 Irreversible and Irretrievable Commitment of Resources 

The use of treatments could inadvertently harm desirable edible plants, fish, and other fauna used for traditional 

lifeways or basketweaving. Prescribed burning and use of wildland fire for resource benefit would result in short-term 

habitat degradation and loss of plants and animals. However, these losses would be reversible as habitats would 

improve (USDOI BLM 2007c:251-252). Inadvertent impacts would only affect a small percentage of the treated 

acreage, and these impacts would be reversible. Further, the long-term benefits associated with all treatments that 

reduce the cover of noxious weeds and other invasive non-native vegetation, restore native vegetation, restore natural 

fire regimes, and restore long-term ecosystem health would substantially improve the diversity and quantity of 

traditional flora and fauna of importance to maintaining Native American traditional/cultural values, practices, or 

resources. 

3.24.3.8 Significance of the Effects under the Alternatives 

3 Bars Project and other actions in the CESA could have a significant impact on Native American traditional/cultural 

values, practices, or resources if the actions restrict access to sites used for religious ceremonies and/or documented 

sacred sites, in some way impede the exercise of ceremonies at such sites, or affect the physical integrity of such sites; 

impacts traditional plant resources or ceremonial sites; alter the setting of sites; or introduce visual, noise, or 

atmospheric elements that are out of character with the religious ceremonies or that compromise the sacred values. 

The only Traditional Cultural Property within the CESA is the Mount Tenabo Traditional Cultural Property, which is 

immediately northwest of the 3 Bars Project area. It is probably the single most culturally important landscape feature 

on the homeland of the Western Shoshone (Fowler 1986). No reasonably foreseeable actions are proposed for this 

area, thus, effects from reasonably foreseeable future actions within the CESA would not be significant under all 

alternatives. 

Based on the number of acres treated, short-term impacts to plants, as well as habitats used by fish and wildlife, that 

are important to Native peoples would be greatest under Alternative A and least under Alternative D. However, as the 

long-term objective of treatments is to restore native plant communities and habitats, including those of traditional 

importance to Native peoples, these effects to traditional plant resources would not be significant under the 

alternatives, especially given the likelihood of greater risk of catastrophic wildfire, and loss of plant and animal 

resources used by local tribes, that would occur without the treatments. 

The BLM and State Historic Preservation Office have entered into a Programmatic Agreement that outlines the 

stipulations that will be followed to ensure compliance with Section 106 of the National Historic Preservation Act for 

each phase of the 3 Bars Project (see Appendix B). According to the Programmatic Agreement, all treatments shall 

be conducted in a manner consistent with the BLM and State Historic Preservation Office Protocol. The BLM, in 

consultation with the State Historic Preservation Office, shall ensure that effects to cultural resources and properties of 

traditional religious and cultural importance are avoided through design, or redesign, or by other means in a manner 

consistent with the BLM and State Historic Preservation Office protocol. When avoidance is not feasible, the BLM, in 

consultation with State Historic Preservation Office, Native American Tribes, and interested persons, shall develop, or 

ensure that, an appropriate treatment plan is designed to lessen or mitigate project-related effects to these resources 

and properties. By following the Programmatic Agreement, the BLM would ensure that there are no significant direct, 

indirect, or cumulative effects to cultural resources and properties of traditional religious and cultural importance 

under all alternatives from 3 Bars Project actions. A similar Programmatic Agreement was prepared for the Mount 

Hope Project, and the BLM and other federal agencies with land interests within the CESA would develop similar 
NATIVE AMERICAN TRADITIONAL/CULTURAL VALUES, PRACTICES, AND RESOURCES 

3 Bars Project Final EIS 3-478 October 2016 

agreements, if needed, before conducting actions within the CESA that could impact cultural resources and properties 

of traditional religious and cultural importance. 

3.24.4 Mitigation 

Under all alternatives, the BLM shall implement the following measures in accordance with the Programmatic 

Agreement prepared for the 3 Bars Project and as discussed in Section 3.23.4, Cultural Resources, Mitigation. 

3.25 Social and Economic Values and Environmental Justice 

3.25.1 Regulatory Framework 

The NEPA requires consideration of local plans and policies in the assessment of the social and economic effects of 

proposed activities involving federal lands (43 CFR § 1506.2). Federal, state, and local plans and guidelines that apply 

to social and economic values within the analysis area include the Eureka County 2010 Master Plan, including the 

updated Natural Resources, Federal or State Land Use, and Economic Development Elements; the Shoshone-Eureka 

RMP; and the Land and Resource Management Plan for the Toiyabe National Forest. 

Chapter 6 of the Eureka County Master Plan, Natural Resource and Land Use Element, is designed to: 1) protect the 

human and natural environment of Eureka County, 2) facilitate federal agency efforts to resolve inconsistencies 

between federal land use decisions and County policy, and 3) provide strategies and policies for progressive land and 

resource management. The updated Growth Management, Public Facilities and Services, Economic Development, 

Land Use, and Housing Elements of the Eureka County Master Plan outline specific goals that pertain to the project. 

Guidance and input for this assessment have also been provided by Eureka County staff, the Board of Eureka County 

Commissioners, and the Eureka County NEPA Committee (Eureka County 2010). 

On February 11, 1994, President Clinton issued Executive Order12898, Federal Actions to Address Environmental 

Justice in Minority Populations and Low-Income Populations. Executive Order 12898 tasks “each Federal agency [to] 

make achieving environmental justice part of its mission by identifying and addressing, as appropriate, 

disproportionately high adverse human health and environmental effects of its programs, policies, and activities on 

minority populations and low-income populations.” 

Executive Order 13045, Protection of Children from Environmental Health Risks and Safety Risks, instructs federal 

agencies to identify and assess environmental health risks and safety risks that may disproportionately affect children, 

and to ensure that their policies, programs, activities, and standards address disproportionate risks to children that 

result from environmental health or safety risks. 

3.25.2 Affected Environment 

3.25.2.1 Study Methods and Study Area 

Information for this section is drawn from the Mount Hope Project EIS (USDOI BLM 2012b) and other sources as 

indicated. Where necessary, baseline socioeconomic data from the Mount Hope Project EIS has been updated, 

drawing from published sources as cited and from information provided by Eureka County. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-479 October 2016 

Public concerns expressed during scoping included potential effects on the area’s agricultural community and effects 

related to a temporary work force associated with project implementation. These issues and concerns were considered 

in developing the description of the Affected Environment. 

Environmental justice is defined as the fair treatment and meaningful involvement of all people regardless of race, 

color, national origin, or income with respect to the development, implementation, and enforcement of environmental 

laws, regulations, and policies (CEQ 1998). The assessment of environmental justice reflects USEPA’s Guidance for 

Incorporating Environmental Justice Concerns in USEPA’s NEPA Compliance Analyses (USEPA 1998). That 

guidance suggests a two-step screening process to identify environmental justice concerns. This two-step process 

defines criteria for this issue, as follows: 

1. Does the potentially affected community include a substantial minority and/or low-income population? 

2. Are there potentially high and adverse environmental or human health effects associated with the proposed 

action? 

If either of these criteria are unmet, there is little likelihood of environmental justice effects occurring. If the two-step 

process indicates a potential exists for environment justice effects to occur, further analyses are conducted to consider 

the following: 

 whether the potential exists for these effects to fall disproportionately on minority or low-income members of 

the community or on tribal resources; 

 whether the affected communities have had the opportunity to be sufficiently involved in the decisionmaking process; and 

 whether communities currently suffer, or have historically suffered, from environmental and health risks and 

hazards. 

The study area for direct, indirect, and cumulative social, economic, and environmental justice effects is the southern 

portion of Eureka County, from the BLM Elko District boundary to the Nye County line (Figure 3-1). Eureka County 

is long and narrow, approximately 128 miles from north to south, between 22 and 42 miles wide, and contains 4,182 

square miles. Eureka County government provides public services throughout the County. There are no incorporated 

towns in Eureka County. The town of Eureka, the County seat and largest community in the County, and Crescent 

Valley, the other town within the County, are unincorporated towns as defined by Nevada statutes.5 The town of 

Eureka is approximately 10 miles south of the southeast corner of the 3 Bars project area and the town of Crescent 

Valley is approximately 10 miles north (via unpaved road) from the project area’s northwest corner. The community 

of Beowawe is also in the northern part of Eureka County, approximately 14 miles north of Crescent Valley and 6 

miles south of Interstate 80. 

 

5 Nevada Revised Statute § 269.520. “Unincorporated town” or “town” means a specific area within a county in which one or more 

governmental services are provided by the county in addition to those services provided in the general unincorporated area of the 

county, for which the residents of such area pay through ad valorem taxes or for which other revenue is secured from within the area. 
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3 Bars Project Final EIS 3-480 October 2016 

3.25.2.2 Minority Populations and Poverty 

The number of residents in Eureka County that describe themselves as a member of a racial or ethnic minority and the 

incidence of poverty are both a lower percentage of the total population than comparable statewide and national levels 

(Table 3-65). No tribally owned lands, or mineral resources or lands or minerals held in trust for Native American 

Tribes by the federal government, are within or near the project area. 

TABLE 3-65 

Minority Population and the Incidence of Poverty in Eureka County, 2010 

Geographic Area Percent Racial or Ethnic 

Minority Population

Proportion of Population 

Below Poverty Level

United States 29.5 15.3

Nevada 45.9 14.8

Eureka County 15.9 10.1

Note: Racial minorities include all persons identifying themselves in the census as a non-white race, including “Black or 

African American,” “American Indian and Alaska Native,” “Asian,” “Native Hawaiian and Other Pacific Islander,” “Some 

other race alone,” and “Two or more races.” Ethnic minorities include persons who identify themselves as Hispanic or Latino. 

Persons of Hispanic or Latino origin can identify themselves as part of any race (including white) and as persons of Hispanic or 

Latino origin. 

Source: U.S. Census Bureau (2011a, b, c, 2012). 

Comparing the screening criteria outlined above to the local settlement patterns, demographics, and poverty 

characteristics of the resident population in the County, and absence of major construction or other activity having 

direct effects that would extend beyond the project area, suggests no need for further assessment of potential 

environmental justice concerns as related to the proposed 3 Bars Project. The BLM is conducting government-togovernment consultations with local tribes. If environmental justice concerns are identified during consultations, they 

will be addressed during the EIS process. 

3.25.2.3 Economic and Social Setting 

Eureka County is the second least populous county in Nevada with a 2011 estimated population of 1,994 and a 2011 

average population density of 0.48 residents per square mile (Nevada State Demographer 2012a). The 2011 

population estimate is virtually unchanged from the 1,987 residents reported for the County in the 2010 census. 

The town of Eureka initially developed in conjunction with the mining industry, but has been sustained through the 

years by the agricultural industry and local government. Farm and ranch households live on agricultural operations on 

private lands across the county, most of which are in the central portion of the county in the vicinity of Nevada State 

Route 278 (Eureka County 2010). 

Eureka County’s economy is predominately natural resource-based. Mining, farming and ranching, tourism, and 

many forms of outdoor recreation rely on the land and its resources. Agriculture, primarily growing high quality 

alfalfa and hay for sale and winter feed and cattle and sheep ranching, has historically served as a base for the Eureka 

County economy, with mining responsible for periods of economic prosperity and decline. 

Mining plays a vital and complex role in the economy and culture of Eureka County. The two largest gold mining 

operations in the state, Barrick Gold’s Goldstrike Complex and Newmont Mining’s Carlin Trend Complex, are 
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3 Bars Project Final EIS 3-481 October 2016 

located in northern Eureka County. However, most of the economic activity associated with these mines accrues to 

Elko County, which is also home to most of the employees. These and other mines provide substantial tax revenue for 

Eureka County, which is used in part to provide public services and facilities throughout the County. 

Land ownership and management also factor prominently in Eureka County’s economic and social setting. The 

federal government manages 79 percent of all land in Eureka County, providing habitat and other environmental 

functions and supporting a variety of consumptive and non-consumptive uses. About 21 percent of the land is 

privately owned, including lands in the “checkerboard” along the Union Pacific Railroad mainline in the northern 

portion of the county. State- and County-managed lands together comprise less than one-half percent of the total. 

3.25.2.4 Population and Demography 

Eureka County’s population peaked at more than 7,000 residents in 1880, fell to a low of 767 residents in 1960, then 

trended upward through the 1990s. Between 2000 and 2005, the County’s population declined by nearly 200 

residents, but subsequently gained more than 500 residents to 1,987 in 2010. The decline in the County’s population 

between 2000 and 2005 coincided with a suspension of operations at the Ruby Hill Mine. 

Between 2000 and 2011, population trends in Eureka County’s unincorporated towns and outlying areas mirrored 

both those of the entire County and employment trends in the mining industry. During this period, just over two-thirds 

of the County’s residents lived in the town of Eureka and nearby rural areas in the southern portion of the County. In 

2011, the town of Eureka had 611 residents, with 396 in Crescent Valley and 987 living elsewhere in the County 

(Table 3-66). 

In 2011, the average household size in southern Eureka County was 2.38 persons, which is smaller than the statewide 

average of 2.65 individuals (U.S. Census Bureau 2011a). 

The racial composition of the resident population in southern Eureka County is more predominately white than that of 

the state as a whole. In 2010, 89.6 percent of area residents identified themselves as white, alone or in combination 

with one or more other races. That compares to 66.2 percent at the statewide level (U.S. Census Bureau 2011a). 

The Nevada State Demographer prepares population estimates and population projections for Nevada’s counties, 

cities, and unincorporated towns. The forecasts released in April 2012 anticipate a net gain of approximately 300 

residents in Eureka County by 2020, with a further gain of 200 residents by 2030. The projected population gains 

initially parallel anticipated gains of 400 jobs in the County, on a place of work basis. Population growth is projected 

to slow thereafter (Nevada State Demographer 2012b). 

TABLE 3-66 

Eureka County Population, Selected Years, 2000 to 2011

Area 2000 2005 2011 

Eureka County 1,651 1,485 1,994 

Eureka Town 499 440 611 

Crescent Valley 330 311 396 

Remainder of the County 822 734 987

 Source: U.S. Census Bureau (2011a, b), and Nevada State Demographer (2012a). 
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3 Bars Project Final EIS 3-482 October 2016 

3.25.2.5 Economy and Employment 

Mining dominates the Eureka County economy in terms of employment and earnings. Total employment in the 

County topped 5,300 jobs in 1997, nearly 4,400 of which were in mining. The concentration of employment in the 

6 

mining sector is the result of the expansion of several gold mines along the Carlin Trend in the northern part of the 

County, and whose employees reside, for the most part, outside of the County. 

Data on the resident labor force and employment by place of residence are more reflective of the much smaller and 

more recent mining presence in southern Eureka County. Barrick Gold’s Ruby Hill Mine is just outside the town of 

Eureka, and provides an economic and employment boost for southern Eureka County. Since 2006, the Ruby Hill 

Mine has been recovering gold from the East Archimedes ore body, and recently announced additional reserves which 

may support mining for several more years. 

Eureka County’s labor market conditions generally parallel trends in the mining industry, although they are more 

closely tied to activities in the southern part of the County. In 2005, when construction of the East Archimedes 

expansion of the Ruby Hill Mine was underway, the labor force stood at 674 and unemployment at 3.6 percent. The 

resident labor force has subsequently expanded to nearly 1,100, 65 percent over the 2005 levels, while unemployment 

remains relatively low 6.4 percent in February 2012 (Table 3-67). 

TABLE 3-67 

Eureka County Labor Force, Unemployed, and Unemployment Rate, Selected Years 

2007 2008 2009 2010 2011 2012 

(Feb)

Labor Force 793 845 906 1,082 1,115 1,081

Unemployed 59 46 62 82 67 69 

Unemployment Rate (%) 4.3 5.5 6.8 7.6 6.0 6.4 

Source: U.S. Department of Labor Bureau of Labor Statistics (2012). 

Based on the strength of Eureka County’s economy, local unemployment rates are consistently lower than both the 

statewide and national averages; 6.0 percent in Eureka County for 2011, as compared to 13.5 percent statewide and 

8.9 percent for the nation. 

Eureka County personal income data by place of work statistics reflect the presence of the Barrick and Newmont 

mines in the northern part of the County, whereby most of the labor earnings paid by Eureka County employers flow 

out of the local economy. Over the 3-year period 2008 to 2010, more than 80 percent of the total wages and salaries 

paid by employers in Eureka County were to workers living outside the county. After additional adjustments, social 

security deductions, and other income such as interest and dividends, the total personal income of residents averaged 

approximately $66 million (Table 3-68). 

 

6 The Carlin Trend, one of the world’s most productive gold mining districts, is a northwest trending belt of mineral deposits over 50 

miles long and 5 miles wide extending through northern Eureka County into Elko County on the northwest and southeast. 
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TABLE 3-68 

Eureka County Personal Income by Place of Residence, Selected Years (in millions of dollars)

20081 20091 20101

Earnings by Place of Work 441.1 463.9 453.6

Net Residency Adjustment -347.8 -369.4 -357.3

Social Security Deductions -43.9 -48.7 -48.0

Other Income to Residents 16.8 16.9 17.3

Total Personal Income - Residents 66.2 62.7 65.7

Per Capita Income $37,227 $32,577 $32,876

1A negative residency adjustment reflects the net earnings of workers employed in Eureka County, but who reside 

elsewhere, primarily in Elko County, that are in excess of the earnings of Eureka County residents employed outside the 

County. 

 Source: U.S. Bureau of Economic Analysis (2012a). 

Prior to the late 1990s, per capita personal income of Eureka County residents was higher than that for Nevada and 

the U.S. Eureka County residents have trailed the state and national norms since 2000. In 2010, the variance was 11 

percent below the statewide average and nearly 18 percent below the national average (Table 3-69). A substantial 

decline in farm income between 2008 and 2009 was largely accountable for a decrease of more than $4,600 in per 

capita personal income (U.S. Bureau of Economic Analysis 2012b). 

Although the mining industry is the dominant employer in the county, other sectors play important roles in supporting 

the County’s economy, particularly in the southern portion of the County. These sectors include government and 

public education, retail trade and services, construction, and agriculture. The levels of economic activity and 

employment in sectors other than agriculture, particularly construction, have historically reflected changes in mining 

activity. 

TABLE 3-69 

Per Capita Personal Income, Eureka County, Nevada, and the United States 

2008 2009 2010 

Eureka $37,227 $32,577 $32,876

Nevada $39,879 $36,533 $36,938

United States $40,947 $38,846 $39,937

Source: U.S. Bureau of Economic Analysis (2012c). 

Public sector employment, which includes federal, state, and local government and public school employment, 

increased through much of the 1990s, eventually peaking at approximately 275 (U.S. Bureau of Economic Analysis 

2012d). Public sector employment subsequently fell to 166 in 2003 before climbing to 250 in 2011 (Nevada 

Department of Employment, Training and Rehabilitation 2012). Most of the public sector employment in Eureka 

County is based in the town of Eureka due to the location of the County administrative and other functions, the 

Eureka County School District, and some state agencies within the town. Farm employment accounted for 3.3 percent 

of all employment. 

The local business sector in the town of Eureka is limited in diversity and scale, focused primarily on essential 

consumer, building, and automotive goods and services. Retail shopping opportunities include groceries, hardware 

and lumber, auto parts/fuel/supplies, and novelties and gifts targeted at tourists. There are also several restaurants and 
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3 Bars Project Final EIS 3-484 October 2016 

other food service establishments, two bars, and a casino in town. Residents use the internet or travel to Elko, Reno, 

or elsewhere to access a wider selection of goods, financial services, and a broader range of medical and dental care 

(USDOI BLM 2012b).

The local business sector in Crescent Valley includes a convenience/gas store, a restaurant and bar, a trailer park, and 

a contractor and tire, lube and equipment rental establishment (Eureka County 2012). Tourism, recreation activities, 

attractions, and events in Eureka County include big and small-game hunting, fishing, sightseeing, off-highway 

vehicle use, visits to the Eureka Opera House and Sentinel Museum, general interest in the historic mining character 

of the community, and events such as the county fair, county youth fair, high school rodeo, and special events (e.g., 

car show and drag race, and shooting and archery tournaments [Eureka County 2012, USDOI BLM 2012b]). 

Travelers along U.S. Highway 50, including bicyclists and motorcyclists, contribute to the Eureka County economy. 

The economic stimulus generated by recreation and tourism cuts across several retail and service industries; as a 

result, data regarding the levels of activity are not readily available. 

Closely aligned with recreational activity on public lands is the harvest and collection of resources for personal use 

and enjoyment. Eligible resources include flowers, berries, pinyon and other nuts, seeds, cones, and other plant parts, 

campfire wood, rocks, mineral specimens, petrified wood, Christmas trees, semiprecious gemstones, and common 

invertebrate fossils. Harvesting of berries, nuts, and other plants and plant material is an important customary and 

traditional use of public lands for Native Americans. 

3.25.2.6 Farming and Ranching 

Local agriculture is an important element of the area’s economic base. Although agriculture’s importance may not 

always be reflected on a strict accounting basis and farm income is sensitive to outside influences and varies year to 

year, farming and ranching provide livelihoods for many households, support local government and public education 

by contributing to the local tax base, and indirectly support other local businesses through purchases of farm 

equipment, fuel, veterinary services, and other goods and services. Since members of agricultural households often 

work “off the ranch” for additional income, they are also a source of labor for other employers. A study of economic 

linkages in Eureka County reported that each direct job on local farms and ranches supported between 0.28 and 0.68 

jobs elsewhere in the local economy, and that every $1 in economic output resulted in another $0.66 to $1.02 in 

secondary economic impact (Fadali et al. 2005). Examples of such linkages include local purchases of diesel fuel, 

lubricants, tools, other farm supplies, and groceries from local merchants and service providers, as well as electrical 

power used for irrigation purchased from Mt. Wheeler Power. Furthermore, the farm-based population tends to be 

connected to the land in ways that anchors it to the area more so than households associated with other elements of the 

economy. 

Farm employment in Eureka County has experienced some volatility since 2000, declining for several years at the 

beginning of the decade, but increasing thereafter. As a consequence, farm employment in 2010 was reported at 163, 

a net increase of 30 farm jobs, or 23 percent, as compared to 2000. 

The USDA National Agricultural Statistics Service (2009) reported 86 farms and ranches in Eureka County in 2007, 

up from 73 in 2002. Together those 86 operations reported operating a total of 783,440 acres, which corresponds to an 
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3 Bars Project Final EIS 3-485 October 2016 

average farm size of 9,110 acres.7 Eureka County farmers and ranchers reported just under $27 million in livestock, 

commodity, and other agricultural product sales in 2007 and out of 17 counties in Nevada, Eureka County was ranked 

fourth in the state in terms of crop value. The combined sales of livestock and products rose to $32 million in 2008, 

declining to $24.1 million in 2010. Revenue derived from livestock sales generally accounts for about one-third of the 

aggregate sales by local farms and ranches, and receipts from crop sales account for about two-thirds of the total. 

Cattle account for most of the livestock raised in Eureka County with sheep and horses accounting for most of the 

remainder. Approximately 35,000 acres of farmland are devoted to forage production (U.S. Bureau of Economic 

Analysis 2012b). 

Eureka County growers are known to raise high quality alfalfa and other hay that is marketed out-of-state to dairies 

and horse breeders, as well as exported internationally. Data for Eureka County in 2011 indicated a total of 

approximately 42,400 acres devoted to raising crops; hay (31,200 acres) and alfalfa (10,400 acres) being the two 

primary crops (USDA National Agricultural Statistics Service 2012a). More than 70 percent of the total land planted 

in crops was in the Diamond Valley and elsewhere in southern Eureka County. As shown in Figure 3-52, Eureka 

County alfalfa production has ranged from a 2004 low of slightly over 60,000 tons, to a peak in 2007 of over 100,000 

tons. Production in 2011 was 77,000 tons, comparable to the annual average for the period 1995 to 2011. Weather, 

including an extended period of drought, was largely responsible for much of the year-to-year variation in hay 

production over the past decade. 

Eureka County livestock production over the past 11 years peaked at 37,000 units in 1999 and 2000, but has since 

decreased to 25,000 units in 2011 (see Figure 3-53)

8

. As in the case of hay production, some of the changes in the 

number of cattle produced reflect the effects of drought, as some ranchers adjusted to the availability of hay. 

Historically, substantial numbers of both sheep and cattle were raised in Eureka County but more recently cattle have 

become predominant. Table 3-70 summarizes farm income and expenses from 2007 to 2010 for farms in the study 

area. 

It is not uncommon for households dependent on agriculture to derive income from multiple sources, with one 

member engaged in farming/ranching and another working in education, government, or mining, for example. In fact, 

some residents note that having an “off-the-ranch” income is economically imperative, particularly recently when 

agricultural production and income have been adversely affected by the extended drought. 

 

7

 The 783,440 acres in farms in 2007 is over 500,000 acres more than was reported in 2002 and exceeds the approximate total of 550,000 

acres of privately owned land reported by Eureka County (2010). The reason for this discrepancy is unclear. 

8

 The information regarding livestock production for 2007 to 2011 is of questionable reliability due to cutbacks in federal funding that has 

affected data collection, analysis, and reporting of agricultural production. 
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3.25.2.7 Housing 

Eureka County had a total of 1,076 housing units in 2010, a net increase of 51 units compared to the 2000 Census 

(U.S. Census Bureau 2002; 2011a). Most of the net change was in multi-family units built in the town of Eureka. 

According to the Census Bureau, just over half of all units were single family residences, mobile homes accounted for 

40 percent of all homes, and multi-family units about 7 percent. Vacancy rates are low across the County. The County 

is working with the Nevada Rural Housing Authority to develop new housing and commercial development in the 

Eureka Canyon subdivision located on the north end of the town of Eureka. 

Figure 3-52. Eureka County Alfalfa Production 1995 – 2011. 

Source: USDA National Agricultural Statistics Service (2012a).

Figure 3-53. Eureka County Livestock Production 1995 – 2011.

Source: USDA National Agricultural Statistics Service (2012b).

0

20,000

40,000

60,000

80,000

100,000

120,000

1995 1997 1999 2001 2003 2005 2007 2009 2011

Tons

 -

 5,000

 10,000

 15,000

 20,000

 25,000

 30,000

 35,000

 40,000

 45,000

Units

Sheep

Cattle & Calves
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3 Bars Project Final EIS 3-487 October 2016 

TABLE 3-70 

Farm Income and Expenses, Eureka County 2007 to 2010 (x $1,000) 

2007 2008 2009 2010

Cash receipts from livestock and products $ 9,460 $ 7,965 $ 7,878 $ 9,000

Cash receipts from crops 17,341 24,056 17,808 15,124

Other income 1,344 880 1,675 1,084

Production expenses 22,325 23,216 23,888 23,001

Value of inventory change -3,063 -412 517 -121

Net income of corporate farms 629 1,484 457 390

Net farm proprietors income 2,128 7,789 3,533 1,696

Source: U.S. Bureau of Economic Analysis (2012b).

Accommodations for tourists and visitors, including four motels offering a total of 88 rooms, are in the town of 

Eureka (Eureka County 2010). Four mobile home and recreational vehicle parks provide nearly 100 spaces for shortand long-term rental. During the peak summer travel and hunting seasons, the short-term accommodations are 

frequently at or near full occupancy. A 36-space mobile home park in the town of Eureka was refurbished by Eureka 

Moly Limited Liability Corporation (LLC), and two additional recreational vehicle parks were recently refurbished or 

built. Much of the recent housing activity is being prompted by the potential development of the Mount Hope Project 

north of Eureka, in the vicinity of the 3 Bars Project area (USDOI BLM 2012b). There is one recreational vehicle 

park in Crescent Valley. 

3.25.2.8 Eureka County Facilities, Services, and Public Utilities 

Eureka County is governed by a three member Board of County Commissioners elected at-large to overlapping 4-year 

terms. Each year the Board selects one of its members to serve as Chairperson. County government provides a broad 

range of services to the two unincorporated towns and to the County as a whole. To provide these services, Eureka 

County employed 92 full-time employees and 45 casual employees in fiscal year 2011. The County also uses 

contractors and various service vendors. Within the County, the three largest functions in terms of full-time 

employees were public works (25), public safety (22), and general government (18). Public works includes the 

County’s road and bridge department, as well as staff associated with water and wastewater utilities, solid waste 

control, fairgrounds, and county buildings and grounds (Eureka County 2011). 

3.25.2.8.1 Law Enforcement and Criminal Justice 

The Eureka County Sheriff's Office is based in the town of Eureka and provides law enforcement for the entire 

County, operates the County’s detention facilities, and provides dispatch services for all County public safety 

functions including police, emergency medical, and fire suppression activities. The District Attorney, District Court, 

and Juvenile Probation office are also based in the town of Eureka. 

3.25.2.8.2 Emergency Response 

Emergency response includes fire protection and emergency medical/ambulance services. Eureka County funds an 

emergency management services coordinator to oversee emergency planning, response, and management among the 
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various local service providers, serves as a liaison with various statewide entities, and directs the volunteer 

ambulance/emergency medical service in Eureka. 

3.25.2.8.3 Fire Protection

Eureka County funds six local volunteer fire departments. In addition to departments in the town of Eureka and 

Diamond Valley, volunteer fire departments are located in Beowawe, Crescent Valley, Dunphy, and Pine Valley. 

The Eureka Volunteer Fire Service (VFS) and the Diamond Valley VFS service southern Eureka County. The Eureka 

VFS provides fire suppression service in and around the town of Eureka and accompanies the ambulance on motor 

vehicle accident calls. During dry years, the VSF frequently responds to calls to fight wildfires. The Eureka VFS is 

staffed by volunteers and is housed in a two-story, seven-bay fire station commissioned in late 2009. 

The Diamond Valley VFS located on 11th Street in Diamond Valley. The Diamond Valley VFS maintains a three-bay 

fire station that accommodates five vehicles including an ambulance. Most calls to the VFS are for vehicle accidents 

along State Route 278 and for wildfires (USDOI BLM 2012b). 

These departments, along with the Nevada Department of Forestry and BLM, maintain mutual-aid agreements to 

augment the capacities of any given department when the need arises. Eureka County provides funds to the Nevada 

Department of Forestry to help fund its fire suppression activities. 

3.25.2.8.4 Emergency Medical/Ambulance Services

Emergency medical care and transportation in the County are provided by the Eureka County Emergency Medical 

Service, a volunteer ambulance service. In the southern part of the County, the Emergency Medical Service is staffed 

by the full-time paid Eureka County Emergency Medical Service Coordinator and volunteers. Two ambulances and a 

search and rescue vehicle are housed in the town of Eureka. An older ambulance is stationed in Diamond Valley. The 

ambulances have radio communication with Northeast Nevada Regional Hospital in Elko, where most patients are 

transported. Fixed-wing and helicopter emergency medical air transportation is available to hospitals in Elko and

Reno, Nevada, and Salt Lake City, Utah (USDOI BLM 2012b).

3.25.2.8.5 Health Care 

Primary health care in southern Eureka County is provided at the Eureka Medical Clinic in the town of Eureka and 

operated by the Nevada Health Centers, Inc. The Eureka Medical Clinic facility was constructed in 1998 with funding 

from Eureka County. When fully staffed, the clinic employs a physician, a physician’s assistant/clinic coordinator, 

two medical assistants, and an administrative employee. The clinic provides a full range of basic and emergency 

medical services. 

Another health care clinic is in Crescent Valley. It is open on a part-time basis, staffed by practitioners from the 

Eureka Medical clinic who travel to the facility. Most patients requiring hospitalization use the Northeastern Nevada 

Regional Hospital in Elko. Patients requiring specialized care often choose to access facilities in Reno (USDOI BLM 

2012b). 

3.25.2.8.6 Public Education 

Public education (kindergarten through 12th grade) in Eureka County is provided by the Eureka County School 

District, headquartered in the town of Eureka. In addition to administrative offices, the Eureka County School District 
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3 Bars Project Final EIS 3-489 October 2016 

operates an elementary school and a junior/senior high school in Eureka, which serve the southern portion of the 

County. The Eureka County School District also operates an elementary school in Crescent Valley, serving the 

Crescent Valley/Beowawe area. The Eureka County School District sends junior and senior high school students from 

the Crescent Valley/Beowawe area to the Lander County School District’s schools in Battle Mountain and sends 

some Pine Valley area students to the Elko County School District Combined School in Carlin. Public school 

th enrollment in grades kindergarten through 12 grade totaled 235 students in the fall of 2012, an increase of 6 students 

compared to the preceding year (Nevada Department of Education 2012). 

3.25.2.8.7 Other Public Facilities and Services 

Eureka County provides social and senior services from offices in Eureka. The County fairgrounds, a library, 

swimming pool, and other recreational facilities are also in Eureka.

Eureka County maintains and operates three water systems in the southern part of the County, the Eureka Town 

Water System and two general improvement district systems in the Devils Gate subdivision about 4 miles north of 

Eureka. The County also operates a water system in Crescent Valley. 

Wastewater collection and treatment services in the town of Eureka are provided by a central system, with a multiplecell, aerated, evaporative lagoon wastewater treatment facility managed by the County public works department. 

Developments in Crescent Valley and elsewhere in the County rely on septic systems. 

Eureka County operates the Class II-rated Whiskey Flat Landfill north of the town of Eureka. The landfill is staffed 

by two County public works employees. The County has long-term plans to open a new landfill (USDOI BLM 

2012b). 

Mt. Wheeler Power provides electric power to central and southern Eureka County including the town of Eureka and 

the project area. Nevada Energy provides power to the Crescent Valley area. Residential and commercial gas is 

provided by private propane vendors. Conventional landline telephone service is provided by AT&T. Cellular phone 

coverage is available across much of the County except in Pine Valley along State Route 278. 

3.25.2.9 Fiscal Conditions 

Eureka County has a solid fiscal foundation. That strength derives from a combination of substantial revenues 

generated by the mining industry, a relatively low service population, and local governance policies focused on using 

revenues to fund essential countywide services and maintaining a strong reserve fund during periods of prosperity 

which can be used to cushion the budgetary impacts of mine closures or declining net proceeds or assessments. 

Total County revenues have risen by nearly $10 million per year over the past 5 years, from $22.6 million in fiscal 

year 2006/2007 to $32.4 million in fiscal year 2010/2011 (Table 3-71). Eureka County’s primary revenue sources are 

ad valorem taxes and intergovernmental revenues. These two categories of revenue have accounted for more than 85 

percent of the County’s total revenues in each of the past 3 years.

Ad valorem taxes are a function of the tax rate and assessed valuation. Local ad valorem tax rates are consistently the 

lowest or among the lowest rates in Nevada. In 2010/2011, the tax rate on property in the town of Eureka was $1.9896 

per $100 of assessed valuation, 45 percent less than the state-mandated maximum of $3.64 per $100. All property 

owners benefit from the relatively low tax rates. Recognizing the potential volatility in revenues associated with 

mining activity, the Board of Eureka County Commissioners has a long-standing a policy to maintain relatively 
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3 Bars Project Final EIS 3-490 October 2016 

steady property tax rates, funding reserve accounts during periods of prosperity that can be used to cushion the 

budgetary impacts of mine closures or declining net proceeds or assessments (USDOI BLM 2012b). 

Over the past decade, Eureka County’s total assessed valuation has grown dramatically as a result of capital 

investment in mining, higher production, and record high gold prices. In 2008/2009, the County’s total assessed value 

reached $1.51 billion, more than a 150 percent increase in just 3 years. Driven by the increases in gold prices, the total 

valuation doubled to more than $3.1 billion for the 2010/2011 tax year and primarily the result of a large jump in net 

proceeds (Table 3-72).

In fiscal year 2010-11, agricultural lands and improvements accounted for approximately 1.9 percent of Eureka 

County’s total assessed value, if the net proceeds from mining are excluded. If net proceeds of mining are included, 

agriculture’s share is 0.5 percent (Nevada Department of Taxation 2012). 

As a result of the growth in assessed value, ad valorem taxes levied by Eureka County increased from $7.1 million in 

fiscal year 2006/2007 to $18.5 million in fiscal year 2010/2011. The latter is a record high. Combining the real and 

personal property valuations associated with the mining industry and net proceeds reveals that the mining industry 

accounts for approximately 90 percent of the total ad valorem tax base of the County and Eureka County School 

District. 

TABLE 3-71 

Eureka County Budget Summary, Fiscal Years 2007 to 2011 

2006/2007 2007/2008 2008/2009 2009/2010 2010/2011

Total Revenues $22,566,806 $24,495,445 $32,088,413 $29,242,039 $32,362,380

Total Expenditures 14,439,988 21,468,845 24,651,142 28,202,042 27,824,071

Net Current Revenue 8,126,818 3,026,600 7,437,271 1,039,997 4,538,309

Reserve Fund Balance 

(Ending) 46,551,069 49,592,669 57,036,340 56,326,337 59,625,419

 Source: Eureka County (2011). 

TABLE 3-72 

Eureka County Assessed Value, Fiscal Years 2005/2006 through 2010/2011 (in millions of dollars) 

Fiscal Year Secured1 Unsecured, Including Net 

Proceeds of Mines1 Total 

2005/2006 $273.4 $322.6 $596.0 

2006/2007 333.8 488.9 822.7 

2007/2008 381.9 653.0 1,034.9 

2008/2009 473.1 1034.4 1,507.5 

2009/2010 583.7 832.6 1,416.3 

2010/2011 546.2 2,627.2 3,173.4 

1

Secured property generally refers to real property, mobile homes placed on foundations, and some improvements held by a title. 

Unsecured property generally refers to personal property, mobile homes not placed on foundation, and other property interest subject to 

property tax. 

Source: Nevada Department of Taxation (2012). 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-491 October 2016 

Intergovernmental revenues, the second major category of revenues for Eureka County, increased from $11.6 million 

in fiscal year 2005/2006 to $13.3 million in fiscal year 2009/2010, falling to $9.7 million in fiscal year 2010/2011. 

Intergovernmental revenues from the state include the Basic County-City Relief Tax, Supplemental County-City 

Relief Tax, motor vehicle property taxes, and fuel taxes. Basic County-City Relief Tax and Supplemental CountyCity Relief Tax are statewide sales and use taxes enacted to provide property tax relief. Intergovernmental revenues 

also include various federal payments and grants, including receipts of federal Payments in Lieu of Taxes. In 2010, 

federal Payments in Lieu of Taxes payments totaled $275,208, based on 2,156,915 acres of qualifying federal lands 

(USDOI BLM 2012b). 

Eureka County expenditures have also increased in recent years from $14.4 million in 2006/2007 to $27.8 million in 

2010/2011, the rise generally tracking the growth in revenues over time (Table 3-71). Budgeted expenditures 

increased across all major functions/departments. Much of the increase is accounted for by non-recurring outlays for 

facility and road improvements funded from current revenues and the County’s accumulated reserves for such 

purposes. Eureka County completed several major capital improvement projects in recent years. These projects 

included a new Eureka Fire House, water storage and distribution projects in Eureka, a Main Street water/sewer 

project in Eureka, arsenic treatment projects in the Devils Gate and Crescent Valley water systems, and a Countywide 

chip seal project. 

Net current revenues, defined as total revenues less total expenditures, ranged between $1.0 and $8.1 million over the 

past 5 years (Table 3-71). For fiscal year 2010/2011, the net current revenue was $4.5 million. After accounting for 

other financing sources or outlays, the residual net revenue was transferred to the County’s reserve funds. The 

County’s combined reserve fund balances stood at $59.6 million at the end of the 2010/2011 fiscal year. 

A small portion of the reserve fund is held as a reserve against an outstanding note receivable; however, the majority 

of the funds is unreserved, and are held for potential use in meeting future general fund needs, capital projects, and 

other special needs as established by the County Commission. The County had no bonded debt as of June 30, 2011. 

3.25.2.10 Social Conditions and Affected Publics 

This section generally describes existing social conditions in Eureka County and groups that could be affected by the 

3 Bars Project. Information for this section was obtained from interviews (between 2006 and 2008) with local 

officials, County staff and local residents, and from a review of secondary sources (Blankenship Consulting LLC and 

Sammons/Dutton LLC 2008). 

Southern Eureka County, including the town of Eureka and Diamond Valley, is a close-knit community where many 

residents know each other because of their long association with the community. There are a number of multigenerational families in the community, some whose roots date back to the original settlement of the area by people of 

European descent. Many southern Eureka County residents are deeply involved in the community. It is not 

uncommon for an individual to be a hay grower or business person, serve as an elected official or be an appointed 

member of a board or committee, and also serve as a member of a volunteer fire department, search and rescue team, 

or other civic organization. 

Although the town of Eureka hosts tourists and highway travelers during summer months and experiences periodic 

influxes of mine workers from area mines, it endeavors to maintain its small town traditions and lifestyles. Many 

residents enjoy knowing many of their neighbors and value the low crime rate and the casual atmosphere of the town. 
SOCIAL AND ECONOMIC VALUES AND ENVIRONMENTAL JUSTICE 

3 Bars Project Final EIS 3-492 October 2016 

On the other hand, some community members are concerned that many of the community’s youth move away to find 

suitable employment and would like to have a somewhat larger student body at the high school to support a broader 

curriculum. The limited range of commercial, dining, and entertainment options, is a drawback for some residents. 

Specific public and groups identified during scoping and interviews as potentially affected by development and 

operation of the mine include: 

 Eureka County ranchers who hold grazing permits for the allotments within the 3 Bars Project area. 

 Individuals and businesses that provide goods and services to the agricultural sector. 

 Individuals and businesses that may provide goods and services to contractors or the BLM personnel 

involved in the restoration efforts. 

 Recreational users of the 3 Bars Project area. These users mainly include hunters, some off-highway vehicle 

users (all-terrain vehicle and snowmobile) and visitors, and re-enactors and supporters interested in the Pony 

Express National Historic Trail, which traverses the project area. 

 Individuals and businesses that provide goods and services to outdoor recreational users of the 3 Bars Project 

area. 

3.25.3 Environmental Consequences 

Public lands play an important role in the economy, social structure, and quality of life for area residents as well as for 

tourists and other visitors to the area. The economic contributions derived from use of public lands, including 

expenditures by local and non-local recreational users, provide support for local ranching, mining, and other natural 

resource uses. The “wide open spaces” that are common across the West and that are comprised largely of public 

lands also contribute to the “sense of place” that is important to residents and nonresidents alike. Because of the 

important ties between public lands and communities and residents, actions that affect public lands, including 

landscape restoration activities, may have social and economic consequences in the region. 

Implementation of the proposed vegetation treatment program would create temporary and long-term effects on land 

use patterns, resulting in short-term socioeconomic effects. However, effects would also result from non-action, 

although the timing, extent, and location of these effects are subject to a higher degree of uncertainty. Consequently, 

the socioeconomic assessment seeks to describe the trade-offs involved between action and no action. 

3.25.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

Specific stakeholder groups identified during scoping as potentially affected by the restoration initiatives include: 

 Individuals and businesses providing goods and services to the BLM in conjunction with the landscape 

restoration projects. 

 Farmers and ranchers in the Kobeh and Diamond Valleys, who raise livestock and grow alfalfa, hay, or other 

grasses, including high quality dairy and export grade hay. 

 Grazing operators who manage cattle on BLM grazing allotments in the 3 Bars Project area. 

 Businesses that provide goods and services to local farming and ranching operations. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-493 October 2016 

 Recreational users of the area around the 3 Bars Project, including hunters, anglers, off-highway vehicle 

users, sightseers, and re-enactors and supporters of the Pony Express National Historic Trail, which traverses 

the 3 Bars Project area. 

The key issues of concern regarding socioeconomics identified by stakeholders during scoping include: 

 Recognize the contributions of the existing agriculture industry to the economic and social structure of 

Eureka County. 

 Recognize the economic and social benefits of other land uses and activities that occur in the area. 

 Consider the potential short- and long-term economic effects of the treatment alternatives on ranch operators. 

 Consider the local job opportunities and economic development effects supported by the landscape treatment 

alternatives. 

 Plan and schedule vegetation treatments and coordinate with grazing permittees to limit the extent of shortterm economic disruptions. 

 Consider the overall cost of the restoration project and how the project would be funded. 

3.25.3.2 Significance Criteria 

The NEPA (Section 1508.14) states that “...economic or social effects are not intended by themselves to require 

preparation of an environmental impact statement. When an environmental impact statement is prepared and 

economic or social and natural or physical environmental effects are interrelated, then the environmental impact 

statement would discuss all of these effects on the human environment.” This means that social or economic 

differences are not enough to result in a potentially significant adverse effect, but need to manifest themselves with 

some physical change, as described in the NEPA (Section 1508.8[b]), “...effects may include growth inducing 

impacts and other effects related to induced changes in the pattern of land use, population density or growth rate.”

The proposed action would be considered to have a significant effect on social and economic values if the 

following occurred:

 Substantial long-term change in any sector of the local economy, such as major expansion or contraction of 

employment, output, or diversity. 

 An increase in temporary or resident populations that would unduly strain the ability of affected communities 

to provide housing and services or otherwise adapt to growth-related social and economic changes. 

 An aggregate change in public sector revenue and/or expenditure flow likely to either compromise the ability 

of affected units of government to maintain public services and facilities at established service levels, or to 

compromise their ability to allow for improved services without increasing the tax burdens on existing 

taxpayers. 

 Permanent displacement of residents or users of affected areas that would result from project induced 

changes in or conflicts with existing uses or ways of life. 

The significance threshold would be triggered if any one of the above criteria were satisfied.
SOCIAL AND ECONOMIC VALUES AND ENVIRONMENTAL JUSTICE 

3 Bars Project Final EIS 3-494 October 2016 

3.25.3.3. Direct and Indirect Effects 

3.25.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

Adverse Effects 

Because the 3 Bars Project area is rural and largely undeveloped, potential adverse social effects related to restoration 

would be indirect and largely intangible, and would most likely affect general degrees of satisfaction or dissatisfaction 

of individuals, families, and various stakeholders. In general, the social and economic effects associated with the 

management types and treatment methods would be similar in type, varying in degree based on the cost of treatment 

and the acres of area treated. 

There could be short-term reductions in authorized grazing levels and subsequent downward pressure on ranch 

income as a result of grazing restrictions and increases in the required amount of livestock management. It is 

estimated that the total economic cost to ranchers and the local economy would be $69.57 per AUM, much of which 

would accrue to the regional economy of northeastern Nevada. This value differs from the $53.40 (1999 dollars) and 

$73.75 (2012 dollars) values given in the Mount Hope Project Final EIS. Those values were based on the Nevada 

Grazing Statistics Report and Economic Analysis for Federal Lands in Nevada (Resource Concepts, Inc. 2001) and an 

adjustment for general inflation. However, the original $53.40 value was determined to be incorrect because of 

double-counting of the industry’s labor income and value-added when Resource Concepts, Inc., reported total output 

as defined by the Impact Analysis for Planning (IMPLAN) model. By adding the three lines items together, all other 

things remaining the same, the net result is that the economic values of an AUM to regional output were 

overestimated in the Mount Hope Project Final EIS. To correct the issues associated with the Resource Concepts, 

Inc., values, the updated value of $69.57 per AUM was derived based on average beef prices over the period January 

2004 to January 2013, as compared to the 1999 base value used by Resource Concepts, Inc. (USDA National 

Agricultural Statistics Service 2013), and an updated local economic output multiplier of 2.02 as compared to the 

statewide multiplier of 1.82 reported by Resource Concepts, Inc. (Fadali 2005). 

The BLM would experience short-term, and possibly long-term, reductions in annual grazing fees as a result of 

reductions in the level of authorized grazing use during and following treatment. Existing linkages between grazing 

and ranch families in the Diamond and Kobeh Valleys, public lands and public lands management, and the Eureka 

community would continue, with short-term uncertainties regarding the timing and effectiveness of implementation, 

and potential long-term reduction in uncertainty regarding future grazing levels. 

Social effects would include effects on ranchers, outfitters, individual recreationists, some business owners, local law 

enforcement and fire departments in Eureka County, and others affected directly and indirectly by changes in access, 

temporary closures, or other restrictions associated with the mechanical and fire treatments. These effects would 

manifest themselves in terms of concerns for social and economic well-being, increased satisfaction or dissatisfaction 

with public lands management by the Mount Lewis Field Office, and quality of life in general. Some individuals may 

also experience dissatisfaction with the types and locations of treatments proposed. 

Treatments could occur within designated harvest units for woodland products, as discussed in Section 3.12. There is 

a large degree of overlap between harvest units and pinyon-juniper treatment areas. As a result of thinning treatments, 

the number of pinyon pine and juniper trees within harvest areas would be reduced, although woodland products 

would still be available over portions of treatment areas. Treatments would affect approximately 26 percent of the 

total designated woodland products harvest area during the life of the project. Removal of pinyon pines and juniper 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-495 October 2016 

from these areas would eliminate or limit the ability to harvest woodland products there, although a large portion of 

the potential treatment area would not be affected. Additionally, other nearby areas in the Battle Mountain District, 

which make up a substantial portion of the annual harvest area, would not be affected by treatments under the 3 Bars 

Project. 

None of the action alternatives would cause substantive changes to existing patterns and trends in local population and 

demographic conditions in Eureka County. The employment opportunities associated with implementation of the 

restoration initiative would generally be temporary and unlikely to substantially affect migration to or from the region. 

Beneficial Effects 

The project would generate a short-term temporary local economic stimulus (e.g., purchases of materials and supplies, 

equipment-related rentals and leases, and retail and lodging expenditures) associated with BLM and contractor efforts 

and jobs. Locally, these benefits would accrue primarily to residents and businesses in southern Eureka County. At a 

national level, the short-term effects on employment and income would not necessarily represent benefits, but rather 

transfers funded through the BLM's budget process. 

In addition, pinyon-juniper trees with potential for use as fence posts or for firewood could be gathered up and offered 

for sale to the public, providing additional benefits to residents, local businesses, and landowners, including farmers 

and ranchers. Potential long-term benefits associated with future increases in the level of authorized grazing use 

would be dependent on the successful achievement of the treatment objectives. 

It is assumed that restoration treatments would meet, to varying degrees, the identified need for reducing the risk of 

wildfire and improving ecosystem health. Restoration treatments would reduce the amount and concentration of 

hazardous fuels. As a result, the number, size, and severity of wildfires would be reduced, as would the cost of 

wildfire suppression and the risk of loss of life and property. The reduction in risk of a large-scale reduction in 

wildfire would benefit nearby private property owners and facilities constructed on public land, including facilities for 

mining and infrastructure, reducing the risk of property damage and interference with operations. Treatments that 

improve ecosystem health could increase or improve the amount and quality of commercial and casual uses of public 

lands, improve or maintain market and non-market values of public land resources, and reduce the cost of operations 

on public lands (USDOI BLM 2007c:4-124).

3.25.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

The BLM would treat on average about 127,000 acres annually using all available methods under Alternative A. The 

2- to 4-fold increase in acres treated compared to Alternatives B and C, respectively, reflects the BLM’s ability to use 

lower cost treatment methods under Alternative A. For example, the BLM would be able to use prescribed fire 

(approximately $50 per acre) under this alternative, but not under Alternatives B and C. This is less than the costs 

associated with manual (cutting trees with a chainsaw, $200-1,000 per acre) and mechanical (mowing or chopping, 

$90 per acre; shredding, $300-350 per acre) treatment methods (Table 3-73). 

Riparian Treatments 

Riparian treatments would be relatively expensive on a per-acre basis, and would be completed using construction 

equipment and substantial levels of labor to complete stream channel reconstruction, rock placement for channel 

stabilization, and to install fencing to prevent access to treated sites by livestock, wild horses, and other wild 

ungulates. Based on stream restoration work done by NDOW, it could cost about $250,000 per mile for stream 
SOCIAL AND ECONOMIC VALUES AND ENVIRONMENTAL JUSTICE 

3 Bars Project Final EIS 3-496 October 2016 

channel restoration and plantings, and another $5,000 per mile for temporary fencing (Table 3-73; Lee 2013). Trees 

could be removed using chainsaws, and piled or used for stream restoration, at a cost of about $550, or shredded at a 

cost of about $300 to $350 per acre. If trees are piled and burned, this would add an additional $250 per acre. 

TABLE 3-73

Estimated Treatment Costs per Acre 

Treatment Method Estimated Cost per Acre1

Manual

Chainsaw and leave trees in place $2002

Chainsaw, pile trees, and burn $600 - $1,000 ($800)2

Pipe rail fencing $9.39 per lineal foot ($4,957 per mile) 2

Mechanical

Sagebrush mowing or chopping $902

Drill seeding $902

Shred trees and shrubs $300 - $350 ($325)2

Hand planting $6002

Fire

Prescribed fire $502

Pile burning $200- $3002

Biological

Insect, pathogen, and nematode $80 - $300 ($150)3

Livestock $152

1

 Value in parentheses is the average value use to calculate costs of treatment methods. 

2

 Source: Mount Lewis Field Office. 

3

 Source: 17- States PEIS and PER (USDOI BLM 2007b, c). Cost estimates from 2005. 

Adverse Effects 

Short-term adverse socioeconomic effects include additional management efforts for ranchers associated with grazing 

management and with the potential need to establish and maintain new water sources for livestock. 

Beneficial Effects 

Stream channel restoration and bioengineering treatments would improve riparian habitat and stream water quality. 

These effects could benefit livestock, wild horses, and other wild ungulates, to the benefit of ranchers and the public. 

Removal of pinyon-juniper near streams and within floodplains would help to reduce wildfire risk and associated 

wildfire suppression costs and the risk of loss of life and property. 

Aspen Treatments 

Adverse Effects 

Aspen treatments would be relatively expensive on a per acre basis, in part due to their small size, use of some 

mechanized equipment, substantial levels of labor, and the costs associated with the distribution of pinyon-juniper 

slash. It would cost about $200 per acre to use chainsaws to stimulate root suckering, and about $800 per acre to use 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-497 October 2016 

chainsaws to remove pinyon-juniper to slow encroachment and create fire breaks. Some of the slash from pinyonjuniper removal would be left in place to stimulate aspen root suckering and would lessen treatment costs compared to 

pile burning of trees. 

Short-term adverse socioeconomic effects include additional cost and effort for ranchers associated with grazing 

management due to the placement of small, temporary exclosure fencing, and/or changes in season of use. Short-term 

reductions in the authorized level of grazing, and thus the potential for adverse effects on production and income from 

livestock, would be a function of the size of each treated area and the aggregate total of such areas treated within a 

specific allotment. 

Beneficial Effects 

Short-term benefits would include seasonal employment opportunities with the BLM, contracting opportunities for 

local residents and contractors, and income potential for businesses that support construction for lodging, eating, and 

drinking establishments, and for specialized aerial application contractors. Removal of pinyon-juniper near roads 

associated with aspen stands would help to reduce wildfire risk and associated wildfire suppression costs and the risk 

of loss of life and property. 

Pinyon-juniper Treatments 

Adverse Effects 

Short-term adverse socioeconomic effects include cost and management effort for ranchers associated with grazing 

management in preparation for prescribed fires and mechanized treatments, changes in rest/rotation/seasons of use, 

and possibly the need for provisions to relocate or provide alternative livestock water. Short-term reductions in the 

authorized level of grazing, and thus the potential for adverse effects on production and income from livestock, would 

be a function of the size of individual treated areas, and the aggregate total of such areas treated within a specific 

allotment. 

Beneficial Effects 

Short-term benefits would include seasonal employment opportunities with the BLM, contracting opportunities for 

local residents and contractors, and income potential for businesses that support construction for lodging, eating, and 

drinking establishments. Economic benefits would occur to the local community from pinyon-juniper treatments. 

Additional economic benefit could come from the sale of pinyon-juniper trees with commercial market potential for 

fence posts and firewood. 

Sagebrush Treatments 

Adverse Effects 

Short-term adverse socioeconomic effects would include additional cost and effort for ranchers associated with 

grazing management in preparation for prescribed fires and mechanized treatments, installing small, temporary 

exclosure fencing, changes in rest/rotation/seasons of use, and possibly the need for provisions to relocate or provide 

alternative sources of water to livestock. Short-term reductions in the authorized level of grazing, and thus the 

potential for adverse effects on production and income from livestock, would be a function of the size of individual 

treatment areas, and the aggregate total of such areas treated within a specific allotment. 
SOCIAL AND ECONOMIC VALUES AND ENVIRONMENTAL JUSTICE 

3 Bars Project Final EIS 3-498 October 2016 

Beneficial Effects 

Short-term benefits would include seasonal employment opportunities with the BLM, contracting opportunities for 

local residents and contractors, and income potential for businesses that support construction for lodging, eating, and 

drinking establishments. Additional economic benefit could come from the sale of pinyon-juniper trees with 

commercial market potential for fence posts and firewood. 

3.25.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The cost per acre of treatment would be greater under Alternative B than under Alternative A. This reflects, in part, 

the higher expenditures associated with manual and mechanical treatments, which generally cost about 2 times or 

more per acre to implement than do fire treatments (Table 3-73).

Such outlays could increase the annual level of expenditures and the associated short-term employment and income 

and business revenue benefits associated with landscape restoration in the 3 Bars Project area. The level of financial 

and other resources devoted to implementation of actions under Alternative B would be minor relative to the overall 

economy in the 3 Bars Project area and surroundings. 

Grazing permittees would experience short-term reductions in income in conjunction with the proposed treatments, 

particularly the pinyon-juniper treatments, which could necessitate reductions in herd size, the need to purchase 

additional private pasture or feed, and increases in management efforts and costs. The actual reductions would vary 

over time in response to the actual acreages treated in any given year. The BLM could experience reductions in 

grazing fee receipts as a result of the temporary reductions in grazing use, although the effects on grazing fee receipts 

are unknown due to uncertainties regarding the magnitude in reductions in grazing due to restoration efforts and 

future decisions regarding the allocation of available forage to competing uses. 

Temporary and long-term social effects under Alternative B would be similar to those for Alternative A, although 

some individuals and stakeholder groups would be more or less satisfied by the preclusion of prescribed fire. 

3.25.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

The cost 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 (Table 3-73).

Due to the reduction in acres treated, the temporary reductions in grazing use associated with treatments would be 

lower, and the potential for other reductions due to declining rangeland health would persist. The actual reductions 

would vary over time in response to the actual acreages treated in any given year. The BLM would experience 

reductions in grazing fee receipts as a result of the temporary reductions in grazing use, although the effects on 

grazing fee receipts are unknown due to uncertainties regarding the magnitude in reductions in grazing due to 

restoration efforts and future decisions regarding the allocation of available forage to competing uses. 

Over the long-term, treatments would do little to slow the declines in rangeland health and promote a stabilization of 

future grazing levels and support for rural lifestyles. Treatments would do little to improve habitat for fish and 

wildlife, conditions of woodland stands to the benefit of pine nut production and other woodland products, and 

aesthetic qualities of the landscape for the recreational and commercial resource users. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-499 October 2016 

3.25.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects on social and economic values from 3 Bars Project treatments as no treatments 

would be authorized under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyonjuniper to promote healthy, diverse stands; slow the spread of noxious weeds and other invasive non-native 

vegetation, especially cheatgrass; restore fire as an integral part of the ecosystem; or reduce the risk of a large-scale 

wildfire that could be detrimental to public resources. Treatments to improve 3 Bars ecosystem health and increase or 

improve the amount and quality of commercial and casual uses of public lands, improve or maintain market and nonmarket values of public land resources, and reduce the cost of operations on public lands, would not occur under this 

alternative. 

3.25.3.4 Cumulative Effects 

The CESA for social and economic cumulative effects is the southern portion of Eureka County, from the BLM Elko 

District boundary to the Nye County line, and includes the town of Eureka (Figure 3-1). The area is approximately 

1,692,238 acres and approximately 86 percent of the area is administered by the BLM, 9 percent is administered by 

the Forest Service, and 5 percent is privately owned. Past and present actions that have influenced land use and access 

in the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.25.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Agriculture, land development, and mineral, oil, gas, and hydrothermal exploration and development could affect 

lands within the CESA in the reasonably foreseeable future, including land sales, new croplands, roads, and rights-ofway for power and telephone lines. These actions would provide economic benefits to the local community, but 

would also result in loss of fish and wildlife habitat, and possibly recreational opportunities. 

The Mount Hope Project would directly disturb approximately 8,300 acres over the long-term and another 6,000 acres 

would be fenced to exclude the public and livestock. The proposed mine project would have economic costs and 

benefits. Economic costs would include the loss of 32 AUMs in perpetuity due to construction of the mine pit. In 

addition, another 781 AUMs would be lost for approximately 70 years due to the mine project. The total economic 

cost from these reductions is estimated at $56,560 annually during the 70 year period ($69.57 multiplied by 813 

AUMs), and $2,226 in perpetuity thereafter, all other things remaining the same. More than 70,000 AUMs of 

livestock grazing are supported annually on public lands in the 3 Bars Project area and nearby areas of the CESA 

around the Mount Hope Project area. Consequently, the loss of grazing associated with the mine project would 

represent about 1 percent of the AUMS in the surrounding area and less than 1 percent of total grazing levels within 

Eureka County. In addition, there could be some impact to property values from the loss of AUMs, but this loss is 

difficult to quantify. While this impact may not be significant to the ranching community, the impact may be 

important to individual ranch operations. This loss of income was considered potentially significant in the Mount 

Hope Project EIS (USDOI BLM 2012b:3-421 to 3-422). In addition, there would be losses of AUMs associated with 

the 3 Bars Project, although annual losses would vary depending upon the amount of acreage treated, and where. 

These losses would occur at the same time as those for the Mount Hope Project, and would be a cumulative effect. 

Construction employment for the Mount Hope Project would peak at about 600 workers, with about 455 workers 

needed for mine operations. There would be a similar level of indirect employment as a result of the mine project. 

Thus, the number of workers within Eureka County could increase by 50 percent from current levels due to the mine 

project. Annual mine payroll is projected to be $33.4 million at full production, about half of which is projected to 
SOCIAL AND ECONOMIC VALUES AND ENVIRONMENTAL JUSTICE 

3 Bars Project Final EIS 3-500 October 2016 

accrue to Eureka County residents. The increase in income would be equal to about 28 percent of the income realized 

by local residents in 2008. Mining taxes over the life of the project are estimated at $384 million, while sales and use 

tax revenues would total about $63.9 million during construction through year 10 of operation. Additional 

information on mine-related revenues and costs, and their effects on housing, social conditions, and the affected 

public, is available in the Mount Hope Project EIS (USDOI BLM 2012b:Section 3.17). 

3 Bars Project treatments would have little impact on population growth, as most work would be done by local or 

outside contractors for short periods each year. The Mount Hope Project, however, would significantly impact the 

local population. The population of southern Eureka County is expected to increase by about 50 percent during the 

construction phase, and decrease slightly from this during mine operations (USDOI BLM 2012b:3-540 to 3-541). 

Public and private lands in the CESA are used for a variety of recreational uses. It is expected that recreation activity 

would reflect population growth in Eureka County over the life of the project. 

Since 1985, wildfires have burned about 7,000 acres annually in the 3 Bars Project Area CESA, at an estimated 

annual cost of $1,890,000, including costs for fire suppression and burned area rehabilitation (USDOI BLM 2007c:4-

131). Wildfires degrade fish and wildlife habitat, and may destroy human property, at substantial cost to recreation 

users and landowners. In addition, it is difficult to restore some burned lands, due to their remote location and uneven 

terrain, and noxious weeds and other invasive non-native vegetation often out-compete and displace native vegetation, 

to the long-term detriment of resources used by the public. Based on past acreage burned by wildfires, approximately 

140,000 acres would burn over the next 20 years in the CESA, at an estimated cost of $37.8 million for fire 

suppression and burned area rehabilitation costs. 

To reduce the risk of wildfire and improve 3 Bars ecosystem health, the BLM proposes to treat 127,000 acres under 

the 3 Bar Project, and about an additional 15,000 acres under current and reasonably foreseeable future authorizations 

within the CESA, including in high to very high wildfire risk areas within the CESA. These include treatments of 

noxious weeds and other invasive non-native vegetation on up to about 1,000 acres annually within the CESA. New 

infestations would typically be found in newly burned or disturbed areas, and in areas where livestock and wild horses 

congregate. Herbicide treatments generally cost about $50 per acre or less, so the economic benefits would be 

negligible. Treatments that remove hazardous fuels, including decadent and diseased pinyon-juniper and cheatgrass 

and other non-native vegetation, and construction of fire breaks, would be expected to reduce the risk of catastrophic 

wildfire and its associated costs on about 8 percent of the CESA. 

3 Bars Project and other BLM actions within the CESA would have little effect on the social and economic conditions 

within the CESA. The growth in economic activity and social trends, and stakeholder perceptions and concerns 

regarding various issues related to rangeland health, including grazing use, the allocation of forage for wildlife, wild 

horses, and grazing, would generally be greatest under Alternative A.

3.25.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

The effects from non-3 Bars Project reasonably foreseeable future actions on social and economic values would be 

similar to those described under Alternative A The social and economic benefits from actions under Alternative B 

would be limited in scale compared to those from the Mount Hope Project and other proposed infrastructure 

development projects and agricultural in the reasonably foreseeable future. 

The BLM would conduct treatments on approximately 63,000 acres on the 3 Bars Project area, and about another 

15,000 acres on other portions of the CESA, or collectively about 4 percent of the CESA, to reduce hazardous fuels 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-501 October 2016 

and improve fish and wildlife habitat. The types of risks and benefits to social and economic resources under 

Alternative B would be similar to those for Alternative A within the CESA. The economic costs and benefits to social 

and economic resources under Alternative B would be about one-half those for Alternative A within the CESA. 3 

Bars Project and other BLM actions within the CESA would have negligible effect on the social and economic 

conditions within the CESA. The growth in economic activity and social trends, and stakeholder perceptions and 

concerns regarding various issues related to rangeland health, including grazing use, the allocation of forage for 

wildlife, wild horses, and grazing, would generally be less under Alternative B than under Alternative A. 

3.25.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

The effects from non-3 Bars Project reasonably foreseeable future actions on social and economic values would be 

similar to those described under Alternative A. The types of risks and benefits to social and economic resources under 

Alternative C also would be similar to those for Alternative A within the CESA. 

The BLM would conduct treatments on approximately 32,000 acres on the 3 Bars Project area, and about another 

15,000 acres on other portions of the CESA, or collectively about 2 percent of the CESA, to reduce hazardous fuels 

and improve fish and wildlife habitat. The economic costs and benefits to social and economic resources under 

Alternative C would be about one-fourth those for Alternative A within the CESA. 3 Bars Project and other BLM 

actions within the CESA would have negligible effect on the social and economic conditions within the CESA. The 

growth in economic activity and social trends, and stakeholder perceptions and concerns regarding various issues 

related to rangeland health, including grazing use, the allocation of forage for wildlife, wild horses, and grazing, 

would generally be less under Alternative C than under Alternatives A and B. 

3.25.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on social and economic 

values would be similar to those described under Alternative A. There would be no cumulative effects on social and 

economic values and environmental justice from 3 Bars Project treatments as no treatments would be authorized 

under this alternative. The BLM could create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, 

diverse stands; slow the spread of noxious weeds and other invasive non-native vegetation using ground-based and 

aerial application methods of herbicides, especially cheatgrass; restore fire as an integral part of the ecosystem; and 

reduce the risk of a large-scale wildfire under current and reasonably foreseeable future authorized actions, but on a 

very limited acreage (about 1,500 acres annually). Thus, benefits to social and economic values and environmental 

justice would be negligible and least among the alternatives. 

3.25.3.5 Unavoidable Adverse Effects 

Implementation of the 3 Bars Project would result in short-term adverse effects on livestock grazing, outdoor 

recreation, and wildfire risk, which would have economic and social manifestations affecting individual ranchers 

and the local economy. The economic effects would include reductions in ranch income, higher management costs 

for ranchers, and adverse effects on local businesses and tax revenues. Adverse social effects could include 

changes in recreation experience (quality of life) and stress for individuals and households engaged in the ranching 

industry. Closures of treatment areas for extended periods of time could temporarily affect some recreational uses and 

commercial activities.
SOCIAL AND ECONOMIC VALUES AND ENVIRONMENTAL JUSTICE 

3 Bars Project Final EIS 3-502 October 2016 

3.25.3.6 Relationship between Local Short-term Uses and Long-term Productivity 

Restoration treatments would adversely affect use of treated areas over the short-term. Any restrictions on the use of 

treated lands could cause social and economic hardship to affected parties. However, individuals and industries 

involved in the restoration of native ecosystems on public lands would benefit. 

Over the long-term, most users of public lands, and those with interests near public lands, would likely benefit. An 

important goal of treatments is to restore ecosystem health so that public lands can provide sustainable and predictable 

products and services. In addition, treatments would reduce risks associated with large-scale wildfire, improve 

ecosystem health to the benefit of recreational and other public land users, and emphasize employment- and incomeproducing management activities near those communities most in need of economic support and stimulus. The 

enhancement in long-term productivity of public lands and in the ability of the land to provide for social and 

economic needs would reflect not only the success or failure of treatments, but also the influence of outside forces 

(e.g., economy, lifestyle changes, climate) over which the BLM and other federal agencies have no control (USDOI 

BLM 2007b:4-250). 

3.25.3.7 Irreversible and Irretrievable Commitment of Resources 

Implementation of the 3 Bars Landscape Project would require the commitment of natural, human, engineered, and 

monetary resources, as well as the resource commitment associated with subsequent changes to existing natural 

resources (e.g., existing pinyon-juniper stands). Once completed, most of the resource investments would be 

irretrievable and their use for this project would preclude or foreclose their use for other purposes. The latter 

characteristic serves to make these resource commitments largely irreversible from a social and economic 

perspective. However, because of the environmental restoration objectives associated with the landscape 

restoration initiative, the long-term environmental and potential social and economic effects of the resource 

commitments are viewed as positive. 

3.25.3.8 Significance of the Effects under the Alternatives 

Based on the criteria used to determine if social and economic values and environmental justice effects are 

significant, none of the alternatives would have significant direct, indirect, or cumulative effects. 

3.25.4 Mitigation 

No mitigation measures are proposed for social and economic values and environmental justice effects. 

3.26 Human Health and Safety 

3.26.1 Regulatory Framework 

3.26.1.1 Federal Laws 

The BLM must comply with laws and regulations that are protective of human health and safety. Numerous federal 

statutes, including the Clean Air Act, the Clean Water Act, the Safe Drinking Water Act, and the Resource 

Conservation and Recovery Act have been established to regulate actions that may directly pose human health risks 

through degradation of air and water quality and land pollution. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-503 October 2016 

Under the Clean Air Act, the USEPA sets limits on air pollution and certain air pollutants, including sulfur dioxide, 

nitrogen dioxide, carbon monoxide, ozone, lead, and particulate matter. An interim policy to address public health and 

welfare impacts caused by wildland and prescribed fires that are managed to achieve was adopted by the USEPA in 

May 1998. Visibility impairment and ambient air quality worse than the national ambient air quality standards for 

particulate matter are used as the principal indicators of public welfare impacts. The USEPA policy is interim until 

further recommendations from the U.S. Department of Agriculture’s Air Quality Task Force and final rules for 

implementing USEPA’s Regional Haze Program are adopted. 

The Clean Water Act regulates discharges of pollutants and sets water quality standards for all contaminants in 

surface waters of the U.S. The Safe Drinking Water Act was established to protect the quality of drinking water in the 

U.S., including all surface or underground waters sources that may potentially be designated for drinking use. 

The generation, transportation, treatment, storage, and disposal of hazardous waste is regulated by the Resource 

Conservation and Recovery Act, as administered by the USEPA. In the case of spills of hazardous materials, 

requirements for agency notification and clean-up procedures are regulated under the Comprehensive Environmental 

Response, Compensation, and Liability Act also administered by the USEPA. 

Under the Occupational Safety and Health Act (OSHA) of 1970, employers are responsible for providing a safe and 

healthful workplace. In addition to complying with all applicable OSHA standards, employers must also comply with 

the General Duty Clause of the OSHA, which requires employers to keep their workplace free of serious recognized 

hazards. 

3.26.1.2 Nevada Laws 

Nevada State regulations related to water and to air are outlined in Nevada Administrative Code and Nevada Revised 

Statutes 100-955 and 445B 100-445 B.845, respectively. 

The State of Nevada’s Division of Environmental Protection is authorized to implement air pollution control 

requirements in Eureka County. The State of Nevada’s standards for ambient air quality differ from the USEPA’s 

established National Ambient Air Quality Standards for criteria pollutions including the notable addition of standards 

for carbon monoxide at elevations at or greater than 5,000 feet amsl. In order to meet the USEPA’s interim air quality 

policy on wildland and prescribed burns, the Bureau of Air Quality Planning’s Mobile, Smoke and Area Sources 

Branch coordinates and facilitates the management of prescribed outdoor burning in Nevada.

Nevada’s laws regarding occupational diseases and occupational safety and health are set forth in Nevada 

Administrative Code and Nevada Revised Statutes § 617 and 618 respectively. 

3.26.2 Affected Environment 

3.26.2.1 Study Methods and Study Area 

Background information pertinent to human health issues for the 3 Bars Project area has been compiled from various 

public agencies and other data sources, including the State of Nevada Health Division, U.S. Census Bureau, U.S. 

Department of Labor, American Cancer Society, and the National Centers for Disease Control and Prevention, Injury 

Prevention and Control, and Health Statistics. Data on motor vehicle injuries and death was obtained from the U.S. 

Department of Transportation National Highway Traffic Safety Administration. 
HUMAN HEALTH AND SAFETY 

3 Bars Project Final EIS 3-504 October 2016 

Information about occupational health issues and risk was obtained from the State of Nevada and National Institute 

for Occupational Safety and Health Administration and the Bureau of Labor Statistics. Information pertinent to 

wildfires and associated health issues was obtained from the USEPA, the National Interagency Fire Center, the 

Western Greater Basin Coordination Center, the National Wildfire Coordinating Group, the U.S. Fire Administration, 

the Nevada BLM, and the State of Nevada Division of Environmental Protection Bureau of Air Quality Planning. 

The study area for direct, indirect, and cumulative human health and safety effects is the southern portion of Eureka 

County, from the BLM Elko District boundary to the Nye County line (Figure 3-1).

3.26.2.2 Health Risks 

The leading causes of deaths in Nevada and Eureka County are presented in Table 3-74. The most common causes of 

death in Nevada include heart disease, cancer, chronic lower respiratory disease, accidents, cerebrovascular diseases 

(strokes), and suicide. The four leading causes of death in Eureka County are heart disease, cancer, accidents, and 

respiratory disease. Strokes and intentional harm (suicide) are equally ranked as the fifth leading cause of death. 

Eureka County has higher than average mortality rates for heart disease and accidents and slightly higher than average 

incidences of suicide, compared to averages compiled for the entire state of Nevada. Eureka County has low to 

average mortality rates for cancer, respiratory, and cerebrovascular (stroke) diseases. 

TABLE 3-74 

Leading Causes of Death in Nevada and Eureka County, 2000 to 2008 

Cause of Death

Percent of Total Deaths

Eureka County Nevada

Heart Disease 40 25.7

Cancer 19 22.6

Chronic Lower Respiratory Disease 5 6.4

Accidents/Injuries 9 5.3

Cerebrovascular Disease (Stroke) 3 5.2

Intentional Harm (Suicide) 3 2.5

All other causes of death 21 32.3

Source: Nevada State Health Division (2011a). 

3.26.2.2.1 Risks from Diseases 

As the nation’s leading cause of death, heart disease results in approximately one in every four deaths (26 percent) in 

the U.S. Lifestyle and certain medical conditions, such as high cholesterol and blood pressure levels, diabetes, 

smoking, obesity, physical inactivity, poor nutrition, and alcohol use contribute to increased risk of heart disease. 

Heart disease is also the leading cause of death for both men and women in Eureka County. Forty percent of the total 

deaths in Eureka County between 2000 and 2007 were attributed to coronary heart disease, which is 1.5 times higher 

than the mortality rate for heart disease in Nevada and the U.S. 

Cancer is the second leading cause of death in the United States, Nevada, and Eureka County. According to the 

American Cancer Society, the probability of developing cancer during a person’s life is 1 in 2 for men and 1 in 3 for 

women. There are many causes of cancer development, including lifestyle conditions (smoking, obesity, and poor 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-505 October 2016 

nutrition), as well as occupational exposure to carcinogens, environmental contaminants, and substances in food. In 

the U.S., one-third of all cancers are attributed to tobacco smoking. Occupational exposures were previously 

estimated to account for approximately 4 percent of cancer deaths in the U.S. Further studies indicate that the burden 

of occupational cancer is actually higher, and some workers have a proportional increase in mortality before age 65, 

compared to those without occupational exposures. 

3.26.2.2.2 Risks from Injuries 

In Nevada, injury is a leading cause of death for children, teens, and young adults. For older adults, aged 45 years and 

greater, other medical conditions, such as heart disease and cancer, result in more deaths than injury (Nevada State 

Health Division 2011b).

Motor vehicle crashes are the leading cause of injury in Nevada, and account for more than 46 percent of all 

unintentional injury deaths in the state (Nevada Health Division 2005). More than 53 percent of reported trauma 

injuries in Nevada were attributed to motor vehicle, motorcycle, and pedal cycle crashes (Nevada State Health 

Division 2005). 

Unintentional falls are the second leading cause of injury in Nevada, and rank among the most serious injuries facing 

the elderly. Falls represented 12 percent of all reported trauma injuries in the Nevada from 2000 to 2002. Falls are the 

second leading cause of occupational injury-related fatalities, after transportation-related deaths (Chino et. al 2010). 

Other causes of injury include stabbings, assaults, and fights, pedestrian injuries (11 percent of reported injuries), 

gunshot wounds (7 percent), and all other injuries (7 percent; Nevada State Health Division 2005). Gunshot wounds 

account for the second highest number of unintentional injury deaths in the State. 

3.26.2.2.3 Motor Vehicle Mortality 

Motor vehicle crashes are the leading cause of death and injury for Nevadans aged 5 to 34 years. In 2006, 62,225 

motor vehicle crashes resulted in 32,669 injuries and 423 deaths. Most motor vehicle accidents occur during daylight 

hours in clear weather conditions. More males than females are injured in motor vehicle crashes, and in 2006, alcohol 

was involved in 10 percent of non-fatal and 30 percent of fatal motor vehicle crashes in 2006 (Chino et. al 2010). 

Rural communities are at a much higher risk for motor vehicle injury and death. Higher vehicle speeds, fewer traffic 

control devices, and/or longer distances to emergency medical care facilities may factor into the higher motor vehicle 

fatalities rates in rural areas. In Nevada, Eureka County has the second highest rate of motor vehicle fatalities, at 47.2 

per 100,000 people (age adjusted for the combined years 2000 through 2008; U.S. Department of Transportation 

2010a). This rate is more than triple the median rate of 17.1 for all U.S. counties, as estimated by the U.S. Department 

of Transportation National Highway Traffic Safety Administration. 

3.26.2.2.4 Occupational Fatalities and Injury 

An occupational fatality or injury is death or bodily damage, respectively, resulting from working. The fatality or 

injury may result from a single event (e.g., a fall from a building), or it may represent a physical injury which results 

from repeated use or exposure. 

In 2010, the highest number of fatal work injuries in the U.S. occurred in the transportation and material moving 

occupations (U.S. Department of Labor Bureau of Labor Statistics 2011a, b). However the highest reported fatal work 
HUMAN HEALTH AND SAFETY 

3 Bars Project Final EIS 3-506 October 2016 

injury rate (25.3 per 100,000 full-time equivalent workers) was for the farming, fishing, and forestry occupation 

groups. The transportation and construction industries had the second and third highest fatal work injury rates (14.2 

and 11.5, respectively).

During the period 2003 to 2008, there were 324 occupational injury-related deaths, primarily involving males, in 

Nevada (Chino et al. 2010). During this period, Nevada’s occupational injury fatality rate was 1.8 per 100,000 people, 

slightly higher that U.S. rate of 1.4 per 100,000 people. In 2010, Nevada’s non-fatal occupational injury and illness 

total recordable case incidence rate was 3.8 per 100 full-time workers in private industries and state and local 

governments, which was slightly higher than the national rate of 3.5 (U.S. Department of Labor Bureau of Labor 

Statistics 2011a, b). 

Forty-two percent of all occupational injury-related fatalities in Nevada result from transportation incidents. 

Construction and mining injuries involving falls represent 20 percent of all occupational fatalities. Contact with 

equipment is also common, while occupational injury fatalities resulting from violence and exposure to harmful 

substances or environments occur less frequently (Chino et. al 2010). Over 90 percent of non-fatal occupational cases 

are attributed to injuries. Five percent are attributed to illnesses associated with repetitive motion cases, systemic 

diseases and disorders, skin diseases, hearing loss, respiratory conditions, and poisoning (U.S. Department of Labor 

Bureau of Labor Statistics 2011 a, b). 

In 2010, the non-fatal occupational injury rate of 4.5 reported for the agricultural, forestry, fishing, and hunting 

industry was higher than the national rate of 3.5 per 100 workers. However the rate of non-fatal incidents resulting 

from crop and animal production and other support activities for agricultural and forestry was greater than the rate of 

those directly associated with natural resources and mining, forestry and logging. 

Within the BLM, the national injury rate (total accidents and illnesses) for 2009 to 2011 was 8.4 per 100 workers, 

which is the same as the injury rate for the Nevada BLM during the same period. Within the Battle Mountain District, 

the injury rate was lower, at 5.3. Lost time injury rates in the Battle Mountain District for 2009 to 2011 averaged 1.64, 

compared to 2.4 for the Nevada BLM and 2.1 for the BLM nationally (USDOI BLM 2012q).

From 2009 to 2011, the most common types of injuries in the BLM Battle Mountain District were falls, followed by 

slips/twists/trips and weather exposure. For the BLM statewide, the most common injuries were unclassified, 

slips/twists/trips, manual labor, and equipment (USDOI BLM 2012q). Hazards associated with poisonous plants and 

insects, dangerous wildlife, falling objects, including trees, protruding branches and twigs, and other obstacles on the 

ground that may cause slips and falls may be encountered by workers during BLM activities. Extreme and adverse 

weather conditions may lead to workers suffering heat-related illness or hypothermia. 

The operation of tools and equipment, such as chainsaws and mowers, may present inherent risks, such as exposure to 

hazardous fuels and lubricants used in the mechanized equipment, sharp tool edges, and loud noise that could result in 

hearing damage to workers. Nearby workers and the public can be struck by flying debris around some equipment. 

Equipment operators could also be injured from improperly operating or losing control of the machinery on steep or 

slippery terrain. Some injuries and fatalities have occurred during use of all-terrain vehicles. 

Injuries can vary from minor cuts, sprains, bruises, and abrasions to major arterial bleeding, compound bone fractures, 

serious brain concussions, and death. Manual and mechanical methods treatment methods also present potential 

ergonomic hazards related to lifting and carrying equipment, and when pulling vegetation. Improper body mechanics 

may lead to muscular-skeletal injuries. Some chronic disorders associated with repeated trauma are directly linked to 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-507 October 2016 

the nature of the work. For example, a large proportion of workers regularly using hand-held power tools, such as 

chippers, grinders, chainsaws and jackhammers, often suffer from the effects of vibration syndrome, which causes 

blanching and reduced sensitivity in the fingers. 

3.26.2.2.5 Risks from Fire 

Wildfires cause the loss of life and property. According to compiled data reported by the National Interagency 

Coordination Center, over 74,000 wildfires burned more than 8,700,000 acres in the U.S. in 2011 (National 

Interagency Coordination Center 2011). More than 86 percent of all reported fires in the nation were caused by 

humans. 

According to the U.S. Fire Administration, 81 U.S. firefighters died while on duty in 2010. Ten on-duty firefighters 

died in association with wildfires, the lowest number of annual firefighters associated with wildfires since 1996. Heart 

attacks were responsible for the deaths of 48 firefighters (59 percent) in 2011. Fifty-four percent of all firefighter 

fatalities occurred while performing emergency duties. Only three firefighters were killed in vehicle collisions. 

For the past decade, the leading cause of all USDOI/USDA wildland firefighter fatalities has been aviation accidents 

(50 percent; National Wildfire Coordinating Group 2010). Additional leading causes of wildland firefighter fatalities 

include burnovers/entrapments (20 percent), driving accidents (13 percent), heart attacks (7 percent), and hazard trees 

(6 percent). 

Smoke from wildfires is a mixture of gases that may cause irritation to the throat and eyes. Although the main 

components of smoke are water vapor and carbon dioxide, other pollutants and fine particulate matter are also present. 

Fine particulate matter is the primary human health concern for smoke management. Because of its small size (similar 

to a pollen grain), smoke can easily penetrate deep into lung tissues causing severe respiratory and cardiovascular 

disease. 

The average exposure to smoke and its most likely hazards, acrolein, benzene, carbon monoxide, formaldehyde and 

PM2.5, among 200 firefighters at prescribed burns in the Pacific Northwest, was studied by the USDA Forest Service, 

Pacific Northwest Research Station and Radian Corporation between 1991 and 19, and acrolien) and 2 percent of the 

carbon monoxide exposures exceeded permissible exposures limits set by the OSHA. Average exposures were 

highest during line holding, line supervision, and direct attack activities during the fire (Reinhardt et al. 2000). In most 

cases, the unexposed time spent traveling and setting up the prescribed burn reduced the overall work shift exposure 

to levels below the permissible exposure limits. Benzene exposure was found to not be significant. 

Persons with heart or lung disease may be more suspect to irritation from exposure to smoke. Particulate matter in 

smoke can also significantly reduce visibility on highways by scattering and absorbing light, thus compromising safe 

driving conditions. 

3.26.3 Environmental Consequences 

3.26.3.1 Key Issues of Concern Considered during Evaluation of the Environmental 

Consequences 

No issues of concern pertaining to human health and safety were identified during scoping, except for treatments 

using herbicides. The BLM does not propose to use herbicides under the alternatives. 
HUMAN HEALTH AND SAFETY 

3 Bars Project Final EIS 3-508 October 2016 

3.26.3.2 Significance Criteria 

The following would have a significant adverse effect on human health and safety: 

 Loss of life, or moderate to severe injuries which may require hospitalization. 

 Exposure of workers or the public to chemicals, contaminants, or smoke at levels that would cause adverse 

health effects. 

 Violation of any laws or regulations implemented to protect worker or public health and safety. 

3.26.3.3 Direct and Indirect Effects 

3.26.3.3.1 Direct and Indirect Effects Common to All Action Alternatives 

This analysis assumes that the SOPs, which have been designed expressly to protect worker and public health and 

safety, would be effective at preventing most accidents and injuries (see Appendix C). However, it is also assumed 

that some injuries could still occur, particularly if workers do not follow the SOPs closely. 

Under all alternatives, and for all treatment methods, workers conducting the treatments could be at risk for adverse 

effects from walking on uneven ground, on broken terrain, and in dense vegetation. Other potential adverse effects 

associated with the proposed treatments would vary by treatment method, as there are human health risks unique to 

each method. 

Treatments that remove noxious and poisonous weeds and other harmful vegetation near public use sites and facilities 

would benefit public health and welfare and would involve all treatment methods. Treatments that reduce the risk of 

catastrophic wildfire on public lands would have similar benefits to human health and safety. These benefits are 

discussed in the 17-States PER (USDOI BLM 2007c:4-139). Benefits would include reduced threats to public health 

and safety, as well as to air quality, firefighters, and property. 

3.26.3.3.2 Direct and Indirect Effects under Alternative A (Preferred Alternative) 

Riparian Treatments 

Adverse Effects 

Manual treatments utilized in riparian zones (installation of small, temporary exclosure fencing and plantings) should 

not adversely affect public health or physical well-being, as appropriate safety zones around work areas would 

prevent public access. The greatest risks to human health and safety from manual treatments would be to workers 

performing the treatments. These risks are discussed in the 17-States PER (USDOI BLM 2007c:4-137). Risks include 

exposure to plant irritants, biting and sucking insects, poisonous snakes, physical exertion, falls, use of hand tools, and 

noise and exhaust from motorized equipment. The SOPs designed to protect worker health and safety would minimize 

risks for severe injuries, as well as most minor injuries. Appropriate first aid treatment on site would also help to 

minimize the risk of infection or other long-term effects from minor injuries. Provided SOPs are followed, no laws or 

regulations implemented to protect worker or public health or safety would be violated, and the risk of injuries 

resulting in loss of life or hospitalization would be minimized. Nonetheless, it is possible that moderate to severe 

injuries could result from use of hand tools such as chainsaws. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-509 October 2016 

Similar to manual treatments, the greatest health and safety risks associated with mechanical treatments would be to 

workers performing the treatments, rather than to the public. The public would be at a slight risk of injury from flying 

debris, but these risks would be minimized by maintaining safety buffers around mechanical treatment areas. Risks to 

workers from mechanical treatments are discussed in the 17-States PER (USDOI BLM 2007c:4-137). These risks 

include injuries associated with use of heavy equipment, contact with sharp cutting blades, exposure to rocks and 

other flying debris, loss of control of equipment, high noise levels, and vehicle exhaust. Risks would be greatest for 

project groups with the most extensive mechanical treatment component, involving streambank earthworks and 

pinyon-juniper removal (Garden Spring Group and Frazier Creek Group). For the Denay Pond group, risks would be 

lower, since only fence installation would occur. For all mechanical treatments, risks would be minimized through the 

use of appropriate SOPs. 

Beneficial Effects 

Treatments would help reduce the risks to human health from wildfire smoke and fire. Additionally, treatments that 

improve the physical and ecological processes of creeks and that improve water quality in water bodies designated for 

beneficial uses (such as fisheries, irrigation, and drinking water) would be likely to benefit human health by providing 

cleaner water for drinking and for aquatic species that are consumed by the public.

Aspen Treatments 

Aspen treatments would consist of manual and mechanical methods and may include small, temporary 

exclosures/changes in livestock use. Risks associated with creating exclosures or changing livestock use would be 

minimal, provided SOPs were followed. The initial acreage of aspen identified for treatment is low (451 acres over 

the life of the project). Therefore, associated health and safety risks initially would be localized to very small areas in 

the Roberts Mountain, JD, 3 Bars, and Santa Fe allotments. 

Pinyon-juniper Treatments 

Adverse Effects 

The number of people potentially exposed to treatment projects could be relatively high for pinyon-juniper 

enhancement projects, given the size of treatments and the geographic area covered. Risks to workers and the public 

from treatments in these areas would be similar to those described for aspen enhancement projects. 

The potential effects associated with use of prescribed fire are discussed in the 17-States PER USDOI BLM (2007c:4-

135). Workers and the public would be at risk for fatality or injury as a result of the fire itself, from inhalation 

exposure from combustion products. Standard Operating Procedures would be implemented to protect workers and 

the public from fire-related injuries. Smoke inhalation could result in health risks, particularly for those exposed to 

smoke repeatedly over a long period, such as firefighters. Of greatest toxicological concern are polynuclear aromatic 

hydrocarbons, which contain multiple carcinogenic materials. A human health risk assessment was completed in 2007

(and also used for the 17-States PEIS and PER) estimated that cancer risks to workers and the public from 

polynuclear aromatic hydrocarbons found in wood smoke are very low (USDOI BLM 2007b:4-136). 

Recreational users near treatment sites could be exposed to smoke from prescribed fire. Advance notice to the public 

and posting treatment areas would warn recreational users about potential smoke related impacts so that they could 

avoid use of nearby recreation sites. 
HUMAN HEALTH AND SAFETY 

3 Bars Project Final EIS 3-510 October 2016 

Fires can affect public safety by reducing visibility and create hazardous driving conditions on nearby roads. The 

Sulphur Spring Wildfire Management Unit (62,000 acres) and the Whistler Unit (23,000 acres), in particular, are 

adjacent to State Route 278 and U.S. Highway 50, where the risks to motorists from reduced visibility would likely be 

greatest. Prescribed fires in the Whistler Unit would generally be 5 to 50 acres in size. Wildland fires managed for 

resource benefit in the Sulphur Spring Wildfire Management Unit would be 1,000 acres or less. When there are 

potential visibility issues on public roadways, the BLM utilizes traffic control measures and road signing, as 

appropriate, to reduce safety risks to motorists (USDOI BLM 2002). 

To limit air quality impacts and the associated potential human health effects from smoke inhalation, the BLM would 

implement site-specific fire prescriptions to minimize impacts to air quality. These prescriptions could include timing 

the fire to minimize smoke, procedures to limit the smoldering stage, and procedures to reduce fire intensity (USDOI 

BLM 2002). Most risks associated with prescribed fire would be offset by reductions in the incidence of wildfires, 

which would be expected to release more smoke and affect people over a larger geographic area than prescribed fires. 

Wildland fire for resource benefit would be used in addition to prescribed fire, which does not allow the same degree 

of pre-planning to reduce smoke impacts as prescribed fire. The BLM would measure air parameters and take 

appropriate action to reduce these emissions if these parameters are exceeded. Fires near roadways could affect 

human health and safety by reducing driving visibility and increasing the risk of an accident. 

Beneficial Effects 

Much of the focus of pinyon-juniper management is to reduce the risk of catastrophic wildfire. Creating and 

enhancing fuel breaks in pinyon-juniper stands associated with the Atlas Unit group would break up of the continuity 

of fuels, moderate fire behavior, and reduce the risk of loss of life and property from a catastrophic wildfire. On the 

Cottonwood/Meadow Canyon, Dry Canyon, Lower Pete Hanson, Three Bars Ranch, Tonkin North, and Whistler 

units, the focus of treatments would be on hazardous fuels reduction using manual and mechanical methods and 

prescribed fire. Much of the west slope of Roberts Mountains has not experienced a large-scale wildfire in over 100 

years. 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). The Three 

Bars Ranch is at the base of Roberts Mountains. 

Pathogens and pests, including mistletoe, have led to unhealthy pinyon-juniper stands in the Tonkin North and South 

units and a build-up of hazardous fuels. The BLM proposes to remove up to half of the trees using manual and 

mechanical means and prescribed fire. These projects would enhance the health and resilience of pinyon-juniper 

woodlands and reduce the amount of hazardous fuels and wildfire risk. 

The BLM would restore fire as an integral part of the ecosystem, improve species diversity, and reduce hazardous 

fuels on the Sulphur Spring Wildfire Management Unit by using wildland fire for resource benefit. The BLM would 

allow fire to burn on about 20 to 40 percent of the area. Several wildfires have occurred in this area in recent years 

due to dense fuel accumulations and pinyon-juniper cover. As discussed above, the Sulphur Spring Wildfire 

Management Unit is near State Route 278. 

Over the long-term, hazardous fuels reduction and other actions to reduce wildfire occurrence would lead to 

substantial benefits as far as reducing human exposure to smoke. Unplanned or unwanted fires, such as catastrophic 

wildfires, can pose serious threats to public health and safety, as well as to air quality. Because these fires are 

uncontrolled, they can pose significant threats to the safety of firefighters and the general public and destroy property. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-511 October 2016 

The intense or extended periods of smoke associated with uncontrolled wildfires can cause serious health problems 

and decrease visibility. Wildfires also cause the loss of life and property. 

Prescribed fires and fire use for resource benefit, on the other hand, are used to restore natural fire cycles, reduce the 

buildup of hazardous fuels, and restore native vegetation and natural ecosystem processes. Scheduling burning during 

favorable weather conditions and controlling the amount of fuel and acreage burned can minimize emissions and 

adverse effects of smoke on public health and the environment. As part of this effort to manage smoke and its health 

effects, the BLM would use alternative treatments to fire, including mechanical and manual treatments, and reduce 

fuel levels before burning. Mechanical thinning and biomass utilization are part of the suite of treatments the BLM 

would use in areas where fire presents an unacceptable risk (USDOI BLM 2007c:4-13). 

Sagebrush Treatments 

Adverse Effects 

Human health and safety risks associated with biological control would be minimal, and are discussed in the 17-States 

PER (USDOI BLM 2007c 4-138). They primarily include physical injuries to workers from livestock, and injuries 

associated with use of equipment to release biological control agents at treatment sites. Risks for these injuries would 

be reduced by following standard SOPs, such as wearing appropriate personal protective equipment and using 

equipment that is maintained properly. 

Prescribed fire would be used to control cheatgrass on the West Simpson Park Unit. The more predominant health and 

safety risk factors in sagebrush treatment unit would be to workers using mechanical equipment. 

Beneficial Effects 

Much of the focus of sagebrush treatments is to reduce the risk of catastrophic wildfire. Treatments to reseed and 

replant to promote sagebrush and perennial grass cover, and reduce the occurrence of cheatgrass and other noxious 

weeds and other invasive non-native vegetation on the Rocky Hills and West Simpson Park units, should reduce this 

risk.

3.26.3.3.3 Direct and Indirect Effects under Alternative B (No Fire Use Alternative) 

The human health and safety risks associated with exposure to smoke from prescribed fire would not be present under 

this alternative. The acreage of land treated using mechanical methods, and the associated level of risk to worker 

safety associated with this treatment method, would be similar to that under Alternative A. Risks to workers and the 

public would continue to be minimized through implementation of SOPs, which would prevent worker deaths or 

severe injuries. It is expected that the rate of accidents associated with manual and mechanical treatments would be 

similar to that under Alternative A. 

The effectiveness of treatments at reducing catastrophic wildfire potential would likely be less under Alternative B 

than under Alternative A. While mechanical treatments can be used to remove fuels, in some instances a combination 

of treatments (mechanical plus fire) might produce better results. Therefore, wildfire risk reduction and associated 

health and safety benefits would likely be less under this alternative than under Alternative A. 
HUMAN HEALTH AND SAFETY 

3 Bars Project Final EIS 3-512 October 2016 

3.26.3.3.4 Direct and Indirect Effects under Alternative C (Minimal Land Disturbance Alternative) 

Under this alternative, only manual and classical biological control methods would be used. Workers and the public 

would not be at risk for exposure to smoke, or for accidents associated with operation of heavy equipment. Risks 

associated with manual methods and classical biological control would be minimal, and SOPs for operation of handheld equipment would help prevent accidents associated with using this equipment. Out of all the action alternatives, 

short-term health and safety risks associated with project treatments would be lowest under Alternative C. However 

the long-term health and safety benefits associated with reducing catastrophic wildfire risk would be lower than under 

the other alternatives because the least amount of hazardous fuel removal would occur. 

3.26.3.3.5 Direct and Indirect Effects under Alternative D (No Action Alternative) 

There would be no direct effects on human health and safety from 3 Bars Project treatments as no treatments would 

be authorized under this alternative. The BLM would not create fire and fuel breaks; thin and remove pinyon-juniper 

to promote healthy, diverse stands; slow the spread of noxious weeds and other invasive non-native vegetation, 

especially cheatgrass; restore fire as an integral part of the ecosystem; or reduce the risk of a large-scale wildfire that 

could be detrimental to human health and safety. 

3.26.3.4 Cumulative Effects 

The study area for direct, indirect, and cumulative human health and safety effects is the southern portion of Eureka 

County, from the BLM Elko District boundary to the Nye County line (Figure 3-1). This area is approximately 

1,692,238 acres. Approximately 86 percent of the area is administered by the BLM, 9 percent is administered by the 

Forest Service, and 5 percent is privately owned. Past and present actions that have influenced land use and access in 

the 3 Bars ecosystem are discussed in Section 3.3.2.3.3.

3.26.3.4.1 Cumulative Effects under Alternative A (Preferred Alternative) 

Members of the public who visit or drive through the 3 Bars Project area may also visit or drive through areas shown 

on Figures 3-2 to 3-6, where other projects are occurring. Additionally, workers who implement the BLM’s 3 Bars 

treatment projects may live in the vicinity of other projects, may visit or drive through areas where other projects are 

occurring, or may be hired to implement other projects that have been identified. Therefore, it is likely that both 

workers and members of the public who would potentially be exposed to 3 Bars project treatments would also be 

exposed to human health and safety risks associated with other reasonably foreseeable future actions, resulting in 

cumulative health and safety risks. 

Grazing, agriculture, woodland product harvest activities, and recreation are associated with health and safety risks, 

including risks of injury from livestock; installing and maintaining range improvements; applying pesticides on 

cropland; using saws and other hand tools to harvest woodland products; exposure to poisonous vegetation or 

vegetation with thorns; exposure to harmful snakes and other wildlife; or accidents from recreation activities such as 

off-highway vehicle use. The safety of members of the public who harvest woodland products would be dependent on 

each individual’s personal responsibility for his or her own safety. Commercial harvest would follow the health and 

safety guidance of the responsible commercial entity, which should include policies and procedures for protecting 

human health and safety. 

Projects associated with utilities construction and distribution include road development, powerlines, communication 

sites, wind generation facilities, railroads, and related projects. All of these projects have associated occupational and 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-513 October 2016 

public health and safety risks during the construction phase, and some would have associated risks during the 

operational phase. It is assumed that industry standard SOPs and other procedures would be implemented to minimize 

health and safety risks. Road development is expected to be limited to dirt roads created by recreational use of public 

lands. However, traffic volumes on U.S. Highway 50 and State Route 58, as well as other roads are predicted to 

increase as a result of increased economic activity and population growth. New roads and increased traffic would 

increase the risk of injuries from motor vehicle crashes, which is the leading cause of death and injury for Nevadans 

aged 5 to 34 years (Chino et al. 2010), and is already very high in Eureka County (U.S. Department of Transportation 

2010a, b). 

Land development, mineral development, and oil, gas and geothermal leasing and development could all have 

associated health and safety risks. All types of development in the CESA are expected to bring more people into the 

area, which would increase the number of people potentially exposed to smoke from the proposed treatments. 

Additionally, there are numerous health and safety risks associated with resource extraction activities. Workers and 

the public could be exposed to these risks, in addition to the risks associated with the 3 Bars Project. It is expected that 

all of the future development and resource extraction in the region would involve industry standard safety protocols 

designed to minimize health and safety risks to workers and the public. 

Approximately 7,000 acres burn annually within the CESA, although acreage burned each year by wildfire is quite 

variable. Wildfires would lead to potential exposure to smoke by the public and firefighters, risk of accidents due to 

low visibility on roadways, and risk of loss of life and damage to property from the fire itself. 

The BLM would treat about 142,000 acres (127,000 on the 3 Bars Project area, and 15,000 on other areas within the 

CESA), or about 8 percent of the CESA, to restore natural fire regimes and encourage the growth of native vegetation 

that is more resilient to wildfire, reducing the risk of wildfire. This includes the use of herbicides on several hundred 

acres annually under existing authorizations. Human health concerns are associated with herbicide exposure 

scenarios, including direct spray, dermal contact with foliage, swimming, and ingestion scenarios for public exposure, 

and some occupational exposures that predominantly involve contact with accidental releases of herbicides. 

Herbicides that could be used by the BLM generally have negligible or minor risks to workers and the public, as 

discussed in the 17-States PEIS (USDOI BLM 2007b:4-174 to 4-196). In all cases, human health risks can be avoided 

by following SOPs including to apply herbicides with appropriate protective equipment, prevent spills and other 

accidental releases, and prevent public access to sprayed areas for the appropriate time interval. 

If plant community structure, species composition, and disturbance regimes return to near historical ranges, then 

disturbances should have effects that are similar to historical effects, which would be less severe, and result in less 

wildfire danger and risks to the public, than at present. 

3.26.3.4.2 Cumulative Effects under Alternative B (No Fire Use Alternative) 

The effects from non-3 Bars Project reasonably foreseeable future actions on human health and safety would be 

similar to those described under Alternative A. Because fire would not be used on the project area, risks associated 

with exposure to fire and smoke would not contribute to cumulative health effects. 

Hazardous fuels reduction and habitat improvement projects could occur on about 63,000 acres within the 3 Bars 

Project area, and on up to 15,000 acres within the CESA, or about 4 percent of acreage within the CESA. The BLM 

would be limited to hand pulling, discing, plowing, and using livestock to control non-native vegetation on the 3 Bars 

Project area, and using chainsaws and mechanical equipment, instead of prescribed fire and wildland fire for resource 
HUMAN HEALTH AND SAFETY 

3 Bars Project Final EIS 3-514 October 2016 

benefit, to manage pinyon-juniper. The cumulative risks to workers from these treatments could be greater from 

manual and mechanical methods than from fire treatments. Over the long-term, cumulative effects to health and safety 

associated with wildfire would be greater than under Alternative B than under Alternative A, since the acreage treated 

for fuels reduction would be less and treatments would likely not be as effective. 

3.26.3.4.3 Cumulative Effects under Alternative C (Minimal Land Disturbance Alternative) 

The effects from non-3 Bars Project reasonably foreseeable future actions on human health and safety would be 

similar to those described under Alternative A. Under Alternative C, the BLM would only be able to use manual and 

classical biological control methods to restore the 3 Bars ecosystem. Adverse, short-term effects to human health and 

safety with the use of fire and mechanized equipment would not occur under Alternative C. However, fire and 

mechanized equipment would be used in other portions of the CESA to improve habitat, remove hazardous fuels, and 

reduce the risk of wildfire. 

By not being able to use mechanical methods and fire to reduce hazardous fuels, restore ecosystem health, create fire 

and fuel breaks, and remove downed wood and slash, however, the risk of wildfire and its impacts on human health 

and safety would likely increase on the 3 Bars Project area. About 48,000 acres would be treated in the CESA to 

reduce hazardous fuels, but only 32,000 acres would be treated in the 3 Bars Project area. This would be less than 2 

percent of the land within the CESA and within the 3 Bars Project area. 

Under Alternative C, the acreage treated would be less than under Alternatives B and C, and only manual and 

classical biological treatment methods would be used. Therefore, short-term cumulative health and safety risks would 

likely be lowest under Alternative C. Over the long-term, cumulative effects to human health and safety associated 

with wildfire would be greater than under the other action alternatives, as the least amount of hazardous fuel removal 

would occur under Alternative C. 

3.26.3.4.4 Cumulative Effects under Alternative D (No Action Alternative) 

Under Alternative D, effects from non-3 Bars Project reasonably foreseeable future actions on human health and 

safety would be similar to those described under Alternative A. There would be no cumulative effects on human 

health and safety from 3 Bars Project treatments as no treatments would be authorized under this alternative. The 

BLM could create fire and fuel breaks; thin and remove pinyon-juniper to promote healthy, diverse stands; slow the 

spread of noxious weeds and other invasive non-native vegetation using ground-based and aerial application methods 

of herbicides, especially cheatgrass; restore fire as an integral part of the ecosystem; and reduce the risk of a largescale wildland fire under current and reasonably foreseeable future authorized actions, but on a very limited acreage 

(about 1,500 acres annually). Thus, benefits to human health and safety would be negligible and least among the 

alternatives. 

3.26.3.5 Unavoidable Adverse Effects 

All treatment methods have the potential to harm workers or the public. The health and safety of workers could be at 

risk from working on uneven ground, on broken terrain, and in dense vegetation; from the use of hand and power 

tools; from exposure to falling debris; from exposure to smoke from fires; and from other accidental situations. 

Although the BLM would implement numerous SOPs to minimize health and safety risks, not all injuries would be 

avoided. 
AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 

3 Bars Project Final EIS 3-515 October 2016 

Members of the public could be at risk from flying debris if they were near an area where manual or mechanical 

equipment was being used. Risks would be minimized by establishment of safe zones around work areas, provided 

the public complied with restrictions on entry into these areas. Particulate matter and other harmful materials 

associated with fire treatments could harm the public outside of treatment areas. However, it is expected that these 

exposures would be kept to minimum levels by following fire prescriptions, and conducting treatments during 

climatic conditions that minimize drift of smoke. 

3.26.3.6 Relationship between the Local Short-term Uses and Maintenance and 

Enhancement of Long-term Productivity 

The proposed vegetation treatments could harm the health of workers and the public over the short-term, particularly 

if SOPs to protect health were not followed. Adverse reactions to smoke could cause minor to severe discomfort to 

sensitive individuals, but most symptoms would go away in a few hours. If serious injury or death resulted from 

treatments, the effects on the health of the affected individual would be long-term, or in the case of death, permanent. 

Proposed treatments to reduce the buildup of hazardous fuels and restore native vegetation would help restore natural 

fire regimes and improve ecosystem health. If treatments are successful, there would be a long-term reduction in the 

risk of wildfire, which would benefit public health by resulting in a reduced exposure to smoke and a reduced risk of 

adverse human health effects from fires. 

3.26.3.7 Irreversible and Irretrievable Commitment of Resources 

Serious injury or death caused by vegetation treatments could be irreversible and irretrievable. However, risk of death 

and serious injury is very unlikely based on the current rate of injury (very low) and death (none) associated with 

BLM vegetation treatments during the past decade. It is likely that a few people would experience minor discomfort 

from fire treatments, but these effects would be short-term and reversible. 

3.26.3.8 Significance of the Effects under the Alternatives 

The BLM’s SOPs to protect worker and public safety substantially reduce the risks for accidents and injuries during 

vegetation treatments. Many employers, especially those involved with agricultural and mining operations, have 

health and safety plans to protect worker health. However, there is some risk for injury and adverse health impacts 

associated with all working conditions, such as those associated with operation of chainsaws and heavy equipment, 

working on uneven terrain, and managing fires. Accidents would be possible. If workers do not follow SOPs closely, 

severe injuries could occur. While SOPs provide the maximum amount of realistic prevention of injury, it is not 

possible to state that death or moderate to severe injury would not occur. Exposure of workers to chemicals, 

contaminants, and smoke is possible, but the health effects of these exposures should be limited to insignificant levels 

through SOPs to limit exposure, use of Personal Protective Equipment, and establishing safety buffers around 

treatment sites. Standard Operating Procedures also would ensure that the BLM’s treatment program did not violate 

any laws or regulations implemented to protect worker or public health and safety. Based on the BLM’s past safety 

record for vegetation treatments, there has been a very low rate of injury and no deaths associated with vegetation 

treatment programs. Therefore, direct, indirect, and cumulative effects to human health and safety from 3 Bars Project 

actions are unlikely to be significant. 
HUMAN HEALTH AND SAFETY 

3 Bars Project Final EIS 3-516 October 2016 

3.26.4 Mitigation 

Given that BLM SOPs for the various treatment methods are already highly protective of public and worker health 

and safety, no additional mitigation is recommended.