APPENDICES
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Jarbidge Proposed RMP/Final EIS Appendices: Table of Contents

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Appendices 

Table of Contents

Appendix A: Specific Mandates and Authorities A-1

Appendix B: Best Management Practices, Design Features, and Operating Procedures A-5

Appendix C: Jarbidge RMP Mailing List A-77

Appendix D: Aquatic and Riparian Management Strategy A-85

Appendix E: Conservation Measures A-129

Appendix F: Drought Management Guidelines A-191

Appendix G: Cultural Resource Use Categories A-193

Appendix H: Recreation Management Areas A-201

Appendix I: Lands Available for Disposal A-221

Appendix J: Livestock Grazing Allotments A-233

Appendix K: Reasonably Foreseeable Development Scenario for Oil and Gas Development A-241

Appendix L: Reasonably Foreseeable Development Scenario for Geothermal Development A-249

Appendix M: Evaluation of Nominated Areas of Critical Environmental Concern A-261

Appendix N: Wild and Scenic River Eligibility Determination A-345

Appendix O: Upland and Riparian Area Reference Areas A-387

Appendix P: Response to Comments from the Draft RMP/EIS A-395
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Jarbidge Proposed RMP/Final EIS Appendix A: Specific Mandates and Authorities

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APPENDIX A: SPECIFIC MANDATES AND AUTHORITIES

The development of the revised Jarbidge Resource Management Plan (RMP) followed all applicable 

laws, regulations, and policies, including, but not limited to, those listed in Table A-1. For more detail on 

what is required by these documents, please refer to the original document.

Table A-1. Specific Mandates and Authorities

Document Name

Laws

General Mining Law of 1872, as amended (30 United States Code [U.S.C.] 21)

Antiquities Act of 1906 (16 U.S.C. 431-433)

Migratory Bird Treaty Act of 1918 (16 U.S.C. 703 et seq.)

Mineral Leasing Act of 1920, as amended (30 U.S.C. 181)

Taylor Grazing Act of 1934, as amended (43 U.S.C. 315)

Soil Conservation and Domestic Allotment Act of 1935 (16 U.S.C. 590)

Food, Drug, and Cosmetic Act of 1938 and the Miller Amendment to the Act (21 U.S.C. 301 et seq.)

Federal Insecticide, Fungicide, and Rodenticide Act of 1947, as amended (7 U.S.C. 136 et seq.)

Appropriations Act of 1952, McCarran Amendment (43 U.S.C. 666)

Recreation and Public Purposes Act of 1954 (68 Statute 173; 43 U.S.C. 869 et. seq.; a complete 

revision of the Recreation Act of 1926 [44 Statute 741]) 

Watershed Protection and Flood Prevention Act of 1954, as amended (16 U.S.C. 1001 et seq.)

Sikes Act of 1960, as amended (16 U.S.C. 670 et seq.)

Water Resources Planning Act of 1962 (42 U.S.C. 1962 et seq.)

Classification and Multiple Use Act of 1964 (43 U.S.C. 1411-18)

Land and Water Conservation Fund Act of 1964, as amended (16 U.S.C. 460 et seq.)

Wilderness Act of 1964 (16 U.S.C. 1131 et seq.)

Fish and Wildlife Coordination Act of 1965 (16 U.S.C. 661 et seq.)

National Historic Preservation Act of 1966, as amended, (16 U.S.C. 470

National Trails System Act of 1968 (16 U.S.C. 1241-1251)

Wild and Scenic Rivers Act of 1968, as amended (16 U.S.C. 1271 et seq.)

National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.)

Mining and Mineral Policy Act of 1970, as amended (30 U.S.C. 21)

Clean Air Act of 1970, as amended (42 U.S.C. 7401 et seq.)

Control of Pollution from Federal Facilities Act of 1970 (33 U.S.C. 1323)

Horse Protection Act of 1970 (15 U.S.C. 1821 et seq.)

Wild and Free-Roaming Horses and Burros Act of 1971 (16 U.S.C. 1331 et seq.) 

Federal Environmental Pesticide Control Act of 1972 (7 U.S.C. 136 et seq.)

Endangered Species Act of 1973 (16 U.S.C. 1531 et. seq.)

Archaeological and Historic Preservation Act of 1974 (16 U.S.C. 469)

Federal Noxious Weed Act of 1975 (7 U.S.C. 2801 et seq.)

Federal Land Policy and Management Act of 1976, as amended (43 U.S.C. 1701 et seq.)

Surface Mining Control and Reclamation Act of 1977 (30 U.S.C. 1201)

Clean Water Act of 1977, as amended (30 U.S.C. 1251)

Safe Drinking Water Act Amendments of 1977 (42 U.S.C. 201)

Soil and Water Resources Conservation Act of 1977 (16 U.S.C. 2001)

American Indian Religious Freedom Act of 1978 (42 U.S.C. 1996)

Public Rangelands Improvement Act of 1978 (43 U.S.C. 1901 et seq.)

Migratory Bird Conservation Act of 1979, as amended (16 U.S.C. 715)

Archaeological Resources Protection Act of 1979, as amended (16 U.S.C. 470 et seq.)

Emergency Wetland Resources Act of 1986 (16 U.S.C. 3901)

Federal Cave Resources Protection Act of 1988 (16 U.S.C. 4301 et seq.)

Native American Graves Protection and Repatriation Act of 1990 (25 U.S.C. 301) 
Appendix A: Specific Mandates and Authorities Jarbidge Proposed RMP/Final EIS

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Document Name

Laws

Pollution Prevention Act of 1990 (42 U.S.C. 13101 et seq.)

Energy Policy and Conservation Act Reauthorization of 2000, as amended (PL 106-469)

Energy Policy Act of 2005 (PL 109-58)

Wild Horse and Burro Sale-Authority, within Consolidated Appropriations Act of 2005 (PL 108-447, Sec 

142)

Omnibus Public Lands Management Act of 2009 (PL 111-11)

Executive Orders and Memoranda

Executive Order of April 17, 1926—Public Water Reserve No. 107

Executive Order 11514—Protection and Enhancement of Environmental Quality, March 5, 1970 (35 FR 

4247)

Executive Order 11593—Protection and Enhancement of the Cultural Environment, May 13, 1971 (36 

FR 8921)

Executive Order 11644—Use of Off-Road Vehicles on Public Lands, February 8, 1972 (37 FR 2877), as 

amended by Executive Order 11989

Executive Order 11738—Providing for administration of the Clean Air Act and the Federal Water 

Pollution Control Act with respect to Federal contracts, grants or loans, September 10, 1973 (38 FR 

25161)

Executive Order 11752—Prevention, control, and abatement of environmental pollution at Federal 

facilities, December 17, 1973 (38 FR 34793)

Executive Order 11987—Exotic Organisms, May 24, 1977 (42 FR 26949)

Executive Order 11988—Floodplain Management, May 24, 1977 (42 FR 26951), as amended by 

Executive Order 12148

Executive Order 11990—Protection of Wetlands, May 25, 1977 (42 FR 26961)

Executive Order 12088—Federal Compliance with Pollution Control Standards, October 17, 1978 (43 

FR 47707)

Executive Order 12372—Intergovernmental Review of Federal Programs, July 14, 1982 (47 FR 30959)

Executive Order 12898—Federal actions to address environmental justice in minority populations and 

low-income populations, February 11, 1994 (59 FR 7629)

Executive Order 12962—Recreational Fisheries, June 7, 1995 (60 FR 30769), as amended by 

Executive Order 13474, September 28, 2008 (73 FR 57229) 

Executive Order 13007—Indian Sacred Sites, May 24 1996 (61 FR 104)

Executive Order 13084—Consultation and Coordination with Indian Tribal Governments, May 14, 1998 

(63 FR 27655)

Executive Order 13112—Invasive Species, February 3, 1999 (64 FR 6183)

Executive Order 13186—Responsibilities of Federal Agencies To Protect Migratory Birds, January 10, 

2001 (66 FR 3853) 

Executive Order 13287—Preserve America, March 5, 2003 (68 FR 43)

Executive Order 13443—Facilitation of Hunting Heritage and Wildlife Conservation (72 FR 46537) 

Executive Memorandum—Government-to-Government Relations with Native American Tribal 

Governments, April 29, 1994

Regulations

36 CFR---Parks, Forests, and Public Property

40 CFR—Protection of Environment

43 CFR—Public Lands: Interior 

50 CFR—Wildlife and Fisheries

Departmental Guidance

Secretarial Order 3206—American Indian Tribal Rights, Federal Tribal Trust Responsibilities, and the 

Endangered Species Act

Secretarial Order 3226A1—Climate Change and the Department of the Interior

Secretarial Order 3285A1—Renewable Energy Development by the Department of the Interior
Jarbidge Proposed RMP/Final EIS Appendix A: Specific Mandates and Authorities

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Document Name

Departmental Guidance

Secretarial Order 3289A1—Addressing the Impacts of Climate Change on America's Water, Land, and 

Other Natural and Cultural Resources

Secretarial Order 3305—Ensuring Scientific Integrity within the Department of the Interior

Secretarial Order 3310—Protecting Wilderness Characteristics on Lands Managed by the Bureau of 

Land Management

Secretarial Order 3317A1—Department of the Interior Policy on Consultation with Indian Tribes

BLM Manuals

1601—Land Use Planning

1613—Areas of Critical Environmental Concern

1626—Travel and Transportation

1703—Hazardous Management and Resource Restoration

1734—Rangeland Interagency Ecological Site Manual

1740—Renewable Resource Improvements and Treatments

2200—Land Exchanges

2881—Mineral Leasing Act-General 

2930—Recreation Permits and Fees

3800—Mining Claims under the General Mining Laws

4180—Land Health

4700—Wild Free-Roaming Horse and Burro Management

6250—National Scenic and Historic Trail Administration

6280—Management of National Scenic and Historic Trails and Trails Under Study or Recommended as 

Suitable for Congressional Designation

6310—Conducting Wilderness Characteristics Inventory on BLM Lands

6320—Considering Lands with Wilderness Characteristics in the BLM Land Use Planning Process

6330—Management of Wilderness Study Areas

6340—Management of Designated Wilderness Areas

6400—Wild and Scenic Rivers – Policy and Program Direction for Identification, Evaluation, Planning, 

and Management

6840—Special Status Species Management

7100—Soil Resource Management

7200—Water Resources

7300—Air Resource Management Program

8100—The Foundations for Managing Cultural Resources

8110—Identifying and Evaluating Cultural Resource Authorities

8120—Tribal Consultation under Cultural Resources

8130—Planning for Uses of Cultural Resources

8140—Protecting Cultural Resources

8150—Permitting Uses of Cultural Resources

8170—Interpreting Cultural Resources for the Public

8270—Paleontological Resource Management

8320—Planning for Recreation and Visitor Services

8330—Policy on Reasonable Accommodations for Persons with Disabilities

8353—Trail Management Areas – Secretarially Designated National Recreation, Water, and Connecting 

and Side Trails

8380—Cave and Karst Resources Management

8400—Visual Resource Management

9113—Roads

9115—Primitive Roads

9210—Fire Management

9211—Fire Planning Manual
Appendix A: Specific Mandates and Authorities Jarbidge Proposed RMP/Final EIS

A-4 

Document Name

BLM Handbooks

H-1601-1—Land Use Planning Handbook

H-1740-2—Integrated Vegetation Management

H-1742-1—Emergency Fire Rehabilitation Handbook

H-1790-1—National Environmental Policy Act Handbook

H-2200-1—Land Exchange Handbook

H-3070-1—Economic Evaluation of Coal Properties

H-3070-2—Economic Evaluation of Oil and Gas Properties

H-3600-1—Mineral Materials Disposal Handbook

H-3809-1—Surface Management

H-4180-1—Rangeland Health Standards

H-4700-1—Wild Horses and Burros Management

H-8120-1—General Procedural Guidance for Native American Consultation

H-8342—Travel and Transportation Handbook

H-8410-1—Visual Resource Inventory Handbook

H-9211-1—Fire Planning Handbook
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

Design Features, and Operating Procedures

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APPENDIX B: BEST MANAGEMENT PRACTICES, DESIGN 

FEATURES, AND OPERATING PROCEDURES

This appendix provides a listing of best management practices (BMPs), design features, and operating 

procedures that, when applied with management actions described in Chapter 2, would aid in achieving 

goals and objectives. These BMPs, design features, and operating procedures are tools to reduce 

adverse social, economic, and environmental effects. Additional practices may be added or included in 

this list as they are developed and determined to reduce unwanted impacts from management activities. 

Likewise, practices included in this list that do not achieve the desired results may be altered or removed 

from consideration. These BMPs, design features, and operating procedures were from many sources 

and could be applied alone or in combination as necessary to make progress towards or to achieve 

objectives.

While the overall vision embraces the use of these BMPs, design features, and operating procedures to 

reduce or minimize impacts, they are not to be considered a land use plan decision. They are dynamic 

and may be updated or modified based on future guidance, policy, and science without a plan 

amendment. BMPs, design features, and operating procedures used in site-specific situations would be 

incorporated into the proposed action or used as mitigation measures to reduce impacts. The 

determination of which BMPs, design features, and operating procedures to apply will be made during 

individual project planning. The use of BMPs, design features, or operating procedures will be analyzed 

through the NEPA process for site-specific projects. 

The BMPs, design features, and operating procedures are categorized by resource use or activity. 

Because BMPs, design features, or operating procedures from programmatic Records of Decision are 

included, some are listed more than once. New information could result in BMPs being modified or added 

to reduce or mitigate impacts.

Vegetation Treatments

The economic effects of alternative fuels management practices would be considered. 

Collaborate with local partners to assess wildland urban interface areas and to develop or update 

County Wildfire Protection Plans. 

Incorporate cultural protection practices in treatments using prescribed fire. Practices may include but 

are not limited to: 

Reducing fuels manually on vulnerable sites or features.

Disposing of debris away from cultural features.

Using low-intensity backing fire in areas near historic features.

Saturating ground or grass adjacent to vulnerable structures with water, foam, or gel before 

burning.

Pre-burning site(s) at lower intensity than planned for the surrounding areas.

Limiting fire intensity and duration over vulnerable sites.

Using a fast-moving, higher intensity fire over lithic scatters, where rock materials are vulnerable 

to longer-duration heating.

Creating fire breaks near or around sites.

Wrapping structures in fire-proof materials or using retardant or foam to protect structures.

Covering rock art or wrapping carved trees or other such features in fire retardant fabric.

Reducing fuels and smoke near rock art.

o Covering fuels near rock art with foam, water, or retardant, avoiding the rock art.

Hazardous materials and abandoned mine sites identified in any specific fuels management or 

vegetation treatment area should be avoided.

The use of hazardous substances (e.g., gasoline in riparian zones, explosives) for prescribed fire 

control should be avoided whenever practical.

Treatments should be designed to minimize impacts to the character of the managed recreation 

setting in Special Recreation Management Areas and Extensive Recreation Management Areas and 

to the recreation experiences and benefits desired by the recreation participant. 
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Wherever possible, vegetation treatments in Visual Resource Management Class I and II areas would 

replicate the natural line, form, color, and texture found in the surrounding area. Treatments that 

result in long-term disruption of natural visual qualities (e.g., drill seeding that establishes vegetation 

rows) should not be used unless the visual impacts can be hidden through treatment design.

Water Quality

The best management practices in this section expand and supplement the basic guidelines and 

minimum requirements of the Idaho Department of Lands (Forest Practices Regulations), Idaho 

Department of Water Resources Stream Channel Alteration Regulations, and the Corps of Engineers 404 

Regulations. 

Transportation and Travel

Road Planning – Design and Location

Plan each road to the minimum standards for the intended use.

Plan to dispose of excavated waste material on geologically stable sites and away from Riparian 

Conservation Areas (RCAs). 

Design full-bench roads for slopes over 60 percent. End-haul excess material to a geologically stable 

site for disposal and away from RCAs. Use balanced cut-and-fill road construction where practical.

Design stream channel crossings as near to a right angle with the stream as possible to minimize 

disturbance to banks and existing channels.

For road segments that parallel stream courses, consider the need for stream shade along with safety 

considerations during brushing operations. This may necessitate hand brushing, partial brushing, or 

limbing, with consideration for providing growth for future shade for the RCA.

Road Construction

For any repair work in fish-bearing streams, instream work will be timed to avoid disturbance of 

staging adult fish, redds, or gravels with un-emerged juveniles where possible. Timing restrictions 

may be waived in cases of overriding safety concerns or the threat of severe resource damage.

Fuel storage and fueling of equipment will not occur within RCAs. 

Before working in a stream channel or in a RCA, all heavy equipment or other machinery will be 

inspected for hydraulic or other leaks. Fix identified problems before entering areas that could affect 

water quality. Clean equipment with accumulations of oil, grease, or other toxic materials prior to use 

in these areas. An emergency spill containment kit will be located on site during construction activity.

Clear drainage ways of all debris generated during construction or maintenance that may interfere 

with drainage or affect water quality.

When constructing roads near RCAs, use hay bales, silt fences or other sediment filtering materials to 

minimize sediment reaching the RCA. Minimize the amount of woody debris buried in embankments 

and minimize the amount of snow, ice, and frozen soil added to embankments.

Construct stream culverts, cross drains, or relief culverts to prevent erosion. Use riprap, woody 

debris, downspouts, or similar devices to prevent erosion of fills. Culverts in natural drainage ways 

would be oriented to minimize fill slope erosion or to carry water beyond fills. 

Bridges

Use an adequately long bridge span to avoid constricting the natural active flow channel and 

minimize constriction of any overflow channel.

Avoid placing abutments in the active stream channel to the extent practicable.

Place foundations onto nonscour-susceptible material (e.g., bedrock or coarse rock material) or below 

the expected maximum depth of scour.

Set bridge abutments or footings into firm natural ground (e.g., not fill material or loose soil) when 

placed on natural slopes.
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

Design Features, and Operating Procedures

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Low-Water Crossings

Locate low-water crossings where streambanks are low with gentle slopes and channels are not 

deeply incised.

Select and design low-water crossing structures to maintain the function and bedload movement of 

the natural stream channel.

Construct the low-water crossing to conform to the site, channel shape, and original streambed 

elevation and to minimize flow restriction, site disturbance, and channel blockage to the extent 

practicable.

Use suitable measures to stabilize or harden the streambed and approaches, including the entire 

bankfull width and sufficient clearance, where necessary to support the vehicle traffic design. 

Construct the driving surface with material suitable to resist expected shear stress or lateral forces of 

water flow at the site.

Road Drainage

For insloped roads, generally design ditch gradients to be between two and eight percent to prevent 

sediment deposition and ditch erosion. The higher gradients may be suitable for more stable soils; 

use the lower gradients for less stable soils.

Construct drain dips deep enough into the subgrade so that traffic will not obliterate them. Dips 

should be angled 20 to 45 degrees perpendicular to the road and have a drainage grade of 2% to 8%. 

Where possible, install relief culverts at the gradient of the original ground slope; otherwise armor 

outlets with rock or anchor downspouts to carry water across the fill slope.

Skew relief culverts 20 to 30 degrees toward the inflow from the ditch to improve inlet efficiency. 

Develop the catch basin at sufficient size to prevent the culvert inlet from plugging. 

Construct at or near natural elevation of the streambed to avoid or minimize potential flooding 

upstream of the crossing and erosion below the outlet.

Install culverts long enough to extend beyond the toe of the fill slopes to minimize erosion.

Use suitable measures to avoid or minimize water from seeping around the culvert.

Road Maintenance

Maintain erosion control features through periodic inspection and maintenance, including cleaning 

dips and cross-drains, repairing ditches, marking culvert inlets to aid in location, and clearing debris 

from catch basins and culverts.

Avoid using roads during wet periods if such use would damage the road drainage features.

Apply dust abatement or other surface stabilizing chemicals to prevent entry into streams. Do not 

place dust abatement chemicals in road ditches, and apply at rates which do not pooling of 

abatement chemicalson the road surface.

When removing down logs in the road which extend into a stream, any woody material on the fill 

slope and in the stream will not be removed to provide for woody debris recruitment, except in cases 

where the retention of this material would result in a safety concern (i.e., downstream facilities).

Grade road surfaces only as often as necessary to maintain a stable running surface and to retain the 

original surface drainage.

Avoid cutting the toe of cut slopes when grading roads or pulling ditches.

Avoid sidecasting material where these materials may be introduced into a stream, or where the 

placement of these materials will contribute to destabilization of the slope.

Snow Removal

Snow will not be completely removed. In general, a minimum two inches of snow must be left on the 

roadway during plowing operations to protect the surface of the road.

Prevent plugging ditches and culverts during snow plowing operations.

Sidecast material will not include dirt and gravel. 

Snow berms will not be left on the road or shoulder unless drainage holes are opened and 

maintained. Drainage holes will be spaced as required to obtain satisfactory surface drainage without 

discharge on erodible fills. 
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Damage from, or as a result of snow removal, will be restored in a timely manner.

Resources and Resource Uses

Livestock Grazing

Collect no more water than is sufficient to meet the intended purpose of the spring development.

Equip the spring box with a shut off valve to return water to the spring when not in use.

Ensure that enough water remains in the spring to support the source groundwater, dependent 

ecosystem, and downstream aquatic ecosystems.

Recreation Management

Educate the public to conduct their activities in ways that will not degrade water quality. Avoid 

discharges and disposal of human and animal waste, petroleum products, and other hazardous 

substances in or near RCAs in recreation areas. 

Provide primitive sanitation facilities in areas where perpetual concentrated dispersed recreation use 

is causing adverse effects to soil, water quality, or riparian resources.

Design, construct, and maintain trail width, grades, curves, and switchbacks suitable to the terrain 

and designated use.

Design stream crossings to use the most cost-efficient structure consistent with resource protection, 

facility needs, and types of use and safety obligations.

Develop and designate campsites in appropriate locations where repeated use is causing adverse 

effects.

Design and locate parking and staging areas of appropriate size and configuration to accommodate 

expected vehicles and avoid or minimize adverse effects to adjacent soil, water quality, and riparian 

resources. Use suitable measures to harden and avoid or minimize damage to parking area surfaces 

that experience heavy use or are used during wet periods.

Locate and design watercraft launch sites to avoid, minimize, or mitigate adverse effects to soil, water 

quality, and riparian resources.

Fire Management

Conduct water drafting at locations and in a manner that avoids or minimizes adverse effects to water 

quality.

Avoid mixing chemicals (retardant, foam, etc.) in wetlands and riparian zones.

Avoid refueling in wetlands and riparian zones. If refueling a pump drafting from a water source use 

measures to minimize and contain spills.

During fire suppression efforts, avoid watershed damage in excess of that which would be caused by 

the fire itself. Avoid heavy equipment operation on fragile soils and steep slopes when possible. Use 

resource advisors and specialists to advise the incident commander on resource values during the 

suppression effort.

Stabilize areas where erosion potential increased or drainage patterns are altered by wildfires or by 

suppression related activities. Treatments include, but are not limited to:

 Installing water bars and other drainage diversions in fire roads, fire lines, and other cleared 

areas;

Seeding, planting and fertilizing to provide vegetative cover;

Spreading slash or mulch to protect bare soil;

Repairing damaged road drainage facilities; and

Installing erosion barriers. 

Provide for water quality protection in formulating prescribed fire prescriptions. Prescription elements 

include fire weather, slope, aspect, soil moisture, and fuel moisture. These elements influence the fire 

intensity and have a direct effect on whether desired ground cover remains after burning, and 

whether a water repellent layer is formed.

Maintain soil productivity, minimize erosion, and prevent ash, sediment, nutrients, and debris from 

entering water bodies during prescribed fires. Some of the techniques used to prevent water quality 

impacts include:
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

Design Features, and Operating Procedures

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Maintaining the integrity of the stream course and RCA width and

Planning prescribed fires with intensities that will not result in soils becoming hydrophobic.

Special Status Species

Greater Sage-Grouse

Avoid spraying treatment areas for the control of grasshoppers and Mormon crickets in key sagegrouse habitat in May and June (or as appropriate to local circumstances) to provide insect 

availability for early development of sage-grouse chicks.

Use approved chemicals with the lowest toxicity to sage-grouse that still provide effective control of 

grasshoppers and Mormon crickets. Coordinate with US Department of Agriculture Animal and Plant 

Health Inspection Service to determine the approved chemical with the lowest toxicity.

Slickspot Peppergrass

A qualified biologist may be required to monitor slickspots to avoid impacts during projects in habitat 

categories for slickspot peppergrass.

In occupied habitat, only hand sprayers will be used for the application of herbicide.

Within 10 feet of occupied slickspots, weeds will only be treated by hand.

Noxious Weeds and Invasive Plants

When relevant, incorporate noxious weed and invasive plant prevention into project designs, 

including but not limited to: Emergency Stabilization and Burned Area Rehabilitation, fuels, range 

infrastructure, wildlife, fisheries, botany, soil, watershed, cultural resource, paleontology, recreation, 

and stream restoration projects.

Encourage noxious weed and invasive plant awareness and education in employee development, 

training plans, and orientation for field, fire, and administrative positions.

Promptly treat recreation sites or other high use areas when noxious weeds and invasive species are 

found.

Wildland Fire Suppression

In the event a wildland fire escapes initial attack, a resource advisor should be assigned to ensure 

that resource management concerns are adequately addressed and that necessary mitigation occurs. 

If one of the following is being threatened or has the potential to be threatened, the authorized officer 

must be notified and a resource advisor should be dispatched:

Public health and safety; 

 Wildland urban interface; 

Sage-grouse habitat; 

Occupied habitat for slickspot peppergrass; or

Areas of Critical Environmental Concern; Wilderness Study Areas (WSAs); Wilderness; 

designated, eligible, or suitable Wild and Scenic Rivers; or National Historic Trails (NHTs). 

Use the minimum control line width necessary for containing fires; following containment, additional 

control lines should be avoided.

Existing roads should be used for dozer lines before new dozer lines are constructed.

Use of natural firebreaks and existing roads and trails to contain a wildland fire would be encouraged 

within special designations (e.g., WSAs, Areas of Critical Environmental Concern, and NHTs). 

Equipment used during extended attack should be cleaned before arriving on site and prior to 

demobilization to minimize the spread of noxious weeds and invasive plants. Wash stations should be 

set up in base camps and staging areas when practical.

For fires requiring an incident management team, coordinate with the Field Office specialists prior to 

the establishment of base camps, staging areas, or support facilities so areas with special 

designations, special status species habitat, cultural resources sites, noxious weed patches, or 

riparian areas would be avoided to the extent practical.

Through the authorized officer or resource advisor, an archaeologist should be notified to provide 

technical expertise, identify cultural resources that may be encountered, and identify best cultural 

protection practices to be used during suppression activities.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Prior to wildland fire season, potential areas of conflict between archaeological resources and 

wildland fire suppression activities should be identified.

Consider covering rock art or wrapping historic buildings or other such features in fire retardant fabric.

To the extent practicable, suppress wildfires near rock art sites to minimize smoke damage. Rock art 

sites would be a suppression priority once the wildfire is contained. Avoid direct applications of foam, 

water, or retardant to rock art sites during suppression operations.

Livestock Grazing

General

Ensure noxious weed and invasive plant prevention and control are considered in the management of 

grazing allotments.

Implement grazing practices that allow for periodic rest during the growing season and promote 

rangeland health.

Use annual indicators to evaluate implementation of grazing scedules. 

Manage water availability to alter distribution of livestock to maintain plant vigor and habitat for wildlife 

and special status plant species.

Consider kind and breed of livestock to improve distribution patterns and forage use.

Encourage the use of animal husbandry practices, such as early weaning of calves or culling of 

problem cattle, to achieve resource objectives.

Remove and properly dispose of supplement tubs, old pipe, troughs, wire, and etc. from BLM 

managed lands.

Pursue opportunities to incorporate multiple allotments under a single management plan/strategy 

where incorporation would result in enhanced management to promote rangeland health and resolve 

resource issues.

Upland Areas

Periodically treat crested wheatgrass seedings to prevent widespread development of decadent 

plants undergoing a process of decline of vigor, production, and palatability to wildlife and livestock 

due to accumulation of previous year’s biomass. (i.e., manage livestock grazing to reduce 

disturbance to special status birds in native plant communities during nesting. For example, deferring 

some pastures during nesting or active herding of livestock between pastures.

Place salt and other supplements in annual grasslands or non-native perennial grassland sites. If 

specific pastures contain only native habitats, place salt and supplements in areas that are already 

disturbed including, but not limited to:

dirt road or jeep trail intersections,

water troughs located in the uplands,

gravel pits, or

areas previously used for salting.

In pastures with non-native plant communities, place salt and other supplements at least 0.25 mile 

from native plant communities. If space limits this practice, place supplements to minimize livestock 

congregation in native plant communities.

Consider placing livestock water or supplements away from agricultural land to provide relatively 

large blocks of suitable nesting and wintering habitat for pheasants, as well as nesting habitat for 

other taller grass dependent species such as northern harriers, short-eared owls, and several 

songbirds.

Riparian Areas

Use water developments in upland areas to reduce livestock concentrations in riparian areas.

Place salt and other supplements in the uplands at least 0.25 mile away from riparian zones and 

wetlands, unless determined necessary to meet specific resource objectives.

Use localized hardened crossings to limit surface disturbance and reduce erosion at streamside 

livestock watering and crossing areas as long as fish migration through the watering areas is not 

impeded.
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Use riding and herding to control livestock distribution and use in areas with identified resource 

concerns such as in riparian areas, wet meadows, or stream crossings. Frequency of this method 

would vary by allotment, pasture and resource concern.

Use gap fencing in conjunction with gullies, cliffs, and other natural barriers to limit livestock trailing 

and bedding in riparian areas; bed livestock in the uplands where possible.

When water gaps are necessary, locate water gaps in rocky or hardened areas (natural or manmade) 

to minimize trampling damage to streambanks and streambeds. Use narrow water gaps to 

discourage livestock from loafing at the water source.

Ensure utilization levels provide for sufficient herbaceous and woody vegetation during periods of 

high flow to protect streambanks, dissipate energy, and trap sediments.

When entering a pasture, locate livestock near upland troughs or ponds to avoid impacts to riparian 

areas.

Range Infrastructure

Fences (Applicable to all programs)

Encourage reducing fence densities by implementing alternative control methods such as herding, 

turning off waters, and placement of salt or supplements (Autenrieth et al., 2006; Yoakum, 2004b). 

When reconfiguring pastures within an allotment and when the allotment size allows, larger pasture 

sizes (greater than 3,000 acres) are preferred to smaller pasture sizes to meet big game objectives.

Modify fences that cross big game migration routes (e.g., Davison clips, let-down fence, or other 

techniques) to ensure that pronghorn and mule deer movements are not blocked.

Exclosure fences should be at least 10 acres to accommodate big game use (Gross and Knight, 

2000). 

If it is necessary to restrict big game to protect resource values, including rare plant habitat, such 

exclosures should be of adequate height (at least 8 feet) to prevent big game access. These types of 

exclosures would be sized to protect the resource value which may cover less than 10 acres.

Water Developments 

Proposed Authorizations/Activities

Design structures in a manner that minimizes potential for production of mosquitoes which may carry 

West Nile virus.

Fences should not be placed on dams or berms to minimize waterfowl, shorebird, and other avian 

collisions. Fences should be beyond the high water mark surrounding the pond/reservoir to minimize 

collision with waterfowl and shorebirds. Anchor troughs without wires, poles, and other obstructions 

directly over the trough surface to reduce injuries and make the troughs more accessible to bats 

(Tuttle et al., 2006). 

Evaluate ponds and reservoirs as habitat for amphibians. Where habitat is occupied by amphibians, 

take measures to maintain or improve habitat quality, including planting aquatic cover, providing 

basking areas, reducing trampling at critical times of the year, and providing water from spring 

through fall (CSFTT, 2003). 

Explore alternative strategies to divert water that reduce impacts on the spring source or riparian 

habitat (e.g., locating collection devices far enough below the spring source that it reduces 

detrimental impacts on the spring source or surrounding riparian vegetation (CSFTT, 2003), leaving 

adequate water at the spring source to maintain or enhance the existing condition).

Recreation

Recreation Sites

Develop site-specific measures to avoid impacts to sage-grouse at existing or new recreation sites 

(e.g., seasonal closures, location of facilities). 

In the sage-grouse management area, use perch deterrents on signs and kiosks to reduce raven or 

raptor use of this infrastructure as foraging perches.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

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Transportation and Travel

In coordination with Idaho Department of Fish and Game, Nevada Department of Wildlife, and local 

highway districts, evaluate primitive roads and trails and consider seasonal restrictions. Primitive 

roads in sage-grouse nesting and big game winter habitat would have the highest priority for seasonal 

closures during sensitive periods (Mule Deer Working Group, 2004) (Idaho Sage-grouse Advisory 

Committee, 2006). 

Through the transportation and travel management planning process, address important wildlife 

habitat values including key sage-grouse breeding habitat (Idaho Sage-grouse Advisory Committee, 

2006) and big game parturition and winter habitats (Mule Deer Working Group, 2004) through actions 

such as closing or rerouting roads and seasonal restrictions.

To the extent practical, schedule road realignments and other major construction to occur between 

June 21 and November 30 in big game winter habitat and sage-grouse habitat.

Spray herbicides along roadsides to minimize sources of noxious weed and invasive plant seed that 

could be transported to other areas. Follow conservation measures found in Appendix E when 

applying herbicide along roadsides in occupied habitat for slickspot peppergrass.

Ensure road blading and roadside herbicide applications are coordinated chronologically to minimize 

herbicide use and increase effectiveness.

Use spot grading whenever possible to reduce route braiding.

Where culverts and water bars are installed, use methods to slow water flow to prevent erosion. 

Methods may include rock, filter cloth, straw rolls, or other methods.

When culverts are removed, they will be hauled to a land fill or recycled.

Place a high priority on closing and reclaiming unauthorized motor vehicle routes.

Ditch outs should remain within the road’s right-of-way. Avoid ending ditch outs in defined ephemeral 

channels.

Land Use Authorizations

Communication Towers and Overhead Transmission Lines

Construct new power lines and bury cable next to existing roads or other linear disturbance features 

to the extent possible.

Remove wires from abandoned overhead power or telephone lines; cut off poles near ground level 

and remove them.

Design towers and configure power poles to prevent raptors from using them as perches or nest 

sites.

Design towers and adjacent structures with the smallest footprint possible; however, a larger footprint 

for self-supporting towers is preferable to guy-supported towers with a smaller footprint.

Install visual markers or other proven methods on guyed towers to prevent collisions by wildlife.

Install downshield security lighting for on-the-ground facilities to minimize attraction to birds and bats.

Wind Energy Development

The design features for wind energy development are from the Implementation of a Wind Energy 

Development Program and Associated Land Use Plan Documents Record of Decision (BLM, 2005) which 

amended the 1987 Jarbidge RMP and Record of Decision. Applicable design features will be adopted as 

required elements of project-specific Plans of Development (PODs) and/or as right-of-way (ROW) 

authorization stipulations. They are categorized by development activity: site monitoring and testing, 

development of the POD, construction, operation, and decommissioning. The design features for 

development of the POD identify elements that address potential impacts associated with subsequent 

phases of development.

Site Monitoring and Testing

The Federal Aviation Administration (FAA)-required notice of proposed construction shall be made as 

early as possible to identify any air safety measures that would be required. 

The area disturbed by installation of meteorological towers (i.e., footprint) shall be kept to a minimum.
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Existing roads shall be used to the maximum extent feasible. If new roads are necessary, they shall 

be designed and constructed to the appropriate standard.

Meteorological towers shall not be located in sensitive habitats or in areas where ecological 

resources known to be sensitive to human activities (e.g., sage-grouse, golden eagle nest territories, 

etc) are present. Installation of towers shall be scheduled to avoid disruption of wildlife reproductive 

activities or other important behaviors.

Meteorological towers installed for site monitoring and testing shall be inspected periodically for 

structural integrity.

Plan of Development Preparation

General

Project developers shall coordinate with the BLM, Department of Defense, and FAA early in the 

project planning process to identify and minimize impacts on airspace use. Identifying impacts on 

airspace use shall include, but is not limited to: 

Consult with the FAA on proposed construction of any facility that is 100 feet (~61 m) or taller to 

evaluate potential safety hazards.

Consult with the DoD to minimize and/or eliminate impacts on military operations, and encourage 

compatible development. 

Available information describing the environmental and sociocultural conditions in the vicinity of the 

proposed project shall be collected and reviewed as needed to predict potential impacts of the 

project.

To plan for efficient use of the land, necessary infrastructure requirements shall be consolidated 

wherever possible, and current transmission and market access shall be evaluated carefully.

The project shall be planned to utilize existing roads and utility corridors to the maximum extent 

feasible, and to minimize the number and length/size of new roads, lay-down areas, and borrow 

areas.

A monitoring program shall be developed to ensure that environmental conditions are monitored 

during the construction, operation, and decommissioning phases. The monitoring program 

requirements, including adaptive management strategies, shall be established at the project level to 

ensure that potential adverse impacts of wind energy development are mitigated. The monitoring 

program shall identify the monitoring requirements for each environmental resource present at the 

site, establish metrics against which monitoring observations can be measured, identify potential 

mitigation measures, and establish protocols for incorporating monitoring observations and additional 

mitigation measures into standard operating procedures and best management practices.

“Good housekeeping” procedures shall be developed to ensure that during construction, operation 

and decommissioning the site will be kept clean of debris, garbage, fugitive trash or waste, and 

graffiti; to prohibit scrap heaps and dumps; and to minimize storage yards.

Wildlife and Other Ecological Resources

 Operators shall review existing information on species and habitats in the vicinity of the project area 

to identify potential concerns.

Operators shall conduct surveys for Federal and/or State-protected species and other species of 

concern (including special status plant and animal species) within the project and adjoining areas, 

design the project to avoid (if possible), minimize, or mitigate impacts to these resources.

Operators shall identify important, sensitive, or unique habitats in the vicinity of the project and design 

the project to avoid (if possible), minimize, or mitigate impacts to these habitats (e.g., locate the

turbines, roads, and ancillary facilities in the least environmentally sensitive areas; i.e., away from 

riparian habitats, streams, wetlands, drainages, or critical wildlife habitats).

The BLM will prohibit the disturbance of any population of Federally listed plant species.

Operators shall use best available information to evaluate avian and bat use of the project area and 

design the project and site-specifi BMPs to minimize or mitigate the potential for bird and bat strikes 

(e.g., development shall not occur in riparian habitats and wetlands). Scientifically rigorous avian and 

bat use surveys shall be conducted; the amount and extent of ecological baseline data required shall 
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be determined on a project basis. The surveys will cover all seasons and be at least two years in 

duration. An avian and bat protection plan shall be completed for wind energy development projects.

Turbines shall be configured to avoid landscape features known to attract raptors, if site studies show 

that placing turbines there would pose a significant risk to raptors.

Operators shall determine the presence of bat colonies and avoid placing turbines near known bat 

hibernation, breeding, and maternity/nursery colonies; in known migration corridors; or in known flight 

paths between colonies and feeding areas.

Operators shall determine the presence of raptor nests (i.e., active raptor nests and alternate nest 

sites within breeding territories during the breeding season). Measures to reduce raptor use at a 

project site (e.g., minimize road cuts, maintain either no vegetation or non-attractive plant species 

around the turbines) shall be considered.

A habitat restoration plan shall be developed to avoid (if possible), minimize, or mitigate negative 

impacts on vulnerable wildlife while maintaining or enhancing habitat values for other species. The 

plan shall identify revegetation, soil stabilization, and erosion reduction measures that shall be 

implemented to ensure that all temporary use areas are restored. The plan shall require that 

restoration occur as soon as possible after completion of activities to reduce the amount of habitat 

converted at any one time and to speed up the recovery to natural habitats.

Procedures shall be developed to mitigate potential impacts to special status species. Such 

measures could include avoidance, relocation of project facilities or lay-down areas, and/or relocation 

of biota.

Facilities shall be designed to discourage their use as perching or nesting substrates by birds. For 

example, power lines and poles shall be configured to minimize raptor electrocutions and discourage 

raptor and raven nesting and perching.

Visual Resources

The public shall be involved and informed about the visual site design elements of the proposed wind 

energy facilities. Possible approaches include conducting public forums for disseminating information, 

offering organized tours of operating wind developments, and using computer simulation and 

visualization techniques in public presentations.

Turbine arrays and turbine design shall be integrated with the surrounding landscape. Design 

elements to be addressed include visual uniformity, use of tubular towers, proportion of turbines, color 

of nonreflective paints, and prohibition of messages on turbines.

Other site design elements shall be integrated with the surrounding landscape. Elements to address 

include minimizing the profile of the ancillary structures, burial of cables, prohibition of commercial 

symbols, and lighting. Regarding lighting, efforts shall be made to minimize the need for and amount 

of lighting on ancillary structures.

Roads

An access road siting and management plan shall be prepared incorporating existing BLM standards 

regarding road design, construction, and maintenance, such as those described in the BLM 9113 

Manual and the Surface Operating Standards for Oil and Gas Exploration and Development (i.e., the 

Gold Book, 4th Edition, 2007).

Ground Transportation

A transportation plan shall be developed, particularly for the transport of turbine components, main 

assembly cranes, and other large pieces of equipment. The plan shall consider specific object sizes, 

weights, origin, destination, and unique handling requirements and shall evaluate alternative 

transportation approaches. In addition, the process to be used to comply with unique State 

requirements and to obtain all necessary permits shall be clearly identified.

A traffic management plan shall be prepared for the site access roads to ensure that no hazards 

would result from the increased truck traffic and that traffic flow would not be adversely impacted. 

This plan shall incorporate measures such as informational signs, flaggers when equipment may 

result in blocked throughways, and traffic cones to identify any necessary changes in temporary lane 

configuration.
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Noise

Proponents of a wind energy development project shall take multiple measurements in multiple 

seasons to assess the existing background noise levels at multiple sites and compare them with the 

anticipated noise levels associated with the proposed project.

Noxious Weeds and Pesticides

Operators shall develop a plan for control of noxious weeds and invasive plant species, which could 

occur as a result of new surface disturbance activities at the site. The plan shall address monitoring, 

education of personnel on weed identification, the manner in which weeds spread, and methods for 

treating infestations. The use of certified weed-free mulching shall be required. A controlled 

inspection and cleaning area shall be established to visually inspect construction equipment arriving 

at the project area and to remove and collect seeds that may be adhering to tires and other 

equipment surfaces.

If pesticides are used on the site, an integrated pest management plan shall be developed to ensure 

that applications would be conducted within the framework of BLM and USDI policies and entail only 

the use of Environmental Protection Agency-registered pesticides. Pesticide use shall be limited to 

nonpersistent, immobile pesticides and shall only be applied in accordance with label and application 

permit directions and stipulations for terrestrial and aquatic applications.

Cultural/Historic Resources

BLM will consult with Indian tribal governments early in the planning process to identify issues 

regarding the proposed wind energy development, including issues related to the presence of cultural 

properties, access rights, disruption to traditional cultural practices, and impacts to visual resources 

important to the tribe(s).

The presence of archaeological sites and historic properties in the area of potential effect shall be 

determined on the basis of a records search of recorded sites and properties in the area and/or, 

depending on the extent and reliability of existing information, an archaeological survey. 

Archaeological sites and historic properties present in the area of potential effect shall be reviewed to 

determine whether they meet the criteria of eligibility for listing on the National Register of Historic 

Places (NRHP).

When any ROW application includes remnants of a National Historic Trail, is located within the 

viewshed of a National Historic Trail’s designated centerline, or includes or is within the viewshed of a 

trail eligible for listing on the NRHP, the operator shall evaluate the potential visual impacts to the trail 

associated with the proposed project and identify appropriate mitigation measures for inclusion as 

stipulations in the POD.

If cultural resources are present at the site, or if areas with a high potential to contain cultural material 

have been identified, a Cultural Resources Management Plan (CRMP) shall be developed. This plan 

shall address mitigation activities to be taken for cultural resources found at the site. Avoidance of the 

area is always the preferred mitigation option. Other mitigation options include archaeological survey 

and excavation (as warranted) and monitoring. If an area exhibits a high potential, but no artifacts 

were observed during an archaeological survey, monitoring by a qualified archaeologist could be 

required during all excavation and earthmoving in the high-potential area. A report shall be prepared 

documenting these activities. The CRMP also shall: 

 Establish a monitoring program,

 Identify measures to prevent potential looting/vandalism or erosion impacts, and

 Address the education of workers and the public to make them aware of the consequences of 

unauthorized collection of artifacts and destruction of property on public land.

Paleontological Resources

Operators shall determine whether paleontological resources exist in a project area on the basis of 

the sedimentary context of the area, a records search for past paleontological finds in the area, 

and/or, depending on the extent of existing information, a paleontological survey.

If paleontological resources are present at the site, or if areas with a high potential to contain 

paleontological material have been identified, a paleontological resources management plan shall be 

developed. This plan shall include a mitigation plan for collection of the fossils; mitigation could 
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include avoidance, removal of fossils, or monitoring. If an area exhibits a high potential but no fossils 

were observed during survey, monitoring by a qualified paleontologist could be required during all 

excavation and earthmoving in the sensitive area. A report shall be prepared documenting these 

activities. The paleontological resources management plan also shall: 

 Establish a monitoring program,

 Identify measures to prevent potential looting/vandalism or erosion impacts, and

 Address the education of workers and the public to make them aware of the consequences of 

unauthorized collection of fossils on public land.

Hazardous Materials and Waste Management

Operators shall develop a hazardous materials management plan addressing storage, use, 

transportation, and disposal of each hazardous material anticipated to be used at the site. The plan 

shall identify all hazardous materials that would be used, stored, or transported at the site. It shall 

establish inspection procedures, storage requirements, storage quantity limits, inventory control, 

nonhazardous product substitutes, and disposition of excess materials. The plan shall also identify 

requirements for notices to Federal and local emergency response authorities and include emergency 

response plans.

Operators shall develop a waste management plan identifying the waste streams that are expected to 

be generated at the site and addressing hazardous waste determination procedures, waste storage 

locations, waste-specific management and disposal requirements, inspection procedures, and waste 

minimization procedures. This plan shall address all solid and liquid wastes that may be generated at 

the site.

Operators shall develop a spill prevention and response plan identifying where hazardous materials 

and wastes are stored on site, spill prevention measures to be implemented, training requirements, 

appropriate spill response actions for each material or waste, the locations of spill response kits on 

site, a procedure for ensuring that the spill response kits are adequately stocked at all times, and 

procedures for making timely notifications to authorities.

Storm Water

Operators shall develop a storm water management plan for the site to ensure compliance with 

applicable regulations and prevent off-site migration of contaminated storm water or increased soil 

erosion. 

Human Health and Safety

A safety assessment shall be conducted to describe potential safety issues and the means that would 

be taken to mitigate them, including issues such as site access, construction, safe work practices, 

security, heavy equipment transportation, traffic management, emergency procedures, and fire 

control.

A health and safety program shall be developed to protect both workers and the general public during 

construction, operation, and decommissioning of a wind energy project. Regarding occupational 

health and safety, the program shall identify all applicable Federal and State occupational safety 

standards; establish safe work practices for each task (e.g., requirements for personal protective 

equipment and safety harnesses; Occupational Safety and Health Administration standard practices 

for safe use of explosives and blasting agents; and measures for reducing occupational electric and 

magnetic fields exposures); establish fire safety evacuation procedures; and define safety 

performance standards (e.g., electrical system standards and lightning protection standards). The 

program shall include a training program to identify hazard training requirements for workers for each 

task and establish procedures for providing required training to all workers. Documentation of training 

and a mechanism for reporting serious accidents to appropriate agencies shall be established.

Regarding public health and safety, the health and safety program shall establish a safety zone or 

setback for wind turbine generators from residences and occupied buildings, roads, ROWs, and other 

public access areas that is sufficient to prevent accidents resulting from the operation of wind turbine 

generators. It shall identify requirements for temporary fencing around staging areas, storage yards, 

and excavations during construction or decommissioning activities. It shall also identify measures to 

be taken during the operation phase to limit public access to hazardous facilities (e.g., permanent 
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fencing would be installed only around electrical substations, and turbine tower access doors would 

be locked).

Operators shall consult with local planning authorities regarding increased traffic during the 

construction phase, including an assessment of the number of vehicles per day, their size, and type. 

Specific issues of concern (e.g., location of school bus routes and stops) shall be identified and 

addressed in the traffic management plan.

If operation of the wind turbines is expected to cause significant adverse impacts to nearby 

residences and occupied buildings from shadow flicker, low-frequency sound, or electric and 

magnetic fields site-specific recommendations for addressing these concerns shall be incorporated 

into the project design (e.g., establishing a sufficient setback from turbines).

The project shall be planned to minimize electromagnetic interference (e.g., impacts to radar, 

microwave, television, and radio transmissions) and comply with Federal Communications 

Commission regulations. Signal strength studies shall be conducted when proposed locations have 

the potential to impact transmissions. Potential interference with public safety communication 

systems (e.g., radio traffic related to emergency activities) shall be avoided.

The project shall be planned to comply with FAA regulations, including lighting regulations, and to 

avoid potential safety issues associated with proximity to airports, military bases or training areas, or 

landing strips.

Operators shall develop a fire management strategy to implement measures to minimize the potential 

for a human-caused fire.

Construction

General

All control and mitigation measures established for the project in the POD and the resource-specific 

management plans that are part of the POD shall be maintained and implemented throughout the 

construction phase, as appropriate.

The area disturbed by construction and operation of a wind energy development project (i.e., 

footprint) shall be kept to a minimum.

The number and size/length of roads, temporary fences, lay-down areas, and borrow areas shall be 

minimized.

Topsoil from all excavations and construction activities shall be salvaged and reapplied during 

reclamation.

All areas of disturbed soil shall be reclaimed using weed-free native grasses, forbs, and shrubs.

Reclamation activities shall be undertaken as early as possible on disturbed areas.

All electrical collector lines shall be buried in a manner that minimizes additional surface disturbance 

(e.g., along roads or other paths of surface disturbance). Overhead lines may be used in cases where 

burial of lines would result in further habitat disturbance.

Operators shall identify unstable slopes and local factors that can induce slope instability (such as 

groundwater conditions, precipitation, earthquake activities, slope angles, and the dip angles of 

geologic strata). Operators also shall avoid creating excessive slopes during excavation and blasting 

operations. Special construction techniques shall be used where applicable in areas of steep slopes, 

erodible soil, and stream channel crossings.

Erosion controls that comply with Federal, State, and local standards shall be applied. Practices such 

as jute netting, silt fences, and check dams shall be applied near disturbed areas.

Wildlife

Guy wires on permanent meteorological towers shall be avoided, however, may be necessary on 

temporary meteorological towers installed during site monitoring and testing. If used guy wires would 

be marked to reduce wildlife mortality.

In accordance with the habitat restoration plan, restoration shall be undertaken as soon as possible 

after completion of construction activities to reduce the amount of habitat converted at any one time 

and to speed up the recovery to natural habitats.
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All construction employees shall be instructed to avoid harassment and disturbance of wildlife, 

especially during reproductive (e.g., courtship and nesting) seasons. In addition, pets shall not be 

permitted on site during construction.

Visual Resources

Operators shall reduce visual impacts during construction by minimizing areas of surface disturbance, 

controlling erosion, using dust suppression techniques, and restoring exposed soils as closely as 

possible to their original contour and vegetation.

Roads

Existing roads shall be used, but only if in safe and environmentally sound locations. If new roads are 

necessary, they shall be designed and constructed to the appropriate standard and be no higher than 

necessary to accommodate their intended functions (e.g., traffic volume and weight of vehicles). 

Excessive grades on roads, road embankments, ditches, and drainages shall be avoided, especially 

in areas with erodible soils. Special construction techniques shall be used, where applicable. 

Abandoned roads and roads that are no longer needed shall be recontoured and revegetated.

Access roads and on-site roads shall be surfaced with aggregate materials, wherever appropriate.

Access roads shall be located to follow natural contours and minimize side hill cuts.

Roads shall be located away from drainage bottoms and avoid wetlands, if practicable.

Roads shall be designed so that changes to surface water runoff are avoided and erosion is not 

initiated.

Access roads shall be located to minimize stream crossings. All structures crossing streams shall be 

located and constructed so that they do not decrease channel stability or increase water velocity. 

Operators shall obtain all applicable Federal and State permits.

Existing drainage systems shall not be altered, especially in sensitive areas such as erodible soils or 

steep slopes. Potential soil erosion shall be controlled at culvert outlets with appropriate structures. 

Catch basins, roadway ditches, and culverts shall be cleaned and maintained regularly.

Ground Transportation

Project personnel and contractors shall be instructed and required to adhere to speed limits 

commensurate with road types, traffic volumes, vehicle types, and site-specific conditions, to ensure 

safe and efficient traffic flow and to reduce wildlife collisions and disturbance and airborne dust.

Traffic shall be restricted to the roads developed for the project. Use of other unimproved roads shall 

be restricted to emergency situations.

Signs shall be placed along construction roads to identify speed limits, travel restrictions, and other 

standard traffic control information. To minimize impacts on local commuters, consideration shall be 

given to limiting construction vehicles traveling on public roadways during the morning and late 

afternoon commute time.

Air Emissions

Dust abatement techniques shall be used on unpaved, unvegetated surfaces to minimize airborne 

dust.

Speed limits (e.g., 25 mph [40 km/h]) shall be posted and enforced to reduce airborne fugitive dust.

Construction materials and stockpiled soils shall be covered if they are a source of fugitive dust.

Dust abatement techniques shall be used before and during surface clearing, excavation, or blasting 

activities.

Excavation and Blasting Activities

Operators shall gain a clear understanding of the local hydrogeology. Areas of groundwater discharge 

and recharge and their potential relationships with surface water bodies shall be identified.

Operators shall avoid creating hydrologic conduits between two aquifers during foundation excavation 

and other activities.

Foundations and trenches shall be backfilled with originally excavated material as much as possible. 

Excess excavation materials shall be disposed of only in approved areas or, if suitable, stockpiled for 

use in reclamation activities.
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Borrow material shall be obtained only from authorized and permitted sites. Existing sites shall be 

used in preference to new sites.

Explosives shall be used only within specified times and at specified distances from sensitive wildlife 

or streams and lakes, as established by the BLM or other Federal and State agencies. 

Noise

Noisy construction activities (including blasting) shall be limited to the least noise-sensitive times of 

day (i.e., daytime only between 9 a.m. and 10 p.m.) and weekdays.

All equipment shall have sound-control devices no less effective than those provided on the original 

equipment. All construction equipment used shall be adequately muffled and maintained.

All stationary construction equipment (i.e., compressors and generators) shall be located as far as 

practicable from nearby residences.

If blasting or other noisy activities are required during the construction period, nearby residents shall 

be notified in advance. 

Cultural and Paleontological Resources

Unexpected discovery of cultural or paleontological resources during construction shall be brought to 

the attention of the responsible BLM authorized officer immediately. Work shall be halted in the 

vicinity of the find to avoid further disturbance to the resources while they are being evaluated and 

appropriate mitigation measures are being developed.

Hazardous Materials and Waste Management

Secondary containment shall be provided for all on-site hazardous materials and waste storage, 

including fuel. In particular, fuel storage (for construction vehicles and equipment) shall be a 

temporary activity occurring only for as long as is needed to support construction activities.

Wastes shall be properly containerized and removed periodically for disposal at appropriate off-site 

permitted disposal facilities.

In the event of an accidental release to the environment, the operator shall document the event, 

including a root cause analysis, appropriate corrective actions taken, and a characterization of the 

resulting environmental or health and safety impacts. Documentation of the event shall be provided to 

the BLM authorized officer and other Federal and State agencies, as required.

Any wastewater generated in association with temporary, portable sanitary facilities shall be 

periodically removed by a licensed hauler and introduced into an existing municipal sewage treatment 

facility. Temporary, portable sanitary facilities provided for construction crews shall be adequate to 

support expected on-site personnel and shall be removed at completion of construction activities.

Public Health and Safety

Temporary fencing shall be installed around staging areas, storage yards, and excavations during 

construction to limit public access.

Operations

General

All control and mitigation measures established for the project in the POD and the resource-specific 

management plans that are part of the POD shall be maintained and implemented throughout the 

operational phase, as appropriate. These control and mitigation measures shall be reviewed and 

revised, as needed, to address changing conditions or requirements at the site, throughout the 

operational phase. This adaptive management approach would help ensure that impacts from 

operations are kept to a minimum.

Inoperative turbines shall be repaired, replaced, or removed in a timely manner. Requirements to do 

so shall be incorporated into the due diligence provisions of the right-of-way (ROW) authorization. 

Operators will be required to demonstrate due diligence in the repair, replacement, or removal of 

turbines; failure to do so could result in termination of the ROW authorization.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Wildlife

Employees, contractors, and site visitors shall be instructed to avoid harassment and disturbance of 

wildlife, especially during reproductive (e.g., courtship and nesting) seasons. In addition, any pets 

shall be controlled to avoid harassment and disturbance of wildlife.

Observations of potential wildlife problems, including wildlife mortality, shall be reported to the BLM 

authorized officer immediately.

Ground Transportation

Ongoing ground transportation planning shall be conducted to evaluate road use, minimize traffic 

volume, and ensure that roads are maintained adequately to minimize associated impacts.

Monitoring Program

Site monitoring protocols defined in the POD shall be implemented. These will incorporate monitoring 

program observations and additional mitigation measures to minimize future environmental impacts.

Results of monitoring program efforts shall be provided to the BLM authorized officer.

Public Health and Safety

Permanent fencing shall be installed and maintained around electrical substations. 

 Turbine tower access doors shall be locked to limit public access.

In the event an installed wind energy development project results in electromagnetic interference, the 

operator shall work with the owner of the impacted communications system to resolve the problem. 

Additional warning information may also need to be conveyed to aircraft with onboard radar systems 

so that echoes from wind turbines can be quickly recognized.

Decommissioning

General

Prior to the termination of the ROW authorization, a decommissioning plan shall be developed and 

approved by the BLM. The decommissioning plan shall include a site reclamation plan and monitoring 

program.

All management plans, best management practices, and stipulations developed for the construction 

phase shall be applied to similar activities during the decommissioning phase.

All turbines and ancillary structures shall be removed from the site.

Topsoil from all decommissioning activities shall be salvaged and reapplied during final reclamation.

All areas of disturbed soil shall be reclaimed using weed-free native shrubs, grasses, and forbs. 

The vegetation cover, composition, and diversity shall be restored to values commensurate with the 

ecological setting.

Solar Energy Development

The following design features were adopted from the Approved Resource Management Plan 

Amendments/Record of Decision for Solar Energy Development in 6 Southwestern States (BLM and 

DOE, 2012) to provide consistency. Applicable design features will be adopted as required elements of 

project-specific Plans of Development (PODs) and/or as right-of-way (ROW) authorization stipulations.

Lands and Realty

General

Project developers shall consult with the BLM in the early phases of project planning to identify 

potential land use conflicts and constraints. Identification of potential land use conflicts shall include, 

but is not limited to:

 In coordination with the BLM, developers shall consult existing BLM land use plans and local land 

use plans, as well as appropriate affected Tribes; Federal, State, and local agencies; and 

adjacent property owners.

Identifying legal access to Federal, State, and private lands surrounding the proposed solar 

facilities and the potential to create areas that are inaccessible to the public.
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

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Considering the effects on the uses of public lands around boundaries of solar energy facilities.

Considering the potential effects on prime and unique farmland.

Evaluating land use impacts and constraints for the project and consider options to avoid, 

minimize, and/or mitigate adverse impacts.

Informing existing BLM ROW authorization holders within solar energy development areas, 

pursuant to Title 43, Part 2807.14 of the Code of Federal Regulations (43 CFR 2807.14), that an 

application that might affect their existing ROW has been filed and request their comments. 

Identifying public land boundaries. Proposed solar energy developments within 0.25 mile of any 

project boundary will require issuance of a Chain of Survey Certificate in conformance with the 

Departmental standard. In some cases, Land Description Reviews, Certificates of Inspection and 

Possession, Boundary Assurance Certificates, resurveys, re-monumentation, and/or referencing 

of Public Land Survey System corners may be required before the start of any action.

Methods to minimize land use conflicts and constraints may include, but are not limited to:

Informing project personnel of all laws and regulations that they may be subject to, such as state 

borders limitations on the removal of salable materials such as stone or wood from a project site 

for personal use, and use of vehicles off of the project site in limited access areas. This 

information should be incorporated into a Worker Education and Awareness Plan that is provided 

to all project personnel prior to entering the project worksite. The worker education and 

awareness plan shall be provided on a regular basis, covering multiple resources, to ensure the 

awareness of mitigation efforts during all phases of the project’s life. Information in the worker 

education and awareness plan shall be reviewed and approved by the BLM prior to the issuance 

of a Notice to Proceed and shall incorporate adaptive management protocols for addressing 

changes over the life of the project, should they occur.

Site Characterization, Siting and Design, Construction

Solar facilities shall be sited, designed, and constructed to avoid, minimize, and/or mitigate impacts 

on BLM managed lands. Methods to minimize impacts on BLM managed lands may include:

Identifying and protecting evidence of the Public Land Survey System and related Federal 

property boundaries prior to commencement of any ground-disturbing activity. This will be 

accomplished by contacting the BLM Cadastral Survey to coordinate data research, evidence 

examination and evaluation, and locating, referencing, or protecting monuments of the Public 

Land Survey System and related land boundary markers from destruction. In the event of 

obliteration or disturbance of the Federal boundary evidence, the responsible party shall 

immediately report the incident, in writing, to the BLM authorized officier. The BLM Cadastral 

Survey will determine how the marker is to be restored. In rehabilitating or replacing the evidence 

the responsible party will be instructed to use the services of a Certified Federal Surveyor, whose 

procurement shall be per qualification-based selection, or to reimburse the BLM for costs. All 

surveying activities will conform to the Manual of Surveying Instructions and appropriate State 

laws and regulations. Local surveys will be reviewed by Cadastral Survey before being finalized 

or filed in the appropriate State or county office. The responsible party shall pay for all survey, 

investigation, penalty, and administrative costs.

Considering opportunities to consolidate access to and other supporting infrastructure for single 

projects and for cases where there is more than one project in close proximity to another in order 

to maximize the efficient use of public land and minimize impacts.

Special Designations and Lands Managed for Wilderness Characteristics

General

Protection of existing values of specially designated areas and Lands with Wilderness Characteristics

shall be evaluated during the environmental analysis for solar energy projects, and the results shall 

be incorporated into the project planning and design.

Assessing potential impacts on specially designated areas and Lands with Wilderness Characteristics

shall include, but is not limited to, the following:

Identifying specially designated areas and Lands with Wilderness Characteristics in proximity to 

the proposed projects. In coordination with the BLM, developers shall consult existing land use 

plans and updated inventories.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

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Identifying lands that are within the geographic scope of a proposed solar energy project that 

have not been recently inventoried for wilderness characteristics or any lands that have been 

identified in a citizen’s wilderness proposal in order to determine whether they possess 

wilderness characteristics. Developers shall consider including the wilderness characteristics 

evaluation as part of the processing of a solar energy ROW application for those lands without a 

recent wilderness characteristics inventory. All work must be completed in accordance with 

current BLM policies and procedures.

Methods to mitigate unavoidable impacts on special designations and Lands with Wilderness 

Characteristics may include, but are not limited to:

Acquiring wilderness inholdings from willing sellers.

Acquiring private lands from willing sellers adjacent to designated wilderness.

Acquiring private lands from willing sellers within designated wilderness or Wilderness Study 

Areas.

Acquiring other lands containing important wilderness or related values, such as opportunities for 

solitude or a primitive, unconfined (type of) recreation. 

Restoring wilderness (e.g., modifying routes or other structures that detract from wilderness 

character). 

Site Characterization, Siting and Design, Construction

Solar facilities shall avoid, minimize, and/or mitigate impacts on the values of special designations 

and Lands with Wilderness Characteristics. 

Rangeland Resources – Grazing

General

Project developers shall consult with the BLM and coordinate with affected grazing 

permittees/lessees to discuss how a proposed project may affect grazing operations and to address 

possible alternatives to avoid and minimize impacts, as well as mitigation and compensation 

strategies. 

Site Characterization, Siting and Design, Construction

Roads shall be constructed, improved, and maintained to minimize their impact on grazing 

operations. Road design shall include fencing, cattle guards, and speed control and information signs 

where appropriate.

Wild Horses

General

Project developers shall coordinate with the BLM and other stakeholders early in the project planning 

process to assess and consider options to avoid, minimize, and/or mitigate impacts on wild horses 

and their management areas. Assessing impacts on wild horses and their management areas shall 

include: 

 Identifying wild horses and their use areas within the herd area in proximity to the proposed 

projects.

Evaluating potential impacts on wild horses and their management areas as part of the 

environmental impact analysis for the project and considering options to avoid, minimize, and/or 

mitigate adverse impacts in coordination with the BLM.

Methods to minimize impacts on wild horses and their management areas may include:

Installing fencing and access control.

Providing for movement corridors.

Delineating open range.

Requiring traffic management measures (e.g., vehicle speed limits).

Ensuring access to or replacement of water sources.

Incorporating key mitigation elements for wild horse in a worker education and awareness plan

that is provided to all project personnel prior to entering the project work sites.
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Site Characterization, Siting and Design, Construction

Project access roads shall be sited, designed, constructed, fenced, and/or improved to minimize 

potential wild horse collisions. Fences, or other appropriate structures, should be constructed to 

exclude wild horses from solar energy project site facilities. Either water sources or access routes to 

water sources for horses should be excluded from the solar energy development area, or alternate 

water sources or routes should be provided.

Wildland Fire Ecology and Management

General

Project developers shall coordinate with the BLM and other appropriate fire organizations early in the 

project planning process to determine fire risk and methods to minimize fire risk. Identifying fire risk 

shall include:

Minimize the potential for fire risk associated of the proposed project in coordination with the BLM 

and other appropriate fire organizations. Developers shall consult existing land use plans and fire 

management plans.

Evaluating fire risk as part of the environmental impact analysis for the project and considering 

options to avoid, minimize, and/or mitigate such risk in coordination with the BLM.

General methods to minimize fire risk mayinclude:

Develop and implement fire management measures that include providing worker training.

Incorporate key elements to mitigate the potential for fire into a worker education and awareness 

plan that is provided to all project personnel prior to entering the project worksite. 

Incorporate inspection and monitoring measures, including adaptive management protocols, to 

minimize fire risk during construction, operations, and decommissioning of a solar energy 

development.

Site Characterization, Siting and Design, Construction

Solar facilities shall minimize fire risk. Methods to minimize fire risk may include, but are not limited to, 

the following:

Siting and designing the solar facilities to ensure sufficient room for fire management within the 

ROW and its facilities to minimize the risk of fire moving outside the ROW and the risk of fire 

threatening the facility from outside.

Consulting fire management personnel to determine actions, both active and passive (e.g., 

vegetation manipulation), that may minimize the need for protective responses by the BLM and 

State and local fire organizations.

Developing and implementing measures to integrate vegetation management to minimize the 

potential to increase the frequency of wildland fires and prevent the establishment of non-native, 

invasive species on the solar energy facility and its transmission line and roads.

Transportation, Travel, and Recreation

General

Project developers shall consult with the BLM in the early phases of project planning to identify public 

access and recreation use areas in and adjacent to a project site. Identifying public access and 

recreation in and adjacent to a project shall include, but is not limited to, the following:

Considering existing public access through or around proposed solar facilities that allows for 

access to and use of BLM managed public lands and non-BLM managed lands. Developers shall 

conduct this assessment in coordination with the BLM and consult existing land use plans, 

recreation management plans, etc.

Identifying legal access to Federal, State, and private lands surrounding the solar facilities to 

avoid creating areas that are inaccessible to the public.

Methods to minimize access and recreation conflicts may include, but are not limited to, the following:

Considering replacement of acreage lost for identified recreation opportunities, such as offhighway vehicle use.

Considering, to the extent practicable, providing access through or around a solar energy facility 

to provide for adequate public access and/or recreation.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

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Incorporating environmental inspection and monitoring measures into the POD and other 

applicable plans to monitor and respond to impacts on recreation during construction, operations, 

and decommissioning of a solar energy development, including adaptive management protocols.

Site Characterization, Siting and Design, Construction

Solar facilities shall not be sited in areas designated as unique or important recreation resources 

(such as Special Recreation Management Areas), where it has been determined that a solar facility or 

other such development of the land would be in direct conflict with the objectives of the relevant 

management plan.

Aviation

General

Project developers shall coordinate with the BLM, Department of Defense, and Federal Aviation 

Administration (FAA) early in the project planning process to identify and minimize impacts on 

airspace use. Identifying impacts on airspace use shall include, but is not limited to:

Consult with the FAA on proposed construction of any facility that is 100 feet (~ 61 m) or taller to 

evaluate potential safety hazards.

Consult with the DoD to minimize and/or eliminate impacts on military operations, and encourage 

compatible development.

Soil Resources and Geologic Hazards

General

Project developers shall coordinate with the BLM and other Federal, State, and local agencies early 

in the project planning process to assess soil erosion and geologic hazard concerns and to minimize 

potential impacts. Assessing soil erosion and geologic hazard concerns shall include, but is not 

limited to, the following:

Identifying soil erosion and geologic hazard concerns on-site and in proximity to the proposed 

projects. In coordination with the BLM, developers shall consult existing land use plans, updated 

inventories, soil surveys, etc.

Identifying local factors that can cause slope instability (e.g., groundwater conditions, 

precipitation, earthquake activity, slope angles, and the dip angles of geologic strata).

Consulting with Federal, State, and local agencies regarding road design on the basis of local 

meteorological conditions, soil moisture, and erosion potential.

Determining the potential safety and resource impacts associated with soil erosion.

Evaluating soil erosion and geologic hazard concerns as part of the environmental impact 

analysis for the project and considering options to avoid, minimize, and/or mitigate adverse 

impacts.

Site Characterization, Siting and Design, Construction

Solar facilities shall be sited to minimize soil erosion and geologic hazard concerns. Methods to 

minimize soil erosion may include, but are not limited to:

Designing structures to meet the requirements of all applicable Federal, State, and local permits 

and building codes.

Minimizing ground-disturbing activities.

Preventing channel erosion from project runoff.

Controlling culvert outlets with appropriate structures (e.g., rock lining or apron) to reduce soil 

erosion and scouring.

Recontouring and revegetating project roads that are no longer needed in order to increase 

infiltration and reduce soil compaction.

 Utilizing excavated materials for backfill.

Controlling project vehicle and equipment speeds to reduce dust erosion.

Controlling water runoff and directing it to settling or rapid infiltration basins.

Retaining sediment-laden waters from disturbed, active areas within the project through the use 

of barriers and sedimentation devices (e.g., berms, straw bales, sandbags, jute netting, or silt 
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fences). Removing sediment from barriers and sedimentation devices to restore sediment-control 

capacity.

Placing barriers and sedimentation devices around drainages and wetlands.

Siting project structures and facilities to avoid disturbance in areas with existing biological soil 

crusts.

Replanting project areas with native or non-native perennial vegetation at spaced intervals to 

break up areas of exposed soil and reduce soil loss through wind erosion.

Minimizing land disturbance (including crossings) in natural drainage systems and groundwater 

recharge zones (i.e., ephemeral washes and playas).

Locating and constructing drainage crossing structures so as not to decrease channel stability or 

increase water volume or velocity.

Providing adequate space (i.e., setbacks) between solar facilities and natural washes to preserve 

hydrologic function.

Considering the use of existing roads, disturbance areas, and borrow pits before creating new 

infrastructure. 

Siting, designing, and constructing new roads consistent with the appropriate design standards 

and criteria, such as those described in BLM Manual 9113 and 43 CFR 8342.1. Roads should 

follow natural land contours, and hill cuts should be minimized in the project area.

Avoiding areas with unstable slopes and soils.

Avoiding excessive grades on roads, road embankments, ditches, and drainages during site 

preparation and construction.

Considering use of special construction techniques in areas of steep slopes, erodible soil, and 

drainage ways.

Considering construction in stages to limit the areas of exposed and unstabilized soils.

Reducing construction activity timeframes so that ground-disturbing activities take place over as 

short a timeframe as possible.

Lessening fugitive dust by using dust abatement on designated roads used by construction traffic. 

Lessening fugitive dust emissions and site soils compaction by gravelling surfaces used for 

construction traffic and watering unvegetated surfaces.

Avoiding clearing and disturbing areas outside the construction zone.

Clearly identifying construction zone boundaries on the ground (e.g., through the use of 

construction fencing) to minimize conflict with resource.

Avoiding ground disturbance in areas with intact biological soil crusts.

Burying electrical lines from solar collectors along existing features (e.g., roads or other paths of 

disturbance) to minimize the overall area of surface disturbance.

Obtaining borrow materials from authorized and permitted sites.

Conducting construction grading in compliance with industry practice (e.g., the American Society 

for Testing and Materials international standard methods) and other requirements (e.g., BLM 

and/or local grading and construction permits). 

Using temporary stabilization devices (i.e., erosion matting blankets or soil stabilizing agents) for 

areas that are not actively under construction.

Salvaging topsoil from all excavation and construction and reapplying it to disturbed areas upon 

completion of construction. 

Restoring native plant communities as quickly as possible in disturbed areas through revegetation 

or by seeding and transplanting (using weed-free native grasses, forbs, and shrubs). 

Minimizing soil-disturbing activities on wet soils.

Incorporating environmental inspection and monitoring measures into the POD and other 

applicable plans to monitor and respond to impacts on soil resources during construction, 

operations, and decommissioning of a solar energy development, including adaptive 

management protocols.

Methods to minimize geologic hazard concerns may include, but are not limited to, the following:

Building project structures in accordance with the design-based recommendations in the projectspecific geotechnical investigation report.

Considering special siting, design, and engineering strategies in areas that have potential for 

flooding or debris flow.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

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Operations and Maintenance

Compliance with the stipulations for soil resources and geologic hazards shall be monitored by the 

project developer. Consultation with the BLM shall be maintained through the operations and 

maintenance of the project, employing an adaptive management strategy and modifications, as 

necessary and approved by the BLM. Methods to minimize soil erosion and geologic hazard 

operations and maintenance of the project shall include, but are not limited to, the following:

Applying best management practices (BMPs) developed for the construction phase to similar 

activities during the operations phase to minimize soil loss.

Performing routine site inspections to assess the effectiveness of maintenance requirements for 

erosion and sediment control systems.

Maintaining permanent barriers and sedimentation devices to ensure effective control.

Regularly maintaining catch basins, roadway ditches, and culverts.

Identifying soil erosion and geologic hazard requirements within the POD and other applicable 

plans.

Reclamation and Decommissioning

All BMPs for soil erosion and geologic hazards developed for the construction phase shall be applied 

to similar activities undertaken during the decommissioning and reclamation phase.

To the extent possible, the original grade and drainage pattern shall be re-established.

Native plant communities in disturbed areas shall be restored by revegetation or by seeding and 

transplanting (using weed-free native grasses, forbs, and shrubs), on the basis of recommendations 

by the BLM.

Mineral Resources

General

Project developers shall consult with the BLM in the early phases of project planning to identify 

potential impacts on mineral development activities and ways to minimize potential adverse impacts. 

Assessing impacts on mineral resources shall include, but is not limited to, the following:

Identifying active mining claims or mineral development activities and potential for mineral 

development in proximity to a proposed project. In coordination with the BLM, developers shall 

consult existing land use plans and updated inventories. 

 Solar energy development ROWs shall contain the stipulation that the BLM retains the right to issue 

oil and gas or geothermal leases with a stipulation of no surface occupancy within the ROW area.

Site Characterization, Siting and Design, Construction

Solar energy development projects shall be located to minimize conflicts with valid existing mineral 

rights and/or ongoing mineral development.

Water Resources 

General

The following activities will be undertaken to minimize impacts on water resources. They are to be 

done in coordination with the appropriate Federal, State, and local regulating agencies.

The project developer shall control project site drainage, erosion, and sedimentation related to 

stormwater runoff. The project developer shall identify site surface water runoff patterns and develop 

measures that prevent adverse impacts associated with project related soil deposition and erosion 

throughout and downslope of the project site and project related construction areas. This shall be 

implemented within a Stormwater Pollution Prevention Plan (SWPPP) and incorporated into the POD, 

as appropriate. Assessing stormwater runoff concerns shall include, but is not limited to, the following:

Conducting hydrologic analysis and modeling to define the 100-year, 24-hour rainfall for the 

project area and calculating projected runoff from this storm at the site.

Demonstrating the project will not increase off-site flooding potential, and including provisions for 

stormwater and sediment retention on the project site.
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Demonstrating compliance with construction stormwater permitting through the Environmental 

Protection Agency (EPA) or State-run National Pollutant Discharge Elimination System program 

(whichever applies within the State).

Demonstrating compliance with the EPA requirement that any development larger than 20 acres 

(0.08 km2

) and begun after August 2011 must monitor construction discharges for turbidity 

concentrations.

Methods to minimize stormwater runoff may include, but are not limited to, the following:

Managing runoff from parking lots, roofs, or other impervious surfaces.

Creating or improving landscaping used for stormwater treatment to capture runoff.

Considering reduction of impervious surfaces through the use of permeable pavement or other 

pervious surfaces.

Maintaining natural drainages and pre-project hydrographs for the project ROW to the extent 

practicable.

Maintaining pre-development flood hydrograph for all storms up to and including the 100-year 

rainfall event.

Incorporating environmental inspection and monitoring measures into the POD and other 

applicable plans to monitor and respond to impacts from stormwater runoff during construction, 

operations, and decommissioning of a solar energy development, including adaptive 

management protocols.

Project developers shall conduct hydrologic study (or studies) that demonstrate a clear understanding 

of the local surface water and groundwater hydrology. Assessing surface water and groundwater 

hydrology may include, but is not limited to, the following:

Determining the relationship of the project site hydrologic basin to the basins in the region.

Identifying surface water bodies within the watershed or individual projects (including rivers, 

streams, ephemeral washes/drainages, reservoirs, wetlands, playas, and floodplains) and 

identifying the 100-year floodplain of any surface water feature on the site.

Identifying applicable groundwater aquifers.

Quantifying physical characteristics of surface water features, such as stream flow rates, stream 

cross sections, channel routings, seasonal flow rates.

Quantifying physical characteristics of the groundwater aquifer, such as physical dimensions of 

the aquifer, sediment characteristics, confined/unconfined conditions, hydraulic conductivity, and 

transmissivity distribution of the aquifer.

Quantifying the regional climate, including seasonal and long-term information on temperatures, 

precipitation, evaporation, and evapotranspiration.

Quantifying the sustainable yield of surface waters and groundwater available to the project.

Consulting with the US Army Corps of Engineers regarding the siting of solar energy generating 

facilities in relation to hydrological features that have the potential to be subject to USACE 

jurisdiction.

Project developers shall coordinate with the BLM and other Federal, State, and local agencies early 

in the planning process in order to identify water use for the solar energy project, and to secure a 

reliable and legally available water supply to meet project water needs. Assessing water use shall 

include, but is not limited to, the following:

Quantifying water use requirements for project construction, operations, and decommissioning.

Meeting potable water supply standards of Federal, State, and local water quality authorities 

(e.g., Sections 303 and 304 of the Clean Water Act).

Identifying wastewater treatment measures and new or expanded facilities, if any, to be included 

as part of the facilities’ National Pollutant Discharge Elimination System permit.

Methods for minimizing water use may include, but are not limited to, the following:

Considering water conservation measures related to solar energy technology water needs to 

reduce project water requirements (i.e., use dry cooling, use recycled or impaired water).

Incorporating environmental inspection and monitoring measures into the POD and other 

applicable plans to monitor water use during construction, operations, and decommissioning of 

the solar energy development, including adaptive management protocols.

Project developers shall avoid and/or minimize impacts on existing surface water features, including 

streams, reservoirs wetlands, floodplains, intermittent/ephemeral streams, and playas ( from the 

development in accordance with the following:
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

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 The Clean Water Act, including Sections 401, 402, and 404, addressing licensing and permitting 

issues;

Executive Orders (E.O.s) 11988 and 11990 of May 24, 1977, regarding floodplain and wetland 

management: E.O. 11988, “Floodplain Management” (Federal Register, Volume 42, page 26951 

[42 FR 26951]), and E.O. 11990, “Protection of Wetlands” (42 FR 26961);

EPA stormwater management guidelines and applicable State and local guidelines;

 Consultation with the USACE, in accordance with the 1987 wetlands delineation manual and 

appropriate regional supplement; avoidance, minimization and compensation proposals;

USACE permit, Nationwide verification, or other approved jurisdiction. This includes identification 

of a Least Environmentally Damaging Practicable Alternative within the environmental analysis. 

The USACE permit, Nationwide verification, or approved jurisdiction letter shall be provided to the 

BLM prior to a decision;

National Wild and Scenic Rivers System (Public Law 90-542; 16 United States Code [U.S.C.] 

1271 et seq.); and

Required Clean Water Act Section 303(d) identification of impaired surface water bodies.

Site Characterization, Siting and Design, Construction

Project developers shall minimize impacts on groundwater and surface water resources in 

accordance with the laws and policies above. Methods to minimize impacts on surface water and 

groundwater resources may include:

Reclaiming disturbed soils as quickly as possible.

Preventing the release of project waste materials into stormwater discharges.

Avoiding impacts on sole source aquifers according to EPA guidelines.

Developing measures to prevent potential groundwater and surface water contamination and 

incorporating them into the Spill Prevention and Emergency Response Plan and POD, as 

appropriate.

Minimizing land disturbance in ephemeral washes and playas. Stormwater facilities shall be 

designed to route flow through or around the facility using existing washes when feasible, instead 

of concrete-lined channels.

Designing culverts and water conveyances to comply with BLM, State, and local standards, or to 

accommodate the runoff of a 100-year storm, whichever is larger.

Designing stormwater retention and/or infiltration and treatment systems for storm events up to 

and including the 100-year storm event.

Utilizing geotextile matting to stabilize disturbed channels and stream banks.

Diverting worksite runoff from entering disturbed streams using earth dikes, swales, and lined 

ditches.

Placing sediment control devices so that sediment-laden water can pond, thus allowing sediment 

to settle out.

Considering placement of check dams (i.e., small barriers constructed of rock, gravel bags, 

sandbags, fiber rolls, or reusable products) across a swale or drainage ditch to reduce the 

velocity of flowing water.

Considering special construction techniques in areas of erodible soil, alluvial fans, and stream 

channel/wash crossings.

Backfilling foundations and trenches with originally excavated material.

Disposing of excess excavated material according to Federal and State laws.

Maintaining drilling fluids or cuttings in a manner so as not to contact aquatic habitats. Temporary 

impoundments for storing drilling fluids and cuttings shall be lined to minimize the infiltration of 

runoff into groundwater or surface water.

Avoiding washing equipment or vehicles in streams and wetlands.

Constructing entry and exit pits in work areas to trap sediments from vehicles so they do not enter 

streams at stream crossings.

Providing for periodic removal of wastewater generated in association with sanitary facilities by a 

licensed hauler.

Avoiding the creation of hydrologic conduits between two aquifers. 
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

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Using herbicides and pesticides within the framework of BLM and USDI policies and standard 

operating procedures, to include the use of only EPA-registered pesticides/herbicides that also 

comply with State and local regulations.

Transporting, storing, managing, and disposing of hazardous materials and vehicle/equipment 

fuels in accordance with accepted BMPs and in compliance with all applicable regulations, and 

where applicable, the SWPPP.

Operations and Maintenance

Compliance with the terms and conditions for water resource mitigation shall be monitored by the 

project developer. The developer shall consult with the BLM through operations and maintenance of 

the project, employing an adaptive management strategy and modifications, as necessary and 

approved by the BLM. Maintaining the water resources during operations and maintenance of the 

project shall include:

Monitoring water quantity and quality in areas adjacent to or downstream from development 

areas through the life of the project to ensure that water flows and water quality are protected.

Treating of sanitary and industrial wastewater either on-site or off-site to comply with Federal, 

State, and local regulations. Any discharges to surface waters would require National Pollutant 

Discharge Elimination System permitting. Any storage or treatment of wastewater on-site must 

use proper lining of holding ponds and tanks to prevent leaks.

Implementing monitoring using adaptive management strategies to ensure that long-term water 

use during operations does not substantially and disproportionately contribute to the long-term 

decline of groundwater levels or surface water flows and volumes, considering any mitigation 

measures that have been taken.

Reclamation and Decommissioning

Reclamation of the project site shall begin immediately after decommissioning to reduce the likelihood 

of water resource impacts from project activities. Developers shall coordinate with the BLM in 

advance of interim/final reclamation to have the BLM or other designated resource specialists on-site 

during reclamation to ensure water resource requirements and BMPs are implemented. Methods for 

minimizing water resource impacts associated with reclamation and decommissioning activities may 

include:

Restoring the project area to predevelopment water conditions or to the extent acceptable to the 

BLM.

Considering contouring of soil borrow areas, cut-and-fill slopes, berms, water bars, and other 

disturbed areas to approximate naturally occurring slopes.

Salvaging and reapplying topsoil from decommissioning activities during final reclamation. 

Continuing groundwater and surface water monitoring activities for a limited period of time, if 

appropriate given the specific situation.

Ecological Resources

Many BMPs are similar for different types of ecological resources (plant communities and habitats, 

wildlife, aquatic resources, and special status species). BMPs for avoiding or minimizing impacts on

ecological resources in general and during the various project phases are presented in the following 

sections. 

General

Project developers shall consult with the BLM and other Federal, State, and local agencies in the 

early phases of project planning to help ensure compliance with Federal regulations that address the 

protection of fish, wildlife, and plant resources, with appropriate Federal, State, and local agencies. 

Assessing compliance with pertinent regulations for ecological resources shall include, but is not 

limited to, the following:

Developing, in coordination with the BLM and US Fish and Wildlife Service (FWS), strategies for 

complying with regulatory requirements of the Bald and Golden Eagle Act.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Developing in coordination with appropriate Federal and State agencies (e.g., BLM, FWS, and 

State resource management agencies) measures to protect birds (including migratory species 

protected under the Migratory Bird Treaty Act).

Contacting appropriate agencies (e.g., BLM, FWS, and State resource management agencies) 

early in the project planning process to identify potentially sensitive ecological resources such as 

aquatic habitats, wetland habitats, unique biological communities, crucial wildlife habitats, and 

special status species locations and habitats located within or in the vicinity of the solar energy 

facility and associated access roads and ROWs.

Consulting with the USACE regarding the siting of solar energy generating facilities and energy 

transmission infrastructure in relation to hydrological features that have the potential to be subject 

to USACE jurisdiction. 

Considering restrictions on timing and duration of activities developed in coordination with the 

BLM, FWS, and other appropriate agencies to minimize impacts from project activities on nesting 

birds (especially passerines and listed species).

Considering recommendations contained in the Interim Golden Eagle Technical Guidance: 

Inventory and Monitoring Protocol and Other Recommendations in Support of Golden Eagle 

Management and Permit Issuance (Pagel et al., 2010).

Adhering to Instruction Memorandum 2010-156, the Bald and Golden Eagle Protection Act—

Golden Eagle National Environmental Policy Act and Avian Protection Plan Guidance for 

Renewable Energy, until programmatic permits from the FWS are available. The analysis of 

potential impacts on and mitigation for, golden eagles shall be made in coordination with the 

FWS. 

Avoiding take of golden eagles and other raptors. Mitigation regarding the golden eagle shall be 

developed in consultation with the FWS and appropriate State natural resource agencies. A 

permit may be required under the Bald and Golden Eagle Protection Act.

Methods to minimize impacts to ecological resources may include: 

Including submittal of a jurisdictional delineation for consultation with the USACE, in accordance 

with the 1987 wetlands delineation manual and appropriate regional supplement; avoidance, 

minimization and compensation proposals.

Developing measures to ensure protection of raptors in coordination with appropriate Federal and 

State agencies (e.g., BLM, FWS, and State resource management agencies).

Developing measures to ensure protection of bats in coordination with appropriate Federal and 

State agencies (e.g., BLM, FWS, and State resource agencies).

Developing measures to ensure mitigation and monitoring of impacts on special status species in 

coordination with appropriate Federal and State agencies (e.g., BLM, FWS, and State resource 

management agencies).

Consulting with the FWS upon discovery of Federally listed threatened and endangered species 

during any phase of the project. All applicable terms and conditions and conservation measures 

listed in the programmatic Biological Opinion, issued by the FWS, shall be followed.

Informing project personnel that only qualified biologists are permitted to handle listed species 

according to specialized protocols approved by the FWS. 

Considering plants, wildlife, and their habitats in the facility’s Dust Abatement Plan.

Limiting herbicide use to non-persistent, immobile substances. Only herbicides with low toxicity to 

wildlife and non-target native plants species shall be used, as determined in consultation with the 

FWS. Section 5.10.2.1.5 of the Draft Solar Energy Development Programmatic Environmental 

Impact Statement (BLM and DOE, 2010) discusses the potential impacts of herbicides on wildlife. 

All herbicides shall be applied in a manner consistent with their label requirements and in 

accordance with guidance provided in the Draft Programatic Environmental Impact Statement for 

Solar Energy Development in Six South Western States, (BLM and DOE, 2010) and the 

Programmatic Environmental Impact Statement Vegetation Treatments Using Herbicides on 

Bureau of Land Management Lands in 17 Western States (BLM, 2007d) using herbicides. Prior to 

application of herbicide treatments, a qualified person, such as a biologist, shall conduct surveys 

of bird nests and of special status species to identify the special measures or BMPs necessary to 

avoid and minimize impacts on migratory birds and special status species.

Developing a SWPPP for each project that avoids, to the extent practicable, changes in surface 

water or groundwater quality (e.g., chemical contamination, increased salinity, increased 
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

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temperature, decreased dissolved oxygen, and increased sediment loads) or flow that result in 

the alteration of terrestrial plant communities or communities in wetlands, springs, seeps, 

intermittent streams, perennial streams, and riparian areas (including the alteration of cover and 

community structure, species composition, and diversity) off the project site.

Utilizing block or check valves on both sides of the waterway or habitat to minimize product 

release from pipelines that transport hazardous liquids (e.g., oils) that pass through aquatic or 

other habitats. Such pipelines shall be constructed of double-walled pipe at river crossings.

Considering compensatory mitigation and monitoring of significant direct, indirect, and cumulative 

impacts on, and loss of habitat for, special status plant and animal species.

Incorporating key elements on the identification and protection of ecological resources (especially 

for special status species), including knowledge of required design features, in instructions to all 

personnel. Incorporate the knowledge into a worker education and awareness plan that is 

provided to all project personnel prior to entering the project worksite. 

Planning for vegetation management that is consistent with applicable regulations and agency 

policies for the control of noxious weeds and invasive plant species. 

Developing measures for fire management and protection that minimize the potential for a 

human- or facility-caused fire to affect ecological resources and that respond to natural fire 

situations.

Developing measures to investigate the possibility of revegetating parts of the solar array area.

Designating a qualified biologist who will be responsible for overseeing compliance with all design 

features related to the protection of ecological resources throughout all project phases, 

particularly in areas requiring avoidance or containing sensitive biological resources. This person 

shall be reviewed and approved by the FWS and the BLM for designation as a qualified biologist.

Conducting pre-construction surveys, in coordination with BLM, FWS, and State agency statutes, 

programs, and policies.

Conducting seasonally appropriate inspections by a qualified biologist or team of biologists to 

ensure that important or sensitive species or habitats are not present in or near project areas. 

Attendees at the inspections may include appropriate Federal agency representatives, State 

natural resource agencies, and construction contractors, as appropriate. Habitats or locations to 

be avoided shall be clearly marked.

Site Characterization, Siting and Design, Construction

Solar facilities shall be sited to avoid, minimize, or mitigate impacts on ecological resources. Methods 

to mitigate impacts on ecological resources include:

Siting and designing projects to avoid on important, sensitive, or unique habitats in the project 

vicinity, including, but not limited to waters of the United States, wetlands (both jurisdictional and 

non-jurisdictional), springs, seeps, streams (ephemeral, intermittent, and perennial), 100-year 

floodplains, ponds and other aquatic habitats, riparian habitat, crucial wildlife habitats, and 

habitats supporting special status species populations (including designated and proposed critical 

habitat).

Reducing the attractiveness of solar energy development and infrastructure areas to opportunistic 

predators such as desert kit fox, coyotes, and common ravens. Considering opportunities to 

upgrade or maintain crossings along existing facilities (e.g., roads) such that listed species 

occupancy and connectivity are not compromised.

Avoiding siting projects in designated critical habitat, Areas of Critical Environmental Concern, or 

other specially designated areas that are identified as necessary for special status species and 

habitat conservation.

Consider siting projects on previously disturbed lands in close proximity to energy load centers to 

avoid and minimize impacts on remote, undisturbed lands.

Designing project facilities to reduce the number of stream (e.g., access roads and utilities could 

share common ROWs, where feasible), and locating facilities in pre-disturbed areas to reduce 

potential for habitat fragmentation.

Preventing establishment and spread of invasive plant species and noxious weeds within the 

ROW. Developers should consider siting project facilities and activities, including associated 

roads and utility corridors, out of occupied habitats of special status animal species.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Coordinate with Federal and State agencies to translocate special status plants including longterm monitoring of populations at receptor sites to evaluate success. Considering conducting 

interim and final restoration activities as soon as possible after development activities are 

completed in order to reduce the amount of habitat converted at any one time and to speed up 

the recovery to natural habitats.

Implementing revegetation, soil stabilization, and erosion reduction measures to ensure 

temporary use areas are restored. 

Conducting a nesting bird survey or other necessary survey for nesting birds. If active nests are

detected, the nest area shall be flagged, and no activity shall take place near the nest (at a 

distance determined by the BLM in coordination with the FWS and/or appropriate State 

agencies), or until the appropriate agencies agree that construction can proceed with the 

incorporation of agreed-upon monitoring measures. 

To the extent practicable, avoiding entry into aquatic habitats, such as streams and springs, 

during site characterization activities until surveys by qualified biologists have evaluated the 

potential for unique flora and fauna to be present.

Locating and designing individual project facilities to minimize disruption of animal movement 

patterns and connectivity of habitats.

Avoiding surface water or groundwater withdrawals that adversely affect sensitive habitats (e.g., 

aquatic, wetland, playa, and riparian habitats) and habitats occupied by special status species.

Designing water intake facilities to minimize the potential for aquatic organisms from surface 

waters to be entrained in cooling water systems.

Demonstrating, through hydrologic modeling, that the withdrawals required for the project are not 

going to affect groundwater discharges that support special status species or their habitats.

Considering the use of fencing and netting for evaporation ponds to prevent their use by wildlife.

To the extent practicable, locating meteorological towers, solar sensors, soil borings, wells, and 

travel routes to avoid sensitive habitats or areas where wildlife (e.g., sage-grouse) is known to be 

sensitive to human activities.

To the extent practicable, avoiding siting solar power facilities near open water or other areas that 

are known to attract large numbers of birds.

 To the extent practicable, placing tall structures, such as meteorological towers and solar power 

towers, to avoid known flight paths of birds and bats.

Implementing current guidelines and methodologies in the design of proposed transmission 

facilities in order to minimize the potential for raptors and other birds to collide or be electrocuted 

by them.

Placing mechanisms to visually warn birds (permanent markers or bird flight diverters) on 

transmission lines at regular intervals to prevent birds from colliding with the lines.

Designing transmission line support structures and other facility structures to discourage use by 

raptors for perching or nesting (e.g., by using monopoles rather than lattice support structures or

by use of anti-perching devices).

Considering spanning important or sensitive habitats with transmission line conductors within the 

limits of standard structure design.

Using low-water crossings (fords) during the driest time of the year. Developers should consider 

using rocked approaches to fords and returning the crossing to pre-existing stream channel

conditions after the need for a low-water ford has passed.

Employing noise reduction devices (e.g., mufflers) to minimize the impacts on wildlife and special 

status species populations.

Explosives shall be used only within specified times and at specified distances from sensitive 

wildlife or surface waters as established by the BLM or other Federal and State agencies.

Minimizing the number of areas where wildlife could hide or be trapped (e.g., open sheds, pits, 

uncovered basins, and laydown areas). Trapping of special status species wildlife is prohibited

unless the animal is removed from the path of harmful activity. Trapped animals shall be released 

nearby in appropriate habitat. 

Implementing measures for proper trash removal and storage, such as using secured containers 

and periodic emptying, on the project site to reduce attractive opportunistic species, such as 

common ravens, coyotes, and feral cats and dogs.
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

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Constructing, improving, and maintaining access roads to minimize potential wildlife/vehicle 

collisions and facilitate wildlife movement through the project area.

Limiting project vehicle speeds and using shuttle vans and carpooling in areas occupied by 

special status animal species. Traffic shall yield to wildlife, allowing safe road crossing.

Utilizing existing access roads, utility corridors, and other infrastructure to the maximum extent 

feasible.

Locating staging and parking areas within the site of the utility scale solar energy facility to 

minimize habitat disturbance.

Considering rolled and compacted on-site construction access routes to allow trucks and 

equipment to access construction locations.

Minimizing vehicle use off of access roads and foot traffic through undisturbed areas.

Constructing fences (as practicable) to exclude livestock and wildlife from project facilities.

Prohibiting project personnel from bringing firearms and pets to project sites. 

Placing food refuse and other garbage in closed containers so it is not available to scavengers. 

Reducing the collection, harassment, or disturbance of plants, wildlife, and their habitats 

(particularly special status species) through employee and contractor education about applicable 

Federal and State laws.

Advising personnel to minimize stopping and exiting their vehicles in the winter ranges of large 

game while there is snow on the ground.

Coordinating with BLM and appropriate project personnel to handle unreasonable traffic delays 

caused by wildlife in roads. Utilizing appropriate personnel to move live, injured, or dead wildlife 

off roads, ROWs, or the project site.

Considering road closures or other travel modifications (e.g., lower speed limits, no foot travel) 

during crucial periods (e.g., winter conditions, calving/fawning seasons, raptor nesting).

Reporting any vehicle-wildlife collisions. Observations of potential wildlife problems, including 

wildlife mortality, shall be immediately reported to the BLM or other appropriate agency 

authorized officer.

Conducting pre-construction surveys by qualified personnel, such as a qualified biologist, in areas 

with potential to adversely affect special status species.

Considering the number of qualified biological monitors (as determined by the Federal authorizing 

agency and FWS) to be on-site during initial site preparation and during the construction period to 

monitor, capture, and relocate animals that could be harmed and are unable to leave the site on 

their own.

Relocating wildlife found in harm’s way from the area of the activity. Qualified personnel shall be 

required to relocate some animals such as rattlesnakes.

Establishing a controlled inspection and cleaning area to visually inspect construction equipment 

arriving at the project area and to remove and collect seeds that may be adhering to tires and 

other equipment surfaces.

To the extent practicable, avoiding placement of transmission towers within aquatic and wetland 

habitats, or other sensitive habitats such as riparian habitats. If towers must be placed within 

these habitats, they shall be designed and installed to not impede flows or fish passage.

Designing necessary stream crossings to provide in-stream conditions that allow for and maintain 

uninterrupted movement and safe passage of fish during all project periods.

Considering cutting trees in stream buffers that are able to grow into a transmission line 

conductor clearance zone within three to four years.

Considering the use of helicopters where access roads do not exist or where access roads could 

not be constructed without significantly impacting habitats.

Operations and Maintenance

The developer shall manage vegetation utilizing the principles of integrated pest management, 

including biological controls to prevent the spread of invasive species, per the Vegetation Treatments 

Using Herbicides on BLM Lands in 17 Western States, (BLM, 2007d) and the National Invasive 

Species Management Plan (National Invasive Species Council, 2009). Consultation with the BLM 

shall be maintained through operations and maintenance of the project, employing an adaptive 

management strategy and modifications, as necessary and approved by the BLM. Methods to 
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

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manage vegetation, including controlling for noxious weeds and invasive plant species, during 

operations and maintenance of the project may include, but are not limited to, the following:

Using certified weed-free seed and mulching.

Cleaning vehicles to avoid introducing noxious weeds and invasive plants.

Educating project personnel on noxious weed identification, the manner in which weeds spread, 

and methods for treating infestations.

Considering periodic monitoring, reporting, and immediate eradication of noxious weed or 

invasive plants occurring within the ROW. 

Limiting vegetation maintenance and performing maintenance mechanically rather than with 

herbicides.

Considering retaining short (i.e., less than 7-in. (18-cm) tall) native species during maintenance 

and operation activities. 

Reducing risk of non-native, invasive and nuisance species introductions. Developers should 

decontaminate equipment used in surface water, especially equipment used to convey water (i.e., 

pumps).

Monitoring for and eradicating non-native, invasive plants. 

Reestablishing vegetation within temporarily disturbed areas immediately following the 

completion of construction activities.

Focusing revegetation efforts on the establishment of native plant communities similar to those 

present in the vicinity of the project site. Considering dominant native species within the plant 

communities that exist in adjacent areas and have similar soil conditions for revegetation.

The developer shall, in consultation with the BLM and appropriate Federal, State, and local agencies, 

manage projects so as to minimize impacts on ecological resources during operations and 

maintenance of the project, employing an adaptive management strategy and modifications, as 

necessary and approved by the BLM. Methods to minimize impacts on ecological resources during 

operations and maintenance of the project shall include, but are not limited to, the following:

Monitoring for increase in predation of special status species (e.g., greater sage-grouse) from 

ravens and other species that are attracted to developed areas and use tall structures 

opportunistically to spot vulnerable prey.

Turning off all unnecessary lighting at night to limit attracting wildlife, particularly migratory birds.

Monitoring for and reporting bird mortality species (e.g., raptors) that are associated with power 

lines to the BLM and the FWS. 

Monitoring for the effects of groundwater withdrawals on plant communities.

Monitoring unavoidable impacts on wetlands and waters of the United States.

Removing raptor nests only if the birds are not actively using the nest.

Considering relocating nests to nesting platforms. Report on relocated or destroyed nests to the

appropriate Federal and/or State agencies.

Coordinating with the FWS and BLM project personnel in the event that a raptor nest is located 

on a transmission line structure.

Remove raven nests when inactive (i.e., no eggs or young). 

Minimizing removal of deadfall or overhanging vegetation in streams for crossings.

Installing fish screens on cooling water intakes to limit the potential for impingement impacts on 

organisms in surface water sources used for cooling water. 

Maintaining areas left in a natural condition during construction (e.g., wildlife crossings) in as 

natural a condition as possible within safety and operational constraints.

Avoiding use of guy wires to minimize impacts on birds and bats. If guy wires are necessary, 

permanent markers (e.g., bird flight diverters) shall be used to increase their visibility.

Maintaining native vegetation cover and soils and minimizing grading.

Instructing personnel to avoid harassment and disturbance of local plants and wildlife.

Informing personnel of the potential for wildlife interactions around facility structures.

Reclamation and Decommissioning

Reclamation of the project site shall begin immediately after decommissioning to reduce the likelihood 

of resource impacts in disturbed areas as quickly as possible. Addressing resource impacts during 

reclamation and decommissioning may include, but is not limited to, the following:
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

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Applying design features developed for the construction phase to similar activities during the 

decommissioning and reclamation phase.

Developing and implementing a Decommissioning and Site Reclamation Plan specific to the 

project, approved by the BLM in consultation with appropriate agencies, that incorporates 

adaptive management strategies.

Using weed-free seed mixes of, grasses, forbs, and native shrubs of local sources where 

available.

Developing and implementing monitoring measures to ensure successful reclamation.

Lightly raking and/or ripping and reseeding with seeds from low stature plant species collected 

from the immediate vicinity in disturbed areas.

Reclaiming access roads when they are no longer needed, considering seasonal restrictions.

Filling or grading holes and ruts created by the removal of structures and access roads.

Considering maximizing area reclaimed during solar energy operations to minimize habitat loss 

and fragmentation.

Maintaining a clean and orderly worksite during and after decommissioning to ensure land is clear 

of debris.

 Returning land surfaces to pre-development contours immediately following decommissioning.

Expediting the reestablishment of vegetation for site stabilization.

Continuing vegetation reestablishment efforts until all success criteria have been met.

Focusing revegetation on the establishment of native plant communities similar to those present 

in the vicinity of the project site. Considering dominant native species within the plant 

communities that exist in adjacent areas and have similar soil conditions for revegetation.

Leaving the facility fencing in place for several years, or replacing it with new exclusion fencing, to 

assist reclamation (e.g., the fence could preclude large mammals and vehicles from disturbing 

revegetation efforts). Shorter times for maintaining fencing may be appropriate in cases where 

the likelihood of disturbance by cattle and wildlife is low.

Air Quality and Climate

General

Project developers shall consult with the BLM in the early phases of project planning to help 

determine the potential conformance to air quality and other potential constraints. Assessing 

conformance to air quality and other related constraints may include the following:

Identify air quality and other related constraints associated with the project site. In coordination 

with BLM, the appropriate State and local air regulatory authorities shall be consulted to identify 

air quality and related constraints and requirements.

Minimize the PM10 and PM2.5 particulate matter from the solar energy project and its facilities.

Site Characterization, Siting and Design, Construction

Solar facilities shall be sited to minimize impacts on air quality. Methods to minimize air quality 

impacts shall include:

Use equipment that meets emission standards specified in the State code of regulations and 

meets the applicable EPA Tier 3 (motor vehicle emission and fuel) and Tier 4 (nonroad diesel 

engines) emissions requirements.

The Dust Abatement Plan for the solar facilities may use multiple methods for dust suppressant 

(i.e., water, paving, gravel, and/or regulation-compliant palliatives).

Other methods to minimize air quality impacts and related constraints may include:

 Surfacing access roads with aggregate that is hard enough that vehicles cannot crush it.

Manage unpaved roads, disturbed areas (e.g., areas of scraping, excavation, backfilling, grading, 

and compacting), and loose materials generated during project activities as frequently as 

necessary to effectively minimize fugitive dust generation.

Use machinery that has air-emission-control devices as required by Federal, State, and local 

regulations or ordinances.

Limit travel to stabilized roads.

Considerpaving the main access road to the main power block and the main maintenance 

building.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Post and enforce speed limits (e.g., 10 mph [16 km/h]) within the construction site to minimize 

airborne fugitive dust.

Cover vehicles that transport loose materials as they travel on public roads, using dust 

suppressants on truck loads, and keeping loads below the freeboard of the truck bed.

Install wind fences around disturbed areas that could affect the area beyond the site boundaries 

(e.g., nearby residences).

Suspend soil disturbance activities and travel on unpaved roads during periods of high winds. 

Site-specific wind speed thresholds shall be determined on the basis of soil properties determined 

during site characterization.

Plant compatible native vegetative to limit dust generation from stockpiles that will be inactive for 

a relatively long period.

To the extent practicable, avoid chemical dust suppressants that emit volatile organic compounds 

within or near ozone non-attainment areas.

 Use of ultra-low sulfur diesel with a sulfur content of 15 parts per million or less for project 

vehicles.

Limit idling time of equipment to no more than five minutes, unless idling must be maintained for 

proper operation (e.g., drilling, hoisting, and trenching).

Minimize use of dust palliatives in areas of close proximity to sensitive soil and streams.

Access transmission lines from public roads and designated routes to minimize fugitive dust 

emissions.

Minimize on-site vehicle use and require routine preventive maintenance, including tune-ups to 

meet the manufacturer’s specifications, to ensure efficient combustion and minimal emissions.

Encourage use of newer and cleaner equipment that meets more stringent emission controls.

Limit access to the construction site and staging areas to authorized vehicles only through the 

designated treated roads.

 Schedule construction to limit the areas with exposed soil at any time.

 Inspect and clean the tires of all construction related vehicles to ensure they are free of dirt before 

they enter paved public roadways.

Clean up visible track-out or runoff dirt on public roadways resulting from the construction site 

(e.g., street vacuum/ sweeping).

Salvage topsoil from all excavations and construction activities during reclamation or interim 

reclamation and reapply and seed topsoil atconstruction areas not needed for facility operation as 

soon as activities in that area have ceased.

Consider atmospheric conditions when planning construction activities to minimize dust.

To the extent practicable, avoid ground disturbance from construction-related activities in areas 

with intact biological soil crusts and desert pavement. Developers should salvage soil crusts for 

restoration, on the basis of recommendations by the BLM once construction has been completed.

Incorporate environmental inspection and monitoring measures into the Plan of Development and 

other relevant plans to monitor and respond to air quality during construction, operations, and 

decommissioning of a solar energy development, including adaptive management protocols.

Operations and Maintenance

Compliance with the terms and conditions for air quality shall be monitored by the project developer. 

Consultation with BLM shall be maintained through operations and maintenance of the project, 

employing an adaptive management strategy and modifications, as necessary and approved by the 

BLM. Methods for maintaining compliance with the terms and conditions for air quality during 

operations and maintenance may include:

Monitoring and treating areas that have been graded, scraped, bladed, compacted, or denuded of 

vegetation ahead of actual construction/assembly.

Reapply palliatives or water as necessary to effectively manage fugitive dust.

Use dust abatement on the portions of facilities maintained free of vegetation during operations to

limit fugitive dust from bare surfaces and unpaved access roads.

 Combustion sources would comply with State emission standards.
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Reclamation and Decommissioning

Reclamation of the site shall incorporate the BMPs listed above for construction to reduce air quality 

impacts associated decommissioning.

Visual Resource Management 

General

Project developers shall consult with the BLM in the early phases of project planning to help 

determine the proposed project’s potential conformance to Visual Resource Management (VRM) 

class designations and other potential constraints, thus avoiding costly unforeseen planning 

implications and re-design. Assessing conformance to VRM class designations and identifying visual 

resource conflicts shall include:

Consulting with the appropriate BLM field office for VRM class designations and associated 

management objectives during the early phases of project planning, including those related to 

project site selection, planning, and design. 

Analyzing how the visual values influence project design and how the impacts on these values 

will be minimized through consideration for the proposed project location and its relationship to 

the surrounding viewshed.

Including a qualified professional, such as a landscape architect, with demonstrated experience 

of the BLM’s VRM policies and procedures as part of the developer’s and the BLM’s respective 

planning teams, to evaluate visual resource issues as project siting options are considered.

Consulting with the locally based public to provide input on identifying important visual resources 

in the project area and on the siting and design process. The public shall be involved and 

informed about the visual site design elements of the proposed solar energy facilities.

Consult on viewshed protection objectives and practices with the respective land management

agencies for landscapes having special designations, such as Wilderness Areas, National Scenic 

and Historic Trails, Wild and Scenic Rivers, and National Parks located within the project’s 

viewshed. Developers shall demonstrate a concerted effort to reconcile conflicts while 

recognizing that the BLM retains authority for final decisions for project approval and stipulations. 

For applications that include artifacts and remnants of a National Historic Trail, are located within 

the viewshed of a National Historic Trail’s designated centerline, or include or are within the 

viewshed of a trail eligible for listing on the the National Register of Historic Places by virtue of its 

important historical or cultural values and integrity of setting. Mitigate adverse effects to the 

potential visual impacts on the trail associated with the proposed project through the Section 106 

consultation process. 

 Landscape settings observed from a unit of the National Park system, National Historic Trail, and 

cultural resources of tribal concern may be a part of the historic context contributing to the historic 

significance of the site or trail.

Project developers are encouraged to obtain topographical data of engineering-design quality and 

use digital terrain mapping tools at a landscape-viewshed scale for project location selection, site 

planning and design, visual impact analysis, and visual impact mitigation planning and design. 

The digital terrain mapping tools shall be at a resolution and contour interval suitable for site 

design and accurate placement of proposed developments into the digital viewshed. Visual 

simulations shall be prepared and evaluated in accordance with BLM Handbook H-8431-1 and 

other agency directives, to create spatially accurate and realistic depictions of the appearance of 

proposed facilities. Simulations shall depict proposed project facilities from Key Observation 

Points (KOPs) and other visual resource sensitive locations.

Conduct public outreach to disseminate visual resource information through methods such as 

offering organized tours of operating solar energy development projects, and using simulations in 

public presentations.

Performing visual mitigation planning and design through field assessments, applied global 

positioning system technology, photo documentation, use of computer-aided design and 

development software, three-dimensional geographic information system modeling software, and 

imaging software to depict visual simulations to reflect a full range of visual resource mitigation 

measures.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

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Site Characterization, Siting Design, and Construction

Solar facilities shall minimize glint and glare. Identification of glint and glare effects shall include, but 

is not limited to, the following:

Assessing and quantifying potential glint and glare effects and determining the potential safety 

and visual impacts associated with glint and glare using appropriate and commonly accepted 

software, procedures, and past project examples.

Having qualified individuals conduct assessments for glint and glare.

Methods to minimize glint and glare effects may include, but are not limited to, the following:

Limiting use of signs and project construction signs. Beyond those required for basic facility and 

company identification for safety, navigation, and delivery purposes, commercial symbols or signs 

and associated lighting on buildings and other structures should be prohibited.

Utilizing retro-reflective or luminescent markers in lieu of permanent lighting.

Minimizing off-site visibility of all commercial symbols and signs and associated lighting. 

Necessary signs should be made of non-glare materials and utilize unobtrusive colors. The 

reverse sides of signs and mounts should be painted or coated using a suitable color selected 

from the BLM Standard Environmental Color Chart to reduce contrasts with the existing 

landscape. However, placement and design of any signs required by safety regulations must 

conform to regulatory requirements.

Considering off-site mitigation of visual impacts. In some situations, off-site mitigation may serve 

as a means to offset and/or recover the loss of visual landscape integrity. For example, off-site 

mitigation could include reclaiming unnecessary roads, removing abandoned buildings, 

reclaiming abandoned mine sites, putting utility lines underground, rehabilitating and revegetating 

existing erosion or disturbed areas, or establishing scenic conservation easements. Appropriate 

off-site mitigation will be determined on a project specific basis in consultation with the BLM.

Solar facilities shall minimize night-sky effects. Identification of night-sky effects shall include, but is 

not limited to the following:

Assessing and quantifying potential lighting impacts on the night sky and nocturnal wildlife, while 

providing lighting for hazard marking, safety, and other necessary site needs.

Conducting assessments for night-sky effects by qualified individuals using appropriate and 

commonly accepted procedures and past project examples.

Methods to minimize night-sky effects may include, but are not limited to, the following:

Using minimum intensity lighting that meets safety criteria. When accurate color rendition is not 

required (e.g., roadway, basic security), lighting shall be amber in color, using low pressure 

sodium lamps, yellow LED lighting, or equivalent. When white light is required for accurate color 

rendition, it shall be equal to or less than 3500° Kelvin color temperature. Bluish white lighting is 

discouraged.

Prohibiting the use of red or white strobe lighting unless the BLM approves its use because of 

conflicting mitigation requirements.

Fully shielding all permanent lighting (e.g., full cut-off), except for collision markers required by 

the FAA or other emergency lighting triggered by alarms.

Mount lighting so that no light is emitted above an imaginary horizontal plane through the fixture.

Considering lighting control through timers, sensors, dimmers, or switches that are available to 

facility operators.

Considering vehicle-mounted lights over permanently mounted lighting for nighttime maintenance 

activities. When possible, such vehicle-mounted lighting shall be aimed toward the ground to 

avoid causing glare and skyglow.

The siting and design of solar facilities, structures, roads, and other project elements shall explore 

and document design considerations for reducing visual dominance in the viewshed and shall comply 

with the VRM class objectives above. Assessing visual dominance shall include, but is not limited to, 

the following:

Conforming with VRM class objectives through the use of the BLM contrast rating procedures 

defined in BLM Handbook H-8431-1. Visual contrast rating mitigation of visual impacts shall abide 

by the requirements outlined in the handbook and other BLM directives. Revised project plans 

and simulations are to be reevaluated by using the contrast rating procedures.
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Selecting KOPs by first determining the extent of the viewshed using the viewshed modeling tools 

previously cited above. The viewshed modeling shall illustrate the areas from which the proposed 

facilities may be seen out to 25 miles (40 km). From within the areas, KOPs are to be selected at 

places where people would be expected: scenic overlooks, roads, trails, campgrounds, 

recreationally active river corridors, residential areas, etc. For the purpose of conducting a visual 

contrast rating evaluation, the number of KOPs would be reduced to those that serve as the best

representations for demonstrating conformance to the respective VRM class objectives. The BLM 

is consulted on the KOP selections, and reserves the right to require additional KOPs to further 

determine the extent of visual impacts and conformance to VRM class objectives.

Integrating visual design elements into the construction plans, details, drawings, and 

specifications for the project.

Incorporating facility siting measures to minimize the profile of all facility-related structures to 

reduce visibility and visual dominance within the viewshed, particularly for facilities proposed 

within the foreground/middleground distance zone (0–5 miles [0–8 km]) of sensitive viewing 

locations.

Measures to minimize visual dominance may include, but are not limited to, the following:

Using existing topography and vegetation as screening or partially screening devices.

Incorporating visual design elements when planning for grubbing and clearing, vegetation 

thinning and clearing, grading, revegetation, drainage, and structural measures.

Minimizing visual dominance of projects by siting projects outside the viewsheds of KOPs or by 

diminishing dominance through maximizing visible separation with distance.

Avoiding, when feasible, locating facilities near visually prominent landscape features (e.g., knobs 

and waterfalls) that naturally draw an observer’s attention.

Avoiding visual “skylining” by placing structures, transmission lines, and other facilities away from 

ridgelines, summits, or other locations where they would silhouette against the sky from important 

viewing locations; however, consideration should be given to the potential for increased ground 

disturbance and other resource impacts.

Designing linear features (e.g., ROWs and roads) to follow natural land contours rather than 

straight lines; however, consideration should be given to the potential for increased ground 

disturbance and other resource impacts.

Locating linear developments (e.g., transmission lines, pipelines, roads) at the edges of natural 

clearings or natural lines of transition between vegetation type and topography.

Considering alternative means of access in visually sensitive areas, to preserve the natural 

landscape conditions between tower locations.

Minimizing vegetation and ground disturbance, and taking advantage of existing clearings where 

feasible.

Reducing cut and fill for structures and roads by design and location. Retaining walls, binwalls, 

half bridges, etc., can be used to reduce cut and fill.

Considering rounded and varied road-cut slopes and the cut-and fill pitches to reduce contrasts in 

form and line; encouraging slope cuts to preserve specimen trees and nonhazardous rock 

outcroppings.

Considering sculpting and shaping natural or previously excavated bedrock landforms when 

excavation of these landforms is required. For example, percent backslope, benches, and vertical 

variations may be integrated into a final landform that repeats the natural shapes, forms, textures, 

and lines of the surrounding landscape. The earthen landform may be integrated and transitioned 

into the excavated bedrock landform. Sculpted rock face angles, bench formations, and 

backslope could adhere to the natural bedding planes of the natural bedrock geology. The color 

contrast from the excavated rock faces may be removed by color treating with a rock stain. Native 

vegetation or a mix of native and non-native species (if necessary to ensure successful 

revegetation) could be reestablished with the benches and cavities created within the created 

bedrock formation.

Designing and installing natural-looking earthwork landforms, or vegetative or architectural 

screening to minimize visual impacts. Considering shape and height of earthwork landforms for 

adaptation to the surrounding landscape.

Repeating the size, shape, and characteristics of naturally occurring openings in vegetation for 

facilities, structures, roads, etc.
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Burying electrical collector lines, pipelines, and communication and local utility lines to minimize 

additional surface disturbance where feasible (e.g., along roads or other paths of surface 

disturbance).

Minimizing visual impacts associated with solar energy and electricity transmission projects by 

choosing appropriate building and structural materials and surface treatments (i.e., paints or 

coatings designed to reduce contrast and reflectivity). A careful study of the site should be 

performed to identify appropriate colors and textures for materials; both summer and winter 

appearance shall be considered, as well as seasons of peak visitor use. Materials and surface 

treatments shall repeat and/or blend with the existing form, line, color, and texture of the 

landscape.

Considering the typical viewing distances and landscape when choosing colors. Appropriate 

colors for smooth surfaces often need to be two to three shades darker than the background color 

to compensate for shadows that darken most textured natural surfaces. The BLM Standard 

Environmental Color Chart CC-001 and guidance shall be referenced when selecting colors.

Selecting appropriately colored materials for structures, or stains/coatings to blend with the 

project’s backdrop. Materials, coatings, or paints having little or no reflectivity shall be used 

whenever possible.

Color treating solar panel/mirror/heliostat backs/supports to reduce visual contrast with the 

landscape setting.

Color treating solar towers to reduce visual contrast.

Considering multiple-color camouflage technology application projects within sensitive viewsheds 

and with a visibility distance that is between 0.25 and two miles (0.40 and 3.20 km).

Matching aboveground pipelines’ paint or coating to their surroundings.

Considering the appropriate choice of monopoles versus lattice towers for a given landscape 

setting to further reduce visual impacts.

Utilizing non-specular conductors and non-reflective coatings on insulators for electricity 

transmission/distribution projects.

Minimizing the use of signs. Where signs are necessary, they shall be made of non-glare 

materials and utilize unobtrusive colors. The reverse sides of signs and mounts shall be painted 

or coated by using the most suitable color selected from the BLM Standard Environmental Color 

Chart; however, placement and design of any signs required by safety regulations must conform 

to regulatory requirements.

Clearly delineating construction boundaries and minimizing areas of surface disturbance; 

preserving vegetation to the greatest extent possible; utilizing undulating surface disturbance 

edges; stripping, salvaging, and replacing topsoil; using contoured grading; controlling erosion; 

using dust suppression techniques; and stabilizing exposed soils.

Preserving existing rocks, vegetation, and drainage patterns to the maximum extent possible.

Employing brush-beating, mowing, or the use of protective surface matting rather than removing 

vegetation.

Considering mulching and spreading slash from vegetation removal over fresh soil disturbances.

Avoiding leaving slash piles in sensitive viewing areas.

Considering restoration of disturbed soils by use of weed-free native grasses, forbs, and shrubs 

representative of the surrounding and intact native vegetation composition and/or using nonnative species, if necessary, to ensure successful revegetation.

Reducing the visual color contrast of graveled surfaces with approved color treatment practices.

Considering segregating and spreading topsoil from cut-and-fill activities on freshly disturbed 

areas to reduce color contrast.

Avoiding leaving topsoil piles in sensitive viewing areas.

Spreading excess cut and fill material within project disturbance area and vegetate per approved 

restoration plan requirements while maintaining natural drainage pathways. Where soil cannot 

reasonably be spread within project disturbance areas, excess cut-and-fill materials should be 

hauled out to minimize ground disturbance and impacts from piles.

Removing stakes and flagging from the construction area after completion of construction.

Project developer shall perform a pre-construction meeting with BLM or their designated visual/scenic 

resource specialists, such as a landscape architect, to coordinate the project construction VRM 

mitigation strategy. Final design and construction documents will be reviewed with regard to the 
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visual mitigation elements, assuring that requirements and commitments are adequately addressed.

The review of construction documents will include, but not be limited to, grading, drainage, 

revegetation, vegetation clearing, and feathering.

Operations and Maintenance

Compliance with the terms and conditions for VRM mitigation shall be monitored by the project 

developer. Consultation with the BLM shall be maintained through operations and maintenance of the 

project, employing an adaptive management strategy and modifications, as necessary and approved 

by the BLM. Maintaining the visual resource design elements during operations and maintenance 

shall include, but is not limited to, the following:

Maintaining revegetated surfaces until a self-sustaining stand of vegetation is reestablished and 

visually adapted to the undisturbed surrounding vegetation. No new disturbance shall be created 

during operations without completion of a VRM analysis and approval by the BLM authorized 

officer.

Keeping painted and color-treated facilities in good repair and repainting when the color fades or 

flakes.

Using interim restoration during the operating life of the project as soon as possible after land 

disturbances.

Including dust abatement and noxious weed control in maintenance activities.

Deploying and operating mirrors/heliostats to avoid high intensity light (glare) reflected off-site. 

Where off-site glare is unavoidable and project site/off-site spatial relationships favor effective 

results, fencing with privacy slats or similar screening materials should be considered.

Reclamation and Decommissioning

Reclamation of the construction site shall begin immediately after construction to reduce the 

likelihood of visual contrasts associated with erosion and invasive weed infestation and to reduce the 

visibility of temporarily disturbed areas as quickly as possible. Developers shall coordinate with BLM 

in advance of interim/final reclamation to have BLM or other designated visual/scenic resource 

specialists, such as a landscape architect, on-site during reclamation to work on implementing visual 

resource requirements and BMPs. Methods for minimizing visual contrast associated with reclamation 

and decommissioning of the project may include, but are not limited to, the following:

Including treatments, such as thinning and feathering vegetation along project edges, enhanced 

contour grading, salvaging landscape materials from within construction areas, special 

revegetation requirements (e.g., use of mix of native and non-native species).

Designing and implementing restoration of the project area to predevelopment visual conditions 

and the inventoried visual quality rating, or to that of the surrounding landscape setting conditions 

to the best extent possible or to conditions agreed upon by the BLM.

Removing aboveground and near-ground-level structures. Some structures may need to be 

removed to a level below the ground surface to allow reclamation/restoration.

Considering contouring soil borrow areas, cut-and-fill slopes, berms, water bars, and other 

disturbed areas to approximate naturally occurring slopes. Contouring to a rough texture would 

trap seeds and discourage off-road travel, thereby reducing associated visual impacts. Cut slopes 

can be randomly scarified and roughened to reduce texture contrasts with existing landscapes 

and aid in revegetation.

Utilizing native vegetation to establish a composition consistent with the form, line, color, and 

texture of the surrounding undisturbed landscape.

Reapplying stockpiled topsoil to disturbed areas, where applicable, or using a mix of native and 

non-native species if necessary to ensure successful revegetation.

Removing or burying gravel and other surface treatments.

Restoring rocks, brush, and forest to approximate pre-existing visual conditions.

Integrating feathering edges of vegetation to reduce form and line contrasts with the existing 

landscapes.
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Noise

General

Project developers shall consult with the BLM in the early phases of project planning to assess and 

minimize the proposed project’s noise impacts on sensitive noise receptors. Assessing noise impacts 

may include, but is not limited to:

Measuring the existing background ambient sound levels both within and outside the project site 

and comparing these with the anticipated noise levels proposed at the facility. Nearby residences 

and likely sensitive human and important wildlife habitat areas (leks, sage-grouse nesting areas, 

big game winter range) shall be identified.

Site Characterization, Siting and Design, Construction

The siting and design of solar facilities, structures, roads, and other project elements shall seek to 

minimize impacts on sensitive noise receptors. Methods to minimize project impacts on sensitive 

noise receptors may include:

Enclose noisy equipment.

Post warning signs at high-noise areas and implement a hearing protection program for work 

areas with noise in excess of 85 Decibel A.

Implement a noise complaint process and hotline, including documentation, investigation, 

evaluation, and resolution of legitimate project-related noise complaints.

Maintain project equipment in accordance with manufacturers’ specifications. For example, 

suitable mufflers and/or air-inlet silencers shall be installed on all internal combustion engines and 

certain compressor components. 

Limit low-altitude (under 1,500 feet [457 m]) helicopter flights to install transmission lines near 

noise-sensitive locations where only helicopter activities can perform the installation.

Schedule construction to minimize disruption to nearby residents and existing operations 

surrounding the project areas.

 Noisy construction activities near sensitive receptors would take place during the least noisesensitive times of day (i.e., daytime between 7 a.m. and 7 p.m.), and on weekdays.

Schedule individual noisy activities to occur at the same time to reduce the frequency of site 

boundary noise.

Implement noise control measures (e.g., erection of temporary wooden noise barriers) where 

activities are expected near sensitive receptors.

Notify nearby residents in advance of noisy activities, such as blasting or pile driving, before and 

during the construction period.

Site immobile construction equipment (e.g., compressors and generators) away from nearby 

residences and other sensitive receptors to the extent practicable. 

Site permanent sound-generating facilities (e.g., compressors, pumps) away from residences and 

other sensitive areas to the extent practicable. Acoustic screening may be required.

Use low-noise systems (e.g., for ventilation systems, pumps, generators, compressors, and fans) 

and equipment without prominent discrete tones.

Install louvered side(s) of wet cooling tower(s) away from sensitive receptors. Noise impacts may 

be further reduced by selecting quieter fans and fans that operate at a lower speed, particularly if 

they operate at night. Silencers on fan stacks may also be used.

Reduce potential noise impacts by taking advantage of existing topography and distances, 

constructing engineered sound barriers and/or berms, or sound insulated buildings. 

 Monitor and respond to noise impacts during construction, operations, and decommissioning of a 

solar energy development, including adaptive management protocols.

Operations and Maintenance

Compliance with the terms and conditions for noise shall be monitored by the project developer. 

Consultation with the BLM shall be maintained through operations and maintenance of the project, 

employing an adaptive management strategy and modifications as necessary and approved by the 

BLM. Methods for maintaining compliance with the noise design elements during operations and 

maintenance may include:
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Manage cooling systems and dish engine technology so that noise levels at the nearest 

residences and sensitive receptor areas to the facility boundary are kept within applicable 

guidelines.

Reduce vehicle noise within and around the project area with posted speed limits.

Schedule activities to minimize disruption to nearby residents and existing operations surrounding 

the project areas.

Notify nearby residents in advance of noisy activities, such as blasting or pile driving, before and 

during the site reclamation and decommissioning.

Monitor and minimize to the extent practicable transformer noise levels. Install of new 

transformers with reduced flux density or construct a barrier walls, partial enclosures, or full 

enclosures to shield or contain the noise.

Reclamation and Decommissioning

Reclamation of the construction site shall minimize the project’s noise impacts on sensitive noise 

receptors.

Paleontological Resources

General

Project developers shall coordinate with the BLM early in the project planning process to identify and 

minimize impacts on paleontological resources. Identifying paleontological resources shall include the 

following:

Determining in coordination with the BLM whether paleontological resources exist in a project 

area.

Determining the potential presence of paleontological resources on the basis of the following: the 

sedimentary context of the area and its potential to contain paleontological resources (potential 

fossil yield classification class); a records search of published and unpublished literature for past 

paleontological finds in the area; coordination with paleontological researchers working locally in 

potentially affected geographic areas and geologic strata; and/or depending on the extent of 

existing information, the completion of a paleontological survey.

Methods to minimize impacts on paleontological resources may include, but are not limited to, the 

following:

Instituting training/education programs in the worker education and awareness plan, to reduce the 

amount of inadvertent destruction to paleontological sites. Project-specific management practices 

shall be established in coordination with the BLM, incorporating BLM Instruction Memorandum

2009-011.

Planning for management and mitigation of paleontological resources of the project area for 

areas of known presence or high potential of presence.

Identifying measures to prevent potential looting/vandalism or erosion impacts and addressing 

the education of workers and the public to make them aware of the consequences of 

unauthorized collection of fossils on public land.

Incorporating environmental inspection and monitoring measures into Plans of Development and 

other relevant plans to monitor and respond to paleontological resource impacts during 

construction, operations, and decommissioning of a solar energy development, including adaptive 

management protocols.

Site Characterization, Siting and Design, Construction

Project developers should use a qualified paleontological monitor during excavation and earthmoving 

activities in areas with high potential for paleontological resources.

Project developers shall notify the BLM immediately upon discovery of fossils. Work shall be halted at 

the fossil site and continued elsewhere until qualified personnel, such as a paleontologist, can visit 

the site, determine the significance of the find, and, if significant, make site specific recommendations 

for collection or other resource protection. The area of the discovery shall be protected to ensure that 

the fossils are not removed, handled, altered, or damaged until the site is properly evaluated and 

further action determined.
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Cultural Resources

General

Project developers shall coordinate with the BLM early in the planning process to identify and 

minimize cultural resource impacts; the BLM will consult with other Tribal, Federal, State, and local 

agencies as appropriate. Determining cultural resource impacts shall include the following:

Initiating National Historic Preservation Act, Section 106 consultations between the BLM, State 

Historic Preservation Officer (SHPO), Indian tribes, and other consulting parties early in the 

project planning process. 

Conducting site-specific Section 106 review for individual projects. The BLM will require the 

completion of inventory, evaluation, determinations of effect, and treatment in accordance with 

the National Programmatic Agreement and appropriate State protocol agreements. 

General methods to minimize cultural resource impacts may include the following:

If historic properties that could be adversely affected are present in the project location, 

developing a Memorandum of Agreement to address the mitigation steps that will be followed to 

avoid, minimize, or mitigate adverse effects on historic properties.

Where the BLM determines that a specific proposed solar energy project has the potential to 

adversely affect historic properties but those effects cannot be determined prior to its approval, 

the BLM may elect to review a proposed solar energy project using an undertaking-specific 

Programmatic Agreement (PA) executed pursuant to 36 CFR 800.6.

Using training/educational programs for solar company workers to reduce occurrences of 

disturbances, vandalism, and harm to nearby historic properties. The specifics of these sensitivity 

training programs shall be established in project-specific consultations between the applicant, 

BLM, SHPO, and affected Indian tribes. 

Securing a performance and reclamation bond for all solar energy generation facilities to ensure 

compliance with the terms and conditions of the ROW authorization. When establishing bond 

amounts and conditions, the BLM authorized officer shall require coverage of all expenses tied to 

cultural resources identification, protection, and mitigation. These may include, but are not limited 

to, costs for ethnographic studies, inventory, testing, geomorphological studies, data recovery, 

curation, monitoring, treatment of damaged sites, and generation and submission of reports.

Site Characterization, Siting and Design, Construction

Solar facilities shall be characterized, sited and designed, and constructed in coordination with the 

BLM to minimize cultural resource impacts. Methods to minimize impacts on cultural resources shall 

include the following:

The BLM determining the Area of Potential Effects (APE) for each proposed solar energy project, 

to include a review of existing information, and efforts to seek information from and views of tribes 

and other parties likely to have knowledge of or concerns with historic properties in the APE. This 

information will be supplemented by discussions at pre-application meetings with the solar energy 

project applicant, SHPO, and affected tribes regarding project designs, sacred sites, traditional 

cultural properties, and proposed cultural resource inventory strategies.

The BLM consulting the SHPO, affected tribes (regarding the treatment of adverse effects for 

those property types on which the tribes indicate at pre-application or other meetings they wish to 

provide input), and any other consulting parties, if the National Register of Historic Places the 

National Register of Historic Places (NRHP)-eligible properties are present at the site and would 

be adversely affected. The BLM will seek agreement to avoid, minimize, or mitigate adverse 

effects on historic properties. The BLM will execute a Memorandum of Agreement with the SHPO 

to conclude the Section 106 process and will file a copy with the Advisory Council on Historic 

Preservation. Where the BLM and the SHPO are unable to execute a Memorandum of 

Agreement, the BLM will invite the Advisory Council on Historic Preservation to participate in an 

undertaking-specific Memorandum of Agreement. The Memorandum of Agreement will specify 

the treatment for which the BLM will be responsible, and which will be implemented by the solar 

applicant.

Undertaking a Class III inventory of the APE. If the BLM decides to require less than a Class III 

inventory for the entire APE, the BLM will seek additional views of the SHPO, affected tribes, and 
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other parties and determine the final inventory strategy that best represents a reasonable and 

good-faith effort to carry out appropriate identification efforts.

Conducting inventories according to the standards set forth in the Secretary of the Interior’s 

Standards and Guidelines for Archaeology and Historic Preservation (48 FR 44716); BLM 

Handbook H-8110 (Handbook for Identifying Cultural Resources); revised BLM Manual 8110; and 

applicable BLM or SHPO survey, site record, or reporting standards. All inventory data must be 

provided to the BLM in digitized or paper format that meets BLM accuracy standards, including 

shape files for surveyed areas.

Bringing any unexpected discovery of cultural resources during any phase of development 

(construction, operations and maintenance, or decommissioning) to the attention of the 

responsible BLM authorized officer immediately, as specified in the PA. Work shall be halted in 

the vicinity of the find. The area of the find shall be protected to ensure that the resources are not 

removed, handled, altered, or damaged while they are being evaluated and to ensure that 

appropriate mitigative or protective measures can be developed and implemented.

Methods to minimize cultural resource impacts may include, but are not limited to, the following:

Including in the Memorandum of Agreement measures for management of historic properties, in 

situations where historic properties require management or monitoring for avoidance and 

protection within or near a project’s boundaries. Such measures will specify the preparation and 

implementation of steps to lessen the adverse effects of the undertaking upon those aspects of 

NRHP eligibility criteria that make the historic properties eligible for nomination to the NRHP.

Requiring that surface disturbance be restricted or prohibited within the viewshed of such 

property types when their eligibility is tied to their visual setting to protect NRHP-eligible traditional 

cultural properties, sacred sites, or historic trails from visual intrusion and to maintain the integrity 

of their historic setting unless acceptable mitigation is proposed.

Employing cultural field monitors (appropriate for the resource anticipated) to monitor grounddisturbing activities (for example in geomorphic settings, such as in shifting sands, where buried 

deposits may be present) in cases where there is a probability of encountering cultural resources 

during construction that could not be detected during prior Class III inventories. Monitoring plans 

shall be specified within Memorandums of Agreement. 

Encouraging the use of previously disturbed lands and lands determined by archeological 

inventories to be devoid of historic properties.

Reclamation and Decommissioning

Prior to reclamation activities, the BLM may require further planning for treatment of historic 

properties or planning for mitigation addressing reclamation activities.

The BLM shall be notified prior to the demolition or substantial alteration of any building or structure. If 

judged necessary by the BLM, the developer will be required to evaluate the structures for their 

significance employing professionally qualified architects or historic architects. If structures slated for 

demolition are found to be eligible for listing on the NRHP, they will be recorded to Historic American 

Building Survey and/or Historic American Engineering Record standards before alteration or removal.

Project developers shall confine soil-disturbing reclamation and decommissioning activities to 

previously disturbed areas. Known historic properties will be avoided during these activities.

Tribal Rights and Interests

General

The BLM shall consult with Federally recognized Indian tribes early in the planning process to identify 

issues and areas of concern regarding any proposed solar energy project as required by the National 

Historic Preservation Act and other authorities to determine whether construction and operation of a 

project is likely to disturb traditional cultural properties or sacred sites, impede access to culturally 

important locations, disrupt traditional cultural practices, affect movements of animals important to 

tribes, or visually affect culturally important landscapes. Identifying issues and areas of concern to 

Federally recognized Indian tribes shall include, but is not limited to, the following:

Covering planning, construction, operation, and reclamation activities during consultation. 

Agreements or understandings reached with affected tribes shall be carried out in accordance 

with the terms of Memorandums of Agreement or project specific PAs.
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The BLM consulting with affected Indian tribes during the Section 106 process at the points 

specified in the PA.

The BLM consulting with Indian tribes under the terms of the Native American Graves Protection 

and Repatriation Act (NAGPRA). Any planning for treatment of historic properties or mitigation will 

take such consultations into account.

The BLM seeking, during consultation, to develop agreements with affected tribes on how to 

appropriately respond to input and concerns in advance to save time and avoid confusion.

Methods to minimize issues and areas of concern to Federally recognized Indian tribes may include, 

but are not limited to, the following: 

Employing standard noise design features for solar facilities located near sacred sites to minimize 

the impacts of noise on culturally significant areas.

Employing health and safety design features for the general public for solar facilities located near

Native American traditional use areas in order to minimize potential health and safety impacts on 

Native Americans.

Avoiding known human burial sites. Where there is a reasonable probability of encountering 

undetected human remains and associated funerary objects by a solar energy project, the BLM 

will carry out discussions with Indian tribes before the project is authorized, in order to provide 

general guidance on the treatment of any cultural items (as defined by NAGPRA) that might be 

exposed.

Avoiding visual intrusion on sacred sites through the selection of the solar facility location and 

solar technology. When complete avoidance is not practicable or economically feasible, the BLM 

shall engage in timely and meaningful consultation with the affected tribe(s) and shall attempt to 

formulate a mutually acceptable plan to mitigate or reduce the adverse effects.

Avoiding rock art (panels of petroglyphs and/or pictographs). These panels may be just one 

component of a larger sacred landscape, in which avoidance of all impacts may not be possible. 

Mitigation plans for eliminating or reducing potential impacts on rock art shall be formulated in 

consultation with the appropriate tribal cultural authorities.

Avoiding springs and other water sources that are or may be sacred or culturally important. If it is 

necessary for construction, maintenance, or operational activities to take place in proximity to 

springs or other water sources, appropriate measures, such as the use of geotextiles or silt 

fencing, should be taken to prevent silt from degrading water sources. The effectiveness of these 

mitigating barriers shall be monitored. Measures for preventing water depletion impacts on 

springs should also be employed. Particular mitigations shall be determined in consultation with 

the appropriate Indian tribe(s).

Avoiding culturally important plant species. When it is not possible to avoid affecting these plant 

resources, consultations shall be undertaken with the affected Indian tribe(s). If the species is 

available elsewhere on agency-managed lands, guaranteed access may suffice. For rare or lesscommon species, establishing (transplanting) or propagating an equal amount of the plant 

resource elsewhere on agency-managed land accessible to the affected tribe may be acceptable.

Avoiding culturally important wildlife species and their habitats. When it is not possible to avoid 

these habitats, solar facilities should be designed to minimize impacts on game trails, migration 

routes, and nesting and breeding areas of tribally important species. Mitigation and monitoring 

procedures should be developed in consultation with the affected tribe(s).

Securing a performance and reclamation bond for all solar energy generation facilities to ensure 

compliance with the terms and conditions of the ROW authorization. When establishing bond 

amounts and conditions, the BLM authorized officer shall require coverage of all expenses tied to 

identification, protection, and mitigation of cultural resources of concern to Indian tribes. These 

may include, but are not limited to, costs for ethnographic studies, inventory, testing, 

geomorphological studies, data recovery, curation, monitoring, treatment of damaged sites, and 

generation and submission of reports. 

Site Characterization, Siting and Design, Construction

Prior to construction, the project developer shall provide training to contractor personnel whose 

activities or responsibilities could affect issues and areas of concern to Federally recognized Indian 

tribes.
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Operations and Maintenance

Consultation with affected Federally recognized Indian tribes shall be ongoing during the life of the 

project.

The project developer shall train facility personnel regarding their responsibilities to protect any 

known resources of importance to Federally recognized Indian tribes.

Reclamation and Decommissioning

The project developer shall confine reclamation and decommissioning activities to previously 

disturbed areas and existing access roads to the extent practicable.

The project developer shall return the site to its pre-construction condition, to the extent practicable 

and approved by the BLM.

Socioeconomic Impacts 

General

Project developers shall coordinate with the BLM and other Federal, State, and local agencies to 

identify and minimize potential socioeconomic impacts. Identifying socioeconomic impacts may

include:

Project developers may need to collect and evaluate available information describing the 

socioeconomic conditions in the vicinity of the proposed project.

Develop options to minimize and/or mitigate adverse sociaoeconomic impacts in coordination 

with the BLM.

Develop a community monitoring program that would be sufficient to identify and evaluate 

socioeconomic impacts resulting from solar energy development. Measures developed for 

monitoring may include the collection of data reflecting the economic, fiscal, and social impacts of 

development at the Tribal, State, and local level.

Develop community outreach programs that would help communities adjust to changes triggered 

by solar energy development.

Establish vocational training programs for the local workforce to promote development of skills 

required by the solar energy industry.

Develop instructional materials for use in area schools to educate the local communities on the 

solar energy industry.

Environmental Justice 

General

Project developers shall coordinate with the BLM and other Federal, State, and local agencies to 

identify and minimize the potential for environmental justice impacts. Identifying environmental justice 

impacts may include:

Project developers shall identify all environmental justice communities and collect and evaluate 

available information describing the socioeconomic conditions in the vicinity of the proposed 

project, as needed, to predict potential environmental justice impacts of the project (i.e., 

environmental, economic, cultural, and health impacts on low-income and minority populations).

Evaluate environmental justice impacts as part of the environmental impact analysis for the 

project and consider options to mitigate such risk in coordination with the BLM.

Develop and implement focused public information campaigns providing technical and 

environmental health information directly to low-income and minority groups or to local agencies 

and representative groups. Include key information such as any likely impact on air quality, 

drinking water supplies, subsistence resources, public services, and the relevant 

preventative/minimization measures to be taken.

Provide community health screenings for low-income and minority groups.

Provide financial support to local libraries in low-income and minority communities for the 

development of information repositories on solar energy, including materials on the hazards and 

benefits of commercial development.

Establish vocational training programs for the local low income and minority workforce to promote 

development of skills for the solar energy industry.
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Develop instructional materials for use in area schools to educate the local communities on the 

solar energy industry.

Provide key information to local governments and directly to low-income and minority populations 

on the scale and timeline of expected solar energy projects and on the experience of other lowincome and minority communities that have followed the same energy development path.

Make information available about planning activities that may be initiated to provide local 

infrastructure, public services, education, and housing.

Transportation

Site Characterization, Siting and Design, Construction

Project developers shall coordinate with the BLM and other Federal, State, and local agencies to 

identify and minimize impacts on transportation. Identifying impacts on transportation may include:

Consult land use plans, transportation plans, and local plans as necessary. The developer may 

be required to perform traffic studies, analyses, or other studies of the capacity of existing and 

proposed new roads to physically handle the added wear and tear from increased construction 

commuter and truck traffic.

Develop options to minimize risk of increased transportation in coordination with the BLM.

Methods to minimize impacts on transportation may include:

Incorporate site access into the local and regional road network. Incorporation must be done 

under the supervision of the pertinent Federal, State, and local agencies.

Considering public roadway corridors through a site to maintain proper traffic flows and retain 

more direct routing for the local population.

Considering implementing local road improvements, providing multiple site access locations and 

routes, staggering work schedules, and implementing a ride-sharing or shuttle program to 

minimize daily commutes of construction workers.

Implement traffic control measures to reduce hazards for incoming and outgoing traffic and 

streamline traffic flow, such as intersection realignment and speed limit reductions; installing 

signage; and adding acceleration, deceleration, and turn lanes on routes with site entrances.

Inspect, monitor, and respond to transportation impacts during construction, operations, and 

decommissioning of a solar energy development using adaptive management protocols.

Hazardous Materials and Waste

General

Project developers shall coordinate with the BLM and other Federal, State, and local agencies early 

in the planning process to assess hazardous material and waste concerns and to minimize potential 

impacts. Assessing hazardous material and waste concerns may include:

Identify expected waste generation streams at the solar energy site and hazardous waste storage 

locations for the proposed project.

Conduct site characterization, construction, operation, and decommissioning activities in 

compliance with applicable Federal and State laws and regulations, including the Toxic 

Substances Control Act of 1976, as amended (15 U.S.C. 2601, et seq.). An example of complying 

with applicable law is reporting any release of toxic substances (leaks, spills, etc.) in excess of 

the reportable quantity established by 40 CFR Part 117 as required by the Comprehensive 

Environmental Response, Compensation, and Liability Act of 1980, Section 102b.

Methods to minimize hazardous material and waste related impacts may include:

Develop a Hazardous Materials and Waste Management Plan that addresses the selection, 

transport, storage, and use of all hazardous materials needed for construction, operations, and 

decommissioning of the facility for local emergency response and public safety authorities and for 

the designated BLM land manager. Furthermore, the plan shall address the characterization, onsite storage, recycling, and disposal of all resulting wastes. At minimum, the plan will discuss 

facility identification; comprehensive hazardous materials inventory; Material Safety Data Sheets 

for each type of hazardous material; emergency contacts and mutual aid agreements, if any; site 

map showing all hazardous materials and waste storage and use locations; copies of spill and 

emergency response plans, and hazardous materials–related elements of a Decommissioning 

and Site Reclamation Plan.
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The waste management plan will address all solid and liquid wastes that may be generated at the 

site in compliance with the Clean Water Act requirements to obtain the project’s National 

Pollutant Discharge Elimination System or similar permit.

Conside fire management in developing hazardous materials and waste management measures.

Identify and implement prevention measures, including material substitution of less hazardous 

alternatives, recycling, and waste minimization.

Establish procedures for fuel storage and dispensing that consider health and safety of personnel 

and methods for safe use (i.e., fire safety, authorized equipment use).

Ensure vehicles and equipment are in proper working condition to reduce potential for leaks of 

motor oil, antifreeze, hydraulic fluid, grease, or other hazardous materials.

 Establish schedules for regular removal of wastes (including sanitary wastewater generated in 

temporary, portable sanitary facilities) for delivery and removal by licensed haulers to appropriate 

off-site treatment or disposal facilities.

Site Characterization, Siting and Design, Construction

Solar facilities shall be characterized, sited and designed, and constructed to minimize hazardous 

materials and waste management design elements. Methods to minimize hazardous material and 

waste management impacts may include:

Indemnify the United States against any liability arising from the release of any hazardous 

substance or hazardous waste on the facility or associated with facility activities.

Provide a copy of any report required or requested by any Federal agency or State government 

as a result of a reportable release or spill of any toxic substances to the BLM authorized officer 

concurrent with the filing of the reports to the involved Federal agency or State government.

Design and operate systems containing hazardous materials in a manner that limits the potential 

for their release.

Establish measures for construction with compatible materials in safe conditions.

Establish dedicated areas with secondary containment for loading or off loading hazardous 

materials to transport vehicles.

Implement “just-in-time” ordering procedures to limit the amounts of hazardous materials present 

on the site to quantities minimally necessary to support continued operations. Excess hazardous 

materials shall be promptly disposed. 

Survey project sites for unexploded ordnance if projects are within 20 miles of a current DoD 

installation or formerly utilized defense site.

Site refueling areas away from surface waters and drainages and on paved surfaces; features 

shall be added to direct any spilled materials to sumps or safe storage areas where they can be 

subsequently recovered.

Designate hazardous materials and waste storage areas and facilities. Limit access to designated 

areas to authorized personnel only.

Operations and Maintenance

Compliance with the terms and conditions for hazardous materials and waste management shall be 

monitored by the project developer.

Consultation with the BLM shall be maintained through the operations and maintenance of the 

project, employing an adaptive management strategy and modifications, as necessary and approved 

by the BLM.

Methods for maintaining compliance with the terms and conditions for hazardous materials and waste 

management during operations and maintenance of the project may include the following:

Installing sensors or other devices to monitor system integrity and

Implementing robust site inspection and repair procedures.

Reclamation and Decommissioning

Project developers shall maintain emergency response capabilities throughout the reclamation and 

decommissioning period as long as hazardous materials and wastes remain on-site.

All design features developed for the construction phase shall be applied to similar activities during 

the reclamation and decommissioning phases.
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Health and Safety

General

Project developers shall coordinate with the BLM and other Federal, State, and local agencies early 

in the planning process to identify project health and safety risks and methods to minimize those 

risks. Assessing project health and safety risks may include:

Identifying and establishing Federal and State occupational health and safety standards, such as 

Occupational Safety and Health Administration’s (OSHA’s) Occupational Health and Safety 

Standards, 29 CFR Parts 1910 and 1926, respectively, for all phases of the project.

Identifying safety zones or setbacks for solar facilities and associated transmission lines from 

residences and occupied buildings, roads, ROWs, and other public access areas that are 

sufficient to prevent accidents resulting from various hazards during all phases of development.

Methods to minimize project health and safety risks may include, but are not limited to, the following:

Identifying and accounting for general project injury prevention within the Plan of Development

and the Health and Safety Plan, such as established personal protective equipment

requirements, respiratory protection, hearing conservation measures, electrical safety 

considerations, hazardous materials safety and communication, housekeeping and waste 

handling, confined space identification, and rescue response and emergency medical support, 

including on-site first aid capability.

Implementing training and awareness measures for workers and the general public to minimize 

and address standard practices (such as OSHA’s) for the safe use of explosives and blasting 

agents; occupational electric and magnetic field exposures; fire safety and evacuation 

procedures; and safety performance standards (e.g., electrical system standards and lighting 

protection standards). Consider further training for additional health and safety risks from the 

solar energy project and its ancillary facilities.

Establishing measures to document training activities and reporting of serious accidents to 

appropriate agencies.

Assessing cancer and non-cancer risks to workers and the general public from exposure to 

facility emission sources that exceed threshold levels.

Considering implementation of measures to reduce site emissions and the cancer and noncancer from exposure to facility emissions.

Implementing a reporting structure for accidental release of hazardous substances to the 

environment where project developers shall document the event, including a root cause analysis, 

a description of appropriate corrective actions taken, and a characterization of the resulting 

environmental or health and safety impacts. Documentation of the event shall be provided to the 

permitting agencies and other Federal and State agencies within 30 days.

Considering manufacturer requirements, and Federal and State standards, when establishing 

safety zones or setbacks for solar facilities and associated transmission lines.

Project developers coordinating with the BLM and appropriate agencies (e.g., the Department of 

Energy and Transportation Security Administration to address critical infrastructure and key 

resource vulnerabilities at solar facilities in order to minimize and plan for potential risks from 

natural events, sabotage, and terrorism.

Site Characterization, Siting and Design, Construction

Solar facilities shall be characterized, sited and designed, and constructed to minimize risk to health 

and safety. Methods to minimize risk to health and safety may include:

Designing electrical systems to meet all applicable safety standards (e.g., National Electrical 

Code) and to comply with the interconnection requirements of the transmission system operator.

Complying with applicable FAA regulations, including lighting requirements, to avoid or minimize 

potential safety issues associated with proximity to airports, military bases or training areas, or 

landing strips.

Considering temporary fencing and other measures for staging areas, storage yards, and 

excavations during construction or decommissioning activities to limit public access to health and 

safety risks.

Planning for traffic management of site access to ensure that traffic flow would not be 

unnecessarily affected and that specific issues of concern (e.g., the locations of school bus routes 
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and stops) are identified and addressed. Planning may include measures such as informational 

signs and temporary lane configurations. Planning shall be coordinated with local planning 

authorities.

Considering use of alternative dielectric fluids that do not contain sulfur hexafluoride to reduce the 

global warming potential.

Considering measures to reduce occupational electric and magnetic fields) exposures, such as 

backing electrical generators with iron to block the electric and magnetic fields, shutting down 

generators when work is being done near them, and otherwise limiting exposure time and 

proximity while generators are running.

Operations and Maintenance

Compliance with the terms and conditions for health and safety shall be monitored by the project 

developer. Consultation with the BLM shall be maintained through operations and maintenance of the 

project employing an adaptive management strategy and modifications, as necessary and approved 

by the BLM.

National Historic Trails

General

Project developers shall consult with the BLM early in the project planning to help determine the 

proposed project’s conformance with trail management prescriptions and other potential trail-related 

constraints. Assessing conformance to trail management prescriptions and other potential trail related 

constraints shall include, but is not limited to:

Consider the Oregon National Historic Trail management corridor as an avoidance area in order 

to prevent substantial interference with the nature and purposes of designated National Historic 

Trail, and to make efforts to avoid activities incompatible with trail purposes. Residual impacts on 

trails will be avoided, minimized, and/or mitigated to the extent practicable.

Apply on-site or off-site mitigation for any residual adverse impact according to program policy 

standards.

West Wide Energy Corridors Interagency Operating Procedures These Interagency Operating Procedures are from the Approved Resource Management Plan 

Amendments/Record of Decision for Designation of Energy Corridors on Bureau of Land Management 

Administered Land in the 11 Western States (BLM, 2009a) and are for projects proposed within the 

Section 368 corridors. Not all operating procedures will be appropriate for all projects; those that apply to 

pipelines, for instance, are not appropriate to transmission lines. These operating procedures are 

practicable means to avoid or minimize environmental impacts from future project development that may 

occur within the designated corridors. 

Project Planning

Agency Coordination

Applicants seeking to develop energy transport projects within corridors located on or near Saylor 

Creek Training Range or within military operating areas must, early in the planning process and in 

conjunction with the appropriate agency staff, inform and coordinate with the DoD regarding the 

characteristics and locations of the anticipated project infrastructure.

Early in the planning process, applicants seeking a right-of-way (ROW) authorization within a Section 

368 energy corridor that is located within five miles of a unit of the National Park Service should 

contact the appropriate Agency staff and work with the National Park Service regarding the 

characteristics and locations of anticipated project infrastructure. In those instances where corridors 

cross lands within the boundaries of a unit of the National Park Service, the National Park Service 

Organic Act and other relevant laws and policies shall apply.

For electricity transmission projects, the applicant shall notify the Federal Aviation Administration 

(FAA) as early as practicable in the planning process in order to identify appropriate aircraft safety 

requirements.
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All project applications must reflect applicable findings, mitigation, and/or standards contained in 

regional land management plans, such as the Northwest Forest Plan, when such regional plans have 

been incorporated into agency planning guidelines and requirements. Modification of some standards 

may be needed to reasonably allow for energy transport within a corridor. 

Government-to-Government Consultation

The appropriate agency, assisted by the project applicant, must initiate government-to-government 

consultation with affected tribes at the outset of project planning and shall continue consultation 

throughout all phases of the project, as necessary. Agencies should determine how to consult in a 

manner that reflects the cultural values, socioeconomic factors, and administrative structures of the 

interested tribes. 

The agency point-of-contact (POC) may require the project proponent to prepare an ethnographic 

study when tribal consultation indicates the need. The study shall be conducted by a qualified 

professional selected in consultation with the affected tribes.

General

Applicants seeking to develop an electricity transmission or pipeline project will develop a projectspecific Plan of Development (POD). The POD should display the location of the project infrastructure 

(i.e., towers, power lines) and identify areas of short- and long-term land and resource impacts and 

the mitigation measures for site-specific and resource-specific environmental impacts. The POD 

should also include notification of project termination and decommissioning to the agencies at a time 

period specified by the agencies.

Applicants, working with the appropriate agencies, shall design projects to comply with all appropriate 

and applicable agency policies and guidance.

Project planning shall be based on the current state of knowledge. Where corridors are subject to 

sequential projects, project-related planning (such as the development of spill-response plans, 

cultural resource management plans, and visual resource management plans) and project-specific 

mitigation and monitoring should incorporate information and lessons learned from previous projects.

Applicants shall follow the best management practices for energy transport project siting, 

construction, and operations of the States in which the proposed project would be located, as well as 

Federal agency practices.

Corridors are to be efficiently used. The applicant, assisted by the appropriate agency, shall 

consolidate the proposed infrastructure, such as access roads, wherever possible and utilize existing 

roads to the maximum extent feasible, minimizing the number, lengths, and widths of roads, 

construction support areas, and borrow areas.

When concurrent development projects are proposed and implemented within a corridor, the agency 

POC shall coordinate the projects to ensure consistency with regard to all regulatory compliance and 

consultation requirements, and to avoid duplication of effort.

Applicants, assisted by the appropriate agency, shall prepare a monitoring plan for all project-specific 

mitigation activities.

Potential cumulative impacts to resources should be considered during the early stages of the project. 

Agency POCs must coordinate various development projects to consider and minimize cumulative 

impacts. A review of resource impacts resulting from other projects in the region should be conducted 

and any pertinent information be considered during project planning.

Project Design

Applicants shall locate desired projects within energy corridors to promote effective use of the 

corridors by subsequent applicants and to avoid the elimination of use or encumbrance of use of the 

corridors by ROW holders. Proposed projects should be compatible with identified energy transport 

modes and avoid conflicts with other land uses within a corridor.

Applicant shall identify and delineate existing underground metallic pipelines in the vicinity of a 

proposed electricity transmission line project and design the project to avoid accelerating the 

corrosion of the pipelines and/or pumping wells.
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Transportation

The applicant shall prepare an access road siting and management plan that incorporates relevant 

agency standards regarding road design, construction, maintenance, and decommissioning. 

Corridors will be closed to public vehicular access unless determined by the BLM authorized officer to 

be managed as part of an existing travel and transportation network in a land use plan or subsequent 

travel management plan(s).

The applicant shall prepare a comprehensive transportation plan for the transport of transmission 

tower or pipeline components, main assembly cranes, and other large equipment. The plan should 

address specific sizes, weights, origin, destination, and unique equipment handling requirements. The 

plan should evaluate alternative transportation routes and should comply with State regulations and 

all necessary permitting requirements. The plan should address site access roads and eliminate 

hazards from truck traffic or adverse impacts to normal traffic flow. The plan should include measures 

such as informational signage and traffic controls that may be necessary during construction or 

maintenance of facilities.

Applicants shall consult with local planning authorities regarding increased traffic during the 

construction phase, including an assessment of the number of vehicles per day, their size, and type. 

Specific issues of concern (e.g., location of school bus routes and stops) should be identified and 

addressed in the traffic management plan.

Groundwater

Applicants must identify and delineate all sole source aquifers in the vicinity of a proposed project and 

design the project to avoid disturbing these aquifers or to minimize potential risks that the aquifers 

could be contaminated by spills or leaks of chemicals used in the projects.

In instances where a project within an energy corridor crosses sole source aquifers, the applicant 

must notify the Environmental Protection Agency (EPA) and the agencies that administer the land as 

early as practicable in the planning process. Section 1424(e) of the Safe Drinking Water Act (42 

U.S.C. Chapter 6A) and other relevant laws and policies pertinent to the corridors that cross sole 

source aquifers shall apply.

Surface Water

Applicants must identify all wild and scenic rivers (designated by act of Congress or by the Secretary 

of the Interior under Section 3(a) or 2(a)(ii) of the Wild and Scenic Rivers Act (16 U.S.C. 1271-1287), 

respectively), congressionally authorized wild and scenic study rivers, and agency identified (eligible 

or suitable) wild and scenic study rivers in the vicinity of a proposed project and design the project to 

avoid the rivers or mitigate the disturbance to the rivers and their vicinity.

In instances where a project within an energy corridor crosses a wild and scenic river or a wild and 

scenic study river, the appropriate Federal permitting agency, assisted by the project applicant, must 

coordinate and consult with the river-administrating agency regarding the protection and 

enhancement of the river’s free-flowing condition, water quality, and Outstandingly Remarkable

Values.

Applicants shall identify all streams in the vicinity of proposed project sites that are listed as impaired 

under Section 303(d) of the Clean Water Act (33 U.S.C. Chapter 26) and provide a management plan 

to avoid or mitigate adverse impacts on those streams. 

Paleontological Resources

The applicant shall conduct an initial scoping assessment to determine whether construction activities 

would disturb formations that may contain important paleontological resources. Potential impacts to 

significant paleontological resources should be avoided by moving or rerouting the site of construction 

or removing or reducing the need for surface disturbance. When avoidance is not possible, a 

mitigation plan should be prepared to identify physical and administrative protective measures and 

protocols such as halting work, to be implemented in the event of fossil discoveries. The scoping 

assessment and mitigation plan should be conducted in accordance with the managing agency’s 

fossil management practices and policies.

If significant paleontological resources are known to be present in the project area, or if areas with a 

high potential to contain paleontological material have been identified, the applicant shall prepare a 
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paleontological resources management and mitigation plan. If adverse impacts to paleontological 

resources cannot be avoided or mitigated within the designated corridors, the agency may consider 

alternative development routes to avoid, minimize, or mitigate adverse effects.

A protocol for unexpected discoveries of significant paleontological resources should be developed. 

Unexpected discovery during construction should be brought to the immediate attention of the 

responsible Federal agency’s authorized officer. Work should be halted in the vicinity of the discovery 

to avoid further disturbance of the resource while the resource is being evaluated and appropriate 

mitigation measures are being developed.

Ecological Resources

Applicants shall identify important, sensitive, or unique habitats and BLM-special status species and 

State-listed species in the vicinity of proposed projects and design the project to avoid or mitigate 

impacts to these habitats and species.

To restore disturbed habitats, the applicant will prepare a habitat restoration plan that identifies the 

approach and methods to be used to restore habitats disturbed during project construction activities. 

The plan will be designed to expedite the recovery to natural habitats supporting native vegetation, 

and require restoration to be completed as soon as practicable after completion of construction, 

minimizing the habitat converted at any one time. To ensure rapid and successful restoration efforts, 

the plan will include restoration success criteria, including time frames, which will be developed in 

coordination with the appropriate agency and which must be met by the applicant. Bonding to cover 

the full cost of restoration will be required.

In consultation with the US Army Corps of Engineers, the appropriate agency, assisted by the project 

applicant, will identify wetlands (including ephemeral, intermittent, and isolated wetlands), riparian 

habitats, streams, and other aquatic habitats in the project area and design the project to avoid or 

mitigate impacts to these habitats.

Vegetation Management

Applicants shall develop an integrated vegetation management plan consistent with applicable 

regulations and agency policies for the control of unwanted vegetation, noxious weeds, and invasive 

species (E.O. 13112). The plan should address monitoring; ROW vegetation management; the use of 

certified weed-seed-free hay, straw, and/or mulch; the cleaning of vehicles to avoid the introduction of 

noxious weeds and invasive plants; education of personnel on weed identification, the manner in 

which weeds spread, and the methods for treating infestations.

Cultural Resources

Cultural resources management services and individuals providing those services shall meet the 

Secretary of the Interior’s Standards for Archaeology and Historic Preservation, 48 FR 44716 (Sept. 

29, 1983).

The project applicant may, with the approval of the agency POC, assign a Cultural Resource 

Coordinator to ensure an integrated compliance process across administrative and jurisdictional 

boundaries. The Cultural Resource Coordinator will facilitate and coordinate compliance with laws, 

policies, regulations, and existing pertinent agreements (PAs, Memorandums of Agreement, or 

memoranda of understanding) among multiple agencies and other entities, jurisdictions, and 

Federally recognized tribes. The coordinator may assist with development of pertinent agreements 

among concerned parties during the course of the project. The coordinator shall be a qualified 

professional with experience in cultural resource compliance. Where appropriate, the Cultural 

Resource Coordinator may also serve as the Tribal Coordinator. Alternatively, the agency POC may 

assign such coordinators, to be paid for through project cost-recovery funds. The agencies, through 

the POC, remain responsible for consultation.

The project applicant may, with the approval of the agency POC, assign a Tribal Coordinator to 

facilitate and coordinate consultation and compliance with multiple laws, agencies, and tribes in order 

to ensure effective government-to-government consultation throughout the life of the project. 

Alternatively, the agency POC may assign such coordinators, to be paid for through project costrecovery funds. The agencies, through the POC, remain responsible for consultation.
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All historic properties in the Area of Potential Effect (APE) will be identified and evaluated. The APE 

shall include that area within which an undertaking may directly or indirectly cause alterations in the 

character or use of historic properties and shall include a reasonable construction buffer zone and 

laydown areas, access roads, and borrow areas, as well as a reasonable assessment of areas 

subject to effects from visual, auditory, or atmospheric impacts, or impacts from increased access.

Project proponents must develop a Cultural Resources Management Plan (CRMP) to outline the 

process for compliance with applicable cultural resource laws during pre-project planning, 

management of resources during operation, and consideration of the effect of decommissioning. 

CRMPs should meet the specifications of the appropriate agency and address compliance with all 

appropriate laws. CRMPs should include the following, as appropriate: identification of the Federally 

recognized tribes, State Historic Preservation Officers (SHPOs), and consulting parties for the project; 

identification of long- and short-term management goals for cultural resources within the APE of the 

project; the definition of the APE; appropriate procedures for inventory, evaluation, and identification 

of effects to historic properties; evaluation of eligibility for the the National Register of Historic Places 

(NRHP) for all resources in the APE; description of the measures to avoid, minimize, or mitigate 

adverse effects to historic properties; procedures for inadvertent discovery; procedures for 

considering Native American Graves Protection and Repatriation Act (NAGPRA) issues, monitoring 

needs, and plans to be employed during construction; curation procedures; anticipated personnel 

requirements and qualifications; public outreach and interpretation plans; and discussion of other 

concerns. The draft CRMP should be reviewed and approved by the agency POC in consultation with 

historic preservation partners, including appropriate SHPOs, tribes, and consulting parties. CRMPs 

must specify procedures that would be followed for compliance with cultural resource laws, should the 

project change during the course of implementation.

Project applicants will provide cultural resources training for project personnel regarding the laws 

protecting cultural resources, appropriate conduct in the field (such as procedures for the inadvertent 

discovery of human remains), and other project-specific issues identified in the CRMP. Training plans 

should be part of the CRMP and should be subject to the approval of the POC. When government-togovernment consultation identifies the need and the possibility, tribes may be invited to participate in 

or contribute to relevant sessions.

If adverse effects to historic properties will result from a project, a Historic Property Treatment Plan 

will be developed in consultation with the SHPO, the appropriate Federally recognized tribes, and any 

consulting parties. The plan will outline how the impacts to the historic properties would be mitigated, 

minimized, or avoided. 

Cultural resources inventory, evaluation, and mitigation practices should incorporate modeling and 

sampling strategies to the extent practicable, in concurrence with SHPOs and other relevant parties, 

and as approved by the agency POC.

Project applicants shall provide all cultural resources reports and data in an electronic format that is 

approved by the Agency POC and integrated across jurisdictional boundaries, that meets current 

standards, and that is compatible with SHPO systems. The Agency will submit this data to the SHPO 

in a timely fashion. Project proponents should submit cultural resources data on a regular basis to 

ensure that SHPO systems are kept up to date for reference as the different phases of the project 

proceed. Paper records may also be required by the agency.

Cultural resources inventory procedures, specified in the CRMP, will include development of historic 

contexts based on the Secretary of the Interior’s Standards and Guidelines for Archeology and 

Historic Preservation (48 FR 44716) sufficient to support the evaluation of cultural resources 

encountered in the APE.

Government to Government Consultation

The appropriate agency, assisted by the applicant, must comply with all laws, policies, and 

regulations pertaining to government-to-government consultation with Federally recognized tribes. 

Agencies shall initiate consultation with affected tribes at the outset of project planning and shall 

continue consultation throughout project planning, construction, operation, and decommissioning. 

Consultation shall include, but not be limited to, the following:

Identification of potentially affected tribes;
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Identification of appropriate tribal contacts and the preferred means of communication with these 

tribes;

Provision to the tribes of project-specific information (e.g., project proponents, maps, design 

features, proposed ROW routes, construction methods) at the outset of project planning and 

throughout the life of the project;

Identification of issues of concern specific to affected tribes (e.g., potential impacts to culturally 

sensitive areas or resources, hazard and safety management plans, treaty reserved rights and 

trust responsibilities);

Identification of areas and resources of concern to tribes; and

Resolution of concerns (e.g., actions to avoid, minimize, or mitigate impacts to important 

resources; Memoranda of Agreement stating what actions would be taken to mitigate project 

effects; or agreements for tribal participation in monitoring efforts or operator training programs).

The appropriate agency, assisted by the applicant, must comply with all pertinent laws, policies, and 

regulations addressing cultural and other resources important to tribes, including the National Historic 

Preservation Act, the Archaeological Resources Protection Act, the Native American Graves 

Protection Act (NAGPRA), and other laws and regulations.

The agencies shall recognize the significance to tribes of traditional cultural places, such as sacred 

sites, sacred landscapes, gathering grounds, and burial areas, and shall seek to identify such areas 

through consultation with affected tribes early in the project planning process. Agencies shall seek to 

avoid, minimize, or mitigate impacts to such places in consultation with the tribes, project proponents, 

and other relevant parties. Where confidentiality concerning these areas is important to an affected 

tribe, agencies shall honor such confidentiality unless the tribe agrees to release the information.

A protocol must be developed for inadvertent discovery of Native American human remains and 

funerary items to comply with the NAGPRA in consultation with appropriate Federally recognized 

tribes. Unexpected discovery of Native American human remains and funerary items during 

construction must be brought to the immediate attention of the BLM authorized officer. Work must be 

halted in the vicinity of the find of Native American graves and funerary items to avoid further 

disturbance to the resources while they are being evaluated and appropriate mitigation measures are 

being developed. The procedures for reporting items covered under NAGPRA must be identified in 

the CRMP.

Visual Resources

Applicants shall identify and consider Visual Resource Management (VRM) issues early in the design 

process to facilitate integration of VRM into the overall site development program and construction 

documents. Visual management considerations, environmental analyses, mitigation planning, and 

design shall reference and be in accordance with the land management agency visual management 

policies and procedures applicable to the jurisdiction the project lies within. Applicants shall 

coordinate between multiple agencies on visual sensitive issues when projects transition from one 

jurisdiction to another, especially when transitions occur within a shared viewshed.

Applicants shall prepare a VRM plan. The applicant’s shall include an appropriately trained specialist, 

such as a landscape architect with demonstrated VRM experience. The VRM specialist shall 

coordinate with the BLM on the availability of the appropriate visual inventory data, VRM 

management class delineations, and Federal agency expectations for preparing project plans and 

mitigation strategies to comply with RMP direction related to visual resources. Applicants shall 

confirm that a current Visual Resource Inventory is available and that VRM classifications have been 

designated in the current land management plan. Project plans shall abide by the VRM class 

designations and consider sensitivities defined within the Visual Resource Inventory. If visual 

management objectives are absent, then the proper inventory and classification process shall be 

followed to develop them in accordance with the BLM VRM manual and handbooks. When the VRM 

classes are absent, then the project alternatives must reflect a range of management options related 

to visual resources that reflect the values identified in the visual inventory. Responsibility for 

developing an inventory or VRM classes will remain with the agency, but how to accomplish these 

tasks will be determined by the BLM authorized officer who will consider the applicant’s role and 

financial participation in completing the work.
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Visual mitigation planning/design and analysis shall be performed through integrated field 

assessment, applied global positioning system technology, field photo documentation, use of 

computer-aided design and development software, 3-D modeling geographic information system

software, and visual simulation software, as appropriate. Proposed activities, projects, and site 

development plans shall be analyzed and further developed using these technologies to meet visual 

objectives for the project area and surrounding areas sufficient to provide the full context of the 

viewshed. Visual simulations shall be prepared according to BLM Handbook H-8432-1, or other 

agency requirements, to create spatially accurate depictions of the appearance of proposed facilities, 

as reflected in the 3-D design models. Simulations shall depict proposed project appearance from 

sensitive/scenic locations as well as more typical viewing locations. Transmission towers, roads, 

compressor stations, valves, and other aboveground infrastructure should be integrated aesthetically 

with the surrounding landscape in order to minimize contrast with the natural environment.

Applicants shall develop adequate terrain mapping on a landscape/viewshed scale for site 

planning/design, visual impact analysis, visual impact mitigation planning/design, and for full 

assessment and mitigation of cumulative visual impacts through applied, state-of-the-art design 

practices using the cited software systems. The landscape/viewshed scale mapping shall be georeferenced and at the same Digital Elevation Model resolution and contour interval within the margin 

of error suitable for engineered site design. This level of mapping shall enable proper placement of 

proposed developments into the digital viewshed context. Final plans shall be field verified for 

compliance.

The full range of visual best management practices (BMPs)shall be considered, and plans shall 

incorporate all pertinent BMPs. Visual resource monitoring and compliance strategies shall be 

included as a part of the project mitigation plans.

Public Health and Safety

An electricity transmission project shall be planned by the applicant to comply with FAA regulations, 

including lighting regulations, and to avoid potential safety issues associated with proximity to 

airports, military bases or training areas, or landing strips.

A health and safety program shall be developed by the applicant to protect both workers and the 

general public during construction, operation, and decommissioning of an energy transport project. 

The program should identify all applicable Federal and State occupational safety standards, establish 

safe work practices for each task (e.g., requirements for personal protective equipment and safety 

harnesses, Occupational Safety and Health Administration standard practices for safe use of 

explosives and blasting agents, measures for reducing occupational electric and magnetic fields 

exposures), and define safety performance standards (e.g., electrical system standards). The 

program should include a training program to identify hazard training requirements for workers for 

each task and establish procedures for providing required training to all workers. Documentation of 

training and a mechanism for reporting serious accidents to appropriate agencies should be 

established.

The health and safety program shall establish a safety zone or setback from roads and other public 

access areas that is sufficient to prevent accidents resulting from various hazards. It should identify 

requirements for temporary fencing around staging areas, storage yards, and excavations during 

construction or decommissioning activities. It should also identify measures to be taken during the 

operations phase to limit public access to those components of energy facilities that present health or 

safety risks. 

Applicants shall develop a comprehensive emergency plan that considers the vulnerabilities of their 

energy system to all credible events initiated by natural causes (earthquakes, avalanches, floods, 

high winds, violent storms, etc.), human error, mechanical failure, cyber-attack, sabotage, or 

deliberate destructive acts of both domestic and international origin and the potential for and possible 

consequences of those events. Vulnerability, threat, and consequence assessment methodologies 
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and criteria in the sector-specific plan for energy will be used and appropriate preemptive and 

mitigative response actions will be identified.

The sector-specifc plan for energy, developed by the Department of Energy’s Office of Electricity Delivery and 

Energy Reliability, is one of seventeen such SSPs that comprise the National Infrastructure Protection Plan. The 

energy sector-specifc plan (redacted) is available at http://energy.gov/oe/downloads/energy-sector-specific-planannex-national-infrastructure-protection-plan. The National Infrastructure Protection Plan is available at 

http://www.dhs.gov/national-infrastructure-protection-plan. 

 The applicant must coordinate emergency planning with 

Tribal, State, and local emergency and public safety authorities and with owners and operators of 

other energy systems collocated in the corridor or in adjacent corridors that could also be impacted.

In addition to directives contained in other BMPs herein, the applicant must identify all Federal, State, 

and local regulations pertaining to environmental protection, worker health and safety, public safety, 

and system reliability that are applicable throughout the construction, operation, and 

decommissioning phases of their facility’s life cycle and must develop appropriate compliance 

strategies, including securing all necessary permits and approvals.

Hazardous Materials Management

Applicants for petroleum pipelines and projects involving oil-filled electrical devices shall develop a 

spill prevention and response plan identifying spill prevention measures to be implemented, training 

requirements, appropriate spill response actions, and procedures for making timely notifications to 

authorities. The spill prevention and response plan should include identification of any sensitive biotic 

resources and locations (such as habitats) that require special measures to provide protection, as 

well as the measures needed to provide that protection.

Fire Management

Applicants shall develop a fire management strategy and implement measures to minimize the 

potential for a human-caused fire during project construction, operation, and decommissioning. The 

strategy should consider the need to reduce hazardous fuels (e.g., native and non-native annual 

grasses and shrubs) and to prevent the spread of fires started outside or inside a corridor, and clarify 

who has responsibility for fire suppression and hazardous fuels reduction for the corridor.

Applicants must work with the local land management agency to identify project areas that may incur 

heavy fuel buildups, and develop a long-term strategy on vegetation management of these areas. 

The strategy may include land treatment during project construction, which may extend outside the 

planned ROW clearing limits.

Project Construction

General

To avoid conflict with Federal and non-Federal operations, the applicant shall be aware of liabilities 

pertaining to environmental hazards, safety standards, and military flying areas.

The applicant shall locate all stationary construction equipment (i.e., compressors and generators) as 

far as practicable from nearby residences.

Applicants shall pay fair market value to the land management agency for any merchantable forest 

products that will be cut during ROW clearing. The local land management agency will determine the 

fair market value, which will be paid prior to clearing. The applicant will either remove the forest 

products from the area or will stack the material at locations determined by the local land 

management agency. Treatment of unmerchantable products will be determined by the local land 

management agency.

Soils, Excavation and Blasting

Applicants shall salvage, safeguard, and reapply topsoil from all excavations and construction 

activities during restoration.

All areas of disturbed soil shall be restored by the applicant using weed-free native grasses, forbs, 

shrubs, and trees as directed by the agency. Restoration should not be unnecessarily delayed. If 

native species are not available, noninvasive vegetation recommended by agency specialists may be 

used.
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The applicant must not create excessive slopes during excavation. Areas of steep slopes, biological 

soil crusts, erodible soil, and stream channel crossings will often require site-specific and specialized 

construction techniques by the applicant. These specialized construction techniques should be 

implemented by adequately trained and experienced employees.

Blasting activities will be avoided or minimized in the vicinity of sole source aquifer areas to reduce 

the risk of releasing sediments or particles into the groundwater and inadvertently plugging water 

supply wells.

The applicant must backfill foundations and trenches with originally excavated material as much as 

possible. Excess excavation materials should be disposed of by the applicant only in approved areas.

The applicant shall obtain borrow (fill) material only from authorized sites. Existing sites should be 

used in preference to new sites.

The applicant shall prepare an explosives use plan that specifies the times and meteorological 

conditions when explosives will be used and specifies minimum distances from sensitive vegetation 

and wildlife or streams and lakes.

If blasting or other noisy activities are required during the construction period, the applicant must 

notify nearby residents in advance.

Mitigation and Monitoring

All control and mitigation measures established for the project in the Plan of Development (POD) and 

other required plans shall be maintained and implemented by the applicant throughout construction. 

Necessary adjustments may be made with the concurrence of the appropriate agency.

Surface and Groundwater Resources

The applicant shall safeguard against the possibility of dewatering shallow groundwater and/or 

wetlands in the vicinity of project sites during foundation excavations or excavations for buried 

pipelines.

The applicant shall implement erosion controls complying with Federal, State, and county standards, 

such as jute netting, silt fences, and check dams, and secure all necessary storm water pollution 

prevention plan (SWPPP) permits.

The applicant shall minimize stream crossings by access roads to the extent practicable. All 

structures crossing intermittent and perennial streams should be located and constructed so that they 

do not decrease channel stability, increase water velocity, or impede fish passage.

Applicants shall not alter existing drainage systems and should give particular care to sensitive areas 

such as erodible soils or steep slopes. Soil erosion should be reduced at culvert outlets by 

appropriate structures. Catch basins, roadway ditches, and culverts should be cleaned and 

maintained.

Applicants must not create hydrologic conduits between aquifers.

Paleontological Resources

Project construction activities will follow the protective measures and protocols identified in the 

paleontological resources mitigation plan.

All paleontological specimens found on Federal lands remain the property of the US government. 

Specimens may only be collected by a qualified paleontologist under a permit issued by the 

managing agency and must be curated in an approved repository.

Ecological Resources

Areas that are known to support Endangered Species Act-listed species, BLM-special-status species, 

and State-listed species or their habitats shall be identified and marked with flagging or other 

appropriate means to avoid direct impacts during construction activities. Construction activities 

upslope of these areas should be avoided to prevent indirect impacts of surface water and sediment 

runoff.

All construction activities that could affect wetlands or waters of the United States shall be conducted 

in accordance with the requirements identified in permits issued by the US Army Corps of Engineers.
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Visual Resources

A pre-construction meeting with BLM landscape architects or other designated visual resource 

specialist shall be held before construction begins to coordinate on the VRM mitigation strategy and 

confirm the compliance-checking schedule and procedures. Applicants shall integrate interim/final 

reclamation VRM mitigation elements early in the construction, which may include treatments such as 

thinning and feathering vegetation along project edges, enhanced contour grading, salvaging 

landscape materials from within construction areas, special revegetation requirements, etc. 

Applicants shall coordinate with BLM in advance to haver designated visual resource specialists 

onsite during construction to work with implementing BMPs.

Cultural Resources

Project applicants shall provide all cultural resources reports and data in an approved electronic 

format that is integrated across jurisdictional boundaries, that meets current standards, and that is 

compatible with State Historic Preservation Officer (SHPO) systems. Project proponents shall submit 

cultural resources data on a regular basis to ensure that SHPO systems are kept up to date for 

reference as the different phases of the project proceed.

When an area is identified as having a high potential for cultural resources but none are found during 

a pre-construction field survey, a professionally qualified cultural resources specialist will be required 

to monitor ground-disturbing activities during project construction, and to complete a report when the 

activities are finished. The protocol for monitoring should be identified in the Cultural Resources 

Management Plan (CRMP). 

When human remains, funerary objects, sacred objects, or objects of cultural patrimony are 

inadvertently discovered, the provisions of NAGPRA shall apply and the process identified in the 

CRMP must be followed.

Hazardous Materials and Wastewater Management

Any wastewater generated by the applicant in association with temporary, portable sanitary facilities 

must be periodically removed on a schedule approved by the agency, by a licensed hauler, and 

introduced into an existing municipal sewage treatment facility. Temporary, portable sanitary facilities 

provided for construction crews should be adequate to support expected onsite personnel and should 

be removed at completion of construction activities.

All hazardous materials (including vehicle and equipment fuels) brought to the project site will be in 

appropriate containers and will be stored in designated and properly designed storage areas with 

appropriate secondary containment features. Excess hazardous materials will be removed from the 

project site after completion of the activities in which they are used.

Air Emissions

The applicant shall cover construction materials and stockpiled soils if these are sources of fugitive 

dust.

To minimize fugitive dust generation, the applicant shall water land before and during surface clearing 

or excavation activities. Areas where blasting would occur should be covered with mats.

Noise

The applicant shall limit noisy construction activities (including blasting) to the least noise-sensitive 

times of day (i.e., daytime only between 7 a.m. and 10 p.m.) and weekdays. The blasting period may 

be shortened during sage-grouse breeding and nesting or proximity to residences.

Fire Safety

The applicant must ensure that all construction equipment used is adequately muffled and maintained 

and that spark arrestors are used with construction equipment in areas with, and during periods of, 

high fire danger.

Flammable materials (including fuels) will be stored in appropriate containers.
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Project Operation

Mitigation and Monitoring

All control and mitigation measures established for the project shall be maintained and implemented 

by the applicant throughout the operation of the project. Necessary adjustments may be made with 

the concurrence of the BLM authorized officer. 

Ecological Resources

Project staff shall avoid harassment or disturbance of wildlife, especially during reproductive 

courtship, migratory, and nesting seasons.

Observations by project staff of potential wildlife problems, including wildlife mortality, will be 

immediately reported to the applicable agency authorized officer.

Pesticide and Herbicide Use

If pesticides are used, the applicant shall ensure that pesticide applications as specified in the 

integrated vegetation management plan are conducted within the framework of agency policies and 

entail only the use of EPA-registered pesticides that are applied in a manner consistent with label 

directions and State pesticide regulations. Pesticide use shall be limited to non-persistent immobile 

pesticides and shall be applied only in accordance with label and application permit directions and 

stipulations for terrestrial and aquatic applications.

Pesticide and herbicide uses must be avoided in the vicinity of sole source aquifer areas. 

Visual Resources

Terms and conditions for VRM mitigation compliance shall be maintained and monitored for 

compliance with visual objectives, with adaptive management adjustments and modifications as 

necessary, and approved by theBLM authorized officer. 

Hazardous Materials, Wastes, and Wastewater Management

The applicant shall provide secondary containment for all on-site hazardous materials and waste 

storage areas.

The applicant shall ensure that wastes are properly containerized and removed periodically for 

disposal at appropriate offsite permitted disposal facilities.

In the event of an accidental release to the environment, the applicant shall initiate spill cleanup 

procedures and document the event, including a cause analysis; appropriate corrective actions taken; 

and a characterization of the resulting environmental or health and safety impacts. Documentation of 

the event shall be provided to the BLM authorized officer and other Federal and State agencies, as 

required.

Air Quality

Dust abatement techniques (e.g., water spraying) shall be used by the applicant on unpaved, 

unvegetated surfaces to minimize airborne dust. Water for dust abatement should be obtained and 

used by the applicant under the appropriate State water use permitting system. Used oil will not be 

used for dust abatement.

Noise

The applicant shall ensure that all equipment has sound-control devices no less effective than those 

provided on the original equipment.
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Project Decommissioning

General

Where applicable, decommissioning activities will conform to agency standards and guidance for 

mitigation and reclamation (e.g., the Gold Book, 4th Edition, 2007 ).

Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development, 4th Edition, revised 

2007. Available electronically at

http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/best_management_practices/gold_book.html. 

Applicants must receive approval for changes to the ROW authorization prior to any modifications to 

the ROW required for decommissioning.

Gravel work pads will be removed; gravel and other borrow material brought to the ROW during 

construction will be disposed of as approved by the agency.

Any wells constructed on the ROW to support operations may be removed and properly closed in 

accordance with applicable local or State regulations.

All equipment, components, and above-ground structures shall be cleaned and removed from the site 

for reclamation, salvage, or disposal; all below-ground components shall be removed to a minimum 

depth of 3 feet to establish a root zone free of obstacles; pipeline segments and other components 

located at greater depths may be abandoned in place provided they are cleaned (of all residue) and 

filled with inert material to prevent possible future subsidence.

Dismantled and cleaned components shall be promptly removed; interim storage of removed 

components or salvaged materials that is required before final disposition is completed will not occur 

on Federal land.

At the close of decommissioning, applicants will provide the BLM authorized officer with survey data 

precisely locating all below grade components that were abandoned in place.

Mitigation and Monitoring

All control and mitigation measures established for the project in the POD and other required plans 

shall be incorporated into a decommissioning plan that shall be approved by the BLM authorized 

officer); the decommissioning plan shall include a site reclamation plan and a monitoring program and 

shall be coordinated with owners and operators of other systems on the corridor to ensure no 

disruption to the operation of those systems.

Surface Water

A SWPPP permit shall be obtained and its provisions implemented for all affected areas before any 

ground-disturbance activities commence.

Transportation

Additional access roads needed for decommissioning shall follow the paths of access roads 

established during construction to the greatest extent possible; all access roads not required for the 

continued operation and maintenance of other energy systems present in the corridor shall be 

removed and their footprints reclaimed and restored.

Restoration

Topsoil removed during decommissioning activities shall be salvaged and reapplied during final 

reclamation; all areas of disturbed soil shall be reclaimed using weed-free native shrubs, grasses, 

and forbs or other plant species approved by the BLM authorized officer; grades shall be returned to 

pre-development contours to the greatest extent feasible.

The vegetation cover, composition, and diversity shall be restored to values commensurate with the 

ecological setting, as approved by the authorized officer.

Hazardous Materials and Waste Management

All fuels, hazardous materials, and other chemicals shall be removed from the site and properly 

disposed of or reused.
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Incidental spills of petroleum products and other chemicals shall be removed and the affected area 

cleaned to meet applicable standards.

Solid wastes generated during decommissioning shall be accumulated, transported, and disposed in 

permitted offsite facilities in accordance with State and local requirements; no solid wastes shall be 

disposed of within the footprint of the ROW or the corridor.

Hazardous wastes generated as a result of component cleaning shall be containerized and disposed 

of in permitted facilities.

Minerals

Leasable Minerals

Geothermal Energy Development

The following best management practices (BMPs) are taken from the Record of Decision and Resource 

Management Plan Amendments for Geothermal Leasing in the Western United States (BLM, 2008c). 

Information Collection and Monitoring

General 

Prior to geothermal exploration and development, a complete subsurface geotechnical investigation 

will be conducted to analyze the soil and geologic conditions. The investigation will evaluate and 

identify potential geologic hazards and would provide remedial grading recommendations, foundation 

and slab design criteria, and soil parameters for the design of geothermal power infrastructure. 

The operator will collect available information describing the environmental and socio-cultural 

conditions in the vicinity of the proposed project and will provide the information to the agency. 

A monitoring program will be developed by the operator to ensure that environmental conditions are 

monitored during the exploration and well drilling, testing, construction, and utilization and reclamation 

phases. The monitoring program requirements, including adaptive management strategies, will be 

established at the project level to ensure that potential adverse impacts of geothermal development 

are mitigated. The monitoring program will identify the monitoring requirements for each major 

environmental resource present at the site, establish metrics against which monitoring observations 

can be measured, identify potential mitigation measures, and establish protocols for incorporating 

monitoring observations and additional mitigation measures into ongoing activities. The operator will 

provide results of the monitoring program to the agency in an annual report.

Paleontological and Cultural Resources 

Before any specific permits are issued under leases, treatment of cultural resources will follow the 

procedures established by the Advisory Council on Historic Preservation for compliance with Section 

106 of the National Historic Preservation Act. A pedestrian inventory will be undertaken of all portions 

that have not been previously surveyed or are identified by BLM as requiring inventory to identify 

properties that are eligible for the the National Register of Historic Places (NRHP). Those sites not 

already evaluated for NRHP eligibility will be evaluated based on surface remains, subsurface testing, 

and archival and/or ethnographic sources. Subsurface testing will be kept to a minimum whenever 

possible if sufficient information is available to evaluate the site or if avoidance is an expected 

mitigation outcome. Recommendations regarding the eligibility of sites will be submitted to the BLM, 

and a treatment plan will be prepared to detail methods for avoidance of impacts or mitigation of 

impacts. The BLM will make determinations of eligibility and effect and consult with the State Historic 

Preservation Officer as necessary based on each proposed lease application and project plans. The 

BLM may require modification to exploration or development proposals to protect such properties, or 

disapprove any activity that is likely to result in adverse effects that cannot be successfully avoided, 

minimized, or mitigated. Avoidance of impacts through project design will be given priority over data 

recovery as the preferred mitigation measure. Avoidance measures include moving project elements 

away from site locations or to areas of previous impacts, restricting travel to existing roads, and 

maintaining barriers and signs in areas of cultural sensitivity. Any data recovery will be preceded by 
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approval of a detailed research design, Native American consultation, and other requirements for 

BLM issuance of a permit under the Archaeological Resources Protection Act. 

If cultural resources are present at the site, or if areas with a high potential to contain cultural material 

have been identified, a Cultural Resources Management Plan (CRMP) will be developed. This plan 

will address mitigation activities to be taken for cultural resources found at the site. Avoidance of the 

area is always the preferred mitigation option. Other mitigation options include archaeological survey 

and excavation (as warranted) and monitoring. If an area exhibits a high potential, but no artifacts 

were observed during an archaeological survey, monitoring by a qualified archaeologist could be 

required during all excavation and earthmoving in the high potential area. A report will be prepared 

documenting these activities. The CRMP also will: 

Establish a monitoring program, 

Identify measures to prevent potential looting/vandalism or erosion impacts, and

Address the education of workers and the public to make them aware of the consequences of 

unauthorized collection of artifacts and destruction of property on public land.

Operators will determine whether paleontological resources exist in a project area on the basis of the 

sedimentary context of the area, a records search for past paleontological finds in the area, and/or, 

depending on the extent of existing information, a paleontological survey. 

If paleontological resources are present at the site, or if areas with a high potential to contain 

paleontological material have been identified, a paleontological resources management plan will be 

developed. This plan will include a mitigation plan for avoidance, removal of fossils, or monitoring. If 

an area exhibits a high potential but no fossils were observed during survey, monitoring by a qualified 

paleontologist may be required during excavation and earthmoving in the sensitive area. The operator 

will submit a report to the agency documenting these activities. The paleontological resources 

management plan also will: 

Establish a monitoring program, 

Identify measures to prevent potential looting/vandalism or erosion impacts, and 

Address the education of workers and the public to make them aware of the consequences of 

unauthorized collection of fossils on public land.

Water Resources 

In coordination with State regulatory agencies the operator will comply with all Federal and State 

surface and ground water rules and regulations for all phases of geothermal exploration, 

development, and reclamation. 

Operators will develop a storm water management plan for the site to ensure compliance with 

applicable regulations and prevent off-site migration of contaminated storm water or increased soil 

erosion. 

Operators will gain a clear understanding of the local hydrogeology. Areas of groundwater discharge 

and recharge and their potential relationships with surface water bodies will be identified. 

Operators will avoid creating hydrologic conduits between discrete aquifers during foundation 

excavation and other activities.

Freshwater-bearing and other usable water aquifers will be protected from contamination by assuring 

all well casing (excluding the liner) is required to be cemented from the casing shoe to the surface.

Periodic testing and monitoring via observation wells will be conducted in a manner to assure 

maximum protection of water resources from geothermal fluids or alterations in reservoir pressure.

Vegetation and Fish and Wildlife

The operator will conduct surveys for plant and animal species that are listed or proposed for listing 

as threatened or endangered and their habitats in areas proposed for development where these 

species could potentially occur, following accepted protocols and in consultation with the US Fish ad 

Wildlife Service or National Marine Fisheries Service, as appropriate. Particular care should be taken 

to avoid disturbing listed species during surveys in any designated critical habitat. The operator will 

monitor activities and their effects on Endangered Species Act-listed species throughout the duration 

of the project. 

The operator will identify important, sensitive, or unique habitat and biota in the project vicinity and 

site and should design the project to avoid (if possible), minimize, or mitigate potential impacts on 
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these resources. The design and siting of the facilities will follow appropriate guidance and 

requirements from the BLM and other resource agencies, as available and applicable.

National Scenic and Historic Trails 

When any right-of-way application includes remnants of a National Historic Trail, is located within the 

viewshed of a National Historic Trail’s designated centerline, or includes or is within the viewshed of a 

trail eligible for listing on the National Register of Historic Places, the operator will evaluate the 

potential visual impacts to the trail associated with the proposed project and identify appropriate 

mitigation measures for inclusion in the operation plan. 

Air Quality and Climate 

The operator will coordinate with the State Air Quality Division to develop and implement an air 

quality monitoring plan.

Planning, Location, And Design

Traffic Planning 

Operators will consult with local planning authorities regarding increased traffic prior to the 

construction phase, including an assessment of the number of vehicles per day, their size, and type. 

Specific issues of concern (e.g., location of school bus routes and stops) will be identified and 

addressed in the traffic management plan.

Roads and Pads 

To plan for efficient use of the land, necessary infrastructure will be consolidated wherever possible. 

Existing roads and pad sites will be used to the maximum extent feasible, but only if located in a safe 

and environmentally sound location. No new roads and pad sites will be constructed without agency 

authorization. If new roads and pad sites have been authorized, they will be designed and 

constructed by the operator to the appropriate agency standard, no higher than necessary to 

accommodate their intended function. Roads and pad sites will be routinely maintained by the 

operator to maintain public safety and to minimize impacts to the environment such as erosion, 

sedimentation, fugitive dust, and/or loss of vegetation.

An access road siting and management plan will be prepared incorporating existing Agency 

standards regarding road design, construction, and maintenance such as those described in the BLM 

9113 Manual and the Surface Operating Standards for Oil and Gas Exploration and Development

(i.e., the Gold Book, 4th Edition, 2007).

A traffic management plan will be prepared for the site access roads to ensure that no hazards would 

result from the increased truck traffic and that traffic flow would not be adversely impacted. This plan 

will incorporate measures such as informational signs, flaggers when equipment may result in 

blocked throughways, and traffic cones to identify any necessary changes in temporary lane 

configuration. 

Where possible, access roads will be located to follow natural contours and minimize side hill cuts 

and fills. Excessive grades on roads, road embankments, ditches, and drainages will be avoided, 

especially in areas with erodible soils. 

Roads will be designed so that changes to surface water runoff are minimized and new erosion is not 

initiated.

Access roads will be located to minimize stream crossings. All structures crossing streams will be 

located and constructed so that they do not decrease channel stability or increase water velocity. 

Operators will obtain all applicable Federal and State water crossing permits. 

Roads will be located away from drainage bottoms and avoid wetlands, if practicable.

Geotechnical Analysis 

The operator will perform a detailed geotechnical analysis prior to the construction of any structures; 

so they will be sited to avoid any hazards from subsidence or liquefaction (i.e., the changing of a 

saturated soil from a relatively stable solid state to a liquid during earthquakes or nearby blasting).
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Visual Design Considerations 

The operator will incorporate visual design considerations into the planning and design of the project 

to minimize potential visual impacts of the proposal and to meet the VRM objectives including:

Construct low-profile structures whenever possible to reduce structure visibility.

Select and design materials and surface treatments to repeat or blend with landscape elements.

Site projects outside of the viewsheds of publicly accessible vantage points, or if this cannot be 

avoided, as far away as possible.

Site projects to take advantage of both topography and vegetation as screening devices to restrict 

views of projects from visually sensitive areas.

Site facilities away from and not adjacent to prominent landscape features (e.g., knobs and water 

features).

Avoid placing facilities on ridgelines, summits, or other locations such that they will be silhouetted 

against the sky from important viewing locations.

Co-locate facilities to the extent possible to use existing and shared rights-of-way (ROWs), 

existing and shared access and maintenance roads, and other infrastructure to reduce visual they 

do not bisect ridge tops or run down the center of valley bottoms.

Site linear features (aboveground pipelines, ROWs, and roads) to follow natural land contours 

rather than straight lines (particularly up slopes) when possible. Fall-line cuts should be avoided.

Site facilities, especially linear facilities, to take advantage of natural topographic breaks (i.e., 

pronounced changes in slope) to avoid siting facilities on steep side slopes.

Where available, site linear features such as ROWs and roads to follow the edges of clearings 

(where they will be less conspicuous) rather than passing through the centers of clearings.

Site facilities to take advantage of existing clearings to reduce vegetation clearing and ground 

disturbance, where possible.

Site linear features (e.g., trails, roads, rivers) to cross other linear features at right angles 

whenever possible to minimize viewing area and duration.

Site and design structures and roads to minimize and balance cuts and fills and to preserve 

existing rocks, vegetation, and drainage patterns to the maximum extent possible. 

Use appropriately colored materials for structures or appropriate stains and coatings to blend with 

the project’s backdrop. Refer to the Standard Environmental Colors chart available from the BLM.

Use non-reflective or low-reflectivity materials, coatings, or paints whenever possible.

Paint grouped structures the same color to reduce visual complexity and color contrast.

Design and install efficient facility lighting so that the minimum amount of lighting required for 

safety and security is provided but not exceeded and so that upward light scattering (light 

pollution) is minimized. This may include, for example, installing shrouds to minimize light from 

straying off-site, properly directing light to only illuminate necessary areas, and installing motion 

sensors to only illuminate areas when necessary.

Site construction staging areas and laydown areas outside of the viewsheds of publicly 

accessible vantage points and visually sensitive areas, where possible, including siting in swales, 

around bends, and behind ridges and vegetative screens.

Discuss visual impact mitigation objectives and activities with equipment operators prior to 

commencement of construction activities.

 Mulch or scatter slash from vegetation removal and spread it to cover fresh soil disturbances or, if 

not possible, bury or compost slash. 

If slash piles are necessary, stage them out of sight of sensitive viewing areas. 

Avoid installing gravel and pavement where possible to reduce color and texture contrasts with 

existing landscape. 

Use excess fill to fill uphill-side swales resulting from road construction in order to reduce 

unnatural-appearing slope interruption and to reduce fill piles. 

Avoid downslope wasting of excess fill material. 

Round road-cut slopes, vary cut and fill pitch to reduce contrasts in form and line, and vary slope 

to preserve specimen trees and nonhazardous rock outcroppings. 

Leave planting pockets on slopes where feasible. 

Combine methods of re-establishing native vegetation through seeding, planting of nursery stock, 

transplanting of local vegetation within the proposed disturbance areas, and staging of 

construction enabling direct transplanting.
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Revegetate with native vegetation establishing a composition consistent with the form, line, color, 

and texture of the surrounding undisturbed landscape.

Provide benches in rock cuts to accent natural strata. 

Use split-face rock blasting to minimize unnatural form and texture resulting from blasting. 

Segregate topsoil from cut and fill activities and spread it on freshly disturbed areas to reduce 

color contrast and to aid rapid revegetation. 

Bury utility cables in or adjacent to the road where feasible. 

Minimize signage and paint or coat reverse sides of signs and mounts to reduce color contrast 

with existing landscape. 

Prohibit trash burning; store trash in containers to be hauled off-site for disposal. 

Undertake interim restoration during the operating life of the project as soon as possible after 

disturbances. During road maintenance activities, avoid blading existing forbs and grasses in 

ditches and along roads.

Randomly scarify cut slopes to reduce texture contrast with existing landscape and to aid in 

revegetation. 

Cover disturbed areas with stockpiled topsoil or mulch, and revegetate with a mix of native 

species selected for visual compatibility with existing vegetation. 

Restore rocks, brush, and natural debris whenever possible to approximate preexisting visual 

conditions.

Air Quality and Climate 

The operator will prepare and submit to the agency an Equipment Emissions Mitigation Plan for 

managing diesel exhaust. An Equipment Emissions Mitigation Plan will identify actions to reduce 

diesel particulate, carbon monoxide, hydrocarbons, and nitrogen oxides associated with construction 

and drilling activities. The Equipment Emissions Mitigation Plan will require that all 

drilling/construction related engines are maintained and operated as follows: 

Are tuned to the engine manufacturer’s specification in accordance with an appropriate time 

frame. 

Do not idle for more than five minutes (unless, in the case of certain drilling engines, it is 

necessary for the operating scope). 

Are not tampered with in order to increase engine horsepower. 

Include particulate traps, oxidation catalysts, and other suitable control devices on all 

drilling/construction equipment used at the project site. 

Use diesel fuel having a sulfur content of 15 parts per million or less, or other suitable alternative 

diesel fuel, unless such fuel cannot be reasonably procured in the market area. 

Include control devices to reduce air emissions. The determination of which equipment is suitable 

for control devices should be made by an independent Licensed Mechanical Engineer. 

Equipment suitable for control devices may include drilling equipment, work over and service rigs, 

mud pumps, generators, compressors, graders, bulldozers, and dump trucks.

Health and Safety 

Operators will develop a hazardous materials management plan addressing storage, use, 

transportation, and disposal of each hazardous material anticipated to be used at the site. The plan 

will identify all hazardous materials that would be used, stored, or transported at the site. It will 

establish inspection procedures, storage requirements, storage quantity limits, inventory control, 

nonhazardous product substitutes, and disposition of excess materials. The plan will also identify 

requirements for notices to Federal and local emergency response authorities and include emergency 

response plans. 

Operators will develop a waste management plan identifying the waste streams that are expected to 

be generated at the site and addressing hazardous waste determination procedures, waste storage 

locations, waste-specific management and disposal requirements, inspection procedures, and waste 

minimization procedures. This plan will address all solid and liquid wastes that may be generated at 

the site. 

Operators will develop a spill prevention and response plan identifying where hazardous materials 

and wastes are stored on site, spill prevention measures to be implemented, training requirements, 

appropriate spill response actions for each material or waste, the locations of spill response kits on
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site, a procedure for ensuring that the spill response kits are adequately stocked at all times, and 

procedures for making timely notifications to authorities. 

A safety assessment will be conducted to describe potential safety issues and the means that would 

be taken to mitigate them, including issues such as site access, construction, safe work practices, 

security, heavy equipment transportation, traffic management, emergency procedures, and fire 

control. 

A health and safety program will be developed to protect both workers and the general public during 

construction and operation of geothermal projects.

 The safety program will identify all applicable Federal and State occupational safety standards; 

establish safe work practices for each task (e.g., requirements for personal protective equipment and 

safety harnesses; Occupational Safety and Health Administration standard practices for safe use of 

explosives and blasting agents; and measures for reducing occupational electric and magnetic fields 

exposures); establish fire safety evacuation procedures; and define safety performance standards 

(e.g., electrical system standards and lightning protection standards). The program will include a 

training program to identify hazard training requirements for workers for each task and establish 

procedures for providing required training to all workers. Documentation of training and a mechanism 

for reporting serious accidents to appropriate agencies will be established. 

 The health and safety program will establish a safety zone or setback for generators from residences 

and occupied buildings, roads, ROWs, and other public access areas that is sufficient to prevent 

accidents resulting from the operation of generators. It will identify requirements for temporary fencing 

around staging areas, storage yards, and excavations during construction or rehabilitation activities. It 

will also identify measures to be taken during the operation phase to limit public access to hazardous 

facilities (e.g., permanent fencing would be installed only around electrical substations, and facility 

access doors would be locked). 

Operators will consult with local planning authorities regarding increased traffic during the 

construction phase, including an assessment of the number of vehicles per day, their size, and type. 

Specific issues of concern (e.g., location of school bus routes and stops) will be identified and 

addressed in the traffic management plan. 

Operators will develop a fire management strategy to implement measures to minimize the potential 

for a human-caused fire.

Livestock Grazing 

The operator will coordinate with livestock operators to minimize impacts to livestock operations.

Noxious Weeds and Pesticides 

Operators will develop a plan for control of noxious weeds and invasive plant species, which could 

occur as a result of new surface disturbance activities at the site. The most recent recommendations 

at the State and local level should be incorporated into any operating plan for the geothermal 

exploration and development. The plan will address monitoring, education of personnel on weed 

identification, the manner in which weeds spread, and methods for treating infestations. The use of 

certified weed-free mulching will be required. If trucks and construction equipment are arriving from 

locations with known invasive vegetation problems, a controlled inspection and cleaning area will be 

established to visually noxious weed and inspect construction equipment arriving at the project area 

and to remove and collect seeds that may be adhering to tires and other equipment surfaces. 

If pesticides are used on the site, an integrated pest management plan will be developed to ensure 

that applications would be conducted within the framework of all Federal, State, and local laws and 

regulations and entail only the use of Environmental Protection Agency-registered pesticides.

Vegetation and Fish and Wildlife 

The operator will prepare a habitat restoration plan to avoid (if possible), minimize, or mitigate 

negative impacts on wildlife while maintaining or enhancing habitat values for other species. The plan 

will identify revegetation, soil stabilization, and erosion reduction measures that will be implemented 

to ensure that all temporary use areas are restored. The plan will require that restoration occur as 

soon as possible after completion of activities to reduce the amount of habitat converted at any one 

time and to speed up the recovery to natural habitats.
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Construction

Traffic Management 

Traffic will be restricted to the roads developed for the project. Use of other unimproved roads will be 

restricted to emergency situations. 

Signs will be placed along roads to identify speed limits, travel restrictions, and other standard traffic 

control information. Signs directing vehicles to alternate park access and parking will be posted in the 

event construction temporarily obstructs recreational parking areas near trailheads. Whenever active 

work is being performed, the area will be posted with “construction ahead” signs on any adjacent 

access roads or trails that might be affected.

Project personnel and contractors will be instructed and required to adhere to speed limits 

commensurate with road types, traffic volumes, vehicle types, and site-specific conditions, to ensure 

safe and efficient traffic flow and to reduce wildlife collisions and disturbance and fugitive dust. 

When practical, construction activities will be avoided during high recreational use periods.

Roads and Pads 

The operator will obtain agency authorization prior to using soil or rock material from agency lands. 

Road use will be restricted during the wet season if road surfacing is not adequate to prevent soil 

displacement, rutting, etc., and resultant stream sedimentation. 

Access roads and on-site roads will be surfaced with aggregate materials where necessary to provide 

a stable road surface, support anticipated traffic, reduce fugitive dust, and prevent erosion. 

Dust abatement techniques will be used before and during surface clearing, excavation, or blasting 

activities. Dust abatement techniques will be used on unpaved, unvegetated surfaces to minimize 

fugitive dust. Speed limits (e.g., 25 mph) will be posted and enforced to reduce fugitive dust. 

Construction materials and stockpiled soils will be covered if they are a source of fugitive dust. 

Culvert outlets will be rip-rapped to dissipate water energy at the outlet and reduce erosion. Catch 

basins, roadway ditches, and culverts will be cleaned and maintained regularly.

Pipelines 

Pipelines constructed above ground due to thermal gradient induced expansion and contraction will 

rest on cradles above ground level, allowing small animals to pass underneath. Projects should be 

analyzed to ensure adequate passage for all wildlife species. The pipeline will be raised higher to 

allow wildlife passage where needed. Because pipeline corridors through certain habitat types can 

alter local predator-prey dynamics by providing predators with lines of sight and travel corridors, large 

projects should be analyzed to ensure there will be no significant changes to predator-prey balance. 

Utilities 

Underground utilities will be installed to minimize the amount of open trenches at any given time, 

keeping trenching and backfilling crews close together. Avoid leaving trenches open overnight. Where 

trenches cannot be back-filled immediately, escape ramps should be constructed at least every 100 

feet.

Specific Resources

Cultural and Paleontological Resources 

Unexpected discovery of cultural or paleontological resources during construction will be brought to

the attention of the BLM authorized officer immediately. Work will be halted in the vicinity of the find to 

avoid further disturbance to the resources while they are being evaluated and appropriate mitigation 

measures are being developed.

Noise 

The operator will take measurements to assess the existing background noise levels at a given site 

and compare them with the anticipated noise levels associated with the proposed project.

Within two miles of existing, occupied residences, geothermal well drilling or major facility 

construction operations will be restricted to non-sleeping hours (7:00 am to 10:00 pm).
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All equipment will have sound-control devices no less effective than those provided on the original 

equipment. All construction equipment used will be adequately muffled and maintained. 

All stationary construction equipment (i.e., compressors and generators) will be located as far as 

practicable from nearby residences. 

If blasting or other noisy activities are required during the construction period, nearby residents will be 

notified by the operator at least one hour in advance. 

Explosives will be used only within specified times and at specified distances from sensitive wildlife or 

streams and lakes, as established by the Federal and State agencies.

Noxious Weeds and Pesticides 

The use of certified, weed-free mulch will be required when stabilizing areas of disturbed soil. 

If trucks and construction equipment are arriving from locations with known noxious weeds or

invasive vegetation problems, a controlled inspection and cleaning area will be established to visually 

inspect construction equipment arriving at the project area and to remove and collect seeds that may 

be adhering to tires and other equipment surfaces. 

Fill materials and road surfacing materials that originate from areas with known noxious weeds and 

invasive vegetation problems will not be used. 

Revegetation, habitat restoration, and weed control activities will be initiated as soon as possible after 

construction activities are completed. 

Use of pesticides must be approved by the agency. Pesticide use will be limited to agency-approved 

pesticides and will only be applied in accordance with label and application permit directions and 

stipulations for terrestrial and aquatic applications.

Waste Management 

All refueling will occur in a designated fueling area that includes a temporary berm to limit the spread 

of any spill. 

Drip pans will be used during refueling to contain accidental releases. 

Drip pans will be used under fuel pump and valve mechanisms of any bulk fueling vehicles parked at 

the construction site.

 Any containers used to collect liquids will be enclosed or screened to prevent access to contaminants 

by wildlife, livestock, and migratory birds. 

Spills will be immediately addressed per the spill management plan, and soil cleanup and removal 

initiated as soon as feasible.

Wild Horses and Burros 

The operator will ensure employees, contractors, and site visitors avoid harassment and disturbance 

of wild horses and burros, especially during reproductive (e.g., breeding and birthing) seasons. In 

addition, any pets will be controlled to avoid harassment and disturbance of wild horses and burros. 

Observations of potential problems regarding wild horses or burros, including animal mortality, will be 

immediately reported to the agency.

Wildlife

The operator will ensure that employees, contractors, and site visitors avoid harassment and 

disturbance of wildlife, especially during reproductive (e.g., courtship and nesting) seasons. In 

addition, pets will be controlled or excluded to avoid harassment and disturbance of wildlife. 

Ponds, tanks, and impoundments (including but not limited to drill pits) containing liquids can present 

hazards to wildlife. Any liquids contaminated by substances which may be harmful due to toxicity or 

fouling of the fur or feathers (detergents, oils), should be excluded from wildlife access by fencing, 

netting, or covering at all times when not in active use. Liquids at excessive temperature should 

likewise be excluded. If exclusion is not feasible, such as a large pond, a hazing program based on 

radar or visual detection, in conjunction with formal monitoring, should be implemented. Clean water 

impoundments can also present a trapping hazard if they are steep-sided or lined with smooth 

material. All pits, ponds, and tanks should have escape ramps functional at any reasonably 

anticipated water level, down to almost empty. Escape ramps can take various forms depending on 

the configuration of the impoundment. Earthen pits may be constructed with one side sloped 3:1 or 
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greater; lined ponds can use textured material; straight-sided tanks can be fitted with expanded metal 

escape ladders. 

Operations/Utilization

“Good housekeeping” procedures will be developed by the operator to ensure that during all phases 

of operation, the site will be kept clean of noxious weeds, debris, litter, garbage, fugitive trash or 

waste, and graffiti. Scrap heaps and dumps are prohibited. Storage yards are to be minimized to that 

which is absolutely necessary.

Reclamation

The following objectives, performance standards, and recommended reclamation BMPs and mitigation 

measures are based on the standards and guidelines found in the BLM Gold Book, 4th Edition, updated 

in 2007.

Reclamation Objectives 

The objective of interim reclamation is to restore vegetative cover and a portion of the landform 

sufficient to maintain healthy, biologically active topsoil; control erosion; and minimize habitat, visual, 

and forage loss during the life of the well or facilities. 

The long-term objective of final reclamation is to return the land to a condition approximating that 

which existed prior to disturbance. This includes restoration of the landform and natural vegetative 

community, hydrologic systems, visual resources, and wildlife habitats. To ensure that the long-term 

objective will be reached through human and natural processes, actions will be taken to ensure 

standards are met for site stability, visual quality, hydrological functioning, and vegetative productivity.

Reclamation Performance Standards 

The following reclamation performance standards will be met:

Interim Reclamation: 

Includes disturbed areas that may be redisturbed during operations and will be redisturbed at final 

reclamation to achieve restoration of the original landform and a natural vegetative community.

Disturbed areas not needed for active, long-term production operations or vehicle travel have been 

recontoured, protected from erosion, and revegetated with a self-sustaining, vigorous, diverse, native 

(or as otherwise approved) plant community sufficient to minimize visual impacts, provide forage, 

stabilize soils, and impede the invasion of noxious, invasive, and non-native weeds.

Final Reclamation: 

[ ] Indicates site-specific values to be filled in by the authorized officer

Includes disturbed areas where the original landform and a natural vegetative community have been 

restored. 

The original landform has been restored for all disturbed areas including well pads, production 

facilities, roads, pipelines, and utility corridors. 

General: A self-sustaining, vigorous, diverse, native (or otherwise approved) plant community is 

established on the site, with a density sufficient to control erosion and invasion by noxious weeds and 

invasive plants and to reestablish wildlife habitat or forage production. At a minimum, the established 

plant community will consist of species included in the seed mix and/or desirable species occurring in 

the surrounding natural vegetation.

Specific: No single species will account for more than 30% total vegetative composition unless it is 

evident at higher levels in the adjacent landscape. Permanent vegetative cover will be determined 

successful when the basal cover of desirable perennial species is at least [80]% of the basal cover on 

adjacent or nearby undisturbed areas where vegetation is in a healthy condition; or [80]% of the 

potential basal cover as defined in the National Resource Conservation Service Ecological Site(s) for 

the area. Plants must be resilient as evidenced by well-developed root systems and flowers. [Shrubs 

will be well established and in a “young” age class at a minimum (therefore, not comprised mainly of 

seedlings that may not survive until the following year).] 
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In agricultural areas, irrigation systems and soil conditions are reestablished in such a way as to 

ensure successful cultivation and harvesting of crops.

Erosion features are equal to or less than surrounding area and erosion control is sufficient so that 

water naturally infiltrates into the soil and gullying, headcutting, slumping, and deep or excessive rills 

(greater than three inches) are not observed.

The site is free of State- or county-listed noxious weeds, oil field debris and equipment, and 

contaminated soil. Noxious weeds and invasive plants are controlled.

Reclamation Actions 

During initial well pad, production facility, road, pipeline, and utility corridor construction and prior to 

completion of the final well on the well pad, pre-interim reclamation stormwater management actions 

will be taken to ensure disturbed areas are quickly stabilized to control surface water flow and to 

protect both the disturbed and adjacent areas from erosion and siltation. This may involve 

construction and maintenance of temporary silt ponds, silt fences, berms, ditches, and mulching.

When the last well on the pad has been completed, some portions of the well location will undergo 

interim reclamation and some portions of the well pad will usually undergo final reclamation. Most well 

locations will have limited areas of bare ground, such as a small area around production facilities or 

the surface of a rocked road. Other areas will have interim reclamation where workover rigs and 

fracturing tanks may need a level area to set up in the future. Some areas will undergo final 

reclamation where portions of the well pad will no longer be needed for production operations and 

can be recontoured to restore the original landform.

The following minimum reclamation actions will be taken to ensure that the reclamation objectives 

and standards are met. It may be necessary to take additional reclamation actions beyond the 

minimum in order to achieve the Reclamation Standards. 

Reclamation - General 

Procedure: 

The agency will be notified 24 hours prior to commencement of any reclamation operations. 

Housekeeping: 

Immediately upon well completion, the well location and surrounding areas(s) will be cleared of, and 

maintained free of, all debris, materials, trash, and equipment not required for production. 

No hazardous substances, trash, or litter will be buried or placed in pits. Upon well completion, any 

hydrocarbons in the pit will be remediated or removed.

Vegetation Clearing: 

Vegetation removal and the degree of surface disturbance will be minimized wherever possible. 

Example of site-specific requirement: During vegetation clearing activities, trees and woody 

vegetation removed from the well pad and access road will be moved aside prior to any soil 

disturbing activities. Care will be taken to avoid mixing soil with the trees and woody vegetation. 

Trees left for wood gathering will be cut 12 inches or less from the ground, delimbed, and the 

trunks, 6 inches or more in diameter will be removed and placed either by the uphill side of the 

access road, or moved to the end of the road, or to a road junction for easy access for wood 

gatherers and to reduce vehicle traffic on the well pad. Trees with a trunk diameter less than six 

inches and woody vegetation will be used to trap sediment, slow runoff, or scattered on reclaimed 

areas to stabilize slopes, control erosion, and improve visual resources.

Topsoil Management: 

Operations will disturb the minimum amount of surface area necessary to conduct safe and efficient 

operations. When possible, equipment will be stored and operated on top of vegetated ground to 

minimize surface disturbance.

In areas to be heavily disturbed, the top eight inches of soil material, will be stripped and stockpiled 

around the perimeter of the well location to control run-on and run-off, and to make redistribution of 

topsoil more efficient during interim reclamation. Stockpiled topsoil may include vegetative material. 

Topsoil will be clearly segregated and stored separately from subsoils.
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

Design Features, and Operating Procedures

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Earthwork for interim and final reclamation will be completed within 6 months of well completion or 

plugging unless a delay is approved in writing by the BLM authorized officer.

Salvaging and spreading topsoil will not be performed when the ground or topsoil is frozen or too wet 

to adequately support construction equipment. If such equipment creates ruts in excess of four inches 

deep, the soil will be deemed too wet. 

No major depressions will be left that would trap water and cause ponding.

Seeding: 

Seedbed Preparation

Initial seedbed preparation will consist of recontouring to the appropriate interim or final reclamation 

standard. All compacted areas to be seeded will be ripped to a minimum depth of 18 inches with a 

minimum furrow spacing of two feet, followed by recontouring the surface and then evenly spreading 

the stockpiled topsoil. Prior to seeding, the seedbed will be scarified and left with a rough surface.

If broadcast seeding is to be used and is delayed, final seedbed preparation will consist of contour 

cultivating to a depth of four to six inches within 24 hours prior to seeding, dozer tracking, or other

imprinting in order to loosen up the soil and create seed germination micro-sites. 

Seed Application

Seeding will be conducted no more than 24 hours following completion of final seedbed preparation. 

A certified weed free seed mix designed by BLM to meet reclamation standards will be used.

No seeding will occur from [May 15 to September 15]. Fall seeding is preferred and will be conducted 

after [September 15] and prior to ground freezing. [Shrub species will be seeded separately and will 

be seeded during the winter.] Spring seeding will be conducted after the frost leaves the ground and 

no later than [May 15].

Erosion Control and Mulching: 

Mulch, silt fencing, waddles, hay bales, and other erosion control devices will be used on areas at risk 

of soil movement from wind and water erosion.

Mulch will be used if necessary to control erosion, create vegetation micro-sites, and retain soil 

moisture and may include hay, small grain straw, wood fiber, live mulch, cotton, jute, or synthetic 

netting. Mulch will be free from mold, fungi, and certified free of noxious or invasive weed seeds.

If straw mulch is used, it will contain fibers long enough to facilitate crimping and provide the greatest 

cover. 

Pit Closure: 

Reserve pits will be closed and backfilled within 60days of release of the rig. All reserve pits 

remaining open after 60 days will require written authorization of the authorized officer. Immediately 

upon well completion, any hydrocarbons or trash in the pit will be removed. Pits will be allowed to dry, 

be pumped dry, or solidified in-situ prior to backfilling.

Following completion activities, pit liners will be completely removed or removed down to the solids 

level and disposed of at an approved landfill, or treated to prevent their reemergence to the surface 

and interference with long-term successful revegetation. If it was necessary to line the pit with a 

synthetic liner, the pit will not be trenched (cut) or filled (squeezed) while containing fluids. When dry, 

the pit will be backfilled with a minimum of five feet of soil material. In relatively flat areas the pit area 

will be slightly mounded above the surrounding grade to allow for settling and to promote surface 

drainage away from the backfilled pit. 

Management of Noxious Weeds and Invasive Plants: 

All reclamation equipment will be cleaned prior to use to reduce the potential for introduction of 

noxious weeds or other undesirable non-native species. 

An intensive weed monitoring and control program will be implemented prior to site preparation for 

planting and will continue until interim or final reclamation is approved by the authorized officer. 

Monitoring will be conducted at least annually during the growing season to determine the presence 

of any noxious weeds and invasive plant species. Noxious weeds and invasive plant species that 

have been identified during monitoring will be promptly treated and controlled. A Pesticide Use 

Proposal will be submitted to the BLM for approval prior to the use of herbicides.
Appendix B: Best Management Practices, Jarbidge Proposed RMP/Final EIS

Design Features, and Operating Procedures

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Interim Reclamation Procedures

Recontouring: 

Interim reclamation actions will be completed no later than six months from when the final well on the 

location has been completed, weather permitting. The portions of the cleared well site not needed for 

active operational and safety purposes will be recontoured to the original contour if feasible, or if not 

feasible, to an interim contour that blends with the surrounding topography as much as possible. 

Sufficient semi-level area will remain for setup of a workover rig and to park equipment. In some

cases, rig anchors may need to be pulled and reset after recontouring to allow for maximum interim 

reclamation. 

If the well is a producer, the interim cut and fill slopes prior to reseeding will not be steeper than a 3:1 

ratio, unless the adjacent native topography is steeper. Note: Constructed slopes may be much 

steeper during drilling, but will be recontoured to the above ratios during interim reclamation. 

Roads and well production equipment will be placed on location so as to permit maximum interim 

reclamation of disturbed areas. If equipment is found to interfere with the proper interim reclamation 

of disturbed areas, the equipment will be moved so proper recontouring and revegetation can occur.

Application of Topsoil and Revegetation: 

Topsoil will be evenly respread and aggressively revegetated over the entire disturbed area not 

needed for all-weather operations including road cuts and fills and to within a few feet of the 

production facilities, unless an all-weather, surfaced, access route or small “teardrop” turnaround is 

needed on the well pad.

In order to inspect and operate the well or complete workover operations, it may be necessary to 

drive, park, and operate equipment on restored, interim vegetation within the previously disturbed 

area. Damage to soils and interim vegetation will be repaired and reclaimed following use. To prevent 

soil compaction, under some situations, such as the presence of moist, clay soils, the vegetation and 

topsoil will be removed prior to workover operations and restored and reclaimed following workover 

operations. 

Visual Resources: 

Trees, if present, and vegetation will be left along the edges of the pads whenever feasible to provide 

screening.

To help mitigate the contrast of recontoured slopes, reclamation will include measures to feather 

cleared lines of vegetation and to save and redistribute cleared trees, debris, and rock over 

recontoured cut and fill slopes.

To reduce the view of production facilities from visibility corridors and private residences, facilities will 

not be placed in visually exposed locations (such as ridgelines and hilltops) 

Production facilities will be clustered and placed away from cut slopes and fill slopes to allow the 

maximum recontouring of the cut and fill slopes.

All long-term, above-ground structures will be painted [Covert Green] (from the Standard 

Environmental Colors chart) to blend with the natural color of the late summer landscape background. 

Final Reclamation Procedures

Final reclamation actions will be completed within six months of well plugging, weather permitting.

All disturbed areas, including roads, pipelines, pads, production facilities, and interim reclaimed areas 

will be recontoured to the contour existing prior to initial construction or a contour that blends 

indistinguishably with the surrounding landscape. Resalvaged topsoil will be respread evenly over the 

entire disturbed site to ensure successful revegetation. To help mitigate the contrast of recontoured 

slopes, reclamation will include measures to feather cleared lines of vegetation and to save and 

redistribute cleared trees, woody debris, and large rocks over recontoured cut and fill slopes. 

Water breaks and terracing will only be installed when absolutely necessary to prevent erosion of fill 

material. Water breaks and terracing are not permanent features and will be removed and reseeded 

when the rest of the site is successfully revegetated and stabilized. 

If necessary to ensure timely revegetation, the pad will be fenced to BLM standards to exclude 

livestock grazing for the first two growing seasons or until seeded species become firmly established, 

whichever comes later. End panels and ‘H’ braces for fencing will meet standards found on page 18 
Jarbidge Proposed RMP/Final EIS Appendix B: Best Management Practices,

Design Features, and Operating Procedures

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of the BLM Gold Book, 4th Edition. Metal “T” posts should be approximately 16.5 feet apart. Wire 

spacing for three strand fence would be bottom wire smooth 16 inches above ground, second strand 

26 inches above ground, top strand 38 inches above ground. Wire spacing for strand strand fence 

(bottom wire smooth 16 inches above ground, second strand 22 inches above ground, third strand 28 

inches above ground, and top strand not to exceed 40 inches above ground) to allow big game 

movements. In sage-grouse habitat the top strand will be marked with permanent markers to reduce 

sage-grouse collisions with the fence. Operational electric fence may be used in lieu of barbed wire 

fences. The top strand of electric fence would not exceed 42 inches. The the electric fence has 

multiple wires bottom strand should be 20 inches or more above ground. If exclusion of big game is 

needed an eight foot tall fence could be constructed. 

Final abandonment of pipelines and flowlines will involve flushing and properly disposing of any fluids 

in the lines. All surface lines and any lines that are buried close to the surface that may become 

exposed in the foreseeable future due to water or wind erosion, soil movement, or anticipated 

subsequent use, must be removed. Deeply buried lines may remain in place unless otherwise 

directed by the authorized officer. 

Reclamation Monitoring and Final Abandonment Approval 

Reclaimed areas will be monitored annually. Actions will be taken to ensure that reclamation 

standards are met as quickly as reasonably practical. 

Reclamation monitoring will be documented in an annual reclamation report submitted to the 

authorized officer by [March 1]. The report will document compliance with all aspects of the 

reclamation objectives and standards, identify whether the reclamation objectives and standards are 

likely to be achieved in the near future without additional actions, and identify actions that have been 

or will be taken to meet the objectives and standards. The report will also include acreage figures for: 

Initial Disturbed Acres; Successful Interim Reclaimed Acres; Successful Final Reclaimed Acres. 

Annual reports will not be submitted for sites approved by the authorized officer in writing as having 

met interim or final reclamation standards. Monitoring and reporting continues annually until interim or 

final reclamation is approved. Any time 30% or more of a reclaimed area is redisturbed, monitoring 

will be reinitiated. 

The authorized officer will be informed when reclamation has been completed, appears to be 

successful, and the site is ready for final inspection.

Salable Minerals 

Ongoing Authorizations/Activities (i.e., an authorization has been issued)

Minimize the spread of noxious weed and invasive plant species caused by moving infested gravel 

and fill material (e.g., close the pit, treat infested areas).

Proposed Authorizations/Activities

Locate new salable mineral developments in annual or non-native grass communities rather than in 

native plant communities where practical.

For gravel pits in big game or sage-grouse winter or breeding habitat, schedule blasting, crushing, 

screening, and other operations from mid June through November.

Issue decorative rock permits in big game or sage-grouse winter or breeding habitat so rock gathering 

occurs between mid June and November. Monitoring of the pit areas in big game or sage-grouse 

habitat should include the monitoring of unauthorized routes to other areas that have rock. Sign 

unauthorized routes as closed.
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Jarbidge Proposed RMP/Final EIS Appendix C: Jarbidge RMP Mailing List

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APPENDIX C: JARBIDGE RMP MAILING LIST

All recipients of the Draft RMP/Environmental Impact Statement (EIS) and all parties who submitted 

written comments on the Draft RMP/EIS will receive the Proposed RMP/Final EIS in either a hard copy or 

CD-ROM, or they will be able to download it elctronically from the Idaho BLM Web site. 

The following organizations, businesses, and government entities are on the Jarbidge RMP mailing list

and will receive a hard copy, CD-ROM, or will be able to download it electronically from the Idaho BLM 

Web site. Individuals on the mailing list were not included in this appendix as they number over 26,000. 

The Jarbidge Field Office maintains the complete RMP mailing list in the administrative record, which is 

available upon request.

Organizations

 “71” Livestock Association

Advisory Council on Historic Preservation

American Horse Defense Fund

American Sportfishing Association

Animal Welfare Institute

Archery Trade Association

Association of Fish and Wildlife Agencies

Backcountry Hunters and Anglers

Bear Trust International

BLM Twin Falls District Resource Advisory Council

BlueRibbon Coalition

Boise ATV Trail Riders

Boise District Grazing Board

Boone and Crockett Club of America

Bowhunting Preservation Alliance

Buhl Chamber of Commerce

Campfire Club of America

Center for Biological Diversity

Committee for the High Desert

Congressional Sportsman’s Foundation

Conservation Force

Dallas Safari Club

Delta Waterfowl Foundation

Ducks Unlimited

Elko Area Chamber of Commerce

Elko County Cooperative Extension Office

Elko County Economic Diversification Authority

Elmore County Agri-Business Coalition, Inc.

Elmore County Cooperative Extension Office

Foundation for North American Wild Sheep

Friends of the Mustang

Glenns Ferry Chamber of Commerce

Golden Springs Homeowners 

Goodtime Association

Grand View Chamber of Commerce

Great Plains Restoration Council

Hagerman Valley Chamber of Commerce

High Desert Back Country Horsemen

High Desert Coalition, Inc.

Houston Safari Club
Appendix C: Jarbidge RMP Mailing List Jarbidge Proposed RMP/Final EIS

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Idaho Archaeological Society

Idaho Association of Soil Conservation Districts

Idaho ATV Association, Inc.

Idaho Cattle Association

Idaho Conservation League

Idaho Environmental Council

Idaho Fish and Wildlife Foundation

Idaho Migrant Council

Idaho Museum of Natural History

Idaho Native Plant Society

Idaho Native Plant Society, Loasa Chapter

Idaho Outfitters and Guides Association

Idaho Professional Archaeological Council, Inc.

Idaho Rivers United

Idaho State 4X4 Association

Idaho State Snowmobile Association

Idaho Wild Sheep Foundation

Idaho Wool Growers Association

 International Mountain Bike Association

Izaak Walton League of America

Jarbidge Sage-Grouse Local Working Group

Magic Valley ATV Riders, Inc.

Magic Valley Cattlemen’s Association

Magic Valley Gem Club

Magic Valley Trail Machine Association

Mountain Home ATV Club

Mountain Home Chamber of Commerce

Mule Deer Foundation

Mule Deer Foundation, Idaho

Mule Deer Foundation, Nevada

National Assembly of Sportsmen’s Caucuses

National Association for the Advancement of Colored People 

National Association for the Advancement of Colored People, Treasure Valley Branch

National Audubon Society, Prairie Falcon Chapter

National Rifle Association of America

National Shooting Sports Foundation

National Trapper’s Association

National Trust for Historic Preservation

 National Wild Turkey Federation

Nevada Bureau of Mines

Nevada Cattlemen’s Association

Nevada Mining Association

North American Bear Foundation

North American Grouse Partnership

Northwest Power Planning Council

Oregon-California Trails Association

Oregon-California Trails Association, Idaho Chapter

Orion-The Hunters Institute

Owyhee Cattlemen’s Association

Owyhee County Cooperative Extension Office

Owyhee County Historical Society

Owyhee Gem and Mineral Society, Inc.

Pheasants Forever
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Pheasants Forever, Region 7

Pope and Young Club

Preservation Idaho-Idaho Historic Preservation Council

Public Lands Foundation

Quail Unlimited

Quality Deer Management Association

Recreational Boating and Fishing Foundation

Rocky Mountain Elk Foundation

Ruffed Grouse Society

Safari Club International 

Sage Community Resources

Sagebrush Sea Campaign

Sand County Foundation

Sierra Club, Middle Snake Group

Snake River Canyon Krawlers

Society for Range Management, Idaho Section

South Central Idaho Tourism and Recreation Development Association

Southern Idaho Off-Road Association

Southwestern Idaho Desert Racing Association

Sporting Arms and Ammunition Manufacturers Institute

Sportsmen for Fish and Wildlife

Students Promoting Environmental Action and Knowledge, Cookeville High Chapter

Texas Wildlife Association

The College of Idaho

The Nature Conservancy

The Wilderness Society

The Wilderness Society, BLM Action Center

Theodore Roosevelt Conservation Partnership

Treasure Valley Trail Machine Association

Trout Unlimited

Twin Falls Chamber of Commerce

Twin Falls Research and Extension Center

University of Idaho

University of Idaho Extension

US Sportsmen’s Alliance

Wake Forest University

Western Watersheds Project

Whitetails Unlimited

Wild West Off Roaders

Wildlife Forever

Wildlife Management Institute

Wood River Land Trust

Businesses

Ace Black Ranches

Advocates for the West

American Tower Corp.

AT&T Mobility Corporation

Barker River Expeditions

Bell Rapids Mutual Irrigation

Black Mesa Farms

Blue Butte Grazing Association LLC
Appendix C: Jarbidge RMP Mailing List Jarbidge Proposed RMP/Final EIS

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Brackett Ranches

Brackett Ranches LTD

Buhl Herald

C.E. Brackett Cattle Company

Camas Creek Cattle Association LLC

Cedar Creek Farms

Cedar Mesa Reservoir and Canal

Cellular One

Chevron Pipeline Company

Conservation Geography

Conservation Seeding and Restoration, Inc.

Cooper Norman

Devil Creek Ranch, Inc.

Driscoll Brothers Partnership

Ecology and Environment, Inc.

Elmore County Farm Bureau

Far and Away Adventures

Farm Development Corp.

Flying Triangle, Inc.

Frog Hollow Ranch

Guerry, Inc.

Half Moon Ranches

Hammett Livestock Company

High Desert Ecology

House Creek Grazing Association LLC

ID Holding LLC, C/O AllTell Communication

Idaho Guide Service, Inc.

Idaho Mountain Express

Idaho Power Company

Intermountain Range Consultants

J.R. Simplot Company

Joe Black and Sons

King Hill Irrigation District

Kinyon & Kinyon

KLIX 96.5 FM/KEZJ 95.7 FM

KMVT Channel 11

KSAW Channel 51/KTFT Channel 38

National Public Lands News

Nevada Power Company

Nextel WIP Lease Corp.

Northwest Pipeline

Owyhee County Farm Bureau

Pacificorp Property Management

Progressive Rancher

Redwillow Research, Inc.

RES America Developments, Inc.

Ringert Clark Chartered

River Odysseys West

Rockin S Ranch

Roseworth Farms LLC

Rural Telephone Co.

Sage Ecosystem Science

Salmon Falls Land and Livestock Co.
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Schroeder and Lezamiz Law Offices

Seawest Windpower, Inc.

Simplot Livestock Company

Stetson & Jordan

Stowell Ranches

Tews Land and Livestock, Inc.

The Idaho Statesman

The Times-News

Trinity Exploration, Inc.

Twin Falls County Farm Bureau

URS Corporation

Verizon Business

Verizon Wireless

Wells Livestock, Inc.

Wilderness River Outfitters

Wintercamp Livestock Company

Wood River Ranches

 Y-3 Ranch

Government Entities

Animal and Plant Health Inspection Service, Wildlife Services, Gooding Office

Animal and Plant Health Inspection Service, Wildlife Services, Idaho Office

Animal and Plant Health Inspection Service, Deputy Director’s Office

Balanced Rock Soil Conservation District

BLM Boise District Office

BLM Bruneau Field Office

BLM Elko District Office

BLM Fire and Aviation, National Interagency Fire Center

BLM Idaho State Office

BLM Washington Office

BLM Wells Field Office

Bruneau Dunes State Park

Bruneau River Soil Conservation District

Buhl Highway District

Bureau of Reclamation, Pacific Northwest Regional Office

Bureau of Reclamation, Snake River Area Office-East

Bureau of Reclamation, Snake River Area Office-West

City of Bliss

City of Buhl

City of Castleford

City of Filer

City of Glenns Ferry

City of Grand View

City of Hagerman

City of Mountain Home

City of Twin Falls

Elko County Board of Commissioners

Elko County Highway Department

Elko County Manager’s Office

Elko County Planning Commission

Elko County Public Land Use Advisory Commission

Elko County Weed Control
Appendix C: Jarbidge RMP Mailing List Jarbidge Proposed RMP/Final EIS

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Elmore County Board of Commissioners

Elmore County Growth and Development Department

Elmore County Weed Control

Elmore Soil Conservation District

Environmental Protection Agency, Region 10

Federal Aviation Administration, Northwest Mountain Region

Federal Highway Administration

Glenns Ferry Highway District

Hagerman Highway District

Hagerman Translator District

Idaho Beef Council

Idaho Commission on Hispanic Affairs

Idaho Conservation Data Center (Idaho Natural Heritage Program)

Idaho Department of Commerce

Idaho Department of Education

Idaho Department of Environmental Quality

Idaho Department of Fish and Game

Idaho Department of Lands

Idaho Department of Parks and Recreation

Idaho Department of Transportation

Idaho Department of Water Resources

Idaho Fish and Game Commission

Idaho Governor’s Office of Species Conservation

Idaho House of Representatives, Office of the District 22 Representative, House Seat A 

Idaho House of Representatives, Office of the District 22 Representative, House Seat B 

Idaho House of Representatives, Office of the District 23 Representative, House Seat A 

Idaho House of Representatives, Office of the District 23 Representative, House Seat B 

Idaho House of Representatives, Office of the District 24 Representative, House Seat A 

Idaho House of Representatives, Office of the District 24 Representative, House Seat B 

Idaho Office of Energy Resources

Idaho Office of the Attorney General

Idaho Office of the Governor

Idaho Office of the Lieutenant Governor

Idaho Outfitters and Guides Licensing Board

Idaho Park and Recreation Board

Idaho Rangeland Resource Commission

Idaho Rural Partnership

Idaho Secretary of State’s Office

Idaho Senate, Office of the District 22 Senator

Idaho Senate, Office of the District 23 Senator

Idaho Senate, Office of the District 24 Senator

Idaho Sheep Commission

Idaho Soil Conservation Commission

Idaho Soil Conservation Districts, Division III

Idaho Soil Conservation Districts, Division IV

Idaho State Department of Agriculture

Idaho State Historic Preservation Office

Idaho State Historical Society

Idaho State Historical Society, District 4

Idaho State Historical Society, District 5

Idaho Transportation Department

Jackpot Advisory Board

Jarbidge Advisory Board
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Malad Gorge State Park

Mountain Home Air Force Base, 366 CES/CEVA 

National Oceanic and Atmospheric Administration, National Marine Fisheries Service

National Park Service, Hagerman Fossil Beds National Monument

National Park Service, Mojave National Preserve

National Park Service, National Trails System

Natural Resources Conservation Service, Elko Service Center

Natural Resources Conservation Service, Marsing Service Center

Natural Resources Conservation Service, Mountain Home Service Center

Natural Resources Conservation Service, Twin Falls Service Center

Natural Resources Conservation Service, Washington Office

Nevada Department of Agriculture

Nevada Department of Transportation

Nevada Division of Environmental Protection

Nevada Division of Forestry, Region 2

Nevada Division of State Lands

Nevada Division of Wildlife, Region 2

Nevada Natural Heritage Program

Nevada Office of the Governor

Nevada Rangeland Resources Commission

Nevada State Historic Preservation Office

Nevada State Land Use Planning Agency

Northeast Elko Conservation District

Owyhee Conservation District

Owyhee County Board of Commissioners

Owyhee County Natural Resources Committee

Owyhee County Planning and Zoning Commission

Owyhee County Road and Bridge

Owyhee County Weed Control

Shoshone-Bannock Tribes

Shoshone-Paiute Tribes

Snake River Soil Conservation District

Thousand Springs State Park

Three Creek Good Road District

Three Island Crossing State Park

Twin Falls County Board of Commissioners

Twin Falls County Planning and Zoning Commission

Twin Falls County Weed Control

Twin Falls Highway District

Twin Falls Soil and Water Conservation District

US Army Engineer, Northwestern Division

US Coast Guard

US Department of Agriculture, Agricultural Research Service, Northwest Irrigation and Soils Research 

Lab

US Department of Agriculture, National Agriculture Library

US Department of Energy

US Department of Justice, US Attorney’s Office for the District of Idaho

US Department of the Interior, Office of Environmental Policy and Compliance

US Department of the Interior, Office of the Solicitor, Pacific NW Region

US Fish and Wildlife Service, Pacific Northwest Region, Idaho Fish and Wildlife Office

US Fish and Wildlife Service, Pacific Southwest Region, Nevada Fish and Wildlife Office

US Forest Service, Humboldt-Toiyabe National Forest

US Forest Service, Ruby Mountains/Jarbidge Ranger District
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US Forest Service, Sawtooth National Forest

US Forest Service, Washington Office

US Geological Survey, Water Resources Division, Twin Falls Field Office

US House of Representatives, Office of the Representative of Idaho’s 1st Congressional District, 

US House of Representatives, Office of the Representative of Idaho’s 2nd Congressional District

US House of Representatives, Office of the Representative of Nevada’s 2nd Congressional District

US Senate, Offices of the Senators of the State of Idaho

US Senate, Offices of the Senators of the State of Nevada
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APPENDIX D: AQUATIC AND RIPARIAN MANAGEMENT 

STRATEGY

Introduction

The Aquatic and Riparian Management Strategy (ARMS) consolidates the Bureau of Land Management 

(BLM) Jarbidge Field Office guidance and programmatic direction for watershed and sub-watershed 

riparian and aquatic conservation and restoration. This strategy conforms to the direction issued on 

August 21, 2008 for implementation of the Aquatic and Riparian Habitat component of the Interior 

Columbia Basin Strategy and Aquatic Framework (USFS et al., 2008). Conservation of aquatic wildlife, 

plants, and habitats are considered together with the full array of broad-scale ecosystem components 

addressed by the strategy, which includes landscape dynamics, terrestrial source habitats, aquatic 

species, and riparian and hydrologic processes. The proposed Jarbidge RMP balances short-term risks to 

aquatic and other resources with long-term benefits through goals, objectives, and management actions 

designed to move these resources toward a natural variability of conditions or desired conditions. The 

Guidance for Developing Aquatic Conservation Strategies for BLM Resource Management Plans in the 

Interior Columbia Basin (BLM, 2008a) was referred to during the creation of the ARMS. 

The ARMS contains the following key components:

Establishment of Riparian Conservation Areas where aquatic and riparian-dependent resources 

receive management emphasis;

Priorities for Conservation and Restoration of Special Status Species Habitat and Riparian Areas;

Identification of population strongholds of special status fish and areas with priority for restoration of 

aquatic and riparian habitats;

Aquatic and riparian management direction including goals, objectives, and management actions; 

Provisions for multi-scale analysis and how it will be used in project-level decisions; and

Monitoring and adaptive management for determining if the plan is being implemented and is 

achieving desired results.

The guidance in this strategy was created to support the goals, objectives, and management actions 

identified in Chapter 2 for Water Resources, Riparian Areas and Wetlands, Fish, and Special Status 

Species (specifically the Management for Special Status Species in Riparian Areas, Wetlands, and 

Streams section). The BLM adopted the Inland Native Fish Strategy (INFISH) (USDA, 1995) in bull trout 

occupied watersheds in an Instruction Memorandum (IM-ID-96-010). The justification for BLM to apply the 

the ARMS to watersheds containing other special status aquatic species, such as redband trout, is 

included in the BLM Policy Manual 6840 and the BLM Land Use Planning Handbook (H-1610-1, 

Appendix C).

Riparian Conservation Areas

This section addresses material for Component I, Riparian Conservation Areas, in the Guidance for Developing 

Aquatic Conservation Strategies (BLM, 2008a). 

Riparian Conservations Areas (RCAs) are portions of watersheds where riparian-dependent resources 

receive management emphasis and they are likely to affect aquatic habitat condition or function. RCAs 

include riparian corridors, wetlands, intermittent headwater streams, and other areas where proper 

ecological function is essential for maintaining water, sediment, woody debris, and nutrient delivery to 

streams and either contain or are tributaries to streams that contain special status species or their habitat. 

Functionally, RCAs 1) influence the delivery of coarse sediment, organic matter, and woody debris to 

streams; 2) accommodate vegetation that provides root strength for channel stability; 3) provide 

streamside shade; and 4) protect water quality. Management of RCAs is designed to maintain and restore 

riparian structure and function; benefit fish and riparian-dependent resources; enhance conservation of 

organisms dependent on the transition zone between upslope and instream habitats; and improve 

connectivity of travel and dispersal corridors for terrestrial animals, plants, and aquatic organisms.
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The values considered when identifying and managing RCAs may be specific to the riparian area or 

stream channel. The ARMS allows for adjusting management of RCAs to reflect site-specific conditions 

(e.g., conditions of specific stream channels, the life stage of specific fish), while also recognizing 

watershed (e.g., watershed characteristics and land uses) and riparian conditions and trends. RCAs are 

not intended to be treated as “no management zones” since treatments may be essential to achieving or 

maintaining desired riparian conditions. 

Riparian Conservation Area Widths 

RCA widths are to be adequate to protect the stream from non-channelized sediment inputs, to deliver 

organic matter and woody debris, and to provide stream shade and streambank stability. In the absence 

of a watershed or site-specific analysis, the default RCA widths for the stream categories described below 

will be applied. These default widths were recommended in INFISH (USDA, 1995) and the Interior 

Columbia Basin Science Assessment and literature review (Quigley and Arbelbide, 1997), which 

concluded that these prescribed RCA widths are sufficient to provide for riparian function.

Category 1—Fish-bearing Streams: 

Category 1 RCAs contain the stream and the area from the edges of the active channel, on either edge of 

the stream, to the top of the inner gorge, the outer edges of the 100-year floodplain, the outer edges of 

the riparian vegetation, or 300 feet slope distance (600 feet, including both sides of the stream channel), 

whichever is widest. 

Category 2—Permanently Flowing Non Fish-bearing Streams: 

Category 2 RCAs contain the stream and the area from the edges of the active channel, on either edge of 

the stream, to the top of the inner gorge, the outer edges of the 100-year floodplain, the outer edges of 

the riparian vegetation, or 150 feet slope distance (300 feet, including both sides of the stream channel), 

whichever is widest. 

Category 3—Ponds, Lakes, Reservoirs, and Wetlands Greater than One Acre: 

Category 3 RCAs contain the body of water or wetland and the area from the edges of the body of water 

or wetland to the outer edges of the riparian vegetation, the extent of the seasonally saturated soil, or to 

the extent of moderately or highly unstable areas, or 150 feet slope distance from the edge of the 

maximum pool elevation of constructed ponds and reservoirs or from the edge of the wetland, pond, or 

lake, whichever is widest. 

Category 4—Seasonally Flowing or Intermittent Streams and Wetlands Less than One

Acre; Landslides and Landslide-prone Areas: 

This category includes features with high variability in size and site-specific characteristics. Category 4 

RCAs for intermittent streams contain the intermittent stream channel and the area from the edges of the 

channel to the top of the inner gorge, the outer edges of the riparian vegetation, or 50 feet slope distance, 

whichever is greatest. Category 4 RCAs for wetlands less than one acre contain the wetland and the area 

from the edges of the wetland to the outer edges of the riparian vegetation or 50 feet slope distance, 

whichever is greatest. Category 4 RCAs for landslides or landslide-prone areas contain the landslide or 

landslide-prone area and the area within 50 feet slope distance, whichever is widest. 

Modification of Riparian Conservation Area Widths 

Modification of RCA widths requires a watershed- or reach-specific analysis to provide the ecological 

basis for the change (see the Watershed Analysis section below). The RCAs may be modified in the 

absence of watershed analysis where stream reach or site-specific data support the change. A watershed 

or reach-specific determination is not a decision process; it provides information that would support RCA 

width modification. Modifying RCA widths will be determinedusing scientific information in combination 

with local knowledge and information on riparian and aquatic processes and functions, resource values, 

and risks. Because stream channel characteristics can vary substantially between geographic areas, 

RCA modification needs to consider ecological and geomorphic factors of the specific reach. 
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Modification of RCA widths may occur during project-level planning or implementation of management 

activities that could affect attainment of the riparian objectives. Changes to RCA widths, along with 

information that explains the change, would be documented in the project file. Pertinent site-specific, 

stream reach, and watershed values (e.g., specific riparian or aquatic characteristics, slope, soils, etc.) 

would be addressed in the rationale for modifying RCAs. 

Priorities for Conservation and Restoration of Special Status 

Species Habitat and Riparian Areas

This section addresses material for Component II, Protection of Population Strongholds, and Component IV, 

Restoration Priorities and Guidance, in Guidance for Developing Aquatic Conservation Strategies (BLM, 2008a). 

Introduction

Relationship between Measures of Instream and Riparian Habitat Condition

Conditions within and near streams can be described from various perspectives. Assessments can focus 

on the condition of riparian areas, instream habitat for specific species, as well as water quality, and can 

be based on qualitative or quantitative data. Within the Jarbidge Field Office, data are available to 

describe riparian conditions in terms of proper functioning condition (PFC), special status fish habitat 

conditions in terms of habitat condition (HC), and water quality impaired streams as identified by Idaho 

Department of Environmental Quality and Nevada Division of Environmental Protection. These measures 

are all interrelated; some measures are even based on similar types of data. The relationships between 

these condition measures are displayed in Figure D-1. 

Figure D-1. The Relationship between Riparian Functional Condition, Aquatic Habitat Condition, 

and State Water Quality Standards 

Nonfunctional

Functional-at-Risk Proper Functioning Condition

Time

Bare Ground

Decision Space

Water Quality Standard

PNC

Vegetation 

(component of PFC Rating)

Livestock Forage

Aquatic Habitat 

(component of HC Rating)

Channel Stability 

(component of HC and PFC Rating)

As vegetation improves from non-functional to functional at risk, there is little improvement in the other 

resource values (e.g, vegetation, channel stability). There is an increased recovery rate of all the resource 

values within the FAR range as the streamchannel begins to stabilize and vegetation and aquatic habitat 

values improve. At PFC, the stream channel stabilizes at a point when the vegetation, water, and 

landform are in a relative balance. After a stream reach has reached PFC, vegetation continues toward 

the potential natural community, livestock forage increases, and aquatic habitat improves. Improvement in 
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water quality to levels that would result in the delisting of water quality impaired streams and attainment of 

designated beneficial uses would not occur until riparian condition improved beyond the initial rating of 

PFC. When the riparian area is functioning properly, there is an opportunity to make decisions as to the 

use or uses that will be emphasized. 

Indicators of Instream and Riparian Habitat Condition

Indicators of instream and riparian habitat conditions form the basis for instream HC ratings and riparian 

PFC ratings. HC ratings were used to identify population strongholds for special status fish and determine 

priorities for special status fish habitat restoration (see Special Status Fish Habitat section), while PFC 

ratings were used to assess priority for riparian restoration (see Riparian Habitat section). 

The indicators used to develop these ratings include an integrated suite of aquatic (including a biological 

component), riparian (including riparian-associated terrestrial species), and hydrologic (including uplands) 

condition measures that are primarily intended to be used at the watershed and sub-watershed scale and 

include both quantitative and qualitative measures. These watersheds and sub-watersheds are typically 

5th to 6th field Hydrologic Unit Codes; both will be referred to as “watersheds” in the ARMS. These 

indicators are intended to serve three main purposes:

To establish priorities and objectives for conservation or restoration of stream reaches;

To design projects and determine the appropriateness of management activities with respect to 

aquatic, riparian, and hydrologic goals and objectives; and

To serve as measures of the effectiveness of management in attaining broad-scale aquatic, riparian, 

and hydrologic goals and objectives.

The values for an indicator to be rated as functioning appropriately are not absolute criteria and are rated 

in comparison to the functional, ecological, or biological conditions of specific stream reaches. The 

indicators should be used as a suite of integrated indicators and should not be used individually as fixed 

targets to manage toward or as specific thresholds from which to make project implementation decisions. 

The indicators should be used to design or mitigate ongoing and proposed activities in order to move 

watersheds toward desired resource objectives. If certain indicators highlight a concern in a watershed, 

proposed activities could be modified or designed to take into account the resource concerns or 

determine when an action is needed to achieve goals and objectives. 

HC ratings, PFC ratings, and the values for the indicators on which these ratings are based can be 

updated based on monitoring, inventory, scientific literature, or watershed analysis by local experts (e.g., 

fisheries biologist, ecologist, botanist, and/or hydrologist). Updates may be necessary to more accurately 

depict the characteristics and range of natural variability of aquatic and riparian habitats in the planning 

area or to reflect changes in condition on the ground. Instream and riparian indicators and thresholds may 

be refined at the watershed scale to illustrate the variability of conditions among watersheds within a 

landscape context. 

The current status of instream and riparian habitat condition indicators is based on BLM stream survey 

data collected between 1999 and 2007; the majority of these data were collected between 2002 and 

2006. BLM-managed lands in the planning area are continuous across watershed and sub-watershed 

boundaries except in a few areas of private and State inholdings and military withdrawals. This land 

ownership pattern allows for inventory and monitoring efforts to be conducted across broad areas where 

public land comprises the majority of the land base. Additional details on the methods used to collect and 

analyze the baseline data can be found in the Analysis of the Management Situation of the BLM Twin 

Falls District, Jarbidge Field Office (BLM, 2007a). How these indicators were used to develop priorities for 

special status fish habitat restoration and riparian restoration are described below.

Special Status Fish Habitat

Identifying Conservation and Restoration Reaches provides a means for prioritizing management and for 

establishing goals, objectives, and management actions for stream reaches containing special status fish 

habitat. It also provides a process that considers opportunities for conservation and restoration, with 

consideration for the availability of staff and budgetary resources. Some stream reaches will not be 
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restored to physical or biological potential within the life of the plan because of effects of past land 

management actions or activities outside the authority of the BLM. These stream reaches would have 

reduced priority for restoration treatment. 

Conservation Reaches

Conservation Reaches are managed to maintain the condition of habitats in these reaches. Conservation 

Reaches are often associated with aquatic species strongholds and contain populations or 

subpopulations of high genetic integrity, connectivity, or potential for expansion into nearby stream 

reaches. Conservation Reaches are located in watersheds that often have watershed processes or 

functions that are relatively undisturbed and natural in setting. Hydrologic function, such as sediment 

routing and flow regimes, are within the natural range of frequency, duration, and intensity. Water quality 

generally meets the designated beneficial uses. Land uses and human activities minimally influence 

aquatic and hydrologic function, as indicated by low road density and few stream crossings. Examples of 

areas containing Conservation Reaches include wilderness, roadless areas, and undeveloped subwatersheds; however, Conservation Reaches or portions thereof may be subject to management that 

allows land uses while maintaining natural processes. The goal is to maintain the existing condition of the 

habitats within these reaches.

In Conservation Reaches, management allows natural disturbance because vegetation composition and 

structure that trend outside the historic range of variability due to fire suppression may pose a risk to 

ecological processes. Management in Conservation Reaches may rely on active management to 

conserve physical and biological processes and patterns. For example, active management to conserve 

hydrologic and biological processes maintains roads and trails in a condition that minimizes erosion and 

sedimentation to nearby streams and water bodies. Passive management can also be effective for 

meeting habitat objectives. As a general rule, minimal investment in these watersheds over time is 

necessary to maintain function and critical elements on instream and upland habitat in these watersheds. 

The criteria for identifying Conservation Reaches, which have important value for protecting populations 

of special status fish, are described in the Habitat Dependency Network (Decision Support Model) and 

Habitat Condition Ratings section below. There are currently several stream reaches in the planning area 

meeting the criteria for designation as Conservation Reaches for special status species. The intent of this 

designation and management for these watersheds is to provide high-quality habitat for species and 

support the expansion and recolonization of species into adjacent watersheds. These areas should 

conserve key processes likely to influence the persistence of metapopulations (core populations) and 

interconnected sub-populations of special status fish. 

Restoration Reaches

Restoration Reaches are identified where biological and physical processes and functions do not reflect 

natural conditions because of past and on-going land disturbances. Common effects of disturbances to 

Restoration Reaches may include long-term (e.g., decades) increases of sediment input to streams, loss 

of large woody debris recruitment potential, altered hydrologic (e.g., streamflow) patterns, and elevated 

water temperatures. Cumulative impacts and natural disturbances such as large fires, landslides, and 

floods exacerbate altered watershed and biological conditions. The goal for these stream reaches is to 

restore habitat condition to an identified desired condition. 

Active management may be necessary to restore the physical and biological function of systems to their 

natural range of variability. Identifying and assessing the impacts of management on habitat focuses 

restoration efforts to achieve goals and objectives for hydrologic and biological recovery. Within some 

Restoration Reaches, opportunities for active restoration management may be limited. In those cases, 

management that reduces or avoids adverse effects and does not delay the achievement of desired 

resource objectives in the long term also supports the restoration goal. In some instances, BLM 

managers will exercise individual discretion to balance short-term risks to aquatic and other resources 

with long-term benefits for multiple resources in order to move these reaches toward the natural range of 

variability. 
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The criteria used to identify Restoration Reaches and priorities for restoration of those reaches are 

described in the Habitat Dependency Network (Decision Support Model) and Habitat Condition Ratings

section below. Priority ranking (high, moderate, and low) for each Restoration Reach was based on 

habitat condition indicators, Endangered Species Act status, restoration feasibility, the extent of habitat, 

and relative fish abundance. Characteristics of Restoration Reaches within the three priority types are 

described below.

High Priority 

High Priority Restoration Reaches have potential for highly productive or unique fish communities with 

restoration efforts. Loss of connected populations or competition or hybridization with non-native species 

has caused the loss of diversity of some unique populations of special status fish. The assumption is that 

the aquatic community is largely intact but is not resilient to landscape disturbance events, nor does it 

provide a source of individuals to nearby recovering populations.

Water quality may not support all designated beneficial uses or municipal water supplies. 

Moderate Priority 

Moderate Priority Restoration Reaches have potential for moderately productive fish habitat with 

restoration efforts. Long-term loss of connected populations or competition or hybridization with nonnative species has caused the loss of diversity of some unique special status fish populations. The 

assumption is that the aquatic community is largely intact but is not resilient to landscape disturbance 

events, nor does it provide a source of individuals to nearby recovering populations.

Water quality may not support all designated beneficial uses or municipal water supplies.

Low Priority 

Low Priority Restoration Reaches have a minor amount of fish habitat. Long-term loss of connected 

populations or competition or hybridization with non-native species has caused the loss of diversity of 

special status fish populations. The assumption is that the aquatic community is not intact, is not resilient 

to natural events, and does not provide a source of individuals to nearby recovering populations. Low 

priority restoration reaches also include reaches that are rated as PFC.These reaches are in a condition 

where the stream channel is functioning properly and therefore are a low priority for restoration.

Water quality may not support all designated beneficial uses, and municipal water is not considered as a 

future use. 

Habitat Dependency Network (Decision Support Model) and Habitat Condition Ratings

Habitat dependency networks are used in decision support models to prioritize stream reaches containing 

special status species habitat based on instream and riparian habitat indicators, which reflect overall 

watershed condition. NetWeaver was used as the decision support model for identifying Conservation 

and Restoration Reaches in the planning area.

NetWeaver was developed by The Heron Group LLC.

 Thresholds for habitat functionality for each riparian and 

stream indicator were developed based on scientific literature, information gathered in the 2006 Jarbidge 

fish survey, and other habitat data for bull trout. The indicators and thresholds for bull trout and redband 

trout used in the NetWeaver analysis are provided in Table D-1 and Table D-2; these tables are based on 

the Matrix of Diagnostics/Pathways and Indicators of watershed and aquatic conditions developed by the 

National Marine Fisheries Service and adapted by the US Fish and Wildlife Service for use in watersheds 

containing bull trout (FWS, 1998). Indicator thresholds were validated using habitat and fish abundance 

data for stream reaches within the planning area. 
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Table D-1. Bull Trout Habitat Condition Indicators and Thresholds

Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at 

Unacceptable Risk

Indicators for Species Characteristics

Subpopulation

Characteristics 

within 

Subpopulation 

Watersheds

Subpopulation 

Size

Mean total 

subpopulation size or 

local habitat capacity 

more than several 

thousand individuals. 

All life stages evenly 

represented in the 

subpopulation.

A

< 500 but > 50 adults 

in subpopulationA

< 50 adults in 

subpopulationA

Growth and 

Survival

Subpopulation has 

the resilience to 

recover from shortterm disturbances 

(e.g., catastrophic 

events) or 

subpopulation 

declines within one to 

two generations (5 to 

10 years).A The 

subpopulation is 

characterized as 

increasing or stable. 

At least 10 years of 

data support this 

estimate.B

When disturbed, the 

subpopulation will not 

recover to predisturbance 

conditions within one 

generation (5 years). 

Survival or growth 

rates have been 

reduced from those in 

the best habitats. The 

subpopulation is 

reduced in size, but 

the reduction does not 

represent a long-term 

trend.A At least 10 

years of data support 

this characterization.B

If less data are 

available and a trend 

cannot be confirmed, 

a subpopulation will 

be considered “at risk” 

until enough data are 

available to accurately 

determine trend. 

The subpopulation is 

characterized as in 

rapid decline or is 

maintaining at 

alarmingly low 

numbers. Under 

current management, 

the subpopulation 

condition will not 

improve within two 

generations (5 to 10 

years).A This is 

supported by a 

minimum of 5 years of 

data.

Life History 

Diversity and 

Isolation

The migratory form is 

present, and the 

subpopulation exists 

in close proximity to 

other spawning and 

rearing groups. 

Migratory corridors 

and rearing habitat 

(lakes or large rivers) 

are in good to 

excellent condition for 

the species. 

Neighboring 

subpopulations are 

large with high 

likelihood of 

producing surplus 

individuals or straying 

The migratory form is 

present but the 

subpopulation is not 

close to other 

subpopulations or 

habitat disruption has 

produced a strong 

correlation among 

subpopulations that 

do exist in proximity to 

each other.A 

The migratory form is 

absent and the 

subpopulation is 

isolated to the local 

stream or small 

watershed not likely to 

support more than 

2,000 fish.A
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Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at 

Unacceptable Risk

Subpopulation 

Characteristics 

within 

Subpopulation 

Watersheds

adults that will mix 

with other 

subpopulations.A

Persistence 

and Genetic 

Integrity

Connectivity is high 

among multiple (5 or 

more) subpopulations 

with at least several 

thousand fish each. 

Each of the relevant 

subpopulations has 

low risk of extinction.A 

The probability of 

hybridization or 

displacement by 

competitive species is 

low to nonexistent. 

Connectivity among 

multiple 

subpopulations does 

occur, but habitats are 

more fragmented. 

Only one or two of the 

subpopulations 

represent most of the 

fish production.A The 

probability of 

hybridization or 

displacement by 

competitive species is 

imminent, although 

few documented 

cases have occurred. 

Little or no connectivity 

remains for 

reestablishing 

subpopulations in low 

numbers, in decline, or 

nearing extirpation. 

Only a single 

subpopulation or 

several local 

populations that are 

very small or that

otherwise are at high 

risk remain.A

Competitive species 

readily displace bull 

trout. The probability 

of hybridization is high 

and documented 

cases have occurred. 

Indicators for Habitat Characteristics

Water Quality

Temperature

Mean maximum weekly temperature in a reach during the following life 

history stages:A,C

Incubation

2 - 5oC < 2oC or = 6oC < 1oC or > 6oC

Rearing

4 - 12oC < 4oC or 13 - 15oC > 15oC

Spawning

4 - 9oC < 4oC or = 10oC < 4oC or > 10oC

Also, temperatures in 

areas used by adults 

during migration do 

not exceed 15oC (no 

thermal barriers).

Also, temperatures in 

areas used by adults 

during migration 

sometimes exceed 

15oC.

Also, temperatures in 

areas used by adults 

during migration 

regularly exceed 15oC 

(thermal barriers 

present).

SedimentD

Similar to chinook 

salmonA (e.g., < 12% 

fines (< 0.85 mm) in 

gravelE

); < 12% 

surface finesF (≤ 6 

mmG,H) 

Similar to chinook 

salmonA (e.g., 12 - 

17% fines (< 0.85 

mm) in gravelE

); 12-

20% surface finesF (≤

6 mmG,H) 

Similar to chinook 

salmonA (e.g., > 17% 

fines (< 0.85 mm) in 

gravelE

); > 20% fines 

at surface or depth in 

spawning habitatF (≤ 6 

mmG,H) 

Chemical 

Contamination/

Nutrients

Low levels of 

chemical 

contamination from 

agricultural, industrial, 

and other sources; no 

excess nutrients; and 

no water quality 

impaired reaches.

I

Moderate levels of 

chemical 

contamination from 

agricultural, industrial, 

and other sources; 

some excess nutrients; 

and one water quality 

impaired reach.

I

High levels of chemical 

contamination from 

agricultural, industrial, 

and other sources; high 

levels of excess 

nutrients; and more 

than one water quality 

impaired reach.

I
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Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at Unacceptable Risk

Habitat 

Access

Physical 

BarriersJ

Man-made structures

present in watershed 

allow upstream and 

downstream fish 

passage at all flows.

Man-made structures

present in watershed 

do not allow upstream 

and/or downstream 

fish passage at 

base/low flows.

Man-made structures

present in watershed 

do not allow upstream 

and/or downstream 

fish passage at a 

range of flows.

Habitat 

Elements

Substrate 

Embeddedness

K

Reach 

embeddedness 

< 20%.

F,L

Reach 

embeddedness 20 - 

30%.

F,L

Reach embeddedness 

> 30%.F,L

Large Woody 

Debris

(LWD)S

LWD levels are 

commensurate with 

the vegetation 

potential of the 

surrounding 

landscape and 

contributing to high 

quality and complex 

habitat including deep 

pools and stable 

streambanks. Future 

LWD recruitement is 

occurring at a natural 

rate and not reduced 

by land management 

activities.

LWD is contributing to 

high quality and 

complex habitat 

commensurate with 

the vegetation 

potential of the 

surrounding 

landscape, but at 

rates below natural 

recruitement. Future 

LWD recruitement to 

the RCA is locally 

reduced by land 

management 

activities.

LWD contribution to 

habitat complexity is 

well below what is 

expected from the 

natural recruitement 

potential of the 

surrounding 

landscape. Future 

LWD recruitement to 

the RCA is reduced at 

a landscape scale by 

land management 

activities.

Pool 

Frequency 

and Quality

Pool frequency in a 

reach closely 

approximated:G

Pool frequency is 

similar to values in 

“functioning 

appropriately,” but 

pools have 

inadequate 

cover/temperature,

E

and/or there has been 

a moderate reduction 

of pool volume by fine 

sediment.

Pool frequency is 

considerably lower 

than values desired for 

“functioning 

appropriately;” also, 

cover/temperature is 

inadequate,E and there 

has been a major 

reduction of pool 

volume by fine 

sediment.

Wetted

Width (ft)

# Pools/

Mile

0-5 39

5-10 60

10-15 48

15-20 39

20-30 23

30-35 18

35-40 10

40-65 9 

65-100 4 

Pools have good 

cover and cool 

waterE

; only minor 

reduction of pool 

volume by fine 

sediment.

Large PoolsN

Each reach has many 

large pools > 1 meter 

deep.E

Each reach has few 

large pools > 1 meter 

deep.E

Reaches have no 

large pools > 1 meter 

deep.E
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Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at 

Unacceptable Risk

Habitat 

Elements

Off-Channel 

Habitat

Watershed has many 

ponds, oxbows, 

backwaters, and other 

off-channel areas with 

cover, and sidechannels are lowenergy areas.E

Watershed has some 

ponds, oxbows, 

backwaters, and other 

off-channel areas with 

cover, but sidechannels are 

generally high-energy

areas.E

Watershed has few or 

no ponds, oxbows, 

backwaters, or other 

off-channel areas.E

Refugia

Habitats capable of 

supporting strong and 

significant populations 

are protected and are 

well distributed and 

connected for all life 

stages and forms of 

the species.O,P

Habitats capable of 

supporting strong and 

significant populations 

are insufficient in size, 

number and 

connectivity to 

maintain all life stages 

and forms of the 

species.O,P

Habitat refugia do not 

exist.O

Channel 

Condition 

and 

Dynamics

Average 

Wetted 

Width/ 

Maximum 

Depth Ratio 

in Scour 

Pools in a 

Reach

≤ 10F,G 11 - 20G > 20G

Streambank 

Condition

> 80% of any stream 

reach has ≥ 90% 

stability.

G

50 - 80% of any 

stream reach has 

≥ 90% stability.

G

< 50% of any stream 

reach has ≥ 90% 

stability.

G

Floodplain 

Connectivity

Off-channel areas are 

frequently 

hydrogically linked to 

main channel; 

overbank flows occur 

and maintain wetland 

functions and riparian 

vegetation/ 

succession.

Reduced linkage of 

wetland, floodplains, 

and riparian areas to 

main channel; 

overbank flows are 

reduced relative to 

historic frequency, as 

evidenced by 

moderate degradation 

of wetland function 

and riparian 

vegetation/

succession. 

Severe reduction in 

hydrologic connectivity 

between off-channel, 

wetland, floodplain, 

and riparian areas; 

wetland extent 

drastically reduced 

and riparian 

vegetation/succession 

altered significantly. 

Flow/ 

Hydrology

Change in 

Peak/Base 

Flows

Watershed 

hydrograph indicates 

peak flow, base flow, 

and flow timing 

characteristics 

comparable to an 

undisturbed 

watershed of similar 

size, geology, and 

geography.

Some evidence of 

altered peak flow, 

base flow, and/or flow 

timing relative to an 

undisturbed 

watershed of similar 

size, geology, and 

geography. 

Pronounced changes 

in peak flow, base 

flow, and/or flow timing 

relative to an 

undisturbed watershed 

of similar size, 

geology, and 

geography.
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A-95

Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at 

Unacceptable Risk

Flow/ 

Hydrology

Increase in 

Drainage 

Network

Zero or minimum 

increases in active 

channel length 

correlated with human 

caused disturbance.

Low to moderate 

increase in active 

channel length 

correlated with human 

caused disturbance.

Greater than moderate 

increase in active 

channel length 

correlated with human 

caused disturbance.

Watershed 

Condition

Road Density 

and Location

< 1mi/mi2 P; no valley 

bottom roads.

1 - 2.4 mi/mi2 P; some 

valley bottom roads. 

> 2.4 mi/mi2 P; many 

valley bottom roads.

Disturbance 

History

< 15% of entire 

watershed with no 

concentration of 

disturbance in 

unstable or potentially 

unstable areas, 

refugia, and/or 

riparian areas.

Q 

< 15% of entire 

watershed but 

disturbance 

concentrated in 

unstable or potentially 

unstable areas, 

refugia, and/or 

riparian areas.

Q 

> 15% of entire 

watershed and 

disturbance 

concentrated in 

unstable or potentially 

unstable areas, 

refugia, and/or riparian 

areas. 

Watershed 

Condition

Riparian 

Conservation 

Areas 

(RCAs) 

RCAs provide 

adequate shade, 

large woody debris 

recruitment, and 

habitat protection and 

connectivity in subwatersheds and 

buffers or include 

known refugia for 

Sensitive aquatic 

species (> 80% intact) 

and adequately buffer 

impacts on 

rangelands. Percent 

similarity of riparian 

vegetation to the 

potential natural 

community(PNC)/ 

composition is 

> 50%.R

RCAs have moderate 

loss of connectivity or 

function (shade, LWD 

recruitment, etc.) or

provide incomplete 

protection of habitats 

and refugia for 

Sensitive aquatic 

species (70 - 80% 

intact) and adequately 

buffer impacts on 

rangeland. Percent 

similarity of riparian 

vegetation to the 

PNC/composition is 

25 - 50% or better.R 

RCAs are fragmented 

or poorly connected or

provide inadequate 

protection of habitats 

for Sensitive aquatic 

species (< 70% intact, 

refugia do not occur) 

and inadequately 

buffer impacts on 

rangelands. Percent 

similarity of riparian 

vegetation to the PNC/ 

composition is <

25%.R

Disturbance 

Regime

Environmental 

disturbance is short 

lived; predictable 

hydrograph, highquality habitat and 

watershed complexity 

providing refuge and 

rearing space for all 

life stages or multiple 

life-history forms.A

Natural processes are 

stable.

Scour events, debris 

torrents, or 

catastrophic fire are 

localized events that 

occur in several minor 

parts of the 

watershed. Resiliency 

of habitat to recover 

from environmental 

disturbances is 

moderate. 

Frequent flood or 

drought, producing 

highly variable and 

unpredictable flows, 

scour events, debris 

torrents, or high 

probability of 

catastrophic fire exists 

throughout a major part 

of the watershed. The 

channel is simplified, 

providing little hydraulic 

complexity in the form 

of pools or side 

channels.A Natural 

processes are unstable.
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

A-96

Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at 

Unacceptable Risk

Summary of 

Species and 

Habitat 

Conditions

NA

Habitat quality and 

connectivity among 

subpopulations is 

high. The migratory 

form is present. 

Disturbance has not 

altered channel 

equilibrium. Fine 

sediments and other 

habitat characteristics 

influencing survival or 

growth are consistent 

with pristine habitat. 

The subpopulation 

has the resilience to 

recover from shortterm disturbance 

within one to two 

generations (5 to 10 

years). The 

subpopulation is 

fluctuating around

equilibrium or is 

growing.A

Fine sediments, 

stream temperatures, 

or the availability of 

suitable habitats have 

been altered and will 

not recover to predisturbance conditions 

within one generation 

(5 years). Survival or 

growth rates have 

been reduced from 

those in the best 

habitats. The 

subpopulation is 

reduced in size, but 

the reduction does not 

represent a long-term 

trend. The 

subpopulation is 

stable or fluctuating in 

a downward trend. 

Connectivity among 

subpopulations 

occurs, but habitats 

are fragmented.A

Cumulative disruption 

of habitat has resulted 

in a clear declining 

trend in the 

subpopulation size. 

Under current 

management, habitat 

conditions will not 

improve within two 

generations (5 to 10 

years). Little or no 

connectivity remains 

among 

subpopulations. The 

subpopulation survival 

and recruitment 

responds sharply to 

normal environmental 

events.A

A (Rieman and McIntyre, 1993). B (Rieman and Meyers, 1997). C (Buchanan and Gregory, 1997). D Applies to areas of spawning and incubation. Rearing areas are addressed under Substrate Embeddedness 

indicator.

E (WTFWCMERC, 1993). F Inland Native Fish Strategy (USDA, 1995). G (Overton et al., 1995). H

 (Overton et al., 1997). I

(Regional Interagency Executive Committee and Intergovernmental Advisory Committee, 1995). J Subsurface flows impeding fish passage are addressed under the Flow/Hydrology indicator category.

K Spawning and incubation areas are addressed under the Sediment indicator. L

 (Shepard et al., 1984). M (Quigley and Arbelbide, 1997). N Applies to adult holding, juvenile rearing, and overwintering reaches where streams are >3m in wetted width at base 

flow.

O (Frissell et al., 1993). P (Lee et al., 1997). Q (USDI and USDA, 1994). R (Winward, 1989). S

(Forster, 2014)
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A-97

Table D-2. Redband Trout Habitat Condition Indicators and Thresholds

Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at 

Unacceptable Risk

Habitat 

Elements

Pools/Pool 

FrequencyA,D 

Pool frequency falls 

within described 

natural conditionsG: All 

streams:

Geology-Volcanic

75 - 99% of natural 

condition for given 

stream width, geology, 

and channel type

< 75% of natural 

condition for given 

stream width, geology, 

and channel type

Average

Width (ft)

Pools per 

mile

Channel Type A

0-15 33

15-20 3 

Channel Type B

0-10 28

10-15 59

15-20 24

20-25 21

Channel Type C

0-10 6 

10-15 19

15-20 24

20-25 22

Large 

PoolsD,E,G 

At a minimum; > 75% 

of pools have a 

maximum pool depth 

appropriate for the 

stream’s natural 

conditions based on 

geomorphology and 

stream width:

Geology- Volcanic

At a minimum, 50 - 

75% of pools have a 

maximum pool depth 

appropriate for the 

stream’s natural 

conditions based on 

geomorphology and 

stream width.

At a minimum, < 50% 

of pools have a 

maximum pool depth 

appropriate for the 

stream’s natural 

conditions based on 

geomorphology and 

stream width.

Average

Width (ft)

Max 

Depth (ft)

0-10 1.0

> 10 1.3

Streambank 

ConditionA,H 

> 80% of of any 

stream reach is stable

50 - 80% of any 

stream reach is stable

< 50% of any stream 

reach is stable

Water Quality Temperature

C,F,J 

Mean maximum 

weekly temperature is 

always < 65oF (10 - 

18o

C) during summer 

months

Mean maximum 

weekly temperature 

within 65 - 75oF during 

summer months

Mean maximum 

weekly temperature 

> 75oF during summer 

months

Life History 

Diversity and 

Isolation

Connectivity/

BarriersB,K 

Subpopulation is 

connected (barrierfree) to other subpopulations in the 

watershed throughout 

the year.

Subpopulation has 

seasonal barriers due 

to low water levels or 

drying of the stream 

bed.

Subpopulation is 

completely isolated 

throughout the entire 

year.
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

•

•

•

A-98

Indicator 

Category Indicator

Thresholds

Functioning 

Appropriately Functioning at Risk Functioning at 

Unacceptable Risk

Watershed 

Condition

Functional 

ConditionI 

Adequate vegetation 

and land form is 

present to dissipate 

stream energy 

associated with high 

flow. 

Riparian/wetland area 

is in functional 

condition but an 

existing soil, water, or 

vegetation attribute 

makes the area 

susceptible to 

degradation.

Riparian/wetland 

areas are nonfunctional and are not 

providing adequate 

vegetation and land 

form to dissipate 

stream energy 

associated with high 

stream flows. A (Buffington et al., 2002). B (Cegelski et al., 2004). C (Meyer et al., 2010). D (Muhlfeld et al., 2001a). E (Muhfeld et al., 2001b). F (Muhlfeld, 2002).

G (Overton et al., 1995). H (USDA and USDI, 1995). I (Prichard et al., 1998a). J (Raleigh et al., 1984). K (Zoellick et al., 2005).

For each stream reach, values for each indicator were compared to the thresholds for that indicator and 

given a score that ranged between +1.0 and –1.0, where +1.0 reflects conditions functioning properly for 

fish and –1.0 reflects conditions functioning at an unacceptable risk for fish. Scores between +0.5 and -

1.0 reflect stream reaches with reduced functional condition for fish. 

Where indicators described different components of the same stream characteristic (e.g., pools per mile 

and large pools both describe pools), the NetWeaver model calculated the mean of the scores for those 

indicators to yield an overall score for that stream indicator. Finally, the NetWeaver model calculated the 

mean of the stream indicator scores to yield an overall NetWeaver ranking for each stream reach. The 

stream indicator scores were weighted equally in calculating the mean as scientific literature and field 

data suggest the indicators used in the model are all important in determining habitat functionality for 

special status fish.

The results of the analysis allow the identification of stream reaches not meeting desired conditions 

(Restoration Reaches) and those mostly meeting desired conditions (Conservation Reaches). Although 

indicator data are aggregated for the overall NetWeaver ranking, the model output also shows the relative 

condition of each individual indicator. 

HC ratings for special status fish were based on the NetWeaver analysis combined with an evaluation of 

restoration feasibility, the extent of the habitat, and relative fish abundance. Stream reaches were 

classified as either Conservation Reaches or Restoration Reaches; restoration priorities for Restoration 

Reaches, as well as any indicators in a degraded condition (i.e., NetWeaver score <0.0), were identified 

as well. The process for determining the HC rating for a stream reach is outlined below:

Step 1: Assign an initial HC rating based on NetWeaver rankings: 

Conservation Reaches: +0.5 to +1.0

Restoration Reaches: -1.0 to +0.5

High Priority Restoration Reaches: 0.0 to +0.5

Moderate Priority Restoration Reaches: -0.5 to 0.0

Low Priority Restoration Reaches: -1.0 to -0.5
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A-99

Step 2: For Restoration Reaches, increase or decrease restoration priority according to the following 

guidelines:

Restoration feasibility: Increase restoration priority where BLM can address the limiting indicator (e.g., 

replacing a culvert, modifying livestock grazing season of use) or decrease restoration priority where BLM 

cannot address the limiting indicator (e.g., removing diversions). 

Extent of habitat: Increase restoration priority if stream reach is longer than 0.6 miles and is primarily 

comprised of public lands. 

Relative fish abundance: Increase restoration priority if the reach has high abundance of bull trout or 

redband trout. 

Conservation and Restoration Reaches with Special Status Fish

As described above, HC ratings were used to describe priorities for restoration of special status fish 

habitat. Table D-3 displays the conservation and restoration priorities for streams occupied by special 

status fish; for Restoration Reaches, the indicators in a degraded condition (i.e., NetWeaver score -1.0 to 

+0.5) are identified. These indicators can help focus restoration efforts toward those indicators most in 

need of improvement with respect to habitat for special status fish. For Conservation Reaches, the 

indicators are in good condition (i.e., NetWeaver score +0.5 to +1.0). Maps D-1 through D-9 (in the Maps

section below) display the locations of these reaches. HC data is available for 21% of the approximated 

250 miles of streams containing special status speciesl habitat. Restoration priorites would continue to 

focus on reaches containing special status fish but may be adjusted as additional HC inventories are 

completed. 

Table D-3. HC Ratings and Indicators in a Degraded Condition for Stream Reaches Containing 

Special Status Fish

Stream Reach Miles Indicators in a Degraded Condition

Streams Containing Bull Trout, Critical Habitat for Bull Trout, and Redband Trout

Conservation Reaches

Jack CreekA Reach 1 0.1 None identified

Jarbidge River, East ForkA Reach 3 2.3 None identified

Reach 4 1.9 None identified

Jarbidge River, West ForkA

Reach 1 0.7 None identified

Reach 2 2.1 None identified

Reach 3 5.8 None identified

Total 12.9

Restoration Reaches – High Priority

Buck Creek Reach 1 2.5 Spawning substrate (redband trout)

Dave CreekA Reach 2 0.9 Habitat complexity, spawning substrate (bull trout)

Deer CreekA (NV) Reach 1 0.9 Spawning substrate (redband trout)

Jarbidge River, East ForkA Reach 1 1.9 Water temperature, spawning substrate (redband 

trout)

Total 6.2

Restoration Reaches – Moderate Priority

Dave CreekA Reach 1 1.7 Habitat complexity, spawning substrate

Total 1.7

Restoration Reaches – Low Priority

Jarbidge RiverA

Reach 1 0.5 Water temperature – juvenile rearing, spawning 

substrate (redband trout) 

Reach 2 1.2 Water temperature – juvenile rearing, spawning 

substrate (redband trout)

Reach 3 1.2 Water temperature – juvenile rearing (redband 

trout)
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

A-100

Stream Reach Miles Indicators in a Degraded Condition

Restoration Reaches – Low Priority

Jarbidge RiverA Reach 4 0.9 Water temperature – juvenile rearing, spawning 

substrate (redband trout)

Jarbidge River, East ForkA Reach 2 1.3 Pools/mile, water temperature – juvenile rearing

Total 5.1

Streams Containing Redband Trout but not Bull Trout or Critical Habitat for Bull Trout

Conservation Reaches

Cedar Creek 

Reach 1 0.2 None identified

Reach 3 1.0 None identified

Reach 4 1.2 None identified

Reach 5 0.8 None identified

Reach 6 2.1 None identified

Total 5.3

Restoration Reaches – High Priority

Deer Creek (ID) Reach 3 0.6 Streambank stability, cover

Reach 4 1.1 Pool volume

Flat Creek Reach 2 1.1 Water temperature – juvenile rearing (redband 

trout)

House Creek, Lower Reach 1 0.4 Pool volume

Three Creek, Lower Reach 1 0.4 Water temperature, migration barrier

Total 3.6

Restoration Reaches – Moderate Priority

Bear Creek Reach 1 0.4 Pool quality, volume 

Reach 2 0.4 Pool quality, volume 

China Creek, Upper Reach 1 0.1 Pool volume, quality, migration barrier

Deer Creek (ID) 

Reach 1 0.8 Pool quality, streambank stability, cover 

Reach 2 0.2 Pool quality, streambank stability, cover, substrate 

Reach 5 0.7 Streambank stability, cover

Deadwood Creek Reach 1 0.5 Streambank stability, pool volume 

Reach 2 0.5 Pool volume

House Creek, Lower Reach 2 0.4 Pool volume, streambank stability, pool quality

Reach 3 0.4 Pool volume, quality

House Creek, Upper 

Reach 1 0.1 Streambank stability, pool volume, quality

Reach 2 0.2 Pool volume, quality

Reach 3 0.4 Pool volume

Reach 4 0.3 Streambank stability, substrate, pool quality

Rocky Canyon Creek 

Reach 1 0.8 Pool quality, substrate

Reach 2 0.3 Pool quality, substrate 

Reach 3 0.5 Pool volume, quality

Total 7.0

Restoration Reaches – Low Priority

Cedar Creek Reach 2 0.3 Streambank cover, stability 

Reach 7 1.2 Pool volume

Chimney Creek Reach 1 0.1 Pool volume, quality

China Creek, Lower 

Reach 1 0.3 Streambank stability, cover, substrate

Reach 2 1.0 Streambank cover, stability, substrate, pool quality 

Reach 3 1.0 Streambank stability, substrate, pool quality

Reach 4 0.4 Substrate, pool quality

Deadwood Creek, East Fork Reach 1 0.1 Pool volume, quality

Deadwood Creek, West Fork Reach 1 0.2 Pool volume, quality

Flat Creek Reach 1 0.5 Substrate

Reach 3 0.6 Pool quality

House Creek, Little Reach 1 0.3 Streambank stability, pool volume
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A-101

Stream Reach Miles Indicators in a Degraded Condition

Restoration Reaches – Low Priority

Pole Creek 

Reach 1 0.8 Streambank stability, cover, pool volume, quality 

Reach 2 0.9 Streambank stability, cover, substrate, pool 

volume

Shack Creek Reach 1 0.2 Pool quality, volume

Reach 2 0.6 Pool quality, substrate

Three Creek, Lower Reach 2 0.3 Substrate, pool quality

Reach 3 0.3 Streambank stability, cover, substrate

Three Creek, Middle Reach 1 0.3 Streambank cover, stability

Three Creek, Upper Reach 1 0.1 Streambank stability, cover, pool volume, quality

Timber Canyon Creek Reach 1 0.8 Streambank stability, pool volume

Reach 2 1.1 Streambank stability, pool volume

Total 11.4

Grand Total HC Rated Streams 53.2 A Streams containing critical habitat for Jarbidge River bull trout.

Riparian Habitat

Proper functioning condition (PFC) ratings were used to assess priority for riparian restoration. Riparian 

restoration priorities focus on reaches that are functioning-at-risk with no apparent trend (FAR-NA) or 

functioning-at-risk with a downward trend (FAR-DN). Once an area is rated as non-functioning (NF), the 

effort, cost, and time required for recovery is dramatically increased (Prichard et al., 1998a). Areas that 

are at PFC are usually not the highest priority for restoration because they are more resilient than the 

functional-at-risk reaches. Consequently, stream reaches rated as FAR-NA and FAR-DN were prioritized 

as Priority 1 for restoration, streams rated as functioning-at-risk with an upward trend (FAR-UP) and NF 

were prioritized as Priority 2, and streams rated as PFC were prioritized as Priority 3. 

For the stream reaches with 2006 PFC and HC data, the PFC data were validated using the quantitative 

HC data for individual stream reaches. The PFC evaluation was used to assess riparian function at a 

watershed scale (general qualitative assessment), and the HC data were used to assess stream channel 

condition (i.e., hydrology, riparian vegetation, erosion, and deposition) at a site-specific scale (detailed 

quantitative assessment). The validation process used the HC data to answer PFC questions 3, 8, 9, 11, 

14, and 15 (Prichard et al., 1998a) to ensure consistency between the HC and PFC determination of 

functional condition. 

Management of stream reaches is prioritized based on instream (HC) and riparian habitat condition (PFC)

ratings, which are based on instream and riparian indicators; the relationship between habitat and riparian 

priorities are displayed in Table D-4. Where streams have both HC and PFC ratings, the priority based on 

the HC rating takes precedence. 

Table D-4. Crosswalk between Priority Rankings for Special Status Fish Habitat Management and 

Riparian Area Management

HC Rating PFC Rating

Conservation Reach NA 

High Priority Restoration Reach Priority 1 (FAR-NA, FAR-DN)

Moderate Priority Restoration Reach Priority 2 (FAR-UP, NF)

Low Priority Restoration Reach Priority 3 (PFC)

The validated PFC ratings were used to prioritize riparian reaches for restoration or conservation 

(maintenance). The priorities for riparian restoration are summarized in Table D-5. PFC data is available 

for 71% of the perennial streams within the planning area. Restoration priorites may be adjusted as 

additional PFC assessments are completed.
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

A-102

Table D-5. Riparian PFC Ratings and Restoration Priorities

Stream Stream Reach Miles

Restoration Priority 1

Antelope Springs 0.0 - 0.3 0.4

1.4 - 2.7 1.3

Bear Creek

4.2 - 4.3 0.1

4.3 - 4.6 0.3

4.6 - 5.4 0.8

Bear Creek, East Fork 0.6 - 1.5 1.0

Bear Creek, Middle Fork 0.2 - 0.4 0.2 

Browns Creek 1.4 - 3.1 1.7

Cedar Creek 15.2 - 15.7 0.5

30.0 - 30.7 0.7 

Cherry Creek

1.5 - 1.8 0.3

5.1 - 5.2 0.1

12.3 - 13.4 1.1

China Creek 1.4 - 1.8 0.4 

2.0 - 2.8 0.8

China Creek, East Fork 0.0 - 3.5 3.4

Clover Creek

0.7 - 3.4 2.7

0.0 - 0.7 0.6

3.4 - 7.8 4.4

7.8 - 9.3 1.5

11.0 - 12.3 1.3

18.5 - 21.9 3.4

21.9 - 22.5 0.6

30.9 - 31.1 0.2

33.0 - 33.6 0.6

40.2 - 41.8 1.6

Columbet Creek 0.0 - 1.2 1.5 

9.8 - 9.9 0.1

Cougar Creek 0.0 - 3.0 3.0

Deadwood Creek

1.8 - 2.7 0.9

2.7 - 3.0 0.3

16.8 - 17.8 1.0 

Deep Creek 2.3 - 2.8 0.4

2.8 - 3.2 0.4

Deer Creek (ID)

3.2 - 5.1 1.9

5.7 - 6.3 0.6 

6.3 - 6.5 0.2

6.5 - 7.7 1.2

Devil Creek

35.5 - 36.2 0.6

34.7 - 35.5 0.8

32.8 - 34.7 1.9

28.7 - 32.8 0.4

33.2 - 33.4 0.2

33.4 - 34.0 0.6

34.0 - 34.7 0.8

Hayes Canyon 1.0 - 2.4 1.3 

2.4 - 3.7 1.3 

House Creek 0.0 - 0.3 0.3

Jarbidge RiverA

29.4 - 30.1 0.7

30.1 - 30.7 0.6

31.1 - 32.1 1.0
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A-103

Stream Stream Reach Miles

Restoration Priority 1

Jarbidge RiverA

32.1 - 32.5 0.4

32.5 - 33.2 0.7

33.2 - 33.4 0.2

33.4 - 37.5 4.0 

37.6 - 38.7 1.0 

38.7 - 39.8 1.0 

Jarbidge River, East ForkA

0.0 - 1.2 1.1

1.2 - 2.2 1.0

2.9 - 4.7 1.8

Little House Creek 4.2 - 5.6 1.4

Pole Creek 0.4 - 0.7 0.3

Ross Pasture Creek 0.0 - 2.1 2.1

Shack Creek 3.6 - 3.8 0.2

3.8 - 4.2 0.4

Sheep Creek 0.1 - 0.3 0.2

Spring Creek 5.6 - 7.0 1.4

Three Creek

0.3 - 1.5 1.2

4.7 - 5.8 1.1

11.8 - 12.1 0.3

12.1 - 12.3 0.2

Timber Canyon 2.0 - 2.3 0.3

0.7 - 2.0 1.3

Tuana Gulch 5.9 - 6.9 1.0

Whiskey Slough 0.0 - 1.3 1.3

Yahoo Creek 3.3 - 3.4 0.1

Total 76.0

Restoration Priority 2

Big Flat Creek 0.3 - 1.2 1.0

12.6 - 12.8 0.2

Cedar Creek

16.7 - 17.3 0.6

24.9 - 25.6 0.7

25.6 - 26.1 0.5

26.1 - 26.7 0.6

28.2 - 28.4 0.2

28.4 - 29.0 0.6

29.0 - 30.0 1.0

Cherry Creek 9.3 - 10.1 0.9

13.4 - 14.1 0.8

China Creek

0.0 - 0.2 0.2

0.2 - 0.7 0.6

0.7 - 1.4 0.7

2.8 - 3.2 0.4

Clover Creek

12.3 - 13.5 1.0

13.5 - 15.7 2.5

17.4 - 18.3 1.1

18.3 - 18.5 0.2

23.0 - 23.8 0.9

26.8 - 27.6 0.8

27.6 - 29.2 1.4

29.2 - 29.9 0.7

29.9 - 30.2 0.3
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

A-104

Stream Stream Reach Miles

Restoration Priority 2

Clover Creek

30.2 - 30.9 0.7

31.1 - 32.8 1.7

32.8 - 33.0 0.2

35.5 - 36.4 0.9

36.4 - 38.0 1.6

38.0 - 40.2 2.2

41.8 - 46.0 4.2

46.3 - 47.5 1.4

52.0 - 52.2 0.3

52.2 - 52.7 0.6

52.7 - 53.5 0.8

Columbet Creek

2.3 - 3.4 1.2

3.4 - 3.7 0.3

3.7 - 5.0 1.4

9.0 - 9.3 0.3

Deadman Creek (NV) 0.0 - 0.8 0.8

Deadwood Creek 3.0 - 4.2 1.2

Deer Creek (ID) 3.2 - 4.3 0.9

House Creek 3.6 - 4.4 0.8

Little Spring Creek 2.5 - 2.8 0.3

2.8 - 3.0 0.2

Pole Creek 0.7 - 1.3 0.7

3.4 - 4.9 1.5

Ring Springs

0.9 - 1.5 0.9

0.0 - 0.6 0.6

0.6 - 0.9 0.3

Rocky Canyon 0.7 - 1.7 1.1

1.7 - 2.0 0.6

Shack Creek, East Fork 0.0 - 0.2 0.2

Snake River

539.7 - 540.7 0.9

563.4 - 567.7 4.0

556.6 - 557.1 0.5

Three Creek 6.3 - 6.8 0.5

Tuana Gulch 2.5 - 3.5 1.0

3.5 - 5.2 1.7

Total 63.4

Restoration Priority 3

Big Flat Creek

7.7 - 8.6 0.9

8.6 - 8.9 0.3

12.0 - 12.6 0.7

12.8 - 13.2 0.4

Browns Creek 3.1 - 4.2 1.1

Buck Creek 0.0 - 2.5 2.5

Cedar Creek

15.7 - 16.7 1.0

17.3 - 18.8 2.0

26.7 - 27.4 0.7

27.4 - 27.9 0.6

30.7 - 31.1 0.4

Cherry Creek

10.1 - 10.9 0.6

10.9 - 12.3 1.3

14.1 - 14.6 0.5
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Stream Stream Reach Miles

Restoration Priority 3

China Creek

4.5 - 4.7 0.2

4.7 - 5.0 0.3

5.0 - 5.2 0.4

China Creek, Middle Fork 1.8 - 2.0 0.7

Clover Creek 49.5 - 52.0 2.5

Columbet Creek 5.0 - 6.0 1.0

8.3 - 9.0 0.7

Corral Creek 0.4 - 1.1 0.6

Crawfish Springs Creek 0.5 - 0.9 0.3

Dave CreekA 0.0 - 2.2 2.3

2.4 - 2.7 0.3

Deep Creek 0.0 - 2.3 2.4

3.2 - 4.5 1.4

Deer CreekA (NV) 0.7 - 1.6 0.8

Deer Creek (ID) 5.1 - 5.7 0.6

Dorsey Creek 14.2 - 14.7 0.4

Flat Creek 13.2 - 14.4 1.2

15.7 - 16.6 0.9

House Creek

3.4 - 3.6 0.2

16.8 - 17.5 0.7

17.6 - 17.8 0.2

17.8 - 18.1 0.3

18.4 - 19.6 1.2

Jarbidge RiverA

0.0 - 2.6 2.6

2.6 - 9.6 6.3

9.6 - 13.0 3.3

13.0 - 15.6 1.8

15.6 - 21.7 6.2

21.7 - 28.6 7.0

28.6 - 29.1 0.5

29.1 - 29.4 0.3

Jarbidge River, East ForkA 4.9 - 8.7 3.7

Little House Creek 5.6 - 6.2 0.7

Meadow Springs Creek 0.6 - 1.0 0.4

Player Creek

1.9 - 3.4 1.5

trib. 1 0.3

trib. 2 0.2

Pole Creek

0.0 - 0.4 0.4

1.3 - 1.8 0.5

1.8 - 3.4 1.5

Snake River

551.7 - 554.5 1.5

541.4 - 545.6 0.3

533.6 - 535.5 1.8

530.2 - 532.5 2.3

558.8 - 561.6 0.3

558.8 - 561.6 1.8

571.1 - 577.9 1.1

Taylor Canyon Creek 0.0 - 1.0 1.0

Three Creek 12.3 - 14.4 2.1

14.4 - 15.3 1.0
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

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4

A-106

Stream Stream Reach Miles

Restoration Priority 3

Tuana Gulch 5.2 - 5.6 0.4

5.6 - 5.9 0.3

Yahoo Creek

0.6 - 0.9 0.3

0.9 - 1.1 0.2

1.1 - 2.1 1.0

Total 85.2 

Grand Total PFC Rated Streams 225.0 A Streams containing critical habitat for Jarbidge River bull trout.

Management Direction

This section addresses material for Component V, Management Direction – Adaptive Management, related to 

management direction in the Guidance for Developing Aquatic Conservation Strategies (BLM, 2008a). 

Goals The goals for aquatic resources (Water Resources, Riparian Areas and Wetlands, Fish, and Special 

Status Fish and Aquatic Invertebrates) establish an expectation of the characteristics of healthy, 

functioning watersheds, riparian areas, and associated fish habitats. Because the quality of water and 

condition of riparian and fish habitat is directly influenced by the integrity of upland and riparian areas 

within the watersheds, the aquatic resource goals are to move towards or accomplish the goals, as 

displayed in Table D-6. 

Table D-6. Goals for Aquatic Resources

Goal Number Goal

Water Resources

WR-CA-G-1. Maintain or improve the chemical, physical, and biological integrity of water resources.

Riparian Areas and Wetlands

RI-CA-G-1. Achieve healthy, functioning watersheds, riparian areas, wetlands, and associated 

aquatic habitats.

RI-CA-G-2. 

Provide habitat to support populations of well-distributed native and desired non-native 

plant, vertebrate, and invertebrate populations that contribute to the sustainability of 

riparian-dependent communities. 

RI-CA-G-3. 

Maintain or improve naturally functioning vegetation communities that include natural 

timing and variability of surface and groundwater in riparian areas and wetlands, and 

diversity and productivity of native and desired non-native plant communities. 

Fish

FI-I-G-1. 

FI-IV-G-1. 

FI-V-G-1. 

FI-VI-G-1.

Manage public lands to promote diverse, structured, resilient, and connected habitats 

for fish.

FI-II-G-1. Manage public lands to maintain or improve habitat for fish.

FI-III-G-1. Manage public lands to maintain habitat for fish while reducing wildland fire size and 

intensity.

Special Status Fish and Aquatic Invertebrates

SS-CA-G-1. Manage public lands to contribute to the conservation and recovery of sage-grouse 

and other special status species.

Objectives

The ARMS is intended to guide management toward desired outcomes comprised of goals and 

objectives. The objectives for aquatic resources (Water Resources, Riparian Areas and Wetlands, Fish, 

and Special Status Aquatic Fish and Aquatic Invertebrates) are based on indicators that are measurable 
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A-107

and relate to the specific resource or species of interest. Bull trout and redband trout population and 

habitat objectives that are appropriate for the watershed scale can be described in terms of the habitat 

condition indicators displayed in Table D-1 and Table D-2. The objective for streams containing bull trout 

or redband trout habitat is a rating of “Functioning Properly” for the indicators listed in Table D-1 and 

Table D-2, which reflect desired aquatic, riparian, and watershed conditions that are adapted locally. 

Optimum conditions may not always be achievable for every indicator in every stream reach because of 

historic land uses, land ownership patterns (e.g., private and other non-BLM managed lands), and 

specific watershed characteristics. Table D-7 describes objectives for stream reaches containing special 

status fish habitat relative to the NetWeaver rankings that formed the basis for the HC ratings as 

Conservation or Restoration reaches. 

Table D-7. Objectives for Aquatic Resources

Objective 

Number Objective

Water Resources

WR-CA-O-1. Make progress towards meeting Federal and State water quality standards. 

Riparian Areas and Wetlands

RI-I-O-1. 

Maintain 85 miles of Priority 3 streams at proper functioning condition (PFC); improve 

60 miles of Priority 1 streams to achieve PFC; and improve the remaining 17 miles of 

Priority 1 streams and 63 miles of Priority 2 streams to be moving toward PFC over the 

life of the plan.

RI-II-O-1. Maintain 85 miles of Priority 3 streams at proper functioning condition (PFC) and 

manage Priority 1 and 2 streams to move toward PFC over the life of the plan. 

RI-III-O-1. 

RI-IV-O-1. 

RI-V-O-1. 

RI-VI-O-1. 

Maintain 85 miles of Priority 3 streams at proper functioning condition (PFC); improve 

77 miles of Priority 1 streams and 21 miles of Priority 2 streams to achieve PFC; and 

improve the remaining 42 miles of Priority 2 streams to be moving toward PFC over

the life of the plan. 

RI-I-O-2.

RI-II-O-2. 

RI-III-O-2. 

RI-IV-O-2.

RI-V-O-2. 

Manage wetlands to move toward PFC.

RI-VI-O-2. Manage wetlands not associated with streams (springs, seeps, playas) to achieve 

PFC.

Fish

FI-I-O-1.

Maintain or improve streams so 70% of the miles of non-game fish-bearing streams 

are managed for properly functioning condition. The remaining 30% of non-game fishbearing streams would be moving toward properly functioning condition. 

FI-II-O-1. 

FI-III-O-1.

Maintain or improve all non-game fish-bearing streams so they remain or are moving 

toward properly functioning condition. 

FI-IV-O-1. 

FI-V-O-1. 

Maintain or improve streams so 70% of the miles of non-game fish-bearing streams 

and their perennial tributaries are managed for properly functioning condition. The 

remaining 30% of miles of non-game fish-bearing streams and their perennial 

tributaries would be moving toward properly functioning condition. 

FI-VI-O-1.

Maintain 85 miles of Priority 3 streams at proper functioning condition (PFC); improve 

77 miles of Priority 1 streams and 21 miles of Priority 2 streams to achieve PFC; and 

improve the remaining 42 miles of Priority 2 streams and 20 miles of streams with 

unknown PFC rating to move towards PFC over the life of the plan.

FI-VI-O-2. Manage the 72 miles of stream containing only native non-game fish to maintain or 

improve habitat condition.

Status Special Fish and Aquatic Invertebrates

SS-I-O-1. 

SS-IV-O-1. 

SS-V-O-1. 

SS-VI-O-1.

Maintain or improve the quality and quantity of habitat for sage-grouse and other 

special status species by managing public land activities to sustain or benefit those 

species. 
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

A-108

Objective 

Number Objective

Status Special Fish and Aquatic Invertebrates

SS-II-O-1.

SS-III-O-1. 

Maintain or improve the quality of habitat for sage-grouse and other special status 

species by managing public land activities to sustain or benefit those species.

Management Approaches Four general types of management approaches that may be considered for achieving the aquatic and 

riparian objectives.

Protection

This management strategy would conserve aquatic and riparian areas that are ecologically intact and fully 

functional. Human activities that influence instream and riparian ecological functions are restricted. This

management strategy strives to protect aquatic and riparian ecosystems currently in good condition so 

that naturally regenerative processes can continue to operate. Conservation designations that typically 

include wilderness and minimally developed watersheds would fall within this management strategy. High 

priority restoration projects do exist within portions of some Conservation Reaches. Also, some 

Restoration Reaches may have a stream segment or watershed area that is ecologically intact and 

functional. 

Passive Restoration

This management strategy emphasizes preventing further decline in aquatic and riparian ecosystem 

integrity. To the extent possible, human disturbances to altered aquatic and riparian ecosystems would be 

removed or minimized in order to allow natural processes to be the primary agents of recovery. This 

management strategy would allow the natural disturbance regime to dictate the speed of recovery in 

areas that have a high probability of returning to a fully functional condition without human intervention. 

This management strategy can be applied to the low and moderate priority Restoration Reaches and 

Priority 2 and 3 riparian reaches. The rate of recovery may be several decades or more. 

Active Restoration

This management strategy would focus on returning functionally impaired aquatic and riparian 

ecosystems to a state that would occur naturally at the site by actively managing certain aspects of 

habitat recovery. It uses a combination of elements of natural recovery along with management activities 

directed at accelerating development of self-sustaining, ecologically healthy riparian ecosystems. This 

management strategy applies to the high and some moderate priority Restoration Reaches and Priority 1 

and 2 riparian reaches. Many watershed, riparian, and stream restoration projects fall into this category, 

including vegetation treatments, stream channel restoration, stream crossings removal or improvement, 

reducing road densities, and improving road condition. The rate of recovery may be one to two decades. 

Rehabilitation 

This management strategy would re-establish naturally self-sustaining riparian ecosystems to the extent 

possible, while acknowledging that irreversible changes, such as dams, permanent channel changes due 

to urbanization and streamside roads, stream channel incision, and human development within the RCA, 

would only result in partial restoration of ecological functions. This management strategy applies to the 

high and some moderate and low priority Restoration Reaches and Priority 1 and 2 riparian reaches. It 

would use a combination of passive and active management approaches where fully functional ecological 

conditions cannot occur.

Management for Riparian Conservation Areas 

Used in conjunction with adaptive management, the following management actions are designed to 

achieve aquatic and riparian goals (Table D-6) and objectives (Table D-7). This management is derived 

from the management direction contained in the Inland Native Fish Stragegy (INFISH) (USDA, 1995) and 

the Interior Columbia Basin Ecosystem Management Project (Quigley et al., 1997) and is consistent with 
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A-109

existing conservation and recovery plans for special status aquatic species within the planning area

(Table D- 9). The management actions in Table D-8 apply to all RCAs and to projects and activities in 

areas outside of RCAs that are identified through the NEPA analysis process as having the potential to 

degrade RCAs. Management to be applied to a specific project will be identified during project planning 

on a site- and project-specific basis.

Table D-8. Management Actions for Activities In or Affecting Riparian Conservation Areas 

Management 

Action Number Management Actions

Water Resources

WR-CA-MA-6. Consult or coordinate with the tribes and with Federal, State, and local agencies 

when determining location and designs for water development projects.

WR-CA-MA-10.

Consult or coordinate as appropriate with Tribal, Federal, State, and local 

governments to identify and secure instream flows needed to maintain riparian 

resources, channel conditions, and aquatic habitat.

WR-CA-MA-11.

Apply chemicals (i.e., herbicides, pesticides, insecticides, and other toxicants) in a 

manner that does not impair water quality or prevent attainment of objectives for 

riparian areas and wetlands and avoids adverse effects on inland non-game fish and 

their habitat. When applying chemicals in a Riparian Conservation Area (RCA), a 

spill kit would be onsite as appropriate. Prohibit storing and mixing chemicals within 

RCAs unless there are no other practical alternatives.

WR-CA-MA-12.

Prohibit storage of fuels and other toxicants and refueling within RCAs unless there 

are no other practical alternatives. Any refueling sites and/or storage areas within an 

RCA would have an approved refueling and spill containment plan. 

Riparian Areas and Wetlands

RI-CA-MA-8.

Modify existing management activities and authorized uses in RCAs to attain PFC

and ensure that habitat conditions of streams, riparian areas, and wetlands are 

moving toward achieving the goals and objectives for riparian areas and wetlands. 

RI- CA-MA-9.

Conduct new management activities within or affecting RCAs only if they are 

consistent with achieving the goals and objectives for riparian areas and wetlands. 

New management activities would avoid or reduce adverse effects on inland nongame fish, their habitats, and RCAs. 

RI- CA-MA-10. Trees may be felled in RCAs when they pose a safety risk. Keep felled trees on-site 

when needed to maintain or improve riparian or instream conditions.

RI-CA-MA-11.

Cooperate with Tribal, Federal, State, and local agencies and private landowners to 

develop watershed-based coordinated resource management plans or other 

cooperative agreements to achieve the goals and objectives for riparian areas and 

wetlands.

Fish and Wildlife Resources

FI-CA-MA-4.

To avoid adverse effects on non-game fish and instream flows, locate water drafting 

sites in upland areas (e.g., stock ponds, storage tanks, hydrants). Where these water 

sources are not available, locate water drafting sites at existing stream road 

crossings (e.g., bridges, culverts, fords) to divert water in a manner that does not 

retard or prevent achievement of the goals and objectives for riparian areas and 

wetlands. 

FI-CA-MA-5.

Design and implement watershed restoration projects in a manner that promotes the 

long-term ecological integrity of ecosystems, conserves the genetic integrity of nongame fish species, and contributes to the achievement of the goals and objectives for 

riparian areas and wetlands. 

FI-CA-MA-6. New fisheries and instream channel restoration projects would avoid or minimize 

adverse effects on non-game fish, their habitats, and RCAs.

FI-CA-MA-7.

Cooperate with Federal and State fish management agencies to identify and reduce 

adverse effects on non-game fish associated with habitat manipulation, fish stocking, 

fish harvest, and illegal harvest. 
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

A-110

Management 

Action Number Management Actions

Wildland Fire Ecology and Management

WFM-CA-MA-10. Fire suppression strategies, practices, and actions in RCAs should be designed to 

minimize disturbance to riparian vegetation. 

WFM-CA-MA-11. Minimum Impact Suppression Tactics would be used within RCAs unless safety to 

human life or property is an issue. 

WFM-CA-MA-12.

Incident bases, camps, helibases, staging areas, helispots, and other centers for 

incident activities would be located outside of RCAs. If the only suitable location for 

these activities is within the RCA, an exemption may be granted by the BLM 

authorized officer. 

WFM-CA-MA-13.

Avoid delivery of chemical retardant, foam, or additives into surface waters. An 

exception is warranted where overriding immediate safety imperatives exist or when 

the BLM determines a fire would cause more long-term damage to fish habitats than 

chemical delivery to surface waters.

FE-CA-MA-5. Fuels treatments in RCAs would be designed to maintain or improve riparian 

vegetation. 

FE-CA-MA-7.

Implement the Programmatic Emergency Stabilization and Burned Area 

Rehabilitation (ES&BAR) Plan and update as needed. Individual ES&BAR plans 

would be completed through the interdisciplinary process to reduce impacts of 

wildland fire and suppression and to achieve resource objectives.

Livestock Grazing

LG-CA-MA-11.

Grazing management activities (e.g., grazing, trailing, bedding, watering, salting, 

loading, other handling efforts) would be modified, discontinued, or relocated if they 

are not maintaining aquatic and riparian conditions. 

LG-CA-MA-12.

In areas that are readily accessible to cattle and known or suspected special status

fish spawning habitat, develop and implement grazing practices to avoid or restrict 

trampling of redds (eggs) and other direct and indirect effects that may result in 

adverse impacts to the species.

LG-CA-MA-14. 

Grazing facilities and infrastructure (e.g., livestock handling and management 

facilities, fences, watering facilities) would be modified, discontinued, or relocated if 

they are not maintaining aquatic and riparian conditions. 

Recreation

REC-CA-MA-3.

New and existing recreation-related activities and facilities within or affecting RCAs 

would be designed, modified, relocated, or discontinued if they are not maintaining 

aquatic and riparian conditions. 

Transportation and Travel

TR-CA-MA-9.

Cooperate with tribes, Federal, State, and county agencies to reduce adverse effects 

and support the achievement of the goals and objectives for riparian areas and 

wetlands in the long term.

TR-CA-MA-10.

Minimize locating new roads or road-related facilities in RCAs. Before building new 

roads or other road-related facilities in RCAs, complete a watershed or site-specific 

analysis. The level of analysis should be commensurate with the scope and issues of 

the project and related aquatic resources. Analysis should identify how road design 

features would minimize or avoid adverse effects to aquatic and riparian resources at 

site-specific, reach, and watershed scales.

TR-CA-MA-11. Temporary roads within or affecting RCAs would be fully decommissioned and 

rehabilitated once the road is no longer needed to meet the intended purpose. 

TR-CA-MA-12. Avoid or minimize sediment delivery to streams from the road surface to allow the 

achievement of the goals and objectives for riparian areas and wetlands. 

TR-CA-MA-13. Avoid sidecasting road surface material into areas where it may reach RCAs.
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Management 

Action Number Management Actions

Transportation and Travel

TR-CA-MA-14.

Design new, replacement, and reconstructed stream crossings (culverts, bridges, 

and other stream crossings) to: 

• Accommodate a 100-year flood, including associated bedload and debris in bull 

trout occupied watersheds. In watersheds containing other non-game fish, 

design new, replacement and reconstructed stream crossings to accommodate a 

100-year flood event, unless a site-specific analysis determines the goals and 

objectives for riparian areas and wetlands could be achieved with fewer impacts 

to the RCA;

• Provide and maintain fish passage at all road crossings of existing and potential 

fish-bearing streams; and

• Accommodate mean bankfull channel widths to maintain channel integrity.

Leasable Minerals

LE-CA-MA-8.

For those leasable mineral development activities conducted pursuant to valid 

existing rights that pose risks to achievement of management objectives, use existing 

authorities to mitigate and/or require, to the extent authorized, design features that 

would contribute to the maintenance of streambanks, shorelines, streambed 

configuration, water quality, amount and distribution of woody debris, thermal 

regulation, characteristic erosion rates, and amount and distribution of source 

habitats.

LE-CA-MA-9.

Locate leasable mineral project related infrastructure outside RCAs. Where there is 

no alternative, locate and construct the infrastructure to avoid impacts on RCAs. 

Keep the number of roads to the minimum necessary for the approved mineral 

activity. Decommission and revegetate roads no longer required for mineral 

management and related activities.

LE-CA-MA-10. New leasable mineral management projects and operations would avoid or minimize 

adverse effects on non-game fish, their habitats, and RCAs.

LE-CA-MA-11.

Develop inspection, monitoring, and reporting requirements for leasable mineral 

activities within or affecting RCAs. Evaluate and apply the results of inspection and 

monitoring to modify mineral plans, leases, or permits as needed to achieve the 

goals and objectives for riparian areas and wetlands.

Salable Minerals

SA-CA-MA-5.

For those salable mineral development activities conducted pursuant to valid existing 

rights that pose risks to achievement of goals and objectives for riparian areas and 

wetlands, use existing authorities to mitigate and/or require, to the extent authorized, 

design features that would contribute to the maintenance of streambanks, shorelines, 

streambed configuration, water quality, amount and distribution of woody debris, 

thermal regulation, characteristic erosion rates, and amount and distribution of 

source habitats.

SA-CA-MA-6.

Locate salable mineral project related infrastructure outside RCAs. Where there is no 

alternative, locate and construct the infrastructure to avoid impacts on RCAs. Keep 

the number of roads to the minimum necessary for the approved mineral activity. 

Decommission and revegetate roads no longer required for mineral management 

and related activities.

SA-CA-MA-7. New salable mineral management projects and operations would avoid or minimize 

adverse effects on non-game fish, their habitats, and RCAs.

Locatable Minerals

LO-CA-MA-2.

Locate mineral project related infrastructure outside RCAs. Where there is no 

alternative, locate and construct the infrastructure to avoid impacts on RCAs. Keep 

the number of roads to the minimum necessary for the approved mineral activity. 

Decommission and revegetate roads no longer required for mineral management 

and related activities.
Appendix D: Aquatic and Riparian Management Strategy Jarbidge Proposed RMP/Final EIS

A-112

Management 

Action Number Management Actions

Locatable Minerals

LO-CA-MA-3. New locatable mineral management projects and operations would avoid or minimize 

adverse effects on non-game fish, their habitats, and RCAs.

LO-CA-MA-4.

Develop inspection, monitoring, and reporting requirements for locatable mineral 

activities within or affecting RCAs. Evaluate and apply the results of inspection and 

monitoring to modify mineral plans, leases, or permits as needed to achieve the 

goals and objectives for riparian areas and wetlands.

Land Use Authorizations 

LA-CA-MA-13. New land use authorizations would avoid or minimize adverse effects on non-game 

fish, their habitats, and RCAs.

LA-CA-MA-14.

For existing land use authorizations that prevent the achievement of the goals and 

objectives for riparian areas and wetlands, use existing authorities to redesign, 

modify, or apply mitigations to reduce impacts to non-game fish, their habitats and 

RCAs.

LA-CA-MA-15.

During Federal Energy Regulatory Commission (FERC) licensing or relicensing of 

hydroelectric projects, terms and conditions that achieve the goals and objectives for 

riparian areas and wetlands over the new license term should be submitted to the 

FERC.

Land Tenure

LT-CA-MA-7.

Use land acquisition, exchanges, and conservation easements to support 

achievement of the goals and objectives for riparian areas and wetlands and facilitate 

restoration of native species and their habitat.

Note: These conservation measures are derived from those contained in INFISH (USDA, 1995). These measures 

promote the attainment of the Goals, Objectives,and Management Actions identified in Chapter 2 for Water 

Resources, Riparian Areas and Wetlands, Fish, and Special Status Fish and Aquatic Invertebrates. 

Management for Aquatic Species

Management for Non-Special Status Aquatic Species

The following management applies to aquatic species other than those listed under Endangered Species 

Act (ESA) or designated as Sensitive species under BLM’s policy for special status species. In the 

planning area, these include sculpins (Cottidae), suckers (Catostomidae), and minnows (Cyprinidae). 

These non-special status fish, commonly referred to as native non-game fish, occur independent of 

special status fish in five streams in the planning area, including portions of Barbour Creek, Tuana Gulch, 

Big Flat Creek, Clover Creek, and Salmon Falls Creek. Clover Creek, which is identified as a stream 

containing only native non-game fish, is identified as a water quality impaired stream by the Idaho 

Department of Environmental Quality. Sediment and bacteria were identified as the factors limiting water 

quality. The goals, objectives, and management actions specific to non-special status fish are provided in 

Chapter 2, Fish and Wildlife and displayed above in Tables D-6, D-7, and D-8. Where these fish occur in 

streams containing special status species, the goals, objectives, and management actions in for Special 

Status Fish and Aquatic Invertebrates would also achieve the habitat requirement needs of non-special 

status fish. 

Indicators for riparian habitat condition (HC) and proper functioning condition (PFC) ratings are used to 

determine if the desired riparian goals, objectives, and desired conditions are being met for native nongame fish. PFC addresses a variety of factors that are linked to water quality. Any improvement in riparian 

function (i.e., the PFC rating) would improve water quality and instream habitat condition for native nongame fish. 

In order to protect water quality resources in streams containing native non-game fish, the Idaho Stream 

Channel Alteration Rules (IDWR, 1993) would be applied to actions involving construction activities within 

the high water lines of streams in the planning area. These standards are intended to cover the ordinary 

type of stream channel alteration and to prescribe minimum conditions for approval of such construction. 
Jarbidge Proposed RMP/Final EIS Appendix D: Aquatic and Riparian Management Strategy

A

B

C

A 

B

C

A-113

For grazing management, these streams should be managed according to the management processes 

and strategies as described in Grazing Management Processes and Strategies for Riparian-Wetland 

Areas (Wyman et al., 2006). 

Management for Special Status Aquatic Species

BLM Manual 6840, Special Status Species Management, provides policy and direction, consistent with 

appropriate laws, for the conservation of special status plants, fish, and wildlife and the ecosystems on 

which they depend. The special status aquatic species in the planning area are currently managed 

according to four special status aquatic species conservation or recovery plans as well as conservation 

requirements derived through ESA consultation with the US Fish and Wildlife Service (FWS). Recovery 

plans are developed by FWS to establish recovery objectives for a species, provide a list of tasks 

necessary to achieve those objectives, and recommend assignments to involve agencies to carry out 

these tasks. A primary function of recovery plans is to combine programs of all agencies involved in 

managing a species into a coordinated management effort. The BLM may adopt recovery plans. Even if a 

recovery plan is not officially adopted, BLM Manual 6840 directs the BLM to incorporate the objectives of 

the recovery plan into appropriate land use activity plans (BLM Manual 6840.04.E.5). These plans provide 

guidance and direction for protecting special status aquatic species and their habitat to ensure their longterm survival and recovery. The conservation and recovery plans for special status aquatic species in the 

planning area are identified in Table D-9; these plans will guide the protection and conservation of 

stronghold populations. For species for which there is an existing recovery plan, such as Snake River 

snails and Bruneau hot springsnail, or for which there is a draft recovery plan, such as Jarbidge River bull 

trout, the conservation measures identified in those plans will also be incorporated in restoration and 

recovery planning efforts at the watershed or site-specific scale.

Table D-9. Conservation and Recovery Plans for Special Status Aquatic Species in the Planning 

Area

Conservation/Recovery Plan Date Species Addressed

Common Name Scientific Name

Snake River Aquatic Species 

Recovery Plan 1995

Idaho springsnail Pyrgulopsis idahoensis

Utah valvata Valvata utahensis

Snake River physa snail Physa natricina

Bliss Rapids snail Taylorconcha serpenticola

California floater Anodonta californiensis

Columbia pebblesnail Fluminicola columbianus

Shoshone sculpin Cottus greenei

Redband trout Oncorhynchus mykiss 

gairdeneri

Snake River white sturgeon Acipenser transmontanus

Snake River White Sturgeon 

Conservation Plan 2003 Snake River white sturgeon Acipenser transmontanus

Recovery Plan for the Jarbidge 

River Distinct Population 

Segment of Bull Trout (Draft)

2004 Jarbidge River bull trout Salvelinus confluentus

Recovery Plan for the Bruneau 

Hot Springsnail 2006 Bruneau hot springsnail Pyrgulopsis bruneauensis

Idaho springsnail was removed from the Endangered Species list in September 2007.

Utah Valvata was removed from the Endangered Species list in August 2010. 

The recovery plan for the Jarbidge River Distinct Population Segment of Bull Trout has not been finalized by FWS.

Additional management for ESA-listed aquatic species include conservation requirements derived 

through ESA consultation with FWS; these requirements are intended to allow for activities to occur at 

levels that would not result in a decline in the ESA-listed species or their habitat. These conservation 

requirements are contained in Biological Opinions as well as Biological Assessments with letters of 

concurrence. Table D-10 displays those consultation documents currently in effect; these may be 
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superseded through future consultation with the FWS. The conservation measures as derived through 

ESA consultation with the FWS are displayed in Appendix E.

Table D-10. FWS Biological Opinions and Letters of Concurrence for ESA-Listed Aquatic Species 

in the Planning Area

Document Name Date Species Addressed Action(s) Addressed

Letter of Concurrence – BLM 

Twin Falls District 

Programmatic Emergency 

Stabilization and Rehabilitation 

Plan – Blaine, Cassia, Camas, 

Elmore, Gooding, Jerome, 

Lincoln, Minidoka, Oneida, 

Owyhee, Power, and Twin 

Falls Counties, Idaho and Elko 

County, Nevada.

May 10, 2013

Bull trout and 

Designated Critical 

Habitat, 

Bliss Rapids snail, 

Snake River physa 

snail, and

Bruneau hot 

springsnail. 

Post wildland fire 

rehabilitation and 

emergency stabilization 

actions. 

Biological Opinion - Bureau of 

Land Management Ongoing 

Actions and Livestock Trailing 

– Bull Trout Critical Habitat – 

Benewah, Bonner, Boundary, 

Kootenai, Owyhee, and 

Shoshone Counties, Idaho and 

Elko County, Nevada

November 2, 2012

Bull trout and 

Designated Critical 

Habitat. 

RMP amended by 

INFISH, ongoing wildfire 

suppression, livestock 

grazing, and livestock 

trailing.

Biological Opinion – 

Restoration Activities at 

Stream Crossings (Stream 

Crossing Programmatic).

June 15, 2012.

Bull trout and 

Designated Critical 

Habitat.

Stream crossing 

replacements (culverts 

and bridges) and

maintenance, road and 

trail decommissioning.

Letter of Concurrence – Idaho 

BLM Ongoing Actions (Bull 

Trout Critical Habitat). 

May 25, 2011 Bull trout Critical 

Habitat. 

Ongoing livestock 

grazing, irrigation 

diversion, normal 

wildfire rehabilitation 

plan, noxious weeds

treatments, recreational 

special use permits, 

rights-of-way, and 

juniper thinning.

Biological Opinion – Existing 

BLM Land Use Plans March 10, 2008

Bliss Rapids snail, 

Snake River physa 

snail, and

Bruneau hot 

springsnail. 

1987 Jarbidge 

Resource Management 

Plan. 

Letter of Concurrence – 

Noxious and Invasive Weed 

Treatment Program for the 

Boise District and the Jarbidge 

Field Office of the Twin Falls 

District 

September 21, 

2005

Bull trout, 

Bliss Rapids snail, 

Snake River physa 

snail, and

Bruneau hot 

springsnail. 

Noxious weed and 

invasive plant 

treatments.

Biological Opinion – Biological 

Assessment of the BLM Boise 

District and the Jarbidge Field 

Office of the Twin Falls District, 

Ongoing Permitted Grazing 

Activities in 36 Allotments

August 15, 2005

Bliss Rapids snail and

Snake River physa 

snail. 

Livestock grazing on 

allotments in the Snake 

River watershed. 
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Document Name Date Species Addressed Action(s) Addressed

Biological Opinion – Ongoing 

Grazing Activities in the 

Bruneau Arm Allotment, the 

Hagerman Allotment, and Flat 

Iron Allotment, Owyhee 

County, Idaho

March 23, 2005 

Bliss Rapids snail and

Snake River physa 

snail. 

Livestock grazing in the 

named allotments. 

Biological Opinion on BLM’s 

Ongoing Activities in the 

Jarbidge River Watershed in 

Owyhee County, Idaho, and 

Elko County, Nevada

November 17, 2004 Bull trout

Livestock grazing, 

pipelines, and fire 

suppression in the 

Jarbidge River 

Watershed. 

Letter of Concurrence – 

Allocation of Forage in the 71 

Desert, Blackrock Pocket, 

Bruneau Hill, Crawfish, North 

Fork, and Winter Camp 

Allotments for the Jarbidge 

Field Office

November 12, 2004 Bull trout Forage allocation in 

named allotments. 

Letter of Concurrence – 

Excess Forage Allocation and 

Grazing Permit Renewal for 

the Yahoo Allotment, Twin 

Falls County, Idaho

April 13, 2004

Bull trout, 

Bliss Rapids snail, 

Snake River physa 

snail, and

Bruneau hot 

springsnail. 

Forage allocation and 

permit renewal in the 

Yahoo allotment. 

Multi-Scale Assessments and Ecosystem Analysis at the 

Watershed Scale

This section addresses material for Component III, Multi-Scale Analysis, in the Guidance for Developing Aquatic 

Conservation Strategies (BLM, 2008a). 

Multi-Scale Assessments

Generally, no single assessment will adequately address the complex issues facing resource managers 

today. Fine-scale assessments provide context for management and project planning, but they cannot 

adequately address broad patterns and processes, such as habitat conditions for wide-ranging species. 

Broad-scale assessments provide context for policy formulation and for mid- and fine-scale assessment, 

but they cannot by themselves provide detailed information, such as site-specific habitat conditions. 

Together, multi-scale assessments provide comprehensive information for land management.

Multiple scales of review and assessment provide the context to implement broad-scale decisions within 

individual BLM District and Field Offices. As needed, multi-scale analysis may be used for future plan 

amendments or revisions and for subsequent project-level decisions. Analysis at the appropriate scale is 

generally recognized to provide the needed context for decision making. The four levels of review or 

assessment that may be used for multi-scale analysis are: 

Broad-scale (e.g., analysis at the basin scale, such as the Interior Columbia River Basin); 

Mid-scale (e.g., analysis at the subbasin scale, such as the Snake River subbasin); 

Fine-scale (e.g., analysis at the watershed scale, such as the Salmon Falls Creek Watershed); and

Site-scale (e.g., analysis at the stream reach or project scale, such as China Creek). 
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Management considerations for multi-scale analysis include the following:

Land Use Plans are generally developed and analyzed at the scale of the land management unit, 

normally analogous to a subbasin (or group of subbasins) scale.

Subsequent finer-scale analysis, such as to support restoration prioritization and monitoring strategy 

development, should include interagency coordination. 

Assessments should include evaluation of existing conditions, factors limiting aquatic species 

populations, resource risks, management needs, and restoration opportunities.

Information developed at the finer scale should be considered in implementing aquatic conservation 

or restoration measures and used to make adjustments or modifications to appropriate management 

actions, as warranted. 

Multi-scale analysis provides a basis for integrating and prioritizing conservation measures for wideranging species.

Watershed Analysis

The purpose of an ecosystem analysis at the watershed scale is to develop and document an 

understanding of the ecological structures, functions, processes, and interactions occurring at the 

watershed scale by systematically characterizing the watershed’s human, aquatic, riparian, and terrestrial 

features, conditions, processes, and interactions. This process is designed to describe past and current 

conditions and develop restoration and management recommendations. The ultimate goal is to provide 

guidance for management activities that would sustain or improve the health and productivity of natural 

resources.

Objectives of Watershed Analysis

The following are the objectives of a watershed analysis:

Provide sufficient watershed context for understanding and carrying out land use activities in 

a geomorphic context – Watershed analysis is an important tool used to meet ecosystem 

management objectives at larger scales. 

Evaluate cumulative watershed effects – Watershed analysis enhances the ability to estimate 

direct, indirect, and cumulative effects of management activities.

Define watershed restoration needs, goals, and objectives – Watershed analysis provides 

guidance on the general type, location, and sequence of appropriate activities within a watershed.

Monitor the effectiveness of watershed protection measures – Watershed analysis provides an 

iterative process for the adaptive management feedback loop.

Methodology for Watershed Analysis

The Federal Guide for Watershed Analysis-Ecosystem Analysis at the Watershed Scale, Version 2.2

(Regional Interagency Executive Committee and Intergovernmental Advisory Committee, 1995) was used 

as a guide; the process outlined in this guide provides resource managers with the flexibility to focus 

watershed analysis as necessary to meet management objectives. This six-step process is issue-driven; it 

focuses on analysis topics, along with specific watershed problems and concerns. Management 

discretion applies to defining the number and scope of topics and concerns to be analyzed, illustrating 

that “...It should be emphasized that watershed analyses can be a very simple and straightforward 

process taking a few days or weeks to develop or a complicated process. The complexity is intertwined 

with the issues and questions being addressed” (BLM Instruction Memorandum OR-2007-071). This 

analysis is not a decision-making process but helps identify opportunities for future management 

activities, including planning, project development, and regulatory compliance. The six-step process may 

also be used to guide analysis at the reach scale, including modification of Riparian Conservation Area 

(RCA) widths. Below is a summary of each of the six steps taken to develop an ecosystem analysis at the 

watershed scale.

Step 1 - Characterize the Watershed

The purpose of Step 1 is to identify the dominant physical, biological, and human processes or features of 

the watershed that affect ecosystem functions or conditions, including the relationship between these 
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ecosystem elements and those occurring in the river basin and/or watersheds. When characterizing the 

watershed, team members identify the most important land allocations, plan objectives, and regulatory 

constraints that influence resource management in the watershed. At the reach scale, the RCA and 

stream are characterized, including aquatic and riparian habitats, channel type, valley type, and stream 

gradient.

Step 2 - Identify Issues and Key Questions

The purpose of Step 2 is to focus the analysis on the key elements of the ecosystem that are most 

relevant to the management questions and objectives, human values, or resource conditions within the 

watershed. Key analysis questions are formulated from instream and riparian indicators used to measure 

or interpret key ecosystem elements. At the reach scale, the issue(s) are described, including which 

instream and riparian indicators are affected by the proposed or past management action(s). 

Step 3 - Describe Current Conditions

The purpose of Step 3 is to develop more detailed information relevant to the issues and key questions 

identified in Step 2. Step 3 is where the current range, distribution, and condition of the relevant 

ecosystem elements are documented. At the reach scale, this section describes the current condition of 

the RCA and may include a discussion of riparian function using proper functioning condition and 

quantitative stream and riparian condition assessments such as multiple indicator monitoring (Burton et 

al., 2011). 

Step 4 - Describe Reference Conditions

Step 4 explains how ecological conditions have changed over time with respect to historic or reference 

conditions as a result of human influence and natural disturbances. At the reach scale, if an undisturbed 

reference reach similar in channel, valley, and vegetation type is available, current conditions are 

measured to establish reference conditions for future comparison. This section establishes objectives for 

the desired future condition.

Step 5 - Synthesize and Interpret Information

The purpose of Step 5 is to compare existing and reference conditions of specific ecosystem elements 

and to explain significant differences, similarities, or trends and their causes. The capability of the system 

to achieve key management plan objectives is also evaluated.

Step 6 - Identify Recommendations

The purpose of Step 6 is to bring the results of the previous steps to conclusion by addressing each of the 

issues and answering the key questions, focusing on recommendations that are responsive to watershed 

or reach-scale processes identified in the analysis. Step 6 identifies recommendations that address 

resource problems noted in this analysis in order to change the current watershed or reach conditions 

toward the desired future condition. Monitoring needs and data gaps are also identified and described.

Watershed Analysis for the Jarbidge Planning Area 

BLM-managed lands in the planning area include large, contiguous blocks of public land interspersed with 

State lands, private lands, and two military withdrawal areas. Portions of the planning area are located in 

northern Nevada and are adjacent to land managed by the Humboldt-Toiyabe National Forest and other 

BLM Field Offices; these lands include the upper reaches of the Jarbidge River and its East Fork, the 

Bruneau River, and several headwater reaches of perennial streams in the Jarbidge Foothills. For 

analyses of these watersheds, the BLM Jarbidge Field Office will collaborate with the Forest Service and 

other BLM FOs to complete watershed analyses and subbasin assessments or updates, as appropriate. 

The level of site-specific or focused analysis will be commensurate with the scope, magnitude, and issues 

related to BLM activities or projects and related aquatic resources and values.

The BLM and Forest Service have completed two watershed analyses within the planning area; the

Jarbidge Ranger District of the Humboldt-Toiyabe National Forest was the lead agency for both of these 

analyses. The Jarbidge Canyon Watershed Analysis (McNeill et al., 1997) included the upper West Fork 

of the Jarbidge River on USFS managed lands. The Watershed Analysis for the East Fork Jarbidge River
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(USDA, 2004) encompassed the East Fork Jarbidge River watershed above the confluence of Dave 

Creek and included a small portion of BLM managed land (3,640 acres). Both of these documents 

provide guidance for cumulative effects analysis, prioritization for restoration and management actions, 

and direction and information for landscape and ecosystem management in the Jarbidge Watershed.

Although no other watershed analyses have been completed in the planning area using the six-step 

process in the Federal Guide for Watershed Analysis, there have been several other multi-scale reviews 

that assessed aquatic resources in the planning area (Table D-10). Through these broad-scale (FWS, 

1995) and mid-scale (FWS, 1998, 2002; Idaho Power Company, 2005) analyses, habitat was 

characterized, issues affecting the species were identified, current and reference conditions were 

described, and data were used to identify changes to reduce threats to the ESA-listed and BLM Sensitive 

aquatic species in the planning area. The ARMS, which uses site-specific data to identify conservation 

and restoration priorities, provides the framework for a fine-scale assessment for the planning area. 

Future watershed analysis in the planning area may be completed depending on the intensity, scope, or 

scale of issues that drive the need for additional fine-scale assessments. 

Monitoring and Adaptive Management

This section addresses material for Component V, Management Direction – Adaptive Management, related to 

adaptive management and Component VI, Monitoring, Adaptive Management, and Oversight, in the Guidance for 

Developing Aquatic Conservation Strategies (BLM, 2008a). 

Monitoring

Monitoring provides a mechanism for observation and measurement to ensure that project design criteria 

and mitigation are being implemented and to determine if project and program goals and objectives are 

being achieved. The basics of plan-level monitoring should: 

 Determine if the plan, project, or activity is being implemented correctly and is achieving desired 

results; 

 Provide a mechanism for accountability and oversight; 

 Evaluate the effectiveness of recovery and restoration efforts; and 

 Provide a feedback loop so that management direction may be evaluated and modified (i.e., adaptive 

management). 

Implementation monitoring is used to determine if management practices are implemented as identified in 

an activity plan, Environmental Assessment (EA), EIS, Biological Assessment (BA) with a letter of 

concurrence, or Biological Opinion (BO). Effectiveness monitoring is used to determine if management 

practices, as designed and executed, are effective in meeting project goals and objectives as defined in 

an activity plan, EA, EIS, BA with a letter of concurrence, or BO. 

The results of monitoring will be summarized and shared, as requested, with the tribes and Federal and 

State agencies. Management considerations for monitoring include the following:

Monitoring should be focused on key questions that inform decision making and allow timely 

adjustments to management. 

Monitoring emphasis and intensity should be commensurate with the importance of the question 

being asked. For example, if adaptive management is being used, it is important to monitor the key 

parameters to the degree necessary to support the current course of action or to trigger an alternate 

approach.

Plan-level monitoring should make use of and not duplicate broad-scale monitoring programs. To the 

extent practicable, monitoring done at the plan scale should be compatible with and complementary 

to broader- and finer-scale monitoring.

Monitoring should be coordinated with and, where possible, consolidated with similar efforts of other 

agencies.

Outcome-based management approaches rely on monitoring for their success. These approaches 

typically require a different level and type of monitoring than prescriptive approaches.
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• Monitoring commitments in plans should be feasible and achievable.

The implementation and effectiveness monitoring protocols will be in accordance with appropriate BLM 

Technical Bulletins or other acceptable monitoring methods that would address the bull trout and redband 

trout habitat condition indicators in Table D-1 and Table D-2. 

Adaptive Management

The ARMS allows for adaptive management, a continuing process of planning, implementation, 

monitoring, and evaluation to adjust management to meet goals and objectives of ecosystem-based 

management. Adaptive Management is a decision process that promotes decision making in the face of 

uncertainty as outcomes from management activities become better understood. The approach improves 

resource management by learning from prior management outcomes. The process of adaptive 

management uses the latest scientific information, site-specific information and monitoring data, and 

professional judgment to select the management strategy most likely to meet goals and objectives. By 

continually adjusting management strategies as needed, supported by monitoring or additional 

information, adaptive management will result in achievement of short- and long-term trends toward 

meeting objectives. Adaptive management provides the capability to respond quickly to monitoring data 

with consideration given to past season monitoring or preseason conditions. It also allows changes 

needed to meet long-term objectives of the RMP including direction from ESA, the Clean Water Act, and 

Fundamentals for Rangeland Health. The USDI guidance on using adaptive management can be found in 

Williams and others (2009). 

Adaptive management requires knowledge of the current conditions, potential or capability of riparian 

sites and streams, current management and effects of the management on the resources, and 

management changes that may be made to move the current condition toward the desired condition. 

Single indicators of conditions or trend are usually not adequate to make good decisions. Information on 

the condition and trend of the vegetation, streambanks, and aquatic resources and knowledge of current 

management practices can help establish cause-and-effect relationships that are important for making 

appropriate decisions. Such information allows refinement and development of locally-derived project or 

activity design standards or criteria. 
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Maps

Map D-1. Bear Creek, Rocky Canyon Creek, Shack Creek, and Timber Canyon Creek Reaches
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Map D-2. Buck Creek, Deer Creek (NV), Jack Creek, Jarbidge River, and West Fork Jarbidge River 

Reaches. 
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Map D-3. Cedar Creek Reaches
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Map D-4. House Creek, Chimney Creek, and Little House Creek Reaches
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Map D-5. China Creek Reaches
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Map D-6. Dave Creek and East Fork Jarbidge River Reaches
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Map D-7. Deadwood Creek, East Fork Deadwood Creek, and West Fork Deadwood Creek Reaches
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Map D-8. Deer Creek and Three Creek Reaches
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Map D-9. Flat Creek and Pole Creek Reaches
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APPENDIX E: CONSERVATION MEASURES

The BLM Manual for Special Status Species Management (Section 6840) provides policy and guidance 

for the conservation of special status species, plants and animals, and the ecosystems upon which they 

depend on BLM-managed lands. 

The following tables identify conservation measures to bring the species and their habitat to the condition 

under which the provisions of the Endangered Species Act (ESA) are not necessary, current listings 

under special status species categories are no longer needed, and future listings under special status 

species categories would not be necessary. The sources of these conservation measures (i.e. land use 

plan consultations or existing species recovery plans) are identified.

The following comprise the conservation plans, strategies, and agreements in place for species in the 

planning area. This list will be updated as new plans, strategies, and agreements are adopted and 

existing plans, strategies, and agreements become obsolete, expire, or are replaced. 

The BLM intends that the species-specific conservation measures included in the documents identified 

below will be implemented. While a high priority for BLM, both the BLM and US Fish and Wildlife Service 

(FWS) recognize that funding constraints may affect the ability to implement specific conservation 

measures as planned. Where funding is lacking, BLM and FWS will cooperate to set priorities and 

timelines for accomplishing recovery objectives for listed, proposed, and candidate species.

Conservation Agreements

Conservation Agreement between BLM Idaho State Office and the US Fish and Wildlife Service 

Snake River Fish and Wildlife Office. Janaury 2014 – The purpose of the Conservation Agreement 

is to provide for the conservation of slickspot peppergrass related to existing Idaho BLM land use 

plans and a subset of ongoing actions. 

Conservation Agreement for Bureau of Land Management – Idaho State Office, US Fish and 

Wildlife Service – Snake River Basin and Spokane Field Offices: Idaho Bureau of Land 

Management Existing Land Use Plans Consultation. Signed by Idaho BLM State Director. 

December 2005 – This Conservation Agreement is intended to promote the conservation of Listed, 

Proposed, and Candidate species that have not previously undergone land use plan-level 

consultation under the ESA.

Candidate Conservation Agreement for Slickspot Peppergrass (Lepidium papilliferum). 2006. 

Governor’s Office of Species Conservation, et al. 158 pp. – The purpose of this Candidate 

Conservation Agreement is to expedite implementation of conservation measures for slickspot 

peppergrass in Idaho. Threats that warrant listing should be significantly reduced, mitigated, or 

eliminated through implementation of this Candidate Conservation Agreement, and additional 

measures to enhance slickspot peppergrass occurrences and habitat are provided for.

Memoranda of Understanding

Interagency Memorandum of Understanding to Implement the Interior Columbia Basin 

Strategy. November 2002 – This Memorandum of Understanding (MOU) provides guidance to all 

BLM offices to implement the Interior Columbia Basin Strategy to ensure an ecosystem-based 

process is used in resource management plan (RMP) revisions within the Columbia River Basin (IBID-2003-062). 

Memorandum of Understanding to Support and Implement to the Extent Practicable and 

Where Appropriate the Intent and Actions Contained in the 2006 Conservation Plan for the 

Greater Sage-grouse in Idaho. July 2006 – This MOU was signed by Idaho Department of Fish and 

Game, Idaho Department of Lands, Idaho State Department of Agriculture, Office of Species 

Conservation, Idaho BLM, United States Forest Service Region 4, Animal and Plant Health Inspection 

Service-Wildlife Service, and Natural Resource Conservation Service to support and implement the 

sage-grouse conservation plan. This candidate species is not addressed under Section 7 consultation 

but is covered under this MOU between the BLM and FWS.
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Memoranda of Agreement

Memorandum of Agreement for Endangered Species Act Section 7 Programmatic 

Consultation and Coordination among Bureau of Land Management, Forest Service, National 

Marine Fisheries Service, and US Fish and Wildlife Service. August 30, 2000 – This agreement 

outlines consultation procedures for the BLM and other Federal agencies.

Conservation Strategies

Interior Columbia Basin Strategy. 2002. A Strategy for Applying the Knowledge gained by the 

Interior Columbia Basin Ecosystem Management Project to the Revision of Forest and 

Resource Management Plans and Project Implementation. Included as Attachment 1 in Bureau 

of Land Management IB No. ID-2003-062. 11 pp. – The strategy will be used to guide the 

amendment and revision of this land and resource management plan. The Strategy includes 

guidance for terrestrial and aquatic ecosystems and to use multi-scale analysis in resource 

management planning. It also identified emphasis areas for preparing an Aquatic Conservation 

Strategy as a component of the RMP. An Aquatic Conservation Strategy was incorporated into the

Jarbidge RMP and Final EIS (see Appendix D).

National Sage-Grouse Habitat Conservation Strategy. 2004. Prepared by the Bureau of Land 

Management. 25 pp. – This strategy sets goals and objectives, assembles guidance and resource 

materials, and provides comprehensive management direction for the BLM’s contributions to the ongoing multi-state greater sage-grouse conservation effort. 

Recovery Plans

Snake River Aquatic Species Recovery Plan. 1995. US Fish and Wildlife Service, Snake River 

Basin Office, Ecological Services, Boise, Idaho. 92 pp. – The recovery plan includes short- and 

long-term objectives to protect known live colonies of Federally listed snails, as well as redband trout, 

Snake River white sturgeon, and Shoshone sculpin, by eliminating or reducing known threats to these 

species and their habitat. 

Recovery Plan for the Bruneau Hot Springsnail (Pyrgulopsis bruneauensis). 2002. US Fish and 

Wildlife Service, Region 1, Portland, Oregon. 52 pp. – The primary objective of the recovery plan 

is to recover the species to a point where listing is no longer warranted by implementing groundwater 

management activities and monitoring species recovery. 

Draft Recovery Plan for the Jarbidge River Distinct Population Segment of Bull Trout 

(Salvelinus confluentus). 2004. US Fish and Wildlife Service, Portland, Oregon. – The primary 

objective of the plan is to reduce threats to bull trout and their habitat and to increase population 

numbers to habitat potential.
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Conservation Measures 

Slickspot Peppergrass

Table E-1. Conservation Measures for Slickspot Peppergrass.

Conservation Measures BLM Implementation Actions

Special Status Animal and Plant Management: Common to All Programs

The conservation measures contained throughout 

this table implement important elements included in 

the Candidate Conservation Agreement for 

slickspot peppergrass. The conservation measures 

reflect BLM’s commitment to support species 

conservation.

The implementation actions reflect BLM’s 

commitment to support species conservation and 

meet ESA objectives. Actions apply to BLM 

managed lands and activities only and will be 

implemented as staffing and funds allow.

Special Status Animal and Plant Management: Common to All Programs

Special Status Animal and Plant Management conservation measures for slickspot peppergrass apply to all program 

areas listed below.

1) In cooperation with Idaho Department of Fish 

and Game, Idaho Natural Heritage Program

(INHP), US Fish and Wildlife Service (FWS), Idaho 

Army National Guard (IDARNG), the US Air Force, 

and others:

1) Following actions to be completed in 

cooperation with others: 

a) Use survey protocols consistent with the FWS

Rare Plant Survey Guidelines to conduct Stage 

1, 2, and 3 surveys (see Figure E-2 at the end 

of this table for the general survey process).

a) Apply current survey methods, and assure that 

inventories are done at the appropriate time of 

the year by qualified botanists or by persons 

who are under the guidance of qualified 

botanists.

b) Cooperate to refine slickspot peppergrass 

habitat and potential habitat maps (Stage 1 

survey, Figure E-2), and to identify and map 

slickspot peppergrass occurrences (Stage 2 

survey, Figure E-2).

b) Surveys, mapping, and data management 

(refer to Figure E-2, Survey Flowchart for 

Slickspot Peppergrass):

i). Cooperate with CDC and FWS to record, 

refine, and map all habitat features 

including potential habitat, slickspot 

peppergrass habitat, non-habitat, occupied 

habitat, and element occurrences (EOs) on

BLM-managed lands. Use current 

geographic information system standards 

for mapping and database management. In 

cooperation with CDC, maintain a spatial 

database of species population and habitat 

information for BLM-managed lands.

ii). BLM will continue to conduct Stage 1 and 2 

surveys, report survey information to the 

CDC, and incorporate the information into 

the adaptive management strategy.

iii). BLM’s intent will be to conduct Stage 1 

surveys (slickspot survey) for at least 

25,000 acres of potential habitat averaged 

over 10 years. BLM will work 

collaboratively with FWS to prioritize 

surveys during the first 5 years to areas 

that have a high likelihood of species 

occurrence, or that are needed for BLM 
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Conservation Measures BLM Implementation Actions

project purposes. BLM will also target at 

least 10,000 acres of Stage 2 surveys 

(slickspot peppergrass plant surveys) that 

can be done concurrently with the Stage 1 

surveys. The amount of habitat to be 

surveyed each year will be based on 

available annual funding. Stage 3 plant 

surveys will be conducted as necessary 

and desired. 

iv). Prioritize Stage 1 and 2 surveys to address 

slickspot peppergrass habitat with a high 

likelihood of species occurrence. Surveys 

should be scheduled to complement other 

program needs.

c) Cooperate in regular monitoring of slickspot 

peppergrass population trends and land health 

conditions on BLM-managed lands, and follow 

current monitoring protocols. Land health 

conditions include forb diversity to support 

pollinators and habitat for slickspot 

peppergrass.

c) Follow the Habitat Integrity and Population 

(HIP) monitoring protocol or other accepted 

monitoring methodology. BLM will cooperate 

with others to conduct annual monitoring within 

all EOs on BLM-managed lands to assess the 

effectiveness of the conservation measures as 

part of the adaptive management strategy.

i). Establish permanent ecological reference 

areas (ERAs) in selected EOs to evaluate 

land health conditions associated with 

slickspot peppergrass. 

ii). Use data from the ERAs to assist in 

completing land health assessments. This 

information will be used to evaluate 

permitted management actions and to 

design restoration projects for slickspot 

peppergrass.

d) Participate in research essential to 

conservation of the species.

d) BLM will participate in research as funding 

allows. Areas to focus on include, but are not 

limited to, the following: 

i). Elimination and control of invasive species. 

ii). Pollination, forb restoration, and effects of 

ground disturbance on the species. 

iii). Determination of specific limiting factors in 

terms of habitat needs and characteristics. 

iv). Population viability analyses.

e) Continue to support seed banks in a long-term 

seed storage facility.

e) As needed, make seed available to a suitable 

repository to support a seed bank.

f) Support the establishment and maintenance of 

new populations in habitat categories for 

slickspot peppergrass. The goal of these 

activities is to maintain or enhance viable 

populations.

f) Reintroduce slickspot peppergrass at selected 

experimental reintroduction or historic sites as 

funding allows.

2) Ensure that ongoing Federal actions support or 

do not preclude species conservation in habitat 

categories for slickspot peppergrass. 

2) Ongoing BLM authorized activities:

a) Based on the results of Stage 1 and 2 surveys, 

review ongoing activities in s habitat categories 
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Conservation Measures BLM Implementation Actions

for slickspot peppergrass. The Level 1 Team 

will conduct these reviews in a manner 

consistent with streamlining procedures where 

local section 7 compliance activities with FWS

(if necessary) have not yet been completed.

b) If reviews indicate that direct or indirect 

negative impacts to the species or its habitat 

are occurring as a result of ongoing 

discretionary BLM actions, the activity will be 

modified to avoid or minimize anticipated 

negative impacts and, where feasible, promote 

species conservation.

c) Where habitat categories for slickspot 

peppergrass exist, BLM will conserve 

remaining stands of sagebrush and native 

vegetation in making activity plan and projectlevel decisions.

3) Ensure that new Federal actions support or do 

not preclude species conservation in habitat 

categories for slickspot peppergrass. 

3) New proposed BLM authorized activities:

a) Consistent with streamlining procedures, BLM 

will require project-level inventories for any 

project in slickspot peppergrass habitat and in 

potential habitat during project planning if 

inventory information is not available or 

adequate. BLM will use the protocols described 

in (1) (a).

b) If direct or indirect negative impacts to the 

species or its habitat are anticipated as a result 

of new BLM actions, the activity will be 

modified to avoid or minimize negative impacts 

and, where feasible, promote species 

conservation.

c) Where needed, complete section 7 compliance 

for new activities that may affect this species 

and its habitat.

d) Where slickspot peppergrass habitat exists, 

BLM will conserve remaining stands of 

sagebrush and native vegetation in making 

activity plan and project-level decisions.

4) Implement adaptive management as needed to 

achieve conservation objectives.

4) Conduct site-specific implementation and 

effectiveness monitoring of management actions. 

Adjust management as needed to ensure that 

objectives are met. See additional details within 

other programs.

5) Support programs to conserve and enhance 

slickspot peppergrass on non-Federal lands.

5) Take advantage of opportunities to support 

conservation of slickspot peppergrass through 

easements, cooperative management efforts, and 

other programs.

6) Include language in all land use authorizations to 

require rehabilitation of s habitat categories for 

slickspot peppergrass in case of trespass or permit 

violations, if damage occurs.

6) As a part of management authorizations, require 

rehabilitation to native vegetation in habitat 

categories for slickspot peppergrass if trespass or 

permit violation occurs and the habitat is damaged. 
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Conservation Measures BLM Implementation Actions

If ecological site conditions preclude the use of 

native species, use non-invasive, non-native plant 

species for rehabilitation in trespass or permit 

violation situations.

Air Resources

None None

Soil Resources, Water Resources, and Riparian Areas and Wetlands 

None None

Upland Vegetation (includes noxious weed management)

1) Although non-chemical methods will be the 

preferred approach in occupied habitat, when 

appropriate, projects involving the application of 

pesticides (including herbicides, fungicides, and 

other related chemicals) in slickspot peppergrass 

habitat and potential habitat that may affect the 

species will be analyzed at the project level and 

designed such that pesticide applications will 

support conservation and minimize risks of 

exposure.

1) Site-specific stipulations will be developed 

locally using these criteria: 

a) Evaluate the benefits and risks of vegetation 

treatment including the following: application 

methods; pesticides, carriers, and surfactants 

used; needed treatment buffers; and use of 

non-chemical noxious weed control (for 

example, bio-controls, hand pulling). 

b) Apply appropriate spatial and temporal buffers 

to avoid species’ exposure to harmful 

chemicals.

c) Explore opportunities to eradicate competing 

non-native invasive plants in occupied habitat 

where slickspots are being invaded by such 

plants.

d) Implement revegetation and noxious weed 

control measures to reduce the risks of nonnative invasive plant infestations following 

ground/soil disturbing actions in slickspot 

peppergrass habitat.

e) BLM will provide the US Department of 

Agriculture Animal and Plant Health Inspection 

Service with the location of habitat categories 

for slickspot peppergrass. Mormon cricket, 

grasshopper, or other insect control in habitat 

categories for slickspot peppergrass will only 

include those methods that minimize impacts 

to the plant’s pollinators.

2) Where needed and feasible, coordinate with 

adjacent land owners and local governments 

regarding control of invasive plants in upland areas 

through cooperative weed management programs. 

One of BLM’s priorities within the cooperative weed 

management program is the protection of special 

status plants on BLM-managed lands.

2) Take advantage of coordination opportunities as 

they arise.

3) BLM will promote diversity, richness, and health 

of native plant communities to support pollinators 

and habitat for slickspot peppergrass.

3) BLM will focus slickspot peppergrass habitat 

conservation and restoration efforts in or adjacent 

to occupied habitat to encourage connectivity 

among populations through the following 

measures:

a) Where habitat categories for slickspot 

peppergrass exist, BLM will conserve 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

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Conservation Measures BLM Implementation Actions

remaining stands of sagebrush and native 

vegetation in making activity plan and projectlevel decisions. 

b) Vegetation treatment projects undertaken in 

habitat categories for slickspot peppergrass will 

be compatible with species habitat restoration 

objectives, as described in item (d) below. 

c) BLM will select and implement specific projects 

to restore habitat categories for slickspot 

peppergrass in degraded areas as funding 

allows, such as planting shrubs and forbs and 

controlling noxious weeds, within and adjacent 

to occupied habitat. Apply methods described 

in item (d) below.

d) When conducting vegetation treatment 

projects, BLM will use seeding techniques that 

minimize soil disturbance such as minimum-till 

drills and rangeland drills equipped with depth 

bands, use native plant materials and seed 

during restoration activities, and select native 

forbs that benefit slickspot peppergrass insect 

pollinators.

Forest and Woodland Management 

None None

Wildlife 

1) Manage facilities installed for wildlife to promote 

maintenance of habitat categories for slickspot 

peppergrass. 

1) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). For new actions, see Special 

Status Animal and Plant Management program 

section item (3). As appropriate to avoid or 

minimize negative impacts, modify existing and 

avoid placement of new wildlife facilities in 

occupied habitat.

2) Restore wildlife habitat while promoting slickspot 

peppergrass conservation.

2) Any restoration efforts for wildlife within habitat 

categories for slickspot peppergrass will be 

compatible with the species’ habitat requirements.

Fish and Aquatic Habitat 

None None

Livestock Grazing: Permits and Leases

1) Manage livestock grazing and trailing to 

conserve suitable habitat conditions for slickspot 

peppergrass while implementing rangeland health 

standards and guidelines. Apply the 

Implementation of Annual Grazing Adaptive 

Management (Figure E-1), located at the end of 

this conservation measures table, to adjust 

livestock use as appropriate.

1) Permit or lease renewal actions and annual 

authorizations:

a) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). 

b) Schedule surveys in habitat categories for 

slickspot peppergrass as needed for rangeland 

health assessments associated with permit and 

lease renewals. Surveys will be prioritized for 

habitat with a medium to high potential for 

species occurrence. Unsurveyed habitat with a 

low potential for species occurrence will be 

treated as unoccupied by slickspot 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

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Conservation Measures BLM Implementation Actions

peppergrass until surveys can be completed. 

The BLM Slickspot Peppergrass Occurance 

Potential Map will be used to determine 

potential for occurance within the Jarbidge 

planning area. Use survey procedures and 

flowchart (Figure E-1, Implementation of 

Annual Grazing Adaptive Management)

referenced in Special Status Animal and Plant 

Management program section 1(b).

c) For new actions, see Special Status Animal 

and Plant Management program section item 

(3). 

d) As part of adaptive management to avoid or 

minimize negative impacts, modify livestock 

grazing activities as outlined in Figure E-1, 

Implementation of Annual Grazing Adaptive 

Management, located at the end of this 

conservation measures table. In addition, the 

following measures will be implemented, as 

appropriate:

i). As part of range readiness assessments, 

delay livestock turnout when soils are 

saturated.

ii). Minimize gathering livestock in EOs.

iii). Avoid impacts to EOs from heard 

movementthrough rested and deferred 

pastures.

iv). Trailing permits will not be authorized 

through EOs.

v). Sheep grazing permits will be modified to 

restrict bedding, trailing or watering herds 

within 1⁄2 mile of EOs.

vi). Supplements will be placed at least 1⁄2 mile 

from EOs. Supplements will be placed so 

that livestock will be drawn away from the 

EO and avoid traveling through the EO en 

route to the supplement or water source. 

Management requirments will be adjusted 

to maintain an appropriate distance 

between supplements and existing EOs to 

avoid impacts.

vii). No new domestic horse AUMs will be 

authorizedin pastures containing EOs to 

avoid trampling impacts.

2) As part of adaptive management, BLM will 

conduct scheduled compliance inspections in 

pastures with occupied habitat as part of BLM 

range use supervision to minimize impacts.

2) BLM, in coordination with the FWS, will create a 

schedule to prioritize compliance inspections 

associated with livestock grazing permits in 

occupied habitat areas. These compliance 

inspections are a complement to the HIP 

monitoring listed under Special Status Animal and 

Plant Management and where practical the efforts 

may be combined. BLM staff will conduct 

inspections as determined by the schedule.
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Conservation Measures BLM Implementation Actions

a) BLM range staff will conduct pre-season range 

readiness checks for soil moisture conditions in 

allotments with occupied habitat. 

b) BLM will conduct post-use monitoring for 

trampling in slickspots within EOs (could be 

done in conjunction with utilization compliance 

checks). 

c) Monitoring results will be documented in a 

standard format (to be developed by BLM) in 

the grazing allotment files. Copies will be 

provided to the FWS as completed. 

d) Apply Grazing Adaptive Management 

Implementation Flowchart, Figure E-1.

3) Provide adequate rest from livestock use for 

areas treated after major disturbances in habitat 

categories for slickspot peppergrass. Major 

disturbances include fire, fire rehabilitation, or other 

soil-disturbing occurrences.

3) Protect treated areas by using temporary 

livestock closures or other measures. The length of 

rest will be determined by achieving certain goals 

associated with plant establishment outlined in the 

restoration, fire rehabilitation, or other plan.

4) BLM will work cooperatively with the livestock 

permittees to promote slickspot peppergrass 

conservation.

4) BLM will train permittees on slickspot 

peppergrass habitat and plant recognition. BLM will 

also work with permittees to use the Idaho Natural 

Heritage Program rare plant observation form to 

report survey information in a standard format.

Livestock Grazing: Livestock Management Facilities

1) Manage livestock facilities to promote slickspot 

peppergrass conservation while implementing 

rangeland health standards and guidelines. 

1) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). For new actions, see Special 

Status Animal and Plant Management program 

section item (3). As appropriate to avoid or 

minimize negative impacts, modify existing and 

avoid placement of new livestock facilities in 

occupied habitat areas.

a) Within pastures, place water facilities to 

support slickspot peppergrass conservation: 

i). Existing water troughs (includes troughs 

that are tied into pipelines, as well as both 

permanent and movable troughs to which 

water is delivered throughout the grazing 

season) will be moved at least 1/2 mile 

from EOs, when feasible. Where troughs 

cannot be moved (for example, because of 

topographical constraints, additional 

disturbance, or impacts to sensitive 

species), management will be adjusted to 

mitigate the impacts during the periods of 

critical concern for slickspot peppergrass 

(such as when soils are saturated and 

subject to trampling impacts). Management 

adjustments could include shutting the 

water off seasonally, changing pasture 

boundary fences, or other appropriate 

measures. 
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Conservation Measures BLM Implementation Actions

ii). New water troughs (not including existing 

water troughs moved in [2][a][i], above) will 

be placed at least 1 mile from EOs. A 

deviation from this standard may be 

developed on a case-by-case basis 

through collaboration with the FWS. New 

water troughs will be placed so that cattle 

are drawn away from the EO and avoid 

trailing through an EO en route to a water 

source. 

iii). Temporary water troughs (short-term, 

emergency, or single-season use) will be 

located at least 1 mile from EOs. A 

deviation to this standard may be 

developed on a case-by-case basis 

through collaboration with the FWS. New 

water troughs will be placed so that cattle 

are drawn away from the EO and avoid 

trailing through an EO en route to a water 

source.

b) Placement of new livestock infrastructure will 

be compatible with slickspot peppergrass 

habitat conservation. Avoid placement of new 

fences within EOs.

Wild Horses 

1) If the range of wild horses and occupied habitat 

for slickspot peppergrass overlaps now or in the 

future, protect these areas from wild horses by 

including applicable conservation measures in herd 

management plans.

1) Manage wild horse herd size to minimize 

conflicts with slickspot peppergrass. Limit trampling 

in occupied habitat by implementing appropriate 

range management practices, such as fencing and 

water trough placement.

Recreation 

1) Developed facilities (paved campgrounds, vault 

toilets, interpretive kiosks, etc.): Manage existing 

and new recreation facilities to promote 

conservation of species habitat.

1) Management of existing and new facilities:

a) For review of existing facilities, see Special 

Status Animal and Plant Management program 

section item (2). As appropriate to avoid or 

minimize negative impacts, modify existing 

facilities. 

b) For new facilities, or for expansion of uses at 

existing facilities, see Special Status Animal 

and Plant Management program section item 

(3). In addition, avoid development of new 

recreation facilities or expansion of existing 

facilities in habitat categories for slickspot 

peppergrass if negative impacts are 

anticipated. 

2) Dispersed use areas (informal areas, including 

camping areas and tie-up areas for pack animals): 

Manage dispersed use sites to promote 

conservation of species habitat. This includes 

limiting disturbances to the species resulting from 

human uses.

2) For review of ongoing activities, see Special 

Status Animal and Plant Management program 

section item (2). In addition, minimize human 

activity in and adjacent to occupied habitat if 

negative impacts are occurring. Close areas, either 

seasonally or year-round, as needed to protect the 

species and its habitat.
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Conservation Measures BLM Implementation Actions

3) Commercial and noncommercial recreation 

permits, including hunting guides and outfitter 

camps: issue commercial and noncommercial 

recreation permits to promote conservation of 

habitat categories for slickspot peppergrass. This 

includes management of physical facilities (such as 

camps), as well as disturbances to habitat 

categories for slickspot peppergrass resulting from 

human uses.

3) Issuance and review of existing and new 

permits:

a) For review of existing permits, see Special 

Status Animal and Plant Management program 

section item (2). If needed, modify existing 

permits that negatively impact habitat for this 

species.

b) For new permits, see Special Status Animal 

and Plant Management program section item 

(3). Avoid issuing recreation permits in habitat 

categories for slickspot peppergrass if negative 

impacts are expected. In particular, avoid 

permitting new recreation activities in and 

adjacent to occupied habitat. If a recreation 

permit is to be issued, apply stipulations to the 

permit to support or to not preclude species 

conservation and educate permit holders about 

species’ biology and needs.

c) BLM will not authorize organized recreation 

activities in habitat categories for slickspot 

peppergrass if negative impacts are anticipated 

(for example, off-highway vehicle [OHV] races, 

equestrian events, and other events).

Transportation and Travel

1) Manage roads, OHV routes and areas, as well 

as non-motorized trails, to promote species habitat 

conservation. This includes management of roads 

and trails, as well as ground disturbance resulting 

from human uses.

1) Review of existing and new roads, OHV routes 

and areas, and non-motorized trails:

a) For existing roads, designated OHV routes and 

areas, and designated non-motorized trails, 

see Special Status Animal and Plant

Management program section item (2). Modify 

roads and routes in and adjacent to habitat 

categories for slickspot peppergrass if negative 

impacts are occurring. Implement restrictions 

to reduce ground disturbance. Seek 

opportunities to close and revegetate roads, 

OHV routes, or non-motorized trails and use 

areas in and adjacent to habitat if negative 

impacts are occurring.

b) For new roads, OHV routes and areas, and 

non-motorized trails, see Special Status Animal 

and Plant Management program section item 

(3). Avoid creating new roads, trails, routes, 

and areas if negative impacts are expected in 

and adjacent to habitat categories for slickspot 

peppergrass. 

c) Evaluate off-road vehicle use in occupied 

habitat, and where needed, limit access or 

close areas to motorized and mechanized

vehicles to promote species conservation.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-140

Conservation Measures BLM Implementation Actions

2) Perform compliance checks on OHV closures to 

protect occupied habitat, identify problems as soon 

as possible, and take immediate corrective 

measures.

2) See Special Status Animal and Plant 

Management program section item (2).

Visual Resource 

None None

Special Designations 

1) Explore the potential for new designations that 

would enhance species conservation.

1) Evaluate establishing Areas of Critical 

Environmental Concern for several stronghold 

populations of slickspot peppergrass during land 

use plan amendments. 

Wildland Fire Ecology and Management: Fire Suppression

1) Fire suppression efforts will be conducted, as 

possible, to protect s habitat categories for 

slickspot peppergrass. Place a high priority on 

protecting habitat categories for slickspot 

peppergrass. 

1) Fire management activities:

a) Fire Management Plans will include Standard 

Operating Procedures that address 

conservation of slickspot peppergrass. 

i). BLM will provide adequate fire suppression 

coverage at all stations to meet objectives 

with the intent to suppress 90% of fires to 

the acreages specified in the fire 

management plans for slickspot 

peppergrass. BLM will maintain existing 

remote fire guard stations easily accessible 

to occupied habitat (for example, Juniper 

Butte fire guard station) and explore 

opportunities to establish additional 

stations to provide better initial attack and 

reduced response times for wildfires in 

habitat categories for slickspot 

peppergrass. 

ii). Apply Minimum Impact Suppression 

Tactics (MIST) in habitat categories for 

slickspot peppergrass, as appropriate. 

Consult with resource advisors to 

determine where MIST tactics should be 

applied to avoid or minimize negative 

impacts. 

iii). Although MIST are preferred, aggressive 

fire suppression tactics (e.g., blade lines, 

back fires) may be applied in habitat if EOs 

are threatened. 

b) Do not locate fire base camps, staging areas, 

and fueling areas within occupied habitat.

2) As needed, coordinate with appropriate agency 

personnel regarding fire suppression activities in or 

adjacent to habitat categories for slickspot 

peppergrass. 

2) Ongoing interagency coordination.

a) BLM and cooperators will expand on and 

continue to provide special status plant and 

habitat awareness training to fire resource 

advisors, Incident Commanders, Engine 

Operators, and Fire Operations Supervisors.

b) BLM and cooperators will distribute maps and 

inform fire crews on locations of the EOs to 

maximize fire protection and to avoid or 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-141

Conservation Measures BLM Implementation Actions

minimize impacts from fire suppression 

activities.

Wildland Fire Ecology and Management: Emergency Stabilization and Burned Area Rehabilitation

1) Implement Emergency Stabilization and Burned 

Area Rehabilitation (ES&BAR) activities to consider 

slickspot peppergrass in and adjacent to slickspot 

peppergrass habitat rehabilitation.

1) The following measures will be applied:

a) All wildfires within habitat categories for 

slickspot peppergrass will be evaluated for 

ES&BAR treatments, regardless of size. 

b) As needed, protect disturbed and recovering 

areas using temporary closures or other 

measures. BLM will continue to rest areas from 

land use activities to meet ES&R objectives, 

defined through the ES&BAR plans.

c) BLM will initiate and complete ES&BAR efforts 

for slickspot peppergrass, such as planting 

shrubs and forbs, within habitat categories for 

slickspot peppergrass. BLM will implement the 

following measures during fire ES&BAR efforts: 

i). BLM will use seeding techniques that 

minimize soil disturbance such as 

minimum-till drills and rangeland drills 

equipped with depth bands when ES&BAR

projects have the potential to impact 

slickspot peppergrass habitat. 

ii). BLM will use native plant materials and 

seed during ES&BAR activities. BLM will 

include native forbs in seed mixtures that 

will benefit slickspot peppergrass insect 

pollinators.

iii). If native plant materials and seed are not 

available, non-invasive, non-native species 

may be used for stabilization activities in 

habitat categories for slickspot 

peppergrass. 

iv). In areas adjacent to habitat categories for 

slickspot peppergrass, if natives are not 

available, non-invasive non-native species 

are acceptable for stabilization activities.

2) Fire rehabilitation projects involving the 

application of pesticides in habitat categories for 

slickspot peppergrass will be analyzed and 

implemented in accordance with the approach 

described in the Upland Vegetation Management: 

Rangelands program section.

2) See Upland Vegetation Management:

Rangelands program section.

Wildland Fire Ecology and Management: Wildland Fire Use

1) Wildland fire use projects will not be allowed in 

slickspot peppergrass habitat.

1) Wildland fire use is not an option in the planning 

area per WFM-CA-A-1 in chapter 2.

Wildland Fire Ecology and Management: Prescribed Fire

1) Prescribed fire projects will be designed to 

conserve and enhance slickspot peppergrass 

habitat.

1) Prescribed fire in slickspot peppergrass habitat will 

only be used as a tool for assisting with species 

conservation (for example, a burn in preparation to 

decrease cheatgrass litter before herbicide 

application, or to clear fence lines of accumulated 

windblown weeds).
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Conservation Measures BLM Implementation Actions

Wildland Fire Ecology and Management: Non-Fire Fuels Management

1) Implement projects involving the application of 

pesticides in accordance with the approach 

described in the Upland Vegetation Management: 

Rangelands program section.

1) See Upland Vegetation management: 

Rangelands program section.

2) Fuels management projects conducted in habitat 

categories for slickspot peppergrass should have 

long-term benefits to slickspot peppergrass.

2) Avoid fuels management projects in occupied 

habitat, unless such projects would enhance 

species conservation or are necessary for 

hazardous fuels reduction near the urban interface. 

Implement protection measures to avoid or 

minimize negative impacts to the species. In 

habitat categories for slickspot peppergrass, 

design native seed mixes that emphasize local 

stock and will promote species conservation.

a) Because of potential negative impacts to 

habitat categories for slickspot peppergrass

from linear fuel breaks, which can act as weed 

dispersal corridors, the following measures will 

be applied in or adjacent to habitat categories 

for slickspot peppergrass: 

i). BLM will evaluate the effectiveness of 

existing fuel breaks (location, dry fuel load, 

and noxious weed and invasive plant 

composition) in protecting habitat 

categories for slickspot peppergrass. 

ii). BLM may create and maintain fuel breaks 

where frequent fires can threaten habitat 

categories for slickspot peppergrass. New 

fuel breaks in habitat categories for 

slickspot peppergrass will be designed to 

conserve and enhance species habitat. 

Where appropriate and where objectives 

will be met, native vegetation should be 

emphasized in the creation of new fuel 

breaks. If native vegetation or seed is not 

available or if objectives would be met 

through their use, fuel breaks may include 

non-native, non-invasive, species that will 

not invade slickspots. In areas adjacent to 

habitat categories for slickspot 

peppergrass, fuel breaks may include 

potentially invasive non-native species such 

as intermediate wheatgrass and forage

kochia as a last resort if the benefits of their 

use are demonstrated to outweigh the risks 

to slickspot peppergrass and its habitat. If 

potentially invasive non-native species are 

used, monitoring for spread will occur. If 

spread is found to occur outside the original 

treatment area, control measures will be 

applied to elimante further spread. Apply 

conservation measure (2) in the Fire 

Management: ES&BAR program section 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-143

Conservation Measures BLM Implementation Actions

and conservation measure (4) in the Upland 

Vegetation Management program. 

iii). Consider actions to repair or restore fuel 

breaks so they function as desired. Apply 

conservation measure (2) in the Fire 

Management: ES&BAR program section 

and conservation measure (4) in the 

Upland Vegetation Management program. 

b) In addition to the reduction in fuels associated 

with managed livestock grazing (see relevant 

conservation measures from Livestock Grazing 

Management section), BLM may create fuel 

breaks using techniques such as mowing or 

targeted grazing to strategically reduce fuel 

loads where frequent fires can threaten habitat 

categories for slickspot peppergrass if the 

benefit of these actions can be demonstrated 

to outweigh the risks to slickspot peppergrass 

and its habitat.

Wildland Fire Ecology and Management: Community Assistance

1) Follow all measures included throughout the Fire 

Management program sections.

1) See actions within Fire Management program 

sections. Incorporate into community assistance 

agreements.

Land Tenure (sale, exchanges, withdrawals, etc.)

1) Where feasible and funding is available, acquire 

through land exchange or purchase private lands 

that contain habitat categories for slickspot 

peppergrass. 

1) BLM will opportunistically acquire habitat 

categories for slickspot peppergrass, particularly 

occupied habitat and critical habitat, in land 

exchanges and purchases.

2) Retain occupied habitat and critical habitat for 

slickspot peppergrass Federal ownership unless 

such a transfer would result in a net benefit to the 

species.

2) Occupied habitat and critical habitat for slickspot 

peppergrass within the planning area are allocated 

as land tenure zone 1, lands for retention that are 

not available for disposal.

Lands and Realty Management: Land Use Permits and Leases

1) Issue new land use permits and leases and 

review existing permits and leases at renewal to 

conserve species habitat. This includes 

management of physical facilities, as well as 

ground disturbance resulting from human uses.

1) For new authorizations, as well as those being 

renewed, see Special Status Animal and Plant 

Management program section item (3). Avoid 

issuing new authorizations, or renewing existing 

authorizations, in or adjacent to habitat categories 

for slickspot peppergrass if negative impacts are 

expected. If an authorization is to be issued or reissued in such areas, apply stipulations to the 

authorization that support species conservation 

and that avoid or minimize negative impacts. BLM 

will require control of invasive non-native plant or 

noxious weed species on new, renewing, or 

amending land use permits and leases in habitat 

categories for slickspot peppergrass. 

a) Conduct periodic project compliance 

inspections during implementation of projects 

involving soil disturbance. BLM may require a 

qualified botanist to monitor slickspots to avoid 

ground disturbing activities in habitat 

categories for slickspot peppergrass.
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A-144

Conservation Measures BLM Implementation Actions

b) BLM will require that new or renewing permit or 

lease holders establish at least 50% perennial 

cover after all ground-disturbing activities, 

unless ecological site conditions preclude that 

level of cover. If a native species component 

existed prior to the ground disturbance, then 

the native species component of the perennial 

cover should be restored.

Land Use Authorizationss: Rights-of-Way

1) Issue new rights-of-way (ROWs) and review 

existing ROWs at renewal to conserve species 

habitat. This includes management of physical 

facilities, as well as disturbances to the species 

resulting from human uses.

1) For new rights-of-way and renewal of existing 

rights-of-way, see Special Status Animal and Plant 

Management program section item (3) Avoid 

issuing new rights-of-way, or renewing rights-ofway, in or adjacent to habitat categories for 

slickspot peppergrass if negative impacts are 

expected. In habitat categories for slickspot 

peppergrass, only issue or re-issue rights-of-way 

with stipulations to avoid negative impacts to the 

habitat. BLM will require control of invasive nonnative plants or noxious weed species on new, 

renewing, or amending right of way authorizations 

in habitat categories for slickspot peppergrass.

a) BLM will require that new or renewing permit or 

lease holders establish at least 50% perennial 

cover after all ground-disturbing activities, 

unless ecological site conditions preclude that 

level of cover. If a native species component 

existed prior to the ground disturbance, then 

the native species component of the perennial 

cover should be restored.

b) As appropriate, BLM may require a qualified 

botanist to monitor slickspots to avoid or minimize 

impacts during BLM-authorized activities that occur 

in habitat categories for slickspot peppergrass.

Minerals: Locatable Minerals 

1) Approve plans of operations or allow notice-level 

operations so as not to preclude species habitat 

conservation. This includes management of 

physical facilities, as well as disturbances to the 

species resulting from human uses.

1) Approval of plans of operations and notice-level 

operations:

a) For review of existing plans of operation and 

notice-level operations, see Special Status 

Animal and Plant Management program 

section item (2). To the extent allowed by law, 

modify plans of operation or notice-level 

operations that may have negative impacts on 

the species or its habitat. For notice-level 

operations, notify the operator that 

modifications to proposed activities will be 

required to avoid negative impacts.

b) For new plans of operation and notice-level 

operations, see Special Status Animal and 

Plant Management program section item (3). 

To the extent allowed by law, avoid approving 

plans of operation or notice-level operations 

that may have negative impacts on the species 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-145

Conservation Measures BLM Implementation Actions

or its habitat. For notice-level operations, notify 

the operator that modifications to proposed 

activities will be required to avoid negative 

impacts. If a plan of operations is to be 

approved in or adjacent to habitat categories 

for slickspot peppergrass, apply stipulations to 

support or to not preclude species 

conservation. A notice will require modification 

by the operator until BLM determines that it will 

not result in undue or unnecessary 

degradation.

Minerals: Salable and Leasable Minerals 

1) Approve development of salable or leasable 

minerals so as not to preclude species habitat 

conservation. This includes management of 

physical facilities, as well as disturbances to the 

species resulting from human uses.

1) Approval of salable and leasable minerals:

a) For review of existing mineral leases, see 

Special Status Animal and Plant Management 

program section item (2). Modify existing 

mineral leases if negative impacts are 

occurring. 

b) For new sales or leases, see Special Status 

Animal and Plant Management program 

section item (3). Avoid development of salable

or leasable minerals in or adjacent to habitat 

categories for slickspot peppergrass if negative 

impacts are expected. If a minerals lease or 

sale is to be issued in or adjacent to habitat, 

apply stipulations to support or to not preclude 

species conservation.

Cultural Resources

1) Activities within the Cultural Management 

program will implement relevant conservation 

measures as described in the Special Status 

Animal and Plant Management program section to 

promote conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management 

program section at the beginning of this table.

Paleontological Resources

1) Activities within the Paleontology program will 

implement relevant conservation measures as 

described in the Special Status Animal and Plant 

Management program section to promote 

conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management 

program section at the beginning of this table.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-146

Figure E-1. Implementation of Annual Grazing Adaptive Management 

 

1. Was the Annual Indicator standard 

achieved? (Stubble height, etc.)

4. Review/analyze current vs. 

desired condition and 

trend. Need for annual 

change?

5. Assign adaptive action. 

Was the action implemented?

6. Is failure the result of a 

design problem or changed 

condition outside the control of 

permittee?

7. Is an administrative action 

warranted?

8. Implement 

Administrative action

2. Continue current management 

and monitoring (short- & longterm) to determine if desired 

condition is being achieved.

3. Change or modify annual 

indicator and/or management as 

appropriate.

Yes No

Yes

No

Yes

No

No

Yes

No

Yes

1. Was the Annual Indicator standard 

achieved? (Stubble height, etc.)

4. Review/analyze current vs. 

desired condition and 

trend. Need for annual 

change?

5. Assign adaptive action. 

Was the action implemented?

6. Is failure the result of a 

design problem or changed 

condition outside the control of 

permittee?

7. Is an administrative action 

warranted?

8. Implement 

Administrative action

2. Continue current management 

and monitoring (short- & longterm) to determine if desired 

condition is being achieved.

3. Change or modify annual 

indicator and/or management as 

appropriate.

Yes No

Yes

No

Yes

No

No

Yes

No

Yes
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-147

Figure E-2. BLM Survey Flow Chart for Slickspot Peppergrass. 

Potential Habitat 

Unoccupied Habitat 

Slickspot 

Occupied Habitat Peppergrass Habitat 

Slickspot Peppergrass 

Habitat 

Stage 1 Slickspot Survey: Are slickspots 

present?

Stage 2 Plant Survey: Is slickspot peppergrass 

present?

Stage 3 Additional Plant Survey: Repeat Stage 2 Plant 

Surveys. Were slickspot peppergrass plants found at 

least once in 3 out of 12 years of Stage 2 surveys*?

No

Yes No

Yes No

Yes

Non-habitat 

*Based on Idaho Natural Heritage Program standards 

for viable annual plant seedbank.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-148

Proposed Critical Habitat for Slickspot Peppergrass 

The FWS has identified Primary Constituent Elements (PCEs), those physical and biological features 

essential to the conservation of the species and its habitat, and within areas occupied by the species at 

the time of listing, that may require special management considerations and protection.The conservation 

measures from Table E-1. Conservation Measures for Slickspot Peppergrass are designed to enhance 

slickspot peppergrass occurrences and habitat. The following table contains a crosswalk between PCEs 

for slickspot peppergrass proposed critical habitat and Corresponding Pathway Indicators for making 

effects determinations on the species and its habitat. The most effective way to evaluate the impact an 

activity will have on slickspot peppergrass proposed critical habitat is to analyze the effects that the 

activity will have on the PCEs. 

Table E-2. PCEs for Proposed Critical Habitat for Slickspot Peppergrass and the Associated Matrix 

Indicators.

PCE PCE Description Corresponding Pathway Indicator

1 

Ecologically functional microsites or 

“slickspots” that are characterized 

by: (a) a high sodium and clay 

content and a three-layer soil 

horizonation and (b) sparse 

vegetation with low to moderate 

invasive non-native plant species 

cover

A-1. Density of non-native annual and/or non-native 

perennial plants established within slickspots

A-2. Level of ground disturbance within slickspots

A-3. Level of organic debris (litter or feces) and/or 

soil deposition and accumulation within slickspots

2 

Relatively intact native Wyoming big 

sagebrush vegetation assemblages 

within 820 feet (250 meters) of 

slickspot peppergrass EOs 

B-1. Level of ground disturbance within the action 

area

B-2. Condition of native vegetation within the action 

area - level of habitat fragmentation 

B-3. Condition of native vegetation within the action 

area - presence of non-native annuals and/or nonnative perennial plants

B-4. Condition of native vegetation within the action 

area - percent cover of biological soil crusts

B-5. Condition of native vegetation within the action 

area - percent cover of native forbs

3 

A diversity of native plants to 

provide for insect pollinator 

foraging, nesting, and sheltering

B-3. Condition of native vegetation within the action 

area - presence of non-native annuals and/or nonnative perennial plants

B-5. Condition of native vegetation within the action 

area - percent cover of native forbs

4 Sufficient pollinators for successful 

fruit and seed production

B-1. Level of ground disturbance within the action 

area

B-2. Condition of native vegetation within the action 

area - level of habitat fragmentation

B-3. Condition of native vegetation within the action 

area - presence of non-native annuals and/or nonnative perennial plants

B-5. Condition of native vegetation within the action 

area - percent cover of native forbs
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-149

Listed Snake River Aquatic Snails

Table E-3. Conservation Measures for Listed Snake River Aquatic Snails (Snake River Physa and 

Bliss Rapids Snail). 

Conservation Measures BLM Implementation Actions

Special Status Animal and Plant Management: Common to All Programs

1) In cooperation with Idaho Department of Fish 

and Game, US Fish and Wildlife Service, Bureau of 

Reclamation, hydroelectric power companies, and 

others:

a) Cooperate in gathering existing information to 

understand the distribution of known 

populations, and contribute new information as 

opportunities arise.

1) Following actions to be completed:

a) Provide new occurrence information to Idaho 

Natural Heritage Program as project-level 

clearance inventories are completed. 

Cooperate with other agencies to develop and 

update a map or spatial database of known 

listed Snake River snail locations.

2) Ensure that ongoing Federal actions support or 

do not preclude species recovery.

2) Ongoing BLM activities:

a) As needed, review ongoing activities in and 

adjacent to occupied suitable habitat where 

local consultation has not yet been completed.

b) Determine if direct or indirect negative impacts 

to the species or its habitat are occurring as a 

result of ongoing discretionary BLM actions. If 

so, modify the activity to avoid or minimize 

anticipated negative impacts and, where 

feasible, promote species recovery.

c) Where needed, complete section 7 

consultation for ongoing activities that may 

affect any of these species and their habitat.

3) Ensure that new Federal actions support or do 

not preclude species recovery.

3) New BLM activities:

a) Project-level inventories will be completed in 

suitable habitat during project planning if 

inventory information is not available or 

adequate. 

b) b) If direct or indirect negative impacts to the 

species or their habitats are anticipated as the 

result of new BLM actions, modify the activity 

to avoid or minimize negative impacts and, 

where feasible, promote species recovery.

c) Where needed, complete section 7 

consultation for new activities that may affect 

any of these species and their habitats.

4) Implement adaptive management as needed to 

achieve conservation objectives.

4) Conduct site-specific implementation and 

effectiveness monitoring. Adjust management as 

needed to ensure that management objectives are 

met.

5) Support conservation easements, cooperative 

management efforts, and other programs on 

adjacent non-Federal land to support recovery of 

the listed Snake River snails.

5) Take advantage of opportunities as they arise.

Air Resources

None None
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-150

Conservation Measures BLM Implementation Actions

Soil and Water Resources: Riparian/Wetland Areas (includes noxious weed management)

1) Projects involving the application of pesticides 

(herbicides, insecticides, etc.) that may affect the 

species will be analyzed at the project level and 

designed such that pesticide applications will 

support conservation and recovery and minimize 

risks of exposure.

1) Site-specific stipulations will be developed 

locally using the following criteria:

a) Evaluate the benefits and risks of vegetation 

treatment, including the following: application 

methods; pesticides, carriers, and surfactants 

used; needed treatment buffers; and use of 

non-chemical weed control (for example, biocontrols, hand pulling). If objectives can be 

effectively accomplished using non-chemical 

methods, such is the preferred alternative.

b) Apply appropriate spatial and temporal buffers 

to avoid species’ exposure to harmful 

chemicals.

c) Implement appropriate revegetation measures 

to reduce the risks of soil erosion and water 

quality impacts adjacent to suitable habitat.

2) Where needed and feasible, coordinate with 

adjacent landowners and local governments 

regarding control of noxious weeds and invasive 

plants in riparian areas through cooperative weed 

management programs.

2) Take advantage of opportunities as they arise.

3) Where needed, improve watershed conditions 

adjacent to suitable habitat to prevent soil erosion 

and negative water quality impacts. Conserve 

riparian vegetation near suitable habitat to 

minimize potential for erosion and sediment 

delivery to springs.

3) Management actions:

a) Identify areas with unsuitable watershed 

conditions that are negatively impacting 

suitable habitat. Develop and implement a 

restoration plan to reduce or eliminate negative 

impacts.

b) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and 

sediment delivery are high.

Upland Vegetation Management: Rangelands (includes noxious weed management)

1) Projects involving the application of pesticides in 

uplands adjacent to riparian areas located near 

suitable listed Snake River snail habitat will be 

designed and implemented in accordance with the 

approach described in the Soils and Water 

Resources: Riparian and Wetland Areas program.

1) See Soil and Water Resources:

Riparian/Wetland Areas (includes weed

management) program section.

2) Manage upland areas to minimize sediment 

delivery into suitable habitat.

2) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and sediment 

delivery to suitable habitat are high.

Forest and Woodland Management

None None

Wildlife and Wildlife Habitat Management 

1) Activities within the Wildlife and Wildlife Habitat 

Management Program will implement relevant 

conservation measures as described in the Special 

Status Plant and Animal Management program 

section to promote recovery.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-151

Conservation Measures BLM Implementation Actions

Fish and Aquatic Habitat Management

1) Activities within the Fish and Aquatic Habitat 

Management program will implement relevant 

conservation measures as described in the Special 

Status Animal and Plant Management program 

section to promote recovery.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Livestock Grazing Management: Permits and Leases

1) Manage livestock grazing and trailing adjacent 

to suitable listed Snake River snail habitat to 

promote healthy watershed conditions while 

implementing rangeland health standards and 

guidelines.

1) Permit or lease renewal actions:

a) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2).

b) For new actions, see Special Status Animal 

and Plant Management program section item 

(3).

c) As appropriate to avoid or minimize negative 

impacts, modify livestock grazing permits and 

leases.

2) Promote restoration of areas adjacent to suitable 

habitat following fire, fire rehabilitation, restoration 

treatments, or other major disturbances.

2) As needed, protect disturbed areas using 

temporary closures or other measures until 

vegetation is re-established and self-sustaining.

3) Maintain regular compliance checks on grazing 

allotments with suitable habitat to identify problems 

as soon as possible and take immediate corrective 

measures.

3) Ongoing, day-to-day BLM action.

Livestock Grazing Management: Livestock Management Facilities

1) Manage livestock facilities to promote healthy 

riparian communities or to prevent erosion, or a 

combination of these objectives, while 

implementing rangeland health standards and 

guidelines.

1) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). For new actions, see Special 

Status Animal and Plant Management program 

section item (3). As appropriate to avoid or 

minimize negative impacts, modify existing and 

avoid placement of new livestock facilities adjacent 

to suitable habitat. Consider fencing livestock away 

from suitable habitat, and developing water gaps 

for livestock.

2) Protect springs in or adjacent to suitable habitat 

to conserve and recover listed Snake River snail 

habitat.

2) Avoid development of springs or other water 

sources in or adjacent to suitable habitat unless the 

activity will have beneficial long-term or neutral 

effects on listed Snake River snail populations. If a 

spring or water site is to be developed, install 

facilities as needed to avoid or minimize negative 

impacts.

Wild Horse Management

1) Activities within the Wild Horse Management 

program will implement relevant conservation 

measures as described in the Special Status 

Animal and Plant Management program section to 

promote recovery.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-152

Conservation Measures BLM Implementation Actions

Recreation Management

1) Developed facilities (boat access, paved 

campgrounds, vault toilets, interpretive kiosks, 

etc.): Manage existing and new recreation facilities 

so as not to preclude species habitat conservation 

and recovery. This includes management of the 

physical facilities, as well as disturbances to the 

species resulting from human uses.

1) Management of existing and new facilities:

a) For review of existing facilities, see Special 

Status Animal and Plant Management program 

section item (2). As appropriate to avoid or 

minimize negative impacts, modify existing 

facilities.

b) For new facilities, or for expansion of uses at 

existing facilities, see Special Status Animal 

and Plant Management program section item 

(3). In addition, modify new recreation facilities 

in or adjacent to suitable habitat if negative 

impacts are anticipated.

2) Dispersed use areas (informal areas including 

camping, spring access, and tie-up areas for pack 

animals and boats): Manage dispersed use sites 

so as not to preclude species habitat conservation 

and recovery. This includes limiting disturbance to 

the species resulting from human uses.

2) For review of ongoing activities, see Special 

Status Animal and Plant Management program 

section item (2). In addition, minimize human 

activity in and adjacent to known populations, if 

negative impacts are occurring. Close areas, either 

seasonally or year-round, as needed, and post and 

monitor the closure.

3) Commercial and non-commercial recreation 

permits including outfitter camps: Issue commercial 

and non-commercial recreation permits so as not to 

preclude species habitat conservation and 

recovery. This includes management of physical 

facilities (such as camps), as well as disturbance to 

the species resulting from human uses.

3) Issuance and review of existing and new 

permits:

a) For review of existing permits, see Special 

Status Animal and Plant Management program 

section item (2). If needed, modify existing 

permits if the permitted activity is causing 

negative impacts.

b) For new permits, see Special Status Animal 

and Plant Management program section item 

(3). If a recreation permit is to be issued in or 

adjacent to suitable habitat, apply stipulations 

to the permit to support or to not preclude 

species conservation and recovery.

4) Protect springs with known populations to 

conserve listed Snake River snail habitat.

4) Discourage or prohibit human entry in springs 

with known listed Snake River snail populations, if 

such entry causes negative impacts.

5) Educate the public on the listed Snake River 

snails’ unique ecological requirements, sensitivity 

to habitat alteration and need for protection.

5) Take advantage of opportunities as they arise.

Recreation Management: Travel Management

1) Manage roads, off-highway vehicle (OHV) routes 

and areas, and non-motorized trails, so as not to 

preclude species habitat conservation and 

recovery. This includes management of physical 

facilities, as well as disturbances to the species 

resulting from human uses.

1) Review of existing and new roads, OHV routes, 

and areas and non-motorized trails:

a) For existing roads, OHV routes and areas, and 

non-motorized trails, see Special Status Animal 

and Plant Management program section item 

(2). Limit OHV activities in areas adjacent to 

suitable habitat that are particularly susceptible 

to erosion and thus sediment delivery. Seek 

opportunities to close and revegetate OHV 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-153

Conservation Measures BLM Implementation Actions

routes or non-motorized trails and use areas if 

negative impacts are occurring.

b) For new roads, OHV routes and areas, and 

non-motorized trails, see Special Status Animal 

and Plant Management program section item 

(3). Avoid constructing new roads, trails,

routes, and areas if negative impacts are 

expected. In particular, avoid opening new 

roads, trails, routes, and areas adjacent to 

suitable habitat particularly susceptible to 

erosion and thus sediment delivery.

2) Maintain regular compliance checks on OHV 

closures to protect known populations and to 

identify problems as soon as possible and take 

immediate corrective measures.

2) Ongoing, day-to-day BLM activities.

Visual Resource Management

None None

Special Designation Area Management

1) Explore the potential for new designations that 

would enhance species recovery.

1) Take advantage of opportunities as they arise.

Fire Management: Fire Suppression

1) Fire suppression efforts will be conducted, as 

possible, to protect listed Snake River snail habitat. 

Place a high priority on protecting highly erosive 

areas adjacent to suitable habitat from wildfire.

1) Fire management activities:

a) Review Fire Management Plan for adequacy in 

addressing conservation measures. Modify the 

plan if needed.

b) Apply Minimum Impact Suppression Tactics 

(MIST) adjacent to suitable habitat, as 

appropriate. Consult with resource advisors to 

determine where MIST tactics should be 

applied to avoid or minimize negative impacts.

c) Avoid fire base camps, staging areas, fueling 

areas, or other related activities in highly 

erosive areas adjacent to suitable habitat.

2) Coordinate with US Forest Service, Idaho 

Department of Lands, or other applicable agency 

personnel regarding fire suppression activities in or 

near suitable habitat.

2) Ongoing interagency coordination.

Fire Management: Emergency Stabilization and Burned Area Rehabilitation

1) Implement Emergency Stabilization and Burned 

Area Rehabilitation (ES&BAR) activities to promote 

restoration of areas adjacent to suitable listed 

Snake River snail habitat.

1) ES&BAR activities:

a) If needed and if natural recovery would not 

achieve habitat objectives, implement ES&BAR

activities to promote rehabilitation of areas 

adjacent to suitable habitat. Plant locally 

appropriate vegetation to prevent erosion, if 

natural recovery of such vegetation is doubtful. 

Include requirements that protect listed Snake 

River snail habitat, for example, sediment 

barriers.

b) As needed, protect disturbed areas using 

temporary closures or other measures until site 

specific stabilization, rehabilitation, and 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-154

Conservation Measures BLM Implementation Actions

revegetation plan goals are met.

2) Fire rehabilitation projects involving the 

application of pesticides will be analyzed and 

implemented in accordance with the approach 

described in Soil and Water Resources: 

Riparian/Wetland areas.

2) See Soil and Water Resources:

Riparian/Wetland Areas program section.

Fire Management: Wildland Fire Use

1) Wildland fire use projects will be designed to 

conserve suitable listed Snake River snail habitat.

1) When developing wildland fire use plans, avoid 

burning lands adjacent to suitable habitat.

Fire Management: Prescribed Fire

1) Prescribed fire projects will be designed to 

conserve suitable listed Snake River snail habitat.

1) When developing and implementing prescribed 

fire plans, avoid or minimize negative impacts to 

suitable habitat. Avoid prescribed fire use adjacent 

to suitable habitat, unless adequate erosion 

protections are implemented.

Fire Management: Non-Fire Fuels Management

1) Projects involving the application of pesticides 

will be designed in accordance with the approach 

described in Soil and Water Resources: 

Riparian/Wetland program section.

1) See Soil and Water Resources:

Riparian/Wetland Areas program section.

2) Promote the establishment of plant species 

needed to control erosion adjacent to suitable 

habitat.

2) Incorporate conservation actions into the fuels 

projects, as needed, to control erosion and prevent 

sediment delivery to suitable habitat.

Fire Management: Community Assistance

1) Follow all measures included throughout the Fire 

Management program sections.

1) See actions within Fire Management program 

sections. Incorporate into community assistance 

agreements.

Lands and Realty Management: Land Tenure Adjustment (sale, exchanges, withdrawals, etc.)

1) Where feasible and funding is available, acquire 

through land exchange or purchase, private lands 

that support known populations or could enhance 

habitat for listed Snake River snails.

1) Take advantage of opportunities as they arise. 

Priority should be given to lands that are adjacent 

to or near public lands.

2) Retain listed Snake River snail habitat in Federal 

ownership to the extent possible, while balancing 

other needs.

2) Review each land tenure decision in terms of 

species habitat. Avoid the loss of riparian habitat 

along the Snake River from Federal ownership. If 

property is to be transferred out of Federal 

ownership, permanent conservation easements 

may be attached to the transfer that would result in 

equal or greater protection than under Federal 

management. Such measures must be approved 

by the State Director.

Lands and Realty Management: Land Use Permits and Leases

1) Issue new land use permits and leases and 

review existing permits and leases at renewal so as 

not to preclude species habitat conservation and 

recovery. This includes management of physical 

facilities, as well as disturbances to the species 

resulting from human uses.

1) For new permits and renewal of existing permits, 

see Special Status Animal and Plant Management

program section item (3). Avoid issuing new 

permits or leases, or renewing existing permits or 

leases, adjacent to suitable habitat if negative 

impacts are expected. If a permit or lease is to be 

issued or re-issued adjacent to suitable habitat, 

apply stipulations to the permit that support or do 

not preclude species recovery and that avoid or 

minimize negative impacts.
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-155

Conservation Measures BLM Implementation Actions

2) Protect the watershed contributing to listed 

Snake River snail habitat.

2) Conduct appropriate hydrologic studies or 

analysis before permitting developments on BLMmanaged lands where the extraction of 

groundwater may negatively impact suitable 

habitat. Depending on the scope of the activity, this 

may require coordination and cooperation with 

other agencies.

Lands and Realty Management: Rights-of-Way

1) Issue new rights-of-way (ROWs) and review 

existing ROWs at renewal so as not to preclude 

species habitat conservation and recovery. This 

includes management of physical facilities, as well 

as disturbances to the species resulting from 

human uses.

1) For new ROWs and renewal of existing ROWs, 

see Special Status Animal and Plant Management

program section item (3). Avoid issuing ROWs, or 

renewing existing ROWs, in or adjacent to suitable 

habitat if negative impacts are expected. If a ROW 

is to be issued or re-issued in or adjacent to 

suitable habitat, apply stipulations to the ROW that 

support or do not preclude species recovery and 

that avoid or minimize negative impacts.

Mineral Management: Locatable Minerals 

1) Approve plans of operations or allow notice-level 

operations so as not to preclude species habitat 

conservation and recovery. This includes 

management of physical facilities, as well as 

disturbances to the species resulting from human 

uses.

1) Approval of plans of operations and notice-level 

operations:

a) For review of existing plans of operation and 

notice-level operations, see Special Status 

Animal and Plant Management program 

section item (2). To the extent allowed by law, 

modify plans of operation or notice-level 

operations that negatively impact Snake River 

snail habitat. For notice-level operations, notify 

the operator that modifications to proposed 

activities will be required to avoid negative 

impacts.

b) For new plans of operation and notice-level 

operations, see Special Status Animal and 

Plant Management program section item (3). 

To the extent allowed by law, avoid approving 

plans of operation or notice-level operations 

that negatively impact listed Snake River snail 

habitat. For notice-level operations, notify the 

operator that modifications to proposed 

activities will be required to avoid negative 

impacts. If a plan of operations is to be 

approved in suitable habitat, apply stipulations 

to support or to not preclude species recovery. 

A notice will require modification by the 

operator until BLM determines that it will not 

result in undue or unnecessary degradation.

Mineral Management: Salable and Leasable Minerals 

1) Approve development of salable or leasable 

minerals so as not to preclude species habitat 

conservation and recovery. This includes 

management of physical facilities, as well as 

disturbances to the species resulting from human 

uses.

1) Approval of salable and leasable minerals:

a) For review of existing mineral leases, see 

Special Status Animal and Plant Management

program section item (2). Modify existing 

mineral leases if negative impacts are 

occurring. 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-156

Conservation Measures BLM Implementation Actions

b) For new sales or leases, see Special Status 

Animal and Plant Management program 

section item (3). Avoid development of salable

or leasable minerals adjacent to suitable 

habitat if negative impacts are expected. If a 

minerals lease or sale is to be issued adjacent 

to suitable habitat, apply stipulations to support 

or to not preclude species recovery.

2) Protect the watershed contributing to listed 

Snake River snail habitat.

2) Conduct appropriate hydrologic studies or 

analysis before permitting developments on BLMmanaged lands where the extraction of 

groundwater may negatively impact suitable 

habitat. Depending on the scope of the activity, this 

may require coordination and cooperation with 

other agencies.

Cultural Management

1) Activities within the cultural management

program will implement relevant conservation 

measures as described in the Special Status 

Animal and Plant Management program section to 

promote recovery of Snake River snails.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Paleontology

1) Activities within the paleontology program will 

implement relevant conservation measures as 

described in the Special Status Animal and Plant 

Management program section to promote recovery 

of Snake River snails.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.
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Bruneau Hot Springsnail

Table E-4. Conservation Measures for Bruneau Hot Springsnail.

Conservation Measures BLM Implementation Actions

Special Status Animal and Plant Management: Common to All Programs

1) In cooperation with Idaho Department of Fish 

and Game (IDFG), US Fish and Wildlife Service

(FWS), Bureau of Reclamation, hydroelectric 

power companies, and others:

1) Following actions to be completed in 

cooperation with others:

a) Continue to cooperate to identify and map all 

known populations and suitable habitat.

a) Mapping and data inventory:

i). Cooperate with IDFG, Idaho Natural 

Heritage Program (IDHP), and FWS to 

update maps of all known populations and 

suitable habitat on BLM-managed lands.

ii). In cooperation with IDHP, maintain a 

spatial database of species population and 

habitat information for BLM-managed 

lands.

b) Follow current monitoring protocols and

cooperate in monitoring Bruneau hot 

springsnail population trends and habitat 

conditions.

b) Cooperate with FWS, IDFG, and IDHP to 

conduct regular monitoring of populations on 

BLM-managed lands.

c) Manage BLM lands with or adjacent to suitable 

habitat and populations to promote species 

recovery and support re-colonization of 

suitable habitat.

c) Develop a habitat management plan, as 

funding allows.

d) Participate in research essential to recovery of 

the species. Support the geothermal aquifer 

groundwater modeling and monitoring 

program. Cooperate in determining specific 

limiting factors in terms of habitat needs and 

characteristics. Cooperate in population 

viability analyses to ensure that recovery 

criteria objectives are being met.

d) BLM will participate as funding allows.

e) Cooperate in incorporating geothermal aquifer 

conservation measures.

e) As opportunities arise, work with FWS and 

Idaho Department of Water Resources to 

pursue the permanent acquisition of non-use 

groundwater rights from current groundwater 

rights holders and protect these rights to 

support species conservation.

f) Working with other agencies, pursue funding 

for implementation of recovery tasks.

f) Cooperate with other agencies to identify 

potential sources of funding for actions that 

promote recovery, such as monitoring.

2) Ensure that ongoing Federal actions support or 

do not preclude species recovery.

2) Ongoing BLM activities:

a) As needed, review ongoing activities within and 

adjacent to suitable habitat, where local 

consultation has not yet been completed.

b) Determine if direct or indirect negative impacts 

to the species or its habitat are occurring as a 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

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Conservation Measures BLM Implementation Actions

result of ongoing discretionary BLM actions. If 

so, modify the activity to avoid or minimize 

anticipated negative impacts and, where 

feasible, promote species recovery.

c) Where needed, complete section 7 

consultation for ongoing activities that may 

affect this species and its habitat.

3) Ensure that new Federal actions support or do 

not preclude species recovery.

3) New BLM activities:

a) Project-level inventories will be completed in 

suitable habitat during project planning if 

inventory information is not available or 

adequate.

b) If direct or indirect negative impacts to the 

species or its habitat are anticipated as a result 

of new BLM actions, modify the activity to 

avoid negative impacts and, where feasible, 

promote species recovery.

c) Where needed, complete section 7 

consultation for new activities that may affect 

this species and its habitat.

4) Implement adaptive management for 

conservation actions.

4) Conduct site-specific implementation and 

effectiveness monitoring. Adjust management as 

needed to ensure that management objectives are 

met.

5) Support conservation easements, cooperative 

management efforts, and other programs on 

adjacent non-Federal lands to support 

conservation of suitable habitat.

5) Take advantage of opportunities as they arise.

Air Resources

None None

Soil and Water Resources: Riparian/ Wetland Areas (includes noxious weed management)

1) Projects involving the application of pesticides 

(herbicides, insecticides, etc.) that may affect the 

species will be analyzed at the project level and 

designed such that pesticide applications will 

support conservation and recovery and minimize 

risks of exposure.

1) Site specific stipulations will be developed locally 

using the following criteria:

a) Evaluate the benefits and risks of vegetation 

treatment, including the following: application 

methods; pesticides, carriers, and surfactants 

used; needed treatment buffers; and use of 

non-chemical weed control (for example, biocontrols, hand pulling). If objectives can be 

effectively accomplished using non-chemical 

methods, such is the preferred alternative.

b) Apply appropriate spatial and temporal buffers 

to avoid species’ exposure to harmful 

chemicals.

c) Implement appropriate revegetation and 

noxious weed control measures to reduce the 

risks of non-native species infestations and soil 

erosion following any ground or vegetation 

disturbing actions in or adjacent to suitable 

habitat.
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Conservation Measures BLM Implementation Actions

2) Where needed and feasible, coordinate with 

adjacent landowners and local governments 

regarding control of noxious weeds and invasive 

plants in riparian area through cooperative weed 

management programs.

2) Take advantage of opportunities as they arise.

3) Where needed, improve watershed conditions 

adjacent to suitable habitat to prevent soil erosion 

and negative water quality impacts. Conserve 

riparian vegetation near suitable habitat to minimize 

potential for erosion and sediment delivery to 

springs.

3) Management actions:

a) Identify areas with unsuitable watershed 

conditions that are negatively impacting 

suitable habitat. Restore to reduce or eliminate 

negative impacts.

b) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and 

sediment delivery are high.

Upland Vegetation Management: Rangelands (includes noxious weed management)

1) Projects involving the application of pesticides in 

uplands adjacent to riparian areas located near 

suitable habitat for the Brueau hot springsnail will 

be designed and implemented in accordance with 

the approach described in the Soils and Water 

Resources: Riparian and Wetland Areas program.

1) See Soil and Water Resources: Riparian and 

Wetland Areas program section.

2) Protect upland areas adjacent to riparian areas 

where management activities could affect suitable 

habitat.

2) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and sediment 

delivery to springs are high.

Forest and Woodland Management

None None

Wildlife and Wildlife Habitat Management 

1) Activities within the Wildlife and Wildlife Habitat 

Management Program will implement relevant 

conservation measures as described in the Special 

Status Plant and Animal Management program

section to promote recovery.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Fish and Aquatic Habitat Management

1) Cooperate with IDFG in protecting Bruneau hot 

springsnails from competition and predation from 

non-native species.

1) Protection from predators and competition 

actions:

a) Cooperate in seeking opportunities to remove 

non-native competitive or predatory fish from 

watersheds with suitable habitat.

b) Work with IDFG to inform the public of the 

adverse effects of introducing non-native 

predator and competitive species to Bruneau 

hot springsnail-occupied thermal springs and 

seeps.

2) Cooperate in restoring habitat for possible 

reintroduction of the species.

2) Participate with other agencies in restoring 

habitats for potential re-colonization, as 

opportunities allow.

Livestock Grazing Management: Permits and Leases

1) Manage livestock grazing and trailing adjacent 

to suitable Bruneau hot springsnail habitat to 

promote healthy watershed conditions. Maintain 

and promote suitable habitat conditions for the 

1) Permit or lease actions:

a) For review of ongoing actions, see Special 

Status Animal and Plant Management program 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-160

Conservation Measures BLM Implementation Actions

Bruneau hot springsnail while implementing 

rangeland health standards and guidelines.

section item (2).

b) For new actions, see Special Status Animal 

and Plant Management program section item 

(3).

c) As appropriate to avoid or minimize negative 

impacts, modify livestock grazing permits and 

leases.

2) Promote restoration in or adjacent to suitable 

habitat following fire, fire rehabilitation, restoration 

treatments, or other major disturbances.

2) As needed, issue temporary pasture closures 

until vegetation is re-established, self-sustaining, 

and on an upward trend for controlling erosion and 

preventing sediment delivery.

3) Maintain regular compliance checks on grazing 

allotments within or adjacent to suitable habitat to 

identify problems as soon as possible and take 

immediate corrective measures.

3) Ongoing, day-to-day BLM action.

4) Protect suitable Bruneau Hot springsnail habitat 

in the Bruneau Canyon.

4) Continue to exclude grazing in the portion of the 

Bruneau canyon that contains springs and seeps 

occupied by the Bruneau hot springsnail and 

formalize this by modifying the appropriate grazing 

decisions.

Livestock Grazing Management: Livestock Management Facilities

1) Manage livestock facilities to promote healthy 

riparian communities or to prevent erosion, or a 

combination of these objectives, while 

implementing rangeland health standards and 

guidelines.

1) For review of ongoing actions in or adjacent to 

suitable habitat, see Special Status Animal and 

Plant Management program section item (2). For 

new actions in or adjacent to suitable habitat, see

Special Status Animal and Plant Management

program section item (3). As appropriate to avoid 

or minimize negative impacts, modify existing and 

avoid placement of new livestock facilities.

2) Protect all springs in or adjacent to suitable 

habitat to conserve and recover Bruneau Hot 

springsnail habitat.

2) Facilities management actions:

a) On BLM managed lands, prohibit development 

of springs or other water sources in or adjacent 

to suitable habitat unless the activity will have 

beneficial long-term or neutral effects on 

Bruneau hot springsnail populations.

b) Continue to maintain livestock exclosure 

fencing annually and assess the need for 

additional measures to promote species 

recovery.

Wild Horse Management

None None

Recreation Management

1) Developed facilities (boat access, paved 

campgrounds, vault toilets, interpretive kiosks, 

etc.): Manage existing and new recreation facilities 

so as not to preclude species habitat conservation 

and recovery. This includes management of the 

physical facilities, as well as disturbances to the 

species resulting from human uses.

1) Management of existing and new facilities:

a) For review of existing facilities near known 

populations, see Special Status Animal and 

Plant Management program section item (2). 

As appropriate to avoid or minimize negative 

impacts, modify existing facilities.

b) Prohibit development of new recreation 
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Conservation Measures BLM Implementation Actions

facilities in or adjacent to suitable habitat.

2) Dispersed use areas (informal areas, including 

camping, spring access, and tie-up areas for pack 

animals and boats): Protect thermal springs in or 

adjacent to suitable habitat to conserve Bruneau 

hot springsnail habitat. Manage dispersed use sites 

so as not to preclude species habitat conservation 

and recovery. This includes limiting disturbance to 

the species resulting from human uses.

2) Dispersed use areas:

a) Minimize human activity in suitable habitat. 

Close areas, either seasonally or year-round, 

as needed if negative impacts are occurring to 

protect the species and its habitat, and post 

and monitor the closure.

b) Discourage human entry in springs in suitable 

habitat. Post and monitor needed closures.

3) Commercial and non-commercial recreation 

permits including outfitter camps: Issue commercial 

and non-commercial recreation permits in 

accordance with goals for promoting species 

habitat conservation and recovery. This includes 

management of physical facilities (such as camps), 

as well as disturbance to the species resulting from 

human uses.

3) Issuance and review of existing and new 

permits:

a) For review of existing permits near known 

populations, see Special Status Animal and 

Plant Management program section item (2). If 

needed, modify existing permits if the permitted 

activity is causing negative impacts. 

b) For new permits in or adjacent to suitable 

habitat, see Special Status Animal and Plant 

Management program section item (3). Avoid 

issuing recreation permits if negative impacts 

are expected. In particular, avoid permitting 

new recreation activities in or adjacent to 

suitable habitat. If a recreation permit is to be 

issued, apply stipulations to the permit to 

support or to not preclude species 

conservation and recovery.

4) Educate the public on the springsnail's unique 

ecological requirements, sensitivity to habitat 

alteration and need for protection.

4) Take advantage of opportunities as they arise.

Recreation Management: Travel Management

1) Manage roads, off-highway vehicle (OHV) routes 

and areas, and non-motorized trails, so as not to 

preclude species habitat conservation and 

recovery. This includes management of physical 

facilities, as well as disturbances to the species 

resulting from human uses.

1) Review of existing and new roads, OHV routes 

and areas, and non-motorized trails:

a) For existing roads, designated OHV routes and 

areas, and designated non-motorized trails 

near known populations, see Special Status 

Animal and Plant Management program 

section item (2). Limit OHV activities in areas 

particularly susceptible to erosion and thus 

sediment delivery to springs. Seek 

opportunities to close and revegetate OHV 

routes or non-motorized trails and use areas if 

negative impacts are occurring.

b) For new roads, OHV routes and areas, and 

non-motorized trails, see Special Status Animal 

and Plant Management program section item 

(3). Avoid constructing new roads, trails, 

routes, and areas if negative impacts are 

expected. Avoid opening new roads, trails, 

routes, and areas in or adjacent to suitable 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

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Conservation Measures BLM Implementation Actions

habitat particularly susceptible to erosion and 

thus sediment delivery to springs.

2) Seek opportunities to close and revegetate 

designated and user-created OHV routes or nonmotorized trails and use areas, if such use causes 

negative impacts to suitable habitat.

2) See Special Status Animal and Plant

Management program section item (2).

3) Maintain regular compliance checks on OHV 

closures to protect known populations and to 

identify problems as soon as possible and take 

immediate corrective measures.

3) Ongoing, day-to-day BLM activities.

Visual Resource Management

None None

Special Designation Area Management

1) Explore the potential for new designations that 

would enhance species recovery.

1) As opportunities arise, recommend suitable 

habitat for Area of Critical Environmental Concern

designation.

Fire Management: Fire Suppression

1) Fire suppression efforts will be conducted, as 

much as possible, to protect Bruneau hot 

springsnail habitat. Place a high priority on 

protecting highly erosive areas in or adjacent to 

suitable habitat.

1) Fire management activities:

a) Review Fire Management Plan for adequacy in 

addressing conservation measures. Modify the 

plan if needed.

b) Apply Minimum Impact Suppression Tactics 

(MIST) in or adjacent to suitable habitat, as 

appropriate. Consult with resource advisors to 

determine where MIST tactics should be 

applied to avoid or minimize negative impacts.

c) Do not locate fire base camps, staging areas, 

fueling areas, or other related activities in 

highly erosive areas in or adjacent to suitable 

habitat.

2) Coordinate with Idaho Department of Lands or 

other applicable agency personnel regarding fire 

suppression activities in or adjacent to suitable 

habitat.

2) Ongoing interagency coordination.

Fire Management: Emergency Stabilization and Burned Area Rehabilitation

1) Implement Emergency Stabilization and Burned 

Area Rehabilitation (ES&BAR) activities to promote 

restoration in or adjacent to suitable Bruneau hot 

Springsnail habitat.

1) ES&BAR activities:

a) If needed and if natural recovery would not 

achieve habitat objectives, implement ES&BAR

activities to promote rehabilitation in or 

adjacent to suitable habitat. Plant locally 

appropriate vegetation to prevent erosion, if the 

natural drainage regime has been altered or if 

natural recovery of such vegetation is doubtful. 

Include requirements that protect Bruneau hot 

springsnail habitat, for example, sediment 

barriers.

b) As needed, protect disturbed areas using 

temporary closures or other measures until 

site-specific stabilization, rehabilitation, and 

revegetation plan goals are met.
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A-163

Conservation Measures BLM Implementation Actions

2) Fire rehabilitation projects involving the 

application of pesticides will be analyzed and 

implemented in accordance with the approach 

described in Soil and Water Resources: Riparian

and Wetland areas.

2) See Soil and Water Resources: Riparian and 

Wetland Areas program section.

Fire Management: Wildland Fire Use

1) Wildland fire use projects will be designed to 

conserve suitable Bruneau hot Springsnail habitat.

1) When developing wildland fire use plans, do not 

include suitable habitat or adjacent areas in any 

wildland fire use area.

Fire Management: Prescribed Fire

1) Prescribed fire projects will be designed to 

conserve suitable Bruneau hot Springsnail habitat.

1) When developing and implementing prescribed 

fire plans, avoid negative impacts in or adjacent to 

suitable habitat.

Fire Management: Non-Fire Fuels Management

1) Implement projects involving the application of 

pesticides in accordance with the approach 

described in the Soil and Water Resources: 

Riparian/Wetland Areas program section.

1) See Soil and Water Resources:

Riparian/Wetland Areas program section.

Fire Management: Community Assistance

1) Follow all measures included throughout the Fire 

Management program sections.

1) See actions within Fire Management program 

sections. Incorporate into community assistance 

agreements.

Lands and Realty Management: Land Tenure Adjustment (sale, exchanges, withdrawals, etc.)

1) Where feasible and funding is available, acquire 

through land exchange or purchase, private lands 

that support known populations or could enhance 

habitat for Bruneau hot springsnails.

1) Take advantage of opportunities as they arise. 

Priority should be given to lands that are adjacent 

to or near public lands.

2) Retain Bruneau hot springsnail habitats in 

Federal ownership.

2) Land tenure adjustments:

a) Retain all suitable habitat in Federal 

ownership.

b) Within areas adjacent to suitable habitat review 

each land tenure decision in terms of species 

recovery. Retain these areas in Federal

ownership unless the land tenure adjustment 

results in a long-term benefit to species 

recovery.

Lands and Realty Management: Land Use Permits and Leases

1) Issue new land use permits and leases and 

review existing permits and leases at renewal so as 

not to preclude species habitat conservation and 

recovery. This includes management of physical 

facilities, as well as disturbances to the species 

resulting from human uses.

1) For new permits and renewal of existing permits 

near known populations and suitable habitat, see 

Special Status Animal and Plant Management

program section item (3). Avoid issuing new 

permits or leases, or renewing existing permits or 

leases, in or adjacent to suitable habitat if negative 

impacts are expected. If a permit or lease is to be

issued or re-issued in suitable habitat, apply 

stipulations to the permit that support or do not 

preclude species recovery and that avoid negative 

impacts.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-164

Conservation Measures BLM Implementation Actions

2) Protect the groundwater contributing to Bruneau 

hot springsnail habitat.

2) Conduct appropriate hydrologic studies or 

analysis before permitting developments on BLMmanaged lands where the extraction of 

groundwater may reduce or eliminate flows in 

suitable habitat. Depending on the scope of the 

activity, this may require coordination and 

cooperation with other agencies.

Lands and Realty Management: Rights-of-Way

1) Issue new rights-of-way (ROWs) and review 

existing ROWs at renewal so as not to preclude 

species habitat conservation and recovery. This 

includes management of physical facilities, as well 

as disturbances to the species resulting from 

human uses.

1) For new ROWs and renewal of existing ROWs in 

and adjacent to suitable habitat, see Special Status 

Animal and Plant Management program section 

item (3). Avoid issuing ROWs, or renewing existing 

ROWs, in and adjacent to suitable habitat if 

negative impacts are expected. If a ROW is to be 

granted or renewed in or adjacent to suitable 

habitat, apply stipulations to the ROW that support 

or do not preclude species recovery and that avoid 

negative impacts.

Mineral Management: Locatable Minerals 

1) Approve plans of operations or allow notice-level 

operations so as not to preclude species habitat 

conservation and recovery. This includes 

management of physical facilities, as well as 

disturbances to the species resulting from human 

uses.

1) Approval of plans of operations and notice-level 

operations:

a) For review of existing plans of operation and 

notice-level operations near known 

populations, see Special Status Animal and 

Plant Management program section item (2). 

To the extent allowed by law, modify plans of 

operation or notice-level operations that conflict 

with Bruneau hot springsnail objectives in or 

adjacent to suitable habitat. For notice-level 

operations, notify the operator that 

modifications to proposed activities will be 

required to avoid negative impacts.

b) For new plans of operation and notice-level 

operations in or adjacent to suitable habitat, 

see Special Status Animal and Plant 

Management program section item (3). To the 

extent allowed by law, avoid approving plans of 

operation or notice-level operations that conflict 

with Bruneau hot springsnail objectives in or 

adjacent to suitable habitat. For notice-level 

operations, notify the operator that 

modifications to proposed activities will be 

required to avoid negative impacts. If a plan of 

operations is to be approved in or adjacent to 

suitable habitat, apply stipulations to support or 

to not preclude species recovery. A notice will 

require modification by the operator until BLM 

determines that it will not result in undue or 

unnecessary degradation.
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Conservation Measures BLM Implementation Actions

Mineral Management: Salable and Leasable Minerals 

1) Approve development of salable or leasable 

minerals so as not to preclude species habitat 

conservation and recovery. This includes 

management of physical facilities, as well as 

disturbances to the species resulting from human 

uses.

1) Approval of salable and leasable minerals:

a) For review of existing mineral leases, see 

Special Status Animal and Plant Management

program section item (2). Modify existing 

mineral leases if negative impacts are 

occurring.

b) For new sales or leases in or adjacent to 

suitable habitat, see Special Status Animal and 

Plant Management program section item (3). 

Avoid development of salable or leasable 

minerals in or adjacent to suitable habitat if 

negative impacts are expected. If a minerals 

lease or sale is to be issued in or adjacent to 

suitable habitat, apply stipulations to support or 

to not preclude species recovery.

2) Protect the groundwater sources that contribute 

to Bruneau hot springsnail habitat.

2) Conduct appropriate hydrologic studies or 

analysis before permitting developments on BLMmanaged lands where the extraction of 

groundwater may reduce or eliminate flows in or 

adjacent to habitats. Depending on the scope of 

the activity, this may require coordination and 

cooperation with other agencies.

Cultural Management

1) Activities in the Cultural Management Program 

will implement relevant conservation measures as 

described in the Special Status Animal and Plant 

Management program section to promote recovery.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Paleontology

1) Activities in the Paleontology Program will 

implement relevant conservation measures as 

described in the Special Status Animal and Plant 

Management program section to promote recovery.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-166

Jarbidge River Bull Trout

Recovery plans are developed by the US Fish and Wildlife Service (FWS) and/or National Marine 

Fisheries Service and establish recovery objectives for a species, provide a listing of tasks necessary to 

achieve those objectives, and recommend assignments to involve agencies to carry put these tasks. A 

primary function of recovery plans is to combine programs of all agencies involved in managing a species 

into a coordinated management effort. The BLM has incorporated conservation measures for Jarbidge 

River bull trout into the Jarbidge RMP to promote the attainment of the objectives from the Draft Recovery 

Plan for the Jarbidge River Distinct Population Segment of Bull Trout (FWS, 2004). These recovery 

objectives and implementation actions conform to the goals, objectives and management actions 

common to all action alternatives in Chapter 2 of the Jarbidge Proposed RMP/Final EIS. Conservation 

measures are subject to revision in cooperation with the Federal and State agencies identified below. 

Table E-5. Conservation Measures for Jarbidge River Bull Trout.

Conservation Measures BLM Implementation Actions

Interagency Cooperation and Coordination

1) In cooperation with Nevada Department of 

Wildlife, Idaho Department of Fish and Game, US

Department of Agriculture Forest Service, Idaho 

Department of Environmental Quality (DEQ), 

Nevada Division of Environmental Protection 

(NDEP), Duck Valley Paiute-Shoshone Tribes, US 

Geologic Survey, and FWS (Boise, ID and Reno, 

NV), provide long-term habitat protection for bull 

trout on BLM managed land. 

1) Cooperate with other Federal and State 

agencies as BLM staffing and budgets allow. 

Support opportunities for interagency conservation 

and restoration actions on BLM managed land as 

they become available.

2) Support collaborative efforts by local watershed 

groups to implement bull trout recovery actions and 

provide long-term habitat protection for Jarbidge 

River bull trout.

Population Characteristics

1) Cooperate with other Federal and State 

agencies as BLM staffing and budgets allow. 

Support opportunities for interagency conservation 

and restoration actions on BLM managed land as 

they become available.

a) Identify and implement a standardized, 

statistically sound bull trout population 

monitoring program on BLM-managed land. 

Increase bull trout surveys to locate and 

assess bull trout spawning habitats on BLM 

land.

b) Coordinate and evaluate scientific data 

collection to determine seasonal movement 

patterns and habitat use of migratory bull trout 

on BLM-managed land.

c) Determine basic genetic and resident and 

migratory life history characteristics for bull 

trout on BLM-managed land.

d) Determine range of water temperature 

tolerances for bull trout life stages and life 

history forms on BLM-managed land.

Habitat Condition Assessment

1) Cooperate with other Federal and State 

agencies as BLM staffing and budgets allow. 

Support opportunities for interagency conservation 

and restoration actions on BLM managed land as 

they become available.

a) Assess, restore and maintain riparian habitat 

and stream channels on BLM-managed land. 

Minimize stream channel degradation on BLMmanaged land.

b) Assess and reduce sources of thermal loading, 

sediment delivery, and nutrient delivery to 

streams on BLM-managed land. Reduce 

instream and riparian wood harvest on BLMmanaged land. Determine the effect of water 

withdrawals on stream temperatures and flows 

on streams.

c) Work cooperatively with DEQ and NDEP to 

attain water quality objectives for streams on 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-167

Conservation Measures BLM Implementation Actions

BLM-managed land.

Habitat Restoration

1) Cooperate with other Federal and State 

agencies as BLM staffing and budgets allow. 

Support opportunities for interagency conservation 

and restoration actions on BLM managed land as 

they become available.

a) Assess habitat restoration techniques and 

effectiveness on BLM managed land. 

b) Assess and minimize livestock grazing and 

recreation related impacts on BLM managed 

lands.

c) Assess suitability of degraded and unoccupied 

habitats for expanding distribution and 

abundance of bull trout on BLM managed land.

Critical Habitat for Bull Trout

The FWS has identified Primary Constituent Elements (PCEs) as those physical and biological features 

essential to the conservation of the species, and within areas occupied by the species at the time of 

listing, that may require special management considerations and protection (Endangered and Threatened 

Wildlife and Plants, 2010). These include space for individual and population growth and for normal 

behavior; food, water, air, light, minerals or other nutritional or physiological requirements; cover or 

shelter; sites for breeding, reproduction, rearing of offspring; and habitats that are protected from 

disturbance or are representative of the historic geographical and ecological distributions of a species. 

The PCEs and their associated matrix indicator are displayed in Table E-6.

The FWS evaluates the impacts of activities on critical habitat for bull trout by determining the impact of 

the activity on the PCEs of critical habitat. The impacts of BLM land management activities were 

evaluated using the Bull Trout Matrix of Pathways and Indicators (matrix) (FWS, 1998). The matrix of 

pathways and indicators for Jarbidge River bull trout is displayed in Appendix D, Table D-1). The matrix 

indicators correspond to the critical habitat for bull trout PCEs. The matrix contains 23 indicators, four of 

which are tied to subpopulation characteristics and 19 of which are tied to habitat. Twenty of the 23 

indicators are directly or indirectly related to one or more of the nine PCEs, and each PCE corresponds to 

one or more indicators. Essentially, if an action results inpacts to one of the 23 indicators in the matrix, 

than at least one of the PCEs for critical habitat would also be impacted.

Table E-6. PCEs for Critical Habitat for Bull Trout and the Associated Matrix Indicators.

PCE PCE Description Associated Matrix Indicators

1 

Springs, seeps, groundwater sources, and 

sub-surface water to contribute to water 

quality and quantity as a cold water 

source.

Floodplain connectivity, sediment, substrate 

embeddedness, chemical contamination and 

nutrients, off-channel habitat, streambank 

condition, change in peak/base flows, increase in 

drainage network, road density and location, 

disturbance history, riparian conservation areas, 

and refugia. 

2 

Migratory corridors with minimal physical, 

biological, or water quality impediments 

between spawning, rearing, overwintering, 

and foraging habitats, including intermittent 

or seasonal barriers induced by high water 

temperatures or low flows.

Physical barriers, substrate embeddedness, 

average wetted width/maximum depth ratio, 

change in peak/base flows, persistence and 

genetic integrity, temperature, chemical 

contamination and nutrients, and refugia. 

3 

An abundant food base, including 

terrestrial organisms of riparian origin, 

aquatic macro invertebrates, and forage 

fish. 

Sediment, substrate embeddedness, chemical 

contamination/nutrients, large woody debris, offchannel habitat, floodplain connectivity, 

streambank condition, riparian conservation 

areas, and refugia. 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-168

PCE PCE Description Associated Matrix Indicators

4 

Complex stream channels with features 

such as woody debris, side channels, 

pools, and undercut banks to provide a 

variety of depths, velocities, and instream 

structures. 

Sediment, substrate embeddedness, large woody 

debris, pool frequency and quality, large pools, 

off-channel habitat, average wetted 

width/maximum depth ratio, streambank condition, 

riparian conservation areas, floodplain 

connectivity, road density and location, 

disturbance regime, and refugia. 

5 

Water temperatures that support bull trout 

use. Bull trout have been documented in 

streams with temperatures from 32 to 72°F 

(0 to 22°C) but are found more frequently 

in temperatures ranging from 36 to 59°F (2 

to 15 °C). These temperature ranges may 

vary depending on bull trout life history 

stage and form, geography, elevation, 

diurnal and seasonal variation, shade, 

such as that provided by riparian habitat, 

and local groundwater influence. 

Temperature, off-channel habitat, floodplain 

connectivity, average wetted width/maximum 

depth ratio, streambank condition, change in 

peak/base flows, road density and location, 

disturbance history, riparian conservation areas, 

and refugia. 

6 

Substrates of sufficient amount, size, and 

composition to ensure success of egg and 

embryo overwinter survival, fry emergence, 

and young-of-the-year and juvenile 

survival. This should include a minimal 

amount of fine substrate less than 0.25 

inch in diameter. The size and amounts of 

fine sediment suitable to bull trout will likely 

vary from system to system.

Sediment, substrate embeddedness, streambank 

condition, riparian conservation areas, floodplain 

connectivity, increase in drainage network, road 

density and location, disturbance regime, and 

refugia. 

7 

A natural hydrograph, including peak, high, 

low, and base flows within historic ranges 

or, if regulated, that operates under a 

Biological Opinion that addresses bull trout 

or a hydro graph that demonstrates the 

ability to support bull trout populations by 

minimizing daily and day-to-day 

fluctuations and minimizing departures 

from the natural cycle of flow levels 

corresponding with seasonal variation. 

Change in peak/base flows, streambank 

condition, floodplain connectivity, increase in 

drainage network, road density and location, 

disturbance history, riparian conservation areas, 

and refugia. 

8 

Permanent water of sufficient quantity and 

quality such that normal reproduction, 

growth, and survival are not inhibited.

Temperature, chemical contamination/nutrients, 

streambank condition, riparian conservation 

areas, floodplain connectivity, increases in 

drainage network, road density and location, 

disturbance regime, and refugia. 

9 

Sufficiently low levels of occurrence of 

non-native predatory (e.g., lake trout, 

walleye, northern pike, smallmouth bass); 

interbreeding (e.g., brook trout); or 

competing (e.g., brown trout) species that, 

if present, are adequately temporally and 

spatially isolated from bull trout.

Persistence and genetic integrity. 

The BLM consults with the FWS on actions that may affect Endangered Species Act (ESA)-listed species 

or their habitat according to the Streamlined Consultation Procedures for Section 7 of the Endangered 

Species Act (USFS et al., 1999). Actions that “may affect, but are not likely to adversely affect” ESA-listed 

species or their habitat are implemented under letters of concurrence provided by the FWS. Actions that 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-169

“may affect, and are likely to adversely affect” ESA-listed species or their habitat are implemented under 

FWS Biological Opinions which include reasonale and prudent measures and mandatory terms and 

conditions that are to be applied to implemented actions to avoid jeopardizing the species. There are 

three Bioloical Opinions for bull trout and their critical habitat in the Jarbidge planning area; one is for 

stream crossing replacements and the other is for livestock trailing. The terms and conditions specific to 

these consultations are displayed in Table E-7. This list of terms and condition is dynamic and subject to 

change with future actions that may result in adverse impacts to ESA-listed species or their habitat.

Table E-7 Conservation Measures for Jarbidge River Bull Trout Derived from ESA Consultation

Reasonable and Prudent Measures Terms and Conditions

Biological Opinion – Restoration Activities at Stream Crossings (Stream Crossing Programmatic; 

Terms and Conditions) 

1) Minimize incidence of take and site 

disturbance during stream crossing 

installations and replacement.

1) Ensure the stream crossing project design team seeks 

input and agreement from the Level 1 team during the design 

process and during pre-project reviews. The project design 

team shall remain flexible in the design process in order to 

adapt to various and unique site conditions and ensure the 

likelihood that completed projects meet programmatic 

objectives.

2) Minimize the incidence of take that 

occurs as a result of programmatic 

stream crossing replacements.

2) Ensure the following:

a) Implement the following best management practices in 

addition to implementing all programmatic activities 

consistent with the project design criteria, activity types, 

and mitigation measures presented in the proposed 

action:

i). Determine, based on site characteristics, whether or 

not reducing streamflow in order to passively move 

fish out of the construction site prior to 

electroshocking would reduce the potential for take 

of bull trout associated with electroshocking. 

Prioritize this passive movement of fish as 

appropriate.

ii). Electroshocking, where utilized, will be conducted 

with a three pass methods to ensure the greatest 

level of fish salvage unless previously approved by 

the Level 1 Team to perform more or fewer passes.

iii). Ensure that holding conditions for any transported 

fish provide the lowest level of stress to captures 

individuals by ensuring the availability of cold, well 

oxygenated water in holding vessels, minimizing 

holding time, and avoiding any predation in holding 

vessels. To avoid predation, consider separate 

holding vessels for different age classes of bull trout.

iv). While block nets are set, inspect them regularly for 

fish and remove any living to an area far enough 

away from the crossing to void additional 

impingement risk.

v). Stream dewatering is not expected to last more than 

two weeks. If site specific conditions require 

dewatering and diverting the stream channel for 

longer than two weeks, Level 1 teams shall be 

consulted to determine if additional measures are 

necessary to ensure that project effects are within 

those described in the Biological Opinion (BO). 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-170

Reasonable and Prudent Measures Terms and Conditions

vi). For project in bull trout spawning and rearing habitat, 

if instream work is required, it shall be completed by 

August 15th and instream work may not commence 

until May 1, to avoid potential effects to spawning 

bull trout, eggs, alevins, and fry. If site specific 

information and rationale shows that these time 

frames can be adjusted without additional harm to 

bull trout, the Level 1 team has the discretion to do 

so. Rationale for work in spawning areas in the 

spring prior to May 1 should also include site specific 

survey data that indicates bull trout dis not span 

there the previous year.

b) The NOAA (2009) guidelines shall be used for any 

installation of treated wood if copper or creosote-based 

treatments are used. For other treated wood products, 

adhere to guidelines in Preservative-Treated Wood and 

Alternative Products in the Forest Service (Groenier and 

Lebow, 2006) and Best Management Practices for the 

Use of Treated Wood in Aquatic Environments (Western 

Wood Preservers Institute, 1996).

c) Survey all proposed ford sites prior to design and 

implementation to evaluate the stream for potential bull 

trout spawning habitat and to ensure project design does 

not promote spawning at or immediately downstream of 

the proposed ford site.

d) Provide Level 1 Teams with a written rationale statement 

(attached to project checklist) supporting any 

determination that overall impacts to stream channels will 

be reduced at crossing sites proposed for conversion to 

a ford.

e) If a temporary crossing is needed, the project design 

team will ensure that the designated temporary crossing 

area minimizes effects to bull trout and critical habitat.

i). Provide Level 1 Teams with a written rationale 

statement (attached to the pre-project checklist) as to 

why the temporary crossing is necessary and what 

steps are being taken to ensure effects are 

minimized.

ii). The area shall be cleared of bull trout prior to 

equipment crossing, and the block nets will be 

removed immediately after equipment crosses.

iii). Minimize the frequency of crossings by equipment: 

only allow equipment and vehicles to cross that are 

absolutely necessary.

iv). Width of temporary crossings will be approximately 

14 feet wide, the average road width of Forest 

Service roads.

3) Establish a monitoring plan to confirm 

projects implemented under the 

programmatic BO meet the objectives of 

the programmatic BO and are also not 

exceeding the amount and/or extent of 

take from permitted activities.

a) Ensure the following:

i). All captured, handled and killed ESA-listed fish shall 

be identified, counted, and reported on the “postproject checklist” in Appendix A of the BO. 

ii). The BLM will implement a suspended 

sediment/turbidity monitoring program. Under the 

monitoring plan, a reasonable sample of project 

implemented under this consultation will be assessed 
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A-171 

Reasonable and Prudent Measures Terms and Conditions

to assure that the incidental take associated with 

suspended sediment and exempted in the BO has 

not been exceeded. At a minimum, 25 percent of the 

project completed under the BO will have monitoring 

completed that assesses the duration and intensity of 

turbidity. Monitoring can be adjusted as needed, but 

should consider the following recommendations:

a. Monitoring should occur above the site once for 

reference conditions before project begins and 

prior to stream re-watering.

b. Monitoring should occur below the construction 

site where the bypass or stream diversion enters 

the stream and 600 feet below the site. 

Alternative sites may be chosen if 600 feet is 

excessive for a particular site.

c. Measurements shall be recorded at the following 

times: 

i. Prior to re-watering the stream and

ii. Every 30 minutes after re-watering for 4 

hours or until turbidity decreases to 

background levels.

Biological Opinion - Bureau of Land Management Ongoing Actions and Livestock Trailing – Bull 

Trout Critical Habitat – Benewah, Bonner, Boundary, Kootenai, Owyhee, and Shoshone Counties, 

Idaho and Elko County, Nevada

1) Minimize the potential for harassment 

of bull trout and disruption of riparian 

and aquatic habitat from project 

activities.

1) Ensure the following:

a) Livestock trailing activities occur as described in the 

livestock trailing EA (DOI-BLM-ID-T010-2012-0004-

EA) and associated trailing permits.

b) Individual livestock stream crossing events shall be 

completed in the minimum amount of time possible 

within the allowable 1 hour stream crossing time 

window.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-172

Columbia Spotted Frog

Table E-8. Conservation Measures and Implementation Actions for Columbia Spotted Frog.

Conservation Measures BLM Implementation Actions

Special Status Animal and Plant Management: Common to All Programs

1) In cooperation with Idaho Department of Fish 

and Game (IDFG), US Fish and Wildlife Service 

(FWS), and others:

1) Following actions to be completed in 

cooperation with others:

a) Continue to cooperate to identify and map all 

known populations and suitable habitat.

a) Mapping and data inventory:

i). Use Idaho Natural Heritage Program and 

other data to identify, record, and map 

known populations and suitable habitat on 

BLM managed land.

ii). Participate in surveys and map new 

populations as found. Systematic 

inventories will continue to be conducted in 

cooperation with other agencies.

iii). Maintain a spatial database of species 

population and habitat information for BLM 

managed lands.

b) Following current monitoring protocols,

cooperate in monitoring Columbia spotted frog 

population trends and habitat conditions.

b) Continue to cooperate with IDFG and FWS to 

conduct regular monitoring of populations on 

BLM managed lands.

c) Promote species conservation by maintaining 

or improving habitat conditions in occupied 

sub-watersheds.

c) Habitat management and species conservation 

in occupied sub-watersheds:

i). Develop and implement habitat 

management plans for sub-watersheds, as 

funding allows. 

ii). Identify barriers or impediments to 

seasonal movements or dispersal. This 

could include nonfunctioning stream 

sections or poor watershed conditions 

adjacent to suitable habitat within the 

scope of the sub-watershed plans.

iii). Identify restoration areas where habitat

improvements will be emphasized within 

the scope of the sub-watershed plans.

iv). Cooperate with IDFG and others to 

improve habitat, as funding and 

opportunities allow.

d) Cooperate to expand the distribution of

Columbia spotted frogs.

d) Cooperate with IDFG and others to reintroduce 

spotted frogs into suitable habitat.

e) Participate in research essential to recovery of 

the species. Cooperate in determining specific 

limiting factors in terms of habitat needs and 

characteristics. Cooperate in population 

viability analyses.

e) BLM will participate as funding allows.

2) Ensure that ongoing Federal actions support 

species conservation.

2) Ongoing BLM activities:

a) As needed, review ongoing activities in areas 

with known populations and associated 
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A-173

Conservation Measures BLM Implementation Actions

suitable habitat.

b) Determine if direct or indirect negative impacts 

to the species or its habitat are occurring as a 

result of ongoing discretionary BLM actions. If 

so, modify the activity to avoid or minimize 

anticipated negative impacts and, where 

feasible, promote species conservation.

3) Ensure that new Federal actions support or do 

not preclude species conservation.

3) New BLM activities:

a) Project-level inventories will be completed 

using currently accepted survey protocols in 

suitable habitat during project planning if 

inventory information is not available or

adequate. 

b) If direct or indirect negative impacts to the 

species or its habitat are anticipated as a result 

of new BLM actions, modify the activity to 

avoid or minimize negative impacts and, where 

feasible, promote species conservation.

4) Implement adaptive management as needed to 

achieve conservation objectives.

4) Conduct site-specific implementation and 

effectiveness monitoring. Adjust management as 

needed to ensure that management objectives are 

met.

5) Support conservation easements, cooperative 

management efforts, and other programs on 

adjacent non-Federal lands to support 

conservation of the Columbia spotted frog.

5) Take advantage of opportunities as they arise.

Air Resources

None None

Soil and Water Resources: Riparian/ Wetland Areas (includes noxious weed management)

1) Projects involving the application of pesticides 

(herbicides, insecticides, etc.) that may affect the 

species will be analyzed at the project level and 

designed such that pesticide applications will 

support conservation and minimize risks of 

exposure.

1) Site-specific stipulations will be developed 

locally using the following criteria:

a) Evaluate the benefits and risks of vegetation 

treatment, including the following: application 

methods; pesticides, carriers, and surfactants 

used; needed treatment buffers; and use of 

non-chemical weed control (for example, biocontrols, hand pulling). If objectives can be 

effectively accomplished using non-chemical 

methods, such is the preferred alternative.

b) Apply appropriate spatial and temporal buffers 

to avoid species’ exposure to harmful 

chemicals.

c) Implement appropriate revegetation and 

noxious weed control measures to reduce the 

risks of non-native species infestations 

following any ground/soil-disturbing actions in 

or near suitable habitat within occupied subwatersheds.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-174

Conservation Measures BLM Implementation Actions

2) Where needed and feasible, coordinate with 

adjacent landowners and local governments 

regarding control of noxious weeds and invasive 

plants in occupied sub-watersheds through 

cooperative weed management programs.

2) Take advantage of opportunities as they arise.

3) Conserve and, where possible, enhance 

watershed conditions for Columbia spotted frogs to 

prevent soil erosion, promote riparian health, and 

prevent negative impacts to water quality.

3) Implementation actions in occupied subwatersheds:

a) Identify riparian and upland areas with 

unsuitable watershed conditions near occupied 

habitat. Restore to improve habitat and habitat 

connectivity.

b) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and 

sediment delivery are high.

c) Seek opportunities, as funding allows, to 

expand suitable habitat by restoring riparian 

and wetland habitats.

Upland Vegetation Management: Rangelands (includes noxious weed management)

1) Within occupied sub-watersheds, projects 

involving the application of pesticides in uplands 

adjacent to riparian areas that provide suitable 

Columbia spotted frog habitat or in restoration 

areas will be designed and implemented in 

accordance with the approach described in the Soil 

and Water Resources: Riparian/Wetland Areas 

program section.

1) See Soil and Water Resources:

Riparian/Wetland Areas program section.

2) Protect upland areas adjacent to riparian areas 

where management activities could affect known 

populations.

2) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and sediment 

delivery to suitable habitat are high. 

Forest and Woodland Management

1) Manage woodland areas adjacent to riparian 

areas where management activities could affect 

suitable habitat and restoration areas.

1) Implementation actions in occupied subwatersheds:

a) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and 

sediment delivery to suitable habitat are high.

b) Control juniper that encroach into suitable 

habitat or restoration areas if the trees are 

affecting spring recharge or degrading 

Columbia spotted frog habitat.

Wildlife and Wildlife Habitat Management 

1) Cooperate in protecting Columbia spotted frogs 

from competition and predation.

1) Work with IDFG to avoid introduction of

competitive or predatory species into subwatersheds with known populations of Columbia 

spotted frogs. Cooperate in seeking opportunities 

to remove non-native competitive or predatory 

species (for example, bullfrogs) from subwatersheds with known populations of Columbia 

spotted frogs.

2) Cooperate in creating opportunities for Columbia 

spotted frog occupancy by enhancing habitat.

2) Work with IDFG to transplant beavers to 

enhance suitable habitat and restoration areas in 

occupied sub-watersheds, where appropriate.
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A-175

Conservation Measures BLM Implementation Actions

Fish and Aquatic Habitat Management

1) Cooperate with IDFG in protecting Columbia 

spotted frogs from competition and predation by 

non-native species.

1) If needed, work with IDFG to avoid introduction 

of competitive or predatory species into watersheds 

with known populations of Columbia spotted frogs. 

Cooperate in seeking opportunities to remove nonnative competitive or predatory species (for 

example, smallmouth bass) from watersheds with 

known populations of Columbia spotted frogs.

Livestock Grazing Management: Permits and Leases

1) Manage livestock grazing and trailing to promote 

healthy riparian communities in sub-watersheds 

occupied by Columbia spotted frogs. Maintain and 

promote suitable habitat and restore areas for the 

Columbia spotted frog while implementing 

rangeland health standards and guidelines. 

1) Permit or lease renewal actions:

a) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). In unsurveyed suitable habitat, 

schedule surveys so Columbia spotted frog 

occurrence information is available for

rangeland health assessments associated with 

permit and lease renewals.

b) For new actions, see Special Status Animal 

and Plant Management program section item 

(3).

c) As appropriate to avoid or minimize negative 

impacts, modify livestock grazing permits and 

leases.

2) Promote restoration of suitable habitat following 

fire, fire rehabilitation, restoration treatments, or 

other major disturbances.

2) As needed to protect disturbed areas in 

occupied sub-watersheds, use temporary closures 

or other measures until desired riparian or wetland 

vegetation species are re-established and selfsustaining.

3) Maintain regular compliance checks on grazing 

allotments with known populations to identify 

problems as soon as possible and take immediate 

corrective measures.

3) Ongoing, day-to-day BLM action.

Livestock Grazing Management: Livestock Management Facilities

1) Manage livestock facilities to promote healthy 

riparian communities. Maintain and promote 

suitable habitat and restore areas for the Columbia 

spotted frog while implementing rangeland health 

standards and guidelines. 

1) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). For new actions, see Special 

Status Animal and Plant Management program 

section item (3).

a) As appropriate to avoid or minimize negative 

impacts to Columbia spotted frogs in occupied 

sub-watersheds, modify existing and avoid 

placement of new livestock facilities in or 

adjacent to areas with known populations.

b) Protect hibernacula and water sources from 

spring or other water developments in 

occupied sub-watersheds unless the activity 

will have beneficial long-term or neutral effects 

on Columbia spotted frogs and their habitat.

c) Construct livestock exclosures to protect locally 

important habitats in occupied sub-watersheds. 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-176

Conservation Measures BLM Implementation Actions

Wild Horse Management

1) If the range of wild horses and Columbia spotted 

frogs is found to overlap in the future, protect 

suitable habitat areas in occupied sub-watersheds 

from damage by wild horses by including 

applicable conservation measures in herd 

management plans.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Recreation Management

1) Developed facilities (boat access, paved 

campgrounds, vault toilets, interpretive kiosks, 

etc.): Manage existing and new recreation facilities 

so as not to preclude species habitat conservation. 

This includes management of the physical facilities, 

as well as disturbances to the species resulting 

from human uses.

1) Management of existing and new facilities in 

occupied sub-watersheds:

a) For review of existing facilities, see Special 

Status Animal and Plant Management program 

section item (2). As appropriate to avoid or 

minimize negative impacts, modify existing 

facilities.

b) For new facilities, or for expansion of uses at 

existing facilities, see Special Status Animal 

and Plant Management program section item 

(3). In addition, avoid development of new 

recreation facilities or expansion of existing 

facilities in or adjacent to areas with known 

populations, if negative impacts are 

anticipated.

2) Dispersed use areas (informal areas, including 

camping areas and tie-up areas for pack animals 

and boats): Manage dispersed use sites so as not 

to preclude species and habitat conservation. This 

includes limiting disturbances to species habitat 

resulting from human uses.

2) For review of ongoing activities, see Special 

Status Animal and Plant Management program 

section item (2). In addition, minimize human 

activity in and adjacent to known populations, if 

negative impacts are occurring. Close areas, either 

seasonally or year-round, as needed to protect the 

species and its habitat, and post and monitor the 

closure.

3) Commercial and non-commercial recreation 

permits, including outfitter camps: Issue 

commercial and non-commercial recreation permits 

so as not to preclude species habitat conservation. 

This includes management of physical facilities 

(such as camps), as well as disturbances to habitat 

resulting from human uses.

3) Issuance and review of existing and new permits 

in occupied sub-watersheds: 

a) For review of existing permits, see Special 

Status Animal and Plant Management program 

section item (2). If needed, modify existing 

permits if the permitted activity is causing 

negative impacts.

b) For new permits, see Special Status Animal 

and Plant Management program section item 

(3). Avoid issuing recreation permits in and 

adjacent to areas with known populations if 

negative impacts are expected. If a recreation 

permit is to be issued, apply stipulations to the 

permit to support or to not preclude species 

conservation.
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A-177

Conservation Measures BLM Implementation Actions

4) Coordinate with the IDFG to educate the public 

on the frog’s unique ecological requirements, 

sensitivity to habitat alteration, and need for 

protection in order to reduce recreation impacts 

and stop collection of frogs.

4) Take advantage of opportunities as they arise.

Recreation Management: Travel Management

1) Manage roads, off-highway vehicle (OHV) routes 

and areas, as well as non-motorized trails, so as 

not to preclude species habitat conservation. This 

includes management of physical facilities, as well 

as disturbances to habitat resulting from human 

uses.

1) Review of existing and new roads, OHV routes 

and areas, and non-motorized trails in occupied 

sub-watersheds:

a) For existing roads, designated OHV routes and 

areas, and designated non-motorized trails, 

see Special Status Animal and Plant 

Management program section item (2). Modify 

routes in and adjacent to areas with known 

populations if negative impacts are occurring. 

Seek opportunities to close and revegetate 

roads, OHV routes, or non-motorized trails and 

use areas in and adjacent to suitable habitat, if 

negative impacts are occurring.

b) For new roads, OHV routes and areas, and 

non-motorized trails, see Special Status Animal 

and Plant Management program section item 

(3). Avoid constructing new roads, trails, 

routes, and areas in suitable habitat if negative 

impacts to riparian or wetland habitat are 

expected. In particular, avoid opening new 

roads, trails, routes, and areas adjacent to 

suitable habitat particularly susceptible to 

erosion and thus sediment delivery to suitable 

habitat.

2) Maintain regular compliance checks on OHV 

closures to protect suitable habitat and to identify 

problems as soon as possible and take immediate 

corrective measures.

2) Ongoing, day-to-day BLM activities.

Visual Resource Management

None None

Special Designation Area Management

1) Explore the potential for new designations that 

would enhance species conservation, such as 

healthy riparian and emergent aquatic vegetation.

1) Take advantage of opportunities as they arise.

Fire Management: Fire Suppression

1) Fire suppression efforts will be conducted, as 

possible, to protect occupied Columbia spotted frog 

habitat.

1) Fire management activities in occupied subwatersheds:

a) Review Fire Management Plan for adequacy in 

addressing conservation measures. Modify the 

plan if needed.

b) Apply Minimum Impact Suppression Tactics 

(MIST) in suitable habitat, as appropriate. 

Consult with resource advisors to determine 

where MIST tactics should be applied to avoid 

or minimize negative impacts.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-178

Conservation Measures BLM Implementation Actions

c) Avoid fire base camps, staging areas, fueling 

areas, or other related activities in or adjacent 

to areas with known populations.

d) Avoid drawing water from springs, streams, 

and ponds occupied by Columbia spotted frogs 

unless required to do so to protect life or 

property.

2) Coordinate with Idaho Department of Lands or 

other applicable agency personnel regarding fire 

suppression activities in or near suitable habitat. 

2) Ongoing interagency coordination.

Fire Management: Emergency Stabilization and Burned Area Rehabilitation

1) Implement Emergency Stabilization and Burned 

Area Rehabilitation (ES&BAR) activities to promote 

spotted frog habitat rehabilitation.

1) ES&BAR activities in occupied sub-watersheds:

a) If needed and if natural recovery would not 

achieve habitat objectives, implement ES&BAR

activities to promote rehabilitation of suitable 

habitat. In areas where the natural drainage 

regime has been altered, plant locally 

appropriate vegetation to reestablish suitable 

habitat.

b) As needed, protect disturbed areas using 

temporary closures or other measures until 

riparian vegetation is re-established and selfsustaining.

2) Fire rehabilitation projects involving the

application of pesticides will be analyzed and 

implemented in accordance with the approach 

described in the Soil and Water Resources: 

Riparian/Wetland Areas program section.

2) See Soil and Water Resources:

Riparian/Wetland Areas program section.

Fire Management: Wildland Fire Use

1) Wildland fire use projects (where allowed) will be 

designed to conserve suitable Columbia spotted 

frog habitat.

1) When developing wildland fire use plans in 

occupied sub-watersheds, avoid burning in and 

adjacent to suitable habitat and develop burn 

prescriptions that promote habitat conservation.

Fire Management: Prescribed Fire

1) Prescribed fire projects will be designed to 

conserve suitable Columbia spotted frog habitat.

1) When developing and implementing prescribed 

fire plans, avoid or minimize negative impacts to 

suitable habitat, and use prescribed fire as a tool 

for assisting with species conservation. Consider 

allowing prescribed fires to burn in and adjacent to 

suitable habitat if it is likely to benefit Columbia 

spotted frog habitat or have a neutral effect. 

Management actions in occupied sub-watersheds:

a) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and 

sediment delivery to suitable habitat are high.

b) Control juniper that encroach into suitable 

habitat or restoration areas, if the trees are 

affecting spring recharge or degrading 

Columbia spotted frog habitat.
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Conservation Measures BLM Implementation Actions

Fire Management: Non-Fire Fuels Management

1) Implement projects involving the application of 

pesticides in accordance with the approach 

described in the Soil and Water Resources: 

Riparian/ Wetland Areas program section.

1) See Soil and Water Resources:

Riparian/Wetland Areas program section.

2) Non-fire fuels management projects will be 

designed to conserve Columbia spotted frog 

habitat.

2) Incorporate conservation actions into the fuels 

projects, as needed. Avoid non-fire fuels 

management activities in or adjacent to suitable 

habitat, if negative impacts may occur. 

Management actions in occupied sub-watersheds:

a) Emphasize soil stabilization and avoid ground 

disturbance when risks of erosion and 

sediment delivery to suitable habitat are high.

b) Control juniper that encroach into suitable 

habitat or restoration areas if the trees are 

affecting spring recharge or degrading 

Columbia spotted frog habitat.

Fire Management: Community Assistance

1) Follow all measures included throughout the Fire 

Management program sections.

1) See actions within Fire Management program 

sections. Incorporate into community assistance 

agreements.

Lands and Realty Management: Land Tenure Adjustment (sale, exchanges, withdrawals, etc.)

1) Where feasible and funding is available, acquire 

through land exchange or purchase private lands in 

suitable habitat areas that could enhance habitat 

for Columbia spotted frogs.

1) Take advantage of opportunities as they arise. 

Priority should be given to lands that are adjacent 

to or near public lands and/or a population 

occurring on BLM and private lands.

2) Retain spotted frog habitat in Federal ownership 

to the extent possible, while balancing other needs.

2) Review each land tenure decision in terms of 

species habitat. Retain areas with known 

populations in public ownership unless compelling 

circumstances necessitate the land tenure 

adjustment. Avoid the loss of suitable habitat from

Federal ownership. If property with known 

populations is to be transferred out of Federal 

ownership, permanent conservation easements 

may be attached to the transfer that would result in 

equal or greater protection than under Federal 

management. Such measures must be approved 

by the State Director.

Lands and Realty Management: Land Use Permits and Leases

1) Issue new land use permits and leases and 

review existing permits and leases at renewal so as 

not to preclude species habitat conservation. This 

includes management of physical facilities, as well 

as disturbances to the species or its habitat 

resulting from human uses.

1) For new permits and renewal of existing permits, 

see Special Status Animal and Plant Management 

program section item (3). In occupied subwatersheds avoid issuing new permits or leases, or 

renewing existing permits or leases, in or adjacent 

to areas with known populations if negative 

impacts are expected. If a permit or lease is to be 

issued or reissued in suitable habitat, apply 

stipulations to the permit that promote species 

conservation and that avoid or minimize negative 

impacts.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-180

Conservation Measures BLM Implementation Actions

2) Protect the groundwater sources that contribute 

to Columbia spotted frog habitat.

2) In occupied sub-watersheds, conduct 

appropriate hydrologic studies or analysis before 

permitting developments on BLM-managed lands 

where the extraction of groundwater may reduce or 

eliminate water in suitable habitat. Depending on 

the scope of the activity, this may require 

coordination and cooperation with other agencies.

Lands and Realty Management: Rights-of-Way

1) Issue new rights-of-way (ROWs) and review

existing ROWs at renewal so as not to preclude 

species habitat conservation. This includes 

management of physical facilities, as well as 

disturbances to the species resulting from human 

uses.

1) For new ROWs and renewal of existing ROWs, 

see Special Status Animal and Plant Management

program section item (3). In occupied subwatersheds, avoid issuing ROWs, or renewing 

existing ROWs, in or adjacent to suitable habitat if 

negative impacts are expected. If a ROW is to be 

issued or re-issued, apply stipulations to the ROW

that support or do not preclude species 

conservation and that avoid or minimize negative 

impacts.

Mineral Management: Locatable Minerals 

1) Approve plans of operations or allow notice-level 

operations so as not to preclude species habitat 

conservation. This includes management of 

physical facilities, as well as disturbances to the 

species resulting from human uses.

1) Approval of plans of operations and notice-level 

operations:

a) For review of existing plans of operation and 

notice-level operations, see Special Status 

Animal and Plant Management program 

section item (2). To the extent allowed by law, 

in occupied sub-watersheds modify plans of 

operation or notice-level operations that conflict 

with Columbia spotted frog objectives in 

suitable habitat. For notice-level operations, 

notify the operator that modifications to 

proposed activities will be required to avoid 

negative impacts.

b) For new plans of operation and notice-level 

operations, see Special Status Animal and 

Plant Management program section item (3).

To the extent allowed by law, in occupied subwatersheds avoid approving plans of operation 

or notice-level operations that conflict with 

Columbia spotted frog objectives in suitable 

habitat. For notice-level operations, notify the 

operator that modifications to proposed 

activities will be required to avoid negative 

impacts. If a plan of operations is to be 

approved in suitable habitat, apply stipulations 

to conserve Columbia spotted frogs. A notice 

will require modification by the operator until 

BLM determines that it will not result in undue 

or unnecessary degradation.

Mineral Management: Salable and Leasable Minerals 

1) Approve plans of operations or allow notice-level 

operations so as not to preclude species habitat 

conservation. This includes management of 

physical facilities, as well as disturbances to the 

1) Approval of plans of operations and notice-level 

operations:

a) For review of existing plans of operation and 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-181

Conservation Measures BLM Implementation Actions

species resulting from human uses. notice-level operations, see Special Status 

Animal and Plant Management program 

section item (2). To the extent allowed by law, 

in occupied sub-watersheds modify plans of 

operation or notice-level operations that conflict 

with Columbia spotted frog objectives in 

suitable habitat. For notice-level operations, 

notify the operator that modifications to 

proposed activities will be required to avoid 

negative impacts.

b) For new plans of operation and notice-level 

operations, see Special Status Animal and 

Plant Management program section item (3). 

To the extent allowed by law, in occupied subwatersheds avoid approving plans of operation 

or notice-level operations that conflict with

Columbia spotted frog objectives in suitable 

habitat. For notice-level operations, notify the 

operator that modifications to proposed 

activities will be required to avoid negative 

impacts. If a plan of operations is to be 

approved in suitable habitat, apply stipulations 

to conserve Columbia spotted frogs. A notice 

will require modification by the operator until 

BLM determines that it will not result in undue 

or unnecessary degradation.

2) Protect the groundwater sources that contribute 

to Columbia spotted frog habitat.

2) Conduct appropriate hydrologic studies or 

analysis before permitting mineral extraction on 

BLM managed lands where the extraction of 

groundwater may reduce or eliminate flows in 

occupied sub-watersheds. Depending on the scope 

of the activity, this may require coordination and 

cooperation with other agencies.

Cultural Management

1) Activities within the Cultural Management

program will implement relevant conservation 

measures as described in the Special Status 

Animal and Plant Management program section to 

promote conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Paleontology

1) Activities within the Paleontology program will 

implement relevant conservation measures as 

described in the Special Status Animal and Plant 

Management program section to promote 

conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-182

Yellow-Billed Cuckoo

Table E-8. Conservation Measures and Implementation Actions for Yellow-Billed Cuckoo. 

Conservation Measures BLM Implementation Actions

Special Status Animal and Plant Management: Common to All Programs

1) In cooperation with Idaho Department of Fish 

and Game (IDFG), US Fish and Wildlife Service

(FWS), and others:

1) Following actions to be completed in

cooperation with others:

a) Continue to cooperate in determining the 

distribution of known populations and suitable 

habitats.

a) Mapping and data inventory:

i). Use IDFG, Idaho Natural Heritage 

Program, FWS, and other data to identify, 

record, and map known populations and 

suitable habitat on BLM managed lands.

ii). Maintain a spatial database of species

population and habitat information for BLM 

managed lands.

iii). Participate in surveys and map new

populations as found. Systematic 

inventories will continue to be conducted in 

cooperation with other agencies.

b) Follow current monitoring protocols and

continue to cooperate in monitoring for species 

presence on a regular basis.

b) Cooperate with IDFG and FWS to conduct 

regular monitoring of populations on BLM 

managed lands. Assist in documenting whether 

cuckoos are using habitats and the type of use.

c) Participate in research essential to 

conservation of the species. Cooperate in 

determining specific limiting factors in terms of 

habitat needs and characteristics.

c) BLM will participate as funding allows.

d) Cooperate in the management and

improvement of suitable habitat to promote 

species conservation.

d) Where appropriate, update or develop

management plans for suitable habitat,

particularly in areas with known populations, as 

well as in restoration areas.

e) Working with other agencies, compile a 

general list of BMPs that would apply to all 

programs, to the extent that such a list would 

assist with species and habitat conservation. 

The intent of implementing BMPs is to avoid or 

minimize negative impacts.

e) BMPs:

i). State Office to coordinate development of 

BMPs with Field Office, District Office,

FWS, and IDFG. Instruction memorandum 

to be issued by State Office. 

ii). Field Office to implement BMPs.

2) Ensure that ongoing Federal actions support or 

do not preclude species conservation.

2) Ongoing BLM activities:

a) Review ongoing activities in locations with 

known populations.

b) Determine if direct or indirect negative impacts 

to the species or its habitat are occurring as a 

result of ongoing discretionary BLM actions. If 

so, modify the activity to avoid or minimize 

negative impacts and, where feasible, promote 

species conservation.
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-183

Conservation Measures BLM Implementation Actions

3) Ensure that new Federal actions support or do 

not preclude species conservation.

3) New BLM activities:

a) Project-level inventories will be completed in 

suitable habitat during project planning if 

inventory information is not available or 

adequate. The State Office will issue 

instruction memorandum concerning special 

status species project-level inventories and 

assessment.

b) If direct or indirect negative impacts to the 

species or its habitat are anticipated as a result 

of new BLM actions, modify the activity to 

avoid or minimize negative impacts and, where 

feasible, promote species conservation.

c) Avoid implementing activities that have the 

potential to disturb or displace known

populations of cuckoos during the breeding 

season (May through September).

4) Implement adaptive management as needed to 

achieve conservation objectives.

4) Conduct site-specific implementation and 

effectiveness monitoring. Adjust management as 

needed to ensure that management objectives are 

met.

5) Support conservation easements, cooperative 

management efforts, and other programs on 

adjacent non-Federal lands to support 

conservation of the yellow-billed cuckoo.

5) Take advantage of opportunities as they arise.

Air Resources

None None

Soil and Water Resources: Riparian/ Wetland Areas (includes noxious weed management)

1) Projects involving the application of pesticides 

(herbicides, insecticides, etc.) that may affect the 

species will be analyzed at the project level and 

designed such that pesticide applications will 

support conservation and minimize risks of 

exposure.

1) Site-specific stipulations will be developed locally 

using the following criteria:

a) Evaluate the benefits and risks of vegetation 

treatment, including the following: application 

methods; pesticides, carriers, and surfactants 

used; needed treatment buffers; and use of 

non-chemical noxious weed control (for 

example, bio-controls, hand pulling). If 

objectives can be effectively accomplished 

using non-chemical methods, such is the

preferred alternative.

b) Apply appropriate spatial and temporal buffers 

to avoid species’ exposure to harmful 

chemicals.

c) Implement appropriate revegetation and

noxious weed control measures to reduce the 

risks of invasive plant species infestations 

following any ground/soil-disturbing actions in 

or near suitable habitat.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-184

Conservation Measures BLM Implementation Actions

2) Where needed and feasible, coordinate with 

adjacent landowners and local governments 

regarding control of noxious weeds and invasive 

plants in riparian areas through cooperative weed 

management programs.

2) Take advantage of opportunities as they arise.

3) Conserve riparian vegetation in suitable habitat 

(for example, healthy willow stands and cottonwood 

trees) to maintain their integrity for use by yellowbilled cuckoos, and initiate management in 

restoration areas.

3) Implementation actions:

a) Emphasize eradication of non-native invasive 

species in riparian areas that compete with 

willow and cottonwood tree regeneration. 

Continue to identify problem areas (such as 

false indigo) and implement appropriate 

noxious weed control measures.

b) Avoid issuing commercial firewood cutting 

permits in suitable habitats in riparian forests. If 

permits are issued, ensure that such activities 

are consistent with the long-term maintenance 

of suitable habitat and enhancement of 

restoration areas.

c) As needed, close suitable habitat in riparian 

forests to non-commercial firewood cutting and 

post the closure.

Upland Vegetation Management: Rangelands 

1) Projects involving the application of pesticides in 

uplands adjacent to suitable yellow-billed cuckoo 

habitat or in restoration areas will be designed and 

implemented in accordance with the approach 

described in the Soil and Water Resources: 

Riparian/Wetland Areas program section.

1) See Soil and Water Resources:

Riparian/Wetland Areas program section.

Forest and Woodland Management)

1) Projects involving the application of pesticides in 

forested areas and woodlands adjacent to suitable 

yellow-billed cuckoo habitat or in restoration areas 

will be designed and implemented in accordance 

with the approach described in the Soil and Water 

Resources: Riparian/Wetland Areas program 

section.

1) See Soil and Water Resources:

Riparian/Wetland Areas program section.

Wildlife and Wildlife Habitat Management 

1) In restoration areas, cooperate in creating 

opportunities for yellow-billed cuckoo occupancy by 

enhancing habitat.

1) Consider planting or other habitat enhancement 

measures to improve yellow-billed cuckoo habitat.

Fish and Aquatic Habitat Management

1) Activities within the Fish and Aquatic Habitat 

Management program will implement relevant 

conservation measures as described in the Special 

Status Animal and Plant Management program 

section to promote conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Livestock Grazing Management: Permits and Leases

1) Manage livestock grazing and trailing to promote 

growth and recruitment of healthy riparian 

vegetation communities (for example, willows and 

cottonwood trees). Maintain and promote suitable 

1) Permit or lease renewal actions:

a) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2).
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-185

Conservation Measures BLM Implementation Actions

habitat and restore areas for the yellow-billed 

cuckoo while implementing rangeland health 

standards and guidelines.

b) For new actions, see Special Status Animal 

and Plant Management program section item 

(3).

c) As appropriate to avoid or minimize negative 

impacts, modify livestock grazing permits and 

leases.

2) Promote restoration of suitable habitat following 

fire, fire rehabilitation, restoration treatments, or 

other major disturbances.

2) As needed, protect disturbed areas using 

temporary closures or other measures until the 

willow shrubs and cottonwood saplings (or other 

target riparian species) are re-established and selfsustaining.

3) Maintain regular compliance checks on grazing 

allotments with known populations to identify 

problems as soon as possible and take immediate 

corrective measures.

3) Ongoing, day-to-day BLM action.

Livestock Grazing Management: Livestock Management Facilities

1) Manage livestock facilities to promote healthy 

riparian vegetation communities (for example, 

willows and cottonwood trees). Maintain and 

promote suitable habitat and restore areas for the 

yellow-billed cuckoo while implementing rangeland 

health standards and guidelines. 

1) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). For new actions, see Special 

Status Animal and Plant Management program 

section item (3). As appropriate to avoid or 

minimize negative impacts, modify existing and 

avoid placement of new livestock facilities.

Wild Horse Management

1) Activities within the Wild Horse Management 

program will implement relevant conservation 

measures as described in the Special Status 

Animal and Plant Management program section to 

promote conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management

program section at the beginning of this table.

Recreation Management

1) Developed facilities (boat access, paved 

campgrounds, vault toilets, interpretive kiosks, 

etc.): Manage existing and new recreation facilities 

so as not to preclude species habitat conservation. 

This includes management of the physical facilities, 

as well as disturbances to the species resulting 

from human uses.

1) Management of existing and new facilities:

a) For review of existing facilities, see Special 

Status Animal and Plant Management program 

section item (2). As appropriate to avoid or 

minimize negative impacts, modify existing 

facilities.

b) For new facilities, or for expansion of uses or 

seasons of use at existing facilities, see 

Special Status Animal and Plant Management

program section item (3). In addition, avoid 

development of new recreation facilities or 

expansion of existing facilities in suitable 

habitat, if negative impacts are anticipated.

2) Dispersed use areas (informal areas, including 

camping areas and tie-up areas for pack animals 

and boats): Manage dispersed use sites so as not 

to preclude species habitat conservation. This 

includes limiting disturbances to the species 

resulting from human uses.

2) For review of ongoing actions, see Special 

Status Animal and Plant Management program 

section item (2). In addition, minimize human 

activity in suitable habitat if negative impacts are 

occurring. Close areas, either seasonally or yearround, as needed to protect the species and its 

habitat, and post and monitor the closure.
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-186

Conservation Measures BLM Implementation Actions

3) Commercial and noncommercial recreation 

permits, including outfitter camps: Issue 

commercial and non-commercial recreation permits 

in accordance with goals for promoting species 

habitat conservation. This includes management of 

physical facilities (such as camps), as well as 

disturbances to the species resulting from human 

uses.

3) Issuance and review of existing and new 

permits:

a) For review of existing permits, see Special 

Status Animal and Plant Management program 

section item (2). If needed, modify existing 

permits that conflict with achieving or 

maintaining suitable habitat conditions.

b) For new permits, see Special Status Animal 

and Plant Management program section item 

(3). Avoid issuing recreation permits if negative 

impacts are expected. Consider the seasonal 

nature of the proposed activities, and whether 

this conflicts with yellow-billed cuckoo 

conservation needs. In particular, avoid 

permitting new recreation activities in suitable 

habitat. If a recreation permit is to be issued, 

apply stipulations to the permit to support or to 

not preclude species conservation. 

4) Coordinate with the IDFG to educate recreation 

users at boat ramps and at designated camp areas 

about the need to conserve yellow-billed cuckoo 

habitat.

4) Take advantage of opportunities as they arise

Recreation Management: Travel Management

1) Manage roads, off-highway vehicle (OHV) routes 

and areas, as well as non-motorized trails, so as 

not to preclude species habitat conservation. This 

includes management of physical facilities, as well 

as disturbances to the species resulting from 

human uses.

1) Review of existing and new roads, OHV routes, 

and areas and non-motorized trails:

a) For existing roads, designated OHV routes and 

areas, and designated non-motorized trails, 

see Special Status Animal and Plant 

Management program section item (2). Modify 

routes in locations with known populations, if 

negative impacts are occurring. Evaluate the 

need for seasonal OHV use restrictions in 

suitable habitat and, if needed, implement

restrictions to reduce disturbance to the 

species and its habitat. Seek opportunities to 

close and revegetate OHV routes or nonmotorized trails and use areas in suitable 

habitat, if negative impacts are occurring.

b) For new roads, OHV routes and areas, and 

trails, see Special Status Animal and Plant 

Management program section item (3). Avoid 

constructing new roads, trails, routes, and 

areas if negative impacts are expected. 

Consider the seasonal nature of the proposed 

activities, and whether this conflicts with 

yellow-billed cuckoo conservation needs. In 

particular, avoid opening new roads, trails, 

routes, and areas in suitable habitat.

2) Maintain regular compliance checks on OHV 

closures to protect known populations and to 

identify problems as soon as possible and take 

immediate corrective measures.

2) Ongoing, day-to-day BLM activities.
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-187

Conservation Measures BLM Implementation Actions

Visual Resource Management

None None

Special Designation Area Management

1) Explore the potential for new designations that 

would enhance species conservation, such as 

good-condition cottonwood/willow riparian forest.

1) Take advantage of opportunities as they arise.

Fire Management: Fire Suppression

1) Fire suppression efforts will be conducted, as 

possible, to protect yellow-billed cuckoo habitat.

1) Fire management activities:

a) Review Fire Management Plan for adequacy in 

addressing conservation measures. Modify the 

plan if needed.

b) Apply Minimum Impact Suppression Tactics 

(MIST) in suitable habitat, as appropriate. 

Consult with resource advisors to determine 

where MIST tactics should be applied to avoid 

or minimize negative impacts.

c) Do not locate fire base camps, staging areas, 

and fueling areas in suitable habitat. Avoid 

locating these and other related activities in 

suitable habitat.

2) Coordinate with US Forest Service, Idaho 

Department of Lands, or other applicable agency 

personnel regarding fire suppression activities in or 

near suitable habitat.

2) Ongoing interagency coordination.

Fire Management: Emergency Stabilization and Burned Area Rehabilitation

1) Implement Emergency Stabilization and Burned 

Area Rehabilitation (ES&BAR) activities to promote 

yellow-billed cuckoo habitat rehabilitation.

1) ES&BAR activities:

a) If needed and if natural recovery would not 

achieve habitat objectives, implement ES&BAR

activities to promote rehabilitation of suitable 

habitat. Plant locally appropriate trees and 

shrubs, if natural recovery of such vegetation is 

doubtful.

b) As needed, protect disturbed areas using 

temporary closures or other measures until the 

cottonwood saplings (and other target tree and 

shrub species) are re-established and selfsustaining.

2) Fire rehabilitation projects involving the 

application of pesticides in or adjacent to suitable 

habitat areas will be analyzed and implemented in 

accordance with the approach described in the Soil 

and Water Resources: Riparian/Wetland Areas

program section.

2) See Soil and Water Resources:

Riparian/Wetland Areas program section.

Fire Management: Wildland Fire Use

1) Wildland fire use projects (where allowed) will be 

designed to conserve suitable yellow-billed cuckoo 

habitat.

1) When developing wildland fire use plans, avoid 

burning suitable habitat, and develop appropriate 

burn prescriptions that maximize conservation for 

suitable habitat. 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-188

Conservation Measures BLM Implementation Actions

Fire Management: Prescribed Fire

1) Prescribed fire use projects will be designed to 

conserve suitable yellow-billed cuckoo habitat and 

restoration areas.

1) When developing and implementing prescribed 

fire plans, avoid or minimize negative impacts to 

suitable habitat, and use prescribed fire as a tool 

for enhancing restoration areas.

Fire Management: Non-Fire Fuels Management

1) Implement projects involving the application of 

pesticides in or adjacent to suitable habitat or 

restoration areas in accordance with the approach 

described in the Soil and Water Resources: 

Riparian/Wetland Areas program section.

1) See Soil and Water Resources:

Riparian/Wetland Areas program section.

2) Promote establishment of vegetation needed to 

achieve suitable yellow-billed cuckoo habitat.

2) Incorporate conservation actions into the fuels 

projects, as needed. For example, design seed 

mixes that will enhance or promote the growth of 

willows, cottonwoods, or other target shrub and 

tree species.

Fire Management: Community Assistance

1) Follow all measures included throughout the Fire 

Management program sections.

1) See actions within Fire Management program 

sections. Incorporate into community assistance 

agreements.

Lands and Realty Management: Land Tenure Adjustment (sale, exchanges, withdrawals, etc.)

1) Where feasible and funding is available, acquire 

through land exchange or purchase private lands 

that support known populations or could enhance 

habitat for yellow-billed cuckoo.

1) Take advantage of opportunities as they arise. 

Priority should be given to lands that are adjacent 

to or near public lands.

2) Retain yellow-billed cuckoo habitat in Federal 

ownership to the extent possible, while balancing 

other needs.

2) Review each land tenure decision in terms of 

species habitat. Retain suitable habitat in public 

ownership unless compelling circumstances 

necessitate the land tenure adjustment. If property 

with suitable habitat is to be transferred out of 

Federal ownership, permanent conservation 

easements may be attached to the transfer that 

would result in equal or greater protection than 

under Federal management. Such measures must 

be approved by the State Director.

Lands and Realty Management: Land Use Permits and Leases

1) Issue new land use permits and leases and 

review existing permits and leases at renewal so as 

not to preclude species habitat conservation. This 

includes management of physical facilities, as well 

as disturbances to the species resulting from 

human uses. 

1) For new permits and renewal of existing permits, 

see Special Status Animal and Plant Management

program section item (3). Avoid issuing new 

permits or leases, or renewing existing permits or 

leases, in suitable habitat if negative impacts are 

expected. Consider the seasonal nature of the 

proposed activities, and whether this conflicts with 

yellow-billed cuckoo conservation needs. If a 

permit or lease is to be issued or re-issued in 

suitable habitat, apply stipulations to the permit that 

support or do not preclude species conservation 

and that avoid or minimize negative impacts.

Lands and Realty Management: Rights-of-Way

1) Issue new rights-of-way (ROWs) and review 

existing ROWs at renewal so as not to preclude 

species habitat conservation. This includes 

management of physical facilities, as well as 

1) For new ROWs and renewal of existing ROWs, 

see Special Status Animal and Plant Management

program section item (3). Avoid issuing ROWs, or 

renewing existing ROWs, in suitable habitat if 
Jarbidge Proposed RMP/Final EIS Appendix E: Conservation Measures

A-189

Conservation Measures BLM Implementation Actions

disturbances to the species resulting from human 

uses.

negative impacts are expected. Consider the 

seasonal nature of the proposed activities, and 

whether this conflicts with yellow-billed cuckoo 

conservation needs. If a ROW is to be issued or reissued in suitable habitat, apply stipulations to the 

ROW that support or do not preclude species 

conservation and that avoid or minimize negative 

impacts.

Mineral Management: Locatable Minerals 

1) Approve plans of operations or allow notice-level 

operations so as not to preclude species habitat 

conservation. This includes management of 

physical facilities, as well as disturbances to the 

species resulting from human uses.

1) Approval of plans of operations and notice-level 

operations:

a) For review of existing plans of operation and 

notice-level operations, see Special Status 

Animal and Plant Management program 

section item (2). To the extent allowed by law, 

modify plans of operation or notice-level 

operations that conflict with yellow-billed 

cuckoo objectives in suitable habitat. For 

notice-level operations, notify the operator that 

modifications to proposed activities will be 

required to avoid negative impacts.

b) For new plans of operation and notice-level 

operations, see Special Status Animal and 

Plant Management program section item (3). 

To the extent allowed by law, avoid approving 

plans of operation or notice-level operations 

that conflict with yellow-billed cuckoo 

objectives in suitable habitat. Consider the 

seasonal nature of the proposed activities, and 

whether they conflict with yellow- billed cuckoo 

conservation needs. For notice-level 

operations, notify the operator that 

modifications to proposed activities will be 

required to avoid negative impacts. If a plan of 

operations is to be approved in suitable habitat, 

apply stipulations to support or to not preclude 

species conservation. A notice will require 

modification by the operator until BLM 

determines that it will not result in undue or 

unnecessary degradation.

Mineral Management: Salable and Leasable Minerals 

1) Approve development of salable or leasable 

minerals so as not to preclude species habitat 

conservation. This includes management of 

physical facilities, as well as disturbances to the 

species resulting from human uses.

1) Approval of salable and leasable minerals:

a) For review of existing mineral leases, see 

Special Status Animal and Plant Management

program section item (2). Modify existing 

mineral leases if negative impacts are 

occurring.

b) For new sales or leases, see Special Status 

Animal and Plant Management program 

section item (3). Avoid development of salable

or leasable minerals in suitable habitat if 

negative impacts are expected. Consider the 

seasonal nature of the proposed activities, and 
Appendix E: Conservation Measures Jarbidge Proposed RMP/Final EIS

A-190

Conservation Measures BLM Implementation Actions

whether this conflicts with yellow-billed cuckoo 

conservation needs. If a minerals lease or sale 

is to be issued in suitable habitat, apply 

stipulations to support or to not preclude 

species conservation.

Cultural Management

1) Activities within the Cultural Management 

program will implement relevant conservation 

measures as described in the Special Status 

Animal and Plant Management program section to 

promote conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management 

program section at the beginning of this table.

Paleontology

1) Activities within the Paleontology program will 

implement relevant conservation measures as 

described in the Special Status Animal and Plant 

Management program section to promote 

conservation.

1) Apply relevant conservation measures from the 

Special Status Animal and Plant Management 

program section at the beginning of this table.
Jarbidge Proposed RMP/Final EIS Appendix F: Drought Management Guidelines

A-191

APPENDIX F: DROUGHT MANAGEMENT GUIDELINES 

Implementation of management actions may be necessary when it is anticipated or evident that, in 

addition to existing terms and conditions of livestock grazing permits, temporary measures are necessary 

to protect public land resources due to developing or existing drought conditions.

Dry or drought conditions can occur seasonally or over long time periods. Mounting drought conditions 

can be can be gradual and difficult to recognize (Wilhite and Glantz, 1985). Drought is defined by the 

Society for Range Management as a period of time when the precipitation is less than 75% of normal 

(Holecheck et al., 1998); normal precipitation is based on the median of 30 years or more of precipitation 

(Thurow and Taylor Jr., 1999; Wilhite and Glantz, 1985). Regional indicators such as the US Drought 

Monitor (http://droughtmonitor.unl.edu/) and the Vegetation Drought Response Index (VegDRI) 

(http://vegdri.unl.edu/) will be used to provide regional depictions of existing or developing climatic 

conditions. However, because drought can occur at a range of spatial scales these tools may or may not 

accurately represent local conditions. 

Within the planning area average annual precipitation varies substantially from north to south (see the Air 

and Atmospheric Values: Climate and Meteorology section in Chapter 3). Additionally, plant growth is 

dependent on timing of precipitation as well as quantity. The April-May-June precipitation period is most 

important for determining vegetation production and making annual adjustments to livestock stocking 

rates (Comstock and Ehleringer, 1992; Sharp et al., 1990). However, the October-through-March 

precipitation period is important for maintenance of vegetation communities through soil moisture 

recharge and initiation of early spring plant growth (Comstock and Ehleringer, 1992). Therefore, to the 

extent possible local climate data should be used to provide site-specific information on the amount and 

timing of precipitation, as well as other environmental factors such as temperature and wind that affect 

the occurrence and severity of drought. In addition to climate data, site visits to allotments would be used 

to evaluate the current condition of water resources and forage production to better define drought 

affected areas.

Wang and others (2012) found wet-dry cycles in the Great Basin to be about six to nine years, making it 

reasonable to expect that during the life of a 10-year grazing permit some level of drought could occur. 

Relative to the effects of livestock grazing, the degree to which drought impairs the range’s potential for 

future forage production depends on the intensity, frequency, and timing of grazing (Howery, 1999).

Properly stocked rangelands should maintain rangeland conditions (Martin and Cable, 1974) and require 

fewer adjustments to grazing operations during drought. Therefore, drought management should begin 

with the determination of livestock stocking rates, seasons of use, and utilization levels for an allotment 

during the permitting process. The likelihood that drought could occur during the period of the permit 

should be considered and stocking rates set at a level that would not require frequent annual adjustments 

in order to provide for watershed protection through retention of litter for watershed protection, 

physiological function of vegetation communities, and wildlife habitat.

Implementation 

When drought conditions develop, and it is determined additional temporary measures are necessary to 

maintain resource values, one or more of the following actions should be implemented. The selection of 

temporary actions will consider the severity of drought, vegetation type, and soil characteristics of the 

affected area. 

The term of temporary measures would reflect the severity of the drought and ensure adequate protection 

of resources during the drought as well as allow for resource recovery following resumption of nondrought climate conditions. As the length and severity of the drought increase, livestock grazing 

management would be more constrained to reduce impacts to soil, water, upland and riparian vegetation, 

and fish and wildlife habitat. Pre-drought grazing levels should not be implemented too rapidly following a 

return to normal precipitation levels as drought-stressed plants require time to regain vigor and be able to

resist normal grazing pressure (Vallentine, 2001).
Appendix F: Drought Management Guidelines Jarbidge Proposed RMP/Final EIS

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Triggers for implementation of temporary actions: 

The following list of actions is not exclusive and can be used singularly or in combinations as field 

conditions require. Persistence of drought through multiple years could result in additional and more 

restrictive actions taken to protect resource values.

If precipitation between October and January is less than 75% of normal, initiate communication with 

affected permittees to coordinate potential changes to their grazing operations if drought conditions 

persist. 

If drought continues to the April-May-June precipitation period, and allotment inspections identify 

resource concerns such as reduced production that would limit maintenance of achievement of 

resource objectives, implement the following measures as appropriate. The specific measures to be 

implemented would depend on the length and severity of the drought as well as vegetation and soil 

characteristics.

Adjust stocking rate using April-May-June precipitation to match current forage production 

available for livestock (Heitschmidt et al., 2005) and ensure adequate residual ground cover for 

watershed protection and wildlife habitat needs.

Adjust timing and duration of grazing to reduce utilization of key native grasses and riparian 

vegetation.

Monitor utilization closely and remove livestock from pastures or the allotment if allowable use 

criteria will be exceeded early.

Adjust timing and duration of grazing to reduce the opportunity for upland and riparian plants to 

be grazed repeatedly during the growing season . 

The growing season is defined as the portion of the year during which temperature and moisture typically enable 

plant growth (Vallentine, 2001). For key species in the planning area, this period typically falls between April 1 and 

July 15; however, drought conditions typically shorten the growing period.

During the growing season, shift use to pastures managed as non-native to defer grazing of 

native pastures until after the growing season. 

Encourage permittees to closely manage livestock watering systems (e.g., turn off troughs when 

not needed by livestock, eliminate overflow) to facilitate conservation of water within streams and 

springs.

Consistent with water rights, consider authorizing water hauling or temporary pipelines to reduce 

impacts to riparian areas and wetlands.

Pastures which are managed as native that are grazed during the growing season one year 

would be deferred until after the end of the growing season the following year.

Defer spring grazing until end of growing season.

Do not allow spring grazing.

Close pasture and/or allotment.
Jarbidge Proposed RMP/Final EIS Appendix G: Cultural Resource Use Categories

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APPENDIX G: CULTURAL RESOURCE USE CATEGORIES 

All cultural properties in the planning area, whether already recorded or projected to occur, are allocated 

to one or more of the uses described below. Allocations apply to individual properties and to classes of 

similar properties. The purpose of these allocations is to provide up-front management direction to aid the 

authorized officer in responding to conflicts between specific cultural resources and land uses and to 

enable the authorized officer to analyze needs and develop appropriate mitigation and treatment options 

during the compliance process for proposed actions. Managing cultural properties according to use 

categories does not relieve the Bureau of Land Management (BLM) of its obligations to consult with the 

tribes, the State Historic Preservation Officer (SHPO), or the Advisory Council on Historic Preservation 

(ACHP) regarding the specific treatment of historic properties, or the potential effects of land use 

proposals on cultural resources.

Allocations of individual sites may be revised when site conditions change or new information becomes 

available. Changes that may warrant revision of a site’s use allocation include:

Destruction of a site’s primary use values due to natural or human-caused disturbance.

When ethnographic, historical, or archaeological research reveals important but previously 

unrecognized values that may be damaged or destroyed under the current allocation or that may 

more effectively meet Resource Management Plan (RMP) goals and objectives if used in another 

way.

When a site’s primary values are legitimately expended or its use potential is fully realized.

Following consultation with the tribes, SHPO, or ACHP, as appropriate for the resource and use 

category being revised.

Traditional Use

The Traditional Use category applies to any cultural resource in the planning area known to be perceived 

by the Shoshone-Paiute Tribes or the Shoshone-Bannock Tribes as important in maintaining their cultural 

identity, heritage, or well-being. Cultural properties assigned to this category are managed in ways that 

recognize the importance ascribed to them and seek to accommodate their continuing traditional use.

Management Direction

Avoidance is the preferred treatment.

If impacts are unavoidable, data recovery and/or other measures will be implemented after 

appropriate consultation and before implementation of a proposed activity.

Sites in this category are available for use by members of the Shoshone-Paiute Tribes and the 

Shoshone-Bannock Tribes for traditional uses. Access to these sites will be accommodated to the 

extent practicable.

Ethnographic studies may be initiated when funding is available to identify these types of properties 

and to ensure that they receive the appropriate level of management.

The following property types in the planning area are allocated to Traditional Use:

Historic/Ethnographic Tribal Sites, 

Ceremonial Locations, 

Burial Sites , 

Native American burials on public lands would normally be subject to the Native American Graves Protection and 

Repatriation Act of 1990 (NAGPRA).

Sacred Sites, 

Natural Resource Collection Sites, and

Native American Trails. 
Appendix G: Cultural Resource Use Categories Jarbidge Proposed RMP/Final EIS

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Conservation for Future Use

The Conservation for Future Use category is reserved for any cultural property in the planning area that is 

unusual because of scarcity or has a research potential that surpasses the current state of the art, 

singular historic importance, cultural importance, architectural interest, or comparable reasons. These 

properties are not currently available for consideration as the subject of scientific or historical study that 

would result in their physical alteration.

Management Direction

Avoidance is the preferred mitigation measure. Discretionary activities will usually be denied within 

the boundaries of these resources if such activities are likely to result in adverse effects to the cultural 

property.

If impacts are unavoidable, data recovery or other measures may be allowed after going through the 

required consultation processes. Avoidance should be possible in most cases. 

Sites in this category have the highest priority for protection and preservation and will generally not be 

available for other uses.

A resource listed in the Conservation for Future Use category may be placed in another use 

management category if: (a) BLM identifies the specific criteria underlying this classification (e.g.,

outstanding research potential), (b) the specific reasons for prohibitions or limitations are identified, 

and (c) BLM identifies or accepts methodological, technological, or other criteria that, if met or 

implemented, justify alterations to the integrity of the resource and placement in another use 

category. 

Protective actions may be taken to ensure preservation of those qualities providing the basis for 

classification. These actions, such as fencing, installation of erosion control structures, road closures, 

etc., must not impinge on the values and integrity of the site. Sites in this category are generally the 

highest priority for monitoring of potential threats.

The following property types in the planning area are allocated to Conservation for Future Use:

Oregon Trail (Main Route and South Alternate) – Undisturbed Ruts, 

Kelton Freight Road – Undisturbed Ruts, 

Toana Freight Road – Undisturbed Ruts, and

Cemeteries and Grave Sites. 

Scientific Use

The Scientific Use category applies to any cultural property in the planning area available for 

consideration as the subject of scientific or historical study at the present time, using currently available 

research techniques. Study includes methods that would result in the property’s physical alteration or 

destruction. This category applies almost entirely to archaeological properties, where the method of use is 

generally archaeological excavation, controlled surface collection, and/or controlled recordation (data 

recovery). Recommendations to allocate individual properties to this use must be based on 

documentation of the kinds of data the property is thought to contain and the data’s importance for 

pursuing specified research topics. Properties in this category need not be conserved in the face of a 

research or data recovery (mitigation) proposal that would make adequate and appropriate use of the 

property’s research importance.

Management Direction

Data recovery rather than avoidance is the preferred option; although sites should be preserved until 

research potential is realized. Data recovery should be accomplished prior to impacts from conflicting 

uses or natural or human-caused deterioration and may be undertaken to mitigate impacts that have 

already occurred.

Resources in this category are available for testing and excavation by qualified researchers operating 

under valid permits with acceptable research designs. Resources in this category may be discharged 

from use or assigned to a category other than Conservation for Future Use once the resource has no 

further scientific use.
Jarbidge Proposed RMP/Final EIS Appendix G: Cultural Resource Use Categories

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The following property types in the planning area are allocated to Scientific Use:

Fur Trade Camps; 

Cabins/Line Shacks, including Ruins; 

Abandoned Homesteads, including Ruins; 

Historic Cairns; 

Trash Dumps – Community; 

Irrigation Project Construction Camps; 

Moonshine Distilleries; and

Archaeological Sites that are not identified through research or consultation as traditional cultural 

properties or sacred sites. 

Public Use

This category may be applied to any cultural property in the planning area found to be appropriate for use 

as an interpretive exhibit in place or for related educational and recreational uses by members of the 

general public. This category may also be applied to historic features (e.g., roads, dams, canals) that are 

still in use.

Management Direction

Interpretation through the development of on-site facilities and/or published materials made available 

to the public is the preferred treatment. Interpretation will be based on appropriate archaeological, 

historic, or ethnographic research and will reflect consultation with the Shoshone-Paiute Tribes and 

the Shoshone-Bannock Tribes when Native American information is included.

These sites are available for educational and recreational use by the general public. Testing, data 

recovery, historic research, oral histories, ethnographic research, and other treatments may be 

necessary to gather sufficient information for suitable educational and interpretive uses and to 

prevent damage from proposed recreational or educational uses.

Interpretive facility designs will be consistent with the area’s Visual Resource Management class and 

compatible with the physical setting of the interpreted site.

Fences, erosion control devices, vehicle barriers, parking areas, and other protective structures may 

be constructed to prevent or limit site damage.

The following property types in the planning area are allocated to Public Use:

Crippen Grade; 

Portions of Historic Roads and Trails that are improved for Modern Use; 

Civilian Conservation Corps (CCC) Dams, Roads, and Related Sites – Still in Use; 

Non-CCC Reservoirs – Still in Use; and

Irrigation Canals and Ditches – Still in Use. 

Experimental Use

This category may be applied to a cultural property in the planning area determined to be well-suited for 

controlled experimental study, conducted by BLM or others concerned with the techniques of managing 

cultural properties, which would result in the property’s alteration, possibly including loss of integrity and 

destruction of physical elements. Committing cultural properties or the data they contain to loss must be 

justified in terms of specific information that would be gained and how it would aid in the management of 

other cultural properties. Experimental study should aim toward understanding the kinds and rates of 

natural or human-caused deterioration, testing the effectiveness of protection measures, or developing 

new research or interpretation methods and similar kinds of practical management information. It would 

not be applied to cultural properties with traditional cultural importance, research potential, or public use 

potential.
Appendix G: Cultural Resource Use Categories Jarbidge Proposed RMP/Final EIS

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Management Direction

These sites are reserved for studies concerning the effects of erosion, fire, land treatments, or other 

site formational processes on cultural resources. The preferred treatment for sites placed in an 

Experimental Use category will be avoidance unless the proposed impacts are related to the study 

being conducted.

If impacts unrelated to the study are unavoidable, then the site may be placed in the Discharged from 

Management category, or may undergo data recovery or other treatment depending on eligibility for 

the National Register of Historic Places (NRHP) or other factors and after appropriate consultation.

If BLM determines the useful experimental life of the site is exhausted, then it can be placed into the 

Discharged from Management or other appropriate category. 

Individual sites within the following property types in the planning area may be allocated to Experimental 

Use as needed:

Temporary Camps – Livestock Industry and

Trash Dumps – Unassociated Household Refuse.

Discharged from Management

This category is assigned to cultural properties in the planning area that have no remaining identifiable 

use. These are most often prehistoric and historic properties, such as small surface scatters of artifacts or 

debris, whose limited research potential is effectively exhausted during documentation. More complex 

archaeological properties that have had their salient information collected and preserved through 

mitigation or research may be discharged from management, as should cultural properties destroyed by 

any natural or human activity. Properties discharged from management remain in the inventory, but are 

removed from further management attention and do not constrain other land uses. Particular classes of

unrecorded cultural resources may be named and described in advance as dischargeable upon 

documentation, but specific cultural properties must be inspected in the field and recorded before they 

may be discharged from management.

Management Direction

Preservation is not required.

Tribal consultation is required before any site of cultural or religious significance to the tribes is placed 

in this category.

SHPO consultation is required before any property previously determined eligible for the the National 

Register of Historic Places (NRHP) or any unevaluated property is placed in this category.

The following property types in the planning area are Discharged from Management:

General Transportation Routes (e.g., ranching, recreation, farming); 

Temporary Camps – Livestock Industry; 

Generic Range Developments (e.g., fences, corrals, water tanks, ponds); 

Irrigation Canals and Ditches – No Longer Used and Not Eligible for NRHP Listing; 

Trash Dumps – Unassociated Household Refuse; 

Non-CCC Reservoirs – Breached; 

Military – Aircraft Debris; 

Military – Expended Ordnance; 

Small, Non-Diagnostic Lithic Scatters; 

Isolated Artifacts; and

Modern Period (post 1960) Sites, Facilities, and Features. 
Jarbidge Proposed RMP/Final EIS Appendix G: Cultural Resource Use Categories

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Traditional/Scientific Use

This category is assigned to cultural properties in the planning area important because of their links to 

traditional values, but also important for the archaeological information they contain.

Management Direction

Access for traditional use will be accommodated to the extent and manner practicable.

Non-destructive recordation, photography, mapping, and analysis, as well as actions needed to 

protect artifacts and sites threatened by theft or physical destruction will be allowed, including 

research and stabilization related to investigations of criminal violations of the Archaeological 

Resources Protection Act. 

Research that does not conflict with traditional use may be allowed after consultation with the tribes, 

SHPO, and the Advisory Council on Historic Preservation, as appropriate.

Public dissemination of research results will take into account the confidentiality and privacy concerns 

of the tribes.

Cultural resource data recovery, using standard archaeological methods, may be allowed, after 

appropriate consultation, if impacts to sites are unavoidable and non-destructive conservation 

measures are not adequate or feasible, or when necessary to determine a site’s eligibility for the the 

National Register of Historic Places (NRHP) or mitigate adverse effects to NRHP-eligible or -listed 

properties. 

The following property types in the planning area are allocated to Traditional/Scientific Use:

Native American Rock Art Sites (petroglyphs and pictographs); 

Native American Cave and Rock Shelter Sites; 

Native American Open Habitation Sites; 

Lithic Scatters; 

Tool Stone Quarries; and

Native American Rock Features (e.g., hunting blinds, rock circles, linear rock alignments, and cairns)

Isolated Native American Artifacts. 

Public/Scientific Use

This category is assigned to cultural properties in the planning area that are most valuable for public use, 

but that may require scientific data collection to enhance their interpretive potential.

Management Direction

Sites assigned to this category will be available for educational and recreational use by the general 

public. Interpretive and educational actions, including but not limited to on-site interpretation, signage, 

or publications, are the preferred management actions.

Data recovery or other treatments deemed necessary to provide sufficient information for suitable 

educational and interpretive uses, or to treat damage from recreational uses, may be authorized 

providing they do not diminish the public use potential of the site.

Data recovery and stabilization actions for investigations and treatments related to criminal violations 

of the Archaeological Resources Protection Act will be allowed.

To the extent practical, data recovery and other treatment actions will involve volunteers.

The following property types in the planning area are allocated to Public/Scientific Use:

Oregon Trail Campsites; 

Pilgrim Stage Station; 

Historic School Sites; 

Historic Inscriptions; 

CCC Dams, Roads, and Related Sites – No Longer Used; and

Irrigation Canals and Ditches – No Longer Used and the National Register of Historic Places Eligible. 
Appendix G: Cultural Resource Use Categories Jarbidge Proposed RMP/Final EIS

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Conservation/Public Use

This category includes cultural resources in the planning area that are suitable for long-term preservation, 

but also possess high public use values. 

Management Direction

Sites in this category will be managed to avoid degradation from competing land uses and from 

natural processes.

Sites may be used for interpretation or other public purposes and for data recovery and other 

treatments if these uses do not conflict with conservation of the property.

The following property types in the planning area are allocated to Conservation/Public Use:

Oregon Trail (Main Route and South Alternate) – the National Register of Historic Places (NRHP) 

Contributing Segments, 

Kelton Freight Road – NRHP Contributing Segments, 

Toana Freight Road – NRHP Contributing Segments, and

Wilkins Rock Fence. 

Summary of Cultural Resource Use Allocations

Table G-1 summarizes the cultural resource use categories to which properties of cultural and religious 

importance and prehistoric and historic sites would be allocated under the action alternatives.

Table G-1. Cultural Resource Property Types and Use Allocations

Property Type Use Category

Properties of Cultural and Religious Importance to Native American Tribes

Historic/Ethnographic Tribal Sites Traditional

Ceremonial Locations Traditional

Burial Sites Traditional

Sacred Sites Traditional

Natural Resource Collection Sites Traditional

Native American Trails Traditional

Native American Archaeological Sites

Petroglyphs Traditional/Scientific

Pictographs Traditional/Scientific

Caves and Rock Shelters Traditional/Scientific

Open Habitation Sites Traditional/Scientific

Lithic Scatters with potential for subsurface deposits, diagnostic 

artifacts, surface patterning of cultural debris, or evidence of cultural 

features 

Traditional/Scientific

Lithic Scatters with no or little potential for subsurface deposits, and no 

diagnostic artifacts, surface artifact patterning, or evidence of cultural 

features

Traditional/Scientific or 

Discharged from Management

Tool Stone Quarries Traditional/Scientific

Hunting Blinds Traditional/Scientific

Rock Circles Traditional/Scientific

Linear Rock Alignments Traditional/Scientific

Cairns Traditional/Scientific

Isolated Artifacts Traditional/Scientific or 

Discharged from Management

Archaeological sites that are not identified through research or 

consultation as traditional cultural properties or sacred sites Scientific
Jarbidge Proposed RMP/Final EIS Appendix G: Cultural Resource Use Categories

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Property Type Use Category

Historic Sites

Fur Trade Camps Scientific

Oregon Trail (Main Route) Conservation or 

Conservation/Public

Oregon Trail (South Alternate) Conservation or 

Conservation/Public

Oregon Trail Campsites Public/Scientific

Kelton Freight Road Conservation or 

Conservation/Public

Pilgrim Stage Station Public/Scientific

Toana Freight Road Conservation or 

Conservation/Public

Crippen Grade Public

General Transportation Routes (Ranching, Recreation, Farming, etc.) Discharged from Management

Portions of Historic Roads and Trails that are Improved for Modern 

Use Public 

Cabins/Line Shacks, including Ruins Scientific

Temporary Camps – Livestock Industry Experimental or Discharged 

from Management

Historic School Sites Public/Scientific

Abandoned Homesteads, including Ruins Scientific

Cemeteries and Grave Sites Conservation 

Cairns Scientific

Wilkins Rock Fence Conservation/Public

Generic Range Developments (Fences, Corrals, Water Tanks, Ponds, 

etc.) Discharged from Management

Trash Dumps – Community Scientific

Trash Dumps – Unassociated Household Refuse Experimental or Discharged 

from Management

Historic Inscriptions Public/Scientific

Irrigation Project Construction Camps Scientific

Irrigation Canals and Ditches – Still in Use Public

Irrigation Canals and Ditches – No Longer Used Public/Scientific or Discharged 

from Management

CCC Dams, Roads, and Related Sites – Still in Use Public

CCC Dams, Roads, and Related Sites – No Longer Used Public/Scientific

Non-CCC Reservoirs – Still in Use Public

Non-CCC Reservoirs – Breached Discharged from Management

Moonshine Distilleries Scientific

Military – Aircraft Debris Discharged from Management

Military – Expended Ordnance Discharged from Management

Isolated Artifacts Discharged from Management

Modern Period (post 1960) Sites, Facilities, and Features Discharged from Management
This Page Intentionally Left Blank
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

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APPENDIX H: RECREATION MANAGEMENT AREAS 

Recreation Setting Characteristics

Recreation settings are the collective, distinguishing attributes of landscapes that influence and 

sometimes determine what kinds of recreation opportunities are produced. Recreation setting 

characteristics are objectively defined along a continuum ranging from primitive to urban landscapes, 

expressed in terms of the nature of the component parts of its physical, social, and administrative 

attributes; recreation setting characteristics are described for both the existing and desired condition of a 

landscape.

The physical setting addresses the land and facilities and describes the character of the natural 

landscape; remoteness, naturalness, and facilities are all components of the physical setting. The 

continuum of setting characteristics for physical setting is displayed in Table H-1. 

Table H-1. Physical Setting

Remoteness Naturalness Facilities

Primitive

Pristine More than 10 miles

from any road. Undisturbed natural 

landscape. None. 

Transition More than 3 miles from 

any road. 

Back Country

More than .5 mile from 

any kind of road, but 

not as distant as 3 

miles, and no road is in 

sight. 

Naturally-appearing 

landscape having 

modifications not 

readily noticeable. 

Structures are rare and 

isolated.

Middle Country

On or near four-wheel 

drive roads, but at least 

1/2 mile from all 

improved roads, though 

they may be in sight. 

Naturally-appearing 

landscape except for 

obvious primitive roads. 

Maintained and marked 

trails, simple trailhead 

development and basic 

toilets.

Front Country

On or near improved 

country roads, but at 

least 1/2 mile from all 

highways. 

Landscape partially 

modified by roads, 

utility lines, etc., but 

none overpower natural 

landscape features. 

Rustic facilities such as 

campsites, restrooms, 

trailheads, and 

interpretive displays.

Rural

On or near primary 

highways, but still 

within a rural area. 

Natural landscape 

substantially modified 

by agriculture or 

industrial development. 

Modern facilities such 

as campgrounds, boat 

launches, and group 

shelters.

Urban

On or near primary 

highways, municipal 

streets, and roads 

within towns or cities. 

Urbanized 

developments dominate 

landscape. 

Elaborate full-service 

facilities.

The social setting addresses visitor use and users and describes the character of recreation and tourism 

use; the number of contacts with other groups, group size, and evidence of use are all components of the 

social setting. The continuum of setting characteristics for social setting is displayed in Table H-2. 

The administrative setting addresses recreation administration and services and describes how public 

land managers, county commissioners and municipal governments, and local businesses care for the 

area and serve visitors and local residents. The amount and type of mechanized use, visitor services, and 

management controls are all components of the administrative setting. The continuum of setting 

characteristics for administrative setting is displayed in Table H-3. 
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

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Table H-2. Social Setting

Contacts with Other 

Groups Group Size Evidence of Use

Primitive

Pristine Fewer than 3 

encounters per day at 

camp sites and fewer 

than 6 encounters per 

day on travel routes. 

Fewer than or equal to 

3 people per group. 

Only footprints 

observed. No noise or 

Transition litter.

Back Country

3-6 encounters per day 

off travel routes (e.g., 

campsites) and 7-15 

encounters per day on 

travel routes. 

4-6 people per group. 

Footprints and bicycle 

tracks observed. Noise 

and litter infrequent. 

Slight vegetation 

trampling at campsites 

and popular areas. Fire 

rings seen.

Middle Country

7-14 encounters per 

day off travel routes

(e.g., staging areas) 

and 15-29 encounters 

per day en route. 

7-12 people per group. 

Vehicle tracks 

observed. Occasional 

noise and litter. 

Vegetation and soils 

becoming worn at 

campsites and at highuse areas.

Front Country

15-29 encounters per 

day off travel routes

(e.g., campgrounds) 

and 30 or more 

encounters per day en 

route. 

13-25 people per 

group. 

Vehicle tracks common. 

Some noise and litter. 

Vegetation and soils 

commonly worn at 

campsites, along travel 

routes, and at popular 

areas.

Rural People seem to be 

generally everywhere.

26-50 people per 

group. 

Frequent noise and 

litter. Large but 

localized areas with 

vegetation damage and 

soil compaction.

Urban

Busy place with other 

people constantly in 

view. 

More than 50 people 

per group. 

Unavoidable noise and 

litter. Widespread

vegetation damage and 

soil compaction.

Table H-3. Administrative Setting

Mechanized Use Visitor Services Management Controls

Primitive

Pristine

None whatsoever. None is available onsite. 

No visitor controls 

apparent. No use limits. 

Enforcement presence 

very rare.

Transition

Back Country

Mountain bikes and 

perhaps other 

mechanized use, but all

is non-motorized. 

Basic maps, but area 

personnel seldom 

available to provide onsite assistance. 

Signs at key access 

points on basic user 

ethics. May have back 

country use restrictions. 

Enforcement presence 

rare. 
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

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Mechanized Use Visitor Services Management Controls

Middle Country

Four-wheel drives, allterrain vehicles, dirt 

bikes, or snowmobiles 

in addition to nonmotorized, mechanized 

use. 

Area brochures and 

maps, plus area 

personnel occasionally

present to provide onsite assistance. 

Occasional regulatory 

signing. Motorized and 

mechanized use 

restrictions. Random 

enforcement presence. 

Front Country

Two-wheel drive 

vehicles predominant, 

but also four-wheel 

drive vehicles and nonmotorized, mechanized 

use. 

Information materials 

describe recreation 

areas and activities. 

Area personnel are

periodically available. 

Rules clearly posted 

with some seasonal or 

day-of-week use 

restrictions. Periodic

enforcement presence. 

Rural

Ordinary highway auto 

and truck traffic is

characteristic. 

Information materials 

same as described in 

Front Country, plus

experience and benefit 

descriptions, staff 

reguraly present.

Regulations prominent. 

Total use limited by 

permit, reservation, etc. 

Routine enforcement 

presence.

Urban

Wide variety of street 

vehicles and highway 

traffic is ever-present. 

Information described 

to the left, plus regularly 

scheduled on-site 

outdoor skills

demonstrations and 

clinics. 

Continuous 

enforcement to 

redistribute use and

reduce user conflicts, 

hazards, and resource 

damage. 

Special Recreation Management Areas 

The Special Recreation Management Area (SRMA) is an administrative unit where the existing or 

proposed recreation opportunities and recreation setting characteristics are recognized for their unique 

value, importance, and/or distinctiveness, especially as compared to other areas used for recreation. The 

SRMA is managed to protect and enhance a targeted set of activities, experiences, benefits, and desired 

recreation setting characteristics. The RMP may subdivide the SRMA into Recreation Management Zones 

(RMZs) to further delineate specific recreation opportunities. Within an SRMA, recreation and visitor 

services management is recognized as the predominant RMP focus, where specific recreation 

opportunities and recreation setting characteristics are managed and protected on a long-term basis. 

Below are management strategies for SRMAs that would be designated under one or more of the action 

alternatives. The existing and prescribed setting characteristics for the physical, social, and administrative 

settings as described in Table H-1, Table H-2, and Table H-3 are identified for each SRMA.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-204

Balanced Rock Special Recreation Management Area

Supporting Information

Appreciation of an area important to the local community.

SRMA/RMZ Objective(s)

Objective Statement: Manage the Balanced Rock SRMA to provide opportunities for visitors to engage 

in activities in an area of importance to the local communities so they realize a “moderate” level of the 

targeted experience and benefit outcomes.

Activities: Hiking, viewing wildlife/natural scenery, non-motorized boating. 

Experiences: Enjoying natural scenery and wildlife, escaping everyday responsibilities, enjoying solitude, 

and being with friends and family. 

Benefits:

Personal: Nature/aesthetic appreciation, improved mental wellbeing, and opportunity to view wildlife 

close-up. 

Community/Social: Improved image of the area and its recreational opportunities, improved perceived 

quality of life, and family bonding/better family life. 

Environmental: Creates sense of “ownership” and stewardship of the area, provides natural habitat and 

open space. 

Economic: Increased desirability of a place to live and work. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Front/Middle 

Country

Facilities – Middle Country

Social Components:

Contacts – Middle Country

Group Size – Back Country

Evidence of Use – Middle 

Country

Administrative Components:

Mechanized Use – Back Country

Visitor Services – Middle Country

Management Controls – Middle 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Focus on developing a hiking trail to enhance existing 

facilities.

Improvements will be preceded by formal site plans and will adhere to guidelines developed for the area.

Other Programs: Manage as Visual Resource Management (VRM) Class III.

Implementation Decisions

Encourage and develop cooperative partnerships with volunteer groups, State, County, and local 

agencies to facilitate management and additional development of the area.

Marketing activities will include directional signing, interpretation, and brochures. 

Support active volunteer programs and develop new partnerships (e.g., National Public Lands Day and 

National Trails Day events and volunteer projects for local groups).

Routine monitoring of area and facilities, periodic visitor contact, and monitoring to assess achievement of 

objectives.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

A-205

Jarbidge Forks Special Recreation Management Area

Supporting Information

Fishing and camping in a remote area with few contacts with other people. 

SRMA/RMZ Objective(s)

Objective Statement: Manage the Jarbidge Forks SRMA to provide opportunities for visitors to engage 

in fishing and camping so they achieve a “moderate” level of the targeted experiences and benefits 

outcomes.

Activities: Rafting, fishing, camping, picnicking, viewing wildlife, and viewing natural scenery. 

Experiences: Engaging in preferred activities with family and friends, relaxing physically, enjoying natural 

scenery and wildlife, and enjoying leisure activities. 

Benefits:

Personal: Nature/aesthetic appreciation, positive change in mood and emotion, social 

bonding/cohesion/cooperation, and identification with a special place. 

Community/Social: Improved image of the area and its recreational opportunities, improved image of land 

management agencies, and family/friends bonding. 

Environmental: Better preservation of riparian environment, creates sense of “ownership” and 

stewardship of the area. 

Economic: Retain recreation spending in local area and increase desirability of a place to live and work. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Middle Country

Facilities – Front Country

Social Components:

Contacts – Back Country

Group Size – Back Country

Evidence of Use – Middle 

Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Front Country

Management Controls – Middle 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Focus on access, whitewater boat launch, parking, resource 

protection, and sanitation. 

Maintain or upgrade existing facilities. 

Other Programs: Manage Jarbidge River portion as VRM Class I (eligible Wild and Scenic River 

segments with a scenic Outstandingly Remarkable Value) and manage the East Fork of the Jarbidge 

River portion as VRM Class II.

Implementation Decisions

Seek cooperative relationships with local groups and other agencies to facilitate management.

Occasional visitor contact and law enforcement.

Marketing activities would include word of mouth, brochures, and interpretative and directional signing.

Routine monitoring of physical facilities; visitor number collections will continue to include whitewater 

boating registration forms; periodic visitor surveys to assess achievement of objectives.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-206

Little Pilgrim Special Recreation Management Area

Supporting Information

Vehicle-accessible fishing. 

SRMA/RMZ Objective(s)

Objective Statement: Manage the Little Pilgrim SRMA to provide opportunities for visitors to engage in 

sturgeon fishing so they realize a “moderate” level of the targeted experiences and benefit outcomes.

Activities: Fishing and bird hunting. 

Experiences: Enjoying activities in a natural setting, enjoying natural scenery and wildlife, engaging in 

preferred activities with family and friends, and testing and improving outdoor skills. 

Benefits:

Personal: Nature/aesthetic appreciation, positive change in mood and emotion, social 

bonding/cohesion/cooperation, and identification with a special place. 

Community/Social: Lifestyle improvement or maintenance, family and friends bonding, improved image of 

the area and its recreational opportunities.

Environmental: Protection of wildlife and fish habitat and provide natural habitat and open space. 

Economic: Retain recreation spending in local area and increase desirability of a place to live and work. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Middle Country

Naturalness – Middle Country

Facilities – Middle Country

Social Components:

Contacts – Back Country

Group Size – Back Country

Evidence of Use – Middle 

Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Middle Country

Management Controls – Middle 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Focus on public access, parking, resource protection, and 

sanitation. 

Develop facilities for parking, camping, and sanitation. Improvements will be preceded by a formal site 

plan and will adhere to guidelines developed for the area. 

Other Programs: Manage areas outside the Oregon National Historict Trail protective zone (VRM Class 

II) as VRM Class III.

Implementation Decisions

Encourage and develop cooperative relationships with land owners and other entities to facilitate 

responsible recreational use of the area.

Marketing activities would include word of mouth and brochures.

Routine monitoring of physical facilities and periodic visitor contact to assess achievement of objectives.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

A-207

Salmon Falls Reservoir Special Recreation Management Area

Antelope Bay Recreation Management Zone

Supporting Information

Fishing, camping, and boating on a reservoir with consistent water levels and within proximity to major 

transportation routes.

SRMA/RMZ Objective(s)

Objective Statement: Manage the Antelope Bay RMZ to provide opportunities for visitors to engage in 

fishing, camping, and boating so they realize a “moderate” level of the targeted experience and benefit 

outcomes.

Activities: Fishing, camping, water sports, hunting, boat launching and take out, equestrian, hiking, allterrain vehicle (ATV) riding, and motorcycle riding.

Experiences: Enjoying having easy access to natural landscapes, engaging in preferred activities with 

family and friends, enjoying activities in a natural setting, relaxing physically, and feeling good about how 

natural resources and facilities are being managed.

Benefits:

Personal: Positive change in mood and emotion, identification with a special place, and nature/aesthetic 

appreciation.

Community/Social: Improved image of the area and its recreational opportunities, improved image of land 

management agencies, and family and friends bonding/ better family life.

Environmental: Greater protection of fish, wildlife, and plant habitat from public use impact, creates sense 

of “ownership” and stewardship of the area.

Economic: Contribution to Recreation and Tourism sector of the local economy and retain recreation 

spending in local area.

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Middle/Front 

Country

Facilities – Front/Rural Country

Social Components:

Contacts – Middle/Front Country

Group Size – Middle Country

Evidence of Use – Middle/Front 

Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Front Country

Management Controls – Front 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Focus on access, boat launch, parking, resource protection, 

and sanitation. 

Develop facilities to provide for access, visitor parking, boat launching and take out, and sanitation. 

Develop multiple-use designated trail system.

Facility development will be preceded by project planning and will adhere to guidelines developed for the 

area.

Other Programs: Manage as VRM Class II (Alternative I and IV) or VRM Class III (Alternative II and III).

Implementation Decisions

Develop cooperative relationships with volunteer groups, State and county agencies to facilitate 

responsible planning and use of the area.

Marketing activities would include directional signing, interpretative signing, brochures, and word of 

mouth.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-208

Provide information and a regular management presence to allow the visitors to enjoy the area while 

protecting its natural resources.

Cedar Creek Recreation Management Zone

Supporting Information

Easily accessed fishing and camping on a stocked reservoir. 

SRMA/RMZ Objective(s)

Objective Statement: Manage the Cedar Creek RMZ to provide opportunities for visitors to engage in 

fishing and camping so they realize a “moderate” level of the targeted experience and benefit outcomes.

Activities: Fishing, camping, boat launching and take out. 

Experiences: Being with friends and family, engaging in preferred activities, relaxing physically, and 

enjoying activities in a natural setting. 

Benefits:

Personal: Positive change in mood and emotion and nature/aesthetic appreciation. 

Community/Social: Improved image of the area and its recreational opportunities and bonding with family 

and friends. 

Environmental: Creates sense of “ownership” and stewardship of the area. 

Economic: Retain recreation spending in local area and increase desirability of a place to live and work. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Front Country

Facilities – Front Country

Social Components:

Contacts – Back Country

Group Size – Back/Middle 

Country

Evidence of Use – Front Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Middle Country

Management Controls – Middle 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Focus on access, boat launch facilities, parking, resource 

protection, and sanitation. 

Develop and upgrade existing facilities to provide for access, visitor parking, and sanitation. Facility 

development will be preceded by project planning and will adhere to guidelines developed for the area.

Other Programs: Manage as VRM Class II (Alternative I) or VRM Class III (Alternative II, III, and IV).

Implementation Decisions

Develop cooperative relationships with land owners and Twin Falls County Parks and Waterways.

Marketing activities would include directional signing, brochures, and word of mouth.

Routine monitoring of physical facilities and periodic visitor contact to assess achievement of objectives. 

Provide information and a regular management presence to allow the visitors to enjoy the area while 

protecting its natural resources.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

A-209

Luds Point Recreation Management Zone

Supporting Information

Fishing, primitive camping, and hunting activities for individuals seeking seclusion and little contact with 

other users. 

SRMA/RMZ Objective(s)

Objective Statement: Manage the Luds Point RMZ to provide opportunities for visitors to engage in 

fishing, primitive camping, and hunting so they realize a “moderate” level of the targeted experience and 

benefit outcomes.

Activities: Fishing; primitive, boat-in camping; hunting; and viewing wildlife and natural scenery.

Experiences: Engaging in preferred activities with friends and family, testing and improving outdoor 

skills, enjoying natural scenery and wildlife, and enjoying activities in a natural setting.

Benefits:

Personal: Nature/aesthetic appreciation, positive change in mood and emotion, and identification with a 

special place.

Community/Social: Improved image of the area and its recreational opportunities, improved image of land 

management agencies, and bonding with family and friends.

Environmental: Greater protection of fish, wildlife, and plant habitat from public use, create sense of 

“ownership,” and create sense of stewardship of the area.

Economic: Retain recreation spending in local area and increase desirability of a place to live and work.

Recreation Setting Characteristics

Physical Components:

Remoteness – Middle Country

Naturalness – Middle Country

Facilities – Middle Country

Social Components:

Contacts – Back Country

Group Size – Back Country

Evidence of Use – Middle 

Country

Administrative Components:

Mechanized Use – Middle 

Country

Visitor Services – Middle Country

Management Controls – Middle 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Focus on public access, resource protection, and sanitation. 

Improvements will be preceded by project planning and will adhere to guidelines developed for the area. 

Other Programs: Manage as VRM Class II (Alternative I and IV) or VRM Class III (Alternative II and III).

Implementation Decisions

Encourage and develop cooperative relationships with user groups and State and county agencies to 

facilitate responsible recreational use of the area.

Occasional visitor contact and law enforcement.

Marketing activities would include directional and interpretative signing, brochures, and word of mouth.

Routine monitoring of facilities and periodic visitor contact to assess achievements of objectives.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-210

Yahoo Special Recreation Management Area

Supporting Information

Off-highway vehicle (OHV) riding in sand washes within proximity to major transportation systems and 

available during the winter season.

SRMA/RMZ Objective(s)

Objective Statement: Manage the Yahoo SRMA to provide opportunities for visitors to engage in OHV 

riding so they realize a “moderate” level of the targeted experience and benefit outcomes.

Activities: OHV riding (e.g., ATV, motorcycle, UTV).

Experiences: Exhilaration and excitement, testing and improving riding skills, being with friends and 

family, enjoying preferred activities in an appropriate setting, and risk taking.

Benefits:

Personal: Positive change in mood and emotion, social bonding/cohesion/ cooperation, and improve skills 

for outdoor enjoyment.

Community/Social: Improved image of the area and its recreational opportunities creates a positive image 

of OHV motorized activities.

Environmental: Creates a sense of “ownership” and stewardship of the area. Increased awareness and 

protection of landscapes.

Economic: Retains recreation spending in the local area and increases attractiveness of southern Idaho 

as a place to live.

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Front Country

Facilities – Front Country

Social Components:

Contacts – Middle/Front Country

Group Size – Middle Country

Evidence of Use – Front Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Front Country

Management Controls – Front 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Improvements geared toward facilitating parking, sanitation, 

and reducing sediment into Yahoo Creek. 

Designated open/play areas and trail system.

Other Programs: Manage as VRM Class III.

Implementation Decisions

Encourage and pursue cooperative partnerships with user groups, land owners, and Idaho Department of 

Parks and Recreation (IDPR) to facilitate responsible recreational use of the area.

Pursue partnerships with user groups and IDPR for a formal site plan.

Marketing activities will include word-of-mouth, directional signing, and brochures.

Routine monitoring of area and facilities and periodic visitor contact and monitoring to assess 

achievement of objectives.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

A-211

Canyonlands Special Recreation Management Area

Supporting Information

A natural setting necessary to provide quality non-motorized hunting and other recreation experiences.

SRMA/RMZ Objective(s)

Objective Statement: Manage the Canyonlands SRMA to provide opportunities for visitors to engage in 

non-motorized recreation experiences including hunting, hiking, and equestrian so they realize a 

“moderate” level of the targeted experience and benefit outcomes.

Activities: Hunting, viewing wildlife/natural scenery, hiking, equestrian, and fishing.

Experiences: Enjoying risk-taking adventure, solitude, and natural scenery and wildlife. Testing and 

improving outdoor skills and engaging in preferred activities with family and friends.

Benefits:

Personal: Improved outdoor recreation skills, nature/aesthetic appreciation, and greater sense of 

adventure. 

Community/Social: Improved image of the area and its recreational opportunities and improved skills for 

outdoor enjoyment with family/friends.

Environmental: Provides natural habitat and open space and protection of wildlife and fish habitat. 

Economic: Increased desirability of a place to live and work.

Recreation Setting Characteristics

Physical Components:

Remoteness – Back Country

Naturalness – Back Country

Facilities – Back Country

Social Components:

Contacts – Primitive

Group Size – Back Country

Evidence of Use – Primitive/Back 

Country

Administrative Components:

Mechanized Use – Middle 

Country

Visitor Services – Back Country

Management Controls – Back 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Maintain the backcountry character and primarily 

undisturbed natural landscape to allow visitors to enjoy opportunities for solitude.

Marketing activities will include word of mouth, Owyhee & Bruneau River Systems Boating Guide, 

interpretive and educational signing, and directional signing.

Visitor number collections will continue to include registration forms for whitewater boating. Complete 

periodic visitor surveys to assess achievement of objectives.

Other Programs: None

Implementation Decisions

Primarily manage for backcountry recreation opportunities, including non-motorized hunting and 

whitewater boating. Maintain and protect natural and cultural resource values. Any improvements will be 

preceded by site/area plans.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-212

Deadman Special Recreation Management Area

Supporting Information

Off-highway vehicle (OHV) riding within proximity to major transportation systems and available during the 

winter season.

SRMA/RMZ Objective(s)

Objective Statement: Manage the Deadman SRMA to provide opportunities for visitors to engage in 

OHV riding so they realize a “moderate” level of the targeted experience and benefit outcomes.

Activities: OHV riding (e.g., ATV, motorcycle, UTV).

Experiences: Exhilaration and excitement, testing and improving riding skills, being with friends and 

family, enjoying preferred activities in an appropriate setting, and risk taking.

Benefits:

Personal: Positive change in mood and emotion, social bonding/cohesion/ cooperation, and improve skills 

for outdoor enjoyment. 

Community/Social: Improved image of the area and its recreational opportunities creates a positive image 

of OHV motorized activities. 

Environmental: Creates a sense of “ownership” and stewardship of the area. Increased awareness and 

protection of landscapes. 

Economic: Retains recreation spending in the local area and increases attractiveness of southern Idaho 

as a place to live. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Front Country

Facilities – Front Country

Social Components:

Contacts – Middle/Front Country

Group Size – Middle Country

Evidence of Use – Front Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Front Country

Management Controls – Front 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Improvements geared toward facilitating parking, sanitation 

for users, and developing an OHV training area. 

Designated Open/Play areas and trail system. 

Other Programs: None.

Implementation Decisions

Encourage and pursue cooperative partnerships with user groups, land owners, and IDPR to facilitate 

responsible recreational use of the area.

Pursue partnerships with user groups and IDPR for a formal site/layout/facility plan.

Marketing activities will include word-of mouth, directional signing, and brochures.

Routine monitoring of area and facilities and periodic visitor contact and monitoring to assess 

achievement of objectives.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

A-213

Deadman/Yahoo Special Recreation Management Area

Deadman Recreation Management Zone (including Pasadena Recreation Management 

Zone, Alternative I)

Supporting Information

Off-highway vehicle (OHV) riding within proximity to major transportation systems and available during the 

winter season.

SRMA/RMZ Objective(s)

Objective Statement: Manage the Deadman SRMA to provide opportunities for visitors to engage in 

OHV riding so they realize a “moderate” level of the targeted experience and benefit outcomes.

Activities: OHV riding (e.g., ATV, motorcycle, UTV).

Experiences: Exhilaration and excitement, testing and improving riding skills, being with friends and 

family, enjoying preferred activities in an appropriate setting, and risk taking. 

Benefits:

Personal: Positive change in mood and emotion, social bonding/cohesion/ cooperation, and improve skills 

for outdoor enjoyment. 

Community/Social: Improved image of the area and its recreational opportunities creates a positive image 

of OHV motorized activities. 

Environmental: Creates a sense of “ownership” and stewardship of the area. Increased awareness and 

protection of landscapes. 

Economic: Retains recreation spending in the local area and increases attractiveness of southern Idaho 

as a place to live. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Front Country

Facilities – Front Country

Social Components:

Contacts – Middle/Front Country

Group Size – Middle Country

Evidence of Use – Front Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Front Country

Management Controls – Front 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Improvements geared toward facilitating parking, sanitation 

for users, and developing an OHV training area. 

Designated Open/Play areas and trail system.

Other Programs: None

Implementation Decisions

Encourage and pursue cooperative partnerships with user groups, land owners, and IIDPR to facilitate 

responsible recreational use of the area.

Pursue partnerships with user groups and IDPR for a formal site/layout/facility plan.

Marketing activities will include word-of mouth, directional signing, and brochures.

Routine monitoring of area and facilities. Periodic visitor contact and monitoring to assess achievement of 

objectives.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-214

Yahoo Recreation Management Zone

Supporting Information

Off-highway vehicle (OHV) riding in sand washes within proximity to major transportation systems and 

available during the winter season.

SRMA/RMZ Objective(s)

Objective Statement: Through the life of the plan, manage the Yahoo SRMA to provide opportunities for 

visitors to engage in OHV riding so they realize a “moderate” level of the targeted experience and benefit 

outcomes.

Activities: OHV riding (e.g., ATV, motorcycle, UTV).

Experiences: Exhilaration and excitement, testing and improving riding skills, being with friends and 

family, enjoying preferred activities in an appropriate setting, risk taking. 

Benefits:

Personal: Positive change in mood and emotion, social bonding/cohesion/ cooperation, improve skills for 

outdoor enjoyment. 

Community/Social: Improved image of the area and its recreational opportunities, creates a positive 

image of OHV motorized activities. 

Environmental: Creates a sense of “ownership” and stewardship of the area, Increased awareness and 

protection of landscapes. 

Economic: Retains recreation spending in the local area, increased attractiveness of southern Idaho as a 

place to live. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Front Country

Facilities – Front Country

Social Components:

Contacts – Middle/Front Country

Group Size – Middle Country

Evidence of Use – Front Country

Administrative Components:

Mechanized Use – Front Country

Visitor Services – Front Country

Management Controls – Front 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Improvements geared toward facilitating parking, sanitation, 

and reducing sediment into Yahoo Creek. 

Designated Open/Play areas and trail system.

Other Programs: Manage as VRM Class III.

Implementation Decisions

Encourage and pursue cooperative partnerships with user groups, land owners, and Idaho State 

Department of Parks and Recreation (IDPR) to facilitate responsible recreational use of the area.

Pursue partnerships with user groups and IDPR for a formal site plan.

Marketing activities will include word-of-mouth, directional signing, and brochures.

Routine monitoring of area and facilities; periodic visitor contact and monitoring to assess achievement of 

management of management objectives.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

A-215

Rosevear Gulch Recreation Management Zone

Supporting Information

Easily accessed designated trail system off-highway vehicles (OHVs) available for use during the winter.

SRMA/RMZ Objective(s)

Objective Statement: Through the life of the plan, manage the Rosevear Gulch RMZ to provide 

opportunities for visitors to engage in motorized trail riding opportunities on a series of designated routes 

so they realize a “moderate” level of the targeted experience and benefit outcomes.

Activities: OHV riding (e.g., ATV, motorcycle, UTV) and wild horse viewing.

Experiences: Exhilaration and excitement, testing and improving riding skills, being with friends and 

family, enjoying preferred activities in an appropriate setting, risk taking. 

Benefits:

Personal: Positive change in mood and emotion, social bonding/cohesion/ cooperation, improve skills for 

outdoor enjoyment. 

Community/Social: Improved image of the area and its recreational opportunities, creates a positive 

image of OHV motorized activities. 

Environmental: Creates a sense of “ownership” and stewardship of the area, Increased awareness and 

protection of landscapes. 

Economic: Retains recreation spending in the local area, increased attractiveness of southern Idaho as a 

place to live. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Front Country

Naturalness – Front Country

Facilities – Middle Country

Social Components:

Contacts – Middle Country

Group Size – Back/Middle 

Country

Evidence of Use – Front Country

Administrative Components:

Mechanized Use – Middle/Front 

Country

Visitor Services – Middle Country

Management Controls – Front 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Improvements geared toward facilitating access and 

accommodating users. Develop designated trail system. Project plan will be developed and will adhere to 

guidelines developed for the area.

Word-of mouth, directional signing, brochure, map.

Routine monitoring of area; periodic visitor contact to assess achievement of management objectives. 

OHV a primary focus of monitoring.

Other Programs: None

Implementation Decisions

Encourage and pursue cooperative partnerships with user groups, land owners, and Idaho State 

Department of Parks and Recreation (IDPR) to facilitate responsible recreational use of the area.

Pursue partnerships with user groups and IDPR for a formal site plan.

Marketing activities will include word-of-mouth, directional signing, and brochures.

Routine monitoring of area and facilities; periodic visitor contact and monitoring to assess achievement of 

management of management objectives.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-216

Jarbidge Foothills Special Recreation Management Area

Supporting Information

A natural setting necessary to provide quality non-motorized hunting and other recreation experiences.

SRMA/RMZ Objective(s)

Objective Statement: Manage the Jarbidge Foothills SRMA to provide opportunities for non-motorized 

recreation experiences including hunting, hiking, and equestrian so they realize a “moderate” level of the 

targeted experience and benefit outcomes.

Activities: Hunting, viewing wildlife/natural scenery, hiking, equestrian, and mountain biking.

Experiences: Enjoying natural scenery and wildlife, testing and improving outdoor skills, and engaging in 

preferred activities with family and friends.

Benefits:

Personal: Nature/aesthetic appreciation, identification with a special place, and improved mental wellbeing.

Community: Improved image of the area and its recreational opportunities and improved skills for outdoor 

enjoyment with family/friends.

Environmental: Provides natural habitat and open space and protection of wildlife and fish habitat.

Economic: Increased desirability of a place to live and work. 

Recreation Setting Characteristics

Physical Components:

Remoteness – Middle Country

Naturalness – Middle Country

Facilities – Back Country

Social Components:

Contacts – Back Country

Group Size – Back Country

Evidence of Use – Middle 

Country

Administrative Components:

Mechanized Use – Middle 

Country

Visitor Services – Back Country

Management Controls – Middle 

Country

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Primarily manage for backcountry recreation opportunities, 

including non-motorized hunting. Maintain and protect natural and cultural resource values. Any 

improvements will be preceded by site/area plans.

Directional and informational signing.

Periodic visitor contact and monitoring to assess achievement of objectives.

Other Programs: Manage as VRM Class II.

Implementation Decisions

Focus on non-motorized recreation experiences. Encourage and develop cooperative relationships with 

land owners, volunteer groups, and state agencies to facilitate responsible recreational use of the area. 

Motorized routes would be designated to maximize wildlife habitat core size.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

A-217

Extensive Recreation Management Areas

The Extensive Recreation Management Area (ERMA) is an administrative unit that requires specific 

management consideration in order to address recreation use, demand, or recreation and visitor services

program investments. The ERMA is managed to support and sustain the principal recreation activities 

and the associated qualities and conditions of the ERMA. Management of ERMAs is commensurate with 

the management of other resources and resource uses. While generally unnecessary, ERMAs may be 

subdivided into Recreation Management Zones to ensure recreation and visitor services are managed 

commensurate with the management of other resources and resource uses. Below are management 

strategies for ERMAs that would be designated under Alternative VI (Proposed Plan).

Canyonlands ERMA

ERMA Objective(s)

Objective Statement: Manage the Canyonlands ERMA to provide opportunities for visitors to engage in 

motorized and non-motorized recreation experiences including hunting, hiking, and equestrian so they 

realize a “moderate” level of the targeted experience and benefit outcomes.

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Maintain the backcountry character and primarily 

undisturbed natural landscape to allow visitors to enjoy opportunities for solitude.

Primarily manage for backcountry recreation opportunities, including non-motorized hunting and 

whitewater boating. 

Maintain and protect natural and cultural resource values. 

Any improvements will be preceded by site/area plans.

Other Programs: Manage as VRM Class I (Wilderness).

Implementation Decisions

Marketing activities will include word of mouth, Owyhee & Bruneau River Systems Boating Guide, 

interpretive and educational signing, and directional signing.

Visitor number collections will continue to include registration forms for whitewater boating. Periodic visitor 

surveys will assess achievement of objectives.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

A-218

Jarbidge Foothills ERMA

ERMA Objective(s)

Objective Statement: Manage the Jarbidge Foothills ERMA to provide opportunities for visitors to 

engage in motorized and non-motorized recreation experiences including hunting, hiking, and equestrian 

so they realize a “moderate” level of the targeted experience and benefit outcomes.

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Motorized routes would be designated to maximize wildlife 

habitat core size.

Primarily manage for backcountry recreation opportunities, including non-motorized hunting. 

Maintain and protect natural and cultural resource values. 

Any improvements will be preceded by site/area plans.

Other Programs: Manage as VRM Class II.

Implementation Decisions

Encourage and develop cooperative relationships with land owners, volunteer groups, and state agencies 

to facilitate responsible recreational use of the area.

Marketing activities will include directional and informational signing.

Periodic visitor contact and monitoring to assess achievement of objectives.

Rosevear ERMA

ERMA Objective(s) 

Objective Statement: Manage the Rosevear Gulch ERMA to provide opportunities for visitors to engage 

in motorized trail riding opportunities on a series of designated routes so they realize a “moderate” level of 

the targeted experience and benefit outcomes.

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Improvements geared toward facilitating access and 

accommodating users. 

Develop designated trail system.

Other Programs: None.

Implementation Decisions

Encourage and pursue cooperative partnerships with user groups and state/county agencies to facilitate 

responsible recreational use of the area.

Project plan will be developed and will adhere to guidelines developed for the area.

Marketing activities will include word-of mouth, directional signing, brochures, and maps.

Routine monitoring of area and periodic visitor contact to assess achievement of objectives. Off-highway 

vehicle a primary focus of monitoring.
Jarbidge Proposed RMP/Final EIS Appendix H: Recreation Management Areas

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A-219

Luds Point ERMA

ERMA Objective(s)

Objective Statement: Manage the Luds Point ERMA to provide opportunities for visitors to engage in 

fishing, primitive camping, and hunting so they realize a “moderate” level of the targeted experience and 

benefit outcomes.

Management Actions and Allowable Use Decisions

Recreation and Visitor Services Program: Focus on public access, resource protection, and sanitation.

Improvements will be preceded by project planning and will adhere to guidelines developed for the area.

Other Programs: None.

Implementation Decisions

Encourage and develop cooperative relationships with user groups and State and county agencies to 

facilitate responsible recreational use of the area.

Occasional visitor contact and law enforcement.

Marketing activities would include directional and interpretative signing, brochure, and word of mouth.

Routine monitoring of facilities and periodic visitor contact to assess achievements of objectives.

Public Lands Not Established as Recreation Management Areas

Those areas not identified in the planning area as recreation management areas (SRMAs or ERMAs) are 

managed to meet basic recreation and visitor services and resource stewardship needs. Recreation is not 

emphasized on these lands; however, recreation activities may occur, except on those lands closed to 

public use. The recreation and visitor services are managed to allow recreation uses that are not in 

conflict with the primary uses of these lands. Public lands not managed as recreation management areas 

include the following objectives:

Visitor Health and Safety - Ensure that participants in dispersed recreational activities have a low 

potential for serious accidents due to human-created conditions and minimal exposure to hazardous 

health conditions.

Use and User Conflicts - Mitigate conflicts with other uses through visitor outreach efforts. Direct 

administration of conflicts may be implemented by way of recreation use restrictions, realignments, 

signage, and closures.

Resource Protection - Create an increased awareness and understanding and a sense of 

stewardship in recreational activity participants so their conduct safeguards natural resource 

values.Implementation actions for Public Lands Not Designated as recreation management areas

include:

Managing the lands to provide a variety of recreational opportunities including primitive, back 

country, middle country, and front country. Provide outdoor settings ranging from areas with a 

high-to-moderate opportunity for solitude and closeness to nature and to areas where visitors 

have a higher interaction with other users.

Limiting recreational access, season of use, and numbers of users, if needed, to protect other 

resources.

Implementing site-specific facility development on a case-by-case basis, based on needs for 

resource protection, user demand, and visitor health and safety.
Appendix H: Recreation Management Areas Jarbidge Proposed RMP/Final EIS

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Providing signs, brochures, and maps to facilitate the use and enjoyment of public lands and to 

protect visitor health, safety, and resources.

Managing BLM lands adjacent to other Federal and State lands to complement the recreational 

experience on the adjoining lands.

Monitoring recreational activities and implementing adaptive management where there are 

conflicts with other uses (e.g., grazing, wilderness management) and private lands.
Jarbidge Proposed RMP/Final EIS Appendix I: Lands Available for Disposal

A-221

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APPENDIX I: LANDS AVAILABLE FOR DISPOSAL

The parcels listed below meet Federal Land Policy and Management Act (FLPMA) Section 203 criteria for 

disposal by sale. These lands, in addition to lands outside of Zone 1, may also be considered for disposal 

under FLPMA Section 206 exchange or under the Recreation and Public Purposes Act of 1954. 

Criteria for Land Ownership Adjustment

Lands with Highest Priority for Retention or Acquisition

Those lands specifically identified by the Shoshone-Bannock and/or Shoshone-Paiute Tribes as 

having special importance related to treaty and/or traditional uses and values;

Important, crucial, or critical habitat for special status species including proposed species, listed 

species, and candidate species under the Endangered Species Act; State-listed species; and BLM 

State Director-designated sensitive species;

Riparian areas and wetlands;

Parcels that provide public and/or administrative access to larger blocks of public land; and

Lands with special designation or management emphasis (see category below).

Special Designation/Management Areas Where it is a High Priority to Acquire 

Inholdings

Areas of Critical Environmental Concern, or lands adjacent to and important for expansion of such 

areas;

National Historic Trails;

Wild and Scenic Rivers (eligible, recommended suitable, or designated);

Significant cultural resources and sites eligible for inclusion on the National Register of Historic 

Places; and

Wilderness and Wilderness Study Areas.

Areas Generally Retained, but May be Exchanged for Parcels with Higher 

Resource Values

Important habitat for fish or wildlife, 

Developed recreation sites and recreation access, 

Recreation opportunities and benefits, 

Significant energy and mineral resources, 

Significant cave resources, 

Significant cultural resources and sites eligible for inclusion on the National Register of Historic 

Places, and

Significant paleontological resources.

Areas that Are a High Priority for Disposal

Parcels which are difficult or costly to administer (manageability and/or isolation of the parcel);

Parcels more suitable for management by another Federal or State agency; and

Parcels of special importance to (and generally adjacent to) local communities for purposes including, 

but not limited to, community expansion, extended community services, or economic development.

Other Issues to be Considered Prior to any Land Tenure Adjustment Action

To what extent the individual action will help achieve overall land ownership management objectives 

at the watershed level, in cooperation with State and private landowners;

Existing legal accessibility of the land for public uses;

Amount of public investments in facilities or improvements and the potential for recovering those 

investments; and

Consistency with cooperative agreements and plans or policies of other agencies.
Appendix I: Lands Available for Disposal Jarbidge Proposed RMP/Final EIS

A-222

Table I-1. Lands Available for Disposal in Alternative I. 

Township and Range Section Legal Description Approximate

Acres

T. 5 S., R. 11 E., 

17 NW1⁄4SW1⁄4 40

18 SE1⁄4SE1⁄4 40

30 Lots 1-4, SE1⁄4NW1⁄4, E1⁄2SW1⁄4, W1⁄2SE1⁄4 343

31 Lot 5, NW1⁄4NE1⁄4, NE1⁄4NW1⁄4 88

32 E1⁄2NW1⁄4 81

T. 6 S., R. 9 E., 

2 SW1⁄4NW1⁄4, NE1⁄4SW1⁄4, S1⁄2SE1⁄4 160

3 Lot 1 43

4 SW1⁄4 159

5 S1⁄2 321

8 W1⁄2NE1⁄4, NW1⁄4 240

9 E1⁄2NW1⁄4 80

15 SE1⁄4 160

17 all 640

20 all 641

21 all 639

22 W1⁄2NE1⁄4, W1⁄2, W1⁄2SE1⁄4 480

23 W1⁄2SW1⁄4 80

26 NW1⁄4NW1⁄4, W1⁄2SE1⁄4 120

27 N1⁄2NE1⁄4, SW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4, 

NW1⁄4SE1⁄4 400

28 N1⁄2, N1⁄2S1⁄2 481

29 all 642

32 all 640

33 S1⁄2N1⁄2, S1⁄2 483

34 SW1⁄4, W1⁄2SE1⁄4, SE1⁄4SE1⁄4 281

35 E1⁄2SW1⁄4, N1⁄2SE1⁄4 160

T. 6 S., R. 11 E., 6 SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 80

T. 7 S., R. 9 E., 

1 SW1⁄4SW1⁄4 40

2 S1⁄2 321

3 Lots 2-4, S1⁄2 442

4 all 480

9 N1⁄2 320

10 N1⁄2N1⁄2, SW1⁄4NE1⁄4, NW1⁄4 283

11 N1⁄2N1⁄2, SE1⁄4NW1⁄4, 203

12 N1⁄2, N1⁄2SE1⁄4, SE1⁄4SE1⁄4 438

T. 7 S., R. 10 E.

6 Lot 2, W1⁄2SE1⁄4 121

7 Lots 1-4, SW1⁄4NE1⁄4, E1⁄2NW1⁄4, S1⁄2 485

8 S1⁄2SW1⁄4, E1⁄2SE1⁄4 160

9 S1⁄2SW1⁄4 80

17 W1⁄2, SE1⁄4 480

T. 7 S., R. 10 E.

18 Lot 1, NE1⁄4, E1⁄2NW1⁄4, SE1⁄4 431

20 N1⁄2NE1⁄4, SE1⁄4NE1⁄4, NE1⁄4SE1⁄4 161

21 N1⁄2NW1⁄4, SW1⁄4NW1⁄4, SW1⁄4, S1⁄2SE1⁄4 361

22 NE1⁄4NW1⁄4, SW1⁄4SE1⁄4 80

27 W1⁄2NW1⁄4, NW1⁄4SW1⁄4 120

28 N1⁄2NE1⁄4, E1⁄2NW1⁄4, S1⁄2SW1⁄4 241

32 N1⁄2NE1⁄4 80

33 N1⁄2NW1⁄4 80

T. 8 S., R. 14 E., 7 NE1⁄4SW1⁄4 40
Jarbidge Proposed RMP/Final EIS Appendix I: Lands Available for Disposal

A-223

Township and Range Section Legal Description Approximate

Acres

T. 12 S., R. 13 E., 

2 Lots 1,2,4, SW1⁄4NE1⁄4, S1⁄2SE1⁄4 240

3 Lots 1-4, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, 

N1⁄2SW1⁄4, SE1⁄4SW1⁄4, W1⁄2SE1⁄4 482

9 W1⁄2NE1⁄4, NW1⁄4, SW1⁄4 402

10 W1⁄2NE1⁄4, NW1⁄4 243

11 NW1⁄4 161

12 N1⁄2, N1⁄2S1⁄2, SE1⁄4SW1⁄4, SE1⁄4 606

13 NE1⁄4NE1⁄4, S1⁄2NE1⁄4, E1⁄2NW1⁄4, 

NE1⁄4SW1⁄4, SE1⁄4 404

19 Lots 1-4, N1⁄2, N1⁄2S1⁄2, SE1⁄4SW1⁄4, 

SW1⁄4SE1⁄4 604

20 N1⁄2, NE1⁄4SW1⁄4, SE1⁄4 525

21 NW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4 283

22 SW1⁄4SW1⁄4 40

24 E1⁄2 323

25 E1⁄2 322

26 SW1⁄4SW1⁄4 40

27 SW1⁄4NE1⁄4, W1⁄2NW1⁄4, SE1⁄4NW1⁄4, S1⁄2 484

28 W1⁄2NW1⁄4, SW1⁄4, S1⁄2SE1⁄4 322

29 N1⁄2NE1⁄4, SE1⁄4NE1⁄4 121

30 Lots 1-4, W1⁄2NE1⁄4, E1⁄2NW1⁄4, S1⁄2 557

35 S1⁄2NE1⁄4, NW1⁄4, S1⁄2 565

Total 19,693

Table I-2. Lands Available for Disposal in Alternative II. 

Township and Range Section Legal Description Approximate 

Acres

T. 5 S., R. 10 E., 

25 SE1⁄4NE1⁄4, S1⁄2 359

26 SW1⁄4NE1⁄4, W1⁄2NW1⁄4, SE1⁄4NW1⁄4, S1⁄2 477

27 S1⁄2NE1⁄4, S1⁄2S1⁄2 , NE1⁄4SE1⁄4 279

33 SE1⁄4NE1⁄4, N1⁄2SE1⁄4 119

34 NE1⁄4, E1⁄2NW1⁄4, N1⁄2S1⁄2, SE1⁄4 515

35 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, SW1⁄4, 

W1⁄2SE1⁄4 519

T. 5 S., R. 11 E., 

17 NW1⁄4SW1⁄4 40

18 SE1⁄4SE1⁄4 40

30 Lots 1-4, SE1⁄4NW1⁄4, E1⁄2SW1⁄4, W1⁄2SE1⁄4 343 

31 Lot 5, NW1⁄4NE1⁄4, NE1⁄4NW1⁄4 88

32 E1⁄2NW1⁄4 81 

T. 6 S., R. 9 E., 

2 SW1⁄4NW1⁄4, NE1⁄4SW1⁄4, S1⁄2SE1⁄4 160

4 SW1⁄4 159

5 S1⁄2 321 

8 W1⁄2NE1⁄4, NW1⁄4 240

9 E1⁄2NW1⁄4 80

11 E1⁄2 321 

12 S1⁄2NE1⁄4, NW1⁄4, S1⁄2 561 

13 All 638

14 E1⁄2, SE1⁄4NW1⁄4, NE1⁄4SW1⁄4, S1⁄2SW1⁄4, 

SE1⁄4 480

15 SE1⁄4 160

17 All 640
Appendix I: Lands Available for Disposal Jarbidge Proposed RMP/Final EIS

A-224

Township and Range Section Legal Description Approximate 

Acres

T. 6 S., R. 9 E., 

20 All 639

21 All 639

22 W1⁄2NE1⁄4, W1⁄2, W1⁄2SE1⁄4 480

23 N1⁄2NE1⁄4, SW1⁄4NE1⁄4, W1⁄2SW1⁄4 201

24 E1⁄2, N1⁄2NW1⁄4, SE1⁄4NW1⁄4, SE1⁄4 439

26 NW1⁄4NW1⁄4, W1⁄2SE1⁄4 120

27 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, N1⁄2SW1⁄4, 

NW1⁄4SE1⁄4 400

28 N1⁄2, N1⁄2S1⁄2 481 

29 All 640

32 All 640

33 S1⁄2N1⁄2, S1⁄2 483 

34 SW1⁄4, W1⁄2SE1⁄4, SE1⁄4SE1⁄4 281 

35 E1⁄2SW1⁄4, N1⁄2SE1⁄4 160

T. 6 S., R. 10 E., 

2 Lots 2-4, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, N1⁄2S1⁄2, 

SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 486 

7 Lots 3-4, S1⁄2 329

8 S1⁄2 323 

11 NW1⁄4NE1⁄4 40

17 All 648 

18 All 664

19 All 655 

20 All 635

21 All 640

27 All 643 

28 All 642 

29 All 641 

30 Lot 1, NE1⁄4, NE1⁄4NW1⁄4, N1⁄2SE1⁄4 324 

T. 6 S., R. 11 E., 

6 SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 80

8 W1⁄2NE1⁄4, E1⁄2, W1⁄2SE1⁄4 482 

17 E1⁄2, E1⁄2NW1⁄4, NE1⁄4SW1⁄4, S1⁄2SW1⁄4, 520

20 N1⁄2N1⁄2, S1⁄2NE1⁄4, SE1⁄4NW1⁄4, N1⁄2SE1⁄4 358

21 Lots 1-4, NW1⁄4, N1⁄2S1⁄2 476

T. 7 S., R. 9 E., 

1 SW1⁄4SW1⁄4 40

2 S1⁄2 321 

3 Lots 2-4, S1⁄2 442 

4 All 480

9 N1⁄2 320

10 N1⁄2N1⁄2, SW1⁄4NE1⁄4, NW1⁄4 283 

11 N1⁄2N1⁄2, SE1⁄4NW1⁄4 203 

12 N1⁄2, N1⁄2SE1⁄4, SE1⁄4SE1⁄4 438

T. 7 S., R. 10 E., 

6 Lot 2, W1⁄2SE1⁄4 121 

7 Lots 1-4, SW1⁄4NE1⁄4, E1⁄2NW1⁄4, S1⁄2 485 

8 S1⁄2SW1⁄4, E1⁄2SE1⁄4 160

9 S1⁄2SW1⁄4 80

17 W1⁄2, SE1⁄4 480

18 Lot 1, E1⁄2, E1⁄2NW1⁄4 431 

20 N1⁄2NE1⁄4, SE1⁄4NE1⁄4, NE1⁄4SE1⁄4 161 

21 N1⁄2NW1⁄4, SW1⁄4NW1⁄4, SW1⁄4, S1⁄2SE1⁄4 361 

22 NE1⁄4NW1⁄4, SW1⁄4SE1⁄4 80

27 W1⁄2NW1⁄4, NW1⁄4SW1⁄4 120

28 N1⁄2NE1⁄4, E1⁄2NW1⁄4, S1⁄2SW1⁄4 241 
Jarbidge Proposed RMP/Final EIS Appendix I: Lands Available for Disposal

A-225

Township and Range Section Legal Description Approximate 

Acres

T. 7 S., R. 10 E., 32 N1⁄2NE1⁄4 80

33 N1⁄2NW1⁄4 80

T. 8 S., R. 13 E., 

2 S1⁄2SW1⁄4 79

3 W1⁄2SE1⁄4, SE1⁄4SE1⁄4 118

5 S1⁄2 321 

6 Lots 10,11, S1⁄2 319

7 All 627 

8 All 644 

9 All 646 

10 All 614

11 NW1⁄4 161 

14 NW1⁄4SW1⁄4 40

15 S1⁄2NE1⁄4, W1⁄2, N1⁄2SE1⁄4, SW1⁄4SE1⁄4 492

21 All 647

22 W1⁄2NE1⁄4, W1⁄2 411

24 E1⁄2, E1⁄2NW1⁄4, E1⁄2SW1⁄4 482

25 All 642

26 E1⁄2SE1⁄4 80

28 N1⁄2, SW1⁄4, W1⁄2SE1⁄4 566

33 W1⁄2NE1⁄4, W1⁄2 404

35 E1⁄2E1⁄2, W1⁄2SE1⁄4 240

T. 8 S., R. 14 E., 30 Lots 1-4, W1⁄2 285

31 Lots 1-4, NE1⁄4NW1⁄4, NE1⁄4SW1⁄4 144 

T. 9 S., R. 13 E., 

1 Lots 1-4, SW1⁄4 NE1⁄4, NW1⁄4, E1⁄2SW1⁄4 340

4 Lots4-6, W1⁄2W1⁄2 229

9 W1⁄2W1⁄2,SE1⁄4NW1⁄4, E1⁄2SW1⁄4, W1⁄2SE1⁄4 363 

11 SE1⁄4NE1⁄4, S1⁄2 356

12 W1⁄2NW1⁄4, NW1⁄4SW1⁄4 47 

14 E1⁄2 219

15 SE1⁄4NE1⁄4, N1⁄2S1⁄2, S1⁄2SW1⁄4, SW1⁄4SE1⁄4 321 

21 N1⁄2, E1⁄2SW1⁄4, SE1⁄4 565 

22 NW1⁄4NE1⁄4, N1⁄2NW1⁄4, W1⁄2SW1⁄4, 

SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 281 

23 W1⁄2NE1⁄4, S1⁄2SW1⁄4, NE1⁄4SW1⁄4 151 

26 SW1⁄4NE1⁄4, NW1⁄4, S1⁄2 387 

27 E1⁄2 321 

28 E1⁄2, SW1⁄4NW1⁄4, E1⁄2SW1⁄4 443 

33 N1⁄2NW1⁄4 81 

35 E1⁄2, N1⁄2NW1⁄4 365

T. 9 S., R. 14 E., 6 Lot 10 1 

T. 10 S., R. 13 E., 

1 Lots 3,4 35

2 Lots 1-4 120

3 Lots 1,2, SW1⁄4NE1⁄4, W1⁄2SE1⁄4 201

4 SE1⁄4SE1⁄4 41 

T. 12 S., R. 13 E., 

2 Lots 1,2,4, SW1⁄4NE1⁄4, S1⁄2SE1⁄4 240

3 Lots 1-4, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, 

N1⁄2SW1⁄4, SE1⁄4SW1⁄4, W1⁄2SE1⁄4 482 

9 W1⁄2NE1⁄4, W1⁄2 402

10 W1⁄2NE1⁄4, NW1⁄4 243 

11 NW1⁄4 161 

12 N1⁄2, N1⁄2S1⁄2, SE1⁄4SW1⁄4, S1⁄2SE1⁄4 606 
Appendix I: Lands Available for Disposal Jarbidge Proposed RMP/Final EIS

A-226

Township and Range Section Legal Description Approximate 

Acres

T. 12 S., R. 13 E., 

13 NE1⁄4NE1⁄4, S1⁄2NE1⁄4, E1⁄2NW1⁄4, 

NE1⁄4SW1⁄4, SE1⁄4 404 

19 Lots 1-4, N1⁄2, N1⁄2S1⁄2, SE1⁄4SW1⁄4 

SW1⁄4SE1⁄4 604 

20 N1⁄2, NE1⁄4SW1⁄4, SE1⁄4 525 

21 NW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4 283 

22 SW1⁄4SW1⁄4 40

24 E1⁄2 323 

25 E1⁄2 322 

26 SW1⁄4SW1⁄4 40

27 W1⁄2W1⁄2, SW1⁄4NE1⁄4, SE1⁄4NW1⁄4, S1⁄2 484 

28 W1⁄2W1⁄2, E1⁄2SW1⁄4, S1⁄2SE1⁄4 322 

29 N1⁄2NE1⁄4, SE1⁄4NE1⁄4 121 

30 Lots 1-4, W1⁄2NE1⁄4, E1⁄2NW1⁄4, S1⁄2 557

35 E1⁄2, S1⁄2NE1⁄4, E1⁄2NW1⁄4, S1⁄2 565 

Total 45,769

Table I-3. Lands Available for Disposal in Alternative III. 

Township and Range Section Legal Description Approximate 

Acres

T. 5 S., R. 11 E., 

17 NW1⁄4SW1⁄4 40

18 SE1⁄4SE1⁄4 40

30 Lots 1-4, SE1⁄4NW1⁄4, SW1⁄4, W1⁄2SE1⁄4 343 

31 Lot 5, NW1⁄4NE1⁄4, NE1⁄4NW1⁄4 88

32 E1⁄2NW1⁄4 81 

T. 6 S., R. 9 E., 

2 SW1⁄4NW1⁄4, NE1⁄4SW1⁄4, S1⁄2SE1⁄4 160

3 Lot 1 43

4 SW1⁄4 159

5 S1⁄2 321 

8 W1⁄2NE1⁄4, NW1⁄4 240

9 E1⁄2NW1⁄4 80

15 SE1⁄4 160

17 All 640

20 All 641

21 All 639

22 W1⁄2, W1⁄2NE1⁄4, W1⁄2SE1⁄4 480

23 W1⁄2SW1⁄4 80

26 NW1⁄4NW1⁄4, W1⁄2SE1⁄4 120

27 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, N1⁄2SW1⁄4, 

NW1⁄4SE1⁄4 400

28 N1⁄2, N1⁄2S1⁄2 481 

29 All 642 

32 All 640

33 S1⁄2N1⁄2, S1⁄2 483 

34 SW1⁄4, W1⁄2SE1⁄4, SE1⁄4SE1⁄4 281 

35 E1⁄2SW1⁄4, N1⁄2SE1⁄4 160

T. 6 S., R. 11 E., 6 SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 80

T. 7 S., R. 9 E., 

1 SW1⁄4SW1⁄4 40

2 S1⁄2 321 

3 Lots 2-4, S1⁄2 442 

4 All 480
Jarbidge Proposed RMP/Final EIS Appendix I: Lands Available for Disposal

A-227

Township and Range Section Legal Description Approximate 

Acres

T. 7 S., R. 9 E., 

9 N1⁄2 320

10 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4 283 

11 N1⁄2N1⁄2, SE1⁄4NW1⁄4 203 

12 N1⁄2, N1⁄2SE1⁄4, SE1⁄4SE1⁄4 438

T. 7 S., R. 10 E., 

6 Lot 2, W1⁄2SE1⁄4 121 

7 Lots 1-4, W1⁄2, SW1⁄4NE1⁄4, S1⁄2 485 

8 S1⁄2SW1⁄4, E1⁄2SE1⁄4 160

9 S1⁄2SW1⁄4 80

17 W1⁄2, SE1⁄4 480

18 Lot 1, E1⁄2, E1⁄2NW1⁄4 431 

20 N1⁄2NE1⁄4, SE1⁄4NE1⁄4, NE1⁄4SE1⁄4 161 

21 W1⁄2W1⁄2, NE1⁄4NW1⁄4, E1⁄2SW1⁄4, S1⁄2SE1⁄4 361 

22 NE1⁄4NW1⁄4, SW1⁄4SE1⁄4 80

27 W1⁄2NW1⁄4, NW1⁄4SW1⁄4 120

28 N1⁄2NE1⁄4, E1⁄2NW1⁄4, S1⁄2SW1⁄4 241 

32 N1⁄2NE1⁄4 80

33 N1⁄2NW1⁄4 80

T. 8 S., R. 14 E., 7 NE1⁄4SW1⁄4 40

T. 12 S., R. 13 E., 

2 Lots 1,2,4, SW1⁄4NE1⁄4, S1⁄2SE1⁄4 240

3 Lots 1-4, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, 

N1⁄2SW1⁄4, SE1⁄4SW1⁄4, W1⁄2SE1⁄4 482 

9 W1⁄2, W1⁄2NE1⁄4 402

10 W1⁄2NE1⁄4, NW1⁄4 243 

11 NW1⁄4 161 

12 N1⁄2, N1⁄2S1⁄2, SE1⁄4SW1⁄4, S1⁄2SE1⁄4 606 

13 E1⁄2E1⁄2, SW1⁄4NE1⁄4, E1⁄2NW1⁄4, 

NE1⁄4SW1⁄4, W1⁄2SE1⁄4 404 

19 Lots 1-4, N1⁄2, N1⁄2S1⁄2, SE1⁄4SW1⁄4 

SW1⁄4SE1⁄4 604 

20 N1⁄2, NE1⁄4SW1⁄4, SE1⁄4 525 

21 NW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4 283 

22 SW1⁄4SW1⁄4 40

24 E1⁄2 323 

25 E1⁄2 322 

26 SW1⁄4SW1⁄4 40

27 S1⁄2, SW1⁄4NE1⁄4, W1⁄2NW1⁄4, SE1⁄4NW1⁄4 484 

28 W1⁄2W1⁄2, E1⁄2SW1⁄4, S1⁄2SE1⁄4 322 

29 N1⁄2NE1⁄4, SE1⁄4NE1⁄4 121 

30 Lots 1-4, W1⁄2,W1⁄2NE1⁄4, SE1⁄4 557

35 W1⁄2, S1⁄2NE1⁄4, SE1⁄4 565 

Total 19,693

Table I-4. Lands Available for Disposal in Alternative IV. 

Township and Range Section Legal Description Approximate 

Acres

T. 5 S., R. 10 E., 

25 S1⁄2, SE1⁄4NE1⁄4 359

26 S1⁄2, SW1⁄4NE1⁄4, W1⁄2NW1⁄4, SE1⁄4NW1⁄4 477

27 S1⁄2S1⁄2, S1⁄2NE1⁄4, NE1⁄4SE1⁄4 279

33 SE1⁄4NE1⁄4, N1⁄2SE1⁄4 119

34 E1⁄2, E1⁄2NW1⁄4, N1⁄2SW1⁄4, SE1⁄4SW1⁄4 515
Appendix I: Lands Available for Disposal Jarbidge Proposed RMP/Final EIS

A-228

Township and Range Section Legal Description Approximate 

Acres

T. 5 S., R. 10 E., 35 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, SW1⁄4, 

W1⁄2SE1⁄4 519

T. 5 S., R. 11 E., 

17 NW1⁄4SW1⁄4 40

18 SE1⁄4SE1⁄4 40

30 Lots 1-4, SE1⁄4NW1⁄4, E1⁄2SW1⁄4, W1⁄2SE1⁄4 343 

31 Lot 5, NW1⁄4NE1⁄4, NE1⁄4NW1⁄4 88

32 E1⁄2NW1⁄4 81 

T. 6 S., R. 9 E., 

2 SW1⁄4NW1⁄4, NE1⁄4SW1⁄4, S1⁄2SE1⁄4 160

3 Lot 1 43 

4 SW1⁄4 159

5 S1⁄2 321 

8 W1⁄2NE1⁄4, NW1⁄4 240

9 E1⁄2NW1⁄4 80

15 SE1⁄4 160

17 All 640

20 All 641 

21 All 639

22 W1⁄2, W1⁄2NE1⁄4, W1⁄2SE1⁄4 480

23 W1⁄2SW1⁄4 80

26 NW1⁄4NW1⁄4, W1⁄2SE1⁄4 120

27 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, N1⁄2SW1⁄4, 

NW1⁄4SE1⁄4 400

28 N1⁄2, N1⁄2S1⁄2 481 

29 All 642 

32 All 640

33 S1⁄2N1⁄2, S1⁄2 483 

34 S1⁄2S1⁄2, N1⁄2SW1⁄4, NW1⁄4SE1⁄4 281 

35 E1⁄2SW1⁄4, N1⁄2SE1⁄4 160

T. 6 S., R. 10 E., 2 Lots 2-4, N1⁄2S1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, 

SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 486 

T. 6 S., R. 11 E., 6 SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 80

T. 7 S., R. 9 E., 

1 SW1⁄4SW1⁄4 40

2 S1⁄2 321 

3 Lots 2-4, S1⁄2 442 

4 All 480

9 N1⁄2 320

10 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4 283 

11 N1⁄2N1⁄2, SE1⁄4NW1⁄4 203 

12 N1⁄2, N1⁄2SE1⁄4, SE1⁄4SE1⁄4 438

T. 7 S., R. 10 E., 

6 Lot 2, W1⁄2SE1⁄4 121 

7 Lots 1-4, W1⁄2, SW1⁄4NE1⁄4, SE1⁄4 485 

8 S1⁄2SW1⁄4, E1⁄2SE1⁄4 160

9 S1⁄2SW1⁄4 80

17 W1⁄2, SE1⁄4 480

18 Lot 1, E1⁄2, E1⁄2NW1⁄4 431 

20 N1⁄2NE1⁄4, SE1⁄4NE1⁄4, NE1⁄4SE1⁄4 161 

21 W1⁄2W1⁄2, NE1⁄4NW1⁄4, E1⁄2SW1⁄4, S1⁄2SE1⁄4 361 

22 NE1⁄4NW1⁄4, SW1⁄4SE1⁄4 80

27 W1⁄2NW1⁄4, NW1⁄4SW1⁄4 120

28 N1⁄2NE1⁄4, E1⁄2NW1⁄4, S1⁄2SW1⁄4 241 

32 N1⁄2NE1⁄4 80

33 N1⁄2NW1⁄4 80
Jarbidge Proposed RMP/Final EIS Appendix I: Lands Available for Disposal

A-229

Township and Range Section Legal Description Approximate 

Acres

T. 8 S., R. 14 E., 7 NE1⁄4SW1⁄4 40

Total 15,723

No lands are available for disposal via sale in Alternative V.

Table I-5. Lands Available for Disposal in Alternative VI (Proposed RMP). 

Township and Range Section Legal Description Approximate 

Acres

T. 5 S., R. 10 E., 

25 S1⁄2S1⁄2, SE1⁄4NE1⁄4 NW1⁄4SW1⁄4, 

NE1⁄4SE1⁄4 279

26 N1⁄2S1⁄2, SW1⁄4NE1⁄4, W1⁄2NW1⁄4, 

SE1⁄4NW1⁄4, SE1⁄4SW1⁄4, S1⁄2SE1⁄4 437

27 S1⁄2NE1⁄4, NE1⁄4SE1⁄4 120

33 SE1⁄4NE1⁄4, N1⁄2SE1⁄4 119

34 N1⁄2 S1⁄2, SE1⁄4SW1⁄4, S1⁄2SE1⁄4 277

35 NE1⁄4NE1⁄4, W1⁄2SW1⁄4, SE1⁄4SW1⁄4 159

T. 5 S., R. 11 E., 

17 NW1⁄4SW1⁄4 40

18 SE1⁄4SE1⁄4 40

30 Lots 1-4, SE1⁄4NW1⁄4 183

31 Lot 5, NW1⁄4NE1⁄4, NE1⁄4NW1⁄4 88

32 E1⁄2NW1⁄4 81 

T. 6 S., R. 9 E., 

2 SW1⁄4NW1⁄4, NE1⁄4SW1⁄4, S1⁄2SE1⁄4 160

3 Lot 1 43

4 SW1⁄4 159

5 S1⁄2 321 

8 W1⁄2NE1⁄4, NW1⁄4 240

9 E1⁄2NW1⁄4 80

14 SE1⁄4NW1⁄4, S1⁄2SW1⁄4, NE1⁄4SW1⁄4 160

15 SE1⁄4 160

17 All 640

20 All 641 

21 All 639

22 W1⁄2, W1⁄2NE1⁄4, W1⁄2SE1⁄4 480

23 W1⁄2SW1⁄4 80

26 NW1⁄4NW1⁄4, W1⁄2SE1⁄4 120

27 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4, N1⁄2SW1⁄4, 

NW1⁄4SE1⁄4 400

28 N1⁄2, N1⁄2S1⁄2 481 

29 All 642

32 All 640

33 S1⁄2, S1⁄2N1⁄2 483 

35 E1⁄2SW1⁄4, N1⁄2SE1⁄4 160

T. 6 S., R. 10 E., 2 Lots 2-4, N1⁄2S1⁄2, SW1⁄4NE1⁄4, 

S1⁄2NW1⁄4,SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 486

T. 6 S., R. 11 E., 6 SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 80

T. 6 S., R. 12 E., 8 Lots 5, 8 70

T. 7 S., R. 9 E., 

1 SW1⁄4SW1⁄4 40

2 S1⁄2 321

3 Lots 2-4, S1⁄2 442
Appendix I: Lands Available for Disposal Jarbidge Proposed RMP/Final EIS

A-230

Township and Range Section Legal Description Approximate 

Acres

T. 7 S., R. 9 E., 

4 All 480

9 N1⁄2 320

10 N1⁄2N1⁄2, SW1⁄4NE1⁄4, S1⁄2NW1⁄4 283 

11 N1⁄2N1⁄2 , SE1⁄4NW1⁄4 203 

12 S1⁄2N1⁄2, N1⁄2NW1⁄4, N1⁄2SE1⁄4, SE1⁄4SE1⁄4 359

T. 7 S., R. 10 E., 

7 Lots 2-4, E1⁄2SW1⁄4, S1⁄2SE1⁄4 253 

17 W1⁄2NW1⁄4, NW1⁄4SW1⁄4 120

18 Lot 1, NE1⁄4, E1⁄2NW1⁄4, N1⁄2SE1⁄4 351 

22 NE1⁄4NW1⁄4, SW1⁄4SE1⁄4 80

28 S1⁄2SW1⁄4 80

32 N1⁄2NE1⁄4 80

33 N1⁄2NW1⁄4 80

T. 8 S., R. 13 E., 14 NW1⁄4SW1⁄4 40

T. 8 S., R. 14 E., 7 NE1⁄4SW1⁄4 40

T. 9 S., R. 12 E., 20 SE1⁄4SE1⁄4 40

24 SE1⁄4SE1⁄4 40

T. 9 S., R. 13 E., 19 Lots 3-4, NE1⁄4NE1⁄4 82 

T. 10 S., R. 12 E., 12 SW1⁄4NW1⁄4 40

Total 12,962

Federal Land Transaction Facilitation Act

The lands listed below were identified for potential disposal as of July 25, 2000, and may therefore be 

considered for disposal under the Federal Land Transaction Facilitation Act of 2000 (FLTFA). Under 

FLTFA, the monies received from sales or exchanges of lands identified for disposal in land use plans as 

of July 25, 2000 are retained in an account and can be used by the BLM and other Federal agencies to 

purchase additional lands; they are not deposited in the General Treasury. 

Table I-6. Lands Available for Disposal under the Federal Land Transaction Facilitation Act in 

Alternative I. 

Township and Range Section Legal Description Approximate 

Acres

T. 6 S., R. 9 E., 

8 S1⁄2NW1⁄4 80

17 All 640

20 W1⁄2NE1⁄4, NW1⁄4, E1⁄2SW1⁄4, SE1⁄4 480

21 N1⁄2, SW1⁄4, W1⁄2SE1⁄4 560

22 W1⁄2NE1⁄4, W1⁄2, W1⁄2SE1⁄4 480

27 SW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4, NW1⁄4SE1⁄4 320

28 N1⁄2, N1⁄2S1⁄2 480

29 NE1⁄4, SW1⁄4NW1⁄4, N1⁄2SW1⁄4 280

32 SW1⁄4SW1⁄4 40

T. 12 S., R. 13 E., 22 SW1⁄4SW1⁄4 40

27 NW1⁄4NW1⁄4 40

Total 3,440
Jarbidge Proposed RMP/Final EIS Appendix I: Lands Available for Disposal

A-231

Table I-7. Lands Available for Disposal under the Federal Land Transaction Facilitation Act in 

Alternative II.

Township and Range Section Legal Description Approximate 

Acres

T. 5 S., R. 10 E., 33 SE1⁄4NE1⁄4 40

T. 6 S., R. 9 E., 

8 S1⁄2NW1⁄4 80

17 All 640

20 W1⁄2NE1⁄4, NW1⁄4, E1⁄2SW1⁄4, SE1⁄4 480

21 N1⁄2, SW1⁄4, W1⁄2SE1⁄4 560

22 W1⁄2NE1⁄4, W1⁄2, W1⁄2SE1⁄4 480

27 SW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4, NW1⁄4SE1⁄4 320

T. 6 S., R. 9 E., 

28 N1⁄2, N1⁄2S1⁄2 480

29 NE1⁄4, SW1⁄4NW1⁄4, N1⁄2SW1⁄4 280

32 SW1⁄4SW1⁄4 80

T. 6 S., R. 10 E., 11 NW1⁄4NE1⁄4 40

T. 9 S., R. 13 E., 

4 Lot 3 53

9 SE1⁄4NW1⁄4, 80

21 N1⁄2 440

28 E1⁄2NE1⁄4, SW1⁄4NW1⁄4, E1⁄2SW1⁄4 80

33 N1⁄2NW1⁄4 80

T. 12 S., R. 13 E., 22 SW1⁄4SW1⁄4 40

27 NW1⁄4NW1⁄4 40

Total 4,293

Table I-8. Lands Available for Disposal under the Federal Land Transaction Facilitation Act in 

Alternative III.

Township and Range Section Legal Description Approximate 

Acres

T. 6 S., R. 9 E., 

8 S1⁄2NW1⁄4 80

17 All 640

20 W1⁄2NE1⁄4, NW1⁄4, E1⁄2SW1⁄4, SE1⁄4 480

21 N1⁄2, SW1⁄4, W1⁄2SE1⁄4 560

22 W1⁄2NE1⁄4, W1⁄2, W1⁄2SE1⁄4 480

27 SW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4, NW1⁄4SE1⁄4 320

28 N1⁄2, N1⁄2S1⁄2 480

29 NE1⁄4, SW1⁄4NW1⁄4, N1⁄2SW1⁄4 280

32 SW1⁄4SW1⁄4 40

T. 12 S., R. 13 E., 22 SW1⁄4SW1⁄4 40

27 NW1⁄4NW1⁄4 40

Total 3,440

Table I-9. Lands Available for Disposal under the Federal Land Transaction Facilitation Act in 

Alternative IV.

Township and Range Section Legal Description Approximate 

Acres

T. 5 S., R. 10 E., 33 SE1⁄4NE1⁄4 40

T. 6 S., R. 9 E., 

8 S1⁄2NW1⁄4 80

17 All 640

20 W1⁄2NE1⁄4, NW1⁄4, E1⁄2SW1⁄4, SE1⁄4 480

21 N1⁄2, SW1⁄4, W1⁄2SE1⁄4 560

22 W1⁄2NE1⁄4, W1⁄2, W1⁄2SE1⁄4 480

27 SW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4, NW1⁄4SE1⁄4 320
Appendix I: Lands Available for Disposal Jarbidge Proposed RMP/Final EIS

A-232

Township and Range Section Legal Description Approximate 

Acres

T. 6 S., R. 9 E., 

28 N1⁄2, N1⁄2S1⁄2 480

29 NE1⁄4, SW1⁄4NW1⁄4, N1⁄2SW1⁄4 280

32 SW1⁄4SW1⁄4 40

Total 3,400

No lands are available for disposal in Alternative V.

Table I-10. Lands Available for Disposal under the Federal Land Transaction Facilitation Act in 

Alternative VI.

Township and Range Section Legal Description Approximate 

Acres

T. 6 S., R. 9 E., 

8 S1⁄2NW1⁄4 80

17 All 640

20 W1⁄2NE1⁄4, NW1⁄4, E1⁄2SW1⁄4, SE1⁄4 480

21 N1⁄2, SW1⁄4, W1⁄2SE1⁄4 560

22 W1⁄2NE1⁄4, W1⁄2, W1⁄2SE1⁄4 480

27 SW1⁄4NE1⁄4, NW1⁄4, N1⁄2SW1⁄4, NW1⁄4SE1⁄4 320

28 N1⁄2, N1⁄2S1⁄2 480

29 NE1⁄4, SW1⁄4NW1⁄4, N1⁄2SW1⁄4 280

32 SW1⁄4SW1⁄4 80

Total 3,400
Jarbidge Proposed RMP/Final EIS Appendix J: Livestock Grazing Allotments

A-233

APPENDIX J: LIVESTOCK GRAZING ALLOTMENTS 

Allotment 

Name

Allotment 

Number

Authorized 

AUMsA,B

Number of 

Livestock

Livestock

TypeC

Season of 

Use

Land OwnershipD 10-Year 

Avg. 

Actual 

UseE

10-Year 

Avg. 

TNR 

BLM State Private Military Use

Antelope Butte 

North 1087 732 61 C 3/1-2/28 7,465 640 0 0 1,060

Antelope 

Springs 1096 5,964 497 C 3/1-2/28 40,826 3,558 7,951 0 5,802

79 33 S 3/1-2/28 62

Bear Creek

Idaho 1026 160 53 C 7/1-9/30 1,034 0 34 0 160

Black Mesa 1080 1,007 340 C 3/1-3/31 10,923 770 660 0 941 1/1-2/28

Blackrock 

Pocket 1102 1,889 159 C 3/1-2/28 12,086 835 221 0 1,229

Blue Butte 277 1,311 127 C 3/1-2/28 9,871 640 0 0 2,392 1,079

Brackett Bench 

AMP 1008 2,376 198 C 3/1-2/28 19,518 866 1,198 0 1,669

Brown’s GulchF 1053 4,464 750 C 3/1-2/28 0 0 0 2,904 2,855

Bruneau HillF 1057 4,205 365 C 3/1-2/28 19,020 2,555 0 17,868 3,748

Buck Flat AMP 1122 1,717

545 C 3/15-6/14

250 C 6/15-7/5 21,898 969 1,249 0 1,323

75 C 7/6-7/15

Camas Slough 1095 252 21 C 3/1-2/28 1,605 0 0 0 120

Canyonview 

(Echo Jewett) 1058 1,082 1,600 C 3/1-2/28 0 0 0 3,164 718

Cedar Butte 10 1007 879 891 C 6/1-6/30 4,853 1,580 7,870 0 759

Cedar Butte 

Devil Cr 1002 3,210 294 C 3/1-2/28 18,929 2,564 10,499 0 1,916

Cedar Butte 

Eastside 1001 373 62 C 4/16-10/15 4,964 0 40 0 493 129
Appendix J: Livestock Grazing Allotments Jarbidge Proposed RMP/Final EIS

A-234

Allotment 

Name

Allotment 

Number

Authorized 

AUMsA,B

Number of 

Livestock

Livestock

TypeC

Season of 

Use

Land OwnershipD 10-Year 

Avg. 

Actual 

UseE

10-Year 

Avg. 

TNR 

BLM State Private Military Use

Cedar Canyon 

Field 1013 15 15 C 3/1-3/30 199 0 97 0 12

Cedar Creek 1131 4,416 350 C 3/1-2/28 25,113 689 2,595 0 3,409

22 9 S 3/1-2/28 14

Cedar Creek 

Canyon 1023 317 158 C 4/1-5/31 2,491 0 48 0 312

Cedar Crossing 1022 741 40 C 4/10-4/30 4,952 594 13 0 695 129 5/1-10/15

Cheatgrass 1069 294 39 C 4/1-11/15 3,387 0 0 0 294

China Creek 1025 713 187 C 4/15-6/30 10,490 640 1,037 0 583 187 11/1-12/9

Clover Crossing 1136 7,734 1,600 C 3/1-2/28 26,048 1,897 439 0 4,045

300 25 H 3/1-2/28 59

Conover 1126 4,217 525 C 4/1-11/30 15,771 1,288 789 0 3,497 5 4/1-4/30

Coonskin AMP 1123 3,552 296 C 3/1-2/28 41,072 1,919 471 0 2,090

1,913 797 S 3/1-2/28 890

Crawfish 1118 648 54 C 3/1-2/28 10,421 640 0 0 635

Deadwood

Pocket 1067 311 155 C 4/15-6/14 2,878 0 64 0 259

Devil Creek/

Balanced Rock 1133 3,588

599

C 

3/1-5/15

38,782 640 3,312 0 2,871

600 11/15-2/28

69 350 S 6/1-6/30 78

Diamond A 

Bruneau 

Canyon

1100 100 50 C 11/16-1/15 276 98 295 100

Diamond A 

Taylor Pocket 1077

320 49 C 4/1-4/15

15,392 160 830 0 

425 271 C 4/16-6/15

22 9 H 4/1-4/30 24 13 H 5/1-5/31
Jarbidge Proposed RMP/Final EIS Appendix J: Livestock Grazing Allotments

A-235

Allotment 

Name

Allotment 

Number

Authorized 

AUMsA,B

Number of 

Livestock

Livestock

TypeC

Season of 

Use

Land OwnershipD 10-Year 

Avg. 

Actual 

UseE

10-Year 

Avg. 

TNR 

BLM State Private Military Use

Diamond A Unit 1021

8,052 671 C 3/1-2/28

102,068 5,691 13,880 0 

5,366

492

50 H 3/1-4/30

367

10 H 5/1-6/30

17 H 9/1-11/15

50 H 11/16-2/28

24 H 3/1-5/31

24 H 11/15-2/28

Dove Springs 1146 1,360

53 C 4/1-11/15

8,943 0 0 0 1,276 331

80 C 3/1-3/15

100 C 3/16-4/15

130 C 4/16-9/30

100 C 10/1-10/31

E&W 

Deadwood Trap 1020

890 309 C 5/1-11/15

3,922 640 1,547 0 

404

27 10 H 5/1-10/31 0 

83 420 S 6/1-6/30 51

East Juniper 

Draw 1132 2,472 206 C 3/1-2/28 20,706 1,281 2,074 0 1,317

East Roseworth 

Point 1061 292 40 C 4/15-11/22 1,988 640 0 0 321 100

Echo 4 296 3,732 311 C 3/1-2/28 16,815 640 0 0 2,254

Echo 5 282 13,704 1,142 C 3/1-2/28 28,196 1,282 0 0 6,885

Echo Clover 341 1,992 1,600 C 3/1-2/28 2,473 0 0 0 763

Echo Hammett 

Livestock 342 818 2,040 S 4/1-5/31 6,178 640 0 0 482

Echo Luby 283 403 125 C 4/4-7/10 3,807 0 640 0 614 377

Flat Top 1059 5,865 503 C 3/1-2/28 12,939 2,557 0 21,938 3,774

Grassy Hills 1029 852 71 C 3/1-2/28 4,904 0 0 0 515

Grassy Hills 

AMP 1121 2,278 306 C 4/1-1/31 20,369 1,922 4,816 0 2,235
Appendix J: Livestock Grazing Allotments Jarbidge Proposed RMP/Final EIS

A-236

Allotment 

Name

Allotment 

Number

Authorized 

AUMsA,B

Number of 

Livestock

Livestock

TypeC

Season of 

Use

Land OwnershipD 10-Year 

Avg. 

Actual 

UseE

10-Year 

Avg. 

TNR 

BLM State Private Military Use

Grassy 

Windmill 1134 442 60 C 4/1-10/31 2,415 0 7 0 348

Grindstone 1062 675 118 C 4/1-11/15 6,784 640 0 0 1,052 479

Guerry Patrick 1094

604 425 C 7/1-7/2

4,115 0 115 0 

350 152 C 7/3-9/30

277 425 C 10/1-10/9 124 1,405 S 6/1-6/30

Hagerman 

Group 1150 2,312

52 C 4/1-11/30

36,153 557 1,756 0 124 C 4/1-11/30 1,432 1,814

75 C 3/1-2/28

204 1,000 S 3/1-3/31 662 0 

Hallelujah 343 2,271 208 C 3/1-2/28 7,190 640 0 0 1,084

Horse Butte 

AMP 1120 1,524 190 C 4/1-11/30 22,397 640 0 0 1,923 848

House Creek 1042 667 676 C 9/1-9/30 4,297 1,191 10,153 0 425

Inside Desert 353 10,088 848 C 3/1-2/28 103,376 5,899 7,334 0 14,807

Juniper Butte 1119 3,528 294 C 3/1-2/28 18,174 954 198 0 1,818

Juniper Draw 1138 684 57 C 3/1-2/28 6,203 1,280 23 0 1,006

Juniper Ranch 1031 2,551 318 C 4/1-1130 36,838 3,199 319 0 3,379 904 40 10 H 4/1-1130 0 

Kinyon 1046 820 122 C 4/1-7/1517,619 640 0 0 968 150 C 11/20-2/7 347

64 8 H 4/1-11/30 0 

Kubic 1147 4,392 366 C 3/1-2/28 21,959 0 3,832 0 3,533

Little Grass/

Deadwood 1017 1,127

200 C 5/1-9/30

9,409 654 3,157 0 112 C 10/1-10/31 800

200 C 10/1-11/15

40 16 H 4/15-11/15 26

Little House 

Creek FFR 1093 110 112 C 6/1-6/30 489 779 1,795 0 106

Little Island 438 720 119 C 5/1–10/31 1,645 0 2,748 0 0 
Jarbidge Proposed RMP/Final EIS Appendix J: Livestock Grazing Allotments

A-237

Allotment 

Name

Allotment 

Number

Authorized 

AUMsA,B

Number of 

Livestock

Livestock

TypeC

Season of 

Use

Land OwnershipD 10-Year 

Avg. 

Actual 

UseE

10-Year 

Avg. 

TNR 

BLM State Private Military Use

Little Three 

Island 1074 151 20 C 4/1-11/15 857 0 0 0 164 40

Lower Salmon 

Falls 1141 126 43 C 4/16-7/15 925 0 21 0 92

Lower Saylor 

Creek 1055

801 265 C 12/30-2/28

10,992 640 0 912

774 265 C 3/1-3/31

101 85 S 3/16-6/15 71

125 S 10/16-12/15

Magic Water 1056 16 16 C 6/16-7/15 166 0 0 0 16

Noh Field 1140 1,068 89 C 3/1-2/28 6,098 640 1,040 0 848

North Balanced 

Rock 1139 49 250 S 6/1-6/30 1,494 0 0 0 52

North Fork 

Field 1088 564 47 C 3/1-2/28 2,502 40 929 0 327

Notch Butte 1144

2,809 353 C 11/1-6/30

27,182 1,280 0 0 

2,278 339

352 2,200 S 3/20-4/8 309 2,400 S 12/22-12/25

Pigtail Butte 1125 5,520 460 C 3/1-2/28 28,524 1,280 1,024 0 2,657

Player Butte 1047 141 110 C 10/23-11/30 1,429 0 640 0 133

Player Canyon 1027 275 68 C 7/1-10/31 1,913 0 0 0 238

Poison Butte 0354 6,360 530 C 3/1-2/28 74,000 3,183 11,803 0 9,778

River Bridge 1072 33 9 C 4/1-1/15 141 0 347 0 21

5 H 4/1-1/15 12

Roseworth 

Point 1014 1,572 196 C 4/1-11/30 11,788 578 0 0 1,443

Roseworth 

Tract FFR 1009 56 7 C 4/1-11/30 859 640 6,637 0 57

Saylor 

Creek/North 

Three Island

1078 2,040 271 C 4/1-11/15 19,765 1,289 1,268 0 2,509 490

Seventy-One 

Desert 1099 3,649 327 C 3/1-2/28 39,891 1,772 0 0 2,965

Sheep Trail 

Allot. 1063 52 3,975 S 6/1-6/2 2,319 0 0 0 36
Appendix J: Livestock Grazing Allotments Jarbidge Proposed RMP/Final EIS

A-238

Allotment 

Name

Allotment 

Number

Authorized 

AUMsA,B

Number of 

Livestock

Livestock

TypeC

Season of 

Use

Land OwnershipD 10-Year 

Avg. 

Actual 

UseE

10-Year 

Avg. 

TNR 

BLM State Private Military Use

Signal Butte 1092 1,182 1,198 C 6/1-6/30 10,978 616 369 0 1,070 88

South Crow’s 

Nest 1135 779 790 C 6/1-6/30 10,444 640 0 0 827 708

South 

Deadwood 1086 299 293 C 8/1-8/31 961 0 553 0 173

South 

Roseworth 1151 35 35 C 10/15-11/13 216 0 0 0 35

Thompson 1079 1,867 248 C 4/1-11/15 22,098 640 0 0 2,650 942

Thousand 

Springs 1142 283 32 C 4/1-12/25 1,516 0 2,539 0 265

Three Creek 

#8B 1075 518 300 C 6/1-6/30 2,819 0 40 0 489 250 C 11/1-11/27

Three Creek #8 1070 792 66 C 3/1-2/28 4,769 0 1,441 0 692

Three Creek #8 

PVT AL 1066 439 168 C 6/1-10/31 3,334 0 1,758 0 436

Three Cr. 

Blossom Prv 1071 498

17 C 6/1-7/15

5,899 0 1,043 0 301

196 C 6/1-6/30

71 C 7/1-8/31

57 C 9/16-10/31

50 C 11/1-11/30

30 5 H 6/1-11/30 0 

Three 

Creek/Devil 

Creek

1076 3,105

810 C 4/1-5/31

675 C 6/1-6/30 19,052 958 6,464 0 2,013

400 C 10/1-12/1

Three Island 1073 474 63 C 4/1-11/15 4,133 0 0 0 571 132

Turner Cedar 

Butte 1000 745 100 C 4/15-10/15 2,401 640 2,829 0 491 550 C 11/5-1/10

Twin Butte 1145

5,208 434 C 3/1-2/28

47,846 1,893 1,601 0 

5,777 1,192

408 1,000 S 3/1-3/31 1,045 1,000 S 12/1-12/31
Jarbidge Proposed RMP/Final EIS Appendix J: Livestock Grazing Allotments

A-239

Allotment 

Name

Allotment 

Number

Authorized 

AUMsA,B

Number of 

Livestock

Livestock

TypeC

Season of 

Use

Land OwnershipD 10-Year 

Avg. 

Actual 

UseE

10-Year 

Avg. 

TNR 

BLM State Private Military Use

West Saylor 

CreekF 1137

4,011 500 C 4/1-11/30

22,944 1,924 0 44,783

4,069

2,575 2,575 S 10/16-12/15 1,039 2,535 S 10/16-12/15

Wilkins Island 1084 772

379 C 5/1-7/1

137 C 5/15-10/31 7,063 67 7,179 0 530

136 C 5/15-10/31

Winter Camp 1064 516 43 C 3/1-2/28 12,009 480 320 0 516

Yahoo 1143 2,952 246 C 3/1-2/28 13,984 640 3,600 0 1,827 A An animal unit month (AUM) is the amount of forage (800 lbs. dry matter) required to sustain a cow and her calf for one month. A horse, bull, or 5 sheep/goats 

are considered equivalent to one AUM.

B All authorized use is active, the Jarbidge Field Office does not have any suspended use.

C C=cattle, S=Sheep, H=Horse D Acreage represented in this table is landownership within allotment boundaries. Some private and State lands may be fenced and managed separately from 

BLM-managed lands. E Actual use is a post-use report demonstrating the actual number of livestock and period of time they were on the allotment. Actual use in this table represents 

both authorized AUMs and Temporary Non-Renewable (TNR) permitted AUMs. F Portions of allotment are also within the Birds of Prey National Conservation Area. Acreage for these areas are not represented in this table.
This Page Intentionally Left Blank
Jarbidge Proposed RMP/Final EIS Appendix K: Reasonably Foreseeable Development

Scenario for Oil and Gas Development

A-241

______ ___________ _ __

_____ __________ _

Prepared by:

Reviewed by:

APPENDIX K: REASONABLY FORESEEABLE 

DEVELOPMENT SCENARIO FOR OIL AND GAS 

DEVELOPMENT

REASONABLY FORESEEABLE DEVELOPMENT SCENARIO

FOR

OIL AND GAS DEVELOPMENT

IN THE

JARBIDGE FIELD OFFICE

Prepared by: Karen Porter, BLM Idaho State Office Geologist

 __signed copy on file__ _ Date: 6/25/2009

Reviewed by: Steven W. Moore, BLM Idaho State Office Geologist

 __signed copy on file Date: 6/25/2009__
Appendix K: Reasonably Foreseeable Development Jarbidge Proposed RMP/Final EIS

Scenario for Oil and Gas Development

A-242

Summary

Based on the geology of the Jarbidge Field Office (i.e., the planning area), the lack of historical drilling 

activity, the lack of any historic or currently producing oil/gas wells/fields in south central Idaho and the 

surrounding area, and the lack of infrastructure to support oil and/or gas development, the potential for 

discovery and development of hydrocarbons in the planning area has been determined to be low. 

It is anticipated that very little to no oil and gas activity, aside from leasing and perhaps approving a few 

geophysical surveys, would occur during the life of the land use plan. However, in order to comply with 

the Supplemental Program Guidance for Fluid Minerals (BLM Manual Section 1624-2); this report 

describes the potential surface impacts associated with a minimal level of activity that could occur. 

Therefore, it is assumed that making the BLM-administered public lands in the planning area available for 

oil and gas leasing could result in the drilling of one to two exploratory wells during the next 20 years, for 

a total surface disturbance of up to 30 acres (five acres/drill pad + 10 acres/access road = 15 acres/drill 

site x 2 drill sites = 30 acres). It is assumed that one of the wells drilled would be capable of commercial 

production. Based on this assumption, a five-well field would be developed, disturbing an additional 60 

acres. It is anticipated that two or three geophysical exploration programs would occur and that they 

would likely be conducted along existing roads or trails or by overland travel, thereby causing minor 

impacts to surface resources. These activities are likely to occur either in the northwest corner of the 

planning area or in the Cedar reservoir/China Mountain area. 

Introduction

This report, describing a Reasonably Foreseeable Development Scenario (RFDS), accompanies the Oil 

and Gas Potential Report (BLM, 2009c) prepared for the planning area. This report describes the 

anticipated level of oil and gas exploration and development activity associated with oil and gas leasing. 

These projections are necessary for assessing the anticipated impacts of oil and gas related activity in the 

EIS for the Jarbidge Resource Management Plan (RMP); for determining which lands within the field 

office area will be available for oil and gas leasing; and for determining what stipulations may be 

necessary to attach to leases in order to protect the surface resources. These anticipated impacts are for 

the BLM-administered public lands described above during the next 20 years (2009-2029). 

Description of Geology

The geology of the planning area is described in detail in the Oil and Gas Potential Report prepared for 

the area (BLM, 2009c). The planning area lies within the Snake River Plain physiographic province, which 

is entirely covered by Cenozoic volcanic and quaternary sedimentary deposits. The planning area is 

dominated by the Owyhee Plateau, a broad volcanic upland considered to be a continuation of the 

eastern Snake River Plain. However, in the northern portion of the planning area, sediments of the 

Glenns Ferry Formation, which originated from Plio- Pleistocene Lakes Bruneau and Idaho, are found. 

These could theoretically contain hydrocarbons, although none have been found. There are no known 

outcrops or exposures of pre-Tertiary rocks in the planning area, and there is no direct or indirect 

evidence to indicate what types of rocks underlay the thick veneer of volcanics that cover the majority of 

the planning area. 

Past and Present Oil and Gas Leasing Activity

A total of 251 leases have been issued at one time or another in the planning area (4.3% of the state 

total). Currently there are no active oil and gas leases in the area. Until recently, no parcels had been 

nominated for leasing in the planning area under the 1987 leasing process. In 2008, approximately 

58,000 acres were nominated by a single entity. These parcels are situated in the Cedar Creek/ China 

Mountain area (T 14-16 S, R 13-14 E), in the southeast corner of the planning area. Leasing is being 

deferred on these parcels pending completion of the RMP/EIS. 

Past and Present Oil and Gas Exploration Activity

Three wells were drilled in 1950 for the purpose of exploring for oil and gas in the planning area - all 

located in the extreme northwest corner. No showings of gas or oil were encountered at any interval in 

any of the three wells. This is the only exploration activity that has occurred in the planning area.
Jarbidge Proposed RMP/Final EIS Appendix K: Reasonably Foreseeable Development

Scenario for Oil and Gas Development

A-243

1

1

2

2

Past and Present Oil and Gas Development Activity

To date, there has never been any oil or gas production in Idaho, despite the drilling of approximately 150 

wells in the state (Breckenridge et. al., 2006). 

Oil and Gas Occurrence Potential

The majority of the planning area has a low potential for oil and gas occurrence throughout, as described 

in detail in the Oil and Gas Potential Report (BLM, 2009c). No Paleozoic or Mesozoic marine sedimentary 

rocks, which could provide possible hydrocarbon source rocks consistent with USGS’s hypothetical PreMiocene or Older Tertiary Plays (Peterson, 1995), are exposed in the planning area, nor is there any 

evidence that such rocks exist at depth. The nearest exposures of Paleozoic sedimentary rocks are found 

14 miles east of the planning area boundary and those rocks are not known to contain hydrocarbons. 

Thick sequences of volcanic rocks in the planning area could conceivably conceal areas of favorable 

Paleozoic and Mesozoic rocks, but this cannot be determined, or even inferred, without adequate 

subsurface data. It is equally possible that plutonic rocks related to the Idaho batholith exist at depth and 

that the Paleozoic and Mesozoic rocks may have been eroded, faulted, or even displaced by plutonic 

activity. Therefore it is concluded that the oil and gas occurrence potential for the majority of the planning 

area is low, with a Level of Certainty A . 

Level A: Available information is insufficient to infer level of potential; however, minimal potential cannot be ruled 

out.

Along the northern edge of the planning area, however, the sedimentary rocks of the Glenns Ferry 

Formation, some of which may contain organic matter, could possibly be a source for hydrocarbons 

consistent with USGS’s Miocene or Pliocene Lacustrine Plays. Although it is not likely, it is possible that 

basalt, which is vesicular and therefore somewhat porous, could be a reservoir rock where it is 

intercalated with the sediments. If a clay or shale layer were found to overlay the basalt, it could act as a 

seal to prevent the hydrocarbons from migrating to the surface, although no such formation is known to 

exist in the area. Also, no trapping structure is known to exist. Direct evidence of oil and gas presence in 

this area is lacking, as three oil and gas exploratory wells drilled in the Glenns Ferry Formation in the 

planning area found no “shows” of oil or gas (Youngquist and Kiilsgaard, 1951). While the potential for a 

discovery of petroleum resources in this area is slightly higher than the potential in the rest of the planning 

area, the potential is still considered to be low, with a Level of Certainty C . 

Level C: Available information provides direct evidence to indicate the level of potential.

Oil and Gas Development Potential

Oil or natural gas production would occur in the planning area only if a significant oil or gas discovery is

made. A significant discovery could be a 4,000- foot deep reservoir capable of producing a total of more 

than one million barrels of oil or a billion cubic feet of natural gas, or it could be a 15,000 foot reservoir 

capable of producing 500 to 700 million barrels of oil equivalent.

Currently very little oil and gas infrastructure exists, making the costs associated with developing and 

producing a field higher than in areas of known production. The Williams’ Northwest natural gas pipeline 

runs through southern Idaho, parallel to Interstate 84 in the planning area. It is a common carrier, so it is 

required to accept gas input from various sources as long as quality standards can be met. In 2006, there 

was space available in the system, at least seasonally (Larsen, 2006). There are no other existing crude 

oil lines or refineries in southern Idaho. One small (8 inch) pipeline operated by Chevron Corp. transmits 

refined liquid petroleum products from the Salt Lake City, Utah, area into southern Idaho (Pocatello, ID), 

where the line roughly parallels the Williams pipeline to the west (Marconi, 2006). Since this line is for 

refined liquid products, it would not be available for wellhead oil or gas condensate products. 

Electric transmission lines are present across some of the planning area. These lines provide power to 

local residents and communities, but could possibly be used to bring electrical power needed for 

hydrocarbon processing facilities if such facilities were ever to be developed in southern Idaho. Large

power needs may require supplemental or new lines to be constructed. 
Appendix K: Reasonably Foreseeable Development Jarbidge Proposed RMP/Final EIS

Scenario for Oil and Gas Development

A-244

Most of the planning area does not currently have roads that would support oil/gas exploratory or 

development drilling needs. While the planning area is relatively flat, many areas are extremely rocky and 

rugged, and road construction could be costly. Paved roads and improved gravel roads suitable for truck 

transportation of oil or liquefied gas products are limited in number and distribution. The only railroad line 

that could be used for liquid hydrocarbon product transportation is located just north of the planning area, 

roughly paralleling Interstate 84. 

The lack of infrastructure to support oil and gas exploration and especially development or processing on 

or near the planning area would make these activities more expensive than in areas where the necessary 

infrastructure already exists. 

Limited reserve gas discoveries, such as marsh gas, are also unlikely to be developed in the foreseeable 

future in the planning area. Gas pipelines are necessary to move gas products. Small gas discoveries 

would not contain reserves sufficient to justify the investment in small diameter, high pressure lines that 

could, in turn, be connected to a larger, existing line.

The overall probability of discovering and developing a producing oil and/or gas field in the planning area 

is considered to be low. This rating is based on the following factors: 

There has been a total lack of oil/gas industry interest in south central Idaho as demonstrated by the lack

of leasing activity in the area during the past 15 years. 

No oil/gas seismic geophysical surveys have been conducted in southeast Idaho in the past 15 years on 

BLM-administered lands in the area.

Exploratory drilling has been very sparse for such a large area, with no wells drilled since 1950, further 

indicating industry’s lack of confidence in the area. 

No wells capable of economic production have ever been drilled in the entire state, let alone the planning 

area.

There are no demonstrated oil or gas reserves in the planning area or adjacent areas. 

There is a general lack of infrastructure to support field development in southern Idaho. 

Reasonably Foreseeable Development Baseline Scenario

Assumptions and Discussion

The following assumptions for oil/gas leasing, exploration, and development in the planning area during 

the next 20 years are based on the oil/gas development potential described above, the regional geology, 

the historical drilling activity for southeast Idaho and surrounding area, topography, the existing access 

situation, and the requirements of the Supplemental Program Guidance for Fluid Minerals: 

It is likely that 10 to 20 leases may be offered over the next 20 years, likely in the Glenns Ferry and/or the 

Cedar Creek/ China Mountain areas. 

Two or three geophysical exploration programs would be conducted to help identify potential exploration 

drilling targets. 

One or two exploration wells would be drilled on leases in the planning area. The wells would likely be 

10,000-14,000 feet deep and would require the construction of a drill pad approximately five acres in size 

(approx. 500 by 500 feet). Each of the proposed drilling sites would be analyzed through the NEPA 

process, separate from the leasing analysis. Wildcat wells that discover only limited reserves of oil and/or 

gas are not likely to be economically viable because of the lack of existing infrastructure and would be 

plugged and abandoned. It is predicted that none of the exploratory wells would encounter hydrocarbons 

in sufficient quantity to justify production expenses and would be plugged and abandoned immediately. 
Jarbidge Proposed RMP/Final EIS Appendix K: Reasonably Foreseeable Development

Scenario for Oil and Gas Development

A-245

•

•

•

•

Access to the drill pads may require up to two miles of construction/reconstruction. Access roads would 

require a 20-foot wide graveled running surface, with an average disturbance width of 40 feet (4.85 

acres/mile). Disturbance from two miles of road would equal about 10 acres. 

Pad and access road construction would likely take one month; drilling operations and well testing would 

typically take from one to four months to complete; and reclamation would be completed within one year 

from when drilling is completed (assuming all wells are non-productive). 

It is likely that about 5,000 to 15,000 gallons of water would be required per day, depending on down-hole 

conditions. Depending on the well locations, water sources in the planning area could be sought and 

applied for. Some wells make water, and disposal could become an issue if the water is saline. 

Anticipated Surface Disturbance Due to Oil and Gas Activity

The following phases of oil and gas exploration/development are typical in searching for and developing 

an oil and gas resource:

Geophysical Exploration, 

Drilling, 

Field Development and Production, and

Plugging and Abandonment. 

The assumptions and scenarios that follow are based on historical drilling activity in the planning area, as 

well as the oil and gas potential for the area. 

Phase One: Geophysical Exploration

Geophysical techniques are often implemented to identify subsurface geologic structures. The BLM 

reviews and approves geophysical operations on a case by case basis, and a lease is not necessary for 

such work. Gravity, magnetics, and seismic reflection are the most common techniques used. Both 

gravity and magnetic surveys cause very little disturbance as the instruments used are small and easily 

transportable in light vehicles or off-highway vehicles. These surveys can cover large areas and take only 

weeks to conduct. It is preferable to use existing roads, yet some overland travel is sometimes necessary. 

In addition, both gravity and magnetic surveys can be completed from aircraft, virtually eliminating surface 

disturbance.

Seismic reflection surveys are the most commonly used geophysical tool. They require a seismic energy 

source and an array of receptors. Shock waves are created either through the use of small explosive 

charges or by vibrating or thumping the ground. Explosive charges are the preferred method and are 

used when access, road conditions, or population centers are not an issue. Two to six-inch diameter shot 

holes are drilled by a truck-mounted drill rig to depths between 25 and 200 feet, where explosive charges 

between five and 50 pounds are detonated. Reflected seismic waves are recorded by a series of surface 

equipment along a three to five mile line. In situations where explosives are not used, the ground surface 

is mechanically vibrated using truck-mounted equipment. Both operations generally utilize a crew of 10 to 

15 people with five to seven vehicles. Seismic surveys may be supported by aircraft.

Based on the occurrence potential of the planning area, it is anticipated that two or three geophysical 

exploration programs would be conducted to aid in identifying potential exploration drilling targets during 

the life of the plan. It is likely that ATVs or other rubber-tired rigs would be utilized for access, and no 

construction of roads would be required. Impacts from such exploration would be temporary (several 

weeks in duration) but somewhat intensive (i.e., 2 to 3 vehicles/personnel in the area), such that seasonal 

restrictions may be necessary to avoid conflicts with some sensitive wildlife. 

Phase Two: Drilling

Exploration wells are drilled in order to test geologic targets. On Federal mineral estate, an oil and gas 

lease must be obtained, and an application for permit to drill must be submitted and then approved by the 

field office. Site specific stipulations can be attached to the approved drilling permit.
Appendix K: Reasonably Foreseeable Development Jarbidge Proposed RMP/Final EIS

Scenario for Oil and Gas Development

A-246

Temporary roads would likely be needed to transport and maintain the heavy equipment. Either existing 

roads would be improved or new roads would be constructed to accommodate the traffic. Typically, roads 

are constructed with a 20-foot wide graveled running surface with adjacent ditches and berms, for a total 

disturbance width of about 40 feet.

Exploration holes range in depth from a few thousand feet to many thousands of feet, but are typically 

about ten thousand feet deep. Drilling to such depths requires large drill rigs and ancillary equipment. A 

drill pad three to five acres in size would be constructed, and may require cut and fill of the site to obtain a 

level pad. Topsoil would be removed and stored on site for reclamation. In addition to the drill rig, the pad 

may house a reserve pit, a mud sump, tool shed, drill pipe, fuel tanks, water tanks, generators, pumps, 

equipment storage, and temporary office quarters.

Well drilling requires water. As much water as possible is recycled on site, yet about 5,000 to 15,000 

gallons of water may be needed each day depending on well conditions. Initially, water would need to be 

provided by some source, either wells or trucked in, to meet demands. Many oil or gas wells encounter 

water at depth when drilling for oil and/or gas, as it may be part of the oil and gas reservoir, and can be 

utilized when production is ongoing. Any water rights required would likely need to be filed in the name of 

the BLM. 

At the conclusion of well testing, if paying quantities of oil and gas are not discovered, the operator is 

required to plug the well according to Federal and State standards. Cement plugs are placed above and 

below water-bearing units with drilling mud placed in the space between plugs. When abandonment is 

complete, the site is reclaimed, which includes pad and road recontouring, topsoil replacement, and 

seeding with approved mixtures. Erosion control measures would be incorporated into the reclamation 

design as needed.

The drilling site could be active for approximately one year, from the start of drill pad and access road 

construction; through drilling and well testing; to completion of plugging the hole and reclamation. 

It is anticipated that one or two exploration wells would be drilled on leases in the planning area. The 

wells would likely be 10,000-14,000 feet deep and would require the construction of a drill pad 

approximately five acres in size (approx. 500 by 500 feet). Based on the road density in the planning 

area, access to the drill pads may require up to two miles of road construction or improvement. Surface 

disturbance from construction of up to two miles of road would equal about 10 acres. Total surface 

disturbance expected from drilling two wells would be up to 30 acres. Each of the proposed drilling sites 

would be analyzed through the NEPA process, separate from the leasing analysis. 

Wildcat wells that discover only limited reserves of oil and/or gas are not likely to be economically viable 

because of the lack of existing infrastructure, and would be plugged and abandoned. It is predicted that 

none of the exploratory wells would encounter hydrocarbons in sufficient quantity to justify production 

expenses and would be plugged and abandoned immediately. 

Phase Three: Field Development and Production

If a producible quantity of oil or gas is discovered, additional development wells would be drilled to 

confirm the discovery, establish the limits of the field, and drain the field. Depending on the field 

characteristics, well spacing may be from 40 to several hundred acres per well.

The speed at which a field is developed is dependent on the anticipated productivity. It may take from one 

to three years to fully develop an oil or gas field. Large fields with several operators may be unitized to 

reduce surface impacts. In addition, directional drilling may allow for drilling more than one well per pad. 

During field development, the road system is greatly expanded. Temporary roads are usually improved to 

accommodate more traffic and increased duration of use. Improvements may include crowning, capping, 

and implementing additional erosion controls. New roads would also be constructed. Depending on well 

location and topography, a main access road is built with smaller secondary roads running to each pad. In 
Jarbidge Proposed RMP/Final EIS Appendix K: Reasonably Foreseeable Development

Scenario for Oil and Gas Development

A-247

addition to roads, other facilities may also be installed including power lines, tank farms, pipelines, 

oil/water separators, and injection wells.

The production phase of an oil or gas field begins soon after discovery, and may coincide with 

development. Temporary facilities are often used initially, but as the extent of the field is determined, 

permanent facilities would be installed.

Where oil and gas flow to the surface naturally, control valves and collection pipes are attached to the 

well head. Otherwise pumps are installed. Oil is typically produced along with water and gas. Separation 

facilities are constructed on site to remove water, carbon dioxide, and hydrogen sulfide. The oil and 

natural gas are then separated. Water, usually saline, is disposed of either through surface discharge, 

evaporation ponds or re-injection into the producing formation.

If gas is present in economic quantities and a pipeline is located within close proximity, a network of 

pipelines would likely be constructed to collect and transport the gas. If not, gas would likely be reinjected into the reservoir. Oil would be collected in a similar manner and stored in tanks in a central 

location. Well operators would likely have service operations (e.g., cementing, logging, bits, testing, etc.) 

provided by established oil field service companies in Wyoming or Utah.

The producing life span of an oil or gas field varies depending on field characteristics. A field may 

produce for a few years to many decades. Commodity price, recovery technique, and the political 

environment also affect the life of a field. Abandonment of wells may begin as soon as they are depleted 

or wells may be rested for a period of time and put back into production. 

For the purposes of this report, it is assumed that one of the exploration wells would potentially encounter 

hydrocarbons in sufficient quantities to warrant field development. Based on this discovery, a five-well 

field would be developed. Disturbance for additional roads, pads, pipelines, and storage tanks may total 

over 60 acres. Depending on the size of the field, oil would either be trucked or piped to a refinery.

Phase Four: Abandonment

If paying quantities of oil and gas are not discovered, or at the end of the producing life span of a 

producing well or field, the operator is required to plug the well according to Federal and State standards 

and reclaim the disturbed areas. To plug a well, cement plugs are placed above and below water-bearing 

units with drilling mud placed in the space between plugs. When well abandonment is complete,

equipment and surface facilities are removed, and the site is reclaimed. In a producing field, underground 

pipelines are often plugged and left in place in order to avoid re-disturbing these areas. Site reclamation 

includes pad and road obliteration and recontouring, topsoil replacement, and seeding with approved 

mixtures. Erosion control measures would be incorporated into the reclamation design as needed. 

Conclusion

The probability of full field development and production occurring in the Jarbidge Field Office over the life 

of the plan is low. The existence or size of oil and natural gas reserves potentially found in the planning 

area is highly uncertain. Total surface disturbance associated with the anticipated oil/gas-related activity 

in the planning area as a result of making the lands available for lease equal about 90 acres during the 

next 20 years. This figure is based on drilling two exploration wells, one of which it is assumed will be 

productive. Disturbance is based on a drill pad (about five acres) + access road (about 10 acres) = 15 

acres per drill site, x 2 wells = 30 acres for exploration drilling. If this activity does indeed occur, it is likely 

that well testing would not be favorable for production and the sites would be immediately reclaimed. Pad 

and access road construction, drilling and well testing, and reclamation would take an estimated four to 

six months, depending on well depth and drilling conditions encountered. Assuming that oil or gas 
Appendix K: Reasonably Foreseeable Development Jarbidge Proposed RMP/Final EIS

Scenario for Oil and Gas Development

A-248

resources are discovered at one of these wells, an additional 60 acres would be disturbed in that vicinity 

by the drilling of five additional wells, spaced at one well per 40 to 160 acres, depending on reservoir 

characteristics. This disturbance would not be reclaimed until the resource is depleted, which could take 

one to 10 years. It is anticipated that two to three geophysical survey programs would be completed 

during the life of the plan. This disturbance would be temporary, on the order of weeks, and would result 

in minor to negligible surface impacts. 

This RFDS meets the requirements of BLM’s Manual Section 1624-2 in describing potential surface 

impacts that could occur as a result of oil and gas leasing activity in the Jarbidge Field Office. 
Jarbidge Proposed RMP/Final EIS Appendix L: Reasonably Foreseeable Development

Scenario for Geothermal Development

A-249

Prepared by: ___ _________ __ __

Reviewed by: ___ _____________ __ ___

APPENDIX L: REASONABLY FORESEEABLE 

DEVELOPMENT SCENARIO FOR GEOTHERMAL 

DEVELOPMENT

REASONABLY FORESEEABLE DEVELOPMENT SCENARIO

FOR

GEOTHERMAL DEVELOPMENT

IN THE

JARBIDGE FIELD OFFICE

Prepared by: Karen Porter, BLM Idaho State Office Geologist

 _signed copy on file_ __ Date: 11/6/2009__

Reviewed by: Al McKee, BLM Utah State Office Petroleum Engineer

 _signed copy on file Date: 11/3/2009_
Appendix L: Reasonably Foreseeable Development Jarbidge Proposed RMP/Final EIS

Scenario for Geothermal Development

A-250

Summary

Based on the geology of the Jarbidge Field Office (i.e., the planning area), the presence of numerous hot 

springs and wells in several locations and a Known Geothermal Resource Area (KGRA), and a review of 

the available data collected and technical reports written on the area, it has been determined that the 

lands within the planning area have some level of potential for the discovery and/or development of a 

geothermal resource for both indirect use (i.e., commercial generation of electricity) and direct use (i.e., 

use of the resource for other purposes). The lands east of the Bruneau River and west of the Saylor 

Creek Training Range are determined to have high geothermal potential, based on the determination of 

high heat flow and the inclusion of most of those lands in the Bruneau KGRA. Lands situated north of the 

numerous faults that trend northwest from roughly the Balanced Rock area to the Bruneau KGRA have 

been determined to have medium potential, while lands situated south of these faults have been 

determined to have low potential, based on currently available information. These conclusions are 

described in more detail in the Geothermal Potential Report prepared for the area (BLM, 2009b). 

Based on the geothermal potential for the planning area, it is reasonable to assume that a 20-megawatt 

(MW) power plant would be developed over the 20-year life of the plan. This development would disturb 

between approximately 185 and 230 acres cumulatively, including the construction of drill pads to support 

the drilling of 20 temperature-gradient wells and 10 production and injection wells, road construction, 

power plant development, and pipeline and transmission line construction. Much of this disturbance would 

be reclaimed after each phase of development, such that once the power plant is operational, the actual 

disturbance would be considerably less than the cumulative total. Surface disturbances for direct use are 

expected to be much less than those anticipated for indirect use. 

Introduction

This report, describing a Reasonably Foreseeable Development Scenario (RFDS), accompanies the 

Geothermal Potential Report (BLM, 2009b) prepared for the planning area. The RFDS describes the 

anticipated level of exploration and development activity associated with geothermal leasing. These 

projections are necessary for assessing the anticipated impacts of geothermal development-related 

activity in the EIS for the Jarbidge Resource Management Plan (RMP); for determining which lands within 

the planning area will be available for geothermal leasing; and for determining what stipulations may be 

necessary to attach to leases in order to protect surface resources. These anticipated impacts are for the 

BLM-administered public lands described above during the next 20 years (2009-2029). 

Description of Geology

The geology of the planning area is described in detail in the Geothermal Potential Report prepared for 

the area (BLM, 2009b). The planning area lies within the Snake River Plain physiographic province and is 

entirely covered by Cenozoic volcanic deposits, with Quaternary lake deposits found overlying the 

volcanics in the northwest corner of the planning area. The planning area is dominated by the Owyhee 

Plateau, a broad volcanic upland considered to be a continuation of the eastern Snake River Plain. These 

volcanic rocks, consisting of multiple sheets of welded ash-flow tuff, rhyolite, and finally basalt, were 

erupted from the Bruneau-Jarbidge eruptive center starting 11 million years ago (Bonnichsen, 1982). The 

silicic rocks (ash-flows and rhyolites) of this sequence are loosely termed the Idavada Volcanics. The 

Idavada volcanic sequence is considered the most important aquifer in the area and has the known 

capacity to act as a reservoir for thermal water (Chapman and Ralston, 1970; Young and Whitehead, 

1975). The sequence is 3,000 feet thick or more and is exposed or underlies all of the planning area. 

In the northern portion of the planning area, a series of northwest-trending en echelon normal faults, 

down dropped to the north, propagate across the Bruneau Desert from roughly the Balanced Rock area 

(also known as the Blue Gulch area) to the Bruneau Hot Springs area (Malde et al, 1963 and Jenks et al, 

1998). High heat flow values are found in springs and wells drilled for agricultural and domestic uses in 

these two areas, although no exploration drilling for geothermal testing has been performed (Blackwell, 

1975; Brott et al., 1976). 
Jarbidge Proposed RMP/Final EIS Appendix L: Reasonably Foreseeable Development

Scenario for Geothermal Development

A-251

Past and Present Geothermal Activity

BLM records indicate that there has never been a geothermal lease issued in the planning area. There is 

a KGRA, the Bruneau KGRA, located in the extreme northwest corner of the planning area (T 7 S, R 6 E, 

sections 14, 15, 21, 22, 23, 26, 27, and 28; 5,120 acres). The KGRA was established in 1975 due to 

overlapping nominations of those lands for geothermal leasing and an analysis of the available 

geothermal indicia at the time. A lease sale was held after the establishment of the KGRA, but records 

indicate the offered parcel(s) did not receive any bids. 

While there are no deep (over 5,000 feet) wells drilled for geothermal resources, there are numerous 

water wells drilled on private lands with temperatures between 20 and 50°C in the planning area (Smith et 

al., 1980). Most of these are concentrated in the Bruneau area; however there are 15 to 20 wells on 

private lands in the Blue Gulch area, located northwest of Balanced Rock (T 9-10 S, R 12-13 E), with 

temperatures between 25 and 35°C. There is also a cluster of warm wells (approximately 25°C) in the 

Glenns Ferry area. Most of the wells in the planning area are used for agricultural (irrigation) purposes; 

however, a few utilize the heat source for direct uses such as heating a greenhouse and aquaculture. 

Most of the wells are less than 1,000 feet deep. 

Reasonably Foreseeable Development Scenario

General Assumptions

The general assumptions and descriptions of the phases of development that follow are based on the 

geothermal potential in the Jarbidge Field Office. This Reasonably Foreseeable Development Scenario 

(RFDS) was adapted from the Final Programmatic Environmental Impact Statement for Geothermal 

Leasing in the Western US, released in October 2008 (BLM, 2008b), and applied to the local conditions 

and mineral potential of the planning area. The RFDS primarily describes the development of the 

resource for the commercial generation of electricity, termed “indirect use”; however, geothermal 

resources also can be utilized directly. Direct uses are briefly described at the end of this RFDS.

Based on the geothermal potential for the planning area, it is reasonable to assume that a total of 20 MW 

of power would be developed over the life of the plan. The most likely location for this development is in 

or near the Bruneau KGRA, determined to have high potential for geothermal resources, but there is a 

possibility that the area designated as having moderate potential may encounter exploration activities and 

possible development as well. 

During the life of the plan, it is assumed that exploration activities would include geophysical exploration 

and drilling of up to 20 temperature gradient wells. Existing roads would be used for access as much as 

possible; however, given the scarcity of roads in the area, it is assumed that up to one mile of temporary 

access road may be required per well on average. This disturbance would be reclaimed and the holes 

plugged immediately after data and samples are collected. 

Once an area is determined to have potential for commercial geothermal development, large-diameter 

production wells would be drilled, for further flow testing and for possible future use in production. 

Assuming the eventual development of a 20-MW resource, approximately 10 large-diameter wells would 

be drilled: half of these would be production wells, and half would be used as injection wells. These wells 

would likely be concentrated within a 9 to 16 square-mile area. Construction of well pads would be 

required. The average well pad is approximately 3.5 acres in size. After drilling is completed, the well pad 

would be reclaimed by blending the well pad material into the surrounding landscape and re-seeding with 

an approved seed mix. 

Additional disturbance would be anticipated if a site is developed. This would include construction of a 

power plant, which would disturb approximately 10 additional acres for a 20-MW plant. Pipelines, needed 

to convey the geothermal fluid from the producing well to the plant and from the plant back to injection 

wells, would be placed approximately 2 feet above the ground. It is assumed that approximately one mile 

of pipeline would be required per well. Transmission lines are also needed, to carry the electricity from the 

plant to the power grid (140 kilovolts or greater). The proposed Gateway West transmission line is within 
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two to five miles of the Bruneau KGRA. It is assumed that between 0.25 miles and10 miles of line would 

be required. 

Table L-1 provides the estimated acreage of land disturbance that would be anticipated for exploration 

and development of a geothermal resource, over the life of the RMP. The actual area of disturbance 

varies depending upon site conditions and the size of power plant being constructed. Acreages are not 

provided for the Reclamation and Abandonment phase since this phase involves the return of previously 

disturbed lands to their existing conditions. Much of the land would be reclaimed after each phase of the 

initial exploration, drilling, and construction. For example, once wells are drilled, the well pad would be 

reduced to a minimum size and the pad reclaimed. Therefore, the actual amount of land occupied during 

the utilization phase would be less than the total cumulative acreage. A typical development generally 

requires several leases or the use of private or other adjacent lands. The details of each phase of 

development are described in the section following the table.

Table L-1. Surface Disturbance Anticipated for Geothermal Resource Development during the Life 

of the Jarbidge RMP (assuming a 20-MW Power Plant)

Development Phase Disturbance Estimate

Exploration

Geologic mapping negligible

Soil surveys 30 square feetA

Gravity and magnetic surveys negligible

Seismic surveys negligible

Resistivity surveys negligible

Shallow temperature measurements negligible

Road/access construction for temperature gradient wells 80 acres

Temperature gradient well pads 5 acres

B

Total Exploration Disturbance 85 acres

Drilling and Utilization

Drill pads 35 acresC

Road improvement/construction 20 acresD

Power plant 10 acresE

Pipelines 30 acresF

Transmission lines 5-50 acresG

Well workovers, repairs and maintenance negligibleH

Total Development and Utilization Disturbance 100-145 acres

Total Cumulative Distance Approximately 185-230 acres A Calculated assuming 10 soil gas samples, at a disturbance of less than three square feet each. B Calculated assuming an area of disturbance of up to 0.25 acre per well and 20 wells. C Calculated assuming a 20-MW power plant requires about 10 well pads, at 3.5 acres (approx. 400’ x 400’) each, to 

support 5 production wells and 5 injection wells. Does not assume multiple wells located on a single well pad. D Assumes 0.5 miles of road per well (10 wells). Estimates 30-foot wide surface disturbance for an 18-20 foot road 

surface, including cut and fill slopes and ditches.

E Based on average of five acres of disturbance per 10-MW power plant. F Pipelines from well to plant assumed to be 1 mile on average, for a total of 10 miles of pipeline in length, with a 25-

foot-wide disturbance corridor. G Transmission lines assumed to be one to 10 miles long, 40-foot-wide construction corridor. H Disturbance would be limited to previously disturbed areas around the well(s).

Typical Phases in Geothermal Development

This RFDS for geothermal resource use describes four sequential phases: (1) exploration, (2) drilling, (3) 

field development and utilization, and (4) reclamation, plugging, and abandonment. The success or failure 

of each phase affects the implementation of subsequent phases and, therefore, subsequent 

environmental impacts. The general assumptions and descriptions of the geothermal development are 

intended to be used in support of the Jarbidge RMP revision, to analyze future environmental impacts that 

may result from the issuance of Federal geothermal leases, and to identify areas that may require 

additional stipulations to the standard lease form to protect other resources, if those lands are nominated 
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for leasing in the future. These anticipated impacts are for the BLM-administered public lands described 

above during the next 20 years (2009-2029). The EIS written in association with the RMP revision 

analyzes the leasing decision; however, additional site-specific NEPA analysis will be conducted for each 

phase of geothermal resource development activity. Additional Conditions of Approval may be developed 

and attached to these permitted activities.

Phase One: Geothermal Resource Exploration

Before geothermal resources are developed, a geothermal resource developer explores for evidence of 

geothermal resources on leased or unleased land. Exploration activities may involve some ground 

disturbance but does not include the direct testing of geothermal resources or the production or utilization 

of geothermal resources. Exploration operations include, but are not limited to, conducting geophysical 

and/or geochemical surveys, and drilling temperature gradient wells. A geothermal lease is not required 

to conduct exploration activities; however, an exploration permit is required from BLM (see 43 CFR 3250 

for regulations pertaining to geothermal exploration operations). 

Usually, the first, on-the-ground step in exploration is to conduct geophysical prospecting or surveying. 

This exploration method consists of collecting and interpreting electrical, gravitational, magnetic, thermal, 

and/or seismic data to identify underground structures favorable for the occurrence of a geothermal 

resource. Geophysical surveying is a relatively inexpensive method of indirectly exploring the sub-surface 

of a relatively large area for a mineral resource, and results in relatively minor disturbance to surface 

resources. Once the data are compiled, geologists and geophysicists examine the data and make 

inferences about where the higher temperature anomalies may occur and whether other geologic 

conditions, such as porosity and faulting, are present. These conditions can indicate the location of 

potential underground geothermal reservoirs capable of supporting commercial uses. 

Resistivity surveys involve laying out long cables (up to 1,000 feet or more) on the land surface, or setting 

up equipment repeatedly in small areas (a few tens of square feet at the most for each measuring site). 

Minor, temporary disturbances are associated with each site for the burial of sensors. 

While not widely used for geothermal surveys, seismic surveys have the greatest impact on the local 

environment. These surveys typically involve setting up an array of geophones and creating a pulse or 

series of pulses of seismic energy. The pulse is created either by detonating a small charge below the 

ground surface (requires drilling a narrow “shot hole”, usually by hand) or by a vibroseis truck that is 

driven through the survey area. Data is transmitted from the geophones to a central location. The 

geophones may be installed on the ground’s surface, in small excavations made specifically for burying 

the geophones, and/or in existing wells. These surveys are typically undertaken over the course of a few 

days. No road building is required for this type of activity.

Geochemical surveying, such as collecting and analyzing water samples from hot springs, can also be 

used to determine the subsurface characteristics of a particular area. In some cases, gas collectors may 

be installed to measure soil gases. These collectors have partially buried sensors and may disturb small 

areas of less than three square feet.

Access requirements for geophysical and geochemical surveying can generally be met by the use of 

existing roads or trails, cross-country travel using all-terrain vehicles, or by foot. While very little surface 

disturbance is associated with these surveys, the survey crew, usually consisting of two to four personnel, 

may be walking or moving through a fairly large area for several days. 

The second step of the exploration phase is to drill temperature gradient wells. A gradient well can 

provide additional information to determine a more precise location of higher-than-normal temperature 

gradients; however, the geothermal resource is not directly accessed or utilized. Temperature gradient 

wells can be drilled using a truck-mounted rig, and range from 200 feet to over 4,000 feet deep. Figure L1 is a photograph of a typical drill rig used to drill a temperature gradient well. The number of gradient 

wells drilled also varies, depending on the geometry of the system being investigated and the anticipated 

size of the geothermal reservoir. Geologists examine either rock fragments or long cores of rock that are 

brought up from the bottom of the well as it is being drilled. Water samples are taken from any 
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groundwater encountered during drilling. Temperatures are measured at various depths. Both well 

temperatures and the results of rock sample analyses are used to determine if additional drilling is 

worthwhile to identify the presence and characteristics of an underground geothermal reservoir. After 

collecting the desired samples and data, the wells are plugged and abandoned in accordance with 

Federal and State requirements.

Figure L-1. Typical Drill Rig for Drilling Temperature Gradient Wells 

Most temperature gradient wells are drilled with a small rotary rig (often truck-mounted), similar to that 

used for drilling water wells, or a diamond-coring rig, similar to that used for geologic sampling in mineral 

exploration and civic works projects. The mast of the drill rig is approximately 60 feet tall. Support 

equipment is needed, including water trucks, tanks for mixing and holding drilling fluids, personnel and 

supply transport vehicles, and sometimes a backhoe for earthmoving activities needed to prepare the 

drilling site. During exploration, a driller is not permitted to produce any fluids out of, or inject any fluids 

into the well; therefore, the site may also host a sump or tanker truck. Additionally, a diesel generator may 

also be used at the site to power equipment. A temperature gradient drilling operation can be run by 

about three on-site personnel and others traveling to the site periodically with materials and supplies. 

Temperature-gradient well drilling requires road access. Whenever possible, a driller would access the 

temperature gradient well site using existing roads. When existing roads are not available, temporary 

access roads may need to be constructed for the truck-mounted rig to reach the site, possibly disturbing 

one acre (for 0.25 miles of 30-foot wide road) to 6 acres (1.5 miles). Given the road density in the 

planning area, it is assumed that an average of one mile (four acres) of temporary access road would be 

required per temperature gradient well. 

Drilling a temperature-gradient well generally does not require construction of a well pad or earth-moving 

equipment unless the site is steeply sloping. Preparing the site for drilling may include leveling the surface 

and clearing away vegetation. The well site itself involves excavation of a small cellar (typically less than 

three feet square and less than three feet deep) to allow the conductor casing to be set beneath the rig. It 

is assumed that 0.25 acres of disturbance would occur per drill site. Drilling takes from several days to 

several weeks per hole. Several temperature gradient wells are usually drilled to determine both the areal 

extent of the temperature anomaly and where the highest temperature gradient occurs. It is assumed that 

20 wells would be drilled over the life of the plan. 
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Temperature gradient wells are not intended to directly contact the geothermal reservoir, and therefore 

produce no geothermal fluids. In areas of known artesian pressures, any drilling expected to penetrate 

the groundwater table would be required to include blow-out prevention equipment. In cases where a 

temperature gradient well does penetrate a geothermal zone, any release of geothermal fluids at the 

surface is likely to be minimal due to the small well diameters and the use of blow-out prevention 

equipment.

Drilling fluids may include drilling mud (bentonite clay, activated montmorillonite clay and crystalline silicaquartz), drilling mud additives (caustic soda, sodium bicarbonate, or anionic polyacrylamide liquid 

polymer), cement (Portland cement and calcium chloride), fuel (diesel), lubricants (usually petroleumbased) and coolants. The specific fluids and additives depend on a variety of factors, including the 

geologic formations being penetrated and the depth of the well. Releases of drilling muds are not 

permitted. Sump and tanker trucks are required to capture all fluids. The risk of spills of other fluids is 

similar to that of any other project involving the use of vehicles and motorized equipment.

All surface disturbances would be reclaimed to the satisfaction of BLM. Once drilling is completed, the 

temperature gradient well would be plugged and abandoned in accordance with BLM and State 

requirements. Site reclamation includes removing all surface equipment and structures; re-grading the 

site to blend into the surrounding landscape and prevent erosion; and replanting vegetation with a seed 

mix approved by BLM, to facilitate natural restoration of the site.

Phase Two: Drilling Operations

Once exploration has indicated a viable prospect and necessary leases have been secured, the drilling of 

large-diameter wells can proceed, in accordance with 43 CFR 3260 regulations. Unlike temperature 

gradient wells, these wells tap the geothermal resource and are capable of being fitted for production; 

however, they are initially used to test the reservoir for commercial development. Multiple wells may be 

drilled per lease. Each well requires an approved Geothermal Drilling Permit. A Drilling Plan and an 

Operations Plan are also required (one Plan can be submitted for multiple wells). NEPA analysis is 

conducted to determine whether the drilling locations are appropriate and whether Conditions of 

Approval, attached to the Drilling Permit, are required in addition to the lease stipulations. A bond is 

required. Drilling operations include drilling large-diameter production wells, flow testing of the wells, 

producing geothermal fluids for chemical evaluation, and injecting fluids back into the geothermal 

reservoir. This would also involve the construction of sumps or pits on the well pad, to hold excess 

geothermal fluids. It could involve development of minor infrastructure to conduct such operations.

Access roads capable of supporting large drill rigs would be required. It is assumed that 0.5 miles of new 

road would be constructed per well on average (total of 5 miles). Depending on the type and use-intensity 

of the road, the areas of surface disturbance is about 30-feet wide for an 18-20 foot wide road surface, 

including cut and fill slopes and ditches.

Construction of a well pad is required for drilling a production well. The size of the well pad is dependent 

upon site conditions and on the number of wells per pad, but they are typically about 3.5 acres (400 x 400 

feet) for one well. The well pad needs to be of sufficient size to safely accommodate drilling activities and 

various temporary support facilities such as generators, mud tanks, cement tanks, trailers for the drillers 

and mud loggers, housing trailers, and storage sheds. Each well pad would be fenced around the 

perimeter to prevent access by unauthorized persons, wildlife, or livestock during the duration of the 

drilling operation. If the drilling site is not located on level ground, minor cut and fill may be required. 

Gravel may be required to stabilize roads and pads and provide for drainage. 

After a well pad has been constructed and support facilities have been assembled, production wells 

would be drilled using a geothermal (or oil and gas) drill rig (Figure L-2). Production-size wells can be 

over two miles (10,560 feet) deep. The wells narrow (telescope) in diameter from 30 inches at the surface 

to 12 inches at the bottom of the well. In order to drill these deep holes, a large drilling rig would be 

erected. The top of the drill rig derrick could be as much as 155 feet above the ground surface, and the 

rig floor could be at least 25 feet above the ground surface. These rigs are typically equipped with diesel 

engines, fuel and drilling mud storage tanks, mud pumps, and other ancillary equipment. Blow-out 
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prevention equipment would be utilized while drilling to prevent uncontrolled flow at the surface if a 

pressurized thermal pocket is encountered. 

Getting the rig and ancillary equipment to the site may require 15 to 20 trips by full-sized tractor-trailers, 

with a similar amount for de-mobilizing the rig. There would be 10 to 40 daily trips for commuting and 

hauling in equipment. Drilling operations would likely occur 24 hours a day and seven days a week. It 

takes approximately one month to drill one well. A drilling operation generally has from 10 to 15 people on 

site at all times, with more people coming and going periodically with equipment and supplies.

Geothermal fluid production and associated waste production (drill cuttings and waste drilling mud) is 

likely to occur for short periods, as wells are tested to determine reservoir characteristics. Excess 

geothermal fluids are either re-injected into a previously drilled well, if available, or are stored in 

temporary pits or sumps, generally lined with a synthetic liner (permeability less than 10-7 cm/sec) or an 

impermeable clay liner. The water in the pit is left to evaporate and any sludge is removed and properly 

disposed of. The rate of fluid production from a geothermal reservoir is unknown until the development 

testing phase is completed. 

Figure L-2. Typical Drill Rig for Drilling Production Wells

During the initial stages of testing, one well is likely to be tested at a time. If testing is successful and the 

well and reservoir are sufficient for development, wellheads, valves, and control equipment would be 

installed on top of the well casing so that the wells can be utilized for production. The size of the well pad 

would be reduced to the minimum necessary for production, and the area reclaimed. If a production well 

is unsuccessful, it may be used for injection of fluids from other wells. If not necessary for either 

production or injection, the well would be plugged and abandoned in accordance with Federal and State 

requirements, and the site would be reclaimed by recontouring the well pad and seeding with an 

approved seed mix. Those roads that are no longer needed would be reclaimed. 

Phase Three: Field Development and Utilization

Utilization of the geothermal resource is the final phase of development, if a viable reservoir is determined 

and a power purchase agreement can been secured. Utilization requires the applicant to secure a site 

license and construction permit from BLM, in accordance with regulations at 43 CFR 3270. An EIS may 

be required for the construction of a power plant on Federal lands. 
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It is likely that the existing production wells would be used, although additional drilling to expand and 

develop the well field may be required. The number of wells is dependent upon the geothermal reservoir 

characteristics and the planned power generation capacity. For example, a 50-MW (net) power plant 

could require up to 25 production wells and 10 injection wells. Based on the geothermal potential in the 

planning area, it is assumed that a 20-MW power plant would be developed, with 5 production wells and 5 

injection wells. The utilization phase could last from 10 to 50 years and involves the operation and 

maintenance of the geothermal field(s) and generation and sale of electricity. 

Additional infrastructure would be needed for commercial operations, including construction of a power 

plant, installation of production and injection pipelines, and installation of transmission lines. It is assumed 

that no new access roads would be required, beyond the roads constructed for the production well 

drilling. 

Geothermal resources can be classified as low temperature (less than 90°C, or 194°F), moderate 

temperature (90 to 150°C, or 194 to 302°F), and high temperature (greater than 150°C, or 302°F). While 

at one time only the highest temperature resources were used for generating electrical power, emerging 

technologies and demand for alternative energy sources are proving that moderate and even lower 

temperature resources can be used for electrical generation.

Moderate to high temperature reservoirs, with adequate flow rates and fracture systems, are currently 

suitable for the commercial production of electricity. While there are several types of power plants that 

harness geothermal resources, the most likely type of plant used for moderate temperature resources is a 

binary-cycle plant. These modular plants use the geothermal resource that has been pumped to the 

surface to heat a secondary “working fluid” such as isobutene or isopentane that has a lower boiling point 

than water. As the working fluid boils, it expands and turns a steam turbine, producing electricity. The 

geothermal fluid and the working fluid never come in contact with each other, nor are they exposed to the 

environment (closed loop system). The geothermal fluid is re-injected back into the geothermal zone via 

injection wells, while the working fluid is cooled, condensed, and recycled. 

Binary plants are by far the most common type of power plant used today, as they can operate with lower 

water temperature (74 to 182° C, or 165 to 360°F) than flash or steam plants, produce few air emissions, 

are quiet, and result in a low impact to the environment once constructed. They can be constructed offsite (e.g., Ormat’s plants are manufactured in Israel), transported to a site, and erected fairly easily, and 

they can be expanded as a well field is developed. In this sense, they are modular units. Generally, the 

final permanent surface disturbance required for all related production wells, the power plant, and surface 

facilities is about one acre per Megawatt of power produced. 

A 50-MW plant would utilize a site area of up to 20 to 25 acres to accommodate all the needed 

equipment, including the power plant itself, space for pipelines geothermal fluids and reinjection, space 

for moving and storing equipment, and buildings needed for various purposes (power plant control, fire 

control, maintenance shop, etc.). The power plant itself would occupy an estimated 25% of this area for a 

water-cooled plant, or about 50% for an air-cooled plant. Where topography permits, the power plant 

could be situated to be less visible from nearby roads, trails, scenic vistas, or scenic highways. The site of 

the plant requires reasonable air circulation to allow for efficient operation of the plant’s condensers. A 

smaller, 20-MW plant would typically require approximately 5 to 10 acres for the entire complex. Figure L3 shows what a recently constructed 10-MW power plant looks like. 
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Figure L-3. 10-MW Power Plant at US Geothermal Inc.’s Raft River Site (from US Geothermal 

Website)

A pipeline system would be needed to connect each of the production wells and injection wells to the 

power plant. Pipelines are usually 24 to 36 inches in diameter and are typically constructed on supports 

above the ground surface, resulting in little if any surface impact to the surrounding area once 

construction is complete and the corridor has been revegetated. The pipelines typically have a few feet of 

clearance underneath them, allowing small animals to easily cross their path. Every 100 to 200 feet or so, 

the pipeline may have an expansion loop, or U-shaped bends, to allow for expansion due to heating and 

cooling. Pipelines transporting hot fluids to the plant are wrapped in insulation, whereas injection pipelines 

are generally not. Where feasible, the pipeline may parallel the access roads and existing roads to the 

power plant. The pipelines are typically painted to blend in with the surrounding environment. For the 

planning area, it is assumed that the pipeline to each well would be approximately one mile long on 

average, with a corridor width of about 25 feet. Once the pipeline is constructed, these corridors would be 

reclaimed.

Transmission lines would be required to carry power from the plant to the electric grid. It is assumed that 

in the planning area, these lines would be from one to 10 miles in length, with a corridor width of 

approximately 40 feet. Wooden poles would most likely support them, and about five acres could be 

disturbed per mile of transmission line.

The number of people required for routine operation of a power plant is typically three per shift; however, 

additional personnel may be on site during the day for maintenance and management of the facility and 

monitoring fluids and power production. Activities associated with operation and maintenance of the

facility and energy production would not generally involve additional ground-disturbing activities.

Using data from other areas of geothermal development, it appears that production of geothermal fluids 

can be expected to vary widely from one to six million gallons per well, per day. Assuming five million 

gallons per day per well as an average production figure, a geothermal field with five producing wells 

would produce 25 million gallons of fluid per day. Geothermal fluids produced are re-injected back into the 

geothermal reservoir via injection wells. Binary power plants utilize a closed loop system; therefore, well 

production and injection wells operate with no fluid loss. 

The routinely used chemicals for a binary geothermal plant include the hydrocarbon working fluid (such 

as iso-butane or n-pentane) and the lubricating oil used in the downhole pumps. While downhole scaling 
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may be a problem for flash or steam plants, it does not occur in binary plants because they are liquid 

dominated systems. Therefore, there is no need for scale-inhibiting chemicals or any other chemicals with 

a binary plant. 

Phase Four: Reclamation and Abandonment

This phase involves abandoning the well after production ceases and reclaiming all disturbed areas in 

conformance with BLM and State standards. Abandonment includes plugging and capping the wells and 

reclaiming the well site. Reclamation also includes removing the power plant and all surface equipment 

and structures, regrading the site and access roads to predisturbance contours, and replanting native or 

appropriate vegetation to facilitate natural restoration.

RFDS for Direct Use

Low temperature geothermal resources are increasingly being used for a wide variety of applications 

across the Western US, including in the planning area and nearby. These direct uses include:

Agricultural uses, such as controlling environmental conditions for growing crops, flowers, or trees;

Aquacultural uses, such as controlling environmental conditions for raising fish or other animals;

Direct heating and cooling systems for buildings;

Public safety uses, such as eliminating ice and snow on public sidewalks;

Public health uses through food processing, such as dehydration, washing, and processing; and 

Recreational uses, such as hot tubs, steam baths, and mud baths.

Use of the geothermal resource for these activities on Federal lands requires a direct use geothermal 

lease, in accordance with regulations at 43 CFR 3205.

Surface disturbances for direct use are generally much less than for indirect use since direct uses are 

more likely to be located near existing communities with less of a need for new access roads. Also, since 

direct use applications utilize the geothermal energy on-site, there is no need for the construction of 

electrical equipment and transmission lines, except for bringing in electricity from the existing grid to the 

facility being constructed. Surface disturbances can still be expected for well pad development, site 

access, and construction of the facility utilizing the resource, although in some cases the facility may 

already exist and may simply be shifting its heat source to geothermal.

Typical Phases in Direct Use Geothermal Development

Phase One: Exploration

Existing direct use applications are largely co-located with, and draw directly from, existing surface 

geothermal manifestations such as hot springs, eliminating the need for most exploration activities. 

Exploration activities in the past have often been limited to water temperature and chemistry analysis. 

Looking to the future, it is likely that most direct use applications will not be able to draw from existing 

surface manifestations as they have in the past. Surface manifestations such as naturally occurring hot 

springs have become increasingly sought after with increases in population in the Western US, increased 

recreational use, and more stringent regulations preserving such resources for their recreational, cultural, 

or scenic value. In such cases where surface manifestations are not nearby or are not being utilized 

directly, exploration activities similar to those described above for indirect use would also apply for direct 

use.

Phase Two: Drilling

In applications where a surface manifestation is used directly, the resource development phase involves 

installing piping into that manifestation to withdraw the hot water. For applications requiring the drilling of 

a well, drilling activities would be similar to those described above under Phase Two for indirect use, 

although the well would not be as deep, likely only one well would be drilled, and the volume of fluid 

would not be as great as for indirect use.
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Phase Three: Utilization

The utilization phase typically lasts for several decades or longer. Activities associated with the 

production phase are generally limited to maintenance and repair activities of all components of the 

collection, distribution and injection/use/disposal system.

As described above for indirect use, the drilling of production wells may be necessary. Drilling activities 

would be similar to that discussed above in the drilling phase, although it is likely that only one production 

well and one injection well would be required. Some applications may inject the post-use geothermal 

fluids back into the ground, in which case an injection well would be drilled and connected via piping to 

the application. In other applications where the spent geothermal fluids are discharged to a surface water 

body or used for some other purpose, then discharge piping, collection systems or distribution systems 

may need to be constructed. For such systems where the waters are not reinjected into the geothermal 

reservoir but are rather discharged or otherwise used, treatment systems may need to be installed to 

reduce levels of any naturally occurring but toxic chemicals present within the geothermal waters, such as 

mercury, arsenic, and boron, to meet applicable health or environmental standards. Operation and 

maintenance of existing facilities and production of geothermal energy also takes place during the 

production phase. Activities associated with operation and maintenance and energy production would 

involve managing waste generated by daily activities, managing geothermal water, landscaping, and 

maneuvering construction and maintenance equipment and vehicles associated with these activities.

Phase Four: Reclamation and Abandonment

As described above for indirect use, this phase involves abandoning the well after production ceases and 

reclaiming all disturbed areas in conformance with BLM and State standards. Abandonment includes 

plugging, capping, and reclaiming the wells. Reclamation includes removing all surface equipment and 

structures, regrading the site to blend into the surrounding landscape, and replanting native or 

appropriate vegetation.
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APPENDIX M: EVALUATION OF NOMINATED AREAS OF 

CRITICAL ENVIRONMENTAL CONCERN

An Area of Critical Environmental Concern (ACEC) is defined in the Federal Land Policy and 

Management Act of 1976 (FLPMA) as an area “within the public lands where special management

attention is required (when such areas are developed or used or where no development is required) to 

protect and prevent irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural hazards.” Ten 

areas were nominated for ACEC designation in the planning area through scoping, through individual or 

group nominations, and from Bureau of Land Management (BLM) staff recommendations; six of these 

areas had more than one boundary nominated. The nominated areas include:

Bruneau-Jarbidge ACEC, including the existing ACEC, extensions to the existing ACEC, and 

reductions to the existing ACEC; 

Inside Desert ACEC, including a large and small version of the ACEC; 

Jarbidge Foothills ACEC, including a large and small version of the ACEC; 

Lower Bruneau Canyon ACEC, including a large and small version of the ACEC; 

Middle Snake ACEC; 

Sagebrush Sea ACEC; 

Salmon Falls Creek ACEC, including the existing ACEC and an extension to the existing ACEC; 

Sand Dunes ACEC; 

Sand Point ACEC, including the existing ACEC and an extension to the existing ACEC; and

Upper Bruneau Canyon ACEC. 

This appendix contains a detailed description of each nominated ACEC or boundary modification and the 

BLM staff evaluation of its relevance and importance and need for special management. The evaluations 

were based on policy provided by 43 CFR 1610.7-2 and BLM Manual 1613, Areas of Critical 

Environmental Concern, which state that potential ACECs to be analyzed in Resource Management Plan 

(RMP) alternatives, must meet specified criteria for relevance and importance. 

Relevance is based on the presence of a significant: 

Historic, cultural, or scenic value, including, but not limited to, rare or sensitive archaeological 

resources and religious or cultural resources important to Native American tribes;

Fish or wildlife resource, including, but not limited to, habitat for Endangered, Threatened, or BLM 

Sensitive fish or wildlife species, or habitat essential for maintaining species diversity;

 Natural process or system, including, but not limited to, Endangered, Threatened, or BLM Sensitive 

plant species; rare, endemic, or relic plants or terrestrial, aquatic, or riparian plant communities; or 

rare geologic features; or 

Natural hazard, including, but not limited to, areas of avalanche, dangerous flooding, landslides, 

unstable soils, or seismic activity.

In the evaluation for relevance, a “yes” answer indicates the area contains a value, resource, process, 

system, or hazard, while a “no” answer indicates the area does not.

Upon meeting the relevance criteria, a nominated site must then have substantial significance and values 

that meet one or more of the following importance criteria:

Has more than locally significant qualities that give it special worth, consequence, meaning, 

distinctiveness, or cause for concern, especially compared to any similar resource;

Has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, exemplary, unique, 

endangered, threatened, or vulnerable to adverse change;

Has been recognized as warranting protection in order to satisfy national priority concerns or to carry 

out the mandates of FLPMA;
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Has qualities that warrant highlighting in order to satisfy public or management concerns about safety 

and public welfare; or

Poses a significant threat to human life and safety or to property.

In the evaluation for importance, a “yes” answer indicates that the value, resource, system, process, or 

hazard has substantial significance and values and meets one or more of the importance factors listed 

above. A “no” answer indicates the area contains the value, resource, system, process, or hazard, but it is 

not substantially significant and does not meet the importance factors listed above. “N/A” indicates that 

the value, resource, system, process, or hazard is not found within the area.

Based on these requirements, the nominated extension to the existing Salmon Falls Creek ACEC was 

dropped from further consideration because while it met the criteria for relevance, it did not meet the 

importance criteria. Additionally, the nominated Sand Dunes ACEC was dropped from further 

consideration because it did not meet criteria for relevance or importance. The remaining nominated 

ACECs and their nominated boundary modifications met the criteria for relevance and importance and 

have been included in the alternatives analyzed in this document.
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_ _______

_______

Jarbidge Field Office

RELEVANCE AND IMPORTANCE EVALUATION

FOR

NOMINATED AREAS OF CRITICAL ENVIRONMENTAL CONCERN

Approved by:

Brian Davis

Jarbidge Field Office Manager

signed copy on file

Date

03/07/2014

Concurrence by:

Mel M. Meier

Twin Falls District Manager

signed copy on file 

Date

_03/07/2014
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Bruneau-Jarbidge Area of Critical Environmental Concern

The Bruneau-Jarbidge ACEC is an existing ACEC. The existing ACEC was renominated; two alternate 

boundaries for the ACEC were nominated as well. The area encompassed by the existing boundary is 

presented first, followed by the area encompassed by the nominated extensions to the existing boundary. 

Finally, the area encompassed by the nominated reduced boundary is discussed.

Existing ACEC

Nominated ACEC: Bruneau-Jarbidge ACEC (existing boundary)

Nominated by: The existing ACEC was renominated by BLM in accordance with BLM Manual 

1613, Areas of Critical Environmental Concern, Section .21A.1.

The existing ACEC was renominated by Western Watersheds Project.

Location: The ACEC encompasses 85,000 acres of BLM-managed land. The ACEC is 

located along the Bruneau River from near Crowbar Gulch upstream to the 

Jarbidge planning area boundary, along the Jarbidge River from the Bruneau 

River confluence to the Buck Creek confluence, and along the East Fork of the 

Jarbidge River from the Jarbidge River confluence to the planning area 

boundary. Portions of Clover, Deep, Cougar, Dorsey, Columbet, and Dave 

Creeks are also within the ACEC. The ACEC includes the canyons as well as 

portions of the adjacent uplands. 

The ACEC is contained within the nominated Sagebrush Sea ACEC. The ACEC 

overlaps 73% of the Bruneau-Jarbidge Rivers Wilderness and 99% of the 

designated Wild and Scenic River (WSR) corridors in the planning area.
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Table M-1. Relevance Evaluation for the Existing Bruneau-Jarbidge ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The only known significant historic resources within the nominated ACEC are on private lands 

within the Bruneau and Jarbidge Canyons. No

Cultural Value

Regionally significant cultural resources are present within the ACEC. Native American use of 

the area extends back thousands of years. While the canyon lands provided food, shelter, and 

water, the adjacent uplands also served as travel corridors between winter villages along the 

Snake and lower Bruneau Rivers and summer camps in the Jarbidge and Owyhee Uplands. 

The area retains traditional cultural importance for the tribes. Many sites are also important for 

their archaeological value.

Yes
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Scenic Value

The canyon complex has exceptional rugged-desert scenery and natural qualities. The 

canyons include both basalt and rhyolite forms of volcanic material. The canyons plunge from 

300 to over 900 feet from the adjacent upland plateaus to the rivers below. Rhyolite columns 

and spires are present through much of the Jarbidge Canyon. The lower portion of the Bruneau 

River contains basalt canyons. Arch Canyon contains a unique, large, natural arch composed 

of rhyolite spanning Cougar Creek.

Yes

Fish or Wildlife Resource

California bighorn sheep: The ACEC contains 41,000 acres of habitat for California bighorn 

sheep (bighorn sheep), a Type 3 BLM Sensitive species, which represents 84% of the bighorn 

sheep habitat within the planning area. The bighorn sheep population within the ACEC is 

estimated to be approximately 210 sheep. The Foundation for North American Wild Sheep and 

the Idaho Department of Fish and Game were instrumental in re-introducing bighorn sheep into 

the Bruneau and Jarbidge Canyons in the 1980s and early 1990s. The canyon lands provide 

secure lambing habitat. The rivers in the canyon bottoms, as well as occasional seeps from 

canyon walls, provide water. Bighorn sheep forage is available in both the canyons and 

adjacent uplands. The vast majority of bighorn sheep observations are within the canyon and 

on the upland plateau within 1 mile of the canyon rim. Bighorn sheep typically avoid human 

disturbance and can be socially displaced in the short term from otherwise suitable habitat 

when livestock are present (Bissonette and Steinkamp, 1996). 

Yes

Big game: The ACEC contains 84,000 acres of big game winter range and supports a 

substantial amount of wintering big game. About half of the wintering mule deer in the planning 

area use portions of the ACEC as winter range. Wintering mule deer and elk include both 

resident and migratory herds.

Yes

Bull trout: The ACEC contains 77 miles of critical habitat for bull trout, which represents 87% of 

the critical habitat within the planning area. The Jarbidge River Distinct Population Segment is 

the southern-most surviving population of bull trout in North America (FWS, 2004), occurring in 

a portion of southern Idaho and northern Nevada, and is isolated from other bull trout 

populations by numerous dams. Bull trout in this area are unique in their arid environmental 

setting.

Yes

Redband trout: The ACEC contains habitat for redband trout in four stream reaches, the 

Bruneau River, the Jarbidge River and its East Fork, and Dave Creek. The ACEC contains 96 

miles of occupied redband trout streams.

Yes

Other fish and wildlife: The Bruneau and Jarbidge Canyons contain habitat for a variety of other 

BLM Sensitive species, including peregrine falcon (Type 3 and NV), prairie falcon (Type 3 and 

NV), spotted bat (Type 3 and NV), and Townsend’s big-eared bat (Type 3 and NV). The upland 

plateaus adjacent to the canyons contain habitat for Brewer’s sparrow (Type 3 and NV), greater 

sage-grouse (Candidate, Type 1), sage sparrow (Type 3), and other sagebrush-obligate 

species. The 2007 Murphy Complex Fires burned a substantial amount of the upland habitat on 

the Diamond A east of Jarbidge Forks to the confluence of Poison Creek in the ACEC.

The Jarbidge River contains a natural diversity of native fish species. Compared to other rivers 

in the region, the proportion of native to non-native species is unusually high, as there are few, 

if any, non-native species present. This is a rather unique characteristic for the fish populations 

in the Jarbidge River Watershed.

Yes

Natural System or Process

Bruneau River phlox: Bruneau River phlox, a Type 3 and NV BLM Sensitive species, occurs 

within the Bruneau and Jarbidge Canyons within the ACEC. The ACEC contains 240 acres of 

Bruneau River phlox habitat; which represents 65% of the habitat within the planning area.

Yes

Davis peppergrass: Davis peppergrass, a Type 3 and NV BLM Sensitive species, is present in 

playas within the existing ACEC. The ACEC contains 30 acres of Davis peppergrass habitat, 

which represents 20% of the habitat within the planning area.

Yes
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Special status plant assemblages: The ACEC contains plant species classified as BLM 

Sensitive or Watch Species, including Cusick’s primrose (Type 5 and NV) and Simpson’s 

hedgehog cactus (Type 4). The population of Cusick’s primrose is in Nevada. While this 

species is found elsewhere in Idaho and Oregon; it is the only population of Cusick’s primrose 

in the planning area and the only population of this species in Nevada.

Yes

Upland vegetation: The ACEC contains two plant communities that are generally isolated 

because of topography and are ungrazed: the curl-leaf mountain mahogany woodland 

community and the mountain big sagebrush/bluebunch wheatgrass community.

Yes

Riparian systems: Over 96 miles of the Bruneau-Jarbidge River System are free flowing in the 

ACEC. The riparian systems in the ACEC are also unique in that they are typically dominated 

by Rocky Mountain juniper with interspersed quaking aspen and a few pockets of cottonwood.

Yes

Natural Hazard

No known significant hazards. No

Table M-2. Importance Evaluation for the Existing Bruneau-Jarbidge ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors: 

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA; 

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA

Historic Value

NA NA 

Cultural Value

(Factors met: 1, 2) Regionally significant cultural resources are present within the nominated 

ACEC. Yes

Scenic Value

(Factors met: 1) Scenic values are outstanding and include 99% of the designated WSR 

corridors in the planning area. The area contains numerous access locations for public viewing. 

Areas such as Arch Canyon, the Jarbidge River, and the Bruneau River attract visitors from 

across the West.

Yes

Fish or Wildlife Resource

California bighorn sheep: (Factors met: 1, 2, 3) Bighorn sheep, a Type 3 BLM Sensitive 

species, are scattered in small herds across parts of Oregon, Idaho, Nevada, and British 

Columbia. In Idaho, bighorn sheep populations in South Hills and Jim Sage Mountains are 

smaller than in the Bruneau/Jarbidge River area. The population in the Owyhee River is larger 

than the Bruneau/Jarbidge River population. Bighorn sheep typically respond negatively to 

increased human activities by avoiding portions of their habitat containing greater disturbance. 

Research in southern Idaho indicates that livestock can alter bighorn sheep habitat use and 

displace bighorn sheep from their habitat (Bissonette and Steinkamp, 1996), which can 

increase the risk of inbreeding and disease, as well as degradation of the higher-use portions 

of their habitat (Krausman and Bowyer, 2003). Bighorn sheep in Idaho are recovering from a 

population crash due to disease in the late 1990s. This population of bighorn sheep is of more 

than local importance, evidenced in part by the fact that bighorn sheep tags for hunts in this 

area are in high demand and attract applicants from across the United States. 

Yes
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Big game: The ACEC is important to wintering big game from parts of Nevada and Idaho 

including mule deer, pronghorn, and elk. Mule deer and pronghorn are featured big game 

species in Idaho. Mule deer and elk are featured species in Nevada. The winter range within 

the ACEC is primarily of local importance.

No

Bull trout: (Factors met: 1, 2, 3) The Jarbidge River in southwest Idaho and northern Nevada is 

a tributary to the Snake River and contains the southernmost existing population of bull trout in 

North America (FWS, 2004). Bull trout are the only fish within the planning area listed as 

Threatened under the Endangered Species Act and are a Type 1 BLM Sensitive species. 

Genetic analysis of bull trout in the Columbia River Basin indicates Jarbidge River bull trout 

have a shared evolutionary history with populations in the upper Columbia River and Snake 

River but are genetically separated. For more than 100 years, Jarbidge River bull trout have 

been geographically isolated from other populations in the Snake River by more than 150 miles 

of unsuitable habitat and several impassable hydroelectric dams on the Snake River and at 

least one irrigation diversion on the lower Bruneau River. Bull trout in the Jarbidge River are 

considered significant because they occupy a unique and unusual ecological setting and their 

loss would result in a substantial modification of the species’ range. The bull trout in the 

Jarbidge River are unique in that a portion of their habitat is in an area categorized as semi-arid 

desert. The ACEC has both spawning and migratory habitat for bull trout. Dave Creek (included 

within the boundary) contains a portion of the spawning and rearing area for bull trout within the 

East Fork of the Jarbidge River.

Yes

Redband trout: (Factors met: 1, 2) Redband trout are a Type 2 BLM Sensitive species present 

in four stream reaches within the ACEC. These redband trout are adapted to both the colder 

streams that are critical for bull trout and the warmer, low elevation streams such as the lower 

Jarbidge River and Bruneau River. These populations of redband trout are also unique in that 

the occupied streams within the ACEC lack migration barriers that prevent redband trout from 

moving between streams, unlike most of the other redband trout streams within the planning 

area.

Yes

Other fish and wildlife: The other fish and wildlife present within the ACEC are found elsewhere 

in and outside the planning area; the populations within the ACEC are primarily of local 

importance.

No

Natural System or Process

Bruneau River phlox: (Factors met: 1, 2, 3) Bruneau River phlox is a Type 3 and NV BLM 

Sensitive species endemic to the area. The ACEC contains 240 acres of Bruneau River phlox 

habitat; which represents 65% of the habitat within the planning area. Bruneau River phlox has 

a total estimated population of 500 plants.

Yes

Davis peppergrass: (Factors met: 1, 2, 3) Davis peppergrass, a Type 3 and NV BLM Sensitive 

species, is limited in its distribution to portions of southeastern Oregon, south-central Idaho, 

and north-central Nevada, with the majority of known populations occurring in Idaho. The 

ACEC contains 30 acres of Davis peppergrass habitat, which represents 20% of the habitat 

within the planning area. There are fewer than 300 populations in six distinct clusters or 

distribution centers. The Bruneau-Jarbidge populations are a population stronghold. The 

Mountain Home populations show downward trend due to poor ecological condition of the 

sagebrush steppe ecosystem. The remaining populations are currently stable. Threats to Davis 

peppergrass include habitat alteration in and surrounding playas and invasion of exotic 

annuals. Davis peppergrass plants show distinct differences in leaf size, shape, and plant 

phenology between playas. This suggests the species disperses poorly, probably not beyond 

individual playas, and there is minimal pollination between neighboring playas. The population 

of Davis peppergrass is declining range wide.

Yes

Special status plant assemblages: Other special status and uncommon plants occur in the 

area, but are not of more than local significance. No

Upland vegetation: The isolated curl-leaf mountain mahogany woodland and mountain big 

sagebrush/bluebunch wheatgrass communities are present in other portions of the planning 

area. These sites are largely ungrazed by livestock.

No
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Riparian systems: (Factors met: 1, 2) The Bruneau and Jarbidge Rivers are unique; they are 

two of the longest free-flowing streams in southern Idaho. The majority of other desert rivers, 

including the Snake and Owyhee Rivers and Salmon Falls Creek, contain dams. The Jarbidge 

River system is critical for bull trout that migrate between suitable streams between the East 

Fork of the Jarbidge River and the Jarbidge River and potentially overwinter in the lower 

Jarbidge River. Riparian zones on BLM-managed portions of lower Dave Creek, as well as the 

Jarbidge River and its East Fork and portions of the Bruneau River (from about 0.5 miles 

downstream of Indian Hot Springs almost to the Bruneau Valley) are ungrazed due to limited 

access. 

Yes

Natural Hazard

NA NA 

The ACEC meets the relevance and importance criteria to be considered as a potential ACEC. The 

rationale for nominating the existing Bruneau-Jarbidge ACEC for designation (under Alternative I) as an 

ACEC is as follows:

The ACEC meets relevance and importance criteria for cultural and scenic values, fish and wildlife 

resources (bighorn sheep, bull trout, and redband trout), and natural systems or processes (Bruneau 

River phlox, Davis peppergrass, and riparian systems).

Existing and potential threats to the relevant and important values of the ACEC include surface-disturbing 

activities, wildland fire and subsequent alteration of habitat, and to a lesser extent livestock grazing and 

recreation. Aside from direct impacts from these threats, many of these indirectly affect the introduction 

and spread of noxious weeds and invasive plants, which are detrimental to the scenic values and the fish 

and wildlife resources within the ACEC.

Outside designated wilderness, surface-disturbing activities, such as mineral exploration and 

development and right-of-way (ROW) development, are a threat to cultural and scenic values and 

bighorn sheep; bighorn sheep typically avoid human disturbance.

There is currently one active mining claim within the ACEC boundary, at Indian Hot Springs for Bruneau jasper.

 Any activities in the uplands or riparian 

zones that increase sediment to the stream can adversely affect bull trout and redband trout. 

Wildland fire is a threat to several of the relevant and important values within the ACEC. Wildland fires 

that burn the riparian zone can reduce the amount of large wood and streambank shade and increase 

sediment to the stream, affecting bull trout, which require cold clean water with low amounts of sediment 

in stream gravels for spawning and rearing. Components of wildland fire suppression (e.g., the use of 

retardant, constructing control lines) can also be detrimental to fish and aquatic wildlife. Cheatgrass 

frequently increases and may dominate in the canyon lands following wildland fires, affecting habitat for 

bighorn sheep as well as Bruneau River phlox and Cusick’s primrose. Wildland fire also presents a threat 

to Davis peppergrass. Wildland fire, including soil erosion and deposition following wildland fire, can 

adversely affect habitat for Davis peppergrass (Moseley, 1996). Davis peppergrass can also be impacted 

by the constructions of fire lines that damage plants directly or increase sediment in occupied playas.

Livestock grazing is a threat primarily to bighorn sheep. Bighorn sheep can be displaced by livestock. 

Livestock water sources as well as salting and supplement sites located in the ACEC have contributed to 

the spread of invasive plants. In addition livestock grazing also presents a threat to Davis peppergrass. 

Livestock trailing and trampling in occupied playas while they are wet damages the perennial plants 

(Moseley, 1996). Stock ponds dug in playas may alter their hydrology and contribute to the spread of 

invasive plant species. Livestock congregating in or near playas also impacts cultural resources 

associated with playas.

Recreational use within the canyon is a threat primarily to the cultural values within the ACEC. Cultural 

resource sites within the river corridors are susceptible to inadvertent damage from legitimate boating 

parties as well as from intentional destruction.
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The ACEC overlaps 44,000 acres of the Bruneau-Jarbidge Rivers Wilderness (73% overlap). Areas within 

the wilderness would be managed consistent with the Wilderness Act and the Omnibus Public Lands 

Management Act (OPLMA) and with allocations and management actions made for wilderness.

Designated wild and Scenic River segments within the ACEC include the Bruneau River from Hot Creek 

to the Bruneau River confluence and the Jarbidge River from the Jarbidge Forks to the Bruneau River 

confluence. Outstandingly Remarkable Values (ORVs) for these segments include cultural, fish, 

geological, recreational, scenic, vegetation, and wildlife values. The Bruneau River from Blackrock 

Crossing to 0.3 mile above the confluence of the West Fork of the Bruneau River and the Jarbidge River 

has been recommended suitable for designation as a WSR. The ACEC also contains portions of river 

segments inventoried as eligible for inclusion in the National Wild and Scenic River System (ORVs 

included in parentheses): Cougar Point Creek (scenic), Dave Creek (fish), East Fork of the Jarbidge River 

(fish), and the Jarbidge River south of the Jarbidge Forks (scenic, fish). Management of these segments 

requires that their ORVs are maintained or enhanced. However, the WSR corridor only extends 0.25 

miles above the high water mark on each side of the river, which does not provide any protection for 

these values in the higher elevations of the canyon or the adjacent upland plateaus.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The cultural and scenic values, the fish and wildlife resources, and natural systems or processes 

(Bruneau River phlox and riparian systems) of the ACEC would be protected through the following 

allocations and management actions:

Under the No Action Alternative, the ACEC would be managed as described in the Areas of Critical Environmental 

Concern section of Chapter 2. 

 

All actions within the portions of the ACEC that are also within the Bruneau-Jarbidge Rivers 

Wilderness must be consistent with the Wilderness Act and OPLMA and with allocations and 

management actions made for wilderness.

Areas within the ACEC with concentrated recreational and livestock grazing use would be a high 

priority for noxious weeds and invasive plants treatment with integrated weed management 

techniques for control, containment, and where practical, eradication. Use of domestic sheep or goats 

to reduce noxious weeds would not be allowed within the ACEC to eliminate potential contact with 

bighorn sheep.

The ACEC would be a critical suppression area.

Minimum Impact Suppression Tactics would be used to suppress wildland fires within the ACEC. Fire 

lines would be rehabilitated to help stabilize soils.

Manage the portion of the Jarbidge ROW corridor within the ACEC as Visual Resource Management 

(VRM) Class III; manage the remainder of the ACEC as VRM Class I.

Adjust livestock grazing so livestock seasons of use would not overlap bighorn sheep breeding and 

winter periods in those pastures that contain bighorn sheep habitat. 

Placing salt or other supplements would not be allowed within the ACEC to reduce livestock use of 

bighorn sheep habitat.

Monitor recreational use within the ACEC. If this use reaches levels that impair the relevant and 

important values of the ACEC, implement protective measures appropriate to the type of recreational 

activity. Protective measures may include, but not be limited to, implementing a permit system for the 

Bruneau and Jarbidge Rivers in coordination with the Bruneau Field Office, requiring the use of 

certified weed-free forage and straw, and designating camping areas outside the ACEC.

 Special Recreation Permits would be allowed within the ACEC as long as the relevant and important 

values are protected. 

Motorized vehicle use within the ACEC would be limited to designated routes. To avoid disturbing 

bighorn sheep during wintering and lambing periods or to protect other relevant and important values, 

seasonal closures of specific designated routes may be considered during the Travel Management 

Plan.
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Continue to maintain the low level of human disturbance in bighorn habitat by not constructing new 

roads or substantially improving other routes in the ACEC. Some designated routes within the ACEC, 

including the road to Indian Hot Springs, could have spot surface treatments to reduce resource 

damage due to road braiding and to improve public safety. 

The ACEC would be a ROW avoidance area; new ROWs would be restricted to ROW corridors and 

locations of existing ROWs.

Lands within the ACEC would be in Land Tenure Zone 1; where practical, acquire private and/or 

State inholdings. The ACEC designation and management would apply to lands acquired within the 

ACEC boundary.

The ACEC would be closed to mineral leasing.

The ACEC would be closed to salable mineral development.

Recommend lands within the ACEC for withdrawal from mining laws for locatable exploration and 

development.

Extensions to the Existing ACEC

Nominated ACEC: Extensions to the existing Bruneau-Jarbidge ACEC

Nominated by: The extensions to the existing Bruneau-Jarbidge ACEC were nominated by BLM 

in accordance with BLM Manual 1613, Areas of Critical Environmental Concern, 

Section 21A.2.b., to include additional habitat for bull trout and cultural resource 

sites; the Idaho Conservation Data Center suggested BLM consider including 

habitat for Davis peppergrass within the existing ACEC as well. 

Western Watersheds Project requested that “future expansion of these areas 

(current ACECs) be considered,” although no specific boundary for expanding 

the existing ACECs was identified.

Location: The nominated extensions would encompass about 38,000 acres of BLMmanaged land; if added to the existing ACEC, the new ACEC would total 

123,000 acres of BLM-managed land. The nominated extensions include the 

remainder of the Jarbidge River and Bruneau River not already within the 

existing ACEC, as well as bull trout habitat along the Jarbidge River above the 

confluence with the East Fork, Dave Creek, Jack Creek, and Buck Creek. The 

eastern boundary of the existing ACEC south of Three Creek Highway was also 

modified to follow a road. 

The nominated extensions are contained within the nominated Sagebrush Sea 

ACEC. The ACEC overlaps 99% of the Bruneau-Jarbidge Rivers Wilderness and 

designated Wild and Scenic River (WSR) corridors.
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Table M-3. Relevance Evaluation for the Extensions to the Existing Bruneau-Jarbidge ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The nominated extensions to the existing ACEC contain several historic sites associated with 

early 20th century mining, including a short segment of the Crippen Grade (an old freight road 

to the town of Jarbidge) and the ruins of several log cabins.

Yes

Cultural Value

In addition to the cultural values present in the existing Bruneau-Jarbidge ACEC the nominated 

ACEC extension includes several additional archaeological sites. Yes

Scenic Value

In addition to the scenic values for the existing Bruneau-Jarbidge ACEC, the Jarbidge River 

south of the Jarbidge Forks contains numerous rhyolite columns, spires, and a few window 

rocks that are visible from the Jarbidge Road. Aspen are present on some of the hillsides and 

draws. The majority of the Jarbidge River riparian zone contains a mix of juniper, willows, 

dogwood, with some cottonwood and limber pine.

Yes
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Fish or Wildlife Resource

California bighorn sheep: The nominated extensions to the existing ACEC would add 4,000 

acres of bighorn sheep habitat; the existing Bruneau-Jarbidge ACEC and nominated 

extensions include 45,000 acres of bighorn sheep habitat, which represents 92% of the bighorn 

sheep habitat in the planning area. 

Yes

Big game: The big game values within the nominated extensions to the existing ACEC are the 

same as those documented for the existing boundary of the Bruneau-Jarbidge ACEC. The 

nominated extension would add 36,000 acres of big game winter range; the existing BruneauJarbidge ACEC and nominated extensions include 120,000 acres of big game winter range, 

which represents 23% of the winter range in the planning area.

Yes

Bull trout: Bull trout were listed as a Threatened species in 1998 by the US Fish and Wildlife 

Service. The nominated extensions to the existing ACEC would cover the remaining BLMmanaged portion of Dave Creek as well as migratory bull trout habitat on the Jarbidge River 

above the confluence with the East Fork and all of the BLM-managed portions of Jack Creek. 

These areas total approximately 8 miles of streams for bull trout. The existing BruneauJarbidge ACEC and nominated extensions include 86 miles of critical habitat for bull trout, 

which represents 97% of the critical habitat in the planning area.

Yes 

Redband trout: The nominated extensions to the existing ACEC would add 11 miles of 

occupied redband trout streams to the existing ACEC, including habitat in the Jarbidge River 

above the confluence with the East Fork, Dave Creek, and Deer Creek (NV). The existing 

Bruneau-Jarbidge ACEC and nominated extensions include 107 miles of occupied redband 

trout streams, which represents 43% of the redband trout streams in the planning area.

Yes

Other fish and wildlife: The other fish and wildlife values within the nominated extensions to the 

existing ACEC are the same as those documented for the existing boundary of the BruneauJarbidge ACEC. In addition, the nominated extensions to the existing ACEC would include the 

majority of the playas within the planning area. Playas are important to migrating waterfowl and 

shorebirds during the spring. Playas are also important breeding habitat for Great Basin 

spadefoot toad; however, playas within the nominated extensions are not the only breeding 

habitat for spadefoot toads within the planning area. In some parts of the planning area, fairy 

shrimp also occupy playas (Rudeen, 2006), although the playas within the nominated 

extensions to the existing ACEC have not been inventoried. Playas function as seasonal water 

sources for a number of wildlife species.

Yes

Natural System or Process

Bruneau River phlox: The Bruneau River phlox value within the nominated extensions to the 

existing ACEC is the same as that documented for the existing boundary of the BruneauJarbidge ACEC; however the extension contains 10 additional acres of Bruneau River phlox 

habitat. The nominated extension includes 68% of the Bruneau River phlox habitat within the 

planning area.

Yes

Davis peppergrass: The Davis peppergrass value within the nominated extension to the 

existing ACEC is the same as that documented for the existing boundary of the BruneauJarbidge ACEC; however the extension contains 90 additional acres of Davis peppergrass 

habitat. The nominated extension includes 80% of the habitat within the planning area. 

Yes

Special status plant assemblages: The other special status plants within the nominated 

extensions to the existing ACEC are the same as those documented for the existing boundary 

of the Bruneau-Jarbidge ACEC.

Yes

Upland vegetation: The upland vegetation within the nominated extensions to the existing 

ACEC is the same as that documented for the existing boundary of the Bruneau-Jarbidge 

ACEC.

Yes

Riparian system: The nominated extensions to the existing ACEC would add 8 miles of the 

Bruneau-Jarbidge River System which are free flowing to the ACEC. The existing BruneauJarbidge ACEC and nominated extensions would include 104 miles of free flowing streams, 

which represents 95% of the free flowing streams in the planning area.

Yes

Natural Hazard

No known significant hazards. No
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Table M-4. Importance Evaluation for the Extensions to the Existing Bruneau-Jarbidge ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors: 

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA; 

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

The historic values of the nominated extensions to the existing ACEC are similar to those in the 

surrounding area. More important, regionally significant historic resources are located outside 

the nominated extensions on private and Forest Service lands.

No

Cultural Value

(Factors met: 1, 2) Numerous regionally significant archaeological sites are located within the 

nominated extensions to the existing ACEC. Many sites associated with playas suggest a 

unique adaptation to the arid uplands, which involved transplanting stream-adapted shellfish to 

seasonal lakes to augment food supplies. 

Yes

Scenic Value

(Factors met: 1) Scenic values are outstanding and include 99% of the designated WSR 

corridors in the planning area. The nominated extensions along the Jarbidge River are viewed 

by hundreds of people traveling to Jarbidge, Nevada, during the late spring into late fall.

Yes

Fish or Wildlife Resource

California bighorn sheep: (Factors met: 1, 2, 3) The importance of bighorn sheep values within 

the nominated extensions is the same as that documented for the existing boundary of the 

Bruneau-Jarbidge ACEC; however, an additional 4,000 acres of bighorn sheep habitat within 

the planning area would be included. The nominated extension would have a limited benefit to 

bighorn sheep since they do not routinely occupy the Jarbidge Canyon south of the Jarbidge 

Forks. The main road to Jarbidge, Nevada lies in the bottom of the canyon. Other main access 

roads in the nominated extension include the roads to the Diamond A, Buck Creek Canyon and 

Deer Creek Grade. 

Yes

Big game: The importance of big game values within the nominated extensions is the same as 

that documented for the existing boundary of the Bruneau-Jarbidge ACEC. No

Bull trout: (Factors met: 1, 2, 3) The importance of the bull trout values within the nominated 

extensions is the same as that documented for the existing boundary of the Bruneau-Jarbidge 

ACEC; however, an additional 8 miles of occupied habitat for bull trout within the planning area 

would be included. The existing Bruneau-Jarbidge ACEC and nominated extensions include 86 

miles of critical habitat for bull trout, which represents 97% of the critical habitat in the planning 

area. The nominated extensions would cover an additional mile of bull trout habitat in Dave 

Creek, which is crucial spawning, rearing, foraging, migratory, and overwintering habitat for bull 

trout within the Jarbidge River system (FWS, 2004). Jack Creek is one of the spawning 

streams in the Jarbidge River Watershed. In 1998, BLM, the Forest Service, and Elko County 

cooperatively replaced a culvert on lower Jack Creek with a bridge to remove a bull trout barrier 

to a spawning stream. The Nevada Department of Wildlife has subsequently confirmed bull 

trout spawning in Jack Creek (NDOW, 2005a).

Yes

Redband trout: (Factors met: 1, 2) The importance of the redband trout values within the 

nominated extensions is the same as that documented for the existing boundary of the 

Bruneau-Jarbidge ACEC; however, 11 additional miles of the occupied redband trout habitat 

within the Jarbidge River Watershed would be included. 

Yes
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Other fish and wildlife: The importance of the other fish and wildlife values within the nominated 

extensions is the same as that documented for the existing boundary of the Bruneau-Jarbidge 

ACEC. In addition, the wildlife values of the playas within the nominated extensions are not of 

more than local importance. Spadefoot toads breed in a number of other playas in the planning 

area; the playas within the nominated extensions are not of more than local importance as 

breeding habitat. Fairy shrimp are present in a number of playas in southern Idaho. Fairy 

shrimp known to be present in the planning area are not unique (Rudeen, 2006). Although a 

number of wildlife species use the playas as a source of drinking water at some times of the 

year, playas only temporarily alter the distribution of wildlife. Playas are used by shorebirds and 

waterfowl during spring migration. During fall migration the playas are usually dry.

No

Natural System or Process

Bruneau River phlox: (Factors met: 1, 2, 3) The importance of Bruneau River phlox within the 

nominated extensions t is the same as that documented for the existing boundary of the 

Bruneau-Jarbidge ACEC.

Yes

Davis peppergrass: (Factors met: 1, 2, 3) The importance of Davis peppergrass within the 

nominated extension is the same as that documented for the existing boundary of the BruneauJarbidge ACEC; however 90 additional acres of Davis peppergrass habitat would be included.Yes

Special status plant assemblages: The importance of other special status plants within the 

nominated extensions is the same as that documented for the existing boundary of the 

Bruneau-Jarbidge ACEC.

No

Upland vegetation: The importance of the upland vegetation values within the nominated

extensions is the same as that documented for the existing boundary of the Bruneau-Jarbidge 

ACEC.

No

Riparian systems: (Factors met: 1, 2) Approximately 10 additional miles of riparian zone are 

included in the nominated extensions. This includes about 8 miles of bull trout habitat. Both 

Buck Creek and the Jarbidge River south of the Jarbidge Forks have roads in close proximity to 

the stream.

Yes

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the existing Bruneau-Jarbidge ACEC be expanded to include the 

nominated extensions (under Alternative IV) is as follows:

The ACEC meets relevance and importance criteria for cultural and scenic values, fish and wildlife 

resources (bighorn sheep, bull trout, and redband trout), and natural systems or processes (Bruneau 

River phlox, Davis peppergrass, and riparian systems).

Existing and potential threats to the relevant and important values of the nominated ACEC include 

surface-disturbing activities, wildland fire and subsequent alteration of habitat, and to a lesser extent 

livestock grazing and recreation. Aside from direct impacts from these threats, many of these indirectly 

affect the introduction and spread of noxious weeds and invasive plants. These threats are the same as 

those described for the existing Bruneau-Jarbidge ACEC.

The ACEC overlaps all but 300 acres of the Bruneau-Jarbidge Rivers Wilderness (99% overlap). Areas 

within the wilderness would be managed consistent with the Wilderness Act and Omnibus Public Lands 

Management Act and with allocations and management actions made for wilderness.

The nominated extensions to the existing ACEC would include additional portions of river segments 

inventoried as eligible for inclusion in the National Wild and Scenic River System (Outstandingly 

Remarkable Values [ORVs] included in parentheses): Jarbidge River south of the Jarbidge Forks (scenic, 

fish) and Dave Creek (fish). Interim management of these segments requires that their ORVs are 

maintained or enhanced. However, the WSR corridor only extends 0.25 mile above the high water mark 

on each side of the river, which does not provide any protection for these values in the higher elevations 

of the canyon or the adjacent upland plateaus.
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If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The cultural and scenic values, the fish and wildlife resources, and natural systems or processes 

(Bruneau River phlox and riparian systems) of the ACEC would be protected through the allocations and 

management actions described for the existing Bruneau-Jarbidge ACEC; additional management actions 

for Davis peppergrass, bull trout, and cultural resources would include:

Under the No Action Alternative, the existing ACEC boundary would be retained, and the ACEC would be managed 

as described in the Areas of Critical Environmental Concern section of Chapter 2. 

Restore playas occupied by Davis peppergrass to improve natural hydrologic function and habitat on 

a case by case basis. Restoration activities may include filling pit reservoirs, stabilizing erosion areas, 

and planting native species with similar pollinators. 

Monitor juniper encroachment into the riparian area, and consider juniper treatments to improve bull 

trout habitat.

 Special stipulations would apply for noxious weed and invasive plants treatments in Davis 

peppergrass habitat. 

Adjust livestock seasons of use or stocking rates on a pasture-specific basis to minimize conflicts with 

bull trout spawning (late August through early November) and Davis peppergrass during flowering 

and when playas are most likely to contain water (December to June). 

 Range infrastructure would be evaluated on a case-by-case basis for retention, modification, or 

removal. New infrastructure would be allowed to the extent that it protects bull trout habitat, cultural 

resources, or botanical values.

Reduced Boundary

Nominated ACEC: Bruneau-Jarbidge ACEC (reduced boundary)

Nominated by: C.E. Brackett Cattle Co., Brackett Livestock, Inc., Brackett Ranches Limited 

Partnership, Bert and Paula Brackett, Chet and Kim Brackett, Jake Brackett, Gus 

and Kimberly Brackett, Ira and Kim Brackett, and Chuck B. Jones (Simplot 

Livestock Co.) nominated a portion of the existing Bruneau-Jarbidge ACEC to 

continue to be designated as an ACEC.

Location: The nominated ACEC would encompass 57,000 acres of BLM-managed land. 

The majority of the nominated ACEC lies within the Bruneau and Jarbidge 

Canyons; some of the adjacent uplands are included within the boundary as well. 

Portions of the existing ACEC that would not be included within this boundary 

include areas south of the Bruneau-Jarbidge Rivers Wilderness boundary on the 

Bruneau River, Jarbidge River and its East Fork, as well as areas north of 

Sheepshead Draw.

The ACEC is contained within the nominated Sagebrush Sea ACEC. The ACEC 

overlaps 93% of the Bruneau-Jarbidge Rivers Wilderness and 82% of the 

designated Wild and Scenic River (WSR) corridors.
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Table M-5. Relevance Evaluation for the Bruneau-Jarbidge ACEC Reduced Boundary

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The only known significant historic resources within the reduced boundary of the ACEC are on 

private lands within the Bruneau and Jarbidge Canyons. No

Cultural Value

The cultural values within the nominated reduced boundary of the ACEC are the same as those 

documented for the existing boundary of the Bruneau-Jarbidge ACEC. Yes

Scenic Value

The scenic values within the nominated reduced boundary of the ACEC are the same as those 

documented for the existing boundary of the Bruneau-Jarbidge ACEC. Yes
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Fish or Wildlife Resource 

California bighorn sheep: The nominated reduced boundary of the ACEC contains 29,000 

acres of bighorn sheep habitat, a Type 3 BLM Sensitive species. The bighorn sheep values 

within the nominated reduced boundary of the ACEC are the same as those documented for 

the existing boundary of the Bruneau-Jarbidge ACEC; the nominated ACEC would contain 59% 

of the bighorn sheep habitat, the majority of the area where bighorn sheep are commonly 

observed. 

Yes

Big game: The big game values within the nominated reduced boundary of the ACEC are the 

same as those documented for the existing boundary of the Bruneau-Jarbidge ACEC; the 

nominated ACEC would contain 56,000 acres of big game winter range.

Yes

Bull trout: The nominated ACEC contains 43 miles of critical habitat for bull trout, which 

represents 48% of the bull trout habitat in the planning area. Yes

Redband trout: The nominated reduced boundary of the ACEC contains 49 miles of occupied 

redband trout habitat in the Bruneau River and the Jarbidge River below the confluence with 

the East Fork. 

Yes

Other fish and wildlife: The other fish and wildlife values within the nominated reduced 

boundary of the ACEC are the same as those documented for the existing boundary of the 

Bruneau-Jarbidge ACEC.

Yes

Natural System or Process

Bruneau River phlox: The Bruneau River phlox values within the nominated reduced boundary 

of the ACEC are the same as those documented for the existing boundary of the BruneauJarbidge ACEC. The nominated reduced boundary includes 68% of the Bruneau River phlox 

habitat within the planning area.

Yes

Davis peppergrass: The Davis peppergrass values within the nominated reduced boundary of 

the ACEC are the same as those documented for the existing boundary of the BruneauJarbidge ACEC. The nominated extension includes 13% of the habitat within the planning area.Yes

Special status plant assemblages: The nominated reduced boundary of the ACEC contains 

Simpson’s hedgehog cactus, a Type 4 BLM Sensitive species. Yes

Upland vegetation: The nominated reduced boundary of the ACEC does not contain the curlleaf mountain mahogany woodland community or the mountain big sagebrush/bluebunch 

wheatgrass community.

No

Riparian system: The nominated reduced boundary of the ACEC would contain 48 miles of 

free-flowing reaches of the Bruneau and Jarbidge River System. Yes

Natural Hazard

No known significant hazards. No

Table M-6. Importance Evaluation for the Bruneau-Jarbidge ACEC Reduced Boundary

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

NA NA 
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Cultural Value

(Factors met: 1, 2) The importance of the cultural values within the nominated reduced 

boundary of the ACEC is the same as that documented for the existing boundary of the 

Bruneau-Jarbidge ACEC.

Yes

Scenic Value

(Factors met: 1) The importance of the scenic values within the nominated reduced boundary 

of the ACEC is the same as that documented for the existing boundary of the BruneauJarbidge ACEC.

Yes

Fish or Wildlife Resource

California bighorn sheep: (Factors met: 1, 2, 3) The importance of the bighorn sheep values 

within the nominated reduced boundary of the ACEC is the same as that documented for the 

existing boundary of the Bruneau-Jarbidge ACEC. 

Yes

Big game: The importance of the big game values within the nominated reduced boundary of 

the ACEC is the same as that documented for the existing boundary of the Bruneau-Jarbidge 

ACEC.

No

Bull trout: (Factors met: 1, 2, 3) The importance of the bull trout values within the nominated 

reduced boundary of the ACEC is the same as that documented for the existing boundary of 

the Bruneau-Jarbidge ACEC.

Yes

Redband trout: (Factors 1, 2) Redband trout habitat in the Jarbidge River below the confluence 

with the East Fork and portions of the Bruneau River would be included in the nominated 

reduced boundary of the ACEC. These reaches lack migration barriers that would prevent 

redband trout from moving between streams. Summer water temperatures in both reaches 

approach the threshold of redband trout survival.

Yes

Other fish and wildlife: The importance of the other fish and wildlife values within the nominated 

reduced boundary of the ACEC is the same as that documented for the existing boundary of 

the Bruneau-Jarbidge ACEC.

No

Natural System or Process

Bruneau River phlox: (Factors met: 1, 2, 3) The importance of the Bruneau River phlox within 

the nominated reduced boundary of the ACEC is the same as that documented for the existing 

boundary of the Bruneau-Jarbidge ACEC.

Yes

Davis peppergrass: (Factors met: 1, 2, 3) Approximately 20 acres of Davis peppergrass habitat 

are included in the nominated reduced boundary of the ACEC. The importance of Davis 

peppergrass within the ACEC is the same as that documented for the existing boundary of the 

Bruneau-Jarbidge ACEC.

Yes

Special status plant assemblages: The importance of other special status plants within the 

nominated reduced boundary of the ACEC is the same as that documented for the existing 

boundary of the Bruneau-Jarbidge ACEC.

No

Upland vegetation: N/A N/A

Riparian Systems: (Factors met: 1, 2) The importance of the riparian system values within the 

nominated reduced boundary of the ACEC is the same as that documented for the existing 

boundary of the Bruneau-Jarbidge ACEC. Approximately 44% of the free flowing stream 

reaches in the Bruneau-Jarbidge River System would be protected under this nominated 

ACEC.

Yes

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Bruneau-Jarbidge ACEC (reduced boundary) for 

designation (under Alternative III) as an ACEC is as follows:

The ACEC meets relevance and importance criteria for cultural and scenic values, fish and wildlife 

resources (bighorn sheep and redband trout), and natural systems or processes (Bruneau River phlox 

and riparian systems).
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Existing and potential threats to the relevant and important values of the nominated ACEC include 

surface-disturbing activities, wildland fire and subsequent alteration of habitat, and to a lesser extent 

livestock grazing and recreation. Aside from direct impacts from these threats, many of these activities

indirectly affect the introduction and spread of noxious weeds and invasive plants, which are detrimental 

to the scenic values and the fish and wildlife resources within the nominated ACEC. Threats resulting 

from these activities in the nominated ACEC are the same as those described for the existing BruneauJarbidge ACEC.

The ACEC overlaps 56,000 acres of the Bruneau-Jarbidge Rivers Wilderness (93% overlap). Areas within 

the wilderness would be managed consistent with the Wilderness Act and Omnibus Public Lands 

Management Act (OPLMA) and with allocations and management actions made for wilderness.

River segments within the ACEC that have been designated as WSRs include the Bruneau River from 

Hot Creek to the Bruneau River confluence and the Jarbidge River from the Jarbidge Forks to the 

Bruneau River confluence. Outstandingly Remarkable Values (ORVs) for these segments include 

cultural, fish, geological, recreational, scenic, vegetation, and wildlife values. The Bruneau River from 

Blackrock Crossing to 0.3 mile above the confluence of the West Fork of the Bruneau River and the 

Jarbidge River has been recommended suitable for designation as a WSR. The ACEC also contains 

portions of river segments inventoried as eligible for inclusion in the National Wild and Scenic River 

System (ORVs included in parentheses): Cougar Point Creek (scenic), Dave Creek (fish), East Fork of 

the Jarbidge River (fish), and the Jarbidge River south of the Jarbidge Forks (scenic, fish). Management 

of these segments requires that they are managed to maintain or enhance their ORVs. However, the 

WSR corridor only extends 0.25 mile above the high water mark on each side of the river, which does not 

provide any protection for these values in the higher elevations of the canyon or the adjacent upland 

plateaus.

Segments of the Bruneau (downstream of the Jarbidge River confluence) and Jarbidge Rivers within the 

nominated ACEC have been designated as WSRs. ORVs for these segments include cultural, fish, 

geological, recreational, scenic, vegetation, and wildlife values. The West Fork of the Bruneau River 

(upstream of the Jarbidge River confluence) within the nominated ACEC has been recommended suitable 

for designation as a WSR. Management of these segments requires that their ORVs are maintained or 

enhanced. However, the Wild and Scenic corridor only extends 0.25 miles above the high water mark on 

each side of the river, which does not provide any protection for these values in the higher elevations of 

the canyon or the adjacent upland plateaus.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The cultural and scenic values, fish and wildlife resources (bighorn sheep and redband trout), and natural 

systems or processes (Bruneau River phlox and riparian systems) of the ACEC would be protected 

through the following allocations and management actions : 

Under the No Action Alternative, the existing ACEC boundary would be retained, and the ACEC would be managed 

as described in the Areas of Critical Environmental Concern section of Chapter 2. 

All actions within the portions of the ACEC that are also within Bruneau-Jarbidge Rivers Wilderness 

must be consistent with the Wilderness Act and OPLMA and with allocations and management 

actions made for wilderness.

The ACEC would be a high priority for noxious weeds and invasive plants treatments with integrated 

weed management techniques for control, containment, and where practical, eradication. Use of 

domestic sheep or goats to reduce noxious weeds would not be allowed within the ACEC to eliminate 

potential contact with bighorn sheep.

 The ACEC would be a critical suppression area.

Manage the ACEC as Visual Resource Management Class I.
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Placing salt or other supplements within the ACEC would not be allowed to reduce livestock use of 

bighorn sheep habitat and protect winter range. 

Monitor recreational use within the ACEC. If this use reaches levels that impair the relevant and 

important values of the ACEC, implement protective measures appropriate to the type of recreational 

activity. Protective measures may include: implementing a permit system for the Bruneau and 

Jarbidge Rivers in coordination with the Bruneau Field Office, requiring the use of certified weed-free 

forage and straw, and designating camping areas outside the ACEC.

 Special Recreation Permits would be allowed within the ACEC as long as the relevant and important 

values are protected. 

 Motorized vehicle use within the ACEC would be limited to designated routes. To avoid disturbing 

bighorn sheep during wintering and lambing periods or to protect other relevant and important values, 

seasonal closures of specific designated routes may be considered during the Travel Management 

Plan. 

Some designated routes within and adjoining the ACEC, including the road to Indian Hot Springs, 

could be improved to reduce resource damage due to road braiding, improve public safety, and 

facilitate visitor traffic. 

The ACEC would be a ROW avoidance area; no overhead authorizations would be allowed.

Lands within the ACEC would be in Land Tenure Zone 1; where practical, acquire private inholdings. 

The ACEC designation and management would apply to lands acquired within the ACEC boundary.

 The ACEC would be closed to mineral leasing.

 The ACEC would be closed to salable mineral development.

Recommend lands within the ACEC for withdrawal from mining laws for locatable exploration and 

development.
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Inside Desert Area of Critical Environmental Concern Two boundaries were nominated for the Inside Desert ACEC. The area encompassed by the larger 

boundary is presented first, followed by the area encompassed by the smaller boundary. 

Large Boundary

Nominated ACEC: Inside Desert ACEC (large boundary)

Nominated by: The Inside Desert ACEC was nominated by BLM in accordance with BLM 

Manual 1613, Areas of Critical Environmental Concern, Section .21A.2.b.; the 

Idaho Conservation Data Center suggested BLM consider special management 

for slickspot peppergrass.

An ACEC for the slickspot peppergrass metapopulation within the Jarbidge Field 

Office was nominated by Western Watersheds Project, although no specific 

boundary was identified. The large boundary of the nominated Inside Desert 

ACEC encompasses the vast majority of the slickspot peppergrass 

metapopulation within the planning area.

Location: The nominated ACEC would encompass 73,000 acres of BLM-managed land. 

The nominated ACEC would be located between Clover Creek and the Jarbidge 

River and from Clover Butte south to approximately Poison Butte. The nominated 

ACEC would be adjacent to the Juniper Butte Training Range. The nominated 

ACEC boundary encompasses 100% of the acres supporting slickspot 

peppergrass on BLM-managed lands in the Jarbidge planning area;

Calculation does not include 1/2 mile habitat integrity buffer.

the 

boundary was drawn along existing pasture fences to make the nominated ACEC 

manageable. 

The nominated ACEC is contained within the nominated Sagebrush Sea ACEC.
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Table M-7. Relevance Evaluation for the Inside Desert ACEC Large Boundary

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

Historic resources within the nominated ACEC are primarily related to the early livestock 

industry and include sheep camps, cairns, and fences. No significant historic sites are known 

within the area.

No

Cultural Value

The area is characterized by a low to moderate density of archaeological sites including sites

that are of traditional cultural importance to the tribes and some that have important scientific 

value.

Yes

Scenic Value

The Jarbidge Mountains are visible to the south and provide some scenic value. Scenic values 

are not outstanding. No

Fish or Wildlife Resource

The area contains habitat for several BLM Sensitive species, including Brewer’s sparrow (Type 

3), ferruginous hawk (Type 3), greater sage-grouse (Candidate, Type 1), loggerhead shrike 

(Type 3), sage sparrow (Type 3), kit fox (Type 4), and pygmy rabbit (Type 2). The area 

contains habitat for antelope and mule deer. Wildland fires have reduced and fragmented the 

habitat to a large degree. No fish habitat or riparian zones are present within the nominated 

ACEC.

Yes

Natural System or Process

Slickspot peppergrass: Slickspot peppergrass is a rare, annual or biennial forb endemic to 

sagebrush steppe in southwestern Idaho (Moseley, 1994). Slickspot peppergrass is a Type 1 

BLM Sensitive species that is Proposed for listing as Endangered under the Endangered 

Species Act (ESA). The nominated ACEC contains patches of high quality habitat for slickspot 

peppergrass, which is characterized by intact sagebrush steppe, low abundance of non-native 

species, and low levels of human-caused disturbances (Colket, 2006; FWS, 2003; Moseley, 

1994). 

Yes

Special status plant assemblages: Earth lichen is a Type 4 BLM Sensitive plant that also 

occurs in slickspots in the nominated ACEC. Yes

Natural Hazard

No known hazards. No

Table M-8. Importance Evaluation for the Inside Desert ACEC Large Boundary

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA

Historic Value

NA NA 

Cultural Value

Although important, the cultural resources here are generally dispersed and similar to those of 

the surrounding area in terms of age and function. No

Scenic Value

NA NA 
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Fish or Wildlife Resource

The presence of kit fox is of local importance. Kit fox are considered uncommon in Idaho; 

southern Idaho is at the northern extent of its range. Habitat conversion and fragmentation 

have reduced the value of the area for sage-grouse, pygmy rabbit, loggerhead shrike, Brewer’s 

sparrow, and sage sparrow. 

No

Natural System or Process

Slickspot peppergrass: (Factors met: 2, 3) Slickspot peppergrass is a Type 1 BLM Sensitive 

species that is Proposed for listing as Endangered under the ESA. The population of slickspot 

peppergrass in the nominated ACEC is the most genetically diverse of the known slickspot 

peppergrass populations (Smith et al., 2009). The nominated ACEC contains 100% of the 

acres supporting slickspot peppergrass populations on BLM-managed lands in the planning 

area.

Slickspot peppergrass is one of the few flowering plant species with two life cycle types: annual 

and biennial. Slickspot peppergrass is highly specific to slickspots that developed on remnant 

Pleistocene surfaces (Fisher et al., 1996). Slickspots, also known as mini-playas or natric sites, 

are small soil inclusions with a silt loam surface crust, a restrictive hardpan, and a subsurface 

clay layer (argillic horizon) (Fisher et al., 1996; Lewis and White, 1964; Sandoval et al., 1959). 

Soils in slickspots tend to be more alkaline or saline than the adjacent uplands. Slickspots can 

range in size from a square foot to interlinked complexes over 900 square feet. Slickspots are 

associated with shrub interspaces in sagebrush steppe and are visually distinct, due to their 

high reflectance and sparsely vegetated surface (Fisher et al., 1996). 

Physical disturbance of slickspots when they are wet can disrupt underlying soil structure 

essential for slickspot peppergrass recruitment (Meyer et al., 2006). Disturbances include 

livestock hoof prints, drill seeding, fire-fighting activities (e.g., fire lines), and cross-country 

motorized vehicle tracks (Meyer et al., 2005; Meyer et al., 2006). Repeated and severe 

penetrating disturbances, especially during saturated soil conditions during the spring, may be 

precursors to slickspot invasion by non-native species (e.g., bur buttercup, clasping-leaf 

pepperweed), further reducing slickspot integrity (FWS, 2003). Degradation of slickspot 

peppergrass habitat has been attributed to large, uncharacteristic wildland fires; conversion of 

sagebrush steppe to non-native annual grasslands; historic over-grazing by livestock; and 

historic rangeland rehabilitation practices (e.g., drill seeding) (Colket, 2005; FWS, 2003; Lesica 

and DeLuca, 1996; Moseley, 1994; Noss et al., 1995; Peters and Bunting, 1994; Whisenant, 

1990). Habitat loss and degradation, fragmentation, and population isolation may 

correspondingly result in the loss of genetic fitness (Moseley, 1994; Reed and Frankham, 

2003). Many slickspot peppergrass element occurrences (EOs) occur in fragmented sagebrush 

steppe or non-native annual grasslands and are highly susceptible to reduced genetic diversity 

and gene flow (Robertson, 2004; Robertson and Klemash, 2003). An EO is a specific 

geographic location where “a species or natural community is, or was, present” (NatureServe, 

2002). 

Yes

Special status plant assemblages: Earth lichen is a Type 4 BLM Sensitive plant species. Earth 

lichen in the nominated ACEC is not more than locally important. No

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Inside Desert ACEC for designation as an ACEC 

(under Alternative IV-A) is as follows:

The nominated ACEC meets relevance and importance criteria for natural systems or processes 

(slickspot peppergrass).
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Threats to slickspot peppergrass within the nominated ACEC include wildland fire, noxious weeds and 

invasive plants, and livestock grazing. Any other activities that result in surface disturbance are also a 

potential threat to slickspot peppergrass. 

Wildland fires are a threat to slickspot peppergrass, through the effects of the fire itself as well as the 

effects of wildland fire suppression activities. Wildland fires and subsequent rehabilitation also has altered 

habitat in the majority of slickspot peppergrass habitat in the planning area. Drill seeding following fires 

from the 1980s through the 1990s converted large portions of slickspot habitat to non-native perennial 

communities. Soil erosion and deposition following wildland fires as well as the construction of fire lines in 

slickspot habitat are also threats to slickspot peppergrass. 

Noxious weeds and invasive plants are also a threat to habitat for slickspot peppergrass within the ACEC. 

Livestock grazing also can be a threat to slickspot peppergrass within the nominated ACEC. Livestock 

grazing in slickspot peppergrass habitat can result in trampling of slickspots and plants when the soils are 

moist. In some instances, range infrastructure can present a threat to slickspot peppergrass through 

increased trampling around water sources and trailing along fences; these actions can also result in the 

spread of noxious weeds and invasive plants, further impacting the species. In other cases, properly 

located fences could help protect concentrations of slickspots from the impacts of livestock grazing.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The natural systems or processes (slickspot peppergrass) of the ACEC would be protected through the 

following allocations and management actions:

Restore slickspot peppergrass habitat by planting native shrubs, grasses, and forbs to improve 

ecological function and increase pollinators.

Seed only native species, with emphasis on plants with similar pollinators.

Where practical, vegetation treatments, including drill seeding, would avoid concentrations of 

slickspots. 

The ACEC would be a high priority for noxious weeds and invasive plants treatments with integrated 

weed management techniques for control, containment, and where practical, eradication.

 The ACEC would be a critical suppression area.

 Staging areas for fire suppression and rehabilitation activities would be located outside the ACEC.

Manage the ACEC as Visual Resource Management Class III.

The ACEC would not be available for livestock grazing. 

Remove troughs, fences, or other infrastructure within the ACEC.

 Camping would not be allowed within the ACEC.

Lands within the ACEC would be in Land Tenure Zone 1; where practical, acquire State inholdings. 

The ACEC designation and management would apply to lands acquired within the ACEC boundary.

 The ACEC would be closed to mineral leasing.

 The ACEC would be closed to salable mineral development.

Small Boundary

Nominated ACEC: Inside Desert ACEC (small boundary)

Nominated by: The Inside Desert ACEC was nominated by BLM in accordance with BLM 

Manual 1613, Areas of Critical Environmental Concern, Section .21A.2.b.; the 

Idaho Conservation Data Center suggested BLM consider special management 

for slickspot peppergrass. 

Location: The nominated ACEC would encompass 41,000 acres of BLM-managed land. 

The nominated ACEC would be located from Clover Butte south to approximately 

Middle Butte in several pastures near the Juniper Butte Training Range. The 
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nominated ACEC boundary encompasses 83% of the acres supporting slickspot 

peppergrass on BLM-managed lands within the Jarbidge planning area.

Calculation does not include 1/2 mile habitat integrity buffer.

The nominated ACEC is contained within the nominated Sagebrush Sea ACEC.

Table M-9. Relevance Evaluation for the Inside Desert ACEC Small Boundary

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The historic values within the small boundary of the nominated ACEC are the same as those 

documented for the large boundary of the nominated Inside Desert ACEC. No

Cultural Value

The cultural values within the small boundary of the nominated ACEC are the same as those 

documented for the large boundary of the nominated Inside Desert ACEC. Yes

Scenic Value

The scenic values within the small boundary of the nominated ACEC are the same as those 

documented for the large boundary of the nominated Inside Desert ACEC. No

Fish or Wildlife Resource

The fish and wildlife values within the small boundary of the nominated ACEC are the same as 

those documented for the large boundary of the nominated Inside Desert ACEC. Yes

Natural System or Process

Slickspot peppergrass: The slickspot peppergrass values within the small boundary of the 

nominated ACEC are the same as those documented for the large boundary of the nominated 

Inside Desert ACEC; the small boundary would encompass 83% of the acres supporting 

slickspot peppergrass in the planning area. 

Yes
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Special status plant assemblages: The other special status plant values within the small 

boundary of the nominated ACEC are the same as those documented for the large boundary of 

the nominated Inside Desert ACEC.

Yes

Natural Hazard

The natural hazards within the small boundary of the nominated ACEC are the same as those 

documented for the large boundary of the nominated Inside Desert ACEC. No

Table M-10. Importance Evaluation for the Inside Desert ACEC Small Boundary

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

NA NA 

Cultural Value

The importance of the cultural values within the small boundary of the nominated ACEC is the 

same as that documented for the large boundary of the nominated Inside Desert ACEC. No

Scenic Value

NA NA 

Fish or Wildlife Resource

The importance of the fish and wildlife values within the small boundary of the nominated 

ACEC is the same as that documented for the large boundary of the nominated Inside Desert 

ACEC.

No

Natural System or Process

Slickspot peppergrass: (Factors met: 2, 3) The importance of the slickspot peppergrass values 

within the small boundary of the nominated ACEC is the same as that documented for the large 

boundary. The nominated small boundary contains 83% of the acres supporting slickspot 

peppergrass in the planning area. 

Yes

Special status plant assemblages: The importance of the other special status plant values 

within the small boundary of the nominated ACEC is the same as that documented for the large 

boundary of the nominated Inside Desert ACEC.

No

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Inside Desert ACEC for designation (under Alternative 

IV-B) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for natural systems or processes 

(slickspot peppergrass).

Threats to slickspot peppergrass within the small boundary of the nominated ACEC are the same as 

those documented for the large boundary of the nominated Inside Desert ACEC.
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If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The natural systems or processes (slickspot peppergrass) of the ACEC would be protected through the 

same allocations and management actions as described for the large boundary of the Inside Desert 

ACEC.
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Jarbidge Foothills Area of Critical Environmental Concern

Two boundaries were nominated for the Jarbidge Foothills ACEC. The area encompassed by the larger 

boundary is presented first, followed by the area encompassed by the smaller boundary. 

Large Boundary

Nominated ACEC: Jarbidge Foothills ACEC (large boundary)

Nominated by: The Jarbidge Foothills ACEC was nominated by BLM in accordance with BLM 

Manual 1613, Areas of Critical Environmental Concern, Section .21A.2.b.; the 

Idaho Conservation Data Center suggested BLM consider special management 

for the concentration of special status species in the area. 

Location: The nominated ACEC would encompass 134,000 acres of BLM-managed land. 

The nominated ACEC would be located in the southern 1/3 of the planning area. 

The boundary would run from the canyon of the East Fork of the Jarbidge River 

to Salmon Falls Creek and from Three Creek Highway to the southern boundary 

of the Jarbidge planning area.

The nominated ACEC is contained within the nominated Sagebrush Sea ACEC.
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Table M-11. Relevance Evaluation for the Jarbidge Foothills ACEC Large Boundary

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The Toana Freight Road, a freight and stage route that serviced Idaho mining communities 

between 1870 and 1883, runs through the eastern portion of the nominated ACEC. Based on 

its importance in the early settlement and development of Idaho Territory, the Toana Freight 

Road is listed on the National Register of Historic Places.

Yes

Cultural Value

The Jarbidge Foothills area was used extensively by Native Americans for thousands of years. 

For the tribes, many of the sites created by this use serve as important links to ancestral 

lifeways and play a critical role in maintaining traditional tribal culture. In addition, many of the 

sites contain important archaeological information concerning human adaptation to the semiarid environment of southern Idaho over time. 

Yes

Scenic Value

The area contains a variety of scenic landscapes including deep, rugged canyons; uplifted 

cliffs; and a variety of plant communities. The area has a few large springs along Cedar Creek 

producing large volumes of water at their source.

Yes

Fish or Wildlife Resource

Redband trout: The ACEC contains 41 miles of streams occupied by redband trout, a Type 2 

BLM Sensitive species, which represents 16% of the occupied streams in the planning area. 

Redband trout occur in 13 stream reaches within the ACEC. 

Yes

Columbia spotted frog (spotted frog): The nominated ACEC would contain all known occupied 

habitat for spotted frog (Candidate, Type 1, and NV BLM Sensitive species) within the planning 

area. 

Yes

Greater sage-grouse (sage-grouse): Browns Bench/Monument Springs is a regionally 

important stronghold area for sage-grouse, a Candidate, Type 1 BLM Sensitive species. Sagegrouse from this area connect sage-grouse in the Shoshone Basin to the east with sage-grouse 

in northern Nevada and further west in Idaho. Both resident and migratory sage-grouse are 

present in the area. The changes in elevation and plant communities in the ACEC provide 

quality late-brood habitat for sage-grouse. Sage-grouse habitat in this area has remained 

relatively intact and has generally not been fragmented by wildland fire. The large boundary of 

the ACEC would contain 94,000 acres of key sage-grouse habitat, including important wintering 

and breeding habitat. There are currently 19 occupied sage-grouse leks, associated satellite 

leks, and sage-grouse nesting habitat present within the large boundary of the ACEC. 

Yes

Big game: The nominated ACEC has winter and summer habitat for a resident population of 

mule deer, pronghorn, and elk. These numbers are naturally augmented by mule deer, 

pronghorn, and elk that move to the area in the winter from Nevada. About 1/3 of the mule deer 

present in the planning area winter in the nominated ACEC.

Yes

Other wildlife: The nominated ACEC contains the majority of occupied Columbian sharp-tailed 

grouse (sharp-tailed grouse) winter and nesting habitat. Sharp-tailed grouse are a Type 3 and 

NV BLM Sensitive species and were re-introduced into the area by the Idaho Department of 

Fish and Game (IDFG) as part of a multi-state effort (Idaho, Nevada, Oregon, and 

Washington). Transplant efforts have been successful and to date have helped to prevent 

listing of this grouse subspecies. 

The area contains some occupied habitat for pygmy rabbit (Type 2 and NV) and historic habitat 

for mountain quail (Type 3 and NV).

At higher elevations, the area contains limited aspen habitat for Lewis woodpecker (Type 3 and 

NV), northern goshawk (Type 3 and NV), Virginia warbler, and willow flycatcher (Type 3). 

Ferruginous hawk (Type 3) nesting has been documented in some scattered junipers in lower 

elevations. Prairie falcons (Type 3 and NV) and other raptors are known to nest in a number of 

canyons including Cedar, Flat, House, Pole, and Salmon Falls Creeks, as well as the cliffs 

associated with Browns Bench. 

Yes
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Waterfowl nest in the oxbows associated with the low gradient portion of Salmon Falls Creek, 

and beaver ponds are present in some of the perennial streams. Because of the diversity of 

habitats, a variety of nesting birds are present, including the following:

 Riparian zones – spotted sandpiper, yellow-breasted chat (NV), yellow warbler, and willow 

flycatcher (Type 3); 

 Aspen – house wren, mountain bluebird, mountain chickadee, red-breasted nuthatch, rednaped sapsucker (NV), tree swallow, and yellow-rumped warbler; 

 Mountain shrub – Brewer’s sparrow (Type 3 and NV), chipping sparrow, and green-tailed 

towhee; 

 Mountain mahogany – orange-crowned warbler, spotted towhee, and Virginia warbler; 

 Mountain big sagebrush – Brewer’s sparrow (Type 3 and NV), sage-grouse (Candidate, 

Type 1), sage sparrow (Type 3), and vesper sparrow;

Wyoming big sagebrush – Brewer’s sparrow (Type 3 and NV), loggerhead shrike (Type 3 

and NV), sage-grouse (Candidate, Type 1), sage sparrow (Type 3), and vesper sparrow; 

and 

 Cliffs – golden eagle (NV) and white-throated swift.

Natural System or Process

Special status plant assemblages: A few areas within the nominated ACEC contain plant 

species classified as BLM Sensitive species, including broadleaf fleabane (NV), four-wing 

milkvetch (Type 4), Newberry’s milkvetch (Type 4), Simpson’s hedgehog cactus (Type 4), twoheaded onion (Type 4), and white-margined wax plant (Type 4).

Yes

Upland vegetation: Some of the late seral range sites in the planning area occur within the 

nominated ACEC. Plant communities in the nominated ACEC include aspen woodlands, 

mountain mahogany woodlands, high elevation low sagebrush, black sagebrush, mountain 

shrub, mountain big sagebrush, riparian zones, and salt desert shrub. Seventy six percent of 

the vegetation in the ACEC has not burned in the last 25 years (102,000 acres).

Yes

Riparian systems: Numerous streams within the nominated ACEC have irrigation diversions; 

however, a number of other streams are free flowing through the nominated ACEC. Yes

Natural Hazard

No known significant hazards. No

Table M-12. Importance Evaluation for the Jarbidge Foothills ACEC Large Boundary

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

The Toana Freight Road on Browns Bench is the most significant historic resource within the 

nominated ACEC, but only a small portion of the historic road is included in the area under 

consideration.

No

Cultural Value

(Factors met: 1) Regionally significant cultural resources are located throughout the nominated 

ACEC. The physical integrity and cultural values attached to many of these sites are 

threatened by increasing levels of use and development.

Yes
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Scenic Value

Scenic values are not of more than local significance. No

Fish or Wildlife Resource

Redband trout: (Factors met: 1, 2) Redband trout are Type 2 BLM Sensitive species that occur 

in perennial streams in the Jarbidge Foothills. The ACEC contains 41 miles of streams 

occupied by redband trout, which represents 16% of the occupied streams in the planning area. 

Redband trout in the Jarbidge Foothills exist in isolated populations or “strongholds” that are 

unable to migrate to adjacent suitable habitats when threatened by low streamflow conditions 

or other environmental disturbance such as wildland fire. Several of the streams within the 

nominated ACEC (Deadwood, Deer [ID], Cedar, Flat, Deadman) lack or have limited 

connectivity with other streams. Due to the lack of connectivity between redband trout occupied 

streams, these fish are vulnerable to population declines. Recent studies of redband trout 

populations in drainages similar to those found in the Jarbidge Foothills suggest that redband 

trout are declining in their lower elevation habitats (Zoellick et al., 2005). This indicates the 

importance of retaining or restoring connectivity between redband trout populations such as 

those that occur in the Jarbidge Foothills. 

Yes

Columbia spotted frog: (Factors met: 2, 3) Spotted frog populations are part of a larger, but 

fragmented, population of spotted frogs in northern Nevada. The Great Basin population of 

spotted frog is of national significance. Great Basin Columbia spotted frog populations continue 

to decline in portions of Nevada. Spotted frogs have been observed along 5 miles of streams; 

the majority of observations have occurred along Shack and Rocky Canyon Creeks. Potentially 

suitable habitat occurs in several other drainages (China, Cedar, Flat, and House Creeks) 

within the nominated ACEC.

Yes

Greater sage-grouse: (Factors met: 1, 2, 3) Sage-grouse are declining range wide. Declines in 

sage-grouse numbers in southern Idaho and northern Nevada are linked to habitat alteration 

and fragmentation due to wildland fire and subsequent conversion to non-native grassland as 

well as the conversion of sagebrush steppe habitat to agricultural (IDFG, 2007a). Sage-grouse 

in this area are of regional importance. The nominated ACEC contains important wintering and 

breeding habitat and maintains the connectivity between sage-grouse populations in Nevada 

and the Shoshone Basin. Radio-collared sage-grouse movements from leks in the Browns 

Bench area have been documented moving in excess of 10 miles. Radio-collared sage-grouse 

in the Shoshone Basin have been documented to winter in the Browns Bench/Monument 

Springs/China Mountain areas. Both resident and migratory sage-grouse are present. The 

higher elevations support a large number of wintering sage-grouse as well as provide important 

late season sage-grouse brood habitat. 

Yes

Big game: The nominated ACEC provides fawning and calving areas for resident mule deer, 

pronghorn, and elk, although not of more than local significance. The majority of pronghorn and 

elk wintering in the area are from Nevada. The entire nominated ACEC is classified as big 

game winter range.

No

Other wildlife: Mountain shrub and aspen habitats provide sharp-tailed grouse winter habitat. 

Sharp-tailed grouse (Type 3 and NV BLM Sensitive species) in the area provide connectivity to 

a population of sharp-tailed grouse in the Shoshone Basin. At least one sharp-tailed grouse lek 

has been documented within the nominated ACEC, and sharp-tailed grouse are known to nest 

immediately adjacent to the nominated ACEC. At this time, sharp-tailed grouse population in 

the area is not more than locally significant. 

Mountain quail (Type 3 and NV) were historically present within the nominated ACEC. IDFG 

and BLM records suggest that mountain quail have likely been extirpated from the area. 

Historical records indicate that mountain quail were occasionally harvested in the 1960s and 

1970s from this general area. There have been no mountain quail documented within the 

nominated ACEC in the last 25 years.

Ferruginous hawk (Type 3), Lewis woodpecker (Type 3 and NV), northern goshawk (Type 3 

and NV), Virginia warbler, and pygmy rabbit (Type 2) numbers within the nominated ACEC are 

low, and habitat is generally limited for these species. They are not of more than local 

No
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importance.

Although the vegetation communities support a high diversity of birds, these are not of more 

than local interest. Other areas with similar diversity include the City of Rocks, Rock Creek 

Canyon, and the South Hills to the east of the planning area. 

Natural System or Process

Special status plant assemblages: Special status plants occur in the area, but are not of more 

than local significance. No

Upland vegetation: (Factors met: 2) The nominated ACEC contains one of the last large, 

contiguous blocks of high-quality sagebrush steppe habitat in the planning area. Although there 

are other blocks of similar size and quality within the region, the habitat within the nominated 

ACEC is important for maintaining connectivity between other regional blocks of habitat. The 

area has a moderate amount of a natural variety of habitats in close proximity including several 

types of riparian zones, low sagebrush communities, black sagebrush communities, mountain 

big sagebrush, mountain shrub, mountain mahogany savannah, and aspen. Depending on 

slope, soils can be quite erosive. Numerous roads, jeep trails, and fences cross the nominated 

ACEC. The 2007 Murphy Complex Fires burned 17,000 acres of the nominated ACEC. 

However, the nominated ACEC is unique within the planning area in that 76% of the nominated 

ACEC has not burned within the last 25 years (102,000 acres).

Yes

Riparian systems: The riparian systems in the area have altered streamflows and are not more 

than locally significant. No

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Jarbidge Foothills ACEC for designation (under 

Alternative IV-A) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for cultural values, fish and wildlife 

resources (redband trout, Columbia spotted frog, and sage-grouse), and natural systems or processes 

(upland vegetation). 

Existing and potential threats to the relevant and important values within the nominated ACEC include 

wildland fire, alterations of riparian systems, and surface-disturbing activities. These threats all contribute 

to the alteration and fragmentation of upland and riparian habitats.

Wildland fire is the primary threat to the relevant and important values within the nominated ACEC. Since 

the 1970s, wildland fires have reduced the amount of sagebrush habitat present in the planning area by 

roughly two-thirds. Throughout the West as well as locally, habitat conversion and fragmentation in part 

due to wildland fire have contributed to declining sage-grouse numbers and the loss of leks (Knick and

Connelly, 2011). Within the nominated ACEC, 17,000 acres burned in the 2007 Murphy Complex Fires, 

reducing the value of sage-grouse habitat in some areas, and previous wildland fires have affected 

several thousand additional acres. However, the majority of the nominated ACEC has not burned in the 

last 25 years; large wildland fires within these areas may reduce habitat quality for sage-grouse as well as 

contribute to fragmentation of a relatively contiguous area of intact sagebrush steppe. 

Alterations of riparian systems are a threat to redband trout and spotted frog. Dams and diversions of 

streams to irrigate private land have resulted in dewatering portions of some streams, contributing to the 

fragmentation of redband trout habitat. This has reduced the ability of redband trout to move between 

streams. Threats to spotted frog include loss of habitat due to down cutting of streams, lowered water 

table, habitat fragmentation, and sediment from roads on steep gradients. 

Several land uses pose threats to the relevant and important values within the nominated ACEC. 

Generally, surface-disturbing activities that remove vegetation or create corridors for the introduction and 

spread of noxious weeds and invasive plants would affect the relevant and important values; these 
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disturbances include livestock grazing infrastructure, transportation and travel routes, and wind energy 

development. The physical integrity and the cultural values attached to many archaeological sites are 

threatened by increasing levels of use and development as well, particularly increasing levels of crosscountry motorized vehicle use. 

River segments within the nominated ACEC that have been inventoried as eligible for inclusion in the 

National Wild and Scenic River System include Rocky Canyon Creek and Salmon Falls Creek south of 

Salmon Falls Reservoir. Outstandingly Remarkable Values (ORVs) for Rocky Canyon Creek include 

wildlife values, while ORVs for the Salmon Falls Creek segment include recreational values. Interim 

management of these segments requires that they be managed to maintain or enhance their ORVs. 

However, the Wild and Scenic River corridor only extends 0.25 mile above the high water mark on each 

side of the river, which does not provide any protection for these values outside this corridor.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The cultural values, fish and wildlife resources (redband trout, spotted frog, and sage-grouse), and natural 

systems or processes (upland vegetation) of the ACEC would be protected through the following 

allocations and management actions:

 Improving, expanding, connecting, and restoring native plant communities would be a high priority 

within the ACEC. 

Restore mountain shrub habitat for sage-grouse.

Restore habitat for spotted frogs in Rocky Canyon, Timber Canyon, Shack, and Bear Creeks.

Restore redband trout habitat and reduce habitat fragmentation in redband trout occupied 

watersheds.

The ACEC would be a high priority for noxious weeds and invasive plants treatment with integrated 

weed management techniques for control, containment, and where practical, eradication. 

 The ACEC would be a critical suppression area.

Manage the majority of the ACEC as Visual Resource Management (VRM) Class III, where not 

otherwise designated as VRM Class I or II (see the Visual Resources section of Chapter 2).

 Livestock seasons of use or stocking rates would be adjusted within the ACEC to minimize conflicts 

with redband trout, sage-grouse wintering, breeding, and nesting periods; and restoration projects.

Monitor recreational use within the ACEC. If this use reaches levels that impair the relevant and 

important values of the ACEC, implement protective measures appropriate to the type of recreational 

activity. Protective measures may include but not be limited to designating camping areas within the 

ACEC; requiring the use of certified weed-free forage and straw; and installing protective barriers to 

protect relevant and important values.

Travel routes would be designated through the Travel Management Plan to increase core habitat for 

sage-grouse.

BLM-managed lands within the ACEC can be exchanged for non-BLM managed lands within the 

ACEC, consistent with the Land Tenure section of Chapter 2; where practical, acquire private and/or 

State inholdings. The ACEC designation and management would apply to lands acquired within the 

ACEC boundary.

The ACEC would be available for salable mineral development; where practical, use existing mineral 

pits and minimize new salable mineral developments within ACEC. Seasonal closures that restrict 

use or activities at the pits during important seasonal periods for sage-grouse may be included when 

existing salable mineral permits are reauthorized and in new permits.

Limit surface disturbing activities within the ACEC to protect cultural resources; ensure that 

authorized impacts are appropriately mitigated.

Prevent or reduce unauthorized impacts to cultural resources through increased monitoring, public 

outreach, and law enforcement patrols.
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-295

Small Boundary

Nominated ACEC: Jarbidge Foothills ACEC (small boundary)

Nominated by: The Jarbidge Foothills ACEC was nominated by BLM in accordance with BLM 

Manual 1613, Areas of Critical Environmental Concern, Section .21A.2.b.; the 

Idaho Conservation Data Center suggested BLM consider special management 

for the concentration of special status species in the area. 

Location: The nominated ACEC would encompass 64,000 acres of BLM-managed land. 

The nominated ACEC would be located in the southeast corner of the planning 

area. The boundary would run from Salmon Falls Creek west to the House Creek 

Allotment, and from Three Creek Highway south to the southern boundary of 

Jarbidge planning area. This boundary for the Jarbidge Foothills ACEC would 

focus management on a block of primarily BLM-managed lands and would 

reduce the amount of private land within the ACEC boundary.

The nominated ACEC is contained within the nominated Sagebrush Sea ACEC.

Table M-13. Relevance Evaluation for the Jarbidge Foothills ACEC Small Boundary

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The historic value within the small boundary of the nominated ACEC is the same as that 

documented for the large boundary of the nominated Jarbidge Foothills ACEC. Yes

Cultural Value

The cultural value within the small boundary of the nominated ACEC is the same as that 

documented for the large boundary of the nominated Jarbidge Foothills ACEC. Yes

Scenic Value

The scenic value within the small boundary of the nominated ACEC is the same as that 

documented for the large boundary of the nominated Jarbidge Foothills ACEC. Yes
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-296

Fish or Wildlife Resource

Redband trout: The small boundary of the nominated ACEC contains 19 miles of streams 

occupied by redband trout, a Type 2 BLM Sensitive species, which represents 8% of the 

occupied streams in the planning area. Redband trout occur in Cedar Creek, Salmon Falls 

Creek, and portions of China Creek in the ACEC.

Yes

Columbia spotted frog: Spotted frog, a Candidate and Type 1 BLM Sensitive species, do not 

occur within the small boundary of the nominated Jarbidge Foothills ACEC. No

Greater sage-grouse: The sage-grouse values within the small boundary of the nominated 

ACEC are the same as those documented for the large boundary of the nominated Jarbidge 

Foothills ACEC. The small boundary of the nominated ACEC contains 49,000 acres of key 

sage-grouse habitat. There are currently 16 occupied sage-grouse leks, associated satellite 

leks, and sage-grouse nesting habitat present within the small boundary of the nominated 

ACEC.

Yes

Big game: The big game values within the small boundary of the nominated ACEC are the 

same as those documented for the large boundary of the nominated Jarbidge Foothills ACEC; 

the small boundary of the nominated ACEC includes 64,000 acres of big game winter range, 

which represents 7% of the winter range in the planning area.

Yes

Other wildlife: The other wildlife within the small boundary of the nominated ACEC are the 

same as those documented for the large boundary of the nominated Jarbidge Foothills ACEC; 

however, the small boundary of the nominated ACEC would contain a smaller portion of habitat 

for these species.

Yes

Natural System or Process

Special status plant assemblages: The special status plants within the small boundary of the 

nominated ACEC are the same as those documented for the large boundary of the nominated 

Jarbidge Foothills ACEC.

Yes

Upland vegetation: The upland vegetation values within the small boundary of the nominated 

ACEC are the same as those documented for the large boundary of the nominated Jarbidge 

Foothills ACEC. The nominated ACEC is unique within the planning area in that 88% of the 

nominated ACEC has not burned within the last 25 years (56,000 acres). 

Yes

Riparian systems: The riparian values within the small boundary of the nominated ACEC are 

the same as those documented for the large boundary of the nominated Jarbidge Foothills 

ACEC.

Yes 

Natural Hazard

No known significant hazards. No

Table M-14. Importance Evaluation for the Jarbidge Foothills ACEC Small Boundary

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

The importance of the historic value within the small boundary of the nominated ACEC is the 

same as that documented for the large boundary of the nominated Jarbidge Foothills ACEC. No
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-297

Cultural Value

(Factors met: 1) The importance of the cultural values within the small boundary of the 

nominated ACEC is the same as that documented for the large boundary of the nominated 

Jarbidge Foothills ACEC.

Yes

Scenic Value

The importance of the scenic values within the small boundary of the nominated ACEC is the 

same as that documented for the large boundary of the nominated Jarbidge Foothills ACEC. No

Fish or Wildlife Resource

Redband trout: Redband trout only occur in three creeks within the small boundary of the 

nominated ACEC. Redband trout in Cedar Creek are limited to roughly a 7-mile reach with poor 

connectivity to other redband trout bearing streams. Redband trout in China Creek are 

potentially linked to other tributary streams above Salmon Falls Creek Dam (Shoshone, North 

Fork, Bear, and Shack Creeks). Warm water temperature may limit fish movements during the 

summer.

No

Columbia spotted frog: NA NA 

Greater sage-grouse: (Factors met: 1, 2, 3) The importance of sage-grouse values within the 

small boundary of the nominated ACEC is the same as that documented for the large 

boundary. The nominated ACEC supports the best key sage-grouse habitat in the planning 

area particularly considering the impacts of the 2007 Murphy Complex Fires. 

Yes

Big game: The importance of big game values within the small boundary of the nominated 

ACEC is the same as that documented for the large boundary of the nominated Jarbidge 

Foothills ACEC.

No 

Other wildlife: The importance of other wildlife within the small boundary of the nominated 

ACEC is the same as that documented for the large boundary of the nominated Jarbidge 

Foothills ACEC.

No

Natural System or Process

Special status plant assemblages: The importance of special status plants within the small 

boundary of the nominated ACEC is the same as that documented for the large boundary. No

Upland vegetation: (Factors met: 2) The importance of the upland vegetation values within the 

small boundary of the nominated ACEC is the same as that documented for the large boundary 

of the nominated Jarbidge Foothills ACEC. The 2007 Murphy Complex Fires burned 1,500 

acres of the nominated ACEC. The nominated ACEC is unique within the planning area in that 

88% of the nominated ACEC has not burned within the last 25 years (56,000 acres).

Yes

Riparian systems: The importance of riparian values within the small boundary of the 

nominated ACEC is the same as that documented for the large boundary of the nominated 

Jarbidge Foothills ACEC.

No

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Jarbidge Foothills ACEC for designation (under 

Alternative IV-B) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for cultural values, wildlife resources 

(sage-grouse), and natural systems or processes (upland vegetation). 

Existing and potential threats to the relevant and important values within the nominated ACEC include 

wildland fire and surface-disturbing activities. These threats contribute to the alteration and fragmentation 

of upland habitats and are similar to those described for the large boundary of the nominated Jarbidge 

Foothills ACEC. 

Wildland fire is the primary threat to the relevant and important values within the nominated ACEC; this 

threat is similar to that described for the large boundary of the nominated Jarbidge Foothills ACEC. Within 

the small boundary of the nominated ACEC, 1,500 acres burned in the 2007 Murphy Complex Fires. 
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-298

Several uses are potential threats to the relevant and important values within the nominated ACEC; these 

threats are similar to those described for the large boundary. 

Within the nominated ACEC, Salmon Falls Creek south of Salmon Falls Reservoir has been inventoried 

as eligible for inclusion in the National Wild and Scenic River System for a recreational Outstandingly 

Remarkable Value (ORV). Interim management of this segment requires that it be managed to maintain 

or enhance its ORVs. However, the Wild and Scenic River corridor only extends 0.25 mile above the high 

water mark on each side of the river, which does not provide any protection for this value outside this 

corridor.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management

prescriptions necessary to protect those values.

The cultural values, wildlife resources (sage-grouse), and natural systems or processes (upland 

vegetation) of the ACEC would be protected through the same allocations and management actions as 

described for the large boundary of the Jarbidge Foothills ACEC, except management prescribed for 

redband trout and spotted frogs would not apply. Also BLM managed land within the ACEC can be 

exchanged with non-BLM managed lands both inside and outside the ACEC, consistent with the land 

tenure section.
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-299

Lower Bruneau Canyon Area of Critical Environmental Concern Two boundaries were nominated for the Lower Bruneau Canyon ACEC. The area encompassed by the 

larger boundary is presented first, followed by the area encompassed by the smaller boundary. 

Large Boundary

Nominated ACEC: Lower Bruneau Canyon ACEC (large boundary)

Nominated by: The Lower Bruneau Canyon ACEC was nominated by BLM in accordance with 

BLM Manual 1613, Areas of Critical Environmental Concern, Section .21A.2.b. 

Location: The nominated ACEC would encompass 1,000 acres of BLM-managed land. The 

ACEC would be located along the east side of the lower Bruneau River, 

southeast of Indian Bathtub.

Table M-15. Relevance Evaluation for the Lower Bruneau Canyon ACEC Large Boundary

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

No historic resources are known. No

Cultural Value

No significant cultural resources are known. No

Scenic Value

No outstanding scenic resources. The view of the Bruneau River and Canyon from within the 

ACEC is impressive, but not of more than local interest. No

Fish or Wildlife Resource

Bruneau hot springsnail: The Bruneau hot springsnail was listed as an Endangered species in 

1998 (Endangered and Threatened Wildlife and Plants, 1998) and is a Type 1 BLM Sensitive 

species. Geothermally influenced seeps and springs in the Bruneau River and one of its 

tributaries (Hot Creek, outside of the planning area) are the only locations where this species 

Yes
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-300

occurs in the world. Surveys conducted in the 2.5 mile reach upstream of Hot Creek (primarily 

within the nominated ACEC) during 1991–2004 indicate that the total numbers of geothermal 

springs are declining at a rate of approximately 5 geothermal springs per year (Myler et al., 

2007). The numbers of geothermal springs containing springsnail in the same reach are 

declining at a rate of 3.75 per year (Myler et al., 2007). The decline of geothermal springs with 

and without springsnail was significantly related to the decline of the thermal aquifer which 

underlies this area (Myler et al., 2007). The nominated ACEC would protect 2.1 miles of 

geothermal springs on the east side of the Bruneau River, which is 81% of the suitable habitat 

on BLM-managed land in the planning area. Approximately one-third of the global population of 

these snails exists within the nominated ACEC.

Other wildlife: Numerous BLM Sensitive wildlife species occur within the nominated ACEC, 

including Great Basin collared lizard (Type 3), long-nose snake (Type 3), western groundsnake 

(Type 3), ferruginous hawk (Type 3), prairie falcon (Type 3), spotted bat (Type 3), and 

Townsend’s big-eared bat (Type 3). A few mule deer and pronghorn use the area as winter 

range.

Yes

Natural System or Process

Special status plant assemblages: Numerous BLM Sensitive plant species occur in the 

nominated ACEC, including Packard’s cowpie buckwheat (Type 4) and spine-node milkvetch 

(Type 4) – both perennials, and rigid threadbush (Type 4), spreading gilia (Type 3), and whitemargin waxplant (Type 4) – all annuals. The nominated ACEC contains 60 acres of Bruneau 

River phlox (Type 3) habitat, which represents 16% of the Bruneau River phlox habitat within 

the planning area.

Yes

Paleontological resources: The Lower Bruneau Canyon ACEC includes extensive outcrops of 

Hot Springs Limestone – a carbonate layer composed of fossilized lacustrine algal reefs which 

formed along the shoreline of ancient Lake Idaho (Straccia et al., 1990). These Miocene-aged 

deposits are associated with the geologic Chalk Hills Formation and contain a variety of 

vertebrate, invertebrate, and micro-fossils ranging in age from 8 million to 6 million years. The 

nominated ACEC contains the only concentrated exposures of the fossil bearing Chalk Hills 

Formation in the planning area.

Yes

Thermal springs and seeps: Thermal springs and seeps are present within the nominated 

ACEC, supporting the Bruneau hot springsnail. Since the early 1990s, the water flows at the 

thermal springs and seeps have declined, reducing habitat for this Endangered species.

Yes

Natural Hazard

No known significant hazards. No

Table M-16. Importance Evaluation for the Lower Bruneau Canyon ACEC Large Boundary

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Values

NA NA 

Cultural Values

NA NA 
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-301

Scenic Values

NA NA 

Fish or Wildlife Resource

Bruneau hot springsnail: (Factors met: 1, 2, 3) Bruneau hot springsnail is endemic to this reach 

of the Bruneau River and is listed as Endangered under the Endangered Species Act and is 

found only in thermal springs. The entire global population occurs in the geothermal seeps and 

springs along a 5-mile reach of the lower Bruneau River and a portion of Hot Creek (outside of 

the planning area). The nominated ACEC would include 81% of the suitable habitat on BLMmanaged land in the planning area. The snail is very small (0.22 inches) and is unable to move 

between spring sources if conditions within a spring become unsuitable. Groundwater pumping 

to irrigate farmland is the primary threat to the snail. Groundwater pumping has dried up a 

number of springs that previously had this species, and reduced the flows and habitat at 

several other springs (FWS, 2002). Myler and others (2007) predicted that if groundwater 

pumping continues at the present rate, the thermal springs upstream of Hot Creek will be 

completely dry by the year 2031.

In addition to changes in the thermal springs, invasion by reed canary grass and hydrilla is 

impacting the habitat of the listed snail. Bruneau hot springsnail are also vulnerable to 

introduced predators such as the non-native guppies and a species of tilapia that now occurs in 

a few of the small geothermal springs along the Bruneau River and Hot Creek (FWS, 2002). 

Yes

Other wildlife: Numerous BLM Sensitive wildlife species occur within the nominated ACEC, 

including Great Basin collared lizard (Type 3), long-nose snake (Type 3), western groundsnake 

(Type 3), ferruginous hawk (Type 3), prairie falcon (Type 3), spotted bat (Type 3), and 

Townsend’s big-eared bat (Type 3). Long-nose snake, western groundsnake, and Great Basin 

collared lizards are at the northern extent of their range in southwestern Idaho, and the 

Bruneau Canyon is near the eastern extent of their range in Idaho. Although these species are 

at the edge of their range, it is not known if they are of more than local significance. Other 

special status species listed are not of more than local significance. Expansion of invasive nonnative annuals is a threat to these species.

No

Natural System or Process

Special status plant assemblages: (Factors met: 1, 2) The amount of spine-node milkvetch 

(Type 4 BLM Sensitive species) is unique within Idaho. The Idaho population is isolated from 

other populations in Utah, northern Arizona, and southern Nevada. The Idaho population in the 

Bruneau Valley has the highest density of spine-node milkvetch in the United States. 

Bruneau River phlox (Type 3) is endemic to the area. The nominated ACEC contains 60 acres 

of Bruneau River phlox (Type 3) habitat, which represents 16% of the Bruneau River phlox 

habitat within the planning area. Bruneau River phlox has a total estimated population of 500 

plants. The Idaho populations are relatively stable. 

Rigid thread bush (Type 4) is often found within the lower Bruneau Canyon as well as other 

special status plants such as Packard’s cowpie buckwheat (Type 4), spreading gilia (Type 3), 

and white-margin waxplant (Type 4). This high concentration of special status plants is unique; 

this assemblage of species does not occur elsewhere in Idaho.

Yes

Paleontological resources: (Factors met: 1, 2) The Lower Bruneau Canyon ACEC includes 

extensive outcrops of Hot Springs Limestone – a carbonate layer composed of fossilized 

lacustrine algal reefs which formed along the shoreline of ancient Lake Idaho (Straccia et al., 

1990). These Miocene-aged deposits are associated with the geologic Chalk Hills Formation 

and contain a variety of vertebrate, invertebrate, and micro-fossils ranging in age from 8 million 

to 6 million years. The nominated ACEC contains the only concentrated exposures of the fossil 

bearing Chalk Hills Formation in the planning area.

Yes
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-302

Thermal springs and seeps: (Factors met: 1, 2) The geothermal springs along the Bruneau 

River and in Hot Creek are the only habitats where the Bruneau hot springsnail can be found in 

the world. This species has evolved to occupy these unique spring habitats and is sensitive to 

actions that affect the surface flows from the springs, the temperature of the spring, or the 

substrates within the springs. The snail is very small (0.22 inches) and is unable to move 

between spring sources if conditions within a spring become unsuitable. Land management 

actions that affect the springs, even if only temporarily, could result in a direct loss of a 

population of snails within a spring or series of springs. The spring sources that would be 

protected by the nominated ACEC are essential to the persistence of the Bruneau hot 

springsnail in the long term.

Yes

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Lower Bruneau Canyon ACEC for designation (under 

Alternatives I, IV, and V) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for invertebrate resources (Bruneau hot 

springsnail) and natural processes or systems (paleontological resources, special status plants 

assemblages, and thermal springs and seeps).

Existing and potential threats to the relevant and important values within the nominated ACEC include 

noxious weeds and invasive plants, mineral exploration and development, and livestock grazing.

Noxious weeds and invasive plants are affecting both the special status plants as well as the Bruneau hot 

springsnail within the nominated ACEC. A quarter of the nominated ACEC has been burned, contributing 

to the expansion of cheatgrass and posing a long-term threat to native annuals in large part due to 

competition. The continued expansion of reed canary grass and now the noxious weed hydrilla is 

impairing habitat for the Bruneau hot springsnail. Both of these invasive plants reduce the amount of open 

water and inhibit the growth of diatoms and other periphyton on which the snails feed.

Mineral exploration and development is a potential threat to the relevant and important values within the 

nominated ACEC. Salable mineral development has the potential to threaten the special status plant 

assemblage through removal of habitat for these species. Of greater concern for the Bruneau hot 

springsnail would be exploration and development for geothermal energy, as the continuing decline in the 

aquifer is the primary concern for the continued existence of the Bruneau hot springsnail.

Livestock grazing is a threat to the special status plants within the nominated ACEC. Livestock grazing 

and its associated infrastructure may directly damage special status plants and their habitat and can also 

contribute to the introduction and spread of noxious weeds and invasive plants.

The segment of the Bruneau River within the nominated ACEC has been designated as a Wild and 

Scenic River (WSR) corridor. Outstandingly Remarkable Values (ORVs) for this segment include cultural, 

fish, geological, recreational, scenic, vegetation, and wildlife values. Management of this segment 

requires that ORVs are maintained or enhanced. However, the WSR corridor only extends 0.25 mile 

above the high water mark on each side of the river, which does not provide any protection for these 

values in the higher elevations of the canyon or the adjacent upland plateaus.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The fish resources (Bruneau hot springsnail) and natural systems or processes (special status plant 

assemblages, paleontological resources, and thermal springs and seeps) of the ACEC would be 

protected through the following allocations and management actions:
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-303

•

•

•

•

•

•

•

•

•

Under Alternatives I, IV, and V:

Restore native upland and riparian plant communities within the ACEC to improve habitat for special 

status species. 

The ACEC would be a high priority for noxious weeds and invasive plants treatment with integrated 

weed management techniques for control, containment, and where practical, eradication. 

 The ACEC would be a critical suppression area.

Manage the ACEC as Visual Resource Management Class III.

Manage lands within the ACEC in Land Tenure Zone 1. 

 The ACEC would be closed to mineral leasing.

 The ACEC would be closed to salable mineral development.

Under Alternative I and IV only, specific to livestock grazing management:

The ACEC would be available for livestock grazing and new infrastructure as long as they are 

compatible with recovery of the area, including protecting seed production of special status plants and 

reducing impacts to their pollinators.

Under Alternative V only, specific to livestock grazing management:

The ACEC would not be available for livestock grazing.

Small Boundary

Nominated ACEC: Lower Bruneau Canyon ACEC (small boundary)

Nominated by: The Lower Bruneau Canyon ACEC was nominated by BLM in accordance with 

BLM Manual 1613, Areas of Critical Environmental Concern, Section .21A.2.b. 

Location: The nominated ACEC would encompass 900 acres of BLM-managed land. The 

ACEC would be located along the east side of the Bruneau River Canyon, 

southeast of Indian Bathtub. The small ACEC boundary does not include areas 

contained within the Bruneau-Jarbidge Rivers Wilderness and the designated 

Wild and Scenic River (WSR) corridor.
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-304

Table M-17. Relevance Evaluation for the Lower Bruneau Canyon ACEC Small Boundary 

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The historic value within the small boundary of the nominated ACEC is the same as that 

documented for the large boundary of the nominated Lower Bruneau Canyon ACEC. No

Cultural Value

The cultural value within the small boundary of the nominated ACEC is the same as that 

documented for the large boundary of the nominated Lower Bruneau Canyon ACEC. No

Scenic Value

The scenic value within the small boundary of the nominated ACEC is the same as that 

documented for the large boundary of the nominated Lower Bruneau Canyon ACEC. No

Fish or Wildlife Resource

Bruneau hot springsnail: Thermal seeps and springs which support the Bruneau hot springsnail 

would no longer be within the small boundary of the ACEC; however, they are within the 

Bruneau-Jarbidge Rivers Wilderness boundary and the designated WSR corridor.

No

Other wildlife: The other wildlife within the small boundary of the nominated ACEC are the 

same as those documented for the large boundary of the nominated Lower Bruneau Canyon 

ACEC.

Yes

Natural System or Process

Special status plant assemblages: The special status plants within the small boundary of the 

nominated ACEC are the same as those documented for the large boundary of the nominated 

Lower Bruneau Canyon ACEC; however, Bruneau River phlox would no longer occur within the 

ACEC since canyon walls where this species occurs are within the Bruneau-Jarbidge Rivers 

Wilderness boundary.

Yes

Paleontological resources: The paleontological resources within the small boundary of the 

nominated ACEC are the same as those documented for the large boundary of the nominated 

Lower Bruneau Canyon ACEC.

Yes
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-305

Thermal springs and seeps: Thermal springs and seeps are not present within the small 

boundary of the nominated ACEC; however, they are within the Bruneau-Jarbidge Rivers 

Wilderness boundary and the designated WSR corridor.

No

Natural Hazard

No known significant hazards. No

Table M-18. Importance Evaluation for the Lower Bruneau Canyon ACEC Small Boundary

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA

Historic Values

NA NA 

Cultural Values

NA NA 

Scenic Values

NA NA

Fish or Wildlife Resource

Bruneau hot springsnail: NA NA 

Other wildlife: The importance of other wildlife within the small boundary of the nominated 

ACEC is the same as that documented for the large boundary of the nominated Lower Bruneau 

Canyon ACEC.

No

Natural System or Process

Special status plant assemblages: (Factors met: 1, 2) The importance of special status plants 

within the small boundary of the nominated ACEC is the same as that documented for the large 

boundary of the nominated Lower Bruneau Canyon ACEC; however, Bruneau River phlox 

would no longer occur within the ACEC since canyon walls where this species occurs are 

within the Bruneau-Jarbidge Rivers Wilderness boundary.

Yes

Paleontological resources: (Factors met: 1, 2) The importance of paleontological resources 

within the small boundary of the nominated ACEC is the same as that documented for the large 

boundary of the nominated Lower Bruneau Canyon ACEC

Yes

Thermal springs and seeps: NA NA

Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Lower Bruneau Canyon ACEC for designation under 

Alternative VI (Proposed RMP) as an ACEC is as follows:

The small boundary of the nominated ACEC meets relevance and importance criteria for natural 

processes or systems (special status plants assemblages and paleontological resources).

Threats to the relevant and important values within the small boundary of the nominated ACEC are the 

same as those documented for the large boundary of the Lower Bruneau Canyon ACEC.
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-306

•

•

•

•

•

•

•

•

The natural systems or processes (special status plants assemblages and paleontological resources) of 

the ACEC would be protected through the same allocations and management actions as described for 

the large boundary of the Lower Bruneau Canyon ACEC.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The natural systems or processes (special status plants assemblages and paleontological resources) of 

the ACEC would be protected through the following allocations and management actions:

Restore native upland plant communities within the ACEC to improve habitat for special status 

species. 

The ACEC would be a high priority for noxious weeds and invasive plants treatment with integrated 

weed management techniques for control, containment, and, where practical, eradication. 

 The ACEC would be a critical suppression area.

Manage the ACEC as Visual Resource Management Class III.

No surface-disturbing activities would be allowed in the ACEC unless they are directly related to 

restoration.

New infrastructure may be considered if it would not impair the relevant and important values of the 

ACEC. Any infrastructure would be located so that it does not increase or encourage impacts to fossil 

bearing areas and special status plants.

 Lands within the ACEC would be in Land Tenure Zone 1. 

 The ACEC would be closed to exploration and development of leasable or salable minerals to protect 

vertebrate and invertebrate fossils.
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-307

Middle Snake Area of Critical Environmental Concern

Nominated ACEC: Middle Snake ACEC 

Nominated by: The Middle Snake ACEC was nominated by BLM in accordance with BLM 

Manual 1613, Areas of Critical Environmental Concern, Section .21A.2.b.; the 

Idaho Conservation Data Center suggested BLM consider special management 

for the special status plants in the area.

Location: The nominated ACEC would encompass 7,000 acres of BLM-managed lands; 

these lands are separated in several areas by blocks of private land. The 

nominated ACEC would be located from an area southeast of King Hill to the 

Hagerman Fossil Beds National Monument. The nominated ACEC would extend 

from the Jarbidge planning area boundary in the Snake River to the canyon rim 

or to existing fences on the adjacent uplands.

Table M-19. Relevance Evaluation for the Middle Snake ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The nominated ACEC contains 180 acres within the Oregon National Historic Trail (NHT) 

protective zone near Pilgrim Gulch. Yes

Cultural Value

Several archaeological sites that may be eligible for the National Register of Historic Places are 

located within the nominated ACEC. In addition to their scientific value, these sites are of 

traditional cultural importance to the tribes.

Yes
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

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A-308

Scenic Value

The breaks from the upland plateau down to the floodplain offer some topographic relief of 

scenic value; scenic values can be seen from a major transportation route (Interstate 84). A 

section of the area between Lower Salmon Dam and Bliss Bridge contains several large 

freshwater springs. Rapids in the somewhat confined canyon increase the scenic quality in 

areas. 

Yes

Fish or Wildlife Resource

Snake River snails: A portion of the global population of the Snake River physa (Endangered, 

Type 1 BLM Sensitive) and the majority of the global population of the Bliss Rapids snail 

(Threatened, Type 1) reside in the Snake River within the nominated ACEC. Both snails are 

primarily in the eastern portion of the nominated ACEC. Other special status mollusks found in 

the Snake River within the nominated ACEC include the California floater (Type 3), Columbia 

pebblesnail (Type 3), short-face lanx (Type 2), and Utah valvata snail (Type 2). 

Yes

White sturgeon: About 11 miles of the Snake River flow through the nominated ACEC; 

however, only the portions downstream from the Bliss Dam are free-flowing (Bliss Dam lies 

roughly at the midpoint). White sturgeon, a Type 2 BLM Sensitive species, is present in this 

free-flowing reach of the Snake River. While the habitat is not the best within the range of white 

sturgeon, this segment contains the best habitat in the upper Snake River. Because of the freeflowing nature of this reach, sturgeon are able to reproduce naturally and do not require 

hatchery supplementation to sustain the population; this is the upper-most reach of the Snake 

River with a self-sustaining population of sturgeon. 

Yes

Other wildlife: Tens of thousands of waterfowl winter in this portion of the Snake River including 

mallard, widgeon, ring-neck duck, scaup, American coot, and Canada geese. These waterfowl 

are typically more concentrated along river reaches with slower moving water. Islands in the 

Snake River are occasionally used by white pelicans. Scattered areas along this reach of the 

Snake River provide habitat for wintering bald eagles, which were delisted in 2007.

The uplands within the nominated ACEC provide nesting habitat for BLM Sensitive species, 

including burrowing owl, golden eagle, long-billed curlew, and prairie falcon (Type 3). Cliffs 

within the nominated ACEC provide habitat for a variety of bat species, including several that 

are special status species (spotted bat [Type 3] and Townsend’s big-eared bat [Type 3]). 

Western toad, a Type 3 BLM Sensitive species, is present in several areas within the 

nominated ACEC boundary.

Yes

Natural System or Process

Special status plants assemblages: Several BLM Sensitive plant species occur within the 

nominated ACEC, including calcareous buckwheat (Type 3), Greeley’s wave-wing (Type 3), 

Janish penstemon (Type 3), matted cowpie buckwheat (Type 4), and Snake River milkvetch 

(Type 4). A few other plant species (e.g., desert dandelion and Torrey’s blazingstar) formerly 

on the Idaho BLM Sensitive species list are also present in the nominated ACEC. 

Yes

Natural Hazard

Several scars have been left by old landslides. The most recent large landslide was in 1993 on 

the north bank of the Snake River near Bliss, across the river from the nominated ACEC. That 

landslide temporarily blocked the Snake River.

Yes
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

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A-309

Table M-20. Importance Evaluation for the Middle Snake ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA

Historic Value

While the nominated ACEC does contain 180 acres within the Oregon NHT protective zone the 

small area is not considered nationally or regionally significant. No

Cultural Value

The cultural resources within the nominated ACEC are significant but generally not rare or 

unique for the region. No

Scenic Value

The scenic values are not unique or of more than local significance. Scenic values are mixed 

and are not outstanding. No

Fish or Wildlife Resource

Snake River snails: (Factors 1, 2) The nominated ACEC contains a portion of the global 

population of Snake River physa snail (Endangered, Type 1) and the majority of the global 

population of Bliss Rapids snail (Threatened, Type 1). This reach of the Snake River was 

identified in the Snake River Aquatic Species Recovery Plan as the recovery area for these 

species (FWS, 1995). A number of other special status mollusks are found in the Snake River 

in this area including California floater (Type 3), Columbia pebblesnail (Type 3), short-face lanx 

(Type 2), and Utah valvata snail (Type 2). According to information in the Idaho 

Comprehensive Wildlife Conservation Strategy (IDFG, 2005), the majority of the known Idaho 

distribution for these species is within the reach of the Snake River between Hagerman 

downstream to King Hill.

Yes

White sturgeon: (Factors 1, 2) The nominated ACEC covers the majority of spawning habitat 

for white sturgeon (Type 2) within the planning area. Because of the free-flowing nature of 

areas downstream of the Bliss Dam, sturgeon are able to reproduce naturally and do not 

require hatchery supplementation to sustain the population; this is the upper-most reach of 

Snake River with a self-sustaining population of sturgeon.

Yes

Other wildlife: Other wildlife values are not more than locally significant. Several special status 

species are present; however, due to the relatively small size of the area and the wide 

distribution of those species, the populations within the ACEC are not of more than local 

interest. The only western toad (Type 3) breeding habitat known in the planning area is within 

the nominated ACEC; however, western toad are generally widespread and are more abundant 

in other locations in Idaho.

No

Natural System or Process

Special status plants assemblages: (Factors met: 1, 2) The Snake River breaks in this area 

contain a mixture of soils. Slopes exceed 20% in more than 30% of the nominated ACEC, and 

the wind erosion hazards for the soils are generally rated as severe to very severe; water 

erosion hazards are generally rated medium. The mix of old lake bed sediments and volcanic 

soils provides habitat for a number of special status plant species including: calcareous 

buckwheat (Type 3), Greeley’s wave-wing (Type 3), Janish penstemon (Type 3), matted 

cowpie buckwheat (Type 4), and Snake River milkvetch (Type 4). Torrey’s blazingstar and 

several other former BLM Sensitive plant species are also present in the nominated ACEC. 

Yes

Natural Hazard

Landslides or slumps do not occur frequently and are not a significant threat to humans. No
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-310

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Middle Snake ACEC for designation (under 

Alternatives I and V) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for its fish resources (Snake River snails, 

white sturgeon) and natural systems or processes (special status plant assemblages). 

Existing and potential threats to the relevant and important values of the nominated ACEC include 

noxious weeds and invasive plants, wildland fires, mineral exploration and development, cross-country 

motorized vehicle use and other recreational uses, and livestock grazing. 

Noxious weeds and invasive plants threaten the habitat for the special status plants and wildlife within the 

nominated ACEC. Many of the upland areas have been invaded by non-native annual species. Noxious 

weeds (e.g., Russian knapweed, puncture vine, Scotch thistle, and Canada thistle) are present and 

increasing in the nominated ACEC. Purple loosestrife, Russian olive, and tamarisk are present and 

scattered along the Snake River riparian zone. The threat of noxious weeds and invasive plants is directly 

related to the other threats to the nominated ACEC, as they all contribute to the introduction and spread 

of these species.

Wildland fire threatens the relevant and important values of the nominated ACEC from the fire itself as 

well as activities associated with wildland fire suppression. Wildland fires have adversely impacted some 

of the habitat for Janish penstemon, Greeley’s wave-wing, and calcareous buckwheat. Matted cowpie 

buckwheat is known to be intolerant of fire. Following wildland fires, cheatgrass usually dominates the 

burned areas, reduces or prohibits the recovery of these Sensitive plant species, and promotes future 

wildland fires. The lack of vegetation following fire, as well as disturbance areas created by wildland fire 

suppression activities, can lead to increased sedimentation into the Snake River, adversely affecting 

habitat for special status species that reside there.

Within the nominated ACEC, there are two active mining claims. Activities associated with mineral 

exploration and development can increase sedimentation into the Snake River, adversely affecting 

special status fish and aquatic invertebrates and their habitat.

Cross-country motorized vehicle use and other recreational uses threaten the relevant and important 

values of the nominated ACEC. Cross-country motorized vehicle use throughout the nominated ACEC 

has impacted habitat for some of the BLM Sensitive species. Several areas along the Snake River within 

the nominated ACEC also receive a high amount of use by fishermen. Fishermen have created new 

routes to access additional locations and to avoid areas where the main access has become powdered or 

rutted. Water erosion further increases the depth of the ruts created by motorized vehicles; these 

disturbance areas are typically invaded by cheatgrass. Erosion due to cross-country motorized vehicle 

use can also increase sedimentation into the Snake River, adversely affecting special status fish and 

aquatic invertebrates and their habitat. Cross-country motorized vehicle use and unattended campfires 

increase the chance of wildland fire; both of these activities occur within the nominated ACEC. 

Livestock grazing also presents a threat to the relevant and important values of the nominated ACEC. 

Trailing of livestock in areas rated as severe for soil erosion is affecting Sensitive plant species habitat as 

well as riparian and aquatic resources. Disturbance areas where livestock have concentrated have 

increased soil erosion and promoted the spread of invasive plants and noxious weeds. 

Two segments of the Snake River within the ACEC have been inventoried as eligible for inclusion in the 

National Wild and Scenic River System. Outstandingly Remarkable Values (ORVs) for the Hagerman 

Reach include fish, geological, historical, recreational, and wildlife values; ORVs for the King Hill Reach 

include fish, geological, recreational, and wildlife values. Interim management of these segments requires 

that they be managed to maintain or enhance their ORVs. However, the Wild and Scenic River corridor 

only extends 0.25 mile above the high water mark on each side of the river, which does not provide any 

protection for these values outside this corridor.
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-311

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The fish resources (Snake River snails and white sturgeon) and natural systems or processes (special 

status plants assemblages) of the ACEC would be protected through the following allocations and 

management actions:

Under Alternatives I and V:

Restore habitat for special status plants within the ACEC. Maintain existing high-quality special status 

plant habitat.

Where habitat is suitable, transplant or seed special status plants within the ACEC.

The ACEC would be a high priority for noxious weeds and invasive plants treatment with integrated 

weed management techniques for control, containment, and where practical eradication. Special 

conditions would apply in habitat occupied by special status plant species.

 The ACEC would be a critical suppression area.

Mitigate the effects of surface-disturbing activities in the ACEC, such as recreation and transportation.

Implement use restrictions within the ACEC in areas with slopes greater than 20%, or in areas where 

soils are rated severe or very severe for wind erosion or high for water erosion.

Manage the ACEC as Visual Resource Management Class III.

Livestock trailing through the ACEC would be allowed in the designated trailing corridor, but livestock 

would not be allowed to remain in the ACEC overnight.

Monitor recreational use within the ACEC. If this use reaches levels that impair the relevant and 

important values of the ACEC, implement protective measures appropriate to the type of recreational 

activity. Protective measures may include, but not be limited to, improving access routes to 

recreational sites along the Snake River, installing barriers to protect relevant and important values, 

and implementing measures to address water quality and public health concerns.

BLM-managed lands within the ACEC can be exchanged for non-BLM-managed lands, consistent 

with the Land Tenure section of Chapter 2, in order to obtain lands with relevant and important values 

or to improve management. Where practical, acquire private or State inholdings. The ACEC 

designation and management would apply to lands acquired within the ACEC boundary.

 The ACEC would be closed to mineral leasing.

Recommend lands within the ACEC for withdrawal from mining laws for locatable exploration and 

development. 

Under Alternative I only, specific to livestock grazing management and salable mineral development:

The Asquena pasture within the ACEC would be available for livestock grazing; the remainder of the 

ACEC would not be available for livestock grazing.

 The ACEC would be closed to new salable mineral development and expansion of existing 

developments.

Under Alternative V only, specific to livestock grazing management and salable mineral development:

The ACEC would not be available for livestock grazing. 

 The ACEC would be closed to salable mineral development.
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-312

Sagebrush Sea Area of Critical Environmental Concern 

Nominated ACEC: Sagebrush Sea ACEC 

Nominated by: The Sagebrush Sea ACEC was nominated by Western Watersheds Project. 

Location: The Sagebrush Sea ACEC would encompass 956,000 acres of BLM-managed 

land. The nominated ACEC would occupy roughly the southern 2/3 of the 

planning area. It would extend from the Bruneau River on the west to Salmon 

Falls Creek on the east. Its southern boundary would follow the southern 

boundary of the Jarbidge planning area. The northern boundary would follow the 

road that runs from Balanced Rock to Crows Nest to Clover Crossing, then follow 

Clover Creek along its east and north canyon rims to Clover Creek’s confluence 

with the Bruneau River. 

The nominated ACEC contains areas within two existing ACECs (Salmon Falls 

Creek and Bruneau-Jarbidge), as well as other nominated ACECs (BruneauJarbidge [expanded and reduced], Inside Desert [large and small boundaries], 

Jarbidge Foothills [large and small boundaries], Salmon Falls Creek [expanded], 

and Upper Bruneau Canyon). The analysis below notes whether the relevant and 

important values within the nominated Sagebrush Sea ACEC are also within 

another existing or nominated ACEC.
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-313

Table M-21. Relevance Evaluation for the Sagebruch Sea ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

Historic resources within the nominated ACEC are primarily related to the early livestock 

industry and include sheep camps, cairns, rock corrals, rock fences, and the remnants of failed 

homesteads. The Toana Freight Road, a freight and stage route that serviced Idaho mining 

communities between 1870 and 1883, runs through the eastern portion of the nominated 

ACEC. Based on its importance in the early settlement and development of Idaho Territory, the 

Toana Freight Road is listed on the National Register of Historic Places.

Yes

Cultural Value

Due to its size, the area contains numerous archaeological sites. Many sites have traditional 

cultural relevance to the tribes and are also important for their scientific value. The nominated 

ACEC contains 612,000 acres of high density cultural resources, which represents 91% of the 

high density cultural resources in the planning area. 

Yes

Scenic Value

The area contains a variety of scenic landscapes including deep, rugged canyons, uplifted 

cliffs, several streams with riparian zones, and a variety of plant communities. Yes

Fish or Wildlife Resource

Bull trout: The nominated ACEC contains 70 miles of bull trout (Threatened, Type 1) critical 

habitat, which represents 79% of the critical habitat within the planning area. The Jarbidge 

River Distinct Population Segment is the southern-most surviving population of bull trout in 

North America (FWS, 2004), occurring in a portion of southern Idaho and northern Nevada, and 

is isolated from other bull trout populations by numerous dams. Within the planning area, this 

population segment is found in the Jarbidge River and its East Fork and Dave and Jack 

Creeks. Bull trout in this area are unique in their arid environmental setting.

Yes

Redband trout: The nominated ACEC contains 201 miles of redband trout (Type 2 BLM 

Sensitive species) streams, which represents 80% of the redband trout streams within the 

planning area. These include perennial streams in the Jarbidge Foothills and most of the 

perennial streams in the Jarbidge River and Salmon Falls Creek Watersheds.

Yes

Columbia spotted frog: The area contains all known occupied habitat for spotted frog 

(Candidate, Type 1 and NV BLM Sensitive species) within the planning area. Yes

Greater sage-grouse: The nominated ACEC would contain the vast majority of the active sagegrouse leks and their nesting and winter habitat. The nominated ACEC would contain 302,000 

acres of key sage-grouse habitat, which represents 97% of the key sage-grouse habitat within 

the planning area. There are currently 87 occupied sage-grouse leks, associated satellite leks, 

and sage-grouse nesting habitat present within the nominated ACEC. Sage-grouse are a 

Candidate, Type 1 BLM Sensitive species; both resident and migratory sage-grouse are 

present in the area.

Yes

California bighorn sheep: The nominated ACEC would encompass all habitat used by bighorn 

sheep, a Type 3 BLM Sensitive species; bighorn sheep are concentrated in the Bruneau and 

Jarbidge Canyons. The bighorn sheep population within the ACEC is estimated to be 

approximately 210 sheep. The Foundation for North American Wild Sheep and the Idaho 

Department of Fish and Game (IDFG) were instrumental in re-introducing bighorn into the 

Bruneau and Jarbidge Canyons in the 1980s and early 1990s. The canyon lands provide 

secure lambing habitat. The rivers in the canyon bottoms, as well as occasional seeps from 

canyon walls, provide water. Bighorn sheep forage is available in both the canyons and 

adjacent uplands. The vast majority of bighorn sheep observations are within the canyon and 

on the upland plateau up to about 1 mile from the canyon rim. Bighorn sheep typically avoid 

human disturbance and can be socially displaced in the short term from otherwise suitable 

habitat when livestock are present (Bissonette and Steinkamp, 1996). 

Yes
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

A-314

Other special status wildlife: The nominated ACEC would contain the vast majority of nesting 

habitat for Brewer’s sparrow (Type 3 and NV BLM Sensitive species), sharp-tailed grouse 

(Type 3 and NV), ferruginous hawk (Type 3), Lewis woodpecker (Type 3 and NV), loggerhead 

shrike (Type 3 and NV), mountain quail (Type 3 and NV), northern goshawk (Type 3 and NV), 

prairie falcon (Type 4 and NV), sage sparrow (Type 3), and willow flycatcher (Type 3). Kit fox, a 

Type 4 BLM Sensitive species, have been sighted in a portion of the nominated ACEC 

(Rudeen, 2006). The majority of the habitat for spotted bat (Type 3 and NV), Townsend’s bigeared bat (Type 3 and NV), and other bat species occurs in various river canyons within the 

nominated ACEC. The extent of Piute (Great Basin) ground squirrel (Type 3) distribution in the 

area is unknown. The nominated area contains all recently documented pygmy rabbit habitat 

(Type 2 and NV). 

Yes

Other fish and wildlife: The area would encompass 861,000 acres of elk, mule deer, and 

pronghorn winter range, more than 95% of the big game winter range within the planning area, 

as well as the important transitional, fawning, calving, and summer range for big game. Some 

of the elk, mule deer, and pronghorn are part of migratory herds that winter in Idaho and move 

back to Nevada in the late spring through fall.

The Jarbidge River contains a natural diversity of native fish species. Compared to other rivers 

in the region, the proportion of native to non-native species is unusually high, as there are few, 

if any, non-native species present. This is a unique characteristic for the fish populations in the 

Jarbidge River Watershed. However, stocked rainbow trout are present in Cedar Creek, 

Salmon Falls Creek, and an unnamed tributary, and brook trout, a non-native fish, have been 

found in Cedar and Flat Creeks.

Yes

Natural System or Process

Slickspot peppergrass: The nominated ACEC would cover all known occupied habitat for 

slickspot peppergrass in the planning area. Slickspot peppergrass is a rare, annual or biennial 

forb endemic to sagebrush steppe in southwestern Idaho (Moseley, 1994). Slickspot 

peppergrass is a Type 1 BLM Sensitive species that has been Proposed for listing as 

Endangered under the Endangered Species Act (ESA). The nominated ACEC contains 

patches of high quality slickspot peppergrass habitat, which is characterized by intact 

sagebrush steppe, low abundance of non-native species, and low levels of human-caused 

disturbances (Colket, 2006; FWS, 2003; Moseley, 1994). 

Yes

Davis peppergrass: The nominated ACEC would cover all known occupied habitat for Davis 

peppergrass in the planning area. Davis peppergrass, a Type 3 and NV BLM Sensitive species, 

is present in playas within the nominated ACEC; the population of Davis peppergrass is 

declining range wide. Davis peppergrass is a fleshy, perennial native mustard (forb) adapted to 

grow in seasonally flooded areas. The species is restricted to a narrow suite of environmental 

conditions, occurring in playas on volcanic plains where the regional vegetation is dominated 

by big sagebrush and, to a lesser extent, shadscale. Playas are naturally flat-bottomed basins 

where water from the adjacent uplands transports silt, clay, and minerals. Playas supporting 

Davis peppergrass have a hard clay bottom and are inundated with water during springs with 

average or above average precipitation; some water may also collect during summer 

thunderstorms. Playas typically dry out in the summer, becoming hard. Davis peppergrass 

plants show distinct differences in leaf size, shape, and plant phenology between playas. This 

suggests the species disperses poorly, probably not beyond individual playas, and there is 

minimal pollination between neighboring playas (Moseley, 1996). 

Yes

Bruneau River phlox: The nominated ACEC would contain 250 acres of Bruneau River phlox 

habitat (Type 3 BLM Sensitive species), which represents 68% of the Bruneau River phlox 

habitat within the planning area.

Yes
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

Critical Environmental Concern

A-315

Special status plant assemblages: A few areas within the nominated ACEC contain other plant 

species classified as BLM Sensitive or Watch species including broadleaf fleabane ( NV), 

Cusick’s primrose (Type 5 and NV), earth lichen (Type 4), four-wing milkvetch (Type 4), 

Newberry’s milkvetch (Type 4), Simpson’s hedgehog cactus (Type 4), two-headed onion (Type 

4), and white-margined wax plant (Type 4). The population of Cusick’s primrose (Type 5 and 

NV) within nominated ACEC is in Nevada. While this species is found elsewhere in Idaho and 

Oregon; it is the only population of Cusick’s primrose in the planning area and the only 

population of this species in Nevada. 

Yes

Upland vegetation: Only 39% of the nominated ACEC has not burned in the last 25 years. The 

Native Grassland Vegetation Sub-Group (VSG) comprises 37% of the vegetation within the 

nominated ACEC (355,000 acres). The Native Shrubland VSG comprises 31% of the 

vegetation within the nominated ACEC (298,000 acres). The Non-Native Perennial VSG 

comprises 18% of the vegetation within the nominated ACEC (172,000 acres), the majority of 

which is within the crested wheatgrass community. The Non-Native Understory VSG comprises 

another 6% of the vegetation within the nominated ACEC (56,000 acres); this VSG is 

dominated by the Wyoming big sagebrush/crested wheatgrass community. The Unvegetated 

VSG covers 5% of the nominated ACEC (44,000 acres). Vegetation communities within the 

Annual VSG are present on nearly 3% of the nominated ACEC (25,000 acres).

Yes

Riparian systems: The Bruneau and Jarbidge Rivers have not been dammed, allowing natural 

processes to operate in that watershed. However, there are dams on Cedar and Salmon Falls 

Creeks and smaller irrigation diversions on a majority of the smaller creeks within the 

nominated ACEC that can be a barrier to fish movements; these diversions can also lead to 

dewatering of these streams.

Yes

Natural Hazard

No known significant hazards. No

Table M-22. Importance Evaluation for the Sagebruch Sea ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, 

irreplaceable, exemplary, unique, endangered, threatened, or vulnerable to 

adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management 

concerns about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, No, 

or NA 

Historic Value

Most of the historic resources in the nominated ACEC are similar to resources in the 

surrounding areas. Their significance is primarily local. An exception is the regionally 

significant Toana Freight Road, which occupies only a very small portion of the entire area.

No

Cultural Value

(Factors met: 1, 2) Numerous regionally significant archaeological sites are present but their 

distribution is not uniform. In general, the canyons and foothill areas of the nominated ACEC 

contain the highest density of cultural resources.

The nominated Sagebrush Sea ACEC encompasses the existing and two nominated 

boundaries of the Bruneau-Jarbidge ACEC, both boundaries of the nominated Jarbidge 

Foothills ACEC, and the Upper Bruneau Canyon ACEC, all of which have cultural values that 

meet relevance and importance criteria.

Yes
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Scenic Value

Other than the canyons, the scenic values are not more than of local significance. Although 

scenic values are unique in some areas (Bruneau, Jarbidge, and Salmon Falls Creek 

Canyons), in the majority of the area, scenic values are not regionally unique or significant. 

The nominated Sagebrush Sea ACEC encompasses the existing and two nominated 

boundaries of the Bruneau-Jarbidge ACEC, the Salmon Falls Creek ACEC, and the Upper 

Bruneau Canyon ACEC, all of which have scenic values that meet relevance and importance 

criteria.

No

Fish or Wildlife Resource

Bull trout: (Factors met: 1, 2, 3) The Jarbidge River contains the southernmost population of 

bull trout in North America (FWS, 2004). Bull trout are the only fish within the planning area 

listed as Threatened under the ESA and are a Type 1 BLM Sensitive species. Genetic 

analysis of bull trout in the Columbia River Basin indicates Jarbidge River bull trout have a 

shared evolutionary history with populations in the upper Columbia River and Snake River but 

are genetically separated. For more than 100 years, Jarbidge River bull trout have been 

geographically isolated from other populations in the Snake River by more than 150 miles of 

unsuitable habitat and several impassable hydroelectric dams on the Snake River and lower 

Bruneau River. Bull trout in the Jarbidge River are considered significant because they 

occupy a unique and unusual ecological setting and their loss would result in a substantial 

modification of the species’ range. The bull trout in the Jarbidge River are unique in that a 

portion of their habitat is in an area categorized as semi-arid desert. The nominated ACEC 

has both spawning and migratory habitat for bull trout. Dave Creek is believed to be a crucial 

spawning area for bull trout within the watershed of the East Fork of the Jarbidge River. 

Bull trout also meet relevance and importance criteria in the existing and two nominated 

boundaries of the Bruneau-Jarbidge ACEC, all of which are encompassed by the nominated 

Sagebrush Sea ACEC.

Yes

Redband trout: (Factors met: 1, 2) Redband trout are Type 2 BLM Sensitive species occurring 

in perennial streams in the Jarbidge Foothills and in most of the perennial streams in the 

Jarbidge River and Salmon Falls Creek Watersheds. The nominated ACEC contains 201 

miles of redband trout streams, which represents 80% of the redband trout streams within the 

planning area. Redband trout in the Jarbidge Foothills exist in isolated populations or 

“strongholds” that are unable to migrate to adjacent suitable habitats when threatened by low 

streamflow conditions or other environmental disturbance such as wildfire. Due to the lack of 

connectivity between the redband trout occupied streams, these fish are vulnerable to 

population declines. Recent studies of redband trout populations in drainages similar to those 

found in the Jarbidge Foothills suggest that redband trout are declining in their lower elevation 

habitats (Zoellick et al., 2005). Redband trout in the Jarbidge River Watershed are less 

isolated than those in the Jarbidge Foothills and can freely migrate between suitable stream 

habitats throughout the Jarbidge and Bruneau River Watersheds. 

Redband trout also meet relevance and importance criteria in the existing and two nominated 

boundaries of the Bruneau-Jarbidge ACEC, the large boundary of the nominated Jarbidge 

Foothills ACEC, the existing Salmon Falls Creek ACEC, and the Upper Bruneau Canyon 

ACEC, all of which are encompassed by the nominated Sagebrush Sea ACEC.

Yes

Columbia spotted frog: (Factors met: 2, 3) Spotted frog populations are part of a larger, but 

fragmented, population of spotted frogs in northern Nevada. The Great Basin population of 

spotted frog is of national significance. Great Basin Columbia spotted frog populations 

continue to decline in portions of Nevada. Spotted frogs have been observed along 5 miles of 

streams; the majority of observations have occurred along Shack and Rocky Canyon Creeks. 

Potentially suitable habitat occurs in several other drainages (China, Cedar, Flat, and House 

Creeks) within the nominated ACEC. 

Spotted frogs also meet relevance and importance criteria in the large boundary of the 

nominated Jarbidge Foothills ACEC, which is encompassed by the nominated Sagebrush 

Yes
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Sea ACEC.

Greater sage-grouse: (Factors met: 1, 2, 3) Sage-grouse (Candidate, Type 1 BLM Sensitive 

species) are present in much of the area in sagebrush with suitable habitat, and the 

nominated ACEC contains more than 90% of the occupied sage-grouse leks within the 

planning area. Locally, sage-grouse are a mix of resident and migratory forms. Although there 

is some information on the movements of sage-grouse in the western portion of the area, 

sage-grouse movements and habitat use in the southeastern part (Browns Bench) of the area 

are better documented. Sage-grouse in this area have been documented to move more than

10 miles into northern Nevada and 15 miles east to the Shoshone Basin. Radio-collared 

sage-grouse in the Shoshone Basin have been documented to winter in the Browns 

Bench/Monument Springs/China Mountain areas. Sage-grouse in this area provide 

connectivity to sage-grouse regionally. The Browns Bench/China Mountain area is presently a 

stronghold or key area for sage-grouse.

Sage-grouse also meet relevance and importance criteria in both boundaries of the 

nominated Jarbidge Foothills ACEC, both of which are encompassed by the nominated 

Sagebrush Sea ACEC.

Yes

California bighorn sheep: (Factors met: 1, 2) Bighorn sheep, a Type 3 BLM Sensitive species, 

are concentrated in the Bruneau and Jarbidge Canyons. Bighorn sheep are scattered in small 

herds across parts of Oregon, Idaho, Nevada, and British Columbia. In Idaho, bighorn sheep 

populations in the South Hills and Jim Sage Mountains are smaller than in the 

Bruneau/Jarbidge River area. The population in the Owyhee River is larger than the 

Bruneau/Jarbidge River population. Bighorn sheep in Idaho are recovering from a population 

crash in the late 1990s. Human disturbance and disease continue to suppress bighorn sheep 

nationwide (Krausman and Bowyer, 2003; Lawson and Johnson, 1982). This population of 

bighorn sheep is of more than local importance, evidenced in part by the fact that bighorn 

sheep tags for hunts in this area are in high demand and attract applicants from across the 

United States. Bighorn sheep habitat in the Bruneau and Jarbidge Canyons accounts for less 

than 10% of the nominated ACEC. The majority of the nominated ACEC is not generally 

suitable for bighorn sheep.

Bighorn sheep also meet relevance and importance criteria in the existing and two nominated 

boundaries of the Bruneau-Jarbidge ACEC, and the Upper Bruneau Canyon ACEC, all of 

which are encompassed by the nominated Sagebrush Sea ACEC.

Yes

Other special status wildlife: Generally, the other special status wildlife within the nominated 

ACEC are not of more than local importance. Mountain shrub and aspen habitats provide 

Columbian sharp-tailed grouse winter habitat. Columbian sharp-tailed grouse (Type 3 BLM 

Sensitive species) in the area provide connectivity to a population in the Shoshone Basin. 

The Columbian sharp-tailed grouse population in the nominated ACEC is small and is 

currently not of more than local importance. 

Mountain quail (Type 3) were historically present within the nominated ACEC. IDFG and BLM 

records suggest that mountain quail have likely been extirpated from the majority of the area. 

Historical records indicate that mountain quail were occasionally harvested in the 1960s and 

1970s from this general area. The last mountain quail documented within the nominated 

ACEC was in the Jarbidge Canyon in 2001.

Habitat within the planning area is limited for Lewis woodpecker (Type 3), northern goshawk 

(Type 3 and NV), and willow flycatcher (Type 3). The limited nesting habitat makes these 

species of only local importance.

Prairie falcons (Type 4), spotted bat (Type 3), and Townsend’s big-eared bat (Type 3 and NV) 

are associated with major canyons but forage well into the uplands. Canyon lands, which are 

used by these species for day roosts, are found only in a small portion of the nominated 

ACEC.

No
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Nesting habitat for Brewer’s sparrow (Type 3 and NV), loggerhead shrike (Type 3 and NV), 

ferruginous hawk (Type 3), and sage sparrow (Type 3) is fairly widespread over the area. 

Songbirds are associated with sagebrush habitats locally and nest wherever suitable habitat 

is present. The majority of active ferruginous hawk nests within the planning area are found 

within the nominated ACEC. These species are of primarily local significance regarding 

connectivity and genetics.

Kit fox (Type 4) in the area have been documented west of Clover Creek, in a small portion of 

the nominated ACEC (Rudeen, 2006). Kit fox are at the northern part of their range in 

southern Idaho. It is not known if kit fox are present east of Clover Creek or the size of their 

population. 

The nominated ACEC covers more than the presently occupied habitat for pygmy rabbit 

(Type 2) within the planning area. Habitat fragmentation, primarily due to wildland fire, has 

contributed to the isolation of pygmy rabbit and Piute ground squirrels (Type 3) locally. 

Other fish and wildlife: The big game winter range values are not unique or of more than local 

importance. While there is high quality big game habitat in a portion of the nominated ACEC 

(e.g., Jarbidge Foothills, Diamond A, and the Jarbidge and Clover Creek Canyons), the high 

quality habitat is present on less than 20% of the area following the 2007 Murphy Complex 

Fires. High quality big game habitat is present south into Nevada and west of the Bruneau 

Canyon.

In addition, the assemblage of fish within the nominated ACEC is not unique or of more than 

local importance. Stocked and non-native fish are present in several major drainages.

No

Natural System or Process

Slickspot peppergrass: (Factors met: 1, 2) Slickspot peppergrass is of more than local 

importance; however, this species is found in only a small portion (<10%) of the area. 

Slickspot peppergrass is a Type 1 BLM Sensitive species that has been Proposed for listing 

as Endangered under the ESA. The nominated ACEC encompasses the known occupied 

habitat of slickspot peppergrass within the planning area and the largest contiguous habitat 

within the range of the species. The Jarbidge population of slickspot peppergrass is the most 

genetically diverse of the known slickspot peppergrass populations.

Slickspot peppergrass is one of the few flowering plant species with two life cycle types: 

annual and biennial. Slickspot peppergrass is highly specific to slickspots that developed on 

remnant Pleistocene surfaces (Fisher et al., 1996). Slickspots, also known as mini-playas or 

natric sites, are small soil inclusions with a silt loam surface crust, a restrictive hardpan, and a 

subsurface clay layer (argillic horizon) (Fisher et al., 1996; Lewis and White, 1964; Sandoval 

et al., 1959). Soils in slickspots tend to be more alkaline or saline than the adjacent uplands. 

Slickspots can range in size from a square foot to interlinked complexes over 900 square feet. 

Slickspots are associated with shrub interspaces in sagebrush steppe and are visually 

distinct, due to their high reflectance and sparsely vegetated surface (Fisher, et al., 1996). 

Physical disturbance of slickspots when they are wet can disrupt underlying soil structure 

essential for slickspot peppergrass recruitment (Meyer et al., 2006). Disturbances include 

livestock hoof prints, drill seeding, fire-fighting activities (e.g., fire lines), and cross-country 

motorized vehicle tracks (Meyer et al., 2005, 2006). Repeated and severe penetrating 

disturbances, especially during saturated soil conditions during the spring, may be precursors 

to slickspot invasion by non-native species (e.g., bur buttercup, clasping-leaf pepperweed), 

further reducing slickspot integrity (FWS, 2003). Degradation of slickspot peppergrass habitat 

has been attributed to large, uncharacteristic wildland fires; conversion of sagebrush steppe 

to non-native annual grasslands; historic livestock grazing levels; and historic fire 

rehabilitation practices (e.g., drill seeding) (Colket, 2005; FWS, 2003; Lesica and DeLuca, 

1996; Moseley, 1994; Noss et al., 1995; Peters and Bunting, 1994; Whisenant, 1990). Habitat 

loss and degradation, fragmentation, and population isolation may correspondingly result in 

the loss of genetic fitness (Moseley, 1994; Reed and Frankham, 2003). Many slickspot 

Yes
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peppergrass element occurrences (EOs) occur in fragmented sagebrush steppe or non-native 

annual grasslands and are highly susceptible to reduced genetic diversity and gene flow 

(Robertson, 2004; Robertson and Klemash, 2003). An EO is a specific geographic location 

where “a species or natural community is, or was, present” (NatureServe, 2002). 

Slickspot peppergrass also meets relevance and importance criteria in both boundaries of the 

nominated Inside Desert ACEC, both of which are encompassed by the nominated 

Sagebrush Sea ACEC.

Davis peppergrass: (Factors met: 1, 2) Davis peppergrass is of more than local importance; 

however, this species is found in only a small portion (<1%) of the area. Davis peppergrass, a 

Type 3 and NV BLM Sensitive species, is limited in its distribution to portions of southeastern 

Oregon, south-central Idaho, and north central Nevada, with the majority of known 

populations occurring in Idaho. There are fewer than 300 populations in six distinct clusters or 

distribution centers. The Bruneau-Jarbidge populations are a population stronghold, whereas 

the Mountain Home populations (outside the planning area) show downward trend due to 

poor ecological condition of the sagebrush steppe ecosystem. The remaining populations 

outside the planning area in Idaho, Oregon, and Nevada are currently stable.

Davis peppergrass also meets relevance and importance criteria in the existing and two 

nominated boundaries of the Bruneau-Jarbidge ACEC, and the Upper Bruneau Canyon 

ACEC, all of which are encompassed by the nominated Sagebrush Sea ACEC.

Yes

Bruneau River phlox: (Factors met: 1, 2) Bruneau River phlox is of more than local 

importance; however, this species is found in only a small portion (<1%) of the area. Bruneau 

River phlox is a Type 3 and NV BLM Sensitive species endemic to the area. All six Idaho 

populations are present in the Bruneau and Jarbidge Canyons; five of these are within the 

nominated ACEC. Two additional populations can be found in Nevada. Bruneau River phlox 

has a total estimated population of 500 plants. The Idaho populations are relatively stable. 

Bruneau River phlox also meets relevance and importance criteria in the existing and two 

nominated boundaries of the Bruneau-Jarbidge ACEC and the nominated Lower Bruneau 

Canyon ACEC; the existing and two nominated boundaries of the Bruneau-Jarbidge ACEC 

are encompassed by the nominated Sagebrush Sea ACEC.

Yes

Special status plant assemblages: Other special status plants occur in the area, but are not of 

more than local importance. No

Upland vegetation: Portions of the nominated ACEC contain examples of late seral and 

potential natural community for a number of range sites. However, the majority of the native 

plant communities have been highly fragmented by wildland fire and previous non-native 

perennial seeding projects. There are other better examples of intact sagebrush steppe 

communities outside of the planning area. Native plant communities within the nominated 

ACEC as well as outside the planning area face similar threats.

The nominated Sagebrush Sea ACEC encompasses both boundaries of the nominated 

Jarbidge Foothills ACEC and the existing Salmon Falls Creek ACEC, all of which have upland 

vegetation values that meet relevance and importance criteria.

No

Riparian systems: Most of the streams within the nominated ACEC have been substantially 

altered through diversions on non-BLM-managed land and are not of more than local 

importance.

The nominated Sagebrush Sea ACEC encompasses the existing and two nominated 

boundaries of the Bruneau-Jarbidge ACEC, and the Upper Bruneau Canyon ACEC, all of 

which have riparian values that meet relevance and importance criteria.

No
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Natural Hazard

NA NA

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Sagebrush Sea ACEC for designation (under 

Alternative V) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for cultural values, fish and wildlife 

resources (bighorn sheep, bull trout, redband trout, sage-grouse, and spotted frog), and natural systems 

or processes (Bruneau River phlox, Davis peppergrass, and slickspot peppergrass). 

Existing and potential threats to the relevant and important values within the nominated ACEC include 

wildland fire, noxious weeds and invasive plants, diversion of streams, and a variety of uses, including 

livestock grazing and energy development. These threats may contribute to the alteration and 

fragmentation of upland and riparian habitats.

Wildland fires are a threat to the relevant and important values in the ACEC, through the effects of the fire 

itself as well as the effects of wildland fire suppression activities. Since the 1970s, wildland fires have 

reduced the amount of sagebrush habitat present in the planning area by roughly two-thirds. Throughout 

the West as well as locally, habitat conversion and fragmentation in part due to wildland fire have 

contributed to declining sage-grouse numbers and the loss of leks (Knick and Connelly, 2011). Wildland

fires and subsequent rehabilitation also has altered habitat in the majority of slickspot peppergrass habitat 

in the planning area. Drill seeding following fires from the 1980s through the 1990s converted large 

portions of slickspot habitat to non-native perennial communities. Soil erosion and deposition following 

wildland fires as well as the construction of fire lines in slickspot habitat are also threats to slickspot 

peppergrass. Davis peppergrass is similarly affected by wildland fire.

Noxious weeds and invasive plants are also a threat to the relevant and important values within the 

ACEC. These species have affected upland habitat for bighorn sheep, Bruneau River phlox, Davis 

peppergrass, sage-grouse, and slickspot peppergrass, as well as riparian habitats for bull trout, redband 

trout, and spotted frog.

Alterations of riparian systems primarily are a threat to bull trout, redband trout, and spotted frog. Wildland 

fires that burn the riparian zone can reduce the amount of large wood and streambank shade and 

increase sediment to the stream, affecting bull trout, which require cold clean water with low amounts of 

sediment in stream gravels for spawning and rearing. Dams and diversions of streams to irrigate private 

land have resulted in the dewatering of portions of some streams, contributing to the fragmentation of 

redband trout habitat. This has reduced the ability of redband trout to move between streams. Threats to 

spotted frog include loss of habitat due to down cutting of streams, lowered water table, habitat 

fragmentation, and sediment from roads on steep gradients. 

Several land uses are potential threats to the relevant and important values within the nominated ACEC. 

Generally, surface-disturbing activities that remove vegetation or create corridors for the introduction and 

spread of noxious weeds and invasive plant species would adversely affect the relevant and important 

values. The physical integrity and the cultural values attached to many archaeological sites are 

threatened by increasing levels of use and development as well, particularly increasing levels of crosscountry motorized vehicle use. Right-of-way (ROW) development, including wind energy, has the 

potential to affect upland and riparian habitats as well as cultural resources due to increased human 

activity and habitat fragmentation and loss. 

Livestock grazing also can adversely affect upland and riparian habitats. Livestock grazing in slickspot 

peppergrass habitat can result in trampling of slickspots and plants when the soils are moist. In some 

instances, range infrastructure can present a threat to slickspot peppergrass through increased trampling 

around water sources and trailing along fences; these actions can also result in the spread of invasive 

plants, further impacting the species. In other cases, properly located fences could help protect 

concentrations of slickspots from the impacts of livestock grazing. Livestock grazing also presents a 
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threat to Davis peppergrass. Livestock trailing/trampling in occupied playas results in seed being buried 

too deep for germination and growth and damages the perennial plants. Stock ponds dug in playas may 

alter the hydrology and contribute to the introduction and spread of invasive plant species. Livestock 

congregating in or near playas also impacts cultural resources associated with playas.

Portions of the nominated Sagebrush Sea ACEC are included in the Bruneau-Jarbidge Rivers Wilderness 

and the Lower Salmon Falls Creek Wilderness Study Area (WSA). Areas within the wilderness would be 

managed consistent with the Wilderness Act and Omnibus Public Lands Management Act (OPLMA) and 

with allocations and management actions made for wilderness. Areas within the WSA would be managed 

according to BLM Manual 6330 - Management of BLM Wilderness Study Areas. 

Designated Wild and Scenci River segments within the ACEC include the Bruneau River from Hot Creek 

to the Bruneau River confluence and the Jarbidge River from the Jarbidge Forks to the Bruneau River 

confluence. Outstandingly Remarkable Values (ORVs) for these segments include cultural, fish, 

geological, recreational, scenic, vegetation, and wildlife. The Bruneau River from Blackrock Crossing to 

0.3 mile above the confluence of the West Fork of the Bruneau River and the Jarbidge River has been 

recommended suitable for designation as a Wild and Scenic River. The ACEC also contains portions of 

river segments inventoried as eligible for inclusion in the National Wild and Scenic River System (ORVs 

included in parentheses): Jarbidge River south of the Jarbidge Forks (scenic, fish), the East Fork of the 

Jarbidge River (fish), Cougar Point Creek (scenic), Dave Creek (fish), Rocky Canyon Creek (wildlife), 

Salmon Falls Creek south of Salmon Falls Reservoir (recreation), and Salmon Falls Creek from Salmon 

Falls Creek Dam to Balanced Rock (geological, recreational, scenic). Interim management of these 

segments requires that they be managed to maintain or enhance their ORVs. 

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The cultural values, fish and wildlife resources (bighorn sheep, bull trout, redband trout, sage-grouse, and 

spotted frog), and natural systems or processes (Bruneau River phlox, Davis peppergrass, and slickspot 

peppergrass) of the ACEC would be protected through the following allocations and management actions:

All actions within the portions of the ACEC that are also within wilderness or WSA must be consistent 

with the Wilderness Act and OPLMA or the Management of Wilderness Study Areas (BLM Manual 

6330) and with allocations and management actions made for wilderness or WSAs. 

Improving, expanding, connecting, and restoring native plant communities through active and passive 

treatments for fuels, noxious weeds, invasive plants, and non-native perennial plant communities 

would be a high priority within the ACEC. 

Implement management actions that improve riparian condition and reduce habitat fragmentation in 

redband trout occupied streams. 

Within nine miles of bighorn sheep habitat, use of domestic sheep or goats would not be allowed to 

eliminate potential contact of domestic sheep or goats with bighorn sheep.

Treatments would include only native plants. Special stipulations would apply for treatments in 

occupied habitat for slickspot peppergrass, such as establishing buffer areas and not allowing aerial 

spraying in occupied habitat.

Restore playas occupied by Davis peppergrass to improve natural hydrologic function and habitat on 

a case-by-case basis. Restoration activities may include filling pit reservoirs, stabilizing erosion areas, 

and planting native species with similar pollinators. 

BLM management activities and authorized uses would result in no net loss of native vegetation; this 

restriction would not apply to fire suppression activities.

Manage the majority of the ACEC as Visual Resource Management (VRM) Class III, where not 

otherwise designated as VRM Class I or II (see the Visual Resources section of Chapter 2).

 The ACEC would be a critical suppression area.

Livestock seasons of use or stocking rates would be adjusted on a pasture-specific basis to minimize 

conflicts with bighorn sheep lambing and sage-grouse breeding and nesting periods and the active 

growing period of native grasses.
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Reduce livestock infrastructure and associated routes to amounts appropriate to ACEC objectives 

and the levels of livestock grazing within the ACEC. Water troughs, corrals or other related livestock 

facilities in reference areas within the ACEC would be removed. Pipelines would remain in the ground 

to minimize disturbance.

Monitor recreational use within the ACEC. If this use reaches levels that impair the relevant and 

important values of the ACEC, implement protective measures appropriate to the type of recreational 

activity. Protective measures may include but not be limited to designating camping areas within the 

ACEC; requiring the use of certified weed-free forage and straw; and installing protective barriers to 

protect relevant and important values.

Travel routes would be designated through the Travel Management Plan to increase core habitat size 

for sage-grouse.

 The ACEC would be a ROW avoidance area; new ROWs would be restricted to ROW corridors and 

locations of existing ROWs.

Lands within the ACEC would be in Land Tenure Zone 1; where practical, private and/or State 

inholdings would be acquired. Lands acquired within the ACEC would become part of the ACEC and 

be managed accordingly. 

The ACEC would be available for salable mineral development. Where practical, use existing mineral 

pits and minimize new salable mineral developments within the ACEC. Seasonal closures that restrict 

use or activities at the pits during important seasonal periods for fish and wildlife may be included 

when existing salable mineral permits are reauthorized and in new permits.

Limit surface disturbing activities within and adjacent to the Bruneau and Jarbidge Rivers, Devil 

Creek, Browns Bench and the Jarbidge Foothills to protect cultural resources; ensure that authorized 

impacts are appropriately mitigated.
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Salmon Falls Creek Area of Critical Environmental Concern

Salmon Falls Creek ACEC is an existing ACEC. The existing ACEC was re-nominated; one alternate 

boundary for the ACEC was nominated as well. The area encompassed by the existing boundary is 

presented first, followed by the area encompassed by the nominated extensions to the existing boundary. 

Existing ACEC

Nominated ACEC: Salmon Falls Creek ACEC (existing ACEC boundary)

Nominated by: The existing ACEC was re-nominated by BLM in accordance with BLM Manual 

1613, Areas of Critical Environmental Concern, Section .21A.1.

The existing ACEC was also re-nominated by Western Watersheds Project. 

Location: The Salmon Falls Creek ACEC encompasses 6,000 acres of BLM-managed 

land. The ACEC is located within the Salmon Falls Creek Canyon (rim to rim), 

extending from Balanced Rock Crossing Park south to the private land near 

Salmon Falls Creek Dam. The Salmon Falls Creek ACEC is located in both the 

Jarbidge and Burley Field Offices; however portions east of Salmon Falls Creek 

are not within the planning area. As a result designation and management of the 

Burley Field Office portion of the ACEC will not be addressed in the Jarbidge 

RMP. While the ACEC encompasses 6,000 acres, only 3,000 acres are within 

the Jarbidge planning area.

The ACEC is contained within the nominated Sagebrush Sea ACEC.
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Table M-23. Relevance Evaluation for the Existing Salmon Falls Creek ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

No significant historic values are associated with the ACEC. No

Cultural Value

Several archaeological sites that may be eligible for the National Register of Historic Places are 

located within the ACEC. In addition to their scientific value, these sites are of traditional 

cultural importance to the tribes.

Yes

Scenic Value

The canyon has impressive scenery. In some areas, basalt lava flows are separated by layers 

of sediment. Other areas of the canyon are dominated by rhyolite columns and spires. A few 

springs on the lower portion of canyon walls provide a contrast with the dominant upland 

vegetation.

Yes
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Fish or Wildlife Resource

Redband trout: Salmon Falls Creek supports a population of redband trout, a Type 2 BLM 

Sensitive species. The ACEC contains 31 stream miles that are occupied by redband trout. Yes

Other wildlife: The canyon supports a variety of BLM Sensitive species, including prairie falcon 

(Type 3), spotted bat (Type 3), and Townsend’s big-eared bat (Type 3). The ACEC also 

includes habitat for a variety of canyon-nesting species, including canyon wren, cliff swallow, 

rock wren, violet-green swallow, and white-throated swift. Waterfowl nest in the lower-gradient 

reaches. Raptors found in the canyon include American kestrel, golden eagle, great horned 

owl, long-eared owl, red-tailed hawk, and western screech owl. Mule deer reside in the canyon 

and on the plateau adjacent to the canyon rim.

Yes

Natural System or Process

Upland vegetation: The canyon has upland plant communities at or near the potential natural 

community, including Wyoming big sagebrush/bluebunch wheatgrass sites and some late seral 

riparian zones. The entire area has been ungrazed since the 1987 Jarbidge RMP was 

completed; the area south of the confluence with Cedar Creek also received no livestock 

grazing prior to 1987 due to natural barriers (e.g., boulder fields, cliffs, talus slopes). The 

upland plant communities have been relatively undisturbed overall.

Yes

Riparian system: Natural streamflow processes have been disrupted by dams on Cedar Creek 

and Salmon Falls Creek on non-BLM-managed lands. Flow alteration has generally eliminated 

flushing flows, enhancing the collection of sediment in portions of the canyon. Invasive plant 

species including reed and reed canary grass are expanding, adversely impacting native 

riparian vegetation.

No

Natural Hazard

No known significant hazards. No

Table M-24. Importance Evaluation for the Existing Salmon Falls Creek ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

NA NA 

Cultural Value

The cultural resources within the ACEC are significant but generally not rare or unique for the 

region. No

Scenic Value

(Factors met: 1, 2) The ACEC contains the easternmost deep canyon in Idaho, making it more 

than locally significant, relatively unique for the south-central portion of the state, and 

irreplaceable. The scenic values of Salmon Falls Creek ACEC are strongly influenced by the 

geology of the area and the high quality of the native vegetation communities.

Yes

Fish or Wildlife Resource

Redband trout: (Factor met: 2) The redband trout population within the ACEC is especially 

fragile, given that it is an isolated population in poor habitat. Natural streamflow processes have 

been disrupted by dams on Cedar Creek and Salmon Falls Creek on non-BLM-managed lands. 

Flow alteration has generally eliminated flushing flows, enhancing the collection of sediment in 

portions of the canyon. The high degree of sedimentation has reduced the quality of habitat for 

Yes
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redband trout. 

Other wildlife: Other wildlife values are not more than locally significant. Big game wintering in 

the area is primarily of local interest, and canyons and adjacent upland plateaus throughout the 

planning area are used by wintering wildlife. Several special status species are present; 

however, due to the relatively small size of the area and the wide distribution of those species, 

the populations within the ACEC are not of more than local interest. The other wildlife that use 

the canyon as habitat are found in other larger canyon systems within the planning area and 

region.

No

Natural System or Process: 

Upland vegetation: (Factor met: 2) The upland vegetation communities within the canyon are 

unique because they are relatively undisturbed and have been relatively unaffected by humans. 

The lands have not been grazed by livestock, and 87% of the ACEC has not burned in the last 

25 years. The only travel route in the ACEC is the paved road at Lilly grade; there are no other 

travel routes within the canyon, and recreational use of the area is low. There are few areas 

within southern Idaho, especially that are close to human population centers, where human 

uses are not the primary forces influencing the vegetation community.

Yes

Riparian system: NA NA 

Natural Hazard

NA NA 

The ACEC meets the relevance and the importance criteria to continue to be considered as an 

ACEC. The rationale for proposing the Salmon Falls Creek ACEC for continued designation (under 

Alternatives I, III, and VI [Proposed RMP]) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for scenic values, fish resources (redband 

trout), and natural systems or processes (upland vegetation). 

Existing and potential threats to the relevant and important values within the ACEC include wildland fire, 

expansion of noxious weeds and invasive plants, mineral exploration and development, livestock grazing, 

and utility corridors. 

Wildland fire is a threat to both the scenic values and the native vegetation communities within the ACEC. 

In the last 25 years, only 400 acres within the ACEC have burned. Wildland fire that adversely impacts

the native upland vegetation also impairs the scenic quality, particularly if the burned area becomes 

dominated by cheatgrass.

Noxious weeds and invasive plants have impacted the quality of the redband trout habitat, as well as the 

upland vegetation communities and the scenic values. Noxious weeds and invasive species known to be 

present include reed, reed canary grass, Russian olive, Canada thistle, bull thistle, and cheatgrass.

Activities related to mineral exploration and development have the potential to threaten the scenic quality 

of the area as well as the native vegetation communities; roads associated with these activities may 

increase sedimentation in redband trout habitat as well. There are currently two active mining claims 

within the ACEC. Gold mining activity on BLM-managed land immediately south of Lilly Grade in the 

1990s caused damage to the area by promoting the invasion of cheatgrass.

Livestock grazing has the potential to threaten the scenic values and native vegetation communities 

within the ACEC as well. The ACEC was closed to livestock grazing in the 1987 Jarbidge RMP. However, 

prior to 1987, the portion of the ACEC north of Cedar Creek was grazed, which contributed to the 

introduction and spread of invasive plants.

Utility corridors threaten the scenic values of the ACEC. Currently, there are few utility lines that cross the 

ACEC north of the Wilderness Study Area (WSA); additional lines would impair the scenic values of the 

canyon.
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The ACEC from Lilly Grade to about 1 mile north of Salmon Falls Creek Dam is within the Lower Salmon 

Falls Creek WSA; these areas would be managed according to BLM Manual 6330 - Management of BLM 

Wilderness Study Areas. 

The segment of Salmon Falls Creek within the ACEC has been inventoried as eligible for inclusion in the 

National Wild and Scenic River System. Outstandingly Remarkable Values (ORVs) for this segment 

include geological, recreational, and scenic values. Interim management of this segment requires that it 

be managed to maintain or enhance its ORVs. 

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The scenic values, fish resources (redband trout), and natural processes or systems (upland vegetation) 

of the ACEC would be protected through the following allocations and management actions:

Allocations and management actions described are for the Jarbidge Field Office only. Under the No Action 

Alternative, the ACEC would be managed as described in the Areas of Critical Environmental Concern section of 

Chapter 2.

All actions within the portion of the ACEC that is also a WSA must be consistent with Management of 

Wilderness Study Areas (BLM Manual 6330) and with allocations and management actions made for 

WSAs. 

Restore vegetation within the riparian area to benefit redband trout habitat (e.g., increasing shade in 

the riparian zone).

Use native species for any vegetation treatments within the ACEC, including for Emergency 

Stabilization and Burned Area Rehabilitation. 

The ACEC would be a high priority for noxious weeds and invasive plants treatment with integrated 

weed management techniques for control, containment, and where practical eradication. 

 The ACEC would be a critical suppression area.

 Minimum Impact Suppression Tactics would be used for wildland fires within the ACEC.

 The ACEC would remain closed to livestock grazing. 

Monitor recreational use within the ACEC. If this use reaches levels that impair the relevant and 

important values of the ACEC, implement protective measures appropriate to the type of recreational 

activity. 

 The ACEC north and south of Lilly Grade crossing would remain closed to motorized vehicle use.

Lands within the ACEC would be in Land Tenure Zone 1. 

 The ACEC would be closed to mineral leasing.

The ACEC would remain closed to salable mineral development.

Under Alternatives I and III only:

Manage the portion of the Jarbidge right-of-way (ROW) corridor within the ACEC as Visual Resource 

Management (VRM) Class III; manage the remainder of the ACEC as VRM Class I. 

The ACEC would remain a ROW avoidance area; new ROWs would be restricted to the Jarbidge 

ROW corridor and locations of existing ROWs.

Recommend lands within the ACEC for withdrawal from mining laws for locatable exploration and 

development.

Under Alternatives VI (Proposed RMP) only:

Manage the portion of the Roseworth ROW corridor within the ACEC as VRM Class III; manage the 

remainder of the ACEC as VRM Class I.

The ACEC would remain a ROW avoidance area; new ROWs would be restricted to the Roseworth 

ROW corridor and locations of existing ROWs. 

Extensions to the Existing ACEC

Nominated ACEC: Extensions to the existing Salmon Falls Creek ACEC
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Nominated by: An area one mile west of the west rim of Salmon Falls Creek Canyon between 

Salmon Falls Creek Dam and the Cedar Creek confluence was nominated by 

BLM to be included in the existing Salmon Falls Creek ACEC; Idaho Department 

of Fish and Game suggested BLM consider special management for mule deer 

wintering in the area.

Western Watersheds Project requested that “future expansion of these areas 

(current ACECs) be considered,” although no specific boundary for expanding 

the existing ACECs was identified.

Location: The nominated extension would encompass 10,000 acres of BLM-managed land. 

The nominated extension would be located along Salmon Falls Creek from the 

Cedar Creek confluence to the private land by Salmon Falls Creek Dam and 

would extend from the west canyon rim to one mile to the west.

The nominated extension is contained within the nominated Sagebrush Sea 

ACEC.
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The analysis documented below assessed whether the extension contributed to relevant and important 

values of the existing ACEC or contained new relevant and important values. The analysis focused only 

on the values within the nominated extension; for information on the values within the existing ACEC, see 

the Existing ACEC section.

Table M-25. Relevance Evaluation for the Extensions to the Existing Salmon Falls Creek ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic

No significant historic sites are known within the area. No

Cultural

Several archaeological sites that may be eligible for the National Register of Historic Places are 

located within the nominated extension to the existing ACEC. In addition to their scientific 

value, these sites are of traditional cultural importance to the tribes.

Yes

Scenic

The upland extension offers little in terms of scenery. No

Fish or Wildlife Resource

The upland plateau provides year-round habitat for sage-grouse (Candidate, Type 1). The 

nominated extension to the existing ACEC includes two occupied and one undetermined status 

sage-grouse lek. The area is important winter range for both mule deer and pronghorn. Mule 

deer from the southern portion of the planning area are funneled to the area by Cedar Creek 

and Salmon Falls Creek Canyons. 

Yes

Natural System or Process

The upland plateau supports a mix of native shrub and non-native perennial communities and 

is grazed by livestock. Water pipelines and accompanying roads are present. Water pipelines 

have increased livestock distribution in much of the plateau area.

No

Natural Hazard

No known significant hazards. No

Table M-26. Importance Evaluation for the Extensions to the Existing Salmon Falls Creek ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

NA NA 

Cultural Value

The cultural resources within the nominated extension to the existing ACEC are significant but 

generally not rare or unique for the region. No

Scenic Value

NA NA 

Fish or Wildlife Resource

The wildlife values are not more than locally significant. Big game wintering in the area are 

primarily of local interest. No
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Natural System or Process

NA NA 

Natural Hazard

NA NA 

The nominated extension to the existing ACEC meets the relevance, but not the importance 

criteria, and will not be considered as a potential extension to the existing ACEC. The BLM’s 

rationale for not proposing the nominated extension to the Salmon Falls Creek ACEC for designation as 

part of the Salmon Falls Creek ACEC is as follows:

Although the nominated extension contains big game winter range, some key sage-grouse habitat, and 

some historic and cultural values, these values are not more than of local importance. Salmon Falls 

Creek Canyon itself contains the majority of the resource values that are of more than local importance. 

List the management prescription(s) necessary to maintain and protect each relevant and 

important value.

Not applicable, since the nominated area does not meet relevance and importance criteria for potential 

designation.
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Sand Dunes Area of Critical Environmental Concern Nominated ACEC: Sand Dunes ACEC

Nominated by: The Sand Dunes ACEC was nominated by Western Watersheds Project. 

Location: The Sand Dunes ACEC would encompass 400 acres of BLM-managed land. The 

nominated ACEC would encompass the historic Bruneau Dunes tiger beetle 

habitat within the planning area, located near the Browns Creek Drainage 

approximately seven miles from the Bruneau Dunes State Park.

Table M-27. Relevance Evaluation for the Sand Dunes ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic

No historic values identified. No

Cultural

No cultural values identified. No

Scenic

No scenic values identified. No

Fish or Wildlife Resource

The nominated ACEC contains a small, isolated duneland habitat that was occupied by 

Bruneau Dunes tiger beetles (Type 2, BLM Sensitive species) (Baker et al., 1994). Tiger 

beetles were last documented in the nominated ACEC in 1998 (Baker and Munger, 2000). 

Idaho Conservation Data Center has not found larval burrows or adults in the nominated ACEC 

since that date (Bosworth et al., 2010); thus, as of this review, the tiger beetle population in the 

planning area appears to have been extirpated. Monitoring conducted in the 1990s indicated 

this species was declining since the early 1990s (Baker and Munger, 2000). 

A permanent water trough was installed about 0.3 mile from tiger beetle habitat in an area 

No
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where water was previously hauled for seasonally grazing sheep and cattle. Trailing by cattle 

increased in larval habitat as a result of the more permanent water source. Bauer (1991)

reported that livestock trampling collapsed burrows and increased larval tiger beetle mortality. 

In addition, the tiger beetle habitat within the nominated ACEC has been invaded by 

cheatgrass and Russian thistle (Baker and Munger, 2000) and planted with crested 

wheatgrass, reducing habitat for tiger beetle larvae. Even with restoration of the vegetation, 

beetles would not likely reappear on their own, but would have to be transplanted.

The nominated ACEC is approximately 7 miles east of Bruneau Dunes State Park, which 

contains the entire global distribution for this narrow endemic species. 

Natural System or Process

The sand dunes have been stabilized with crested wheatgrass. The area is now more blowing 

sand than a significant dune feature. No

Natural Hazard

No known significant hazards. No

Table M-28. Importance Evaluation for the Sand Dunes ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

NA NA 

Cultural Value

NA NA 

Scenic Value

NA NA 

Fish or Wildlife Resource

NA NA 

Natural System or Process

NA NA 

Natural Hazard

NA NA 

The nominated ACEC does not meet the relevance or importance criteria and will not be 

considered as a potential ACEC. The BLM’s rationale for not proposing the nominated Sand Dunes 

ACEC for designation is as follows:

Although the nominated ACEC contains the area historically occupied by Bruneau Dunes tiger beetle, no 

evidence of this species (i.e., adults, larvae, or burrows) has been found within the last decade. The 

criteria for relevance requires the area contain a significant wildlife resource; at this time, there is no 

evidence this area still contains this species.
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List the management prescription(s) necessary to maintain and protect each relevant and 

important value.

Not applicable, since the nominated area does not meet relevance and importance criteria for potential 

designation.
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Sand Point Area of Critical Environmental Concern Sand Point ACEC is an existing ACEC. The existing ACEC was re-nominated with a nominated extension 

on land acquired adjacent to the existing ACEC. The analysis documented below considers both the 

existing ACEC and the nominated extension.

Nominated ACEC: Sand Point ACEC (existing ACEC plus the Morgan property extension)

Nominated by: The existing ACEC was re-nominated by BLM in accordance with BLM Manual 

1613, Areas of Critical Environmental Concern, Section .21A.1.; BLM also 

nominated the Morgan property to be added to the existing ACEC. The Morgan 

property was acquired by BLM using Land and Water Conservation Fund funds 

in 2002; this property is adjacent to the existing ACEC. This land was acquired 

because the relevant and important values in the existing ACEC extended onto 

this property and the previous landowner wanted these values preserved.

The existing ACEC was also re-nominated by Western Watersheds Project 

(WWP). WWP also requested that “future expansion of these areas (current 

ACECs) be considered,” although no specific boundary for expanding the 

existing ACECs was identified.

Location: This ACEC would encompass 1,000 acres of BLM-managed lands; 800 acres 

are in the existing ACEC; 200 acres are in the Morgan property extension. 

The ACEC is located south of the Snake River near Hammett, Idaho. The ACEC 

extends from the high water mark along the Snake River about 0.25 to 1 mile 

south into the upland plateau. 
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Table M-29. Relevance Evaluation for the Sand Point ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

The existing ACEC contains 1.3 miles of Oregon National Historic Trail ruts and the south bank 

landing for the Medbury Ferry. The Morgan property extension would add 1.1 miles of Oregon 

National Historic Trail (NHT) and the historic Morgan cabin to the ACEC.

Yes

Cultural Value

Several large prehistoric archaeological sites are located within the existing ACEC and the 

Morgan property extension. Yes

Scenic Value

The breaks from the upland plateau down to the floodplain offer some topographic relief that 

has scenic value. Scenic values are not outstanding. Russian olive and other non-native plants 

have invaded the riparian zone. As a result of a wildland fire in the early 1980s, substantial 

portions of the uplands are now dominated by non-native annuals and perennial grasses. 

No

Fish or Wildlife Resource

The existing ACEC contains 1.3 miles of Snake River riparian zone; the Morgan property 

extension would add 1.1 miles of Snake River riparian zone. The Snake River contains 

redband trout and white sturgeon. The riparian zone has a few trees used as perches for 

wintering bald eagles, which were delisted in 2007; bald eagles are still considered a Type 2 

BLM Sensitive species. Terrestrial plant communities within the existing ACEC and the Morgan 

property extension support nesting habitat for both long-billed curlew and burrowing owls. 

Several thousand waterfowl are known to winter along the Snake River, including within the 

existing ACEC and the Morgan property extension. 

Yes

Natural System or Process

Paleontologic and geologic resources: The Sand Point area, including the existing ACEC and 

the Morgan property extension, contains one of the largest concentrations of Blancan age (3 

million years old) freshwater snail and clam fossils in the United States. The scientific 

importance of the Sand Point fossils and their geologic context has been recognized since their 

original discovery in 1902. Fish and mammal fossils are also present. The Sand Point fluvial 

deposits are composed of brownish gray, thick bedded sands with minor amounts of 

interbedded silt and clay. The Morgan property extension would add two known paleontological 

sites to the existing ACEC. 

Yes

Special status plant assemblages: Two BLM Sensitive plant species occur in the existing 

ACEC: Janish penstemon (Type 3) and Snake River milkvetch (Type 4). Yes

Natural Hazard

No known significant hazards. No

Table M-30. Importance Evaluation for the Sand Point ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA 

Historic Value

(Factors met: 1, 2, 3) The area contains a 2.4-mile section of the Oregon NHT. This site 

represents a unique opportunity to protect culturally and historically significant sites that have Yes
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been damaged or destroyed in other areas through development and agricultural use. 

Cultural Value

(Factors met: 1, 2, 3) The existing ACEC and the Morgan property extension contain 

archaeological sites in a riverside setting that meet National Register eligibility criteria. Their 

importance is enhanced because most similar sites in the region are in private ownership and 

have been altered by agricultural development.

Yes

Scenic Value

NA NA 

Fish or Wildlife Resource

For fish and wildlife resources, the area identified is small in relation to the Snake River. The 

existing ACEC and the Morgan property extension represent only a small fraction of range-wide 

fish and wildlife habitat. Sand Point represents less than 1% of the winter habitat used by 

wintering waterfowl along the Snake River and supports limited numbers of nesting bald eagle, 

long-billed curlew, or burrowing owl. The fish and wildlife resources within the existing ACEC 

and the Morgan property extension are not of more than local importance. 

No

Natural System or Process

Paleontologic and geologic resources: (Factors met: 1, 2) The vertebrate and invertebrate fossil 

deposits at Sand Point have been the subject of scientific study since the early 20th century and 

have demonstrated their continent-wide importance to the study of late Cenozoic 

biostratigraphy, paleoclimatology, and paleoecology. Although the mollusk fossils are most 

abundant and important, the fish fossils are also important in that they represent the most 

advanced and last occurrence of a diversity of minnows, suckers, sculpin, catfish, and sunfish 

never again seen in western North America (Smith et al., 1982). Sand Point is the type locality 

for a species of microtine rodent first reported in 1959. Other mammalian fossils include 

muskrat, pocket gopher, rabbits, voles, horse, and proboscidean (elephant-like mammals). The 

assemblage of fossils within the existing ACEC and the Morgan property extension are 

significant due to their topographic and stratigraphic location relative to other major Idaho fossil 

localities of Blancan age; the extensive molluscan fauna far exceeds in abundance that found 

at any of the other Idaho Blancan localities. While the vertebrate fossils within the ACEC are 

protected by regulation, regulations do not automatically protect invertebrate fossils.

The Sand Point fluvial depositional environment has the smallest exposed extent within the 

Glenns Ferry Formation region. It lies between the Hagerman locality to the east and the Chalk 

Flat and Grandview localities to the west in elevation and time. This geologic formation is 

important for understanding the paleogeography of this part of western North America during 

the late Cenozoic Era. The geologic formations within Sand Point are of more than regional 

significance because of their use in determining the drainage of this portion of western North 

America prior to the Snake River routing north through Hells Canyon.

Yes

Special status plant assemblages: Other areas within the planning area contain both more 

occupied habitat and larger concentrations of special status plant species. The special status 

plant resources within the existing ACEC are not of more than local importance.

No

Natural Hazard

NA NA 

The nominated ACEC (existing ACEC and the Morgan property extension) meets the relevance 

and importance criteria to be considered as a potential ACEC. The rationale for proposing the 

nominated Sand Point ACEC for designation under Alternatives I, III, IV, V, and VI as an ACEC is as 

follows:

The nominated ACEC (existing ACEC and the Morgan property extension) meets relevance and 

importance criteria for historic and cultural values, and natural systems or processes (paleontologic and 

geologic values). 

Several activities pose threats to the ACEC’s relevant and important values, including mineral exploration 

and development, run-off from agricultural irrigation, wildland fire suppression activities, cross-country 
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motorized vehicle use, and livestock grazing. These activities, as well as other surface-disturbing 

activities, all have the potential to cause direct damage to the relevant and important values, as well as 

cause indirect impacts from accelerating erosion.

Activities related to mineral exploration and development have the potential to impact all of the relevant 

and important values within the ACEC. Although there are currently no mining claims within the ACEC 

(existing or the Morgan property extension), there have been several mining claims in the past. Placer 

mining within the ACEC boundary in the 1980s caused substantial damage to the cultural resources. This 

area has also been under mineral lease in the past.

Agricultural run-off primarily impacts the paleontologic and geologic resources within the ACEC. 

Concentrations of fossils are present in several sites within the area where old lake sediments are 

exposed. The sediment layers are classified by the Natural Resources Conservation Service as severe 

for wind erosion potential and medium for water erosion potential.

The main threat related to wildland fire suppression activities is construction of control lines using 

bulldozers. In addition, because the primary access to the area currently is on the Oregon NHT itself, 

travel by fire suppression vehicles could substantially damage the Oregon NHT.

Travel within the existing ACEC is limited to designated routes; however, no routes were designated. The 

primary access to the existing ACEC and the Morgan property extension goes through private property 

and has restricted access; as a result, there is currently little motorized activity within either area. If public 

access to the ACEC was improved along the Wilson Grade Road, increased motorized use would likely 

occur.

Livestock grazing impacts the relevant and important values within the ACEC as well. The majority of the 

existing ACEC (630 acres) is part of a riparian pasture created in 1997 that is grazed once every three 

years; the remaining area (180 acres) in the existing ACEC is grazed every year. The nominated 200-

acre Morgan property extension is not part of an allotment. Livestock trailing and congregating in areas 

with relevant and important values as well as the placement of range infrastructure, salt, and other 

supplements are the primary threats related to grazing.

The segment of the Snake River adjacent the ACEC has been inventoried as eligible for inclusion in the 

National Wild and Scenic River System. Outstandingly Remarkable Values (ORVs) for this segment 

include recreational, fish, historical, and cultural values. Interim management of this segment requires 

that it be managed to maintain or enhance its ORVs. However, the Wild and Scenic River (WSR) corridor 

only extends 0.25 mile above the high water mark on each side of the river, which does not provide any 

protection for these values present outside the WSR corridor.

The Oregon NHT protective zone overlaps the ACEC. The Oregon NHT is managed to preserve and 

protect the historic, scenic, and recreational values of the trail. The Oregon NHT protective zone extends 

0.25 mile on either side of the trail or the visual corridor, whichever is less. Within this protective zone, 

only the trail-related historic values of the ACEC would be protected; outside this zone, none of the 

relevant and important values would be protected through the NHT designation.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The historic and cultural values and the paleontologic and geologic resources of the ACEC would be 

protected through the following allocations and management actions:

Under the No Action Alternative, the existing ACEC boundary would be retained, and the ACEC would be managed 

as described in the Areas of Critical Environmental Concern section of Chapter 2.
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Under Alternatives I, III, IV, V, and VI (Proposed RMP):

Manage paleontological resources within the ACEC in accordance with the 1988 Sand Point Natural 

History Management Plan. Modify the 1988 plan to encompass the Morgan property extension and to 

be in conformance with the RMP.

The ACEC would be closed to fossil collecting except under permit for scientific research. 

Limit BLM management activities and authorized and allowed uses that may contribute to wind or 

water erosion in the ACEC.

No surface-disturbing activities would be allowed in the ACEC unless they are directly related to 

research on the ACEC’s cultural, paleontologic, or geological resources or unless they can be 

mitigated.

The ACEC would be a critical suppression area.

Consider upgrading the Wilson Grade Road if there is increased need for access for fire suppression 

activities or research.

Structures directly related to the preservation or interpretation of the ACEC may be allowed (e.g., 

kiosks, protective barriers).

The ACEC would be a right-of-way exclusion area.

Lands within the ACEC would be in Land Tenure Zone 1. 

The ACEC would be closed to mineral leasing.

The ACEC would be closed to salable mineral development.

Under Alternatives I, III, and IV:

Work cooperatively with adjacent land owners to reduce or eliminate run-off from the agricultural 

fields that erode soils within the ACEC.

 Minimum Impact Suppression Tactics (MIST) would be used to suppress wildland fires within the 

ACEC to protect the paleontological resources. The BLM authorized officer may allow the use of bull 

dozers to construct control lines within the ACEC on a case-by-case basis. However, dozer lines 

would be rehabilitated to minimize erosion.

Manage the ACEC as Visual Resource Management (VRM) Class III, except within the Oregon NHT 

protective zone, which would be managed as VRM Class II.

The ACEC would be available for livestock grazing.

New range infrastructure may be considered if it does not impair the relevant and important values of 

the ACEC. Any infrastructure would be located so that it does not increase or encourage livestock 

trailing across fossil-bearing areas, cultural resource sites, or Oregon NHT ruts.

Salt or other livestock supplements would not be placed within 0.25 mile of fossil-bearing areas or 

cultural resource sites. Locations closed to salt or other livestock supplements would be made known 

to the livestock permittees.

Motorized vehicle use within the ACEC would be limited to designated routes. 

Recommend lands within the ACEC for withdrawal from mining laws for locatable exploration and 

development.

Under Alternative V:

Work cooperatively with adjacent land owners to reduce or eliminate run-off from the agricultural 

fields that erode soils within the ACEC.

MIST would be used to suppress wildland fires within the ACEC to protect the paleontological 

resources. The BLM authorized officer may allow the use of bull dozers to construct control lines 

within the ACEC on a case-by-case basis. However, dozer lines would be rehabilitated to minimize 

erosion.

Manage the ACEC as VRM Class III, except within the Oregon NHT protective zone, which would be 

managed as VRM Class II.

The ACEC would not be available for livestock grazing.

Motorized vehicle use within the ACEC would be limited to designated routes.

Recommend lands within the ACEC for withdrawal from mining laws for locatable exploration and 

development.
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Under Alternative VI (Proposed RMP):

MIST would be used to suppress wildland fires within the ACEC to protect relevant and important 

values of the ACEC.

Manage the ACEC as VRM Class II.

New range infrastructure may be considered if it would not impair the relevant and important values of 

the ACEC. Any infrastructure would be located so that it does not increase or encourage livestock 

trailing across fossil-bearing areas, cultural resource sites, or Oregon NHT ruts.

Salt or other livestock supplements would not be placed within 0.25 miles of fossil-bearing areas, 

cultural resource sites, or the Oregon NHT protective zone. Coordinate with permitees to identify 

appropriate salt and supplement sites. 
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

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Upper Bruneau Canyon Area of Critical Environmental Concern Nominated ACEC: Upper Bruneau Canyon ACEC 

Nominated by: The Upper Bruneau Canyon ACEC was nominated by BLM in accordance with 

BLM Manual 1613, Areas of Critical Environmental Concern, Section 21A.2.b. 

Location: The nominated ACEC would encompass 18,000 acres of BLM-managed land. 

The nominated ACEC would be located along the Upper Bruneau River and 

within the southernmost portion of the planning area. The ACEC includes the 

Bruneau Canyon and adjacent uplands (0.5 to 0.8 mile from the canyon rim) from 

the Jarbidge planning area boundary in the south extending to the BruneauJarbidge Rivers Wilderness boundary to the north.
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

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Table M-31. Relevance Evaluation for the Upper Bruneau Canyon ACEC

Relevance: Does the area contain a significant historic, cultural, or scenic value; fish or 

wildlife resource; natural process or system; or natural hazard?

Yes or 

No

Historic Value

No significant historic sites are known within the area. No

Cultural Value

Native American use of the area extends back thousands of years. The canyon lands provided 

food, shelter, and water for Native Americans along the Bruneau River. The area retains 

traditional cultural importance for the tribes. Many sites are also important for their 

archaeological value.

Yes

Scenic Value

Scenic values in the Bruneau Canyon are outstanding and the portions of the nominated ACEC 

downstream of Black Rock Crossing are suitable for Wild and Scenic River (WSR) designation. 

The canyon complex has exceptional rugged-desert scenery and natural qualities, including 

both basalt and rhyolite forms of volcanic material. 

Yes

Fish or Wildlife Resource

California bighorn sheep: The nominated ACEC contains 9,000 acres of habitat for bighorn 

sheep, a Type 3 BLM Sensitive species, which represents 18% of the bighorn sheep habitat 

within the planning area. The bighorn sheep population within the Bruneau and Jarbidge River 

Canyons is estimated to be approximately 210 sheep. The canyon lands provide secure 

lambing habitat. The rivers in the canyon bottoms, as well as occasional seeps from canyon 

walls, provide water. Bighorn sheep forage is available in both the canyons and adjacent 

uplands.

Yes

Big game: The nominated ACEC contains 18,000 acres of big game winter range. Yes

Bull trout: Bull trout, a Threatened and Type 1 BLM Sensitive species, are not known to occur 

within the nominated ACEC. The segment of the Bruneau River within the nominated ACEC is 

outside designated critical habitat for bull trout; extensive surveys for bull trout in this river 

segment have not been conducted. 

No

Redband trout: The nominated ACEC contains 14 miles of occupied redband trout habitat in 

the Bruneau River. The Bruneau River within the ACEC lacks migration barriers that prevent 

redband from moving up or down stream, unlike most of the other redband trout streams within 

the planning area.

Yes

Other fish and wildlife: The Bruneau Canyon contains habitat for a variety of BLM Sensitive 

species, including golden eagle (NV), peregrine falcon (Type 3), prairie falcon (Type 4), spotted 

bat (Type 3), Townsend’s big eared bat (Type 3 and NV), fringed myotis (Type 3 and NV), and 

little brown bat (NV). The upland plateaus adjacent to the canyons contain habitat for Brewer’s 

sparrow (Type 3 and NV), greater sage-grouse (Candidate, Type 1), sage sparrow (Type 3), 

and other sagebrush-obligate species. 

Yes

Natural System or Process

Bruneau River phlox: Bruneau River phlox, a Type 3 and NV BLM Sensitive species, do not 

occur within the nominated ACEC. No

Davis peppergrass: Davis peppergrass, a Type 3 and NV BLM Sensitive species, is present in 

playas within the nominated ACEC. The nominated ACEC contains 10 acres of Davis 

peppergrass habitat, which represents 7% of the habitat within the planning area.

Yes

Riparian system: Fourteen miles of the Bruneau River system is within the ACEC. The Bruneau 

River system is free-flowing. Free-flowing streams are unique in southern Idaho since the 

majority of other desert rivers, including the Snake and Owhyee Rivers and Salmon Falls 

Creek, contain dams. The riparian system is dominated by Rocky Mountain juniper and willows.

Yes

Natural Hazard

No known significant hazards. No
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

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Table M-32. Importance Evaluation for the Upper Bruneau Canyon ACEC

Importance: Does the value, resource, system, process, or hazard meet one or more of 

the following importance factors:

1. has more than locally significant qualities that give it special worth, 

consequence, meaning, distinctiveness, or cause for concern, especially 

compared to any similar resource;

2. has qualities or circumstances that make it fragile, sensitive, rare, irreplaceable, 

exemplary, unique, endangered, threatened, or vulnerable to adverse change;

3. has been recognized as warranting protection to satisfy national priority 

concerns or to carry out the mandates of FLPMA;

4. has qualities that warrant highlighting to satisfy public or management concerns 

about safety and public welfare; or

5. poses a significant threat to human life and safety or to property?

Yes, 

No, or 

NA

Historic Value

NA NA 

Cultural Value

(Factors met: 1, 2) Regionally significant cultural resources are present within the nominated 

ACEC. Yes

Scenic Value

Scenic values in the Bruneau Canyon are outstanding and the portions of the nominated ACEC 

downstream of Black Rock Crossing are suitable for WSR designation. The canyon complex 

has exceptional rugged-desert scenery and natural qualities, including both basalt and rhyolite 

forms of volcanic material.

Yes

Fish or Wildlife Resource

California bighorn sheep: (Factors met: 1, 2, 3) The nominated ACEC contains 9,000 acres of 

habitat for bighorn sheep, a Type 3 BLM Sensitive species, which represents 18% of the 

bighorn sheep habitat within the planning area. The bighorn sheep population within the 

Bruneau and Jarbidge River Canyons is estimated to be approximately 210 sheep. The canyon 

lands provide secure lambing habitat. The rivers in the canyon bottoms, as well as occasional 

seeps from canyon walls, provide water. Bighorn sheep forage is available in both the canyons 

and adjacent uplands.

Yes

Big game: The nominated ACEC is important to wintering big game from parts of Nevada and 

Idaho including mule deer, pronghorn, and elk. The nominated ACEC contains 18,000 acres of 

big game winter range; however, the winter range within the ACEC is primarily of local 

importance. 

No

Bull trout: NA NA 

Redband trout: The nominated ACEC contains 14 miles of occupied redband trout habitat in 

the Bruneau River. The Bruneau River within the ACEC lacks migration barriers that prevent 

redband from moving up or down stream, unlike most of the other redband trout streams within 

the planning area.

Yes

Other fish and wildlife: The other fish and wildlife present within the ACEC are found elsewhere 

in and outside the planning area; the populations within the ACEC are primarily of local 

importance.

No

Natural System or Process

Bruneau River phlox: NA NA 

Davis peppergrass: Davis peppergrass, a Type 3 and NV BLM Sensitive species, is present in 

playas within the nominated ACEC. The nominated ACEC contains 10 acres of Davis 

peppergrass habitat, which represents 7% of the habitat within the planning area. Davis 

peppergrass plants show distinct differences in leaf size, shape, and plant phenology between 

playas. This suggests the species disperses poorly, probably not beyond individual playas, and 

there is minimal pollination between neighboring playas.

Yes

Riparian system: Fourteen miles of the Bruneau River system is within the ACEC. The Bruneau 

River system is free-flowing. Free-flowing streams are unique in southern Idaho since the 

majority of other desert rivers, including the Snake and Owhyee Rivers and Salmon Falls 

Creek, contain dams. The riparian system is dominated by Rocky Mountain juniper and willows.

Yes
Jarbidge Proposed RMP/Final EIS Appendix M: Evaluation of Nominated Areas of

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Natural Hazard

NA NA 

The nominated ACEC meets the relevance and importance criteria to be considered as a potential 

ACEC. The rationale for proposing the nominated Upper Bruneau Canyon ACEC for designation (under 

Alternative VI [Proposed RMP]) as an ACEC is as follows:

The nominated ACEC meets relevance and importance criteria for cultural and scenic values, fish and 

wildlife resources (bighorn sheep and redband trout), and natural systems or processes (Davis 

peppergrass and riparian system).

Existing and potential threats to the relevant and important values of the ACEC include surface-disturbing 

activities, wildland fire and subsequent alteration of habitat, and to a lesser extent livestock grazing. Aside 

from direct impacts from these threats, many of these indirectly affect the introduction and spread of 

noxious weeds and invasive plants, which are detrimental to the scenic values and the fish and wildlife 

resources within the ACEC.

Surface-disturbing activities, such as mineral exploration and development and right-of-way (ROW) 

development, are a threat to cultural and scenic values and bighorn sheep; bighorn sheep typically avoid 

human disturbance. Any activities in the uplands or riparian zones that increase sediment to the stream 

can adversely affect redband trout. 

Wildland fire is a threat to several of the relevant and important values within the ACEC. Wildland fires 

that burn the riparian zone can reduce the amount of large wood and streambank shade and increase 

sediment to the stream, affecting redband trout. Components of wildland fire suppression (e.g., the use of 

retardant, constructing control lines) can also be detrimental to fish and aquatic wildlife. Cheatgrass 

frequently increases and may dominate in the canyon lands following wildland fires, affecting habitat for 

bighorn sheep. Wildland fire also presents a threat to Davis peppergrass. Wildland fire, including soil 

erosion and deposition following wildland fire, can adversely affect habitat for Davis peppergrass 

(Moseley, 1996). Davis peppergrass can also be impacted by the constructions of fire lines that damage 

plants directly or increase sediment in occupied playas.

Livestock grazing is a threat primarily to bighorn sheep. Bighorn sheep can be displaced by livestock. 

Livestock water sources as well as salting and supplement sites located in the ACEC have contributed to 

the spread of invasive plants. In addition livestock grazing also presents a threat to Davis peppergrass. 

Livestock trailing and trampling in occupied playas while they are wet damages the perennial plants 

(Moseley, 1996). Stock ponds dug in playas may alter their hydrology and contribute to the spread of 

invasive plant species. Livestock congregating in or near playas also impacts cultural resources 

associated with playas.

The Bruneau River from Blackrock Crossing to 0.3 mile above the confluence of the West Fork of the 

Bruneau River and the Jarbidge River has been recommended suitable for designation as a WSR. 

Outstandingly Remarkable Values (ORVs) for this segment include cultural, fish, geological, recreational, 

scenic, vegetation, and wildlife values. Management of this segment requires that its ORVs are 

maintained or enhanced. However, the WSR corridor only extends 0.25 mile above the high water mark 

on each side of the river, which does not provide any protection for these values in the higher elevations 

of the canyon or the adjacent upland plateaus.

If the nominated ACEC meets the relevance and importance criteria, list the relevant and 

important value(s) that need special management attention and describe the management 

prescriptions necessary to protect those values.

The cultural and scenic values, fish and wildlife resources (bighorn sheep and redband trout), and natural 

systems or processes (riparian system) of the ACEC would be protected through the following allocations 

and management actions:
Appendix M: Evaluation of Nominated Areas of Jarbidge Proposed RMP/Final EIS

Critical Environmental Concern

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New developments would not be allowed within 300 feet of playas within the ACEC.

Areas within the ACEC with concentrated recreational use and livestock grazing would be a high 

priority for noxious weeds and invasive plants treatment with integrated weed management 

techniques for control, containment, and where practical, eradication. Special stipulations would apply 

for noxious weed and invasive plants treatments in Davis peppergrass habitat. Use of domestic 

sheep or goats to reduce noxious weeds would not be allowed within the ACEC to eliminate potential 

contact with bighorn sheep.

The ACEC would be a critical suppression area.

Minimus Impact Suppression Tactics would be used to suppress wildland fires within the ACEC. Fire 

lines would be rehabilitated to help stabilize soils.

Manage the ACEC as Visual Resource Management Class I.

If a conflict between authorized uses and bighorn sheep is identified, schedule authorized uses to 

avoid pastures that contain bighorn sheep habitat during breeding, wintering, and lambing periods to 

minimize disturbance during these important seasonal periods.

Adjust livestock seasons of use or stocking rates on a pasture-specific basis to minimize conflicts with 

Davis peppergrass during flowering and when playas are most likely to contain water (December 

through June).

Range infrastructure would be evaluated for retention, modification, or removal. New infrastructure 

would be allowed to the extent that it protects riparian habitat, cultural resources, botanical values, 

bighorn sheep, or other resource values. Prohibit placement of salt or other supplements within the 

ACEC to reduce livestock use of bighorn sheep habitat and protect big game winter range.

Monitor recreational use within the ACEC. If recreational use impairs the relevant and important 

values of the ACEC, implement protective measures appropriate to the type of recreational activity. 

Protective measures may include: seasonal restrictions for motorized use, and designating camping 

areas outside the ACEC.

 Special Recreation Permits would be allowed within the ACEC as long as the relevant and important 

values are protected. 

No new roads would be constructed and existing routes would not be substantially improved to 

minimize the level of human disturbance in bighorn sheep habitat. Some designated routes within the 

ACEC could have spot surface treatments to reduce resource damage and to improve public safety. 

The ACEC would be a ROW avoidance area.

Lands within the ACEC would be in Land Tenure Zone 1; where practical, acquire private and/or 

State in holdings. The ACEC designation and management would apply to lands acquired within the 

ACEC boundary.

The ACEC would be closed to exploration and development of leasable or salable minerals.
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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APPENDIX N: WILD AND SCENIC RIVER ELIGIBILITY 

DETERMINATION
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____________ _______

____________ _______

Jarbidge Field Office

WILD AND SCENIC RIVER

ELIGIBILITY DETERMINATION

Approved by:

Brian W. Davis 

Jarbidge Field Office Manager

signed copy on file

 Date

_03/07/2014

Tate Fischer

Four Rivers Field Office Manager

 

signed copy on file

 Date

_03/11/2014
This Page Intentionally Left Blank
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Introduction

Congress enacted the Wild and Scenic Rivers Act (WSRA; 16 U.S.C. 1271-1287) on October 2, 1968, to 

provide for a national system of river protection and preservation. As an outgrowth of a national 

conservation agenda in the 1950s and 1960s, the WSRA responded to the dams, diversions, and water 

resource development projects that occurred on America’s rivers between the 1930s and 1960s. The 

WSRA stipulates selected rivers should be preserved in a free-flowing condition and be protected for the 

benefit and enjoyment of present and future generations. Since 1968, the WSRA has been amended 

many times, primarily to designate additional rivers and to authorize the study of other rivers for possible 

inclusion. The WSRA seeks to protect and enhance a river’s natural and cultural values and to provide for 

public use consistent with its free-flowing condition, water quality, and Outstandingly Remarkable Values. 

Designation affords certain legal protection from development. For instance, new dams cannot be 

constructed, and Federally assisted water resource development projects that might negatively affect the 

designated river values are not permitted. Where non-Federal lands are involved, the managing Federal 

agency works with local governments and private landowners to develop protective measures.

Section 5 (d) (1) of the WSRA directs Federal land management agencies to consider potential Wild and 

Scenic Rivers (WSRs) in their land and water planning processes, stating, “In all planning for the use and 

development of water and related land resources, consideration shall be given by all Federal agencies 

involved to potential national wild, scenic and recreational river areas.” To fulfill this requirement, the US 

Department of the Interior BLM inventories and analyzes river and stream segments that might be eligible 

for inclusion in the National Wild and Scenic Rivers System (NWSRS) whenever it undertakes a land use 

planning effort such as a Resource Management Plan (RMP).

The BLM, Twin Falls District, Jarbidge Field Office is preparing an RMP and EIS, which will provide a 

single, comprehensive land use plan to guide future management of public land managed by the Jarbidge 

Field Office. This report is a record of the WSR inventory conducted concurrently with the Jarbidge RMP. 

This report documents the BLM’s examination of Jarbidge Field Office rivers as they relate to eligibility 

and classification criteria in the WSRA. The Wild and Scenic Rivers Inventory Process section describes 

the WSR inventory process. The Criteria for Evaluating Eligibility section describes the WSR inventory 

criteria. The Evaluating Eligibility on Jarbidge Field Office Rivers section describes how the inventory 

process and criteria were applied to the Jarbidge Field Office. The Description of Eligible River Segments

section describes each of the potentially eligible river segments in more detail.

The Omnibus Public Lands Management Act of 2009 designated four WSRs within the planning area:

A 39.3-mile segment of the Bruneau River from the downstream boundary of the Bruneau-Jarbidge 

Rivers Wilderness to the confluence with the West Fork of the Bruneau River, except for a 0.5-mile 

segment at the Indian Hot Springs public road access, to be administered as a wild river; 

A 0.6-mile segment of the Bruneau River at the Indian Hot Springs public road access to be 

administered as a recreational river; 

A 0.35-mile segment of the West Fork of the Bruneau River from the confluence with the Jarbidge 

River to the downstream boundary of the Bruneau Canyon Grazing Allotment to be administered as a 

wild river; and

A 28.8-mile segment of the Jarbidge River from the confluence with the West Fork of the Bruneau 

River to the upstream boundary of the Bruneau-Jarbidge Rivers Wilderness to be administered as a 

wild river. 

All four of these river segments were identified as suitable for inclusion in the NWSRS in the 1976 

Bruneau Wild and Scenic River Study Report.

Rivers or river segments previously deemed eligible, suitable, or designated were not re-evaluated (Table 

N-1; Figure N-1). All current eligible or suitable segments retain any previously determined status.
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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Table N-1. Existing Designated, Eligible, and Suitable River Segments

River Segment 

Description

Length 

(miles)

Outstandingly 

Remarkable Values

Tentative 

Classification

Current 

Status

Salmon Falls 

Creek, upper

Nevada border to 

Salmon Falls Creek 

Reservoir

9 Recreational Recreational Eligible

Salmon Falls 

Creek, lower

Salmon Falls Dam 

to Balanced Rock 

Park

30

Scenic, 

Recreational, 

Geological

Scenic Eligible

Snake River, 

Hagerman Reach

Lower Salmon 

Falls Dam to Bliss 

Dam Reservoir 

8 

Recreational, 

Geological, Fish, 

Wildlife, Historical

Recreational Eligible

Snake River, King 

Hill Reach

Bliss Dam to the 

King Hill Bridge 13

Recreational, 

Geological, Fish, 

Wildlife

Recreational Eligible

Bruneau River, 

upper

Blackrock Crossing 

to 23 miles 

downstream

23

Scenic, 

Recreational, 

Geological, Fish, 

Wildlife, Cultural, 

Vegetation

Scenic Suitable

West Fork 

Bruneau River

Segment of 

Bruneau River .35 

miles upstream 

from confluence of 

Jarbidge River

0.35

Scenic, 

Recreational, 

Geological, Fish, 

Wildlife, Cultural, 

Vegetation

Wild Designated

Bruneau River

Segment of 

Bruneau River at 

the Indian Hot 

Springs public road 

access

.6

Scenic, 

Recreational, 

Geological, Fish, 

Wildlife, Cultural, 

Vegetation

Recreational Designated

Bruneau River

Confluence of 

Jarbidge-Bruneau 

Rivers downstream 

to boundary of 

Bruneau-Jarbidge 

Rivers Wilderness 

39

Scenic, 

Recreational, 

Geological, Fish, 

Wildlife, Cultural, 

Vegetation

Wild Designated

Jarbidge River

East Fork, Jarbidge 

River confluence to 

Bruneau River 

confluence

29

Scenic, 

Recreational, 

Geological, Fish, 

Wildlife, Cultural, 

Vegetation

Wild Designated

Total 152
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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Figure N-1. Existing Designated, Eligible, and Suitable River Segments
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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Wild and Scenic Rivers Inventory Process

Background

Consideration of whether a river should be designated as a wild, scenic, or recreational river can be 

broken into two phases:

1. Eligibility Determination – Federal agencies conduct an evaluation of river features to 

determine which rivers qualify to be added to the National Wild and Scenic Rivers System 

(NWSRS). 

2. Suitability Determination – Most commonly, Federal agencies conduct a review and then 

recommend to Congress which rivers should be protected. Only Congress or the Secretary of the 

Interior can designate a river as wild, scenic, or recreational. 

This document provides the reader with the results of the 2007 Wild and Scenic River Inventory for the 

Jarbidge Field Office (updated 2013). The suitability determination phase will be conducted after the 

Record of Decision is signed for the approved Jarbidge RMP. The Twin Falls District (Burley Field Office, 

Jarbidge Field Office, and Shoshone Field Office) may prepare a comprehensive, District-wide suitability 

study report for all eligible WSR segments within the District. This would result in a programmatic plan 

amendment for all Field Offices involved.

Through Section 5 (d) (1), the BLM is required to assess rivers under its management jurisdiction and 

determine eligibility for these rivers by applying standardized criteria through a documented evaluation 

process. Congress established two screening criteria for a river segment to be eligible for inclusion in the 

NWSRS: it must be 1) free-flowing and 2) possess one or more outstandingly remarkable scenic, 

recreational, geological, fish and wildlife, historical, cultural, or other values including ecological values. 

Inventory of Eligible Rivers

Eligible rivers must be free-flowing

In order for a river to become eligible for further study, it must be free flowing. The Wild and Scenic Rivers 

Act (WSRA) Section 16 (b) defines free flowing as “existing or flowing in a natural condition without 

impoundment, diversion, straightening, riprapping, or other modifications in the waterway. The existence 

of low dams, diversion works, or other minor structures at the time any river is proposed for inclusion in 

the national wild and scenic river system shall not automatically bar its consideration for inclusion.” The 

intent of Congress and Federal regulations implies rivers must be generally free-flowing but not 

necessarily completely without human modification. Free-flowing rivers can lie between impoundments or 

dams and may be intermittent. 

Eligible rivers must possess an outstandingly remarkable value

In order for a river to become eligible for further study as a possible wild, scenic, or recreational river, it 

must have one or more Outstandingly Remarkable Values (ORVs) on BLM-managed lands. The ORVs

fall into categories defined in Section 1 (b) of the WSRA as “scenic, recreational, geologic, fish, wildlife, 

historic, cultural, or other similar values.” “Other similar values” include, but are not limited to, hydrologic, 

ecological/biological diversity, paleontological, botanical, and scientific study opportunities. 

Minimum size and flow

The size of a river is not a criterion of eligibility. Rivers are defined in Section 16 (a) of the WSRA as “a 

flowing body of water or estuary or section, portion, or tributary thereof, including rivers, streams, creeks, 

runs, kills, rills, and small lakes.” Rivers considered eligible need not have outstanding white water or be 

navigable. Smaller rivers may be equally important as large rivers depending on the context within 

different ecosystems. Similarly, the length of a river segment is also not a criterion of eligibility as long as 

a specificORV can be protected if the segment is designated.
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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Tentative classification as wild, scenic, or recreational

River segments found to be eligible are assigned a tentative classification as wild, scenic, or recreational 

based on the development of shoreline, watercourse, and access as they exist at the time of the 

inventory. Different segments of the same river can have different classifications. Section 2(b) of the 

WSRA specifies three classification categories for eligible rivers.

1. Wild River Areas - Wild river areas are those rivers or sections of rivers free of impoundments 

and generally inaccessible except by trail, with watersheds or shorelines essentially primitive and 

waters unpolluted. 

2. Scenic River Areas - Scenic river areas are those rivers or sections of rivers free of 

impoundments, with shorelines or watersheds still largely primitive or shorelines largely 

undeveloped, but accessible in places by roads. “Scenic” does not necessarily mean the river 

corridor has to have scenery as an ORV. 

3. Recreational River Areas - Recreational river areas are those rivers or sections of rivers that are 

readily accessible by road or railroad, that may have some development along their shorelines, 

and that may have undergone some impoundment or diversion in the past. “Recreational” does 

not imply that the river will be managed or prioritized for recreational use or development.

Final classifications are made by Congress or the Secretary of the Interior at the time a segment is 

designated for inclusion in the NWSRS.

Suitability Determinations

The second and final phase of agency review is suitability. During the suitability phase, the agency 

evaluates the river and considers several factors to determine if the river, in its context, should be 

recommended to Congress for addition to the NWSRS. Current and future uses of the surrounding land 

and water, as well as what values would be preserved, lost, or diminished if the river were designated, 

are considered. Public and local governmental interest in designating the river is assessed. Fiscal 

concerns of acquiring any appropriate land are identified. 

Protective Management

Eligible rivers and their corridors on Federal lands are provided interim protection until the suitability 

phase is complete. Rivers recommended as suitable are protected as potential additions to the NWSRS 

until Congress or the Secretary of the Interior determines whether the suitable river will be included in the 

NWSRS. Rivers deemed nonsuitable revert to land management as described in the most recent RMP. 

The characteristics of eligible and suitable segments are managed as described below:

1. Free-flowing values - The free-flowing condition of eligible river segments cannot be modified to 

allow stream impoundments, diversions, channelization, or riprapping to the extent authorized 

under law.

2. River-related values - Each segment is managed to protect ORVs, subject to valid existing 

rights. To the extent practicable, such values are enhanced.

3. Classification impacts - Management and development of the eligible river and its corridor 

cannot be modified, subject to valid existing rights, to the degree that its eligibility or classification 

would be affected.
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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Criteria for Evaluating Eligibility

The following criteria were developed to guide evaluations for potential eligibility of rivers in the Jarbidge 

Field Office and for recommendation as a wild, scenic, or recreational river. These were developed by an 

Interdisciplinary (ID) Team composed of Jarbidge Field Office employees, including specialists in wildlife, 

fisheries, upland and riparian vegetation, recreation, rangeland management, and archaeology 

(Attachment 1).

In developing the criteria described in this report, the RMP Interdisciplinary Team (ID Team) relied on the 

documents listed below. All direction contained in this document is consistent with direction in BLM 

Manual 6400, Wild and Scenic Rivers – Policy and Program Direction for Identification, Evaluation, 

Planning, and Management. The other documents were used as a source for information and guidance.

US Department of the Interior-US Department of Agriculture (USDA) Guidelines for Eligibility, 

Classification, and Management of River Areas (09/07/1982); 

The Wild and Scenic River Study Process, Interagency Wild and Scenic Rivers Coordinating Council 

(12/1999); and

A Compendium of Questions and Answers Relating to Wild and Scenic Rivers, Interagency Wild and 

Scenic Rivers Coordinating Council (06/2006). 

Criteria for Inclusion in the Inventory and for Segmenting Rivers

The following sources were used to identify potentially eligible rivers (Attachment 2):

Perennial and intermittent rivers and streams included on Jarbidge Field Office geographic 

information system layers;

River segments identified in public scoping for the Jarbidge RMP;

All rivers included in the Nationwide Rivers Inventory (NPS, 2004) or the State of Idaho 

Comprehensive Water Plan;

Any river studied but determined to be ineligible in the Bruneau Wild and Scenic River Study Report 

of August 1976; 

The USDA Forest Service, Humboldt-Toiyabe National Forest Wild and Scenic Rivers Eligibility 

Report (USFS, 2005), which describes eligibility studies on streams that flow from the HumboldtToiyabe National Forest into the Jarbidge planning area; and

Boundary rivers not previously deemed eligible during evaluation efforts in adjacent BLM field offices.

A river’s inclusion on any of these source lists does not represent an official determination of eligibility, 

and a river’s absence from these source lists does not indicate its ineligibility. 

Ephemeral waterways, which contain water only in response to local precipitation events, were not 

inventoried for eligibility; however, intermittent streams, which contain a predictable seasonal flow of 

water, were included in the inventory.

BLM limited the eligibility study to the lands it administers, per BLM Manual 6400, Wild and Scenic 

Rivers—Policy and Program Direction for Identification, Evaluation, Planning, and Management, which 

states, “The BLM does not have the authority to evaluate the presence, absence, or quality of values that 

occur on private lands. However, the boundary of that river may include private lands. In such cases 

eligibility determinations should only consider the presence of values on BLM-admisistered lands and 

related waters”. 

Rivers included in the inventory were segmented where substantial changes in eligibility or tentative 

classification might occur, such as the presence of impoundments or dams, noticeable changes in types 

or amounts of development, and obvious changes in physiographic character or land status.

Free-flowing Criteria

In determining whether a river is free-flowing, the Wild and Scenic Rivers Act (WSRA) states “...the 

existences, however, of low dams, diversions works, and other minor structures...shall not automatically 
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bar its consideration....” The ID Team established the following minimum criteria to ensure rivers having 

borderline “minor” modifications would be considered: the flow within the segment must be substantially 

unaltered as a result of human activity to the extent that riparian vegetation is maintained by stream flows.

Considerations for Evaluating Outstandingly Remarkable Values

Section 1 (b) of the WSRA describes the rivers to be protected as possessing Outstandingly Remarkable 

Values (ORVs). ORVs do not have a clear definition in the Act, yet they are crucial components of eligible 

rivers. ORVs identified in the WSRA include scenic, recreational, geological, fish and wildlife, historical, 

cultural, or other values including attributes such as river-related paleontologic deposits or unique 

botanical resources.

Three sideboards were used to consider whether an outstandingly remarkable value could be applied to a 

river. First, the value must be river-related; a value should be directly associated with the river or the river 

corridor, typically considered to be 0.25 mile from the ordinary high water mark on each side of the river. 

The values need to contribute substantially to the functioning of the river ecosystem or to its public value, 

or owe its existence to the river.

The second sideboard is that the values considered should be at least regionally important to be deemed 

outstandingly remarkable. The region of comparison the ID Team used depended on the value being 

evaluated; regions of comparison for each value are noted below in Table N-1.

The third and final sideboard is that within the regions of comparison, the features or ORVs being 

considered need to be rare, unique, or exemplary examples of the occurrence of that feature or value.

Criteria for Each Potential Outstandingly Remarkable Value

Outstandingly Remarkable Scenic Value

Definition

The landscape elements of landform, vegetation, water, color, and related factors must result in notable 

or exemplary visual features or attractions within the geographic region. The rating area must be scenic 

quality “A” as defined in the BLM Visual Resource Inventory Handbook, H-8410-1; the handbook may 

also be used to assess visual quality and to evaluate the extent of development upon scenic values. 

Additional factors may be considered, such as seasonal variations in vegetation, scale of cultural 

modifications, and the length of time negative intrusions are viewed. Scenery and visual attractions may 

be highly diverse over the majority of the river or river segment and not common to other rivers in the 

geographic region.

Region of comparison

The region of comparison for scenic values for the Jarbidge Field Office includes the northern Great 

Basin, the Snake River Plain, and the Owyhee River watershed.

Criteria for evaluating scenic value

Diversity of View: Consider the presence of high relief; severe surface variation; rich color 

combinations including high variety and vivid colors; pleasing contrasts in soil, rock, vegetation, and 

water; views that greatly enhance visual quality; or still or cascading water that is dominant in the 

landscape. River corridors with the greatest diversity and variety of views in both foreground and 

background are of higher value. Consider places that people go to see things, which can range from 

the micro views at pools or waterfalls to the grander views and vistas from along a trail or river.

Special Features: Consider outstanding natural, historical, or cultural features and landforms with 

unusual or outstanding topographic features such as gorges, high relief, rock outcrops, canyons, falls, 

rapids, springs, hot springs, color, and vegetation. River corridors with high relief and focal points that 

are visually striking, particularly memorable, or rare in the region are of higher value.

Seasonal Variations: Consider diversity of vegetation types in interesting patterns, textures, color, and 

contrast. River corridors with the greatest seasonal variation and diversity are of higher value.

Cultural Modifications: Consider human modifications and features within the corridor and viewshed. 

Viewsheds that are free from aesthetically undesirable sights and influences are generally of higher 

value. Human features that exist may in some cases add to visual appeal. 
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Outstandingly Remarkable Recreational Value

Definition

Recreational opportunities are, or have the potential to be, unusual enough to attract visitors to the 

geographic region. Recreational opportunities may be rare or unique within the region. Visitors are willing 

to travel long distances to use the river resources for recreational purposes. River-related opportunities 

could include, but are not limited to, sightseeing, wildlife observation, camping, photography, hiking, 

fishing, hunting, and boating. Interpretive opportunities may be exceptional and attract, or have the 

potential to attract, visitors from outside the geographic region. The river may provide or have the 

potential to provide settings for national or regional commercial usage or competitive events.

Region of comparison

The region of comparison for recreational values for the Jarbidge Field Office includes the Snake River 

Plain south to Interstate 80 in northern Nevada, where there are similar types of water-based recreational 

activities as within the Jarbidge Field Office. 

Criteria for evaluating recreational value

Diversity of Use: Consider the number and variety of recreation uses occurring within the corridor. 

Rivers that provide for the largest number and diversity of recreation uses are of higher value.

Experience Quality: Consider the comparative number or percent of similar experiences available in 

the region. Rivers that provide the most unique opportunities are of higher value for fishing, wildlife 

viewing, and hunting. Highly scenic, pristine rivers and corridors are of higher value as compared to 

other areas that are visually monotonous, heavily developed, malodorous, or noisy.

Access: Consider the availability of private and public access points, ease of use, and attendant 

facilities such as parking, boat ramps, and trails. On some rivers, poor access can be advantageous 

to limit crowding.

Level of Use: A little-used river should not by itself indicate a lower value, and an intensively used 

river may indicate a diminished value due to overcrowding. However, rivers or corridors highly used 

by anglers, hunters, and wildlife viewers are usually of higher value.

Associated Opportunities: Consider the extent of opportunities for hiking, photography, fishing, 

picnicking, swimming, wildlife viewing, and other similar experiences. Rivers with the greatest 

opportunity for associated recreation are of higher value.

Attraction: Consider the ability to attract visitors from outside the geographic region. Rivers that attract 

a variety of users with their primary intent to use the river for recreation experiences as well as rivers 

that provide a setting for national or regional competitive events are of higher value.

Sites and Facilities: Consider the extent of or potential for appropriate facility development. Rivers 

with the greatest number of existing or potential recreation facilities may be of higher value depending 

upon the type of recreation opportunity provided.

Length of Season: Consider the amount of time the river corridor is used or available for recreation 

purposes. Rivers with the longest season of use may be of higher value depending upon the type of 

recreation opportunity provided.

Outstandingly Remarkable Geological Value

Definition

The river or river corridor contains one or more examples of a geologic feature, process, or phenomenon 

that are rare, unusual, or unique within the region. The feature(s) may be in an unusually active stage of 

development, represent a “textbook” example, and/or represent a unique or rare combination of geologic 

features or landforms (e.g., erosional, volcanic, glacial).

Region of comparison

The region of comparison for geological values for the Jarbidge Field Office includes the northern Great 

Basin, the Snake River Plain, and the Owyhee River watershed.

Criteria for evaluating geological value

Feature Abundance: Consider landforms and geologic setting with unusual or outstanding geologic 

features (e.g., gorges, arches, badlands, oxbows, caves, relic shoreline, unusual drainage patterns 

and stream channels, bogs, waterfalls, deep canyons, hot springs, unique rock formations, and 
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outcrops). River corridors with an abundance of unusual, unique, and distinctive geologic features to 

the region are of higher value.

Diversity of Features: Consider the number and variety of special geologic features and the value of 

these features to the region. Consider the unique or rare combination of geologic features or 

landforms (e.g., erosional, volcanic, glacial). River corridors with the greatest diversity of geologic 

features are of higher value.

Educational/Scientific: Geologic features clearly and graphically reveal an interesting or unique 

educational or scientific story of the earth’s history. River corridors that represent “textbook” examples 

of a common feature or are the best example of a feature in the region are of higher value.

Outstandingly Remarkable Fish Value

Definition

Fish values may be judged on the relative merits of fish populations, habitat, or a combination of these 

river-related conditions. 

Populations: The river is a nationally or regionally important producer of indigenous, resident, and/or 

anadromous fish species. Of particular significance may be the presence of wild or unique stocks 

and/or populations of Federal- or State-listed (or Candidate) Threatened, Endangered, or sensitive 

species. Diversity of species is an important consideration and could, in itself, lead to a determination 

of “outstandingly remarkable”. 

Habitat: The river provides exceptionally high quality habitat for fish species indigenous to the region 

of comparison. Of particular significance is habitat for wild stocks and/or Federal- or State-listed (or 

Candidate) Threatened, Endangered, or sensitive species. Diversity of habitats is an important 

consideration and could, in itself, lead to a determination of “outstandingly remarkable”. 

Region of comparison

The region of comparison for fish values for the Jarbidge Field Office includes the Columbia River Basin, 

which corresponds to the range of special status fish species present in the Field Office. 

Criteria for evaluating fish value

Habitat Quality: Consider the presence, extent, and carrying capacity of spawning area, rearing 

areas, and adult habitat, as well as habitat for wild stocks and special status species. Areas with the 

greatest amount and best quality habitat, especially for wild stock and special status species, are of 

higher value.

Diversity of Species: Consider the number and variety of species present and the value of these 

species. Areas with the greatest diversity of species, including wild stocks and special status species, 

are of higher value.

Value of Species: Rivers that are of special interest, are highly used by anglers, or offer an unusual 

recreation experience for the region are of higher value.

Abundance of Fish: Rivers with more fish and/or rivers that have been documented historically for 

sizeable runs are of higher value.

Natural Reproduction: Rivers with extensive self-sustaining natural reproduction are of higher value 

than those supported mostly by stocking.

Size and Vigor of Fish: Rivers that produce large, vigorous fish are of higher value.

Outstandingly Remarkable Wildlife Value

Definition

Wildlife values may be judged on the relative merits of terrestrial or aquatic populations, habitat, or a 

combination of these conditions.

Populations: The river or river corridor contains nationally or regionally important populations of 

indigenous or resident wildlife species dependent on the river environment. Of particular significance 

are species considered to be unique, and/or populations of Federal- or State-listed (or Candidate) 

Threatened, Endangered, or sensitive species. Diversity of species is an important consideration and 

could, in itself, lead to a determination of “outstandingly remarkable”. 
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Habitat: The river or river corridor provides exceptionally high quality habitat for wildlife of national or 

regional significance, or may provide unique habitat or a critical link in habitat conditions for Federalor State-listed (or Candidate) Threatened, Endangered, or sensitive species. Diversity of habitats is 

an important consideration and could, in itself, lead to a determination of “outstandingly remarkable”. 

Contiguous habitat conditions are such that the biological needs of the species are met.

Region of comparison

The region of comparison for wildlife value for the Jarbidge Field Office includes the Snake River Plain 

south to Interstate 80 in northern Nevada, which includes similar habitats as occur within the Field Office, 

but excludes pinyon-juniper communities characteristic of areas further to the south.

Criteria for evaluating wildlife value

Habitat Quality: Consider the presence, extent, and carrying capacity of a variety of wildlife habitats, 

including winter range, summer range, transition zones, travel corridors, and calving areas. Consider 

unique habitats or critical links in habitat for special status species. Areas with the greatest and best 

habitat, contiguous habitat, and habitat for special status species are of higher value.

Diversity of Species: Consider the number and variety of species present and the value of these 

species. Rivers with the greatest diversity of species, including special status species, are of higher 

value.

Abundance of Species: Rivers with the greatest number of wildlife within the river corridor are of 

higher value.

Outstandingly Remarkable Historical Value

Definition

The river or river corridor contains a river-related site or feature associated with a significant event, an 

important person, or a cultural activity of the past that was rare or unusual in the region. Many such sites 

are listed on the National Register of Historic Places. A historic site and/or feature is at least 50 years old 

in most cases.

Region of comparison

The region of comparison for historical value for the Jarbidge Field Office includes southern Idaho and 

northern Nevada.

Criteria for evaluating historical value

Significance: Consider segments that contain a site or feature associated with a historically significant 

event, person, or activity of the past (e.g., major trails, mining history, early explorers). River-related 

rare, unique, or unusual sites or features within the region are of higher value.

Site Integrity: Consider the presence of exceptional examples of architecture from a significant period 

in history; sites that are unmodified and retain their original character; and features that are 

exceptional examples within the region. River corridors that contain exceptional sites in exceptional 

condition are of higher value.

Education/Interpretation: Consider sites that have regional or national importance for interpreting 

significant historic events or people; sites that early and graphically reveal an interesting or unique 

history of the region; and sites that have the ability to attract visitors from outside the region. River 

corridors that represent “textbook” examples of a historic event or provide the best example of a 

historical culture or river-related event in the region are of higher value.

Listing/Eligibility: Consider corridors that contain sites or features that are currently listed in, or are 

eligible for, the National Register of Historic Places, or designated as a National Historic Landmark. 

Rivers with such features, particularly if in abundance, are of higher value.

Number of Historic Themes or Periods: River corridors that represent more then one historic theme or 

culture, may have been used concurrently by more than one historic cultural group, or have been 

used for rare or sacred purposes are of higher value.
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Outstandingly Remarkable Cultural Values

Definition

The river or river corridor contains a river-related site where there is evidence of current or historic 

occupation or use by Native Americans with unique or rare characteristics or exceptional human-interest 

value. Sites may be nationally or regionally important for interpreting prehistory, be rare, represent an 

area where a culture or cultural period was first identified and described, have been or are being used 

concurrently by two or more cultural groups, or have been or are being used by cultural groups for sacred 

purposes. Many such sites are listed on the National Register of Historic Places.

Region of comparison

The region of comparison for cultural values for the Jarbidge Field Office includes the southern 

Columbian Plateau and the northern Great Basin.

Criteria for evaluating cultural value

Significance: Consider evidence of significant occupation and use by Native Americans (e.g., hunting 

sites, ceremonial areas, fishing areas). Consider sites that have significant human interest value, are 

rare, or represent an area where a culture was first identified. Rivers with cultural significance to 

Native Americans are of higher value. Rivers that have substantial existing cultural use or that have 

been traditionally used as a Native American fishery are also of higher value. Rare, unique, or 

unusual sites or features within the region are of higher value.

Current Uses: River corridors containing sites or features that are significant to Native American 

populations today are of higher value.

Number of Cultures: River corridors that represent more than one cultural period, may have been 

used concurrently by more than one cultural group, or have been used for rare or sacred purposes 

are of higher value.

Site Integrity: Consider the presence of exceptional examples of Native American features from a 

significant period in history; sites that are unmodified and retain their original character; features that 

are in excellent condition and provide an exceptional example within the region. River corridors that 

contain exceptional sites in exceptional condition are of higher value.

Education/Interpretation: Consider sites that have regional or national importance for interpreting 

significant events, sites, or people; sites that clearly and graphically reveal an interesting or unique 

history of the region; and sites that have the ability to attract visitors from outside the region. River 

corridors that represent “textbook” examples of a Native American or other culture or provide the best 

example of a culture or river-related event in the region are of higher value. 

Listing/Eligibility: Consider corridors that contain sites or features that are currently listed in, or are 

eligible for, the National Register of Historic Places, or designated as a National Historic Landmark. 

Rivers with such features, particularly if in abundance, are of higher value.

Outstandingly Remarkable Vegetation/Ecological Values

Definition

Vegetation and ecological values may be judged on the relative merits of either populations or 

communities, or a combination of these conditions. The river or river corridor contains nationally or 

regionally important populations of indigenous plant species. Of importance are species considered to be 

unique or populations of Federal- or State-listed (or Candidate) Threatened, Endangered, or sensitive 

species. Diversity and number of species are also important. The river or river corridor may contain 

nationally or regionally important plant communities. Communities may be exceptionally high quality, 

unusual, or critical communities.

Region of comparison

The region of comparison for vegetative and ecological values for the Jarbidge Field Office includes the 

northern Great Basin and southern Snake River Plain.

Criteria for evaluating vegetation/ecological value

Species Diversity: Consider the presence, extent, and diversity of plant communities; ecological 

values that are critical to protection of biological diversity; and critical habitat for species conservation 
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(e.g., refugia). River corridors with the greatest diversity and importance to species conservation are 

of higher value.

Ecological Function: Rivers with rare or unique corridors that are critical and essential for species 

migration and genetic interaction are of higher value.

Rare Communities: Rivers with rare, sensitive, Threatened, or Endangered species and communities 

are of higher value.

Educational/Scientific: Consider vegetation and ecological values and features that clearly and 

graphically reveal an interesting or unique educational or scientific story of vegetative or ecological 

form and function. River corridors that represent “textbook” examples of plant and animal 

associations or ecological values and features in the region are of higher value.

Criteria for Tentative Classification of Eligible Segments

Eligible segments are assigned a tentative classification of wild, scenic, or recreational, based on the 

following criteria: 

Wild River

Free of impoundments.

Essentially primitive. Little or no evidence of human activity.

The presence of a few inconspicuous structures, particularly those of historic or cultural value is 

acceptable.

A limited amount of domestic livestock grazing or hay production is acceptable.

Generally inaccessible except by trail.

No roads, railroads, or other provision for vehicular traffic within the river area. A few inconspicuous 

existing roads leading to the boundary of the river area are acceptable.

Meets or exceeds Federal water quality criteria or Federally approved State water quality standards 

for aesthetics, propagation of fish and wildlife normally adapted to the habitat of the river, and primary 

contact recreation (swimming), except where water quality standards are exceeded by natural 

conditions.

Scenic River

Free of impoundments. 

Largely primitive and undeveloped. No substantial evidence of human activity.

The presence of grazing, hay production, or row crops is acceptable.

Accessible in places by road.

Roads may occasionally reach or bridge the river. The existence of short stretches of conspicuous or 

longer stretches of inconspicuous and well-screened roads or railroads paralleling the river area may 

be permitted.

Meets, exceeds, or is capable of being restored to meet Federal water quality criteria or Federallyapproved State water quality standards for aesthetics, for propagation of fish and wildlife normally 

adapted to the habitat of the river, and for primary contact recreation (swimming), except where water 

quality standards are exceeded by natural conditions.

Recreational River

Some existing impoundment or diversion; or, may have undergone some impoundment or diversion 

in the past.

The existence of low dams, diversions, or other modifications of the waterway is acceptable, provided 

the waterway remains free-flowing and generally natural and river-like in appearance.

Some development present; or, substantial evidence of human activity.

The presence of extensive residential development and a few commercial structures is acceptable.

Lands may have been developed for the full range of agricultural and forestry uses.

Readily accessible by road or railroad.

The existence of parallel roads or railroads on one or both banks as well as bridge crossings and 

other river access points is acceptable.
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Meets, exceeds, or is capable of being restored to meet Federal water quality criteria or Federallyapproved State water quality standards for aesthetics, for propagation of fish and wildlife normally 

adapted to the habitat of the river, and for primary contact recreation (swimming), except where water 

quality standards are exceeded by natural conditions.

Evaluating Eligibility on Jarbidge Field Office Rivers

BLM determined rivers eligible for inclusion into the National Wild and Scenic Rivers System through a 

process of elimination. If a river segment was not free flowing or did not potentially possess at least one 

outstandingly remarkable value, it was not evaluated further. 

In the fall of 2006, the RMP Interdisciplinary Team (ID Team) compiled an initial list of rivers that would be 

assessed for their free-flowing status and for the presence or absence of Outstandingly Remarkable 

Values (ORVs). These river segments included both perennial and intermittent rivers and streams, but not 

ephemeral waterways, as described in Section III. This initial step resulted in a list of 42 rivers or 

segments for further consideration (Attachment 2). 

An in-depth review of these 42 segments on November 29 and 30, 2006, focused on free-flowing criteria 

and ORVs. The ID Team conducted this review using their knowledge of the area, informed professional 

judgment, and available data and information on the river, river segment, environment, and the potential 

ORVs. Only rivers that met the free-flowing criteria were assessed for the presence of ORVs. As a result 

of that review, seven rivers were determined not to be free-flowing, and 24 additional rivers were 

determined not to possess ORVs (Attachment 3). The eligibility inventory and the remaining 11 rivers and

river segments were described in the March 2007 Jarbidge RMP newsletter, which was distributed to the 

Jarbidge RMP mailing list and posted on the RMP website.

The potential ORVs on the remaining 11 rivers and river segments were examined once again by the ID

Team on April 6, 2007; four rivers and river segments were found to not possess an outstandingly 

remarkable value when evaluated in the larger regional context (Attachment 3). The Idaho Department of 

Water Resources (IDWR) was briefed on the eligibility inventory process and preliminary results in June 

2007, in accordance with Memorandum of Understanding ID-273 .

Memorandum of Understanding between the Governor, State of Idaho and Regional Foresters, Northern and 

Intermountain Regions Forest Service and State Director, Idaho Bureau of Land Management regarding river 

planning efforts and Wild and Scenic River studies of Idaho’s rivers, dated February 14, 1991.

 Cougar Point Creek and the Jarbidge 

River were evaluated for their scenic quality as per the BLM Visual Resource Inventory Handbook, H8410-1, on November 2, 2007; both were rated as scenic quality “A.” 

Cougar Point Creek is an unnamed tributary of the Jarbidge River, East Fork; Cougar Point is the adjacent named 

landmark feature. 

As a result of this inventory and review process, seven rivers and river segments were identified as 

eligible for further study (Figure N-2; Table N-2; Attachment 3); IDWR was briefed on these segments 

during the fall of 2008. The BLM Four Rivers Field Office reviewed the evaluation of the Three Island 

Reach of the Snake River and concurred with the ID Team’s findings. The proposed boundary for each of 

the eligible segments is 0.25 mile from the ordinary high water mark on each side of the river or stream, 

averaging no more than 320 acres per river mile. Following eligibility determination, each segment was 

evaluated for its tentative classification (Table N-2). Section V provides a basic description and a map 

showing the location of each segment.

Until suitability determinations are reached, the Jarbidge Field Office will manage the values associated 

with the eligible river segments in a way that will not adversely affect the values contributing to the free 

flow, ORVs, and tentative classification. This management is in place until a river segment is determined 

suitable or nonsuitable during the suitability study phase. 
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Table N-2. Eligible River Segments – 2007 Evaluation

River Segment Description Length 

(miles)

Outstandingly 

Remarkable 

Values

Tentative 

Classification

Cougar Point Creek

Jarbidge Field Office boundary 

to East Fork, Jarbidge River 

confluence

1.0 Scenic Wild

Dave Creek Private land boundary to East 

Fork, Jarbidge River confluence 2.7 Fish Wild

Jarbidge River

Jarbidge Field Office boundary 

to East Fork, Jarbidge River 

confluence

10.2 Fish, Scenic Recreational

East Fork Jarbidge 

River, north 

Downstream private land 

boundary of Murphy Hot Springs 

to Jarbidge River confluence

2.2 Fish Recreational

East Fork Jarbidge 

River, south 

Jarbidge Field Office boundary 

to upstream private land 

boundary of Murphy Hot Springs

7.4 Fish Wild

Rocky Canyon 

Creek

Headwaters to North Fork, 

Salmon Falls Creek confluence 1.5 Wildlife Wild

Snake River, Three 

Island Reach

King Hill Bridge to Hwy 51 

Bridge 25.0

Recreational, 

Fish, Historical, 

Cultural

Recreational

Total 50.0
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Figure N-2. Eligible River Segments – 2007 Evaluation
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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Description of Eligible River Segments

This section provides a description and map of each of the seven river segments identified during the 

Jarbidge Field Office Wild and Scenic River Eligibility Determination, with a focus on values identified by 

the RMP Interdisciplinary Team as outstandingly remarkable, as well as the segment’s tentative 

classification as wild, scenic, or recreational. The river segments are presented in alphabetical order.

Cougar Point Creek

River Name Cougar Point Creek 

Segment Description Jarbidge Field Office boundary to Jarbidge River, East Fork confluence

Total Stream Length 1.0 mile

Free Flowing? Yes

Tentative Classification Wild; there are few or no human developments occurring along this 

segment. Access is limited and typically only by trail.

Outstandingly Remarkable Values

Scenic

Criteria met: diversity of view and special features. 

Cougar Point Creek originates in a boulder field near Cougar Point, where 

its water can be heard flowing beneath the boulders for approximately 300 

feet before it emerges to the surface. Cougar Point Creek then traverses 

rolling uplands to drop more than 1,000 feet to its confluence with the East 

Fork of the Jarbidge River 1 mile downstream. The diversity of view in both 

the foreground and background is generated from this steep creek 

gradient. From the river corridor, one can see 1,000 feet down into the 

canyon of the East Fork of the Jarbidge River, as well as the Jarbidge 

Mountains over 4,000 feet above. Foreground scenery is comprised of the 

boulder field, lichens, and dense vegetation in the creek corridor, with a 

mixture of mountain mahogany and aspen stands.

Cougar Point Creek rates as scenic quality “A” as described in the BLM 

Visual Resource Inventory Handbook, H-8410-1.

Recreational NA 

Geological NA 

Fish NA 

Wildlife NA 

Historical NA 

Cultural NA 

Vegetation/Ecological NA 

Comments

Not evaluated previously. 

Evaluation requested as part of general scoping comments by Idaho Conservation League and 

Western Watersheds Project. 
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Cougar Point Creek
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Dave Creek

River Name Dave Creek

Segment Description Private boundary to Jarbidge River, East Fork confluence

Total Stream Length 2.7 miles

Free Flowing? Yes

Tentative Classification Wild; there are few or no human developments occurring along this 

segment. Access is limited and typically only by trail.

Outstandingly Remarkable Values

Scenic NA 

Recreational NA 

Geological NA 

Fish

Criteria met: habitat quality, value of species, abundance of fish, and 

natural reproduction. 

Dave Creek, a tributary to the Jarbidge River, is crucial spawning, rearing, 

foraging, migratory, and overwintering habitat for bull trout within the 

Jarbidge River system (FWS, 2004). Dave Creek also contains the highest 

population of bull trout in the Jarbidge watershed, including both resident 

and migratory (fluvial) fish. These bull trout are the only species of fish 

within the planning area that are Federally listed as Threatened under the 

Endangered Species Act of 1973. 

The Jarbidge River system contains the southernmost existing population 

of bull trout in North America. Genetic analysis of bull trout in the Columbia 

River Basin indicates Jarbidge River bull trout have a shared evolutionarily 

history with populations in the upper Columbia River and Snake River but 

are genetically distinct. For more than 100 years, Jarbidge River bull trout 

have been geographically isolated from other populations in the Snake 

River by more than 150 miles of marginally suitable habitat and several 

impassable hydroelectric dams on the Snake River and diversion dams on 

the lower Bruneau River. 

Bull trout in the Jarbidge River system are considered significant because 

they occupy a unique and unusual ecological setting and their loss would 

result in a substantial modification of the specie’s range. The bull trout in 

the Jarbidge River are unique in that a portion of their habitat is in an area 

categorized as semi-arid desert. The Rocky Mountain juniper-dominated 

riparian zone interspersed with aspen on BLM portions of the Jarbidge 

River, which grades into aspen and limber pine on Forest Service land, is 

unique to the area. The majority of the other occupied habitat for bull trout 

is in other coniferous forest types (e.g. Douglas-fir, Engelmann spruce, 

and others). 

Wildlife NA 

Historical NA 

Cultural NA 

Vegetation/Ecological NA 

Comments

Not evaluated previously. 

Evaluation requested as part of general scoping comments by Idaho Conservation League. 

Evaluation of Dave Creek was specifically requested in scoping comments by Western Watersheds 

Project. 
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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Dave Creek
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

A-368

Jarbidge River 

River Name Jarbidge River

Segment Description Jarbidge Field Office boundary to Jarbidge River, East Fork confluence

Total Stream Length 10.2 miles

Free Flowing? Yes

Tentative Classification Recreational; improved gravel road with regular motorized traffic borders 

the entire segment. A steel bridge is present at the Buck Creek 

confluence; a wooden bridge is present at the Rattlesnake Creek 

confluence.

Outstandingly Remarkable Values

Scenic

Criteria met: diversity of view, special features, and cultural modifications.

This river segment is visually striking and particularly memorable. The 

foreground and background vary in texture, color, contrast, and depth. The 

diversity of colors results from the variety of trees, shrubs, and lichens 

within view. The high degree of relief and significant changes in geology 

within a short distance lend to the segment’s scenic quality. Special 

features include hoodoos, window rocks, and little arches. The road 

adjacent to this segment provides an opportunity for the public to view 

scenery similar to that found further downstream, as well as unique 

characteristics of this segment. Besides the road, other cultural 

modifications are minimal and do not detract from the scenic value of the 

segment. 

The Jarbidge River rates as scenic quality “A” as described in the BLM 

Visual Resource Inventory Handbook, H-8410-1.

Recreational NA 

Geological NA 

Fish

Criteria met: habitat quality, diversity of species, value of species, and 

natural reproduction. 

The Jarbidge River is an isolated watershed and contains a natural 

diversity of native fish species. Compared to other rivers in the region, the 

proportion of native to non-native species is unusually high, as there are 

few, if any, non-native species present.

The Jarbidge River system contains the southernmost existing population 

of bull trout in North America (FWS, 2004). Bull trout are the only species 

of fish within the planning area that are Federally listed as Threatened 

under the Endangered Species Act of 1973; the Jarbidge River contains 

one of six populations of bull trout identified for recovery. Genetic analysis 

of bull trout in the Columbia River Basin indicates Jarbidge River bull trout 

have a shared evolutionarily history with populations in the upper 

Columbia River and Snake River but are genetically distinct. For more 

than 100 years, Jarbidge River bull trout have been geographically 

isolated from other populations in the Snake River by more than 150 miles 

(240 km) of marginally suitable habitat, several impassable hydroelectric 

dams on the Snake River, and diversion dams on the lower Bruneau 

River. 

Bull trout in the Jarbidge River are considered significant because they 

occupy a unique and unusual ecological setting and their loss would result 

in a substantial modification of the species’ range. The bull trout in the 

Jarbidge River are unique in that a portion of their habitat is in an area 

categorized as semi-arid desert. The Rocky Mountain juniper dominated 
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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A-369

riparian zone and interspersed aspen on BLM portions of the Jarbidge 

River grades into aspen and limber pine on Forest Service land and is 

unique to the area. The majority of the other occupied habitat for bull trout

is in other coniferous forest types (e.g. Douglas-fir, Engelmann spruce, 

and others). The segment has spawning, over-wintering, and migratory 

habitat for bull trout. This reach is a key migration corridor between other 

bull trout bearing streams, and its deeper pools provide important overwintering habitat.

Wildlife NA 

Historical NA 

Cultural NA 

Vegetation/Ecological NA 

Comments

Previously evaluated in the 1976 Bruneau Wild and Scenic River Study and deemed ineligible due 

to the lack of recreational values. 

The Jarbidge River downstream from the confluence with the Jarbidge River, East Fork was 

recommended as suitable, with a tentative classification as wild, in the 1976 Bruneau Wild and 

Scenic River Study. 

The Humboldt-Toiyabe National Forest inventoried the upstream portions of this river as eligible. 

Evaluation requested as part of general scoping comments by Idaho Conservation League. 

Evaluation of Jarbidge River was specifically requested in scoping comments by Western 

Watersheds Project. 
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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Jarbidge River
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

A-371

Jarbidge River, East Fork, north of Murphy Hot Springs

River Name Jarbidge River, East Fork

Segment Description Downstream private boundary of Murphy Hot Springs to Jarbidge River 

confluence

Total Stream Length 2.2 miles

Free Flowing? Yes

Tentative Classification Recreational; human development is present and obvious, as many 

Murphy Hot Springs residences exist at the upstream end of this segment. 

Improved gravel road with regular motorized traffic borders the entire 

segment. Developed campsites are present along the segment. 

Outstandingly Remarkable Values

Scenic NA 

Recreational NA 

Geological NA 

Fish

Criteria met: habitat quality, diversity of species, value of species, and 

natural reproduction. 

The Jarbidge River, East Fork is an isolated watershed and contains a 

natural diversity of native fish species. Compared to other rivers in the 

region, the proportion of native to non-native species is unusually high, as 

there are few, if any, non-native species present. Native fish populations in 

the Jarbidge River, East Fork are largely in tact, and habitats between 

drainages are still connected.

The Jarbidge River system contains the southernmost existing population 

of bull trout in North America (FWS, 2004). Bull trout are the only species 

of fish within the planning area that are Federally listed as Threatened 

under the Endangered Species Act of 1973; the Jarbidge River contains 

one of six populations of bull trout identified for recovery. Genetic analysis 

of bull trout in the Columbia River Basin indicates Jarbidge River bull trout 

have a shared evolutionarily history with populations in the upper 

Columbia River and Snake River but are genetically distinct. For more 

than 100 years, Jarbidge River bull trout have been geographically 

isolated from other populations in the Snake River by more than 150 miles 

(240 km) of marginally suitable habitat, several impassable hydroelectric 

dams on the Snake River, and diversion dams on the lower Bruneau 

River. 

Bull trout in the Jarbidge River are considered significant because they 

occupy a unique and unusual ecological setting and their loss would result 

in a substantial modification of the species’ range. The bull trout in the 

Jarbidge River are unique in that a portion of their habitat is in an area 

categorized as semi-arid desert. The Rocky Mountain juniper dominated 

riparian zone and interspersed aspen on BLM portions of the Jarbidge 

River grades into aspen and limber pine on Forest Service land which is 

unique to the area. The majority of the other occupied habitat for bull trout

is in other coniferous forest types (e.g. Douglas-fir, Engelmann spruce, 

and others). The segment has spawning, over-wintering, and migratory 

habitat for bull trout. This reach provides a migration corridor between 

other bull trout bearing streams, and its deeper pools provide important 

over-wintering habitat. 

Wildlife NA 

Historical NA 

Cultural NA 

Vegetation/Ecological NA 
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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Comments

Previously evaluated in the 1976 Bruneau Wild and Scenic River Study and deemed ineligible due 

to the lack of recreational values. 

The Jarbidge River downstream from the confluence with the Jarbidge River, East Fork was 

recommended as suitable, with a tentative classification as wild, in the 1976 Bruneau Wild and 

Scenic River Study. 

Evaluation requested as part of general scoping comments by Idaho Conservation League. 

Evaluation of Jarbidge River, East Fork was specifically requested in scoping comments by 

Western Watersheds Project. 
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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Jarbidge River, East Fork, north 

of Murphy Hot Springs
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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Jarbidge River, East Fork, south of Murphy Hot Springs

River Name Jarbidge River, East Fork

Segment Description Jarbidge Field Office boundary to the upstream private boundary of 

Murphy Hot Springs

Total Stream Length 7.4 miles

Free Flowing? Yes

Tentative Classification Wild; there are few or no human developments occurring along this 

segment. Access is limited and typically only by trail.

Outstandingly Remarkable Values

Scenic NA 

Recreational NA 

Geological NA 

Fish

Criteria met: habitat quality, diversity of species, value of species, and 

natural reproduction. 

The Jarbidge River, East Fork is an isolated watershed and contains a 

natural diversity of native fish species. Compared to other rivers in the 

region, the proportion of native to non-native species is unusually high, as 

there are few, if any, non-native species present. Native fish populations in 

the Jarbidge River, East Fork are largely in tact, and habitats between 

drainages are still connected.

The Jarbidge River system contains the southernmost existing population 

of bull trout in North America (FWS, 2004). Bull trout are the only species 

of fish within the planning area that are Federally listed as Threatened 

under the Endangered Species Act of 1973; the Jarbidge River contains 

one of six populations of bull trout identified for recovery. Genetic analysis 

of bull trout in the Columbia River Basin indicates Jarbidge River bull trout 

have a shared evolutionarily history with populations in the upper 

Columbia River and Snake River but are genetically distinct. For more 

than 100 years, Jarbidge River bull trout have been geographically 

isolated from other populations in the Snake River by more than 150 miles 

(240 km) of marginally suitable habitat, several impassable hydroelectric 

dams on the Snake River, and diversion dams on the lower Bruneau 

River. 

Bull trout in the Jarbidge River are considered significant because they 

occupy a unique and unusual ecological setting and their loss would result 

in a substantial modification of the species’ range. The bull trout in the 

Jarbidge River are unique in that a portion of their habitat is in an area 

categorized as semi-arid desert. The Rocky Mountain juniper dominated 

riparian zone with interspersed aspen on BLM portions of the Jarbidge 

River grades into aspen and limber pine on Forest Service land. This 

vegetation community is unique to the area. The majority of the other 

occupied habitat for bull trout is in other coniferous forest types (e.g.

Douglas-fir, Engelmann spruce, and others). The segment has spawning, 

over-wintering, and migratory habitat for bull trout. This reach provides a 

migration corridor between other bull trout bearing streams, and its deeper 

pools provide important over-wintering habitat. 

Wildlife NA 

Historical NA 

Cultural NA 

Vegetation/Ecological NA 
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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Comments

Previously evaluated in the 1976 Bruneau Wild and Scenic River Study and deemed ineligible due 

to the lack of recreational values. 

The Humboldt-Toiyabe National Forest did not inventory the upstream portions of this river 

segment. 

Evaluation requested as part of general scoping comments by Idaho Conservation League. 

Evaluation of Jarbidge River, East Fork was specifically requested in scoping comments by 

Western Watersheds Project. 
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

A-376

Jarbidge River, East Fork, south 

of Murphy Hot Springs
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

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Rocky Canyon Creek

River Name Rocky Canyon Creek

Segment Description Headwaters to North Fork, Salmon Falls Creek confluence

Total Stream Length 1.5 miles

Free Flowing? Yes

Tentative Classification Wild; there are few or no human developments occurring along this 

segment. Access is limited and typically only by trail.

Outstandingly Remarkable Values

Scenic NA 

Recreational NA 

Geological NA 

Fish NA 

Wildlife

Criteria met: habitat quality. 

Rocky Canyon Creek supports a portion of the Great Basin population of 

the Columbia spotted frog, which is a Candidate species. The Great Basin 

population of Columbia spotted frogs was determined to warrant listing 

under the Endangered Species Act, but other species have priority at this 

time. Because habitat for spotted frogs throughout the region is 

fragmented and discontinuous, loss of any of the existing populations may

contribute to the need for listing as a threatened or endangered species.

Rocky Canyon Creek represents the easternmost extent of the Owyhee 

subpopulation within the Great Basin population (Engle and Munger, 

1998). Columbia spotted frogs have been documented in seven tributaries 

in the North Fork Salmon Falls Creek watershed (Columbia Spotted Frog 

Technical Team 2003). Rocky Canyon appears to be a stronghold for 

spotted frogs in this watershed; the spotted frog population in this segment 

is a source population within this watershed, dispersing young frogs to 

tributaries downstream. The loss of this population could result in spotted 

frogs being extirpated from the North Fork Salmon Falls Creek watershed.

Rocky Canyon Creek represents the only occupied habitat for Columbia 

spotted frogs in the Jarbidge Field Office, based on 2004-2005 monitoring. 

This segment contains perennial springs, active, stable beaver ponds, and 

beaked sedge communities providing high quality breeding, rearing, and 

overwintering habitat. In addition to being regionally significant spotted frog 

habitat, this segment contains a large assemblage of sensitive birds, 

including calliope hummingbird, Lewis woodpecker, as well as habitat for 

mountain quail and Columbian sharp-tailed grouse.

Historical NA 

Cultural NA 

Vegetation/Ecological NA 

Comments

Not evaluated previously. 

Evaluation requested as part of general scoping comments by Idaho Conservation League and 

Western Watersheds Project. 
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

A-378

Rocky Canyon Creek
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

A-379

Snake River, Three Island Reach

River Name Snake River, Three Island Reach

Segment Description King Hill Bridge to Highway 51 Bridge

Total Stream Length 

(Miles) 25.0

Free Flowing? Yes

Tentative Classification Recreational; human development is present and obvious. This segment 

can be accessed at multiple locations and is sometimes bordered by roads 

or railroads.

Outstandingly Remarkable Values

Scenic NA 

Recreational

Criteria met: experience quality, access, level of use, attraction, and length 

of season. 

This segment of the Snake River is a regionally popular fishing, hunting, 

and sightseeing area. Some form of recreational activity occurs yearround; four-season use is uncommon within the geographic region. There 

are numerous public access points providing for launching of motorized 

and non-motorized boats, nature study, bird watching, wildlife and scenery 

viewing, waterfowl hunting, and bank fishing opportunities.

Catch-and-release fishing of sturgeon is an unusual recreation experience 

for the region, and visitors come from outside the geographic region for 

this recreational experience. Catching 4- to 7-foot long fish is common, 

and larger fish are not unusual. 

This segment also offers a variety of hunting opportunities for water fowl 

and upland game birds.

Geological NA 

Fish

Criteria met: habitat quality, value of species, abundance of fish, natural 

reproduction, and size and vigor of fish. 

White sturgeon is a BLM Sensitive species.This is the largest fish species 

in the Columbia River system. Because of the free-flowing nature of this 

reach, sturgeon are able to reproduce naturally and do not require 

hatchery supplementation to sustain the population. In fact, this is the 

upper-most reach of Snake River with a self-sustaining population. While 

sturgeon habitat in this segment is not the best within its range, this 

segment contains the best sturgeon habitat upstream of the Hells Canyon 

Dam Complex.

Wildlife NA 

Historical

Criteria: significance, education/interpretation, and listing/eligibility. 

The primary historical significance of this segment of the Snake River is its 

relationship to the Oregon Trail, which is designated as a National Historic 

Trail. A portion of the Oregon Trail directed emigrants across the river at 

Three Island Crossing, which is located within this reach. A re-enactment 

of this crossing occurs annually, providing a significant opportunity for 

education and interpretation. This segment hosts the only crossing reenactment on the Snake River. 

Cultural

Criteria: significance and listing/eligibility. 

This segment contains large riverside camps and important Native 

American fishing sites, primarily for salmon and steelhead. Several sites 

within this segment are eligible for listing on the National Register. These 
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

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A-380

cultural sites are rare and significant in that they are in Federal ownership. 

Most of the cultural sites along the Snake River are on private land.

Vegetation/Ecological NA 

Comments

Not evaluated previously. 

Evaluation requested as part of general scoping comments by Idaho Conservation League. 

This reach is adjacent to the Three Island Crossing State Park in Glenns Ferry, Idaho, and borders 

the Snake River Birds of Prey National Conservation Area. 
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

A-381

Snake River, Three 

Island Reach
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

A-382

Attachment 1: Jarbidge Field Office Wild and Scenic Rivers 

Inventory Interdisciplinary Team

Name Title

BLM Staff

Aimee Betts Supervisory Natural Resource Specialist

Richard Bupp Recreation Technician

Kate Forster Fisheries Biologist

Sheri Hagwood Botanist

Amanda Hoffman Writer/Editor

Jim Klott Wildlife Biologist

Arnie Pike Supervisory Rangeland Management Specialist

Bonnie Ross Geographic Information System (GIS) Specialist

Jeff Ross Archaeologist

Max Yingst Outdoor Recreation Planner

Cooperating Agency Representatives

Mike McDonald Wildlife Biologist (Idaho Department of Fish and 

Game)

Kevin Wright Rangeland Management Specialist (Idaho State 

Department of Agriculture)
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

A-383

Attachment 2: Rivers in the Jarbidge Field Office Inventoried for 

Eligibility

The following rivers within the Jarbidge Field Office were included in the inventory for WSR eligibility. 

Where no specific reach is denoted, the entire river, from headwaters to confluence, was assessed where 

it crossed public land within the Jarbidge Field Office. 

River segments were identified through several sources, which are listed for each river in the table below. 

All perennial and intermittent rivers and streams included on Jarbidge Field Office geographic information 

system (GIS) layers were included in the inventory. The Nationwide Rivers Inventory (NPS, 2004) and the 

State of Idaho Comprehensive Water Plan are also sources of rivers to inventory; however, the only rivers 

included on these source lists have already been recommended as suitable. In addition, inventory of 

several rivers was requested during public scoping for the Jarbidge RMP. Rivers that were studied during 

previous inventory efforts or are adjacent to eligible segments on adjoining lands were also studied.

Table N-3. Jarbidge Field Office Rivers Inventoried for Eligibility

River

Source for ConsiderationA 

GIS

WWP

ICL

Bruneau

Bennett

Burley

HTNF

Bear Creek X X X 

Big Flat Creek X X X 

Bruneau River, above Black Rock Crossing X X X X 

Bruneau River, below Hot Creek X X X X 

Bruneau River, East Fork (Clover Creek) X X X 

Buck Creek X X X 

Cedar Creek Reservoir X X 

Cedar Creek, above reservoir X X X 

Cedar Creek, below reservoir X X 

Cherry Creek X X X 

China Creek X X X 

Columbet Creek X X X 

Cougar Creek X X X 

Cougar Point Creek X X X 

Dave Creek X X X 

Deadman Creek (ID) X X

Deadman Creek (NV) X X X 

Deadwood Creek X X X 

Deep Creek X X X 

Deer Creek (ID) X X X 

Deer Creek (NV) X X X 

Devil Creek X X 

Dorsey Creek X X X 

House Creek X X X 

Jarbidge River X X X X X 

Jarbidge River, East Fork, north of Murphy Hot Springs X X X X 

Jarbidge River, East Fork, south of Murphy Hot Springs X X X X 

Player Creek X X X 

Poison Creek X X X 

Pole Creek X X X 

Rocky Canyon Creek X X X 

Sailor Creek X X 
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

A-384

River

Source for ConsiderationA 

GIS

WWP

ICL

Bruneau

Bennett

Burley

HTNF

Salmon Falls Creek Reservoir X X X 

Salmon Falls Creek, below Balanced Rock X X X X 

Salmon Falls Creek, North Fork X X X 

Shack Creek X X X 

Snake River, Three Island Reach X X 

Snake River, Bliss Dam Reservoir X X X 

Snake River, Upper and Lower Salmon Falls Projects X X X 

Spring Creek X X X 

Taylor Creek X X X 

Three Creek X X X A GIS: Jarbidge Field Office GIS stream layer; 

 WWP: requested in scoping by Western Watersheds Project; 

 ICL: requested in scoping by Idaho Conservation League; 

 Bruneau: previously evaluated in Bruneau Wild and Scenic River Study Report (BOR, 1976); 

 Bennett: previously evaluated in Draft Bennett Hills RMP (BLM, 1991); 

 Burley: previously evaluated by the Burley District in1993 and finalized in 2009 (USFS, 2009); 

 HTNF: adjacent to eligible segment identified in Humboldt-Toiyabe National Forest Eligibility Report (USFS, 2005). 
Jarbidge Proposed RMP/Final EIS Appendix N: Wild and Scenic River Eligibility Determination

A-385

Attachment 3: Jarbidge Field Office Wild and Scenic River 

Inventory Worksheet

Where no specific reach is denoted, the entire river, from headwaters to confluence, was assessed where 

it crossed public land.

River Free 

flowing?

Outstandingly 

Remarkable 

Values?

Eligible? Tentative 

Classification

Rivers not meeting eligibility criteria following 2006 and 2007 reviews 

Bruneau River, below Hot Creek No Not Evaluated 

Further No NA 

Cedar Creek Reservoir No Not Evaluated 

Further No NA 

Deadman Creek (ID) No Not Evaluated 

Further No NA 

Salmon Falls Creek, below Balanced 

Rock No Not Evaluated 

Further No NA 

Salmon Falls Creek Reservoir No Not Evaluated 

Further No NA 

Snake River, Bliss Dam Reservoir No Not Evaluated 

Further No NA 

Snake River, Upper and Lower Salmon 

Falls Projects No Not Evaluated 

Further No NA 

Bear Creek Yes None No NA 

Big Flat Creek Yes None No NA 

Bruneau River, above Black Rock 

Crossing Yes None No NA 

Bruneau River, East Fork (Clover Creek) Yes None No NA 

Buck Creek Yes None No NA 

Cedar Creek, above reservoir Yes None No NA 

Cedar Creek, below reservoir Yes None No NA 

Cherry Creek Yes None No NA 

China Creek Yes None No NA 

Columbet Creek Yes None No NA 

Cougar Creek Yes None No NA 

Deadman Creek (NV) Yes None No NA 

Deadwood Creek Yes None No NA 

Deep Creek Yes None No NA 

Deer Creek (ID) Yes None No NA 

Deer Creek (NV) Yes None No NA 

Devil Creek Yes None No NA 

House Creek Yes None No NA 

Poison Creek Yes None No NA 

Pole Creek Yes None No NA 

Sailor Creek Yes None No NA 

Spring Creek Yes None No NA 

Taylor Creek Yes None No NA 

Three Creek Yes None No NA 

Dorsey Creek Yes None No NA 

Player Creek Yes None No NA 

Salmon Falls Creek, North Fork (Timber 

Canyon) Yes None No NA 
Appendix N: Wild and Scenic River Eligibility Determination Jarbidge Proposed RMP/Final EIS

A-386

River Free 

flowing?

Outstandingly 

Remarkable 

Values?

Eligible? Tentative 

Classification

Shack Creek Yes None No NA 

Rivers meeting eligibility criteria following 2007 review

Cougar Point Creek Yes Scenery Yes Wild

Dave Creek Yes Fish Yes Wild

Jarbidge River Yes Scenery, Fish Yes Recreational

Jarbidge River, East Fork, north of 

Murphy Hot Springs Yes Fish Yes Recreational

Jarbidge River, East Fork, south of 

Murphy Hot Springs Yes Fish Yes Wild

Rocky Canyon Creek Yes Wildlife Yes Wild

Snake River, Three Island Reach Yes

Recreation, 

Fish, Historic 

Resources, 

Cultural 

Resources

Yes Recreational
Jarbidge Proposed RMP/Final EIS Appendix O: Upland and Riparian Area Reference Areas

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APPENDIX O: UPLAND AND RIPARIAN AREA 

REFERENCE AREAS

Introduction The September 30, 2005 Stipulated Settlement Agreement (SSA) in the case of Western Watershed 

Project v. Ellis et al. (Case No. CV-04-181-S-BLW) (D. Idaho) discusses the need to identify, maintain, 

and/or establish reference areas in the Jarbidge Resource Management Plan (RMP). Paragraphs 16 and

16D of the SSA state:

“In preparing the Jarbidge RMP and EIS, BLM will follow the provisions of FLPMA, BLM’s land use 

planning regulations, BLM’s Manual, and BLM’s Land Use Planning Handbook (H-1601-1, rev. 3/11/05).

BLM will address issues identified through scoping including (but not limited to) the following issues, 

which are of importance to Plaintiff...

BLM will identify, maintain, and/or establish reference areas (i.e., exclosures and/or isolated areas) 

including upland and riparian areas, that are representative of a variety of ecosystem components, 

vegetation types and elevational gradients, that are ungrazed by livestock in order to allow comparisons 

for future evaluation of livestock grazing impacts on public lands of the Jarbidge Field Office.”

This SSA statement provides direction for developing and implementing an experimental design for 

evaluating livestock grazing impacts in the Jarbidge RMP.

Experimental Design

The SSA states the purpose of the reference areas established in the RMP is to “allow comparisons for 

future evaluation of livestock grazing impacts on public lands of the Jarbidge Field Office.” Generally 

speaking, in order to test the effects of livestock grazing, one of two different treatments must be applied:

Livestock grazing treatment: Introduce livestock grazing to previously ungrazed areas and compare 

these areas with areas that remain ungrazed or

Livestock grazing removal treatment: Remove livestock grazing from previously grazed areas and

compare these areas with areas that continue to be grazed.

More than 1.3 million acres of public lands in the planning area are currently grazed by livestock. These 

acres occur across the full range of elevational gradients and vegetation types present in the planning 

area; in contrast, the 51,000 acres that are currently not grazed by livestock do not occur across the full 

range of elevational gradients and vegetation types in the planning area. As a result, the RMP 

Interdisciplinary Team (ID Team) determined a design with a livestock grazing removal treatment would 

be more appropriate in the planning area.

Using a paired-plot experimental design, where a plot with the livestock grazing removal treatment is 

paired with an adjacent grazed plot with similar vegetation and in a similar condition, improves the ability 

to detect an effect by minimizing the variation between plots due to factors other than the livestock 

grazing removal treatment. The absence of grazing would be the only difference between management of 

the paired plots.

The grazed plot to be paired with each ungrazed reference area will be identified following the signing of 

the Record of Decision (ROD) for the Jarbidge RMP. Maps 11 through 15 present possible locations for 

reference areas that followed the process outlined below.
Appendix O: Upland and Riparian Area Reference AreasJarbidge Proposed RMP/Final EIS

A-388

Sampling Design

Stratification

The SSA directs that reference areas be identified, maintained, or established for “upland and riparian 

areas that are representative of a variety of ecosystem components, vegetation types and elevational 

gradients.” These criteria lend themselves to the development of a stratified sampling design on the basis 

of vegetation type and elevation. The purpose of stratification is to partition an area in a way that the units 

within a stratum are as similar as possible.

The Jarbidge RMP identifies systems for stratifying the planning area on the basis of vegetation type and 

elevation. The Vegetation Sub-Group (VSG) concept aggregates the 55 vegetation communities in the 

planning area into six groups based on dominant vegetation and community structure. Using VSGs as the 

basis for establishing reference areas representative of a variety of vegetation types creates strata that 

are relatively homogeneous and allows more replication within a VSG than would be possible within each 

of the 55 vegetation communities. In addition, this stratification method ensures representation across the 

range of major vegetation types in the planning area. For the purposes of selecting reference areas, 

Unvegetated VSG was not included, as the vegetation communities (e.g., breaks, barren areas, and sand 

dunes) only occur on approximately 2% of the planning area, less than any other VSG, and are generally 

located in areas inaccessible to livestock (e.g., canyons, areas unavailable for livestock grazing). VSG 

acreages were based on the 2016 projected vegetation composition due to the large acreage mapped as

Recent Burn following the 2007 and 2011 fire season. 

The Vegetation Management Area (VMA) concept stratifies the planning area into four west-to-east zones 

based on potential natural community (PNC), elevation, and mean annual precipitation. Using VMAs as 

the basis for establishing reference areas representative of a variety of elevational gradients creates 

strata that are relatively homogeneous with respect to PNC, elevation, and mean annual precipitation and 

ensures representation across the range of elevations in the planning area.

The VSG and VMA concepts were used to stratify the planning area for the selection of reference areas

for upland vegetation types. Combining these concepts yields 20 VSG-VMA combinations, or 20 different 

strata within which upland reference areas were selected. The number of reference areas to be randomly 

selected within each stratum was determined through proportional allocation. That is, the proportion of the 

total number of reference areas in a stratum would be the same as the size of the stratum in proportion to 

the size of the planning area (e.g., a stratum comprising 10% of the planning area would receive 10% of 

the reference areas for upland vegetation types).

Because riparian areas are not identified within VSGs, only the VMA concept was used to stratify the 

planning area for the selection of reference areas for riparian areas. Riparian reference areas were 

selected from among riparian areas associated with the fish-bearing streams in the planning area. For the 

purposes of identifying polygons within which random points could be selected, the 300-foot buffers on

either side of the fish-bearing streams identified in the Aquatic and Riparian Management Strategy as 

Category 1 Riparian Conservation Areas were used. There were four different strata (VMAs A, B, C, and 

D) within which riparian reference areas were selected. The number of riparian reference areas to be 

randomly selected within each stratum was determined through proportional allocation.

Number and Size of Reference Areas

The SSA does not specify how many reference areas must be established or how large the reference 

areas must be. Three different size options for reference areas were identified for consideration and 

analysis: pasture-sized (average of 4,700 acres), 160 acres, and 40 acres; three different numbers of 

reference areas were also identified: 46, 62, and 85.

Pasture-sized reference areas were identified as the upper size limit in response to scoping comments. 

Creating reference areas from existing pastures would minimize the amount of new fencing required to 

establish reference areas and would have the least impact on wildlife behavior of the three sizes 

considered. However, because of its large size,it may be difficult to ensure the only difference between 

the reference area and its adjacent grazed counterpart is the removal of livestock grazing. Based on 
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geographic information system (GIS) analysis, there are 459 pastures in the planning area. A sample of 

10% of the pastures in the planning area (46 pastures) would provide a reasonable sample of the 

planning area and a reasonable data collection workload. In addition, removing livestock grazing from 

more than 10% of the pastures in the planning area would likely have substantial impacts to livestock 

grazing that would be difficult to justify solely on the basis of establishing study plots for evaluating the 

effects of livestock grazing.

The 160-acre size reference area was identified as an intermediate size. This size would have some of 

the benefits of larger reference areas and would have a higher likelihood of being managed in a similar 

manner as its adjacent grazed counterpart. For the 160-acre reference areas, a sample that 

encompassed approximately 10% of the acreage in the planning area would provide a reasonable sample 

of the planning area, resulting in 85 reference areas. The workload required to collect data on this number 

of reference areas would be reasonable and removing livestock grazing from this acreage would have 

fewer impacts to livestock grazing than removing grazing from entire pastures.

The smallest reference area size considered was 40 acres. The 40-acre size was identified as the 

smallest size where edge effects due to fencing (e.g., weed accumulation, moisture accumulation) would 

not affect the majority of the reference area and would still be large enough to be used by wildlife in the 

same ways the higher acreage areas would provide. Because the purpose of reference areas is to be 

able to evaluate impacts of livestock grazing, reference areas need to be large enough to be used by 

wildlife in a similar manner as their grazed counterparts. The minimum 40-acre size also allows for 

breeding bird and small mammal trapping to be conducted in the reference area using the typical 200m x 

240 m trapping grid of 10 x 12 traps; this grid size can be placed well inside a 40-acre reference area, 

minimizing the potential to be affected by edge effects from fences. Each 40-acre reference area was 

identified from acreage within each 160-acre reference area.

Finally, the RMP ID Team developed an option that included 40-acre reference areas within the Native 

Grassland and Native Shrubland VSGs, riparian areas, and Non-Native Perennial VSGs that have burned 

multiple times in the last 20 years (based on GIS analysis of fire history in the Jarbidge Field Office). 

Thus, reference areas in the Annual and Non-native Understory VSGs and Non-Native Perennial VSG 

that did not burn multiple times in the last 20 years would not be reference areas. This option yielded a 

total of 62 reference areas.

As noted above, the stratification process for selecting upland and riparian reference areas was slightly 

different. As a result, the total number of reference areas needed to be split between upland and riparian 

reference areas prior to allocating reference areas to each stratum. Because riparian areas are not 

identified within VSGs and because their ecological importance is larger than the proportion of acres on 

which they occur in the planning area, the proportion of riparian reference areas is larger than the 

proportion of riparian areas in the planning area. For the pasture-sized reference areas, 40 were allocated 

for uplands and six for riparian areas. For the 160-acre and 40-acre reference areas, 75 were allocated 

for uplands and 10 for riparian areas; for the smaller sample size of 40-acre reference areas, 52 were 

allocated for uplands and 10 for riparian areas.

Table O-1 and Table O-2 display the allocation of reference areas to each stratum for upland and riparian 

areas, respectively.
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Table O-1. Stratification and Proportional Allocation of Upland Reference Areas by Vegetation 

Management Area and Vegetation Sub-Group

VSG # of Reference Areas 

Pasture-Sized 160- and 40-Acre

VMA A – Wyoming Sagebrush/Indian Ricegrass

Annual 2 4 

Non-Native Perennial 3 5 

Non-Native Understory 0 0 

Native Grassland 1 2 

Native Shrubland 1 1 

VMA A Total 7 12

VMA B – Wyoming Sagebrush/Thurber’s Needlegrass

Annual 1 2 

Non-Native Perennial 5 10

Non-Native Understory 1 2 

Native Grassland 6 11

Native Shrubland 5 10

VMA B Total 18 35

VMA C – Wyoming Sagebrush/Bluebunch Wheatgrass

Annual 0 0 

Non-Native Perennial 2 3 

Non-Native Understory 1 1 

Native Grassland 4 8 

Native Shrubland 3 5 

VMA C Total 10 17

VMA D – Idaho Fescue (High Elevation) 

Annual 0 0 

Non-Native Perennial 0 0 

Non-Native Understory 0 1 

Native Grassland 2 4 

Native Shrubland 3 6 

VMA D Total 5 11

All VMAs

Annual 3 6 

Non-Native Perennial 10 18

Non-Native Understory 2 4 

Native Grassland 13 25

Native Shrubland 12 22

Grand Total 40 75

 Reference areas were not established in areas with no vegetation community data or in areas mapped as the

Unvegetated VSG.
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Table O-2. Stratification and Proportional Allocation of Riparian Reference Areas by Vegetation 

Management Area

VMA 

# of Reference Areas 

Pasture-Sized 160- and 40-Acre

VMA A 1 1 

VMA B 2 3 

VMA C 1 2 

VMA D 2 4 

Total 6 10

Random Selection Process 

A random selection process was used to determine the pastures within which reference areas would be 

located within each stratum. To begin the random selection process, random points within the planning 

area were generated within each VMA using GIS; the points within each VMA were then arranged in 

random order. The pastures within which these points were located were then evaluated for whether they 

met criteria to be selected as a reference area and, for the 160- and 40-acre reference areas, the specific 

location of the reference area. The selection process differed slightly for selecting the pasture-sized

reference areas and selecting the 160- and 40-acre reference areas. The processes are discussed 

separately below.

Pasture-Sized Reference Areas

Three selection criteria were used to determine whether a pasture within which a random point was 

located would be suitable as a pasture-sized reference area. The first criterion was meeting the allocation 

of reference areas within each stratum described in Table O-1 and Table O-2 above. If the assigned 

number of reference areas for a VSG or riparian area in a VMA had already been selected, additional 

reference areas within that stratum were not identified, and any additional random points within that 

stratum were discarded.

The second criterion related to pasture size. Pastures smaller than 500 acres were excluded from 

consideration to yield reference areas that would be substantially larger than the 160- and 40-acre 

reference areas; pastures larger than 20,000 acres would have livestock grazing removed from a 

maximum of 10,000 acres to reduce impacts to livestock grazing.

The final criterion related to the number of pastures in an allotment. There is a large amount of variation in 

the number of pastures within each allotment in the planning area, ranging from allotments with only one 

pasture to allotments with more than 20 pastures. In order to reduce the impact to livestock grazing within 

any particular allotment, the following rules were applied:

 No pastures would be selected as reference areas in one- or two-pasture allotments, 

One pasture could be selected as a reference area in three- to nine-pasture allotments, 

Two pastures could be selected as reference areas in 10- to 19-pasture allotments, 

Three pastures could be selected as reference areas in 20- to 29-pasture allotments, and

Four pastures could be selected as reference areas in 30- to 39-pasture allotments. 

Once an allotment met the limit for the number of reference areas it was allowed, any additional random 

points within that allotment were discarded.

Overall, this process resulted in 46 reference areas comprised of the entirety of 46 pastures; the average 

size of each reference area was 4,700 acres.

160- and 40-Acre Reference Areas

A similar process was used to select the pastures within which 160- and 40-acre reference areas would 

be located. However, there was no limit to the number of 160- and 40-acre reference areas that could be 
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selected within an allotment. In addition, only one reference area could be established in a pasture, so 

once a reference area was identified within a pasture, any additional random points within that pasture 

were discarded.

Once a pasture was identified for a reference area within a particular VSG, the RMP ID Team examined 

that pasture in detail using a variety of GIS data to ensure the pasture was suitable and determine the 

specific location for the reference area. The ID Team used the following guidelines in this process:

The reference area can be anywhere in the randomly selected pasture as long as it contains the 

same VSG as determined by the random point; the reference area may include more than one VSG.

Minimize the amount of fencing needed by tying into existing fences or canyon rims to the extent 

practical.

Minimize the number of reference area placed adjacent to private land.

To the extent practical, do not place reference areas in a location that would eliminate the only water 

source in a pasture.

To the extent practical, in Native Grassland and Native Shrubland VSGs, place reference areas in 

areas that minimize new access routes.

To the extent practical, locate reference areas in areas that would be less likely to create traps or 

hinder livestock movement between pastures.

Although the reference areas are depicted as squares, the actual shape on the ground may change 

when the exclosure is constructed, though the size would be similar; shapes that minimize the 

perimeter-to-area ratio would be preferred.

Consider the potential for replication if adjacent pastures have reference areas.

Consider the amount of private land in the pasture, particularly in smaller pastures.

Consider other limitations, such as Wilderness Study Areas, Oregon Trail, areas available for crosscountry motorized vehicle use, wild horses, or sage-grouse leks.

Three pastures were replaced using additional random points due to the amount of State and/or private 

land within the pasture. All other selected pastures were determined to be suitable, and locations for 160- 

acre and 40-acre reference areas were digitized using GIS. Each 40-acre reference area was located 

within the 160-acre reference area in that pasture following the same guidelines. Even though the size of 

each identified reference area may have minor deviations from 160 acres and 40 acres, the average sizes 

of the reference areas following this process were still 160 and 40 acres.

Additional GIS work was done to determine the location of riparian reference areas. The linear nature of 

riparian areas does not lend itself well to strict 160- and 40-acre size restrictions. Instead, large and small 

versions of each riparian reference area were delineated to correspond with the 160- and 40-acre upland 

reference areas; the large and small riparian reference areas averaged 270 acres and 110 acres, 

respectively. The large riparian reference areas included the entire length of the riparian area within the 

selected pasture; the boundary was delineated based on easily identifiable physical or map features (e.g., 

canyon rims, topographic contours, existing fences). The small riparian reference areas included 1/4 of

the length of the riparian area in the large riparian reference areas. Riparian reference areas sometimes 

include fenced areas or areas with natural barriers outside the randomly selected pasture in order to 

prevent livestock entry into the reference area.

Implementation and Monitoring

A timeline for installation of reference areas will be developed following the signing of the ROD and will be 

contingent on the availability of funding.

The final locations for the reference areas may vary from what is depicted on Maps 11 through 15. 

Additional factors that will be considered in the final placement of reference areas are:

Quality, location, and condition of current exclosures in meeting the needs of a reference area.

Current location of fences to reduce amount of fencing required. 

Vegetation community quality.
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Access to allow for monitoring.

Distance away from areas of disturbance.

Livestock watering locations.

A strategy outlining the data that will be collected on the paired plots, as well as the methods for and 

frequency of collection, will be developed following the signing of the ROD. All monitoring of reference 

areas will be contingent on available funding and staff.
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APPENDIX P: RESPONSE TO COMMENTS FROM THE DRAFT RMP/EIS

This appendix contains selected public comments received during the public comment period on the Jarbidge Draft Resource Management Plan 

(RMP)/Environmental Impact Statement (EIS) (September 2010) along with the BLM’s responses to those comments as per 40 CFR 1503.4. The 

BLM received more than 28,000 letters, faxes, and e-mails (collectively referred to as comments) from individuals, organizations, industry 

associations, and State and local agencies. Most of the letters, 27,715 of them, were form letters. Public comments covered a wide array of 

interests.

The Jarbidge RMP Interdisciplinary team reviewed every letter, fax, and email and identified both substantive and non-substantive comments 

during the content analysis process. Every comment was read and considered, even though not every comment is restated here. Many comments 

are restated directly from the letters, faxes, and emails. Some comments have been combined with similar comments, while other comments have 

been modified slightly for clarity.

Substantive comments: (1) question, with reasonable basis, the accuracy of information in the Draft EIS, (2) question, with reasonable basis, the 

adequacy of, methodology for, or assumptions used in the environmental analysis, (3) present new information relevant to the analysis, (4) present 

reasonable alternatives other than those already included in the Draft EIS, (5) result in changes or revisions to one or more the alternatives, or (6) 

result in factual corrections. All substantive comments, along with a response, have been included in this appendix. This appendix also includes 

other comments that did not fit as substantive or non-substantive, but the interdisciplinary team determined could be resolved by some means or a 

response could aid in understanding the land use planning process for the Jarbidge RMP.

Non-substantive comments: (1) state a preference for or against the preferred plan or an alternative without reasons, (2) agree or disagree with 

BLM policy (3) agree or disagree with previous decisions with no justification or supporting data, (4) are not relevant to the planning area; or (5) 

are vague, open-ended questions.

Category Comment Response

Adaptive 

Management

The approach in the Draft RMP/EIS contains important 

elements of a monitoring and adaptive management plan in 

Appendix P. However, there are additional elements that 

should be included in the adaptive management process 

(triggers and schedules). We refer the BLM to the referenced 

sections of the Jack Morrow Hills Coordinated Activity Plan as 

an example. Further, we recommend that the RMP set out a 

comprehensive plan that applies in the same manner to 

mineral leasing, wilderness characteristics, wild and scenic 

river segments and Areas of Critical Environmental Concern. 

This plan should be based on available science and include 

the following:

Adaptive management should start small and pace 

development with level of learning. In the early stages of 

The term “adaptive management” describes a broad array of 

approaches that involve learning while doing, but the use of the 

phrase is not always appropriate. The monitoring described in 

Appendix P of the Draft RMP/EIS was not an adaptive 

management plan but was simply a description of intervals and 

standards per regulations in 43 CFR 1610.4-9 for 

implementation and effectiveness monitoring based on resource 

and resource uses. The Final EIS moved Appendix P of the Draft 

RMP/EIS into Chapter 2 under the Monitoring Implementation 

and Effectiveness of RMP Decisions section. 

The Final EIS establishes goals and objectives for managing 

resources in the planning area. An annual congressional 

appropriation determines funding for treatments, personnel, or 

other resources to implement the plan.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

implementation, actions that may cause environmental 

impact should be limited until such a time where inventory, 

monitoring, and analysis can confirm that the resources 

are trending toward the desired goal.

Define in detail what the adaptive management process 

will and will not address. BLM should prepare a monitoring 

protocol that guides whether BLM plans to use adaptive 

management with specific resources. The Draft RMP/EIS

should also describe the resources and specific indicators 

that will be measured and used to determine adaptive 

management so that the public can provide meaningful 

comments on BLM’s proposed approach to adaptive 

management.

Funding for adaptive management should not be 

dependent on shifting the financial and personnel burden 

to various user interests or other cooperating community 

groups.

Adaptive 

Management

BLM should prepare detailed analysis of current inventory 

status to accompany the Draft RMP/EIS that clearly specifies 

resources and what activities may affect them and their 

baseline condition, and then identify indicators for resources or 

groups of resources that will demonstrate the effects of 

management decisions. The Draft RMP/EIS should also 

identify those resources or locations for which BLM lacks 

inventory data and establish a timeframe to accomplish 

inventories for resources or locations where data is lacking.

The Final EIS, Chapter 3, describes the baseline conditions and 

data deficiencies for each Resource and Resource Use. 

Conditions described in Chapter 3 were then used as the 

baseline by which to analyze and describe the effects of 

management actions described in each alternative in Chapter 4. 

Adaptive 

Management

The BLM should include defined limits of acceptable change in 

resource conditions and specify actions to be taken if change 

reaches or exceeds those limits. For all indicators, the RMP 

should identify the range of acceptable change from the 

baseline condition, using best available science, and specify 

those actions that will be taken in the event that unacceptable 

levels of change are identified.

Baseline condition, goals, and objective described in Chapters 3 

and 2, respectively, are at the planning area scale. Defining or 

describing limits of acceptable change to make a reasoned 

choice among alternatives in the Final EIS is unnecessary. The 

Final EIS uses goals and objectives to identify and implement 

management actions or treatments that will help achieve 

resource objectives during project planning. 

Adaptive 

Management

A “fallback” plan is needed in case monitoring or other aspects 

of the adaptive management process do not occur. Adaptive 

management must include requirements for when and how the 

proposed outcome will be reevaluated if it is not being met. 

The agency’s ability to reevaluate or amend desired outcomes 

should not be the fallback if either the adaptive management 

The RMP does not specify an adaptive management plan but 

would allow BLM to apply adaptive management when and 

where appropriate to meet resource objectives. There is no need 

for a fallback plan as suggested in the comment. 
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Category Comment Response

process is not working or outcomes are not being met. BLM 

should build into the Final EIS provisions to address situations 

based on new information, circumstances, regulatory 

requirements, or discontinued agency funding for monitoring 

that would trigger a plan amendment or revision under a new 

EIS.

Adaptive 

Management

Allow the public to actively and effectively participate in the 

adaptive management process. The planning area is broad, 

involving millions of acres; citizens interested in the resources 

governed by the Final EIS reside across States; and, 

involvement of citizens in an adaptive management processes 

can be both timely and costly to individuals. In addition to 

seeking funding commitments for monitoring and analysis, 

BLM should seek funding for citizen participation. BLM should 

also begin planning now as to how citizen involvement in 

adaptive management will meet the requirements of the 

Federal Advisory Committee Act, and do not allow such 

planning be left only to those citizens or community groups 

wishing to collaborate or advise BLM.

The RMP process is not an adaptive management process. 

Policy, rules and regulations, as well as the NEPA process 

provide for public participation and involvement in land 

management planning and decisions. The BLM has allowed for 

public involvement and participation during the preparation of 

this land use plan.

Securing funding for citizen participation is beyond the scope of 

this planning effort.

Affected 

Environment

The description of the Affected Environment in the Draft 

RMP/EIS is inadequate. Intermountain Range Consultants 

submitted comments to the Analysis for Management Situation, 

highlighting errors and omissions therein, including irrational 

and unwarranted statements and actions. Many of these show 

up without any comment/correction in Chapter 3 of the Draft 

RMP/EIS. The lack of reasonable articulation of the Affected 

Environment makes it inadequate for us to comment and/or for 

BLM to identify any alternatives, to identify a preferred 

alternative, to assess the impacts of any alternative, and now 

to select/adopt a Proposed Plan.

The BLM recognizes that there were errors in the Analysis of the 

Management Situation (AMS). The AMS provided a “snap shot 

in time” approach to describe resource conditions in 2007. 

Resource conditions have changed since 2007 due to large fires 

(e.g., Murphy Complex, Long Butte, and Kinyon Road) and other 

factors. The Final EIS used updated information to account for 

these changing resource conditions. 

Affected 

Environment

The “environmental baseline” that is the premise of the Draft 

RMP/EIS Chapter 3 (and Chapter 4) is undisturbed rangeland 

at its potential natural condition (e.g., p. 3-28). However, this is 

a false premise. The true environmental baseline is, or should 

be, what BLM decided to manage “for” (or recognized would 

occur) under the 1987 Jarbidge RMP/EIS.

The environmental baseline is a description of current conditions 

within the planning area. The purpose of the environmental 

baseline is to provide a point of reference to measure the 

effectiveness of management actions proposed within the Final 

EIS for analysis. Chapter 3 of the Final EIS contains a 

description of the environmental baseline.

Affected 

Environment

In the Draft RMP/EIS, BLM never showed if it met any 

objectives of its old plan. BLM must clearly explain and map all 

allocations, goals, objectives, and management actions (or 

RMPs guide future management actions and subsequent sitespecific implementation decisions. They establish goals and 

objectives for resource management and the measure needed to 
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Category Comment Response

their equivalent) of the 1987 Jarbidge RMP/EIS, and show the 

public what has been met, and what has not been met. It must 

explain what occurred.

BLM must include a detailed analysis of fish, wildlife, habitat 

and population, soils, vegetation, watershed, water quality, 

recreation and all other goals, objectives, management actions 

or the equivalent of the 1987 Jarbidge RMP/EIS and 

demonstrate how they were or were not met, and provide 

causal factors for these failures. The Draft RMP/EIS has a 

greatly inadequate evaluation of the No Action Alternative, 

which in some components related to sage-grouse and some 

other wildlife species actually provides more conservation 

requirements than the uncertain and loose Preferred 

Alternative (Alternative IV-B). There is no adequate analyses of 

the shortcomings of the No Action Alternative, and since so 

many parts of most of the “new” alternatives are similar to what 

is occurring now this must be revealed and analyzed in detail.

achieve these goals. Section 202(c) of the Federal Land Policy 

and Management Act of 1976 lists requirements of the BLM in 

developing RMPs. These requirements do not include an 

analysis of the effectiveness of the prior RMP provisions. In any 

event, the impacts of implementing the prior RMP provisions 

throughout the new planning period is analyzed in the No Action 

Alternative.

Air Quality The goal in the Air and Atmospheric Values section of Chapter 

2 should recognize the impacts that are likely or potentially 

likely to result from climate change. Such impacts include 

changes in the quantity and character of precipitation, and 

such changes will impact air quality, water quality, habitat, 

wildlife and vegetation. Changes resulting from climate change 

may cause impacts such as drought or flood. Infrastructure and 

natural structures currently operating to provide for water 

quality and other benefits may become overwhelmed by. 

Changes from outside the planning the planning area may 

impact the planning area. Energy sources within the planning 

area may impact it. Energy sources within the planning area 

may be generators of criteria pollutants impacting air quality. In 

addition, energy sources, such as wind energy, may provide 

local power resulting in less production from nearby 

conventional energy sources within or outside the planning 

area lessening the impact of criteria pollutants.

The Final EIS analyzed the direct, indirect, and cumulative 

impacts of the alternatives on climate change. The Air and 

Atmospheric Values section of Chapter 4 included data that 

shows actions within the planning area are not likely to add to 

climate change. 

Air Quality Energy sources within the planning area, such as wind energy, 

would be a significant contributor toward the global mitigation 

of greenhouse gases, and such potential should be more 

visibly recognized in the management goals, objectives, and 

The Final EIS addressed renewable energy in the objectives and 

management actions in the Land Use Authorizations section of 

each alternative in Chapter 2.
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Category Comment Response

management actions.

Air Quality BLM management actions need to include the development of 

mitigation plans for air resources, wildlife resources, water 

resources, etc. with respect to a reasonable range of climate 

change predictions, as well as plans to forestall these impacts 

as much as possible based on actions that could be taken 

within the planning area, such as the development of 

greenhouse gas-free energy sources.

The Final EIS identified management actions to achieve the 

goals and objectives. Mitigation plans as suggested for air 

resources, wildlife resources, water resources, would be 

developed at the project level. 

Air Quality In the Chapter 3 Air Quality section, the BLM should include 

the Environmental Protection Agency’s intent to regulate 

carbon dioxide, a greenhouse gas, as a pollutant.

BLM did not include the Environmental Protection Agency’s 

(EPA) intent to regulate carbon dioxide as a pollutant in Chapter 

3 because it is not relevant to the Final EIS. 

On March 27, 2012, the EPA issued a proposed rule for a 

Carbon Pollution Standard for New Power Plants. This proposal 

applies only to new fossil-fuel-fired electric utility generating units

and would set limits on the amount of carbon pollution that future 

power plants could emit. The planning area has a low possibility 

of being considered for a new fossil-fuel-fired electric generating 

plant. 

Air Quality BLM ignores assessment of dust produced from grazing, 

roads, and developments under the Draft RMP/EIS

alternatives. Dust can result in early snowmelt and loss of 

glaciers.

The Air Quality section of the Draft RMP/EIS and the Final EIS in 

Chapter 4 discussed the potential sources and impacts of windblown and fugitive dust from soil-disturbing vegetation 

treatments and travel and transportation (which included roads). 

Dust was not the indicator for the analysis of air quality; rather it 

was particulate matter (PM2.5 and PM10) of which dust is a 

contributor. 

Alternatives There is no valid analysis of the effectiveness of any of the 

measures that are claimed as protections or mitigation in 

conserving sage-grouse, recreational uses, or the other values 

of the public lands that large-scale wind or other energy or 

development rights-of-way would greatly impair. There is no 

analysis of the effectiveness of claimed "constraints" in the 

context of the large habitat and population losses in the 

planning area. 

The Final EIS established broad-scale goals and objectives to 

guide future, site-specific implementation decisions. The 

alternatives in the Final EIS identify areas that are available for 

various uses such as those authorized under rights-of way. 

Understanding the effectiveness of constraints, especially at the 

planning scale, is often difficult. The effects of wind or 

geothermal energy development on sagebrush, sage-grouse, 

and other resources are difficult to discern because development 

has been too recent to identify immediate or lag effects (Knick 

and Connelly, 2011b). Alternative VI (Proposed RMP) does not 

allow commercial wind and solar energy development inside the 

sage-grouse management area (LA-VI-A-4). Chapter 4 of the 

Final EIS describes the predicted effects from the management 
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actions (i.e. constraints) prescribed for each of the alternatives.

Alternatives The alternative selected must recognize the threats to multiple 

use, wildfire, noxious weeds and invasive species, and 

administrative closures and curtailments while also recognizing 

the opportunities, economic activity in the four county area, 

open space, and long-term, sustainable use. Who better to 

take care of the resources than the resource users?

All alternatives in the Final EIS recognize threats to resources 

and resource uses. Each alternative has management actions to 

meet the goals of protecting property and natural resources from 

wildfire; preventing, eliminating, or controlling noxious weeds 

and invasive plants; and providing for motorized and nonmotorized access that would balance resource protection and 

uses.

Areas of 

Critical 

Environmental 

Concern

Designate the expanded version of the Bruneau-Jarbidge Area 

of Critical Environmental Concern (ACEC) as identified in

Alternative IV, and designate the larger version of the Jarbidge 

Foothills ACEC as identified in Alternative IV-A. To better 

protect the relevant and important values identified consider 

including the following conservation measures:

Prohibit off-road vehicle cross-country travel.

Do not allow leasable mineral entry.

Disallow renewable energy development if it could harm 

sensitive or endangered species.

Place wind turbines at least 5 miles from sage-grouse leks.

The Final EIS analyzed a range of Area of Critical Environmental 

Concern (ACEC) designations. The expanded Bruneau-Jarbidge 

ACEC and expanded Jarbidge Foothills ACEC were not included 

in Alternative VI (Proposed RMP). After review of the nominated 

ACECs, the BLM determined that special management attention 

is not required because standard or routine management 

prescriptions, combined with specific resource management 

actions in Alternative VI, are sufficient to protect the relevant and 

important values from damage and degradation. 

Areas of 

Critical 

Environmental 

Concern

Close all Areas of Critical Environmental Concern (ACECs) to 

wind energy development, as was originally the policy in the 

Wind Energy Development Programmatic Environmental 

Impact Statement. Wind energy development is incompatible

with the values proposed to protect wildlife, botanical, cultural, 

and scenic values for the ACECs.

The Record of Decision for the Wind Energy Programmatic 

Environmental Impact Statement established the previous policy 

that Areas of Critical Environmental Concern (ACECs) were to 

exclude wind energy development. Instruction Memorandum 

2009-043, issued December 19, 2008, changed this policy to 

ensure consideration of the purpose and specific environmental 

sensitivities for which the ACEC designation took place. This 

planning effort addresses and analyzes ACEC land use 

restrictions individually, including restrictions to wind energy 

development. ACECs do not universally exclude wind energy 

development. Individual ACEC management prescriptions could 

allow or exclude wind energy site testing, monitoring, or wind 

energy development. 

Areas of 

Critical 

Environmental 

Concern

The BLM and Forest Service have no statutory authority to 

designate and manage areas such as critical waterways, 

geological areas, unroaded areas, botanical areas, and 

national scenic areas. Any such designations cannot, by law, 

have an effect on the multiple use and sustained yield 

mandates for management of national forests. The proposed 

alternative should delete these "special designations".

The BLM, under Title II of the Federal Land Policy and 

Management Act of 1976, has the authority and obligation to 

analyze, and if determined suitable, to manage Areas of Critical 

Environmental Concern to preserve relevant and important 

values.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Areas of 

Critical 

Environmental 

Concern

The east boundary of Salmon Falls Creek Area of Critical 

Environmental Concern needs some specific coverage. Once 

the decision was made to expand the ramifications of the EIS 

document into the Burley District, even just to the west rim, 

there would seem to be an ethical, if not a legal obligation to 

address the ecological, socio-economic and other possible 

direct and indirect impacts on the immediately outward laying 

BLM lands and on private property. 

A possible transmission route centered some 0.25 - 0.50 mile 

to the east of Salmon Falls Creek would impact a Wild and 

Scenic River corridor. So, exactly how wide is that corridor and 

why is it not being shown to the public via the current EIS? 

The 1990 amendment to the Jarbidge RMP and the Twin Falls 

Management Framework Plan (MFP) designated the stretch of 

Salmon Falls Creek Canyon between Salmon Dam and 

Balanced Rock Park (excluding non-BLM-managed land) as an 

Area of Critical Environmental Concern (ACEC). The west 

boundary of the ACEC is the west canyon rim in the planning 

area; the east boundary is the east canyon rim in the Burley 

Field Office. Even though the lands included in the ACEC lie 

within two BLM Field Offices, they were considered as a unit and 

analyzed together in the 1990 land use plan amendment. The 

Jarbidge RMP does not create management direction that would 

alter direction established in the Twin Falls MFP (i.e. direction for 

the Burley Field Office).

The Wild and Scenic River (WSR) corridor extends outward from 

the high water mark 0.25 mile. The Draft RMP/EIS inadvertently

omitted the information on the width of the WSR corridor. The 

Final EIS revised this information in the WSR section of Chapter 

2.

Areas of 

Critical 

Environmental 

Concern

The BLM should remove all special designations from the 

planning area, and reinstitute the full and complete multiple 

use policies of the past.

Removal of all special designations from the planning area does 

not fulfill the purpose and need as described in Chapter 1 of the 

Final EIS. Special designations are a tool used to aid in multipleuse management. Special designations help to preserve and 

protect certain lands in their natural condition, provide food and 

habitat for fish and wildlife, and provide for outdoor recreation.

Areas of 

Critical 

Environmental 

Concern

The BLM should clarify the use or modification of the Lily 

Grade by large commercial vehicles.

Use of a paved county road by commercial vehicles is beyond 

the scope of this planning effort. 

Areas of 

Critical 

Environmental 

Concern

The introductory description of Areas of Critical Environmental 

Concern (ACECs) is helpful to the reader but should include 

the regulatory requirement that any resource management 

plan amendment approved by the BLM State Director must 

include the general management practices and uses, including 

mitigation measures, identified to protect Areas of Critical 

Environmental Concern (ACECs) (43 CFR 1610.7-2[b]).

General management practices and mitigation measures

identified to protect Areas of Critical Environmental Concern 

were included in Chapter 2 of the Final EIS.

Areas of 

Critical 

Environmental 

The Final EIS should cite to the September 3, 2010 Federal 

Register Notice listing nominated Areas of Critical 

Environmental Concern (ACECs) and specify the resource use 

The Notice of Availability published in the Federal Register on 

September 3, 2010 included nominated Area of Critical 

Environmental Concern designations and specified a 90-day 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-402

Category Comment Response

Concern limitations that would occur if they were formally designated. 

The Notice failed to specify the 60-day period for public 

comment on the ACEC designations. See 43 CFR 1610.7- 

2(b). BLM should clarify that the comments on the Draft 

RMP/EIS will satisfy the 60-day limitation on comments specific 

to the ACEC.

public comment period (which was later extended an additional 

60 days). The requirements in 43 CFR 1610.7-2(b) were met. 

Areas of 

Critical 

Environmental 

Concern

The other species and resources of concern that the Jarbidge 

Foothills Area of Critical Environmental Concern (ACEC) would 

address are found across much of the planning area. Sagegrouse, mule deer, redband trout, and cultural resources 

should be managed the same across the planning area. No 

one area when it comes to these resources should be 

sacrificed, thus making an ACEC designation for the protection 

of these resources in only one particular area is unacceptable. 

The Final EIS analyzed the Jarbidge Foothills Area of Critical 

Environmental Concern (ACEC) as part of the range of 

alternatives. Alternative VI (Proposed RMP) did not include this 

ACEC designation. 

Areas of 

Critical 

Environmental 

Concern

Slickspot peppergrass in the Inside Desert area does not 

warrant Area of Critical Environmental Concern protection. The 

slickspot peppergrass conservation agreement did not list

livestock as a major threat. Major threats were listed as fire and 

invasive species. Livestock grazing can reduce fire fuel loads 

reducing the risk of fire and subsequent invasion of harmful 

species. 

The Inside Desert Area of Critical Environmental Concern 

(ACEC) was nominated by BLM in accordance with BLM Manual 

1613; the Idaho Conservation Data Center suggested BLM 

consider special management for slickspot peppergrass. The 

Inside Desert ACEC includes measures designed to protect 

slickspot peppergrass and its habitat. The US Fish and Wildlife 

Service has listed livestock grazing as a secondary or 

aggravating threat to slickspot peppergrass. Grazing can amplify 

degraded habitat conditions created by the primary threats (i.e. 

fire and invasive species). The Final EIS included the Inside 

Desert ACEC as part of the range of alternatives. Alternative VI 

(Proposed RMP) did not include this ACEC designation. 

Areas of 

Critical 

Environmental 

Concern

On p. 2-6 of the Draft RMP/EIS, under the Areas of Critical 

Environmental Concern (ACECs) section, it simply lists Salmon 

Falls Creek. It should stipulate the ACEC only applies to the 

area upstream of Balanced Rock Park. The same applies on p. 

2-8 under ACECs and on p. 2-11 for ACECs.

Pages 2-6 through 2-11 of the Draft RMP/EIS are from the 

summary of alternatives section. A detailed description and map 

of the Salmon Falls Creek Area of Critical Environmental 

Concern is provided in Appendix M: Evaluation of Nominated 

Areas of Critical Environmental Concern in the Final EIS. 

Areas of 

Critical 

Environmental 

Concern

On p. 208 of the Draft RMP/EIS, we question ACEC-NA-MA23. Why would you restrict any mechanical fire suppression 

within the Salmon Falls Creek Area of Critical Environmental 

Concern? Why not allow mechanical fire suppression to put the 

fire out as quickly as possible. We also oppose closing the 

area to motorized vehicles.

The Salmon Falls Creek Area of Critical Environmental Concern 

(ACEC) includes only areas within the canyon (rim to rim)

between Salmon Falls Dam and Balanced Rock Park. The 1990 

ACEC designation established the referenced restrictions. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Areas of 

Critical 

Environmental 

Concern

On p. 3-80 of the Draft RMP/EIS, under Jarbidge Foothills Area 

of Critical Environmental Concern-Small Boundary, we are 

assuming you are referring to the portion of Salmon Falls 

Creek above Salmon Dam.

Yes, we are referring to Salmon Falls Creek above Salmon Falls 

Dam. 

Areas of 

Critical 

Environmental 

Concern

In the Draft RMP/EIS on p. A-258, Appendix W, under "Fish or 

Wildlife Resource" Salmon Falls Creek Area of Critical 

Environmental Concern; Are you referring to stream alteration 

from the Salmon Dam that was built in 1911? We take 

exception to the statement that this stretch of the river is in 

poor habitat and has resulted in a high degree of 

sedimentation. It is not caused by what limited traffic is out 

there and road closures are not necessary.

In the Draft RMP/EIS, the relevant and important values 

assessment for the Salmon Falls Creek Area of Critical 

Environmental Concern (ACEC) (Appendix W, p. A-258), 

identified the natural processes in Salmon Creek below the Dam 

as altered due to a lack of flushing flows and invasive plants. 

The assessment does not identify roads as a sediment source 

for Salmon Falls Creek. The 1990 ACEC designation identified 

the Salmon Falls Creek ACEC as closed to motorized vehicles 

(ACEC-NA-MA-21). The Final EIS included the ACEC north and 

south of Lily Grade to remain closed to motorized vehicle use 

(ACEC-VI-MA-32).

Areas of 

Critical 

Environmental 

Concern

One of the State's primary concerns with Alternative IV-B is the 

nomination of several Areas of Critical Environmental Concern 

across the planning area. The State rejects the notion that 

broad-scale curtailment of multiple-use activities within these 

designated areas will better protect the resource.

The Final EIS considers a range of Area of Critical 

Environmental Concern (ACEC) designations. ACEC 

designation does not automatically curtail multiple-use activities

within these areas. Management associated with an ACEC 

designation is specific to the relevant and important values 

present. ACEC designation provides proactive measures to 

maintain or enhance relevant and important values as well as 

measures necessary to protect those values from impacts from 

future activities.

Areas of 

Critical 

Environmental 

Concern

The Middle Snake River Area of Critical Environmental 

Concern (ACEC) is not necessary since the BLM has complete 

authority over the management of listed species under the 

Endangered Species Act and regulations for the authorization 

of uses in this area. The other concern with this ACEC is that it 

has incorporated private and State lands within the boundary 

as mapped. These lands may be impacted long term and 

encumbered by restrictive management from adjacent and 

surrounding BLM lands.

The Final EIS analyzed the Middle Snake River Area of Critical 

Environmental Concern (ACEC) as part of the range of 

alternatives. Alternative VI (Proposed RMP) did not include this 

ACEC designation. 

The Final EIS revised maps to depict both BLM-managed and 

non-BLM-managed lands.

Areas of 

Critical 

Environmental 

Concern

The historical analysis within the Draft RMP/EIS clearly 

demonstrates wildland fire and unmanaged dispersed 

motorized recreation as the major risks to achieving the stated 

goals for the planning area. The BLM Preferred Alternative

(Alternative IV-B) and the associated special management 

area designations (e.g., Areas of Critical Environmental 

After publication of the Draft RMP/EIS comments were received 

and reviewed by the Interdisciplinary Team, Alternative VI 

(Proposed RMP) was developed using Alternative IV-B as a 

baseline. Alternative VI focuses on actively restoring the 

resiliency of sagebrush steppe ecosystem structure and function 

through restoration projects and enhanced fire management 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-404

Category Comment Response

Concern, Wilderness Study Areas, non-Wilderness Study Area

with wilderness characteristics) do little to address either of 

these major risks while unnecessarily limiting active 

management and land use options. 

while balancing resource protection and uses within the planning 

area. Special designations were included in Alternative VI as a 

tool to preserve and protect lands in their natural condition, 

provide food and habitat for fish and wildlife, and provide for 

outdoor recreation. Transportation and travel in Alternative VI 

would be limited to designated routes in the majority of the 

planning area except for areas open to cross-country motorized 

vehicle use in the Deadman and Yahoo Special Recreation 

Management Areas.

Areas of 

Critical 

Environmental 

Concern

If special management areas (i.e., Areas of Critical 

Environmental Concern) are to be designated, acquisition of inholdings from willing private/endowment owners should occur 

prior to implementing such special management areas.

Area of Critical Environmental Concern (ACEC) designations 

occur with the signing of the Record of Decision by the BLM 

Idaho State Director and apply only to BLM-managed lands. Any 

acquisition of private or State endowment lands is dependent on 

the availability of funding and the willingness of landowners to 

sell or exchange their lands. It is not feasible to tie ACEC 

designations to the acquisition of in-holdings.

Areas of 

Critical 

Environmental 

Concern

We believe the overall and specific differences between subalternative IV-A and IV-B for the Jarbidge Foothills and Inside 

Lakes Areas of Critical Environmental Concern (ACECs) 

represent a substantial opportunity to decrease risks to special 

status species and improve the likelihood of attaining water 

quality standards. To take advantage of this opportunity for 

improved environmental benefits we recommend the BLM 

strongly consider committing to Alternative IV-A's ACEC 

designations.

Neither the Jarbidge Foothills nor the Inside Lakes Areas of 

Critical Environmental Concern were included in Alternative VI 

(Proposed RMP). The BLM determined that special 

management attention is not required because standard or 

routine management prescriptions, combined with specific 

resource management actions in Alternative VI, are sufficient to 

protect the relevant and important values from damage and 

degradation. In particular, the management actions associated 

with Special Status Species and Water Resources in Alternative 

VI appear adequate to protect these resources.

Areas of 

Critical 

Environmental 

Concern

The Sagebrush Sea Area of Critical Environmental Concern 

(ACEC) is not necessary since the BLM has complete authority 

over the management of listed species under the Endangered 

Species Act and regulations for the authorization of uses in this 

area. Fire has been and continues to be the biggest threat to 

this area. New information indicates that livestock is a viable 

tool to reduce fine fuel which would lessen fire occurrence. An 

ACEC could be very restrictive to the BLM and not allow

changes in management on a site specific and a landscape 

scale to reduce fires with the use of livestock throughout the 

year. 

The Final EIS analyzed the Sagebrush Sea Area of Critical 

Environmental Concern (ACEC) as part of the range of 

alternatives. Alternative VI (Proposed RMP) did not include this 

ACEC designation. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-405

Category Comment Response

Areas of 

Critical 

Environmental 

Concern

Areas of Critical Environmental Concern (ACECs) are 

designations that place an undue amount of importance on 

endangered species, wildlife, and resources. There must be a 

balance. An ACEC has the power to severely restrict any use 

that could possibly affect the land and resource. ACECs are 

not appropriate in an area that should be managed for all 

users. Any ACEC, for slickspot peppergrass or otherwise, 

violates the spirit and intent of the Omnibus Public Land 

Management Act of 2009, this Act intended that the released 

lands would become multiple-use lands.

Section 202 of the Omnibus Public Land Management Act of 

2009 (OPLMA; Sec.1503-3-B-ii; 43 U.S.C. 1712) directs that 

BLM manage released Wilderness Study Areas in accordance 

with the applicable land use plan. BLM is required by law 

(Federal Land Policy and Management Act of 1976), regulation 

(43 CFR 1610.7-2) and policy (BLM Manual 1613) to determine 

if nominated Areas of Critical Environmental Concern (ACECs) 

meet relevance and importance criteria and require special 

management to protect their historical, cultural scenic, or natural 

resource values (Appendix M: Evaluation of Nominated Areas of 

Critical Environmental Concern). The Owyhee Initiative and the 

resultant OPLMA applies only to lands within Owyhee County 

and is silent on the subject of ACECs. The Final EIS analyzed a 

range of ACEC nominations. After review of public comments, 

four ACECs were included in Alternative VI (Proposed RMP). 

Two of the ACECs remain designated (Salmon Falls Creek and 

Sandpoint), one ACEC is a reduction of the existing BruneauJarbidge ACEC to the Upper Bruneau Canyon ACEC, and one 

ACEC is new (Lower Bruneau Canyon). 

Areas of 

Critical 

Environmental 

Concern

My major concern is with the Jarbidge Foothills Area of Critical 

Environmental Concern in Alternative IV-B. If this area is truly 

an area that warrants remaining the same, then we should not 

be restricting the current management that has created this 

situation. Further regulation and restrictions would only 

encumber current management efforts and jeopardize the 

opportunity for continued success.

The Jarbidge Foothills Area of Critical Environmental Concern is 

not included in Alternative VI (Proposed RMP), but was analyzed 

as part of the range of alternatives.

Areas of 

Critical 

Environmental 

Concern

BLM must reconsider its entire Area of Critical Environmental 

Concern analysis, as all relevant and important values are now 

much greater for sage-grouse.

The Final EIS revised sage-grouse information in Chapters 2, 3, 

and 4. 

Areas of 

Critical 

Environmental 

Concern

BLM must prepare a population viability analysis to examine 

outcomes and time to extinction of populations under 

Alternatives I, II, III, IV, and V. Do this to manage for viable 

populations of slickspot peppergrass, Bruneau Dunes tiger 

beetles, and other sensitive, rare and imperiled species.

It is not necessary for the BLM to develop its own viability 

studies for listed plants/animals. The US Fish and Wildlife 

Service (FWS) with respect to anadromous fish, develop viability 

studies to analyze the likelihood a species will warrant protection 

under the Endangered Species Act. The BLM responds to a 

species listing by drafting a biological assessment. The FWS 

review the assessment to ensure that the BLM’s proposed 

management will not jeopardize the continuation of the species. 

In this case, the BLM has entered into a candidate conservation 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-406

Category Comment Response

agreement with the FWS for slickspot peppergrass. 

Areas of 

Critical 

Environmental 

Concern

Do not designate Juniper Butte Training Range and other US 

Air Force Lands (emitter sites and no-drop sites) as an Area of 

Critical Environmental Concern. 

The BLM did not consider designating Areas of Critical 

Environmental Concern on US Air Force-managed lands. The 

Final EIS revised maps to depict both BLM-managed and nonBLM-managed lands.

Areas of 

Critical 

Environmental 

Concern

The Salmon Falls Creek Area of Critical Environmental 

Concern (ACEC) is not necessary since the BLM has complete 

authority over the management of listed species under the 

Endangered Species Act and regulations for the authorization 

of uses in this area. Most of this area is naturally protected 

from most uses and could be managed with the exclusion of 

uses without being an ACEC. 

The BLM determined, after review of public comments, to

include the existing Salmon Falls Creek Area of Critical 

Environmental Concern (ACEC) in Alternative VI (Proposed 

RMP). The area contains resources that meet the relevance and 

importance criteria for ACECs (BLM Manual 1613) and warrants 

special management prescriptions to protect those resources. 

Resources include scenic quality, redband trout, and upland 

vegetation. Redband trout are a Type 2 BLM Sensitive species

and are not protected by the Endangered Species Act. 

Areas of 

Critical 

Environmental 

Concern

The BLM should clarify that wind energy development could be 

accommodated in the Jarbidge Foothills Area of Critical 

Environmental Concern (ACEC) similar to the way the ACEC 

would accommodate exploration and development of salable 

minerals through the existing 2005 best management 

practices.

The Final EIS analyzed the Jarbidge Foothills Area of Critical 

Environmental Concern (ACEC) as part of the range of 

alternatives. Alternative VI (Proposed RMP) did not include this 

ACEC designation. 

Areas of 

Critical 

Environmental 

Concern

Designation of an Area of Critical Environmental Concern of 

sufficient size to conserve sage-grouse is fully supported by 

new scientific information from the Knick and Connelly (2009)

Monograph Studies in Avian Biology to the recent Wyoming, 

Idaho and other studies on fence collisions and impacts. 

Recent Eco-regional Assessments all highlight the grave 

threats that sage-grouse, pygmy rabbit and other sagebrushdependent species are under.

After review of the nominated Sagebrush Sea Area of Critical 

Environmental Concern, the BLM determined that special 

management attention is not required because standard or 

routine management prescriptions, combined with specific 

resource management actions in Alternative VI (Proposed RMP), 

are sufficient to protect the relevant and important values from 

damage and degradation. The management actions proposed in 

the Water Resources, Special Status Species, Riparian Areas 

and Wetlands, Fish and Wildlife, Cultural Resources, Livestock 

Grazing, Transportation and Travel, and Land Use 

Authorizations sections appear to provide adequate protection 

for the area’s relevant and important values.

Chapter 4 The environmental consequences section needs to 

acknowledge the potential for and consequence of secondary 

impact of resource management during use authorization. 

Apply the same consideration to the cumulative impact 

evaluation.

The Final EIS included analyses in Chapter 4 of direct, indirect, 

and cumulative impacts of resource management actions on 

resources uses. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-407

Category Comment Response

Chapter 4 Elko County, Nevada strongly urges the BLM to re-evaluate 

the ecological, environmental, economic, cultural, and historical 

direct and indirect adverse impacts that the Draft RMP/EIS will 

produce on not only the planning area but also the regions of 

southern Idaho and northeastern Nevada.

The Final EIS revised the analysis of environmental 

consequences found in Chapter 4. The current model used 2010 

Impact Analysis for Planning (IMPLAN) data to analyze 

economic contributions and the economic effects of the 

alternatives. This model assessed the direct economic effects of 

BLM authorized uses within the planning area (which includes 

local businesses) in addition to indirect effects (impact from the 

additional inter-industry spending from the direct impact) and 

induced effects (impact from additional household expenditure 

resulting from the direct and indirect impacts). 

Climate and 

Meteorology

The Climate and Meteorology section in Chapter 3 of the Draft 

RMP/EIS describes periods of drought “in southern Idaho”, 

citing Cook and others (2004) and IDWR (2001). The Cook 

document does not on its face make any such statement, and 

is purportedly based upon tree ring re-construction of drought 

periods. The lack of clarity of this document does not provide 

the reviewer a reasonable opportunity to verify the Draft 

RMP/EIS’s representation of the document. The applicability of 

Cook and others (2004) to the planning area is irrational and/or 

unwarranted. 

BLM recognizes that the Cook and others (2004) citation does 

not on its face state periods of drought in southern Idaho. The 

Final EIS replaced this citation with the Historic Palmers Drought 

Severity Index (PDSI). PDSI is a measurement of dryness based 

on precipitation and temperature and is an effective index for 

determining long-term drought. 

Climate and 

Meteorology

The Draft RMP/EIS’s representation of IDWR (2001) is 

generally accurate as to what is reported in the cited work. 

However, IDWR (2001) also states, “The earliest welldocumented shortages occurred in the 1920’s and 30’s during 

the Dust Bowl era. These historic records are still used today 

as a benchmark in evaluating potential problems. Idaho has 

not been without problems since then, however. ... Overall, 

conditions between 1987 and 1993 in the southwestern part of 

Idaho have displaced the Dust Bowl period of the 1930’s as the 

most severe period of drought on record.” The planning area is 

located in the southwestern portion of Idaho. Therefore, any 

analysis of data and other information relating to this period 

should be conducted with these 1987-1993 severe drought 

conditions in mind. 

The Chapter 3 Climate and Meteorology section in the Draft 

RMP/EIS and the Final EIS mentioned the severe to extreme 

drought that occurred in the late 1980s to early 1990s. 

Climate 

Change

Examining baseline effects of climate change on sensitive and 

rare or imperiled species is critical to understanding the scale 

and severity of effects of BLM’s management actions on 

habitats. This is critical to understanding the effects on 

populations and population viability over the short, mid and 

The Climate Change section in Chapter 4 of the Final EIS 

included a discussion on how resources in the planning area 

(water, aquatic species, vegetation, noxious weeds and invasive 

plants, and wildlife) are currently affected and are projected to be 

affected by climate change. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-408

Category Comment Response

long term. A Federal court has held that the US Fish and 

Wildlife Service, a Federal agency, must consider climate 

change in estimating effects of a water project on the delta 

smelt (Pac. Coast Fed’n of Fishermen’s Ass’ns v. Gutierrez, 

606 F. Supp. 2d 1122, 1184 [E.D. Cal. 2008]). This must be 

done to comply with the Endangered Species Act and other 

regulations, as well as State policies related to species 

protection, water quality, and climate change. BLM’s dismissal 

of Idaho climate change as unpredictable and therefore 

unworthy of analysis is unacceptable.

Climate 

Change

Contrary to BLM’s assertion that climate change is well 

investigated in Washington State but lacking in Idaho, or 

inappropriately scaled for a 1.4 million acre planning area, the 

Climate Change group has been modeling the entire Columbia 

Plateau, and model output at 15km resolution are available for 

Idaho at the National Science Foundation’s 

idahoclimatechange.org. In addition, scientists from the 

Climate Impacts Group held a workshop in Boise in 2009, 

including analysis of Idaho water stream gage stations and 

potential effects.

The Climate Change section in Chapter 3 of the Final EIS was

reworded to say, “The University of Washington Climate Impacts 

Group has produced future climate scenarios for the Columbia 

River Basin in the Pacific Northwest, including Washington, 

Oregon, and Idaho using global climate models (Mote et al., 

2008). However, no climate change models specific to just the 

State of Idaho or the planning area are available. Because data 

is unavailable and the means to obtain it is unknown, BLM 

assumed that similar trends and findings for the Pacific 

Northwest will also occur in the planning area.” 

Climate 

Change

A 2009 US Geological Survey (USGS) circular on climate 

change stated, “Adaptive management is an approach that 

makes decisions sequentially over time and allows adjustments 

to be made as more information is known. This approach may 

be useful in dealing with the additional uncertainty introduced 

by potential climate change.” (Brekke et al., 2009).

The same USGS document contained examples of 

incorporating climate change considerations into a relatively 

short look-ahead period (that is, 19 years). The sample study 

focused on understanding the potential effects of future inflow 

sequences outside the range of historical flow sequences (for 

example, a future with different hydrologic variability and 

associated severity, frequency, and duration of droughts). The 

RMP can direct management actions incorporating 

conservative approaches reflecting the most likely and 

reasonably foreseeable future events (e.g. increased stream 

temperatures).

The Final EIS included an analysis in Chapter 4 on climate 

change. The range of alternatives included management actions 

common to all action alternatives that focused on adaptive 

management. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-409

Category Comment Response

Climate 

Change

BLM’s Programmatic EIS for Geothermal Leasing (BLM, 

2008b) offers insight into the most likely effect of climate 

change: 

“Climate change has a disproportionate effect on special status 

species. Based on analysis of temperature and precipitation 

data from the 20th century and models on continued climate 

change patterns, it is anticipated that global temperatures will 

continue to rise and weather patterns will become increasingly 

erratic. This trend is anticipated to result in ongoing increases 

in precipitation in historically wetter ecoregions and further 

reduced precipitation in historically drier ecoregions. The broad 

implications of these changes affect all species but are 

specifically detrimental to highly specialized species (Diaz, 

2004; Joyce et al., 2007).” 

BLM reviewed the Climate Change analysis in the BLM’s 

Programmatic EIS for Geothermal Leasing in the Western United 

States (BLM, 2008b) and considered it for the Climate Change 

analysis in the Final EIS.

Climate 

Change

BLM should assess direct, indirect, and cumulative 

environmental effects to affected resources, particularly special 

status species, in combination with changing environmental 

conditions resulting from climate change. The Draft RMP/EIS 

greatly ignores assessment of the predicted effects of climate 

change stress on the planning area, and fails to develop 

alternatives to minimize adverse impacts of climate change 

effects.

The Climate Change section in Chapter 4 of the Final EIS 

included a discussion on how resources in the planning area 

(water, aquatic species, vegetation, noxious weeds and invasive 

plants, and wildlife) are currently affected and are projected to be 

affected by climate change. 

Climate 

Change

The current emphasis on climate change has far too much 

weight. Extensive long-term credible scientific conclusions on 

climate change do not exist at this time and, therefore, it would 

be unreasonable to make any assumptions about climate 

change and use those assumptions to impose any impacts on 

motorized recreation. 

Secretarial Order 3226, entitled “Evaluating Climate Change 

Impacts in Management Planning” requires BLM to evaluate 

climate change in Land Use Plans, such as RMPs. 

Climate 

Change

The current emphasis on climate change is being given far too 

much weight. Global temperatures are not warming. Since 

1998, global temperatures have decreased almost half a 

degree Celsius. 

Under Secretarial Order 3226, entitled “Evaluating Climate 

Change Impacts in Management Planning”, the BLM is required 

to consider and analyze potential climate change impacts when 

developing multi-year management plans or when making major 

decisions regarding the potential utilization of resources.

Climate 

Change

In the Chapter 4 analysis of Climate Change, a 2.21 ranch 

level value cited above from Alevy and others (2007) is unreal 

because the cited document contains no such finding or 

conclusion. Furthermore, application of a 2.21 ranch level 

value to the 847,000 Federal animal unit months in Elko 

County produces and estimated beef cow herd of 155,000 

The analysis and reference to Alevy and others (2007) was 

removed from the Climate Change section in the Final EIS. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

head while the 2007 census of agriculture identifies the beef 

cowherd in Elko County as 80,610 head, which is only 50% of 

the number predicted by the multiplier. Remove the entire 

evaluation relative to Climate Change.

Climate 

Change

In the Chapter 3 Climate Change discussion, the BLM should 

refer to Secretarial Order 3289A1 and Secretarial Order 

3285A1, which direct the Department of Interior to address 

climate change, both in terms of prevention and in terms of 

mitigation.

The Final EIS considered these orders. These Secretarial 

Orders require that the Department of Interior address the 

effects of climate change. These orders were added to Appendix 

A: Specific Mandates and Authorities.

Climate 

Change

The Chapter 3 Climate Change discussion should be 

enhanced to elucidate the reasons for Secretarial Order 

3289A1 which include jobs, some of which might be developed 

within the planning area, and the need to aggressively develop 

renewable resources to mitigate climate change which is

expected to impact climates worldwide (impacting energy 

security and national security) as well as locally.

The purpose of Secretarial Order 3289A1 is to “establish a 

Department-wide approach for applying scientific tools to 

increase understanding of climate change and to coordinate an 

effective response to its impacts on tribes and on the land, 

water, ocean, fish and wildlife, and cultural heritage resources 

that the Department manages”. The order requires that the 

Department of Interior address the effects of climate change. 

The Final EIS revised the discussion and analysis related to 

climate change. 

Climate 

Change

The Chapter 3 Climate Change discussion points out the 

consensus that winter precipitation will be more in rain and less 

in snow. It should go on to point out to the public that this 

anticipated impact of climate change will dramatically change 

the operation of the Pacific Northwest hydroelectric system, 

with potential consequences to fish and wildlife, irrigation, 

economies, and costs of electricity as a result of reduced 

storage of hydroelectric potential in the form of snow.

The impacts of climate change on the Pacific Northwest 

hydroelectric system is beyond the scope of this planning effort.

Climate 

Change

The Draft RMP/EIS suggests that climate issues are so 

uncertain as to render any serious quantitative analysis 

unnecessary. In dealing with wildlife issues, the Draft RMP/EIS 

draws conclusions about, for example, tall structures and other 

infrastructure impacts upon sage-grouse without conveying the 

uncertainty in the data from which such conclusions are drawn.

The Climate Change section in Chapter 4 of the Final EIS was 

updated to include a discussion on how resources in the 

planning area (water, aquatic species, vegetation, noxious 

weeds and invasive plants, and wildlife) are currently affected 

and are projected to be affected by climate change. 

Climate 

Change

Methods for reducing greenhouse gas emissions to mitigate 

the effects of climate change were considered in the Methods 

and Assumptions. These methods should be included in the 

Final EIS.

Methods for reducing greenhouse gas emissions to mitigate the 

effects of climate change were not considered in the Draft 

RMP/EIS. The Final EIS revised discussions on how climate 

change affects the resources BLM manages and how BLM 

actions could contribute to or mitigate the effects of climate 

change. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Climate 

Change

BLM fails to provide analysis of how all of the actions under all 

of the alternatives will be affected by predicted or foreseeable 

climate change effects. Clean energy from wind power 

presents one of the best means to reduce greenhouse gas

(GHG) emissions and their contribution to climate change. 

However, the Draft RMP/EIS makes no mention of the benefits 

of wind energy in the context of climate change and its ability 

to avoid the conservation challenges posed by climate change 

through the avoidance of its cause: GHGs. Rather, the BLM 

acknowledged the benefits but then summarily dismissed them

in the Draft RMP/EIS. 

The Final EIS revised the Chapter 4 analysis on Climate Change 

to include BLM actions that could contribute or mitigate the 

effects of climate change. The Final EIS also revised Chapter 4 

to include how climate change may affect resources. 

Climate 

Change

The new RMP should be valid for a much shorter period, 4 to 5 

years maximum. Global (as well as political) climate change 

demands greater flexibility on the part of BLM to respond 

quickly to rapidly-developing conditions on the ground. An

RMP needs to be fresh and up-to-date, especially because 

subsequent decision documents flow from it.

The timeframe an RMP should be valid is beyond the scope of 

this planning effort. The BLM planning regulations 43 CFR 

1610.5 – 6 state "A resource management plan shall be revised 

as necessary, based on monitoring and evaluation findings 

(1610.49), new data, new or revised policy and changes in 

circumstances affecting the entire plan or major portions of the 

plan. Revisions shall comply with all of the requirements of these 

regulations for preparing and approving an original resource 

management plan."

Climate 

Change

BLM provides little meaningful information on climate change, 

sidesteps analysis, fails to look at the overall footprint of 

livestock operations and other activities, and fails to look at the 

overall footprint of alternatives. It fails to address a suitable 

range of alternatives to address the threats and risks posed by 

climate change - i.e. likely increased temperatures, earlier 

snowmelt, more spring rain, and more extreme weather 

scenarios.

The Final EIS included an analysis in Chapter 4 Climate 

Change, with impacts from livestock grazing (greenhouse gas

emissions) and other resource uses. The Final EIS also revised 

the Chapter 4 Climate Change section to include how climate 

change may affect resources. The range of alternatives in 

Chapter 2 included management actions common to all action 

alternatives that focused on adaptive management. 

Climate 

Change

The Draft RMP/EIS ignores the information on desertification 

that we provided and analysis that is required. The degree to 

which lands are desertified feeds into climate change (Steinfeld 

et al., 2006). Where is mapping of desertfication in the Field 

Office and surrounding lands?

We have reviewed and considered all the literature you provided 

on desertification. Alternative VI (Proposed RMP) addresses 

desertification through restoration and vegetation change. The 

goals and objectives in the Upland Vegetation section focus on 

moving annual communities towards a more native shrub 

community over the life of the RMP. 

Climate 

Change

BLM analysis should be much more specific so that real 

greenhouse gas footprint can be understood. This includes the 

livestock and livestock operator emissions, as well as the 

impacts of the livestock disturbance (and other disturbances) in 

adversely affecting the ability of the land to absorb carbon 

The Final EIS revised the Climate Change analysis in Chapter 4 

to include more information on greenhouse gas (GHG) 

emissions and carbon sequestration. However, the “real” GHG

footprint within the planning area is complex and may never be 

completely known.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

dioxide. 

Climate 

Change

BLM fails to answer key questions: How much are current uses 

currently impairing the ecosystem response to climate change? 

How will that impairment be affected by alternatives and 

actions?

The Final EIS, Chapter 4, analyzed impacts of current uses on 

climate change in the No Action Alternative (current 

management under the 1987 RMP).

Climate 

Change

How will all of the predicted adverse impacts of climate change 

affect sage-grouse habitats and populations - and place 

greater stress on them? Bull trout habitats and populations? 

The tiny and disconnected red band trout populations in the Elk

Mountain and Jarbidge Front area? BLM cannot summarily 

dismiss analysis, as it does at p. 3-6. This is critical in applying 

some measure of precautionary management to the public 

lands.

The Final EIS revised Chapter 4 to include how climate change 

affects vegetation, noxious weeds and invasive plants, and 

wildlife. 

Climate 

Change

BLM ignores the predicted impacts of climate change on soils 

and vegetation - for example: Climate change may cause the 

region to become drier and less vegetated in the foreseeable 

future, leaving soils more exposed to wind erosion and 

resulting in an increase in particulate matter (Jarbidge Analysis 

of the Management Situation).

The Final EIS included analyses in Chapter 4 on how climate 

change impacts vegetation and noxious weeds and invasive 

plants. 

Comments Please consider this resubmittal of the Western Watershed 

Project 2007 draft alternative for the Jarbidge RMP planning 

process as a comment on the Draft RMP/EIS.

The BLM considered the alternative re-submitted by Western 

Watersheds Project, known in the Draft RMP/EIS and the Final 

EIS as the “Habitat Restoration Alternative” but eliminated it from 

detailed study as a stand-alone alternative because it did not 

meet the purpose and need; contained internal inconsistencies; 

and was inconsistent with BLM planning criteria. Alternatives IV 

and V incorporated many components of the Habitat Restoration 

Alternative. 

Comments The Jarbidge Coalition for Multiple Use requests that the BLM 

consider its "Multiple Use Plan" for management of resources 

in the Jarbidge Field Office. 

The BLM considered the Multiple Use Plan but eliminated it from 

detailed study as a stand-alone alternative because many of the 

components were inconsistent with BLM policy or planning 

criteria. However, many components of this alternative were 

incorporated into Alternative VI (Proposed RMP).

Comments We mailed to you the affidavits, declarations, and comments to 

the Analysis of the Management Situation (AMS) and 

AMS/RMP, and Multiple Use Plan on January 28, 2011. We 

also incorporate as comments the scoping comments 

submitted by Simplot Land and Livestock Company (and its 

associated entities); Bert and Paula Brackett (and their 

associated entities); Chet and Kim Brackett (and their 

The commenter did not specify how the affidavits, declarations, 

and comments to the Analysis of the Management Situation 

related to the Draft RMP/EIS or how to incorporate them into the 

Final EIS. The BLM considered the Multiple Use Plan but 

eliminated it from detailed study as a stand-alone alternative 

because many of the components were inconsistent with BLM 

policy or planning criteria. Alternative VI (Proposed RMP) 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

associated entity); Winter Grazing LLC (and their associated 

entity, Camas Creek); and Stanley Lehmann (and his 

associated entities).

incorporated many components of this alternative. The 

development of the Draft RMP/EIS used comments received 

during scoping. 

Comments We would like to see the recognition of the transmission 

corridor as recommended in the BLM Gateway Transmission 

Line Study.

The Final EIS recognized the proposed Gateway West 

Transmission Line as a reasonably foreseeable action.

Comments The Final EIS must include the latest research, from a variety 

of sources, and continued utilization of existing and 

prospective resource users, including grazing, off-road vehicle 

users, motorized and non-motorized recreationalists, hunters 

and sportsmen, and even commercial wind energy developers.

The BLM has endeavored to use available science and 

utilization data in the Final EIS. Alternative VI (Proposed RMP) 

provided for a variety of resource uses within the planning area. 

Cultural 

Resources

We are concerned about the preservation of historic mines, 

cabins, settlements, railroads, access routes and other 

features used by pioneers, homesteaders, loggers, settlers, 

and miners. Do not remove these important cultural resources 

from the landscape. Western culture and heritage has been 

characterized by opportunities to work with the land and 

preservation of all remnants of this culture and heritage is 

important. Current management practices are not adequately 

protecting western culture and heritage including the 

opportunity to work with the land. We request that the ties to 

the land that are part of our local western culture and heritage 

be protected and that the preferred travel management 

alternative include opportunities to visit these features as part 

of motorized interpretative spur destinations and loops.

The BLM will continue to manage cultural resources in 

compliance with existing laws, regulations, and policy. After 

signing the Record of Decision adopting a revised Jarbidge 

RMP, a comprehensive travel and transportation management 

plan will be prepared. Motorized opportunities to visit sites 

important to western culture and heritage will be considered and 

analyzed during the travel management planning process. 

Cultural 

Resources

CR-NA-O-1: It is unclear whether BLM intends to make special 

designations of the cultural values of Dry Lake/Bruneau River 

Complex, Arch Canyon, and Dove Spring complex, or if it 

already has as part of the No-Action Alternative. The BLM 

should clarify this.

CR-NA-MA-2: Rewrite this management action to include 

identification of cultural resources through surveys and 

consultations. The BLM should revise as follows: “All significant 

cultural sites, as identified through consultation and surveys, 

and as determined by the State Historic Preservation Office 

(SHPO) and Advisory Council ....”

CR-NA-MA-8: The BLM should clarify whether the second 

Portions of the Dry Lakes/Bruneau River and Arch Canyon 

Complexes are included within the Bruneau-Jarbidge Rivers 

Wilderness and the existing Bruneau-Jarbidge River Area of 

Critical Environmental Concern. Although none of the site 

complexes identified in the 1987 RMP have been formally 

nominated to the National Register of Historic Places, eligible 

sites within these areas are managed to preserve their cultural 

resource values. This management would continue under the No 

Action Alternative.

The Final EIS did not make the suggested modifications to CRNA-MA-2 and CR-NA-MA-8 because the No Action Alternative, 

including objectives and management actions, were taken 

directly from the 1987 RMP. The goals, objectives, and 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-414

Category Comment Response

bullet point should read “Salvaging, though scientific methods, 

the cultural resources values pursuant to SHPO’s agreement” 

instead of “pursuant to the SHPO agreement.” The BLM should 

revise the last bullet point as follows: “Should the site be 

determined to be of significant value, and/or the abovementioned methods are not considered adequate, the project 

could be potentially abandoned.”

management actions in the action alternatives were developed 

to more clearly express current legal and policy direction.

Cultural 

Resources

Evaluate cultural resource values, to the extent that they relate 

to tribal cultural resources, in consultation with the affected 

tribes who can assist the BLM in determining the significance 

of the resource values discovered in a proposed work area. 

Tribes, like other entities, have competing interests in certain 

locations and a Tribe may ultimately determine the benefits of 

a potential project outweigh the value of cultural resources at 

that location. This would similarly apply to the consideration of 

prudent and feasible alternatives to avoid or mitigate adverse 

effects on cultural resources. (CR-CA-MA-12).

The Final EIS acknowledged tribal consultation as an important 

agency obligation many times throughout the document. The 

following sections and management actions in Alternative VI 

(Proposed RMP) specifically address tribal consultation or 

acknowledge our obligation to follow laws that require it: Tribal 

Rights and Interests (TI-CA-MA-1, TI-CA-MA-2, TI-CA-MA-3); 

Cultural Resources (CR-CA-MA-8, CR-CA-MA-10, CR-VI-MA-2, 

Appendix G); Land Tenure (LT-CA-MA-2); and Leasable 

Minerals (LE-CA-MA-2). Management action CR-CA-MA-11 in 

the Final EIS (CR-CA-MA-12 in the Draft RMP/EIS) is subject to 

the overarching requirement to consult on projects that might 

affect properties of traditional cultural importance to Native 

Americans. 

Cultural 

Resources

There is no action listed in CR-CA-MA-5- only a sentence 

fragment. The BLM should revise this to include an action item.

The Final EIS removed this management action and addressed

the description of lands included in the Kelton and Toana Freight 

Road protective corridors in Allocation CR-CA-A-2.

Cultural 

Resources

As written, management actions CR-I-MA-2, CR-II-MA-2, CRIII-MA-2, CR-IV-MA-2, and CR-V-MA-2 make it sound as 

though the BLM may unearth cultural resources and retain 

them through Federal ownership. The BLM should consider 

revising these management actions as follows: “Important 

cultural resources, as determined through consultation with 

tribes and/or State Historic Preservation Office, would 

generally be retained in their current location in the ground on 

Federally managed land.”

To avoid confusion, the Final EIS revised the first sentence in 

CR-I-MA-2, CR-II-MA-2, CR-III-MA-2, CR-IV-MA-2, CR-V-MA-2, 

and CR-VI-MA-2 to read, "Lands containing important cultural 

resources, as determined through consultation with tribes and/or 

State Historic Preservation Office, would generally be retained in 

Federal ownership."

Cultural 

Resources

In Chapter 4, under Cultural Resources, Methods and 

Assumptions, the fourth assumption at p. 4-525 should include 

consultation with private developers to eliminate or mitigate 

adverse impacts to cultural resources.

The BLM revised the statement by adding "project proponents 

and other affected parties" after "Advisory Council on Historic 

Preservation". This is more in line with the 36 CFR 800 

regulations.

Cultural 

Resources

In Chapter 4, under Cultural Resources, Methods and 

Assumptions, the fifth assumption (“given BLM’s preservation 

obligations,”) is confusing since the meaning is unclear. The 

This assumption acknowledges the fact that increased impacts 

to cultural resources will result in increased costs for compliance 

with preservation mandates. The Final EIS revised wording in
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

BLM should either clarify this assumption or delete it. Chapter 4 to clarify the assumption. 

Cultural 

Resources

The impacts from land use authorizations, p. 4-537, unfairly 

singles out large energy development projects as typical 

disturbances of large areas that are difficult to reroute or adjust 

to avoid cultural resources. Delete this statement. It is contrary 

to the best management practices already imposed upon wind 

project developments in the planning area due to the 2005 

amendments to the 1987 Jarbidge RMP. Moreover, a number 

of other land uses have a potential to disturb much larger 

areas containing cultural resources. The footprint of a wind 

energy project of commercial scale could be measured in 

several hundred acres and is not a major threat to cultural 

resources.

The statement in question reflects the current and expected 

trend in large-scale development proposals affecting the 

planning area. The focus of this section is land use 

authorizations under the BLM Lands and Realty program; the 

Final EIS addressed other land uses in the appropriate resource 

use sections, e.g., Livestock Grazing, Recreation, etc. The best 

management practices and mitigation measures imposed on 

particular development projects should reduce, but would not 

eliminate, impacts to cultural resources. To avoid the 

appearance of bias, the Final EIS revised the statement by 

deleting the word “energy”.

Cultural 

Resources

Delete the final sentence of the paragraph on impacts from 

Area of Critical Environmental Concern (ACEC) actions at p. 4-

546. Removal of an ACEC designation would not remove 

protection of cultural resources as they still would be protected 

by other Federal and State laws and/or other measures in 

existing best management practices and mitigation 

requirements imposed by a Record of Decision. Furthermore, 

the BLM wind energy program policies specifically state that 

ACECs are not universally excluded from wind energy site 

monitoring and testing or wind energy development but will be 

managed consistent with the management prescriptions for the 

individual ACEC, which could include management 

prescriptions for cultural resources.

The Final EIS revised the paragraph in question to highlight only 

those Areas of Critical Environmental Concern (ACECs) with 

special management actions that proactively benefit cultural 

resources. The last sentence was revised to more accurately 

describe the effects of ACEC designation or non-designation on 

cultural resources. The Final EIS, Chapter 2, provides

management actions that will directly or indirectly provide 

additional protection for cultural resources specific to the 

ACECs. 

Cultural 

Resources

The impacts from Alternative II overstate the potential impact to 

cultural resources at p. 4-550. Even though Alternative II is the 

most attractive alternative from the perspective of commercial 

development, such development would still be subject to 

avoidance, minimization and mitigation responsibilities related 

to cultural resources as indicated in the stipulations attached to 

any Record of Decision authorizing a wind energy project 

together with existing best management practices (BMPs) and 

the overlay of Federal cultural statutes such as the National 

Historic Preservation Act. Thus, the level of impacts to the 

integrity and setting of cultural resources under Alternative II 

may be no greater than under other alternatives.

In relation to the other alternatives, Alternative II has the most 

potential to affect cultural resources because it makes more area 

available for impact-producing uses, has fewer restrictions, and 

allows higher use levels. While best management practices and 

project specific mitigation measures may reduce impacts, only 

avoidance would eliminate them altogether. Impacts, even at a 

reduced level of intensity, are expected to occur at a higher rate 

under Alternative II.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-416

Category Comment Response

Similarly, the assumption in the discussion of cumulative 

impacts (p. 4-552) that land use authorizations “are expected 

to” result in unavoidable impacts to cultural resources does not 

adequately recognize that new energy developments such as 

wind energy can coexist with many cultural resources through 

stipulations, mitigation, BMPs and other measures.

Cultural

Resources

Management action CR-CA-MA-12 covers cultural resources. 

This management action is very wordy, broad and not specific. 

Typically, these types of actions are not good for management. 

Revise this management action to be more readable to 

managers and the public.

The Final EIS revised and simplified this management action. It 

is now numbered CR-CA-MA-11.

Economic 

Conditions

Federal Land Policy and Management Act of 1976 regulations 

43 CFR 1610.43 and 1610.46 require BLM to analyze social, 

economic, and institutional information. Section 102(2)(A) of 

NEPA requires Federal agencies to “insure the integrated use 

of the natural and social sciences... in planning and decision 

making” (42 U.S.C. 4332(2)(A)). Section 4.6.2 of the Draft 

RMP/EIS analyzes economic conditions in the four-county area 

and predicts economic impacts of various alternatives. Some 

data in the analysis are up-to-date, such as the Bureau of 

Economic Analysis data used in Table 4-375. However, many 

of the economic impacts are calculated using outdated data 

reflecting economic conditions before the current recession. 

The county-level Impact Analysis for Planning (IMPLAN) data 

used to calculate economic impacts are from 2006. Due to the 

significant change in economic conditions in Idaho, Nevada, 

and the nation between 2006 and 2011, the economic impacts 

of different alternatives cannot be accurately calculated with 

data from 2006. BLM needs to use the most recently released 

IMPLAN data, reflecting the changed economic conditions of 

Idaho and Nevada, to calculate economic impacts.

The Final EIS revised the Chapter 4 Economic Conditions

section analysis. Data used in the Chapters 3 and 4 Social and 

Economic Features section of the Final EIS include 2010 Impact 

Analysis for Planning (IMPLAN) data, the most current IMPLAN 

data available. 

Economic 

Conditions

We request that the economic analysis use actual local data to 

determine the true economic and social impact of proposed 

motorized access and closures on the public.

The Chapter 4 Economic Conditions section analysis of 

recreation impacts (including motorized recreation) in both the 

Draft RMP/EIS and the Final EIS used data specific to counties 

in the planning area. The Final EIS updated data to include more 

recent data.

Economic 

Conditions

The analysis and decision-making must adequately evaluate 

the economic and social impacts of this proposed action. 

Additionally, we request that the cumulative negative impact 

The Final EIS revised the cumulative impacts analyses in the 

Social Conditions and Economic Conditions sections to indicate

that the effects from past social and economic activities have 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-417

Category Comment Response

resulting from inadequate evaluation of economic and social 

impacts in past actions are considered in the analysis and 

decision-making and that an adequate mitigation plan be 

included as part of this action to compensate for past 

cumulative negative impacts.

been already absorbed by local communities and are 

represented in the affected environment. The cumulative impacts

analysis in Chapter 4 included changes in the social and 

economic environment as a result of past management actions, 

as well as present and reasonably foreseeable actions. Making a 

reasoned choice among alternatives does not require the 

mitigation plan suggested by the commenter.

Economic 

Conditions

The positive economic impact on the economy of the area 

must be adequately considered in the decision-making. 

Arizona State Parks has prepared a good example of an 

economic analysis of off-highway vehicle (OHV) recreation for 

Coconino County, AZ. This evaluation should be used as 

guideline to evaluate the existing and potential positive 

economic impacts associated with OHV recreation in the 

project area. Additionally, the study does a good job assessing 

the activities and reasons that recreationists enjoy using OHVs. 

The Final EIS updated information related to the economic 

contributions from motorized recreationists in the planning area. 

The Final EIS also added economic effects from changes to 

motorized recreation under each alternative. 

Economic 

Conditions

Despite the significant negative economic impacts of 

Alternative IV, when compared to Alternative II or even the No 

Action Alternative, very little factual information appears 

anywhere in the section (4.6. Social and Economic Features; 

4.6.2 Economic Conditions) concerning the potential economic 

impacts of the decisions being proposed in the Draft RMP/EIS. 

Additionally, the data is confused by comparing the impacts of 

the alternatives in question, which covers a million plus acres 

of rangeland utilized by some 70 ranching families and a 

limited amount of wildlife resources, with the vast economic 

resources of the four-county area of Idaho and Nevada, an 

area that produces over nine billion dollars of economic output 

annually (Table 4-391, p. 7-87). Making such comparisons are 

confusing at best and totally misleading. 

The final portion of the section covering economic impacts 

deals with cumulative impacts. This poorly written section lacks 

meaningful data and conclusions and it warrants no comment. 

Eliminate it or expand it with meaningful and factual data and 

conclusions based on such data.

The Final EIS revised the Social and Economic Features section 

of Chapters 3 and 4 in order to improve the clarity of social and 

economic impacts analysis and comparisons among the 

alternatives. In addition, the discussion augmented the

cumulative impacts to include distinction of cumulative impacts

to social and economics by resource program, where social and 

economic effects occur.

Economic 

Conditions

Owyhee County relies on economic evaluation of land 

management actions through the “Regional Economic Impact 

Model of Owyhee County, Idaho and the Four County Area 

The economic analysis for the Final EIS used multiple resources, 

including the Impact Analysis for Planning (IMPLAN) Pro 

Software and Data (Minnesota IMPLAN Group, 2004) utilizing 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-418

Category Comment Response

Including Ada, Canyon, Elmore, and Owyhee Counties, 

Agricultural Economics Extension Series No. 03-06, June 

2003, T. Darden, N Rimbey and J.D. Wulfhorst.” This model is 

readily available to BLM. BLM also partly funded its 

development. The evaluation of economic consequences of 

the Draft RMP/EIS alternatives must use this model in order to 

consider the economic impact directly related to Owyhee 

County. 

data from Elmore, Owyhee, and Twin Falls Counties, ID, and 

Elko County, NV.; Alevy and others (2007) Analysis of Impacts 

of Public Land Grazing on the Elko County Economy, Jarbidge 

and Mountain City Management Area: Part VII: Economic 

Impacts of Federal Grazing in Elko County published by the 

University of Nevada; and Farm Income and Expenses data for 

Elmore, Owyhee, and Twin Falls Counties, Idaho, and Elko 

County, Nevada from the Bureau of Economic Analysis (Bureau 

of Economic Analysis, 2009 and 2013). 

Economic 

Conditions

The evaluation in the Draft RMP/EIS does not provide the 

complete and reliable assessment of economic consequences 

specific to Owyhee County that is necessary and required by 

the Owyhee Natural Resources Plan (See Owyhee Natural 

Resources Plan Appendix A-1 and A-3). The analysis in the 

Draft RMP/EIS looks only at the regional impact as estimated 

through the Impact Analysis for Planning (IMPLAN) model. 

Reliance on the IMPLAN model and the inclusion of study data 

from Elko County Nevada is unacceptable and entirely 

inconsistent with Owyhee County policy.

During the land use planning process, BLM considered pertinent 

provisions in local plans. BLM reviewed the Owyhee Natural 

Resources Plan and did not find any provisions for the 

assessment of economic consequences in BLM Land Use Plans. 

The Owyhee Natural Resource Plan does provide guidelines for 

grazing permit environmental assessments (EA), such as “The 

EA must also evaluate and include the immediate (short term) 

social and economic consequence as well as the cumulative 

effect (longer term) result of each alternative”. The Chapter 4 

analysis in the Economic Conditions section in the Final EIS 

included direct, indirect, and cumulative impacts of each 

alternative for the planning area.

Impact Analysis for Planning (IMPLAN) is a widely accepted 

socioeconomics model. In fact, Appendix A-1 of the Owyhee 

Natural Resources Plan, “Regional Economic Impact Model of 

Owyhee County, Idaho and the Four County Area Including Ada, 

Canyon, Elmore, and Owyhee Counties” relies on the IMPLAN 

model. 

Economic 

Conditions

Page 4-770, Table 4-373 of the Draft RMP/EIS reports the 

Output, Employment, and Income for North American Industry 

Classification System Sectors Estimated by Impact Analysis for 

Planning (IMPLAN) for the Four-County Region in 2006. The 

IMPLAN model is inadequate for characterizing the economic 

impacts relative to Owyhee, Elmore and Twin Falls Counties in 

Idaho. Values derived from the IMPLAN model, shows output 

of 829 million dollars from mining, quarrying, and oil and gas 

extraction. The $1.6 Billion gold, silver, and other metal ore 

mining output from Elko County (2004) drives this high value. 

Clearly, the removal of Elko County from the IMPLAN model 

While the Draft RMP/EIS included all of Elko County, the 

analysis in the Final EIS examined just that area in Elko County 

where BLM land exists and where potential purchases are made 

by permittees and recreationists who use BLM-managed lands. 

This revised approach avoided dilution of important economic 

relationships between BLM-managed land in the planning area 

and Elko County. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

analysis would show a far lower mining output sector and 

would significantly change the relationship among other sector 

values.

Economic 

Conditions

We are very concerned about the economic impact this plan 

could have on local area businesses. Your plan does not 

adequately address the impacts of reduced livestock grazing, 

reduced motorized recreation opportunities and reduced 

hunting access would have on the towns in the planning Area. 

We suggest that you do further study as to the effect your plan 

would have on the small communities bordering and near the 

planning area.

Since recreationists, hunters, and ranchers make purchases 

within the four-county area that support their activities on BLMmanaged land in the planning area, the economic impact area 

included the four counties in the planning area (Elko, Elmore, 

Owyhee, and Twin Falls). Also included in the economic impact 

area are other small communities bordering and near the 

planning area, since these economies connect to activity in the 

planning area. By including the larger impact area, important 

economic relationships attributable to activity in the planning 

area are included in the analysis that would otherwise be ignored 

by limiting analysis to just the planning area. The Final EIS

added detail to the economic analysis in noting that impacts 

could be greater for smaller communities in the impact area. 

Increases or decreases (which vary by alternative) of resource 

uses were analyzed for economic impacts.

Economic 

Conditions

The BLM should realize the significance and economic value to 

the region, encourage, and expand multiple uses including 

recreation. Ranching, recreation and mining are considerable 

components of the local and regional economy and a viable 

ever-expanding resource. The BLM must also realize the 

immense adverse impacts to the regional economies from 

implementation of the Draft RMP/EIS as per the preferred 

alternative or any other alternative outlined in the Draft 

RMP/EIS (except the no-action alternative).

The Final EIS revised the economic contribution from recreation 

and other resource uses. While changes in BLM’s contribution to 

the local economy are possible relative to the No Action 

Alternative, many of these changes will continue to support 

current uses and enhance local economies in the impact area.

Economic 

Conditions

In Section 2.6.1 Social and Economic Conditions, the 

management actions for all alternatives do not specifically 

address the social and economic opportunities associated with 

wind energy. The counties receive revenues during 

construction and operation of a wind energy project. Operation 

of wind projects typically last 20-25 years; therefore, the local 

counties would have a revenue stream for at least 20-25 years.

The management actions common to all action alternatives did

not specifically address any one activity or authorized use. Wind 

energy projects are included as they are an authorized use.

Economic 

Conditions

Section 3.5.2 Economic Conditions (Wind Energy) states that 

Idaho has approximately 18,000 megawatts (MW) of wind 

energy potential. Yet the example economic impact illustrated 

in Table 3-56, of the Draft RMP/EIS, is for a typical 20 MW 

wind project, or 0.1% of the potential for Idaho. The result to 

The 18,000 megawatt wind energy potential for the State of 

Idaho discussed in the Draft RMP/EIS would not occur 

exclusively within the planning area. Future extent of 

development in the planning area is unknown; thus, Table 3- 56 

and Table 4- 379 of the Draft RMP/EIS describe the potential 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

the casual observer is that wind energy is of limited potential 

economic impact whereas by the 18,000 MW figure presented, 

the economic impact could be substantial.

economic impacts of hypothetical wind projects. The Final EIS 

removed the example economic impact tables and added detail 

to explain that the levels of development depicted in section 

3.6.2, Economic Conditions, are hypothetical and provide a 

frame of reference for potential future development.

Economic 

Conditions

In Section 4.6.2 Economic Conditions, the numbers provided 

by the National Renewable Energy Laboratory in Table 4-379, 

of the Draft RMP/EIS, for a 20-, 150-, and 400-megewatt

project are hypothetical. Therefore, separately evaluate each

wind project in the planning area to determine direct and 

indirect economic impacts.

Since the extent of future wind energy development is not 

known, the Draft RMP/EIS and Final EIS used hypothetical 

levels of development for analysis purpose. The RMP will set 

broad-scale decisions that will guide future site-specific project 

proposals. BLM would evaluate each site-specific wind energy 

proposal in the planning area separately and BLM would 

complete an appropriate NEPA analysis before authorization of 

any wind energy project. 

Economic 

Conditions

In Section 4.6.2 Economic Conditions, the following statement 

is inaccurate: “Alternatives I, III, IV and V would make the 

majority of the southeast corner of the planning area 

unavailable for wind energy development, which would not 

allow consideration of a 400-megewatt (MW) wind energy 

project in that area. Under these alternatives that preclude 

construction of commercial-scale wind energy projects in the 

area with the highest wind resource potential, the opportunity 

to increase output, employment and income due to wind 

energy development as displayed in Table 4-387 would be 

foregone.” With best management practices (BMPs) and 

mitigation measures, all of the alternatives could permit a 

commercial-scale wind energy project in the southeast corner 

of the planning area. The size of the wind energy project in 

Alternatives I, III, IV and V may not be 400 MW, but certainly 

none of the alternatives entirely excludes a commercial-scale 

wind energy project. The BLM should revise the statement 

accordingly: “Alternatives I, III, IV and V may restrict portions of 

the southeast corner of the planning area for wind energy 

development, but with BMPs and mitigation measures, 

construction of a commercial-scale wind energy project in the 

southeast corner of the planning area could be feasible. Under 

these alternatives, the opportunity to increase output, 

employment and income due to wind energy development as 

displayed in Table 4-387 may be reduced.” Revise Tables 4-

387, 4-390 and 4-395 accordingly.

This statement in the Economic Conditions section of Chapter 4 

is accurate for analysis purposes. Each alternative has different 

right-of-way (ROW) exclusion and avoidance areas. For the 

analysis, those Alternatives assumed that utility-scale wind 

developments would not be able to meet any of the avoidance 

criteria identified in the alternatives. Therefore, the potential wind 

development areas included lands within 2 miles of areas rated 

fair or higher for wind resource potential that were also available 

for wind energy development outside the ROW avoidance and 

exclusion areas for that alternative. Exclusion areas included 

areas such as wilderness and Wilderness Study Areas. 

Avoidance areas included areas such as the sage-grouse

management area, Areas of Critical Environmental Concern, and 

military operating areas. These restrictions would not allow 

commercial wind development regardless of best management 

practices and mitigation measures.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Economic 

Conditions

Idaho Department of Lands cannot support the preferred 

alternative in its current form due to the adverse impact it 

would have to revenue generating activities on intermingled 

endowment trust lands.

The Economic Condition section of Chapter 4 described the 

economic impact of each alternative on a regional area (Elmore; 

Owyhee; Twin Falls, ID;and Elko, NV Counties). 

Economic 

Conditions

A final concern is the economic impacts as shown on p. 4-785, 

table 4-388. For the communities involved these are not 

inconsequential numbers and the impacts will be far reaching.

The Final EIS revised the impacts to Economic Conditions to 

discuss effects to smaller geographic units and added detail,

noting that impacts could be greater for smaller communities in 

the impact area. The Final EIS also reduced the economic 

impact area in Elko County, NV to only include zip codes where 

permittees and recreationists potentially make purchases.

Economic 

Conditions

There is no economic analysis to show the cost of active vs. 

passive restoration (removal of livestock, closure of jeep trails, 

etc.) in the Draft RMP/EIS. There is no valid economic analysis 

to show the cost of using herbicides on cheat grass, fencing, 

etc. if treatments are subjected to continued livestock grazing - 

or how much grazing use will slow or retard any recovery or 

rehabilitation. 

At the planning area scale, cost estimation is impractical given 

uncertainty in the extent of future treatment, timeline of 

treatment, costs of material and supplies at the time of 

treatment, and future budget appropriations. 

Economic 

Conditions

Western Watersheds Project is concerned that the analysis of 

the social and economic consequences of each alternative in 

the Draft RMP/EIS is cursory and incomplete.

The social and economic analysis included effects to various 

stakeholders and groups: ranchers, local residents, and 

recreators (including dispersed recreators, motorized recreators, 

hunters, and fishermen). In addition, the Economic Condition

section analyzed impacts from Upland Vegetation, Fish, Wildlife, 

Livestock Grazing, Recreation, Transportation and Travel, and 

Land Use Authorizations actions. Non-market values, such as 

the value of recreation experiences and wildlife habitat, by their 

nature are difficult to quantify. Direction provided in Appendix D 

of the Land Use Planning Handbook H-1601-1 (pp. 6, 7 and 10) 

suggests the use of benefit transfer to evaluate the effects of 

these non-market values. The Final EIS discussed topics 

qualitatively in the absence of quantitative information for other 

non-market values and social effects.

Economic 

Conditions

The BLM needs to enlarge the social and economic analysis to 

include the income and expense of administering the public 

lands in the Field Office for each alternative. Nowhere in the 

Draft RMP/EIS is there any information that assesses the 

expense and income to administer the Field Office including 

the costs to American taxpayers of subsidizing livestock 

grazing. 

A social and economic analysis of the income or expense to 

administer the Field Office is beyond the scope of this planning 

effort. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Economic 

Conditions

I am sure you are aware that the Department of Interior's 

Sustainability Plan includes, "implementing on-site renewable 

energy generation" and Secretarial Orders Nos. 3285 and 

3289. Based on the figures I have seen, this type of growth 

could put about $33 million into Twin Falls County alone in 

wind tax revenues, while creating up to 750 full and part-time 

jobs during the construction of these Commercial types of 

projects. The Final EIS cannot ignore inclusion of those 

potential economic contributions.

The Final EIS, Chapter 4, included the social and economic 

contributions of potential wind energy developments. Data used 

to characterize potential effects from wind energy development 

were from the National Renewable Energy Lab’s Job and 

Economic Impact Assessment Model, and utilize Federal

sources of data (NREL, 2009c). 

Economic 

Conditions

Please see that the Final EIS includes the accurate benefits to 

Twin Falls and its surrounding communities. It must also 

include logical resource analysis and synthesis with the best 

users of the resources, conservationists, hunters and 

sportsmen, livestock grazers, commercial energy developers, 

and off-road vehicle users and recreationalists. This is the 

highest and best use of the resources.

The Final EIS revised the social and economic analysis using

more recent information. The analysis described benefits to Twin 

Falls and other communities within the planning area. The 

analysis also included effects to various stakeholders and 

groups including ranchers, local residents, and recreators, 

(including dispersed recreators, motorized recreators, hunters, 

and fishermen). 

Emergency 

Stabilization 

and Burned 

Area 

Rehabilitation

Emergency Stabilization and Burned Area Rehabilitation 

objectives must be clearly stated and quantifiable. Clearly state 

implementation and effectiveness monitoring schedule and 

criteria for success, establish a schedule for reporting, and 

follow it.

The Final EIS set broad objectives for Emergency Stabilization 

and Burned Area Rehabilitation (ES&BAR). Detailed criteria for 

monitoring, scheduling, and effectiveness would be identified 

during the development of a specific ES&BAR plan.

Emergency 

Stabilization 

and Burned 

Area 

Rehabilitation 

The BLM mentions that rest from uses in Emergency 

Stabilization and Burned Area Rehabilitation (ES&BAR) areas 

is not necessary if “the uses are not in conflict with the 

treatment objectives” (p. 2-96). The Draft RMP/EIS did not 

define which uses conflict with ES&BAR objectives. Please 

Clarify this issue in the Final EIS.

The Final EIS revised management action FE-CA-MA- 4. The 

Final EIS did not define uses that conflict with Emergency 

Stabilization and Burned Area Rehabilitation (ES&BAR) 

objectives because uses and treatment objectives will vary in 

each ES&BAR plan. 

Emergency 

Stabilization 

and Burned 

Area 

Rehabilitation 

BLM needs to develop a map of all past post fire seedings and 

fences and identify the areas for recovery/rehabilitation of 

natives.

BLM maintains data on seedings and fences. Due to the scale 

and nature of the Final EIS, it did not identify the specific 

mapping of this data. Nevertheless, there is sufficient data 

underlying the analysis to reflect the impact of a range of 

Emergency Stabilization and Burned Area Rehabilitation 

management directions. 

Emergency 

Stabilization 

and Burned 

Area 

Rehabilitation 

First, fuels treatments and Emergency Stabilization and Burned 

Area Rehabilitation treatments should focus on stabilizing soils 

and preventing the spread of noxious and invasive plants. 

Species selection for seed mixes must consider this. Species 

that lengthen the fire return interval must also be included 

within seed mixes. Implement rehabilitation on existing nonThe Final EIS analyzed a range of fuel and Emergency 

Stabilization and Burned Area Rehabilitation (ES&BAR) 

treatments. Alternative VI (Proposed RMP) states one objective 

as “Rehabilitate and stabilize areas to help stabilize soils, 

promote natural recovery, and establish pre-fire or historic 

vegetation communities.” Components of management actions 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

native perennial vegetation only when the potential for soil 

instability and/or invasion by noxious weeds and invasive 

plants is imminent.

that support this objective are using native species, moving plant 

communities towards Fire Regime Condition Class 1, and 

treating and preventing noxious weeds and invasive plants. BLM 

Handbook H-1742-1 and Department of Interior Manual 620 DM 

3 provide more specific direction on ES&BAR plans.

Emergency 

Stabilization 

and Burned 

Area 

Rehabilitation 

The Resource Advisory Council unanimously supports the use 

of FE-II-MA-10 and FE-Il-MA-12 over the selection of FE-IVMA-9 and FE-IV-MA-11. In the case of FE-Il-MA-10 versus FEIV-MA-9, the issue is one of equality and management 

flexibility. To prohibit temporary fencing in all instances but 

where 2,000 acres is unburned in a pasture removes the ability 

of BLM to take into account different situations. BLM should 

take into consideration the differing needs of permittees and 

the allotments involved when making temporary fencing needs. 

FE-IV-MA-9 is a good guideline but BLM and permittees need 

additional flexibility.

FE-lV-MA-9 versus FE-IV-MA-11 is a case of economics and 

management flexibility. If BLM determines a temporary fence 

has the ability to serve a purpose after the restoration period 

ends the option should exist. In most cases, after a fire the 

original seeding comes back very strongly and in many cases 

looks like a new seeding. It might be advantageous to BLM, 

wildlife needs, and the permittee to manage the recently

burned area differently than the remaining portion of the 

pasture that did not burn. FE-IV-MA-11 prevents BLM from 

making appropriate management decisions that are flexible 

and best suited for site conditions. In addition, the fence in this 

case has already been constructed; to remove the fence and 

then proceed to rebuild the fence again is a waste of tax 

dollars.

The Final EIS analyzed a range of temporary fencing options for 

use in Emergency Stabilization and Burned Area Rehabilitation 

activities. Alternative VI (Proposed RMP) includes the following 

two management actions for fences. Both of these management 

actions allow for flexibility and cost considerations in burned 

areas.

FE-VI-MA-9. Consider using temporary fences to protect burned 

plant communities. When planning temporary fences, consider 

resource concerns, the size of the pasture, the amount burned, 

the amount of pasture unaffected by rehabilitation, location of 

water, grazing management efficiency, and expense.

FE-VI-MA-10. Temporary fences may become permanent if they 

enhance the management of the burned area; these would be 

considered on a case-by-case basis through site-specific 

analysis.

Energy 

Development

We recommend BLM ensure adequate protective measures 

are imposed on wind energy development and require both onsite and off-site mitigation of impacts to resources, as well as 

loss of uses (such as recreation). The Draft RMP has already 

begun this approach in terms of wind energy by limiting 

projects to areas that have been converted from non-native 

vegetation and restricting development from occupied and 

suitable habitat for special status species, wildlife habitat, and 

The approved RMP will establish broad-scale decisions to guide 

future management and site-specific implementation decisions. 

The approved RMP will include best management practices 

(BMPs) that will be considered and applied during site-specific 

project planning. BMPs related to wind energy development 

would be used on all wind projects per LA-C-MA-1 in Alternative 

VI (Proposed RMP). In addition to BMPs that reduce impacts to 

resources, mitigation measures would be considered during 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

cultural resources. analysis of site-specific implementation decisions.

Energy 

Development

The Draft RMP (p. 1-10) references the China Mountain Wind 

Energy Project as “related” but planned to be analyzed 

separately, although within the scope of the analysis of 

impacts. In order for the protective measures in the Draft RMP 

to successfully protect wildlife and for the analysis in the RMP 

to be sufficient for approving a project, projects comply with the 

management approach set out in the RMP, including the buffer 

for wind turbines. Completion of the China Mountain EIS ahead 

of the Jarbidge RMP, and choosing an alternative that creates 

industrial wind facilities on China Mountain, will prejudice the 

outcome of the RMP, as well as the effectiveness of the RMP’s 

management approach. If the China Mountain project 

supersedes the RMP process, the BLM faces the distinct 

possibility of violating 40 CFR 1506.1, which prohibits interim 

decisions that limit alternatives being considered in a pending 

EIS process. 

The China Mountain Wind Energy Project has been deferred 

until the Idaho/Southwest Montana Sub-Regional Sage-Grouse 

Plan Amendment and the Jarbidge RMP have been completed. 

Energy 

Development

The RMP should explicitly close all Areas of Critical 

Environmental Concern and the Canyonlands Special 

Recreation Management Area to wind energy development, 

consistent with the BLM’s Programmatic Wind Energy EIS.

BLM's current policy related to wind energy development 

(Instruction Memorandum (IM)-2011-061) does not automatically 

exclude wind energy development from all Areas of Critical 

Environmental Concern (ACECs). BLM IM-2011-061 changed 

the previous policy to ensure consideration of the purpose and 

specific environmental sensitivities for which an area was 

designated as an ACEC. Land use planning efforts, such as this 

one, address and analyze ACEC land use restrictions 

individually, including restrictions to wind energy development. 

ACECs are not universally excluded from wind energy site 

testing and monitoring or wind energy development but will be 

managed consistent with the management prescriptions for the 

individual ACEC. 

Alternative VI (Proposed RMP) included Canyonlands as an 

Extensive Recreation Management Area (ERMA), not as a 

Special Recreation Management Area. ERMAs are not 

automatically excluded from wind energy development.

Energy 

Development

The RMP should commit to updating the potential wind 

development areas map to reflect restoration of native 

vegetation. 

Maps depicting expected wind development areas were updated 

in the Final EIS (Maps 99 to105). Expected wind development 

areas include lands within 2 miles of areas rated fair or better for 

wind resource potential and areas available for wind energy 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

development (e.g. outside right-of-way avoidance and exclusion 

areas, outside of Visual Resource Management Classes I and 

II). The maps were not updated simply to reflect restoration of 

native vegetation.

Energy 

Development

The most effective way for BLM to address wind energy 

development throughout the planning area would be for the 

RMP to designate high resource, low-conflict zones for wind 

energy and limit projects to those zones. 

Wind resources were classified according to wind power classes, 

which were based on typical wind speeds 50 meters above the 

ground. Wind classes were used rather than zoning. Areas 

available for wind energy development areas are generally 

outside right-of-way avoidance and exclusion areas, and outside 

of Visual Resource Management Class I and II areas. 

Energy 

Development

The RMP should prohibit wind turbines within 5.3 miles of 

active sage-grouse leks, and provide for adjustment of the 

management action as necessary to accommodate the most 

recent science.

In Alternative VI (Proposed RMP), commercial wind and solar 

energy developments would not be permitted inside the sagegrouse management area or utility right-of-way corridors (LA-VIA-4). Outside the sage-grouse management area, renewable 

energy site testing, monitoring, and development should avoid 

special status species habitat unless unavoidable adverse 

effects can be mitigated (LA-VI-MA-4). Tall structures such as 

overhead power lines and wind turbines would be located more 

than 4 miles away from occupied and unknown-status leks 

unless topographic screening is available ( LA-VI-MA-2). Recent 

science was used in developing management actions.

Energy 

Development

Solar development is an increasingly important element of our 

national energy strategy, and cannot be ignored in public lands 

planning. Solar developments are commercially viable in 

southern Idaho as evidenced by projects under development in 

Boise and the Grand View Solar Project, not far outside the 

planning area. BLM should consider future solar development, 

including clear and comprehensive guidelines for responsible 

solar energy development, identifying lands appropriate for 

solar projects as open for development, and closing all other 

lands to development. Solar developments are a reasonably 

foreseeable action in the planning area.

The BLM did consider solar energy development during 

development of Alternative VI (Proposed RMP) and the Final 

EIS. Policies and relevant design features from the Record of 

Decision for the Solar Energy Development Programmatic EIS 

have been included in Alternative VI. See LA-VI-MA-5. At 

present, no solar projects are proposed within the planning area.

Energy 

Development

NEPA requires agencies to consider the cumulative impacts of 

proposed actions. We want to reiterate the importance of 

considering other projects underway on public lands and, 

specifically, the development of wind and geothermal projects 

on public lands, which are reasonably foreseeable future 

actions that will have significant impacts on natural and cultural 

resources.

Chapter 4 of the Final EIS included a cumulative impacts 

analysis for the Land Use Authorizations and Leasable Minerals

sections. Both sections have been updated to include 

information on reasonably foreseeable wind and geothermal 

development within the planning area. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Energy 

Development

In order for the BLM to comply with the Federal Land Policy 

and Management Act of 1976 and NEPA, the agency should, 

at a minimum, consider and “rigorously explore” alternatives 

which close much larger areas to mineral leasing, especially in 

important habitat for sage-grouse and other key species. The 

RMP should not allow exceptions, waivers, or modifications to 

lease stipulations for species concerns, and should provide 

require public review of all exceptions, waivers, and 

modifications.

Oil and gas development stipulations and constraints are 

included in the range of alternatives considered in the Final EIS 

(Chapter 2, Leasable Minerals). Leasable mineral development 

activities would avoid special status species habitat unless 

adverse effects can be mitigated. Permits would include 

mitigation when needed to reduce adverse effects on special 

status species and their habitats (LE-CA-MA-7).

Energy 

Development

The BLM should define the RMP’s relationship to the Solar 

Programmatic EIS.

The BLM's Programmatic EIS for Solar Energy Development in 

Six Southwestern States does not include Idaho and is not 

specifically related to the Jarbidge RMP. However, BLM has 

recognized solar energy development may be proposed in the 

planning area in the future. Alternative VI (Proposed RMP) 

included design features for solar energy development (LA-VIMA-5). These design features were derived from the Record of 

Decision for Solar Energy Development in 6 Southwestern 

States (BLM and DOE, 2012) and are included in Appendix B: 

Best Management Practices, Design Features, and Operating 

Procedures of the Final EIS.

Energy 

Development

The Final EIS should address cumulative impacts of solar 

developments where they are most likely to occur.

Cumulative impacts for solar developments were addressed in

Chapter 4 of the Final EIS in the Land Use Authorizations

section, even though no solar energy projects have been 

proposed or developed in the planning area.

Energy 

Development

BLM should require off-site mitigation for impacts which cannot 

be mitigated onsite. Off-site mitigation should include: (1) a “no 

net loss” or a “net gain” requirement for resources and values; 

(2) requirements for project developers to fund mitigation 

efforts based on the amount and value of the land impacted 

from development; (3) a centralized body should be 

established to oversee the funds and maximize the 

effectiveness of their use; and (4) off-site mitigation should be 

required to take place in the same ecoregion as the project 

site.

The RMP will establish broad-scale decisions to guide future 

land management actions in the planning area. The 

requirements suggested are not necessary at the planning-area 

scale. Individual project proposals that are analyzed in detail will 

include an analysis of environmental effects along with an 

analysis of mitigation, whether on-site or off-site. Off-site 

mitigation would be considered when appropriate.

Energy 

Development

We recommend BLM further refine the areas available to wind 

energy development by establishing zones where wind 

projects could be considered and closing the remainder of the 

planning area. Zones should be based on high-resource, low 

conflict areas on already-degraded lands and near existing 

The BLM carefully considered potential wind and solar 

development and identified areas available for energy 

development in each alternative. In Alternative VI (Proposed 

RMP), commercial wind and solar energy developments would 

not be permitted inside the sage-grouse management area or 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

infrastructure. The BLM is already taking a similar approach in 

the Programmatic EIS for Solar Energy Development and this 

RMP should designate zones for all types of renewable energy 

and then limit development to those zones. In addition, within 

the zones, BLM should prioritize lands most suitable for 

development.

utility right-of-way corridors (LA-VI-A-4). Outside the sagegrouse management area, renewable site testing, monitoring, 

and development should avoid special status species habitat 

unless unavoidable adverse effects can be mitigated (LA-VI-MA4).

Energy 

Development

The Draft RMP identifies “Potential Wind Development Areas” 

in Maps 79-83 and refers to these areas frequently throughout 

the environmental consequences. These areas might be 

appropriate wind energy development zones. However, we 

could not locate in the Draft RMP a definition for these areas in 

terms of how they were delineated or in the context of potential 

development outside of the areas. 

The wind energy development areas (expected wind energy 

developments areas in the Final EIS) were determined through a 

geographic information system (GIS) analysis of National 

Renewable Energy Laboratory high resolution wind resource 

data, which depicts the wind resource suitable for utility-scale 

wind development. Wind resources were classified according to 

wind power classes, which were based on typical wind speeds 

50 meters above the ground. Using GIS, wind resource data 

were intersected with the areas available for wind energy 

development outside of right-of-way (ROW) exclusion areas, 

ROW avoidance areas, and Visual Resource Management Class

I and II areas. 

Energy 

Development

Energy development and transmission must be focused in their 

occurrence, but allowed to strategically cross the lower 

Jarbidge planning area in order to best serve the nation. 

Electric power corridors need to travel through the peoples 

land to the largest extent possible.

Energy development and transmission projects were included in 

each alternative as an allowable use under Land Use 

Authorizations in both the Draft RMP/EIS and Final EIS. In 

Alternative VI (Proposed RMP), management action LA-VI-MA-2 

states, outside the sage-grouse management area, locate new 

tall structures (e.g. overhead power and phone lines) more than 

4 miles from occupied and unknown- status sage-grouse leks. 

Also, LA-CA-MA-2 allows for new rights-of-way within previous 

areas of disturbance where practical. Alternative VI included 

stipulations for development of energy and transmission (see 

LA-VI-A-1 through 4 and LA-VI-MA-1 through 6). 

Energy 

Development

Please include the following in the record for the Jarbidge 

RMP: “Wind Turbines Help Crops by Channelling Beneficial 

Breezes Over Nearby Plants” from ScienceDaily, Dec. 18, 

2010 at www.ScienceDaily.com. 

The BLM has reviewed “Wind Turbines Help Crops by 

Channelling Beneficial Breezes Over Nearby Plants” from 

www.ScienceDaily.com (DOE/Ames Laboratory, 2010) and 

determined this information is not relevant to this RMP. This is 

an online article about preliminary findings of a research 

program studying how wind turbines on farmlands interact with 

surrounding crops such as corn and soybeans. This article offers 

no information relative to shrub lands. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Energy 

Development

We encourage a more comprehensive review of wind energy in 

the RMP to accommodate prudent commercial wind energy 

development in areas where cost-competitive wind resources 

exist. Prioritization of commercial wind energy development is 

consistent with national energy initiatives and supports the 

economy of south central Idaho and northern Nevada.

The BLM carefully considered potential wind and solar 

development and identified areas available for energy 

development in each alternative, which are generally those 

areas outside of right-of-way exclusion and avoidance areas, 

and Visual Resource Management Class I and II areas.

Energy 

Development

The continued exclusion of wind energy development conflicts 

with the land use sections of the Draft RMP/EIS where wind 

energy development can be permitted if the impacts are 

mitigated (Chapter 4.3).

The Final EIS identified areas available for wind energy 

development, areas available with constraints to protect 

sensitive resources (right-of-way [ROW] avoidance areas), and 

areas not available for wind energy development (ROW

exclusion areas). 

Energy 

Development

Alternative IV allows for construction of wind energy on or in 

close vicinity to sage-grouse leks, but excludes development of 

the proposed commercial wind energy where the nearest lek is 

outside the preferred 2-mile buffer, which has taken the lek 

areas into concern.

Areas available for wind energy development have been revised 

in the Final EIS. In Alternative VI (Proposed RMP), commercial 

wind and solar energy developments would not be permitted 

inside the sage-grouse management area or utility right-of-way

corridors (LA-VI-A-4). Outside the sage-grouse management 

area, renewable site testing, monitoring, and development 

should avoid special status species habitat unless unavoidable 

adverse effects can be mitigated (LA-VI-MA-4). See also LA-VIMA-2.

Energy 

Development

The Jarbidge RMP must provide for the development of 

renewable energy resources, transportation routes, utility 

corridors, transmission lines, communication sites, and other 

uses with consideration for resource objectives (Chapter 2).

The Draft RMP/EIS and Final EIS both include a range of 

alternatives for land use authorizations, such as development of 

renewable energy, utility corridors, transmission lines, 

communications sites, and other uses.

Energy 

Development

Far too many of the Draft RMP/EIS actions will prohibit the 

exploration and development of energy sources ranging from 

wind, geothermal, and oil/gas. The attitude that energy can 

always be produced somewhere else is shortsighted and is 

ignorant of the realities facing our communities, State, and 

nation. The same can also be said for the draft RMP's 

treatment of mineral exploration and extraction. These are all 

products society needs and uses. Outsourcing all of our 

material needs is not sustainable. Rather than excluding large 

areas from exploration and development the focus should be 

on appropriate mitigation. 

The Draft RMP/EIS analyzed a range of alternatives for energy 

exploration and development which included constraints for 

resource use and protection. The alternatives in the Final EIS

allow for energy and mineral exploration and development with a 

range of options.

Energy 

Development

The BLM Draft RMP/EIS preferred alternative and all other 

alternatives as written (excluding the No Action Alternative) 

reject the potential development of sustainable and renewable 

energy sources. Elko County strongly encourages the BLM to 

The BLM carefully considered potential wind and solar 

development and identified areas available and areas not 

available for energy development in each alternative. The Final 

EIS addresses renewable energy throughout the document in 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

re-evaluate this management policy and permit the 

development of these resources to provide the electricity and 

energy sources of the future.

the Land Use Authorizations section of each chapter. The 

Chapter 2 Land Use Authorizations sections provided a range of 

allocations for areas available for renewable energy 

development.

Energy 

Development

The economic and tax benefits of cost-competitive wind power 

is extremely important to our area, as well as, important to the 

ability to meet national energy initiatives.

The economic benefits of wind energy development are 

portrayed in the Economic Condition section in Chapter 4 of the 

Final EIS based on two hypothetical levels of wind energy 

development, since projections of planned development are 

unavailable. This analysis portrays the employment and income 

effects (direct, indirect and induced) from construction and 

maintenance in addition to effects to local government revenues 

specific to the economic impact area.

Energy 

Development

The Final EIS should clearly permit wind energy development 

in areas where there is cost-competitive wind resources (Class 

4-6). As identified in Map 78, there is only small section in the 

southeastern part of the planning area where Class 4-6 wind 

resources exist.

The Final EIS identified areas available or unavailable for wind 

energy development by alternative in the Land Use 

Authorizations sections (Chapter 2). Due to concerns regarding 

the impact of wind energy development on sage-grouse, 

Alternative VI (Proposed RMP) would not allow wind energy 

development within the sage-grouse management area where 

the majority of good to outstanding wind resources exist 

(southeastern portion of the planning area). The range of 

alternatives included alternatives allow wind energy development 

in areas rated good to outstanding for wind resources.

Energy 

Development

The potential wind development areas in the Final EIS should 

include Class 4-6 resources as depicted in Map 78. According 

to the BLM’s own economic analysis in the Draft RMP/EIS, if 

the areas with cost competitive wind resources are not 

included in the Final EIS as potential wind development areas, 

Twin Falls, Elmore, Owyhee, and Elko Counties are at risk of 

losing an estimated $232 million in economic output, 2,200 

jobs, and $69 million in personal income. This is the equivalent 

of a 1-2% increase in employment in the Construction Sector 

over 2-3 years during project construction and a 7% increase 

in employment in the Utilities Sector over 25 years during 

project operations. Potential wind development areas in the 

Final EIS should exclude Class 1-2 resources.

Expected wind energy development areas were updated during 

the preparation of the Final EIS. The BLM utilized the National 

Renewable Energy Laboratory high resolution wind resource 

data in identifying areas available or unavailable for wind energy 

development. The economic advantages of wind energy 

development are portrayed in the Economic Condition section in 

Chapter 4 of the Final EIS for two hypothetical levels of wind 

energy development, since projections of planned development 

are unavailable. This analysis portrays the employment and 

income effects (direct, indirect and induced) from construction 

and maintenance in addition to effects to local government 

revenues specific to the economic impact area; however, there is 

no guarantee construction would occur or any benefits would be 

realized. 

Energy 

Development

The Final EIS should prioritize site-specific impact analysis, as 

required by NEPA, for land use applications and remove the 

broad land-use restrictions currently in the Draft RMP/EIS. In 

The Final EIS does not prioritize site-specific analysis of land 

use applications. The NEPA does not require prioritizing land 

use applications as suggested. The Final EIS does designate 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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particular, the Final EIS should not designate right-of-way 

(ROW) avoidance areas, ROW exclusion areas, or restrictions 

on development within 1-5 miles from active sage-grouse leks 

(LA-I-MA-2; LA-II-MA-2; LA-III-MA-2; LA-IV-MA-2; and LA-VMA-2).

right-of-way (ROW) avoidance and exclusion areas along with 

constraints based on resource objectives. Appendix C of BLM's 

Land Use Planning Handbook H-1601-1 (p. 21) requires 

identification of ROW avoidance areas, ROW exclusion areas, 

and identification of existing and potential development areas for 

renewable energy projects.

Energy 

Development

The Final EIS should ensure wind energy development is 

treated equitably with other forms of energy development, 

particularly oil and gas development. The Draft RMP/EIS 

establishes a goal for all alternatives to “provide leasable 

mineral development opportunities where they are compatible 

with other resources” (LE-CA-G-1). This goal should also apply 

to wind energy development (wind turbines, meteorological 

towers, transmission towers, and associated infrastructure) in 

the Final EIS.

Wind energy development is included in the Land Use 

Authorizations section. In Alternative VI (Proposed RMP) the 

objective is to “provide for the development of renewable energy 

resources, transportation routes, utility corridors, transmission 

lines, communication sites and other uses with consideration for 

resource objectives” (LA-VI-O-1). 

Energy 

Development

The right-of-way (ROW) avoidance areas and restrictions on 

development within 1-5 miles from active sage-grouse leks in 

the Draft RMP/EIS do not apply to leasable minerals. The Final 

EIS should ensure ROW avoidance areas and the restrictions 

on development within 1-5 miles from active sage-grouse leks 

also do not apply to wind energy development (including but 

not limited to wind turbines, meteorological towers, 

transmission towers and associated infrastructure).

In Alternative VI (Proposed RMP), the planning area would be 

open to mineral leasing with moderate constraints within the 

sage-grouse management area. Despite this, leasable mineral 

development activities would avoid special status species habitat 

if the activity would have an adverse effect, unless those 

adverse effects can be mitigated (LE-CA-MA-7). Alternative VI 

allows for development of renewable energy resources such as 

wind energy with consideration for resource objectives (LA-VI-O1). 

Energy 

Development

The Final EIS should establish land use management actions 

that recognize and rely on best management practices (BMPs) 

and comprehensive mitigation of impacts for wind energy 

development. The Final EIS should retain the BMPs in the

Wind Energy Development Programmatic EIS of June 2005, as 

amended by Instruction Memorandum 2009-043, that are 

currently part of the Jarbidge RMP due to the 2005 

amendment to the 1987 RMP.

The Final EIS included a management action common to all 

alternatives that provides direction for implementing best 

management practices from the Record of Decision for the Wind 

Energy Development Programmatic EIS. See LA-C-MA-1 and 

Appendix B: Best Management Practices, Design Features, and 

Operating Procedures. 

Energy

Development

Impacts from wind energy testing and monitoring are de 

minimis. The Final EIS should remove the restrictions on wind 

energy testing and monitoring (LAI-MA-4; LA-II-MA-4; LA-IIIMA-4; LA-IV-MA-4; LA-V-MA-4).

The determination of effects of individual projects, such as 

approvals for wind energy testing and monitoring, are done at 

the site-specific implementation decision level. The RMP 

establishes broad-scale decisions to guide future land 

management actions; management actions related to wind 

energy testing and monitoring have been retained. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Energy 

Development

Chapter 4 of the Draft RMP/EIS neither analyzes nor 

recognizes the significant environmental benefits of wind 

energy development in the planning area. Specifically, Chapter 

4 does not analyze reductions in regional air pollution 

associated with wind energy development, the climate change 

mitigation benefits related to greenhouse gas emissions 

reductions associated with wind energy development, or how 

impact mitigation actions associated with wind energy 

development can provide a net benefit to plants and animals 

(especially species that are particularly vulnerable to climate 

change). The Final EIS should analyze and recognize the 

environmental benefits of wind energy development in the 

planning area.

The potential environmental benefits suggested in the comment 

will vary depending on the specific features and circumstances 

related to individual project proposals. The variability of potential 

wind projects within the planning area is so large any such 

analysis would be speculative and ultimately inconclusive. The 

analysis suggested is more appropriate at the project level 

where details such as development location and footprint, 

product distribution, location of consumption and potential offsets 

of other power generation may be determined. The Final EIS 

does not attempt to analyze the effects of individual projects.

Energy 

Development

The alternatives in the Draft RMP/EIS are, for the most part, 

consistent with the 2005 amendments for wind energy policy. 

BLM should explain and state its consistency with the 2005 

amendments in the Final EIS and Record of Decision. Where 

elements of alternatives are inconsistent, those elements 

should be considered presumptively unreasonable if 

compelling justification is lacking.

The purpose of this RMP effort is to identify overall management 

and long-term direction for the Jarbidge planning area. Where 

practical, the BLM has maintained consistency between this 

RMP effort and the wind energy policy developed as a result of 

the 2005 Wind Energy Development Programmatic EIS. 

Energy 

Development

Section 3.3.4 should be updated to reflect accurate, up-to-date 

information. The section should be changed to: “The only 

authorized use granted to date for renewable energy 

development is rights-of-ways (ROWs) to Renewable Energy 

Systems (RES) Americas for construction and operation of 6 

meteorological towers for wind resource assessment within the 

13,000-acre portion of the Jarbidge Field Office within the 

proposed China Mountain Wind Project ROW area 

(approximately 30,000 acres on a combination of the Jarbidge 

Field Office, Wells Field Office, private land, and the Idaho 

Department of Lands). In May 2007, RES Americas submitted 

an application to construct and operate the proposed China 

Mountain Wind Project. The BLM issued a notice of intent to 

prepare an EIS associated with RES Americas’ application for 

a ROW grant for the project in April 2008 and conducted public 

scoping in April – July 2008 and October – November 2009. 

The proposed wind development is being analyzed in a 

separate EIS and would produce up to 400 megawatts.”

Chapter 3 has been updated in the Final EIS; however, the 

suggested language has not been included. The application filed 

by Renewable Energy Systems America for the China Mountain 

Wind Energy Project has been deferred until the 

Idaho/Southwest Montana Sub-Regional Sage-grouse Plan 

Amendment and the Jarbidge RMP have been completed. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Energy 

Development

BLM must observe principles of multiple use and sustained 

yield whereby the terms multiple use and sustained yield are 

defined in the Federal Land Policy and Management Act of 

1976 (FLPMA) Section 103 (43 U.S.C. 1702). Multiple use 

requires BLM to manage the Jarbidge Field Office for its 

various resource values in a manner that will “best meet the 

present and future needs of the American people; making the 

most judicious use of the land for some or all of these 

resources,” taking “into account the long-term needs of future 

generations for renewable . . . resources.” Sustained yield 

means “achievement and maintenance in perpetuity of a highlevel annual or regular periodic output of the various renewable 

resources of the public lands consistent with multiple uses.” 

The BLM has before it a golden opportunity to comply with the 

multiple use and sustained yield requirements of FLPMA by 

permitting the development of commercial-scale wind energy in 

the planning area.

Allocations in the Final EIS allow for wind energy development 

while fulfilling the requirements of the Federal Land Policy and 

Management Act of 1976 including its multiple use mandate, 

NEPA, and BLM planning policy. Multiple use also includes 

resource protection and harmonious and coordinated 

management of the various resources without permanent 

impairment of the productivity of the land and the quality of the 

environment with consideration being given to the relative values 

of the resources and not necessarily to the combination of uses 

giving the greatest economic return or the greatest unit output.

Energy 

Development

The revisions to the Jarbidge RMP should call upon BLM’s 

systematic, interdisciplinary approach to achieve consideration 

of the science of energy development and transmission, the 

science of climate change, and the economic sciences that 

support the development of commercial wind projects.

Development of the Draft and Final EISs used an 

interdisciplinary approach to integrate consideration of physical, 

biological, economic, and other available science.

Energy 

Development

Areas of Critical Environmental Concern (ACECs) are not 

universally excluded from wind energy development, but must 

be and can be managed consistent with the management 

prescriptions for the individual ACEC. See BLM Wind Energy 

Program Policies and Best Management Practices (BLM 

Instruction Memoranda (IM) 2009-043 and IM-2011-061). The 

relevance and importance of the proposed ACECs discussed 

in the Draft RMP/EIS can only be determined in comparison to 

other relevant and important values found in the planning area. 

Because the BLM prescribes the specific management 

measures to protect values for which any particular ACEC is 

designated, the permissible activities may vary dramatically 

among ACECs. To the extent BLM considers ACECs that 

would overlay commercial wind energy development in the 

Jarbidge planning area, those ACECs must be compared to 

the importance of the wind energy resource as recognized by 

Instruction Memorandum 2011-061 requires BLM "ensure 

consideration of the purpose and specific environmental 

sensitivities for which the area was designated" and that "all 

new, revised, or amended land use planning efforts will address 

and analyze Area of Critical Environmental Concern (ACEC) 

land use restrictions individually, including restrictions to wind 

energy development." In this land use planning effort, ACECs 

are not universally excluded from wind energy site testing and 

monitoring or wind energy development. ACECs will be 

managed consistent with the management prescriptions for the 

individual ACECs. Right-of-way avoidance areas are included in 

the proposed management prescriptions for some ACECs in 

some alternatives, consistent with resource values as defined by 

the relevance and importance criteria.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Congress in the Energy Policy Act and in presidential and 

secretarial policy initiatives. In short, if an ACEC is designated 

where commercial wind energy development is possible, the 

ACEC must and can accommodate the development of this 

important natural resource.

Energy 

Development

The present and potential uses of public lands in the Jarbidge 

Field Office must include presently available data sufficient to 

support applications for commercial wind development, 

specifically potential uses in the southeastern corner of the 

planning area. 

The BLM has considered available data in considering 

allocations for land use authorizations, including potential wind 

energy development. The BLM considered a reasonable range 

of alternatives related to renewable energy development. Areas 

available or unavailable for wind energy development are 

described in the Chapter 2 Land Use Authorizations sections.

Energy 

Development

Except for the extreme southeastern corner, the rest of the 

planning area is comprised almost entirely of low wind 

resource levels except for a smattering of medium resource 

levels dotted about the area. With few exceptions, there is little 

commercial wind resource in the State of Idaho. BLM must 

better explain the relative scarcity of wind values inventoried in 

the planning area and the sites in the southeastern corner 

where realization of wind energy values can be accomplished.

The scarcity of high potential wind areas in the planning area is 

visually apparent on Map 98 “Wind Resource Potential”. Areas 

within 2 miles of lands rated fair or higher for wind resources 

were depicted on the expected wind development area maps 

(Maps 99 to 105). The number of acres within expected 

development areas by alternative is included in the analyses in 

Chapter 4.

Energy 

Development

In weighing long-term versus short-term public benefits, the 

BLM should clarify commercial-scale development of the wind 

resource in the planning area is a long-term benefit lasting 

decades.

Economic impacts of wind development projects were analyzed 

for short-term time frames (<5 years) as well as for the 

anticipated life of a project (25 years). 

Energy 

Development

The Draft RMP/EIS has scattered its references to wind energy 

development throughout the document making it difficult for 

readers to fully appreciate the extent of the resource and 

BLM’s integration of the wind resource into the Draft RMP/EIS.

Wind energy development is specifically addressed in each 

chapter under the Land Use Authorizations section. 

Energy 

Development

Since BLM identified energy development as a substantial 

issue to be addressed and identified for its significance, BLM 

should reorganize the Draft RMP/EIS so as to highlight wind 

energy development as compatible with all alternative actions.

As noted, BLM did identify energy development as an issue to 

be addressed during the land use planning process. Scoping 

efforts resulted in comments both in favor of and opposed to 

wind energy projects and utility corridors (Draft RMP/EIS and 

Final EIS, Chapter 1 p. 1-8). Wind energy development was 

addressed in the Draft and Final EIS through a range of 

alternatives to reflect the potential for wind energy development. 

Wind energy was addressed under the Land Use Authorizations

sections per direction in the BLM Land Use Planning Handbook 

H-1601-1 and Instruction Memorandum 2011-061.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Energy 

Development

Appendix B: Specific Mandates and Authority should reference 

Secretary Order #3285A1 

(http://elips.doi.gov/app_SO/act_getfiles.cfm?order_number=3

285A1) which is the Secretary’s order to prioritize renewable 

development and Secretary Order 3289A1 

(http://elips.doi.gov/app_SO/act_getfiles.cfm?order_number=3

289A1) which is the Secretary’s order addressing the impacts 

of climate change.

Specific Mandates and Authority (Appendix A in the Final EIS) 

does include Secretarial Order 3285A1—Renewable Energy 

Development by the Department of the Interior and Secretarial 

Order 3289A1—Addressing the Impacts of Climate Change on 

America's Water, Land, and Other Natural and Cultural 

Resources. 

Energy 

Development

Management actions (LA-C-MA-1) common to the No Action

Alternative and all action alternatives will implement the 

programmatic policies and best management practices in the 

Wind Energy Development Program. Where other 

management actions conflict with this statement, the conflicting 

actions should be expressly limited to management actions 

unrelated to wind energy development.

The Record of Decision for the Wind Energy Development 

Programmatic EIS states the BLM will not issue right-of-way

authorizations for wind energy development on lands on which 

wind energy development is incompatible with specific resource 

values. Additional areas of land may be excluded from wind 

energy development on the basis of findings of resource impacts 

that cannot be mitigated and/or conflict with existing and planned 

multiple-use activities or land use plans. Including the suggested 

statement would be contrary to the BLM's wind energy policy.

Energy 

Development

The Sagebrush Sea Area of Critical Environmental Concern

discussion needs a discussion of general management 

practices and use that would accommodate wind energy 

development similar to the accommodations of salable 

minerals.

The suggested modification was not included in the Final EIS. 

The Sagebrush Sea Area of Critical Environmental Concern is

not included in Alternative VI (Proposed RMP).

Energy 

Development

The Draft RMP/EIS states the best management practices that 

apply to operational wind farms do not require adaptive 

management and do not address “other displacement 

concerns”. The Final EIS should state the BLM can require 

measures to address adaptive management and displacement 

concerns on a project-specific basis.

The Jarbidge Field Office will continue to follow the 

programmatic wind energy program Record of Decision and 

associated best management practices (BMPs) per LA-C-MA-1 

in the Final EIS. The suggested change was not incorporated 

into the Final EIS because BLM can require site-specific BMPs 

and other measures on a project-specific basis. 

Energy 

Development

The Draft RMP/EIS states: “Wind energy developments and 

other land use authorizations are expected to increase access 

to some areas that presently receive low levels of human use.” 

This is not necessarily accurate. Although wind energy project 

construction would inherently increase use of an area 

temporarily, public access to the area generally would 

decrease during construction for safety reasons. During 

operations, access to the area can remain in the same general 

condition as it was prior to construction. The BLM should 

remove this statement in the Final EIS.

This is stated in the Draft RMP/EIS in No Action Alternative 

under the Special Status Wildlife section in Chapter 4. The 

increased number and condition of roads for land use 

authorizations and wind energy development projects is 

expected to result in an increase of human presence and use in 

areas are currently inaccessible due to the lack of roads. The 

statement in the RMP, “Wind energy developments and other 

land use authorizations are expected to increase access to some 

areas that presently receive low levels of human use” is 

appropriate. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Energy 

Development

The Draft RMP should have considered the adverse 

environmental impacts that could result from not considering 

wind energy development as an alternative. See the BLM Final 

Programmatic Environmental Impact Statement on Wind 

Energy Development on BLM-Administered Lands in the 

Western United States (BLM, 2005), pp. 6-21 to 6-25. As the 

Draft RMP addresses none of the above issues, it does not 

achieve the goals of a fully informed NEPA document: a 

balanced assessment of alternatives. Accordingly, we urge the 

BLM to consider these benefits in its further evaluation in 

finalizing the RMP.

The referenced section in the Programmatic Environmental 

Impact Statement (EIS) provides a comparison of the 

environmental impacts of wind energy development with impacts 

associated with other energy sources. This comparison 

considers the amount of land area disturbed, air emissions, 

water use, and waste generation for the entire fuel cycle of 

different energy technologies. 

The suggested analysis was not included in the Final EIS 

because commercial wind energy development is considered as 

one of the many allowable uses included in each alternative.

Attempting to analyze energy development projects and any 

adverse environmental impacts that may be offset by new 

development in the absence of a project proposal would be 

speculative at best.

Energy 

Development

Achieving the environmental benefits of developing the nation’s 

renewable energy resources and preserving resource 

management goals is usually compatible. In the rare instance 

in which those goals are not, an agency should take a hard 

look at how, if possible, to reconcile these goals. Congress 

adopted NEPA to ensure Federal agencies undertook such a 

hard look before making decisions. In this case, the Draft RMP 

did not take the requisite hard look to support a decision to not 

consider wind energy development in the alternatives. NEPA, 

of course, does not bar BLM from making such a decision, but 

it does require the decision to be fully informed before doing 

so. The Draft RMP’s failure to engage in informed decisionmaking is inconsistent with the precepts of the NEPA process.

The Federal Land Policy and Management Act of 1976 

establishes the requirement for BLM to develop land use plans 

which provide for the use and management of public lands. 

Management is based on the basis of multiple use and sustained 

yield. As part of the process of revising the Jarbidge RMP, the 

BLM is taking a hard look at whether to allow wind energy 

development in the planning area. The alternatives under 

consideration in the Final EIS contain a range of areas where

renewable energy development is allowed. The analysis in 

Chapter 4 of the Final EIS informs the decision-maker of the 

environmental consequences of the various alternatives 

including trade-offs related to developing renewable energy 

resources and preventing undue and unnecessary degradation 

of resources.

Energy 

Development

We were surprised to learn the three key resources prioritized 

in the development of the Draft RMP are vegetation, livestock 

grazing, and Areas of Critical Environmental Concern 

(September 13, 2010 BLM Status Report to U.S. District Court 

for the District of Idaho, p. 5). In contrast, wind energy 

development was not included as one of the priorities. Given 

congressional and the administration’s support for renewable 

energy, wind energy development should have been 

considered an equal or greater priority.

Chapter 1 of the Draft RMP/EIS and Chapter 1 of the Final EIS 

describe the issues addressed in this land use planning effort. 

The planning issues are topics where there are often mutually 

exclusive differences in opinion as to how a resource or use 

should be managed. For the Jarbidge RMP revision effort, 

energy development is one of the six issues identified along with 

vegetation, livestock grazing, recreation, Areas of Critical 

Environmental Concern, and sage-grouse.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Energy 

Development

The Draft RMP’s suggestion that wind energy development 

occur within areas with low to marginal wind resources does 

not make sense from a practical planning perspective. In fact, 

in one example, a “Potential Wind Development Area” was 

identified in a location referred to as “Brown’s Bench”. Under 

the current Draft RMP approach this would be a suggested 

area for wind development. The problem with this 

recommendation is it fails to consider that this area contains 

Class 1-2 winds which are not viable for commercial wind 

development, and also includes an area with several active 

sage-grouse leks (Map 78), which the conservation community 

generally considers to be a sensitive wildlife resource. 

Areas available for wind energy development have been revised 

in the Final EIS. In Alternative VI (Proposed RMP), commercial 

wind and solar energy developments would not be permitted 

inside the sage-grouse management area (LA-VI-A-4). Brown’s 

Bench located in the southeastern portion of the planning area is 

within the sage-grouse management area. 

Energy 

Development

To address apparent inconsistent management approaches, 

the Draft RMP should focus on ensuring wind energy 

development occurs in areas where the wind resource is 

strongest and where potential impacts can be reasonably 

mitigated. BLM’s own goals of choosing the best resource 

management option could be seriously undercut by the blanket 

exclusion of wind development from certain high-capacity wind 

areas, failing to allow projects even in some areas that, upon 

careful evaluation, could be found to compatibly support both 

wind energy and habitat protection.

The Final EIS identifies areas available or unavailable for wind 

energy development in the Chapter 2 Land Use Authorizations

sections. Due to concerns regarding the impact of wind energy 

development on sage-grouse, Alternative VI (Proposed RMP) 

would not allow wind energy development within the sagegrouse management area where the majority of good to 

outstanding wind resources exist (southeastern portion of the 

planning area).

Energy 

Development

In keeping with Department of Interior’s Goals of more 

renewable energy development on public lands, the BLM 

should prioritize cost-effective commercial wind energy 

development in Class 4-7 wind resources consistent with 

Secretarial Order No. 3285 and Secretarial Order No. 3289. 

BLM follows the BLM Land Use Planning Handbook direction (H1601-1) in defining and addressing wind energy in the Land Use 

Authorizations sections. The direction from the handbook is to 

identify existing and potential development areas for renewable 

energy projects. Both the Draft RMP/EIS and the Final EIS

contain a range of alternatives that vary from allowing to 

disallowing wind development. In Alternative VI (Proposed RMP) 

wind energy development was identified based on those areas 

outside of the sage-grouse management area. 

Energy 

Development

The BLM should prioritize site-specific analysis rather than 

broad land management decisions that impact huge swaths of 

the Jarbidge Field Office. 

The purpose of an RMP is to establish broad-scale land 

management decisions to guide future site-specific 

implementation level decisions. The Final EIS contains a range 

of alternatives and considers a variety of allocations for wind 

energy development. 

Energy 

Development

Ensure wind energy development is treated equitably 

compared to other types of development.

The Proposed RMP is structured according to the BLM Land 

Use Planning Handbook where resources include soil and water, 

vegetation, fish and wildlife, wild horses and burros, cultural 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

resources, etc.; and resource uses include livestock grazing, 

recreation, lands and realty, etc. Existing and potential 

development areas for renewable energy projects falls under the 

Lands and Realty section of Resource Uses in the BLM Land 

Use Planning Handbook. Wind energy development was treated 

equitably with other types of development.

Energy 

Development

Emphasize the land use management actions requiring 

mitigation of impacts.

The purpose of an RMP is to establish broad land management 

decisions to guide future site-specific implementation level 

decisions. Emphasizing site-specific mitigation at the land use 

planning level is not practical or reasonable. Specific mitigation 

measures will be identified through site-specific environmental 

analysis at a project level.

Energy 

Development

The BLM should adopt LA‐II‐A‐5 versus LA‐IV‐A‐5. Wind 

energy needs to be permitted wherever the resource exists, 

particularly the areas rated good or better, so long as the 

impacts can be mitigated.

Both the Draft RMP/EIS and the Final EIS identified lands 

available for utility-scale wind development as those within 2 

miles of areas rated fair or higher for wind resources. For the 

analysis in Chapter 4, the BLM assumed there would be more 

interest in developing wind energy on or within 2 miles of lands 

rated fair or higher than on other lands in the planning area. 

However, in Alternative VI (Proposed RMP), wind energy 

development would not be permitted inside the sage-grouse 

management area. Outside the sage-grouse management area, 

renewable energy site testing, monitoring, and development 

should avoid special status species habitat unless unavoidable 

adverse effects can be mitigated.

Energy 

Development

A more complete map showing all the layers of proposed 

management actions needs to be created. Map M‐83 is 

confusing, several areas identified as available for wind energy

development are right on top of sage-grouse leks. The maps, 

tables, and supporting data all need to be checked for 

accuracy and then reconfigured in a more accurate 

representation of what the results of these management action 

will be.

The maps, tables and supporting data have been updated in the 

Final EIS.

Energy 

Development

The BLM maps and data do not fully illustrate on how much 

acreage LA‐IV‐MA‐2 would restrict development. Maps and 

data have failed to take into account the leks from Bud Lewis 

Hill to the Antelope Pocket, if the 5-mile management action is 

used. In addition leks can move and over time new leks can be 

created, field work continues to find new leks. How does BLM 

propose to address leks moving or the discovery of new leks? 

The BLM carefully considered potential renewable energy 

development and identified areas available for energy 

development. Maps and data have been updated in the Final 

EIS. In Alternative VI (Proposed RMP), commercial wind and 

solar energy developments would not be permitted inside the 

sage-grouse management area (LA-VI-A-4). The identification of 

the sage-grouse management area considers sage-grouse 
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All of the maps and data associated with wind energy and 

sage-grouse leks need to be reviewed further for accuracy. 

The intention of the management actions when applied to the 

maps are not readily apparent and often appear inaccurate.

habitat needs, not just lek locations.

Energy 

Development

The Jarbidge RMP should exclude unsupportable bias against 

wind energy (example: sage-grouse buffer analysis must be 

site specific and scientific, rather than broad management 

opinions about what is best for the Jarbidge planning area). 

The Draft RMP/EIS already required best management 

practices for wind energy development in the planning area.

The Draft RMP/EIS and Final EIS identified areas available or 

unavailable for wind energy development by alternative in the

Chapter 2 Land Use Authorizations sections. BLM recognizes 

the construction and operation of a wind energy project would 

require road construction, soil disturbance, vegetation 

disturbance, and consumptive and non-consumptive uses of 

water which would result in impacts to resources (soils, 

vegetation, wildlife, fish, riparian and wetland areas, water 

quality or quantity). Best management practices, design 

features, and operating procedures are included in Appendix B 

to reduce resource impacts and the potential for unnecessary 

and undue degradation of public lands. 

Energy 

Development

In an effort to ensure energy resource development projects 

have the greatest opportunity for success on Federal land, we 

encourage BLM to adopt a final alternative that incorporates 

these principles as well as a reasonable mitigation framework 

that is transparent, inclusive and responsive to the needs of 

the State. Moreover, the State believes that the final RMP 

needs to be expanded to address other forms of energy 

resources (e.g., solar, geothermal, oil gas, nuclear and other 

mineral development).

The Final EIS analyzed a range of alternatives for energy 

development, resource use, and resource protection. 

Energy 

Development

Maps 21 and 78 in the Draft RMP/EIS show most lands with 

good or excellent wind potential do not contain key sagegrouse habitat.

The Final EIS updated maps to include sage-grouse habitat 

(Map 25).

Energy 

Development

BLM must include full analysis of potential night lighting, noise 

and other issues associated with any renewable or other 

energy development, military or other right-of-way here. Night 

lighting on tall structures may result in death of migratory birds, 

interfere with birds like sage-grouse that move around during 

dim light conditions, and impair recreational uses. BLM must 

develop clear protocols for analyzing all of these disturbances 

and their effects.

The analysis suggested is more appropriate at the 

implementation level, when a project is actually proposed and 

the potential impacts can be analyzed. At the RMP level, an 

analysis would be speculative because it is not possible to know 

when, where, or how much light and noise might occur. The 

Final EIS did consider these effects at the broad-scale and 

included management actions (See AAV-CA-MA-6 and 7) to 

manage light and noise impacts.

Energy 

Development

Many of the actions in the RMP are linked or related to other 

energy actions. For example, China Mountain Wind is linked to 

the Southwest Intertie Project. There are inter-relationships - 

Cumulative impacts are assessed for each of the resources for 

all alternatives in Chapter 4. The China Mountain Wind Energy 

Project is not linked to the Southwest Intertie Project. The two 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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and cumulative effects that are not examined. projects are independent of one another and either project could 

feasibly be constructed without the other.

Energy 

Development

BLM must provide much broader area mapping of wind 

"potential". This is necessary to understand the relative 

importance of the Jarbidge planning area for any wind 

development.

Potential wind energy resources are mapped for the planning 

area in the Final EIS (Map 98). Wind developments on private 

lands are identified in the cumulative impacts analyses for each 

resource.

Energy 

Development

All alternatives must be examined across a broader landscape 

context so that the full cumulative effects of wind energy 

development can be understood.

Cumulative impacts analyses from wind energy development 

were included in the Chapter 4 sections for the various 

resources and resource uses. 

Energy 

Development

Why in Map 79 does BLM then show under Alternative I that 

the China Mountain area would be available for wind?

Wind energy would be allowed in Alternative I with major 

constraints. Areas available to energy development have been 

further refined in the Final EIS. In Alternative VI (Proposed 

RMP), wind energy development would not be permitted inside 

the sage-grouse management area or within utility right-of-way 

corridors. 

Energy 

Development

Potential wind development areas cannot be designated within 

restricted airspace. R-3202 and R-3204. The Jarbidge Military 

Operating Area extends from 100 feet above ground level and 

cannot accommodate wind energy development.

In the Final EIS, the US Air Force (USAF) Military Operating 

Area is an avoidance area for each alternative. Alternatives I-VI 

all state that new rights-of-way must be consistent with USAF 

airspace restrictions. 

Energy 

Development

In Chapter 1, it is not clear why the BLM did not analyze 

energy development as alternative worthy of detailed standalone analysis, based on the goals of the Department of the 

Interior . 

Chapter 1 identified energy development as one of the primary 

issues to be addressed. The purpose of the RMP is to establish 

broad-scale direction to guide future management throughout 

the entire planning area. Devoting one alternative entirely to 

energy development would be impractical because it would 

ignore resources and other land uses. 

Energy 

Development

There is also a contradiction in Chapter 2 (1.3.2.3) that the 

China Mountain Wind Project could be considered by the BLM 

"under any of the alternatives analyzed in this document." 

However, it seems that commercial scale wind energy really 

could only be approved under the No Action Alternative and 

Alternative II.

Restrictions on commercial wind development (sage-grouse

management area, wilderness, Visual Resource Management

Class I and II areas, etc.) vary in location for each alternative. 

The location and size of the China Mountain Wind Project, as 

proposed in 2007, would require an RMP Amendment for 

Alternatives I, III, IV, V and VI. The sentence in Chapter 1 was 

removed in the Final EIS.

Energy 

Development

All Draft RMP/EIS alternatives should accommodate 

commercial wind energy development in the only location 

where a cost-competitive wind resource exists (Maps 78-83). 

Careful planning, mitigation, and best management practices 

are already required-for wind energy development in the 

Jarbidge planning area pursuant to BLM's amendments of the 

Jarbidge RMP in 2005. This should be thoroughly discussed in 

Commercial wind energy development was included in each 

alternative as an allowable use in both the Draft RMP/EIS and 

Final EIS. Each alternative varies in the percent of land available 

for utility-scale development. 
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a single section of the RMP so the public better understands 

BLM's support for wind energy. 

Energy 

Development

Potential energy developers want to develop commercial wind 

energy in the area where the wind resource is the greatest, 

while being allowed to mitigate impacts. These must be given 

within the final RMP.

Commercial wind energy development was included in each 

alternative as an allowable use in both the Draft RMP/EIS and 

Final EIS. Each alternative varies in the percent of land available 

for commercial-scale development. The BLM assumed that there 

will be more interest in developing wind energy on or within 2 

miles of lands rated fair or higher (Class 3-7) than on other lands 

in the planning area.

Energy 

Development

Please make sure maximization of wind energy resources is a 

priority in the final RMP.

Commercial wind energy development was included in each 

alternative as an allowable use in both the Draft RMP/EIS and 

Final EIS. However, the focus of the Alternative VI (Proposed 

RMP) is to actively restore the resiliency of ecosystem structure 

and function while balancing uses within the planning areas, not 

to maximize wind energy resources.

Energy 

Development

Wind power is one of the fastest growing forms of new 

electricity generation in the U.S. and is an environmentallyfriendly energy source. The Department of the Interior's (DOI's) 

Sustainability Plan (DOI, 2010) also clearly states that the 

"strategies for meeting the FY2020 greenhouse gas reduction 

goals of the DOI include: implementing on-site renewable 

energy generation projects". Based on the aforementioned 

strategy, the Final EIS should permit environmentallysustainable commercial wind energy development.

The referenced sustainability plan details the Department of the 

Interior’s (DOI’s) efforts to install renewable energy systems at 

wildlife refuges, parks, and science centers around the nation; 

increase the fuel efficiency of its vehicle fleet to exceed emission 

reduction goals; and increase use of alternative fuels. 

Additionally, the Department has initiated a “Green DOI 

Challenge” designed to solicit ideas from employees on how to 

green the Department. 

Some level of commercial wind energy development is allowed 

in each alternative considered in the Final EIS. 

Energy 

Development

Commercial wind energy analysis in the Draft RMP was not 

performed thoroughly and contains inaccuracies. The BLM 

should analyze and recognize the greenhouse gas emissions 

reduction benefits of commercial wind energy development 

and further analyze the ramifications of climate change, which 

are acknowledged, but then dismissed, in the Draft RMP.

No analysis was conducted for the potential for greenhouse gas 

(GHG) emission reduction in association with commercial wind 

energy development. This is because simply allowing or 

disallowing commercial wind energy development within the 

planning area in itself does not reduce GHG emissions. 

Assuming that commercial wind energy development would

displace fossil fuel power plants elsewhere and thereby reduce 

GHG emissions is speculative and is beyond the scope of this 

planning effort.

Energy 

Development

Where wind energy may have an impact, each alternative in 

the Final EIS should recognize avoidance, minimization, and 

mitigation of those impacts. Mitigation actions can provide a 

net benefit to vegetation, the working landscape, and species 

Appendix B: Best Management Practices, Design Features, and 

Operating Procedures in the Final EIS included a list of design 

features and best management practices (BMPs) that will be 

considered and applied, as appropriate, when a wind energy 
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such as sage-grouse. It is clear that wind energy provides a 

net benefit to the environment and most certainly needs to be 

emphasized as part of all reasonable alternatives in the Final 

EIS. 

development project (or other project) is proposed. Design 

features and BMPs help to reduce, avoid, or minimize 

environmental impacts.

Energy 

Development

I am concerned specifically about the RMP and how it does not 

allow renewable energy. Wind energy is booming right now 

and we need to do what we can to allow companies to develop 

our high winds. The RMP should allow the development of 

renewable energy, especially the development of wind energy. 

All alternatives in both the Draft RMP/EIS and Final EIS allow for 

renewable energy. Part of the Alternative VI (Proposed RMP) 

goal for land use authorizations is to provide for the development 

of renewable energy resources (see the Land Use 

Authorizations sections in Chapter 2). Commercial wind energy 

development was included in each alternative as an allowable 

use. However, each alternative varies in the percent of land 

available for utility-scale development.

Energy 

development

Renewable energy is important and development should be 

allowed even if it is going to harm sensitive or endangered 

species.

All alternatives in both the Draft RMP/EIS and Final EIS allow for 

renewable energy development. 

Energy 

Development

I request that you include full access for responsible 

exploration and production of hydrocarbons. Hydrocarbons are 

not a bogyman that must be stopped everywhere. There are 

thousands of examples of responsible hydrocarbon exploration 

and production and that must be allowed.

The alternatives in the Final EIS all include oil and gas 

development opportunities where development is compatible 

with other resources (LE-VI-O-1).

Energy 

Development

The Jarbidge RMP should limit off-road vehicles and wind 

turbines in the areas critical for endangered species.

Under Alternative VI (Proposed RMP), off-road vehicles would 

be limited to designated routes in the majority of the planning 

area, and wind energy development would not be permitted 

inside the sage-grouse management area. Outside the sagegrouse management area, wind energy development should 

avoid special status species habitat unless unavoidable adverse 

effects can be mitigated.

Energy 

Development

Any selected alternative identifying land available for wind 

development should include all lands identified as having fair 

or higher wind potential. 

The Final EIS identifies areas that are available or unavailable 

for wind energy development in the Chapter 2 Land Use 

Authorizations sections. Lands rated with fair or higher wind 

resources are depicted on expected wind development area 

maps (Maps 99 to 105). 

Energy 

Development

One additional area that needs further elaboration within the 

RMP is wind energy development and its economic 

advantages (Sections 2.6, 3.5.1, 3.5.2, 4.6.2 pp. 4-776-779, 4-

789-790). The collective benefits of a commercial wind energy 

project, in the areas where the wind resources are the greatest 

(see Map 78), stand to bring substantial rewards to Twin Falls 

County and its surrounding communities.

The areas open to wind energy development have been updated 

in the Final EIS. The economic advantages of wind energy 

development were portrayed in the Economic Conditions section 

in Chapter 4 of the Final EIS for two hypothetical levels of wind 

energy development, since projections of planned development 

are unavailable. This analysis portrays the employment and 

income effects (direct, indirect and induced) from construction 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

and maintenance in addition to effects to local government 

revenues specific to the economic impact area. The hypothetical 

levels examined include a 1.5 megawatt (MW) project and a 2.0 

MW project and can be used to examine economic effects of 

future development on BLM in the impact area (if structural shifts 

in the economy have not occurred since the time of this 

analysis).

Energy 

Development

Maps 79-83 identify potential wind development areas in 

locations of the planning area with Class 1-2 (poor or marginal) 

wind resources as described in Map 78. Class 1-2 wind 

resources are not viable for wind energy development. Maps 

79-83 should be corrected to identify potential wind 

development areas as locations within the planning area with 

Class 3-6 wind resources as described in Map 78.

Both the Draft RMP/EIS and the Final EIS identified lands 

potentially available for utility-scale wind development as those 

within 2 miles of areas rated fair or higher for wind resources. 

For the analysis in Chapter 4, the BLM assumed there would be 

more interest in developing wind energy on or within 2 miles of 

lands rated fair or higher than on other lands in the planning 

area. However, in Alternative VI (Proposed RMP), wind energy 

development would not be permitted inside the sage-grouse 

management area. Outside the sage-grouse management area, 

wind energy development should avoid special status species 

habitat unless unavoidable adverse effects can be mitigated.

Energy 

Development

The RMP does not provide for the development of wind 

energy. Several management actions in the Draft RMP/EIS 

could be misunderstood to exclude commercial wind energy. 

The Federal government has mandated new forms of 

renewable and sustainable energy must be developed. The 

final RMP must thoroughly consider the value of commercial 

wind and other renewable energy development on our public 

lands, specifically within the Jarbidge Field Office.

The BLM carefully considered potential wind and solar 

development and identified areas available and areas not 

available for energy development in each alternative. The Final 

EIS addresses renewable energy throughout the document in 

the Land Use Authorizations section of each chapter. The 

Chapter 2 Land Use Authorizations sections provides a range of 

allocations for areas available for renewable energy 

development.

Energy 

Development

The Jarbidge planning area has one of the best commercial 

wind energy resources in the State of Idaho (Map 78). Why 

was wind energy not a key resource considered or given equal 

treatment with other resources in the Draft RMP/EIS? The 

Draft RMP/EIS does not identify renewable energy as a 

resource in Sections 2.3 and 3.2 or renewable energy 

development as a stand-alone resource use in Sections 2.4 

and 3.3. The omission of wind as a resource or wind energy as 

a stand-alone resource use is inconsistent with the goals of the 

President, Congress and Secretary Salazar to prioritize 

development of renewable energy resources on Federal land 

and the Federal Land Policy and Management Act of 1976’s 

(FLPMA) identification of “rights-of-way” as a “principal or 

Chapter 1 of the Draft RMP/EIS and Chapter 1 of the Final EIS 

describe the issues addressed in this land use planning effort. 

The planning issues are topics where there are often mutually 

exclusive differences in opinion as to how a resource or use 

should be managed. For the Jarbidge RMP revision effort, 

energy development is one of the six issues identified along with 

vegetation, livestock grazing, recreation, Areas of Critical 

Environmental Concern, and sage-grouse. Wind energy 

development was given consideration as a key resource use.

The areas available to wind energy development have been 

updated in the Final EIS. Commercial wind energy development 

was included in each alternative as an allowable use in both the 
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Category Comment Response

major use” of public lands (FLPMA Sec. 103(1)). All but one of 

the five Alternatives (I, III, IV, and V) exclude wind energy 

development in the limited locations where a commercial-scale 

wind resource exists.

Draft RMP/EIS and Final EIS but was not considered a "key 

resource". The alternatives are structured according to the BLM 

Land Use Planning Handbook where resources include soil, 

water, vegetation, fish and wildlife, wild horses and burros, 

cultural resources, etc.; and resource uses include livestock 

grazing, recreation, lands and realty, etc. Existing and potential 

development areas for renewable energy projects falls under the 

Lands and Realty section of Resource Uses in the BLM Land 

Use Planning Handbook. Wind energy development is 

authorized under a Federal Land Policy and Management Act of 

1976 Title V right-of-way and can be found in the Final EIS in the

Land Use Authorizations sections. 

Energy 

Development

I encourage you to consider mixing and matching the five 

alternatives in the Draft RMP to ensure wind energy 

development is permitted in the Jarbidge planning area where 

the wind resource is at its greatest. 

Commercial wind energy development was included as an 

allowable use in every alternative in both the Draft RMP/EIS and 

Final EIS. Each alternative varies in the percent of land available 

for utility-scale development. The BLM assumed that there will 

be more interest in developing wind energy on or within 2 miles 

of lands rated fair or higher (Class 3-7) than on other lands in the 

planning area. 

Energy 

Development

Renewable energy is important, but development should not 

be allowed if it is going to harm sensitive or endangered 

species or fragment habitat. 

The Federal Land Policy and Management Act of 1976 directs 

the BLM, in the development and revision of land use plans, to 

use and observe the principles of multiple use and sustained 

yield, including both renewable and nonrenewable resources. 

Management actions are included in each of the alternatives to 

aid in achieving multiple use and sustained yield objectives. 

Some specific management actions limit or restrict development. 

Environmental 

Justice

We request that the proposed action comply with US Forest 

Service Departmental Regulation 5600-2 

(http://www.usda.gov/da/5600-2.pdf) including the definition of 

environmental justice provided therein. Environmental justice 

means that, to the greatest extent practicable and permitted by 

law, all populations are provided the opportunity to comment 

before decisions are rendered on, are allowed to share in the 

benefits of, are not excluded from, and are not affected in a 

disproportionately high and adverse manner by, government 

programs and activities affecting human health or the 

environment.

The BLM does not follow US Forest Service departmental 

regulations. However, the BLM has an independent obligation to 

address environmental justice. The Secretary of the Interior 

adopted a Strategic Plan for Environmental Justice in 1995, 

which the BLM has used as guidance for addressing 

environmental justice in its NEPA documents. The intention of 

the guidance is to achieve the goals of Executive Order 12898, 

which the Secretary has described as: "Environmental justice is 

achieved when everyone enjoys the same degree of protection 

from environmental hazards and has equal access to the 

decision-making process." Environmental Justice Strategic Plan 

2012-2017 (November 2011 Revised Draft), p. 7.

 
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The BLM’s public involvement process included the minority and 

under-represented populations described in the Executive Order, 

and Alternative VI (Proposed RMP) ensures that no racial, 

ethnic, cultural or socio-economic group disproportionately bears 

the negative environmental consequences of the BLM's land 

allocation decisions.

Fish The overall objective and management strategy for fish in the 

Final EIS should be to maintain or improve significant fishbearing habitat. Insignificant streams should not be a focus for 

management. Site-specific management guidelines should 

replace the use of the Aquatic and Riparian Management 

Strategy. 

Alternative VI (Proposed RMP) included goals, objectives, and 

management actions for fish in the Chapter 2 Fish section. 

These goals, objectives, and management actions apply to 

native non-game fish (sculpin, minnows, dace, and shiners). The 

goals, objectives and management actions for Endangered 

Species Act-listed and BLM sensitive aquatic species are 

included in the Final EIS in Chapter 2, Special Status Species

section, under Management for Special Status Species in 

Riparian Areas, Wetlands, and Streams. All of the streams in the 

planning area were considered important for special status fish, 

native non-game fish, riparian values, and water quality. 

Appendix D: Aquatic and Riparian Management Strategy used 

site-specific data to define current riparian and instream 

conditions. Management for activities affecting Riparian 

Conservation Areas that were derived from the Inland Native 

Fish Strategy (USDA, 1995) is included in Table D-8. Where 

needed, site-specific management guidelines would be 

developed at the project level. 

Fish In the Executive Summary on ES-31, where it discusses the 

Salmon Falls Creek Area of Critical Environmental Concern 

(ACEC), it mentions this portion of Salmon Falls Creek has 

redband trout, as it does in other areas of the plan. Map 18 

shows redband trout on Salmon Falls Creek below Balanced 

Rock. Correct the map to show redband trout in the ACEC. The 

Idaho Department of Fish and Game and others have done 

previous fish surveys. These surveys show no redband trout 

below Balanced Rock. 

The Final EIS corrected information on the distribution of 

redband trout and bull trout. The BLM contacted Idaho 

Department of Fish and Game and confirmed redband trout are 

present in Salmon Falls Creek downstream of Balanced Rock 

Crossing. Redband trout presence and abundance varies 

seasonally. The Final EIS displayed the updated information on 

Map 24, “Bull Trout and Redband Trout Distribution”. 

Fish We have concerns with the Aquatic and Riparian Management 

Strategy that appears in Appendix D of the Draft RMP/EIS. A 

final Environmental Impact Statement (EIS) and Record of 

Decision have never legitimized this strategy. It is not 

appropriate that the Draft RMP/EIS incorporated this language.

The BLM created the Aquatic and Riparian Management 

Strategy (ARMS; Appendix D) using current BLM guidance as 

described in the Introduction section of the ARMS. This Final 

Environmental Impact Statement is the NEPA analysis of the 

ARMS and the forthcoming Record of Decision will be the 

decision document.
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Fish The Idaho Department of Fish and Game (IDFG, 2005) species 

account for leopard dace indicates that it is ranked by Nature 

Serve as G4 (Apparently secure: uncommon but not rare; 

some cause for long–term concern due to declines or other 

factors). IDFG (2005) species account reports that the sole 

reason for inclusion on the Species of Greatest Conservation 

Need (SGCN) is “Lack of essential information pertaining to 

status.” IDFG (2005) Appendix F/Ray-finned fishes/Leopard 

Dace, can be found at: 

http://fishandgame.idaho.gov/cms/tech/CDC/cwcs_appf/Leopar

d%20Dace.pdf. The Draft RMP/EIS should accurately report 

the reason that leopard dace is included on the SGCN. The 

Draft RMP/EIS does not do so.

The Final EIS included additional information on the inclusion of 

leopard dace on the Idaho Department of Fish and Game (IDFG) 

(2005) list of Species of Greatest Conservation Need (SGCN) in 

Chapter 3, Fish section, Game and Non-Game Fish Species. 

The NatureServe ranking of G4 categorizes this species as 

apparently secure and identified a lack of essential information 

as a basis for the G4 classification. Leopard dace were included 

as a SGCN because changes in taxonomy resulted in a lack of 

essential information pertaining to the status of the species

(IDFG, 2005). The lack of essential information included 

abundance and population trend (IDFG, 2005). 

Fish The over-arching goal for fisheries is nearly identical in all 

alternatives. Reference is made to the thick "Aquatic and 

Riparian Management Strategy" document in Appendix D. This 

appendix fails to provide essential information on the causes of 

loss of flows, fish, or habitat components, and specified actions 

taken to recover flows, fish, water quality, etc. It does not 

provide required actions to make positive change happen.

The Final EIS revised the Chapter 2 Fish sections to clarify that 

the goals, objectives, and management actions for fish apply to 

native non-game fish (sculpin, minnows, dace, and shiners). This 

management direction focused on the 72 miles of stream where 

these fish do not coexist with special status fish such as redband 

trout and bull trout. The goals, objectives and management 

actions for special status fish were included in the Final EIS, 

Chapter 2 Special Status Species section, under Management 

for Special Status Species in Riparian Areas, Wetland, and 

Streams. The Aquatic and Riparian Management Strategy 

summarized the most current information available for riparian 

and instream condition for the planning area. A project level 

analysis would consider the cause(s) for impaired conditions or 

specific actions needed to improve riparian, in-stream and/or

water quality condition. 

Fish Riparian Conservation Areas have four categories with bias 

towards less protection if the waters currently do not have fish. 

Thus, having no fish at present places the stream in a lower 

category.

The Riparian Conservation Area (RCA) widths in the Aquatic and 

Riparian Management Strategy (Appendix D) are based on the 

widths identified in the Inland Native Fish Strategy (INFISH) 

which were adopted by the BLM in 1995 (Instructional 

Memorandum Number ID-96-010). The RCA categories in 

INFISH have greater widths for fish-bearing (Category 1) and 

non fish-bearing (Category 2) streams than for ponds, lakes, 

reservoirs and wetlands greater than one acre (Category 3) or 

seasonally flowing or intermittent streams, wetlands less than 1 

acre, or landslide-prone areas (Category 4). 
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Category Comment Response

Fish Management for Riparian Conservation Areas (RCAs) in the 

Draft RMP/EIS in Appendix D (Table D-7, pp. A-64 to A-70) is 

supposed to show what actions will occur. This contains many 

statements, but no measurable standards for livestock use. We 

note that much of the RCA and riparian system way of viewing 

streams comes from the Inland Native Fish Strategy, and the 

Interior Columbia Basin Ecosystem Management Plan and 

much of the background science was conducted on much 

larger more interconnected waters than the desert systems of 

the planning area. Logging and logging roads were often 

primary threats in those systems and studies and not grazing 

as in the planning area. The BLM must provide more specific 

guidance to limit chronic and cumulative grazing degradation.

The guidance in Appendix D: Aquatic and Riparian Management 

Strategy (Table D-8) comes from the Inland Native Fish Strategy 

(USDA, 1995) and applies to actions that have the potential to 

affect the condition of Riparian Conservation Areas (RCAs). 

Alternative VI (Proposed RMP) provided management for 

livestock grazing in Chapter 2 under the Livestock Grazing, 

Water Resources, Riparian Areas and Wetlands, Fish, Special 

Status Species sections. Site-specific analysis would develop 

measurable standards for actions that may affect RCAs.

Fish The inadequate Fisheries Objectives of the RMP under all 

alternatives rely on proper functioning condition (PFC) ratings. 

Yet the Riparian Conservation Area (RCA) Table states in 

regards to PFC (Appendix D, Table D-7, p. A-65 "Fish and 

Wildlife Restoration") under FW-l that "Management activities 

and land uses in RCAs shall be implemented to attain proper 

functioning condition as an initial step to move habitat 

conditions of streams, riparian areas and wetlands toward 

achieving aquatic and riparian management objectives". The 

BLM proposes 20 years for its initial step.

The Final EIS revised the Chapter 2 Fish sections to clarify that 

the goals, objectives, and management actions for fish apply to 

native non-game fish (sculpin, minnows, dace, and shiners). 

Based on public comments, the objectives for streams 

containing native non-game fish were made consistent with the 

objectives for improving riparian condition (FI-VI-O-1). 

In the Final EIS, RI-CA-MA-8 (Chapter 2, Riparian Areas and 

Wetlands section), stated “Modify existing management activities 

and authorized uses in Riparian Conservation Areas to attain 

proper functioning condition and ensure that habitat conditions of 

streams, riparian areas, and wetlands are moving toward 

achieving the goals and objectives for riparian areas and 

wetlands” but it did not state BLM proposes 20 years to achieve 

this initial step. The Final EIS acknowledged stream condition 

needs to improve beyond a rating of proper functioning condition

to improve water quality to levels which meet State water quality 

standards and designated beneficial uses. This is stated in the 

Final EIS, Chapter 4, Methods and Assumptions in the Riparian 

Areas and Wetlands section; Chapter 4, Indicators in the Water 

Resources section. It is also displayed the Final EIS in Appendix 

D: Aquatic and Riparian Management Strategy (Figure D-1) and 

described in the text below the figure. 

Fish The fish objectives in Alternative IV are to maintain or improve 

streams referring to "70% of the miles of fish-bearing streams 

and their perennial tributaries are properly functioning" (Draft 

The Final EIS revised the Chapter 2 Fish sections to clarify that 

the goals, objectives, and management actions for fish apply to 

native non-game fish (sculpin, minnows, dace, and shiners). This 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

RMP/EIS, p. 2-62). Clarify if this means that some stream

conditions could actually decline. 

management direction focused on the 72 miles of stream where 

these fish do not coexist with special status fish such as redband 

trout and bull trout. The goals, objectives and management 

actions for special status fish were included in the Final EIS, 

Chapter 2 Special Status Species section, under Management 

for Special Status Species in Riparian Areas, Wetland, and 

Streams. These objectives in Alternative IV would result in 

maintaining fish-bearing streams at proper functioning condition 

(PFC), improving to achieve a rating of PFC, or improving to 

move towards PFC. 

Based on public comments, the Alternative VI (Proposed RMP) 

objectives in streams containing native non-game fish were 

made consistent with the objectives for improving riparian 

condition in the Final EIS. 

Fish In the planning area, analyze water diversions and impacts of 

private land practices and degradation. Examine the degree 

and severity of threats to water flows, water quality, aquatic 

biota, impairment of recreational uses, and other information. 

In the Final EIS, the Chapter 4 analysis in the Water Resources, 

Riparian Areas and Wetlands, and Special Status Fish and 

Aquatic Invertebrates sections all identify cumulative impacts to 

the BLM-managed riparian areas from water diversions and 

other private land practices. The comment did not provide the 

BLM with enough information to address the portion of the 

comment related to degradation and other information.

Fish Objective FI-IV-O-1 (Chapter 2, Fish (Section 2.3.6.1)) actually 

allows many watershed conditions to worsen - especially the 

tributaries - many of which become intermittent in summer. The 

Draft RMP/EIS used this same kind of uncertain and unclear 

wording repeatedly in relation to the other public lands values. 

The Final EIS revised the Chapter 2 Fish sections to clarify that 

the goals, objectives, and management actions for fish apply to 

native non-game fish (sculpin, minnows, dace, and shiners). This 

management direction focused on the 72 miles of stream where 

these fish do not coexist with special status fish such as redband 

trout and bull trout. The goals, objectives and management 

actions for special status fish were included in the Final EIS, 

Chapter 2 Special Status Species section, under Management 

for Special Status Species in Riparian Areas, Wetland, and 

Streams. These objectives in Alternative IV would result in 

maintaining fish-bearing streams at proper functioning condition 

(PFC), improving to achieve a rating of PFC, or improving to 

move towards PFC. 

Except in areas with groundwater influence, most of the streams 

in the planning area experience reduced stream flows during the 

summer months, including those which are not accessible to 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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livestock grazing. The Final EIS clarified the Chapter 3 Riparian 

Areas and Wetlands section and the Glossary to include 

definitions for perennial, intermittent and ephemeral streams to 

characterize these riparian systems.

Fish Various parts of the RMP, even covering the same topics, 

appear to be inconsistent and conflicting. In Appendix D, Table 

D-1 provides bull trout habitat indicators. Table D-3 provides 

"Indicators in a degraded condition". This table shows little 

degradation. 

Yet other tables, using minimal proper functioning condition as 

a goal, show problems. For example: Appendix D, (Table D-5, 

p. A-58), identifies the East Fork Jarbidge River segment a 

high priority for improvement. Yet Table D-3 shows fewer 

problems. It is impossible to understand what the situation is, 

and how positive change will occur. 

The Final EIS, Appendix D: Aquatic and Riparian Management 

Strategy, Table D-1 used “A Framework to Assist in Making 

Endangered Species Act Determinations of Effect for Individual 

or Grouped Actions at the Bull Trout Subpopulation Watershed 

Scale (FWS, 1998). The table identified population and habitat 

characteristics (i.e. Indicators) that support the biological 

requirements of bull trout and compared those indicators to 

thresholds that characterize the habitat as functioning properly, 

at risk, or at an unacceptable risk. 

Appendix D, Table D-3 identified the BLM-managed streams that 

have an indicator in a degraded condition and what the 

degraded indicator is (e g., spawning substrate, water 

temperature). The table identified 10 restoration reaches for 

streams containing bull trout, critical habitat for bull trout, and 

redband trout which had at least one degraded indicator. The 

table also identified 54 restoration reaches for redband trout 

streams which had at least one degraded indicator. 

In the Final EIS, Appendix D, Table D-5 displayed the Riparian 

Proper Functioning Condition data and Restoration Priorities. 

The identification of Restoration reaches varied by the location of 

the reach within the watershed. For example: East Fork Jarbidge 

River Reaches 3 and 4 near the confluence of Dave Creek are 

protected by steep canyon walls and in a higher functional 

condition than the East Fork Jarbidge River Reaches 1 and 2 

which are near or below the town of Murphy Hot Springs. These 

reaches are influenced by private land activities and the road 

adjacent to the East Fork Jarbidge River and have a reduced 

functional condition. Therefore, different reaches of the same 

river or stream can have different functional condition ratings or 

priorities for restoration.

The Final EIS included maps with the reach breaks for the 

habitat condition rated streams in Appendix D, Maps D-1 through 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Map D-9. The proper functioning condition rated streams are 

displayed on Map 16 “Proper Functioning Condition Ratings”.

Fish Since the BLM proposes significant use of grazing disturbance 

and herbicide "tools", there must be a detailed analysis of 

potential effects to aquatic species, and non-target upland 

species as well. This includes cumulative effects.

The Final EIS included an analysis of direct, indirect and 

cumulative impacts at the land use planning level for livestock 

grazing and the use of herbicides. The Chapter 4 sections for 

Water Resources, Riparian Areas and Wetland, and Special 

Status Fish and Aquatic Invertebrates included this information 

under the subheadings for Impacts from Noxious Weeds and 

Invasive Plants Actions and Impacts from Livestock Grazing 

Actions. The impacts from noxious weeds and invasive plant 

treatments and livestock grazing are included in the Chapter 4 

section for Special Status Fish and Aquatic Invertebrates. A sitespecific analysis of direct, indirect and cumulative impacts would 

also occur at the project level. 

Fish Where and when has the Animal Plant Health Inspection 

Service sprayed grasshoppers and Mormon crickets? Which 

watersheds? How has this increased? How do current 

degraded land conditions in the planning area contribute to 

expanded rancher claims of native insect "problems"? What 

chemicals are used and what are the effects - not only to 

aquatic biota including through drift, but also to the critical 

insect supply for sage-grouse and Columbia sharp-tailed 

grouse?

The actions implemented by Animal and Plant Health Inspection 

Service are outside the scope of the Final EIS. 

Fish The Humboldt-Toiyabe National Forest has pursued piecemeal 

livestock facilities, with further industrialization of sagebrush 

habitats, and shifting of impacts onto already degraded 

intermittent stream areas and critical sage-grouse habitats. 

Water developments have occurred in bull trout and redband 

trout watersheds under Decisions of NEPA Adequacy and 

Categorical Exclusions. Eight miles of new fence pass through 

sagebrush habitats despite the already high density of fencing 

as on the BLM-managed land. A large-scale fire occurred in 

the Humboldt-Toiyabe National Forest in 2008, Slide Rock, 

altered the baseline for bull trout population in the Jarbidge 

Wilderness. The baseline has changed, including the baseline 

in upstream watersheds of the planning area. 

The authorized actions on the US Forest Service managed lands 

are not under the discretion of the BLM. The effects of Forest 

Service actions in the upper portions of the watersheds 

managed by the BLM are considered in the Cumulative Impacts 

assessments in the Final EIS, Chapter 4 in the Water 

Resources, Riparian Areas and Wetland, and Special Status 

Fish and Aquatic Invertebrates sections.

Fish The Draft RMP/EIS, Volume 2, Chapter 4, p. 4-95 shows that 

there is no real difference in impacts on aquatic species 

between Alternatives I, IV and V without any scientific analysis 

The process used in the development of the alternatives is 

described in the Final EIS Chapter 2 Introduction. 
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and basis for understanding why these alternatives were 

structured in this manner. The BLM claims, "the increased 

emphasis on passive restoration could result in fewer shortterm impacts to water quality and slower rates of recovery for 

water quality impaired streams of the other alternatives". It 

uses its own construction of Alternative V that omits any active 

restoration so that the claim can be made that Alternative V 

would be worse than Alternative IV.

The comment refers to the impacts to water quality from actions 

implemented for special status fish and aquatic invertebrates 

under Alternative V, which emphasized passive restoration 

techniques to improve resource condition. The analysis for 

Alternative V assumed the techniques used for improving special 

status fish and aquatic invertebrate habitats would result in fewer 

short-term impacts to water quality due to the use of passive 

restoration actions. The analysis also assumed passive 

restoration would result in a longer time period for the recovery 

of water quality. In comparison, Alternative IV predicted more 

initial impacts to water quality due to implementation of active 

restoration actions but faster rates of recovery for water quality. 

The assumptions made for passive and active restoration in the 

water resources analysis were identified in the Final EIS, 

Chapter 4 Water Resources section under Methods and 

Assumptions. 

Fish Appendix D describes pool frequency, width, depth, 

temperatures, and conditions for functioning properly. Yet there 

is no path to attain or make real progress on these desired 

conditions.

Incorporating the guidance in the Aquatic and Riparian 

Management Strategy (Appendix D) into ongoing and new 

actions within Riparian Conservation Areas would help achieve 

the desired resource conditions for riparian areas and wetlands, 

fish, special status fish, and water quality. Site and projectspecific analysis would also support the attainment of the 

objectives for these resources. 

Fish In the Draft RMP/EIS in Chapter 2 Water Resources section 

2.3.4, WR-CA-MA-6 states that it would "Consider new water 

developments and water development projects" where impacts 

could be mitigated. Where does data ever show impacts of 

water developments, such as reduced natural spring flows or 

compaction and plant community degradation can be 

mitigated? 

The Final EIS Chapter 2 Water Resources sections, 

management action WR-CA-MA-5 would consider new water 

developments and improvements to existing water development 

projects if impacts to water and riparian resources can be 

mitigated. Alternative VI (Proposed RMP) included management 

direction for water development in Livestock Grazing (LG-CAMA-11, LG-CA-MA-14, LG-CA-MA-15, and LG-VI-MA-10) and in 

Wildland Fire Ecology and Management (WFM-VI-MA-5). 

Alternative VI (Proposed RMP) included management actions for 

new and existing livestock infrastructure to be modified, 

discontinued, or relocated if they are not maintaining aquatic and 

riparian conditions (LG-CA-MA-11, LG-CA-MA-14). Alternative 

VI (Proposed RMP) also included WFM-VI-MA-5 (Wildland Fire 

Ecology and Management) to design water developments for fire 

suppression to mitigate impacts to water resources. This 

management, combined with project level analysis, would serve 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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to mitigate resource impacts from water developments. 

Fish In Volume 3, Map 6 on p. M-7 in the Draft RMP/EIS, as with all 

maps and analysis, an understanding of baseline conditions, 

ecological degradation and management shortcomings in 

adjacent headwater areas in the Humboldt-Toiyabe National 

Forest must be provided to understand what the total sediment 

load may be and all direct, indirect and cumulative effects. This 

is also necessary because it is the same very small number of 

permittees whose cattle and sheep herds impact the 

headwater areas too. Examine the full 

watershed/ecosystem/wildlife disturbance footprint of these 

operations.

The BLM assumed the comment referred to Map 6 “Water 

Erosion Potential” in the Draft RMP/EIS. The map, which 

focused on lands within the planning area, was also included in 

the Final EIS (Map 5). The influence of US Forest Service 

management on BLM-managed streams is incorporated in the 

baseline condition data summarized in the Final EIS, Appendix 

D: Aquatic and Riparian Management Strategy, in Tables D-3 

and D-5. The Final EIS included the potential impacts from 

Forest Service managed lands in the Chapter 4, cumulative 

impacts analysis in the Water Resources, Riparian Areas and 

Wetlands, and Special Status Fish and Aquatic Invertebrates

sections. 

Fish Politicians have also discussed returning salmon to Nevada 

headwaters. If that were indeed undertaken in the next 20 

years, how would that be accomplished?

Actions to restore salmon to headwater streams within the 

planning area would be accomplished under a multiagency effort 

and accompanying site-specific NEPA analysis. The Final EIS 

identified this in Chapter 2, Special Status Species, Alternative 

VI (Proposed RMP), in management action SS-VI-MA-4. None of 

the goals, objectives or management actions in the Final EIS 

would preclude BLM working with other State or Federal 

agencies on returning salmon to Nevada.

Fish Proper functioning condition (PFC) is subjective, and a minimal 

habitat descriptor. Waters at PFC are not assured of meeting 

the actual habitat requirements for aquatic biota. The BLM 

must fully examine aquatic habitat quality and quantity. This 

includes sediment, temperature, cobble embeddedness, 

aquatic biota, bacterial pollution, turbidity, algae, dissolved 

oxygen and many other attributes.

The Final EIS contained a summary of the available proper 

functioning condition (PFC) ratings in the Chapter 3 Riparian 

Areas and Wetlands section. In Appendix D: Aquatic and 

Riparian Management Strategy, Figure D-1 and the paragraph 

below it acknowledged that PFC is a starting point for achieving 

aquatic resource objectives. The Final EIS summarized the PFC 

and habitat condition data used in the assessment of aquatic 

resources in the Chapter 3 Water Resources, Riparian Areas 

and Wetlands, Fish, and Special Status Fish and Aquatic 

Invertebrates sections. The indicators considered in the 

identification of Conservation or Restoration reaches are 

displayed in Appendix D, Tables D-1 and D-2 and included 

sediment, temperature, substrate embeddedness, chemical 

contamination and nutrients, and numerous other aquatic 

indicators. 

Fish Where is a map and analysis that overlay the proper 

functioning condition ratings with the Riparian Conservation 

Areas? How are these areas classified in the upstream Forest 

The Final EIS displayed proper functioning condition ratings on 

Map 16 “Proper Functioning Condition Ratings” and Riparian 

Conservation Areas (RCAs) on Map 22 “Riparian Conservation 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Service managed lands? How does private lands in all 

watersheds (such as in the China Mountain area, Jarbidge 

Foothills, Three Creek, Murphy, Diamond A) impair habitats? 

Areas”. RCA classifications on US Forest Service lands are 

beyond the scope of the Final EIS. The Final EIS analyzed 

impacts to aquatic resources from private lands in the cumulative 

impacts analyses in Chapter 4 for Water Resources, Riparian 

and Wetlands, and Special Status Fish and Aquatic 

Invertebrates sections. 

Fish Designation of critical bull trout habitat occurred on September 

30, 2010, and included areas within the planning area. We 

recommend that the BLM also address designated critical 

habitat in the Final EIS. We anticipate that specific 

conservation measures for primary constituent elements of 

designated bull trout critical habitat for each land use plan 

program would be similar to the existing bull trout conservation 

measures described within the Aquatic and Riparian 

Management Strategy. 

The Final EIS included designated critical habit for bull trout in 

Chapter 3, Special Status Fish and Aquatic Invertebrates

section, under the subheading for Jarbidge River Basin Bull 

Trout. The Conservation Measures for Primary Constituent 

Elements of designated critical habitat for bull trout for each land 

use plan program are included in the Final EIS, Appendix E: 

Conservation Measures and in the Jarbidge RMP Biological 

Assessment. 

Geothermal New power lines, night-lights, heavy-duty roads, constant 

human disturbance, noise, and severe visual intrusions 

accompany modern geothermal development.

This comment references geothermal leases on Nevada BLM 

lands and assumes a plant facility would be built within the 

planning area that would leave an adverse footprint on the 

environment. The Draft RMP/EIS and Final EIS provided for 

geothermal development in LE-C-MA-1 by incorporating the

Record of Decision and Resource Management Plan 

Amendments for Geothermal Leasing in the Western United 

States (December 2008). A site-specific environmental analysis 

and decision process in accordance with the NEPA process 

would identify specific mitigation measures for any proposed 

geothermal projects.

Geothermal The Draft RMP/EIS is lacking in essential ground water and 

aquifer analysis needed to understand the baseline, and 

potential impacts. Geothermal is exploding across the 

landscape.

The BLM does not have the jurisdiction to manage ground water 

and aquifers and therefore does not collect groundwater data. 

Appendix L: Reasonably Foreseeable Development Scenario for 

Geothermal Development provided information on the potential 

geothermal development in the planning area. The potential for 

cumulative impacts from geothermal development are included 

in the Water Resources, Riparian Areas and Wetlands, and 

Special Status Fish and Aquatic Invertebrates sections of the 

Final EIS.

Geothermal Close the Herd Management Area (HMA) to geothermal/fluid 

mineral leasing. Close the HMA to mineral allocations and 

locatable mineral development, as well as rights-of-ways. 

Specific project planning would consider the health and welfare 

of wild horses. A site-specific environmental analysis and 

decision process in accordance with the NEPA process would 

identify specific mitigation measures for any proposed projects 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

within the Herd Management Area. Mitigation measures would 

be implemented through applicable permits (BLM Wild Horses 

and Burros Management Handbook, H-4700-1).

Glossary Define the term “resiliency of ecosystem structure and function” 

in the Upland Vegetation goals in Chapter 2.

The term “resiliency of ecosystem structure and function” used in

Alternatives III and IV means the ability of the ecosystem to 

recover following a disturbance. This wording replaced the term 

“resiliency of ecosystem structure and function” in Alternative VI 

(Proposed RMP) in the Final EIS, where the goal in the Upland 

Vegetation section stated “Manage vegetation to restore the 

ability of the ecosystem to recover following a disturbance and 

reduce fragmentation of habitat for sage-grouse and other native 

species”.

Goals The general multiple use and resource management goals of 

the Final RMP should be: To ensure long-term, sustainable 

multiple-use of the resource. This includes the sustainable 

management of all of the resources listed in the RMP (air and 

atmospheric values, geologic features, soil resources, water 

resources, vegetation communities, fish and wildlife, special 

status species, noxious weeds and invasive species, wildland 

fire, wild horses, paleontological resources, cultural resources, 

and visual resources). We suggest that this resource 

management plan be set up in such a way that meeting this 

goal will enhance the resource uses (livestock grazing, 

recreation, transportation, energy development, and travel).

Managing public lands to ensure the principles of multiple use 

and sustained yield is one of the overall purposes of the Final 

EIS (see Purpose and Need in Chapter 1). BLM designed the 

goals and objectives to accomplish this purpose.

Interpretation, 

Outreach and 

Environmental 

Education

In the Chapter 2 alternatives, the Interpretation, Outreach, and 

Environmental Education section goal should explicitly include 

renewable energy in interpretation, outreach and 

environmental education. The BLM should add a management 

action emphasizing education on renewable energy resource 

utilization benefits, and the environmental research and 

mitigation that can be funded through renewable energy 

operating programs.

The goal, objective, and management actions in the 

Interpretation, Outreach, and Environmental Education section 

are broad. They cover every resource and resource use in the 

planning area. Renewable energy is intrinsically included as a 

resource use. 

Land Tenure On p. 2-179, the suitability classifications need to be classified. 

Soil classifications with 40% Soil Conservation Service Class N 

or poorer soils should not include "draws" or "drainages" that 

can be leveled to eliminate the Class N soil. If by leveling, the 

draw or drainage area eliminates the Class N slope, and then 

the 40-acre parcel should be allowed. This also applies to 

cropland in Capability Classes II through V (particularly 

The Natural Resource Conservation Service determined soil 

classifications and those classifications were included in the 

process for determining the suitability of a Desert Land Entry Act

of 1877 (DLE). See 43 CFR 2520 for more information. Also, see 

LT-CA-MA-8, no new DLE and Carey Act of 1894 applications 

would be accepted for lands within the planning area.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

subclass "e") as well.

Land Tenure For Map 86, Land Tenure Zones in Alternative II, Zone 3 

should go all the way north to the Snake River since the area 

covered under Zone 2 incorporates over 3,000 acres of our 

private land. We have had an application on file for a land 

sale/trade for over 10 years with the BLM.

Under Alternative IV, our private land holdings should at least 

be in Zone 2 for a possible exchange. Please reconsider your 

alternatives and the rezone of your maps.

The Final EIS revised the Land Tenure Zone maps (Maps 106 

through 113) to exclude private land and other lands not 

managed by the BLM. Appendix I: Lands Available for Disposal

lists legal descriptions of public lands that may be considered for 

disposal via exchange or sale by alternative. 

Land Tenure Where irrigation pivots or ditches cross public land, why not 

just simply sell these small land sections to the private 

landowner and omit the time and effort it takes to monitor and 

continually reissue rights-of-way? The total acreage we are 

talking about here has to be very limited and would eliminate a 

lot of red tape. Why are you not trying to work with the private 

landowner in these situations rather than continually being an 

adversary? 

The Final EIS presented a range of alternatives for Land Tenure. 

Land Tenure Zone 3 in Alternative VI (Proposed RMP) included 

many of those small isolated land parcels. Appendix I: Lands 

Available for Disposal listed legal descriptions of public lands 

that may be considered for disposal via exchange or sale by 

alternative. 

Land Tenure The Draft RMP/EIS did not mention that providing water to 

these small tracts where pivots or ditches cross public land 

benefits wildlife. Why have you not mentioned this in an effort 

to improve wildlife habitat?

The Final EIS revised the Wildlife Section in Chapter 2 with 

additional management actions for the wildlife tracts. The Final 

EIS added a brief discussion of wildlife tracts and water under 

Habitat Groups Considered But Not Analyzed in the Wildlife

Section in Chapter 3. The new Wildlife Tracts Plan would 

analyze placing guzzlers to water wildlife or other projects in 

more detail.

Land Tenure On p. 2-178, LT-NA-MA-11, you use the word "public interest" 

in general terms without defining it. It is a good sound bite, but 

without defining specifically what that means, it becomes a 

catchall phrase to prohibit any exchanges. The public interest 

should also include the private interest, as they are "public" as 

well. The "public" interest should also include the economic 

benefit to the public if the exchange was to occur.

The term “public interest” in management action LT-NA-MA-12 

from the 1987 RMP is derived from Section 206 (Land 

Exchanges) of the Federal Land Policy Management Act of 

1976. 

Land Tenure The Capability Classes that were in place when the original 

Desert Land Entry Act of 1877 (DLEs) were filed should be 

used. Please change them back to what they were at the time 

the DLEs were filed.

The processing requirements have not changed. See the 1987 

RMP for Desert Land Entry Act of 1877 processing details.

Land Tenure On p. 2-179, in relation to the four steps identified, an applicant 

who is already farming adjacent land should receive favorable 

consideration when proving that by developing the Desert Land 

The Desert Land Entry Act of 1877 and Carey Act of 1894 

applications submitted prior to 2009 (Case numbers IDD-7401, 

IDI-7402, IDI-27888, and IDI-27889) would be processed within 
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Entry Act of 1877 (DLE) is economically feasible. 

Consideration should also be given if the applicant has been 

farming for a long period of time and is financially stable. 

Please add these as steps in developing the DLE. 

10 years of the signing of the Record of Decision, and those 

lands meeting the criteria of the Acts would be disposed of (LTCA-MA-8).

Land Tenure Applications for agricultural development that would contribute 

to underground mining of groundwater would not be allowed. 

Eliminate this from the plan as it usurps the Idaho Department 

of Water Resources authority over water appropriations.

The management action LA-CA-MA-12 stated, “Authorizations 

involving water use on BLM land must comply with applicable 

State water law. Final authorization to proceed with water 

developments on BLM lands would be withheld until compliance 

from the appropriate authorizing agency (i.e., Idaho Department 

of Water Resources) is obtained. Any water right established on 

public land would be solely in the name of the United States.”

Land Tenure None of the alternatives addresses the processing of Desert 

Land Entry Act of 1877 (DLEs) noted in LT-CA-MA-13 other 

than Alternative II. However, even Alternative II does not say 

for disposal of DLE's. Why is that? In the Land Tenure Maps 

85, 86, 87, 88 and 89, you have eliminated the processing of 

any DLEs except maybe in Map 86 under Alternative II which is 

the only processing of DLEs allowable. We obviously support 

Alternative II here but all Alternatives need to add the Disposal 

of the existing DLEs. I am not sure why you have not listed 

these unless you are trying to slip them under the carpet. We 

ask that you process and approve DLEs 7401 and 7402.

The management action LT-CA-MA-13 was Common to all 

Action Alternatives (Alternative I, II, III, IV-a, IV-b, V, and VI), not 

just Alternative II. As stated in the management action, the 

Desert Land Entry Act of 1877 (DLE) and Carey Act of 1894 

(CA) applications submitted prior to 2009 (Case numbers IDD7401, IDI-7402, IDI-27888, and IDI-27889), would be processed 

within 10 years of the signing of the Record of Decision, and 

those lands meeting the criteria of the acts would be disposed. 

The BLM would not accept new DLE/CA applications for lands 

within the planning area (LT-CA-MA- 8). Per your request to 

process and approve the DLEs, they must meet the economic 

feasibility analysis per 43 CFR 2520 prior to approval.

Land Tenure A majority of the Resource Advisory Council (RAC) supports 

the land acquisition/trades in the following order:

Wilderness areas, 

Special Recreation Management Area’s and Areas of 

Critical Environmental Concern, 

Public access, and

Wildlife needs. 

A majority of the RAC supports land sales with at least one of 

the following conditions:

Parcel is isolated and public access limited, 

There is a public need, 

BLM management of the parcel is limited, and/or

Helps land acquisitions or trades as part of a package. 

The Final EIS revised the Land Tenure section per the criteria 

outlined in 43 CFR 2710 and the management action LT-CAMA-1. Other parcels which were isolated, a public need was 

identified, or BLM access was limited were included for disposal 

in Alternative VI (Proposed RMP). In addition, those parcels, 

which the Draft RMP/EIS identified for sale and/or exchange 

within sage-grouse management areas, were not included in the 

Final EIS.

The Final EIS did not analyze ownership consolidation with 

private landowners, as land exchanges may take approximately 

10 years to process. BLM may process land exchanges per 

management action LT-CA-MA-1 and according to 43 CFR 

2200. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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The BLM needs to block up acreage for better management, 

more cost effective management, and to preserve some 

landscapes. Private land acreages such the Charlie Brackett 

property, Cowan Reservoir, Antelope Pocket Reservoir, Buck 

Flat, Tank Spring, and numerous other State sections have the 

potential to dramatically reduce the desired management 

objectives of whatever Final EIS alternative is chosen. One of 

the primary focuses of the BLM over the course of the life of 

the Land Use Plan should be landownership consolidation. 

Once development starts the process is irreversible.

The alternatives developed for the Draft RMP/EIS all ignore the 

realities of dealing with private parties and the State of Idaho. 

The BLM needs to strive for the greatest degree of flexibility 

possible with this resource issue. Nearly all parties in the 

planning area would benefit from consolidation of real estate 

holdings. This issue before being settled in the Final EIS would 

benefit from extensive talks with the other landowners in the 

planning area to determine what the potential for land 

consolidation might be.

Land Tenure The BLM must have a goal of no net loss of BLM-managed 

land, and strive to increase the amount of public land across 

the planning area over the life of the plan. It must identify 

specific areas where the focus may be land acquisition.

Alternative V closely represented what this comment described 

and the Final EIS analyzed it as part of the range of alternatives. 

See Map 112 "Land Tenure Zones in Alternative V" in the Final 

EIS.

Land Tenure The BLM must not allow submitted Desert Land Entry Act of 

1877 applications to go forward, as it proposes under all 

alternatives. Where are these? How many? Who? See LT-CAMA-13 on p. 2-182 of the Draft RMP/EIS.

The management action in all action alternatives LT-CA-MA-8 

stated “No new Desert Land Entry Act or Carey Act applications 

would be accepted for lands. The Desert Land Act and Carey 

Act applications submitted prior to 2009 (Case numbers IDI -

7401, IDI-7402, IDI-27888, and IDI-27889) would be processed 

within 10 years of the signing of the Record of Decision.” 

Land Tenure We oppose disposal of lands as would be allowed under the 

part of LT-CA-MA-4 (2-181) that serves as a huge loophole for 

actually enabling the disposal of historical properties, 

threatened and endangered species habitat, wildlife tracts, 

cultural sites, etc. Take this provision, allowing a loophole for 

disposal, out of all alternatives.

The Final EIS presented management direction for the BLM’s 

retention and acquisition of lands (LT-CA-MA-3 and 4).

Land Tenure What exactly can the BLM consider under the Recreation and 

Public Purposes Act of 1954? 

The Recreation and Public Purposes Act of 1954 (R&PP) 

authorized the sale or lease of public lands for recreational or 

public purposes to State and local governments and to qualified 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

nonprofit organizations. The BLM would only consider the 

amount of land required for efficient operation of a project 

described in the applicant’s development plan. Examples of 

typical uses under the R&PP act are historic monument sites, 

campgrounds, schools, firehouses, law enforcement facilities, 

municipal facilities, landfills, hospitals, parks, and fairgrounds. 

For more information, see 43 CFR 2740.

Land Use 

Authorization

Vegetation is one of the least stable resources upon which to 

base resource decisions. Wildfire and invasive species are 

capable of transforming sites in a very short period of time. 

There is also considerable confusion as to how wind energy 

directly threatens native vegetation. 

The Final EIS analyzed a range of alternatives. Alternative VI 

(Proposed RMP) did not base wind energy development on 

vegetation data but rather upon avoiding sage-grouse habitat. 

Outside the sage-grouse management area, renewable energy 

site testing, monitoring, and development should avoid special 

status species habitat unless unavoidable adverse effects can 

be mitigated (LA-VI-MA-4). See also LA-VI-MA-2.

Land Use 

Authorizations

Anytime there is a land exchange between private and public 

entities, a public access easement or right-of-way should be 

required in order to offset the trend of less public access to 

public land over the past 35 ± years and the cumulative 

negative impact of that trend on multiple-use recreationists.

The Final EIS updated management action LT-CA-MA-6. 

Disposal of public lands would be subject to all valid existing 

rights, including existing rights-of-way. Existing public access to 

public lands through those lands may be retained if necessary 

for BLM management or for accommodating uses. See also 

management actions LA-CA-MA-10 and LA-CA-MA-11. 

Land Use 

Authorizations

The development of a Multiple Use Area (MUA) plan for MUA 

15 should include wind energy development because the 

China Mountain Wind Energy project has applied for a right-ofway grant with the BLM and should be included in discussion 

of the No Action Alternative.

The China Mountain Wind Energy project was deferred until the 

Idaho and Southwestern Montana Sub-Regional Sage-Grouse 

RMP Amendment/EIS and the Jarbidge RMP have been 

completed. The China Mountain Wind Energy EIS proposed 

changes to the 1987 RMP; However, no changes related to the 

China Mountain Wind Energy project were made. 

Land Use 

Authorizations

There are allocations for solar energy mentioned in the Draft 

RMP/EIS, but no mention of wind energy in this section. This 

section should include all renewable energy development.

The allocation in the Draft RMP/EIS that pertained specifically to 

solar energy developments was not included in the Final EIS. In 

Alternative VI (Proposed RMP) the objective, LA-VI-O-1, is to 

provide for the development of renewable energy resources, 

transportation routes, utility corridors, transmission lines, 

communication sites and other uses with consideration for 

resource objectives. In Alternative VI, the Allocation LA-VI-A-4 

was included, which stated “Commercial wind and solar energy 

developments would not be permitted inside the sage-grouse 

management area or within utility right-of-way corridors.” The 

Final EIS addressed wind energy throughout the document in 

the Land Use Authorization sections of each chapter. Alternative 

VI updated management actions to include more direction on 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

wind and renewable energy. See LA-C-MA-1, LA-VI-MA-4, and 

LA-VI-MA-5. 

Land Use 

Authorizations

Appendix N, p. A-141, states that the policies and best 

management practices (BMPs) can be found on pp. A-8 

through A-26 on Attachment A of the 2005 Wind Energy 

Development on BLM-Administered Lands in the Western 

United States Record of Decision. Our copy of the Record of 

Decision displays the policy and BMPs on pp. A-2 through A20. Please clarify the discrepancy.

The Final EIS revised Appendix B: Best Management Practices, 

Design Features, and Operating Procedures to contain the 

design features from the 2005 Wind Energy Development on 

BLM-Administered Lands in the Western United States Record 

of Decision.

Land Use 

Authorizations

Management actions common to all action alternatives states 

that new rights-of-way would meet Visual Resource 

Management (VRM) class objectives. Provide clarity and 

ensure that Instruction Memorandum 2009-043 and the 

existing best management practices for VRM apply.

The Final EIS analyzed a range of proposed Visual Resource 

Classes and Visual Resource Management classes that vary by 

alternative. The Final EIS incorporated best management 

practices as common to all alternatives (LA-C-MA- 1; Appendix 

B: Best Management Practices, Design Features, and Operating 

Procedures). 

Land Use 

Authorizations

The management action LA-II-MA-4 under Alternative II 

restricts wind turbines and met towers from occupied habitat 

for endangered, threatened, proposed, and candidate species 

where their direct adverse effects cannot be mitigated. The 

1987 Jarbidge RMP protected wildlife habitat through the 2005 

amendment (2005 Wind Energy Development on BLMAdministered Lands in the Western United States Record of 

Decision). Replace language in Alternatives II, IV, and with the 

2005 amendment language.

The Wind Energy Development on BLM-Administered Lands in 

the Western United States Record of Decision (BLM, 2005) 

amended the 1987 Jarbidge RMP. The only alternative that must 

have the language from the 2005 Record of Decision (ROD) was

the No Action Alternative as it continues to implement 

management direction contained in the 1987 Jarbidge RMP (and 

its amendments). The Action Alternatives (I-VI) incorporate 

policy established in the 2005 ROD and follow BLM policy that 

requires existing and potential development areas for renewable 

energy projects (including wind energy) be addressed in land 

use planning efforts. 

Land Use 

Authorizations

The BLM assumed that areas rated good or higher for wind 

generation using large turbines could also generate energy 

with the same turbines in fair wind resource areas. Clarify this 

in the Draft RMP/EIS to say that fair wind resource areas are 

feasible for Public Utility Regulatory Policies Act for wind 

energy projects, but cost-competitive commercial wind energy 

requires good or higher wind resource. Change the maps, text, 

and Table 4-313 to reflect this.

The Final EIS identified lands available for utility-scale wind 

development as those within 2 miles of areas rated fair or better 

for wind resources. For the analysis in Chapter 4, the BLM 

assumed that within the life of the plan, there would be more 

interest in developing wind energy on or within 2 miles of lands 

rated fair or better than on other lands in the planning area. 

However, Alternative VI (Proposed RMP) Allocation LA-VI-A-4 

was included, which stated “Commercial wind and solar energy 

developments would not be permitted inside the sage-grouse 

management area or within utility right-of-way corridors.” 

Land Use 

Authorizations

Under cumulative impacts from the land use authorization 

actions, the BLM assumed that the Department of Defense 

(DOD) land is incompatible with wind energy and utility 

The Final EIS only analyzed BLM-managed lands for expected 

wind energy development. For that analysis, the BLM assumed 

that exclusion and avoidance areas would not be available for 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

projects. In addition, the BLM assumed that management 

actions on the BLM-managed land might make wind energy 

projects unavailable to adjacent public and State lands. Do not 

make these assumptions, as each project is site-specific and 

negotiated with the DOD, private and State landowners, not 

the BLM. The Final EIS should assume that the DOD, private, 

and State land is available for wind energy projects.

wind energy development, as well as areas identified in 

allocations and management actions, such as LA-VI-A-4, which 

stated, “Commercial wind and solar energy developments would 

not be permitted inside the sage-grouse management area or 

within utility right-of-way corridors.”

Land Use 

Authorizations

Under cumulative impacts, it was assumed that Alternatives I, 

III, IV and V would not allow wind energy development within 

98% of the China Mountain Wind Energy project area. This is 

inaccurate. With best management practices (BMPs) and 

mitigation measures, all of the alternatives could permit a 

commercial-scale wind energy project in the southeast corner 

of the Planning Area. The size of the wind energy project in 

Alternatives I, III, IV and V may not be 400 megawatts, but 

certainly none of the alternatives excludes 98% of the project 

area. The BLM should revise the cumulative impacts for 

Alternatives I, III, IV and V to correct the aforementioned 

incorrect assumptions regarding compatibility with the 

Department of Defense land and private land for wind energy. 

The cumulative impacts assessment should also be revised to 

state the following: “Alternatives I, III, IV and V may restrict 

portions of the southeast corner of the planning area for wind 

energy development, but with BMPs and mitigation measures, 

construction of a commercial-scale wind energy project in the 

southeast corner of the planning area could be feasible.”

The Final EIS identified areas that were available or unavailable 

for wind energy development in the Chapter 2 Land Use 

Authorizations sections. Lands rated with fair or better wind 

resources, and lands within 2 miles of those areas were depicted 

on the expected wind development area maps (Map 99 to 105). 

Brown’s Bench, while rated as marginal for wind resources, was 

included within the expected wind development area in various 

alternatives because it was within 2 miles of lands rated fair to 

outstanding for wind resources. In Alternative VI (Proposed 

RMP), wind energy developments were not allowed in the 

Brown’s Bench area because this area is within the sage-grouse 

management area (LA-VI-A-4).

Land Use 

Authorizations

On p. E-13, Implications for the Action Alternatives, I am 

opposed to the "no development" stipulation extending that "no 

development" area from 3,500 feet to a one mile width for the 

four Section 368 energy corridors. I can understand the current 

3,500 feet designation but I do not understand why the onemile designation is necessary. It would eliminate a substantial 

amount of potential energy development such as geothermal 

and the extension is not necessary from any cultural, resource 

or visual standpoint.

There was not a “no development” stipulation. The 3,500 foot 

energy utility right-of-way corridor could be used for overhead 

utility, underground pipelines for oil, gas, and hydrogen, etc.

Land Use 

Authorizations

On p. ES-20, for any of the Alternatives, you are essentially 

closing almost one million acres for energy development. We 

are opposed to all of the Alternatives. We are also opposed to 

the No Action Alternative, as it does not specify which segment

The Final EIS described the Salmon Falls Creek Area of Critical 

Environmental Concern (ACEC) in Chapter 3 and it was depicted 

on Map 136 “ACECs in the No Action Alternative". 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

of the Salmon Falls Creek canyon you are talking about. We 

oppose any utility avoidance/restricted area below Balanced 

Rock.

Land Use 

Authorizations

On p. 2-167, we are opposed to utility avoidance restricted 

areas in the Salmon Falls Creek canyon below Balanced Rock. 

There already are such facilities in that stretch of the canyon 

and this would either eliminate them, or cause modifications, 

which would be detrimental to such existing facilities. This 

would also prevent upgrading or adding new systems as 

technology advanced and would eliminate using renewable 

resources as they become available.

On p. 2-168, we are opposed to LA-NA-MA-9, in giving 

trespass citations for runoff from private lands onto public 

lands. If you allow this, then private lands owners should also 

be allowed to issue trespass citations to BLM for excessive 

water runoff from public lands caused by BLM not rehabilitating 

lands that were burned and cleared of sagebrush, or from 

excessive mustard weed and tumbleweeds which causes the 

plugging of canals and ditches on private land. This is caused 

by the BLM not re-planting on a timely basis, sagebrush that 

acts as a protective screen for mustard weeds and 

tumbleweeds from blowing into the canals.

The 1987 Jarbidge RMP established the referenced 

management actions and the Final EIS presented them as part 

of the range of alternatives. Alternative VI (Proposed RMP) did

not include those management actions.

Land Use 

Authorizations

On pp. 2-172 to 2-176, BLM should designate existing rightsof-way (ROWs) for upgrades and additional facilities and allow 

access to those facilities. With adopting the restrictions for 

ROWs you are eliminating from development anywhere from 

878,000 acres to 1,229,000 acres, depending on the 

Alternative you have written. We are opposed to that.

A right-of-way (ROW) avoidance area is an area where a ROW 

would be strongly discouraged. Authorizations made in 

avoidance areas would have to be compatible with the purpose 

for which the area was designated and not be otherwise feasible 

on lands outside the avoidance area. Pre-existing ROWs within 

an avoidance area would still be valid and subject to the terms 

and conditions of the ROW grant.

Land Use 

Authorizations

On p. 2-178, LT-NA-MA-5, add the word ‘public’ where it states 

"In agricultural... Maintain control of all ‘public’ lands...” You 

would not have any right to control private lands, especially 

where erosion control is already practiced.

This management action is from the No Action Alternative. The 

Final EIS did not change this management because the 

language is directly from p. II-77 of the 1987 RMP. The 

commenter correctly identified that the BLM does not “control” 

private lands.

Land Use 

Authorizations

On page 4-9, second paragraph under Land Use 

Authorizations. We disagree that past utility authorizations 

have affected soil quality. They may have disturbed the soil 

temporarily, but certainly not on a long-term basis. This 

The Final EIS did not remove this language. The Final EIS 

stated, “Past utility-related authorizations, particularly 

transmission lines, have affected soil resources in the northern 

portion of the analysis area.” This statement only meant that 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-461

Category Comment Response

statement is misleading. utility-related authorizations have had an impact to soil 

resources, but did not say what those impacts were or their 

duration.

Land Use 

Authorizations

Avoidance stipulations (e.g., LA-IV-A-1, p. 2-174) ultimately 

define how specific land and resource uses will be 

implemented within avoidance areas. However, the Draft 

RMP/EIS does not provide resource-specific stipulations. 

Therefore, Idaho Department of Fish and Game recommends 

that resource specific stipulations be provided in the document 

for priority resources in each avoidance area to ensure that the 

Land Use Authorization goal (LA-CA-G-1, p.2-168) can be met 

within the purpose of an avoidance area.

The Final EIS included a wide variety of resource-specific 

avoidance stipulations. Resource-specific stipulations pertinent 

to the alternative ultimately selected in the Record of Decision

will be implemented as appropriate. For example, Alternative VI 

(Proposed RMP) in the Land Use Authorizations section lists 

specific avoidance stipulations for sage-grouse (LA-VI-A-2). 

Project level documents will also provide resource-specific 

stipulations.

Land Use 

Authorizations

Idaho Department of Fish and Game recommends reviewing 

Alternative IV right-of-way (ROW) exclusion areas for 

consistency and accuracy between Map 76 and LA-IV-A-2. If 

the current version of Map 76 is correct, than LA-IV-A-2 should 

clearly provide purposes and boundary definitions of these two 

ROW exclusion areas. In particular, we suggest clarifying if the 

ROW exclusion area that includes China Mountain is proposed 

specifically to protect sage-grouse habitat and how the 

boundaries were identified.

The Final EIS revised the “ROW Exclusion Areas in Alternative 

IV” map (Map 95) by removing the Areas of Critical 

Environmental Concern that were not included in Alternative IV. 

Lands with Wilderness Characteristics near the proposed China 

Mountain Wind Energy project were identified as exclusion 

areas.

Land Use 

Authorizations

The Department requests clarification about why Map 82 

proposes the Browns Bench area as a "Potential Wind 

Development Area" despite containing marginal wind 

resources (based on the BLM map) and very important sagegrouse habitat. From the Department’s perspective, the 

significance of the sage-grouse habitat and sage-grouse 

population supports consideration of the Browns Bench area 

as a right-of-way (ROW) exclusion area consistent with criteria 

used to designate other ROW exclusion areas in the RMP. We 

recommend the BLM evaluate this designation for Browns 

Bench.

The Brown’s Bench area was included in the expected wind 

development area because it is within 2 miles of lands rated fair 

or better for wind resources. The BLM assumed any wind energy 

development would occur within 2 miles of where fair (or better) 

wind resources existed. 

In Alternative VI (Proposed RMP), commercial wind and solar 

energy developments would not be permitted inside the sagegrouse management area or within utility right-of-way corridors

(LA-VI-A-4). The Browns Bench area is within the sage-grouse 

management area.

Land Use 

Authorizations

Rather than the term "active," which refers to the annual status 

of a lek, LA-IV-MA-2 should use management status of sagegrouse leks provided in the Idaho Department of Fish and 

Game lek database. Consequently, LA-IV-MA-2 would state 

that transmission lines, phone lines, communication towers, 

meteorological towers, and wind turbines will be located more 

than 5 miles from sage-grouse leks with an occupied or 

The Final EIS revised the term “active” leks to “occupied and 

unknown status” sage-grouse leks in Alternative VI (Proposed 

RMP; LA-VI-MA- 2). 
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Category Comment Response

undetermined status.

Land Use 

Authorizations

Idaho Department of Fish and Game recommends that LA-IVMA-2 include a generalized statement to encompass other 

similar elevated infrastructure features that might be proposed 

in the future in sage-grouse habitat.

Alternative VI (Proposed RMP) incorporated this 

recommendation. See the management action LA-VI-MA-2 

which stated “Outside the sage-grouse management area, locate 

new tall structures (e.g. overhead power and phone lines, 

communications towers, meteorological towers, and wind 

turbines) more than 4 miles from occupied and unknown-status 

sage-grouse leks.” 

Land Use 

Authorizations

The Draft RMP/EIS states adequate access will be provided for 

private in-holdings; however, adequate access will largely be 

defined by the special management area designations for the

BLM-managed lands and therefore may not meet the needs for 

management or development by the in-holding owner. Clarify 

what adequate access is and how it would be achieved.

The travel management plan (TR-CA-MA-8) will address access 

to private in-holdings. Also, see management action LA-VI-MA-6 

in Alternative VI (Proposed RMP) which stated, “New road 

rights-of-way across public land for private purposes would be 

considered only after all other access possibilities have been 

exhausted.” 

Land Use 

Authorizations

Discuss renewable energy generation in a single section of the 

Final EIS so the public better understands the BLM’s support 

for renewable energy.

The Final EIS addressed renewable energy developments in 

Chapters 2 and 4 in the Land Use Authorizations sections. 

Land Use 

Authorizations

Renewable energy should receive consideration at least equal 

to the three key resources that the BLM appeared to prioritize 

in the Draft RMP/EIS (vegetation, grazing, and Areas of Critical 

Environmental Concern).

The Final EIS did not consider renewable energy as a "key 

resource", but included it in each alternative as an allowable use. 

The Final EIS structured alternatives according to the BLM Land 

Use Planning Handbook where resources included, soil and 

water, vegetation, fish and wildlife, wild horses and burros, 

cultural resources, etc.; and resource uses included livestock 

grazing, recreation, lands and realty, etc. Existing and potential 

development areas for renewable energy projects fell under the 

category of the Lands and Realty section of Resource Uses in 

the BLM Land Use Planning Handbook, therefore, renewable 

energy was addressed under the section Land Use 

Authorizations. 

Land Use 

Authorizations

To appropriately value renewable energy, the BLM should 

supplement its analysis. First, the BLM is required to do more 

than briefly note the environmental benefits of renewable 

energy. It should analyze the potential for reduced greenhouse 

gas emissions from developing renewable energy projects, and 

the climate change consequences to other environmental 

values of failing to achieve our renewable energy potential (as 

required by Order Number 3289).

A project level analysis would determine the potential for 

reduced greenhouse gas emissions for any proposed renewable 

energy development projects.
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A-463

Category Comment Response

Land Use 

Authorizations

Where renewable energy may have an impact on other 

important environmental values, each alternative in the Final 

EIS should provide for avoidance, minimization, and mitigation 

of those impacts.

The BLM designed the alternatives and management actions to 

help avoid, minimize, and mitigate impacts of renewable energy 

development (see management actions in Chapter 2 Land Use 

Authorizations). In addition, the best management practices, 

design features, and operating procedures were placed in 

Appendix B; resource-specific stipulations would be included at 

the project level.

Land Use 

Authorizations

The Resource Advisory Council unanimously supports that the 

BLM review the Draft RMP/EIS to ensure that there will be 

sufficient flexibility to address highway district rights-of-way

(ROWs) and material sites. The primary source of conflict 

seems to be restrictions on actions within or along the highway 

ROWs. It would seem appropriate if the Final EIS could provide 

both BLM and the highway districts the opportunity to resolve 

this conflict. 

Expansion of highway ROWs in some cases would allow the 

BLM to be in compliance with the law and allow the highway 

districts the ability to cost effectively construct and maintain 

roads that serve the public needs and provide adequate safety.

Another possible tool to help address the situation would be to 

further review the list of actions allowed in the ROW's.

The primary intent of this recommendation as it is unclear how 

or where highway ROWs are governed is to ensure the Final 

EIS will not adversely impact possible solutions that could 

resolve this issue.

The Final EIS allowed for road rights-of-way (ROWs) and 

mineral sites. Alternative VI (Proposed RMP) included a 

management action for roads outside of exclusion areas The 

management action LA-VI-MA-6 stated, “New road ROWs 

across public land for private purposes would be considered only 

after all other access possibilities have been exhausted.” The 

majority of the planning area would be open to salable mineral 

development subject to site-specific NEPA analysis, etc. (SA-VIA-1). 

Expansion (new ground disturbing activities) of a highway ROW 

must go through the NEPA process prior to amending the ROW 

to remain in compliance with BLM policy and law.

The ROW grant provides a detailed description of actions 

allowed within a ROW.

The governing authority for a ROW is the Federal Land Policy 

and Management Act of 1976.

Land Use 

Authorizations

The Resource Advisory Council unanimously supports LA-II-AS versus LA-IV-A-S. Wind energy will only be developed where 

the wind resource exist. Table 2-4-303 is an inventory of the 

wind resources in the planning area. There are only 34,400 

acres of suitable wind resource in the planning area. Of the 

34,400 acres only 7,400 acres is highly desirable as it is rated 

good or better. The difference in power generation from fair to 

outstanding is substantial, as a 20% increase in wind speed 

translates into a 73% increase in power generation. It makes 

the most sense to place more turbines where the resource is 

best and fewer turbines where the resource is less adequate. 

The Final EIS revised areas available for wind energy 

development. In Alternative VI (Proposed RMP), commercial 

wind and solar energy developments would not be permitted 

inside the sage-grouse management area or within utility rightof-way corridors (LA-VI-A-4). Outside the sage-grouse 

management area, renewable energy site testing, monitoring, 

and development should avoid special status species habitat 

unless unavoidable adverse effects can be mitigated (LA-VI-MA4). See also LA-VI-MA-2.
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Category Comment Response

Wind energy needs to be permitted wherever the resource 

exists, particularly the areas rated good or better, so long as 

the impacts can be mitigated.

Land Use 

Authorizations

Create a more complete map showing all the layers of 

proposed management actions. Map M-83 is confusing, 

several areas identified as available for wind energy 

development are right on top of sage-grouse leks. The maps, 

tables, and supporting data all need to be checked for 

accuracy and then reconfigured in a more accurate 

representation of what the results of these management action 

will be.

The Final EIS revised areas available for wind energy 

development. In Alternative VI (Proposed RMP), commercial 

wind and solar energy developments would not be permitted 

inside the sage-grouse management area or within utility rightof-way corridors. (LA-VI-A-4). Outside the sage-grouse 

management area, renewable energy site testing, monitoring, 

and development should avoid special status species habitat 

unless unavoidable adverse effects can be mitigated (LA-VI-MA4). See also LA-VI-MA-2.

Land Use 

Authorizations

A majority of the Resource Advisory Council supports LA-IIMA-2 over LA-IV-MA-2 with a minority disagreeing. The BLM 

did not provide any justification for restricting development 

within a particular mileage distance from active leks. 

Comprehensive, well-designed pre- and post-construction 

research regarding the potential impacts from a number of the 

resource uses involved has not been conducted to-date. There 

is anecdotal information indicating that sage-grouse have been 

observed, lek attendance continues, and hens have nested 

within 500 meters of wind turbines.

Research from oil/gas development (generally considered to 

have greater impacts than the development of wind energy, 

communication towers, transmission lines, geothermal energy, 

and meteorological towers) indicates some potential indirect 

impacts to sage-grouse within 1 kilometer of infrastructure. 

(Johnson and Holloran, 2010; Johnson, 2010; DGSCP-CMWP 

Tetra Tech, 2010; SWCA, 2006; and BLM, 2003).

The BLM maps and data do not fully illustrate on how much 

acreage LA-IV-MA-2 would restrict development. Maps and 

data have failed to take into account the leks from Bud Lewis 

Hill to the Antelope Pocket, if the 5-mile management action is 

used. In addition, leks can move and over time, new leks can 

be created; fieldwork continues to find new leks. How does the

BLM propose to address leks moving or the discovery of new 

leks? Review all of the maps and data associated with wind 

The 5-mile distance was the original guidance from the US Fish 

and Wildlife Service (FWS) (Manville, 2004). The FWS’s 

guidance included prairie and sage-grouse within the same 

general “prairie grouse” category. The briefing paper provided 

justification for the FWS’s recommendation for a 5-mile buffer 

from occupied prairie grouse leks. 

1. Anecdotal observations can document presence or absence 

but lack context. 2. Individuals of a species can respond 

differently than the species as a whole, which may not be 

desirable. 3. Roads, power lines and other infrastructure are not 

barriers to sage-grouse but can be an added source of mortality 

(collision increased predation, etc.) and/or alter habitat use (e.g. 

fewer sage-grouse use habitat less near infrastructure compared 

to further from infrastructure. 4. Sage-grouse including hens with 

broods are known to use some agricultural fields but use of 

agricultural fields is not without risk including insecticides (see 

Blus et al., 1989) or feral/domestic cats and dogs, or 

synanthropic avian predators such as ravens.

(Commenter did not include full citations for Johnson and 

Holloran, 2010; Johnson, 2010; DGSCP-CMWP Tetra Tech, 

2010; SWCA, 2006; and BLM, 2003, so these references could 

not be addressed).
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Category Comment Response

energy and sage-grouse leks for accuracy.

The intentions of the management actions when applied to the 

maps are not readily apparent and often appear inaccurate.

Land Use 

Authorizations

The Environmental Protection Agency supports clear 

management actions for right-of-way (ROW) authorizations. 

Management actions such as, LA-CA-MA- 4, "New ROWs 

would meet Visual Resource Management class objectives." 

provide clear direction and help to facilitate the RMP's 

effectiveness. To better describe and disclose the implications 

of LA-CA-MA-1, "Place new ROWs for pipelines and overhead 

lines within ROW corridors where practical; other locations 

would be considered on a case-by-case basis in areas not 

identified for ROW avoidance or exclusion, consistent with 

allocations listed above.", we recommend the Final EIS include 

additional clarifying information on how this management 

action appears to prohibit case-by-case ROW consideration in 

"avoidance areas".

Revisions to the Final EIS removed the phrase “case by case” 

from most management actions, including LA-CA-MA-1.

Land Use 

Authorizations

Pg. 4-643, Table 4-302. The BLM knows it will never adopt a 

route density change increase as shown for Alt II- an increase 

over 1,161,000 acres. This is just done to make Alt. IV look 

better. How does the BLM factor Oil and Gas, Geothermal, 

wind and other rights-of-way and industrial uses under the 

industry-friendly range of alternatives of the Draft RMP/EIS?

The Final EIS analyzed a range of Alternatives for management 

of the planning area. Alternative II focused on increasing 

commercial uses in the planning area. Alternative VI (Proposed 

RMP) focused on balancing resource use and protection to 

restore the ability of the ecosystem to recover following a 

disturbance, and reduce fragmentation of habitat for sagegrouse and other native species.

Land Use 

Authorizations

Consider the predicted increase in cheatgrass due to climate 

change in all aspects of the Final EIS, including the suitability 

of lands for Oil and Gas, Geothermal, right-of-way (ROW) or 

other activities that result in significant surface disturbance. 

Also, fully consider it in travel processes and identifying road 

closures to limit weed spread along ROWs or because of road 

upgrades.

The Final EIS revised climate change discussions in the Climate 

Change section of Chapters 3 and 4 to add more information, 

context, and clarity.

Land Use 

Authorizations

The BLM should manage for no increase in communication 

sites, bundling of facilities, and severe constraints in night 

lighting to protect migratory birds and limit intrusion.

New communication sites were included in the range of 

alternatives (Chapter 2, Land Use Authorizations). See LA-CAMA-4 "Co-locate new communication sites with existing sites 

where practical, etc." See also LA-VI-MA-3 "New communication 

sites would avoid special status species habitat if the project 

would have an adverse effect, unless those impacts can be 

mitigated."
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Land Use 

Authorizations

Much larger areas of the landscape must be utility avoidance 

areas.

The Final EIS analyzed a range of different right-of-way (ROW) 

exclusion and avoidance areas. Alternative VI (Proposed RMP) 

revised ROW avoidance and exclusion areas from what was 

presented in the other alternatives. See Maps 93 through 96 in 

the Final EIS for ROW exclusion areas and Maps 86 through 92 

for ROW avoidance areas.

Land Use 

Authorizations

Why is there no mapping of potential wind development areas 

for the No Action Alternative?

A map of expected wind development areas for the No Action 

Alternative was included in the Final EIS (Map 99). 

Lands with

Wilderness

Characteristics

Monitor areas managed for their wilderness characteristics to 

insure that other uses, such as motorized vehicles and grazing 

infrastructure, are not impairing wilderness character and, if 

they are, the use should be changed or ended to stop the 

impairment. Appendix P in the Draft RMP/EIS provides 

generally for evaluation of non-Wilderness Study Area lands 

with wilderness characteristics every five years after 

completion of the comprehensive travel management plan, but 

does not include a specific description of the monitoring that 

will be conducted.

The BLM currently has no policy for monitoring Lands with 

Wilderness Characteristics managed for their wilderness 

characteristics. However, the BLM is required to maintain and 

update its inventory of wilderness resources. 

Lands with

Wilderness

Characteristics

BLM considered Lands with wilderness characteristics, and in 

accordance with the Owyhee Initiative, BLM should manage 

them as described in Alternative II and III.

The BLM is required to evaluate Lands with Wilderness 

Characteristics through the land use planning process. When 

Lands with Wilderness Characteristics are present, the BLM 

must examine options for managing these lands and determine 

the most appropriate land use allocations for them. The BLM 

must determine whether to manage these lands to protect their 

wilderness characteristics or to manage for other uses that may 

be incompatible with protection of wilderness characteristics. 

The Final EIS analyzed a range of alternatives addressing Lands 

with Wilderness Characteristics management in the planning 

area.

Lands with

Wilderness

Characteristics

There is no need to designate any Lands With Wilderness 

Characteristics because:

1) First and foremost, on March 30, President Obama signed 

the Omnibus Public Land Management Act of 2009 (OPLMA) 

which designated 517,000 acres of wilderness, and 316 miles 

of wild and scenic rivers. It instantly released nearly 200,000 

acres of Wilderness Study Areas from the requirement to be 

managed to protect wilderness characteristics.

The Final EIS identified Lands with Wilderness Characteristics 

contained in the planning area through the inventory process 

described in BLM Manual 6310--Conducting Wilderness 

Characteristics Inventory on BLM Lands. By policy set forth 

under Section 201 of the Federal Land Policy and Management 

Act of 1976, Secretarial Order 3310, and BLM Manual 6320--

Considering Lands with Wilderness Characteristics in the BLM 

Land Use Planning Process, the BLM is required to “prepare and 

maintain on a continuing basis an inventory of all public lands 

and their resource and other values.” Regardless of past 
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2) Subtitle F - Owyhee Public Land Management of OPLMA 

states, "The public land in the County administered by the 

Bureau of Land Management has been adequately studied for 

wilderness designation. (B) RELEASE-Any public land referred 

to in subparagraph (A) that is not designated as wilderness by 

this subtitle- (i) is no longer subject to section 603(c) of the 

Federal Land Policy and Management Act of 1976 (43 U.S.C. 

1792( c)); and (ii) shall be managed in accordance with the 

applicable land use plan adopted under section 202 of that Act 

(43 U.S.C.1712).

3) Secretarial Order 3310 signed December 22, 2010 by 

Secretary of the Interior, Ken Salazar orders the BLM to 

maintain wilderness resource inventories and to protect 

wilderness characteristics through land use planning and 

project-level decisions.

4) Owyhee County lands within the planning area have 

previously been assessed for wilderness value, and those 

determined to have wilderness qualities were listed as 

wilderness on 3/30/09 by the OPLMA. Based on this

assessment, there are no remaining lands with wilderness like 

characteristics and therefore this portion of the Draft RMP/EIS 

needs to be removed.

5) Furthermore, Governor of Idaho, C.L. "Butch" Otter, 

representing the majority of Idaho citizens, does not support 

the designation prescribed under Secretarial Order 3310.

6) The designated Non-Wilderness Study Area Lands with 

Wilderness Characteristics fail to recognize the numerous 

roads, trails, byways, salt grounds, fences, pipelines, 

reservoirs, fire suppression cat-lines, and non-native 

vegetation that are present within these areas.

inventory, the BLM must maintain and update as necessary, its 

inventory of wilderness resources on public lands.

1 and 2) Owyhee Public Land Management Act did release the 

Bruneau River-Sheep Creek Wilderness Study Area (WSA) and 

the Jarbidge River WSA, but it did not release the BLM from its 

obligation to inventory Lands with Wilderness Characteristics. 

3 and 5) Secretarial Order 3310 requires the BLM to maintain 

wilderness resource inventories and to protect wilderness 

characteristics through land use planning. 

4) Owyhee County lands in the planning area have been and will 

continue to be inventoried for wilderness characteristics.

6) Lands with Wilderness Characteristics identified in the Final 

EIS meet the criteria described in BLM Manual 6310. 

Lands with

Wilderness 

Characteristics

For Lands with Wilderness Characteristics we urge 

management actions contained in the preferred alternative be 

replaced with the No Action Alternative. Eliminate any action in 

the Final EIS to create de-facto wilderness. Congress reserved 

for itself the power to create wilderness. As spelled out in the 

Consistent with Section 201 of the Federal Land and Policy 

Management Act, which requires the Secretary of the Interior to 

"prepare and maintain on a continuing basis an inventory of all 

public lands and their resource and other values," BLM Manual 

6310, and BLM Handbook H-1601-1, Land Use Planning, the 
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Wilderness Act of 1964, the primary management concern 

within a wilderness area is to maintain wilderness character, 

which is the management prescribed in the Draft Alternative IV. 

Carried to its logical conclusion, such action allows unelected 

agency officials to create bureaucratic wilderness with all the 

ramifications of the real thing. If BLM contends it cannot now 

un-identify those lands it has identified as lands with 

wilderness characteristics, we then recommend under 

"Objectives" Vol. 1 Section 2 p. 120 that WC-IV-O-I, are 

replaced with WC-II-O-l. Do not manage identified lands 

specifically to maintain wilderness characteristics, and do not 

make the false assumption that prior or continuing motorized 

use precludes an area from designation as wilderness by 

Congress. Many two-track routes and "ways" that do not 

qualify as ROADS when identifying for wilderness 

characteristics are useful and desirable for off-highway vehicle

recreation.

Jarbidge Inter Disciplinary Team evaluated and identified BLMmanaged Lands with Wilderness Characteristics outside existing 

Wilderness Study Areas. The Final EIS analyzed a range of 

alternatives for how the BLM would manage Lands with 

Wilderness Characteristics. Alternative VI (Proposed RMP)

would not manage inventoried Lands with Wilderness 

Characteristics to maintain their wilderness character. 

Lands with

Wilderness

Characteristics

Considering the Draft RMP/EIS was released in August 2010 

and Secretary of Interior Salazar did not release his WildLands directive (Secretarial Order 3310) until late December 

2010; among questions this raises is whether the Lands with 

Wilderness Characteristics chapter should even have been in 

the document prior to the official change of policy. 

The inventory process for Lands with Wilderness Characteristics

is different than the executive order 3310 identified in this 

comment. 

On December 22, 2010, the Secretary of the Department of the 

Interior issued Order 3310 to address the BLM’s management of 

wilderness resources under its jurisdiction and to use the land 

use planning process to designate certain Lands with Wilderness 

Characteristics as “Wild Lands.” On April 14, 2011, the United 

States Congress passed the Department of Defense and FullYear Continuing Appropriations Act (Public Law 112-10) (2011 

CR), which includes a provision (Section 1769) that prohibits the 

use of appropriated funds to implement, administer, or enforce 

Secretarial Order 3310 in Fiscal Year 2011. 

On June 1, 2011, the Secretary issued an Instruction 

Memorandum (IM) 2011-154 to the BLM Director that in part 

affirms BLM’s obligations relating to wilderness characteristics 

under Sections 201 and 202 of Federal Land Policy and 

Management Act of 1976 (FLPMA). This Instruction Memo

further clarifies that the requirements of Sections 201 and 202 of 

FLPMA remain in effect. It also provided direction on how to 
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conduct and maintain wilderness characteristics inventories and 

provides direction on how to consider Lands with Wilderness 

Characteristics in the land use planning process. The Final EIS 

revised the Non-Wilderness Study Area Lands with Wilderness 

Characteristics section to the Lands with Wilderness 

Characteristics section and to reflect direction contained in IM2011-154.

Lands with

Wilderness

Characteristics

In Section 2.3.14 Non-Wilderness Study Area Lands with 

Wilderness Characteristics of the Draft RMP/EIS, the 

management goal common to all action alternatives directs 

BLM to “maintain wilderness characteristics of non-Wilderness 

Study Area lands as appropriate, considering the 

manageability and the context of competing resource 

demands” (WC-CA-G-1). The key phrase in this goal is “as 

appropriate.” The Appropriateness of this overall goal or 

alternative-specific goals is not specified in the Draft RMP/EIS. 

The reader must review the management specific to each 

alternative to garner whether BLM believes it would be 

appropriate to maintain wilderness characteristics of nonWilderness Study Area lands.

In Chapter 2 of the Final EIS, for the Lands with Wilderness 

Characteristics section (formerly Non-Wilderness Study Area 

Lands with Wilderness Characteristics), each alternative has a 

goal specific to that alternative. A reasonable range of 

alternatives for managing Lands with Wilderness Characteristics

has been incorporated and analyzed. The Final EIS removed the 

term “as appropriate”.

Lands with

Wilderness

Characteristics

On p. 2-119 of the Draft RMP/EIS, for Non-Wilderness Study 

Area with Wilderness Characteristics, we oppose any road 

closures for the areas mentioned. You are discriminating highly 

against the hunters and sportsmen in favor of rafters. 

Closing Lands with Wilderness Characteristics managed for their 

wilderness characteristics to motorized travel was included in the 

range of alternatives analyzed in the Final EIS. The range of 

alternatives also included options that would not close these 

areas to motorized vehicle use. Alternative VI (Proposed RMP) 

does not close Lands with Wilderness Characteristics to 

motorized travel.

Lands with

Wilderness

Characteristics

On p. 3-62, Table 3-40, please indicate which section of 

Salmon Falls Creek you are referring.

The “Lands with Wilderness Characteristics” map was revised in 

the Final EIS (Map 49), to show that the area of Salmon Falls 

Creek referenced is between the Nevada border and Salmon 

Falls Reservoir (Browns Bench).

Lands with 

Wilderness 

Characteristics

On p. 2-120 of the Draft RMP/EIS, please identify which 

segment of Salmon Falls Creek you are referring. Again, we 

oppose any road closures in this section and any such 

designations for Salmon Falls Creek below Balanced Rock.

Map 42 of the Draft RMP/EIS displays The Salmon Falls Creek 

area referenced on p. 2-120. The area is on Browns Bench 

adjacent to the Nevada border. The Final EIS included an 

updated inventory for Lands with Wilderness Characteristics 

(see Map 49 “Lands with Wilderness Characteristics”), which 

followed direction in BLM Manual 6310.

Livestock

Grazing

It is essential that BLM provide data on the actual use and 

utilization that has been occurring in each pasture under 

Chapter 3 describes current conditions that are the result of past 

management and natural events, such as fire. The information 
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Category Comment Response

various stocking levels, under Temporary Non-renewable 

Authorization use, under seasons of use, residual grass height 

that remains under grazing schemes, cheat grass and other 

weed advance, micro biotic crust losses or degradation, forb 

losses, failed or poorly recovered fire and other rehab efforts, 

etc. Clearly lay out the degree and severity of impacts of 

existing uses on habitats and species so a reader can 

understand how the Draft RMP/EIS would change matters.

included in Chapter 3 is sufficient to provide the reader with an 

understanding of the baseline conditions of the affected 

environment. Chapter 4 describes the direct, indirect, and 

cumulative impacts of each alternative combined with 

reasonably foreseeable future actions, and provides the reader 

with a basis for comparison among the alternatives.

Livestock 

Grazing

Use grazing in conjunction with strip vegetation, to not only 

promote wildlife but to lessen the chance of gigantic fires that 

are starting to characterize the plant and animal ecology.

Alternative VI (Proposed RMP) analyzed the use of targeted 

grazing and vegetated fuel breaks as one of a number of tools to 

manage fuels (see management actions FE-VI-MA-3 and FE-VIMA-4). After signing of the Record of Decision, project specific 

proposals will be developed and analyzed to identify the most 

effective combination of tools to manage fuel loadings.

Livestock 

Grazing

Although never clearly defined, the use of the word "livestock" 

must essentially mean cattle, at least in this particular 

document.

The Final EIS added the term "livestock" to the Glossary.

Livestock 

Grazing

It is also obvious to the reader that due to both the Stipulated 

Settlement Agreement, and the ever-changing Federal land 

management philosophy driven by multiple use and other 

concept that livestock grazing of Federal lands in the Draft 

RMP/EIS will be reduced. In the alternatives (Chapter 2), one 

would assume that reasonably accurate numbers of animal 

unit months (AUMs), etc. would be available. The first 

indication of livestock numbers appears in 2.4.1. Livestock 

Grazing - Management Specific to the No Action Alternative (p. 

2-122). Under Allocation - Forage and Grazing Management 

Practices, LG-NA-A-2 we are told that, "Continue allocating 

approximately 200,000 AUMs for livestock". As the plan is 

implemented, between 160,000 and 260,000 AUMs could be 

issued for livestock depending on implementation of treatments 

described in the Upland Vegetation section. However, this 

information would be useless to the reader, as he already 

knows that the section, Management Specific to the No Action 

Alternative, is meaningless for the future of this RMP/EIS. 

However, the figure of 200,000 AUMs seems to suggest some 

historical perspective, and further, the figure of 260,000 AUMs 

seems to suggest considerable potential for the planning area.

The Final EIS revised Chapter 2 to reflect the estimated range of 

animal unit months allocated to livestock grazing under each 

alternative. 
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Category Comment Response

Under Management Common to All Action Alternatives (pp. 2-

125 through 2-127), there is no further discussion of livestock 

AUMs or livestock numbers.

Under Management Specific to Alternative IV (the Preferred 

Alternative) (pp. 2-139 through 2-143), there again is no further 

discussion of livestock AUMs or livestock numbers. There is a 

presentation of allocated vegetation production for watershed 

and wildlife, wild horses and livestock. However, without 

additional information, it is impossible to determine livestock 

numbers, estimated carrying capacity and a variety of other 

measurements pertinent to livestock interest under Alternative 

IV.

Livestock 

Grazing

The Draft RMP/EIS does not indicate how long treated areas 

will be removed from grazing, nor does it clearly indicate how 

grazing will be curtailed (fencing, herding, etc.).

It is difficult to understand how and why livestock grazing will 

be significantly curtailed in this plan. If as the Agency indicates 

the potential animal unit month (AUM) production could be as 

high as 427,000 AUMs and if as the Agency indicates 

allocation of only 4,859 AUMs to wildlife and horses, then 

potentially some 422,000 AUMs are available for livestock and 

watershed.

The Final EIS described allocations to livestock grazing in two 

ways: (1) areas of land available to livestock grazing, and (2) the 

amount of forage (animal unit months [AUMs]) available to 

livestock grazing. The Final EIS described forage allocation in 

each action alternative as a percentage of the total vegetation 

production allotted for resource use and protection and livestock 

grazing that would achieve resource objectives specific to that 

alternative. The Final EIS revised Chapter 2 to reflect the 

estimated range of AUMs allocated to livestock grazing under 

each alternative.

Under NEPA, BLM is required to analyze a range of reasonable 

alternatives for livestock grazing and forage allocations. The 

2005 Stipulated Settlement Agreement requires analysis of "at 

least one alternative in the EIS addressing significantly reduced 

grazing levels in those areas demonstrating livestock-related 

conflicts with other multiple-use values". The example used in 

this comment is specific to Alternative II, which focuses on 

increasing commercial uses. Whereas Alternatives IV-A, IV-B 

emphasize restoration of ecosystem structure and function, and 

V restoring historic native plant communities. These three 

alternatives would allocate less forage than Alternatives I, II, III, 

and VI.

Between the Draft RMP/EIS and the Final EIS, BLM developed 

Alternative VI (Proposed RMP). Alternative VI focuses on 
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Category Comment Response

actively restoring the resiliency of sagebrush steppe ecosystem 

structure and functions through restoration projects and 

enhanced fire management while balancing resource protection 

and uses within the planning area. BLM considered comments 

received from the public on the Draft RMP/EIS, the analysis of 

effects described in the Chapter 4, and available science to 

select a level of forage allocation to livestock that provides for 

livestock grazing while meeting other resource objectives.

Livestock 

Grazing

The Draft RMP/EIS (p. 4-595) includes Table 4-282. Change in 

Forage Availability for Livestock Grazing Due to Vegetation 

Treatments by Alternative (AUMs). For Alternative IV-A and 

Alternative IV-B, after forage treatment the number of animal 

unit months (AUMs) that may be available for livestock could 

be as low as 89,000 (Alternative IV-A) or 92,000 (Alternative 

IV-B). This leaves an unreasonable amount of forage (upwards 

of 330,000 AUMs, or some 133,200 tons of annual production 

of forage material) that is unaccounted for. This reviewer 

cannot find anything in the Draft RMP/EIS stating anything 

about potential increase in catastrophic fire, or even fire for that 

matter. We consider leaving this amount of fuel buildup on an 

annual basis a significant mismanagement, regardless of 

Stipulated Settlement Agreement, or any other fact for that 

matter.

The Final EIS allocated vegetation production to watershed, 

wildlife, wild horses, and livestock under each alternative (see 

the Livestock Grazing sections in Chapter 2). Chapter 4 

described the effects of these allocations. The Final EIS, 

Wildland Fire Ecology and Management section, describes the 

impacts of the vegetation allocations including discussion and 

evaluation of impacts to fire size relative to vegetation treatment 

and livestock grazing actions.

Livestock 

Grazing

The Draft RMP/EIS (p. 2-48) indicates development of some 

75-ungrazed reference areas, compared to adjacent 75-grazed 

areas, to study the effects of livestock grazing (UV-IV-MA-29). 

The Draft RMP/EIS fails to mention how the ungrazed areas 

will be maintained in an ungrazed condition. If fencing is 

required, these approximately 160 acre fields will each require 

2 miles of fencing, or 150 miles total. How is this fencing to be 

paid for, which could cost as much as $750,000 or more? What 

will BLM measure on both grazed and ungrazed sites? How 

much manpower will these measurements require? How long 

will BLM maintain these sites? Delete or explain this 

management action in detail.

The Draft RMP/EIS (p. 2-59) indicates that BLM will study the 

effect of riparian habitat from 10 ungrazed riparian reference 

areas, compared to adjacent grazed reference areas (RI-IVConsideration of ungrazed reference areas was a requirement of 

the Stipulated Settlement Agreement. Details related to 

establishment and monitoring of reference areas are dependent 

on location of individual areas, topography, vegetation, special 

status species, and existing infrastructure. Generally, monitoring 

would be specific to capturing long-term response of vegetation 

and soils to exclusion of livestock grazing. Maps 11 to 15 provide 

estimates of where reference areas may occur, but final location, 

objectives, and monitoring plans would be addressed in detail 

following approval of the RMP. 

Alternative VI (Proposed RMP) analyzed establishment of up to 

52 40-acre (see management action UV-VI-MA-25) upland and 

10 riparian (UV-VI-MA-25) reference areas. BLM would exclude 

livestock grazing in the reference areas by using a combination 

of natural barriers and existing and new fences. Funding and 
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MA-4). Again no comment occurs in the draft how ungrazed 

areas will be maintained ungrazed, no mention is made of what 

measurements will be made, duration of the study, cost, etc. 

Explain this section in sufficient detail so that the reader can 

determine what BLM proposes, and how BLM will accomplish 

it, and what it will cost.

staffing will be an important consideration of establishment of the 

exclosures following the Record of Decision. 

The land use planning process does not secure funding but 

rather establishes goals, objectives, and priorities by which 

treatments would be applied within the planning area. Annual 

funding levels and priorities would determine treatments, 

personnel, or other resources to implement the plan.

Livestock 

Grazing

The discussion of livestock grazing impact throughout Chapter 

4 frequently and repeatedly makes statements about various 

adverse effects that livestock grazing “could” produce.

However, there are no scientific references related specifically 

to the planning area that support these statements. The 

frequent references to light or moderate utilization values 

attributed to Holechek and the purported vegetation response 

are not appropriate. None of the references relate directly to 

the planning area and further, the conclusions purported by 

Holechek are not based on information directly related to the 

planning area. This is a misuse of purported scientific 

information.

There is a body of literature that relates, in general, to livestockrelated impacts to vegetation in the Great Basin. The use of 

studies or information gathered outside the planning area is an 

acceptable practice as long appropriate caution is used when 

applying the information. BLM made an extensive effort to collect 

and review internal and external resources and current and 

pertinent literature available related to allocation, stocking rates, 

and use levels by conducting multiple public meetings, and 

public review of the Draft RMP/EIS.

Livestock 

Grazing

It should be assumed that livestock grazing would continue to 

be managed to conform to the Idaho Standards and 

Guidelines, thus any adverse impacts that actually were 

occurring would be corrected through adaptive management. 

Consequently, remove all speculation as to what “could” 

happen from the analysis because it provides no reliable 

information as to actual environmental effects or future 

conditions.

The purpose of the analysis is to disclose foreseeable impacts 

resulting from allocations and management actions in each 

alternative. Because these actions could occur at various times 

throughout the life of the plan some reasonable theorizing as to 

what “could” happen must be made to predict environmental 

impacts. One cannot assume that all impacts can be accurately 

predicted, but to the extent possible current monitoring, 

literature, and professional judgment are used to reasonably 

predict impacts. BLM would manage livestock grazing to 

conform to the fundamentals of rangeland health per 43 CFR 

4180.

Livestock 

Grazing

The Draft RMP/EIS reports: “Every rancher interviewed for the 

analysis had family members who would want to become 

ranchers if it were economically feasible (Evans, 2008), but it is 

assumed that it would require more forage allocation to support 

an additional rancher than current levels... It is assumed for the 

purposes of this analysis that a change of 10,000 animal unit 

months (AUMs) beyond the baseline AUM range in the No 

Action Alternative would change the size of the rancher 

The Chapter 4 analysis in the Social Conditions section has 

been revised in the Final EIS. Changes in operator numbers 

using a ratio of animal unit months to operators is no longer used 

in the analysis of grazing in the Final EIS. The updated grazing 

analysis used established BLM methodology.

Alevy and others (2007) inferred use of a “multiplier” to estimate 

the economic impact of federal grazing on ranch production. The 
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Category Comment Response

stakeholder group by one.” However, using the 2.21 ranch 

level AUMs for each Federal land grazing AUM cited at p. 4-40, 

the 10,000 AUMs would equate to a 1,842 head cattle ranch. 

This is hardly the minimum economic size for one additional 

ranch. However, this assumption is in error by a factor of 4. An 

economic ranch unit (full time rancher) would likely be in 400 to 

500 AUM range. Thus, using the mysterious 2.21 ranch level 

multiplier an increase of 2,500 Federal AUMs would support 

one additional full time ranch operation or a decrease of 2,500 

AUMs would cause the loss of one full time rancher.

multiplier of 2.21 as stated in the Draft RMP/EIS was changed to 

2.19 in the Final EIS. This multiplier was derived by using values 

displayed in Table 5 of Alevy and others (2007), and verified by 

Tables 6 and 7. 

Livestock 

Grazing

I am writing concerning your proposal to close Allotment 01100 

Diamond A 1429 Canyon to livestock grazing. This allotment is 

a vital part of the Stowell Ranch. 

Alternatives I-VI kept Allotment 01100 Diamond A Bruneau 

Canyon unavailable for grazing. This allotment is currently 

vacant and not under a livestock grazing permit.

Livestock 

Grazing

It is time to evaluate the grass each year to determine animal 

unit months (AUMs) and turn out dates. Implement these 

vegetation allocations during the permit renewal process. Only 

adjust allocations during permit renewal based on available 

data. The purpose of allocating vegetation is to determine the 

total AUMs available for livestock grazing in the planning area. 

Allocation percentages are not the same as utilization, as the 

allocation is used to identify the total number of AUMs for 

livestock, while utilization identifies the amount of vegetation 

used by livestock in a specific area. The intention of allocation 

is not to prescribe what livestock can actually consume. Adjust 

allocations to reflect varying percentages when there is a mix 

of production type within a particular pasture.

The Final EIS identified lands available or not available for 

livestock grazing and identified on an area-wide basis the 

amount of forage available for livestock (in animal unit months) 

both at initial implementation and in the future with full 

implementation of the land use plan. Changes to allotment 

specific allocations only occur during permit renewals, which 

typically occur every 10 years. However, annual adjustments to 

numbers and grazing periods may occur in order to address 

specific resource issues determined through annual monitoring 

and current environmental factors.

Livestock 

Grazing

In light of the Soil Conservation Districts' long record of working 

cooperatively with numerous stakeholders to achieve results, 

the preferred alternative of the Draft RMP/EIS threatens to 

cripple the ability of the Soil Conservation Districts to continue 

working in the planning area. The primary issue the Twin Falls 

and Balanced Rock Soil Conservation Districts have concerns 

about is the failure of BLM to take into account unintended 

impacts from numerous proposed actions. Actions taken by 

BLM on Federal lands will have impacts on private and State 

lands, which will then in turn have impacts on Federal lands 

due to the connectivity of resource management, issues, or 

impacts don't stop at fence lines or property boundaries. 

The Final EIS analyzed effects to private and State lands 

resulting from Federal actions in the Cumulative Impacts 

analyses. In addition, the Final EIS revised the Cumulative 

Impacts analyses to better explain the effects of Federal actions 

on adjoining lands as well as the combined effects of 

foreseeable actions on all landownerships within the cumulative 

impact analysis area (see Map 60 “Cumulative Impact Analysis 

Area for Livestock Grazing” in the Final EIS).
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An example of this failure to adequately address the impacts 

occurs in the proposed action to reduce animal unit months 

(AUMs) on Federal land. It is unlikely there will be an actual 

reduction in livestock numbers within the planning area. Rather 

a shift in where livestock graze and when, as private and State 

lands will make up the AUM difference. It is reasonable to 

expect much of the increased forage production on private and 

State lands to come from the conversion of native vegetation to 

exotic plant communities. In addition, many of the changes in 

season of use on Federal acreage would require landowners to 

shift use to private and State lands. In most cases, this would 

not result in a net gain for the resource conditions in the 

planning area (all lands Federal, State, private). The Soil 

Conservation Districts have concerns that the proposed BLM 

actions would render inoperative numerous conservation 

projects and decades of working relationships as landowners 

readjust by making dramatic management changes. Many of 

the landowners’ management changes are likely to lead to a 

decrease in water quality, destruction of wildlife habitat, 

increased soil erosion, and an abandonment of conservation 

plans. Has BLM fully accounted for all the impacts the Draft 

RMP/EIS will induce? The actions on Federal lands will have 

impacts elsewhere and in the case of the preferred alternative, 

these impacts may outweigh the perceived benefits if BLM 

considers a broader setting for the environment as required by 

law. Just as projects on private and State lands require a 

Federal analysis if Federal land is deemed to be part of what 

enables the project, cumulative impacts, the same is also true 

in the reverse. Federal actions must not degrade the overall 

environment even in cases where the action might improve the 

Federal lands.

Livestock 

Grazing

There must be alternatives that provide for usage of fine fuels, 

and I believe that managed cattle grazing results in fire 

suppression, protections of wildlife habitat and improved 

diversity and abundance of native plant species. Grazing has 

proved to help reduce the incidence of catastrophic fires, which 

destroy watershed, wildlife and their habitat, especially in a 

year when the growing season produces too much 

vegetation/fuel.

Each alternative considered contains management actions 

addressing fine fuels and wildfire suppression. BLM developed 

Alternative III specifically to restore ecosystem structure and 

function through intensive management of fuels, including forage 

allocations to livestock. The Final EIS, Wildland Fire Ecology and 

Management section, addressed management of fine fuels and 

how allocations to livestock grazing would influence fuel loading 

and fire management.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Livestock 

Grazing

We realize the establishment of livestock grazing enclosures is 

a requirement of the court ordered Stipulated Settlement 

Agreement, but in reality, the enclosures will add very little 

value to the management of the planning area. Ecological and 

range site descriptions are readily available to inform the 

manager of a sites potential in the absence of grazing. 

Because of this lack of value, enclosures should be restricted 

to the smallest number and size possible. UV-III-MA-20 on p. 

2-43 is the best management action in regards to livestock 

grazing enclosures.

In most cases, 40-acre enclosures would be of sufficient size to 

isolate local environmental factors to allow evaluation of 

ecological changes due to management. Alternative VI 

(Proposed RMP) analyzed establishment of up to 52, 40-acre 

upland enclosures and 10 riparian enclosures, in major 

ecological sites within the planning area.

Ecological site descriptions are a planning and evaluation tool. 

However, site potential in parts of the planning area have been 

altered to the extent ecological site descriptions may not fully 

address site conditions or potential, making tools such as 

reference areas valuable in monitoring change in potential.

Livestock 

Grazing

LG-IV-A-1 on p. 2-139 lists the Canyons or riparian corridors 

associated with the Bruneau and Jarbidge Rivers as not 

available for livestock grazing. LG-IV-MA -12 on p. 2-141 

states that livestock grazing may be considered on a case-bycase basis in a portion of big game winter range in native 

shrub communities during winter. LG-IV-A-1 and LG-IV-MA-12 

will potentially restrict or eliminate grazing in several 

allotments. These allocations/management actions disregard 

the relatively large amount of private property and State leased 

grazing lands that are located within and adjacent to the 

canyon areas/winter ranges, and these measures should only 

be implemented when information is available to illustrate a 

direct and site specific cause and effect relationship.

The 1987 RMP did not allocate forage to livestock grazing in the 

Bruneau and Jarbidge canyons (LG-NA-A-1, Map 52). 

Alternative VI (Proposed RMP) keeps the Bruneau and Jarbidge 

canyons unavailable to livestock grazing (LG-VI-A-1, Map 59).

Livestock 

Grazing

Remove management actions LG-CA-MA-9 (guidance for 

trailing in riparian areas) and LG-CA-MA-15 (priority list for 

fence modification) on p. 2-127 of the Draft RMP/EIS.

This specificity should only be done on the activity level, not 

the land use planning level. Grazing to reduce fuels (LG-III-0-2, 

p. 2-135) should not be restricted to non-native perennial 

communities. Native perennial communities, with an 

overabundance of fuel, create fire hazards comparable to nonnative perennials. Within the planning area, whenever livestock 

grazing has been concentrated on non-native perennial 

communities while use on native shrubland is restricted, the 

resultant fires will destroy the native shrubland communities 

due to the buildup of fine fuels.

LG-CA-MA-10 provided direction for trailing activities that would 

limit impacts to riparian resources. The management action 

provided flexibility to prescribe site-specific actions as needed at 

the project level. 

Maintaining fences on public lands to these specifications is 

policy and therefore required. Management action LG-CA-MA-16 

simply prioritized areas in which this action would be 

implemented. 

Wildfire has affected both native and non-native vegetation types 

in recent history. The range of alternatives developed for the 

Final EIS allowed for the use of grazing to reduce fuel loading 

contributed by native and non-native communities. Alternative VI 
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(Proposed RMP) included flexibility necessary to determine sitespecific actions to effectively manage fuel loadings in both native 

and non-native plant communities.

Livestock 

Grazing

In reference to LG-I, II, III, IV, V-A-l, Cat Creek Cattle Company 

has a valid grazing permit for the Bruneau Canyon Allotment, 

which is located along the Bruneau River, up-stream of its 

confluence with the Jarbidge River. The permit is administered 

by the Bruneau Field Office, Boise District BLM. , Cat, Creek 

Cattle Company owns approximately 2,040 acres of private 

land, and leases State sections for grazing within the canyon 

area. Simplot's Livestock Company also owns private land and 

leases State sections for grazing within the canyon area. 

Simplot's livestock operation requires the movement of cattle 

across the canyon at Black Rock Crossing and Indian Hot 

Springs. Any proposals developed for management of the 

Bruneau River Canyon should consider these facts and be 

tailored to prevent any disruption to traditional operations. The 

planning document recognizes the high probability of 

“cheatgrass invasion within the canyon lands following fire. 

Livestock grazing is the only viable method available to remove 

fine fuels, reduce fire hazard and prevent the encroachment of 

this unwanted species.

The proposed closure of the Bruneau Canyon would affect the 

Bruneau Canyon Allotment administered by the Bruneau Field 

Office. Should this action be carried forward in the Final EIS, the 

Record of Decision will detail how this issue should be handle in 

order to coordinate appropriately with the Bruneau Field Office 

and the affected permittee and private landowner.

Livestock 

Grazing

Elko County strongly urges the BLM and other public land 

management agencies to re-evaluate the current and proposed 

policies of the Draft RMP/EIS that prohibit or severely limit 

livestock grazing and other multiple uses on public land to help 

ensure that catastrophic wildfires don't occur. The Federal land 

management agencies must permit the grazing permits to 

utilize the maximum feed value while reducing the fuel loads 

on public lands to promote the health safety and welfare of the 

wildlife and environment including air quality.

The range of alternatives included various methods to manage 

fuel loading and wildfire through various vegetation treatments, 

fuel treatments, and livestock forage allocation. See Chapter 4 

analysis in the Upland Vegetation, Wildland Fire Ecology and 

Management, and Livestock Grazing sections. Alternative VI 

(Proposed RMP) included FE-VI-MA-4, which provided for the 

use of targeted grazing and other options to create fuel breaks to 

reduce fire size.

Livestock 

Grazing

Specific to our Devil Creek family ranch, we are alarmed at the 

proposed option to close access to Clover Creek for animals 

from our BLM allotment in the Buck Flat AMP.

All exclosures, upland and riparian alike, will be analyzed at the 

site-specific level for their effects on resources and resource 

uses, including livestock grazing. BLM will coordinate with all 

affected permittees during the analysis, decision-making, and 

implementation stages of future projects to address specific 

issues such as access to livestock water.

Livestock 

Grazing

My first major concern is with the allocation of vegetation 

production under Alternatives IV-A, IV-B (the Preferred 

The Final EIS included a wide range of forage allocation to 

livestock grazing to allow for an analysis of effects on resources 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Alternatives) and Alternative V. Though these allocation 

percentages are not the same as utilization, if the allocations 

are set unrealistically low (0%), then they create an unworkable 

situation. More specifically, the 0% allocation of annual 

grasses, as well as, shrub and forb production, especially with 

sheep, is unworkable as fine grasses, shrubs and forbs are a 

major portion of their diet. In addition, this allocation is 

unhealthy to the resource as it advances the proliferation of 

cheatgrass and minimizes the vigor of the shrubs and forbs, 

through reduced utilization, by only allowing wildlife use.

Only allocations, such as those in Alternative II, or something 

close to it, will create a workable and sustainable plan to 

maintain and improve a healthy resource. Especially in light of 

the rest rotation and deferred grazing management systems 

that are in place in this resource area. Also, allocations like 

those proposed, would significantly reduce the value of 

targeted grazing on annual grasses for the purpose of fuel 

breaks for fire.

and resource uses. Forage allocation in the Final EIS included 

percentages of native and non-native perennial, annual, and 

shrubs and forbs to more accurately represent actual diet 

selection of domestic livestock as well as facilitate management 

of fine fuels represented in the annual grass communities. The 

majority of the forage base that would be allocated to livestock 

would be made up of grasses. A lesser amount of shrubs and 

forbs would be allocated, recognizing these plants will make up 

some of their diets.

During the development of Alternative VI (Proposed RMP), the 

BLM considered comments received from the public on the Draft 

RMP/EIS, the analysis of effects described in the Chapter 4, and 

available science to determine a level of forage allocation to 

livestock that would both provide the opportunity for livestock 

grazing and meet resource objectives.

Livestock 

Grazing

New unrealistic percentages have been implemented during 

the past decade based on the purported new science that has 

been published. When you read this new science however, you 

find that what it says is "consistent use of the resource, at 

levels of 50% to 60%, may begin to have an impact on the 

vigor of the forage." Therefore, it is difficult to understand, in 

light of the rest-rotation grazing systems that are in place, why 

we would lower utilization to levels of 25% to 40% (effectively 

12.5% to 20% in rest-rotation systems) and leave 80+% of the 

fuels on the ground. It would appear that percentages, such as 

those used on our private lands in the proposed Jarbidge 

Foothills Area of Critical Environmental Concern (40% to 50%) 

would be more effective. Especially, since the management of 

this area, by this plans own admission, has created a resource 

that needs to be preserved. In addition, the fact that this same 

area has remained resistant to major wildfires, over the past 10 

years, speaks volumes on the effectiveness of its management 

practices.

During the development of Alternative VI (Proposed RMP), the 

BLM considered comments received from the public on the Draft 

RMP/EIS, the analysis of effects described in the Chapter 4, and 

available science to determine a level of forage allocation to 

livestock that would both provide the opportunity for livestock 

grazing and meet resource objectives.

The Final EIS did not prescribe annual use criteria. Percentages 

prescribed in Chapter 2 of the Final EIS were specifically for 

allocation of forage and should not be interpreted as prescribed 

utilization levels. Annual use criteria would be determined during 

the permit renewal process allowing BLM to consider sitespecific resource conditions and management such as those 

presented in the comment.

Livestock 

Grazing

My second major concern stems from the Draft RMP/EIS’s 

apparent lack of an effective brush control program in the parts 

Management of livestock grazing is important for the success of 

vegetation treatments. Management actions in Alternative VI 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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of the resource area that remain in solid sage brush cover. Just 

as seas of waving grass may not be the best management of 

the resource or for wildlife, neither are solid oceans of brush. 

Break these areas up by mosaic open spaces, created by 

moderate prescribed burns or mechanical or chemical 

treatments of the brush. This type of management, while first 

reducing the areas susceptibility to major wildfires, also creates 

areas of new forbs and fine grasses for the sage-grouse while 

still providing them the edge effect and protection from the 

brush that they need. 

In conjunction with this brush control program, review the reestablishment of grazing protocols as well. More timely re-entry 

is going to be required if we want to prevent repetitive burns, 

and their denigration of the resource, before grazing is 

resumed.

(Proposed RMP) provide the necessary flexibility to coordinate 

cooperatively with permittees to plan for rest periods, as well as 

the timing of resumption of grazing following land treatments in 

order to meet resource objectives.

Livestock 

Grazing

The discussion of cumulative impacts related to livestock 

grazing at pp. 4-618 through 4-619 discusses alleged conflicts 

from proposed wind energy projects such as the China 

Mountain Wind Energy Project and livestock grazing. The 

narrative discusses a series of potential conflicts. Eliminate this 

discussion from the Final EIS because these potential conflicts 

are not reasonably foreseeable. As correctly noted in the 

narrative, the permanent infrastructure footprint of a 

commercial-scale wind energy project is small, consisting of 

several hundred acres. The project would permit livestock 

grazing to resume following construction and rehabilitation of 

the area, including rehabilitation of grasses and forbs that are 

palatable to livestock just as they were prior to construction. 

Limitations on movement of livestock, water conveyances, and 

possible fencing requirements are wholly speculative and 

unlikely to occur. Because these interferences are not 

reasonably foreseeable, this discussion should be altered or 

deleted.

The cumulative impacts of the China Mountain Wind Energy 

Project are reasonably foreseeable. Impacts from this proposed 

project cannot be limited to the project footprint but must include 

the entire zone of influence of the projects proposed actions. The 

cumulative impacts zone of this particular wind energy project is 

much larger than was analyzed in the Draft RMP/EIS and has 

been adjusted in the Final EIS to more accurately represent the 

potential effects. In addition to the proposed China Mountain 

Wind Energy Project, the expanded cumulative impact analysis 

in the Final EIS included wind energy projects planned and being 

constructed on adjoining public, private, and State lands. The 

effects of each energy project, as with all other activities within 

the analysis area, were analyzed for their effects on livestock 

grazing.

Livestock 

Grazing

Current fences are needed for livestock management to control 

livestock and keep them within defined areas. Fences are also 

needed to use specific areas at specific times to target grazing 

use to stimulate plant growth and harvest plant forage. Future 

fences both permanent and temporary are needed to control 

The Final EIS analyzed management actions that allow for 

existing and new infrastructure if compatible with meeting 

resource objectives. The Final EIS, Chapter 4, analyzed at the 

planning area scale the direct and indirect effects as well as 

cumulative impacts of removing existing or restricting the 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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livestock to meet desired grazing conditions.

Corrals have been put in place to work livestock. Removing 

corrals would result in the need for alternate working facilities.

Incorporate future pipelines and troughs to improve livestock 

distribution and to improve more uniform use of forage.

installation of new infrastructure. The effects of altering or 

removing specific infrastructure, new or existing would be 

considered in site-specific analysis.

Livestock 

Grazing

The RMP should contain the following considerations for 

grazing utilization:

Issue Temporary Non-renewable Authorization where excess 

forage is available.

Allocate 40/50% native, 50/60% nonnative, 70/80% annual 

grass and 12/16% shrub and forbs production to livestock.

Allocations would not be a means or determination of allowed 

utilization.

No date restriction on livestock grazing on winter range.

The Final EIS analyzed a range of different allocations and 

management actions for domestic livestock, including the use of 

Temporary Non-Renewable permits. Alternative VI (Proposed 

RMP) considered public comments, analysis in the Draft 

RMP/EIS, and current science to select allocations and 

management actions that would allow for resource uses while 

meeting resource objectives.

Livestock 

Grazing

BLM fails to mitigate (reference 40 CFR 1508.20) the 

continued imminent fire danger through at least domestic 

livestock use, as well as to assess the cumulative impact of 

such fire danger.

The regulation at 40 CFR 1508.20 refers to mitigation of a BLM 

authorized action. Wildfire is not an authorized action so cannot 

be mitigated within this context. However, the alternatives in the 

Final EIS, including Alternative VI (the Proposed RMP), include 

objectives for upland vegetation and fuels to manage vegetation

to restore the resiliency of the ecosystem structure and function 

and to manage vegetation communities to maintain or restore 

their fire regimes. These goals will guide future management that 

helps to reduce the risk of catastrophic fire. The Final EIS 

analyzed targeted grazing within the range of alternatives.

Livestock 

Grazing

The description of the affected environment 

omits/misrepresents certain details. There is significant underutilization on several of our allotments including, but not limited 

to, Grassy Hills AMP, East and West Deadwood Trap, South 

Deadwood, and Horse Butte. This is causing imminent fire 

danger, subjecting other resources, including our grazing use, 

to significant harm. The Final EIS should allocate more animal 

unit months to deal with this severe underutilization and underallocation.

The Final EIS revised the affected environment chapter to 

provide additional background information regarding current and 

historical stocking rates and 10-year average Temporary NonRenewable permits. Though there is no discussion of underutilization, this history does give an indication of forage 

production within the planning area.

The Final EIS considered a wide range of allocations and 

management actions for livestock grazing, upland vegetation,

and wildfire management. When developing Alternative VI 

(Proposed RMP), the BLM considered comments received from 

the public on the Draft RMP/EIS, the analysis of effects 

described in the Chapter 4, and available science to determine a 
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level of forage allocation to livestock that would both provide the 

opportunity for livestock grazing and also provide the tools and 

flexibility necessary to improve management of wildfire. 

Livestock 

Grazing

On p. 2-140 of the Draft RMP/EIS, LG-IV-MA-2 establishes 

reserve common allotments. The management action states 

that “... in allotments where permits are relinquished, sold, or 

cancelled”. It is unclear what this means. If it means that the 

BLM/Third parties implement a permit buyout system, we 

oppose that except to the extent fully coordinated as part of the 

Owyhee Initiative process.

Management actions providing for the creation of reserve 

common allotments did not introduce or promote any permit 

buyout or retirement proposal. The statements "relinquished, 

sold, or cancelled" refers to the voluntary action of current 

permittees, or in the case a permit is cancelled due to noncompliance with existing terms and conditions.

Livestock 

Grazing

Any closure to grazing in excess of 100,000 acres must be 

duly reported in accordance with 43 U.S.C. 1712(e) (2), and 

failure to complete such reporting would violate such section. 

See also 43 CFR 1610.6.

As noted in the BLM's planning regulations (43 CFR 1610.6), if 

BLM decided to eliminate one or more principal or major uses 

with respect to a tract of 100,000 acres or more, it shall be 

reported by the Secretary to Congress prior to implementation.

Livestock 

Grazing

The Draft RMP/EIS errors in establishing Area of Critical 

Environmental Concerns (ACEC) and in establishing additional

no grazing reference areas (which may include some of the 

ACEC), and in establishing additional seasonal no grazing 

areas (as to deer winter range and bighorn sheep), which 

includes a related closure to grazing in Alternative IV as to 

113,000 to 145,000 acres and in Alternative V as to 309,000 

acres. 

Any closure to grazing, whether via an ACEC or reference 

area, would prevent us from using and otherwise accessing 

our stock water rights therein. 

The Draft RMP/EIS did not establish Areas of Critical 

Environmental Concern (ACECs); the Draft RMP/EIS identified 

and analyzed areas that are being considered for ACEC 

designation. Grazing closures preventing access to stock water 

rights have no effect on the continued use of the quantity of 

water described under the water rights listed above, because the 

source of water for each of the water rights is Pence Spring, 

which is located on private land owned by the holder of the water 

rights. Therefore, the holder of the water rights can put the water 

source over which he has ownership and control to some other 

use.

In addition, the existence of stock water rights on Federal lands 

does not confer an attendant right to graze on Federal lands in 

order to use the stock water rights. Joyce Livestock Co. v. US, 

144 Idaho 1, 19-20, 156 P3d 502 (2007). Therefore, while the 

ability to use water rights on Federal lands may be of concern to 

the holder of those rights, that concern does not need to drive 

the BLM’s land allocation decisions.

Livestock 

Grazing

Any closure to grazing, whether via an Area of Critical 

Environmental Concern or reference area, would occur in 

violation of 43 U.S.C. 1752(g). We have various range 

improvement permits and cooperative agreements within the 

intended closure areas. The Draft RMP/EIS fails to ensure 

compensation for such range improvements.

Federal regulations allow cancellation of permits for a wide 

range of reasons, including devotion to other public purposes, for 

example an Area of Critical Environmental Concern. However, if 

the BLM does choose to cancel a permit, both Federal law (43 

U.S.C. 1752(g)) and BLM’s regulations (43 CFR 4120.3-6 (c)) 

require reasonable compensation to permittees for the loss of 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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value to authorized permanent range improvements.

Livestock 

Grazing

Any closure to grazing, whether via an Area of Critical 

Environmental Concern or reference area, would effectively 

nullify our Idaho State Grazing Leases and otherwise impair 

the Idaho State Endowment Lands. We have various State 

Grazing Leases within the intended closure areas. 

The Final EIS identified the effects of alternatives on private and 

State lands in the cumulative impacts analysis for each resource 

and resource use.

Livestock 

Grazing

Any Final EIS should protect the pre-existing rights and 

practices within the newly designated Wilderness areas.

Grandfather our current livestock grazing practices, including 

both numbers and season of use, are historic, as well as 

ordinary and customary practices, into any continued and 

future use within the Poison Butte Allotment. In addition, any 

changes should conform to the direction of the Owyhee 

Wilderness Board.

Continued and future uses, including grazing, will be considered 

and analyzed on an allotment specific basis after the signing of a 

Record of Decision. Implementation of any management actions 

within the Bruneau-Jarbidge Rivers Wilderness will be consistent 

with the Owyhee Public Lands Management Act of 2009, 

including historic uses and practices related to livestock grazing 

and the applicable wilderness plan. 

Livestock 

Grazing

The Draft RMP/EIS should ensure fairness and equity in 

allocating animal unit months (AUMs) between wild horses and 

livestock. For too long there has been a lopsided distribution of 

AUMs in favor of the latter. This disproportionate allocation 

shows up in the Draft RMP/EIS wherein, depending on the 

alternative, livestock are awarded 20 to 50 times the 

percentage of perennial grasses assigned to wild horses. The 

1987 RMP gives 200,000 AUMs to cattle and 600 to wild 

horses. To begin to rectify the imbalance, AUMs in active 

status but not being used by livestock should be converted to 

wild horse AUMs, and the Appropriate Management Level 

should be increased accordingly. 

The Final EIS analyzed a range of allocations for the wild horse 

Appropriate Management Level. The Federal Land Policy and 

Management Act of 1976 directs the BLM to manage public 

lands under the principles of multiple use and sustained yield. 

Managing use by cattle and sheep, together with wildlife and wild 

horses and burros, and a host of other uses is part of BLM’s 

multiple-use mission. The regulations at 43 CFR 4710.3-2 

indicated that Herd Management Areas might be designated to 

be managed principally, but not necessarily exclusively, for wild 

horse or burro herds. 

Livestock 

Grazing

In addition to the economic impacts, grazing reduction has 

many other negative, if unintended, consequences. Grazing 

can and should continue to be used as a management tool to 

reduce the risk of fires, control invasive weeds, and ensure 

active management of the resource. The multiple-use plan 

includes provisions to allow this to happen. For instance, the 

multiple-use plan focuses on grazing at or near historic use for 

the reduction of fine fuels to lessen the intensity of fire. 

Resource managers would have the ability to control fuel loads 

with the grazing levels and targets in this multiple-use plan. 

There are several scientifically viable mechanisms and 

management to modify fuel loads with grazing. Grazing as 

described in this multiple-use plan also reduces biomass and 

The range of alternatives of the Final EIS included a variety of 

grazing allocations and management tools to address vegetation 

resource objectives. Alternative VI (Proposed RMP) included an 

increase in forage allocation to livestock which is in part reflected 

by the inclusion of annual grass to aid in managing fine fuels. 

Additional actions proposed in the Upland Vegetation and 

Wildland Fire Ecology and Management sections of Alternative 

VI allow for a wide array of options to manage fine fuel loading, 

including fuel breaks and targeted grazing.
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Category Comment Response

fuel loads and the continuity of fuels.

Livestock 

Grazing

Appendix K: Idaho Standards for Rangeland Health and 

Guidelines for Livestock Grazing Management should include 

the Guidelines section, which is part of the "Idaho Standards 

for Rangeland Health and Guidelines for Livestock Grazing 

Management" document.

The Final EIS removed Appendix K: Idaho Standards for 

Rangeland Health and Guidelines for Livestock Grazing 

Management. As stated, Appendix K in the Draft RMP/EIS only 

included a summary of the standards. The Idaho Standards for 

Rangeland Health and Guidelines for Livestock Grazing 

Management are readily available and can be accessed at 

http://www.blm.gov/id/st/en/prog/grazing/Range-HealthStds.html.

Livestock 

Grazing

The BLM should consider implementing different amounts of 

grazing utilization that may be above current levels, if needed 

to reduce fuels at the landscape level, while continuing to 

maintain and enhance sage-grouse habitat.

BLM should allow flexibility to manage permits, allotments and 

pastures, to reduce fuels while continuing to maintain or 

enhance sage-grouse habitat; management could include rest 

periods, stocking rates, season of use, etc.

Utilization levels are an annual indicator used for monitoring the 

effectiveness of implementation of management actions in 

meeting resource objectives. Annual indicators will be 

determined on a site-specific basis during permit renewal and 

will take into consideration resource objectives including 

vegetation, wildlife habitat, and fuels management. Alternative VI 

(Proposed RMP) allocations and management actions that 

would flexibility to implement actions suggested in the comment. 

These actions would all be available for consideration during the 

livestock grazing permit renewal process after the signing of a 

Record of Decision.

Livestock 

Grazing

The Resource Advisory Council unanimously supports the use 

of LG-IV-MA-5 with a change in the order of priority. Move, 

Permittees- Lessees whose normally permitted allotments are 

under an approved vegetation treatment program to the top of 

the priority list.

The rearrangement of priorities would help encourage the 

participation of cooperating permit holders in vegetation 

treatment programs.

The Final EIS incorporated this suggestion as part of Alternative 

VI (Proposed RMP), see LG-VI-MA-4.

Livestock 

Grazing

A majority of the Resource Advisory Council supports the use 

of LG-II-A-3 over the use of LG-IV-A-3 with a minority 

disagreeing.

Temporary Non-renewable Authorizations (TNR) is a means of 

reducing fine fuels in years of above normal precipitation or 

forage growth. To restrict the use of TNR will limit the ability of 

BLM to make appropriate animal unit month adjustments or 

target areas where fuel loads may be excessive. 

The Final EIS analyzed a range of alternatives concerning the 

use of Temporary Non-Renewable (TNR) permits. Alternative VI 

(Proposed RMP) increased the amount of the planning area 

available for TNR, but maintained the same criteria for issuing 

TNR as described in the Draft RMP/EIS for Alternatives I through 

IV.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

The preferred alternative takes the planning area right back to 

a decision that resulted in litigation in the late 1990's. The use 

of TNR was restricted to non-native perennials. Permittees, 

because of this decision, started to use their native pastures 

first, saving the non-native pastures for TNR use. As the 

grazing season begins March 1, this concentrates livestock use 

on native range in the early spring versus on the non-native 

range that is better suited for early spring grazing.

Livestock 

Grazing

A majority of the Resource Advisory Council supports replacing 

LG-IV-MA-12 with LG-II-MA-11 with a minority disagreeing.

To specifically exclude some pastures from livestock winter 

use would make many of the current management systems 

infeasible. Even within individual allotments not all of the big 

game wintering habitat is occupied by livestock at any one 

point in time, when occupancy is spread across numerous 

allotments there is adequate acreage without the presence of 

livestock and in many cases there is a full season of growth for 

wildlife needs as the grazing plan in place has deferred use in 

that pasture. 

The big game wintering area as marked on Map 19 needs 

further refining. Some areas have undergone a questionable 

expansion (higher elevations) while other areas have been 

neglected, (Diamond A Desert, northern end of the planning 

area, Roseworth Point). Some of the most beneficial use of 

native range can occur during the dormant season. Adoption of 

LG-IV-MA-12 may lead to increased use of native range during 

the spring months, as these pastures are unavailable other 

times of the year. Spring use of native pastures can have 

adverse impacts.

The Final EIS analyzed a range of alternatives for livestock 

grazing management. Alternative VI (Proposed RMP) did not 

include LG-IV-MA-12. Management actions such as LG-CA-MA4, LG-CA-MA-8, LG-VI-MA-2, LG-VI-MA-8, and LG-VI-MA-9 can 

achieve resource objectives at the allotment scale.

Livestock 

Grazing

We recommend the Final EIS include clarifying information 

related to livestock grazing. To prioritize the utilization of high 

resource, low conflict lands we recommend the Final EIS 

include a process for permit relinquishment. Consider 

replicating the approach adopted by the BLM Prineville District 

in the Upper Deschutes Resource Management Plan and Final 

EIS.

The current BLM Grazing Regulations provide permittees the 

option to relinquish permits if they desire. If a permit is 

relinquished, the BLM can then consider whether to make the 

allotment and/or animal unit months available to other qualified 

applicants. Alternative VI (Proposed RMP) provided the

additional option to retain a relinquished allotment as a reserve 

common allotment to facilitate restoration efforts and 

rehabilitation following wildfire.
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BLM reviewed the Upper Deschutes RMP and contacted 

Prineville District staff regarding their relinquishment process.

Their resource area has to balance grazing with competing high 

recreational values and urban interface. The process described 

in the Upper Deschutes RMP for classifying allotment status is 

specific to their situation. The Jarbidge Field Office does not 

share the same level of conflict between livestock grazing, 

recreational use and urban interface. Where conflicts do occur 

they are localized and seasonal. Management actions in the 

Final EIS, such as TR-CA-MA-2 and TR-VI-MA-6, provide 

direction to mitigate conflicts between authorized grazing and 

other resources uses. 

Livestock 

Grazing

To protect relevant planning area resources, we recommend 

the Final EIS consider the environmental benefits of timing 

restrictions for the grazing of cattle.

The Final EIS included management actions specifically 

addressing the timing and seasons-of-use of livestock grazing to 

achieve resource objectives (e.g. SS-CA-MA-16, LG-CA-MA-3).

Livestock 

Grazing

To analyze the impacts of reserve common allotments on 

water resources, we recommend the Final EIS include 

additional information. Stating that reserve common allotments 

will follow the Aquatic and Riparian Management Strategy 

does not sufficiently disclose the impacts of utilizing reserve 

common allotments (see Draft RMP/EIS. p. 4-105).

The Final EIS analyzed the creation of reserve common 

allotments to facilitate vegetation treatments and increase 

flexibility for livestock grazing; however, the location of reserve 

common allotments was not identified. Because the location of 

reserve common allotments is not known at this time, a detailed 

analysis of impacts to water resources could not be completed. 

When a reserve common allotment is created, an allotment 

management plan would be developed to ensure maintenance 

or achievement of resource objectives. This would include 

following the direction in the Aquatic and Riparian Management 

Strategy (Appendix D) which requires maintaining or improving 

instream habitat, riparian habitat, and water quality for water 

quality impaired streams. The Final EIS included this 

management direction in Alternative VI (Proposed RMP).

Livestock 

Grazing

We recommend the Final EIS include clarifying information with 

regard to the following impact from Temporary Non-renewable 

Authorizations (TNR), "Issuing TNR late in the grazing season 

would pose an increased risk to water quality where reduced 

condition is related to livestock grazing." (p. 4-104). We are 

unsure if this impact is indeed specific to TNRs. If this impact 

or others are indeed specific to TNRs (relative to other grazing 

allotments), we recommend that the Final EIS TNRs be 

designed in such a way that increased risks to water quality (or 

management action LG-VI-MA-7 in Alternative VI (Proposed 

RMP) describes Temporary Non-Renewable (TNR) permit

consideration criteria, one of which requires issuing TNR 

consistent with resource objectives. If monitoring data 

demonstrated additional forage to be available, project specific 

(application for TNR) analysis would be performed to determine 

how authorizing use of that forage would affect resources and 

resource uses.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

other resources) are eliminated. It also appears that the Draft 

RMP/EIS allows for TNR in riparian areas. 

Livestock 

Grazing

The Draft RMP/EIS (p. 3-7) states: “Accelerated erosion 

exhibited by plant pedestals were documented during Idaho 

Standards for Rangeland Health and Guidelines for Livestock 

Grazing Management assessments.”

However, this statement is misleading, erroneous, and 

incomplete. It is misleading because it implies that accelerated 

erosion as exhibited by plant pedestals was a universal finding 

of all of the standards and guidelines assessments. It is also 

erroneous because it fails to report the fact that BLM 

represented to Judge Williams, during a tour of the area, that 

the ungrazed Murphy Hot Springs Airport would not have met 

the standards that BLM applied in its assessment of grazed 

rangelands (because the pedestalling was a natural 

phenomenon of frost heaving or for other reasons). It is 

incomplete because it fails to report that, notwithstanding the 

belated revelations to Judge Williams, BLM and/or the 

permittees nevertheless undertook changes to grazing 

authorizations subsequent to the standards and guidelines 

assessments. Therefore, the grazing authorized prior to the 

assessment findings is not the same as the current situation. 

See also the “02/29/09 AMS/RMP Supplemental Comments” 

submitted to BLM by Intermountain Range Consultants, 

particularly as concerns “Ground Cover for 13 Allotments”. In 

addition, we submit Exhibit 2, “Ground Cover for 23 

Allotments”, which relates to what are commonly termed the 

Stipulated Settlement Agreement Allotments (less data related 

to Browns Gulch, which is now managed under the auspices of 

a different RMP). Exhibit 2 documents that, relative to these 23 

allotments (as was the case for the previously documented 13 

allotments), ground cover is appropriate for the ecological site 

potential in each of the allotments.

Details of this comment and shared data are beyond the scope 

of this planning effort. BLM will consider this comment while 

performing Rangeland Health Assessments for specific 

allotments. 

Livestock 

Grazing

It is not necessary for BLM to disturb the ground at all by 

ripping up a pipeline. BLM could just remove and recycle the 

troughs, plug the pipe, and leave it buried. This is illustrative of 

how BLM arbitrarily seizes on any possible excuse to scuttle 

any meaningful change, without any science-based or common 

Consideration of range infrastructure removal will be determined 

on a site-specific basis. However, in order to remove and recycle 

a trough and plug a pipeline, it would be necessary to use heavy 

equipment, which would result in some ground disturbance.
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sense rationale.

Livestock 

Grazing

We know of no other landscape that is so tragically 

industrialized for the sole benefit of livestock. See Jarbidge 

Analysis of the Management Situation from 2007, the RMP's 

Water Development Map, Roading Map, and Map of Remnant 

sagebrush habitats. Much of the planning area is within 1 mile 

of water. Removal of half, two thirds or more of these water 

developments, including through expanding pastures and 

removal of fencing would assist in getting rid of some of the 

ecological blight, habitat fragmentation, and degradation 

caused by water developments. Cattle in flat landscapes are 

readily able to travel 2 miles from water sources. Ranchers 

have horses, and can work to herd livestock. Consider this in 

all grazing alternatives.

The Final EIS analyzed a range of infrastructure necessary for 

livestock, including reductions in existing systems. The Final EIS 

analyzed the effects of the removal or relocation of infrastructure 

documented to be contributing to not meeting resource 

objectives.

Livestock 

Grazing

The Draft RMP/EIS does not provide mandatory measurable 

use standards and other actions needed to comply with the 

fundamentals of rangeland health requirements. Specify how 

the Draft RMP/EIS should apply monitoring results.

The Final EIS contained a management action common to all 

action alternatives (LG-CA-MA-1) which provides direction for 

identifying grazing use indicators to monitor the effectiveness of 

implementation of the plan. Coupled with long-term monitoring, 

the annual use indicators will help determine if resource and 

special designation objectives are being achieved. 

Livestock 

Grazing

There is no schedule for standards and guidelines analysis and 

re-analysis. BLM needs a schedule for compliance with the 

Idaho Standards for Rangeland Health and Guidelines for 

Livestock Grazing Management. Even though the Stipulated 

Settlement Agreement requires new permits within 3 years, 

BLM never met the schedule for the Draft RMP/EIS, and will 

likely fail to meet the permit renewal schedule. Prioritize 

actions based on the importance of habitats in affected lands 

for rare and imperiled species like sage-grouse. Schedule 

standards and guidelines for re-assessment, as well.

BLM generally performs standards and guidelines assessments 

once during the 10-year permit cycle unless a specific event or 

monitoring indicates an assessment of conditions is warranted. 

Rangeland health assessments will be performed on allotments 

during the permit renewal process that will follow the signing of 

the Record of Decision (ROD). Scheduling of permit renewals 

following the ROD will consider findings in rangeland health 

assessments and resources such as special status species.

Livestock 

Grazing

BLM must analyze a range of alternatives that rely on 6 inches 

stubble height, analyzing 5% and 10% annual bank trampling 

requirements, and less than 10% woody browse. Livestock use 

reaching any of these levels must serve as a trigger for their 

removal from the pasture.

Specific standards or use indicators for livestock grazing will be 

determined during permit renewal process and will be based on 

site specific data, standards and guidelines assessments, 

analysis performed under NEPA, and consultation with the US 

Fish and Wildlife Service if Endanger Species Act listed species 

or their habitat are affected. 

Livestock 

Grazing

BLM is so paralyzed and unable to control grazing impacts 

caused by politically powerful permittees that it even refuses 

under Alternative IV to prevent destructive sediment producing 

The Final EIS analyzed broad goals and objectives to guide 

future management in the planning area. Decisions whether to 

allow livestock trailing events are site-specific implementation 
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cattle trailing and hill slope erosion caused by Brackett trailing 

across the East Fork Jarbidge River through bull trout critical 

habitat, redband trout habitat, and a campground/recreation 

site. There is a road and bridge that the cattle could use for a 

crossing. Significant loss of the unstable, cattle-trampled banks 

apparently will continue for the next 20 years. Yet a specific 

Alternative IV management action allows this herding to occur 

for the next 20 years.

decisions that are not included at this planning level.

Livestock 

Grazing

Affected animal populations on the National Forest are interconnected and shared with BLM lands. BLM must examine the 

impacts and use levels of Forest grazing, livestock facilities 

such as the many pipelines, fence densities in grazed 

sagebrush lands, fire effects, inter-connected roads and use, 

and other activities. It must address all direct, indirect, and 

cumulative impacts.

Analyses of direct and indirect effects in the Final EIS were 

limited to actions proposed in the Final EIS. Analyses of 

cumulative impacts of reasonable and foreseeable actions were 

limited to the boundaries described within each section. In some 

cases, impacts extended into US Forest Service-managed lands, 

and were therefore included in the cumulative impacts analysis.

Livestock 

Grazing

The Draft RMP/EIS (p. 2-139), Alternative IV, allocates forage 

in broad and unspecific ways under no clear method, as 

discussed below. LG-IV-A-2 allocates 75% to 85% native 

perennial grass to watershed and wildlife and 70 to 80% nonnative perennial grass to watershed and wildlife. In having a 

broad range, BLM is maximizing uncertainty and enabling a 

certain outcome and relentless conflict.

Setting the allocation of forage to livestock at one value across 

the planning area would limit the flexibility to consider sitespecific livestock management actions necessary to meet 

resource objectives. Providing for a range in which to allocate 

forage would allow allocation at lower rates in allotments where 

sensitive resources exist or rangeland conditions need 

improvement.

Livestock 

Grazing

BLM cannot allow spring grazing due to severe conflicts with 

nesting sage-grouse, pygmy rabbits with kits in shallow natal 

burrows, nesting migratory birds, and other concerns. Where 

does the Draft RMP/EIS consider this? Spring grazing also 

poses severe threats to the health of native plants, and results 

in the depletion of native species in understories. Won't 

removal of spring grazing reduce livestock stocking by 25% or 

more?

The Final EIS analyzed effects of seasons-of-use, including 

limitations of spring use, on resources in each relative resource 

section. At the planning level, eliminating all spring livestock 

grazing may or may not achieve resource objectives. Analysis 

during the permit renewal process will consider the specific 

resources contained in individual allotments in determining the 

appropriate seasons-of-use and stocking levels. 

Livestock 

Grazing

BLM will not be able to achieve its allocation of vegetation 

production unless it incorporates all of the necessary 

information into determining carrying capacity and suitability. 

BLM's table doesn't take into account the range of actions 

needed to provide for sage-grouse: habitat security, space, 

timing, removal of harmful fences/water developments, etc.

The Final EIS included allocations and management actions that 

provided the direction and framework to determine allotmentspecific allocations and management. The purpose of a range of 

allocation percentages is to provide the necessary flexibility to 

address specific biological needs for sage-grouse, plants, soils, 

and other wildlife species. Additionally, multiple management 

actions in Alternative VI (Proposed RMP) are designed to meet 

specific habitat and life cycle needs for various plants and 

animals (e.g., SS-CA-MA-11, SS-CA-MA-16). The permit 
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renewal processes would consider specific habitat requirements.

Livestock 

Grazing

Under these simplistic forage-based analyses, will there be 

double, triple livestock numbers in the fall if spring and winter 

grazing are limited? If so, how will this impact resource?

The Final EIS did not analyze management prescriptions of this 

detail. The permit renewal analysis will address these issues in 

project level detail. 

Livestock 

Grazing

The Management Common to All Alternatives section (pp. 2-

125 to 2-126) contains many harmful provisions: The Draft 

RMP/EIS fails to require any measurable standards of use. 

There is no adequate framework for applying any scientifically 

defensible adaptive management. Incorporate specific triggers, 

sideboards, and required actions. Ranchers will claim riparian 

trampling, conservative levels of upland use that provide 9 

inches of nesting cover, and other controls on livestock use are 

"not feasible" and under the Draft RMP/EIS BLM is not 

required to apply this. Under all alternatives, all of the above 

must be mandatory, measurable and based on current 

ecological science. Prescribe specific actions BLM would take 

if standards were not met.

The Draft RMP/EIS also says allotment-specific decisions will 

apply "grazing use indicators and grazing use criteria" but does 

not specify these. There is no certainty that any proper criteria 

will be applied and will be required to be met.

The Final EIS provided the framework for development of 

specific management of all authorized uses. For livestock 

grazing, the permit renewal process would provide management 

specifics. The presence of special status species and results of 

rangeland health assessments will help determine the 

appropriate site-specific resource objectives and the appropriate 

indicators and use criteria to help achieve and or maintain those 

objectives.

Livestock 

Grazing

There is no evidence that grazing in spring on shrubs improves 

browse. In the "common to all alternatives” section, mule deer 

appear to be given more importance than sage-grouse. 

The intent of spring grazing on big game winter range is to 

promote the recruitment of desirable shrubs by reducing grass 

competition and improving forage quality. There are several 

articles in peer-reviewed literature supporting the management 

of livestock grazing to reduce grass competition and promote 

establishment of browse (Austin and Urness, 1998; Austin 

2000). Improving the nutritional quality of forage has also been 

reported (Anderson and Scherzinger, 1975; Alpe et al., 1999). 

Browsing also can increase the growth of individual bitterbrush 

plants (Ganskopp et al., 2004b). The Final EIS revised some 

common to all management actions to remove the confusion on 

priority species. 

Livestock 

Grazing

There is no limitation on salting and the thousands of 

supplement feeding sites that are accelerating habitat declines 

and weed invasions. Nothing here guarantees removal of a 

single livestock facility.

The Final EIS provided for range infrastructure to be evaluated in 

site-specific project proposals in regards to its effectiveness in 

achieving resource objectives. Evaluations would occur during 

the standards and guidelines assessments and permit renewal 
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process. Project level NEPA would analyze use and locations of 

salting and supplement sites during the permit renewal process.

Livestock 

Grazing

In Alternative III under Fuels, BLM would modify pasture and 

allotment boundaries to concentrate livestock for fuels 

reductions - i.e. inflict extreme grazing disturbance that will 

promote flammable weeds and contribute to a further 

downward spiral and ecosystem unraveling in the planning 

area. Yet BLM staff told us that it relied on existing fence lines 

in its slickspot peppergrass proposals. So altering fences for a 

threatened plant species is given lower priority than 

accommodating cattle for fuels projects that are likely to result 

in even worse cheatgrass and flammable weed problems.

Each alternative analyzed in the Final EIS gives Threatened, 

Endangered, and other special status species a higher priority 

and first consideration over all resource uses, including livestock 

grazing. LG-VI-MA-1 in Alternative VI (Proposed RMP) would 

allow modification of existing fences to manage fuel and improve 

the success of meeting objectives in the Wildland Fire Ecology 

and Management, Special Status Species, and Upland 

Vegetation sections. Specific actions to achieve objectives would 

be determined and analyzed at the project level. Any alteration 

or relocation of existing infrastructure would be to improve 

livestock grazing practices in order to meet resource objectives.

Livestock 

Grazing

BLM has allocated vegetation without any reasoned 

consideration of impacts to soils and microbiotic crusts, and a 

specified plan and actions needed for maintenance and 

recovery. BLM has not shown that lands can recover when 

faced with continued grazing use in the face of cheatgrass and 

other weed expansion, or that restoration can be successful 

with high stocking rates. BLM must demonstrate this to ensure 

conservation of sage-grouse, bull trout watersheds, redband 

trout watersheds, and other critical habitats and populations. 

There is no science-based analysis supporting the allocation 

acreage numbers.

The Final EIS considered and analyzed the effects of a 

reasonable range of alternatives to establish and achieve 

resource objectives. 

During the development of Alternative VI (Proposed RMP), BLM 

considered comments received from the public on the Draft 

RMP/EIS, the analysis of effects described in Chapter 4, and 

available science to determine a level of forage allocation to 

livestock that would both provide the opportunity for livestock 

grazing and meet resource objectives.

Livestock 

Grazing

BLM provides a different allocation level for exotic species but 

fails to clarify if these levels will apply to entire pastures. Will 

this be based on a certain percentage of the pasture being 

exotics, or what basis will be used for determining non-native 

vs. native pasture? Or is BLM even planning to split use within 

the already tiny pastures? Protect all sagebrush and 

restoration habitats including smaller areas.

The dominant Vegetation Sub-Group within a pasture would be 

an important factor in determining allocation of forage and 

management of livestock. Specific resources (e.g., sage-grouse)

will also be important in governing management of the pasture 

(e.g., season-of-use, length of grazing periods, and annual use 

criteria). If a pasture contains sage-grouse nesting habitat, 

season-of-use and use criteria would be considered in regards to 

meeting sage-grouse nesting habitat requirements.

Livestock 

Grazing

It's hard to understand how 100% of annual grass production 

could be allocated to watershed and wildlife - yet BLM claims it 

will be doing grazing to reduce fuels. Moreover, how does BLM 

plan to keep cows and sheep from eating forbs?

BLM claims it would do this all during the permit allocation 

process. However, the way it would be done must be specified 

in detail and with clarity here.

The Final EIS analyzed a range of annual grass allocation of 

which only Alternatives IV and V allocated 100% of annual grass 

production to watershed and wildlife. Alternative VI (Proposed 

RMP) allocated 50% to 60% to watershed and wildlife and 40% 

to 50% to livestock. 

Although there is no single way to ensure livestock only forage 
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on certain types or species of plants, diets can be influence or 

managed. For example, cattle are generalists in diet selection 

and will consume grasses, forbs, and shrubs in varying 

proportions throughout the year. Cattle will prefer herbaceous 

plants (grasses and forbs) but as these plants mature and 

become less palatable as the growing season progresses their 

diets will start to include more shrubs because they remain more 

palatable later into the season. This diet switch becomes even 

more pronounced as utilization of the herbaceous component 

becomes higher. Recognizing this dietary tendency, utilization of 

different parts of the plant community can be managed with 

seasons-of-use and utilization levels.

Livestock 

Grazing

BLM allocates 100% of shrub and forb production to wildlife 

and watershed, yet cows consume significant amounts of 

shrubs as well as forbs in the planning area. How will BLM 

prevent cattle from consuming forbs and shrubs other than by 

removing livestock entirely?

The Final EIS analyzed a range of shrub and forb allocation; only 

Alternatives IV and V allocated 100% of shrub and forb 

production to watershed and wildlife. Alternative VI (Proposed 

RMP) allocated 86% to 89% of shrub and forb production to 

watershed and wildlife. 

Although there is no single way to ensure livestock only forage 

on certain types or species of plants, diets can be influence or 

managed. For example, cattle are generalists in diet selection 

and will consume grasses, forbs, and shrubs in varying 

proportions throughout the year. Cattle will prefer herbaceous 

plants (grasses and forbs) but as these plants mature and 

become less palatable as the growing season progresses their 

diets will start to include more shrubs because they remain more 

palatable later into the season. This diet switch becomes even 

more pronounced as utilization of the herbaceous component of 

a plant community becomes higher. Recognizing this dietary 

tendency, utilization of different parts of the plant community can 

be managed with seasons-of-use and utilization levels.

Livestock 

Grazing

Page 2-139 of the Draft RMP/EIS shows that BLM is never 

even planning to reduce animal unit months (AUMs) in 

association with restoration, or for conservation of sage-grouse 

and other values of the public lands. LG-IV-A-3 "forage 

available for livestock use would likely change as the RMP is 

implemented, although allocation percentages would remain 

the same". The Draft RMP/EIS punts to changes in AUMs in 

the future that would be determined after adequate monitoring 

Table 4-282 in the Draft RMP/EIS presented and analyzed 

estimates of animal unit months (AUMs) that would be available 

to livestock grazing at initial implementation and at full 

implementation of the plan. Allocations of forage ranged from 

two fold increases to reductions of 78%. For example, in 

Alternative IVA the initial allocation would result in a 22-50% 

reduction, Alternative, IVB a 20-49% reduction, and Alternative V 

a 51-75% reduction from the No Action Alternative. Adjustments 
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and site-specific NEPA analysis through future permit renewal 

processes. It also appears that the AUM cuts seen in Table 4-

282 would only occur if vegetation treatments were conducted. 

If there is no money for vegetation treatments, will there be no 

cuts? Where in the Draft RMP/EIS are stocking rate reductions 

specified if no or limited restoration occurs?

to current allocations would be a function of the reduced area 

available to livestock grazing and the reduced percentages of 

vegetation allocated to livestock. As the vegetation treatments 

prescribed for each alternative were implemented over the life of 

the plan, additional reductions could occur in area where 

vegetation was converted from non-native to native species. 

Following the Record of Decision, an evaluation of each 

allotment would occur and AUMs allocated to permits within the 

range of percentages described in the approved RMP. The 

reason for describing a range (i.e., 25-40% of native perennial 

grasses) is to provide the flexibility to consider site-specific 

resources. Areas that have resources, such as sage-grouse 

nesting, may be allocated at the lower range in order to provide 

for habitat characteristics for successful nesting. In contrast, 

other areas may be allocated at the upper end of the allocation 

range. As vegetation treatments are implemented over the life of 

the RMP, or successional changes in vegetation communities 

occur that result in changes in production, permits would be 

adjusted. Additionally, if vegetation treatments or successional 

change creates suitable habitat that is then occupied by a 

species such as sage-grouse, changes could be made to 

permits to ensure habitat requirement are maintained. For 

example, as sagebrush reoccupies burned areas and begin to 

provide suitable habitat for sage-grouse, allocations may be reevaluated to determine if adjustments are necessary to meet 

seasonal habitat requirements for the bird. 

Livestock 

Grazing

Under LG-IV-MA-l "Utilization would be determined on a case 

by case basis" to meet Riparian, Fish and Wildlife, and other 

Objectives. Since these other objectives are highly uncertain 

and unclear, it is impossible to understand what levels would 

be applied.

The Final EIS did not specify indicators and use criteria. 

Indicators would be determined during the permit renewal 

process considering site-specific information, including 

rangeland health assessment and other inventories and 

monitoring data that would help achieve resource objectives.

Livestock 

Grazing

LG-IV-MA-2 refers to reserve common allotments. Instead of 

retiring livestock grazing permits so any sound investment in 

habitat and restoration can occur, BLM would sacrifice lands to 

continue grazing abuse (p. 2-140). The Draft RMP/EIS even 

allows this harmful practice in intact native vegetation 

communities. BLM would even sacrifice these lands to 

permittees outside the planning area. It also appears that BLM 

Management action LG-VI-MA-3 in Alternative VI (Proposed 

RMP) described the objectives and parameters for creating a 

reserve common allotment. The primary objective for 

establishing reserve common allotments would be to aid habitat 

restoration by providing alternate grazing areas for permittees 

who have temporarily been displaced from their allotments do to 

wildfire or areas with planned vegetation treatments. This 
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allows grazing of Owyhee wilderness lands under this scheme. management action makes allotments within the BruneauJarbidge Rivers Wilderness ineligible as a reserve common 

allotment.

Once identified to be placed in reserve common allotment status, 

the allotment would have an allotment management plan 

developed that would maintain or achieve resource objectives.

Livestock 

Grazing

LG-IV-MA-8 would allow Temporary Non-renewable 

Authorization nearly everywhere except the Wilderness Study 

Area, one very small riparian pasture, pastures with more than 

50% mule deer habitat, or pastures with more than 25% native 

plant community. Mule deer get higher priority than sagegrouse or slickspot peppergrass. In the extremely fragmented 

and burned Jarbidge Field Office, all remnant sagebrush is 

critical, yet BLM bases imposition of large herds of livestock 

and even potential repeated grazing bouts in the same year on 

barbed wire configurations of its tiny pastures.

The Final EIS analyzed a range of alternatives for Temporary 

Non-Renewable (TNR) permit consideration. Alternative VI 

(Proposed RMP) allowed consideration of TNR within the 

planning area except in pastures within the Bruneau-Jarbidge 

Rivers Wilderness and the Sand Point Area of Critical 

Environmental Concern (LG-VI-MA- 6). 

Management action LG-VI-MA-7 described criteria for issuing 

TNR. Meeting resource objectives remains the priority above 

authorization of TNR. 

Livestock 

Grazing

BLM has not provided detailed analysis of the impacts of 

previous Temporary Non-renewable Authorization (TNR) in 

promoting cheatgrass, depletion of native communities, and 

cheatgrass-fueled fires with resultant dense coarse grass and 

cheatgrass interspace seedings. The pasture and barbed wire 

form the entire basis of how these terribly depleted habitats 

would be managed. Under this bizarre scheme, even occupied 

bull trout habitat or slickspot peppergrass habitat, could be 

subjected to TNR. 

The Final EIS analyzed the direct and indirect impacts of 

Temporary Non-Renewable (TNR) permits allowable under 

each alternative. The affected environment sections of the Final 

EIS takes into consideration the existing conditions of resources 

across the planning area. Past actions influence the existing 

conditions of resources in the planning area. Concerns identified 

in the comment may be considered in future TNR authorizations.

Livestock 

Grazing

Targeted grazing is uncertain, poorly defined, and there is no 

evidence that it is effective at anything other than further 

subsidizing livestock grazing operations.

The Final EIS revised the definition of targeted grazing in the 

glossary.

Livestock 

Grazing

BLM must analyze an expanded range of alternatives, 

including removal of livestock from all lands in the Sagebrush 

Sea Area of Critical Environmental Concern, and in areas 

identified as Areas of Critical Environmental Concern in the 

2007 Western Watersheds Project (WWP) Alternative that BLM 

did not adequately address.

Map 50 of the Draft RMP/EIS does not reflect the information 

provided by WWP to BLM during the scoping period and other 

public comments. It greatly reduces the land area closed to 

The range of alternatives included various levels of livestock 

grazing use. Alternative V was the most restrictive, where 

303,000 acres would be closed to livestock grazing. Grazing in

the remaining 1,160,000 acres would be decreased through 

reduced forage allocation. This alternative only allocated 10-20% 

of the forage for livestock in native and non-native perennial 

grass production areas. All other vegetation production, including 

annual grass, shrubs, and forbs would be allocated to watershed 

functions, wildlife, and wild horses.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

grazing compared to WWP's comments and communications 

with BLM.

The BLM considered the alternative submitted by Western 

Watersheds Project, known in the Draft RMP/EIS and the Final 

EIS as the “Habitat Restoration Alternative” but eliminated it from 

detailed study as a stand-alone alternative because it did not 

meet the purpose and need; contained internal inconsistencies; 

and was inconsistent with BLM planning criteria. Alternatives IV 

and V incorporated many components of the Habitat Restoration 

Alternative.

Livestock 

Grazing

All lands where restoration is undertaken must have livestock 

removed to protect the public's very costly investment needed 

to conserve the species. This has not been done in the past, 

and weed proliferation, desertification and biodiversity losses 

have been the result. See Jarbidge Analysis of the 

Management Situation, BLM's small mammal studies, Jarbidge 

Bartels and other pygmy rabbit studies.

The Final EIS addressed the removal of livestock from lands 

where restoration treatments are occurring in all action 

alternatives (I–VI) with the following management actions:

UV-CA-MA-3. Rest vegetation treatment areas from uses, 

including but not limited to livestock and wild horse grazing and 

recreational use, until treatment objectives are met and are 

predicted to be sustainable. This guideline would not apply to 

uses that do not conflict with the treatment objectives.

FE-CA-MA-10. Rest burned areas from uses, including livestock 

and wild horse grazing and recreational use, until Emergency 

Stabilization and Burned Area Rehabilitation objectives are met 

and are predicted to be sustainable or if the treatment is 

determined by the BLM to be unsuccessful. This would not apply 

to uses that do not conflict with the treatment objectives.

Livestock 

Grazing

BLM must also analyze a No Grazing Alternative for the entire 

planning area especially since it chose to analyze several 

near-status quo or even increased livestock grazing 

alternatives (if Temporary Non-renewable Authorization, Fuels, 

and all the uncertainty are taken into account).

The Final EIS analyzed a reasonable range of alternatives, from 

a large increase to a reduction of as much as 78% of current 

forage allocations for livestock grazing. The No Grazing 

Alternative was considered, but eliminated from detailed study 

because no issue or conflict has been identified during this land 

use planning effort that requires the complete elimination of 

grazing within the planning area for its resolution. Resource 

conditions do not warrant planning area-wide prohibition of any 

particular use, including livestock grazing; therefore, an 

alternative eliminating this use where resource conditions do not 

justify such measures is not reasonable.

Livestock 

Grazing

BLM discusses allocation (Draft RMP/EIS, p. 2-143) stating, 

"the purpose of allocating vegetation is to determine the total 

animal unit months (AUMs) available for livestock grazing". 

Then, BLM claims that allocation percentages are not the 

The allocation of forage represents an estimate of the 

percentage of forage produced in a specific area allocated to 

livestock grazing. The smaller the percentage of vegetation 

allocated to livestock, the greater the percentage that is 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

same as utilization, as the allocation is used to identify the total 

number of AUMs for livestock, while utilization identifies the 

amount of vegetation used by livestock in a specific area. It 

divorces forage from all the other elements of habitat that 

sage-grouse and other species require.

allocated to other uses, such as wildlife. Once that allocation is 

made, livestock is managed to implement the allocation decision. 

Utilization is a monitoring tool that informs managers of the 

success of the implementation strategy. If utilization shows that 

key vegetation species are being consumed by livestock at 

higher rates than appropriate for the allocation, livestock 

stocking rates can be modified. 

Livestock 

Grazing

BLM has failed to provide detailed mapping and analysis of all 

existing fences that were placed in piece meal fashion 

following fires since the 1987 RMP.

The Final EIS included all known existing fences on Map 51 

“Range Infrastructure”.

Livestock 

Grazing

We are concerned that there is no specific mention of removing 

or greatly reducing livestock grazing to promote passive 

restoration.

Alternative V focused on passive restoration of native 

communities while reducing livestock grazing up to 78% when 

compared to current grazing levels. Alternative VI (Proposed 

RMP) allows for passive restoration where success is 

determined to be likely, but prescribes active restoration in highly 

altered sites where more aggressive techniques are necessary 

to achieve objectives. 

Livestock 

Grazing

On p. 4-403 BLM states, "at 20% use, residual herbaceous 

heights of the same grasses are near or exceed the nesting 

cover requirements". However, this is nonsense because 

Sandberg bluegrasses, Stipa, Idaho fescue, etc. at 20% use do 

not meet or exceed the 9-inch residual cover requirements.

Ecological site and annual climatic fluctuations, as well as other 

variables influence herbaceous cover values and the ability of 

many species to meet recommended habitat values across the 

planning area. The Final EIS did not identify a specific cover 

value required for any wildlife habitat because seasonal 

requirements vary widely, usually changing as the season 

progresses. Instead, alternatives analyzed provided the flexibility 

to determine habitat values on site-specific bases in order to 

more effectively manage authorized uses. Habitat requirements 

and ecological site potential would aid in determining allotment 

or pasture specific use criteria. 

Livestock 

Grazing

What does BLM mean on p. 4-403, "the No Action Alternative 

does not have specific utilization levels"? BLM claims that use 

ranges from less than 20% to more than 50% in pastures. Are 

these native, exotic, or blended?

The 1987 RMP did not specify forage utilization criteria. The 

range of utilization described in the Final EIS is a generalization 

of utilization occurring annually across the planning area.

Livestock 

Grazing

Reducing livestock utilization levels does not reduce trailing 

impacts on top of tiger beetles. Moving the illegal trough that 

ranchers placed in the midst of the habitat, requiring ranchers 

to actually work to herd cattle, and closing the pasture to 

grazing does.

Alternative II provided for increased commercial opportunity in 

the planning area, including increased livestock grazing. During 

the development of Alternative VI (Proposed RMP), the BLM 

considered comments received from the public on the Draft 

RMP/EIS, the analysis of effects described in the Chapter 4, and 

available science to determine a level of forage allocation to 

livestock that would both provide the opportunity for livestock 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

grazing and meet resource objectives. The use of allocations 

and management actions, on a site-specific basis, to enhance 

and protect special status species such as tiger beetles.

Livestock 

Grazing

The BLM would continue to graze vast areas of lands in the 

BLM alternative for the Sagebrush Sea Area of Critical 

Environmental Concern. The BLM never analyzes an 

alternative that would not do so.

Rather than close allotments, the Final EIS analyzed the impacts 

of differing levels of livestock grazing by varying the number of 

animal unit months allocated to that use. The Final EIS analyzed 

the Inside Desert Area of Critical Environmental Concern 

(ACEC) in Alternatives IVA and IVB for removal of livestock and 

associated infrastructure on approximately 73,000 and 41,000 

acres, respectively. The Final EIS also analyzed the Sagebrush 

Sea ACEC in Alternative V, the most restrictive alternative for 

livestock grazing, effectively reducing livestock grazing by 78%.

Livestock 

Grazing

We vainly turned to the impacts from livestock grazing section, 

referred to here, to understand the referenced targeted 

grazing. We found minimal analysis.

The Final EIS revised and expanded the Chapter 4 analysis on 

targeted grazing. Alternative VI (Proposed RMP) analyzed and 

addressed targeted grazing in Upland Vegetation, Noxious 

Weeds and Invasive Plants, and Wildland Fire Ecology and 

Management). Targeted grazing, like prescribed fire or herbicide 

use, is a vegetation treatment tool to accomplish resource 

objectives in the Upland Vegetation, Noxious Weeds and 

Invasive Plants, and Wildland Fire Ecology and Management 

sections. 

Livestock 

Grazing

BLM references proper grazing management with no definition. 

What references did the BLM use to understand what is proper 

in the context of conserving sage-grouse or pygmy rabbit?

The definitions for proper grazing are broad and depend upon 

the objectives of implementing the grazing practice. For the 

purposes of the Final EIS, proper grazing is the application of 

grazing management practices that would help achieve resource 

objectives. Management practices would include allocation rates, 

as well as the use of management actions such as seasons-ofuse, timing restrictions, and range infrastructure that would 

maintain or enhance resource values. 

Livestock 

Grazing

There is no valid reason to allocate different amounts of forage 

percentages.

Forage allocation percentages were based on the emphasis, 

goals, and objectives of each alternative analyzed. Thus, the 

Final EIS allocated more forage to wildlife in alternatives that 

emphasize habitat improvements than in commodity production 

alternatives.

Livestock 

Grazing

Please examine the failed rehabilitation actions on US Air 

Force access roads grazed by BLM-managed livestock. What 

was seeded? What is now present, and in what condition, after 

several years of grazing? Factor this into any predictions of 

treatment outcomes in the Final EIS.

The affected environment sections of the Final EIS considered

the existing conditions of resources across the planning area. 

Past actions influence the existing conditions of resources in the 

planning area. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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A-497

Category Comment Response

Livestock 

Grazing

In a hotter, drier, longer summer scenario, is it acceptable or 

sustainable to have any continued livestock disturbance (soil 

compaction, grazing, weed spread) to meadow, spring, 

intermittent, or ephemeral waters?

The Final EIS revised the presented climate change information 

to include both the effects of climate change on resources and 

resource uses, but also the effects of resource use on climate 

change. 

Rangeland health assessments and other monitoring would help 

identify impacts associated with livestock grazing that were 

leading to achieving or not achieving resource objectives. 

Continuation of grazing practices would consider contributing 

factors outside the control of permittees or the BLM, such as 

changing climatic conditions.

Livestock 

Grazing

Identify all fences or facilities built following fires and 

rehabilitation. Provide a range of alternatives that target these 

for removal.

The Emergency Stabilization and Burned Area Rehabilitation 

(ES&BAR) plans prepared after wildfires include criteria for 

installation and removal of temporary fences and other ES&BAR 

structures. 

The Final EIS, Chapter 4, analyzed the use of temporary fencing 

following vegetation treatments for wildfires.

Livestock 

Grazing

Draft RMP/EIS mapping is at a scale where necessary 

understanding of allocation of "forage", habitat, allotment, and 

other specifics is just not possible. Where is mapping that 

shows how much forage was allocated/or used in analysis in 

the Draft RMP/EIS - tied to each land area (pasture, allotment).

Wouldn't the allocation change based on the configuration of 

facilities - as the position of water and fencing may serve to 

limit or reduce livestock use in some areas? So if that changed 

allocations may be different.

The Final EIS analyzed allocation of forage to livestock grazing 

at the planning area level. Allocation of forage to livestock during 

this planning process would not allow the detailed analysis 

necessary to appropriately manage livestock at the allotment 

and pasture scale. Allocation of forage at the allotment and 

pasture scale would be performed during the permit renewal 

process where site-specific resource issues such as seasonal 

wildlife habitat needs, riparian and fishery conditions, and results 

of rangeland health assessments could be considered in 

deciding the appropriate forage allocation and manage 

necessary to meet resource objectives. 

Livestock 

Grazing

BLM must not use the battery of existing fences as the 

baseline in all alternatives. It is clear that BLM does not even 

show the nightmare of pasture fences here. It only shows the 

crazy jigsaw puzzle allotment pattern.

The Land Use Planning Handbook, H-1601-1, states the EIS 

should describe the status, or present characteristics and 

condition of the public land; the status of physical and biological 

processes that affect ecosystem function in order to perform the 

analysis of the No Action Alternatives and all action alternatives. 

The Final EIS described fences in Table 3-52, Chapter 3, to 

portray the existing management situation.

Livestock 

Grazing

BLM must develop a specific avoidance protocol that includes 

livestock grazing during critical and important periods of use.

The BLM analyzed avoidance criteria for special status species 

in both the Draft RMP/EIS and Final EIS. A brief list of examples 

of avoidance criteria include the identification of riparian 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

conservation areas (RI-CA-MA-1) and the adjustment of 

authorized uses to avoid conflict with use of bighorn sheep 

habitat (SS-CA-MA-16).

Livestock 

Grazing

Western Watersheds Project (WWP) provided scoping 

comments requesting that the Jarbidge RMP include language 

that will enable relinquished or waived grazing permits to be 

held indefinitely for wildlife habitat and watershed health and 

not be reissued for livestock use. The Draft RMP/EIS did not 

include such a provision. WWP does not supported using such 

allotment permits as grass banks. This language needs to be 

part of each alternative in the Final EIS. The language WWP 

supports is as follows: Grazing privileges that are lost, retired, 

relinquished, canceled, or have base property sold without 

transfer would have attached animal unit months held for 

watershed protection and wildlife habitat.

Alternative V included language similar to that suggested; see 

management action LG-V-MA-2. However, this language is not 

included in each alternative as requested. BLM determined the 

goals, objectives, and management actions to include in each 

alternative based on the theme or emphasis for the alternative. 

Livestock 

Grazing

Please enter the attached article “Grazing can increase 

flammability: botanist” into the record for the Draft RMP/EIS.

The article is not relevant to the planning area because it 

addresses tussock grasses in Tasmania, which is an ecological 

system vastly different from the planning area.

Livestock 

Grazing

I am attaching the abstract for Leonard and others (2010). 

Please enter this information into the RMP record. This 

abstract discusses the variation in the effects of vertebrate 

grazing on fire potential between grassland structural types.

The article is not relevant to the Final EIS because it addresses 

the effects of grazing on grasses in Tasmania, which is an 

ecological system vastly different from the planning area.

Livestock 

Grazing

No public use of any type will be allowed inside the fenced 

exclusive-use area of the Saylor Creek Range. Grazing use 

shall be permitted on the remainder of the area withdrawn by 

Public Land Order No. 1027, as amended.

The Final EIS revised maps to reflect the availability of BLMmanaged lands to livestock grazing (Maps 52 to 59).

Maps The maps designate State Endowment Trust Lands only as 

State lands. State Endowment Trust Lands are managed quite 

differently than other State owned lands. Please assist us 

designating these lands as State Endowment Trust Lands 

within the documents. State Endowment Trust Lands are not 

managed for the public at large and should not be referred to 

as public lands either specifically or in a generic sense.

Map 2 “Surface Management in the Jarbidge Planning Area” in 

the Final EIS continued to label State Endowment Trust Lands 

as “State” lands. This labeling in the legend followed BLM 

mapping standards.

Maps On p. M-4, Map 3 “Mineral Estate Management in the Jarbidge 

Field Office” in the Draft RMP/EIS does not show military 

withdrawn lands, or the road network associated with the US 

Air Force. Analyze Military activities in detail. It is necessary to 

understand the footprint of the military here, and all direct, 

indirect and cumulative disturbances.

The Final EIS depicted Military withdrawn lands in Map 2 

“Surface Management in the Jarbidge Planning Area”. The Final 

EIS analyzed the impact of military activities under cumulative 

impacts in Chapter 4.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Maps BLM must provide detailed mapping and analysis of springs, 

seeps, ephemeral and intermittent drainages. Provide an 

examination of their condition inside and outside enclosures.

The Final EIS maps depicting streams included perennial and 

intermittent flows(see Map 6 “Water Quality Impaired Streams”, 

Map 22 “Riparian Conservation Areas”, Map 23 “Habitat 

Condition Ratings”, and Map 24 “Bull Trout and Redband Trout 

Distribution”. Analyses of impacts to perennial and intermittent 

streams and riparian areas and wetlands were described in 

Chapter 4.

Maps Provide full and detailed mapping and analysis of all post-fire 

"rehab" and grazing actions. Also, depict and examine 

Infrastructure "creep". 

The requested level of detail is unnecessary to make an 

informed decision at the landscape scale. The existing 

conditions of the planning area has been described in Chapter 3, 

including sections on Livestock Grazing, Wildland Fire Ecology 

and Management, Land Use Authorizations, etc.

Maps Provide new and updated mapping that shows the Long Butte 

Fire. 

The Final EIS provided new and updated mapping of vegetation 

communities following the Long Butte Fire to project the baseline 

vegetation out to 2016. This projection accounts for fires through 

the end of 2011. See Map 10 “2016 Projected Vegetation”.

Maps Please provide detailed mapping of all fuel breaks or green 

strips BLM has planted since the 1987 RMP, or prior.

Providing detailed mapping of all fuel breaks is beyond the 

scope of this planning effort. Map 9 “Existing Vegetation as of 

2011” and Map 10 “2016 Projected Vegetation” accounted for 

seedings, fuel breaks, and other vegetation treatment 

information.

Maps On p. M-33 “Range Infrastructure in the Saylor Creek Herd 

Management Area (HMA)” in the Draft RMP/EIS shows the 

HMA with all the fences. However, the other maps where wind, 

utility, or other energy and all kinds of activities are overlaid do 

not outline the HMA. Therefore, it is very difficult to tell what will 

and will not occur there. All mapping should include an outline 

of the HMA so that the public can clearly understand how the 

HMA and horses will be managed or protected.

The Final EIS added the Saylor Creek Herd Management Area 

boundary to maps for Fire Suppression Areas, Areas Available 

for Livestock Grazing, Special Recreation Management Areas, 

Recreation Management Zones, Travel Designations, Travel 

Management Areas, Utility Right-Of-Way Corridors, Expected 

Wind Energy Development Areas, Land Tenure, Potential Oil 

and Gas Development Areas, Potential Geothermal 

Development Areas, Leasable Minerals, Salable Minerals, and 

Locatable Minerals.

Maps We have attached mapping showing fires that have occurred in 

the broader landscape context of the planning area from 1998 

to 2010. Please view this map side-by-side with Map 24 from 

the Draft RMP/EIS “Wildland Fire Frequency, 1987-2007”, 

which shows significant burned areas of the Inside Desert 

during this period. 

The Final EIS mapped wildland fire frequency in the planning 

area from 1987-2011. See Map 28 "Wildland Fire Frequency 

from 1987-2011".

Maps Please consider the Nevada Department of Wildlife 2008 sagegrouse reporting and mapping that overlays Nevada fires with 

leks.

The Final EIS did not use the referenced literature since the 

report is for the entire State of Nevada. The map depicted a 

large number of fires in Elko County, but acreage by county is 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

not given. The literature reported that over 2,561,000 acres of 

sage-grouse habitat (11.6 %) burned in Nevada over a 9-year 

period. The Final EIS used fire data from Elko District BLM for 

the cumulative impacts analysis.

Maps Maps should display State lands within the boundary of Juniper 

Butte Range.

The Final EIS updated Map 2 "Surface Management in the 

Jarbidge Planning Area" to depict State lands within the 

boundary of Juniper Butte Training Range.

Maps Add Restricted Airspace R-3202 and R-3204 outside US Air 

Force (USAF) range boundaries. USAF has rights to use all 

airspace within these boundaries from ground level to 17,999 

feet mean sea level. Display the southeast portion of the 

Jarbidge Military Operating Area (MOA). Part of the Paradise 

East MOA covers the Southwest part of the planning area.

The Final EIS updated maps displaying right-of-way avoidance 

areas (Maps 86 to 92) to include the Paradise East Military 

Operations Area and to exclude the depiction of military lands.

Minerals The Draft RMP/EIS states that the entire planning area, 

including the potential oil and gas areas, has low potential for 

oil and gas leasing (Draft RMP/EIS, p. ES-31). However, all of 

the management alternatives make the majority of the planning 

area available to mineral leasing. The Preferred Alternative, 

which closes the most areas to leasing (with the exception of 

Alternative IV-A), still opens 85% of the planning area to 

mineral leasing, including areas open with moderate or major 

constraints (Draft RMP/EIS, p. 2-273). Leaving the vast 

majority of a planning area with low potential open to oil and 

gas development does not represent multiple uses, nor provide 

a true range of alternatives.

Chapter 2 provides a range of alternatives for leasable minerals. 

The lands closed to leasing have been determined to represent 

areas where other land uses or resource values cannot be

adequately managed even with the most restrictive lease 

stipulations. The Final EIS identified sufficient moderate and 

major constraints to manage resources in the majority of the 

planning area. 

Minerals BLM often offers companies exceptions, modifications or 

waivers from the application of No Surface Occupancy and 

other lease stipulations, and the preferred alternative lists 

exceptions, modifications and waivers that may be granted for 

each stipulation. The Draft RMP/EIS states, “public review is 

required for exceptions, waivers, or modifications to 

stipulations that involve an issue of major concern to the 

public”.

The exceptions, waivers, and modifications provided in the 

Preferred Alternative relate to key species and important 

historic resources, and therefore will always involve issues of 

major concern to the public. Therefore, we expect public review 

would always be required and so revise the Draft RMP/EIS to 

BLM will follow the appropriate regulations concerning public 

review of leasing stipulations. The regulations at 43 CFR 3101.1-

4 state: If the authorized officer has determined, prior to lease 

issuance, that a stipulation involves an issue of major concern to 

the public, modification or waiver of the stipulation shall be 

subject to public review for at least a 30-day period.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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•

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A-501

Category Comment Response

state that public review would be required for all exceptions, 

waivers, and modifications to lease stipulations.

Minerals It is essential for the BLM to provide salable minerals needed 

for community and economic purposes and facilitate their 

reasonable, economical, and environmentally sound 

development where available and compatible with resource 

objectives, SA-IV-O-l on p. 2-202. The Areas of Critical 

Environmental Concern listed and "non-Wilderness Study Area

lands managed for their wilderness characteristics" in SA-IVA-I 

on p. 2-202 should be removed based on the reason noted 

above.

The Final EIS included a reasonable range of alternatives for 

providing salable mineral materials where they are compatible 

with other resources; see SA-CA-G-1 in Chapter 2, Alternative VI 

(Proposed RMP) in the Salable Minerals section. 

Minerals On ES-23, second issue, No Action Alternative does not 

identify which segment of Salmon Falls Creek canyon they are 

talking about. We oppose any such restriction below Balanced 

Rock.

The Salmon Falls Creek Canyon, from the Salmon Falls Creek 

Dam to Balanced Rock Road between canyon rims, is open to 

mineral leasing (excluding geothermal leasing) with No Surface 

Occupancy year-round. 

Minerals The Three Creek Highway District suggests the following 

objective and management common to all alternatives for 

Salable Minerals: Provide a source for maintenance materials 

needed for travel routes, backfills etc.

The Final EIS did not modify the objective common to all action 

alternatives for Salable Minerals. The objective does not 

specifically mention gravel for road maintenance; however, that 

is the intent. In the Final EIS the goal was to provide for salable 

mineral development opportunities where they are compatible 

with other resources.

Minerals Add the following management action for salable minerals in 

Chapter 2. Locate suitable sources of gravel when distances 

begin to exceed 20 miles to existing sources. 

The Final EIS analyzed a range of areas open to salable mineral 

development among the different alternatives. Under Alternative 

VI (Proposed RMP), the majority of the planning area would be 

open to salable mineral development, subject to site-specific 

NEPA analysis, stipulations, and 43 CFR 3600 regulations. 

Under Alternative VI, the following areas would be closed to 

salable mineral development: 

The Bruneau-Jarbidge Rivers Wilderness; 

Lower Salmon Falls Creek Wilderness Study Area; 

Eligible, suitable, and designated Wild and Scenic River

corridors; 

The Oregon National Historic Trail protective zone; 

The Kelton and Toana Freight Road protective corridors;

 Areas of Critical Environmental Concern; and 

Playas (300-feet buffer).
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-502

Category Comment Response

Minerals The Resource Advisory Council unanimously supports 

permitting gravel pits for highway district use as requested and 

at no cost to the highway districts. There is currently a shortage 

of gravel pits within the planning area for use by highway 

districts. In some cases, highway districts have forgone the use 

of some of these material sources due to the required 

environmental assessments and associated cost of completing 

the paper work. 

The Final EIS provided for exploration of salable mineral 

development in Chapter 2. In all alternatives, consistent with law 

and BLM policy, proposed gravel pits for BLM and/or highway 

district purposes undergo a site-specific environmental analysis 

prior to ground disturbing activities. 

Minerals The Environmental Protection Agency has an ongoing interest 

in ensuring that future mining activities do not cause or 

contribute to existing environmental problems and would like to 

affirm the importance of including adequate and complete 

financial assurance information in all BLM Draft NEPA 

documents prepared for proposed mining projects.

Mining exploration and extraction activities that disturb the 

surface of the land are subject to surface management 

regulations 43 CFR 3809.

Minerals BLM must prohibit any further gravel development in native 

shrub lands, native grasslands, - i.e. any native communities 

and sage-grouse recovery habitats. An example of the damage 

that extensive gravel pits do is the gravel pit developed above 

Clover Creek for the US Air Force destroying intact sagebrush. 

Rehabilitation has been a failure. Soil erosion continues. 

Salable mineral development activities would avoid special 

status species habitat if the activity would have an adverse 

effect, unless those adverse effects can be mitigated. Permits 

would include mitigation for adverse effects on special status 

species and their habitats. (SA-CA-MA-1).

Minerals The Oil and Gas mapping shows that BLM would even allow 

the critical Browns Bench sage-grouse area to be developed. 

BLM must place all lands in the southern and central portions 

of the planning area as proposed in Western Watersheds 

Project’s Sagebrush Sea Alternative, and all lands important to 

sage-grouse conservation, as well as special habitat and wild 

horse areas in the north, off-limits to Oil and Gas development. 

BLM must analyze in detail all of the adverse impacts of 

modern day oil and gas production so it can understand the full 

implications of allocating even a single acre in the planning 

area for oil and gas

The Final EIS analyzed a range of Areas of Critical 

Environmental Concern (ACECs) including the Sagebrush Sea 

ACEC. Alternative VI (Proposed RMP) did not include the 

Sagebrush Sea ACEC. There has never been any oil and gas 

production in Idaho, despite drilling of approximately 150 wells in 

the State (Appendix K: Reasonably Foreseeable Development 

Scenario for Oil and Gas Development). Oil and gas 

development stipulations are included in the range of 

alternatives analyzed (Chapter 2, Leasable Minerals). Chapter 4 

discussed impacts from leasable mineral development. Leasable 

mineral development activities would avoid special status 

species habitat if the activity would have an adverse effect, 

unless those adverse effects can be mitigated. Permits would 

include mitigation for adverse effects on special status species 

and their habitats (LE-CA-MA-7).

Minerals Please review all of the information in the Holloran, Naugle, 

and other sage-grouse studies in Wyoming and Montana. See 

also Connelly and others (2004), and Knick and Connelly 

(2009). Please review all of the recent information about the 

Chapters 3 and 4 of the Final EIS used information on sagegrouse contained in Holloran and others (2005), Naugle and 

others (2011), and Knick and Connelly (2011a) Greater Sagegrouse Ecology and Conservation of a Landscape Species and 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Pinedale anticline. BLM has been unable to prevent deep 

losses to wildlife populations that occur with this development 

with the same meager measures that the Draft RMP/EIS relies 

on. We also stress that the sage-grouse, mule deer, and other 

populations in Wyoming were much less stressed and reduced 

than the crisis now facing the planning area. Anyone can 

understand that oil and gas, wind, geothermal, or large-scale 

energy of any kind - will result in calamity.

Its Habitats. This book contains all the mentioned articles and 

sage-grouse studies conducted in Wyoming and Montana.

Minerals Why are so few areas closed to leasable mineral development 

under all alternatives? Not even potential Areas of Critical 

Environmental Concern or slickspot peppergrass habitats are 

closed under Alternative V.

Oil and gas development stipulations are included in the range of 

alternatives analyzed (Chapter 2, Leasable Minerals). Moderate 

and major constraints are identified to ensure that any mineral 

leasing is compatible with other resources. The Final EIS, 

Chapter 4, analyzed impacts from leasable mineral goals, 

objectives, management actions, and constraints.

Minerals Chapter 4, Leasable Mineral-direct and indirect impacts, States 

in Alternative IV that 7-9% of planning area is inaccessible, 

39% is accessible under standard lease terms. Yet there is no 

analysis of these impacts. Alternative V states 4% as 

inaccessible and 70% as accessible under standard lease 

terms.

The amount of constraint on mineral leasing was used as an 

indicator of impacts for leasable minerals. Table 4-373 in the 

Final EIS contained a summary of constraints for Alternative IV

and Table 4-374 contained a summary for Alternative V. Impacts 

to soil resources, special status species, paleontological 

resources, and visual resources were described by alternative. 

The Final EIS provided a summary of direct and indirect impacts 

for minerals by all alternatives. 

Minerals Withdraw all lands in Areas of Critical Environmental Concern

from locatable mineral or other mining and exploration.

Withdrawing lands within Areas of Critical Environmental 

Concern from locatable mineral exploration and development is 

included within the range of alternatives.

Minerals Alternative IV allows locatable mineral development in lands 

east of Dave Creek including the East Fork area, and in the 

areas of the remaining lek complexes near Browns BenchChina Mountain, Three Creek, and other portions of the 

Jarbidge foothills. BLM can and must place these lands offlimits to locatable mineral development. This includes the 

Toana Freight Road and the Saylor Creek Horse Management 

Area. 

Each alternative reflects a different management focus. 

Changing Alternative IV as suggested would reduce the range of 

alternatives analyzed. 

Minerals The loss of habitat due to groundwater extraction is the primary 

threat to the Bruneau Hot spring snail. We encourage the BLM 

to further expand conservation criteria within the Final EIS to 

prohibit geothermal leasing or other groundwater pumping 

activities in all areas that may affect Groundwater Management 

Basin 51 in Owyhee County (which includes the Bruneau 

It is within the BLMs discretion to authorize or deny proposals for 

geothermal leasing or groundwater pumping on public land but it

is not within the BLMs discretion to authorize or deny these 

activities on private or State lands. The comment recommends 

prohibiting these activities within a 15-mile radius of the Indian 

Bathtub Hot Spring but does not provide literature or data 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-504

Category Comment Response

Valley regional geothermal aquifer in the planning area), or are 

located within a 15 mile radius of the Indian Bathtub Hot 

Spring. Use of the strongest conservation measures available 

to control groundwater pumping activities in this area will 

contribute to the long-term survival and recovery of the 

Bruneau hot springsnail.

supporting this recommendation. A portion of the area within this 

15-mile buffer is not within the Jarbidge planning area. The Final 

EIS included management direction to allow for mineral leasing 

subject to laws, regulations, and formal orders; areas may also 

be subject to additional constraints. The preparation of a sitespecific analysis for geothermal leasing exploration or 

development and completion of Endangered Species Act (ESA) 

consultation for proposals that have the potential to directly, 

indirectly, or cumulatively affect geothermal springs containing 

Bruneau Hot springs snail would assure compliance with the 

ESA for this endangered species.

Minerals BLM does not retain mineral rights on Saylor Creek Range and 

Juniper Butte Range. See Public Land Orders 1027 (1954), 

3192 (1963), and 4302 (1970). This is correct on maps 92-106

of the Draft RMP/EIS.

The mineral estates are in US ownership. The US Air Force 

withdrawn lands are for military uses only. Saylor Creek Training 

Range is open to mineral leasing and Juniper Butte Training 

Range is closed to all mineral entry including leasing. See Title 

XXIX Juniper Butte Withdrawal Public Law 105-261. 

Monitoring Regarding Appendix P: Monitoring and Implementation 

Strategy, p. A-I55 of the Draft RMP/EIS, land use plans are 

supposed to establish intervals for monitoring. This RMP relies 

on properly functioning condition, and that it will use Multiple 

Indicator Monitoring to support this. There is no clear plan with 

clear monitoring requirements and milestones laid out for 

conserving sage-grouse, pygmy rabbit, redband trout, slickspot 

peppergrass, and monitoring to ensure this occurs. There are 

no annual, periodic or other milestones for moving toward 

goals/objectives/MAs.

The Final EIS, Chapter 2, Monitoring Implementation and 

Effectiveness of RMP Decisions section outlined a monitoring 

strategy for assessing the implementation and effectiveness of 

RMP decisions in meeting resource goals and objectives. This 

section identified resources/resource uses, monitoring 

strategies, and monitoring intervals as required for land use 

plans (43 CFR 1610.4-9).

Multiple Use 

Areas

It is time for the BLM to abandon the Multiple Use Areas. They 

make no ecological sense, just like the latest Vegetation 

Management Areas. They have served as a basis for justifying 

continued degradation and fragmentation of shrub and sagegrouse habitats. 

Multiple Use Areas were a component of the 1987 Jarbidge 

RMP and were thereby included in the No Action Alternative. 

Due to differences in vegetation response to management and 

disturbance along a north-south gradient, the planning area was 

divided into Vegetation Management Areas (VMAs) based on 

potential natural community, elevation, and mean annual 

precipitation. The VMA boundary lines were further refined using 

pasture lines to facilitate proposed management of these areas 

as described in Chapter 2. See Map 8 “Potential Vegetation 

Communities and Vegetation Management Areas” in the Final 

EIS. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-505

Category Comment Response

National 

Historic Trails

Add the BLM trail management plan and the National Park 

Service comprehensive management plan to the Final EIS 

works cited section.

The BLM Boise District Oregon Trail Management Plan and the 

National Park Service’s Comprehensive Management and Use 

Plan Update were added to the works cited section in the Final 

EIS. 

National 

Historic Trails

We ask the BLM, in its preferred alternative, to consider 

identifying a broader protective corridor, particularly for the 

intact remnants of the North Trail segment and original wagon 

ruts near Three Island Crossing.

The Final EIS contained a range of corridor widths for the 

Oregon National Historic Trail (NHT). Alternative VI (Proposed 

RMP) expanded the Visual Resource Management Class II 

allocation to include 2 miles on either side of the Oregon NHT (4 

mile total width) to provide consistency with the adjacent Snake 

River Birds of Prey RMP. This expansion should afford adequate 

protection from visual impacts to the trail's setting.

National 

Historic Trails

NHT-CA-MA-12 states, "Proposed land use actions that could 

affect the Oregon National Historic Trail (NHT) or the protective 

corridor would be analyzed to identify mitigation needs and 

ensure compliance with management objectives." We propose 

that this action statement read, "The Oregon NHT would be 

managed to ensure against adverse effects through avoidance 

or through mitigation of disturbance, when disturbance or 

destruction is unavoidable."

NHT-CA-MA-13 states, "Developments such as roads, trails, 

pipelines, and power lines may be allowed to cross the Oregon 

NHT in areas where previous disturbance has occurred and 

after consultation with the State Historic Preservation Office 

(SHPO)." We suggest that this statement read, "Developments 

such as roads, trails, pipelines, and power lines may be 

allowed to cross the Oregon NHT where the affected segment 

is determined, with SHPO concurrence, to be noncontributing 

due to previous disturbance or visual intrusions."

NHT-CA-MA-14 states, "Surface-disturbing equipment, such as 

bulldozers and road graders, cannot be used on the Oregon 

NHT or within the protective corridor without management 

approval, unless to protect life or property." We suggest that 

the statement read, "Surface-disturbing equipment, such as 

bulldozers and road graders, cannot be used on contributing 

segments of the Oregon NHT or within the protective corridor 

of such segments, unless to protect life or property." 

Management action NHT-CA-MA-12 was changed to NHT-CAMA-9 in the Final EIS. The wording was revised to read, 

“Adverse effects to the Oregon National Historic Trail (NHT) 

related to land use authorizations would be prevented through 

avoidance of impacting activities or through mitigation when 

disturbance or destruction is unavoidable.”

Management action NHT-CA-MA-13 was changed to NHT-CAMA-10 in the Final EIS. The wording was revised to read, 

“Developments such as roads, trails, pipelines, fences, and 

power lines may be allowed to cross the Oregon NHT where the 

project is determined by the BLM, with State Historic 

Preservation Office concurrence, to not adversely affect the trail 

due to previous disturbance or visual intrusions.”

Management action NHT-CA-MA-14 was changed to NHT-CAMA-11 in the Final EIS. The wording was revised to read, 

“Surface-disturbing equipment, such as bulldozers and road 

graders, cannot be used on contributing segments of the Oregon 

NHT, or within the protective zone of such segments, unless to 

protect life or property.”
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-506

Category Comment Response

National 

Historic Trails

Revise NHT-CA-MA-3 to read, "Manage the Oregon National 

Historic Trail protective corridor as an avoidance area for 

surface-disturbing activities unless use has previously been 

established in those areas, including but not limited to: 

• Placement of salting, supplemental feeding, watering, and 

holding facilities for livestock, 

• staging areas for recreational activities and events,

• staging areas for fire suppression and rehabilitation activities.

Many salt and supplemental feeding and watering areas have 

been in place for years, and forcing those items to a different 

location would result in unwarranted disturbance to additional 

areas.” 

The intent of this management action is to restrict new 

permanent developments and new or recurrent temporary 

facilities or activities from the Oregon National Historic Trail 

(NHT) protective zone in order to preserve the trail and its 

setting. The suggested revision would allow for the continuation 

of existing activities even if they impact the Oregon NHT. To 

clarify, the Final EIS revised the first bullet in NHT-CA-MA-3 to 

read “Placement of salting, supplemental feeding, temporary 

watering, and temporary holding facilities for livestock”. 

Noxious Weeds 

and Invasive 

Plants

The RMP needs to give additional analysis for prescribed fire 

as a management tool.

The Final EIS presented prescribed fire as a tool to accomplish 

goals and objectives and the analysis is commensurate with the 

planning area scale of the upcoming decision. The Final EIS 

does not include any site-specific proposals for applying 

prescribed fire.

Noxious Weeds 

and Invasive 

Plants

Keeley (2001) notes “there is no convincing demonstration that 

fire alone is an effective technique for diminishing the 

dominance by nonnative annuals” and “generally burning of 

annual grasslands does not greatly alter the native to 

nonnative composition, unless accompanied by active native 

plant restoration.” Burn-related issues that still need to be 

addressed include (1) how vegetation composition (particularly 

native species) responds when sites are burned repeatedly 

over a period of years, and (2) whether burning can effectively 

control non-native species such as tumbleweeds, mustards, 

and prickly lettuce that are very widespread in some years 

and/or in some locations.

The Upland Vegetation section of the Final EIS allowed for the 

use of multiple tools from the tool box, not just prescribed fire. 

The Final EIS did not include any site-specific proposal to apply 

prescribed fire by itself or in combination with other treatments. 

The analysis you suggest is needed, is appropriate at the 

project-specific level when a project is proposed.

Noxious Weeds 

and Invasive 

Plants

We are concerned with the potential unintended consequences 

of prescribed fire, targeted grazing, and chemical treatments as 

noxious weed treatments and invasive species management 

tools. The BLM needs to clearly identify under what 

circumstances and after what successful model these 

treatments will be used. These treatments should not be used 

without analysis of a defined need in a specific place and 

potential side effects. These tools should be used with 

documented attention to their possible unintended 

consequences, monitoring to determine their effectiveness, 

The Final EIS presented possible noxious weed and invasive 

plant treatment methods as tools to accomplish goals and 

objectives. The Final EIS does not include any site-specific 

proposals for applying any of these treatments in a specific 

place. Prior to applying noxious weed or invasive plant 

treatments, a separate, project-specific analysis would need to 

be completed. The project-specific NEPA analysis would 

consider treatment methods at specific locations and would 

disclose the predicted effects of implementing any treatment.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-507

Category Comment Response

and adaptive management to rectify any environmental 

damage created by their use.

Noxious Weeds 

and Invasive 

Plants

The BLM needs to add the following statement to page 3-49 in 

the Noxious Weeds and Invasive Plants section of the Draft 

RMP/EIS: "State Statute may "Not" be used to enforce the 

control of non-State designated species".

The Final EIS pertains to lands in Idaho and Nevada that are 

managed by the BLM. The Final EIS did not state, nor is it 

intended that State statutes would be used to enforce the control 

of non-State designated species.

Noxious Weeds 

and Invasive 

Plants

Use all tools available to optimize the reduction of noxious 

weeds in an effort to continue the enhancement of sagegrouse habitat.

All action alternatives, including Alternative VI (Proposed RMP), 

presented tools in the Upland Vegetation section and Noxious 

Weeds and Invasive Plants section of Chapter 2 to manage 

habitat for sage-grouse and allow for the prevention, elimination, 

and control of noxious weeds and invasive plants. 

Noxious Weeds 

and Invasive 

Plants

Where and when has BLM sprayed herbicides in its post-fire 

treatments? There has been very little success in preventing 

cheatgrass. Rabbitbrush has been eliminated in many areas, 

as well, and prevented from re-sprouting. We have repeatedly 

observed non-target perennials and even shrubs killed or 

weakened by BLM herbicide use. We are very concerned 

BLM's industry-biased alternatives over-emphasize and rely on 

chemical use with likely very significant adverse impacts, not 

just to upland species but also to aquatic species as runoff 

occurs.

The BLM has considered the effects of past treatments in the 

description of the affected environment. Herbicides are one tool 

of many proposed for use in the Final EIS to control and 

eliminate noxious and invasive weeds. Prior to applying noxious 

weed or invasive plant treatments, a separate, project-specific 

analysis would be completed.

Noxious Weeds 

and Invasive 

Plants

BLM must provide detailed mapping and analysis fully 

examining cheatgrass composition in understories, and areas 

"at risk" of cheatgrass increase or dominance under a new 

range of much more conservation-oriented alternatives.

Map 9 “Post-2007 Fire Vegetation” and Map 10 “2012 Projected 

Vegetation (Baseline)” in the Draft RMP/EIS depict an Annual 

Vegetation Sub-Group that included cheatgrass. This sub-group 

was also included on maps in the Final EIS (Map 9 “Existing 

Vegetation as of 2011” and Map 10 “2016 Projected 

Vegetation”). The Final EIS presents a reasonable range of 

alternatives and provided analysis in Chapter 4 Upland 

Vegetation section and Noxious Weeds and Invasive Plants

section. The analysis displayed the change in annual 

communities based upon proposed management for each 

alternative.

Noxious Weeds 

and Invasive 

Plants

Page 3-50, Noxious Weeds and Invasive Plants section of the 

Draft RMP/EIS, provides a shallow and greatly inadequate 

analysis of the vectors and causes of weeds. In the Jarbidge 

planning area where cows outnumber wild horses by more 

than one thousand to one, mentioning horses and livestock to 

an equal degree is just not informative.

Chapter 4 of the Final EIS provided an analysis on Noxious 

Weeds and Invasive Plants. The list of mechanisms for 

introduction and spread of weeds in the Final EIS Chapter 3 is 

simply a list and is not intended to imply the degree to which 

each mechanism may cause spread.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-508

Category Comment Response

Noxious Weeds 

and Invasive 

Plants

Chapter 3 section Noxious Weeds and Invasive Plants, of the 

Draft RMP/EIS doesn't even mention the severe impacts of 

livestock trampling in damaging microbiotic crusts and priming 

lands for weed invasion. 

The Final EIS discussed impacts of livestock trampling in 

Chapter 4 Soil Resources, Upland Vegetation, and Noxious 

Weeds and Invasive Plants sections. 

Noxious Weeds 

and Invasive 

Plants

We stress regular and repeated use of roads by military 

vehicles accessing remote sites poses a very significant threat 

for weed expansion.

Military vehicle use of the planning area was analyzed in the 

Chapter 4 Noxious Weeds and Invasive Plants section under 

Cumulative Impacts in the Final EIS as a past, present, and 

foreseeable action. BLM recognizes road use as a contributing 

factor to the introduction and spread of noxious weeds and 

invasive plants.

Noxious Weeds 

and Invasive 

Plants

US Air Force (USAF) lands at Saylor Creek are choked with 

rush skeleton weed and other aggressive invasive species. 

Military vehicles can readily transport these weeds into 

slickspot peppergrass and other habitats. We have watched in 

alarm as Mountain Home Air Force Base puts out press 

releases about bringing in military tanker aircraft to disperse 

herbicide to try to address the severe weed problems on its 

Saylor Creek site. There is strong risk of aerial drift of herbicide 

and effects to non-target vegetation.

We have watched as the USAF destroyed sage brush, 

replacing it with crested wheatgrass as a so-called "fuel break" 

along the Bruneau Desert road. Then, some shrubs grew into 

the seeding - and the USAF mowed them - and intensive 

grazing continued. This resulted in cheatgrass expansion, and 

wildfires burned right over the fuel break.

Military use was analyzed in Chapter 4 as a past, present, and 

foreseeable action. Cumulative impacts to soil resources, upland 

vegetation, special status plants, noxious weeds and invasive 

plants, and cultural resources were considered.

Noxious Weeds 

and Invasive 

Plants

Page 3-49 of the Draft RMP/EIS, Noxious Weeds and Invasive 

Plants section addresses 57 weed species from a 2006 weed 

list. There is presently a 2008 weed list that lists 64 weed 

species. Tamarisk is now listed on the weed list.

The Final EIS, Chapter 3 Noxious Weeds and Invasive Plants 

section, has been updated to include the most current (2012) 

noxious weeds lists for Idaho and Nevada.

Noxious Weeds 

and Invasive 

Plants

There is no commitment of any kind to practicing integrated 

weed management, which must be a cornerstone of 

conserving native species. BLM must develop alternatives and 

allocations based on integrated weed management to protect 

sage-grouse and other habitats from grave weed threats.

Integrated weed management was incorporated into the 

alternatives in the Final EIS in the Noxious Weeds and Invasive 

Plants sections of Chapter 2. Also, BLM uses integrated weed 

management through direction provided in BLM Manual 9015 

Integrated Weed Management. 

Process Apply and honor all of the instructions and requirements of the 

law under the Federal Land Policy and Management Act of 

1976 to this project.

Acknowledgement of BLM’s responsibilities under the Federal 

Land Policy and Management Act of 1976 are stated in Chapter 

1, purpose and need for the plan.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-509

Category Comment Response

Process Under reasonable management and use, natural resources are 

renewable and sustainable. Management for wilderness or 

roadless character does not improve environmental health. 

Multiple-use policies provide reasonable management and use 

for the benefit of all citizens. We ask that BLM base decisionmaking on restoring reasonable management and use of public 

lands.

The decision-maker will select an alternative based on analysis 

and conclusions in the Final EIS that meets the purpose and 

need and addresses the planning issues. The decision will 

provide management direction that balances resource conditions 

with resource uses. 

Process Elko County does not believe that the BLM has complied with 

NEPA process in that the document that has been provided to 

the public is of a nature that a layman cannot interpret, 

understand and provide timely pertinent and specific comment. 

The prohibitionary alternative actions of the 1,988 pages of 

bureaucratic information do not comply with NEPA and do not 

provide the best commercial data and support available. The 

document itself is too extensive and unnecessarily elaborate 

and it requires more time and effort to read, understand, and 

develop well-informed comments than the allotted 120-day 

comment period allowed for. The BLM is encouraged to limit 

these planning documents in the future to a reasonable and 

practical length. This will provide the reader, ultimately the 

citizen and local entity the ability to make relatable and 

knowledgeable comment. 

We recognize that the Final EIS is lengthy. That is due to the 

scope and complexity of an RMP and the number of alternatives 

included in the analyses. The BLM extended the comment 

period 60 days, allowing reviewers a total of 150 days to review 

and comment on the document.

Process The purpose and need statement in the Draft RMP/EIS does 

not enumerate the nine specific criteria for the development of 

the Jarbidge RMP. Rather, the purpose and need statement 

uses a different list of nine criteria, only one of which is 

consistent with the Federal Land Policy and Management Act 

of 1976 (FLPMA). The other eight are generic statements of 

environmental and multiple use principles. BLM should revert 

to the specific requirements of FLPMA in the development of 

the Final EIS and Record of Decision.

The BLM is considering the specific requirements of the Federal 

Land Policy and Management Act of 1976 (FLPMA) in 

development of the Jarbidge RMP. The purpose and need for 

the RMP was not an attempt to cite text directly from FLPMA, but 

rather paraphrase the law relative to local issues.

Process BLM fails to respond to specific comment as required under 40 

CFR 1503.4 (a). Intermountain Range Consultants submitted 

comments to the Analysis for Management Situation, 

highlighting errs and omissions therein, including irrational and 

unwarranted statements and actions. Many of these errors are 

included without any comment/correction in the Draft RMP/EIS. 

The regulations at 40 CFR 1503.4(a) directs agencies preparing 

a final EIS to assess, consider, and respond to comments 

obtained after preparing the draft EIS (40 CFR 1503.1(a)). The 

BLM was not required to respond to specific comments on the 

Analysis of the Management Situation (AMS). However, the BLM 

recognizes that there were errors in the AMS. BLM designed the 

AMS to provide a snap shot in time approach to describe 

resource conditions in 2007. Resource conditions have changed 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-510

Category Comment Response

since 2007 due to large fires (e.g., Murphy Complex, Long Butte, 

and Kinyon Road) and other factors. The Final EIS used updated 

information to account for these changing resource conditions.

Process I'm concerned about a recent article in the Times-News where 

one BLM official stated that comments from the Advisory 

Committee would be given more weight than the comments 

received from the local public. My concern is that we do not 

know whom those people are, who selected them and by what 

means they were selected.

The Twin Falls Resource Advisory Council (RAC) is an advisory 

committee established under the Federal Land Policy and 

Management Act of 1976. The RAC serves in an advisory 

capacity concerning the planning and management of the public 

land resources located within the geographic area of the Twin 

Falls District. Membership includes a cross section of Idahoans 

around the State representing energy, tourism and commercial 

recreation interests; environmental, archeological or historic 

interests; and elected officials, Tribes, and the public-at-large. 

Council members are selected for their ability to provide 

informed, objective advice on a broad array of public lands 

issues and their commitment to collaboration in seeking 

solutions to those issues. 

While the comments from the RAC on the Draft RMP/EIS are 

important to BLM, the BLM does not give more weight to the 

RAC comments than any of the other comments received. The 

BLM has the duty to consider all substantive comments.

Process The five criteria on p. ES-3 of the Draft RMP/EIS in selecting 

Alternative IV-B do not rely on any comments from the local 

public in general, nor does it rely on anyone who actually uses 

the area identified in the plan.

Page ES-3 of the Draft RMP/EIS, directly after listing the five 

criteria for selecting the Preferred Alternative (Alternative IV-B), 

stated, “The Preferred Alternative indicates the agency’s 

preliminary preference. However, identification of this alternative 

as preferred does not represent a final BLM decision and may 

change between publication of the Draft RMP/EIS and Final EIS 

based on comments received on the Draft RMP/EIS, new 

information, or changes in BLM policies or priorities.” Alternative 

VI (Proposed RMP) reflects changes and adjustments to the 

Preferred Alternative based on information received during 

public comment on the Draft RMP/EIS, new information, or 

changes in BLM policies or priorities. It includes aspects of the 

various alternatives presented in the Draft RMP/EIS.

The BLM had the discretion to select an alternative in its entirety 

or to combine aspects of the various alternatives presented in 

the Draft RMP/EIS to develop Alternative VI. Identification of an 

alternative as “Preferred” in the Draft RMP/EIS was not 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-511

Category Comment Response

equivalent to identification of Alternative VI in the Final EIS. 

Process I would be interested to know why BLM did not give 

presentations to any hunter or sportsman group or association 

listed on p. 1-17 of the Draft RMP/EIS. At the same time, BLM 

presented to a couple of organizations that are not in the local 

area. As a result, severe bias and discrimination occurred 

against the hunter groups while other user groups received 

preference.

The groups listed on p. 1-17 of the Draft RMP/EIS requested a 

special briefing from the BLM on the Draft RMP/EIS. BLM staff 

met with any group that requested a meeting. 

Additionally, numerous sportsman and hunter groups were 

included throughout the entire RMP process, including 

Backcountry Hunters and Anglers, Ducks Unlimited, Idaho 

Outfitter and Guides Association, Idaho Guide Services Inc., 

Mule Deer Foundation, Pheasants Forever, Sportsman 

Warehouse, Sportsmen for Fish and Wildlife, Boone and 

Crockett Club of America, Bow Hunting Preservation Alliance, 

Quail Unlimited, Orion--the Hunters Institute, Idaho Fish and 

Game, Idaho Outfitter and Guides Licensing Board, and the 

Congressional Sportsmen Foundation. BLM advertised all public 

meetings; these meetings were open to all people, including 

hunter groups. 

Process BLM fails to consider "significant new circumstances or 

information" associated with the existing vegetation within the 

whole of the planning area, including within the Blue Butte, 

Grindstone, Hagerman, and Kubic Allotments. Intermountain 

Range Consultants submitted comments to the Analysis for 

Management Situation, highlighting this information. BLM failed 

to account for this information in the Draft RMP/EIS. 

The regulations at 40 CFR 1502.9(c)(1)(ii) provide direction 

when agencies prepare supplements to either draft or final 

environmental impact statements. In this instance, the 

information submitted by Intermountain Range Consultants is not 

significant new circumstances or information that would trigger 

the need to prepare a supplemental EIS. BLM considered the 

comments provided on the Analysis of the Management 

Situation during the preparation of the Draft RMP/EIS. 

Additionally, the BLM has updated the vegetation information in 

Chapter 3 of the Final EIS.

Process The Draft RMP/EIS presented the affected environment section 

with a bias toward selection of the Preferred Alternative

(Alternative IV-B), rather than as an objective description of the 

existing conditions and a balanced review of conditions. It is 

distinctly slanted toward “restoring” sagebrush steppe; 

however, such a position, if ultimately decided, should be the 

result of objective analysis, not a foregone conclusion and 

underlying premise of analysis.

This is particularly the case in the Draft RMP/EIS discussion of 

fragmentation, wherein any departure from imagined preEuropean settlement or imagined pristine conditions is termed 

The Final EIS revised Chapter 3 and rewrote the Wildlife section, 

including the fragmentation discussion, to clarify that fire was a 

natural component of the sagebrush steppe. Past disturbances 

(including wildfire, rodent/rabbit population eruptions, disease, 

and insect outbreaks) have created mosaics of native plant 

community seral stages.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-512

Category Comment Response

fragmenting of the planning area. For example, fire is a natural 

feature of the Great Basin, included within the planning area, 

so that it is more likely than not that at any one point in time, 

portions of the planning area were historically in some stage of 

post-fire fragmentation and some state of recovery from 

wildfires. Therefore, natural fragmentation by fire has always 

been a part of the planning area. 

Process Under the Riparian section, the Upland Section, and indeed 

throughout the whole Draft RMP/EIS with its platitudinous and 

vague Goals, Objectives, and non-binding management 

actions, BLM doesn't have to act to do anything.

BLM managers claim that the agency is not supposed to be 

specific in land use plans. Managers now are asserting that the 

plan is for a large landscape over a long time, so BLM must 

provide for flexibility in management. This completely ignores 

the ecological crisis facing the planning area, the large-scale 

losses of sage-grouse, and other species, the many outdoororiented recreational uses of the lands that are threatened by 

continued conversion of the land to artificial grass seeding, and 

cheatgrass advance under the synergistic adverse effects of 

livestock grazing, or other development and disturbance, and 

fire.

The direction contained in a resource management plan guides 

and controls future site-specific resource use levels.

Chapter 3 of the Final EIS described the affected environment, 

including the impacts caused by events outside of the BLM’s 

control (e.g., fire and private development) and impacts that 

resulted from BLM’s past management (e.g., livestock grazing, 

vegetation treatments). Chapter 4 of the EIS described the 

impacts that are likely to result because of the management 

direction in each alternative. Admittedly, as a landscape scale 

document that addresses the allocation of land uses rather than 

the specific impacts of a particular action, the anticipated effects 

are not described in elaborate detail. However, the information 

disclosed in the Final EIS is sufficient for the reader to 

understand the effects of a combination of actions on resources 

within the planning area.

Process The point of a land use plan is to enable BLM to make changes 

and be current in addressing the environmental and other 

issues and threats that these public lands face. This plan has 

little capability of enabling good choices, since BLM doesn't 

have to do anything, and it is unclear how any potential action 

would occur. BLM, instead of referencing vague lists of tools in 

a toolbox, must methodically lie out effective actions and 

ensure that they are realistically able to occur.

The purpose of a resource management plan is to establish 

desired outcomes (goals and objectives) and designate 

allowable, restricted, or prohibited uses and actions to achieve 

desired outcomes. Once BLM approves a resource management 

plan then subsequent implementation level decisions are put into 

effect. Implementation decisions are actions that are designed to 

achieve goals and objectives established in the Final EIS and, 

generally, are BLM’s final approval before allowing on-theground actions to proceed. For example, the toolbox for upland 

vegetation treatments includes seeding and planting. Based on 

the goal to provide habitat for sage-grouse and other sagebrush 

obligate species, BLM may propose to seed or plant sagebrush 

in areas where little or no sagebrush exist.

Process The Water Development Map (Map 22 on p. M-23 of the Draft 

RMP/EIS) is what is driving the planning process. BLM 

provides no mapping or any specificity of any kind showing it 

Map 22 “Areas within 1 Mile of Water Developments” in the Draft 

RMP/EIS provided baseline information. The Final EIS does not 

include this map.
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will ever remove a single pipeline or water trough to conserve 

and protect sage-grouse or other wildlife, or slickspot 

peppergrass.

A range of management actions allowing modification and/or 

removal of water developments are incorporated into the action 

alternatives in the Riparian Areas and Wetlands section in 

Chapter 2 of the Final EIS. See management action RI-VI-MA-2. 

Process What is the development of alternatives and analysis of 

impacts throughout the Draft RMP/EIS based on? Is it based 

on percentage of Grassland - Map 9 (p. M-10), or Map 10 (p. 

M-11), the projected 2012 that reflects grass and vast shrub 

less expanses in 2010)? On 33% grassland cover - or 60-70% 

grassland cover? Is it based on deer mice being key 

components of sagebrush guilds?

The Section 2.1.2 (Alternative Development Process) describes 

how and what the alternatives were based on.

Process The Settlement Agreement requires BLM to "Make 

determinations for future management of the planning area, 

consistent with the requirements of the Federal Land Policy 

and Management Act of 1976 (FLPMA), NEPA, implementing 

regulations, and BLM's Planning Manual and Handbook".

By developing alternatives with provisions, and in the case of

Alternatives II, III, portions of IV, and V that are not consistent 

with FLPMA and NEPA in the context of the severely altered 

planning area. BLM has violated the Stipulated Settlement 

Agreement.

BLM is also required to consider information including science 

submitted. Many components of the alternatives are not 

consistent with current ecological science in the context of the 

large-scale habitat losses and population declines for 

sagebrush species in the planning area. Nor in the context of 

the rarity of bull trout, the tiny remnant populations of redband 

trout in the Elk Mountain area, and other beleaguered 

populations. Looming predicted climate change effects magnify

threats, especially in the context of this landscape that has 

suffered such a high degree of disturbance and desertification.

We have provided copious comments throughout this process, 

including comments in meetings with BLM that the Draft 

RMP/EIS was not sufficient to conserve and enhance sagegrouse and other wildlife.

The Final EIS is consistent with the provisions of the 2005 

Stipulated Settlement Agreement (SSA). The SSA required a 

range of alternatives, including a significantly reduced livestock 

grazing alternative. 

The Final EIS set out alternatives that described a range of 

management actions and the anticipated consequences of those 

management actions. Chapter 4 analyses are based on current 

science, which was confirmed after review of the information 

presented by Western Watersheds Project and others during the 

Draft RMP/EIS comment period. Where new studies or policy 

resulted in different management direction the BLM revised the 

analysis in the Final EIS. 

The Draft RMP/EIS developed the alternatives to contrast the 

impacts of various management actions. The alternatives 

themselves were not intended to be exactly what might be 

adopted in the Record of Decision. Alternative VI (Proposed 

RMP) incorporated elements from the other alternatives. The 

Final EIS modified the analysis of the impacts of Alternative VI to 

explain the impacts of the shifts in management direction under 

this alternative.

As noted, the Murphy Complex Fires and other fires have 

changed the landscape since the 2007 Ecological Site 

Inventories. The action alternatives respond to the changed 

conditions by considering management that focuses on the 
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BLM expeditiously conducted the Ecological Site Inventories - 

only to have lands burn up in a whole series of fires.

The Settlement requires that BLM "establish protocols and 

develop data necessary to evaluate current populations and 

habitats for BLM-designated "sensitive" species on the 

Jarbidge Field Office ... "

The Draft RMP/EIS fails to do this for sage-grouse, pygmy 

rabbit, bull trout and other rare, declining and imperiled 

species.

BLM has not developed appropriate "desired outcomes" to 

sustain, conserve and enhance biota and waters.

BLM has not balanced uses or acted to sustain, conserve and 

enhance sage-grouse and other rare biota in identifying lands 

available or not available for livestock grazing. It has not 

adequately incorporated current science on soils, micro crusts, 

vegetation, watershed characteristics, invasive species, 

sensitive and imperiled species, and acted to protect them in 

goals, objectives, and management actions in the alternatives 

by zoning lands open to many forms of exploitation and 

developments. It has failed to develop a sustainable range of 

alternatives and appropriate allocations to address the many 

grave threats that native biota and other important values of 

the public lands face here.

minimization of fire threats (Alternative III), active conservation 

and restoration (Alternatives I and IV), passive conservation and 

restoration (Alternative V) and rehabilitation to support intensive 

commodity use (Alternative II). Each alternative set out general 

direction to achieve desired outcomes with respect to sensitive 

species. Chapter 4 of the Final EIS analyzed those impacts. 

Each alternative included monitoring protocols to assess 

conditions, and to guide management in the planning area. In all 

action alternatives, the BLM uses protocols established under 

the Inland Native Fish Strategy, sage-grouse policies, and other 

more general sensitive species inventory and monitoring 

direction.

For example, in Alternative V, management within Areas of 

Critical Environmental Concern, which encompass 

approximately two-thirds of the planning area, focused on 

restoring native habitat conditions. While the planning area still 

managed for multiple uses, livestock grazing was significantly 

reduced, and land use authorizations for wind energy 

development and mineral extraction were very limited. 

Range of 

Alternatives

The Draft RMP/EIS lists assumptions on page 4-11. One of 

those assumptions is that, “BLM will have the funding and 

workforce to implement the selected alternative.” Stated 

differently, BLM formulated the alternatives based on the 

assumption there would be an unlimited budget for 

implementation of any of the alternatives. This assumption is 

invalid and unrealistic. Given the state of the national economy 

and annual Federal deficit and mounting National Debt, BLM 

should assume there would be no increase in funding beyond 

that needed to maintain the status quo.

This particular assumption is necessary to create a “level playing 

field” for the analysis of all alternatives. 
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Range of 

Alternatives

Table 4-36, on p. 4-84 of the Draft RMP/EIS provides an 

example of an impact rank comparisons (used in a number of 

places in the Draft RMP/EIS) that is entirely inappropriate. 

First, this approach implies an assumed equal value difference 

between the ranks. This is not true. Second, a ranking system 

does not confirm that the relationship of a given rank to the 

ranked resource impact is even significant. Third, a ranking at 

either end of the scale does not confirm that a real and 

significant difference exists. For example, a rank of 7 

representing the highest adverse impact among the 

alternatives may still not represent a significant effect on the 

resource in question or a significant difference with other 

alternatives.

The Final EIS removed this table from the Soil Resources

section of Chapter 4.

Range of 

Alternatives

For goals in Management Common to the No Action 

Alternative and All Action Alternatives, we are referred back to 

the goals in Management Specific in the No Action Alternative 

(of which there are none stated) and Management Common to 

All Action Alternatives. 

The Final EIS corrected this error.

Range of 

Alternatives

BLM fails to assess in its Draft RMP/EIS a range of 

“reasonable alternatives”. The Jarbidge Coalition for MultipleUse met with the BLM and submitted comments and a 

Proposed Action to the BLM, highlighting not only a reasonable 

alternative, but a Proposed Action to be selected or adopted as 

the final RMP.

The Final EIS considered but eliminated the alternative 

submitted by the Jarbidge Coalition, known as the “Friends of 

the Jarbidge Alternative”, from detailed study as a stand-alone 

alternative because it did not meet the purpose and need; 

contained internal inconsistencies; and was inconsistent with 

BLM planning criteria. Many components were incorporated into 

Alternatives I, II, and III.

Range of 

Alternatives

We recommend the following addition/replacement items for 

Alternative II: 

(1) Critical suppression areas defined in Alternative IV. (Goal 

WFM-CA-G-1).

(2) Improve water availability defined in Alternative III. (Goal 

WFM-CA-G-1). 

(3) Manage to increase fire interval defined in Alternative III. 

(Goal FE-CA-G-1).

(4) Fuel treatments within wildland urban interface as defined 

in Alternative III. (Goal FE-CA-G-1).

(5) Fuel breaks would focus on strategic locations as defined in 

Alternative III. (Goal FE-CA-G-1).

(6) Landscape-scale fuels reduction as defined in Alternative 

III. (Goal FE-CA-G-1).

Many of the suggested changes are unnecessary, as the goals 

stated by the commenter are Common to All Action Alternatives. 

The Final EIS analyzed a range of alternatives with specific 

goals and objectives unique to each Alternative. Replacing the 

goals, allocations, and management actions of Alternative II with 

goals, allocations, and management actions from other 

Alternatives would change the intent of Alternative II. This 

change in intent would reduce the range of alternatives. 
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(7) Objective FFE-III-O-3 rehabilitation as defined in Alternative 

III. (Goal FE-CA-G-1).

(8) Habitat for Fish, Wildlife ... Goal UV-CA-G-1, Manage 

vegetation to reduce fire size and ... as defined in Alternative III 

(Goal UV-III-G-1).

(9) Priority for vegetation treatments would be to lengthen fire 

return interval and protect native shrub land as defined in 

Alternative III. (Goal UV-CA-G-1).

(10) Both targeted grazing and fire could be used for 

vegetation treatments as defined in Alternative III (Goal UVCA-G-1).

(11) Fire tolerant/resistant species for upland vegetation 

treatments as defined in Alternative III. (Goal UV-CA-G-1).

(12) Livestock Grazing-provide for livestock grazing through 

the proper grazing management to reduce wildland fire size as 

defined in Alternative III. (Goal LG-III-G-1).

(13) Livestock Grazing - Allow Temporary Non-renewable 

Authorizations to meet specific project management objectives 

as allowed under Alternative III.

(14) Range Infrastructure - construct new infrastructure to help 

meet both fire suppression and resource management 

objectives as stated in Alternative III.

(15) Land Use Authorizations include consideration of wildland 

fire prevention and suppression objectives.

Range of 

Alternatives

Unfortunately, the Draft RMP/EIS fails to include a reasonable 

range of alternatives to address BLM’s mismanagement of the 

range and policies set to maximize commercial livestock 

grazing at the expense of the public and Federally protected 

wild horses. Instead, the Draft RMP/EIS promotes land use 

plans that perpetuate intensive resource extraction and the 

development status quo.

The Final EIS analyzed a range of allocations for the Wild Horse 

Appropriate Management Level. Under the Federal Land Policy 

and Management Act of 1976, BLM manages public lands under 

the principles of multiple use and sustained yield. Managing use 

by cattle and sheep, together with wildlife and wild horses and 

burros, and a host of other uses is part of BLM’s multiple-use 

mission. The regulations at 43 CFR 4710.3-2 provide that Herd 

Management Areas may be designated to be managed 

principally, but not necessarily exclusively, for wild horse or burro 

herds. The Saylor Creek Herd Management Area has not been 

designated for principal or exclusive use by wild horses. 

Alternative VI (Proposed RMP) would implement a balance 

between wild horses and other resource uses based on the 

analysis of the Draft RMP/EIS and public comment.
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Range of 

Alternatives

Despite repeated comments by the Western Watersheds 

Project and others throughout this process, and the BLM's own 

analysis of the management situation showing the ecological 

disaster for antelope, sage-grouse, and other values of the 

extremely high fence densities in the planning area. The BLM 

has structured all of its alternatives around allotment fences 

being immutable. There is no alternative that shows fence or 

other project removal and reconfiguration based on a plan to 

conserve sage-grouse.

Management actions designed to conserve sage-grouse by 

allowing removal, modification, and marking of fences have been 

included as common to all action alternatives. See LG-CA-MA13, LG-CA-MA-16, and SS-CA-MA-12. SS-VI-MA-5 allows for 

other project specific removal.

Range of 

Alternatives

In Scoping, the Western Watersheds Project submitted an 

Alternative in a format/template style that BLM required at the 

time. We submitted many comments that relied on both active 

and passive restoration and a conservation centered 

management paradigm. Yet, BLM did not fully consider our 

concerns in the limited and industry-centered near-status quo 

alternatives of the flawed and inadequate Draft RMP/EIS. 

The Final EIS considered but eliminated the alternative 

submitted by the Western Watersheds Project, known as the 

“Habitat Restoration Alternative”, from detailed study as a standalone alternative because it did not meet the purpose and need; 

contained internal inconsistencies; and was inconsistent with 

BLM planning criteria. Many components were incorporated into 

Alternatives IV and V.

Range of 

Alternatives

There is no commitment by the BLM to recover degraded 

ecological conditions.

The Final EIS analyzed a range of alternatives that contained 

goals and objects for restoration and recovery of the planning 

area. Alternative VI (Proposed RMP) commits to recover 

degraded ecological conditions. For example, the Upland 

Vegetation section describes both the current and desired 

number of acres in each Vegetation Sub-Group (VSG) by 

Vegetation Management Area (VMA). Management actions 

describe restoration priorities and treatments designed to 

achieve objectives (i.e., desired number of acres in each VSG by 

VMA).

Range of 

Alternatives

Just include a "plant shrubs" provision in Alternative V, and the 

direction of the change arrow would change! BLM has 

purposefully constructed alternatives to bias the outcome 

towards Alternative IV that will not conserve sage-grouse.

The Final EIS analyzed a range of alternatives. In Alternative V, 

non-native and native shrubland communities would not be a 

focus for active restoration treatments. By changing Alternative V 

to include a “plant shrubs” provision as suggested would change 

its intent and reduce the range of alternatives analyzed. 

Alternative VI (Proposed RMP) is designed to conserve sagegrouse by actively restoring and connecting habitat.

Range of 

Alternatives

BLM must develop a broad range of new alternatives, and 

project the outcomes of key and identified Idaho Fish and 

Game restoration sage-grouse habitat under all of them. 

Provide a full set of actions to minimize disturbance, and 

conserve and enhance habitats for sustainable populations. 

Provide a time frame of efforts made to achieve restoration and 

The Upland Vegetation section describes both the current and 

desired number of acres in each Vegetation Sub-Group (VSG) 

by Vegetation Management Area (VMA). Management actions 

describe restoration priorities and treatments designed to 

achieve objectives (i.e., desired number of acres in each VSG by 

VMA). Specific time frames for achieving the objectives were not 
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disturbance-minimization goals. identified because meeting restoration goals is dependent on a 

number of factors beyond the BLM's control (e.g. wildfire may 

burn an area restored 8 years ago which would delay the 

achievement of the goal; or severe drought may result in the 

failure of a recently restored area; etc.). Alternative VI (Proposed 

RMP) is designed to conserve sage-grouse by actively restoring 

and connecting habitat.

Range of 

Alternatives

Utility avoidance in Alternative V plus the Saylor Creek Herd 

Management Area with a five-mile buffer should be a minimum 

alternative. Provide a range of several more protective 

alternatives.

The Final EIS analyzed a range of alternatives with different 

right-of-way avoidance/exclusion areas and resource protection 

measures. The Final EIS did not analyze utility avoidance in 

Alternative V plus the Saylor Creek Herd Management Area with 

a five-mile buffer, as there was no explanation as to how the 

buffer would achieve resource objectives. 

Recreation Dispersed campsites and very desirable campsites should 

remain open. Limiting dispersed camping to 25 feet off the 

road is unacceptable and would close many of the desirable 

camping locations in the planning area. Closing these camping 

sites due to perceived resource damage is unacceptable. 

The Final EIS analyzes a reasonable range of alternatives. 

Alternative VI (Proposed RMP) address the specific issue of 

dispersed camping by allowing it within 100 feet of the centerline 

of the road (TR-VI-MA-5). Resource impacts or environmental 

conditions may warrant the closure of dispersed campsites.

Recreation The BLM must propose a range of alternatives that manages 

motorized uses in the planning area. The alternatives should 

range from no areas open to cross country travel, to the whole 

planning area being open to cross country travel. These 

alternatives should also consider restricting or allowing other 

activities and uses, such as livestock grazing in open area 

designations. 

The Final EIS analyzed various locations and sizes of areas 

open to off-road motorized use in the range of alternatives. 

Alternative VI (Proposed RMP) does not exclude livestock 

grazing from areas open to cross country travel.

BLM Manual 1626, Travel and Transportation Management 

(2011) directs designation of open areas to be; (1) Limited to a 

size that can be effectively managed and; (2) Expansive open 

areas allowing cross-country travel, without a corresponding and 

identified user need or demand will not be designated in RMP 

revisions or new travel management plans. The 1626 Manual 

also states that retention or designation of large areas open to 

unregulated cross-country travel is no longer a viable 

management strategy. Boundaries of the proposed open areas 

were identified to provide the opportunity for traditional and 

future recreational values while protecting sensitive resource 

values (i.e., wild horses, wildlife, and special status plants).

Recreation We must have more access for all users and shared access for 

all users, or at least equal access for all users. Motorized users 

must have access to and more trails of multiple use or limited 

to motorize use only designation.

The Final EIS analyzed various levels of motorized use in the 

range of alternatives. The Chapter 2 Transportation and Travel

sections describe the allocations for transportation and travel by 

alternative.
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Recreation Adequate recreational opportunity for all visitors is an issue 

that must be addressed in this document. Most environmental 

documents have not taken into consideration the fact that 

motorized multiple use designation serves all recreation 

activities, instead of the few served by nonmotorized/wilderness designations. The Recreation 

Opportunity Spectrum for motorized recreationists should 

consist of an equivalent number, type and quality of 

opportunities as compared to non-motorized recreationists 

including access to back country recreation areas, long 

distance back country discovery routes, back country airstrips 

and destinations including historic areas, lakes, vistas, streams 

and rivers.

Appendix H: Recreation Management Areas was developed to 

show the existing and expected recreation type and quality of 

opportunities in the planning area. The Final EIS used this 

information.

Recreation Land management agencies must acknowledge that public 

land has significant meaning and socio-economic value to the 

public. The relative importance of recreation on a national 

basis is demonstrated by the Bureau of Economic Analysis 

statistics for spending on recreation. In 1979 the index for 

recreation spending was 32.537. In 2004, the index was 

113.695 for an increase of 349%. No other sector has 

increased this dramatically. Off-highway vehicle recreation and 

tourism could be a significant boost to many local economies. 

The Final EIS revised information on economic contributions 

from recreation in the planning area. 

Recreation We request that the BLM provide an adequate and fair 

evaluation of all existing routes including those meeting 

National Off-Highway Vehicle Rule guidelines and currently 

closed routes.

The National Off-Highway Vehicle Rule applies to National 

Forest System Lands managed by the US Forest Service. With 

the exception of Wilderness, US Air Force lands, other agency, 

or private lands, there are no closed routes in the planning area.

Recreation The cumulative effect of all motorized closures has been 

significant and is growing greater every day, yet they have not 

been adequately addressed. The Jarbidge RMP/EIS must 

include adequate evaluation of cumulative effects so that 

motorized recreation will not be removed from our public lands.

An adequate evaluation of cumulative effects would include all 

past, current, and reasonably foreseeable actions that have or 

will produce motorized closures.

Cumulative impacts analysis for open, limited, and closed 

motorized travel allocations within the planning area was 

included in the Final EIS. Travel management planning will occur 

following the signing of the Record Of Decision. The travel 

planning process will complete a cumulative impacts analysis. 

Recreation The environmental analysis must adequately address the 

human environment including issues, needs, alternatives, and 

impacts on the public associated with the reduction or lack of 

adequate motorized recreation. An adequate analysis would 

include evaluation of social, cultural, historical use, current use, 

Analyses of direct and indirect impacts to recreation and travel 

are contained in Chapter 4. 
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future needs, economic impact, and quality of the human 

environment issues from the perspective of motorized 

recreationists. The BLM cannot assume that the impacts are 

adverse in nature.

Recreation Consider a true pro-recreation alternative and pro- off-highway 

vehicle alternative that maximize opportunity in the planning 

area. This alternative should include open areas that can 

expand with increased demand and that mitigate the impacts 

on the public from the loss of motorized access and motorized 

recreational opportunities.

The Final EIS analyzed a reasonable range of alternatives. 

Alternative I included the largest component of active recreation 

management. All of the alternatives provide for continued 

motorized recreation in a variety of settings, experiences, and 

challenges. The range of alternatives also included maintaining 

existing or increasing motorized route use. 

Recreation The BLM must use the most current numbers on off-highway 

vehicle (OHV) use and recreation activities in the planning 

area. This would include use of primitive roads and trails and 

numbers of OHV registrations.

The Final EIS used Idaho off-highway vehicle (OHV) registration 

numbers and regional trend data for OHV use. The Recreation

sections of Chapter 3 and 4 in the Final EIS contain this 

information. 

Recreation We request that the BLM develop and implement screening 

procedures to identify influence groups with annual budgets 

greater than $100,000.

The goal of this program would be to assure that the decision 

produces a wide sharing of resources and life’s amenities. 

These additions to the planning process are needed to restore 

the basis of public benefit and are needed to remove the 

political influence that has obscured public benefit and needs 

from the current process.

Developing and implementing a screening procedure to identify 

influence groups with annual budgets greater than $100,000 is 

beyond the scope of this planning effort.

Recreation Sadly, one indicator of the condition of the human environment 

in Montana is the suicide rate. Montana ranks number 2 in the 

nation. This significant problem has been specifically identified 

as requiring special attention by the Department of Health and 

Human Services. Motorized recreation is popular and it is a 

very healthy and positive human activity that can help address 

this significant human issue. The BLM can help address this 

significant problem by providing an adequate quantity and 

quality of motorized recreational opportunities. We ask that you 

adequately address this significant issue associated with the 

human environment.

There is no information to support that the suicide rate in 

Montana is influenced by motorized recreation or the lack of 

access to motorized recreation. The BLM acknowledges the 

relationship between quality of life and recreational opportunities 

provided for by the planning area.

Recreation The use of off-highway vehicles (OHVs) for cross-country 

travel should be considered. In areas that cross-country travel 

is not allowed the BLM should implement route designation 

with the following in mind: 

Designated roads, routes, and trails should be marked on 

Travel management planning will perform a more thorough sitespecific review of travel routes. This effort will include field data 

collection and verification and will take into account the concerns 

of the public when developing a designated road and trail 

system. 
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maps.

Routes and trails should be designated for different types 

of vehicles and different skill levels.

The OHV designated trail system must be adequate for 

current and future use.

Single-track routes should be included in the OHV trail 

system. We encourage looking at the use of cow trails as 

possible single-tracks for motorcycle use.

Route sharing between motorized and non-motorized 

users should be encouraged.

Creating new routes and providing for loops over cherry 

stems must be looked at.

Routes that provide access to wilderness boundaries, 

historic use areas, and historic cabins should be given 

priority for designation.

Designated routes should avoid riparian areas and other 

areas of high resource concern, (Slickspot peppergrass 

habitat, bull trout habitat, cultural sites, etc.).

Site-specific analysis should look at impacts from different 

uses and modes of travel instead of treating all OHVs as 

having the same impacts.

Recreation We request careful consideration of the multiple-use needs of 

the public and implementation of the objectives of multiple-use 

laws and policies as part of the proposed action. Motorized 

recreationists have been losing ground starting with the 

wilderness designations in the 1960’s and continuing on with 

the Roadless rule, forest plans, resource management plans 

and travel plans. Non-motorized recreationists can use an 

infinite amount of cross-country opportunity and motorized 

recreationists cannot. Data shows more motorized recreation 

occurs on public land than non-motorized recreation, yet there 

is an imbalance of opportunities in favor of the non-motorized 

recreation opportunities.

While we do not support segregation, if segregation is to be 

implemented on multiple-use lands then a corresponding goal 

would be to demonstrate a perfect 50/50 sharing of nonmotorized and motorized trails as part of that segregation.

The Final EIS does not propose any segregation of motorized 

and non-motorized areas. In travel management planning, the 

BLM is required to plan for a wide variety of uses (including uses 

for recreational, traditional, authorized, commercial, educational, 

and other purposes), as well as all forms of motorized and nonmotorized access or use, such as foot, pack stock or animalassisted travel, mountain bike, off-highway vehicle, and other 

forms of transportation. 

The Final EIS is a multiple use plan that provides a range of 

alternatives which allow a wide variety of resource uses (e.g., 

outdoor recreation, minerals extraction, and livestock grazing) 

while meeting statutory and regulatory requirements for the 

protection of natural, biological, and cultural resources. Special 

Recreation Management Area (SRMA) designation provides 

focused management of recreation activities due to historical, 

present, and future recreational use trends. This focused 

management is intended to preserve the setting and recreational 
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experience of the area. SRMA designation does not exclude one 

recreation use over another recreation uses.

Recreation We are concerned that all sediment runoff into streams is 

blamed on off-highway vehicle (OHV) activities. An 

understanding of the background sediment yield needs to be 

known before the finger is pointed at OHV recreation. Many 

things contribute to sediment yield (i.e. fire). Water bars at a 

reasonable spacing is a very effective way to reduce the 

sediment discharge from trails and roads, and many other best 

management practices are available.

The cumulative impacts analysis for aquatic resources (fish, 

special status fish and aquatic invertebrates, water resources 

and riparian areas and wetlands) all acknowledge there are 

many human uses and activities that contribute to the existing 

condition of aquatic resources in the planning area. There are 

natural sources of sediment that also have an additive effect on 

stream and riparian conditions. The environmental baseline 

includes these sediment sources. The travel planning process 

will further analyze sediment and erosion potential. The travel 

planning process will address maintenance levels and road 

development standards using management actions and best 

management practices for travel routes as guidance.

Recreation Please provide an analysis that incorporates the following data 

in the Final EIS analysis. This will help the BLM adequately 

evaluate and disclose motorized and non-motorized 

recreational resource and opportunity information to the public.

Miles of roads, routes, and trails.

The different uses allowed on roads, routes, and trails.

The current and expected future use by motorized and 

non-motorized users on roads, routes, and trails.

Amount of cross-country opportunity available to motorized 

and non-motorized users.

Peer-reviewed literature must support the analysis. 

Table 4-301, Travel Designations by Alternative (Acres), displays 

the off-highway vehicle (OHV) allocations proposed in the Final 

EIS. Analysis completed in the Final EIS used the best science 

available. Peer-reviewed science and methodology had greater 

consideration over that which was not peer-reviewed. The travel 

planning process will use specific data related to miles of OHV 

trails closed, open, limited, and the percent of motorized and 

non-motorized recreation opportunities in its analysis.

Recreation Because of the significant impacts on motorized recreationists 

that are being proposed as part of the Jarbidge Resource

Management Plan and because of the significant cumulative 

effect on motorized recreationists of all past and reasonably 

foreseeable motorized closures, the proposed action is beyond 

the scope of an environmental assessment and an 

environmental impact statement must be prepared.

An EIS supports the Jarbidge Resource Management Plan.

Recreation We request that the Jarbidge Resource Management Plan 

Revision follow the intention of the final Off-Highway Vehicle

Route Designation rule and that the rule not be used 

inappropriately as an action to create wholesale-motorized 

closures and a wholesale conversion of motorized to nonmotorized routes.

The Off-Highway Vehicle Route Designation rule is applicable to 

US Forest Service lands. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Recreation Idaho’s Trail Ranger program combined with cooperative 

management of National Forest lands provides over 9,000 

miles of trail riding opportunities. We ask that this project adopt 

a similar goal.

After Travel Management Plan development, the BLM will 

pursue cooperative management agreements and develop 

volunteer programs.

Recreation When developing travel management alternatives the agency 

must recognize the public’s desire to keep existing 

opportunities open. We suggest the following:

Start with a comprehensive inventory of all existing 

motorized routes in use by the public. 

The BLM should look for management alternatives that 

provide for mitigation of impacts instead of closure. 

The public must be involved.

Use the Forest Service-643 Roads Analysis Manual in 

order to adequately account for the social, economic, 

cultural, and traditional values that motorized roads and 

trails provide to the public.

Work with adjoining Federal agencies to make a better trail 

system.

Include signing, maps, and brochures.

Avoid alternatives, or management guidance, directives 

etc. that require closure as the first or only option in 

reducing identified resource impacts.

The BLM should carefully consider displaced use. 

Consider road closures in areas important to resources 

such as slickspot peppergrass.

A public process, during travel management planning, will help 

facilitate the development of the transportation and travel system 

for the planning area. The Travel Management Plan will 

determine the routes and trails to be designated, modified, 

closed, or rehabilitated as well as the maintenance level, modes 

of travel, and seasonal and access restrictions for designated 

routes (TR-CA-MA- 5). This includes analysis of road and trail 

connectivity with adjoining Federal lands.

The travel management planning analysis will use existing roads 

and trails as the network to start the travel and transportation 

designation process. Public input will help determine use 

restrictions and route configurations in this plan. 

The travel planning process will use various BLM documents to 

evaluate and designate roads and trails, not US Forest Service 

documents. The travel planning analysis will use the BLM Roads 

and Trails Terminology Report and Planning and Conducting 

Route Inventories (BLM Technical Reference 9113-1).

Recreation Analysis of motorized recreation opportunities within a 

reasonable distance from the users must use reasonable 

indicators. These indicators could include documented user 

conflicts, cumulative effects of this motorized closure combined 

with all other motorized closures, existing motorized recreation 

opportunities, and the need for expanding those opportunities. 

These are good considerations for use in the development of the 

travel management planning process. Until implementation level 

travel planning occurs, a comparison of impacts from closures, 

additions, or route density to other resources cannot be 

analyzed.

Recreation The document and decision must clearly disclose on maps, 

tables, and summaries all existing roads and trails that would 

be closed to motorized access and motorized recreationists. 

The only motorized vehicle closures in Alternative VI (Proposed 

RMP) are for the Bruneau-Jarbidge Rivers Wilderness, Salmon 

Falls Creek Area of Critical Environmental Concern, and Lower 

Salmon Falls Creek Wilderness Study Area (WSA). Statute 

closed the Bruneau-Jarbidge Rivers Wilderness to motorized 

travel. The 1987 Jarbidge RMP closed the roadless areas of the 

Lower Salmon Falls Creek WSA and Salmon Falls Creek Area of 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Critical Environmental Concern to motorized travel.

Recreation Considered all available mitigation measures before closing 

routes with environmental concerns. We strongly support 

mitigation before motorized closure and, in fairness to the 

public, encourage the agency to adopt this policy also.

The travel planning process will designate routes along with 

maintenance levels and rehabilitation requirements (TR-CA-MA5).

Recreation We are asking for continued use of routes, including those 

defined by; the 3-State Off-Highway Vehicle decision and route 

definitions, 2477 roads, and other valid agreements, and 

Memorandums of Understanding with local highway districts.

The validations of R.S. 2477 rights are determined through a 

process that is entirely independent of the BLM's planning 

process. The 3-State Off-Highway Vehicle Record Of Decision

covered BLM lands in Montana, North Dakota, and South 

Dakota but not Idaho. The BLM will, as stated in TR-CA-MA-3, 

“Continue to recognize valid agreements and Memoranda of 

Understanding with local highway districts for road 

maintenance.”

Recreation There is also a significant public safety aspect associated with 

squeezing everyone into a small area, as accidents will 

increase with too many motorized recreationists on too few 

routes. 

Safety and resource impacts will be included in the route 

analysis during the travel management planning process.

Recreation There are no identifiable or named features and no road and 

trail numbers on the maps. It is very difficult for the public to 

orient themselves and to interpret the proposed action for each 

specific road and trail. Therefore, the public cannot adequately 

evaluate the proposal and cannot develop comments with 

reference to specific roads and trails.

The Final EIS revised the Travel Designation maps (Map 72 to 

78) to include the names of major routes in the planning area. 

Designation of roads and trails will occur during travel planning 

process.

Recreation Education should be the first line of action before pursuing 

other actions. Educational programs could include use of 

mailings, handouts, improved travel management mapping 

(that includes route depiction and skill level for route), 

pamphlets, TV, and radio spots, web pages, newspaper 

articles, signing, presentations, sign-in and information kiosks 

with mapping, and trail rangers.

The travel plan will determine roads and trails to be designated, 

modified, closed, as well as maintenance levels, modes of travel, 

and seasonal and access issues. Public education through 

signing, mapping, sign-in and information kiosks, and user 

contact will be necessary to develop stewardship of the BLM 

lands in the planning area. Education and interpretation program 

enhancement will occur during implementation projects after the 

completion of the RMP.

Recreation We request that the document make a fair evaluation of all 

sources and uses that contribute to the noxious weed problem 

including hikers, mountain bikers, equestrians (non-use of 

weed-free hay), etc. The document should also fairly evaluate 

how natural processes and wildlife spread noxious weeds. 

Chapter 3 of the Final EIS establishes a baseline of information 

for noxious weeds. Chapter 3 also includes a brief section on 

mechanisms that may spread noxious weeds or invasive 

species. Chapter 4 provides an analysis of each alternative on 

noxious weeds. 

Recreation Site-specific science based monitoring of motorized versus 

non-motorized use must be conducted to comprehend impacts.

Site-specific monitoring of motorized versus non-motorized use 

for each route is beyond the scope of this planning effort. 

Development of the Travel Management Plan will include 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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monitoring elements to determine the effectiveness after 

implementation. Monitoring needs may include:

Maintenance needs, 

Safety issues, 

Impacts to sensitive resources, and

Signing and kiosk condition and placement. 

These monitoring elements would pertain to travel allocations: 

Open, Limited, and Closed.

Recreation Independent scientist should review and participate in all 

aspects of planning, broad-based assessments, local analysis, 

and monitoring.

Scientists may come from within Federal or State agencies, or 

the public, and may hold a variety of important and influential 

positions. 

The RMP planning process included the invitation of a number of 

State and local government agencies to participate as 

cooperating agencies. Representatives from Idaho Department 

of Fish and Game, Idaho Department of Lands, Idaho 

Department of Parks and Recreation, and Idaho State 

Department of Agriculture participated as members of the 

Jarbidge RMP Interdisciplinary Team. The Owyhee County 

Commissioners participated in the Jarbidge RMP through their 

existing coordination agreement with the Twin Falls District. 

Recreation If a private property owner closes a historic motorized access 

or route to public land through their property, then in order to 

be fair, to avoid special privileges; the public routes should be 

closed at the private property line to all motorized use and, 

where the route has access from the other end on public land, 

it should remain open so that it can provide an out and back 

motorized opportunity.

To provide access to public land the BLM may try to obtain 

access across private land. Travel planning will identify these 

routes. See LA-CA-MA-10.

Recreation We are concerned with the way that comments are being used 

by agencies in the decision-making process. Agency 

management has said that the total number of comments 

received during the process is considered during the decisionmaking. There is a clear indication that decisions are being 

made based on those interests producing the most comments. 

We strongly disagree with a decision-making process using 

comments as a voting process.

The BLM reviewed each comment letter received on the Draft 

RMP/EIS. Each substantive comment was responded to, either 

by modifying one or more of the alternatives as requested; 

developing and evaluating suggested alternatives; 

supplementing, improving, or modifying the analysis; making 

factual corrections; or explaining why the comments do not 

warrant further agency response, citing cases, authorities, or 

reasons to support the BLM’s policy and guidelines. The BLM 

did not consider “vote” comments substantive. 

Recreation We request that the adverse impact on the majority of the 

public resulting from the lack of information, education, training, 

understanding and acceptance of the NEPA process be 

evaluated and that the cumulative adverse impacts on the 

public be adequately mitigated.

Analyzing the adverse impact on the majority of the public 

resulting from the lack of information, education, training, and 

understanding and acceptance of the NEPA process is beyond 

the scope of this planning effort.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Recreation Designation of more wilderness should not take place. It is 

closed to motorized vehicles and equipment and therefore, 

multiple-use lands should be open to motorized vehicles and 

equipment. Wilderness criteria and standards should not be 

applied to multiple-use lands.

Wilderness designation is a function of Congress. Wilderness 

accounts for less than 5% of the planning area. Travel criteria 

and standards for wilderness, except closed, are not applied to 

other BLM lands.

Recreation We request that the proposed action adequately address and 

comply with the recommendations of the study conducted to 

address P.L. 105-359 including items 1 and 7.

The Final EIS incorporated all regulations, laws, and BLM 

policies. 

Recreation We are concerned about the loss of access and impact on the 

handicapped, elderly and physically impaired produced by 

each motorized closure to historic sites and traditional use 

areas. We strongly urge you to manage these lands in a way 

that provides recreation for the disabled in accordance with the 

Americans with Disabilities Act.

A public process, during travel management planning, will help 

facilitate the appropriate travel and transportation system for the 

planning area. The design and layout of routes and recreation 

facilities during project implementation will take into 

consideration the access needs of physically impaired public 

land users. The BLM Travel and Transportation Manual (1626) 

states; "Wheelchair and mobility devises, including those that are 

battery-powered, that are designed solely for use by a mobilityimpaired person for locomotion and that are suitable for use in 

an indoor pedestrian area are allowed in all areas open to foot 

travel. There is no legal requirement to allow people with 

disabilities to use motor vehicles on roads, primitive roads, or 

trails and in areas that are closed to motor vehicle use. 

Restrictions on motor vehicle use that are applied consistently to 

everyone are not discriminatory."

Recreation Along with the standardization of signs, there is also a 

significant need to standardize or simplify seasonal closure 

dates as much as possible. We suggest that the number of 

different closures periods should be kept to a maximum of two, 

if possible, in order to avoid confusion and resulting 

misunderstandings.

The travel planning process will analyze seasonal and access 

closure periods.

Recreation The Draft RMP/EIS refers to potential conflicts of passive and 

active users of public lands; however, the draft RMP does not 

express specifically the numbers of user conflicts from 1987 to 

2007. Can the BLM provide current data to show the amount of 

user conflicts or is there no user conflict?

The planning area has documented reports of user conflicts 

during the last 15 years. These reports include concerns for 

noise related to off-highway vehicles (OHV) and adjacent private 

lands, livestock fencing gates being left open and careless OHV 

operators near county roads. The travel planning process will 

consider these documented user conflicts.

Recreation Consider winter All-Terrain Vehicle areas as part of the 

proposed action.

The travel planning process will evaluate the season of use and 

modes of travel for the roads and trails within the planning area.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Recreation We request that the BLM involve motorized recreation planners 

and enthusiasts in order to adequately speak for the needs of 

multiple-use and motorized visitors. NEPA encourages direct 

coordination with the impacted public. Many comments by 

motorized recreationists are being dismissed by the agency as 

not being substantive. The NEPA process should have been 

an issues driven process and the significant issues should be 

those that have the greatest impact on motorized 

recreationists. We request that the EIS address all of the 

significant issues that affect motorized recreationists.

The public scoping process identified recreation as a planning 

issue. This issue covered all forms of recreation activities 

including motorized. The Final EIS included the topics of both 

motorized and non-motorized recreation. The Travel 

Management Plan will include a more detailed analysis of travel 

routes and subsequent route designation. 

Members of the Jarbidge RMP Team conducted briefings and 

presentations on the Jarbidge RMP revision process to the 

following off-highway vehicle (OHV) groups: Idaho All-Terrain 

Vehicle (ATV) Association Inc., Magic Valley ATV Riders, Inc., 

Magic Valley Trail Machine Association, Southern Idaho Desert 

Racing Association, and Treasure Valley Trail Machine 

Association. We also contacted other OHV groups in the RMP 

scoping process, including Blue Ribbon Coalition, Boise ATV 

Trail Riders, Mountain Home ATV Club, Southern Idaho OffRoad Association, and Wild West Off Roaders.

Recreation The agency can no longer ignore that motorized access and 

recreation are the largest and fastest growing group of visitors 

to public land. The Draft RMP/EIS evaluation must adequately 

consider the growing popularity of motorized recreation, the 

aging population and their needs for motorized access, and the 

increased recreation time that the aging population has and 

looked forward to enjoying public lands in their motor vehicles.

The BLM used national and regional off-highway vehicle trends 

in the Recreation and Transportation and Travel sections for 

each alternative in the Final EIS.

Recreation The BLM would like to limit group size to less than 30 and 

require 30 or more to acquire a special recreation permit. BLM 

requires that application be submitted 180 days before date of 

event. Please raise the group size.

The Final EIS has presented a reasonable range of alternatives 

on group size requiring a permit. Alternative VI (Proposed RMP) 

places the determination of issuing an organized group permit 

under the discretion of the authorized officer. The authorized 

officer will take into account the type, location, size, and intent of 

the organized group or proposed event when determining 

whether to require an organized group permit. Management 

action REC-VI-MA-13 does not specify group size. 

Recreation Recreation user should replace the words “non-motorized” in 

the RMP.

The terms motorized and non-motorized recreational user 

generally refer to the types of travel related to recreation 

opportunities.

Recreation We actually need many more trails and campgrounds to 

accommodate the growing number of outdoor recreationalists, 

not reduce the amount.

The Final EIS analyzed a range of alternatives that provided 

varying levels of access and other recreational opportunities 

while providing a balance between resource use and resource 

values.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Recreation The RMP establishes Travel Management Areas, Special 

Recreation Management Areas, Areas of Critical

Environmental Concern, Wilderness Study Areas, Wild and 

Scenic Rivers, Lands with Wilderness Characteristics and 

many other special designations that focus to restrict and 

prohibit multiple uses in these areas. Special designations are 

not required to properly manage the specific areas. The 

elimination of special designations would provide for all 

multiple uses and not prohibit or exclude any public uses.

The Final EIS incorporates new policy (BLM Manual 8320, 

Planning for Recreation and Visitor Services) which has three 

categories of allocation for Recreation Management Areas 

(RMAs): Special Recreation Management Areas, Extensive 

Recreation Management Areas, and public lands not designated 

as RMAs. 

Current BLM policy does not allow any new recommendations 

for Wilderness Study Areas (WSAs) designation and only 

Congress can designate wilderness areas. The Final EIS revised 

designations of Areas of Critical Environmental Concern and 

Lands with Wilderness Characteristics to reflect new policy, 

developing environmental concerns, and comments received 

through public review of the Draft RMP/EIS.

Multiple uses of the land are allowed by the Final EIS but all 

uses may not be compatible on every inch of ground. Special 

designation may exclude some uses but, those uses could be 

allowed elsewhere. WSA management adheres to previous 

legislation and subsequent policy. The development of a 

wilderness management plan will outline management direction

for wilderness within the planning area.

Recreation Please provide a definition of Dispersed Recreation. The Final EIS updated the glossary with the term “Dispersed 

Recreation”.

Recreation All types of recreation including both motorized and nonmotorized recreation have some sort of resource impact. The 

key to reducing those impacts is actively managing the 

recreation resource. Amend the goal to read, "Provide a variety 

of dispersed and developed recreation opportunities and 

experiences for visitors and residents while sustaining the 

recreation resource based and managing for resource 

impacts."

The Final EIS revised REC-CA-G- 1 based on public comment.

Recreation Management action REC-IV-MA-6 gives priority for 

authorization of Special Recreation Permits (SRP) for events to 

applicants proposed to make use of less crowed weekdays. 

Most recreation events are held on weekends because this is 

when most event participants have time off work to compete in 

the event. Prior performance of the permit holder should 

provide priority for SRP authorization. Those permit holders 

Alternative VI (Proposed RMP) removed weekday priority for 

Special Recreation Permits. See REC-VI-MA-11. 
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that have a good record of applying for and keeping the terms 

of the permit should be the ones that have priority. Weekdays 

should not receive priority.

Recreation How can BLM assume that recreational use will not increase 

over the next 20 years? 

The commenter is referring to the statement on p. 4-472 of the 

Draft RMP/EIS, which states, “...recreation use in the BruneauJarbidge and Jarbidge Forks Special Recreation Management 

Areas is not expected to increase...” This assumption is based 

on the existing and historical use of these areas, which is limited 

due to access, and season of use periods.

Recreation We are greatly concerned that expanded off-highway vehicle 

(OHV) torn-up areas will adversely impact native reptiles. Bare 

soil areas and some semblance of native shrubs are found in 

areas of hillier terrain and specific soils where OHV use is now 

being greatly imposed.

The travel management planning process and the subsequent 

monitoring plans will analyze motorized uses, including the use 

of off-highway vehicles. 

Reference 

Areas

Riparian exclosures, like the upland vegetation exclosures, will 

add very little value to the management of the planning area. In 

addition, numerous riparian areas currently exclude livestock 

grazing and these existing exclosures are fully capable of 

illustrating the effects from livestock. Because of this lack of 

value, exclosures should be restricted to the smallest number 

and size possible.

The Final EIS included a range of number and size of reference 

areas in compliance with the 2005 Stipulated Settlement 

Agreement. The Chapter 2, Alternative VI (Proposed RMP), 

Riparian Areas and Wetlands section (RI-VI-MA-4) identified the 

creation of 10 ungrazed riparian reference areas, encompassing 

up to 3,000 acres. The Final EIS, Maps 11 to 15, identified 

potential locations for the reference areas.

Reference 

Areas

In the Draft RMP/EIS, Chapter 2, RI-CA-G-1, it is not clear how 

riparian areas and wetland reference areas were determined.

The Final EIS was revised to include a description of the process 

used to identify riparian reference areas. Appendix O also 

contained this information. The Final EIS selected riparian 

reference areas from the Category 1 streams identified in the 

Aquatic and Riparian Management Strategy (Appendix D). 

Reference 

Areas

The Draft RMP/EIS provides no monitoring requirements for 

reference areas. The RMP does not provide actions that will 

occur if monitoring shows adverse impacts.

The Final EIS provided for the development of a reference areamonitoring plan in which specific monitoring requirements will be 

determined. At a minimum, the BLM would use the Idaho 

Standards for Rangeland Health and Guidelines for Livestock 

Grazing Management.

Reference 

Areas

BLM must close entire pastures or allotments for reference 

sites; otherwise the burden of fencing in this tragically 

industrialized landscape becomes even greater. The Stipulated 

Settlement Agreement says that the reference areas are to 

allow comparisons for future evaluations of livestock grazing. 

Therefore, there is no need for fencing of these areas in lands 

that will be closed to livestock.

The Final EIS analyzed a range of alternatives for reference area 

number, size, and locations. Reference areas in Alternative V 

include pasture sized reference areas. Refer to Map 14, 

"Potential Reference Areas in Alternative V”.
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Reference 

Areas

Due to the large amount of evidence of adverse impacts of 

fences to sage-grouse, BLM must set aside existing pastures 

as reference areas.

The Final EIS analyzed a range of Alternatives that included 

pasture size reference areas. Reference areas in Alternative V 

include pasture sized reference areas. Alternative VI (Proposed 

RMP) proposed up to 52 40-acre upland reference areas. 

Reference 

Areas

Where are all lands that BLM currently considers reference 

areas? All lands in good, better, or reference conditions? 

Identify these lands.

Currently, no reference areas exist. The Stipulated Settlement 

Agreement (SSA) required the BLM to identify, maintain, and/or 

establish ungrazed reference areas in both upland and riparian 

settings that represent a variety of ecological components, 

vegetation types, and elevational gradients. The Final EIS 

analyzed a reasonable range of alternatives to meet the SSA 

requirements.

Rights-of-Way On p. 2-169, the Draft RMP/EIS does not, but should, contain 

language that would incentivize use of the designated utility 

right-of-way (ROW) corridors, thereby limiting the protective 

impacts of the utility ROW corridors.

See LA-CA-MA-1 in the Final EIS. This management action 

stated, “place new rights-of-way (ROWs) for oil and gas 

pipelines and overhead lines within ROW corridors where 

practical; other locations would be considered in areas not 

identified for ROW avoidance or exclusion, etc.” Using ROW 

corridors and previously disturbed areas increases the likelihood 

that a project may be approved thereby providing incentives to 

applicants to use designated utility ROW corridors.

Rights-of-Way The Draft RMP/EIS notes that the proposed Gateway West 

Transmission Line project would be located in the planning 

area, but will be analyzed separately, although it is expected 

that the environmental impacts would be within the scope of 

that analyzed in the Draft RMP/EIS. However, the proposed 

location is outside the utility right-of-way (ROW) corridors 

analyzed in the Draft RMP/EIS. In order to limit the effects of 

this project on the other resources and uses of the public lands 

managed by the BLM, the Draft RMP/EIS should emphasize 

that any new projects, including the Gateway West 

Transmission Line, must consider siting within the designated 

utility ROW corridors and justify alternative locations.

See LA-CA-MA-2 in the Final EIS. This management action 

stated, “New rights-of-way (ROWs) would be located in areas of 

previous disturbance where practical.” A separate EIS will 

analyze the Gateway West Transmission Line Project. This 

separate EIS will take into account if the existing utility ROW 

corridors could accommodate the project.

Rights-of-Way Incorporate The Gateway West Transmission Line right-of-way 

exclusion areas into the Final EIS.

The Final EIS discussed the Gateway West Transmission Line 

Project as a reasonably foreseeable development within the 

planning area. The proposed placement of the transmission line 

and the alternatives considered are beyond the scope of this 

planning effort. 

Rights-of-Way We request that agencies acquire private land and rights-ofway to provide access to blocked public land.See LA-CA-MA-10 in the Final EIS. This management action 

stated, “Access across non-BLM lands would be identified and 

obtained, where possible, through easements, rights-of-way 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

(ROWs), or acquisitions to accomplish BLM objectives.” 

Rights-of-Way Because of the designation of Wilderness and Areas of Critical 

Environmental Concern (ACECs) along the northeast margin, 

all alternatives listed in the current plan support moving new 

utility right-of-way (ROW) corridors/lines only along the existing 

ROWs and then essentially prohibiting them elsewhere. There 

are allowances made for Wind Farming where vegetation, etc. 

would allow and where current wind research indicates 

location. However, this is blind to the fact that the newest 

turbines are profitable at annual wind speeds averaging less 

than 16 mph, and that they could eventually occur in many 

more settings, although that potential is a moot point if one 

can't get line ROWs to connect this valuable resource to the 

grid. The Bush and Obama administrations listed the need for 

new electrical infrastructure as a national security interest. I 

must add that the major utility ROW crossing near Lilly Grade 

would no more affect the scenic value of Salmon Falls Creek 

Canyon (if strategically placed) than the motorized vehicles in 

which 99% of the people who see that placement would be 

riding. Major utility lines are already strategically placed across 

the Birds of Prey Area, Hells Canyon, the Salmon River, the 

lower Bennett Hills, and the Snake River near the Hagerman 

Fossil Beds, just to mention a few ACECs.

In the Final EIS, Alternative VI (Proposed RMP), LA-VI-A-2 

stated, “...Upper Bruneau Canyon and Salmon Falls Creek 

Areas of Critical Environmental Concern (21,000 acres): New 

rights-of-way (ROWs) would be restricted to ROW corridors and 

locations of existing ROWs...” See Map 94 “ROW Exclusion 

Areas in Alternatives I, III, and VI (Proposed RMP)” and Map 92 

“ROW Avoidance Areas in Alternative VI (Proposed RMP)”. The 

Roseworth utility ROW corridor would allow for a ROW crossing 

in the Lily Grade area (See LA-VI-A-3).

Rights-of-Way The BLM's Alternative IV has zoned vast areas for rights-ofway (ROWs) (see Map 76 p. M-77, ROW Exclusion Areas). 

This shows that nearly the entire planning area outside 

wilderness and canyons can be developed with ROWs granted 

under Alternative IV. Industrial-style development and extreme 

visual scarring may also occur under Alternative IV Visual 

Resource Management (Maps pp. M-40 to M-41), Oil and Gas, 

Geothermal, etc.

Outside of right-of-way (ROW) exclusion areas, ROWs would be 

consistent with avoidance stipulations. Maps 86 to 92 display 

ROW avoidance areas, and Maps 93 to 96 display ROW 

exclusion areas in the Final EIS. 

Rights-of-Way Right-of-way (ROW) mapping shows that the BLM plans for all 

manner of development to occur over vast areas. It becomes 

apparent that the BLM contrived components of Alternative V 

to be purposefully damaging so that it could more readily 

discard even this weak alternative for conservation. See Map 

76, where ROW exclusion is identical between Alternatives IV 

and V; Map 90 Potential Oil and Gas Development Areas, 

which are the same under all of the alternatives; Map 91 

The Final EIS analyzed a range of alternatives for land use 

authorizations and leasable, salable, and locatable minerals. The 

Final EIS revised right-of-way (ROW) exclusions areas for 

Alternatives IV and V (see Map 95 “ROW Exclusion Areas in 

Alternative IV” and Map 96 “ROW Exclusion Areas in Alternative 

V”). Appendix K of the Final EIS described the potential for oil 

and gas development in the planning area as low, See Appendix 

K: Reasonable Foreseeable Development Scenario For Oil And 
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Geothermal Development Potential, which are the same under 

all; Map 96, Leasable Mineral Allocations in Alternative V, 

where the BLM would have more wide-open damaging 

leasable mineral allocations than Alternative IV; Map 101 

showing more wide-open damaging salable mineral allocations 

under Alternative V than Alternative IV; and Map 106, showing 

more wide-open damaging locatable mineral withdrawals 

under Alternative V than Alternative IV.

Gas Development. Appendix L described potential for 

geothermal development. See Appendix L: Reasonable 

Foreseeable Development Scenario For Geothermal 

Development.

Rights-of-Way Western Watershed Project incorporates all of our comments 

and concerns provided for the China Mountain process into 

these comments.

This comment is beyond the scope of this planning effort. The 

BLM has deferred the China Mountain Wind Energy project until 

completion of the Idaho and Southwestern Montana SubRegional Greater Sage-Grouse RMP Amendment/EIS and the 

Jarbidge RMP. 

Rights-of-Way Why doesn't the BLM provide clear mapping of the utility rightof-way (ROW) corridors under all of the alternatives? Why has 

the BLM even considered a ROW south of Murphy Hot 

Springs, Idaho? If this is an existing power line, BLM must 

prohibit any expanded use on this route.

The Final EIS analyzed a range of alternatives for the utility rightof-way (ROW) corridor locations. Chapter 2 described 

designation of utility ROW corridors by alternative. Map 97 

"Utility ROW Corridors" depicts the locations of utility ROW 

corridors in the planning area. Alternative VI (Proposed RMP) 

did not provide for a utility ROW corridor south of Murphy Hot 

Springs. 

Rights-of-Way In areas where a power line may be present, that use should 

be capped and no additional power lines, water, or other 

pipelines, structures, gas lines, etc. be built.

Restricting all power line and pipeline development did not fit the 

purpose and need described in the Final EIS, and is not 

necessary to protect resources. The Final EIS analyzed requiring 

that utility developments comply with applicable laws, regulations 

and policies. Where necessary, mitigation will be required to 

minimize or avoid impacts.

Rights-of-Way The BLM must specify that the existing power line to the town 

of Jarbidge, Nevada is not a utility right-of-way corridor, other 

than for the current power line.

The Final EIS analyzed a range of alternatives for utility right-ofway (ROW) corridor locations. The utility ROW corridor to the 

town of Jarbidge was not included in Alternative VI (Proposed 

RMP).

Rights-of-Way The BLM must zone the China Mountain and all areas of the 

Western Watershed Project Sagebrush Sea Alternative "off 

limits" to wind development under all alternatives.

The Sagebrush Sea Area of Critical Environmental Concern is a 

right-of-way (ROW) avoidance area and the Final EIS analyzed it 

in the range of alternatives. The Final EIS revised areas 

available for wind energy development. Alternative VI (Proposed 

RMP) commercial wind and solar energy developments would 

not be permitted inside the sage-grouse management area or 

within utility ROW corridors (LA-VI-A-4). Outside the sagegrouse management area, renewable energy site testing, 

monitoring, and development should avoid special status 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

species habitat unless unavoidable adverse effects can be 

mitigated (LA-VI-MA-4). 

Rights-of-Way The Juniper Butte Range should be included in the Utility 

Avoidance Areas. Consider Restricted Airspace R-3202 and R3204.

The Final EIS updated maps displaying right-of-way (ROW) 

avoidance areas (Maps 86 to 92) to include the US Air Force 

Military Operations Areas as Utility Avoidance Areas and ROW 

Avoidance Areas.

Riparian Areas 

and Wetlands 

In the Draft RMP/EIS (p. 2-57), the objectives in the Riparian 

Areas and Wetlands sections for Alterative I, III, IV and V are 

unrealistic and unlikely to be achieved due to conditions 

affecting proper functioning condition (PFC) that are outside of 

BLM control. The only acceptable alternative is Alterative II 

because it has the objective of "Maintain 85 miles of Priority 3 

streams at PFC and improve the Priority 1 and 2 streams to be 

moving toward PFC in the life of the plan." 

The Final EIS included a range of alternatives that would result 

in different rates of improvement in riparian condition. Of all 

action alternatives, Alternative II resulted in the fewest miles of 

stream achieving proper functioning condition (PFC) (140 miles) 

over the life of the plan. In the Final EIS, Alternative VI 

(Proposed RMP) would result in 183 miles of stream achieving 

PFC over the life of the plan (RI-VI-O-1). The Aquatic and 

Riparian Management Strategy (Appendix D) included 

restoration priorities for achieving this objective. Although some 

riparian area would continue to be affected by factors that are 

beyond BLM control, the stream reaches on the BLM will be 

managed to move toward or achieve PFC.

Riparian Areas 

and Wetlands 

Priorities for restoration should be based on: (1) Fish Bearing 

Streams (2) Permanently Flowing Streams and (3) Ponds, 

Lakes, Reservoirs, Wetlands greater than 1 acre. Insignificant 

riparian areas and stream reaches should not be a focus for 

management (Chapter 2, Riparian Areas and Wetlands

(Section 2.3.5.2), p. 2-55, RI-CA-MA-1). Priorities within the 

above categories can be broken down further as described by 

Chapter 2, Riparian Areas and Wetlands (Section 2.3.5.2), p. 

2-56, RI-CA-MA-3: focusing just on streams with segments that 

are functioning-at-risk with no apparent trend (FAR-NA), or 

functioning–at-risk with a downward trend (FAR-DN), second 

on stream segments that are functioning–at-risk with an 

upward trend (FAR-UP), or non-functional (NF), and lastly on 

stream segments rated as proper functioning condition. 

The priorities for riparian management are included in the Final 

EIS in Chapter 2, the Riparian Areas and Wetlands section in 

management action RI-CA-MA-3 and in the Aquatic and Riparian 

Management Strategy (ARMS), Appendix D, Tables D-3 through 

D-5. The ARMS based the priorities on proper functioning 

condition ratings and habitat condition ratings for streams 

containing special status fish.

The Final EIS included management direction for riparian areas 

and wetlands according to the four categories identified in the 

Inland Native Fish Strategy (USDA, 1995). The Final EIS 

contained this information in Chapter 2, the Riparian Areas and 

Wetlands section in management action RI-CA-MA-1, and in 

Appendix D, under the subheadings Riparian Conservation 

Areas, Riparian Conservation Area Widths. Seasonally flowing 

and intermittent streams were included in the Final EIS because 

of their direct and indirect influence on fish-bearing streams.

The Final EIS (RI-CA-MA-3; Appendix D, Table D-4 and Table 

D-5) does not specifically list seasonally flowing or intermittent 

streams (Category 4 streams) as a restoration priority because 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

they do not have a proper functioning condition rating. BLM may 

conduct restoration actions on Category 4 streams where sitespecific analysis indicated they are preventing the achievement 

of riparian and wetland objectives.

Riparian Areas 

and Wetlands 

Wind energy infrastructure is broadly referred to in the Draft 

RMP/EIS, Chapter 4, Riparian Areas and Wetlands (Section 

4.3.5.2) p. 4-204 under the heading for Land Use 

Authorizations). 

The Draft RMP/EIS assumes that the land use authorizations 

for wind development would impact fish and aquatic 

environments. The BLM requires wind energy projects to 

conduct detailed hydrology studies, comply with stream 

buffers, and comply with all grading, drainage and storm water

monitoring during construction and operations. If there are 

impacts, mitigation will be required. Therefore, impacts to fish 

and aquatic environments are not expected from wind energy 

projects. The Final EIS should not assume the land use 

authorizations related to wind energy development would 

impact fish and aquatic environments.

In the Draft RMP/EIS, Chapter 4, Riparian Areas and Wetlands

and Land Use Authorizations, the analysis stated that land use 

authorizations, such as wind energy infrastructure, have the 

potential to impact riparian condition depending on their 

proximity to riparian areas and wetlands. The analysis also 

stated that infrastructure for wind projects in upland areas would 

have limited impacts to proper functioning condition ratings, but 

the road systems that support wind projects would pose risk for 

impacts to riparian and wetland condition. 

The Final EIS allocated public land for a variety of uses. 

Allocating lands for a specific use leads to the assumption that 

constructing and implementing the use could result in direct, 

indirect or cumulative impacts to resource values within the 

allocation area. Because the construction and operation of a 

wind energy project would require road construction, ground

disturbance, and consumptive and non-consumptive uses of 

water, it was predicted to result in impacts to aquatic resources 

(water quality or quantity, riparian areas and wetlands, fish, and 

special status fish). The Final EIS clarified this assumption in, 

Chapter 4, Riparian Areas and Wetlands section, Methods and 

Assumptions. Mitigation measures applied at the project level 

would compensate for, rectify, or reduce the potential for 

negative impacts at the project level, but do not ensure all 

project-related impacts would be eliminated. 

Riparian Areas 

and Wetlands

In the Draft RMP/EIS (p. ES-12), Objective RI-NA-O-l, I cannot 

tell from the information listed in the Alternatives, what stream 

segments they are talking about. I'm also against creating 

Riparian Conservations Areas of 300 feet from the edge of 

fish-bearing streams. This would eliminate any activity from 

occurring for any reason in the bottom of any canyon, including 

any energy-related development.

The Draft RMP/EIS included an Executive Summary with a table 

that displayed how management varied between the alternatives 

(p. ES-5 through ES-40). The Executive Summary is a 

condensed summary that does not include the level of detail 

provided in the Chapter 2, Chapter 3 and Chapter 4 portions of 

the Draft RMP/EIS. In the Draft RMP/EIS, Chapter 2, Riparian 

Areas and Wetlands, RI-NA-O-1 refers to Map 4 “MUAs in the 

No Action Alternative” for information on the Multiple Use Areas

as part of the No Action Alternative. This information is also 

included in the Chapter 2, Riparian Areas and Wetlands section 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

of the Final EIS (see Map 3). 

The creation of Riparian Conservation Areas (RCAs) complied 

with current BLM management direction to incorporate the Inland 

Native Fish Strategy into RMP revisions. The RCA definitions 

are included in the Final EIS in Chapter 2, Riparian Areas and 

Wetlands section under RI-CA-MA-1 and in Appendix D: The 

Aquatic and Riparian Management Strategy under the 

subheadings of Riparian Conservation Areas, Riparian 

Conservation Area Widths. Authorized uses are allowed in the 

RCA as long as they maintain or promote the attainment of the 

RCA in proper functioning condition (Chapter 2, Riparian Areas 

and Wetlands, RI-CA-MA-8 and RI-CA-MA-9). 

Riparian Areas 

and Wetlands

In the Draft RMP/EIS, Chapter 2, Riparian Areas and 

Wetlands, on pp. 2-56 through 2-59, we oppose all alternatives 

that suggest modification or removal of all water developments. 

That would suggest removing water developments that would 

have a great economic impact on a great deal of families and 

local communities who have for generations, depended on 

such developments for a living. 

In the Draft RMP/EIS, Chapter 2, Riparian Areas and Wetlands

section, Alternatives I through V identified either modification or 

removal of water developments as actions that would improve 

wetland and riparian condition. The intent of these management 

actions was to remove non-essential human-made structures 

and objects that reduce the function of floodplains (e.g., unused 

bridges abutments, unused diversions, and abandoned cars) as 

identified in the Draft RMP/EIS in RI-CA-MA-7. The Final EIS 

included RI-CA-MA-7 (Chapter 2, Riparian Areas and Wetlands

section) with an added clarification to define the term water 

development in the glossary. The modification or removal of 

water developments was included in Alternative VI (Proposed 

RMP) as a tool for restoration of stream reaches (Final EIS, 

Chapter 2, Riparian Areas and Wetlands, RI-VI-MA-2).

Riparian Areas 

and Wetlands

In Chapter 4, Riparian Areas and Wetlands, under the 

subheading for Livestock Grazing (pg. 4-195, 4-234), the first 

sentence in the Impact for Management Common to All Action 

Alternatives section states, "livestock grazing would comply 

with management guidance in the ARMS". The Aquatic and 

Riparian Management Strategy (ARMS) is not a decision 

document and is not NEPA compliant. 

The BLM created the Aquatic and Riparian Management 

Strategy (ARMS) using current BLM guidance as described in 

the introduction of the ARMS (Appendix D). In the Final EIS, the 

ARMS was revised to include the same goals, objectives, and 

management actions from Chapter 2. This Final EIS is the NEPA 

analysis of the ARMS and the forthcoming Record of Decision

will be the decision document.

Riparian Areas 

and Wetlands

We are concerned that the preferred alternative would 

designate as open to minerals actions in the following Riparian 

Conservation Areas (RCAs) around water quality impaired 

streams: 16 miles for oil and gas leasing, 86 miles for 

geothermal, and 88 miles for salable mineral development 

In the Draft RMP/EIS, Chapter 2, Riparian Areas and Wetlands

section (RI-CA-MA-1), and in the Aquatic and Riparian 

Management Strategy (ARMS) (Appendix D) buffered all of the 

water quality impaired streams using the Riparian Conservation 

Area (RCA) definitions from the Inland Native Fish Strategy 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

(Draft RMP/EIS, p. 4-115 and 4-116). To reduce the risk of 

adverse impacts to water quality impaired streams, we 

recommend closing these areas to minerals actions. We 

appreciate that the preferred alternative does close many miles 

of the RCAs for water quality impaired streams (approximately 

75 miles). If additional miles cannot reasonably be closed, the 

Proposed EIS should explain why and describe how Clean 

Water Act and Endangered Species Act requirements are met.

(USDA, 1995). The mineral leasing provisions in Alternative VI 

(Proposed RMP) allow for leasing subject to laws, regulations, 

and formal orders; areas may also be subject to additional 

constraints (LE-VI-A-1). Alternative VI identified additional 

seasonal restrictions in LE-VI-MA-1 for redband trout and bull 

trout and included guidelines for exceptions. Direction for salable 

mineral authorizations is provided in the Chapter 2 Salable 

Minerals sections in SA-CA-MA-5 and SA-CA-MA-6. All minerals 

activities in the RCA must be consistent with Chapter 2, Riparian 

Areas and Wetlands section, RI-CA-MA-8 and RI-CA-MA-9 

which require management actions to attain proper functioning 

condition or movement toward proper functioning condition. 

Actions affecting RCAs must also be consistent with the ARMS 

which identified RCAs as areas where authorized actions are to 

maintain and restore riparian structure and function; benefit fish 

and riparian-dependent resources; enhance conservation of 

organisms dependent on the transition zone between upslope 

and in stream habitats; and improve connectivity of travel and 

dispersal corridors for terrestrial animals and plants and aquatic 

organisms. The process identified in the ARMS complies with 

Endangered Species Act requirements. 

Riparian Areas 

and Wetlands

To protect fish, we recommend the Final EIS consider the 

benefits of screening pumps at drafting sites to prevent 

entrainment and the installation of one-way valves to prevent 

back-flow into streams.

To protect water resources and riparian areas, we recommend 

the Final EIS consider prohibiting the installation of livestock 

handling, management or watering facilities within riparian 

management areas unless required for resource management.

Endangered Species Act consultation requirements for noxious 

weed and invasive plant treatments, wildland fire suppression, 

emergency stabilization and rehabilitation treatments, and 

restoration activities at stream crossings require the use of 

screens when drafting water from streams containing bull trout 

and other salmonids. The consultation documents related to 

these activities are included in the Final EIS, Aquatic and 

Riparian Management Strategy (Appendix D), in Table D-10. 

Direction for screening irrigation diversions is provided in the 

Final EIS, Chapter 2, Special Status Species section (SS-CAMA-20). The Final EIS provided direction for management 

activities in riparian conservation areas in Chapter 2, Riparian 

Areas and Wetlands, in RI-CA-MA-2, RI-CA-MA-8, and RI-CAMA-9. The direction for livestock grazing and related 

infrastructure is provided in Chapter 2, Livestock Grazing, LGCA-MA-11 and LG-CA-MA-14.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Riparian Areas 

and Wetlands

We appreciate the effectiveness monitoring proposed for 

Riparian Areas and Wetland in the Draft RMP/EIS, Appendix P, 

Table P-l. To maximize the usefulness of this monitoring, as an 

aspect of adaptive management (either related to Appendix D 

or Appendix P), we recommend the Final EIS include clarifying 

information on intervals and standards (consistent with 43 CFR 

Sub-part 1610.4-9), and, decision thresholds and adaptive 

management actions. 

Please disclose the potential usefulness of establishing 

decision thresholds based on one or more of the following: 

(1) The attainment of water quality standards. 

(2) The achievement of stream miles meeting proper 

functioning condition - e.g., 98 miles over the life of the plan for 

Alternative IV. 

(3) The establishment of healthy riparian conditions (e.g., 

potential natural vegetation). Please also design and propose, 

or discuss the potential usefulness of, specific adaptive 

management actions. Consider, for example and as 

appropriate, closing additional Priority 1 and 2 water quality 

impaired streams to livestock grazing, reducing wild horse herd 

numbers, travel management restrictions etc.

The Final EIS, Chapter 2 (Section 2.9), outlined a monitoring 

strategy for assessing the implementation and effectiveness of 

RMP decisions in meeting resource goals and objectives. This 

implementation and effectiveness monitoring is supplemented by 

the monitoring and adaptive management guidance for aquatic 

resources provided in Appendix D: Aquatic and Riparian 

Management Strategy. Site specific details on the intervals, 

standards, and monitoring for the achievement of resource 

objectives would be determined at the project or activity level. 

Because decision thresholds would vary according to sitespecific conditions, they were not defined in the Final EIS. 

The Final EIS analyzed the achievement of water quality 

standards and proper functioning condition (PFC) ratings in the 

Chapter 2 sections for Water Resources and Riparian Areas and 

Wetlands for all action alternatives. The Final EIS, Chapter 2, 

Alternative VI (Proposed RMP), Water Resources section 

included the objective of meeting Federal and State water quality 

standards (WR-CA-O-1). In Chapter 2, Alternative VI (Proposed 

RMP), Riparian Areas and Wetlands section , would result in 183 

miles of stream achieving PFC over the life of the plan (RI-VI-O1).

Riparian Areas 

and Wetlands

The Draft RMP/EIS, Chapter 3 (pp.3-17 to 3-20), incorrectly 

identified, assessed, and reported the amount of lentic and 

lotic riparian and wetland resources within the planning area. 

The BLM has applied incorrect definitions, has included and 

assessed as Functioning-at-Risk with a Downward trend and 

Non-Functional to numerous areas that are excluded from the 

definition of riparian habitat.

The Draft RMP/EIS, Chapter 3, Riparian Areas and Wetlands 

provided a description of the five riparian functional condition 

ratings based on the descriptions provided in BLMs’ “User Guide 

to Assessing Proper Functioning Condition and the Supporting 

Science for Lotic Areas” (Prichard et al., 1998a). The Final EIS 

revised Chapter 3, Riparian Areas and Wetlands, to provide 

clarity by including a more detailed description of riparian and 

wetlands conditions that would be rated as Functioning-at-Risk 

with a downward trend or Non-Functional. These definitions 

were also added to the Glossary for the Final EIS. 

Riparian Areas 

and Wetlands

The Draft RMP/EIS (pp. 3-17 to 3-18) states: “Riparian areas 

are lands adjacent to or contiguous with permanent and 

intermittently flowing water bodies,” citing Hansen and Hall, 

2002. However, the definition in the Draft RMP/EIS is not the 

definition given by Hansen and Hall (2002). 

The Final EIS revised the Chapter 3 Riparian Areas and 

Wetlands section to include a more detailed definition of riparian 

area as defined by Hansen and Hall (2002). The Final EIS also 

included definitions for perennial, intermittent or seasonal, and 

ephemeral streams, and wetland in the Chapter 3 Riparian 

Areas and Wetlands section and in the Glossary. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Riparian Areas 

and Wetlands

It is important to note that Hansen and Hall (2002), as well as 

the BLM Technical References 1737-9 (Prichard et al., 1993) 

and 1737-11 (Prichard et al., 1998b) upon which Hansen and 

Hall (2002) rely, do not include ephemeral areas as a type of 

riparian or wetland.

The Final EIS revised the Chapter 3 Riparian Areas and 

Wetlands section and the Glossary to include a definition for 

ephemeral streams. Ephemeral streams are a type of riparian 

area, but they are not given a proper functioning condition rating 

according the BLM TR 1737-9 and TR 1737-11.

Riparian Areas 

and Wetlands

The Draft RMP/EIS infers in Chapter 3, Riparian Areas and 

Wetlands, Table 3-10 that canals and ditches (including any 

canals or ditches that are RS 2339 rights-of-way or equivalent) 

are streams (even though such areas may in whole or in part 

support riparian vegetation). These descriptions do not 

properly describe the Affected Environment. 

The Draft RMP/EIS in the Chapter 3 Riparian Areas and 

Wetlands section, Table 3-10, identified the miles of canals and 

ditches as features that distribute surface water across the 

planning area. The Final EIS revised the Chapter 3 Riparian 

Areas and Wetlands section, Table 3-11 to remove any 

inference that ditches and canals are streams. 

Riparian Areas 

and Wetlands

The Draft RMP/EIS is wrong in not pointing out that the 

permittees and/or BLM implemented management changes to 

livestock authorization because of proper functioning condition

assessments, where BLM found that livestock management 

was causing undesired ratings.

The Final EIS did not incorporate the requested change into the 

Chapter 3 Riparian Areas and Wetlands section because 

Chapter 3 is the Affected Environment and provided a baseline 

for analysis. 

Riparian Areas 

and Wetlands

The Draft RMP/EIS, Chapter 3 (p. 3-19), discusses various 

states of “functionality”, and states, relative to proper 

functioning condition: “Stream banks are stable, and evidence 

of degradation is minimal.” and states, relative to FunctioningAt-Risk (FAR), Upward Trend: “Erosion and deposition are 

often observed.” However, “stable” and “minimal” are not 

quantified by the Draft RMP/EIS, and the statement leaves the 

erroneous inference that the natural setting does not have 

anything but “undisturbed” banks, with no erosion and 

deposition occurring. This is erroneous because the natural 

setting includes variation away from “undisturbed”. The BLM 

should re-assess any areas that were given a lowered rating to 

FAR from proper functioning condition because of any 

departure from “undisturbed”, and present corrected miles and 

percentages in the Final EIS.

The Draft RMP/EIS, Chapter 3, Riparian Areas and Wetlands

section included a description of the five riparian functional 

condition ratings based on the summaries provided in BLMs’ 

“User Guide to Assessing Proper Functioning Condition and the 

Supporting Science for Lotic Areas” (Prichard et al., 1998a). The 

Final EIS revised Chapter 3 Riparian Areas and Wetlands

section to include more detailed descriptions of riparian and 

wetland condition ratings. These definitions were also added to 

the Glossary.

The Final EIS clarified Chapter 4 Riparian Areas and Wetlands

section, Methods and Assumptions, to recognize that riparian 

systems have instability due to natural disturbances as 

described by Kershner and others (2004) and Kershner and 

Roper (2010). 

The definitions provided for the functional condition ratings in the 

Draft RMP/EIS did not use the term “undisturbed” to define any 

of the functional condition ratings. Because the BLM did not 

correlate “undisturbed” to a rating as proper functioning condition 

(PFC), streams not rated as PFC were not reassessed. 
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Category Comment Response

Riparian Areas 

and Wetlands

The Draft RMP/EIS, Chapter 3 (pp. 3-19 to 3-20), discusses 

various states of “functionality”, and states, relative to 

Functioning-at-Risk (FAR) with an Upward (UP) trend and 

FAR- No Apparent Trend (NA), respectively: 

The presence or absence of noxious weeds does not create a 

threshold which otherwise changes the site from a status of 

“proper functioning condition” to FAR-UP or FAR-NA (or too 

FAR-Downward Trend or Non-Functional). The BLM Technical 

References 1737-9 (Prichard et al., 1993) and 1737-11 

(Prichard et al, 1998b) do not even contain the phrase “noxious 

weeds”, and the uniform checklists provided therein do not 

include consideration of noxious weeds per se. Their presence 

or absence does not form a determination of hydrologic 

functionality or a threshold between states of functionality.

Although Technical References 1737-9 and 1737-11 do 

provide for a lowered functionality-rating if “non-desirable 

species are present”, this is in the context of whether bankstabilizing vegetation is dominant or non-desirable other 

species is dominant on the stream bank. It is not in the context 

of the mere presence of one or more plant of one or more 

noxious weed species. The BLM should re-assess any areas 

that were given a lowered rating to FAR (or NF) from proper 

functioning condition because of the presence of noxious 

weeds. The Final EIS should present the corrected areas and 

percentages.

The Final EIS, Chapter 3, Riparian Areas and Wetlands section, 

under the subheading for proper functioning condition (PFC), 

included six bulleted items for riparian areas and wetlands that 

are functioning properly. One of the bullets refers to the 

presence of adequate vegetation to develop root masses that 

stabilize streambanks. This correlates to questions 9 and 11 on 

the PFC checklist (Prichard et al., 1998a), which considered if 

adequate riparian-wetland vegetative cover is present to protect 

banks and dissipate energy at high flows. Because noxious 

weeds and other invasive plants do not develop root masses 

capable of maintaining streambanks during periods of high flows, 

their occurrence in a riparian area or wetlands is an indicator of 

change in condition. PFC ratings were based on a compilation of 

17 questions related to hydrologic, vegetative, and 

soil/erosion/deposition. 

The PFC assessments did not base PFC ratings solely on the 

occurrence of noxious weeds or invasive vegetation within the 

PFC assessment area. Therefore, streams not rated as PFC 

were not reassessed. 

Riparian Areas 

and Wetlands

We are concerned that the BLM is going to use riparian areas 

as a reason to construct fencing, rather than require 

measurable standards of use for riparian areas.

The Final EIS stated the BLM would implement adaptive 

management using grazing use indicators to meet resource and 

special designation area objectives in LG-CA-MA-1. Utilization 

for riparian areas is one of the grazing use indicators that would 

be applied. The use of rangeland infrastructure, such as fences, 

is identified as a tool for managing livestock in LG-CA-MA-3.

Riparian Areas 

and Wetlands

Under BLM's 1997 National Riparian Goal, within five years, all 

streams were supposed to be in proper functioning condition

(PFC). Yet here is the BLM, 13 years later, taking minimal 

steps towards attaining PFC with no clear path to achieve this 

condition on some of the streams in the planning area. There 

are no mandatory annual grazing use requirements and 

In the Final EIS, Alternative VI (Proposed RMP), Chapter 2, 

Riparian Areas and Wetlands, included management actions for 

achieving or moving streams toward proper functioning condition

(RI-CA-MA-1 through RI-CA-MA-9 and RI-VI-MA-1 through RIVI-MA-4). Tables D-3 through D-5 in Appendix D: Aquatic and 

Riparian Management Strategy, summarized priority streams for 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

specified timely monitoring in the Draft RMP/EIS. restoration. The Monitoring Implementation and Effectiveness of 

RMP Decisions section in Chapter 2 of the Final EIS included 

implementation and effectiveness monitoring for all resources 

including livestock grazing. Mandatory annual grazing use 

requirements and allotment specific monitoring strategies are 

developed at the allotment level and supported by rangeland 

health assessments and site-specific data. 

Riparian Areas 

and Wetlands

Proper functioning condition (PFC) is the wrong goal. BLM 

should use a desired natural condition that far exceeds PFC. 

PFC does not address in stream habitat conditions for riparian 

areas. The BLM efforts to claim PFC can be "cross-walked" 

and translate into in stream conditions are not valid.

The Final EIS, Aquatic and Riparian Management Strategy

(Appendix D), Figure D-1 and the paragraph below it 

acknowledged riparian condition has to improve beyond the 

initial rating of proper functioning condition (PFC) to achieve 

riparian, in stream, and water quality objectives. 

The Final EIS, Chapter 3 Riparian Areas and Wetlands section

identified PFC as a broad scale qualitative assessment to 

determine if a riparian area is functioning properly. The BLM 

validated the PFC assessments using site-specific habitat 

condition (HC) data collected on multiple stream channel 

characteristics. This validation of PFC ratings was only done 

where the PFC and HC stream reaches overlapped. The 

validation process is possible because the riparian condition 

indicators (PFC checklist questions 3, 8, 9, 11, 14, and 15; 

Prichard et al., 1998a) correlate to the measured HC indicators 

(stream width and depth, vegetation composition and 

abundance, streambed composition). Photographs of the PFC 

and stream survey reaches were also used during the validation 

process. The validation process, as identified in BLMs’ PFC 

protocol (Prichard et al., 1998a), was included in the Final EIS in 

Appendix D, under the subheading of Conservation and 

Restoration Reaches, Riparian Habitat. This validation process 

is also described in the BLM Technical Reference 1737-23; 

Multiple Indicator Monitoring of Stream Channels and 

Streamside Vegetation (Burton et al., 2011). 

Riparian Areas 

and Wetlands

In the Draft EIS, the BLM provides no analysis of the 

effectiveness of the Multiple Indicator Monitoring (MIM) riparian 

monitoring. Under the BLM methodology of the MIM, the 

agency claims that it is not necessary to meet particular use 

levels every year. There is little grazing accountability with 

MIM.

The Multiple Indicator Monitoring (MIM) protocol in BLM 

Technical Reference 1737-23 (Burton et al., 2011) is a peer 

reviewed methodology and is the current riparian monitoring 

protocol adopted by the BLM. The Final EIS incorporated the 

use of MIM for monitoring riparian areas in Chapter 2, 

Effectiveness Monitoring, Table 2-5 and in Appendix D: Aquatic 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

The MIM measurements for riparian vegetation are taken right 

by the water's edge - the first line of vegetation where even the 

thinnest of green spikerush (Eleocharis) or other shallowrooted poor bank stabilizers would be measured and 

considered towards meeting goals.

The MIM sets no standards of use. 

and Riparian Management Strategy, under Methodology for 

Watershed Analysis (Step 3). The MIM protocol established a 

procedure for monitoring riparian condition based on short- and 

long-term indicators. The protocol was not intended to establish 

specific use standards to be applied to all riparian areas. 

The MIM Protocol identified riparian data collection along the 

greenline, which is the linear grouping of plants near the water’s 

edge along a stream channel. The greenline often forms at just 

below the bankfull level of the stream channel and forms a line 

along the annual scour of the stream channel during high water. 

The greenline often coincides with the presence of water in the 

plant-rooting zone, which allows for the growth of robust, 

hydrophytic plant species with deep roots that resist the erosive 

forces of the stream. 

Riparian Areas 

and Wetlands

The Final RMP/EIS must set the standards for stubble height 

(including in meadows), bank trampling of livestock, accessible 

areas of stream banks, and riparian browse under a range of 

alterative to be measured by the Multiple Indicator Monitoring 

system.

In the Final EIS, the Aquatic and Riparian Management Strategy 

(Appendix D) provided guidance for achieving riparian goals and 

objectives for public land uses including livestock grazing. 

Allotment specific grazing standards are based on site-specific 

data collected according to current BLM methods and protocols 

such as the Multiple Indicator Monitoring Protocol (Burton et 

al.,2011), Rangeland Health Assessments, site-specific NEPA, 

Interim Grazing Management Plans, and Endangered Species 

Act consultation where Federally listed species or their habitat 

may be affected. Specific measurable standards, where 

necessary, are included in project-level decisions.

Riparian Areas 

and Wetlands

The Draft RMP/EIS does not include requirements for the 

many miles of intermittent tributaries that characterize large 

areas of the redband trout and bull trout tributaries in southern 

Idaho and northern Nevada. The BLM provides no commitment 

whatsoever to improve or address the intermittent and 

ephemeral tributaries. 

In the Final EIS, all action alternatives included direction for 

intermittent streams (Chapter 2, Riparian Areas and Wetlands

section, RI-CA-MA 1, Category 4). Alternative VI (Proposed 

RMP) included direction for seasonally flowing or intermittent 

streams in Chapter 2, Riparian Areas and Wetlands section, RICA-MA 1, Category 4. Management direction for seasonally 

flowing or intermittent streams is also included in the Final EIS, 

Appendix D: Aquatic and Riparian Management Strategy, 

Riparian Conservation Areas, under Category 4. 

The Final EIS, Chapter 3 Riparian Areas and Wetlands section, 

Table 3-11 identified the miles of intermittent (seasonally flowing)

and ephemeral streams within the planning area. The Final EIS 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

considered impacts to intermittent stream channels in Chapter 4,

Riparian Areas and Wetlands section, Methods and 

Assumptions. 

Riparian Areas 

and Wetlands

The Aquatic and Riparian Management Strategy section 

discusses Watershed Analysis, and Monitoring and Adaptive 

Management. The Draft RMP/EIS does not provide information 

on the results of any watershed analysis. BLM cannot conduct 

a valid watershed NEPA analysis until BLM provides much 

more information on soils, soil erosion, micro biotic crusts, and 

vegetative conditions in watersheds. This is necessary to 

understand the risks associated with continued grazing or 

other allocations under the Draft RMP/EIS.

In the Draft RMP/EIS, the Aquatic and Riparian Management 

Strategy (ARMS), Appendix D included guidance for completing 

multi-scale assessments and ecosystem analysis at the 

watershed scale. The ARMS identified one Watershed Analysis 

that was completed by the BLM and US Forest Service. In the 

Final EIS, Appendix D clarified there were two Watershed 

Analyses completed in the Jarbidge Watershed, one in 1997 and 

one in 2004. The ARMS identified other more recent broad scale 

and mid-scale aquatic resource assessments, including 

Conservation and Recovery Plans (Table D-9) and Endangered 

Species Act consultation with the US Fish and Wildlife Service 

(Table D-10) that were completed in the planning area. The 

ARMS summarized the most current habitat condition data 

(Table D-3) and proper functioning condition data (Table D-5) as 

the baseline conditions for the aquatic resource analysis in 

Chapter 4. The Final EIS included information on soils, soil 

erosion, and micro biotic crusts in the Chapter 3 Soil Resources

section. Vegetative conditions are described in Chapter 3 in the 

Vegetation Communities section.

Riparian Areas 

and Wetlands

On p. A-47, Appendix D: Aquatic and Riparian Management 

Strategy, in the Draft RMP/EIS shows that the timeframe for 

change or actions (like maintain or improve 70% to proper 

functioning condition (PFC) is the life of plan --- 20 years! 

There are no milestones to be met at 5 years (BLM used to say 

that PFC would be attained in 5 years in most instances), 10 

years, etc. There is no analysis to show that this slow pace will 

sustain viable populations of native biota, or if this relatively 

low goal of improvement is even attainable under a series of 

near-status quo disturbance alternatives, especially with the 

added stressor of climate change. There is no real analysis of 

the adverse impacts of climate change, the timing and severity 

of grazing disturbances on BLM and Forest lands, road 

impacts and other direct, indirect or cumulative impacts that 

may impede progress or attainment.

The comment refers to the Draft RMP/EIS, Appendix D: Aquatic 

and Riparian Management Strategy, in Table D-1. This table 

displayed the Bull Trout Habitat Condition Indicators and 

Thresholds. The table identified the Indicators for Species 

Characteristics and the Thresholds for the Indicators 

(Functioning Properly, Functioning at Risk, Functioning at an 

Unacceptable Risk). It was developed by the US Fish and 

Wildlife Service (FWS, 1998) and created from the peerreviewed literature that is provided at the end of the table. This 

table was included in the Final EIS, Appendix D as a basis for 

identifying conservation and restoration areas for Jarbidge River 

bull trout and their designated critical habitat. The purpose of the 

table was not to establish timelines for recovery. The Final EIS 

included an impact analysis in Chapter 4, Riparian Areas and 

Wetlands, and included an analysis of direct, indirect, and 

cumulative impacts relative to climate change, livestock grazing, 

and roads. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Riparian Areas 

and Wetlands

The BLM's analysis in the Draft RMP/EIS, Chapter 4, Riparian 

Areas and Wetlands, p. 4-197, states "estimated use levels in 

the Sagebrush Sea Area of Critical Environmental Concern 

(ACEC) would be 10% to 20%, less than in other alternatives". 

Yet the BLM provides no information on the levels of use that 

have been occurring in riparian areas at present. The BLM 

proposes to continue livestock grazing in large areas of the 

ACEC with no mandatory annual measurable standards of use 

to riparian areas. Identify how the BLM plans to live up to the 

claims of 10% to 20% utilization for riparian areas within the 

ACEC. 

The Draft RMP/EIS analyzed the impacts from livestock grazing 

in the Sagebrush Sea Area of Critical Environmental Concern in 

Alternative V. Across the range of alternatives, Alternative V had 

the fewest miles of perennial streams available to livestock

grazing (63 miles). The Final EIS revised the analysis in Riparian 

Areas and Wetlands, Alternative V, to clarify that based on the 

miles of perennial streams available to livestock grazing (58 

miles) and the reduced number of animal unit months at full 

implementation, it would pose the least risk for impacts to 

riparian condition. Measurable use standards for livestock 

grazing in riparian areas are to be developed based on sitespecific NEPA analysis. 

Riparian Areas 

and Wetlands

The objective for riparian areas is to "move toward objectives"- 

not even to make significant progress and to achieve goals and 

objectives.

The Final EIS included a range of riparian objectives for moving 

toward or achieving proper functioning condition (PFC). 

Alternative II had the fewest miles achieving PFC (85 miles) and 

the most miles moving toward PFC (145 miles). Alternative VI 

(Proposed RMP) Chapter 2, Riparian Areas and Wetlands, RIVI-O-1, included a riparian objective for 183 miles of stream 

achieving PFC and 42 miles of stream to be moving toward PFC. 

Riparian Areas 

and Wetlands

The Draft RMP/EIS must layout clear and required mandatory 

standards of use that serve as annual triggers from livestock 

removal from grazed riparian areas.

In the Final EIS, Chapter 2, Riparian Areas and Wetlands, 

provided management actions for achieving riparian goals and 

objectives for public land uses including livestock grazing. 

Allotment specific grazing standards are based on site-specific 

data collected according to current BLM methods and protocols 

such as the Multiple Indicator Monitoring protocol (Burton et 

al.,2011), Rangeland Health Assessments, NEPA, Interim 

Grazing Management Plans, and Endangered Species Act

consultation where Federally listed species or their habitat may 

be affected. Specific measurable standards, where necessary, 

are included in project-level decisions.

Riparian Areas 

and Wetlands

The BLM must rely on non-structural methods to ensure 

functioning riparian areas and watershed processes. This 

includes closures, reduced stocking coupled with requirements 

for active herding of livestock.

The Final EIS analyzed a range of alternatives that included 

different methods for managing livestock grazing and 

maintaining or improving riparian areas. Non-structural methods 

for maintaining or improving riparian condition relative to 

livestock grazing included closures for resource protection, 

herding, and adjusting stocking rates (LG-CA-MA-3).

Riparian Areas 

and Wetlands

Requiring procedural and management actions to conform to 

the Aquatic and Riparian Management Strategy (ARMS) (Draft 

RMP/EIS, Chapter 2, WR-CA-MA-2; RI-CA-MA-2; FI-CA-MA-1; 

The Draft RMP/EIS identified the Aquatic and Riparian 

Management Strategy (ARMS) as guidance for managing 

riparian areas in the planning area. To comply with current BLM 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

and SS-CA-MA-19) over a 20-year and likely even longer time 

frame is unwise because knowledge of stream/riparian system 

evaluation and management as well as assessment 

technology is always improving. Reliance on the ARMS does 

not allow BLM to adjust to significant new information and 

technology as it becomes available.

policy, this management strategy was included in the Final EIS 

(Appendix D). The ARMS established the baseline instream and 

riparian condition and identified priorities for Conservation and 

Restoration throughout the planning area. 

The current BLM policy is to use the most current science and 

available data to achieve aquatic resource goals and objectives 

as defined in the Final EIS (Chapter 2). This would apply to 

revisions to the current science, such as the Multiple Indicator 

Monitoring Protocol (Burton et al, 2011), or new peer-reviewed 

science or methodologies developed after the signing of the 

Record of Decision for the Jarbidge Proposed RMP/Final EIS. 

Riparian Areas 

and Wetlands

As shown in the Aquatic and Riparian Management Strategy 

document, the guidance is derived from elements of the 

Interior Columbia Basin Ecosystem Management Plan 

(ICBEMP), which has never had a Record of Decision

completed by which public input, or challenge of the entire 

concept could occur. The Congress of the United States 

denied funding to proceed with implementation of the ICBEMP; 

therefore, any effort to implement it by agreement, 

Memorandum of Understanding or other means has the 

appearance of circumventing the intent of Congress.

In the Final EIS, the Aquatic and Riparian Management Strategy 

(ARMS; Appendix D), complied with BLM direction to use the 

Interior Columbia Basin Ecosystem Management Plan science 

(Strategy and Framework) and other available science to 

improve riparian condition. The Jarbidge Proposed RMP/Final 

EIS and Record of Decision (ROD) are the NEPA documents 

that incorporated this management direction into the Jarbidge 

RMP. In accordance with current BLM policy, the ARMS 

incorporated the Inland Native Fish Strategy guidance, which 

has a completed ROD that amended the 1987 Jarbidge RMP. 

Riparian Areas 

and Wetlands

One of the components of the Aquatic and Riparian 

Management Strategy (ARMS) derived from the Interior 

Columbia Basin Ecosystem Management Plan is the 

identification and establishment of Riparian Conservation 

Areas (RCAs). As has been previously pointed out, the manner 

of establishment of RCA boundaries is arbitrarily (Draft 

RMP/EIS, Appendix D, p. A-42) based on broad scale 

circumstance resulting in varied but predetermined RCA width 

without regard to site specific conditions and/or uses. The 

ARMS document itself allows for RCA width modification basis 

on site-specific circumstances, thus the entirety of all 

predetermined categorical RCAs is subject to modification in 

consideration of site-specific conditions.

The creation of Riparian Conservation Areas (RCAs) to prioritize 

streams was from the Inland Native Fish Strategy (INFISH) 

(USDA 1995), which amended the 1987 Jarbidge RMP. INFISH 

identified Riparian Habitat Conservation Areas (or RCAs) using 

standardized widths based on the occurrence or absence of fish 

or surface water (Chapter 2, Riparian Areas and Wetlands, RICA-MA-1; Appendix D: Aquatic and Riparian Management 

Strategy, Riparian Conservation Areas, Riparian Conservation 

Area Widths). The RCAs help identify activities and authorized 

uses that may affect riparian condition. 

The INFISH RCAs were developed based on science that 

supported the RCA widths as adequate to protect streams from 

non-channelized sediment and sufficient to provide other riparian 

functions. The Aquatic and Riparian Management Strategy

included a process for using site-specific data and analysis to 

modify RCA widths where appropriate. In the absence of site-
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

specific analysis, the default widths are used. 

Riparian Areas 

and Wetlands

In the Draft RMP/EIS, much of the Aquatic and Riparian 

Management Strategy (ARMS) document is devoted to listing 

and describing actions that are also addressed in the various 

management actions in the Alternatives, including the 

management actions determined by Owyhee County to be 

consistent with its own Owyhee County Natural Resources 

Plan. The frequent redundancy of objective and action that are 

described in different verbiage in the ARMS and Alternatives 

leads to considerable confusion as to what the guiding 

language would actually be.

In the Final EIS, the goals, objectives, and management actions 

for the Water Resources, Riparian Areas and Wetlands, Fish, 

and Special Status Species sections in Chapter 2 were made 

consistent with the goals, objectives and management actions 

provided in the Aquatic and Riparian Management Strategy 

(ARMS; Appendix D, Tables D-6, D-7, and D-8). ARMS also 

included the priorities for achieving those goals, objectives and 

management actions (Tables D-3 and D-5).

Riparian Areas 

and Wetlands

The proper functioning condition process is neither intended for 

nor suitable for determining trend and while it may be useful for 

documenting probable change over a very long term, it is not 

suited to the kind of trend analysis needed for short-term 

management decisions.

The Final EIS identified the use of proper functioning condition

(PFC) assessments to determine if a stream channel is 

functioning properly, functioning-at-risk or non-functioning due to 

BLM authorized uses. The PFC assessments were used to 

identify where to focus inventory and monitoring and to assist in 

developing actions to improve riparian condition. Site-specific 

data using protocols such as Multiple Indicator Monitoring 

(Burton et al., 2011) would be used to determine short- and longterm trends in riparian and in-stream condition over time. 

Riparian Areas 

and Wetlands 

In the Draft RMP/EIS, the Aquatic and Riparian Management 

Strategy proposes the following relationship of priority status 

based on proper functioning condition (PFC) and Habitat 

Condition (HC) ratings. This approach, as modified below, 

appears to be generally consistent with the Owyhee County 

Natural Resources Plan. 

HC Rating PFC Rating

Conservation Reach (PFC, PNC)

High Priority Restoration Reach Priority 1 (FAR-NA, FAR-DN)

Mod. Priority Restoration Reach Priority 2 (FAR-UP, NF)

Low Priority Restoration Reach Priority 3 (PFC)

Where:

PFC – Proper Functioning Condition

PNC – Potential Natural Community

FAR-NA – Functioning-at-Risk with No Apparent Trend 

FAR-DN – Functioning-at-Risk with a Downward Trend

FAR-UP – Functioning-at-Risk with an Upward Trend

The comment refers to the Draft RMP/EIS, Appendix D: Aquatic 

and Riparian Management Strategy, in Table D-4. The table 

provided a crosswalk between priority rankings for special status 

fish habitat management and riparian area management. The 

comment correlated a habitat condition rating of Conservation 

Reach as proper functioning condition (PFC)/potential natural 

community (PNC). The Final EIS did not incorporate this 

comment.

The Final EIS displayed the relationship between PFC and PNC 

in Appendix D, Figure D-1. The text below the figure states, 

“after a stream reach has reached PFC, vegetation continues 

toward the potential natural community, livestock forage 

increases, and aquatic habitat improves. Improvement in water 

quality to levels that would result in the delisting of water quality 

impaired streams...would not occur until riparian condition 

improved beyond the initial rating of PFC.” For this reason, PFC 

does not equate to a PNC because instream and riparian 

condition, as well as water quality, would continue to improve 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

NF- Non-Functioning after the initial rating of PFC.

The BLM’s User Guide to Assessing Proper Functioning 

Condition and the Supporting Science for Lotic Areas (Prichard 

et al., 1998a), defined the potential of a stream as “the highest 

ecological status a riparian-wetland area can attain given no 

political, social, or economic constraints, and is often referred to 

as the potential natural community”. Streams can be rated as 

PFC but not be at PNC.

Social 

Conditions

Recognize that ranchers derive a significant level of quality of 

life from stewardship of the land they utilize. Clearly, the 

increased effort to achieve management goals is an increased 

opportunity to achieve a higher quality of life. The BLM should 

review and consider information directly related to social and 

community impacts relevant to the planning area, e.g. “Social 

and Community Impacts of Public Land Grazing Policy 

Alternatives in the Bruneau Resource Area of Owyhee County, 

Idaho” by J.D. Wulfhorst, Neil Rimbey and Tim Darden (2003). 

The BLM’s failure to consult and utilize this information leaves 

the Social Conditions section entirely inadequate. Consider 

and incorporate the discussions of the custom and culture of 

Owyhee County, contained in the Owyhee County Natural 

Resource Plan, into the environmental consequence analysis.

The Draft RMP/EIS, beginning at p. 4-766, provides a 

purported Summary of Direct and Indirect Impacts affecting 

“Quality of Life”. However, merely indicating the direction of 

change for each alternative does not provide a meaningful 

reference as to the magnitude or significance of changes or 

impacts. As noted in prior comment regarding the relative 

impact on livestock grazing opportunity, the variation among 

alternatives is in excess of 850%, which indicates a greater 

difference among alternatives than is indicated by mere 

direction of change. Clearly and accurately quantify the relative

effect of each alternative for livestock grazing opportunity, 

recreation, and transportation and travel.

The Final EIS revised the Social Conditions section of Chapter 3 

to include details on rancher quality of life from stewardship 

ethic, as well as detail from the report “Social and Community 

impacts of Public Land Grazing Policy Alternatives in the 

Bruneau Resource Area of Owyhee County, Idaho" (Wulfhorst et 

al., 2003). 

The tables that described impacts to quality of life for each 

alternative by identified stakeholders depended on qualitative 

information. Non-market values by their nature are difficult to 

quantify. Direction provided in the BLM Land Use Planning 

Handbook (H-1601-1) suggested the use of benefit transfer to 

evaluate the effects of these non-market values. The Final EIS 

discussed non-market values and social effects qualitatively in 

the absence of quantitative information.

Social 

Conditions

Twin Falls and Elko County communities stand to gain 

substantially once China Mountain Wind Project is operational. 

We provided you an unbiased independent analysis on 

Financial data used in the Final EIS to characterize potential 

effects from wind energy development were from the National 

Renewable Energy Lab’s Job and Economic Impact Assessment 
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Category Comment Response

financial and employment specifics of wind energy 

development.

Model, and utilize Federal sources of data (NREL, 2009c) and 

are considered unbiased. 

Social 

Conditions

The China Mountain Wind Project would provide social 

features, as discussed in Section 4.6.1, to the local community. 

This would include access, especially to the hunters and 

anglers. The proposed project would not change livestock 

grazing in the area. Building the project would maintain the 

quality of life for all groups. Operation of a wind farm would not 

affect quality of life for ranchers or hunters using the area.

A separate EIS addressing the effects related to the China 

Mountain Wind Energy Project will occur after the completion of 

the Idaho and Southwestern Montana Sub-Regional Greater 

Sage-Grouse Resource Management Plan Amendment and the 

Jarbidge RMP. 

Social 

Conditions

In the Draft RMP/EIS on p. 3-89, Social Conditions, you have 

left one significant "Connected" group out and those include 

"farmers' to which have a significant economic impact in the 

area and their livelihoods at stake. Why would you leave such 

a group out?

Cultural or emotional investment connects farmers to the 

planning area. This fits the definition of disconnected groups as 

currently defined in the Draft RMP/EIS. This categorization of 

connected and disconnected groups has been revised for the 

Final EIS in order to portray a more inclusive approach that does 

not categorize individuals and groups who are culturally and 

emotionally connected to the planning area as “disconnected.” 

Employment and income information for the Farm and 

Agricultural Services sectors was included in the Draft RMP/EIS 

(see Tables 3-52 and 3-53). The Final EIS revised this 

information to include the most recent available data on these 

sectors. In addition, information on the importance of agriculture 

was included in the Final EIS Economic Conditions section 

under Impacts from Livestock Grazing Actions. Chapters 3 and 4 

of the Final EIS highlighted the importance of agriculture to the 

area. 

Social 

Conditions

In the Draft RMP/EIS on p. 4-757, under Hunters and 

Fisherman, you do not mention upland game bird hunters.

In the Social and Economic Features section of Chapter 4, the 

term Recreators was broken down into more specific groups, 

including Hunters and Fishermen. This term included all types of 

hunters and fishermen that use the planning area. We did not 

break them down further as you have suggested.

Social 

Conditions

The State agrees that Alternative IV-B in the Draft RMP/EIS 

best accomplishes the need to restore the resiliency of 

ecosystem and structure and function through restoration 

projects and managing uses. However, the preferred 

alternative fails to both adequately account for the impact to 

wildlife from the deleterious impacts of wildfire and the impact 

to the human environment by unnecessarily restricting multipleuse activities.

The term “human environment” is defined as the “natural and 

physical environment and the relationship of people with that 

environment” (CEQ NEPA regulations, 40 CFR Sec. 1508.14). 

Both the Draft RMP/EIS and Final EIS consider a wide range of 

alternatives that allow varying levels of multiple-use activities. 

The Wildlife section of Chapter 4 analyzed the impacts of wildfire 

on wildlife by alternative. The Social and Economic Features

section in Chapter 4 analyzed the effects to the human 
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Category Comment Response

environment, including social and economic conditions, for all 

alternatives. 

Social 

Conditions

Please change the impactions from management specific to 

alternatives in the Social and Economic Features Impacts 

section of Chapter 4 in the Final EIS due to Owyhee Public 

Lands Management Act of 2009 creating the Bruneau-Jarbidge 

Wilderness and designated the Bruneau and Jarbidge Rivers 

Wild and Scenic Rivers. These two designations change the 

impacts. The Final EIS should document the impacts from this 

legislation.

The Final EIS revised the analysis in Chapter 4 due to the 

designation of the Bruneau-Jarbidge Rivers Wilderness and the 

Wild and Scenic Rivers. However, the impacts from the 

legislation of designating were not included in the Final EIS 

analysis as Congress made the designation, not the Final EIS. 

Any effects from designation would be the same for each 

alternative.

Social 

Conditions

It is critical that any Alternative selected by the Jarbidge 

Planning Team considers correct socio-economic analysis of 

development, multiple use, and resource management 

throughout the document.

When selecting an alternative, the BLM decision-maker will 

determine which alternative is the environmentally preferable 

alternative, taking into account both the human (social and 

economic) environment and the natural environment.

Soil Resources Soil erosion created by BLM management activities and 

authorized uses should be mitigated regardless of the erosion 

potential. Conversely, if activity impacts can be mitigated there 

is no reason to arbitrarily disallow the activity based solely on 

percent slope.

A reasonable range of alternatives addressing soil erosion from 

a variety of resource activities and uses was analyzed in the 

Final EIS (Chapter 2, Soil Resources section). Management 

actions for minimizing soil erosion was also included in 

Alternative VI (Proposed RMP). 

Soil Resources The Water Erosion Potential map (Map 6) of the Draft 

RMP/EIS is in substantial error and should not include private 

lands that are currently being farmed and have their own 

erosion controls. 

The “Water Erosion Potential” map (Map 5) has been updated in 

the Final EIS to display water erosion potential only on BLMmanaged lands.

Soil Resources Page 3-17 of the Draft RMP/EIS includes a footnote that shows 

the scale for the level of crust cover. What reference is used to 

determine the different level of percent of crust as being high, 

moderate and low? This section addresses some of the various 

plant communities on the percent of crust, but there is no 

reference to ecological sites and the potential of the percent 

crust by sites. The amount of crust should be addressed by 

ecological sites that would address the normal percent of crust 

and potential for each site. The information within a site writeup would identify some of the factors that influence the amount 

of crust like soil texture as noted in this section, various plant 

communities that may be influencing amount of crust.

The Final EIS has been updated by adding a reference to the 

crust cover scale and by further discussing crust cover potential 

within the planning area.

Soil Resources Page 3-31 in the Draft RMP/EIS states that 33 percent of the 

planning area is mapped as grasslands but only 1 percent 

should be grassland based on soil site description. This 

paragraph should explain that the majority of the grasslands 

As recommended, the discussion related to grasslands has been 

updated between the Draft RMP/EIS and the Final EIS
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Category Comment Response

are an early successional stage of a shrub community which is 

the major community based on soil site descriptions.

Soil Resources Page 3-7 of the Draft RMP/EIS states “Most of the planning 

area contains soils with medium or greater potential for water 

erosion or moderate or greater potential for wind erosion. 

Some of these areas overlap (Table 3-2, Map 5, and Map 6).” 

However, Maps 5 and 6 cannot be relied upon because they 

reflect arbitrary different standards being used for different soil 

maps, and do not provide the public a reasonable opportunity 

to comment upon their veracity. For example, both maps show 

distinct “squared off” erosion potential lines as a result of 

changes in the definition and/or standard of reporting between 

soil surveys. This results in Map 5 reporting that wind erosion 

is “moderate” on one side of the arbitrary line but “severe” on 

the other side of the arbitrary line; is “slight” on one side of the 

arbitrary line but “moderate” on the other side of the arbitrary 

line, etc. The same type of differences occurs on Map 6, 

purportedly demonstrating Water Erosion Potential. It is 

impossible to know which, if either, survey is accurate, but they 

cannot both be relied upon for any decision-making by the

BLM. 

Natural Resources Conservation Service Soil Survey 

Geographic Database soils data was used in production of the 

Wind Erosion Potential and Water Erosion Potential Maps (Maps 

4 and 5). The imperfections and abrupt line changes in the 

representation of the data are a consequence of soil mapping 

and survey areas and the process in which these separate 

mapping units are tied together into digital data. 

Soil Resources Page 3-7 of the Draft RMP/EIS states “Erosion resulting in rill 

and gully formation is estimated to be low over most of the 

planning area except on the sandy-alluvial soils of the Snake 

River Sediments and the clayey-rhyolitic soils of the Jarbidge 

Foothills. Some of the soils in these areas occur on steep 

slopes with naturally low vegetation cover and are inherently 

prone to erosion.” However, the Draft RMP/EIS errs in not 

reporting the extent, acreage, or percentage of “most of the 

planning area” versus the “sandy-alluvial soils” and the “clayeyrhyolitic soils”. This is important in planning and to the ability for 

the public to comment, because there is a difference in the 

“affected environment” if “most” means “50.1%” or if “most” 

means “99.9%” of the planning area. The lack of specificity 

prevents the public from making meaningful comment to this 

representation by the Draft RMP/EIS. The same is true of the 

statement that “some” of the soils are inherently prone to 

erosion.”

The Chapter 3 Soil Resources section has been clarified in the 

Final EIS by removing generic quantifiers such as “most” and 

“some”. 
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Category Comment Response

Soil Resources Page 3-17 of the Draft RMP/EIS discusses Biological Soil 

Crusts, but does not adequately describe the affected 

environment as it pertains to the ecological potential of the 

different soils, elevations, and precipitation areas. That is, the 

Draft RMP/EIS does not discuss the monitoring results in terms 

of what is “normal” or the “range of normal” for such different 

areas, and whether the monitoring concludes any departure 

from the “range of normal”. In addition, the “scale” used to 

describe crust cover is an “absolute” scale, and is employed 

without regard for or discussion of the ecological potential. For 

example, the Draft RMP/EIS states: “Aspen, greasewood/basin 

wild rye, and mountain big sagebrush/blue bunch wheatgrassIdaho fescue had no recorded cover of biological crust.” 

However, little-to-no biological crust (i.e. “very low crust cover 

= less than 3%” on the absolute scale) within these vegetation 

types represents the “norm”. The Draft RMP/EIS is wrong in 

not discussing this normality or degree of departure from the 

“norm” where it may exist.

Chapter 3 of the Draft RMP/EIS described the affected 

environment for biological soil crusts. Providing a description of 

what is “normal” or “the range of normal” is not the purpose of 

Chapter 3. The purpose of the affected environment is to provide 

a description of the existing environment to be affected by the 

alternatives to be analyzed (40 CFR 1502.15). 

Soil Resources The Draft RMP/EIS is wrong in not discussing that biological 

soil crusts also may inhibit seedling germination of non-native 

and native grass species, and may inhibit moisture infiltration 

into the soil.

The Final EIS has been updated and Chapter 4, in the Soil 

Resources section, discusses water movement in the soil profile 

and vegetation establishment.

Soil Resources We submit “Biological Crust Cover for 23 Allotments”, which 

relates to what are commonly termed the Stipulated Settlement 

Agreement Allotments. This paper demonstrates, relative to 

these 23 allotments (without even considering the effects of 

seedings, past burns, and other disturbances), biological crusts 

are being maintained within the range of their ecological 

potential.

BLM used data collected across the entire planning area during 

the 2006 and 2007 field seasons to adequately describe the 

affected environment. Relying on the data presented which is for 

23 allotments and not the entire planning area would be 

arbitrary.

Soil Resources In the Upland Vegetation section of the Draft RMP/EIS, there is 

no analysis of management actions that will be taken for 

biological crusts. We remind BLM that healthy biological crusts 

in the sagebrush matrix as well as on the surface of slickspots 

help prevent weed invasion into the matrix and slickspots.

Management actions for biological crusts were included in 

Alternatives I, IV, V, and VI of the Final EIS. An analysis of the 

management actions for biological crusts is included in Chapter 

4, Soil Resources section and Upland Vegetation section. 

Soil Resources The presence of taller shrubs trap wind-blown soils. Windblown soils are of concern to slickspot peppergrass habitat and 

populations. Soil deposited on slickspots and the surrounding 

sagebrush matrix would adversely alter site hydrology, 

increase nutrient composition that may foster weed 

The Final EIS analyzed the impacts of erosion on special status 

plant species in Chapter 4 of the Final EIS through the 

assumption that increasing perennial vegetation cover would 

reduce erosion. The Chapter 4 Soil Resources section provided 

an analysis of vegetation treatments, livestock grazing, 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

proliferation, and have many other adverse impacts. The 

disturbance from livestock grazing generates dust that erodes 

and is then deposited in slickspots. 

While mapping of "potential" is fine - how is the potential for 

wind erosion affected by the presence of vegetative cover? By 

livestock trampling disturbance? By both? BLM must provide 

mapping and analysis that examines these factors, and a set of 

alterative actions that addresses this. 

trampling, and vegetative cover on soil erosion across all 

alternatives. 

Soil Resources Please provide detailed analysis and mapping of a range of 

alternatives that serve to minimize dust production from the 

planning area. This must include specific measurement of 

trampling impacts, and establishment of upland and riparian 

standards of livestock trampling disturbance use for any lands 

that continued to be grazed. An emphasis on restoration of 

biological crusts to minimize wind-caused soil erosion is 

critical.

The Chapter 4 Soil Resources section in the Final EIS provided 

an analysis of vegetation treatments and livestock grazing on 

soil erosion across all alternatives.

Soil Resources There is a shocking lack of information and analysis of soils. 

BLM cannot develop a reasonable range of alternatives until it 

provides much more substantial information and analysis of the 

current degree and severity of soil degradation, losses, and 

desertification processes.

The Chapter 3 Soil Resources section of the Final EIS 

expresses potential for water and wind erosion and provided 

data on the condition of soil in the planning area. The Chapter 4 

Soil Resources section provided an analysis of management for 

Soil Resources, Upland Vegetation, Wildland Fire Ecology and 

Management, Livestock Grazing, Transportation and Travel, 

Land Use Authorizations, and Minerals on soils and erosion for 

each alternative.

Soil Resources BLM provides minimal information on land uses on soils. How 

will summer grazing disturbance impact soils of various types 

and condition compared to winter, or grazing when soils are 

saturated? How long-lasting are heavy to severe trampling 

impacts during these times on soils of varying types? How 

much of the planning area currently receives heavy trampling? 

Where? Where have soil horizons been lost due to erosion? 

Are depleted soils and monoculture coarse grasses 

responsible in part for the need to feed so many supplements 

to livestock? What is the current soil formation rate? How has 

past erosion exceeded that rate, and where? How will the 

various alternatives affect this rate? How will depleted or 

degraded soils hinder rehabilitation actions?

The Final EIS recognized erosion of soils occurs within the 

planning area (Soil Resource section Chapters 3 and 4) and 

some areas and soil types are more erosive than other areas 

and soils. The Final EIS also acknowledged human activities 

could accelerate the erosion of topsoil above what would occur 

naturally, through a variety of ground-disturbing activities. The 

Chapter 2 Soil Resources section identified management actions 

to reduce erosion from natural and human-caused disturbances. 

The Chapter 4 Soil Resources section provided an analysis of 

management for Soil Resources, Upland Vegetation, Wildland 

Fire Ecology and Management, Livestock Grazing, 

Transportation and Travel, Land Use Authorizations, and 

Minerals on soils and erosion and how each alternative affects 

soil resources. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Soil Resources BLM fails to provide mapping and analysis of the soil health, 

biological crust condition and composition, erosion rates from 

current activities, predicted erosion rates under all alternatives, 

measures of soil compaction, and a host of other information 

and analysis necessary to develop and analyze a suitable 

range of alternatives.

The Chapter 3 Soil Resources section of the Final EIS 

expressed potential for water and wind erosion and provided 

data on the condition of soil in the planning area. The Chapter 4 

Soil Resources section provided an analysis of management for 

Soil Resources, Upland Vegetation, Wildland Fire Ecology and 

Management, Livestock Grazing, Transportation and Travel, 

Land Use Authorizations, and Minerals on soils and erosion for 

each alternative.

Soil Resources The analysis of effects to soils under the limited alternatives is 

minimal. BLM basically points to other Draft RMP/EIS Sections 

- see 4-50, heaping all the confusion and uncertainty of the 

Vegetation, Fire, Treatments, and other sections on top of the 

substanceless soils section.

The Chapter 4 Soil Resources section of the Draft RMP/EIS on 

page 4-50 does not point the reader to other sections. It simply 

lists the sections of Chapter 2 that has management that impacts 

soil resources. These impacts from management to Soil 

Resources are analyzed in detail in the Chapter 4 Soil 

Resources section. 

Soil Resources There is no real analysis of the current loss of soil horizons, 

widespread pedestaling, depletion of essential nutrients, loss 

of biological crusts, ecological conditions of soils in slickspots 

and surrounding habitats, soil conditions in all vegetation 

communities that are still native in composition, etc. 

The Final EIS Chapter 3 Soil Resources section has been 

updated to include more detailed information on the soils within 

the planning area. The analysis on how each alternative effects 

soil resources can be found in the Chapter 4 Soil Resources

section. 

Soil Resources We have no idea how the information on the Water Erosion 

Potential map (Map 6) of the Draft RMP/EIS was obtained and 

how "high" erosion classifications were assigned. What 

reference material was used to develop the erosion potential 

information in Table 3-2 in the Soil Resources section?

BLM used Natural Resources Conservation Service Soil Survey 

Geographic Database soils data to identify erosion potential.

Special 

Recreation 

Management 

Areas

The BLM should provide further clarification on Special 

Recreation Management Area (SRMA) designations to comply 

with the new BLM guidance released in October 2010 

(Instruction Memorandum 2011-004). This new BLM guidance 

modified the matrix the BLM used in the Appendix M of the 

Draft RMP/EIS to classify the existing and desired physical 

setting for each SRMA (Table M-1, A-119). The “physical 

setting” criteria have changed and will likely impact the 

existing, and potentially the prescribed, character of each 

SRMA. We recommend the BLM look at the new guidance on 

SRMA’s and make sure the classifications for proposed 

SRMA’s comply. 

The Final EIS incorporates the new BLM Manual 8320, Planning 

for Recreation and Visitor Services, which has 3 categories of 

allocation for Recreation Management Areas (RMAs): Special 

Recreation Management Areas, Extensive Recreation 

Management Areas, and public lands not designated as RMAs. 

Special 

Recreation 

Management 

Do not designate the Canyonlands and the Jarbidge Foothills 

as Special Recreation Management Areas (SRMAs). SRMA 

designation must be limited to site-specific areas and not largeThe Canyonlands and Jarbidge Foothills Special Recreation 

Management Areas are presented and analyzed as part of a full 

range of alternatives. Alternative VI (Proposed RMP) designates 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Areas scale landscapes. In addition, the increased recreational 

impact and pressure that will result from designation as a 

SRMA will adversely affect sensitive resources the BLM is 

trying to protect that are located within those areas. REC-I-MA6 and 7 are unacceptable; as the activities proposed are 

already occurring under current management. The 

inaccessibility of these areas, the restrictions imposed by 

Omnibus Public Land Management Act of 2009, and 

transportation and travel management plans already prevent 

off - road use and other conflicting uses. There is no need for 

further restrictions.

Canyonlands and Jarbidge Foothills as Extensive Recreation 

Management Areas. The Final EIS incorporated these changes 

into Appendix H: Recreation Management Areas. 

Special 

Recreation 

Management 

Areas

The BLM should manage the entire planning area as an 

Extensive Recreation Management Area. 

The Final EIS and Alternative VI (Proposed RMP) incorporates 

the new policy direction found in BLM Manual 8320, Planning for 

Recreation and Visitor Services, which has 3 categories of 

allocation for Recreation Management Areas (RMAs). Special 

Recreation Management Areas, Extensive Recreation 

Management Areas, and public lands not designated as RMAs.

Special 

Recreation 

Management 

Areas

Special Recreation Management Areas (SRMA's), areas of 

focused management. In some cases, a focus on one form of 

recreation would lead to reduction in opportunities and 

restrictions placed on other users. For example, both the 

Jarbidge Foothills and Canyon Lands SRMA's in Alternative I 

and IV have a focused management of non-motorized 

recreation on 348,000 acres. In both of these SRMA's there is 

no mention of motorized recreation. Both of these areas have a 

good network of popular roads and trails. So, why do we need 

SRMAs? 

The Final EIS analyzed the Canyonlands and Jarbidge Foothills 

Special Recreation Management Areas (SRMAs) as part of a full 

range of alternatives. Alternative VI (Proposed RMP) designates 

Canyonlands and Jarbidge Foothills as Extensive Recreation 

Management Areas (ERMAs). The focused management of 

recreation activities associated with SRMAs are used to manage 

an area due to historical, present, and future recreational use 

trends. This focused management is intended to preserve the 

setting and recreational experience of the area. SRMA or ERMA 

designations do not exclude one recreation use over another 

recreation use.

Special 

Recreation 

Management 

Areas

The No Action Alternative does not specify which segment of 

Salmon Falls Creek canyon would be managed as a Special 

Recreation Management Area (SRMA). It should be specific. It 

is difficult to tell what areas are being proposed as SRMA's for 

the other Alternatives, and what areas are being proposed for 

Extensive Recreation Management Areas. We oppose either 

designation for the segment below Balanced Rock crossing.

The No Action Alternative Special Recreation Management Area 

(SRMA) boundary was not clearly defined in the 1987 RMP for 

Salmon Falls Creek. Refer to Appendix H: Recreation 

Management Areas for a description of SRMAs and Extensive 

Recreation Management Areas focused management. See 

Maps 61 - 66 for SRMAs by Alternative.

Special 

Recreation 

Management 

Areas

Alternative IV proposes 5 different Special Recreation 

Management Areas (SRMAs). Looking at Map 54 of the Draft 

RMP/EIS, it appears that some of these SRMAs overlap each 

other. The Jarbidge Forks SRMA appears to overlap the 

The Jarbidge Forks and the Canyonlands Special Recreation 

Management Area boundaries do not overlap. They have a 

shared boundary. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Canyonlands SRMA. While these two SRMA have a different 

emphasis, it might be possible to combine these two areas 

under the same SRMA plan.

Special 

Recreation 

Management 

Areas

A majority of the Resource Advisory Council supports REC-1-

MA-2, and REC-1-MA-3, with allowances for transmission 

lines, communication sites, and for current resource uses with 

a minority disagreeing.

 

The Balanced Rock Special Recreation Management Area

(SRMA) with its close proximity to Balanced Rock can provide 

picnicking/hiking for tourists and local community members. 

The Little Pilgrim SRMA offers access to the Snake River. 

The Final EIS has presented a range of Special Recreation 

Management Area (SRMA) designations. Alternative VI 

(Proposed RMP), REC-VI-A-1, propose the Balanced Rock and 

Little Pilgrim SRMAs.

Special 

Recreation 

Management 

Areas

The Burley Resource Area side of Salmon Falls Reservoir is 

reaching full capacity. Further develop the Jarbidge side in 

order to handle increased public use. The off road vehicle play 

areas in the reservoir bottoms when the water levels allow are 

of extra value for the area. This Special Recreation 

Management Area (SRMA) has the potential to support a wide 

range of recreation uses if properly developed. Clearly define 

the boundaries, as currently there are portions that extend 

considerable distance from the water and could lead to impacts 

on other resource uses. An SRMA designation should not 

prohibit transmission lines or communication sites. 

The Final EIS has presented a range of Special Recreation 

Management Area (SRMA) designations. Alternative VI 

(Proposed RMP) redesigned the SRMA boundaries for the 

Recreation Management Zones in the Salmon Falls Reservoir 

SRMA. The SRMA designation does not place right-of-way 

avoidance or exclusion prohibitions. 

Special 

Recreation 

Management 

Areas

The Bruneau-Jarbidge Special Recreation Management Area 

(SRMA) and the Jarbidge Forks SRMA were in existence prior 

to Omnibus Public Land Management Act of 2009 and will 

continue to receive public recreation use. Neither of these 

SRMA's should degrade the wilderness area and Wild and 

Scenic Rivers designation and in some cases may help the 

BLM management. The current primary use of the BruneauJarbidge SRMA is white water rafting, water levels only allow 

for a 1-2 month season of use. The creation of a trail system 

would allow for year around use of this area and expand the 

recreational opportunities this area has to offer.

The Final EIS has presented a range of Special Recreation 

Management Area designations. Omnibus Public Land 

Management Act of 2009 states (Sec.1503. Wilderness Areas 

(5) Trail Plan [A]); “The Secretary, after providing opportunities 

for public comment, shall establish a trail plan that addresses 

hiking and equestrian trails on the land designated as wilderness 

by this subtitle, in a manner consistent with the Wilderness Act 

(16 U.S.C. 1131 et seq.). The pending Owyhee Canyonlands 

Wilderness and Wild and Scenic Rivers Management Plan will 

analyze trail development in the wilderness. 

Special 

Recreation 

Management 

Areas

We are very concerned that BLM has considered a broad 

range of off-highway vehicle (OHV) Special Recreation 

Management Areas (SRMAs) and not more non-motorized use 

SRMAs or non-OHV focused SRMAs

The Final EIS included a range of alternatives that would allow 

off-highway vehicle use as well as non-motorized use areas. 

Alternative VI (Proposed RMP) proposes designating multiple 

Extensive Recreation Management Areas (ERMAs) to facilitate a 

variety of recreational uses. The focused management of 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

recreation activities associated with Special Recreation 

Management Areas (SRMAs) are used to manage an area due 

to historical, present, and future recreational use trends. This 

focused management is intended to preserve the setting and 

recreational experience of the area. SRMA or ERMA 

designations do not exclude one recreation use over another 

recreation use.

Special 

Recreation 

Management 

Areas

We are greatly concerned that expanded off-highway vehicle 

(OHV) torn-up areas will adversely impact native reptiles. Bare 

soil areas and some semblance of native shrubs are found in 

areas of hillier terrain and specific soils where OHV use is now 

being greatly imposed.

The travel management planning process and the subsequent 

monitoring plans will analyze motorized uses, including the use 

of off-highway vehicle. 

Special 

Recreation 

Management 

Areas

Aren't there also larger Special Recreation Management Areas 

near Salmon Falls Creek as well? Why not all of Antelope 

Pocket?

The Final EIS included Salmon Falls Reservoir Special 

Recreation Management Area as part of a range of Alternatives. 

Antelope Pocket is below the dam and projected to receive low 

recreation visits.

Special 

Recreation 

Management 

Areas

On p. ES-17, the third issue down states, "manage the 

Balanced Rock Special Recreation Management Area for nonmotorized boating". It is not possible to float Salmon Falls 

Creek down from Balanced Rock. Please do not encourage 

Salmon Falls Creek as an area to participate in flat water 

kayaking, rafting, or canoeing. 

The proposed Special Recreation Management Area is 

upstream from Balanced Rock Crossing not downstream and 

has 1.25 miles of shoreline and is an appropriate place to 

participate in non-motorized boating activities.

Special Status 

Fish and 

Aquatic 

Invertebrates

Some population information is provided on bull trout. Yet there 

is not an adequate analysis that reveals how few bull trout 

currently are present in the entire Distinct Population Segment, 

problems with connectivity between occupied reaches, and 

that examines the causes of low numbers. The BLM must 

examine the degree and severity of threats the Distinct 

Population Segment faces from climate change to livestock 

and road-produced sediment. This is needed to present a 

coherent and coordinated set of actions to restore and recover 

populations. A valid analysis of the cumulative impacts of 

roads, grazing, water developments, trailing, recent fire effects 

including Slide Rock, etc. must be undertaken. Population 

viability and persistence must be examined under a range of 

alternatives. 

The Final EIS included bull trout distribution, migration, and 

genetic information that was not available in 2009 when the BLM 

released the Draft RMP/EIS for public comment. The 

supplemental information was collected by the US Geological 

Survey (USGS) (Allen et al., 2010) and is provided in the Final 

EIS in Chapter 3, Special Status Fish and Aquatic Invertebrates, 

Jarbidge River Bull Trout. 

Based on the results of the USGS study, there is estimated to be 

four times the number of bull trout present in the Jarbidge River 

Distinct Population Segment than the 500 bull trout estimated to 

be present in the US Fish and Wildlife Service’s 2004 Draft 

Recovery Plan for the Jarbidge River Distinct Population 

Segment of Bull Trout (Salvelinus confluentus) (FWS, 2004). 

The cumulative impacts assessment for Alternative VI (Proposed 

RMP) considered threats to bull trout and their habitat from 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-556

Category Comment Response

livestock grazing, roads, water developments, wildland fire and 

other human activities and uses. This analysis is provided in 

Chapter 4, Cumulative Impacts, Special Status Fish and Aquatic 

Invertebrates. 

The Final EIS designed the restoration priorities in the Aquatic 

and Riparian Management Strategy (Appendix D) to promote 

population viability and persistence for bull trout in the long term. 

Conservation measures for the protection of Endangered 

Species Act-listed aquatic species are included in the Final EIS 

in Appendix E: Conservation Measures. These measures were 

also included in the Biological Assessment for the Proposed 

Jarbidge Resource Management Plan Final EIS. 

Special Status 

Fish and 

Aquatic 

Invertebrates

Chapter 3 of the Draft RMP/EIS (Table 3-25 on p. 3-39) 

describes Columbia River Basin bull trout. What happened to 

consideration of the unique Distinct Population Segment living 

at the southern periphery of the species' range?

The Final EIS clarified the relationship between Columbia River 

Basin bull trout, the Jarbidge River bull trout Distinct Population 

Segment and the importance of the Distinct Population Segment

relative to the southern-most portion of the species’ range in 

Chapter 3, Special Status Fish and Aquatic Invertebrates, under

Jarbidge River Bull Trout. 

Special Status 

Fish and 

Aquatic 

Invertebrates

The BLM's stream surveys in Table 3-25 are 9 years old. The information provided in the Draft RMP/EIS for Jarbidge 

River bull trout were the best information that was available at 

the time. Since then, the US Geological Survey (Allen et al., 

2010) collected additional data regarding bull trout movements 

throughout the Jarbidge Watershed. The Final EIS incorporated 

the new information into Chapter 3, Special Status Fish and 

Aquatic Invertebrates, Jarbidge River Bull Trout. 

Special Status 

Fish and 

Aquatic 

Invertebrates

The Draft RMP/EIS at p. 3-40 shows that there is very little 

movement of bull trout between the Jarbidge River and the 

East Fork Jarbidge River. This simplifies concerns about the 

small and very vulnerable population in the East Fork Jarbidge 

River, Dave Creek and Slide Creek as well as dewatering from 

Jim Bob Creek and other water development concerns, 

especially now that large areas in the Jarbidge Wilderness in 

the East Fork Jarbidge River watershed has burned.

The Final EIS included bull trout population and distribution 

information that was not available when the BLM released the 

Draft RMP/EIS for public comment. The US Geological Survey 

(USGS) (Allen et al., 2010) collected the supplemental 

information regarding bull trout movements throughout the 

Jarbidge Watershed. The Final EIS incorporated the new 

information into Chapter 3, Special Status Fish and Aquatic 

Invertebrates, Jarbidge River Bull Trout. 

Based on the results of the USGS study, there is estimated to be 

four times the number of bull trout present in the Distinct 

Population Segment than the 500 bull trout estimated to be 

present in the Draft Recovery Plan for the Jarbidge River Distinct 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-557

Category Comment Response

Population Segment of Bull Trout (Salvelinus confluentus) (FWS, 

2004). The USGS study documented substantial movement of 

bull trout within the upper East Fork Jarbidge River and its 

headwater streams and within the upper West Fork Jarbidge 

River and its headwater streams, but very little bull trout 

movement between these two watersheds. 

Special Status 

Fish and 

Aquatic 

Invertebrates

We are very concerned that this Draft RMP/EIS and the BLM 

Standards and Guidelines for Rangeland Health Assessments 

and other actions do not adequately address the role of 

intermittent and ephemeral drainages in a high desert 

ecosystem in transporting large volumes of sediment into 

canyon and other stream systems during a very brief period of 

intensive late winter-spring flows. 

Alternative VI (Proposed RMP) included direction for seasonally 

flowing and intermittent streams in Chapter 2, Riparian Areas 

and Wetlands, management action RI-CA-MA-1, Category 4. 

In the Final EIS, information on the miles of intermittent and 

ephemeral (seasonally flowing) streams is provided in the 

Chapter 3 Water Resources section. Definitions for intermittent 

and ephemeral streams are provided in Chapter 3, Riparian 

Areas and Wetlands, and in the Glossary. 

The impacts analysis in Chapter 4 for Special Status Fish and 

Aquatic Invertebrates focused on perennial streams because 

they have the most influence on streams containing special 

status fish and aquatic invertebrates. 

Special Status 

Fish and 

Aquatic 

Invertebrates

Make actions to restore bull trout and quality habitat and 

connectivity with US Forest Service lands in the upper Jarbidge 

River and Bruneau River watersheds a high priority of the Final 

EIS. This is necessary to recover populations, and the range of 

alternatives must examine it.

Actions to restore bull trout habitat on US Forest Service 

managed lands are beyond the scope of the Jarbidge RMP.

The Special Status Species section for all action alternatives in 

Chapter 2 included management actions under Management for 

Special Status Species in Riparian Areas, Wetlands and 

Streams, SS-CA-MA-19 through SS-CA-MA-21 to improve 

habitat quality and connectivity for bull trout. The Riparian Areas 

and Wetlands sections included management actions RI-CAMA-1 listed the riparian management priorities, with specific 

stream priorities in Appendix D: Aquatic and Riparian 

Management Strategy.

Special Status 

Fish and 

Aquatic 

Invertebrates

For bull trout, redband trout, spotted frog, California floater and 

other aquatic species, the BLM must analyze the degree of 

predicted impacts to watersheds, drainage networks, stream 

flows, pattern of runoff, etc. The BLM must provide baseline 

information in water flows over all seasons of the year. How 

can the BLM increase perennial flows?

The Final EIS included an impacts analysis for numerous aquatic 

species such as bull trout, redband trout, spotted frog, California 

floater, and their habitat. The Chapter 4 Water Resources, 

Riparian Areas and Wetlands, and Special Status Fish and 

Aquatic Invertebrates sections provided this information along 

with an assessment of direct, indirect and cumulative impacts. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-558

Category Comment Response

Special Status 

Fish and 

Aquatic 

Invertebrates

Please identify all critical bull trout habitat tributaries, all 

redband trout tributaries, all potential spotted frog, all sagegrouse brood rearing, and all tributaries including intermittent 

and ephemeral streams as priority waters.

The Final EIS analyzed a range of priority streams among the 

alternatives. Alternative VI (Proposed RMP) identified the 

priorities for streams containing bull trout, redband trout, and 

spotted frog in Chapter 2, Riparian Areas and Wetlands, in RICA-MA 1 through RI-CA-MA 7 and in RI-VI-MA-1 through RI-VIMA-3. Map 24 “Bull Trout and Redband Trout Distribution” in the 

Final EIS display the streams containing redband trout and bull

trout. 

The Final EIS included management direction for seasonally 

flowing or intermittent streams in Chapter 2, Riparian Areas and 

Wetlands, RI-CA-MA 1, Category 4 and in Appendix D: Aquatic 

and Riparian Management Strategy, Riparian Conservation 

Areas, Riparian Conservation Area Widths, under Category 4. 

The Final EIS identified streams containing special status fish as 

a higher priority than seasonally flowing or intermittent streams. 

The Final EIS in Chapter 4, Riparian Areas and Wetlands, 

Methods and Assumptions, Riparian Areas, considered the 

influence of intermittent streams on streams containing special 

status species.

Special Status 

Fish and 

Aquatic 

Invertebrates

When were redband trout lost from so many drainages near 

Elk Mountain? The BLM must set a timetable and establish a 

set of specific actions focused on livestock grazing removal 

and large-scale reductions in numbers of livestock in any 

remaining degraded watersheds in order to sustain isolated 

and threatened rare native fish species that are in danger of 

extinction.

The BLM assumed the comment referred to Map 18 “Streams 

Containing Bull Trout and Redband Trout” in the Draft RMP/EIS, 

which inadvertently omitted several known redband trout 

streams. The Final EIS updated the map to include all of streams 

containing bull trout and redband trout (Map 24). The Final EIS, 

Appendix D: Aquatic and Riparian Management Strategy, Table 

D-3 and Table D-5, contain information on the condition of the 

redband trout streams and their restoration priority. Chapter 3, 

Special Status Fish and Aquatic Invertebrates, under the 

subheading for Interior Columbia River Redband Trout, provided 

a summary of the current redband trout data. 

Special Status 

Fish and 

Aquatics

On p. 3-84, Table 3-46 of the Draft RMP/EIS, please designate 

what portion of Salmon Falls Creek contains redband trout. It is 

not the section below Balanced Rock as shown on Map 18.

The Final EIS corrected the information on the distribution of 

redband trout and bull trout. The BLM contacted Idaho 

Department of Fish and Game and confirmed redband trout are 

present in Salmon Falls Creek downstream of Balanced Rock 

Crossing. Redband trout presence and abundance varies 

seasonally. The Final EIS display the updated information on

Map 24, “Bull Trout and Redband Trout Distribution”. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-559

Category Comment Response

Special Status 

Fish and 

Aquatics

Appendix H., p. A-94, provides a description of redband trout 

habitat based on Muhlfeld (2002). The Idaho Department of 

Fish and Game recommends consideration of research from

Idaho and the project area that was recently published as a 

basis to change the habitat description to, "Occupies habitats 

with less fines (10%) and more cobble (>25%), in reaches with 

stable stream banks (>80%) that are more shaded (>20%), in 

water temperatures from 10-18°C (Meyer et al., 2010).

The Final EIS incorporated the information for substrate, stream 

banks streamside shade and water temperature for redband 

trout as provided in Meyer et al., 2010. The information can be 

found in the Aquatic and Riparian Management Strategy 

(Appendix D), Table D-2, Redband Trout Habitat Condition 

Indicators and Thresholds.

Special Status 

Plants

The Final EIS should incorporate the information collected from 

project related surveys, which include the fact that no slickspot 

peppergrass was found along the northern outbound haul 

route. 

The Final EIS revised Chapter 3, Special Status Plants section, 

to include a discussion on slickspot peppergrass stage 1 

inventories.

Special Status 

Plants

The Final EIS should refer to the Bureau of Land Management 

Slickspot Peppergrass Inventory and Clearance Standards, 

May 13, 2010 as the appropriate inventory method.

The Final EIS included a reference to the most current slickspot 

peppergrass inventory and clearance standards in Appendix E: 

Conservation Measures. 

Special Status 

Plants

The Draft RMP/EIS states: “Allowing activities to occur with 

mitigation for adverse effects could result in destruction of 

special status plants, populations, seed banks, or habitats in 

localized areas.” This statement is inaccurate and presumptive. 

If mitigation were done properly, the opposite of the statement 

would be true.

The Draft RMP/EIS statement is correct because it is talking 

about localized areas. Mitigation can have a net benefit to 

special status species as a whole, but projects that have ground 

disturbing activities will locally impact plants within the project 

footprint. Plant surveys do not always detect populations of 

special status plant species, particularly annuals, and even 

though mitigation measures are in place adverse effects may still 

take place locally.

Special Status 

Plants

The State of Idaho takes particular umbrage with BLM's 

decision to nominate the Inside Desert Area of Critical 

Environmental Concern in order to protect Slickspot 

peppergrass. The State strongly encourages the BLM to drop 

this nomination in the final alternative.

As you are undoubtedly aware, the State of Idaho and the BLM 

entered into a Candidate Conservation Agreement in 2003 to 

protect the species and its habitat while maintaining 

predictable levels of land use. Without any demonstrable 

scientific information linking the abundance of the species to 

livestock use, Federal grazing permittees willingly modified 

their operations to include conservation measures to avoid, 

mitigate, and monitor the effects of livestock use on Lepidium 

papilliferum. Not only does the BLM have the measures of the 

Candidate Conservation Agreement currently in place to 

The Final EIS analyzed a range of different Areas of Critical 

Environmental Concern (ACECs) among the alternatives. 

Alternative VI (Proposed RMP) did not include a proposal for the 

Inside Desert ACEC. The Inside Desert ACEC was nominated 

during scoping and included measures designed to protect 

slickspot peppergrass and its habitat. The two primary threats to 

slickspot peppergrass as identified by the US Fish and Wildlife 

Service are wildfire and invasive non-native annual plants. 

Livestock grazing is listed as a secondary or an aggravating 

threat. Grazing amplifies degraded habitat conditions created by 

the primary threats. As stated in the 2009 listing decision, 

"Livestock pose a threat to Lepidium papilliferum primarily 

through mechanical damage to individual plants and slickspot 

habitat." 
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protect the species, but the BLM has the added regulatory 

protection of an Endangered Species Act -listing should 

credible scientific information demonstrate an actual need for 

increased protection.

Special Status 

Plants

Consider the following: Species delimitation tests of endemic 

Lepidium papilliferum and identification of other possible 

evolutionarily significant units in the Lepidium montanum

complex (Brassicaceae) of western North America by Steven 

R. Larson, C. M. Culumber, R. N. Schweigert, and N. J. 

Chatterton. 

The presented literature is not relevant to the Final EIS analysis. 

The Final EIS included management actions, in Chapter 2 

Special Status Species section, designed to provide protection to 

Lepidium papilliferum. The Final EIS added a more detailed 

discussion on slickspot peppergrass to Chapter 3 and 4, Special 

Status Plants sections. 

Special Status 

Plants

Consider the following ground cover data taken for 23 

Allotments within the planning area. The ground cover was 

taken for the following allotments: Blackrock Pocket, Blue 

Butte*, Bracket Bench, Bruneau Hill, Camas Slough, Canyon 

View*, Clover Crossing*, Cedar Creek, Coonskin, East Juniper 

Draw*, Echo 4, Echo 5, Echo Clover*, Flat Top, Grassy Hills 

AMP, Grindstone, Hagerman Group, Juniper Butte, Kubic, Noh 

Field, North Fork Field*, Pigtail Butte, Seventy-One Desert (* = 

No 2006 SWA data). Source: SWA RSD table and Cover 

Reports, Source: BLM 2006 Cover Reports, Access Database, 

"First Level"

The BLM used data collected across the entire planning area 

during the 2006 and 2007 field seasons as compared to the data 

presented which is for 23 allotments.

Special Status 

Plants

BLM has not conducted a necessary habitat and population 

analysis to ensure viability of slickspot peppergrass through 

preservation of habitats and restoration of degraded or 

fragmented areas of potential habitat.

The Final EIS added Map 21 “Slickspot Peppergrass Habitat” 

and revised Chapter 3 Special Status Plants section to include 

data on slickspot peppergrass and its habitat within the planning 

area. 

Special Status 

Plants

BLM must provide detailed mapping of all potential habitat for 

slickspot peppergrass, as well as concrete plans for gazing 

removal and livestock facility decommissioning and some road 

removals in the affected areas.

The Final EIS added Map 21 “Slickspot Peppergrass Habitat”.

Special Status 

Plants

BLM must tie existing areas together and re-connect habitats. 

It must provide for pollinator habitat as well. How can BLM 

maximize continued existence and recovery? Provide an 

expanded range of alternatives.

The Final EIS analyzed a range of vegetation restoration 

objectives among the different alternatives. Alternative VI 

(Proposed RMP) included objectives and management actions in 

Chapter 2, Upland Vegetation and Special Status Species

sections, that proposed to move plant communities towards a 

native shrubland community which would help reconnect habitat 

for sagebrush obligate species and provide habitat for pollinators 

of special status plant species.
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Special Status 

Plants

Special Status Plants (pp. 3-33 to 3-38) of the Draft RMP/EIS 

omits critical baseline information and analysis of the actual 

status of habitats and populations of these species. How 

degraded are habitats? How much of the habitat for all of these 

species is at risk to cheat grass invasion? How will the range of 

alternatives and each alternative aggravate conditions - and 

increase risk?

The Final EIS revised Chapter 3, Special Status Plant section, to 

include more up to date information on special status plants and 

specific information on slickspot peppergrass. Chapter 4 

analyzed the impacts to special status plants from actions 

associated with upland vegetation treatments, noxious weed and 

invasive plant control, wildland fire, livestock grazing, 

transportation and travel, and Areas of Critical Environmental 

Concern management for each alternative in.

Special Status 

Plants

There is no basis for understanding the impacts of the severe 

grazing pressures under many parts of the range of 

alternatives on pollinators for native plants - including life 

stages in soils, and their dispersion across the landscape. 

The Final EIS analyzed impacts to pollinators by alternative in 

Chapter 4 Special Status Plants. 

Special Status 

Plants

Why does BLM put out a Draft RMP/EIS in late 2010 that has 

2008 plant status?

The Final EIS updated the “Special Status Plants Occurring or 

Potentially Occurring in the Planning Area” table with the 2012 

special status plant status. 

Special Status 

Plants

Why is there no mapping that shows the location and 

dispersion of rare plant species in the planning area? The 

location of slickspot peppergrass potential vs. occupied 

habitat? 

Not all special status plant species are mapped due to the lack 

of extensive inventory for these species. The Final EIS did add 

Map 21 “Slickspot Peppergrass Habitat”

Special Status 

Plants

Despite all the efforts made to try to conserve slickspot 

peppergrass by Western Watersheds Project and others, BLM 

merely lists this species in Table 3-22, claims population vigor 

"fair" and habitat quality Fair. This, of course, is counter to all 

the information habitat degradation affecting specific element 

occurrences.

The Final EIS add a more detailed discussion on slickspot 

peppergrass to Chapter 3 and 4, Special Status Plants section.

Special Status 

Plants

The BLM must examine the footprint of military-permitted 

grazing levels, and the disturbance and conflicts with wildlife, 

promotion of weeds, losses and disturbance to slickspot 

peppergrass and other impacts that are caused.

The Final EIS revised Chapter 4 to include the military-permitted 

grazing on Juniper Butte Training Range as a cumulative impact.

Special Status 

Plants

The US Fish and Wildlife Service recommends the Final EIS 

contain program-specific conservation measures for all land 

use plan programs, particularly regarding ground disturbing 

activities in occupied habitat (areas known to contain the 

plant), to ensure that injury or mortality to slickspot 

peppergrass plants and seeds or impacts to slickspot 

microsites are avoided or minimized during periods when 

slickspot micro site soils are saturated as well as when the 

species is flowering. 

The Final EIS included program-specific conservation measures 

for slickspot peppergrass in Appendix E: Conservation 

Measures. 
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Special Status 

Wildlife

The planning area, including the proposed Jarbidge Foothills 

Area of Critical Environmental Concern, contains one of a few 

Greater sage-grouse population strongholds in the State of 

Idaho. The US Fish and Wildlife Service (FWS) encourages the 

Bureau to use the land use planning process to implement land 

use plan level conservation measures to avoid habitat 

fragmentation within this Greater sage-grouse population 

stronghold, and to focus additional habitat restoration efforts in 

this area if habitat degradation or loss occurs due to 

catastrophic events such as wildfire. The FWS also 

encourages the use of conservation measures identified in the 

Idaho Sage-grouse Advisory Committee's 2006 Conservation 

Plan for the Greater Sage-grouse in Idaho in the Browns 

Bench area, including measures that avoid habitat 

fragmentation near areas important for breeding, wintering, 

and lekking. 

There are several strongholds for sage-grouse in the State of 

Idaho, including the Bruneau Plateau to the west of the planning 

area and Shoshone Basin east of the planning area. Sagegrouse in the Brown’s Bench area were linked to sage-grouse in 

Shoshone Basin and northern Nevada. The Proposed RMP 

prescribed restoration of habitat to enlarge and connect 

sagebrush habitats for sage-grouse in the planning area. The 

Jarbidge Local Sage-grouse Working Group Plan as well as the 

Idaho Sage-grouse Advisory Committee’s 2006 Conservation 

Plan for Greater Sage-grouse were used when considering 

restoration of sage-grouse habitat. 

Special Status 

Wildlife

We support the Preferred Alternative’s approach of not 

allowing wind development within 5 miles of active sagegrouse leks (Draft RMP/EIS, p. 2-271). This is a progressive 

and important measure to protect the sensitive species. 

However, the most recent science indicates that 5.3 miles is a 

minimal necessary buffer (Doherty, 2008). The Final EIS 

should adopt the scientifically supported 5.3-mile buffer. We 

encourage the BLM to evaluate this management action on a 

continuing basis and make changes as needed to reflect 

emerging science and/or monitoring results.

The BLM reviewed Doherty’s 2008 PhD dissertation. The 

dissertation dealt with coal bed natural gas field development in 

the Powder River Basin of Montana and Wyoming. Alternative VI 

(Proposed RMP) included current scientific literature including 

the adoption of Western Association Fish and Wildlife Agencies 

(WAFWA) sage-grouse management zone –IV Snake River 

Plain (Knick and Connelly, 2011b). Alternative VI adopted sagegrouse management areas (see LA-VI-MA-2 and LA-VI-MA-4 in 

Chapter 2 of the Final EIS). Naugle and others (2011) reported 

adverse impacts of gas and oil development continued to occur 

at 6.4 km (4.0 miles) but did not report at a larger 5.3-mile buffer 

distance. 

Special Status 

Wildlife

The BLM should establish activity levels and implementation 

plan with Humboldt-Toiyabe National Forest to protect Sage 

Grouse/Pygmy habitats with Area of Critical Environmental 

Concern level protections.

Nothing in the Final EIS precluded interagency cooperation and 

restoration. BLM was not aware of pygmy rabbits being 

confirmed on Humboldt-Toiyabe National Forest adjoining the 

planning area. The BLM cannot obligate other agencies to enter 

such agreements.

Special Status 

Wildlife

On p. 2-78 of the Draft RMP/EIS, management actions SS-IVMA-9 through SS-IV-MA-11 state Remove troughs and 

reservoirs --- Remove fences and corrals --- New troughs, 

reservoirs, permanent fences, all to be at least one (1) mile 

from bighorn sheep habitat. Displacing all water sources to at 

least a mile from existing bighorn habitat makes little sense. 

Water in water troughs and ponds near bighorn habitat is not 

present year round. Water in troughs is present when livestock 

are in the pastures. Water in playas and ponds is present

following precipitation events sufficient to produce run-off. 

Because water is not perennial the value to wildlife is somewhat 

reduced. Removal of waters in the uplands within 1 mile of 
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Category Comment Response

Are not these water sources used by all forms of wildlife. It 

would seem that the development of more strategically placed 

water troughs could be used to control livestock (cattle), but the 

old water sources would still provide a valuable tool for all 

wildlife. Further, is there any data that the existence of this 

infrastructure has harmed the bighorn? Current reported 

numbers seem to suggest that this has not been a problem in 

the past. 

bighorn habitat would reduce potential competition and social 

displacement. Potential benefits of increasing water sources to 

wildlife depend on a number of factors including wildlife species, 

time of year, distance to other water sources, and habitat. The 

management actions in Alternative IV were included as part of 

the range of alternatives. Management actions for special status 

species in Alternative II, Chapter 2, were different from 

Alternative IV. The Final EIS revised management actions for 

special status species based on public comments.

Special Status 

Wildlife

On p. 2-78, SS -CA-MA-17 states “Schedule livestock grazing 

to avoid pastures that contain bighorn sheep habitat during 

breeding, wintering, and lambing periods to minimize 

disturbance during these important seasonal periods”. Now 

lambing is interjected into this scenario, this document should 

be consistent! Again, where is the support for statements of 

this nature? If carried out, these decisions have the potential to 

further diminish livestock animal unit months on this very 

valuable and economically important resource. 

There was an error in the Draft RMP/EIS. This management 

action was not intended to be common to all action alternatives. 

The Final EIS modified the management action for Alternative II 

and it was not common to all action alternatives. Chapter 2, SSCA-MA-5 included a monitoring component for Special Status 

Species with adaptive management to mitigate impacts, SS-CAMA-16 provided for change, “If a conflict is identified”. 

Special Status 

Wildlife

On p. 4-406, Impacts From Management (Impacts From 

Livestock Grazing Actions) Specific to Alternative IV (The 

Preferred Alternative) states, “Livestock grazing would be 

scheduled to avoid pastures with bighorn sheep habitat during 

the breeding and winter period, minimizing displacement 

during this time. Placement of additional infrastructure and 

supplements may still influence bighorn sheep habitat”. Do 

grazing livestock (cattle) and bighorn sheep really ever share 

the same space, at least for a period long enough to influence 

bighorn sheep habitat use? This seems very doubtful, and the 

Draft RMP/EIS offers no data whatsoever to support any such 

conclusion. 

With respect to overlapping time, cattle grazing occurs in 

pastures of the Diamond A (winter), Blackrock Pocket (late fall), 

Seventy One Desert (winter) and Poison Butte allotments (late 

fall through spring which overlaps bighorn habitat. Cattle graze 

Bruneau Canyon Allotment in the Bruneau Field Office during 

the winter. Depending on the year and allotment, livestock graze 

individual pastures a few weeks to 4 to 5 months overlapping 

bighorn habitat. The Final EIS included Map 27 “Bighorn Sheep 

Habitat and Distribution”. Because the vast majority of bighorn 

locations were made following lambing, the data are likely 

skewed for this season. Spatial overlap between bighorn and 

cattle at other times of the year was poorly documented in the 

planning area. Bighorn have been observed in the upland more 

than 1.5 miles from the canyons.

Special Status 

Wildlife

We may be modifying and updating some provisions of (the 

Western Watersheds Project Alternative) due to the passage of 

3 1/2 years, the expanded habitat loss in the sagebrush biome, 

greater scientific understanding of threats to sage-grouse and 

other biota, and other concerns. For example, there is much 

new information related to the problems fences may cause for 

sage-grouse - so large-scale riparian fencing is a concern.

The Final EIS updated the Special Status Wildlife sections in

Chapters 3 and 4 using current sage-grouse literature including 

several chapters in Knick and Connelly (2011a) Greater Sage 

Grouse Ecology and Conservation of a Landscape Species and 

Its Habitats, Stevens (2011), and Stevens and others (2012). 

The BLM did not receive a letter that modified or updated the 

Western Watersheds Project alternative.
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Special Status 

Wildlife

Livestock grazing in the Bruneau Canyon is a historical use, 

and BLMs own documentation shows sheep routinely 

habituate to cattle. The only research documentation cited in 

the Draft RMP/EIS that relates to disturbance or displacement 

of sheep by cattle, applies only to recently relocated sheep. 

These restrictions fail to consider that the majority and most 

flourishing bighorn sheep populations within the area currently 

coexist with livestock, and significant areas of suitable habitat 

without livestock do not have any sheep. These restrictions fail 

to consider the fact that buffer distances within which 

concentrations of cattle are of concern are about 400 meters 

from canyon rims for ewes and 700 meters from canyon rims 

for rams. (Taylor, Elroy, and Dale E. Toweill. "Effects of spring 

cattle grazing on bighorn sheep habitat use." 2003 Desert 

Bighorn Council Transactions: Volume 47: p.54.)

Within the planning area only the Bruneau Canyon Allotment

(#1100) (≈ 670 acres; 100 animal unit months) lies within the 

Bruneau Canyon. The 1987 Jarbidge RMP shows no other 

allotment which included the Bruneau, Jarbidge or East Fork of 

the Jarbidge Canyons until downstream of the confluence of 

Clover Creek. BLM did not locate any documentation showing 

bighorn routinely habituate to cattle. The document cited was an 

abstract submitted to the Desert Bighorn Council prior to a 

conference. BLM obtained a copy of the entire Taylor and 

Toweill (2003b) draft manuscript from one of the authors. The 

study did not address bighorn habituation. The Taylor and 

Toweill study found when cattle grazed the allotments bighorn 

ewes moved further into canyon habitat using steeper terrain 

than when cattle were absent. Other factors confounded 

potential changes, or lack of change, in bighorn distribution due 

to livestock. Ewe movements into canyons may have been in 

response to livestock or to lambing. Radio-collared ewes 

returned to the areas above the canyon rims after livestock left 

the allotment, which coincided with lambs being large enough for 

longer movements. Taylor and Toweill cautioned against using 

average distances because of the timing of their flights early 

morning. The majority of the flights occurred from April into July 

(weekly) whereas flights were monthly for the rest of the year, 

which may have skewed their data under representing habitat 

use at other times of the year. They noted bighorn ewes used 

areas up to a mile away whereas rams used areas up to 2.4 

miles away from canyon rims. 

Special Status 

Wildlife

Management actions should only be addressed and developed 

at the activity plan level using the conservation plans, 

strategies and agreements in Appendix G of the Draft RMP/EIS 

for guidance.

Management actions to achieve large-scale objectives are 

appropriate for landscape scale analyses. Many management 

actions varied by alternative. If warranted, the BLM would apply 

specific management actions, best management practices, or 

other mitigation at the activity plan/project plan level.

Special Status 

Wildlife

Any restriction on development near an active sage-grouse lek 

should use a sound scientific analysis, and the science does 

not exist with respect to wind energy’s potential impact on 

sage-grouse. Further, numerous avoidance, minimization, and 

mitigation measures can be incorporated into any wind energy 

development, including extensive on-site and off-site 

mitigation, to provide a net benefit to sage-grouse. Mitigation 

The science regarding gas/oil energy development impacts to 

wildlife continues to develop. Because wind energy lacks similar 

wildlife impact information, oil/gas development was used as a 

conservative surrogate for analysis. Although less infrastructure 

development may be needed, wind energy development 

contains several similarities to oil/gas development including an 

increase in road density, an increase in disturbance, and an 
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measures can include enhancement and restoration of sagebrush habitat, creation of riparian areas, and grazing 

management. Finally, the Planning Area could serve as a 

valuable scientific laboratory for long-term pre- and postconstruction research on the effects of wind energy on sagegrouse and the effectiveness of mitigation measures.

increase other infrastructure. Mitigation measures would be

determined and applied at the project level and are beyond the 

scope of this planning effort. 

Special Status 

Wildlife

From 2008-2010, the BLM conducted extensive surveys in the 

proposed China Mountain Wind Project area and within a 2-

mile vicinity of the project area. These surveys include detailed 

information on avian and bat use, sensitive wildlife and plant 

species, raptor nests, big game, cultural resources, and sagegrouse (visual observations, identification of active leks, and 

radio telemetry). The sage-grouse radio telemetry data 

collection is ongoing. In addition, the Idaho Department of Fish 

and Game (IDFG) has been collecting sage-grouse radio 

telemetry data near the project area since 1993. 

The Draft RMP/EIS does not include the data from these 

surveys into the affected environment description of resources 

in Section 3.2. Importantly, the key sage-grouse habitat 

described in Section 3.2.7.3 and in Map 21 is based on 

vegetation rather than evidence of sage-grouse use based on 

radio telemetry data and locations of active leks. The Draft 

RMP/EIS states “The majority of sage-grouse leks in the 

planning area are located within key sage-grouse habitat.” (p. 

3-44), but this statement is not consistent with the active lek 

survey data conducted by the BLM within and in the 2-mile 

vicinity of the proposed China Mountain Wind Project 

(described in Renewable Energy Systems, Appendix D). For 

example, Map 21 identifies key sage-grouse habitat within the 

project area, but there are no active sage-grouse leks within 

the project area. In addition, Map 21 does not identify key 

sage-grouse habitat in large portions of Browns Bench, even 

though IDFG sage-grouse radio telemetry data from 1993-

2009 has shown a concentration of sage-grouse use on 

Browns Bench (Renewable Energy Systems, Appendix E). The 

Final RMP/EIS should incorporate the data from the extensive 

surveys associated with the proposed China Mountain Wind 

Project area and the IDFG sage-grouse radio telemetry data 

With respect to general wildlife (bats, raptors, songbirds) 

inventories, the BLM reviewed the data collected in the China 

Mountain considered it for inclusion. However, general wildlife 

was analyzed by habitat group rather than taxonomic groups so 

inclusion of the data was not practical. 

The Final EIS updated Special Status Wildlife and Special Status 

Plants sections in Chapter 3. Sage-grouse telemetry was not 

available at the time the Draft RMP/EIS was prepared, but were 

subsequently acquired. The majority of the planning area lacked

long-term radio telemetry data on sage-grouse and other wildlife 

movements. Where available sage-grouse radio telemetry data 

were used to define movements from lek of capture and nest 

sites in Chapter 3 and define the cumulative impacts analysis for 

sage-grouse in Chapter 4. Because the majority of the telemetry 

work focused on nesting and brood rearing sage-grouse, the 

locations are not necessarily representative of use during other 

seasons. Basing key sage-grouse habitat solely on existing 

telemetry data or lek locations would likely miss other seasonally 

important areas used by sage-grouse. At the planning area 

scale, the majority of the active sage-grouse leks were in or in 

close proximity to sagebrush habitats. In Chapter 3 of the Final 

EIS, the BLM included sage-grouse key habitat. Portions of 

Browns Bench were not originally mapped as key habitat 

because key habitat was supposed to be relatively intact 

sagebrush. This does not mean grasslands in the Brown’s 

Bench area were not used by sage-grouse periodically.

The sage-grouse habitat map was updated in the Final EIS (Map 

25) to depict key sage-grouse habitat, leks, and the sage-grouse 

management area.
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into the affected environment description of resources in 

Section 3.2.

Special Status 

Wildlife

Regarding the Chapter 2 Special Status Species section (SS-IMA-8, SS-II-MA-6, SS-III-MA-6, SS-IV-MA-8, and SS-V-MA-8), 

different distances from ferruginous hawks and prairie falcon 

nests are referred to in each of the alternatives. There is no 

rationale for these distances; the BLM should explain the 

rationale in the Final EIS.

The 1987 RMP previously identified distances from nest sites 

(shown in SS-NA-MA-11) for some raptors. Part of the variation 

in distance between alternatives was to provide a range for 

analysis. Current Idaho BLM direction (Information Bulletin IB-ID2010-039) was to provide a 1.0 mile buffer for peregrine falcon 

and ferruginous hawk nests, 0.5 miles for goshawk, golden eagle 

and prairie falcon nests unless a more restrictive buffer is 

designated in the land use plan. The scientific support for the 

distances and time periods was found Whittington and Allen 

(2008) Draft Guidelines for Raptor Conservation in the Western 

United States, (and Table B draft Seasonal Buffers-in progress)

Pagel and others (2010) Interim Golden Eagle Technical 

Guidance: Inventory and Monitoring Protocols; and Other 

Recommendations in Support of Golden Eagle Management and 

Permit Issuance;

Special Status 

Wildlife

The order of importance for fire management is 3 (out of 4) for 

Vegetation Management Area D except in the preferred 

alternative where it is 2 out of 4. Protection of sagebrush from 

wildfire in this area should be a higher priority.

Irrespective of Vegetation Management Area, suppression of 

wildland fires in key sage-grouse habitat is a priority in the Final 

EIS (see WFM-I-A-1, WFM-II-A-1, WFM-IV-A-I, and WFM-V-I-A1). Allocation WFM-VI-A-1 in Alternative VI (Proposed RMP) in 

the Final EIS identified key sage-grouse habitat as a critical 

suppression area.

Special Status 

Wildlife

The Draft RMP/EIS states: “Female sage-grouse attend leks to 

breed, and most nest within 3 miles of the lek.” There is no 

reference for this statement. The BLM should substantiate any 

statement regarding distance of nesting from leks with detailed 

references that are specific to sage-grouse populations in the 

planning Area in the Final EIS.

The Draft RMP/EIS states: “Between 1983 and 2006, active 

leks in the planning area declined between 1983 and 2006 

from 152 to 39 leks due to habitat change.” The BLM should 

revise this statement to incorporate all relevant survey data 

(including data collected by the BLM associated with the China 

Mountain Wind Project) from 2006-2010 in the Final EIS. The 

statement also asserts that declines in active leks are due to 

habitat change, but the BLM does not provide any references 

to substantiate this claim. If there are declines in active leks, 

The Final EIS updated the Special Status Wildlife sections in

Chapters 3 and 4.

The Final EIS updated Chapter 3 with respect to sage-grouse. It 

included summarized movements from lek of capture to nest 

sites. 

The Idaho Department of Fish and Game provided lek route 

information for the planning area. It included the current (2012) 

data with respect to sage-grouse leks monitored on lek routes. 

BLM used the 2011 sage-grouse lek data to summarize known 

sage-grouse leks in the planning area. 

The Final EIS indicated about 723,000 acres of sagebrush 

habitat have burned since 1987. The Wildland Fire Ecology and 

Management section noted a total of 1,394,000 acres burned 
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the BLM should provide detailed references as to the many 

factors that could be the cause of the decline.

The Draft RMP/EIS states: “Sage-grouse populations in areas 

where formerly extensive sagebrush habitat is broken into 

small patches are at risk from increased predation and loss of 

habitat.” There is no reference for this statement. The BLM 

should substantiate any statement regarding impacts of habitat 

fragmentation with detailed references.

between 1987 and 2007 and provided other fire information. The 

combined effect of these fires was a reduction of sagebrush 

habitat and fragmentation of remaining areas of sagebrush in the 

planning area. Johnson and others (2011) noted range wide the 

trends on leks declined where a greater proportion of their 

habitat burned range wide. Wisdom and others (2011) 

addressed other factors associated with the extirpation of sagegrouse. The Idaho Sage-grouse Advisory Committee (2006) 

addressed the influence of wildlife on the amount of sage-grouse 

habitat in Idaho.

Special Status 

Wildlife

The Draft RMP/EIS refers to potential impacts of roads, 

pipelines and power lines and other forms of infrastructure on 

habitat, but does not refer to avoidance, minimization and 

compensatory mitigation measures that can reduce impacts 

and have the ability to provide a net benefit to wildlife species. 

As described in Renewable Energy Systems Appendix D, the 

China Mountain Wind Project, for example, has avoided and 

minimized impacts to habitat to the maximum extent 

practicable and provides compensatory mitigation in the form 

of habitat enhancement and restoration to provide a net benefit 

to wildlife. The habitat restoration mitigation in particular could 

be done near the project to improve habitat connectivity in 

areas of the project burned by the Murphy Complex Fires.

Alternative VI (Proposed RMP) included additional avoidance 

and minimization guidance. Specific mitigation would be applied 

at the project scale as appropriate. Renewable Energy Systems 

Appendix D is a draft document without specifics on type, 

acreage, or location of the potential habitat mitigation.

Any “net” benefits to wildlife would depend on wildlife species 

targeted by the mitigation as well as amount location and type of 

mitigation. Measures adopted in Wyoming and other areas for 

oil/gas and coal bed methane were not adequate to mitigate 

impacts to sage-grouse in the long term (see Naugle et al., 2011; 

Doherty et al., 2008). To date it has not been shown that 

mitigation results in a net benefit to sage-grouse.

Special Status 

Wildlife

Mitigation measures, both on-site and off-site, can render 

practices and uses acceptable within an Area of Critical 

Environmental Concern (ACEC). For example, development of 

wind energy facilities in sage-grouse habitat can be mitigated 

both on-site and off-site through careful planning and 

incorporation of mitigation requirements into a Record of 

Decision approving a commercial scale wind energy project. 

Mitigation, combined with avoidance and minimization 

measures, can further accommodate uses within a designated 

ACEC that has relevant and possibly important sage-grouse 

habitat.

Project specific mitigation within an Area of Critical 

Environmental Concern (ACEC) was beyond the scope of this 

planning effort. Suitability of a project and subsequent mitigation 

would be dependent on the relevant and important values of the 

particular ACEC. 

Special Status 

Wildlife

Throughout the impacts assessment for all of the alternatives, 

the Draft RMP/EIS relies upon incorrect analysis from previous 

chapters. As stated in our comments on previous chapters, the 

incorrect analysis includes, but is not limited to; acreage 

associated with potential wind development areas, 

Chapter 2 was a presentation of the alternatives, goals and 

objectives and management actions for the specific alternatives 

and management actions to attain the objectives, not an 

analysis. Based on public comment Chapter 2 was updated in 

the Final EIS. Chapter 3 was a presentation of the baseline data, 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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identification of key sage-grouse habitat, the proximity of 

potential wind development areas to active sage-grouse leks, 

and the impact of wind energy development on sage-grouse, 

sensitive species, fish and watersheds.

not an analysis and was updated in the Final EIS. Alternative VI 

(Proposed RMP) redefines areas available for renewable energy 

development and does not base it on present vegetation. 

Chapter 4 in the Final EIS used the updated baseline and 

references in the analyses.

Special Status 

Wildlife

The Draft RMP/EIS refers to Instruction Memorandum (IM) ID2009-06 regarding guidelines related to meteorological towers 

near active leks. IM-ID-2009-06 expired on September 30, 

2009 and as a result should not be referred to in the Final EIS. 

In addition, the Draft RMP/EIS states that because of IM-ID2009-06, meteorological towers are “not to be placed within 2 

miles of active leks unless there is visual obstruction that 

reduces the visibility of the tower.” Even if IM-ID-2009-06 was 

applicable to the EIS (which is not the case given that the 

Instruction Memorandum has expired), the Instruction 

Memorandum would not exclude met towers from within 2 

miles of active leks. Rather, the Instruction Memorandum 

states “met towers shall be avoided (emphasis added) within 

two miles of active sage-grouse leks”. Finally, there is no 

scientific evidence to justify any restrictions on placement of 

meteorological towers away from active leks. Impacts from 

meteorological towers are de minimums. The Final RMP/EIS 

should remove all references to restrictions on locations of 

meteorological towers.

Information Bulletin IB-ID-2010-39 and attachment A modified 

the BLM policy in Idaho. The IB resulted in changes to 

Alternative VI (Proposed RMP) in Chapters 2 and Chapter 3 of 

the Final EIS and subsequent analysis in Chapter 4.

Special Status 

Wildlife

The Draft RMP/EIS assumes that transmission lines could 

result in increased predation on sage-grouse or make the 

habitat unsuitable. This assumption is inaccurate. Increased 

predation can be mitigated with perch guards or other 

deterrents and reduce the potential impacts. The BLM should 

remove this assumption in the Final EIS.

The Final EIS updated Chapter 4 and included discussion of 

perch deterrents and citations. (Lammers and Collopy, 2007; 

Prather and Messmer, 2010; Slater and Smith, 2010).

Special Status 

Wildlife

The Draft RMP/EIS states, “The vast majority of acres of 

sagebrush steppe, aspen, mountain mahogany/mountain 

shrub, and canyon land guild habitats were classified as having 

a marginal wind resource.” This statement confirms that there 

are very limited areas with these habitat types with 

commercially viable wind resource within the planning area. 

The BLM should insert following sentence immediately after 

the aforementioned sentence in the Final EIS, “As a result, 

commercial wind energy development would have limited 

Amount and types of habitat in the wind development areas were 

updated. Impacts of specific projects on habitats can only be 

analyzed in detail in the environmental analysis for the project

when the locations of infrastructure (roads, turbine lines, 

buildings, substations and power lines) and disturbance are 

known. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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impacts on these habitat types.”

Special Status 

Wildlife

The Draft RMP/EIS states, “Wind energy development in the 

northern portion of the planning area would avoid sage-grouse 

habitat.” This statement fails to mention that commercial wind 

energy is not viable in the northern portion of the planning area 

because the wind resources in this area fall into the “fair” or 

worse classification, and is therefore not cost-competitive. The 

Final EIS should state that the wind resource in the northern 

portion of the planning area is not commercially viable.

The Final EIS allocated areas available for potential 

development for each of the alternatives. The best area for wind 

energy development was not required to be allocated in all 

alternatives. The Final EIS changed areas available to wind 

energy development due to sage-grouse habitat in Alternative VI 

(Proposed RMP). Technology continues to change and areas 

with lower wind classifications may become viable for 

commercial development in the future. Over 100 turbines are 

presently located in the northern portion of the planning area on 

private land. Project proponent determines the commercial 

viability of a specific project.

Special Status 

Wildlife

We are concerned that the Draft RMP/EIS does not include 

any of the findings contained in the recent scientific monograph 

"Ecology and Conservation of Greater Sage-Grouse: A 

Landscape Species and Its Habitats" (available at 

http://sagemap.wr.usgs.gov/monograph.aspx) when describing 

the basis for Greater sage-grouse local and landscape scale 

habitat requirements. As a guidance document for the next 15 -

20 years, we believe it is imperative that the Final EIS base its 

management decisions on the best available science.

At the time the Draft RMP/EIS was prepared the manuscripts 

were in draft form. Greater Sage-Grouse Ecology and 

Conservation of a Landscape Species and Its Habitats by Knick 

and Connelly (2011a) was reviewed and appropriately cited in 

the Final EIS. 

Special Status 

Wildlife

In 2005, the BLM Jarbidge Field Office, where the project is 

proposed, agreed to create a new Resource Management Plan 

and accompanying Environmental Impact Statement focused 

on restoring wildlife habitat. In 2007, the Murphy Complex Fire 

burned more than 425,815 acres in the planning area. 

Stemming from this fire, in 2009, the U.S. District Court 

summarized the new situation in Western Watersheds Project

v. Dyer, CV-04-18l-BLW, 2009:

Between 1982 and 2006, the planning area lost 797,409 

acres of native sagebrush steppe habitat. The Murphy 

Complex Fire in 2007 burned 425,815 acres, destroying 

70% of remaining sage-grouse nesting habitat and over 

80% of known occupied pygmy rabbit habitat.

The best remaining population stronghold for sage-grouse 

in the planning area is in the southern foothills area, which 

encompasses the proposed wind turbine project area.

Under these new circumstances for wildlife and for land 

The Draft RMP/Environmental Impact Statement (EIS) provided 

different areas for wind energy development that varied between 

some of the alternatives to create a range for analysis. The Final 

EIS revised the area available to wind energy development in 

Special Status Wildlife section based on the identification of 

sage-grouse management area for Alternative VI (Proposed 

RMP). 
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managers in southern Idaho, there are multiple reasons to shift 

wind energy development to another location where the loss of 

habitat will be lessened or mitigated, and the feasibility of wind 

development will be more predictable.

Special Status 

Wildlife

The BLM's habitat mitigation policy codified at 43 CFR 

1508.20, lists habitat mitigation actions in descending order of 

preference: avoidance, minimization, rectification, reduction, 

and compensation. Idaho Fish and Game research and other 

research has documented the importance of China Mountain 

and Brown's Bench to sage-grouse. Renewable Energy 

System's own Draft Sage-grouse Conservation Plan (the Plan) 

described at least 61% of the proposed project as key sagegrouse habitat. There is no possibility of constructing the 

project while avoiding key habitat. The Plan created by 

Renewable Energy Systems consultants is largely an offsite 

compensatory mitigation plan.

This comment was beyond the scope of this planning effort. Any 

decision regarding the China Mountain Wind Energy Project has 

been deferred until the Idaho/Southwest Montana Sub-regional 

Sage-Grouse Plan Amendment and the Jarbidge RMP have 

been completed. 

Special Status 

Wildlife

One possible reason BLM might have tied wind energy 

development to native vegetation is sage-grouse concerns. If it 

is due to sage-grouse concerns, those concerns are not 

scientifically proven given the lack of comprehensive, well‐

designed, pre and post construction research regarding the 

potential impacts of wind energy development on sage-grouse. 

The BLM will need to permit projects in sage-grouse areas 

before impacts will be known. The BLM should require 

monitoring and data collection so the impacts can be quantified 

for use in other projects in the planning area and west wide. 

Further, sage-grouse use a wide variety of vegetation types, 

making any connection between wind energy development and 

native vegetation weak at best. The Browns Bench grouse 

stronghold is primarily composed of exotic communities and 

even though grouse have a year around presence here, the 

area under the BLM preferred alternative would be open for 

wind energy development. The use of native vegetation for 

sage-grouse habitat is not linked with reality and the true 

situation on the ground. The data exists to show where the leks 

are and where the birds spend the majority of their time, BLM 

should spend more time applying the data to proposed 

management actions.

The Final EIS revised areas available to wind energy 

development. Alternative VI (Proposed RMP) did not base areas 

available to wind development on vegetation for all alternatives 

in the Final EIS. 

Long-term monitoring required at the project level and was 

beyond the scope of this planning effort. However, the best 

management practices adopted by the Record of Decision for 

the Programmatic Wind Energy EIS stated at least 2 years of 

inventory for baseline data would be necessary (see Appendix B: 

Best Management Practices, Design Features, and Operating 

Procedures).

Although some of the Brown’s Bench/Monument Springs area 

has some areas dominated by exotic vegetation, crested 

wheatgrass seedings, the area as a whole is primarily a native 

shrubland community.

With respect to the use of native vegetation as sage-grouse 

habitat, Connelly and others (2011b) review the numerous 

studies across the range of the species linking sage-grouse with 

native vegetation, principally sagebrush communities.
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Special Status 

Wildlife

The BLM did not provide any justification for restricting 

development within a particular mileage distance from active 

leks. Comprehensive, well-designed pre‐ and post-construction 

research regarding the potential impacts from a number of the 

resource uses involved has not been conducted to‐date. There 

is anecdotal information indicating that sage-grouse have been 

observed, lek attendance continues, and hens have nested 

within 500 meters of wind turbines. Research from oil/gas 

development (which is generally considered to have greater 

impacts than the development of wind energy, communication 

towers, transmission lines, geothermal energy, and 

meteorological towers) indicates some potential indirect 

impacts to sage-grouse within 1 kilometer of infrastructure 

(Johnson and Holloran 2010, Johnson 2010, DGSCP‐CMWP 

Tetra Tech 2010, SWCA 2006 BLM 2003).

The Final EIS analyzed a variety of distances from leks as part 

of the range of alternatives. The 2-mile limit was from the current 

land use plan. The 5-mile distance from sage-grouse leks was a 

US Fish and Wildlife Service recommendation regarding wind 

development (Manville, 2004). Oil and gas development initially 

did not appear to impact sage-grouse; however, impacts 

occurred in the long term. Anecdotal observations do not provide 

context. Individuals of a species can respond differently than the 

species as a whole. Only through a properly designed study can 

preference or avoidance be determined. Some impacts to a 

species are manifest only after a period of years.

BLM included Johnson and others (2011) in the Final EIS. 

(Commenter did not include full citations for Johnson and 

Holloran, 2010; Johnson, 2010; DGSCP-CMWP Tetra Tech, 

2010; SWCA, 2006; and BLM, 2003, so these references could 

not be addressed).

Special Status 

Wildlife

On p. 2-68, please identify which segment of Salmon Falls 

Creek you are referencing under the first management action 

for habitat for bighorn sheep. We are assuming you refer to the 

Area of Critical Environmental Concern segment. Or, are you 

referring to the segment above Salmon Falls Dam?

Management action SS-NA-MA-1 in the No Action Alternative 

was stated as it was written in the 1987 RMP. It was unclear if 

the area for potential release was limited to the Wilderness 

Study Area or included all of the Area of Critical Environmental 

Concern. After the 1987 RMP was completed, the canyon was 

evaluated. Due to the proximity of domestic sheep/goats on 

private land and grazing allotments in the eastern portion of the 

planning area, Idaho Department of Fish and Game determined 

a bighorn population would not be established in any portion of 

Salmon Falls Creek Canyon.

Special Status 

Wildlife

In order to fulfill Endangered Species Act Section 7 

consultation requirements, The US Fish and Wildlife Service

(FWS) will need site-specific information. This site-specific 

information will allow the FWS to fully address the potential 

effects to listed and candidate species. To achieve this, we 

recommend conducting a programmatic consultation, followed 

by project-specific consultations. This approach is consistent 

with the RMP planning process adopted by the BLM.

The BLM will consult with the US Fish and Wildlife Service 

(FWS) to meet its Endangered Species Act (ESA) requirements. 

Since the Final EIS is at the broad, landscape scale and does 

not approve any site-specific projects, project specific 

information is not available. Through consultation with the FWS,

BLM will identify best management practices (BMPs) to reduce 

or minimize impacts of projects. Not all BMPs will be required for 

all projects. The BLM will continue to complete project specific 

consultation as required to meet its ESA obligations. 
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Special Status 

Wildlife

It would be helpful to indicate for appropriate Type I species 

their actual Federal status (endangered, threatened, or 

candidate). On March 23, 2010, the US Fish and Wildlife 

Service determined that the Greater sage-grouse warrants the 

protection of the Endangered Species Act, but that listing the 

species at this time is precluded by the need to address higher 

priority species first (75 FR 13910). The Greater sage-grouse 

has been placed on the candidate list for future action.

The Final EIS revised the table listing special status species in 

Chapter 3 to reflect Type I status, (Candidate) for Greater sagegrouse.

Special Status 

Wildlife

The BLM already has the necessary tools to protect 

Endangered Species Act-listed, candidate and sensitive 

species without creating Areas of Critical Environmental 

Concern (ACECs). These tools make the creation of ACECs 

largely redundant. The State also believes that these purported 

wildlife management goals can be better accomplished through 

on-the-ground decision making and consultation with the Idaho 

Department of Fish and Game and other stakeholders than 

through sweeping changes by administrative fiat.

A variety of Areas of Critical Environmental Concern (ACECs)

and acreages were included in the various alternatives due to 

nominations received during scoping. ACECs acreage varies 

from 0 in Alternative II to 956,000 acres in Alternative V. Based 

on comments and Omnibus Public Lands Management Act of 

2009; ACECs in Alternative VI (Proposed RMP) were modified 

from the Draft RMP EIS. ACECs in Alternative VI include Upper 

Bruneau Canyon (18,000 acres), Lower Bruneau Canyon (1,000 

acres), Salmon Falls Creek (2,700 acres), and Sandpoint (950 

acres). Special management for each ACEC was designed to 

protect relevant and important values associated with that ACEC 

which are not exclusively based on special status wildlife. 

Federal Land Policy and Management Act of 1976 states that 

ACECs need “special management attention”. ACEC 

designations by design should not provide redundant protection 

because they should need “special management attention.” 

Special management prescribed for ACECs was beyond the 

normal management for adjacent lands. 

Special Status 

Wildlife

The State does not believe the Final EIS should automatically 

preclude (in contrast to the preferred alternative) the ongoing 

and requisite environmental analysis of this project so long as 

the developer can affirmatively demonstrate that it can 

effectively avoid or mitigate for the loss of key sage-grouse 

habitat.

The China Mountain Wind Energy Project has been deferred 

until the Idaho/Southwest Montana Sub-regional Sage-Grouse 

Plan Amendment and the Jarbidge RMP have been completed. 

An EIS specific to the China Mountain Wind Energy project 

would analyze the effects of the China Mountain Wind Energy 

project, including any proposed mitigation.

Special Status 

Wildlife

The draft RMP needs further clarification regarding the Browns 

Bench and China Mountain areas. Map 76 notes that 

Alternative IV right-of-way exclusion area, partially falling within 

the proposed project boundary (Map 77), contains the best 

potential wind resources within the planning area. By contrast, 

the Browns Bench area, which contains key sage-grouse 

habitat, is proposed (Map 82) as "Potential Wind Development 

Areas allocated to renewable energy development varied 

between some of the alternatives. Areas allocated to energy 

development were updated in Alternative VI (Proposed RMP) in 

the Final EIS. The changes included identifying key sage-grouse 

habitat, sage-grouse management area, as well as eliminating 

the link to non-native vegetation.
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Category Comment Response

Areas" while only containing marginal wind resources. The 

State suggests that the BLM better explain the apparent 

discrepancy.

Special Status 

Wildlife

LA-IV-MA-2, on p. 2-175, specifies that transmission lines, 

phones lines, communication towers, meteorological towers, 

and wind turbines will be located more than 5 miles from 

"active" sage-grouse leks. While the State believes it is vitally 

important to protect key sage-grouse habitat, this conservation 

measure needs to be refined. Should the BLM adopt this 

measure in the Final EIS, the conservation measure should 

encourage (not require), to the extent practicable, 

infrastructure to be located at least 5 miles from leks with an 

occupied or undetermined status. The Final EIS should also 

afford project proponents the opportunity to demonstrate that 

an effective mitigation plan negates the applicability of this 

general measure.

The Final EIS had different mileage buffers proposed in some of 

the alternatives to create a range of alternatives for analysis. The 

5-mile buffer was interim guidance recommended by the US Fish 

and Wildlife Service (Manville, 2004). Alternative VI (Proposed 

RMP) in the Final EIS modified management Actions in Chapter 

2, Special Status Wildlife section. 

Special Status 

Wildlife

Page 3-23, Big Game section, addresses bighorn sheep as a 

BLM Sensitive species. On p. 3-33 third paragraph in section 

3.2.7 Special Status Species address that the BLM State 

Director cooperates with State wildlife agencies in the 

designation of sensitive species. At this time, the State of 

Idaho does not have bighorn sheep as a sensitive species and 

we question why BLM has identified bighorn sheep as a 

sensitive species?

BLM Manual 6840.04.E.4. The BLM State Director has the 

responsibility for designating BLM sensitive species, and 

periodically reviewing and updating the BLM sensitive species 

list, as appropriate, in coordination with State agencies that are 

responsible for fisheries, wildlife, and botanical resources and 

State Natural Heritage programs. The current Master 

Memorandum of Understanding between the Idaho Department 

of Fish and Game and the Bureau of Land Management 

identified California bighorn sheep as a sensitive species. Idaho 

Department of Fish and Game (IDFG) presently manages the 

bighorn sheep populations south of the Snake River in Idaho as 

California bighorn rather than Rocky Mountain bighorn north of 

the Snake River. As noted in SS-CA-MA-2. Special status 

species management would not apply to species that are 

removed from the BLM Sensitive species list. Those species 

would be managed according to applicable delisting 

requirements, conservation strategies, BLM policy, and IDFG or 

Nevada Department of Wildlife management guidance.

Special Status 

Wildlife

The Bruneau-Jarbidge Area of Critical Environmental Concern 

(ACEC) is not necessary since the BLM has complete authority 

to management of listed species and critical habitat under the 

Endangered Species Act, Wilderness Act and regulations for 

the authorization of uses in this area. With fire, being one of 

The Final EIS modified the Bruneau-Jarbidge Area of Critical 

Environmental Concern boundary based on public comment and 

Omnibus Public Lands Management Act of 2009. The 

modification removed any of the designated Bruneau-Jarbidge 

Rivers Wilderness lands. Area of Critical Environmental Concern 
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Category Comment Response

the biggest threats to wildlife habitat and identified values, and 

with the new information that livestock is a viable tool to reduce 

fine fuel (Davies et al., 2010) that would lessen the fire 

occurrence, that an ACEC could be very restrictive to the BLM 

to change the management on a site specific location and on a 

landscape scale to reduce fires with the use of livestock 

throughout the year.

(ACEC) designation indicates that an area has values that meet 

criteria for relevance and importance. These values include 

historic, cultural, and scenic values; fish and wildlife resources; 

and natural systems and processes (Appendix M: Evaluation of 

Nominated Areas of Critical Environmental Concern). 

Management, including an increased fire suppression priority, 

associated with an ACEC designation is specific to the relevant 

and important values present in the ACEC. Special management 

would provide proactive measures to maintain or enhance those 

values as well as measures necessary to protect those values. 

Livestock grazing would continue to be authorized on the plateau 

area. The Wildand Fire Ecology and Management section in 

Chapter 4 briefly addressed the role of livestock in altering fuels. 

Special Status 

Wildlife

The Jarbidge Foothill Area of Critical Environmental Concern 

(ACEC) (both large and small) is not necessary since the BLM 

has complete authority to management of listed species under 

the Endangered Species Act and regulations for the 

authorization of uses in this area. With fire being one of the 

biggest threats to the habitat in this area, and with the new 

information that livestock is a viable tool to reduce fine fuel 

(Davies et al., 2010) which would lessen the fire occurrence, 

an ACEC could be very restrictive to the BLM to change the 

management on a site specific location and on a landscape to 

reduce fires with the use of livestock throughout the year. The 

other concern with this ACEC is that private lands are 

intermingled throughout the area and that the ACEC could 

have major implications to private lands uses and access.

The Final EIS analyzed the Jarbidge Foothills Area of Critical 

Environmental Concern (ACEC) as part of the reasonable range 

of alternatives. Alternative VI (Proposed RMP) in the Final EIS 

did not designate this ACEC. 

Special Status 

Wildlife

Management action SS-NA-MA-10 states, "Manage human 

use within big horn sheep habitat at levels that are not 

detrimental to the big horn sheep population". This 

management action is broad and can be interpreted in a 

couple of different ways. Some people might see any human 

use as detrimental to the big horn sheep population. At what 

use levels is human use detrimental to the sheep population? 

This management action needs to be modified to protect visitor 

use and access.

The BLM concurs this management could be interpreted in more 

than one manner. However, the management action is for the No 

Action Alternative, directly from the current RMP and was not 

changed. Management actions for bighorn sheep varied 

between some of the Alternatives to create a range for analysis.

Special Status 

Wildlife

The Jarbidge Sage-grouse Local Working Group (the Group) 

requests that BLM consider the existing Jarbidge Sage-Grouse 

Local Working Group Sage Grouse Conservation Plan 

The Final EIS used various aspects of the Jarbidge Sage-grouse 

Local Working Group sage-grouse plan. Alternative VI 

(Proposed RMP) in the Final EIS also included management 
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Category Comment Response

(Jarbidge Sage-Grouse Local Working Group, 2007) as it 

pertains to the implementation of the Final EIS.

The Group supports habitat development and management 

that maintains and enhances sage-grouse habitat and 

populations.

The Group requests and supports cooperation between 

Jarbidge Local Working Group and the Jarbidge BLM Field 

Office in project planning and implementation.

actions based in part on the Jarbidge Local Working Group Plan. 

UV-VI-MA-21 and 22 make restoration of sage-grouse habitat a 

priority. WFM-VI-A-1 makes sage-grouse habitat a critical 

suppression priority. WFM-VI-MA-2 directs fire crews to 

suppress fire burning sagebrush islands once the fire is 

contained. 

Special Status 

Wildlife

The BLM should: 

Site new infrastructure using best available science to 

determine the potential negative impacts or positive 

benefits to sage-grouse and

Site infrastructure to be in the best interest of sage-grouse 

and sage-grouse habitat.

However, if impacts from infrastructure developments are 

unavoidable, require effective mitigation to result in no net loss 

to sage-grouse habitat.

Several management actions in the Final EIS, Chapter 2, 

Alternative VI (Proposed RMP), involved the placement of 

infrastructure and mitigation for impacts to sensitive species 

habitat. They were contained in the following sections: Special 

Status Species (SS-CA-MA-9, SS-CA-MA-10, SS-VI-MA-8), 

Livestock Grazing (LG-CA-MA-15, LG-CA-MA-16, LG-VI-MA11), 

Transportation and Travel (TR-VI-MA-7), and Land Use 

Authorizations (LA-VI-A-2, LA-VI-MA-1, LA-VI-MA-2, LA-VI-MA4, LA-VI-MA-5). Site-specific mitigation measures would apply at 

the project level, if the project were authorized.

Special Status 

Wildlife

Chapter 3 of the Draft RMP/EIS on p. 3-44 states, relative to 

Ferruginous hawks: “Wildfires have also eliminated several 

nest trees and altered the habitat used by their prey, mainly 

jackrabbits, mountain cottontail rabbits, and ground squirrels 

(Bechard and Schmutz, 1995).”

However, Bechard and Schmutz, 1995 indicates that this bird 

uses a variety of nest sites, including nearly level ground, if 

they need to: “Birds seem to show a strong preference for 

elevated nest sites (boulders, creek banks, knolls, low cliffs, 

buttes, trees, large shrubs, utility structures, and haystacks), 

will nest on nearly level ground when elevated sites are 

absent. Trees in deserted homesteads or otherwise unbroken 

grasslands often serve as nest.”

The Final EIS revised the Sensitive Species portion of Chapter 3 

regarding ferruginous hawks. In the planning area no ferruginous 

hawk nests have been observed on nearly level ground. About 

20 ground nests have been documented, but these nest sites 

are on either rock outcrops or breaks. Checks of several ground 

ferruginous hawk nests in the northern part of the planning area 

did not find any nest sites marked as active in the late 1980’s as 

remaining active by the early 1990’s. Checks of known 

ferruginous hawk territories following fires have not shown they 

returned to the area to nest on the ground once the nest tree 

was destroyed. They have returned if the nest tree was not 

destroyed or if alternate nest trees were available. There are no 

artificial nest platforms for raptors in the Jarbidge Field Office.

Special Status 

Wildlife

Chapter 3 of the Draft RMP/EIS on p. 3-44 states: “Key sagegrouse habitat is defined by the Idaho Sage-grouse Advisory 

Committee as “areas of generally intact sagebrush that provide 

sage-grouse habitat during some portion of the year (Idaho 

Sage-grouse Advisory Committee, 2006).”

a. The precise definition of key sage-grouse habitat was in 

Appendix A of the Conservation Strategy for Greater Sagegrouse in Idaho (Idaho Sage-grouse Advisory Committee, 2006). 

The Final EIS added the definition in its entirety to the Glossary.
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Category Comment Response

a. However, while this statement is contained in the referenced 

work, it has since been refined to more accurately state the 

definition. “Key sage-grouse habitat” is currently defined as, 

“areas of generally intact sagebrush that provide sage-grouse 

habitat during some portion of the year including winter, spring, 

summer, late brood-rearing, fall transition sites from winter to 

spring, spring to summer, summer/fall to winter. Key habitat 

may or may not provide adequate nesting, early brood-rearing, 

and winter cover due to elevation, snow depth, lack of early 

season forbs, limited herbaceous cover, or small sagebrush 

patch size” (Idaho Sage-grouse Local Working Group’s 

Statewide Annual Report 2009, p. 16 [Idaho Sage-grouse 

Advisory Committee, 2010]).

b. In addition, it notes that Map 21, at Volume 3, p. M-22, 

which purports to depict key sage-grouse habitat is flawed in its 

depiction of intact sagebrush (which also continues to change 

annually due to wildfires). 

b. The Final EIS revised the map of key sage-grouse habitat 

(Map 25 “Sage-Grouse Habitat”). The amount of sagebrush 

habitat varies annually, primarily due to wildfires.

Special Status 

Wildlife

Chapter 3 of the Draft RMP/EIS on p. 3-44 states, “The number 

of sage-grouse leks and numbers of sage-grouse on leks have 

declined throughout most of the planning area since the 1960s. 

Between 1983 and 2006, active leks in the planning area 

declined from 152 to 39 due to habitat change. In 2007, the 

Murphy Complex Fires burned approximately 30% of the 

remaining occupied sage- grouse habitat in the planning area.

However, the Draft RMP/EIS does not accurately report the 

available information. A number of problems exist with these 

Draft RMP/EIS statements: 

First, lek counts can be highly variable and unreliable. 

a. “Breeding populations should be assessed by either lek 

counts (census number of males attending leks) or lek surveys 

(classify known leks as active or inactive) each year 

(Autenrieth et al., 1982). Depending on number of counts each 

spring (Jenni and Hartzler 1978, Emmons and Braun 1984) 

and weather conditions when the counts were made, lek 

counts may not provide an accurate assessment of sageThe Final EIS revised the sage-grouse section of Chapter 3. 

Revisions include tables showing numbers of males per lek route 

based on the Idaho Department of Fish and Game (IDFG) sagegrouse lek database.

a. Garton and others (2011) noted the initial concerns voiced by 

earlier authors with lek counts; however, they also noted lek 

counts were a useful index to the minimum number of breeding 

males.

b. In Region IV, IDFG conducted a number of lek routes in the 

planning area since the 1990’s. The protocols adopted in the 

1990’s were the basis for the 2006 guidelines. At the time the 

2006 document was prepared several of the routes had data 

only for a limited number of years. Discussion and a table were 

added in Chapter 3 showing the long-term trends on the lek 

routes. There was 7 years of data for lek routes in the planning 

area compared to the Conservation Plan for Greater Sagegrouse in Idaho. The Conservation Plan truncated the data in 

2004.
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grouse populations (Beck and Braun 1980) and the data 

should be viewed with caution.” From Connelly and others 

(2000), p. 975-976.

b. Second, a review of the lek data relative to the planning area 

shows that such data has not been consistently gathered (in 

contrast to the requirements noted above), and it is not 

reliable.

c. Third, the five-year running average of the Brown’s Bench 

lek route (the only reliably monitored lek route) shows an 

overall upward trend between 1992 (actually 1994) and 2010. 

In addition, the Brown’s Bench lek route had more males 

counted in 2006 than in any previous year.

d. Fourth, it was not until about 2006, under the guidance of 

the Conservation Plan protocols, that Idaho began using a 

unified and systematic means of counting attendance at leks. 

In addition, prior to 2008, the leks in the planning area were 

counted in January, whereas since 2008, they have been 

counted in March or April.

e. Fifth, lek count information received from Idaho Department 

of Fish and Game reports that 38 new leks or locations have 

been identified in the 2005-2009 time period in the Jarbidge 

SGPA. It appears that the more attention is given to obtaining 

accurate information, the more new leks are identified.

f. Sixth, the Murphy Complex Fire and other subsequent fires 

likely have resulted in change of location of leks since 2007 

(including perhaps the Brown’s Bench lek route leks), which 

changed locations have not yet been identified.

c. A 5-year running average is not the best measure of male 

sage-grouse lek attendance. Only using a 5-7 year running 

average obscures potential cycles and long-term trends. 

d. In Region IV, IDFG adopted the protocol of counting lek routes 

multiple times in the spring (March to early May) at least a week 

apart, at the appropriate time of day (30 minutes before sunrise 

to an hour after sunrise), with suitable weather and wind 

conditions. IDFG and the BLM have used this protocol for at 

least a decade prior to 2006. The BLM and IDFG in the Magic 

Valley never ran sage-grouse lek routes in January. However, 

IDFG has collected some winter location data on sage-grouse in 

January. 

e. The Final EIS updated the sage-grouse portion of Chapter 3 

to include recent leks as well as leks with more data. Some of 

the "new" leks are based on an observation in a single morning. 

A few of the "new" leks were not observed in subsequent checks 

the same year or in subsequent years. 

f. A number of the leks in the Murphy Complex still persist but at 

lower numbers. Some leks are no longer attended by sagegrouse. Some lek locations may have shifted as a result of 

habitat changes. It cannot be assumed the “new” leks were not 

already present, but they may not previously detected. 

Special Status 

Wildlife

Please consider: Long-term effects of fire on sage-grouse 

habitat by Pamela J. Nelle, Kerry P. Reese, and John W. 

Connelly. Journal of Range Management. 53: 586–591 

November 2000.

Authors are former research assistant and professor, 

Department of Fish and Wildlife Resources, University of 

The Chapter 4 Special Status Wildlife section was updated to 

include a brief discussion of fire impacts to sage-grouse habitat. 

Nelle and others (2000) was reviewed. However, the BLM cited 

Beck and others (2009) Recovery of Greater sage-grouse 

habitat features in Wyoming big sagebrush following prescribed 

fire in Restoration Ecology, which was similar but more recent 

than the Nelle and other (2000) reference. (Connelly and Reese 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Idaho, Moscow, Ida, 83844; and principal wildlife research 

biologist, Idaho Department of Fish and Game, 1345 Barton

Rd, Pocatello, Ida, 83204.

were also co-authors of the Beck and others (2009) article.) 

Special Status 

Wildlife

Slickspot peppergrass is a threatened species, yet the BLM is 

holding fence lines that bisect critical habitats. It also appears 

that the whole Draft RMP/EIS is structured to give far more 

protections to disturbance-tolerant mule deer than it gives to 

sage-grouse, the sensitive California bighorn sheep, the pygmy 

rabbit, sensitive migratory birds, golden eagles, etc.

Alternative VI (Proposed RMP) in Chapter 2 included a number 

of allocations and management actions that to reduce impacts 

from a number of land uses to a variety of special status species 

and their habitats. Examples include: SS-VI-MA-5 which allowed

for the modification of range infrastructure to maintain or 

enhance special status species or their habitat; SS-VI-MA-10 

which addressed maintaining separation between bighorn and 

domestic sheep or goats; REC-CA-MA-2 which allowed 

scheduling restrictions to be applied to reduce impacts to fish 

and wildlife during important seasonal periods; LA-VI-A-2 which 

made bighorn habitat associated with eligible segment of Wild 

and Scenic Rivers an avoidance area for land use 

authorizations; SA-VI-A-1 which closed Areas of Critical 

Environmental Concern (ACECs) to salable minerals; LE-VI-A-2 

which closed designated Wilderness, Wild and Scenic River 

segments and ACECs to leasable mineral development

protected bighorn habitat; and WI-CA-MA-9 which addressed

periods and buffer distances for nesting raptors.

Special Status 

Wildlife

Under Kleppe v New Mexico (1976), the Federal government 

has authority over wildlife on Federal lands, because it owns 

them. BLM has authority to protect habitat. Yet for sagegrouse, BLM defaults to the Idaho sage-grouse Plan and the 

industry-dominated Local Working Group and never bothers to 

show how these efforts would effectively conserve sagegrouse.

Kleppe v New Mexico (1976) involved wild burros federally 

protected under the Wild Horse and Burro Act. BLM manages 

habitat and cooperates with states and the US Fish and Wildlife 

Service to conserve or restore fish and wildlife. 

The Local Working Group Plan had a number of 

recommendations including making it a priority to suppress fires 

in key sage-grouse habitat, managing of wetlands and wet 

meadows, restoring 3,000 of sagebrush habitat per year, 

extending and connecting large islands of sagebrush, using 

native grasses and forbs in seed mixes, etc. Many of these 

recommendations were incorporated into allocations or 

management actions in some of the alternatives. 

Special Status 

Wildlife

The BLM never presents a single map or plan or required 

action to remove a single one of these harmful habitat 

fragmenting, predator sink areas. These facilities promote 

West Nile virus, facilitate livestock depletion of sagebrush 

habitats, serve as infestations sites for weeds, and have many 

Based on public comment the BLM added SS-VI-MA-9 which 

provided for the construction and maintenance of water facilities 

to minimize the production of mosquitoes which may carry West 

Nile virus - Chapter 2 in the Sensitive Species section Alternative 

VI (Proposed RMP). LG-VI-MA-14 provides for maintaining 
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other adverse impacts. See Connelly and others (2004), Knick 

and Connelly (2009), Declaration of Dr. David Dobkin (Dobkin 

and Sauder, 2004). 

attaining adequate nesting winter cover by adjusting 

salt/supplement and water locations in sagebrush steppe habitat 

and other intact sagebrush stands which would benefit sagegrouse

Special Status 

Wildlife

The Draft RMP/EIS must prioritize areas and clearly identify 

what must be done to preserve and restore sage-grouse 

habitats. This must then be incorporated into determining 

carrying capacity and suitability for any continued livestock 

use. This then must form the basis of any allocation. 

The BLM identified general areas (Vegetation Management 

Areas) and priorities for restoration for the various alternatives in 

the Chapter 2 Upland Vegetation sections. Specific locations 

were not identified due to the likelihood of future events (e.g. 

wildfires) altering treatment areas. With respect to habitat 

protection, individual alternatives define fire suppression 

priorities. Sage-grouse habitat was a high priority (critical 

suppression) in several alternatives identified in the Final EIS.

Special Status 

Wildlife

Big game habitat and restoration receive attention in Maps 19, 

Map 20 "Big Game Winter Range Restoration Areas". There is 

only one map for sage-grouse, i.e. Map 21. Despite the 

Stipulated Settlement Agreement, the BLM has provided no 

mapping and coherent planning for conserving sage-grouse - 

yet has laid out mapping identifying habitats for both winter 

range and restoration for mule deer. The BLM then uses this 

planning to overlay more restrictive mineral leasing, 

geothermal and other actions on mule deer habitats.

The Final EIS updated Chapter 3 and included Map 25 “Sagegrouse Habitat” which depicts key sage-grouse habitat. The 

Final EIS included management actions which directly or 

indirectly benefit sage-grouse and its habitat for Land Use 

Authorizations, Minerals, Wildland Fire Ecology and 

Management, and Upland Vegetation sections in Alternative VI 

(Proposed RMP) in the Final EIS.

Special Status 

Wildlife

The BLM does not even provide mapping that identifies crucial 

winter habitats for sage-grouse - such as the 71 Desert – 

where the BLM has long sought to pretend that sage-grouse 

are not a very significant concern.

Within the planning area, wintering sage-grouse have been 

observed in numerous locations varying from high elevation low 

sagebrush wind swept ridges to lower elevation black sagebrush 

and Wyoming big sagebrush sites. The Final EIS updated the 

sage-grouse habitat map (Map 25) to depict the current 

configuration. Key sage-grouse habitat shown on Map 25 will 

change over time due to future restoration and wildfires. 

Special Status 

Wildlife

LG-IV-MA-10 states BLM will manage "for a variety of cover 

heights" for ground-nesting birds. It does not meet sage-grouse 

conservation requirements.

The Final EIS addressed habitat for a variety of wildlife. Some 

species prefer areas with little visual obstruction for nesting 

(curlew) whereas other species select areas with taller denser 

herbaceous vegetation for nesting (northern harrier). The intent 

of the management action was to provide habitat to a variety of 

species not just sage-grouse. This management action was not 

included in Alternative VI (Proposed RMP) in the Final EIS.

Special Status 

Wildlife

The BLM must apply mandatory measurable standards of use 

to provide 9-inch herbaceous nesting cover for sage-grouse to 

all permits as a provision of the Final EIS. It must reduce 

livestock impacts to understory diversity and shrub canopy 

LG-CA-MA-1 prescribed adaptive management including using 

indicators to meet resource objectives. Specific indicators would 

be most effective when prescribed site-specifically using the 

most current science and monitoring data to meet resource 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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complexity. For many native bunchgrasses, essentially no 

grazing use can be made and this standard achieved until 

long-term rest has occurred.

objectives. LG-VI-MA-2 notes utilization limits would be 

determined on an allotment specific basis to meet objectives for 

Riparian Areas and Wetlands, Fish and Wildlife, and Special 

Status Species.

Connelly and others (2011a) and Connelly and others (2000) 

mentioned 7 inches (18 cm) not 9 inches (≈23 cm) of residual 

herbaceous vegetation as being suitable for nesting sagegrouse. Residual grass height varies by grass species, annual 

growing conditions and amount of utilization by wildlife and 

livestock. 

Special Status 

Wildlife

Other provisions of this preferred alternative section allow 

livestock grazing to occur in mule deer winter habitats 

(including burned lands where deer may face maximum 

stress), provide no limit on winter grazing in sage-grouse 

habitats, don't even identify sage-grouse seasonal habitats, 

and provide no limit on spring grazing in sage-grouse lekking 

and nesting habitats.

Areas without shrubs (previously burned) provide little winter 

browse or cover for wintering mule deer or pronghorn. In 

Alternative VI (Proposed RMP) of Chapter 2, LG-CA-MA-7 

allows periodic spring grazing of big game habitat at levels to 

promote browse. WI-VI-MA-2 provides a restoration focus on big 

game winter range, which has burned. Planting of sagebrush, 

bitterbrush or other shrubs would also improve habitat for sagegrouse. SS-CA-MA-11 provided for the management of 

shrublands in a landscape context to ensure seasonal habitat 

needs are met for sage-grouse and other sagebrush obligates. 

LG-CA-MA-4 allows season of use changes to be made when 

warranted. LG-VI-MA-8 addressed livestock grazing in sagegrouse habitat. 

Special Status 

Wildlife

There is no plan to conserve sage-grouse in Alternative IV. 

The livestock grazing section conserves all or nearly all animal 

unit months and perhaps even imposes more use through 

Temporary Non-renewable Authorizations, or by classifying 

areas as grasslands following rehabilitation or restoration.

In Alternative VI (Proposed RMP), management actions in the 

Upland Vegetation, Riparian Areas and Wetlands, and Special 

Status Species sections identify actions that will benefit sagegrouse habitat and indirectly populations. Additionally, 

allocations and management actions for resource uses in the 

Land Use Authorizations, Livestock Grazing, Leasable Minerals, 

and Salable Minerals sections also identify management actions 

allowing effective regulation of these authorized uses to maintain 

or enhance resource values, including sage-grouse. The BLM 

guidelines for sage-grouse habitat management considered 

recommendation in the following sources: Sage-grouse Advisory 

Committee 2006 Conservation Plan for the Greater Sage-grouse 

in Idaho and Jarbidge Local Working Group Sage-grouse Plans. 

The classification of areas without shrubs as grasslands is 

appropriate since they no longer have a substantive shrub 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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overstory. Alternative VI includes the identification of sagegrouse management area in accordance with current BLM 

guidance. This places additional management consideration for 

a number of land uses.

Special Status 

Wildlife

There are no components of Alternative IV that will clearly and 

effectively conserve sage-grouse habitats and populations.

Chapter 2 of the Final EIS contained numerous management 

actions to conserve sage-grouse habitats including: restoring 

habitat to enlarge and connect present islands of sagebrush 

habitat; increasing forbs in sagebrush habitat, making key 

habitat a critical suppression priority, and restrictions in land use 

authorizations, leasable and salable minerals, and livestock 

grazing.

Special Status 

Wildlife

On p. 2-141, what does variety of vegetation types mean? 

Sage-grouse are present and they need 9 inches of residual 

cover and abundant structurally complex sagebrush, and an 

absence of cheatgrass. 

In the Draft RMP/EIS, management action LG-IV-MA-10 states

"Manage livestock grazing to provide a variety of residual cover 

heights to meet the needs of ground nesting birds." This 

acknowledges that not all grassland bird species prefer taller 

grass habitats. Based on comments, the Final EIS did not 

include that management action. 

Regarding the 9-inch grass herbaceous height standard for 

sage-grouse, Connelly and others (2000), Connelly and others

(2004; pp. 4-5) and Connelly and others (2011b; p. 74) noted 

successful nests had taller grass (7 inches [18 cm], not 9 inches) 

than unsuccessful nests.

Special Status 

Wildlife

Reference to a 6-inch residual cover is buried in the midst of 

best management practices at p. A-81, and there is no 

requirement that even this inadequate measure be applied to 

all sage-grouse habitats and to recover seeded areas.

Residual cover measured at sage-grouse nests in most studies 

usually occurred after the nest failed or the eggs hatched. 

Grasses actively grow during the nesting period. Retaining 6 

inches of residual cover following grazing from late summer 

through winter should provide the 7 or more inches of residual 

cover for nesting the next spring. Residual cover is one of the 

tools that could be considered for sage-grouse nesting habitat 

during permit renewal.

Special Status 

Wildlife

On p. 4-404, Alternative II applies sage-grouse standards to 

"allotments with greater than 50% native plant communities". 

This is a non-starter as is this entire alternative. Alternative II is 

not a valid alternative for an RMP in the context of the woefully 

altered planning area landscape.

Alternative II was included in the Final EIS based on comments 

wanting commercial uses emphasized in the planning area. 

Alternative II also assists the BLM in establishing the range of 

alternatives. BLM received comments supporting all or aspects 

of the Alternative II.

Special Status 

Wildlife

On p. 4-405 in Alternative III, BLM claims (based on fire and 

resource objectives) impacts would be the same as Alternative 

I. The No Action Alternative, similar to Alternative I, has been a 

Draft RMP/EIS stated “The overall effects of estimated utilization 

levels at 30% to 40% to achieve fire and resource objectives in 

Alternative III would be similar to Alternative I.” It does not state 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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complete and utter disaster in preventing fires. Alternative III is the same or similar to the No Action Alternative.

Monitoring over the past few years indicate comparatively low 

utilization levels on grass (fine fuels) in many pastures under the 

No Action Alternative. This is one factor contributing to fire. 

Special Status 

Wildlife

The BLM cannot arbitrarily segregate endangered Bruneau 

dunes tiger beetles into a different sensitive species category. 

This is another attempt at segregation to avoid addressing 

impacts of commodity industrial uses on species. It is counter 

to requirements for conserving native wildlife violates Federal 

Land and Policy Management Act, and the Fundamentals of 

Rangeland Health. 

Bruneau Dunes tiger beetle was identified as a BLM sensitive 

species (Table 3-27 in the Draft RMP/EIS) and was identified as 

a sensitive species in the Final EIS. Idaho BLM adopted type 

categories for sensitive species in coordination with the Idaho 

Department of Fish and Game over a decade ago. Although the 

Bruneau Dunes tiger beetle was not specifically mentioned, SSCA-MA-13 provided for the protection and restoration of 

sensitive species habitat including the Bruneau Dunes tiger 

beetle.

Special Status 

Wildlife

Several recent papers by Fothergill and others demonstrate 

the extreme rarity and imperilment of the Bruneau dunes tiger 

beetles.

Although one author (Fothergill) was mentioned, no specific 

citation(s) were provided for Fothergill and others. Using Google 

Scholar, the BLM found the following articles: Fothergill (2010), 

which reported observed mating behavior of the Bruneau Dune 

tiger beetle, Cicindela waynei; and Goldberg and others (2012) 

which researched mitochondrial DNA that supported the species 

status for the Bruneau Dunes tiger beetle. Neither article

assessed rarity or imperilment of Bruneau Dunes tiger beetle.

Special Status 

Wildlife

On p. 4-245, BLM elevates big game to special mention but 

does not do the same for sage-grouse? Why?

Big game and their habitat were identified issues by the public 

during scoping, as was sage-grouse. The Final EIS mentioned 

sage-grouse numerous times. 

Sage-grouse serve as the umbrella for the sagebrush group.

Additional management direction for sage-grouse was 

developed since the printing of the Draft RMP/EIS and was 

incorporated into the Alternative VI (Proposed RMP) in the Final 

EIS.

Special Status 

Wildlife

On p. 3-44, the BLM underplays the crisis facing sage-grouse 

and sagebrush species. "Between 1983 and 2006, active leks 

... declined from 152 to 39 due to habitat change". What are 

the numbers of birds on the remaining leks? How are they 

dispersed spatially?

The Final EIS revised Chapter 3 to include information on sagegrouse counts per lek on lek routes. Because not all leks are 

counted annually, similar data are not available for all leks. A 

new map was included in the Final EIS, Map 25 “Sage-Grouse 

Habitat” which depicts the locations of sage-grouse leks and key 

habitat in the planning area, and the sage-grouse management 

area.
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Special Status 

Wildlife

How can the BLM maximize the security of lekking, nesting, 

brood rearing and wintering sage-grouse? The Draft RMP/EIS 

and its alternatives simply do not answer this question. And 

this cannot be answered until BLM does what the Settlement 

Agreement requires it to do - conduct a detailed site-specific 

analysis of the current habitat conditions and population status 

of sage-grouse across the planning area - taking into full 

account the degree and severity of losses and degradation 

across the Field Office and surrounding lands as well as 

severe losses in other portions of the biome. Then it must 

develop effective conservation.

The NEPA does not require maximum protection or development 

for any resource. However, NEPA does require disclosure. 

Chapter 2 presented a variety of allocations and management 

actions for the various alternatives. Chapter 3 in the Final EIS 

provided information on the amount of sage-grouse habitat, 

sage-grouse leks and their status. The Final EIS incorporated 

sage-grouse habitat in the analysis. Chapter 4 addressed 

impacts of various resource uses for the Alternatives in the Final 

EIS. The cumulative impacts area for sage-grouse extends well 

past the planning area boundary. 

Special Status 

Wildlife

In the Special Status Species Guilds section of Chapter 3, the 

BLM devotes a single paragraph to sage-grouse. This serves 

as no basis for conducting a valid analysis of any of the 

alterative, or for understanding threats, developing a viable 

plan to conserve the species, etc. The section on Habitat 

Fragmentation (p. 3-48) is minimal. There is no current science 

applied on the severity of losses to persistence of a viable 

population. It provides no overlay of all the threats tied to the 

land areas of the planning area so that proper sage-grouse 

conservation planning and alterative development can occur.

The Final EIS revised Chapter 3 to include more information 

concerning special status species in wildlife habitat groups. The 

Final EIS revised the analysis in the Special Status Wildlife

section of Chapter 4. 

Special Status 

Wildlife

BLM must radically revise its analysis of sage-grouse and all 

rare and declining species, and develop a range of alternative 

that would honestly act to conserve sage-grouse and other 

wildlife, rare plants, aquatic species, recreational uses, clean 

air and clean water, and other values of the public lands.

The BLM developed alternatives based on comments received 

during scoping. General themes included maintaining traditional 

uses, increasing commercial uses, reducing wildfire, a focus on 

active restoration of native vegetation, and a focus on passive 

recovery coupled with reduced commodity use. The alternatives 

create a range that was analyzed in the Draft RMP/EIS. 

Alternative VI (Proposed RMP) contained aspects of some of the 

alternatives and adds additional management actions to benefit 

sage-grouse.

Special Status 

Wildlife

The key sage-grouse habitat map (Map 21 in the Draft 

RMP/EIS) is inaccurate. BLM refuses to provide mapping of all 

key sage-grouse habitat in important land areas grazed by 

permittees.

The Final EIS updated the sage-grouse habitat map (Map 25) to 

include key sage-grouse habitat and leks.

Special Status 

Wildlife

The BLM does not define a sage-grouse lek radius. We 

assume the BLM is using a greatly inadequate two-mile 

distance. Current science suggests wind and other energy 

developments should be located 5 miles or more from leks. In 

the case of the planning area, where grouse are known to 

The Final EIS analyzed different development lek buffer 

distances in the range of alternatives. A 5-mile buffer was 

included in Alternative V, whereas the No Action Alternative had 

a 2-mile radius and Alternative II included a 1-mile buffer 

distance from leks for the placement of new communications 
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Category Comment Response

move over large distances to nest and fulfill their seasonal 

needs, the entire area of the Sagebrush Sea Area of Critical 

Environmental Concern must be off-limits to wind development. 

There is no alternative that examines this.

towers, meteorological towers, and wind turbines. Alternative VI 

(Proposed RMP) refined areas available to energy development 

as areas outside sage-grouse management area and 4 miles.

Special Status 

Wildlife

The BLM also fails to provide a large context for its very high 

fence densities, roads and water developments, and many 

other sources of habitat disturbance that sage-grouse and 

other wildlife populations face.

The Final EIS updated the Special Status Species sections in

Chapter 3 and 4. The cumulative impacts analysis in the Special 

Status Wildlife section in Chapter 4 included fence density, route 

density, and other infrastructure to the extent the information 

was available for bighorn sheep and sage-grouse cumulative 

impacts analysis areas.

Special Status 

Wildlife

We could find no on-line Nevada Forest or the BLM fence layer 

- but Idaho BLM must obtain this information from sister 

agencies so the fence Footprint on sage-grouse, antelope, 

migratory bird and other populations over a broader landscape 

can be understood.

The Final EIS revised the cumulative impacts to include fences 

on National Forest lands for sage-grouse and other wild species 

to the extent the information was provided or available. 

Special Status 

Wildlife

What is the current direct, indirect and cumulative footprint of 

fragmentation and facilities that the Jarbidge grouse population 

faces?

The Final EIS analyzed the direct, indirect, and cumulative 

impacts of habitat alternation (wildfire), facilities, routes, 

transmission lines, and fences on sage-grouse and other wild 

species to the extent the information was available.

Special Status 

Wildlife

We recommend the Final EIS reflect the status of the Greater 

sage-grouse as a candidate species. 

The Final EIS presented the updated Greater sage-grouse to 

Candidate status. 

Special Status 

Wildlife

We recommend that program-specific land use plan level 

conservation measures be identified in the Final EIS, and that 

they be addressed within the section 7 conference process.

Alternative VI (Proposed RMP) in Chapter 2 of the Final EIS 

contains additional management actions (conservation 

measures) to protect sage-grouse habitat for land use 

authorizations, leasable and salable minerals, wildland fire, and

livestock grazing. Specific conservation measures are given in 

Appendix E: Conservation Measures. BLM will enter Section 7 

consultation with the US Fish and Wildlife Service on the final 

plan to be implemented prior to the signing of the Record Of 

Decision. 

Special Status 

Wildlife

Alternative IV proposes designating the Jarbidge Foothills Area 

of Critical Environmental Concern (ACEC) for the conservation 

of special status species, including the Greater sage-grouse. 

The proposed Jarbidge Foothills ACEC boundary contains 

important habitat for lekking, nesting, wintering, and migratory 

Greater sage-grouse. The proposed larger boundary area 

Jarbidge Foothills ACEC contains almost twice the acreage of 

key sage-grouse habitat as the smaller boundary area ACEC 

(90,000 acres and 47,000 acres, respectively); and thus, 

The Jarbidge Foothill Area of Critical Environmental Concern

(ACEC) was not included in Alternative VI (Proposed RMP) 

because prescribed management, additional management 

actions, and restrictions (including key sage-grouse habitat) 

negated the need for special management as an ACEC. Spotted 

frogs in Rocky Canyon receive additional protection as a Wild 

and Scenic River segment and as a Type 1 sensitive species.
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Category Comment Response

provides greater conservation value for the species.

Special Status 

Wildlife

Although no longer included on the list of threatened and 

endangered species in the lower 48 states pursuant to the Act 

as of August 7, 2007, the bald eagle continues to be Federally 

protected under the Bald and Golden Eagle Protection Act and 

the Migratory Bird Treaty Act. We encourage the Bureau to 

incorporate land use plan level conservation measures for both 

the bald eagle and the golden eagle into the Final EIS to 

ensure conservation needs for these species are adequately 

addressed.

Alternative VI (Proposed RMP) in the Final EIS contained an 

updated management action specific to eagles including a nest 

buffer (WI-CA-MA-5). The project proponent would develop an 

Eagle Conservation Plan and Avian Protection Plan in 

coordination with and approval of the US Fish and Wildlife 

Service. BLM does not develop or approve either plan. Design 

features from the Records of Decision for the Implementation of 

a Wind Energy Development Program and Associated Land Use 

Plan Documents (BLM, 2005) and the Solar Energy 

Development in 6 Southwestern States (BLM and DOE, 2012) 

Records of Decision were adopted for projects regarding siting, 

data collection prior to development for bats, raptors, and 

songbirds and other species, data collection during all seasons 

and post development monitoring needed for adaptive 

management to reduce impacts for raptors, bats, and songbirds.

Special Status 

Wildlife

BLM has failed to develop a realistic plan for the future to 

minimize noise and all other disturbances to sage‐grouse.

Alternative VI (Proposed RMP) in Chapter 2 of the Final EIS 

contains management actions that directly and indirectly address 

noise or disturbances. LA-VI-MA-1 and SS-CA-MA-10 includes 

seasonal restrictions on construction and maintenance in sagegrouse habitat, LE-VI-MA-1 has seasonal restrictions during the 

spring for sage-grouse, SA-CA-MA-1 provided mitigation to 

avoid impacts to special status species and their habitat. RECCA-MA-2 provided for imposing restriction to minimize impacts to 

fish and wildlife during important seasonal periods. 

Special Status 

Wildlife

Please enter this scientific information on noise impacts into 

the record for the Draft RMP/EIS: The Impacts of Energy 

Development Noise on Breeding Greater Sage-Grouse Jessica 

Blickley, UC Davis, Evolution and Ecology 3:10 to 4:00 p.m. – 

1003 Kemper Hall. 

The referred document was an abstract printed in the Journal of 

the Acoustical Society of America regarding a conference. The 

BLM used Blickley and others (2012) “Experimental evidence for 

the effects of chronic anthropogenic noise on abundance of 

Greater sage-grouse at leks regarding noise” from Conservation 

Biology, a peer-reviewed journal. The Final EIS revised Chapter 

4 with respect to noise in cumulative impacts analysis in the 

Special Status Wildlife section. 

Special Status 

Wildlife

Please incorporate this information into the Draft RMP/EIS 

analysis: Sage Grouse 2011 Southwest Intertie Project 

Western Ecological Research Center Projects (USGS, 2011). 

The referred to information was not available at the time the 

Draft RMP/EIS was prepared. The information is preliminary and 

briefly summarized and not peer reviewed. 

Special Status 

Wildlife

Please incorporate this information into the Draft RMP/EIS 

analysis: Sage-grouse 2011 nesting rabbit brush Western 

Ecological Research Center Projects (USGS, 2011). 

The information was not available at the time the Draft RMP/EIS 

was prepared. The information posted on the US Geological 

Survey Western Ecological Research Center web page for the 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Southwest Intertie Project is preliminary, briefly summarized and 

not peer reviewed. Connelly and others (2011a, 2011b) in the 

peer reviewed Studies in Avian Biology No. 38 also included 

information regarding sage-grouse use of shrubs other than 

sagebrush for nesting. The Final EIS used this reference in 

Chapter 3 and Chapter 4.

Transportation 

and Travel

Why do you feel it is necessary to focus different areas Travel 

Management Areas (TMAs) for different types of use? Many of 

the TMAs do not have transportation as a focus; rather they 

focus on big game or sage-grouse habitat. Are these being 

used as ways to reduce motorized access? In addition, TMAs 

should not include portions of Owyhee and Twin Falls Counties 

together as Omnibus Public Land Management Act of 2009 

has already set regulations on Owyhee county that do not 

apply to Twin Falls county.

The seven alternatives considered in the Final EIS provide a 

reasonable range of alternatives for Travel Management Areas 

(TMAs) within the planning area. Creation of the TMAs was to 

help with the manageability and area specific travel issues of the 

planning area. Some TMAs will have less controversy from an 

access and use standpoint while others will need a higher-level 

of public involvement and special resource considerations. The 

travel planning process will develop the designation of roads and 

trails for each of the TMAs.

Transportation 

and Travel

There is a significant need for youth motorized loops. Youth 

loops would include a small area of several acres, either 

contained by fencing or clearly marked boundary, with short, 

tight trail system that is designed to entertain kids under adult 

supervision. We request that this important need be 

adequately addressed in the preferred alternative.

Building a set of trails specifically benefiting one group is beyond 

the scope of this planning effort. Subsequent implementation 

projects for Special Recreation Management Areas and 

Extensive Recreation Management Areas will analyze 

opportunities for various recreation activities and experiences.

Transportation 

and Travel

Develop a national mapping standard for travel planning 

actions starting with the proposed action in order to address 

this inadequacy and the environmental justice issue associated 

with it.

The BLM will use various plans, manuals, handbooks, and 

technical references to develop the Jarbidge Travel 

Management Plan, such as the BLM Travel and Transportation 

Manual (1626); Travel and Transportation Management 

Handbook (H-8342-1); Planning and Conducting Route 

Inventories (BLM Technical Reference 9113-1); and Roads and 

Trails Terminology (BLM Technical Note 422).

Transportation 

and Travel

A reasonable travel management alternative would maintain 

existing travel ways that provide motorized recreationists with a 

system of loops and destinations. The preferred alternative 

should provide access to motorized looped trail systems, spurs 

for exploration and destinations, and motorized access to 

areas located outside the project area.

The Final EIS presented a reasonable range of alternatives, 

included having 25% of the planning area open to cross-country 

motorized travel (No Action Alternative) to various-sized limited 

and closed areas. The travel planning process will designate the

travel system for the planning area.

Transportation 

and Travel

The BLM must produce a travel plan that specifically 

designates roads, trails and areas for motorized use, including 

what type of vehicles will be allowed on which routes and if 

seasonal restrictions apply. This plan should also include all 

trail uses, including mountain bike, equestrian and hiking. 

The travel management planning process will consider and 

address a reasonable range of various modes of travel on 

designated routes and trails. These modes of travel will be 

motorized and non-motorized.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Sharing of single-track trails between motorized and nonmotorized users is a strategy that should be considered.

Transportation 

and Travel

Do not allow vehicular intrusions for the purposes of racing in 

the Herd Management Area. 

All alternatives, except Alternative II and the No Action 

Alternative, would not allow or would limit commercial Special 

Recreation Permits in the Herd Management Area. Special 

Recreation Permits would be required for motorized vehicle 

racing.

Transportation 

and Travel

In Chapter 2.4.3, please provide a transportation and travel 

system that facilitates multiple use, with an emphasis on 

recreation, livestock grazing, wind energy development, all 

while minimizing perceived and real impacts to big game 

habitats.

The Transportation and Travel section (section 2.4.3) in the Draft 

RMP/EIS included the goal “Manage and provide for motorized, 

non-motorized, and non-mechanized access that would balance 

resource protection and use” for all action alternatives. The 

objective for Alternative II in both the Draft RMP/EIS and the 

Final EIS is to provide a transportation and travel system to 

facilitate multiple use with an emphasis on commercial use and 

minimizing impacts on native vegetation. This objective was 

developed because Alternative II focused on increasing 

commercial uses.

Transportation 

and Travel

BLM must allow permittee access for grazing management and 

administration purposes. Every alternative must contain this 

consideration.

Reword TR-I-A-2 on p. 2-158 to remove "non-Wilderness 

Study Area lands managed for their wilderness characteristics" 

for the reason addressed above.

Alternatives I-IV and Alternative VI (Proposed RMP) have 

management actions authorizing administrative access. 

Alternative VI does not propose to not manage Lands with 

Wilderness Characteristics to maintain wilderness characteristics 

(WC-VI-G- 1).

Transportation 

and Travel

The preferred alternative does not allow game retrieval off 

designated routes. Alternative II allows it, except in areas 

closed to motor vehicles and Wilderness Study Areas. We urge 

the adoption of TR-II-MA-3 rather than Alternative IV language. 

We recognize there will be locations and conditions where 

Alternative TR-II-MA-3 may not be appropriate. The Travel 

Management Plan must address these concerns. 

Allowing exceptions for cross-country travel would likely create a 

compliance situation, which would negate the point of having a 

designated travel and transportation system. Allowances for 

people to travel an arbitrary distance off of motorized routes to 

retrieve game makes it difficult for law enforcement officials to 

protect against resource damage.

Transportation 

and Travel

The BLM should define the phrase "during fire restrictions." Fire restrictions are administrative restrictions due to the high 

risk of fire starts or numerous fires or public safety issues 

associated with a wildfire. The restrictions are short-term 

restrictions on activities or access which could contribute to fires 

or impair public safety. 

Transportation 

and Travel

In TR-IV-MA-7 and TR-V-MA-7, the BLM should clarify if the 

restrictions in the Jarbidge Foothills Travel Management Area

in Alternatives IV and V are directly associated with Area of 

Specific management focus for Travel Management Areas is 

consistent with management objectives for all action alternatives 

in the Final EIS. Designation of routes in established Areas of 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-588

Category Comment Response

Critical Environmental Concern designations and associated 

land use management in Alternatives IV and V.

Critical Environmental Concern will occur through the travel 

planning process.

Transportation 

and Travel

The motorized closure trend has created significant cumulative 

effects and has reached the point where it is causing severe 

public distress. Reasonable alternatives to motorized closures 

must be pursued. This trend towards massive motorized 

closures is not responsible to the public’s needs for motorized 

access and recreation and is contrary to the multiple-use 

management directives specified by congress. Any significant 

closing of motorized routes in the project area does not meet 

the basic requirement of the NEPA act of 1969 as stated in 

“Sec. 101 (b) (5) achieve a balance between population and 

resource use which will permit high standards of living and a 

wide sharing of life’s amenities”.

The Final EIS analyzed a reasonable range of alternatives, as 

well as a cumulative impact analysis for motorized and nonmotorized recreation in the Transportation and Travel section of 

Chapter 4. Alternative VI (Proposed RMP) allocates areas that 

are open, limited to designated trails, or closed to motorized use. 

Travel management planning will determine the actual 

designation of roads and trails upon completion of the Final EIS. 

Transportation 

and Travel

BLM workers and permittees need a well-maintained roadway 

system for management. For firefighting, a well-maintained 

system would provide both a fire line for firefighting and access 

by BLM firefighters.

Road improvements for fire suppression were included in the 

range of alternatives with Alternative III having the largest 

amount of road improvements and maintenance for fire 

suppression activities. The travel planning process will designate 

roads and trails. 

Transportation 

and Travel

Incorporate roads along the Jarbidge River into the 

management plan so that needed bank stabilization and 

channel work can be done under routine maintenance and not 

need special approvals for each incident.

These projects will require implementation level analysis. Road 

management agreements will include routine maintenance (TRCA-MA-4).

Transportation 

and Travel

Any final RMP should ensure that pre-existing rights and 

practices are protected within the newly designated Wilderness 

areas. The Draft RMP/EIS did not deal with implications of the 

recently designated wilderness; we still wish to note our 

comment thereto beyond what we previously shared on June 

19, 2009 and November 25, 2009. We acquired the right under 

ordinary and customary practices within Owyhee County to use 

pickups and all-terrain vehicles both on and off road to check 

livestock and move them.

The Owyhee Canyonlands Wilderness and Wild and Scenic 

Rivers Management Plan will address grazing management and 

travel associated with grazing facilities inside wilderness. The 

travel management planning process will address travel outside 

the wilderness.

Transportation 

and Travel

We oppose road closings in Multiple Use Areas 10 and 14 as 

depicted in Map 4 of the Draft RMP/EIS. We agree that all 

travel should be restricted to existing roads.

Omnibus Public Land Management Act of 2009 closed roads in 

the designated wilderness area (Bruneau-Jarbidge Rivers 

Wilderness), which is contained in Multiple Use Area (MUA) 10. 

Due to terrain, the Salmon Falls Creek Area of Critical 

Environmental Concern and Wilderness Study Area in MUA 14 

have no inventoried roads contained within their boundaries (rim 

to rim). 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Transportation 

and Travel

On p. 2-159, TR-I-MA-7, regarding the Jarbidge Foothills, 

closing this area to motorized traffic is discriminating against 

hunters who need access for pickup and drop-off of hunters. It 

is also discriminating the person who is handicapped. You are 

proposing to close off another 137,000 acres to sportsmen.

Limiting the amount of motorized travel in the Jarbidge Foothills 

Travel Management Area (TMA) was included in the range of 

alternatives analyzed in the Final EIS. Closing the Jarbidge 

Foothills TMA to motorized travel is not included in Alternative VI 

(Proposed RMP). TR-VI-MA- 7 states: "Jarbidge Foothills TMA 

(135,000 acres): Focus on increasing core habitat size for sagegrouse and big game, while providing for motorized and nonmotorized recreation experiences."

Transportation 

and Travel

We are opposed to any more road closings, especially the 

areas between the Jarbidge and Bruneau canyons and the 

Salmon Falls Area of Critical Environmental Concern. You are 

proposing to close prime hunting areas to hunters. 

No Alternatives in the Final FIS close hunting management units. 

Transportation 

and Travel

We suggest the following objective be common to all 

alternatives: Provide a travel and transportation system that is 

flexible enough to compliment multiple use, while addressing 

area specific challenges.

The Final EIS revised TR-VI-O-1 to provide more flexibility 

“Provide a transportation and travel system to facilitate habitat 

restoration, resource protection, and multiple use.”

Transportation 

and Travel

We suggest the following management action be common to 

all alternatives: TR-I-MA-6 (modified) Identify locations for and 

install gates and cattle guards on designated routes to 

minimize conflicts between grazing operations and motorized 

activities.

Alternative VI (Proposed RMP) states: “Install gates and cattle 

guards along designated routes to minimize conflicts between 

transportation-related activities and livestock grazing operations” 

(TR-VI-MA-6).

Transportation 

and Travel

Based on the map provided we cannot tell if Black Rock 

crossing is closed to motorized traffic. It appears open to 

motorized traffic but Idaho Department of Fish and Game

recommends further clarification because the scale of the map 

does not provide sufficient clarity for review. 

The Final EIS allocates Black Rock Crossing as limited to 

designated routes. See Map 78 "Travel Designations in 

Alternative VI (Proposed RMP)."

Transportation 

and Travel

Omnibus Public Land Management Act of 2009 (OPLMA) 

requires the BLM to complete travel planning before March 

2012. Management action TRC-MA-5 states, "Complete a 

Comprehensive Transportation and Travel Management Plan 

(CTTMP) within 5 years of the signing of the Record Of 

Decision". This management action is inconsistent with 

OPLMA. The BLM should start travel planning immediately 

after the signing of the Record of Decision. 

The BLM is aware of the timeline for travel management 

planning contained in Omnibus Public Land Management Act of 

2009. 

Transportation 

and Travel

The Canyonlands Travel Management Area (TMA) does not 

provide for public access. This TMA has jeep roads that 

provide a critical linking opportunity for motorcyclists and allterrain vehicle riders looking to connect with Murphy Hot 

Springs and Jarbidge NV from the west. The TMA should be 

The Final EIS presents a range of Travel Management Areas 

(TMAs) designations and management. Alternative VI (Proposed 

RMP) allows for motorized and non-motorized opportunities in 

the Canyonlands TMA (188,000 acres).
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-590

Category Comment Response

amended to provide public access. 

Transportation 

and Travel

Alternative IV would manage a couple of smaller open areas 

for motorized recreation, however Alternative IV will reduce 

motorized route opportunities by increasing core habitat size 

for wildlife. These effects should be documented in the Final 

EIS.

Chapter 4, Transportation and Travel section of the Final EIS 

discussed the effects of increasing core habitat size for wildlife 

on route density and location.

Transportation 

and Travel

Idaho Department of Lands (IDL) fully supports the BLM 

initiative to develop a Travel Management Plan with the 

understanding that approval by IDL is required for locating 

trails and roads on State Endowment Trust Lands.

The travel management process includes public input on the 

Travel Management Plan for the planning area. The involvement 

will be collaborative by incorporating internal and external input 

from agencies, communities, and interest groups. 

Transportation 

and Travel

The Resource Advisory Council unanimously supports 

replacing TR-IV-MA-7 with a modified TR-II-MA-6.

The Final EIS analyzed a reasonable range of alternatives 

addressing transportation and travel. The Travel Management 

Area (TMA) definition in the BLM Travel and Transportation 

Manual 1626 states that TMAs can be used to separate specific 

areas from the larger planning area for a variety of reasons, such 

as the area's complexity or level of controversy, the need for 

higher level of public involvement, the consideration of special 

resource characteristics, or the improved manageability of the 

area. Between the signing of the Record Of Decision and the 

development of the travel management plan, site-specific 

resources or resource use situations could dictate some 

modification of the TMAs consistent with objectives in the RMP.

Transportation 

and Travel

A majority of the Resource Advisory Council supports removing 

TR-CA-MA-8, and replacing it with, “Route designation shall 

recognize that off-highway vehicle (OHV) travel on public lands 

is a legitimate use of these lands consistent with other values 

and resource considerations is not merely a feel-good phrase 

but an imperative. Adequate, varied and desirable OHV 

recreation opportunity is not to be offered only after all other 

competing interests have been satisfied, but as an integral part 

of the total output of the planning area. Route designations will 

be reviewed annually with public participation to meet changing 

needs and conditions. The authorized officer, throughout the 

life of the plan, shall seek and encourage assistance from 

interested parties, including OHV groups, to resolve localized 

resource issues including the use of volunteer labor whenever 

practical.”

The Final EIS analyzed a reasonable range of alternatives 

addressing transportation and travel. Alternative VI (the 

Proposed RMP) in the Final EIS does not include TR-CA-MA-8. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-591

Category Comment Response

Transportation 

and Travel

The RMP provides no baseline numbers on road densities, and 

no specific goals, objectives and management actions for 

removing miles of roads, or binding requirement to reduce road 

densities in important habitat areas to conserve wildlife. 

The Final EIS provides maps of allotment facilities (Map 51 

“Range Infrastructure”) and existing roads (Map 71 “Travel 

Routes as of 2011”). The travel management planning process 

uses a public procedure to determine the transportation and 

travel system for the planning area. The Travel Management 

Plan will determine the routes and trails to be designated, 

modified, closed, or rehabilitated as well as the maintenance 

level, modes of travel, and seasonal and access restrictions for 

designated routes.

Transportation 

and Travel

The issue of failing to clearly identify facilities (or at least a 

percentage of them) for removal is linked to BLM's ability to 

develop an appropriate travel planning process and lay a 

framework in the RMP. BLM must layout in the RMP targeted 

pipelines, troughs, and fencing for removal so that 

unnecessary roads can be removed and high road densities 

reduced to provide habitat security and limit human infusion, 

reduce or limit weed spread, decrease sage-grouse predator 

travel corridors, and provide many other habitat security 

benefits. These unnecessary roads can then be closed in the 

Travel Plan and slated for de-commissioning and rehabilitation.

The NEPA analysis that accompanies the Travel Management 

Plan would include, at a minimum, cumulative impacts 

assessments of road density and fragmentation of sage-grouse 

habitat. Alternative VI (Proposed RMP) proposes Transportation 

and Travel management actions specific to wildlife include: TRCA-MA- 2, TR-CA-MA- 3, and TR-CA-MA- 6., In reference to 

fencing and range infrastructure see WI-CA-MA- 4, LG-CA-MA13, LG-CA-MA-14, and LG-CA-MA- 16. 

Transportation 

and Travel

Page 4-639 of the Draft RMP/EIS has phrasing that indicates 

BLM foresees increased recreational use. Yet BLM elsewhere 

claimed in some of the most important wild recreation areas 

there would not be an increase. How do you explain this 

contradiction?

The Final EIS does indicate that BLM foresees an increase in 

recreation when considering the planning area as a whole. 

These increases will take place in localized areas. 

Transportation 

and Travel

BLM must greatly restrict snowmobile use in sage-grouse, big 

game and other habitats. These areas should be closed to 

snowmobile use. Snowmobiles must be restricted to roads. Not 

only is wildlife disturbed, shrubs may be broken off and 

crushed. Pygmy rabbit snow burrows may be collapsed.

The Final EIS does not analyze snowmobile use due to the 

marginal snowpack associated with the planning area and low 

use numbers. Further analysis of this use will be determined 

during the travel planning process.

Transportation 

and Travel

Page 4-646 of the Draft RMP/EIS refers to Alternative V, but 

this appears to be the Alternative IV section.

The Final EIS corrected the typographical error, found in Chapter 

4 Transportation and Travel section.

Transportation 

and Travel

BLM must provide detailed analysis of the role of livestock 

infrastructure and management actions in expanding the road 

network within the planning area. Alternative V does not 

adequately layout a plan to close roads associated with 

livestock facilities, supplement artificial feeding, etc. in lands 

where grazing would not occur. Plus, it does not identify a 

protocol for terminating unnecessary roads in grazed areas if 

The Final EIS Chapter 3 Transportation and Travel section 

presents the current condition of the road network within the 

planning area. The Travel Management Plan will determine the 

routes and trails to be designated, modified, closed, or 

rehabilitated as well as the maintenance level, modes of travel, 

and seasonal and access restrictions for designated routes. The 

permit renewal process will identify specific tools to for resource 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-592

Category Comment Response

ranchers were required to rely more on horses and herding to 

distribute livestock rather than fences and supplements.

protection on an allotment-specific basis. 

Transportation 

and Travel

How does the road network in the planning area compare with 

that present in 1987?

Section 202(c) of Federal Land Policy and Management Act of 

1976 lists the requirements of the BLM in developing RMPs. 

These requirements do not include comparing the current 

affected environment with the affected environment from the old 

RMP. 

Transportation 

and Travel

There is nothing in the various development actions 

components to Alternative IV that prohibits new or expanded 

roads across nearly the entire Jarbidge Field Office.

The Travel Management Plan will determine the routes and trails 

to be designated, modified, closed, or rehabilitated as well as the 

maintenance level, modes of travel, and season and access 

restrictions for designated routes. 

Transportation 

and Travel

BLM should develop a series of alternatives with specific goals 

for reduction of road densities in important areas and critical 

habitats, and layout a specific decision making process and 

time-frame to do so.

RMPs guide future management actions and subsequent sitespecific implementation decisions. RMPs establish goals and 

objectives for resource management and the measures needed 

to achieve these goals. The Travel Management Plan will 

address road densities in support of the goals and objectives in 

the Approved RMP. 

Transportation 

and Travel

BLM does not have management responsibility for Travel 

Designations on Saylor Creek Range and Juniper Butte 

Range. All roads within the exclusive use area on Saylor Creek 

Range and roads within Juniper Butte Range are unavailable 

as travel routes.

Decisions made in the Travel Management Plan will be limited to 

management of roads and trails on BLM-managed lands. Travel 

Designation maps (Maps 72-78) in the Final EIS depicts 

allocations related to travel and does not designate routes.

Transportation 

and Travel

Off-highway vehicles (OHVs) should not be allowed or greatly 

restricted in the planning area. If they are allowed, than the 

area open to their use should be small and limit the type of 

OHVs to less polluting 4-stroke models with noise muffling.

The Final EIS analyzed a reasonable range of alternatives. 

Alternative VI (Proposed RMP) would designate 4,000 acres 

within the Deadman and Yahoo Special Recreation Management 

Areas as open to cross-country motorized vehicle use. The 

Bruneau-Jarbidge Rivers Wilderness, Salmon Falls Creek Area 

of Critical Environmental Concern, and Lower Salmon Falls 

Creek Wilderness Study Area would be closed to all motorized 

vehicle use. Travel would be limited to designated routes in the 

remainder of the planning area. Current BLM policy does not 

limit model types of off-highway vehicles allowed on BLMmanaged lands. 

Transportation 

and Travel

Off-road vehicle use impacts wilderness areas immediately and 

for many years, so I would prefer that cross-country travel of 

off-highway vehicles be reserved for non-wilderness areas.

The Bruneau-Jarbidge Rivers Wilderness is closed to all 

motorized and mechanized vehicle use.

Transportation 

and Travel

Consequences for those who ride illegally in undesignated 

areas must also be enforced, this is an essential part of what 

you legislate because many off-road vehicle riders have a 

Consequences for those illegally riding in undesignated areas 

are beyond the scope of this planning effort.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-593

Category Comment Response

sense of entitlement regarding where they ride.

Tribal Rights 

and Interests

Revise TI-CA-G-1 as follows to include the BLM’s obligations 

to tribes beyond applicable treaty rights: “Manage public lands 

to protect resources and values associated with Native 

Americans as established by Federal statutes, regulations, 

government trust responsibilities, and, if applicable, treaty 

rights.”

Revise TI-CA-G-2 as follows to include protection of sacred 

sites and other cultural resources: “Manage and protect natural 

and cultural resources, including traditional cultural properties 

and sacred sites, of importance to the tribes consistent with the 

BLM’s statutory obligations and general trust responsibilities in 

a manner respective of tribal beliefs, traditions, and values.”

The first Goal and Objective under Tribal Rights and Interests in 

both the Draft RMP/EIS and the Final EIS applies to treaty rights 

because they are different from the BLM’s obligations under 

general statutes. The second Goal and Objective applies to 

BLM’s other obligations to the tribes. Between the Draft 

RMP/EIS and the Final EIS a third Goal and Objective, TI-CA-G3, was developed. This goal reads, “Protect the physical 

condition of sacred sites and traditional cultural properties and 

preserve tribal access to such sites”. The Final EIS adequately 

addressed sacred sites and traditional cultural properties with 

these goals, objectives, and management action TI-CA-MA-3 

which states, “Work collaboratively with the tribes regarding the 

identification and management of traditional cultural properties”. 

Tribal Rights 

and Interests

The very broadly written management action TI-CA-MA-1 

should include an iteration of the applicable statutes and 

authorities with which the BLM must comply. The BLM should 

consider revising the paragraph as follows: Consult with the 

Shoshone-Paiute Tribes and Shoshone-Bannock Tribes in 

accordance with the National Environmental Policy Act, the 

National Historic Preservation Act, the Archaeological 

Resources Protection Act, the Native American Graves 

Protection and Repatriation Act, the American Indian Religious 

Freedom Act, and Executive Order 13007, as well as BLM 

policy. Consultation would be an ongoing process between the 

BLM and the tribes, with the context of general management of 

public lands and programs, the BLM’s general trust 

responsibilities, and scientific proposals that may affect natural 

and cultural resources of importance to the tribes.

The Draft RMP/EIS and Final EIS did not cite specific laws, 

regulations, and policies in the management actions for Tribal 

Interests due to the potential for change during the life of the 

plan. BLM is obligated to follow all pertinent statutes, regulations, 

and executive orders. 

Tribal Rights 

and Interests

Revise management action TI-CA-MA-4 as follows: "Work 

collaboratively with the tribes to identify, manage, and protect 

traditional cultural properties”. 

In response to your comment, the Final EIS revised this 

management action, now numbered TI-CA-MA-3, to read, “Work 

collaboratively with the tribes regarding the identification and 

management of traditional cultural properties.”

Tribal Rights 

and Interests

Revise management action TI-CA-MA-5 as follows to ensure 

confidentiality of traditional cultural properties: “Provide 

information to staff, contractors and any project proponent 

regarding existing and historic use of the Planning Area by the 

tribes while, when appropriate, maintaining information 

regarding cultural resources and traditional cultural properties, 

The BLM revised this management action, now numbered TICA-MA-4, in the Final EIS to read, “Provide general information 

to staff and contractors regarding existing and historic uses of 

the planning area by the tribes, Federal government trust 

responsibilities, and the importance of Native American treaty 

rights in order to foster a greater understanding and appreciation 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-594

Category Comment Response

including inventories, evaluation records, maps, and reports, 

protected from public disclosure, as necessary to protect the 

resources.”

of tribal rights and interests related to public land management.” 

This management action is intended to enhance appreciation 

among BLM staff and contract employees for tribal rights and 

interests regarding public lands. It does not apply to confidential, 

protected information obtained through consultation or the 

Section 106 process.

Tribal Rights 

and Interests

The BLM should revise the last sentence at p. 3-1, second 

paragraph, as follows: “The relationship between Federal 

agencies and sovereign tribes is defined by numerous laws 

and regulations addressing the requirement of Federal 

agencies to notify and/or consult with Native American 

tribes....”

Based on the comment the BLM revised the Final EIS as 

suggested.

Tribal Rights 

and Interests 

Revise the Draft RMP/EIS, Chapter 4, Tribal Rights and 

Interests section, the second paragraph on p. 4-15 under 

“Methods and Assumptions” by deleting the last sentence and 

inserting in its place “Thus, site specific land use authorization 

impacts will need to be addressed on a case-by-case basis in 

consultation with tribes.”

The suggested revision is not necessary; the first assumption at 

the bottom of p. 4-15 in the Draft RMP/EIS covers the need to 

consult on site-specific land use authorizations. This assumption 

states: “Government-to-government consultation during 

implementation-level planning would identify and address 

potential impacts to tribal rights and interests at the project 

level”. 

Tribal Rights 

and Interests

Under the assumptions used when analyzing impacts to tribal 

rights and interests (p. 4-16 of the Draft RMP/EIS), the BLM 

should eliminate the last assumption and instead state, 

“Management actions that result in surface development and 

disturbance can be mitigated so as to coexist with tribal rights 

and interests, especially with the incorporation of existing best 

management practices (BMPs) from the 2005 amendments to 

the Jarbidge RMP regarding cultural and historical resources.” 

Assume these BMPs in the analysis of cultural impacts with 

regard to wind energy development.

The assumption in question states: “Management actions that 

restrict surface development and disturbance generally protect 

natural and cultural resources associated with tribal rights and 

interests”. Based on years of consultation with the ShoshonePaiute and Shoshone-Bannock Tribes we feel this is a valid 

assumption for the planning area. The use of best management 

practices and mitigation measures may reduce effects to 

resources of importance to the tribes but rarely would they 

eliminate them. 

Tribal Rights 

and Interests

Mitigation efforts and best management practices imposed on 

any project developer through existing amendments to the 

Jarbidge RMP offset cumulative impacts from wind energy 

development.

Best management practices and mitigation measures may or 

may not reduce effects to resources of importance to the tribes. 

Project specific analyses would assess the effectiveness of such 

measures.

Tribal Rights 

and Interests

Alternatives I, III, and IV, p. 4-26 of the Draft RMP/EIS, mislead 

the reader into believing that restrictions on location of wind 

energy development on Federal lands could result in more use 

of suitable state, private or adjacent public lands with fewer 

restrictions. Delete this sentence because it suggests that wind 

energy sites can be moved at will to avoid land use restrictions 

The statement in question does not distinguish between 

commercial-scale and smaller wind energy projects. Suitable, in 

this context, refers to both the wind resource and the specific 

requirements of the project. If land use allocations restrict project 

development on “suitable” Federal lands to protect sensitive 

resources, it is reasonable to assume that development would 
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while still generating sufficient wind energy to be commercially 

viable. As shown from the wind resource maps included in the 

Draft RMP/EIS and in our comments above, and through onsite 

testing, commercial scale wind energy is available in very 

specific locations in the planning area regardless of the 

underlying land tenure. It is not possible to move a project to 

other locations to avoid land use restrictions and still maintain 

a commercially viable project.

occur on “suitable” but less restrictive non-Federal lands. This is 

precisely what has occurred in the northern portion of the 

planning area. 

Tribal Rights 

and Interests

The cumulative impacts from the Alternative II discussion on p. 

4-26 of the Draft RMP/EIS assumes that tribal interests could 

be adversely affected by commercial use or development to 

accommodate larger scale wind energy projects. This may or 

may not be true depending on the goals and objectives of the 

particular tribe with an interest in the area whose rights and 

interests may, in fact, be advanced by commercial scale wind 

energy development through a lessening of global warming 

impacts on tribal resources that are particularly affected by 

global warming (see Secretarial Order No. 3289A1), by the 

tribal interest in wind energy development on tribal lands and 

lessons learned from commercial developments off of tribal 

lands, from tribal opportunities to participate in monitoring and 

mitigation efforts associated with wind energy projects, from 

the energy produced by a wind energy project, and from other 

benefits to the rights and interests of tribes.

Analysis of project specific mitigation measures is beyond the 

scope of this planning effort. In general, large-scale 

developments adversely impact natural and cultural resources of 

importance to the tribes. In our experience, such projects always 

involve the development of design features and/or mitigation 

measures to reduce these impacts. The need for mitigation is 

evidence of expected impacts. 

Upland 

Vegetation

The Final EIS needs to have more specific current vegetation 

communities especially sagebrush communities.

Map 10 “2016 Projected Vegetation” in the Final EIS is general 

and used only for comparison of alternatives. Geographical 

information system data exists that illustrates vegetation cover 

by plant community and with a minimum mapping unit of 20 

acres. The Final EIS used this data in development of the 

vegetation baseline and maps.

Upland 

Vegetation

The priority of this Draft RMP/EIS should be management 

actions that decrease the frequency of fire, especially in areas 

that have burned in the past 20 years. 

The BLM recognized that reducing the threat of fire was an 

important consideration in developing the alternatives for the 

planning area (see Issue 1a in Chapter 1). The Final EIS 

analyzed fire frequency reduction in the range of alternatives. 

Alternative III specifically focused on enhancing fire suppression 

capabilities and had the largest amount of fuels treatments 

across alternatives.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Upland 

Vegetation

The preferred alternative seems to rely on a natural conversion 

of grassland to shrubland, which over time leads to a decrease 

in the quantity of fine fuels (grass) as the shrubs become more 

competitive.

The Final EIS analyzed a range of different restoration 

strategies. Alternative VI (Proposed RMP) in the Upland 

Vegetation section of Chapter 2 has management actions for 

active restoration of grassland communities to shrubland 

communities within each Vegetation Management Area.

Upland 

Vegetation

In the Upland Vegetation section of the Draft RMP/EIS the 

definition of unvegetated areas is given as, "Unvegetated 

Areas include breaks, barren areas, sand dunes, and Recent 

Burn vegetation communities, which may be present for up to 

two years following a fire." (p. 2-25) Numerous management 

actions state: "Unvegetated areas would not be a focus for 

vegetation treatments." Applying this to unvegetated areas, as 

defined above, will eliminate timely fire rehabilitation efforts 

across the entire planning area. Without emergency fire 

rehabilitation, funding it is doubtful that adequate 

appropriations will be available to complete the vegetation 

treatment and restoration projects called for in any of the action 

alternatives. In addition, the presence of many of the sand 

dunes, in the Northern portion of the planning area, is the 

result of repeated wildfires and the ebb and flow of drought like 

conditions. Arbitrarily eliminating restoration on these sites is 

unacceptable land management when restoration with 

appropriate fire resistant and drought tolerant vegetation will 

result in long-term stabilization of the sites.

The Final EIS has separated recent burns from unvegetated 

areas to add clarity to the document.

Upland 

Vegetation

Vegetation Management Areas should be to reduce or 

eliminate acres dominated by annual vegetation to increase 

the shrub component across the planning area, and where 

needed increase the amount of perennial grasses and forbs in 

the understory.

The first management action for each Vegetation Management 

Area (VMA) within each alternative of the Final EIS focused on 

reducing annual communities. Other management actions within 

the Upland Vegetation section called for restoring a shrub 

component and increasing forbs and perennial grasses across 

VMAs.

Upland 

Vegetation

All opportunities, priorities, acreages, and focus areas for 

vegetation treatments and restoration projects should be 

determined on a case-by-case basis after considering the overriding objective/goal selected for the upland vegetation 

resource. Arbitrarily selecting number of acres or percent of a 

vegetation community to achieve or treat creates unrealistic 

expectations influenced by numerous external factors over 

which the local BLM office has no control.

The stated number of acres and percentages for vegetation 

treatments within the Upland Vegetation section helped to create 

a range of alternatives and provided the reader with a desired 

outcome based on management. Both a range of alternatives 

and a statement of desired outcomes are required components 

of an RMP by the Land Use Planning Handbook. Once an RMP 

is approved and goals and objectives are established, individual 

projects will be considered to achieve those goals and 

objectives.
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Upland 

Vegetation

During the summer of 2010, site visits to verify vegetation 

types provided by the BLM, revealed 10 of the 32 sites visited 

were incorrectly classified. 

On November 3, 2010, ground-truthing "intact sagebrush" 

revealed what was classified as Native Shrubland was, in 

reality, a non-native perennial site with very little sagebrush 

present. 

Within the Flat Top Allotment, a significant portion of what is 

classified as "intact sagebrush" contains a large crested 

wheatgrass island that was created by a recent bum within an 

old crested wheatgrass seeding dominated by sagebrush. 

These examples are illustrative, but not exhaustive, of areas 

incorrectly classified.

Map 10 “2016 Projected Vegetation” in the Final EIS was 

developed and validated according to the process outlined in 

Chapter 3 Upland Vegetation of the Final EIS. This mapping 

effort took place on a large scale and the BLM recognizes that 

the vegetation on the ground occurs in a mosaic at the small 

scale and that this causes site-specific discrepancies. These 

discrepancies do not change the Goals and Objectives or 

analysis of the Final EIS. 

Upland 

Vegetation

Closely scrutinized Proposed management action to convert 

non-native perennial vegetation to native shrublands as being 

highly impractical and extremely cost prohibitive. It is highly 

unlikely that any successful long-term shrub restoration will 

occur without first significantly reducing wildfires. Once fire is 

reduced, shrub restoration can be readily achieved, but as the 

situation currently exists, repeated wildfire will prevent 

attainment of shrub restoration goals or restoration to historical 

Fire Regime Condition Class classifications.

The Final EIS analyzed a range of alternatives that presented 

multiple ways for reducing fire frequency and size. These 

management actions can be found in the Wildland Fire Ecology 

and Management section of Chapter 2. Alternative III is the most 

aggressive alternative for addressing fire. 

Upland 

Vegetation

Automatic exclusion of non-native species in seed mixes is

unacceptable and akin to eliminating any other item in a 

toolbox designed to manage an upland vegetation community. 

Seed mixes should be determined on a site-specific basis and 

be based on resource objectives, not the current fad of native 

species only. Many non-native species are capable of 

mimicking the structure and function of native species, while 

providing soil stability and habitat for various animal species. 

UV-I-MA-27 on page 2-33 of the Draft RMP/EIS is the best 

management action in regards to seed mixes.

The Final EIS analyzed different restoration strategies among 

the alternatives. Only Alternative V specified use of native seed 

only. Alternative VI (Proposed RMP) allowed for the use of 

native and non-native species in seed mixes.

Upland 

Vegetation

My second major concern stems from the plans apparent lack 

of an effective brush control program in the parts of the 

resource area that remain in solid sagebrush cover. Just as 

seas of waving grass may not be the best management of the 

The range of alternatives analyzed a toolbox of options for 

vegetation treatments including; chemical, mechanical, targeted 

grazing, prescribed fire, seeding and planting vegetation, 

biological treatments, harrowing, and chaining. Alternative VI 
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resource or for wildlife, neither are solid oceans of brush. 

These areas need to be broken up by mosaic open spaces, 

created by moderate prescribed burns or mechanical or 

chemical treatments of the brush. This type of management, 

while first reducing the areas susceptibility to major wildfires, 

also creates areas of new forbs and fine grasses for the sagegrouse while still providing them the edge effect and protection 

from the brush that they need.

(Proposed RMP) would use this toolbox to achieve the Goals 

and Objectives of which does not specifically exclude brush 

removal.

Upland 

Vegetation

Management action UV-CA-G-1 of the Draft RMP/EIS is not 

clear on how upland vegetation reference areas are 

determined. 

The Final EIS has been updated with Appendix O: Upland and 

Riparian Area Reference Areas.

Upland 

Vegetation

Vegetation is one of the least stable resources upon which to 

base resource decisions. Wildfire and invasive species are 

capable of transforming sites in a very short period. The Draft 

RMP/EIS should include specific time commitments to update 

the map so that as areas change to native vegetation they are 

excluded from consideration for wind projects.

Alternative VI (Proposed RMP) in the Final EIS does not base 

the availability of an area for wind projects on vegetation 

communities as the other alternatives do. Instead Alternative VI 

states, “Commercial wind and solar energy developments would 

not be permitted inside the sage-grouse management area.”

Upland 

Vegetation

Plant fuel breaks and green strips including but not limited to 

crested wheat and forage kochia.

Chapter 2 of the Final EIS contained management actions for all 

alternatives in the Upland Vegetation and Wildland Fire Ecology 

and Management sections that addressed vegetation use and 

fuel breaks. A project specific analysis would analyze specific 

species composition for fuel breaks.

Upland 

Vegetation

The vegetation map is incorrect in the Canal Field in the 

Conover Allotment. The map shows that it is sagebrush with 

native bluegrass understory, which is incorrect. It actually is a 

crested wheatgrass understory.

The Final EIS mapped the Canal Field and Conover allotments 

as Non-native Understory Vegetation Sub-Group. Map 10 “2016 

Projected Vegetation” in the Final EIS was developed and 

validated according to the process outlined in Chapter 3 Upland 

Vegetation of the Final EIS. This mapping effort took place on a 

large scale and the BLM recognizes that the vegetation on the 

ground occurs in a mosaic at the small scale and that this 

causes site-specific discrepancies. These discrepancies do not 

change the Goals and Objectives or analysis of the Final EIS. 

Upland 

Vegetation

The Draft RMP/EIS identifies a number of “no grazing use” 

reference areas. Many of these areas are not ideal as they 

have had high amounts of disturbance or are located in 

pastures that already contain exclosures. The BLM should 

rethink where they are placing “no grazing use” reference 

areas. 

The reference areas varied by alternative to produce a range of 

alternatives. The Final EIS explained the process of selecting 

reference areas in Appendix O.
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Upland 

Vegetation

The BLM should re-seed small-stature native species instead 

of non-native grasses that have been seeded incrementally for 

livestock and following fires. 

The Final EIS analyzed the use of native species in the range of 

alternatives.

Upland 

Vegetation

On page 247, in the Upland Vegetation section of the Draft 

RMP/EIS, please clarify what segment of Salmon Falls Creek 

canyon Objective UV-NA-O-l is referring to.

The Final EIS revised Chapter 2 to provide consistency between 

the alternatives and clarify the correct segment of Salmon Falls 

Creek Canyon. 

Upland 

Vegetation

Management action NW-IV-MA-5, of the Draft RMP/EIS, 

requires the use of certified weed-free forage, seed and straw 

for all the BLM management activities and allowed uses. The 

Idaho State Office has already developed rules for this 

management action. Drop this management action since 

weed-free forage is already required in the planning area.

The BLM Idaho Policy as of August 20, 2011 is requiring the use 

of certified weed-free hay, straw and mulch. The BLM kept this 

as a proposed management action in Alternative VI (Proposed 

RMP). 

Upland 

Vegetation

Manage sage-grouse habitat at a landscape level to contain 

both a diversity of species and successional stages, in order to 

reduce the potential for large and frequent fires.

Alternative VI (Proposed RMP) provided goals in Chapter 2 

Upland Vegetation that focused on providing habitat for sagegrouse and other sagebrush steppe species and to manage 

vegetation to restore the ability of the ecosystem to recover 

following a disturbance and reduce fragmentation of habitat for 

sage-grouse and other native species.

Upland 

Vegetation

The vulnerability to fire in this area appears to be linked to the 

extensive non-native grasses present in this area, and which

have been planted to maximize livestock grazing. The BLM 

appears to be compounding this problem by now proposing to 

plant non-native forage kochia – essentially a non-native weed 

-- that will prevent restoration of the range with native forage, 

including sagebrush.

The BLM recognized fire within the planning area as a large 

problem. The Final EIS, Wildland Fire Ecology and Management

section, proposed the use of fuel breaks as part of a toolbox for 

fuel reduction and to help reduce the size of fires. Depending on 

the Alternative analyzed, non-native or native seed would be 

used in the fuel break. For the Alternatives that allowed for the 

use of non-native seeds this could include forage kochia.

Upland 

Vegetation

As an overall statement, a comparison of the Upland 

Vegetation Affected Environment (as disclosed at Table 3-7 

and Table 3-9, at p. 3-16), of the Draft RMP/EIS, to the desired 

future vegetation proposed under the preferred alternative (as 

disclosed at pp. ES-9 and ES-10) indicates that the BLM 

projects that, in the life of the Plan, Annual vegetation would be 

reduced by roughly 74,000 acres; Non-native Perennial 

vegetation (seeding) would be reduced by roughly 188,000 

acres; Non-native Understory vegetation (sagebrush over 

story, seeded understory) would be increased by roughly 

68,000 acres (presumably by seeding sagebrush into existing 

seeding, or a sagebrush/non-native perennial conversion from 

Annual vegetation), Native Grassland would be reduced by 

roughly 274,000 acres (presumably by seeding sagebrush into 

The BLM understands that budgets could be a limiting factor, as 

well as concerns related to wildland fire. The BLM will implement 

management actions as budget, workforce, and other legally 

binding requirements allow. The analysis for Upland Vegetation

acknowledged there are logistical issues and challenges for 

achieving the identified goals and objectives. The Final EIS 

provided this information in the Methods and Assumptions 

section of the Upland Vegetation analysis in Chapter 4.
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Category Comment Response

existing previously-burned areas with native understory), and 

Native Scrubland would be increased by roughly 470,000 

acres. In total, an increase of about 540,000 acres with 

sagebrush cover would result.

This endeavor would require the net successful seeding to 

sagebrush of 27,000 acres per year, every year, if no other 

fires occurred. However, the average acreage burned over the 

past 21-year period has been 66,000 acres per year (p. 3-52 

Draft RMP/EIS). Therefore, in order to show a net increase in 

sagebrush-dominated landscape, it should be reasonably 

anticipated that an average of 93,000 acres must be 

successfully seeded to sagebrush, each year, for each of the 

20 years of this plan. Assuming a 50% success rate (which is 

itself optimistic with today’s state of the science and art), this 

would mean that about 150,000 acres would need to be 

seeded to sagebrush every year, with 150,000 pounds of 

sagebrush seed purchased, and a financial commitment 

approaching $750,000 per year, just for the seed (at today’s 

price of $4.65). Obviously, if the success rate is lower than 

50%, the endeavor would require higher repeat seeding 

acreage and higher attendant annual costs. While some of the 

necessary funding could be expected to come from fire 

rehabilitation funds, some could not. The Draft RMP/EIS does 

not adequately disclose these logistical issues and challenges, 

nor how they will be addressed in a real-world scenario.

Upland 

Vegetation

With the state of knowledge and technology that presently 

exists, the successful conversion of non-native perennial 

seeding, native perennial grasslands, and annual grasslands to 

native shrubland with native species, on a landscape-scale of 

these dimensions, does not appear to be a reasonably 

attainable and rational expectation.

The BLM is currently working with cooperators to develop 

materials and techniques for vegetation treatments. The 

development of plant materials adapted to sites such as those 

found throughout the planning area is ongoing. The BLM is also 

working with cooperators to develop techniques to convert nonnative vegetation types to native. Techniques and materials for 

restoration will continue to develop over the life of the plan.

Upland 

Vegetation

The Draft RMP/EIS Chapter 3 Upland Vegetation section, p. 3-

12 states: “....vegetation communities were subsequently 

organized into five classes and six sub-classes (Table 3- 5) 

according to national standards (Grossman et al., 1998) with 

the exception of evergreen shrub lands dominated by 

sagebrush. In the planning area, these communities were 

The referenced documents state that 10% sagebrush cover is a

recommended minimum for winter sage-grouse (Connelly et al.,

2004). Sather-Blair and others (2000) guidelines (Table 1) 

indicated that 10-14% sagebrush cover is marginal for sagegrouse nesting. However, they note, "However, if a site had 

suitable habitat conditions for all indicators, except sagebrush 
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defined as having 10% or more shrub cover rather than the 

national standard of more than 25% shrub cover. This was 

done to provide consistency with defined habitat needs 

(Wisdom et al., 2000) and proposed management objectives 

for Greater sage-grouse (sage-grouse).”

This is nearly the same language as used in the Analysis of the 

Management Situation (AMS). Intermountain Range 

Consultants commented on this error within the AMS. The 

Draft RMP/EIS continues the errors of the AMS. Any Final EIS 

and subsequent decision-making should not do so.

Wisdom and others (2000) does not support BLM’s unilateral 

and universal change to Grossman and others (1998) 

protocols. The only reference to sage-grouse cover of 10% is 

found at Wisdom Volume 2, pp. 353 and 354. To the extent 

that BLM took it upon themselves to (erroneously) infer that 

10% sagebrush cover was recommended, such changes 

should have been applicable at most only to sage-grouse 

winter habitat.

canopy cover was only 5%, then this site would be unsuitable 

since sage-grouse must have sagebrush for nesting. Areas with 

10% or greater sagebrush cover can meet sage-grouse needs if 

other indicators are rated suitable." Areas with 10% sagebrush 

cover can provide both nesting and winter habitat. Mapping 

areas with 10% sagebrush cover is appropriate.

Upland 

Vegetation

The Upland Vegetation section of the Draft RMP/EIS does not 

list an understory species for basin big sagebrush or evergreen 

mountain shrub. These are incomplete descriptions of the 

vegetation types.

The Final EIS classified vegetation communities into Vegetation 

Sub-Groups (VSGs). Basin big sagebrush is shown with an 

understory only when it would put it in a different category from 

native shrubland. For example, basin big sagebrush/crested is in 

the Non-Native Understory VSG. 

Upland 

Vegetation

The Upland Vegetation section of the Draft RMP/EIS Table 3.5 

lists “bluegrass” as the understory dominant cover under 

Rabbitbrush and Wyoming Big Sagebrush. However, as noted 

by the Draft RMP/EIS at p. 3-15, bluegrass cover does not 

equate to production. Nor does “cover” equate to vertical cover 

or hiding/nesting cover for sage-grouse and other species; 

however, many such areas mapped as dominated by 

“bluegrass cover” contain perennial species that do provide 

other types of “cover” than “ground cover”. The Draft RMP/EIS 

is wrong in not reporting these distinctions.

The protocol used to determine Vegetation Sub-Groups only 

represented the dominant vegetation and does not reflect 

vertical or hiding/nesting cover values. The Final EIS, Chapter 3 

Upland Vegetation section, lists multiple grass species as 

understory components of Wyoming big sagebrush. 

Upland 

Vegetation

The Upland Vegetation section of the Draft RMP/EIS states: 

“Bluegrass communities include those communities whose 

production is primarily from non-native perennial grasses, but 

whose cover is dominated by bluegrass; these are areas 

The Final EIS revised Chapter 3 Upland Vegetation to clarify 

bluegrass cover and how it relates to areas that contain 

bluegrass and have dominate native and non-native perennial 

grass production. 
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referred to as Sandberg/non-native perennial areas.” Except 

for clarification to the public, relative to the relationship of cover 

to production, it is unclear why this statement is made. 

Upland 

Vegetation

The Draft RMP/EIS alternatives fail to take into account and 

allocate based on removal of non-native perennial grasses to 

reduce coarse dense unpalatable fuel hazards, and to provide 

for recovery of the full component of native vegetation and 

healthy microbiotic crusts required to support sagebrush 

ecosystems and sage-grouse.

The Final EIS analyzed a range of alternatives, which have a 

variety of objectives, goals, allocations, and management 

actions. The Final EIS outlined restoration priorities in the 

Upland Vegetation sections, which delineate the priority of areas 

for restoration. Native vegetation, sage-grouse and other wildlife 

habitat were considerations in prioritizing broad restoration 

areas. Alternative VI (Proposed RMP), management action UVVI-MA-28, would manage biological soil crust to move towards 

site potential.

Upland 

Vegetation

Alternatives should not allocate any annual grass to watershed 

and wildlife. The BLM should act to restore these weed lands.

The Final EIS analyzed a range of alternatives for restoring 

annual communities. Alternative VI (Proposed RMP), Upland 

Vegetation section, proposes restoring 33%-75% of annual 

communities to native shrubland by Vegetation Management 

Area. 

Upland 

Vegetation

Please provide full and detailed analysis of the effects of using 

small statured native plants such as Poa and yarrow vs. use of 

exotics, and place management emphasis on healing and 

recovering microbiotic crusts in interspaces to prevent 

cheatgrass and other annual weed invasions.

In the Final EIS, management actions FE-V-MA-5, UV-V-MA-24, 

and goal UV-V-G-1 restricted vegetation treatments to native 

species with a goal of improving, sustaining, and increasing 

native plant communities. Chapter 4, Upland Vegetation, 

analyzed these management actions.

Upland 

Vegetation

The BLM under all alternatives must consider large-scale 

removal of crested wheatgrass, Siberian wheatgrass and other 

large statured coarse and unpalatable flammable grasses. 

Replace these with small native Poa, yarrow, and the likes. 

The livestock grazing, facility, and all other components of the 

Draft RMP/EIS must mesh with this essential removal of 

disastrous post-fire and other livestock forage-based seedings.

In the Final EIS, the management direction for crested and 

Siberian wheatgrass seedings is in Chapter 2, Upland 

Vegetation, and lumps them as non-native perennials and varies 

by alternative. Alternatives IV, V, and VI would manage for a 

reduction in non-native perennials.

Upland 

Vegetation

The BLM greatly complicates the vegetation section (ES-9 to 

ES-13). The vegetation totals are now different due to the Long 

Butte fire.

The Final EIS included more detailed information on upland 

vegetation in Chapters, 2, 3 and 4 than what the Executive 

Summary of the Draft RMP/EIS provided. Wildland fires are 

continually changing the on-the-ground picture. The Final EIS 

updated vegetation on Map 9 “Existing Vegetation as of 2011” 

and Map 10 “2016 Projected Vegetation”.

Upland 

Vegetation

The BLM must consider an alternative that removes livestock 

to improve lands across the planning area through natural 

plant succession in all native community areas.

In the Final EIS, Alternative V proposed significantly reduced 

grazing. Alternative V, Upland Vegetation section, proposed 

management actions that manage for natural succession.
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Upland 

Vegetation

There is no clarity provided on what will comprise a native plant 

community. Will crested wheatgrass with some sagebrush be 

treated as non-native? Crested wheatgrass and rabbitbrush?

The Final EIS defined native plant communities in the Upland 

Vegetation section of Chapter 3, both in Tables and in the text. 

Sagebrush or rabbitbrush with a crested wheatgrass understory 

was classified as a Non-native Understory Vegetation SubGroup). 

Upland 

Vegetation

The acres in the VSGs (yet another acronym) have already 

changed due to fires.

Fires are continually changing the on the ground picture. The 

Final EIS updated vegetation on Map 9 “Existing Vegetation as 

of 2011” and Map 10 “2016 Projected Vegetation”. 

The BLM has spelled out acronyms more frequently in the Final 

EIS. The Final EIS has also provided a list of acronyms. This 

acronym is also defined in the beginning of the Upland 

Vegetation section in Chapter 2, beginning of the Upland 

Vegetation section in Chapter 3, and in the beginning of the 

Chapter 4 Upland Vegetation section, first bullet under the 

heading for Indicators. 

Upland 

Vegetation

Why in the world would the BLM want to manage for "native 

grassland" of 130,000 acres in Vegetation Management Area 

(VMA) B unless it was giving overwhelming weight to ranchers 

over sage-grouse and other imperiled species habitat needs? 

Or for other vast grassland acreages elsewhere in the other 

VMAs? The goal should be to recover native shrubs in as 

many areas as possible - so if a fire does occur, relative losses 

will not be as great. 

The number of desired acres of native grassland varies by 

alternative. The Final EIS provided the goals and objectives for 

restoring native plant communities in Chapter 2 of the Upland 

Vegetation section. 

Upland 

Vegetation

The BLM has not provided clarity on how it categorized lands 

into Vegetation Sub-Groups. Provide detailed mapping and 

analysis so that the public can understand this process.

Chapter 3 of the Final EIS described how vegetation 

communities of the planning area where classified into 

Vegetation Sub-Groups (VSGs). The Chapter 2 introduction to 

Vegetation Communities, Upland Vegetation section, in the Final 

EIS also provided the criteria used for categorizing the VSGs. 

The Final EIS updated vegetation on Map 9 “Existing Vegetation 

as of 2011” and Map 10 “2016 Projected Vegetation”.

Upland 

Vegetation

The BLM fails to provide adequate detailed mapping, analysis 

and ecological science for understanding the complexities of its 

segregation of the planning area into yet another category the

Vegetation Management Area. This segregation appears to 

have very little to do with conserving and recovering sagebrush 

dependent species with viable and thriving populations.

Chapter 3, Upland Vegetation section, of the Final EIS identified 

why the BLM created Vegetation Management Areas (VMAs). 

Chapter 4, Upland Vegetation section, provided a VMA analysis 

by alternative. The Final EIS mapped VMAs on Map 8 “Potential

Vegetation Communities and Vegetation Management Areas”.
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Category Comment Response

Upland 

Vegetation

The BLM appears to be clinging to some hope that it can 

"conserve" sage-grouse by focusing its efforts in large part on 

only some portion of the land area of Vegetation Management 

Area D - 20% or less of the planning area. Why else would the 

BLM propose goals, objectives, and management actions as it 

does on pp. 2-39 to 2-53 of the Draft RMP/EIS? Why else 

would the BLM propose under its Preferred Alternative to only 

designate a small sagebrush Area of Critical Environmental 

Concern and to allow all manner of development and extractive 

use and despoliation of resources to occur over the great 

majority of the planning area under all alternatives - in defiance 

of all current ecological science? 

Alternative V in the Final EIS analyzed the Sagebrush Sea Area 

of Critical Environmental Concern that would cover 70% of the 

planning area. Chapter 2, Upland Vegetation section, presents 

management actions that propose management for all 

Vegetation Management Area to focus restoration treatments on 

habitat for sage-grouse.

Upland 

Vegetation

At p. 4-144, in the Upland Vegetation section of the Draft 

RMP/EIS, the BLM's preferred alternative would create midseral shrub lands. BLM refers to monitoring microbiotic crusts - 

but this appears to be in relation to reference areas. The BLM 

established no annual required monitoring protocol for 

livestock trampling impacts to microbiotic crusts.

Alternative IV, as analyzed in Chapter 4 of the Final EIS, would 

create a landscape dominated by native vegetation with an 

emphasis on mid-seral shrubland communities through the 

conversion of annual, non-native perennial, and non-native 

understory communities. Monitoring will take place in the 

reference areas as well as throughout the planning area. The 

Final EIS, Chapter 2, Monitoring Implementation and 

Effectiveness of RMP Decisions section states, "Effectiveness 

monitoring would be an annual effort, with a portion of the 

planning area being monitored each year..."

Upland 

Vegetation

In the Upland Vegetation section of the Draft RMP/EIS at 4-

145, we learn than BLM's definitions and predictions of "midseral" are based on categorizing mid-seral as 5-25% 

sagebrush canopy cover. Yet sage-grouse require at a 

minimum 15% cover, and it is increasingly known that 

especially in depleted areas - much higher canopy cover is 

required - as shown by Mono Lake and other recent sagegrouse research.

There is a big difference between 5% and 25% sagebrush 

cover. In the past, the BLM refused to consider 5% sagebrush 

canopy cover as the basis for management as sagebrush 

habitats. Now, when it is to the BLM's advantage to paint it's 

deeply flawed and limited range of alternatives in a favorable 

light - we are suddenly told by the BLM that 5% is "mid-seral" 

sagebrush habitat.

The Final EIS revised Chapter 4 to remove the link between 

seral stage and a percentage of shrub canopy cover. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Upland 

Vegetation

The BLM provides no mandatory measurable standards of 

sagebrush breakage or trampling of seedlings, and no required 

mandatory measurable standards of use to prevent continued 

advances of cheatgrass in understories.

Standards would be identified and measured based on the 

Standards and Guides process during permit renewal.

Upland 

Vegetation

Vegetation Management Area (VMA) A actions continue to 

promote grass seedings. VMA B and VMA C actions (4-146, of 

the Draft RMP/EIS) continue intensive livestock grazing in 

native shrub and grass areas. This fails to recover vast areas 

of native and perennial grasslands.

In the Draft RMP/EIS, p. 4-146 has no discussion on livestock 

grazing. It presented the outcome of an analysis of Alternative IV 

management actions on upland vegetation, which showed an 

increase in native vegetation communities across the planning 

area. 

Upland 

Vegetation

Vegetation Management Area C on p. 4-146 of the Draft 

RMP/EIS proposes "assisted succession" i.e. further 

fragmentation and destruction of shrubs in sagebrush 

communities in order to attempt to get some forb or grass 

growth. Many research projects have shown this is a waste 

and will only lead to further losses. 

Pp. 4-146-147 of the Draft RMP/EIS focuses on the addition of 

shrubs to vegetation communities within Vegetation 

Management Areas (VMAs). The analysis on VMA C in Chapter 

4 (4-146-147, of the Draft RMP/EIS) stated, "assisted succession 

of native shrubland communities by introducing forbs and lateseral grasses to the understory." There is no mention of shrub 

removal, but it does emphasize this would add structural 

complexity. These pages of the Draft RMP/EIS also discussed

treatments to add shrubs into vegetation communities within the 

VMAs and this has been included in the Final EIS. 

Upland 

Vegetation

It is not possible to understand what is supposed to occur 

under various alternatives given statements like Vegetation 

Management Area C for Alternative II, UV-III-MA-9 of the Draft 

RMP/EIS. This part refers to other confusing sections of the 

Draft RMP/EIS such as the confusing "noxious weeds and 

invasive plants, and wild land fire ecology sections. 

The Upland Vegetation section of the Final EIS referred readers 

to the Noxious Weeds and Invasive Plants and Wildland Fire 

Ecology and Management sections because these sections 

contained management actions that resulted in treating 

vegetation.

Upland 

Vegetation

Under Alternative III (p. 2-43, of the Draft RMP/EIS,) it is clear 

protecting forage from burning up is the priority -as it focuses 

first on Vegetation Management Area A. Isn't that the case? 

The Final EIS Summary of Alternatives in Chapter 2 made it 

clear that Alternative III was a fire centric alternative.

Upland 

Vegetation

Alternative III and others also greatly over-emphasize herbicide 

use while continuing to inflict severe livestock grazing 

disturbances on public lands.

The use of herbicide is a tool found in the Noxious Weeds and 

Invasive Plants section of Chapter 2. Herbicide use is not the 

only tool presented for controlling weeds in the Final EIS. 

Upland 

Vegetation

What NEPA coverage does the BLM believe it will have for its 

treatments?

The BLM would complete site-specific NEPA for vegetative 

treatments.

Upland 

Vegetation

UV-IV-MA-5, of the Draft RMP/EIS, allows further destruction 

of sagebrush, even though abundant studies now show this is 

ineffective. 

Management action UV-IV-MA-5 in the Final EIS allowed for the 

introduction of forbs and late-seral grasses, but does not allow 

for removal of sagebrush. 

Upland 

Vegetation

Removal of livestock and allowing required mandatory 

measurable standards of use, significant rest or passive 

recovery is not even a fundamental part of Alternative IV.

The Final EIS analyzed substantially reduced grazing as part of 

Alternative V.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Upland 

Vegetation

There is no emphasis on recovering microbiotic crusts, as 

there are no measurable standards to limit chronic grazing 

disturbance, no goals for percent recovery, and no goals to 

protect remnant better conditions areas. These concerns apply 

to all of the Vegetation Management Areas and alternatives in 

the Draft RMP/EIS.

Chapter 2 of the Final EIS provided management actions for the 

recovery of microbiotic crusts (see UV-IV-MA-31, UV-V-MA-27, 

and UV-VI-MA-28). Chapter 4 analyzed impacts to microbiotic 

crusts in the Upland Vegetation section.

Upland 

Vegetation

Vegetation Management Area B is nearly 2/5 of the land area 

of the planning area, and it is a large portion of the land area is 

essential to recover for a viable and inter-connected population 

of sage-grouse to thrive. There is no current baseline 

identifying areas of annuals, non-native perennials, etc. It is 

impossible to understand where the percentages came from, 

how they may relate to existing infrastructure, etc.

The percentages of vegetation came from calculating acres of 

dominate cover for a vegetation type compared to the acres 

within the Vegetation Management Area. 

Upland 

Vegetation

Alternative IV would even allow native shrublands to be treated 

and sagebrush or rabbitbrush killed to promote grass and forbs 

even though 20% or less of the lands in this Vegetation 

Management Area now are native shrubs. 

Alternative IV in the Draft RMP/EIS allows for the introduction of 

forbs and late-seral grasses to shrublands, but does not discuss

removal of sagebrush.

Upland 

Vegetation

What is the basis for defining shrublands? What canopy cover 

or other values? 

The Final EIS defined shrubland communities in Chapter 3 

Upland Vegetation as communities that have 10% or greater 

shrub cover. 

Upland 

Vegetation

In reference to vegetation management, are whole pastures 

managed based on the "majority" species?

The Final EIS described vegetation management by Vegetation 

Sub-Group in each Vegetation Management Area to meet 

objectives. 

Upland 

Vegetation

As before, the BLM refers to "additional vegetation treatments 

in the Noxious Weeds and Invasive Plants and Wildland Fire 

Ecology and Management sections”. This means vast areas 

could be "treated" with fuel breaks - and more coarse 

unpalatable or non-native species seeded. There is no 

adequate mapping and analysis that shows what all of this 

treatment would really look like, and where it could occur, and 

if it would be meaningful or effective at recovering sagegrouse.

Much of this would occur at project level; Spraying of weeds and 

creating fuel breaks are part of the toolbox in the Final EIS. The 

Vegetation Management Area (VMA) objectives provide a 

general acreage of possible treatments, VMA priorities for 

treatment vary by alternative and the general intent of treatments 

vary by alternative. Map 10 “2016 Projected Vegetation” in the 

Final EIS provided a base for reconnecting or expanding 

sagebrush habitats for management actions in the Upland 

Vegetation sections. The Final EIS does not specify exact areas 

due to future changes in vegetation, which would affect where 

treatments would occur.

Upland 

Vegetation

The maps that are provided (8-10, of the Draft RMP/EIS) 

conflict in many ways. Will "Unvegetated" areas on Map 10 not 

be treated if post-fire seedings fail-as they already appear to 

have with vast areas having minimal sagebrush establishment?

The Final EIS updated vegetation on Map 9 “Existing Vegetation 

as of 2011” and Map 10 “2016 Projected Vegetation” by 

removing recent burn areas from the Unvegetated category. 

“Recent burn” is now its own category on the vegetation maps 

and in the text of the document.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Upland 

Vegetation

In order to allow a reader to even begin to understand what 

any of the Vegetation Management Area (VMA) vegetation 

treatment planning means, the BLM must provide current 

baseline mapping showing where and how it categorizes the 

underlying communities on top of which the VMA is imposed. 

At present - where are all exotic annual grasslands? Perennial 

exotic grasslands? Native "grasslands" (early seral 

communities)? 

The Final EIS described Vegetation Sub-Groups (VSGs) and 

Vegetation Management Areas (VMAs) in the Chapter 2, Upland 

Vegetation section. Chapter 3, Upland Vegetation section under 

the VSG and VMA subsections, explain the categorization 

process in detail. The Final EIS updated vegetation on Map 9 

“Existing Vegetation as of 2011” and Map 10 “2016 Projected 

Vegetation”.

Upland 

Vegetation

Where in Map M-II (Vol. 3, of the Draft RMP/EIS) has 

sagebrush been seeded in the past 10 years? Where are there 

now sagebrush seedlings? How will the BLM effectively 

recover all the areas where sagebrush has been reseeded?

The Final EIS described the current information regarding the 

composition of vegetation in the planning area in the Upland 

Vegetation sections of Chapter 2 and 3. The Final EIS updated 

vegetation on Map 9 “Existing Vegetation as of 2011” and Map 

10 “2016 Projected Vegetation”.

Upland 

Vegetation

In viewing Maps 9 and 10 (Vol. 3, of the Draft RMP/EIS) we are 

greatly concerned that the BLM categorizes lands on Browns 

Bench as non-native understory with an apparently different 

criteria being used than in other areas. We cannot understand 

how the BLM actually decided what was and was not a "nonnative understory" for management purposes, and setting up 

its whole elaborate Vegetation Management Area, Vegetation, 

Fire Regime Condition Class, Forage and other schemes. 

Clearly define this, as so much of the planning area has been 

treated with herbicides, disked, railed, burned and seeded with 

exotics in some composition. It is hard to understand how the 

BLM has separated out these often-blended communities.

Some of the land on Browns Bench was planted to intermediate 

wheatgrass and crested wheatgrass in the 1960’s. The 

vegetation mapping process applied criteria consistently across 

the planning area. Chapter 2 and 3, Upland Vegetation, of the 

Final EIS explained that communities are based on dominant 

cover. 

Upland 

Vegetation

The BLM continues to use large coarse exotics in many 

seedings with some native species thrown in. However, with 

minimal post-fire rest, it is often the exotics that thrive, 

dominate and out-compete natives, especially local ecotype 

natives. The plowing-style seeding techniques often destroy

native species. The BLM must clarify whether seedings where 

sagebrush and some other natives were seeded are located. 

Where in these sagebrush seedings is the plant community 

now is dominated by large exotic grasses - if these are 

considered native or non-native seedings? How are plant 

communities on the ground really delineated and defined -and 

how are they then fed into the morass of Vegetation 

Management Area, Fire Regime Condition Class, Fuel breaks, 

Forage allocations, and the rest of the confusion of the 

The Final EIS, Upland Vegetation sections of Chapter 2 and 3, 

described the current information regarding the composition of 

vegetation in the planning area. The Final EIS updated 

vegetation on Map 9 “Existing Vegetation as of 2011” and Map 

10 “2016 Projected Vegetation”.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

livestock-industry centered Draft RMP/EIS?

Upland 

Vegetation

Why is there no mapping and science-based analysis that 

shows where and how vegetation will be managed and 

restored to conserve sage-grouse habitats and populations 

and other sagebrush-dependent species? Why isn't this the 

foremost part, and the basis of all alternatives, in the Draft 

RMP/EIS?

Why is there no mapping of sage-grouse leks and other 

seasonal habitats in the Draft RMP/EIS? How can a plan to 

conserve sage-grouse be developed without this? This 

mapping and analysis must include adjacent Burley and 

Bruneau lands, as well as the Forest Service and Elko BLM 

lands to the south. What are the cumulative impacts of fire, 

fences, water developments, treatments, energy 

developments, etc. on this landscape that is used by sagegrouse?

The Final EIS added Map 25 “Sage-Grouse Habitat” that 

included the sage-grouse management area and key sagegrouse habitat. More information for restoring sage-grouse 

habitat can be found in Chapter 2, 3 and 4, Upland Vegetation

and Special Status Wildlife. Priorities for vegetation treatments 

varied by alternative for Vegetation Management Areas. The 

Final EIS revised the cumulative impacts analysis area for sagegrouse to include more of the lands surrounding the planning 

area.

Upland 

Vegetation

Alternative IV MA-25, in the Upland Vegetation section of the 

Draft RMP/EIS, (applies to all Vegetation Management Area 

[VMAs]) states "the first priority to improve would be VMA D" is 

not defined. Since the preceding management actions for 

Alternative IV under the VMA category never mention removal 

of livestock - but do indeed specify "treating" shrublands (MA 

23) in grouse habitat", it is clear that "improve" means destroy 

more sagebrush - even though current ecological science 

shows this will not help sage-grouse. Then after more 

sagebrush is destroyed, the BLM would consider treatments to 

expand and connect habitats in VMA C.

Management action UV-IV-MA-25 in the Draft RMP/EIS simply 

identifies priorities to restore sage-grouse habitat; there is no 

mention of removing sagebrush. 

Upland 

Vegetation

UV-IV-MA-31, in the Upland Vegetation section of the Draft 

RMP/EIS, states that the BLM will assess microbiotic crusts 

and manage to move them towards potential by modifying 

grazing. It already is required to do this under the 

Fundamentals of Rangeland Health regulations. There is no 

mandatory trampling or other standard to limit grazing 

disturbance, no milestones, and no concrete information 

provided on how this would be achieved. There is no 

comparison provided on predicted recovery with or without 

grazing, or mapping of the conditions of the crusts from the 

information BLM already has on hand.

UV-IV-MA-31, of the Draft RMP/EIS, does not say that biological 

crusts would be managed to move towards potential by 

modifying grazing. Rather it says, “Assess biological soil crusts 

and manage them to move toward site potential by modifying 

levels and timing of BLM management activities and authorized 

uses during periods when soil crusts are most vulnerable to 

damage.” This statement is more inclusive than just grazing.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Upland 

Vegetation

How depleted are crusts? Where? What season of use may 

cause more significant harm to crusts? Since fire kills or 

reduces crusts, and they can take many years to recover, BLM 

in the much-burned Jarbidge landscape must apply annual 

measurable standards for trampling in upland habitats. This 

can be done with transects. Define the desirable crust 

communities and percent cover, and measurable standards put 

in place to achieve this, the BLM has Technical and other 

references that address crusts. 

The Final EIS updated Chapter 3, Upland Vegetation section, 

with biological crust cover percentages in the planning area and 

what the biological crust cover potential is across the planning 

area. Chapter 4, Upland Vegetation, provided the analysis of the 

different impacts by alternatives on biological crusts.

Upland 

Vegetation

There is no requirement to use only native species in 

restoration. We have communicated with the BLM many times 

with concern about their continued use of exotics mixed in with 

large-sized coarse native cultivars.

The sole use of natives in restoration is included in Alternative V, 

UV-V-MA-24 and FE-V-MA-5.

Upland 

Vegetation

MA-28, in the Upland Vegetation section of the Draft RMP/EIS, 

provides all kinds of excuses for the BLM to never have to use 

native species. There is no reference of any kind emphasizing 

relying on local native ecotypes.

The Final EIS provides a range of alternatives for use of native 

and non-native species for vegetation treatments. Alternative V 

limits upland vegetation treatments to native species only. 

Alternative IV emphasizes use of natives but allows for use of 

non-natives to meet management objectives and goals, and 

Alternative II focuses on using primarily non-native species. 

Alternative VI (Proposed RMP) carries forward the use of native 

and non-native species with an emphasis on native species. 

Upland 

Vegetation

Alternative V, 2-49 to 2-53, of the Draft RMP/EIS, appears to 

rely on the Fire Regime Condition Class contrived "historic" 

vegetation communities. Just what the BLM believes this to be 

in 2011 is not defined.

Fires are continually changing the on the ground picture. The 

Final EIS Chapter 3, Wildland Fire Ecology and Management

section, discussed Fire Regime Condition Class and how it is a 

classification of departure from Historic Fire Regime (HFR). This 

section also provided a crosswalk table that allows the reader to 

go from HFR to Potential Natural Community.

Upland 

Vegetation

Page 2-49 in the Upland Vegetation section of the Draft 

RMP/EIS provides extremely limited management actions that 

are designed to not significantly alter the vast wastelands of 

exotic seedings. Here, the BLM would not even try to restore 

"native grasslands. Vegetation Management Area A (UV-VMA-3).

The emphasis of Alternative V is passive restoration but allowed

for active restoration in the Vegetation Management Areas. 

Other alternatives provided for more active restoration 

management actions. This provided a range of alternatives for 

analysis in the Final EIS.

Upland 

Vegetation

We support Alt V, Vegetation Management Area B, and Goal 

IV, which is to "restore 50% of sagebrush sea annual 

communities". MA-6 "treats 67% of non-native perennials to 

introduce shrubs - and also add to this the following: "remove 

significant acreages of large non-native perennials and re-seed 

with natives to produce natural composition, function, and 

This revision would be active restoration not passive restoration 

as is the emphasis for Alternative V. Other alternatives provided 

for more active restoration management actions. This provided a 

range of alternatives for analysis.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

structure".

Upland 

Vegetation

Upland Vegetation MA-7, of the Draft RMP/EIS, would restore 

much too little native "grassland". Why wouldn't the BLM try to 

restore all of this - as it is the easiest plant community to try to 

recover native biodiversity?

The emphasis of Alternative V was passive restoration but 

allowed for active restoration in the Vegetation Management 

Areas. Other alternatives provided for more active restoration 

management actions. This provided a range of alternatives for 

analysis in the Final EIS.

Upland 

Vegetation

Vegetation Management Area C, p. 2-51, of the Draft 

RMP/EIS. The BLM must specify in detail what managed 

treatments mean in Wilderness Study Areas/Wilderness. What 

would be a "Minimum" of treatment? What would it be?

Any treatments in Wilderness or a Wilderness Study Area (WSA) 

would be consistent with WSA/Wilderness policy. 

Upland 

Vegetation

Page 2-53 of the Draft RMP/EIS in the Upland Vegetation

section, Alt V, All Vegetation Management Areas (VMAs). Why 

in the world, in an EIS that is supposed to conserve sagegrouse, does BLM place as its highest priority of all the 

implementation of vegetation treatments in VMA A "to move 

toward perennial vegetation"?

Chapter 1 of the Final EIS described the Purpose and Need for 

Action. The purpose of the EIS is not to conserve sage-grouse 

as stated. The alternatives provided a range of management 

options, goals, and objects for analysis in the Final EIS. The 

Alternative V Upland Vegetation section focused on passive 

restoration. Vegetation Management Area A is the farthest from 

the desired vegetation condition making it the highest priority for 

active restoration treatments in an alternative that focused on 

passive restoration.

Upland 

Vegetation

Upland Vegetation MA-23 of the Draft RMP/EIS, which limits 

treatments in non-native vegetation communities, is to ensure 

that the crested wheatgrass/Siberian wheatgrass or forage 

kochia weeds cannot be removed.

The Alternative V Upland Vegetation section focused on passive 

restoration. Other alternatives provided for more active 

restoration management actions. The alternatives provided a 

range of management options, goals, and objectives for analysis 

in the Final EIS.

Upland 

Vegetation

The BLM must radically revise this Vegetation Management 

Area (VMA) segregation of the planning area - and get rid of 

the artificial VMA categories that draw arbitrary lines east west 

across the planning area. This is meaningless to sage-grouse 

and other wildlife in the planning area - where research has 

long shown that birds move all over the landscape.

Due to the difference in vegetation response to management 

and disturbance along a north-south gradient, the planning area 

was divided into Vegetation Management Areas (VMAs) based 

on the potential natural community, elevation, and mean annual 

precipitation. The Final EIS, Chapter 3 Upland Vegetation

section, provided more information on VMAs.

Upland 

Vegetation

The BLM constantly downplays the importance of rabbitbrush - 

ignoring that this species provides functions of moderating 

micro-site climate, produces blooms that are alive with native 

insects that are a critical part of biodiversity, and it provides 

winter and other food in a greatly depleted environment.

The Final EIS discussed rabbitbrush in Chapter 3 Upland 

Vegetation section.

Upland 

Vegetation

In the Wildlife section, pp. 3-28 to 3-29, of the Draft RMP/EIS. 

Since aspen communities comprise so little of the planning 

area. Across the west, they are now recognized to be greatly 

threatened by new diseases and climate change. Grazing 

Aspen are present within the planning area but are not a 

dominant component of the vegetation within the planning area. 

The Final EIS analyzed aspen in Chapter 4 Upland Vegetation

and Wildlife sections.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

exacerbates aspen health problems and understory condition. 

Mechanical browsing or trampling injury wounds trees and 

promotes fungal infections. Given all the stresses on aspen, 

and the importance of the avian and other wildlife associated 

with them, removal of livestock grazing stress from all aspen 

communities is critical to ensure they are conserved and 

sustained in the planning area.

Upland 

Vegetation

Map-6 of the Draft RMP/EIS. Wind erosion potential. The BLM 

must provide full analysis of the synergistic effects of loss of 

shrubs that has altered winds near the ground surface in the 

Jarbidge at the micro-site scale. How has this affected fire 

spread? Could an increase in taller shrubs actually serve to 

reduce fire risk - not only through providing windbreaks - but 

also through shading the ground surface and slowing snowmelt 

and runoff, as well as retention of rainwater moisture on site? 

Provide full analysis of how significant native shrub cover may 

ameliorate micro-site/local climate. If sites dry out one, two, 

three or even more weeks later if shrub cover has helped retain 

moisture on-site how might that, help to reduce the time period 

of fire risk? We stress that many devastating fires have 

occurred in July, and with climate change, too, sites are 

predicted to dry out faster. So sound management must 

include providing taller shrub composition to retain moisture 

on-site and limit early-onset of fire season.

The Final EIS analyzed the impacts of wind erosion and the 

introduction and increase in shrub cover at the planning area 

scale in the Chapter 4 Soil Resources and Upland Vegetation

sections. 

Upland 

Vegetation

The BLM must provide mapping showing changes over the 

next 2 years - based on current vegetation recovery in all sagegrouse habitats. This is also necessary to understand what 

areas sagebrush, rabbitbrush or other shrubs will have to be 

replanted, and how and where restoration can best be 

accomplished.

Map 10 “2016 Projected Vegetation” in the Final EIS presented 

in the Final EIS is general and used only for comparison of 

alternatives. Geographic information system data exists that 

illustrates vegetation cover by plant community and with a 

minimum mapping unit of 20 acres. The Final EIS used this data 

in development of the vegetation baseline and maps.

Upland 

Vegetation

Why is there not more detailed information and mapping of the 

ecological site inventory in the Draft RMP/EIS?

The Final EIS used the data collected in the ecological site 

inventory effort to establish the existing conditions described in 

Chapter 3 Upland Vegetation and depicted on Map 9 “Existing 

Vegetation as of 2011” and Map 10 “2016 Projected Vegetation”.

Upland 

Vegetation

The BLM must provide detailed mapping and analysis that 

shows the current sagebrush and other vegetation 

communities, and depict key habitat.

The Final EIS updated vegetation on Map 9 “Existing Vegetation 

as of 2011” and Map 10 “2016 Projected Vegetation”.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Upland

Vegetation

Please provide mapping and analysis of the land area that 

must be recovered to provide viable populations, disturbance 

reduced, and protection measures taken to comply with the 

BLM conservation plan for sage-grouse.

The BLM planning regulations do not require analysis for viable 

populations. Best management practices would be applied for 

specific projects and include consideration of the site. The Final 

EIS updated vegetation on Map 9 “Existing Vegetation as of 

2011” and Map 10 “2016 Projected Vegetation”.

Upland 

Vegetation

Identify a full analysis of the location, species seeded, and year 

seeded, and current composition of all Fuel breaks.

Seedings, fuel breaks and other vegetation treatment data 

helped in developing the vegetation map and are reflected in 

Map 10 “2016 Projected Vegetation”.

Upland 

Vegetation

The BLM should focus fuels projects on using small statured 

native species and reductions in the large unpalatable exotic 

grass monocultures.

This approach was analyzed in the Final EIS as part of 

Alternative V in the Wildland Fire Ecology and Management

section. This alternative would only allow for the use of native 

species and would work on reducing the fuel continuity of nonnative perennial communities.

Upland 

Vegetation

We have attached a file based on 2006-2007 agency 

cheatgrass mapping.

The Final EIS did not use the attached map of 2006-2007 annual 

grass. Vegetation mapping in the planning area used field 

observations, field cover data, and National Agricultural Imagery 

Program imagery. The Final EIS updated vegetation maps and 

incorporated fires, seedings, and fuel treatment data through 

2011. See Map 9 “Existing Vegetation as of 2011” and Map 10 

"2016 Projected Vegetation". Cheatgrass is included in the 

Annual Vegetation Sub-Group on the maps.

Upland 

Vegetation

Our review of the Draft RMP/EIS alternatives and analysis 

shows the BLM does not adequately map and include 

rabbitbrush and sagebrush‐rabbitbrush communities in 

displaying sage‐grouse habitat. Nor does it act to protect and 

conserve these communities in many areas.

Rabbitbrush and sagebrush communities are predominantly 

mapped within the Native Shrubland Vegetation Sub-Group 

(VSG), but also in the Annual and Non-Native Understory VSGs 

(see Chapter 3 for a full description of VSGs). Management 

actions have been included in the Final EIS to protect sagegrouse habitat. 

Upland 

Vegetation

We incorporate by reference into these comments all the BLM 

post-fire seeding, grazing, facility, and wildlife habitat related 

actions NEPA documents from 1998 to the present. It is 

essential that the full information and analysis of past actions 

all fences or facilities that were built following fires and rehab 

must be identified, and a range of alternatives must be 

developed that target these for removal. The BLM must 

similarly provide a detailed accounting of all post-fire 

rehabilitation actions it has taken. Seedings, species, location, 

etc. and show where it has told the public it would recover 

sagebrush.

The requested background information comprises the Affected 

Environment as described in Chapter 3 Upland Vegetation and 

Livestock Grazing sections of the Final EIS. The Final EIS 

analyzed the cumulative impacts vegetation treatments in the 

Upland Vegetation, Wildlife, and Special Status Species sections 

in Chapter 4.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Visual 

Resource 

Management

NEPA requires that the BLM takes measures to “assure for all 

Americans . . . Aesthetically pleasing surroundings.” In 

addition, the Federal Land Policy and Management Act of 1976

directs the agency to manage the public lands in a manner that 

will protect scenic values. BLM should meet this requirement 

by protecting more areas as Visual Resource Management 

(VRM) II, such as Areas of Critical Environmental Concern and 

recreation management areas. Furthermore, BLM should 

manage non-Wilderness Study Area lands with wilderness 

characteristics as VRM I.

BLM should ensure visual resources are protected and 

appropriately managed in the Draft RMP/EIS by designating 

special management areas and other scenic areas as VRM I 

and II.

The Final EIS analyzed a reasonable range of alternatives 

addressing Visual Resource Management classes.

Visual 

Resource 

Management

Explain how the BLM concluded to identify the same area as 

Visual Resource Management (VRM) Class II-IV in the various 

alternatives. The BLM should provide an explanation.

VRM Management with regard to wind energy development is 

discussed both in BLM Instruction Memorandum 2009-043 and 

in the best management practices that have already been 

incorporated by amendment of the existing Jarbidge RMP. The 

Instruction Memorandum requires BLM to consider 

management class designations in areas of high wind energy 

resource potential. The Instruction Memorandum. notes that 

the goal of the VRM program is to apply basic principles of 

design of wind energy projects at the site-specific project level 

to mitigate or minimize visual resource impacts and meet VRM 

objectives established in the land use plan. The I.M. instructs 

BLM staff to perform view-shed analyses in high wind energy 

areas to, among other things, “avoid unwarranted exclusion 

and avoidance designations.” Finally, the Instruction 

Memorandum instructs BLM to work collaboratively with wind 

energy operators to “seek creative ways to provide for 

renewable energy development while protecting visual 

resource values on the public lands.”

Visual Resource Management (VRM) class designation varies 

by alternative based on the alternative theme. The Final EIS 

analyzed a reasonable range of alternatives addressing VRM 

classes.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Visual 

Resource 

Management

The best management practices incorporated into the Jarbidge 

RMP for wind energy development address visual resources as 

part of the preparation of the Plan of Development, during 

construction and during operations. Change the Draft RMP/EIS 

to recognize the incorporation of the existing visual resource 

protections imposed upon wind energy development projects in 

the planning area.

The Final EIS incorporated Visual Resource Management (VRM)

classes into the Chapter 4 analysis of wind energy. VRM classes 

I and II were considered unavailable for wind energy 

development. 

Visual 

Resource 

Management

Designate the Herd Management Area as a Visual Resource 

Management (VRM) Class 2 and not a VRM Class 4.

The Final EIS describes impacts from land use authorizations on 

the Herd Management Area (HMA) in the Wild Horse section of 

Chapter 4. The right-of-way avoidance area includes 64,000 

acres of the 94,987 acres in the HMA.

Visual 

Resource 

Management

On pp. 2-113 to 2-118 of the Draft RMP/EIS, under Visual 

Resources, identify which segment of Salmon Falls Creek you 

are referring for all alternatives. We agree with the Visual 

Resource Management - IV classifications as specified in Map 

35 of the Draft RMP/EIS, No Action Alternative and Map 37, 

Alterative II. I cannot tell which segments you are referring on 

pp. 2-113 to 2-118.

The Final EIS provides maps of Visual Resource Management 

(VRM) classes for each alternative (Maps 41 to 48). VRM 

classes do not apply to State or private land. All Alternatives 

would manage Salmon Falls Creek Wilderness Study Area from 

Salmon Falls Dam to Lily Grade as VRM Class I. Alternative VI 

(Proposed RMP) would manage a 1-mile wide right-of-way 

(ROW) corridor centered on Lilly Grade as VRM Class III. All 

action Alternatives (Alternative VI from the ROW corridor) would 

manage the Salmon Falls Creek Wild and Scenic River corridor 

from Lilly Grade to Balanced Rock Park as VRM I, except a 1-

mile ROW corridor in Alternative III which would be managed as 

VRM III . All action Alternatives would manage Balanced Rock 

Park to Balanced Rock road as VRM Class III. For VRM classes 

described above (i.e. Salmon Falls Dam to Balanced Rock road), 

the VRM classes extend west approximately 0.25 mile from the 

center of the stream channel or approximately 0.1 mile beyond 

the canyon rim. All action Alternatives would manage Balanced 

Rock road to 2 miles north of Balanced Rock road as VRM Class 

IV. Alternatives I, III-V would manage approximately 2 miles 

north of Balanced Rock road to 0.5 miles from the Snake River 

as VRM Class III. Alternative II would manage approximately 2 

miles North of Balanced Rock road to 0.5 miles from the Snake 

River as VRM Class IV. 

Visual 

Resource 

Management

On p. 2-117 of the Draft RMP/EIS, VR-IV-A-3, please list what 

segment of Salmon Falls Creek (from Toana Road protective 

corridor and Salmon Falls Creek). 

The Final EIS included maps of Visual Resource Management 

(VRM) classes for all alternatives (Maps 41 to 48). VRM Class III 

in Alternative IV-A extends from the Toana Freight Road 

protective corridor to approximately 0.1 mile beyond the Salmon 

Falls Creek canyon rim, excluding the managed Lands with 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Wilderness Characteristics which will be VRM Class II. VRM 

classes do not apply to State or private land. 

Visual 

Resource 

Management

Management action IV-A designates Visual Resource 

Management (VRM) Class 1 areas under Alternative IV. Check 

the acres and areas designated with the Bruneau-Jarbidge 

Wilderness boundary. Wilderness requires a VRM Class I 

designation.

The Final EIS revised all alternative boundaries to include the 

Bruneau-Jarbidge Rivers Wilderness and to manage it as Visual 

Resource Management Class I.

Visual 

Resource 

Management

The majority of the Resource Advisory Council (RAC) voted in 

favor of the least restrictive visual resource allocations in 

Alternative II over more restrictive allocations in Alternative IV. 

The minority of the RAC voted in favor of Alternative IV over 

Alternative II. Wind energy, oil/gas, geothermal energy, 

transmission lines, and communication sites must be built 

where either the resource exists or where they are needed. 

Selection of Alternative II for visual resources would allow 

these resources to be located where the resource and needs 

exists, while providing a cost effective means of accomplishing 

the task. 

The Final EIS analyzed a reasonable range of alternatives 

addressing visual resource allocations in Chapter 2, Visual 

Resources. 

Visual 

Resource 

Management

Visual resource allocation in Alternative IV could force utilities 

to site large transmission lines on private property. The NEPA 

process failed to study these impacts adequately enough to 

revise the Draft RMP/EIS.

The Final EIS revised the analysis of visual resources in Chapter 

4 to include a discussion on the potential for Visual Resource 

Management classes on BLM-managed land to impact adjacent 

private land.

Visual 

Resource 

Management

The Draft RMP/EIS on p. 3-61 describes three steps in 

Ratings: A, B, and C. From BLM's verbal description of this at 

the RMP meeting, it appears the BLM interjected a strong bias 

against shrub steppe habitats. The methodology that BLM 

described using has inherent bias against sage-steppe. BLM 

claims it relied on adjacent scenery, and scarcity, and looked at 

modification. BLM will not be able to conserve and recover 

sage-grouse habitat under Visual Resource Management 

(VRM) III and VRM IV designations/allocations. BLM ignores 

the fact it can use VRM to limit any further intrusions, and to 

aid in restoration and sage-grouse conservation efforts. It can 

use VRM to manage lands to conserve sage-grouse. 

BLM used the Visual Resource Inventory (VRI) process in 

assigning VRI classes (BLM Manual Section H-8410-1; Draft 

RMP/EIS 3.2.13; BLM Visual Inventory Technical Report 2008a 

(updated 2013)). After overlaying scenic quality, sensitivity and 

distance zone maps and applying the criteria for assigning VRI 

Classes, 71,000 BLM-managed acres were identified as VRI 

class I, 90,000 acres as VRI class II, 51,000 as VRI class III, and 

1,159,000 acres as VRI class IV. Map 40 “Visual Resource 

Inventory Classes” displays the results of the VRI. The Final EIS 

analyzed a reasonable range of alternatives addressing Visual 

Resource Management (VRM) classes. VRM is not the only way 

in which BLM can manage for sage-grouse conservation and 

habitat restoration. Management actions specific to sage-grouse 

conservation are contained in the following sections: Upland 

Vegetation, Riparian and Wetlands, Wildlife, Special Status

Species, Wildland Fire Ecology and Management, Livestock 

Grazing, Transportation and Travel, Land Use Authorizations,
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

and Minerals.

Visual 

Resource 

Management

The first sentence in the RMP Visual discussion states: "the 

Jarbidge ...is known for its unique geology of broad, gently 

rolling plateau lands with deeply incised rivers, which provide a 

variety of scenic values. Yet in the Visual Resource 

Management (VRM) process, BLM discarded the visual 

qualities of the vast rolling plateau areas.

The Draft RMP/EIS admits that BLM has a responsibility that 

scenic values are considered, before allowing uses that may 

have adverse impacts. BLM got around this by just writing off 

the scenic values over vast areas under all alternatives so that 

it would not have to protect the lands from more grazing 

industrialization, energy developments, and other intrusions.

Since the broad rolling plateau over such a vast area is part of 

the unique landscape of the planning area, how can BLM then 

turn around and claim it has no visual appeal, and proceed to 

impose VRM III and IV over vast areas? Redo the visual 

analysis and take into account the context, as well as the high 

sensitivity of wide-open sagebrush landscapes to visual 

intrusions.

BLM used the Visual Resource Inventory (VRI) process in 

assigning VRI classes (BLM Manual Section H-8410-1; Draft 

RMP/EIS 3.2.13; BLM Visual Inventory Technical Report 2008a 

(updated 2013)). After overlaying scenic quality, sensitivity and 

distance zone maps and applying the criteria for assigning VRI 

Classes, 71,000 BLM-managed acres were identified as VRI 

class I, 90,000 acres as VRI class II, 51,000 as VRI class III, and 

1,159,000 acres as VRI class IV. Map 40 “Visual Resource 

Inventory Classes” displays the results of the VRI. The Final EIS 

analyzed a reasonable range of alternatives addressing Visual 

Resource Management classes. 

Visual 

Resource 

Management

The discussion of Visual Resource Inventory (VRI) and Visual 

Resource Management (VRM) is murky. BLM assigns VRI I to 

lands where a "management decision has been made". There 

could be degraded lands, but because a decision had been 

made, it receives high priority, even though the visual quality is 

not different from immediately adjacent lands? This makes no 

sense. How does a management decision per se change the 

Visual Quality, from Class I to Class III? This all just proves the 

point that VRM is used by BLM to manage to protect lands, or 

in the case of this Draft RMP/EIS to allow all manner of 

industrial development to occur over vast areas (as in 

Alternative IV and even more so in Alternative V with vast 

areas Zoned III and IV).

Visual Resource Inventory Class I is assigned to those areas 

where a management decision has been made previously to 

maintain a natural landscape. This includes areas such as 

national wilderness areas, the wild section of national wild and 

scenic rivers, and other congressionally and administratively 

designated areas where decisions have been made to preserve 

a natural landscape (BLM Manual Section H-8410-1). The Final 

EIS analyzed a reasonable range of alternatives addressing 

Visual Resource Management classes.

Visual 

Resource 

Management

BLM's shortchanging of the visual setting of the planning area 

enables widespread continued destruction of visual setting and 

further severe habitat intrusions and reductions in recreational 

activities.

The Final EIS analyzed a reasonable range of alternatives 

addressing Visual Resource Management classes.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Visual 

Resource 

Management

BLM can use Visual Resource Management to manage lands. 

BLM has not even provided the public with its Visual Report.

The Final EIS cites the Visual Inventory Technical Report (2008 

(updated 2013)) and the public can obtain it upon request.

Visual 

Resource 

Management

There is no possible rationale for BLM to designate Visual 

Resource Management (VRM) IV (maximum disturbance 

allowed) over such a vast area. The VRM actions would allow 

industrial development, mining, energy or other development to 

occur across nearly the entire planning area, including the very 

lands that elsewhere are supposed to be "restored" for 

conservation of rare and declining species.

The Final EIS analyzed a reasonable range of alternatives 

addressing Visual Resource Management (VRM) classes. Any 

development would have to comply with all allocations and 

management actions presented in the RMP, not just VRM.

Visual 

Resource 

Management

Why is there no mapping of the No Action Alternative Visual 

Resource Management? 

Mapping of Visual Resource Management for the No Action 

Alternative was included in the Draft RMP/EIS on Map 35. A 

similar map was also included in the Final EIS, Map 41. 

Visual 

Resource 

Management

Do Visual Resource Management I and II categories under the 

current RMP mean that development would be constrained in 

the China Mountain area?

A separate EIS addressing the effects related to the China 

Mountain Wind Energy Project will occur after the completion of 

the Idaho/Southwest Montana Sub-regional Sage-Grouse Plan 

Amendments and the Jarbidge RMP. 

Water 

Resources

Water quality standards are typically composed of numeric 

standards, narrative standards, designated uses, and/or an 

anti-degradation policy. The Draft Plan, however, only reflects 

numeric standards as “water quality standards.” That narrow 

view is incorrect. The Supreme Court held in Public Utility 

District No. 1 of Jefferson County v. Washington Department of 

Ecology, 511 U.S. 700 (1994), that all components of water 

quality standards are enforceable limits. Consequently, the 

Draft RMP/EIS is required to outline not only the ways in which 

BLM will meet or exceed the numeric standards, but also how it 

will manage its lands to ensure compliance with the State’s 

designated uses, narrative standards, and anti-degradation 

policy.

Adopting this legally sanctioned view of water quality standards 

is important. For example, a typical designated use for a 

stream might state that the stream is “protected for cold-water 

species of game fish and other cold-water aquatic life, 

including necessary organisms in their food chain.” Designated 

uses of this sort encompass a far more holistic, ecosystembased view than focusing on, say, the concentration of 

ammonia in the stream (a numeric standard). Consequently, 

The comment refers to the Draft RMP/EIS, Chapter 3 Water 

Resources section which described the baseline water resource 

conditions within the planning area. BLM revised the Chapter 3 

Water Resources section in the Final EIS to include a more 

detailed description of the Idaho water quality standards 

(numeric, narrative and anti-degradation) and the role of the 

Environmental Protection Agency, Idaho Department of 

Environmental Quality (DEQ), and Nevada Division of 

Environmental Protection (NDEP) in developing and enforcing 

water quality standards that protect beneficial uses such as 

drinking water, cold-water fisheries, industrial water supply, 

recreation, and agricultural water supply. 

The goals, objectives and management actions to achieve water 

quality standard are included in Alternative VI (Proposed RMP) 

in the Chapter 2 sections for Water Resource, Fish, Riparian 

Areas and Wetlands, and Special Status Species. All of these 

aquatic resource sections include the use of the guidance in the 

Aquatic and Riparian Management Strategy (ARMS) to improve 

riparian condition, in stream conditions and water quality. 

Implementing the guidance in the ARMS would be consistent 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

the Draft RMP/EIS should provide that designated uses be fully 

achieved, and if they are not, require prompt management 

changes even if numeric standards are otherwise being met. 

Similarly, the BLM should develop and commit to an active 

monitoring protocol to meet numeric standards, and develop 

their monitoring protocol to take into account narrative 

standards as well.

with the attainment of the State of Idaho and State of Nevada’s 

designated uses, narrative standards, and anti-degradation 

policy for water quality. In the Chapter 2, Alternative VI Water 

Resources section, WR-CA-MA-7 through WR-CA-MA-9 

included direction to coordinate with Idaho Department of Water 

Resources, DEQ, and NDEP to comply with State water quality 

standards.

Water 

Resources

In addition to the anti-degradation policy’s protections for 

waters that are meeting water quality standards, where State 

water quality standards have not been achieved despite 

implementation of point source pollution controls, section 

303(d) of the Clean Water Act requires a State to develop a list 

of those still-impaired waters, with a priority ranking, and to set 

Total Maximum Daily Load of pollutants for the stream “at a 

level necessary to implement the applicable water quality 

standards. . . .” 33 U.S.C. §1313(d) (1) (C).

Consequently, to the extent waters within the BLM’s jurisdiction 

have been identified as water quality impaired segments, or 

contribute stream flow to such segments, the Draft RMP/EIS 

should include affirmative steps toward reducing that impaired 

status. If any specific load allocation has been made by the 

State for activities on BLM-managed lands, the BLM should 

ensure that all activities are in compliance.

The Final EIS, Chapter 2, Alternative VI (Proposed RMP) Water 

Resources section included goals, objectives and management 

actions to meet State water quality standards (WR-CA-MA-1 

through 4; WR-CA-MA-7 through 10). This direction included 

working closely with Idaho Department of Water Resources, 

Idaho Department of Environmental Quality (DEQ), and Nevada 

Division of Environmental Protection (NDEP) to identify 

opportunities to improve water quality and to be consistent with 

water quality restoration and Total Daily Maximum Loads. The 

specific steps that would be taken to achieve water quality 

standards would be determined at the project level and would be 

based on site-specific conditions and in coordination with DEQ 

and NDEP.

Water 

Resources

The Proposed Plan should also ensure full compliance with 

sections 401 and 404 of the Clean Water Act. 

Section 401 requires State certification of compliance with 

State water quality standards prior to authorization of certain 

actions on BLM lands (33 U.S.C. § 1341). Section 404 requires 

permits to discharge dredged or fill material into navigable 

waters, and BLM, through the Draft RMP/EIS, should assist the 

Environmental Protection Agency and US Army Corps of 

Engineers with implementation and enforcement of this 

requirement, which, of course, is a powerful means for the 

protection of wetlands. See 33 U.S.C. § 1344.

The Final EIS, Chapter 2, Alternative VI (Proposed RMP) Water 

Resources section included goals, objectives and management 

actions to meet State water quality standards and attain 

designated beneficial uses. The result of this direction is full 

compliance with Section 401 and 404 of the Clean Water Act. In 

the Final EIS, Appendix D: Aquatic and Riparian Management 

Strategy included guidance for applying the Idaho Stream 

Channel Alteration Rules (IDWR, 1993) to actions involving 

construction activities within the high water lines of streams in 

the planning area. This guidance included obtaining Section 404 

Permits from the US Army Corps of Engineers when required. 

Water 

Resources

The Draft RMP/EIS appears to be missing crucial baseline data 

necessary for making planning decisions for water resources. 

For instance, BLM States that fish tissue mercury levels are not 

The Final EIS revised the Chapter 3 Water Resources section 

under Impounded Waters and Reservoirs to include information 

on mercury contamination in the Salmon Falls Creek Reservoir 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

published for Salmon Falls Creek Reservoir. The mercury level 

for fish tissue in Salmon Falls Creek Reservoir was published 

in Idaho Department of Environmental Quality’s 2008 “Arsenic, 

Mercury, and Selenium in Fish Tissue from Idaho Lakes and 

Reservoirs: A Statewide Assessment” (Essig and Kosterman, 

2008) and in the Salmon Falls Creek Subbasin Assessment 

and Total Maximum Daily Loads (DEQ, 2007). The sub basin 

assessment states that for Salmon Falls Creek Reservoir fish 

tissues “to achieve the water quality standard, mercury levels 

would need to be reduced by 69 percent.”

and the source of the contamination, which is not within the 

planning area. The source for this information is Essig and 

Kosterman (2008). Actions to reduce airborne sources of 

mercury contamination to Salmon Falls Creek reservoir are 

beyond the scope of the Final EIS.

Water 

Resources

The BLM states in the 2007 Analysis of the Management 

Situation that it has no data on nutrient levels in the Snake 

River or Bruneau River watersheds (pp. 43 and 45), even 

though several streams are water quality limited in these 

watersheds for nutrients. Without baseline data on nutrients, 

BLM cannot effectively manage for special status species such 

as the Snake River white sturgeon, which is sensitive to 

nutrient levels (Draft RMP/EIS p. 3-41).

The Final EIS revised the Chapter 3 Water Resources section to 

include links to the most current information for water quality 

impaired streams within the planning area. Every two years 

Idaho Department of Environmental Quality (DEQ) and Nevada 

Division of Environmental Protection (NDEP) update their lists of 

water quality impaired streams. The Final EIS provided links to 

the most current water quality information available, as displayed 

on the DEQ and NDEP web.

Water 

Resources

We urge the BLM to provide a list of best management 

practices (BMPs) for riparian areas, make these BMPs 

mandatory, and make the No Surface Occupancy stipulation 

next to perennial streams non-waivable.

The Final EIS included best management practices (BMPs) for 

all resources and resource uses within the planning area 

(Appendix B: Best Management Practices, Design Features, and 

Operating Procedures). The use of specific BMPs would be 

determined on site and project-specific basis. In the Final EIS, 

management actions for leasable minerals activities in the 

Riparian Conservation Areas (RCAs) containing special status 

species are provided in Chapter 2, Leasable Minerals section, 

management actions LE-CA-MA-2, LE-CA-MA-3, LE-CA-MA-4, 

LE-CA-MA-7, LE-CA-MA-8 and LE-VI-MA-1. For salable 

minerals, requirements for actions in RCAs with special status 

species were included in SA-CA-MA-1 through SA-CA-MA-7. 

Direction for management activities and authorized uses is also 

provided under Riparian Areas and Wetlands, RI-CA-MA-8, 

which identifies the modification of existing management and 

activities and authorized uses in RCAs to attain proper 

functioning condition and ensure that habitat conditions of 

streams, riparian areas, and wetlands are moving toward or 

achieving the goals and objectives for riparian areas and 

wetlands. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Water 

Resources

Analyze the impacts to water resources from commercial and 

recreational uses.

The Chapter 4 Alternative VI (Proposed RMP) Water Resources

section included an analysis of impacts from a variety of land 

uses (Recreation, Transportation and Travel, and Land Use 

Authorizations) on water resources. The comment did not 

provide the BLM with enough specific information on how to 

address the portion of the comment regarding commercial uses. 

Water 

Resources

The BLM needs to establish baseline water quality conditions, 

and develop a monitoring system and enforcement protocol 

which not only considers numeric standards, but also meets or 

exceed narrative standards, designated uses, and antidegradation rules.

The Final EIS revised the Chapter 3 Water Resources section to 

include a more detailed description of the Idaho water quality 

standards (numeric, narrative and anti-degradation) and the role 

of the Environmental Protection Agency, Idaho Department of 

Environmental Quality (DEQ), and Nevada Division of 

Environmental Protection (NDEP) in developing and enforcing 

water quality standards that protect designated beneficial uses 

such as drinking water, cold-water fisheries, industrial water 

supply, recreation, and agricultural water supply. The Chapter 2, 

Alternative VI (Proposed RMP) Water Resources section 

included direction to coordinate with Idaho Department of Water 

Resources, DEQ, and NDEP in compliance with State water 

quality standards in WR-CA-MA-7 through WR-CA-MA-9.

Water 

Resources

In the Draft RMP/EIS, Table 4-62 (page 4-125).purports to 

provide a Summary of “Impacts to Proper Functioning 

Condition (PFC) rating” for water quality impaired Listed 

Streams By Alternative.” The values (miles of stream) appear 

to be related only to the acres assigned to various resource 

use designations. This approach is predicated on assumptions 

about the potential risk to stream PFC rating of the various 

resource use designations. However, there is no valid basis is 

for assuming a risk solely related to resource use, especially 

when consideration is given to management of permitted uses 

to maintain or achieve stream PFC. 

Assume that management related to resource use that is 

intended to achieve improved PFC ratings would be largely 

successful, thus removing the purported risk. Delete this table, 

as it provides no useful information relative to the true and 

relative environmental consequence of the alternatives. (See 

also Table 4- 287. Summary of Impacts to Livestock Grazing 

and Table 4- 363 Comparison of Alternative by Livestock 

Grazing Indicators).

In the Draft RMP/EIS, Chapter 4, Water Resources, Table 4-62 

included a summary of predicted impacts to proper functioning 

condition (PFC) ratings for water quality impaired streams based 

on the acres allocated for various public land uses. The table 

provided a general comparison of predicted impacts across all of 

the alternatives so the differences were easy to identify. The 

same table was included in the Final EIS in Chapter 4, Water 

Resources, Table 4-77. 

The Final EIS included the assumption that allocating an area to 

a specific resource would affect the resources within the 

allocation area. For example, an authorized use within a riparian 

area would result in some level of risk to PFC ratings. Authorized 

livestock grazing in pasture with riparian areas, could not 

eliminate all potential risks to the PFC rating. Table 4- 287 

(Chapter 4, Livestock Grazing, Summary of Impacts to Livestock 

Grazing) and Table 4- 363 (Chapter 4, Social and Economic 

Features, Comparison of Alternatives by Livestock Grazing 

Indicators), were not included in the Final EIS.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Water 

Resources

The Owyhee County Natural Resources Plan has established 

the Idaho Agricultural Pollution Abatement Plan as the 

standard for management of water quality resources in 

Owyhee County Natural Resources Plan (Ch. 4).The process 

for addressing water quality impaired streams involves basin or 

sub-basin assessment for achievement of assigned beneficial 

uses by waters within the basin or sub-basin. 

The next step is the development of a Total Maximum Daily 

Load (TMDL) for pollutant input limits. Upon completion of the 

sub-basin assessment and TMDL, each area develops an 

implementation plan including the management actions 

expected to achieve the TMDL. The Ag Plan (adaptive 

management) management identified, implemented, monitored 

and modified as necessary. This process has been the 

standard in Idaho and Owyhee County for many years and 

must continue as the one comprehensive approach to water 

quality management throughout the County. 

While some of the science and data developed through the 

Interior Columbia Basin Ecosystem Management Plan 

(ICBEMP) may be useful on a basin wide scale, the 

management strategies and actions such as the Aquatic and 

Riparian Management Strategy (ARMS) cannot be 

implemented in the absence of a Record of Decision. The 

application of the ARMS through the Land Use Planning 

process does not conform to the NEPA requirements for 

coordination with Owyhee County (40 C.F.R. § 1502.16 and 

1502.2) specifically in regard to the ICBEMP and its 

component strategy (ARMS). Nor does this approach comply 

with requirements of the Federal Land Management Planning 

Act for coordination and consistency with local plans and 

policies of Owyhee County. The ARMS as presented in 

Appendix D consists of 37 pages and is essentially a decision 

document with regard to management strategies and actions 

therein to apply through the Draft RMP/EIS. As such, this 

document is subject to a public review process and an EIS as 

required by NEPA before implementation. Furthermore, the 

ARMS strategy has never been presented to the County for 

In the Final EIS, the Water Resources sections in Chapter 2 and 

Chapter 3 were revised to include a more detailed description of 

the Idaho and Nevada water quality standards (numeric, 

narrative and anti-degradation) and the role of the Environmental 

Protection Agency, Idaho Department of Environmental Quality 

(DEQ), and Nevada Division of Environmental Quality (NDEP) in 

developing and enforcing water quality standards that protect 

beneficial uses such as drinking water, cold-water fisheries, 

industrial water supply, recreation, and agricultural water supply. 

Information on coordination with DEQ and NDEP to identify 

opportunities to mitigate impacts to water quality (WR-CA-MA-7) 

and during the Total Maximum Daily Load development process 

(WR-CA-MA-8) was included in the Final EIS. 

The Final EIS, which included the Aquatic and Riparian 

Management Strategy (ARMS; Appendix D), conforms with BLM 

direction to use the Interior Columbia Basin Ecosystem 

Management Plan Strategy and Framework and other available 

science to improve riparian condition. This Final EIS is the NEPA 

analysis of the ARMS and the forthcoming Record of Decision

(ROD) will be the decision document. The ARMS incorporates 

the Inland Native Fish Strategy guidance which has a completed 

ROD and amended the 1987 Jarbidge RMP.

In December, 2010, Owyhee County provided the BLM with

written comments on the Draft RMP/EIS, which included 

comments on the ARMS, as part of their review for consistency 

with the Owyhee County Resource Management Plan (ORMP). 

The BLM met with representatives of Owyhee County on 

February 14, 2011 in Murphy, Idaho to discuss the County’s 

comments on the ARMS in detail. Owyhee County provided the 

BLM with additional comments on the ARMS on March 6, 2011.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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consideration under their coordination agreement.

Water 

Resources

Another area of concern for the Twin Falls County Soil and 

Water Conservation District and the Bruneau River Soil and 

Water Conservation District would include 

easements/diversions for water development, both irrigation 

and livestock. Many of the Soil and Water Conservation 

Districts’ efforts relating to improvements for both water quality 

and quantity are related to the conversion of irrigated acres 

from furrow irrigation to sprinkler and off stream livestock water 

development. The ability of BLM to provide sufficient flexibility 

and cooperation will be crucial to the implementation of many 

future resource conservation projects.

In the Final EIS, the Chapter 2 Alternative VI (Proposed RMP) 

Water Resources section would not preclude easements or 

diversions for water development projects. New projects or 

modifications to existing water developments would have a site 

analysis to assure project objectives can be met without 

preventing the attainment of Federal and State water quality 

standards. Actions related to irrigation uses and modifications on 

private lands are beyond the scope of this planning effort.

Water 

Resources

Use of the Aquatic and Riparian Management Strategy 

(ARMS) is not appropriate because the goals and objectives 

for water resources relate to Federal and State water quality 

standards as called for in the Clean Water Act and not to the 

riparian and aquatic conservation and restoration guidance 

contained in the ARMS (Appendix D).

To comply with current BLM policy, the Aquatic and Riparian 

Management Strategy (ARMS) was included in the Final EIS 

(Appendix D). The ARMS supports the goals, objectives and 

management actions in Chapter 2, Water Resources and 

provided a framework for meeting Federal and State water 

quality standards as called for in the Clean Water Act. Appendix 

D, Figure D-1 displayed the relationship between riparian 

functional condition, aquatic habitat condition and State water 

quality standards. In the Final EIS, Alternative VI (Proposed 

RMP) used the ARMS to improve riparian condition, instream 

conditions and ultimately water quality to levels that meet 

Federal and State water quality standards.

Water 

Resources

The Draft RMP/EIS errs in eliminating/prohibiting in one or 

more alternatives, including the preferred alternative, the 

livestock trailing/crossing on the East Fork of the Jarbidge 

River above Murphy Hot Springs. 

(1) Any elimination/prohibition of such trailing/crossing is 

unwarranted by the facts, as discussed in our previous 

comments, including the stream water quality information.

(2) A BLM Biological Assessment dated September 2, 1998, 

and a US Fish and Wildlife Service Memorandum dated 

September 10, 1998, determined that such trailing/crossing “is 

not likely to adversely affect bull trout”. 

In the Final EIS, this activity was removed from the management 

actions in Chapter 2 because it is not a land use plan level 

decision. It is identified in Appendix D: Aquatic and Riparian 

Management Strategy, Table D-10 as an ongoing action with 

Endangered Species Act completed consultation. 

Water 

Resources

In the Draft RMP/EIS (p. 3-11), Water Resources, second 

paragraph, the Idaho Department of Environmental Quality 

listed only one small segment of Salmon Falls Creek as water 

quality limited, not the whole creek.

The Final EIS revised the Chapter 3 Water Resources section to 

include links to the most current information for water quality 

impaired streams within the planning area. The water quality 

impaired stream segments for Salmon Falls Creek was clarified 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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based on Idaho’s 2010 Integrated Report prepared (DEQ, 2011). 

In this report, Salmon Falls Creek is water quality impaired near 

the Nevada State line. 

Water 

Resources

In the Draft RMP/EIS, Chapter 4, Water Resources, on pp. 4-

87 to 4-132, the BLM mentioned numerous times that 

motorized vehicle use affects water quality. The use of roads 

generally does not affect water quality, especially roads up on 

the plateau. Do not use this as an excuse to close roads. The 

factor that the BLM does not mention is mother nature. When 

there is a substantial snow pack and then fast melting occurs, 

a substantial amount of runoff occurs and it usually runs in the 

already existing ravines or gullies, not roads. The same is true 

for torrential rain or hailstorms. The fact that the BLM does not 

mention this anywhere in the Draft RMP/EIS misleads the 

public for the purpose of road closure.

The comment refers to the Draft RMP/EIS, Chapter 4, analysis in 

the Water Resources section, Impacts from Transportation and 

Travel Actions which referenced Furniss and others (1991) to 

support the conclusion that roads contribute substantial amounts 

of sediment to streams. The discussion of impacts in that section 

acknowledged that roads in riparian areas are a greater source 

of sediment to streams than roads in upland areas. The Final 

EIS also used the reference for Furniss and others (1991) in 

assessing impacts to Water Resources from Transportation and 

Travel actions. The comment did not provide the BLM with 

literature to consider that supports the view that roads do not 

affect water quality. The Final EIS revised the Chapter 3 Soil 

Resources section to include additional information regarding the 

natural erosion processes within the planning area. 

Water 

Resources

In the Draft RMP/EIS, Chapter 4, Water Resources, (pp. 4-87 

to 4-132), I cannot tell to which streams and segments you are 

referring.

The Final EIS, Chapter 4 Water Resources section was revised 

to include references to the maps for Water Quality Impaired 

Streams (Map 6); Proper Functioning Condition Ratings (Map 

16); Riparian Conservation Areas (Map 22); Habitat Condition 

Ratings (Map 23; and Appendix D: Aquatic and Riparian 

Management Strategy, Maps D-1 through D-9); and Bull Trout 

and Redband Trout Distribution (Map 24). 

Water 

Resources

In the Draft RMP/EIS, on p. 4-132, we take exception to your 

comment "Designating the Sagebrush Sea Area of Critical 

Environmental Concern as a Critical Suppression Area with 

management objectives that include minimizing public land 

uses would reduce the potential for impacts to water quality in 

water quality impaired streams and riparian areas not at Proper 

Functioning Condition". 

The comment refers to the Draft RMP/EIS, Chapter 4, Water 

Resources section, Cumulative Impacts from Alternative V (p. 4-

132). The Sagebrush Sea Area of Critical Environmental 

Concern (ACEC) was included in Alternative V and emphasizes 

reduced authorized uses to restore resource conditions over 

time. The Water Resources analysis for Alternative V predicted 

fewer cumulative impacts to proper functioning condition (PFC) 

ratings and water quality due to having the least amount of

authorized uses. In addition, designating the Sagebrush Sea 

(956,000 acres) as a Critical Suppression Area would reduce the 

potential for cumulative impacts to PFC ratings and water quality 

from wildland fire. The analysis for the impacts to water quality in 

the Sagebrush Sea ACEC relative to critical suppression areas 

was clarified in the Final EIS in Chapter 4, Water Resources

section, Impacts from Wildland Fire Ecology and Management 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Actions, Alternative V. 

Water 

Resources

Draft RMP/EIS, Section 2.3.4, Water Resources: 

An inconsistency in the management of water resources in 

relation to the Yahoo Creek area and the proposed 

Deadman/Yahoo Special Recreation Management Area 

(SRMA) may exist (WR-CA-MA- 1, p. 2-24). 

The proposed Deadman/Yahoo SRMA (Map 54) in Alternative 

IV of the Draft RMP/EIS included a portion of Yahoo Creek. 

Improving water quality on priority streams (Map 17), including 

Yahoo Creek, is a stated goal common to all action alternatives 

and this area is designated to allow off-road travel. Vehicle 

travel through streams in SRMAs would increase sediment and 

nutrient loads and impede water quality improvement. Any 

actions implemented to increase water quality upstream would 

be likely be compromised by this action in the SRMA 

downstream. Eliminating the section of the SRMA that included 

Yahoo Creek or implementing stream crossings designed to 

protect water quality in the Yahoo Creek section of the SRMA 

would address this issue. The latter would dually protect water 

quality and uphold off road travel. 

Additionally, WR-CA-MA-4 (p. 2-25) states that uses can be 

suspended if they are a factor in not meeting water quality 

standards. If the BLM anticipates that off-road stream 

crossings that protect water quality cannot be implemented, 

then Idaho Department of Fish and Game suggests it would be 

prudent to amend the SRMA at this stage of the planning 

process rather than suspending the use later.

The comment refers to the Draft RMP/EIS, Chapter 2, Water 

Resources section, WR-CA-MA-1 and how it relates to the 

Chapter 2, Recreation section, and REC-IV-A-1 which 

designates a 34,000 acre Deadman/Yahoo Special Recreation 

Management Area (SRMA). This SRMA encompasses Yahoo 

Creek which is a water quality impaired stream. 

Alternative VI (Proposed RMP), Chapter 2, Recreation, REC-VIA-1 created a separate Yahoo SRMA (3,000 acres) and 

Deadman SRMA (13,000 acres). A map displaying the revised 

SRMA boundaries is included in the Final EIS (Map 66). With the 

revised SRMA boundaries, Yahoo Creek is within the Yahoo 

SRMA. 

The Final EIS, Chapter 2, Recreation, included management 

actions to reduce impacts to water quality in the Yahoo SRMA 

during the development of an implementation and monitoring 

plan for the SRMA (REC-CA-MA-1), to implement resource 

protection measures (REC CA-MA-2), or to design new or 

modify, relocate or discontinue existing recreation-related 

activities and facilities if they are not maintaining aquatic and 

riparian conditions (REC-CA-MA-3). The Transportation and 

Travel section includes direction for new, replacement and 

reconstructed stream crossings (i.e., culverts, bridges and other 

stream crossings) (TR-CA-MA-14). These management actions, 

used in conjunction with adaptive management, would reduce 

impacts to water quality and support the attainment of water 

quality objectives in the Yahoo SRMA. 

The restoration priorities in the Aquatic and Riparian 

Management Strategy (Appendix D) would be used to address 

water quality concerns within the Yahoo SRMA. 

Water 

Resources

While the Draft RMP/EIS in Chapter 3, Water Resources, 

discusses water rights as related to surface water diversions 

for irrigation purposes (p. 3-10, 3-11, 3-40) and as related to 

Desert Land Entries (p. 3-70), the Draft RMP/EIS does not 

discuss such water rights related to livestock watering.

The Final EIS revised the Chapter 3 Water Resources section to 

clarify that surface water is diverted from streams under water 

rights granted by Idaho Department of Water Resources. The 

Final EIS removed the distinction for water rights related to 

private land irrigation. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Water 

Resources

As an overall statement, while the Draft RMP/EIS in Chapter 4, 

Water Resources discusses water rights as related to 

administration by the States (p. 4-4, p. 4-391), as related to 

private land use (p. 4-130, p. 4-225), briefly as related private 

and public land uses (p. 382), as related to wild horses (p. 4-

502, p. 4-509), and as related to Oil and Gas operations (p. 4-

505, p. 4-610), the Draft RMP/EIS does not discuss such water 

rights as related to livestock watering.

The exception to this rule occurs as related to wild horses, 

wherein the Draft RMP/EIS understands that the alternative(s) 

would create conflict; but, the Draft RMP/EIS treats water rights 

as some kind of burden on the permittee: “If the amount of 

forage available to livestock in the Saylor Creek Herd 

Management Area (HMA) decreases substantially, the 

permittees would no longer need to maintain or provide access 

to those private water rights within the HMA. In that case, in 

order to maintain sufficient water availability for wild horses, 

water rights would need to be secured, and new wells would 

need to be drilled on BLM-managed land.” (see Draft RMP/EIS, 

p. 4-502). However, the Draft RMP/EIS entirely fails to 

recognize that water rights are a property right, and entirely 

fails to assess the implications of these water rights under the 

various alternatives.

The Draft RMP/EIS, Chapter 4, Introduction (p. 4-4) 

acknowledged surface water rights are allocated by the Idaho 

Department of Water Resources and the Nevada Division of 

Water Resources. The Final EIS considered that surface water 

management is not under BLM discretion or authority, but has 

direct, indirect and cumulative impacts to BLM-managed streams 

in the Chapter 4 analysis in the Water Resources, Riparian 

Areas and Wetlands, and Special Status Fish and Aquatic 

Invertebrates sections. The recognition of water rights as a 

property right and the need for an assessment of the implications 

of water rights is beyond the scope of this planning effort.

The Draft RMP/EIS, Chapter 4, Wild Horses recognized that a 

private water right is used to supply water to wild horses on the 

Saylor Creek Herd Management Area (HMA). Because the 

permittees have a vested interest in the wells and pipeline 

systems, they conduct the majority of the maintenance. The 

analysis identified the potential for future changes in the 

management of surface waters within the HMA which could lead 

to a shift in the maintenance of the water system to the BLM or 

the need to develop water on the public land if the water right 

holder decides to use the water outside of the HMA and a 

portion of the private water right cannot be committed to the 

HMA through a cooperative agreement. Additionally, because 

portions of the water supplied to the HMA comes from a private 

well through an agreement between the permittees and the 

owner of the well, there would be no guarantee the BLM would 

be able to continue accessing that water for use within the HMA. 

Water 

Resources

The non-perennial stream segments are likely to be particularly 

important to sage-grouse, since many of these areas are not in 

steep canyons, and so they are used by grouse for brood 

rearing and water. 

In the Final EIS, management direction for seasonally flowing or 

intermittent streams is included in Alternative VI (Proposed 

RMP), Chapter 2, Riparian Areas and Wetlands, RI-CA-MA-1 

(Category 4 ) and in the Aquatic and Riparian management 

Strategy (Appendix D) on p. 2 (Category 4). 

Water 

Resources

Did BLM place any thermometers in the currently unoccupied 

reaches? BLM has no idea how high the temperatures are in 

the streams that are currently unfit for trout to live in. (see Draft 

EIS, Chapter 3, p.3-40).

The comment refers to the Draft RMP/EIS, Chapter 3 Special 

Status Fish and Aquatic Invertebrates section, under the 

subhead for Interior Columbia River Redband Trout. Water 

temperature monitoring sites focused on streams that contain 

Endangered Species Act-listed or BLM sensitive aquatic 

species. The sites for monitoring water temperature in the bull 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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trout occupied watersheds were coordinated with the US Fish 

and Wildlife Service in Reno, Nevada, and US Geological 

Survey in support of a bull trout migration study under a 

Cooperative Agreement between these two agencies. The 

placement of thermographs in the redband trout occupied 

watersheds was based on the occurrence of redband trout and 

the confluence of perennial tributaries that could have a 

measurable effect on water temperature. The Final EIS revised 

Chapter 3, Special Status Fish and Aquatic Invertebrates, to 

include the BLM water temperature data that was collected 

between 2008 and 2011 for redband trout and bull trout streams. 

Water 

Resources

There is no analysis of cumulative impacts of resuming grazing 

in burned watersheds or for activities on the Forest Service 

lands that comprises the upstream portion of bull trout 

watersheds.

In the Final EIS, the Chapter 4 analyses in the Water Resources, 

Riparian Areas and Wetlands, and Special Status Fish and 

Aquatic Invertebrates sections considered the cumulative 

impacts from activities that occur on the Humboldt-Toiyabe 

National Forest managed lands in the upper Jarbidge River 

Watershed. The resumption of authorized uses after a wildland 

fire is based on site-specific objectives and determined by an 

Interdisciplinary Team. 

Water 

Resources

Which sections of streams have lost beaver dams, and how 

has this impacted hydrology, perennial flows, and aquatic 

species persistence?

The comment refers to the Draft RMP/EIS, Chapter 3, Special 

Status Wildlife section under the subheading for the 

Riparian/Wetland Guild. The discussion noted the beaver ponds 

that were present in Bear and Shack Creeks and Timber Canyon 

have failed and no longer provide habitat for spotted frog. The 

proper functioning condition assessments displayed in the Final 

EIS in Chapter 3, Riparian Areas and Wetlands (Table 3-12) and 

in Appendix D: Aquatic and Riparian Management Strategy

(Table D-5) reflect the impacts of beaver dams on riparian areas. 

Habitat condition data for these streams is included in Appendix 

D (Table D-3). The impacts analysis for special status species is 

included in Chapter 4 of the Final EIS in the Special Status Fish 

and Aquatic Invertebrates and Special Status Wildlife sections. 

Water 

Resources

The BLM refers to a 1997 Watershed Analysis. This analysis 

pre-dated Bull Trout Endangered Species Act listing for the 

Jarbidge Distinct Population Segment. The reference to this 

document highlights the need for the BLM to analyze 

cumulative impacts of livestock grazing caused by the same 

BLM-managed lands that herds graze on the shared Forest 

watershed. These herds, and this same very small number of 

In the Draft RMP/EIS, the Aquatic and Riparian Management 

Strategy (ARMS; Appendix D) included guidance for completing 

multi-scale assessments and ecosystem analysis at the 

watershed scale. The ARMS identified one Watershed Analysis 

that was completed by the BLM and US Forest Service in 1997. 

The ARMS identified other broad scale and mid-scale aquatic 

resource assessments, Conservation and Recovery Plans 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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permittees affects populations of bull trout, redband trout, as 

well as sage-grouse, pygmy rabbit and other wildlife over a 

huge land area.

(Table D-9) and Endangered Species Act consultation with the 

US Fish and Wildlife Service (Table D-10) that were completed 

in the Jarbidge planning area. The ARMS summarized the most 

current habitat condition data (Table D-3) and proper functioning 

condition data (Table D-5) which define the baseline conditions 

for the aquatic resource analysis in Chapter 4. The Final EIS, 

Appendix D, included a clarification there were two watershed 

analysis completed in the Jarbidge River Watershed. The 

second watershed analysis, Watershed Analysis for the East 

Fork Jarbidge River, was completed by the Forest Service in 

2004.

Water 

Resources

Under this Plan, the BLM has no obligation to do water quality 

monitoring. This runs counter to the Fundamentals of 

Rangeland Health. The BLM must monitor for E. coli and other 

bacteria on a required and specific schedule associated with 

livestock and other use impacts.

The Final EIS, Chapter 2 Alternative VI (Proposed RMP) Water 

Resources section included management direction for 

coordination with Idaho Department of Water Resources (IDWR, 

1993), Idaho Department of Environmental Quality (DEQ), and 

Nevada Division of Environmental Protection (NDEP) to identify 

and mitigate impacts of public land management on water 

resources (WR-CA-MA-7 and WR-CA-MA-8). This coordination 

included monitoring of water quality indicators, data sharing for 

Total Maximum Daily Load development, and other coordination 

to reduce duplication of effort for these agencies. The Final EIS, 

Chapter 2 (Table 2-5) also identified coordination with Idaho 

Department of Water Resources, DEQ, and NDEP to monitor 

water quality impaired or other priority streams as resource 

conditions warrant.

Water 

Resources

BLM must identify all causes of water quality standards 

exceedances, and examine all direct, indirect and cumulative 

impacts - including activities on private lands.

The Final EIS revised Chapter 3 to include links to the most 

current information for water quality impaired streams within the 

planning area. The causes for not attaining water quality 

standards can be attributed to numerous public land uses and 

environmental factors. The process for identify the causes for 

exceedances are determined at the site–specific level. The 

Chapter 2 Alternative VI (Proposed RMP) Water Resources

section included management direction for coordination with 

Idaho Department of Water Resources, Idaho Department of 

Environmental Quality, and Nevada Division of Environmental 

Protection to identify and mitigate impacts of water management 

on public land resources (WR-CA-MA-7). The Final EIS included 

an analysis of the direct, indirect and cumulative impacts to 

water resources in the Chapter 4 Water Resources section. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Water 

Resources

The Draft RMP/EIS refers to the Idaho Agricultural Pollution 

Abatement Plan and does not explain that this is voluntary. It 

lists best management practices, but the list does not show 

how management would occur, and how the BLM would 

achieve significant positive change.

In the Final EIS, Chapter 2 Water Resources section,

management action WR-CA-MA-4 identified the use of best 

management practices, where applicable, to maintain or improve 

water quality (Appendix B: Best Management Practices, Design 

Features, and Operating Procedures) and to implement 

recommendations from State water quality plans to achieve 

water resource goals and objectives. The management action 

identified the Idaho Agricultural Abatement Plan as an example 

of a State water quality plan. This management action was 

included in Alternative VI (Proposed RMP).

Alternative VI also included management direction to coordinate 

with Idaho Department of Water Resources, Idaho Department 

of Environmental Quality, and Nevada Department of 

Environmental Protection to identify opportunities to mitigate 

impacts to water quality from management on public land 

resources (WR-CA-MA-7). This interagency coordination would 

improve water quality within the planning area. 

Water 

Resources

There has never yet been a full and detailed analysis of water 

developments and all direct, indirect and cumulative impacts in 

the Jarbidge planning area. The Draft RMP/EIS lacks 

information on flows and changes in flows over time.

The Draft RMP/EIS identified the location of water developments 

within the planning area on Map 22. The water developments 

used to transfer water under private water rights are considered 

in the Final EIS in the Chapter 4 sections for Water Resources, 

Riparian Areas and Wetlands, and Special Status Fish and 

Aquatic Invertebrates under the Cumulative Impacts. All of the 

aquatic resources sections identify cumulative impacts from 

water developments. 

Water 

Resources

We are concerned the BLM has been conducting limited water 

quality monitoring, and does not have an adequate baseline 

data for sedimentation, turbidity, algal growth, temperature and 

bacterial contamination of waters due to livestock grazing 

impacts, and in some cases, the combined impacts of grazing 

and roads.

The Final EIS revised the Chapter 3 Water Resources section to 

include links to the most current information for water quality 

impaired streams within the planning area and the role of the 

Environmental Protection Agency, Idaho Department of 

Environmental Quality (DEQ), and Nevada Division of 

Environmental Protection (NDEP) in developing and enforcing 

water quality standards that protect designated beneficial uses.

In Alternative VI (Proposed RMP), Chapter 2, Water Resources

section, WR-CA-MA-7 included direction to coordinate with 

Idaho Department of Water Resources, DEQ, and NDEP to 

comply with State water quality standards. This coordination 

included monitoring of water quality indicators, data sharing to 

reduce duplication of effort, and coordination on Total Maximum 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Daily Load development for water quality restoration (WR-CAMA-8). 

Water

Resources

Clarify how the BLM post-fire grazing and other activities 

heighten water quality problems. 

In the Final EIS, the Chapter 4 Water Resources section 

analysis described the general impacts from wildland fire and 

livestock grazing on water quality under the subheadings for 

Impacts from Wildland Fire Ecology and Management Actions 

and Impacts from Livestock Grazing Actions, respectively. The 

analysis stated the impacts to water quality from wildland fire 

vary according to fire frequency, severity, and the functional 

condition of the riparian area. The loss of vegetation can 

increase erosion rates to levels which impacts water quality. 

Emergency stabilization and rehabilitation actions, as well as 

modification or suspension of authorized land uses, reduces 

impacts to water quality from wildland fire and expedites 

resource recovery within the burned area. Alternative VI 

(Proposed RMP), Chapter 2, Wildland Fire Ecology and 

Management section, under Fuels and Emergency Stabilization 

and Burned Area Rehabilitation, included management direction

to rest burned areas from authorized uses, such as livestock 

grazing, until Emergency Stabilization and Burned Area 

Rehabilitation objectives have been met (FE-CA-MA-10). 

Water 

Resources

The Draft RMP/EIS fails to provide required mandatory 

monitoring of bacterial contamination sediment, temperature, 

and other water quality concerns during periods of livestock 

use, when runoff occurs, and other critical time periods. It fails 

to provide thresholds/triggers for rectifying exceedances by 

minimizing disturbance such as livestock degradation of 

uplands and riparian areas. There is not a reasonable range of 

alternatives to address water quality issues.

In the Final EIS, the Chapter 2 Alternative VI (Proposed RMP) 

Water Resources section included management direction for 

coordination with Idaho Department of Water Resources, Idaho 

Department of Environmental Quality, and Nevada Division of 

Environmental Protection to identify and mitigate impacts to 

water quality from public land management (WR-CA-MA-7). This 

coordination included monitoring of water quality indicators, data 

sharing to reduce duplication of effort, and coordination on Total 

Maximum Daily Load development for water quality restoration 

(WR-CA-MA-8). 

The Draft RMP/EIS, the Chapter 2 Water Resources sections 

included goals, objectives and management actions for 

maintaining or improving the chemical, physical and biological 

integrity of water resources and meeting Federal and State water 

quality standards for all action alternatives. The Clean Water Act

requires compliance with Federal and State water quality 

standards and therefore does not vary for the alternatives 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

analyzed. In the Final EIS, the Chapter 2 Alternative VI Water 

Resources section included this same goal to maintain or 

improve the chemical, physical, and biological integrity of water 

resources (WR-CA-G-1) and make progress towards meeting

Federal and State water quality standards (WR-CA-O-1). 

Water 

Resources

Estimating some degree of temperature increase is essential to 

understanding if water quality criteria can be met with 

continued commodity uses or management stresses on 

systems. Since shading vegetation is critical to maintaining 

cool water temperatures, the BLM must have much stronger 

recovery goals than proper functioning condition in some 

places over the next 20 years. Examine the combined 

cumulative effects of livestock grazing and trampling in 

watersheds, existing flow reductions for diversions and 

developments, along with the additional stresses posed by 

climate change on ecosystems.

In the Final EIS, the Chapter 2 Alternative VI (Proposed RMP) 

Water Resources section included the goal to improve the 

chemical, physical, and biological integrity of water resources 

(WR-CA-G-1) and make progress towards meeting Federal and 

State water quality standards (WR-CA-O-1). Appendix D: 

Aquatic and Riparian Management Strategy, Figure D-1 

displayed the relationship between riparian functional conditions 

(proper functioning condition [PFC], habitat condition, and State 

water quality standards). Improvement in water quality to levels 

that could result in the delisting of water quality impaired streams 

occurs when riparian condition improves beyond the initial rating 

of PFC. For this reason, the goals, objectives and management 

actions for maintaining or improving water quality are to meet 

Federal and State water quality standards, not for attaining PFC. 

The combined effects of multiple land uses on water quality are 

included in the Final EIS, Chapter 4 Water Resources section 

under Cumulative Impacts.

Wild and 

Scenic Rivers

The Draft RMP provides for management of designated 

segments of the Bruneau and Jarbidge Rivers to maintain or 

enhance their outstandingly remarkable values. However, the 

Wild and Scenic Rivers Act requires preparation of a 

comprehensive management plan for designated river 

segments. 16 U.S.C. § 1274(d) (1). The Draft RMP/EIS does 

not mention this important next step. We assume that the 

forthcoming wilderness plan by the Boise District BLM will 

include a management plan for Wild and Scenic Rivers in the 

planning area.

The Final EIS updated management related to the Omnibus 

Public Land Management Act of 2009 and Wild and Scenic 

Rivers that occurred just prior to the release of the Draft 

RMP/EIS. In the Final EIS, management action WSR-CA-MA-1 

provides direction to “Manage the designated segments of the 

Bruneau and Jarbidge Rivers in accordance with the Owyhee 

Canyonlands Wilderness and Wild and Scenic Rivers 

Management Plan to maintain or enhance their Outstandingly 

Remarkable Values, free-flowing condition, water quality, and 

classification.” 

Wild and 

Scenic Rivers

The prescriptions for opening designated, suitable and eligible 

river segments to salable mineral development and mineral 

leasing are not sufficiently protective. Designated, suitable, or 

eligible segments should not be available for right-of-way 

development.

The comment refers to Alternatives II and III in the Draft 

RMP/EIS where Eligible, Suitable, and Designated Wild and 

Scenic Rivers (WSR) would be available for leasable mineral 

development with a No Surface Occupancy stipulation with 

exception and waiver clauses if environmental analysis 

determines Outstandingly Remarkable Values (ORVs) would not

be impaired (LE-II –MA-1; LE-III-MA-1). Eligible, Suitable and 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Designated WSR would be available for salable mineral 

development in Alternative II (SA-II-MA-1). In the Final EIS, 

Alternative VI (Proposed RMP) includes management direction 

that designated, suitable, and eligible WSR would be closed to 

exploration and development of leasable or salable minerals. 

Management direction also states designated, suitable, and 

eligible WSR corridors would be a right-of-way (ROW) avoidance 

area that retained the existing utility corridor south of Murphy Hot 

Springs on Jarbidge River, East Fork and Jarbidge River. In 

addition, new ROWs within designated, suitable, and eligible 

WSR corridors must maintain or enhance the river segment's 

ORV, free-flowing condition, water quality, and tentative 

classification.

Wild and 

Scenic Rivers

Section 2.5.3 Wild and Scenic Rivers (WSRs) of the Draft 

RMP/EIS is irrelevant. The Wild and Scenic Rivers Act was 

originally designed to regulate dam construction across 

significant rivers and maintain those rivers in their free flowing 

state. The proposal to designate the small streams, such as 

Dave Creek, Cougar Point Creek, and Rocky Canyon Creek, 

as WSRs is an abuse of agency discretion and authority that 

far exceeds the intent of Congress.

The determination of eligibility during land use planning is 

required under Section 5 (d) (1) of the Wild and Scenic Rivers 

Act. The BLM identifies areas that meet the eligibility and 

suitability criteria but does not have the authority to make the 

designation official. The segments identified in the Final EIS 

meet criteria set forth in the Act. The Final EIS revised 

management related to the Omnibus Public Land Management 

Act of 2009 and Wild and Scenic Rivers that occurred just prior 

to the release of the Draft RMP/EIS. 

Wild and 

Scenic Rivers

Map 113 indicates that a segment of Rocky Canyon Creek is 

eligible for inclusion in the nation’s system of wild and scenic 

rivers. The management common to all action alternatives 

suggests restrictions that could interfere with wind energy 

development. In fact, while this segment of the creek may be 

within the overall boundary of a proposed wind energy project, 

the creek would not be physically impacted by a project. The 

BLM should explain this in the Final EIS.

Through Section 5 (d) (1) of the Wild and Scenic Rivers Act, the 

BLM is required to assess rivers under its management 

jurisdiction and determine eligibility for these rivers by applying 

standardized criteria through a documented evaluation process. 

The Final EIS describes this process in Section 3.4.3 and in 

Appendix N: Wild and Scenic River Eligibility Determination. 

Because the Omnibus Public Land Management Act of 2009

does not "release" eligible or suitable segments of rivers that 

were not designated (Sec.1504), Rocky Canyon Creek was 

included in Alternative VI (Proposed RMP) in Chapter 2 (WSRC-A-3) as eligible for inclusion in the National Wild and Scenic 

Rivers System. A determination of site-specific impacts of a 

proposed project is not appropriate at the land use planning 

level. The potential impacts to this eligible segment would be 

determined in a project specific NEPA analysis.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Wild and 

Scenic Rivers

Because Congress has spoken, no additional segments or 

portions of rivers should receive special status or management 

prescription in the planning area.

The comment refers to Chapter 2, Section 2.5.3, (WSR‐C‐A‐1, 

WSR‐C‐A‐2) which recommended segments of the Bruneau 

River (Blackrock Crossing to Hot Creek) and Jarbidge River 

(Jarbidge Forks to Bruneau River) as suitable for inclusion in the 

Wild and Scenic River system. Because the Omnibus Public 

Land Management Act of 2009 (OPLMA) does not "release" 

eligible or suitable segments of rivers that were not designated 

by OPLMA (OPLMA, Sec.1504), these river segments retain 

their eligible or suitable status.

Wild and 

Scenic Rivers

In Appendix W of the Draft RMP/EIS please clarify the 

following statement in the fourth paragraph: "However, the Wild 

and Scenic River corridor only extends 0.25 miles above the 

high water mark on each side of the river, which does not 

provide any protection for these values outside the Wild and 

Scenic corridor". Actually, this stretch of the Salmon Falls 

Creek Area of Critical Environmental Concern is not accessible 

to anyone, contains steep canyon walls, and is virtually 

covered by large lava rocks for the whole segment of that river. 

It is virtually impossible to even hike it. It does not warrant any 

further protection.

The Final EIS, Appendix N: Wild and Scenic River Eligibility 

Determination includes description of the relevant and important 

values for the Salmon Falls Creek Area of Critical Environmental 

Concern. The Wild and Scenic Rivers Act (WSRA) (Sec. 4-d) 

states the boundaries of any river proposed for potential addition 

to the National Wild and Scenic Rivers System shall generally 

comprise that area measured within one-quarter mile from the 

ordinary high water mark on each side of the river. The WSRA

defined this corridor and BLM does not have discretion to adjust 

it.

Wild and 

Scenic Rivers

Salmon Falls Creek offers recreational opportunities and the 

Resource Advisory Council has supported an Special 

Recreation Management Area designation with allowances for 

transmission lines. The Salmon Falls Creek area is currently a 

transmission line chokepoint due to several designations, 

Furthermore; the issue needs to be addressed cooperatively 

with the Burley Field Office to ensure consistency.

Alternative VI (Proposed RMP) would designate the Roseworth 

right-of-way corridor for utilities across Lily Grade, LA-VI-A- 3. 

Wild Horses I urge that the following tenets be incorporated in the Draft 

RMP/EIS: 

Designate all Herd Management Areas (HMAs) principally for 

wild horse or burro herds as allowed under 4.3 CFR 4710.3-2. 

Decrease or eliminate livestock grazing in HMAs pursuant to 

43 C.F.R. 4710.5[a]).

Base Appropriate Management Levels on scientific and 

rational principles that provide adequate herd size for genetic 

viability.

43 CFR 4710.3-2 states “Herd management areas may also be 

designated as wild horse or burro ranges to be managed 

principally, but not necessarily exclusively, for wild horse or 

burro herds”. It is not necessary to designate the Saylor Creek 

Herd Management Area (HMA) as a “Horse Range” because the 

criteria described in the Wild Horses and Burros Management 

Handbook (H-4700-1) has not been determined to exist. Criteria 

for consideration as a Horse Range include the presence of one 

or more of the following: unique herd characteristics, outstanding 

viewing opportunities, unique landscape, or significant historical 

or cultural features.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Allocate resources equitably. Do not allocate more resources 

to ranching and other commercial usages than given to wild 

horses and burros.

43 CFR 4710.5(a) states “If necessary to provide habitat for wild 

horses or burros, to implement herd management actions, or to 

protect wild horses or burros, to implement herd management 

actions, or to protect wild horses or burros from disease, 

harassment or injury, the authorized officer may close 

appropriate areas of the public lands to grazing use by all or a 

particular kind of livestock.” It is not necessary to close the 

Saylor Creek HMA to grazing because the closure criteria 

described in the above CFR does not exist.

The Appropriate Management Level (AML) as analyzed in 

Alternative VI (Proposed RMP) would maintain a wild horse 

population between 50 and 200 animals. Determination of the 

AML conforms to the Wild Horses and Burros Management 

Handbook (H-4700-1) by performing the 3-tier analysis and 

report.

Review of published scientific literature (Coates-Markle, 2000) 

supports selection of the population range in the Proposed RMP 

as being able to maintain and promote genetic fitness and be in 

balance with livestock grazing and available water on the HMA. 

If genetic testing indicates diversity is declining, introduction of 1 

or 2 mares every generation would strengthen the genetic pool.

The Saylor Creek HMA is not an exclusive use area and the 

Proposed RMP balances competing uses through allocation and 

management of resources in order to maintain or achieve 

resource objectives established by the Final EIS. 

Wild Horses I urge that the following tenets be incorporated the Draft 

RMP/EIS:

Utilize range management to address wild horses and burros 

who wander across the borders of Herd Management Areas 

(HMAs) instead of permanently removing them.

Removals of any kind should be rare and minimal. Employ 

other methods of management and give them a fair opportunity 

to succeed before removing the horses. If a limited removal is 

necessary, complete it in a humane manner that respects 

The Final EIS analyzed a wide array of tools to manage 

population growth in a balance with the ecosystem and other 

uses of the Herd Management Area (HMA) that will reduce the 

need for gathers and removals in order to maintain Appropriate 

Management Level (AML). See management actions WH-VIMA- 1-7. 

Alternative VI (Proposed RMP) analyzed an AML of 50-200 

animals. This AML would balance resource objectives and the 

need of users groups with the need to manage the wild horse 

herd at a number that would sustain genetic viability and 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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horse social structure and keeps families intact.

Range management and controlling populations on the range 

should be the cornerstone of management of 'wild horses and 

burros. Allow the development of water resources, such as a 

system of guzzlers in the HMA.

maximize the interval between gathers. Exceeding 200 wild 

horses would require removal of excess horses.

The Final EIS considered the effects of allocation of forage and 

use of infrastructure to manage wild horses, wildlife, and 

livestock grazing on meeting resource objectives. 

Implementation of AML and other management actions would 

maintain or improve rangeland conditions and herd health. 

Alternative VI would allow for the establishment of water 

collection systems for meeting water needs of horses in the 

HMA.

Wild Horses Support public/private partnership for on-the-range 

management of wild horses and burros and the creation of wild 

horse preserves (i.e. Soldier Meadows proposal).

Alternative VI (Proposed RMP) analyzed the use of a wide array 

of measures for managing Saylor Creek wild horses, including 

development of public/private partnerships. 

Wild Horses Incorporate protection for predators in and around Herd 

Management Areas as a part of managing wild horses and 

burros.

Wildlife population management is the responsibility of the State 

of Idaho. The Final EIS analyzed a range of alternatives that 

provided habitat improvement for multiple species including prey 

species that would support a broader array of predator species.

Wild Horses The BLM has an Herd Management Area (HMA) in the 

planning area.

The BLM is required to leave the designated HMA as an HMA, 

but they are not required to have any wild horses in the area. 

The decision on how many horses are allowed in the area and 

how other users are handled in this area is up to the BLM. This 

area is located south of Glenn's Ferry in a very popular offhighway vehicle (OHV) use area The BLM would like to restrict 

OHV use in this area during the spring, which is when most of 

the OHV use occurs. During this time, motorized traffic would 

be allowed only on major gravel roads, which are extremely 

limited in this area. This restriction would amount to a closure 

of OHV activity in the area from March to June of each year. 

OHV travel would be limited to designated roads and trails 

under the Draft RMP/EIS to prevent resource damage, yet the 

BLM does not seem to be concerned about the damage that a 

herd of wild horses could inflict. To restrict activity to other 

users because of the wild horses goes against the policy of 

multiple use of public land. The approval of a certain use 

should not constitute restriction to other users.

Policy and regulation requires the BLM to provide a safe 

environment for wild horses to exist within designated Herd 

Management Areas (HMAs). Documented conflicts between wild 

horses and recreational activity have occurred within the Saylor 

Creek HMA over the last number of years. Much of the 

disturbance has occurred during important seasonal periods for 

the horses such as foaling. Management action WH-VI-MA- 5 

would provide the ability to restrict motorized use in the HMA

during foaling periods only if conflicts were determined to exist.

Alternative VI (Proposed RMP) analyzed managing the wild 

horse herd to maintain a population size of 50-200 animals. The 

population ranges were determined to be a balance between 

competing uses of the resource, and would maintain or improve 

rangeland resources within the HMA.
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Category Comment Response

BLM should manage the herd size to allow it to coexist with 

other users. Alterative IV would be the proper alterative for 

HMA management. Manage HMA as a multiuse area. OHV 

use would be allowed on inventoried roads and trails within the 

HMA.

Wild Horses The BLM has a Herd Management Area (HMA) in the planning 

area.

Problem with this: The BLM is required to leave the designated 

HMA as an HMA, but they are not required to have any wild 

horses in the area. The decision on how many horses are to be 

allowed in the area and how other users are handled in this 

area is up to the BLM. This area is located south of Glenn's 

Ferry in a very popular off-highway vehicle (OHV) use area 

The BLM would like to restrict OHV use in this area during the 

spring, which is when most of the OHV use occurs. During this 

time, motorized traffic would be allowed only on major gravel 

roads, which are extremely limited in this area. This restriction 

would amount to a closure of OHV activity in the area from 

March to June of each year. There is also the issue of the 

amount of forage these animals would eat that could be utilized 

by livestock grazers. OHV travel would be limited to designated 

roads and trails under this RMP to prevent resource damage, 

yet the BLM does not seem to be concerned about the damage 

that a herd of wild horses could inflict. To restrict activity to 

other users because of the wild horses goes against the policy 

of multiple use of public land. The approval of a certain use 

should not constitute restriction to other users.

Solution: Manage the herd size to allow it to coexist with other 

users. Alterative IV would be the proper alterative for HMA 

management. Manage HMA as a multiuse area. OHV use 

would be allowed on inventoried roads and trails within the 

HMA.

Policy and regulation requires the BLM to provide a safe 

environment for wild horses to exist within designated Herd 

Management Areas (HMAs). Conflicts between wild horses and 

recreational activity have been documented to occur within the 

Saylor Creek HMA over the last number of years. Much of the 

disturbance has occurred during important seasonal periods for 

the horses such as foaling. Management action WH-VI-MA- 5 

would restrict motorized use during foaling periods only if 

conflicts were determined to exist.

Alternative VI (Proposed RMP) would manage the wild horse 

herd to maintain a population size of 50-200 animals which 

would balance competing uses of the resource and would 

maintain or improve rangeland resources within the HMA.

Wild Horses Remove fencing in the Herd Management Area would allow 

the horses to better utilize the range and maintain their wild 

and free-roaming behavior. However, any re-designing of 

pasture configurations or fence removal should involve 

The Final EIS analyzed a range of options for fence removal and 

pasture reconfiguration among the different Alternatives. 

Management action WH-VI-MA-3 in Alternative VI (Proposed 

RMP) allows re-design of pasture configurations and fences 
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Category Comment Response

coordination with livestock grazing permittees and the 

development of a Herd Management Area Plan with full public 

participation.

within the Herd Management Area where necessary to facilitate 

genetic exchange and free-roaming character.

Consideration of pasture reconfiguration or any other action that 

affects grazing allotments would require close coordination 

between the BLM, permittees and other users to ensure 

achievement of management objectives for the Saylor Creek 

wild horse herd while also meeting, to the extent possible, the 

needs of other user groups.

Wild Horses Alternative III is acceptable however; the initial herd size 

should be at least 200 reproducing wild horses rather than 130.

The Final EIS analyzed a range of Alternatives for the size of the 

wild horse herd in the Saylor Creek Herd Management Area. 

Alternative VI (Proposed RMP) proposes a herd size of 50-200

which would balance the wild horse herd with ecological 

environment as well as user groups. 

Wild Horses The Draft RMP/EIS should state that it is issued conditionally, 

depending on the findings of the report issued by the National 

Academy of Sciences (NAS) following its study of the Wild 

Horse and Burro Program. (The NAS review is expected to 

take 2 years.) The Draft RMP/EIS should advise that it is 

subject to immediate amendment pursuant to the findings and 

corrective actions outlined in the NAS report.

BLM’s management of public land and its resources is subject to 

current laws and policy. If the National Academy of Sciences 

report results in changes to current law or policy, or new science 

that required changes to existing management of the Herd 

Management Area and wild horses, necessary changes to the 

Final EIS and Herd Management Area Plan would be made in 

order for the BLM to remain compliant.

Wild Horses All alternatives must include fertility control, where necessary, 

to control wild horse reproduction and avoid mass removals of 

wild horses from the range. The Draft RMP/EIS should provide 

that, until a herd's population reaches the level deemed 

adequate for genetic viability, fertility controls would not be 

used. Further, the Draft RMP/EIS should provide for the 

transition to an improved contraceptive as soon as one is 

available. The current amino-suppressive drug has too many 

adverse side effects.

The Final EIS analyzed a range of Alternatives that provide the 

opportunity for selection of the most effective tools to manage 

the horse herd within the Appropriate Management Level (AML) 

to maintain genetic diversity but would not limit incorporation of 

new, more effective tools to manage the Saylor Creek wild horse 

herd within AML.

Wild Horses All alternatives must accommodate horse population numbers 

over Appropriate Management Level through conversion of 

livestock grazing animal unit months to wild horses. Increase 

grazing fees during the phase-out period to cover BLM's true 

costs of managing livestock grazing activities.

The Final EIS analyzed a range of Alternatives for the herd size 

of the Herd Management Area. Alternative VI (Proposed RMP) 

has an Appropriate Management Level (AML) of 50-200 animals. 

This AML would balance resource objectives and the need of 

users groups with the need to manage the wild horse herd at a 

number that would sustain genetic viability and maximize the 

interval between gathers. Exceeding 200 wild horses would 

require removal of excess horses. 
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Category Comment Response

Determination of grazing fees on public lands is beyond the 

scope of this planning effort.

Wild Horses Close the Herd Management Area (HMA) to all motorized 

vehicles at all times, not just seasonally. I also support a buffer 

zone to limit noise pollution and disturbance from activities 

taking place outside the HMA.

The Final EIS did not analyze year round exclusion of motorized 

actives. Documented conflict between motorized recreation and 

horses does not warrant year round closure due to the infrequent 

and small extent of such conflicts in the Saylor Creek Herd 

Management Area. However, WH-VI-MA-5 would provide for 

appropriate travel restrictions when conflicts between wild 

horses and uses are identified.

Wild Horses The Draft RMP/EIS should provide for experimentation with 

innovative approaches for managing the Wild Horse and Burro 

Program. For instance, to help support the Program without 

complete dependence on the annual budget, there could be a 

campaign called "Adopt a Mustang on the Range." For a 

nominal yearly fee, thousands of moderate-income persons 

across the country could each "own" a wild horse. Such a 

program would likely be so "wildly" popular that BLM might 

even run out of enough horses to accommodate the number of 

would-be sponsors. The income generated could be put to 

good use in range-pasture improvements and the development 

of water resources.

Consideration of a specific pilot project as described in the 

comment is beyond the scope of this planning effort. However, 

Alternative VI (Proposed RMP) would not limit future exploration 

of a proposal of this type.

Wild Horses When you publish the Final EIS, you would do well to improve 

the clarity of the various maps and charts. The public should 

be able to see clearly the location of wind, utility, and energy 

development projects and where they stand relative to the 

Herd Management Area. 

The Final EIS revised maps to include the Saylor Creek Herd 

Management Area (HMA) where the HMA is affected, such as 

Expected Wind Development Areas (Maps 99 to 105), Land 

Tenure (Maps 106 to 113), Areas Available and Unavailable for 

Livestock Grazing (Maps 52 to 59), Geothermal Development 

Potential (Map 115), Leasable Minerals (Maps 116 to 122), 

Salable Minerals (Maps 123 to 129), and Locatable Minerals 

(Maps 130 to 135). 

Wild Horses In paragraph two of p. 3-57, the Draft RMP/EIS notes that 

there are no naturally occurring perennial water sources in the 

Herd Management Area (HMA) and that the wild horses rely 

solely on water sources that are installed facilities for livestock 

management and to support the horse herd. In paragraph five, 

noted regulation 43 CFR 4700.0-6(a) that wild horses be 

managed as self-sustaining population of healthy animals in 

the balance with other uses and the productive capacity of their 

habitat. With an artificial water source, it is not clear in the 

section on how this water source is self-sustaining to sustain 

The Final EIS recognized the lack of naturally occurring water as 

an issue in the analysis. The importance of water supplied 

through systems installed to support livestock grazing, and the 

fact the majority of maintenance of these systems is performed 

by permittees was recognized as critical to successfully 

sustaining the wild horse herd. In the case of the Saylor Creek 

Herd Management Area (HMA), part of balancing the horse herd 

with the environment and meeting resource objectives, is 

consideration of the effects horses have on the water supply 

systems in terms of both water use, and increased maintenance 
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Category Comment Response

the horse herd without some sort of maintenance of the water 

system. Will this plan address the maintenance of the water 

system to sustain the wild horse herd in the HMA?

costs. The Final EIS included management direction in 

Alternative VI (Proposed RMP) to increase the reliability of 

artificial water sources for wild horses within the HMA (Chapter 

2, Wild Horses, WH-VI-MA-4).

Wild Horses The Resource Advisory Council unanimously supports WH-IVA-2. 

Wild horses are an ongoing drain on the operating budget of 

the BLM. The Saylor Creek herd is composed of abandoned 

animals with no unique genetic value. This herd is entirely 

dependent on artificial water and is not capable of continued 

existence without the intervention of man. It makes sense to 

manage this herd area as a non-breeding population with herd 

numbers capped at 200. The herd areas across multiple states 

will be able to provide surplus horses to keep this area fully 

populated. The BLM while still having the costs associated with 

horse management would no longer have gathering costs 

except in the case of wildfire. 

The Final EIS analyzed a range of wild horse herd sizes. 

Alternative VI (Proposed RMP) sets the Appropriate 

Management Level (AML) at 50-200 head of wild horses. This 

AML was determined following consideration of the analysis of 

effects of the AML within the range of alternatives on resources 

and resource uses in the Draft RMP/EIS, and public opinion 

expressed through comments. The proposed AML would 

balance the size of the horse herd with resource objectives, 

while giving consideration of the input to maintenance of the 

water supply system by permittees.

Wild Horses When revising its land use policies and establishing 

Appropriate Management Levels for wild horses and livestock 

grazing allotments, BLM must consider social factors including 

prevailing public opinion.

This was highlighted in a 1982 National Research Council 

report on the BLM’s wild horse and burro program: 

Biologically, the area may be able to support 500 cattle and 

500 horses, and may be carrying them. However, if the weight 

of public opinion calls for 1,000 horses, the area can be said in 

this context to have an excess of 500 cattle. For these 

reasons, the term excess has both biological and social 

components. In the above example, biological excess 

constitutes any number of animals, regardless of which class 

above 1,000. Social excess depends on management policies, 

legal issues, and prevailing public preference.

This public outcry constitutes a “prevailing public preference” 

and provides sufficient reason for the BLM to reanalyze the 

division of resources within the Herd Management Area. This 

The Final EIS analyzed a range of wild horse herd sizes. 

Alternative VI (Proposed RMP) set the Appropriate Management 

Level (AML) at 50-200 head of wild horses. This AML was 

determined following consideration of the analysis of effects of 

the AML within the range of alternatives on resources and 

resource uses in the Draft RMP/EIS, and public opinion 

expressed through comments. The proposed AML would 

balance the size of the horse herd with resource objectives, 

while giving consideration of the input to maintenance of the 

water supply system by permittees.
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Category Comment Response

strong public preference also mandates the BLM to fully 

consider all alternatives that would accomplish this goal and 

avoid the mass capture and removal of wild horses from public 

lands.

Wild Horses Unfortunately, the limited and industry-centered range of 

alternatives presented in the Draft RMP/EIS fail to provide the 

necessary protections to wild horses, as well as for sagegrouse, pygmy rabbit, songbirds, eagles and other wildlife for 

which the public values protection. 

The Final EIS analyzed eight alternatives that included a wide 

range of allocations to resources and resource uses. For 

example, allocations (forage and areas available) to livestock 

ranged from two fold increases to reductions of 78%. For 

example, in Alternative IVA the initial allocation would result in a 

22-50% reduction, Alternative, IVB a 22-50% reduction, and 

Alternative V a 51-75% reduction from the No Action Alternative. 

Adjustments to current allocations would be a function of the 

reduced area available to livestock grazing and the reduced 

percentages of vegetation allocated to livestock in order to meet 

wild horse, special status species, wildlife, soils, and vegetation 

resource objectives. 

Wild Horses Further, all alternatives presented in the Final EIS should 

include options for:

(1) Maximize conditions for wild horse population in the Herd 

Management Area. 

(2) Break the unsustainable cycle of roundups and removals.

(3) Manage horses on the range in a humane and costeffective manner.

The Final EIS analyzed a range of wild horse herd sizes. 

Development of Alternative VI (Proposed RMP) considered 

comments received from the public on the Draft RMP/EIS, the 

analysis of effects described in the Chapter 4, and the best 

available science to determine the Appropriate Management 

Level (AML) would establish the AML at 50-200 wild horses. This 

AML would increase the interval between roundups, decrease 

stress to the horses during gathers and while placed in 

temporary holding facilities, and decrease costs to the tax-payer 

related to these activities.

Wild Horses All alternatives must declare the Herd Management Area 

closed, off-limits to geothermal/fluid mineral leasing, mineral 

allocations, locatable mineral development, and gas and oil 

exploration, and mining.

The Wild Free-Roaming Horse and Burro Act and the BLM’s 

Wild Horses and Burros Management Handbook do not preclude 

energy and mineral exploration and development. Activities 

within the Herd Management Area (HMA) would be required to 

have stipulations to protect the health and welfare of the wild 

horses and HMA.

Only Congress can close the HMA to locatable mineral 

development so this request is beyond the scope of this planning 

effort. 

Wild Horses All alternatives must prohibit transmission or energy corridors 

in the Herd Management Area (HMA). Create a five-mile buffer 

zone around the HMA, to be “off-limits” to development and all 

The Wild Free-Roaming Wild Horse and Burro Act and the 

BLM’s Wild Horses and Burros Management Handbook do not 

preclude transmission and energy corridors. Authorization of 
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Category Comment Response

kinds of leasing, given the HMA’s small size and the 

vulnerability of the horses to disturbance.

activities within the Herd Management Area would require 

stipulations to protect the health and welfare of the wild horses.

Wild Horses All alternatives must place the Herd Management Area as a 

priority for fire suppression, utilizing strategies that restore 

native plant communities and reduce or eliminate livestock 

grazing.

The Final EIS analyzed a range of Alternatives for critical 

suppression areas. Alternative VI (Proposed RMP) would add 

the Herd Management Area to the critical suppression areas. 

Multiple management actions in the Wildland Fire Ecology and 

Management section provide direction for managing fuels to 

reduce fire size and intensity to help achieve resource 

objectives.

Wild Horses All alternatives must focus fuels projects on use of smallstature native species and reductions in the large unpalatable 

exotic grass monocultures it has seeded incrementally for 

livestock and following fires. These past efforts have cost 

taxpayers significant funds, but have exacerbated the fuels and 

weed problems in the area.

A wide range of plant materials for fuels projects were included 

in the Draft RMP/EIS and Final EIS. Alternative VI (Proposed 

RMP) did not limit plant material use in fuels project to low 

stature plants but would allow their use where appropriate.

Wild Horses All alternatives must avoid “zeroing out” of wild horse or burro 

herds. 

The Final EIS analyzed a range of Alternatives for the herd size 

of the Herd Management Area (HMA) from depopulating the 

HMA (Alternative II) to an Appropriate Management Level (AML) 

as high as 600 horses (Alternative VI). Alternative VI (Proposed 

RMP) has an AML of 50-200 animals that would balance 

resource objectives and the need of users groups with the need 

to manage the wild horse herd at a number that sustain genetic 

viability and maximize the interval between gathers. Exceeding

200 wild horses would require removal of excess horses.

Wild Horses The term or concept of thriving natural ecological balance

(TNEB) is included in the Wild and Free Roaming Horse and 

Burro Act (WFRHBA). Though the term TNEB is not itself 

defined in the WFRHBA or its implementing regulations, it is 

used to define the term “excess animals” to include wild horses 

that “must be removed from an area in order to preserve and 

maintain a thriving natural ecological balance and multiple-use 

relationship in that area.” WFRHBA at Section 2(f). An 

explanation of TNEB is provided, however, in the BLM’s Wild 

Horses and Burros Management Handbook which specifies 

that “to achieve a TNEB on the public lands, Wild Horses and 

Burros should be managed in a manner that assures 

significant progress is made toward achieving the Land Health 

Standards for upland vegetation and riparian plant 

communities, watershed function, and habitat quality for 

Thriving Natural Ecological Balance (TNEB) is not quantifiable, 

but Appropriate Management Level (AML) is. AML is the number 

of adult horses (expressed as a range) to be managed within an 

Herd Management Area (HMA), where the upper limit of the 

AML range results in a TNEB and avoids deterioration of the 

range or is out of balance with competing uses of the same 

resource. The Final EIS revised the analysis of how BLM 

determined the AML range.

The Wild Free-Roaming Wild Horses and Burro Act does not

preclude livestock grazing in HMAs. 43 CFR 4700.0-2 states, 

“The objectives of these regulations are management of wild 

horses and burros as an integral part of the natural system of the 

public lands under the principle of multiple use.” Further, 43 CFR 

4710.3-2 states “Herd management areas may also be 
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animals populations, as well as other site-specific or 

landscape-level objectives, including those necessary to 

protect and managed Threatened, Endangered, and Sensitive 

Species.” 1 Handbook at 4.1.5. This suggest that there the 

TNEB must be a quantifiable measure (based on Land Health 

Standards for various components of the ecosystem) that is 

used by the BLM to determine if or when wild horses constitute 

“excess animals” and must be removed. It is not, and given the 

plain language of the WFRHBA cannot be, a nebulous concept 

or phrase used to justify a particular management action 

without any evidence of what the TNEB is, how it is measured 

or quantified, and whether there is sufficient data to 

demonstrate that the TNEB has been impaired or degraded 

thereby justifying management action including, in the case of 

wild horses, management removals. Moreover, in regard to 

wild horse management, the BLM cannot simply claim that the 

number of wild horses are preventing achievement of TNEB 

but, rather, must demonstrate explicitly how wild horses 

(versus livestock, wildlife, recreation, or other potential threats) 

are causing any relevant land health standards not to be 

achieved in order to use a failure to achieve TNEB as a trigger 

for management actions.

designated as wild horse or burro ranges to be managed

principally, but not necessarily exclusively, for wild horse or burro 

herds.” The Saylor Creek HMA is not managed principally for 

wild horses. Other activities are allowed in HMAs and include

recreational and commercial uses such as livestock grazing and

energy and mineral exploration and development. 

Wild Horses If there are to be adjustments in forage allocations on BLM 

lands used or occupied by wild horses, such adjustments must 

take into consideration the needs of “other wildlife species 

which inhabit such lands.” Again, the statutory language does 

not refer to livestock, domestic livestock or other animals 

indicating that adjusted forage allocations on wild horse 

occupied lands are not to consider wild horse use. 

Furthermore, the BLMs proposed allocation of less than 1 

percent of native and non-native perennial grass production 

and no annual grass or shrub/forb production to wild horses in 

Alternatives I, III, IV, and V which does not reflect anything 

resembling a natural balance either between wildlife and wild 

horses or between wildlife, wild horses, or domestic livestock. 

All the alternatives prioritize forage allocations to resources (i.e., 

watershed, soils, and wildlife) over resource uses such as 

livestock grazing. Alternatives I, III, IV, V, and VI allocate more 

forage to wildlife than to livestock. Wild horses are considered a 

“Resource” and would be given consideration above all 

Resource Uses, including livestock grazing. Alternative VI 

(Proposed RMP) allocates approximately 2400 animal unit 

months (AUMs) for wild horses, an increase from 600 AUMs in 

the 1987 Jarbidge RMP. The wild horse forage allocation of less 

than 1% is based on the entire planning area, not just the Herd 

Management Area (HMA). The analysis in the Final EIS Chapter 

4 Wild Horses section was updated to include a comparison of 

forage allocation to wild horses and livestock within the HMA as 

well as at the planning level.

Wild Horses A second legal issue of relevance in the analysis of the Draft 

RMP/EIS is the BLM’s proposal to establish either small wild 

horse populations and/or non-reproducing herds of wild horses 

The No Action Alternative (the 1987 RMP) analyzed and an 

Appropriate Management Level 50 wild horses. A non-breeding 

herd was analyzed in Alternatives IV and V to help create a 
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within the Saylor Creek Herd Management Area. This is clearly 

inconsistent with regulations implementing the Wild FreeRoaming Wild Horses and Burro Acts, which states, “wild 

horses and burros shall be managed as self-sustaining 

populations of healthy animals in balance with other uses and 

the productive capacity of their habitat.” 43 CFR 4700.0-6(a).

range of alternatives. Alternative VI (Proposed RMP) would 

manage the wild horse herd to maintain a population size of 50-

200 animals which would balance competing uses of the 

resource and would maintain or improve rangeland resources 

within the Herd Management Area. 

Wild Horses Despite the apparent lack of legal authority to establish nonreproducing wild horse herds, the BLM provides no explanation 

in the Draft RMP/EIS as to why it believes establishing such 

non-reproducing herds (as it proposes to do in two of the 

alternatives in the Draft RMP/EIS) is permitted under its own 

laws and regulations. Admittedly, the BLM’s Wild Horses and 

Burros Management Handbook does contain provisions 

authorizing the establishment of such non-reproducing herds 

(see section 4.5.4 and 4.5.4.1), if there is no legal authority for 

the creation of non-reproducing herds then the policy is invalid.

The Wild Free-Roaming Wild Horses and Burro Acts and 

Handbook provide the necessary authority to establish a nonbreeding wild horse herd. However, Alternative VI (Proposed 

RMP) sets the Appropriate Management Level (AML) at 50-200 

head of wild horses. This AML was determined following 

consideration of the analysis of effects of the AML within the 

range of alternatives on resources and resource uses in the 

Draft RMP/EIS, and public opinion expressed through 

comments.

Wild Horses Before the BLM can authorize the establishment of nonreproducing herds, it must, particularly given the statutory and 

regulatory standards that seemingly prohibit such herds, 

provide a rational explanation for the legal basis for the 

creation of such herds. 

The Wild Free-Roaming Wild Horses and Burros Act and Wild 

Horses and Burros Handbook provide the necessary authority to 

establish a non-breeding horse herd. The Final EIS analyzed a 

range of Alternatives for the size of the wild horse herd in the 

Saylor Creek Herd Management Area. Alternative VI (Proposed 

RMP) proposes a herd size of 50-200 which would balance the 

wild horse herd with ecological environment as well as user 

groups.

Wild Horses The Wild Horses and Burros Management Handbook (H-4700-

1) provides the BLM with two separate strategies for setting or 

revising wild horse Appropriate Management Level (AML). The 

first option is through the Land Use Plan or RMP process while 

the second option is to establish AML through a Herd 

Management Area Plan (HMAP). Indeed, the BLM Handbook 

reports “habitat or population management and monitoring 

objectives regarding the management of a specific Herd 

Management Area (HMA) or complex of HMAs are normally 

identified in a HMAP rather than a Land Use Plan.” Handbook 

at 2.4.1.

The Wild Horses and Burros Management Handbook (H-4700-

1) also points out that when the AML is established in a Land 

Use Plan, the BLM is to follow the process outlined in the Land 

The Wild Horses and Burros Handbook states:

2.5.1.1 Appropriate Management Levels (AML) Established in 

Land Use Plans 

When AML is established in a Land Use Plan, follow the 

process outlined in the Land Use Plan to adjust AML. 

When the Land Use Plan does not outline a process for AML 

adjustment, the Land Use Plan may need to be amended or 

revised to adjust AML. 

The Final EIS does not prescribe a process for AML 

adjustment. If future adjustments to AML are necessary, the 

current plan would be amended using existing direction from 

the Wild Horses and Burros Handbook (H4700-1) to address 

current conditions.
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Use Plan to adjust AML. When the Land Use Plan does not 

outline a process for AML adjustment, the Land Use Plan may 

need to be amended or revised to adjust AML. 

Wild Horses More specifically, Herd Management Area Plans (HMAPs) are 

intended to establish short- and long-term management and 

monitoring objectives for a specific Wild Horse and Burro herd 

and its habitat including actions to be taken to accomplish herd 

and habitat management objectives. HMAPs “tier to and must 

be in conformance with the applicable Land Use Plan” or, if 

not, then either the Land Use Plan must be amended or the 

proposal should be modified or rejected. HMAPs must also be 

subject to analysis in an environmental assessment or 

environmental impact statement as required under the National 

Environmental Policy Act. 

Development of the Herd Management Area Plan (HMAP) will 

occur following the issuance of a Record of Decision and 

Approved Jarbidge RMP. The HMAP would follow applicable 

procedures described by policy and regulation. The goals and 

objectives in the Approved Jarbidge RMP would function as 

general goals and objectives, with more specific resource and 

herd objectives identified in the HMAP. Implementation and 

effectiveness monitoring would also be detailed in the plan to 

validate progress towards identified goals and objectives.

Wild Horses If the Appropriate Management Level (AML) in the Land Use 

Plan defers analysis of how it set AML to the Horse 

Management Area Plan, it is violating the law by failing to 

provide the AML analysis in the Land Use Plan. 

The Final EIS analysis of the Appropriate Management Level

(AML) in the Wild Horses sections is in conformance with BLM 

Wild Horses and Burros Management Handbook section 4.2.2.1. 

The AML will be set in the Record of Decision.

Wild Horses In the context of the Draft RMP/EIS, the problem is that the 

BLM has not engaged in any of the analysis contained in its 

handbook for establishing or adjusting Appropriate 

Management Level (AML). It does not provide an in-depth 

evaluation of intensive monitoring data, it does not specify how 

or if wild horses are affecting land health within the project 

area, nor does it disclose intensive monitoring data including 

any studies of grazing utilization (by wild horses, livestock or 

wildlife), range ecological condition and trend data, or 

climate/weather data. It is not even clear if the BLM has three 

to five years of monitoring data for the project area. Similarly, 

the BLM has not disclosed information about the current year’s 

forage production and water flows, the seasonal 

distribution/movement of wild horses, evidence related to the 

condition of wild horses, or any other data that its own policies 

specify must be collected to establish/adjust AML and to 

achieve other management objectives. Without providing such 

information and/or the required analysis, the BLM cannot 

complete the Draft RMP/EIS.

The BLM considered comments received from the public on the 

Draft RMP/EIS, the analysis of effects described in the Chapter 

4, and available science to analyze the Appropriate Management 

Level (AML) in all alternatives considered in the Final EIS 

including Alternative VI (Proposed RMP). The AML analysis in 

Chapter 4 of the Final EIS follows direction established in the 

BLM Wild Horses and Burros Management Handbook section 

4.2.2.1. 
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Wild Horses What is the wild horses’ allocation in the Herd Management 

Area relative to livestock?

The Wild Horses section in Chapter 2 has been updated to 

include allocation of vegetation to wild horses relative to 

livestock within the Herd Management Area. 

Wild Horses The Draft RMP/EIS should allow for consideration of expansion 

of the Herd Management Area (HMA) if livestock permits in 

adjacent lands to the HMA are bought out and retired.

The Wild Horses and Burros Management Handbook (H-4700-

1), 2.1.5, provides for adjusting Herd Management Area (HMA) 

boundaries through a Land Use Plan amendment to address 

conflicts or achieve resource objectives. Adjustments to an HMA 

boundary would be required to remain within the Herd Area (HA) 

boundary established by Congress with the passage of the Wild 

Free-Roaming Wild Horses and Burros Act.

Wild Horses BLM must fully explain all the changes that have occurred in 

the Herd Management Area (infrastructure expansion, 

seedings including species used, etc.) over all periods since 

the Wild Horse and Burro Act.

The Final EIS revised the Wild Horses section in Chapter 3 to 

include more details of the development of the Herd 

Management Area and origin of the wild horse herd.

Wild Horses What is the basis for the current allocation of forage to wild 

horses?

The Draft RMP/EIS and Final EIS based forage allocations on 

resource objectives and vegetation production. Priority of 

allocation of vegetation was to watershed, wildlife, wild horses, 

and livestock; in that order. The Wild Horses and Burros 

Management Handbook (H-4700-1) directs forage allocations 

expressed in animal unit months (AUMs) to be determined using 

the higher Appropriate Management Level (AML) range. For 

Alternative VI (Proposed RMP) the AML would be set at 50-200 

horses. Using the upper range of 200, 2,400 AUMs (200 animals 

X 12 months) would be allocated to wild horses. 

Wild Horses Designate the Herd Management Area (HMA) should as a 

Visual Resource Management (VRM) Class 2 and not a VRM 

4. The latter would allow the HMA to be turned into an 

industrial zone.

The No Action Alternative and Alternative II would manage the 

entire Herd Management Area (HMA) as Visual Resource 

Management (VRM) Class IV, however, Alternatives I, III, IV-A 

and IV-B would manage part of the HMA as VRM III, but most of 

the HMA would be VRM IV. Alternative VI (Proposed RMP) 

would manage the portion of the HMA in the Oregon National 

Historic Trail Protective Corridor as VRM II, with the majority of 

the area as VRM IV. Other uses (i.e., livestock grazing, 

commercial recreation use, and energy/mineral exploration) are 

allowed in HMAs as long as the activities have safeguards to 

protect the health and welfare of the wild horses. Management 

actions that would place restrictions on authorized uses within 

the HMA would be more effective at meeting objectives for 

managing wild horses than VRM classification.
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Wild Horses The RMP should include an Oregon Trail, Wild Horse, and

Fossil Bed Recreational Scenic Resource Management Area. 

Promoting wild horse eco-tourism, along with other public 

visitor interests should be a priority.

At a national level, the BLM has several programs that promote 

ecotourism, including the National Watchable Wildlife Program, 

Tread Lightly, and Leave No Trace. At the local level, wild horse 

ecotourism proposals could be considered as long as resource 

damage is avoided or minimized. A Special Recreation Permit 

would need to be obtained for commercial use, competitive use, 

vending, special area use, and organized group activity/event 

use. These actions are provided for in Alternative VI (Proposed 

RMP) REC-VI-MA-12, as long as they are compatible with 

management of the Herd Management Area (WH-VI-MA-7).

Wild Horses Interior Secretary order N0. 3270 issued March 9, 2007 

established agency policy to incorporate Adaptive 

Management into agency management programs. Under this 

policy, land use decisions can be adjusted in order to meet 

environmental, social and economic goals; to increase 

scientific knowledge; and to decrease tensions among 

stakeholders. Clearly, the high public interest in wild horses 

mandates reconsideration of current policies that maximize 

livestock grazing opportunities at the expense of wild horses.

Adaptive management is a major component of the BLMs Wild 

Horses and Burros Management Handbook. The Herd 

Management Area Plan will incorporate adaptive management 

strategies based on the results of monitoring and evaluation.

Wild Horses I encourage your agency to work very closely with Madeleine 

Pickens' new eco-sanctuary, which is the only solution so far 

that represents a sustainable and humane future for these 

animals.

Ms. Pickens’ proposal is outside the planning area and beyond 

the scope of this planning effort.

Wild Horses A goal should be established for an “in the wild” management 

plan for the Saylor Creek Wild Horse herd. This would avoid 

costly and unnecessary round-ups and removals.

It is not made clear by the commenter what “in the wild” 

management actually is or how it would be different from any of 

the alternatives presented in the Draft RMP/EIS. However, the 

goal of Alternative VI (Proposed RMP) is to manage the Saylor 

Creek Wild Horse Herd Management Area for a thriving natural 

ecological balance. 

Wild Horses I feel it is an outdated method used by the BLM for determining 

Appropriate Management Level for wild horses. Where are the 

independent scientists and biologists, who are not part of the 

BLM, without any bias to do the counts? Where are 

environmental impact reports on any plans to remove horses 

from lands deliberately set aside for them? These lands that 

were not to be taken away from mustangs and given to cattle.

The method the BLM uses to determine Appropriate 

Management Level (AML) is outlined in the Wild Horses and 

Burros Management Handbook (H-4700-1) updated in 2010. 

AML is established through a site-specific, multi-tiered analysis 

process (NEPA) that considers the four essential habitat 

components (forage, water, cover, and space), the amount of 

sustainable forage available for wild horse use, and whether the 

herd size is sufficient to maintain genetically diverse populations.
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Wild Horses The Saylor Creek Area, at over 94,000 acres, will support 

several thousand wild horses. As the monies collected from 

cattle grazing leases is a negligible amount in comparison to 

the cost of caring for the horses outside the Herd Management 

Area, the horses should take precedence as they are under the 

auspices of the BLM, while privately owned cattle are not and 

do not significantly contribute to either the preservation of the 

area nor do they pay their own way to repair the damage they 

cause.

The Appropriate Management Level (AML) upper limit 

determined in the Final EIS is the maximum number of wild 

horses that would result in a thriving natural ecological balance 

and avoid deterioration of the range due to overpopulation on the 

Saylor Creek Herd Management Area (HMA). One of the critical 

factors considered in determining AML was the availability of 

water. Though forage is not a limiting factor in the Saylor Creek 

HMA, there is no naturally occurring water. All water is provided 

though pipeline systems developed to support livestock grazing 

as well as wild horses. Currently, permittees assume the majority 

of the responsibility and costs associated with maintaining and 

operating the water system. If livestock were removed the 

responsibility for maintenance and operation would fall entirely 

upon the BLM.

Wild Horses The Draft RMP/EIS fails to include a reasonable range of 

alternatives to meet the current conservation challenges in the 

Herd Management Area and in the planning area as a whole. 

Instead, the Draft RMP/EIS promotes land use plans that 

perpetuate intensive resource extraction and the development 

status quo.

Land Use Plans normally contain general habitat and population 

goals and objectives. Habitat and population objectives specific 

to Herd Management Areas (HMAs) are normally identified in 

Herd Management Area Plans rather than a Land Use Plan. Wild 

horse habitat is composed of four essential components: forage, 

water, cover, and space. Alternatives I, III, IV, V, and VI 

(Proposed RMP) have goals and objectives that address these 

essential components, such as allocating sufficient forage, 

increasing the number and reliability of artificial water sources, 

and considering relocation or removal of fences to facilitate freeroaming characteristics. Alternatives IV and VI (Proposed RMP) 

have management actions that focus on vegetation restoration 

treatments in the HMA. Alternative VI (Proposed RMP) 

designates the HMA as a critical wildfire suppression area. 

Alternatives I, III, and VI require seasonal restrictions for 

motorized travel in the HMA during foaling season. These are 

just some examples of how the range of alternatives were 

developed and analyzed for effectively meeting the current 

conservation challenges in the Saylor Creek HMA.

Wild Horses Formulate the Draft RMP/EIS in consideration of and around 

those previously designated “other” special uses. Or restated: 

Land use plans centered in or around or having to do or 

effecting wild free-roaming horse and burro lands, must clearly 

specify in those land use plans, that the lands are designated 

as principally for wild equines, and that any proposed new 

Under 43 CFR 4700.0-6(b), Wild horses shall be considered 

comparably with other resource values in the formulation of Land 

Use Plans. Wild horses are a resource value and considered in 

the same manner as other resource values (e.g., cultural, 

historic, scenic, wildlife, and vegetation) as opposed to a land 

use or special use.
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plans must work around and preserve and protect that special 

use, In structure and purpose, the Wild Free-Roaming Horses 

and Burros Act is nothing more than a land use regulation 

enacted by Congress to ensure the survival of a particular 

species of wildlife. Free roaming wild horses/burros are 

protected as a non-game wildlife species of special concern.

Wild Horses The Government Accountability Office in 1990 reported that 

wild horse removals did not significantly improve range 

conditions, pointing to millions of cattle as the culprit as they 

greatly outnumber wild horses and burros on our western 

public lands. If BLM wishes to protect rangeland from further 

deterioration and restore a thriving natural ecological balance, 

they should seriously consider removing livestock from 

designated wild horse areas.

The 1990 Government Accountability Office Report concluded, 

"With nearly 60 percent of Federal rangelands in unsatisfactory 

condition, improvements are needed. In this context, wild horse 

removals based on reliable carrying capacity and range 

condition data make sense. However, our work during this and 

several previous reviews demonstrates that reliance on wild 

horse removals alone to improve range conditions cannot work. 

Since domestic livestock substantially outnumber wild horses on 

Federal rangelands and are a primary cause of range 

deterioration, any strategy for rangeland improvement must also 

include plans for improving the management of livestock to give 

the native vegetation more opportunity to grow and as necessary 

reducing authorized livestock grazing levels. Since wild horse 

removal and livestock grazing reduction decisions need to be 

based on reasonably up to date carrying capacity and range 

condition data, efforts to develop these data need to move 

ahead without delay. Moreover, once data are developed, we 

believe BLM needs to pursue the actions suggested by the data, 

both for wild horses and domestic livestock. Wild horse removal 

levels based on these data may be less than historic levels. To 

this end, we believe BLM'S decision to manage wild horse 

removals based on the number that can be adopted is prudent. “

In the 2008 Report, the Government Accountability Office 

concluded, "BLM has made significant progress in setting and 

meeting Appropriate Management Level for the Herd 

Management Areas. Our 1990 report was critical of BLM’s 

decisions on the number of wild horses and burros to remove 

from the range. At that time, we concluded that the decisions 

were made without adequate information about range carrying 

capacity or the impact of the animals on range conditions. Since 

then, in August 2005, BLM updated its formal policy on gathers 

and removals and specified the key factors that should be 
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considered in the decision making process. Since the passage of 

the 1971 act, there has been controversy over the number of 

wild horses and burros that BLM manages in the wild and the 

amount of public land available for their management. There is 

concern by some, including wild horse and burro advocacy 

groups, that the number of animals managed in the wild is too 

low to protect their genetic integrity; that the numbers are based 

on insufficient rangeland monitoring data; and that BLM gives 

preference to other users of the range, primarily livestock and 

wildlife. For instance, groups often point out that BLM permits far 

more cattle and sheep to graze on BLM-managed lands than 

horses. Specifically, in fiscal year 2007, approximately 567,000 

head of cattle or sheep grazed BLM public lands. However, 

livestock are managed on 160 million acres of BLM lands, 

compared to the 29 million BLM acres that are available for wild 

horses and burros."

The 1990 GOA Report was a report on the National Wild Horse 

and Burro Program level and was general in addressing 

conditions of rangelands and wild horse and livestock 

management. The Draft RMP/EIS and Final EIS specifically 

addressed conditions and management within the planning area. 

Neither the Draft RMP/EIS nor the Final EIS proposes 

eliminating livestock grazing in the Saylor Creek Herd 

Management Area. However, Alternative VI (Proposed RMP) 

would allow consideration of reducing or eliminating domestic 

livestock grazing if monitoring data suggests those measures 

were necessary to achieve resource objectives, including those 

described for wild horses.

Wild Horses I put forth that now is the time to match the agency's rhetoric 

with actions by implementing a humane and progressive 

management program for the Saylor Creek mustangs before it 

is too late.

The Senate directed the BLM to develop a new comprehensive 

long-term plan for wild horse populations. The time has come 

to implement a sustainable plan to preserve OUR wild herds on 

OUR Western public lands (not non-reproducing herds in the 

east) and restore their protections set forth in the 1971 Wild 

In February 2011, the BLM released "Details of the BLM’s 

Proposed Strategy for Future Management of America’s Wild 

Horses and Burros" and "Caring for America’s Wild Horses and 

Burros: Fundamental Reforms—An Overview". This national 

initiative would create a cost-efficient and sustainable Wild Horse 

and Burro Program. Over time, implementation of the 

Secretary’s initiative would reduce the number of wild horses 

and burros in short-term corrals or long-term pastures; reduce 

the costs to the American taxpayer for their care; and conserve, 

protect, and manage these animals in the West for future 
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Free-Roaming Horse and Burro Act allowing these magnificent

animals to live in peace on their rightful ranges. This “new 

direction” needs to be taken to save our national heritage from 

the managed extinction plans of the BLM.

generations to enjoy.

Specific to the Saylor Creek Herd Management Area, a more 

detailed Herd Management Area plan will be developed following 

the Record of Decision. 

Wild Horses The BLM's wild horse program is costing taxpayers millions 

and is destroying America's wild horse and burro herds. I am 

demanding that you stop all round-ups until a National 

Academy of Science review is completed. We want real, 

accurate numbers; numbers=science! Then, we want to 

conduct a full congressional investigation with advocate 

testimony at which point humane, responsible and innovative 

reform will be wholeheartedly considered and put in place. It is 

time to listen to the American people.

Addressing national policy regarding wild horse gathers is 

beyond the scope of this planning effort. BLM is required to 

follow current policy and regulation, if policy changes occur 

following completion of the Final EIS, the RMP would be 

amended as necessary.

Wild Horses In preparing the Final EIS, please take this opportunity to make 

corrections to manage a true “thriving ecological balance” by 

reducing the ever-increasing numbers of livestock and 

supporting a viable number of wild horses within this Herd 

Management Area who have been allocated a 

disproportionately low percentage of resources. Include buffer 

zones, natural barriers and predators in your plan and allow 

the wild horses to fill their niche and naturally self-stabilize. 

This would eliminate the need for helicopter roundups and 

removals.

The Final EIS analyzed a range of wild horse herd sizes. Under 

Alternative VI (the Proposed RMP), the Saylor Creek Wild Horse 

Herd Management Area (HMA) would be managed for a thriving 

natural ecological balance, with a herd of 50 to 200 wild horses. 

While the HMA would remain open to livestock grazing, grazing 

levels on an allotment-specific basis would be adjusted if 

monitoring demonstrated it to be necessary to maintain the 

health and welfare of the wild horse herd.

Wilderness and

Wilderness 

Study Areas

Key management prescriptions applicable to Wilderness Study 

Areas should be specifically detailed in the RMP. The Draft 

RMP should also fulfill the requirements of Instruction 

Memorandum ID-2008-016 in terms of documenting preFederal Land Policy and Management Act of 1976 uses and 

future monitoring for motorized vehicles, as well as 

commitments to adjust management of motorized use if 

impairment of wilderness character is occurring.

The only remaining Wilderness Study Area (WSA) in the 

planning area is the Lower Salmon Falls Creek WSA. One 

documented instance of off-highway vehicle impairment for the 

Lower Salmon Falls Creek WSA exists. BLM manages the WSA 

in accordance with BLM Manual 6330, Management of BLM 

Wilderness Study Areas. This manual became effective in 

August 2012.

Wilderness and

Wilderness 

Study Areas

A number of areas in the planning area have been designated 

as wilderness through the Omnibus Public Lands Act of 2009. 

However, these areas are not acknowledged in the 

management section of the Draft RMP. Again, we are aware 

that there is a management plan currently being developed for 

Wilderness within Owyhee County, but it is unclear if there is a 

need to develop a separate plan. The RMP should identify the 

Congress designated one wilderness area in the planning area, 

the Bruneau-Jarbidge Rivers Wilderness (Omnibus Public Lands 

Management Act of 2009, P.L. 111-11). The 89,996-acre 

Bruneau-Jarbidge Rivers Wilderness will be managed in 

accordance with the Wilderness Act of 1964, the enabling 

legislation, regulations for wilderness management at 43 CFR 

6300, BLM Manuals 8560 and 8561, BLM Handbook H-8560-1, 
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recently designated Wilderness areas and provide for 

preparation of wilderness management plans for each area.

and the Owyhee Canyonlands Wilderness and Wild and Scenic 

Rivers Management Plan which will be prepared by the BLM 

(WD-C-MA- 1). The Final EIS included the Bruneau-Jarbidge 

Rivers Wilderness Area.

Wilderness and

Wilderness 

Study Areas

BLM must consider all lands that may be adjacent to 

designated Wilderness as potential Wilderness Study Area

lands, as well as adjacent to US Forest Service lands where 

the total would be significant. A complete and thorough 

inventory must be done, including significant wild land areas 

less than 5000 acres in size. There are several areas in or near 

China Mountain, Dave Creek and other areas that, although 

small in size, should be considered for Wilderness status due 

to the very appealing, scenic and beautiful character of the 

land. We look forward to seeing Secretarial Order 3310 and 

the new guidance on inventory and planning incorporated into 

the Jarbidge RMP.

On December 22, 2010, the Secretary of the Department of the 

Interior issued Order 3310 to address the BLM’s management of

wilderness resources under its jurisdiction and to use the land 

use planning process to designate certain Lands with Wilderness 

Characteristics as “Wild Lands.” On April 14, 2011, the US

Congress passed the Department of Defense and Full-Year 

Continuing Appropriations Act (Public Law 112-10) (2011 CR), 

which includes a provision (Section 1769) that prohibits the use 

of appropriated funds to implement, administer, or enforce 

Secretarial Order 3310.

On June 1, 2011, the Secretary issued Instruction Memorandum 

2011-154 to the BLM Director that in part affirms BLM’s 

obligations relating to wilderness characteristics under Sections 

201 and 202 of the Federal Land Policy and Management Act of 

1976 (Public Law 94-579, 1976). This Instruction Memorandum 

further clarifies that the requirements of Sections 201 and 202 of 

the Federal Land Policy and Management Act of 1976 remain in 

effect. It also provided direction on how to conduct and maintain 

wilderness characteristics inventories and how to consider Lands 

with Wilderness Characteristics in the land use planning 

process. 

The Final EIS included an inventory for Lands with Wilderness 

Characteristics, which followed direction of this Instruction 

Memorandum and BLM Manual 6310. The wilderness 

characteristics inventory inventoried lands within the planning 

area.

Wilderness and

Wilderness 

Study Areas

Designating even more of the area as wilderness and locking 

out access is unacceptable.

Designation of wilderness is outside the scope of the RMP.

Wilderness and

Wilderness 

Study Areas

There seems to be a considerable amount of confusion 

concerning exactly where the downstream end of the Salmon 

Falls Creek Wilderness Study Area is located and what 

segments are eligible/suitable Wild and Scenic River's with 

The Lower Salmon Falls Creek Wilderness Study Area is located 

downstream from Salmon Falls Creek Dam to the Lilly Grade 

crossing (see Map 145 in the Final EIS). The Salmon Falls

Creek Area of Critical Environmental Concern (ACEC) is located 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Scenic Outstandingly Remarkable Value’s. The websites for 

the Burley (in 2008) and Jarbidge (in 2009) BLM offices have 

previously listed the downstream end as being Lilly Grade. Yet 

the Draft RMP/EIS lists the downstream end as being the start 

of Balanced Rock Park (p. A-256). 

downstream from the Salmon Falls Creek Dam to the upstream 

end of Balanced Rock Park (see Map 142 in the Final EIS). Map 

146 “Wild and Scenic River Segments” in the Final EIS display 

the “eligible” portion of Salmon Falls Creek. The ACEC and 

eligible Wild and Scenic River segments of Salmon Falls Creek 

are all above Balanced Rock Park. There has been no change in 

these boundaries since the ACEC designation in 1990.

Wilderness and

Wilderness 

Study Areas

Language in Omnibus Public Land Management Act of 2009 

clearly intended that lands not included in wilderness were to 

be released to multiple uses within Owyhee County. The RMP 

should honor the bargain that Congress made. I believe any 

additional wilderness areas or Wilderness Study Areas in Idaho 

should be put on hold. 

The Final EIS does not propose creating additional Wilderness 

Study Areas (WSAs). After passage of Omnibus Public Land 

Management Act of 2009, the only designated WSA remaining in 

the planning area is the Lower Salmon Falls WSA, which is 

common to all alternatives. 

Wilderness and

Wilderness 

Study Areas

The BLM wants to manage some non-wilderness areas for 

their Wilderness characteristics. These lands are not 

Wilderness; they have been managed as multiple use lands 

forever. Some do not even meet the criteria for Wilderness 

Designation. Alternative IV, the preferred alternative lists 

53,000 acres to be included in this designation. The BLM 

states these areas will be "closed to motorized travel". Yes, 

they would manage them as Wilderness. The Monument 

Springs road, a graveled well-traveled main road goes through 

the middle of one of these proposed Wilderness Study Areas.

Regarding Lands with Wilderness Characteristics, Section 201 of 

the Federal Land Policy and Management Act of 1976 (FLPMA) 

requires the Secretary of the Interior to "prepare and maintain on 

a continuing basis an inventory of all public lands and their 

resource and other values." Consistent with FLPMA and the 

BLM Land Use Planning Handbook (H-1601-1), the Jarbidge 

RMP Team evaluated and identified BLM-managed Lands with 

Wilderness Characteristics outside the existing wilderness and 

Wilderness Study Area. The Final EIS revised the inventory of 

Lands with Wilderness Characteristics following the direction in 

BLM Instruction Memorandum 2011-154 and BLM Manual 6310. 

The Final EIS analyzed a range of Lands with Wilderness 

Characteristics and associated management. Alternative VI 

(Proposed RMP) does not propose to manage inventoried Lands 

with Wilderness Characteristics to maintain their wilderness 

character (WC-VI-G-1). Note: The Monument Springs Road 

formed the boundary between two separate areas.

Wilderness and

Wilderness 

Study Areas

The preferred alternative has failed to analyze what the impact 

would be to establishing Wilderness Study Areas or lands 

managed in that fashion, the impact being local access, 

hunting, recreation, grazing while maintaining compliance with 

national priorities like renewable energy development.

The Final EIS cumulative impact analysis includes Wilderness 

Study Areas and Lands with Wilderness Characteristics within 

and adjacent to the planning area. Impacts to ranchers, local 

residents, and recreationists are addressed in the Social and 

Economic Features section. 

Wilderness and 

Wilderness 

Study Areas

I have driven most of the roads in the area including the Little 

House Creek drainage, Monument Springs, Devils Creek, all 

the roads on Brown Bench, over to the Bruneau overlook, 

Clover Creek, Sailor Cap and many others. Without motorized 

Designating wilderness is beyond the scope and authority of this 

planning effort. The travel planning process designates routes, 

roads, and trails.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

access to these areas, I would not have been able to 

experience the beauty, the wildlife, and this unique country. 

This area should not be Wilderness or have restricted 

motorized access. It should be open for all to use.

Wilderness and 

Wilderness 

Study Areas

The Final EIS should clarify whether the northern end of the 

Lower Salmon Falls Creek Wilderness Study Area could 

impose restrictions on realignment of the county road along 

Lilly Grade and, if so, accommodate the potential for road 

realignment that would be necessary for large truck traffic.

This is beyond the scope of this planning effort. Road realignment is a site-specific project and not a RMP level decision.

Wilderness and 

Wilderness 

Study Areas

The Non-Wilderness Study Area Lands with Wilderness 

Characteristics section of the Draft RMP/EIS should be 

expanded to address the value and need for the identified 

lands with wilderness characteristics. Additionally, there should 

be a further discussion of roads within these potential 5,000 

acre or greater blocks of land. BLM apparently believes that 

fences, reservoirs, and meteorological towers do not detract 

from naturalness. 

The Final EIS included an inventory for Lands with Wilderness 

Characteristics which followed direction in BLM Manual 6310 

(Conducting Wilderness Characteristics Inventory on BLM 

Lands). Each of the areas identified in the wilderness 

characteristics inventory met the criteria set forth in BLM Manual 

6310. In accordance with the inventory direction, the presence of 

fences, stock ponds, and other man-made features may be 

considered substantially unnoticeable and do not automatically 

disqualify an area from consideration. The Final EIS analyzed a 

reasonable range of alternatives addressing Lands with 

Wilderness Characteristics. Alternative VI (Proposed RMP) does 

not manage inventoried Lands with Wilderness Characteristics to 

maintain their wilderness character. 

Wilderness and 

Wilderness 

Study Areas

Do wilderness areas necessarily need to be very large? 

Perhaps they can be relatively small and still protect what is 

aesthetically appealing, archaeologically unique, and 

ecologically most valuable.

Congress determines the size of wilderness areas during the 

designation process. Such determinations are beyond the scope 

of this planning process.

Wilderness and 

Wilderness 

Study Areas

Management action AAV-CA-MA-1 under Air and Atmospheric 

Values manages the planning area as a Class II air shed. The 

Bruneau-Jarbidge Rivers Wilderness is also in the planning 

area. Wilderness typically requires a Class I air shed 

designation. This management action should be revised to 

reflect the Omnibus Public Land Management Act of 2009 

designations.

All BLM-managed lands in the planning area are designated as a 

Class II air shed unless reclassified by the State through the 

process prescribed in the Clean Air Act. Omnibus Public Land 

Management Act of 2009 did not designate the BruneauJarbidge Rivers Wilderness as a Class I air shed.

Wilderness and 

Wilderness 

Study Areas

The Travel Route designations in Alternative V are clearly 

preferable for a Wilderness experience in the near linear and 

narrow Wilderness areas of the planning area. How do the 

sights and sounds of vehicles, coupled with livestock activities, 

intrude on wilderness areas? On untrammeled view sheds, 

solitude? Primitive and unconfined recreation? What 

“The fact that non-wilderness activities or uses can be seen or 

heard from areas within a wilderness area designated by this 

subtitle shall not preclude the conduct of those activities or uses 

outside the boundary of the wilderness area” (Omnibus Public 

Land Management Act 2009 Sec.1503-10-B; 43 U.S.C. 1712). 

Nothing in this subtitle restricts or precludes low-level over flights 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

cumulative or indirect adverse intrusions -such as military over 

flights - add to the disturbance footprint in the wilderness 

areas?

of military aircraft over the areas designated as wilderness. 

Wilderness and 

Wilderness 

Study Areas

The planning area is a beautiful and one-of-a-kind place that 

should be maintained as protected habitat and wilderness.

Congress designates wilderness and this is outside the scope of 

the RMP.

Wildland Fire 

Ecology and 

Management

Fire management is a growing concern with climate change 

and with the recent fire history in the planning area. However, 

excessive fuel reduction efforts can cause damage, and the 

cost effectiveness of fire management activities needs close 

examination. The combination of fuel treatment management 

actions in Alternative V will reduce Relative Risk Ratings while 

preserving existing habitat. Therefore, the BLM should use the 

fire suppression guidance identified in Alternative V. The BLM 

should assess the relative effectiveness of fuels treatments at 

preventing wildland fire, and develop metrics for assessing the 

cost effectiveness, including the costs in both dollars and in 

lost ecosystem health.

The Final EIS analyzed a range of alternatives for fire and fuels 

management. Alternative VI (Proposed RMP) included a 

combination of elements from each of the other alternatives. 

The Final EIS, Chapter 2, Monitoring Implementation and 

Effectiveness of RMP Decisions section outlines a monitoring 

strategy for assessing the implementation and effectiveness of 

RMP decisions in meeting resource goals and objectives. This 

section identifies resources/resource uses, monitoring strategies, 

and monitoring intervals as required for land use plans (43 CFR 

1610.4-9).

Wildland Fire 

Ecology and 

Management

Classify the entire area for critical suppression. The Clover, 

Murphy and Long Butte Fires are proof that wildland fire moves 

very rapidly across the planning area. If a fire starts within what 

the Draft RMP/EIS calls a "conditional suppression area" it can 

and will move rapidly to areas classified for "critical response."

If multiple fires occur critical suppression areas have a higher 

priority based on values but every fire is evaluated as to potential 

and receives a commensurate response. 

Wildland Fire 

Ecology and 

Management

Reconsider the risk rating for the residential area along Bell 

Rapids Road. There are many homes bordering BLM ground 

or within 1/4 mile of it.

The Final EIS based the hazard risk rating for wildland urban 

interface on fuels, fire occurrence, and population density. The 

hazard risk rating classified the area along Bell Rapids Road as 

a moderate risk area; the area is a critical suppression area in all 

of the action alternatives. As a result, if a fire occurs near Bell 

Rapids, the BLM will prioritize its fire response to protect life and 

property.

Wildland Fire 

Ecology and 

Management

Fire suppression should concentrate on sensitive areas 

including but not limited to big game winter range, sage-grouse

habitat, and slickspot peppergrass habitat.

The Final EIS analyzed a range of fire suppression priorities. 

Alternative VI (Proposed RMP) identifies habitat for slickspot 

peppergrass, critical habitat for bull trout, and key sage-grouse 

habitat as critical suppression areas. These areas overlap 

substantially with big game winter range.

Wildland Fire 

Ecology and 

Management

Roads should be developed and maintained to allow fire 

equipment to respond quickly to minimize the response time.

The Final EIS addressed roads for fire management in the range 

of alternatives, specifically in Alternative III and in Alternative VI 

(Proposed RMP) under management action WFM-VI-MA-6.

Wildland Fire The State strongly urges the BLM to adopt the more The Final EIS analyzed a range of options for fire suppression 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Ecology and 

Management

aggressive fire suppression actions contained in Alternative III 

as part of any final alternative. BLM's primary rationale for 

selecting Alternative IV-B as the preferred alternative is to 

protect native upland and riparian/wetland habitat for fish and 

wildlife resources. However, BLM will not achieve this objective 

unless BLM augments the preferred alternative with the 

necessary tools contained in Alternative III, as wildfire is the 

most responsible agent for negatively affecting the native 

habitat that supports shrub-steppe obligate species like the 

Greater sage-grouse. 

and reduction while protecting resources. Alternative VI 

(Proposed RMP) was developed as a mix of the other 

alternatives to restore the ability of the ecosystem to recover 

following a disturbance and reduce fragmentation of habitat for 

sage-grouse and other native species.

Wildland Fire 

Ecology and 

Management

The third paragraph on p. 4-152 of the Draft RMP/EIS that 

addresses fire suppression actions does not address livestock 

grazing as a tool to remove the fine fuels. Address livestock 

grazing on a landscape scale, since a majority of the area is 

grazed. Recent research states: "Moderate levels of long-term 

cattle grazing have significant impacts on fuel characteristics 

and subsequently may alter the risk, size, severity and 

continuity of wildfires on sagebrush rangelands" (Davies et al., 

2010).

The Draft RMP/EIS analyzed the effects of livestock grazing on 

fine fuels (Chapter 4, Livestock Grazing, p. 4-472). The effects of 

grazing in fine fuels were included in the analysis for all action 

alternatives. The toolbox of fuels treatments considered targeted 

grazing. The Final EIS analyzed the impacts of livestock grazing 

on wildland fire ecology and management. 

Wildland Fire 

Ecology and 

Management

The Livestock Grazing section states: the analysis under 

Upland Vegetation and Noxious Weeds and Invasive Plants

sections showed no change to vegetation from grazing, and 

that there would be no change to the Fire Regime Condition 

Class from grazing. This section needs to be re-analyzed with 

the new information in the article (Davies et al., 2010) that 

states: "Moderate livestock grazing reduces the risk of wildfires 

on sagebrush rangelands by decreasing the amount of fine 

fuels available for ignition and limiting potential fire spread by 

reducing fine fuel continuity, accumulation and height".

The impacts analysis in the Wildland Fire Ecology and 

Management section in the Draft RMP/EIS, Chapter 4, included 

an explanation of the Fire Regime Condition Class (FRCC) 

methodology used in the analysis. The referenced sentence 

begins “For example if the analysis under Upland ...”. The 

identified sentence gives an example scenario and does not 

suggest that grazing had no effects on fuels. However, if the 

vegetative component does not change relative to the historical 

reference vegetation then the FRCC would not change since 

FRCC is a measure of departure from the historical condition in 

both fire regime and vegetation. FRCC is not a direct measure of 

fire behavior or a fuel complex. The Final EIS also analyzed the 

effects of grazing in decreasing fire size. Fire Research and 

Management Exchange System (www.frames.gov) and the 

Interagency Fire Regime Condition Class Guidebook provide 

more information on FRCC. 

Wildland Fire 

Ecology and 

Management

Modify table 4-178 if grazing does have an effect on the Fire 

Regime Condition Class. 

The Final EIS in Chapter 4 Wildland Fire Ecology and 

Management section indicates that livestock grazing does have 

an effect on Fire Regime Condition Class (FRCC) ratings. The 

referenced table in the Draft RMP/EIS, Table 4-178, also 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

indicated grazing had an effect on FRCC.

Wildland Fire 

Ecology and 

Management

The BLM should consider the use of additional grazing, 

including increased utilization, as a tool to reduce fuels and 

support fire reduction. 

The Final EIS analyzed the effects of forage allocation on fuel 

loading and management. In addition to authorized livestock 

grazing, the Final EIS identified targeted grazing as an additional 

tool for manipulating fine fuel loading and vegetative continuity. 

Alternative VI (Proposed RMP), management actions UV-VI-MA23 and FE-VI-MA-4, allowed for targeted grazing.

Wildland Fire 

Ecology and 

Management

The Resource Advisory Council unanimously supports adding 

WFM-IV-MA 10 with language that addresses large fire 

prevention and suppression actions.

The management actions in the Wildland Fire Ecology and 

Management section focus on fire suppression rather than fire 

prevention. Develop alternatives for large fire prevention by 

employing management techniques that reduce fuel availability 

in critical zones, expand natural and manmade firebreaks in 

strategic locations and use active vegetation manipulation to 

reduce the likelihood of large fires. Forage kochia has the 

potential to greatly aid in large fire control measures. When 

conditions are ripe for a fire or fires to become large fires, fire 

suppression should be paramount and the ordinary rule of "fire 

suppression consistent with other resource objectives" should 

be set aside.

The Final EIS analyzed a range of alternatives for fire prevention 

and suppression actions. The goal of Alternative VI (Proposed 

RMP) is to “Strive to reduce average wildland fire size, number 

of human-caused fire starts, and number of acres burned within 

and outside wildland urban interface throughout the planning 

area.” Every fire is evaluated as to potential and receives a 

commensurate response. All action alternatives in the Final EIS 

included management action WFM-CA-MA-9 to address fire 

prevention.

The use of specific species of plant in fuels treatments would be 

analyzed at the project level but Alternative VI (Proposed RMP) 

allows for the consideration of non-native species in 

management action FE-VI-MA-6.

Wildland Fire 

Ecology and 

Management

The Resource Advisory Council unanimously supports the 

following management actions versus the management actions 

of the preferred alternative.

Alternative I: Implement fuels treatments to reduce fuel loads 

with consideration for other resource and resource use 

objectives.

Alternative III: Fuels treatments in wildland urban interface 

would focus on areas with high, high/moderate, and moderate 

relative risk ratings in the northern portion of the planning area 

and near Roseworth and Three Creek. Fuel breaks would 

focus on strategic locations to disrupt the continuity of fuels 

and to protect structures and important resources such as 

habitat for sage-grouse and slickspot peppergrass.

The Final EIS analyzed a range of alternatives for fire prevention 

and suppression actions. The following management actions are 

included in Alternative VI (Proposed RMP).

FE-VI-MA- 1. Implement fuels treatments to reduce fuel loads 

with consideration for other resource objectives.

FE-VI-MA- 2. Fuels treatments in wildland urban interface (WUI) 

may include fuels reduction treatments and fuel breaks. Fuels 

treatments in WUI would focus on areas with high, 

high/moderate, and moderate relative risk ratings in the northern 

portion of the planning area and near Roseworth and Three 

Creek.

FE-VI-MA- 7. Fuel breaks would focus on strategic locations to 

disrupt the continuity of fuels and to protect structures and 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Unless more effective prevention/suppression of large-scale 

catastrophic fires is accomplished, many of the goals and 

actions of the Draft RMP/EIS will be meaningless. The success 

or failure of the Draft RMP/EIS will ultimately depend on fire 

management. The above management actions offer BLM the 

best means of reducing the chances of large-scale 

catastrophic fires.

important resources such as habitat for sage-grouse and 

slickspot peppergrass. Construct fuel breaks consistent with 

objectives in the Upland Vegetation section.

Wildland Fire 

Ecology and 

Management

The Draft RMP/EIS (p. 3-52) states, “Between 1987 and 2007, 

an average of 66,000 acres burned in the planning area each 

year, with a total of 1,394,000 acres burning during that 21-

year period. The number of acres burned each year varied 

from a low of 700 acres in 1993 to high of 505,000 acres in 

2007. The majority of the total acres (713,000) only burned 

once during this 21-year period. A total of 304,000 acres 

burned more than once.”

The Draft RMP/EIS states, “Fire Regime Condition Class 

(FRCC) 1 (low departure) is considered within the historic 

range of variability of a given Historic Fire Regime (HFR), while 

FRCC 2 (moderate departure) and FRCC 3 (high departure) 

are outside the historic range of variability.” Wyoming big 

sagebrush has an HFR of 35- 100+ years. It is reasonable to 

conclude that acreage within the planning area that has burned 

more than one time in the 21 years reported is outside HFR, 

and therefore assign an FRCC of 2 or 3 to that acreage. 

However, it is not reasonable, based on the description of HFR 

within the Draft RMP/EIS, to assign an FRCC of more than 1 to 

the acreage that has burned once, because normal fire 

frequency of 35-100+ years exists in sagebrush steppe habitat. 

Therefore, an FRCC class of 1 should apply to the approximate 

713,000 acres that only burned once. Additionally, since the 

Draft RMP/EIS states that native shrubland equates to the later 

seral stages, an FRCC of 1 would apply to nearly 390,000 

acres of shrubland. Yet these acreages do not appear in Table 

3-35 at p. 3-55. The Draft RMP/EIS also does not rationally 

explain how “uncharacteristic” S-Class is treated in the fire 

model, and does not contain a sample of the LANDFIRE model 

that was apparently used to classify the FRCCs.

Fire Regime Condition Class (FRCC) measures the departure 

from historical vegetation seral classes and fire frequency. The 

Final EIS, Wildland Fire Ecology and Management section

provides a brief discussion of FRCC. The Final EIS provided the 

source information used for determining successional class (SClass) reference conditions.

FRCC is a landscape-level assessment that evaluates the 

relative proportion of vegetation S-Classes. The determination is 

based on this proportion, not the mere presence of a single seral 

state within a defined area. Therefore, areas mapped as “native 

shrubland” do not necessarily qualify to be rated as FRCC 1. 

Uncharacteristic vegetation is not defined by model, but rather is 

considered vegetation that is a result of invasion (e.g. dominated 

by exotic invasive annuals) or human intervention (e.g. crested 

wheatgrass seedings) that would not occur through natural 

successional patterns (i.e. alternative stable states).

For the 713,000 acres, which have burned once, the vegetation 

would be in an early seral class and would be departed from the 

historical reference. However, as stated in the paragraph 

preceding Table 3-35 of the Draft RMP/EIS, "the results should 

not be interpreted to indicate the condition of each acre within a 

potential natural vegetation group as the FRCC rating applies to 

an entire potential natural vegetation group."
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Category Comment Response

Wildland Fire 

Ecology and 

Management

We have repeatedly commented on the many shortcomings 

associated with the use of the Fire Regime Condition Class 

(FRCC) 1, 2, 3 categories as a basis for credible land use 

planning in the context of the planning area.

FRCC was developed for forested large tree areas (like 

ponderosa pine forests). Inputs/supposed science on which 

disturbance intervals are based are ever changing and depend 

on whose research one believes. FRCC factors in this 

information. BLM than uses this to claim that lands need to be 

further disturbed, or they will be outside a historical range of 

disturbance. Plus, lands in FRCC 1 or 2 as BLM applies this 

loose, uncertain and ever changing fuel description system to 

sagebrush landscapes, typically have few shrubs and provide 

unsuitable habitat for nearly all native wildlife.

Fire Regime Condition Class (FRCC) classification techniques 

are well documented and supported. FRCC 1 would be assigned 

to a landscape-scale area where the current state of the 

vegetation resembles the historical state based on an 

understanding that the state is dynamic and would be comprised 

of different levels of vegetative succession. Even though 

classified as FRCC 1 the entire landscape would not be a 

homogeneous cover of mature sagebrush or a homogeneous 

cover of grasses, for example, but a composition of different 

seral states. BLM utilizes FRCC in subsequent fire planning as 

per BLM manual and handbook direction and it is appropriate to 

address in the Final EIS.

See http://www.frames.gov/partner-sites/frcc/frcc-home/. 

Wildland Fire 

Ecology and 

Management

It is likely that the fire disturbance interval used in preparation 

of the Draft RMP/EIS is now already outdated. Please review 

the W. L. Baker (2009) article in Knick and Connelly (2009) and 

other chapters discussing fire. What fire disturbance intervals is 

the Fire Regime Condition Class analysis based on? Will BLM 

update this and provide detailed analysis of how it arrived at 

claimed disturbance intervals in analysis of an expanded range 

of alternatives?

The fire return intervals in the Draft RMP/EIS were based on 

Hann and Bunnell (2001) and the Interagency Fire Regime 

Condition Class Guidebook Version 1.3.0 (Hann et al., 2004). 

Fire return intervals in Chapter 3 of the Final EIS, Wildland Fire 

Ecology and Management section, were updated using 

Interagency Fire Regime Condition Class Guidebook Version 3.0

(Barrett et al., 2010). The Final EIS described the assignment of 

historical fire regimes (HFR) to the potential natural vegetation 

group. Sagebrush communities are assigned a HFR from III to V 

depending on the community. HFR III and IV are a return interval 

of 35-200 years while HFR V is a 200+ interval. These fire 

disturbance intervals correspond with the article cited by William 

Baker. 

Wildland Fire 

Ecology and 

Management

We repeatedly brought up the flaws and shortcomings of Fire 

Regime Condition Class (FRCC) and BLM ignored these 

concerns. BLM must provide detailed analysis of how 

fire/disturbance and vegetation characteristics have changed 

since the FRCC analysis and alternatives development. BLM 

must provide a detailed appendix that lays this all out and 

explains in detail how they derived it. BLM must also provide 

mapping that shows the current 2011 FRCC categories for the 

field office. We have seen agency-accepted fire/disturbance 

intervals lengthened by 100% - just in the time the Draft 

RMP/EIS was prepared. The dire status of sage-grouse and 

Fire Regime Condition Class (FRCC) is an interagency, 

standardized tool for determining the degree of departure from 

reference condition vegetation, fuels and disturbance regimes. 

FRCC classification techniques are well documented and 

supported (see www.frames.gov). Assessing FRCC can help 

guide management objectives and set priorities for treatments. 

The Final EIS revised information related to wildfires and 

vegetation. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

the sagebrush ecosystem has resulted in much more critical 

examination of range scientists who BLM has relied on in the 

past. Range scientists who wrongly claimed fires were frequent 

(50-75 years or so) in many sagebrush communities.

Wildland Fire 

Ecology and 

Management

BLM does not adequately explain how Fire Regime Condition 

Class applies to all the exotic crested wheatgrass or coarse 

cultivar and cheatgrass lands.

Exotic plant species are by definition not a component of the 

historical vegetation and would result in or contribute to a 

departure from the reference condition (i.e., Fire Regime 

Condition Class 2 or 3). The Final EIS, Chapter 4 Upland 

Vegetation section, considers cultivars of native species as 

native.

Wildland Fire 

Ecology and 

Management

BLM has not provided necessary information and analysis on 

how sparse and simplistically vegetated, as well as how 

structurally simplified and desertified lands would be if 

managed under Fire Regime Condition Class (FRCC) 1 and 2. 

Lands would be nearly devoid of all species of sagebrushdependent wildlife. What species would thrive under each 

FRCC Class?

Fire Regime Condition Class (FRCC) is a measure of the 

departure from the historical fire regime and vegetation. 

Therefore, management actions that would lead to the historical 

vegetation and fire regime would lead to FRCC 1. Management 

actions that would lead away from the historical vegetation and 

fire regime would lead towards FRCC 3. FRCC does not provide 

specific management direction for a particular vegetation 

complex. FRCC 1 and 2 would not be structurally simplified and 

“desertified” as suggested in the comment.

Wildland Fire 

Ecology and 

Management

Why do Alternatives I and II show suppression primarily only in 

the wildland urban interface? This is not realistic in a Draft 

RMP/EIS that is to conserve sage-grouse. Since Fire Regime 

Condition Class (FRCC) requires a certain percentage of 

vegetation communities to be in the arbitrary and everchanging ideal "disturbed" states, to develop a range of 

alternatives based on FRCC results in BLM is considering 

many actions that everyone knows it will never adopt, and that 

are not realistic in the planning area over the next 20 years. 

How can BLM conserve sage-grouse with such limited 

suppression in the Proposed Alternative?

The purpose of the Final EIS is to analyze and provide overall 

management and long-term direction for lands and resources in 

the planning area. One of the many considerations is to promote 

diversity and resilience of biological resources including special 

status species. Each of the alternatives considered in detail had 

a different emphasis as described in Chapter 2 of the Final EIS. 

The BLM did not develop alternatives based on Fire Regime 

Condition Class results as suggested. As noted in the Draft 

RMP/EIS Preferred Alternative (Alternative IV) key sage-grouse 

habitat is one of the areas identified as critical suppression. The 

Final EIS, Alternative VI (Proposed RMP), identified key sagegrouse habitat as a critical suppression area. The objective for 

suppression actions in critical areas is to reduce fire size, reduce 

the number of human-caused fire starts, and reduce the number 

of acres burned. 

Wildland Fire 

Ecology and 

Management

Remove the entire Fire Regime Condition Class section. BLM 

under vegetation, wildlife, etc. should have a goal of full 

suppression across all alternatives, with protection of all 

existing and recovering native communities, surrounded by a 

5-mile buffer, being the highest priority to conserve and 

The Final EIS did not remove the Fire Regime Condition Class 

discussion. The Final EIS included a reasonable range of 

alternatives with differing goals, objectives, and management 

actions related to fire suppression actions. The Final EIS, 

Alternative VI (Proposed RMP), identified key sage-grouse 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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enhance sage-grouse habitats. habitat as a critical suppression area. The objective for 

suppression actions in critical areas is to reduce fire size, reduce 

the number of human-caused fire starts, and reduce the number 

of acres burned.

Wildland Fire 

Ecology and 

Management

The primary "fuels" treatments in the planning area aim at 

restoring annual grass and weed lands under all alternatives.

Fuels treatments target reduction of hazardous fuels in order to 

reduce fire size. Chapter 3, Noxious Weeds and Invasive Plants, 

considered both annual grasses and noxious weeds as 

hazardous fuel. The Upland Vegetation sections in Chapter 2 of 

the Final EIS outline the goals and objectives for vegetation 

treatments, including restoration treatments. 

Wildland Fire 

Ecology and 

Management

Fuel treatments are not effective in the planning area. All fuels 

treatments that reduce or simplify native vegetation should be 

greatly restricted. BLM uses fuel concerns to excuse/justify 

manipulation of native shrubs and trees to promote livestock 

forage. Often weedy flammable annual grasses thrive in the 

aftermath of fuels treatments, thus exacerbating wildfire 

concerns.

Fuel treatments in Alternative VI (Proposed RMP) would conform 

to the goals, objectives, and management actions in the 

Wildland Fire Ecology and Management, Upland Vegetation, and 

Noxious Weeds and Invasive Plants sections. Generally, the 

proposed goals and objectives for wildland fire are to reduce fire 

size, number, and to progress towards Fire Regime Condition 

Class 1. Goals for upland vegetation are to promote soil stability, 

water infiltration, nutrient cycling, and energy flow. Goals for 

noxious weeds and invasive plants are to prevent, eliminate or 

control these species. Management actions to implement these 

goals should promote a more resilient ecosystem.

Wildland Fire 

Ecology and 

Management

There are large irrigated meadows/pastures by Three Creek, 

as well as large irrigated areas near Rogerson. These irrigated 

areas form fuel breaks that are much more substantial and 

effective than anything BLM could do. Mapping and analysis 

must factor in what is actually present on these lands so the 

public can understand how limited the risk is in many of these 

areas. Massive habitat disturbance from fuel breaks and similar 

"treatments" would result under all alternatives.

The Final EIS does not propose any specific fuel breaks. 

Alternative III focuses on restoring the ecosystem through 

intensive management of fuels and enhanced fire suppression 

capabilities. Management actions for Alternative III did include 

an emphasis on fuel breaks; however, this and other alternatives 

did not propose any specific location for fuel breaks. If and when 

the BLM proposes to construct a fuel break, site-specific analysis 

would be completed and consideration would be given to the 

existing condition of the specific area. 

Wildland Fire 

Ecology and 

Management

Incorporate a full and science-based analysis of the impacts of 

livestock grazing in spreading flammable cheat grass in the 

discussion of fuels. Incorporate actions to significantly reduce 

livestock disturbances and promote micro biotic crusts.

The Final EIS addressed the impact of grazing on cheatgrass 

spread in the Chapter 4 Noxious Weeds and Invasive Plants

section, Impacts from Livestock Grazing Actions.

Wildland Fire 

Ecology and 

Management

Alternative V allows fuel breaks along designated roads and 

primitive roads. This means that there could be hundreds or 

even thousands of miles of fuel breaks of unknown widthdrastically adding to the adverse footprint and habitat 

fragmentation of the road network in the planning area. See 

The Final EIS analyzed a range of alternatives with differing 

goals, objectives, and management actions related to fire 

suppression actions. Alternative V would consider fuel breaks; it 

would not construct them along every designated road or 

primitive road. Alternative VI (Proposed RMP) does not propose 
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Draft RMP/EIS Map 56 that shows the appalling number and 

density of roads in the planning area.

roads as the main consideration in fuel break placement.

Wildland Fire 

Ecology and 

Management

The fuel break action that we support is replacement of largestatured coarse exotic and cultivar grasses with small native 

Poas and yarrow, while disturbing no native shrub 

communities. Consider this in an expanded range of 

alternatives that rely on removal of the vast coarse over-sized 

densely planted grasslands as a fuels and habitat action. 

Simply replace flammable and other exotics with small statured

natives. 

The Final EIS analyzed a range of alternatives with differing 

species allowed in fuel breaks. The BLM would decide and 

analyze the composition of a specific fuel break at the project 

level. Alternative V analyzed the use of native plants as the only 

material for use in fuel breaks.

Wildland Fire 

Ecology and 

Management

Page 3-52 of the Draft RMP/EIS shows BLM still obsesses 

over "fire fulfilling its role in the ecosystem and accomplishing 

resource objectives". The presentation of information in this 

section appears designed to minimize the severe effects of the 

fires - and the disaster that BLM's post-fire seedings have 

caused - in promoting repetitive fires. (See Table 3-31, 

Vegetation Management Area [VMA] A and B). These VMAs 

contain many of the harmful dense fire-promoting crested 

wheatgrass and other seedings.

The introductory paragraph merely depicts the current state of 

fire suppression within the planning area. All action alternatives 

in the Final EIS preclude Wildland Fire Use.

Wildland Fire 

Ecology and 

Management

Please describe in detail just what the Fire Regime Condition 

Class was in the lands before the Long Butte fire, the Clover 

Fire, and areas seeded after the Murphy fire.

The Final EIS determined baseline Fire Regime Condition Class 

(FRCC) at the landscape scale. The baseline FRCC accounted 

for fires through 2011. 

Wildland Fire 

Ecology and 

Management

We want to highlight p. 3-53 stating, "FRCC is a classification 

of the amount of departure from the Historic Fire Regime". 

Then, "Departure from HFR is based on comparison of current 

fire return interval and fire severity to the historical fire return 

interval and fire severity". In the case of the planning area 

where credible science would show fire might have burned on 

the average every 200 or more years, what is the interval BLM 

used? Then, if we super-impose "fire severity" on this - based 

on what is actually on the ground - we get much lower fire 

severity than in sagebrush communities.

Table 3-44 in the Final EIS displays the Historic Fire Regimes 

assigned to each potential natural vegetation group. Table 3-43 

shows the associated fire return interval for each Historic Fire 

Regime. 

Wildland Fire 

Ecology and 

Management

The (Fire Regime Condition Class [FRCC]) model appears to 

imply that the severity is based on potential natural 

communities (PNC) and whatever in the world a "VSG" is. 

Then, "HFR in the planning area was determined based on 

potential vegetation. HFR is further defined in the LANDFlRE 

models used to describe the planning area's HFR. Table 3-34 

assigns the potential natural vegetation groups ... from the 

VSG is Vegetation Sub-Group. Fire Regime Condition Class 

(FRCC) is a measure of the departure from the historical fire 

regime and vegetation. The historical fire regime is based on the 

fire return interval and fire severity, not potential vegetation. 

Potential natural communities are the potential vegetation 

community. This community may exist or historically existed 

within the planning area. Potential natural communities are
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LANDFlRE model to an HFR, PNC (based on information from 

SSURGO), and a VSG”. BLM further complicates this by a 

reference to "HFR” as defined in the cohesive strategy. All of 

this FRCC modeling confusion was designed to model timber 

country, not greatly altered coarse seedings and sagebrush.

assigned to a vegetation model, potential natural vegetation 

groups, which were developed for FRCC modeling. 

See http://www.frames.gov/partner-sites/frcc/frcc-home/ for

Interagency Fire Regime Condition Class Guidebook and further 

discussion and documentation of FRCC methodology.

Wildland Fire 

Ecology and 

Management

There is little evidence that the arbitrary categories in the 

Historic Fire Regime Definitions Table have any real relevance 

to understanding fires, controlling fires, or protecting sagegrouse habitat in the planning area.

The Historic Fire Regime Definitions Table in Chapter 3 of the 

Wildland Fire Ecology and Management section of the Final EIS 

identifies the Historic Fire Regime definitions used by BLM as 

defined by Hann and Bunnell (2001). The Final EIS presented 

this information because it was used in Fire Regime Condition 

Class analysis. 

Wildland Fire 

Ecology and 

Management

BLM’s artificial division of the planning area into the 

meaningless Vegetation Management Areas adds yet another 

arbitrary and artificial category to this all.

Due to differences in vegetation response to management and 

disturbance along a north-south gradient, Vegetation 

Management Areas divided the planning area based on potential 

natural community, elevation, and mean annual precipitation. 

This aids in the analysis in Chapter 4 and ultimately in 

implementation of management actions.

Wildland Fire 

Ecology and 

Management

The acres are no longer correct in Table 3-35 of the Draft 

RMP/EIS.

The Final EIS revised Chapter 3 to include updated vegetation 

data.

Wildland Fire 

Ecology and 

Management

Page 3-55 of the Draft RMP/EIS states that seral class (SClasses) had more influence than changes in fire frequency 

and severity in determining Fire Regime Condition Class 

ratings. Does this mean that the coarse woody grasses have 

burned more frequently? Does BLM consider crested 

wheatgrass and Siberian wheatgrass "successional"?

The statement that “S-Classes had more influence than the 

changes in fire frequency and severity in determining Fire 

Regime Condition Class (FRCC) ratings for each potential 

natural vegetation groups” does not mean that crested and 

Siberian wheatgrasses have burned more frequently. Crested 

wheatgrass and Siberian wheatgrass are not a component of the 

succession of vegetation for the potential natural vegetation 

groups described in the Final EIS. Crested wheatgrass and 

Siberian wheatgrass belong to the uncharacteristic succession 

class (S-Class U) in FRCC modeling.

Wildland Fire 

Ecology and 

Management

Page 3-55 states that fuel models do not account for fire return 

intervals, changes in landscape patterns, or length of fire 

season. What does? Did the Long Butte Fire just burn a great 

big hole in the Fire Regime Condition Class and fuels? There, 

the Vegetation Management Areas (northernmost part of the 

planning area), had 0 acres with an extreme spread rating. Yet 

the Lone Butte fire burned at an extreme rate, nearly 300,000 

acres in just 2 days.

Climate, weather, and topography play a large role in fire return 

intervals, changes in landscape patterns, and length of fire 

season. Models do not exactly duplicate all elements that 

influence fire behavior. The Fire Behavior Prediction System 

outputs are rate of spread, fire line intensity, British thermal units 

per square foot, and flame length. The models used do not 

produce outputs related to fire return intervals, changes in 

landscape patterns, or length of fire season as stated in the Final 
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EIS.

The Long Butte fire did not burn a hole in Fire Regime Condition 

Class (FRCC) and fuels modeling tables. The Long Butte fire 

burned an area that was primarily non-native vegetation so the 

FRCC did not substantially change post-fire. 

The adjective ratings, for example “extreme” are from the 

Standard Fire Behavior Fuel Models (Scott and Burgan, 2005) 

as assigned to each fuel model. As previously stated fuel models 

are not an exact duplicate of all elements that influence fire 

behavior.

Wildland Fire 

Ecology and 

Management

Why doesn't BLM have "number of fires" (not just humancaused) as an indicator?Chapter 4 of the Final EIS described the total number of fires 

and the number of human-caused fires. The planning area 

averages 23 fires per year, of which an average of 9 fires are 

caused by human actions. The Final EIS used the number of 

human-caused fires as an indicator for the analysis because it 

measures the effectiveness of management actions that reduce 

the number of fires caused by humans. There are no reasonable 

methods to reduce or alter the number of fires caused by 

lightning.

Wildland Fire 

Ecology and 

Management

On top of the jumble for the fire discussion from Chapter 3, 

BLM in Chapter 4 imposes the jumble of uncertainty from 

livestock grazing, recreation, travel, and claims impacts from 

management in the Vegetation Communities and Noxious 

Weeds and Invasive Plants sections were captured in Wildland 

Fire Ecology and Management. What does this mean?

See Section 4.1.1 How to Read This Chapter to understand how 

each section relates to the other sections in the analysis portion 

of the Final EIS. The Wildland Fire Ecology and Management

section analyzed impacts to fire management from management 

actions in the Upland Vegetation and Noxious Weeds and 

Invasive Plants sections from Chapter 2. 

Wildland Fire 

Ecology and 

Management

The Draft RMP/EIS, p. 4-472, states, "estimated utilization 

levels of non-native vegetation were compared between the 

alternatives". What is the basis for understanding utilization 

levels under any alternative? Please provide details. Then BLM 

states, "it was assumed that higher utilization levels in nonnative vegetation would have an immediate effect in 

decreasing fire size" and cites the Murphy Fire Report 

(Launchbaugh et al., 2008). Unfortunately, that is not what the 

Murphy report said. That report, and Steve Bunting in the BLM 

press conference, admitted that only under the cool, calm 

prescribed fire conditions does his modeling of grazing use

levels show any effect on fire behavior. These are not the 

Launchbaugh and others (2008) as cited in the Draft RMP/EIS 

(p. 4-472) states “Fire modeling revealed that grazing in 

grassland vegetation can reduce surface rate of spread and fireline intensity to a greater extent than in shrub land types. Under 

extreme conditions (low fuel moisture, high temperatures, and 

gusty winds), grazing applied at moderate utilization levels has 

limited or negligible effects on fire behavior. However, when 

weather and fuel-moisture conditions are less extreme, grazing 

may reduce the rate of spread and intensity of fires allowing for 

patchy burns and low levels of fuel consumption.” 

The report indicates that in the sagebrush models “The potential 
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conditions when wildfires naturally burn. This, it appears that 

BLM' s entire basis for analyzing fuels, the high levels of 

grazing and extreme number of treatments of Alternative III 

and targeted grazing in Alternative IV is based on the 

assumption that wildfires in the planning area burn under the 

cool, calm spring or fall temperatures and moisture conditions 

of prescribed fires! BLM's misleading and incorrect use of the 

Murphy Fire report is inexcusable. It is being done to ensure 

very high and harmful levels of use continue in the planning 

area.

role of grazing to reduce fuel loads and fire behavior is more 

feasible and effective under cooler and more humid conditions.” 

But in grass, the report states “The cheat grass and seeded 

grass models were run at 6, 8, 10, and 12 percent dead fuel 

moisture levels. Simulated grazing reduced measures of fire 

behavior at all fuel moisture levels, but was more pronounced 

under more moist conditions (that is higher dead fuel moisture 

values).” Although the cheatgrass and seeded grass models 

were nearly identical, all fire behavior variables were reduced by 

the lower grass volumes (that is, the ratio of surface area to 

volume) in the seeded grass model. This effect on grass volume 

was evident even at 6 percent dead fuel moisture, but it was 

more pronounced at higher dead fuel moisture values 

(Launchbaugh et al., 2008).

In major findings and lessons learned the report states “A few 

abrupt contrasts in burn severity coincided with apparent 

differences in actual use by livestock and other grazing factors, 

as illustrated by fence-line contrasts. Consequently, 

opportunities to influence fire behavior through livestock grazing 

are greatest in grassland vegetation types. Fire modeling 

suggests grazing in grassland vegetation can reduce surface 

rate of spread and fire line intensity to a greater extent than in 

shrub land types where woody fuels generally are not reduced 

by cattle or sheep grazing.”

Reduced fuel volume and loading contributes to reduced fire 

behavior especially in the fine fuels (Scott and Burgan, 2005).

Utilization levels were used for comparison purposes to estimate 

a relative effect of grazing on fuel loading and volume and 

therefore fire behavior and fire size (Table 4-170). The analysis 

was not based on season or particular weather scenario. 

Wildland Fire 

Ecology and 

Management

BLM cannot simplistically claim that limiting travel to roads 

alone is going to reduce fires. Very little off-highway vehicle offroad use occurs except on the hill outcrops in small sections in 

the north.

The Final EIS assumed increased motorized vehicle access 

increased the risk of human-caused wildland fires. Areas 

identified as open to cross-country motorized vehicle use would 

increase human-caused wildland fires. Areas identified as limited 

to designated routes or ways and areas closed to motorized 

vehicle use would decrease human-caused wildland fires.
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Wildland Fire 

Ecology and 

Management

What is the basis for analyzing the Land Use Authorizations – 

rights-of- way, oil and gas, geothermal, military activity, etc.? 

Pages 4-472 to 4-473 in reality say nothing concrete. Wouldn't 

large-scale oil and gas development increase flammable cheat 

grass and likelihood of explosions and other human-caused 

fires? So shouldn't BLM prohibit oil and gas development in all 

remaining sagebrush habitats and recovery/restoration habitats 

to protect the habitat?

The discussion in the Draft RMP/EIS discloses that BLM 

assumed, for purpose of analysis, that the potential for humancaused fires would increase based on the amount of area 

available for development. The Final EIS assumed increased 

activities associated with developments increased the risk of fire 

starts. 

Wildland Fire 

Ecology and 

Management

Page 4-47 of the Draft RMP/EIS states that vegetation 

treatments that change the current plant community could also 

change the fuel model and rate of spread. BLM predicts that 

under Alternative IV, vegetation treatments would affect the 

rate of spread on 5% of the planning area. How much of a 

difference will the rate of spread make? Where is a map that 

shows this bioengineering? Does this mean that 5% of the land 

area will be engineered for fuel breaks?

Vegetation treatments that change the current plant community 

could change the fuel model and rate of fire spread. The 5% is 

the amount of acreage that would see a decreased rate of 

spread resulting from all vegetation treatments within the 

alternative as identified in the Upland Vegetation section. The 

differential change in rates of spread was identified in the Draft 

RMP/EIS in Table 4-166 for Alternative IV (the Preferred 

Alternative). There is no map showing specific vegetation 

treatments since the Final EIS did not propose any specific 

treatments. 

Wildland Fire 

Ecology and 

Management

BLM somehow comes up with 916,000 acres "Improved" and 

claims it is more than any alternative. BLM must provide all 

acreages, livestock stocking rates, use levels, treatments, 

changes in cheat grass predicted over 20 years under 

Alternative IV. What does improved mean?

The term “improve” in this context refers to the changes in 

vegetation, as measured in acres, from the vegetation goals 

objectives and management actions and how those changes 

would match the composition of the potential natural vegetation 

group or the historical vegetation. Fire Regime Condition Class

(FRCC) measured the degree to which the changes would 

match the historical vegetation. FRCC 1 indicated the landscape 

meets the historical vegetation composition. The requested 

information on acreages, stocking rates, use levels, treatments, 

and changes in cheatgrass are not available and are not needed 

to make a choice among alternatives. The Final EIS will 

establish goals and objectives for future management. BLM’s 

future implementation level decisions will move on-the-ground 

conditions toward the established goals.

Wildland Fire 

Ecology and 

Management

What are the climate conditions (humidity, wind speed, fuel 

moisture, etc.) that are used in the predicted rate of spread? 

What percent cheat grass is in all the communities here? What 

is the vegetation that BLM assumes is in the fuel break?

The inputs used for the Fire Behavior Prediction System are 

dead fuel moistures of 3%, 4%, 5%; live fuel moistures of 30%; 

slope of 20%; and wind speed of 10 mph.

The vegetation data used for upland vegetation baseline and 

analysis in the Final EIS are an aggregation of plant communitylevel mapping with a 20-acre minimum mapping unit. Any area 
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with 50% or greater cover of annual species, including but not 

limited to cheatgrass, were classified as annual in both the 

community-level and aggregated classifications. The BLM does 

not have data on cheatgrass cover in all plant communities in 

areas where it does not comprise at least 50% of the vegetative 

cover. 

The BLM does not assume a specific composition of vegetation 

within any fuel break. Specific details of fuel breaks will be 

determined during the project level analysis. The only 

assumption is that the vegetation will meet the goals, objectives, 

and management actions of the alternative.

Wildland Fire 

Ecology and 

Management

How has military activity caused fires on both BLM and US Air 

Force (USAF) lands? How has the risk of military associated 

fires increased? BLM should work with the USAF on USAF

lands to develop fuel breaks. This is also likely to expand with 

increased use, use of white phosphorus, etc.

Fires that start on lands associated with the impact area of the 

Mountain Home Air Force Base are managed by the US Air 

Force (USAF) unless assistance is requested. BLM may respond 

to a fire report within the area but would coordinate with the 

USAF. Contact the USAF for information pertaining to those 

fires. 

The USAF has constructed a firebreak around the Saylor Creek 

Impact Area and they maintain it on a yearly basis. However, this 

is not the case with the Juniper Butte Training Range. The Final 

EIS analyzed a range of alternatives for wildland management 

firebreaks. Management action WFM-CA-MA- 7 in Alternative VI 

(Proposed RMP) addresses the issue and would allow the 

development of fuel breaks adjacent to USAF lands.

Wildland Fire 

Ecology and 

Management

Please provide analysis of risk of military flare-caused fires. 

Has BLM, since expansion of the US Air Force (USAF) 

Bombing Range, ever required the USAF to stop using flares 

during periods of very hot and dry conditions? How many fires 

have occurred on USAF lands from 1987 to the present? 

Where? This includes at least one fire in slickspot peppergrass 

habitat on Juniper Butte. Many of the roads and portions of 

accessing routes would go for days or weeks and receive no 

human motorized use except for the USAF. So what is the 

manner of use and disturbance to wildlands and wildlife that is 

actually occurring, and is foreseeable, over the life of this plan? 

How do military lights interfere with dark night skies?

Management of US Air Force (USAF) activities on USAF lands is 

beyond BLM authority. BLM does not record information 

regarding fires that occur in the impact area from military activity. 

BLM has recorded 67 fires between 1987 and 2011 on USAF

lands outside the impact area. Lightning caused the majority 

(65%) of the fires. Travel planning will analyze travel routes and 

access more thoroughly in the subsequent travel management 

plan. A specific analysis of military lights is beyond the scope of 

this planning effort, as the BLM does not have the authority to 

decide when and how much artificial light is used.
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Wildland Fire 

Ecology and 

Management

The Draft RMP/EIS Fire Vegetation mapping and data is 

outdated due to the Long Butte, China Mountain, and other 

fires. Create clear mapping and analysis for all sagebrush

seedings and rehabilitation actions and success (or failure) 

following Clover, Murphy, and subsequent fires that have 

occurred. Some measure and reporting of rehabilitation and 

other planting success based on monitoring of recent 

rehabilitation efforts must be provided.

The Final EIS revised the Draft RMP/EIS “Post-2007 Fire 

Vegetation” and “2012 Projected Vegetation (Baseline)” maps to 

include wildland fires, Emergency Stabilization and Burned Area 

Rehabilitation seedings, and fuel treatments through 2011. The 

new maps are the “Existing Vegetation as of 2011” and “2016 

Projected Vegetation” maps (Maps 9 and 10). 

Wildland Fire 

Ecology and 

Management

On what basis does BLM consider a seldom-occupied ranch, 

such as at Clover Creek, a wildand urban interface? 

Wildland urban interface data was created for the 2007 Idaho 

Interagency Assessment of Wildland Fire Risk to Communities

as identified in Chapter 3. The source was a geographic 

information system point layer of urban wildland communities 

identified in the Federal Register (66 Fed. Reg. 753, January 4, 

2001) and 2000 Census data which was processed by the 

Wildlife Spatial Analysis Lab, University of Montana.

Wildland Fire 

Ecology and 

Management

We note that Map M-26 shows sagebrush-shrub habitats in 

areas where BLM purposefully left them off the preceding key 

habitat map for sage-grouse.

The purpose of Map 26 in the Draft RMP/EIS is to show critical 

suppression areas in Alternative I. Map 26 shows wildand urban 

interface; Bruneau-Jarbidge Area of Critical Environmental 

Concern (ACEC), Lower Bruneau Canyon ACEC, Middle Snake 

ACEC, and Salmon Falls Creek, ACEC; and key sage-grouse 

habitats. The key sage-grouse habitat shown on Map 21 in the 

Draft RMP/EIS is only a subset of the critical suppression areas 

shown on Map 26.

Wildland Fire 

Ecology and 

Management

Alternative V is the minimum of suppression that should be 

done here. This should just be a part of all alternatives. 

Suppression areas for each alternative were developed based 

on the emphasis of the alternative described in Chapter 2.The 

amount of suppression areas continues to vary from alternative 

to alternative in the Final EIS.

Wildland Fire 

Ecology and 

Management

It makes no sense to include an alternative that would not 

place the single, small Horse Management Area as a priority 

for suppressing fires.

The Final EIS analyzed a range of alternatives concerning 

priority areas for fire suppression. Alternative VI (Proposed 

RMP) included the Saylor Creek Herd Management Area within

a Critical Suppression Area.

Wildland Fire 

Ecology and 

Management

Please read and include data from the article “Variation in the 

effects of vertebrate grazing on fire potential between 

grassland structural types” into the record for the Final EIS. It 

adds to the evidence refuting the livestock industry/BLM range 

conservationist grazing stops fire myth that pervades the 

deeply flawed Draft RMP/EIS.

The referenced study examines the degree to which vertebrate 

grazing affects the fire potential in native grasslands in Tasmania 

Australia. The grazing regime of natural grazers (wallaby) and 1 

sheep per 2 acres is not representative of the planning area. The 

study did not provide any additional information relevant to the 

analysis of impacts in the Final EIS.
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Wildlife Currently, WI-NA-MA-17 on p. 2-64, in the Wildlife section of 

Chapter 2 reads as follows: “Restrict occupancy for oil and gas 

activities in crucial wildlife habitats as is shown below...MidMarch through June within 0.25 miles of Western burrowing”. 

Our monitoring of breeding Burrowing Owls in northwestern 

Utah and northeastern Nevada for >10 years suggests that the 

seasonal protection for this species should instead be mid-April 

through July. Additionally, we would also recommend adding 

spatial protections of 0.5-mile radius for Prairie Falcons (April–

June), Ferruginous Hawks (April–early July), and Red-tailed 

Hawks (late March–early July) based on our recent 

assessment of the relationship between oil and gas 

development and nesting raptors in Utah and Wyoming (see 

BLM Technical Note 433; available online at: 

http://hawkwatch.org/images/stories/NewsEvents/BLMTN433-

2.pdf) and our research on breeding season windows for these 

species.

Management actions associated with the No Action Alternative 

cannot be changed because they are current management. The 

Final EIS updated the Wildlife section of Chapter 2 to reflect 

current Idaho BLM policy with respect to raptors nest sites and 

buffer distances. WI-CA-MA-5 defines the raptor seasonal period 

as February 1 through July 31 and modified the associated 

buffer distances. These time frames were adopted statewide 

Information Bulletin IB-ID-2010-39.

Wildlife On p. 2-123; LG-NA-MA-4: Livestock season of use would be 

adjusted in Multiple Use Areas 10, 15, and 16, if necessary, to 

resolve any conflicts on mule deer, pronghorn and bighorn 

sheep ranges. These adjustments would entail the reduction in 

spring of fall livestock grazing use from a specific period of a 

grazing year. What and where is the rational and/or support for 

this statement? What are the conflicts, how extensive might 

they be, and what might be the impact to the livestock 

producer, especially in light of the fact that this action might 

cause the loss of spring and fall grazing?

LG-NA-MA-4 was a management action for the current RMP, 

current management, and cannot be changed. The rationale was 

these Multiple Use Areas (11, 15, and 16) contained crucial 

winter range for mule deer, and pronghorn. The 1987 RMP did 

not specify conflicts or an extent of conflicts, but provided a 

mechanism to make changes, if necessary.

Wildlife On p. 2-141; LG-IV-MA-13: During big game calving, fawning 

and lambing, livestock grazing management would provide 

adequate cover for big game species; appropriate to site 

potential. Clarify this statement, does "would" mean should, 

must or something else?

In the Draft RMP/EIS, LG-IV-MA-13 “would” meant, “would” not 

could or should. 

Wildlife On p. 2-141; LG-IV-MA-14: Adjust livestock grazing so 

livestock season of use would not overlap bighorn sheep 

breeding and winter periods in those pastures that contain 

bighorn sheep habitat. Again, where is the rational and/or 

support for this statement? This definitely is a new, and I might 

add dangerous, management concept that the BLM seems to 

be initiating in the Draft RMP/EIS that could ultimately have 

The Final EIS updated Chapter 2. Due to public comment, 

Alternative VI (Proposed RMP) has no similar management 

action. The Final EIS modified SS-CA-MA-16 to require the 

identification of a conflict before changing a schedule to avoid 

wintering and lambing. In the planning area all bighorn lambing 

occurs in canyon areas not accessible to livestock. Bighorn 

winter habitat includes the canyon and adjoining plateaus. The 
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very negative impacts on livestock (cattle) use of Federal lands 

throughout the west. These and similar statements throughout 

the text must be based on scientific, provable assumptions, not 

agenda driven agency management decisions.

rationale for the management action was to minimize 

displacement or movement during critical time periods, due to 

livestock grazing, if problem was identified. Seasons of use or 

livestock class would only be changed following NEPA analysis 

(see LG-CA-MA-4).

Wildlife There have been no adequate studies of night-time migrants, 

little to no information on eagle populations across the region, 

and it is quite likely that the individuals from the same 

populations of migrating bats that will suffer mortality from 

Spring Valley or other Ely-Utah borderlands areas wind 

projects will be killed if China Mountain goes forward.

The China Mountain Wind Energy Project has been deferred 

until the Idaho/Southwest Montana Sub-regional Sage-Grouse 

Plan Amendment and the Jarbidge RMP have been completed 

and records of decision signed. Without baseline migratory 

movement information it is speculative to assume or discount 

additive migratory bat mortality for species moving through 

China Mountain to other areas.

Wildlife In section 2.3.6.2. Wildlife: The impacts of the mushrooming 

elk population need to be addressed (WI-CA-MA-4, p. 2-64). 

The elk are not only affecting our livestock operations, but the 

unchecked population will soon be displacing and adversely 

impacting other wildlife species.

In reference to WI-CA-MA-3 on p. 2-64; Idaho Department of 

Fish and Game and Nevada Department of Wildlife have not 

developed guidelines with public participation or NEPA 

analysis.

Based on public comments WI-CA-MA-4 “Management specific 

to elk would not be implemented unless requested by Idaho 

Department of Fish and Game (IDFG) or Nevada Department of 

Wildlife (NDOW); management actions for elk are allowed 

consistent with habitat management for priority wildlife species” 

in the Draft RMP/EIS was not carried forward. NDOW and IDFG

have authority to manage a variety of wildlife including elk. State 

wildlife agencies have their own authorities and processes to 

determine harvest, seasons and weapon type (archery muzzle 

loader, rifle) for hunted species. The BLM would analyze specific 

projects such as restoration of winter range at the project level, 

but would also be consistent with NDOW and IDFG plans for 

mule deer and other game species. 

Wildlife The Federal public land management agencies must also 

further identify and recognize the correlation between livestock 

grazing and the positive growth and health of wildlife. Many 

studies provide information that confirms that livestock grazing 

has many positive impacts on wildlife heath and quantities.

The Final EIS revised the Wildlife section of Chapter 4 to include

benefits to wildlife from livestock grazing. The commenter’s letter 

provided no literature or literature citations.

Wildlife WI-CA-MA-10—Wind energy-related activities can avoid or 

minimize disturbance to priority species and their habitat 

pursuant to the best management practices (Appendix N) and 

BLM’s Instruction Memoranda related to wildlife and migratory 

birds. Note this in the discussion of this management action.

Management action LA-C-MA-1 incorporated programmatic 

policies and design features from the Record of Decision on 

Wind Energy Development on BLM-Administered Lands in the 

Western United States to all alternatives (see Appendix B: Best 

Management Practices, Design Features, and Operating 

Procedures for best management practices for wind energy and 

other resource uses).
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

Wildlife On p. 2-62, we believe upland game nesting and cover habitat 

should be improved, not maintained, in the Multiple Use Areas 

in general in Map 4.

The objective referenced (WI-NA-O-1) was the objective from 

the current 1987 RMP. The wildlife objective in Alternative VI 

(Proposed RMP), WI-VI-O-1, states “maintain or improve wildlife 

habitat by managing uses and activities and actively restoring 

annual, non-native perennial, and native communities”. 

Wildlife Include areas designated on Map 20, Big Game Winter 

Restoration, as critical fire suppression areas. In short, without 

significant progress in controlling and suppressing wildfire, 

most of the preferred alternative's wildlife objectives are 

meaningless.

Alternatives I, III, IV and VI (Proposed RMP) identified key sagegrouse habitat as critical suppression areas to help protect 

remaining winter range and sagebrush habitat from wildfires. 

Wildlife Where grazing may impact portions of big game winter range 

due to potential competition for limited winter food and cover 

resources, existing tools as well as additional criteria that 

consider localized resource conditions can effectively resolve 

the issue.

Management actions in Alternative VI (Proposed RMP) (LG-VIMA-2, LG-VI-MA-9, and SS-CA-MA-11) produced flexibility to 

provide or manage residual cover for upland game and big game 

species. Through adaptive management, changes would be 

implemented if monitoring shows resource objectives were not 

being met.

Wildlife The Draft RMP/EIS refers to "bighorn sheep habitat". No 

definition or delineation of bighorn sheep habitat exists in the 

document. Idaho Department of Fish and Game recommends 

that the BLM designate bighorn sheep habitat consistent with 

the Idaho Big Horn Sheep Management Plan (2011). 

Consistency with this plan would define occupied habitat.

The Final EIS added Map 27 “Bighorn Sheep Habitat and 

Distribution” to delineate bighorn sheep habitat for the planning 

area. The identified area was consistent with the Idaho 

Department of Fish and Game (IDFG) (2010) Idaho Bighorn 

Sheep Management Plan. The electronic copy of the 2010 Plan 

on the IDFG web site mentions the 2010 plan was updated 

January 2011.

Wildlife The citation on p. 4-806 “Does Wildlife Threaten Extinction for 

Salmonids?” is incorrect. "Wildlife" should be "wildfire" in the 

Final EIS.

The Final EIS corrected this typographical error. 

Wildlife Idaho Department of Fish and Game (IDFG) raises the issue 

about the potential for livestock use of designated big game 

winter range during the winter due to potential competition for 

limited winter food and cover resources as a concern. To 

address this issue, IDFG suggests either inclusion of additional 

criteria for evaluation during the decision-making process 

including big game presence, weather severity, habitat 

condition and availability, and winter timing or we suggest 

some mechanism for the BLM consultation and consideration 

of circumstances with the relevant wildlife managers. IDFG 

offers our assistance for defining and evaluating these criteria 

as well as technical assistance for consultation and 

consideration.

Alternative VI (Proposed RMP) in the Final EIS provided various 

tools for use during evaluation of resources, including big game 

habitat, to determine allocations and specific grazing 

management practices that would maintain or enhance habitat 

values (see WI-CA-MA- 2, LG-CA-MA- 7, LG-VI-MA- 7, LG-VIMA-8, LG-VI-MA-9, and ACEC-VI-MA- 6). Additionally, Idaho 

Department of Fish and Game and other publics would have the 

opportunity to provide more site-specific comments and 

recommendations for big game or other wildlife during the permit 

renewal or specific proposed projects.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Wildlife On p. 3-24, the third paragraph in Big Game Winter Range 

Section, the last two sentences are more speculative 

statements than factual. Recommend to remove the two 

sentences.

The Final EIS removed the two sentences from the affected 

environment discussion. 

Wildlife On p. 3-25, Mountain Cottontail Rabbits section states in the 

last sentence that no monitoring data is available, but cottontail 

rabbit numbers have generally declined. This is a speculative 

statement since there is no factual data on cottontail rabbit 

populations. Remove the last sentence.

The Final EIS updated the Upland Game Section, specifically the 

mountain cottontail rabbit discussion, of Chapter 3.

Wildlife On p. 3-31, the first paragraph in Grassland Guild states that 

thirty three percent of the planning area is mapped as 

grasslands but only one percent should be grassland based on 

soil site description. This paragraph should explain that the 

majority of the grasslands are an early successes stage of a 

shrub community, which is the major community, based on soil 

site descriptions.

The Final EIS revised the discussion related to grasslands in 

Chapter 3 to acknowledge grasslands may be an early seral 

state to some other habitat.

Wildlife All places where the phrase "bighorn sheep habitat" is used 

should be replaced by the phrase "occupied bighorn sheep 

habitat" to prevent unnecessarily reducing forage availability 

for livestock.

Bighorn sheep habitat in the planning area is the portion of the 

Bruneau-Jarbidge bighorn population management unit. This 

conforms to the Idaho Department of Fish and Game bighorn 

sheep management plan. The Final EIS added Map 27 “Bighorn 

Sheep Habitat and Distribution” to delineate bighorn sheep 

habitat for the planning area. 

Wildlife The Resource Advisory Council unanimously supports that 

further consideration and analysis of wildlife tracts needs to be 

given in the Draft RMP/EIS, none of the alternatives presented 

appear to resolve the issue adequately.

The wildlife tracts are a leftover from the Desert Land Entry 

process. The original, l intention was to provide some residual 

level of wildlife habitat in areas approved for transfer to private 

hands for farming purposes. In some cases, water was to be 

provided to further aid in the creation of wildlife habitat. In 

recent years, the area has seen large tracts of farmland 

dewatered and returned to rangeland. The timing is ideal to 

reevaluate the current wildlife tracts and plan for the future. It 

would seem appropriate to consolidate acreage and 

concentrate it in areas most likely to support wildlife needs and 

benefit public recreation. The Draft RMP/EIS appears to give 

only superficial attention to the opportunities and challenges 

The Final EIS revised Chapters 3 and 4 with respect to the 

wildlife tracts. The Final EIS added Map 18 “Wildlife Tracts in the 

No Action Alternative and Alternatives I, II, III, IV, and V” to show 

changes in the wildlife tracts for the original alternatives and Map 

19 “Wildlife Tracts in Alternative VI (Proposed RMP)” for

Alternative VI. The following management actions specific to 

wildlife tracts appear in Alternative VI: WI-VI-MA-6. Establish 

desirable perennial grasses, forbs, and shrubs to improve habitat 

for upland game on wildlife tracts; WI-VI-MA-7. Upland game 

(pheasant, gray partridge, chukar, mourning dove and California 

quail) would be the primary focus for the Wildlife Tracts. All other 

authorizations would have to be consistent with improving 

habitat on tracts: WI-VI-MA-8. Prepare a new Wildlife Tract 

management plan with Idaho Department of Fish and Game, 

which outlines specific habitat improvement projects. Wildlife 

tracts were identified for retention in the Land Tenure section 

(see LT-CA-MA-3). 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

wildlife tracts present. Considerable flexibility on the part of the 

BLM will be required to achieve the necessary land trades if 

the value of these tracts for wildlife purposes is to be 

maximized. This section should be included or crossreferenced with the Land Tenure section.

Wildlife The representation that placement on the Species of Greatest 

Conservation Need (SGCN) “identifies the species as at risk for 

decline” is erroneous. Intermountain Range Consultants

addressed SGCN extensively in Comments to the AMS. The 

Draft RMP/EIS continues the same type of erroneous reporting 

as found in the Analysis of the Management Situation. 

The Final EIS revised the leopard dace discussion in the 

Chapter 3 Fish Section. The sentence now reads, “Idaho 

Department of Fish and Game (IDFG) Comprehensive Wildlife 

Conservation Strategy (2005) identified leopard dace as a 

Species of Greatest Conservation Need (SGCN). Leopard dace 

were included as a SGCN because of changes in taxonomy 

resulted in a lack of essential information pertaining to status 

(IDFG, 2005). The lack of essential information includes 

abundance and population trend (IDFG, 2005).” 

Wildlife A species may be included on the Species of Greatest 

Conservation Need for a number of reasons, “e.g., status 

under the Endangered Species Act, high threats, declining 

trend, disjunction population, isolated populations, restricted 

distribution, endemic to Idaho, taxonomic uniqueness, etc.” 

Idaho Department of Fish and Game (IDFG, 2005) p. 6. Please 

list the IDFG process and criteria for having a species included 

on this list.

Determining the Species of Greatest Conservation Need

(SGCN) was an Idaho Department of Fish and Game (IDFG)

process. Listing all the factors that may result in a species being 

qualified as a SGCN does not contribute to the affected 

environment. All the criteria can be reviewed on the IDFG’s web 

site http://fishandgame.idaho.gov/public/wildlife/cwcs/

Wildlife Chapter 3 of the Draft RMP/EIS, p. 3-23 states: “Nevada 

Department of Wildlife (NDOW) is managing for a herd for

1,000 elk in the Jarbidge Mountains (NDOW, 2000) and 

another 1,250 head in the Bruneau River area.” However, no 

source is cited regarding the “Bruneau River area”. This lack of 

disclosure makes it impossible for the public to present 

reasoned comment.

As to NDOW, 2000, the document states: “The elk population 

objective for this area will be to reach 1,000 adult animals by 

the year 2010. The population will be maintained at 1,000 adult 

animals plus or minus 10%.”

Further, Martin, 2007 (see reference citation below) does not 

support the Draft RMP/EIS statement. Martin, 2007 states: 

“The elk management targets are set at 1,000 and 1,500 head 

for the two hunt units that border Idaho for a total of 2,500 elk.”

Since the release of the Draft RMP/EIS, the BLM contacted 

Nevada Department of Wildlife (NDOW), who provided updated

information (NDOW, 2012a). This information was included to 

revise the Nevada portions of the elk section in Chapter 3 for the 

Final EIS. The correction includes NDOWs current population 

targets for both Jarbidge and Bruneau River elk herds. The 

Bruneau River area refers to the Nevada hunt units 61 and 71. 

Jarbidge Mountain area refers to Nevada hunt units 72 and 74. 

The planning area contains only a small portion of any Nevada

hunt units. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-672

Category Comment Response

Thus, there is a discrepancy between the unsupported Draft 

RMP/EIS representation of 1250 animals and the Martin, 2007 

representation of 1500 animals. Correct this and other 

discrepancies.

Wildlife This statement suggests elk consume primarily grass, with

some minor component of their diets composed of browse, and 

that they only turn to browse when the grass is covered by 

snow.

Peek (2003) does not classify elk diets in the manner stated in 

the Draft RMP/EIS. Peek (2003) did not suggest that elk only 

consume browse when snow covers the herbaceous 

component – in fact, snow cover is never mentioned by Peek, 

2003 as affecting winter diet. Peek, 2003 also identified 

changing diets with changing seasons (none of which Peek 

attributed to snow cover).

The Final EIS expanded on Chapter 3 to better address elk food 

habits and included information from a study conducted in 

Jarbidge Mountains of northern Nevada (Beck and Peek, 2005) 

and winter diets (Christianson and Creel, 2007).

Wildlife Chapter 3 of the Draft RMP/EIS, p. 3-23 states, “Mountain lions 

are widespread at low densities in the planning area. Because 

individual mountain lions have large territories, mountain lion 

numbers in a given area are naturally low, approximately 1 lion 

per 103 square miles (Pierce and Bleich, 2003).” However, 

Pierce and Bleich (2003) did not report the density of mountain 

lions reported by the Draft RMP/EIS. Pierce and Bleich (2003) 

reported 10 different studies from different states and 

provinces, which reported densities ranging from 0.4 lions per 

100 square kilometers to 7.1 lions per 100 square kilometers. 

These equate to a range of densities of 1 lion per 96.5 square 

miles to 1 lion per 5.4 square miles. None of the studies 

reported 1 lion per 103 square miles. Relative to Idaho, Pierce 

and Bleich (2003) reported a study by Seidensticker and others

(1973) which reported a mean density of 0.6 mountain lion per 

100 square kilometers. This equates to a density of 1 mountain 

lion per 64 square miles, not 1 lion per 103 square miles. In 

addition, Seidensticker and others (1973), as cited by Pierce 

and Bleich (2003), monitored home ranges in the Idaho 

Primitive Area, which is not within the planning area, and which 

area likely has different climatic conditions and prey 

abundance than the planning area.

The Final EIS revised Chapter 3 for mountain lion and included 

information on territory size on mountain lions occurring in 

southeastern Idaho and food habits, closer to the planning area. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-673

Category Comment Response

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-23 states: 

“Historically, substantial numbers of mule deer from Nevada 

migrated to the planning area during the winter (IDFG, 2007b).

However, IDFG (2007b) does not make the statement 

attributed by the Draft RMP/EIS.

The Draft RMP/EIS had an erroneous citation. The correct 

citation should have been Idaho Department of Fish and Game

2007 Project W-170-R-31, Progress Report, Mule Deer Study 1 

Job 2, Boise, ID 113 pages. The Final EIS updated the mule 

deer discussion in the Chapter 3 Wildlife section using the most 

recent Idaho Mule Deer Plan. 

Wildlife Chapter 3 of the Draft RMP/EIS, p. 3-23 states:

a) While the Idaho Department of Fish and Game (IDFG) has 

no population data for mule deer in the planning area, data 

from adjacent big game management units in southern Idaho 

indicate mule deer numbers and fawn recruitment have 

generally trended downward since the late 1980s (IDFG, 

2008d). Similarly, data from adjacent management units in 

northern Nevada indicate a general declining trend in the 

number of wintering mule deer north of the Jarbidge 

Wilderness area (NDOW).”

However, IDFG (2008d) is a document specific to pronghorn, 

and does not make the statement attributed to it relative to 

mule deer.

Further, Nevada Department of Wildlife (NDOW) is stated to be 

unpublished data, and is not an appropriate reference, 

because it does not permit the public a reasonable opportunity 

to comment to BLM’s reliance on such information. If the 

information is not published, it is presumably not available to 

the BLM, and reliance upon such an unverified source is not 

appropriate to a description of the Affected Environment. If the 

unpublished information is available to the BLM and the BLM 

relies upon it, then make it available for public review of the 

Affected Environment.

a) The Draft RMP/EIS had an erroneous citation. The correct 

citation should have been Idaho Department of Fish and Game. 

Mule Deer Project W-170-R-32 Progress Report (IDFG, 2008c). 

The mule deer section of Chapter 3 was revised in the Final EIS 

and used the Idaho Mule Deer Management Plan 2008-2017 

(IDFG, 2008a) as a base.

b) A variety of unpublished data was used including proper 

functioning condition data, stream bank alteration, water 

temperature, and aquatic habitat. The BLM has access to a 

variety of wildlife data through a data sharing agreement with 

State wildlife agencies including sage-grouse count lek data, 

sage-grouse movement data, rare plant and animal data, mule 

deer harvest data, pronghorn harvest data, winter wildlife 

location data from aerial flights, radio-telemetry data on sagegrouse collected as part of graduate studies or other projects. 

These types of data qualify as unpublished data. Reference to 

unpublished data is allowed where the author(s) are familiar or 

have field information/data sets that were collected but have not 

been published. Data provided by State wildlife agencies were 

appropriately listed as unpublished data.

Wildlife Chapter 3 of the Draft RMP/EIS (p. 3-23) states: “The habitat 

requirements of mule deer in the planning area .... Deer 

fawning, foraging, hiding and migrating.” However, no 

appropriate literature source, appropriate research, planning 

area-specific monitoring data, or site-specific monitoring data is 

cited in support of the statements purporting the habitat 

requirements of mule deer in the planning area. This does not 

permit reasonable review and comment by the public.

The Final EIS added a brief generalized presentation of mule 

deer cover to the mule deer section of Chapter 3. Sources BLM 

reviewed for the general discussion on mule deer habitat 

included Wallmo (1978) and Mackie and others (2003). Neither 

general source was cited. BLM acknowledges no research 

regarding mule deer fawning has been conducted in the planning 

area.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

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Category Comment Response

Wildlife Chapter 3 of the Draft RMP/EIS, p. 3-23 states: “Pronghorn are 

widely distributed in the planning area. Pronghorn numbers 

throughout most of the planning area have generally declined 

since the early 1990s (IDFG, 2008d). Suspected reasons for 

the decline include habitat alteration and fragmentation due to 

wildland fire, conversion of burned areas to non-native 

perennial grass, increases in invasive annuals, failure of 

seeded forbs (e.g., alfalfa) to persist in crested wheatgrass 

seedings, increased road and trail densities, and increased 

fence densities.”

In hunt units 46 and 47, in the 19-year period from 1989 to 

2007, Idaho Department of Fish and Game never offered fewer 

permits than were offered in 1988 and; in those 19 years, 

Idaho hunters harvested more pronghorns each year than 

were harvested in 1988. Please correct the false assumption 

that pronghorn numbers are on the decline.

The Final EIS revised the pronghorn section of Chapter 3. The 

section now includes a table of pronghorn harvest for Hunt Units 

46 and 47 and a summary.

Wildlife Chapter 3 of the Draft RMP/EIS (p. 3-24) states: “Pronghorn 

are adapted to large open expanses and rarely jump fences 

(Sheldon et al., 2006).” However, Sheldon and others (2006) 

did not study whether pronghorn jump fences. Sheldon and 

others (2006) studied the effects on pronghorn of different 

types of roads (including minor and major highways) and roads 

in combination with different types of fence. They also studied 

home range selection and migration routes.

The Final EIS revised the pronghorn section in Chapter 3 to 

provide information on pronghorn crossing fences, fence density, 

and wildlife friendly fence.

Wildlife Of particular note are Sheldon and others (2006) findings 

relative to what they defined as “wildlife friendly” fence. They 

defined wildlife-friendly fence as a four-wire fence with smooth 

bottom wire and at least 41 cm (16 in) above the ground.

Regarding home range selection: Pronghorn consistently 

selected significantly lower densities of all fence types except 

wildlife-friendly fence. 

Regarding selection of migration routes: There was weak 

evidence that pronghorn antelope were selecting migration 

routes with different fence densities than found within the study 

area. Fence densities within buffered migration routes were not 

significantly different from the study area in any of the four 

A three or four strand barbed wire fence may be constructed to 

wildlife friendly standards; however, a variety of wildlife from big 

game to birds die in collisions with fences annually. 

Accumulations of tumbleweeds or snow can also make wildlife 

friendly fences barriers to some wildlife movements. With 

respect to wildlife friendly fences Table 8 in Sheldon and Lindzey 

(2005) shows pronghorn selecting areas with lower fence 

densities at times. However, the avoidance was not as 

consistent as with other fence types. Sheldon and Lindzey 

(2005) wrote “Fence density, however, including all fence types, 

was lower in seasonal home ranges overall than in the study 

area. Location of seasonal ranges was influenced by fence 

density, with pronghorn choosing those areas within the study 

area with lowest densities.” Sheldon and Lindzey (2005) 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

migration periods. 

Regarding crossing fences on migration routes: Crossing rates 

for wildlife-friendly fence did not differ between actual and 

random routes except in fall 2003. 

Regarding fences within home ranges: Wildlife-friendly fence 

has been used by the agency.

recommend, “As little fencing as possible should be constructed 

on pronghorn range.” Similar statements regarding fences are 

present in other peer reviewed pronghorn ecology and 

management reference books.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 purports statements 

made by O’Gara and Yoakum (2004). However, the copy of 

O’Gara and Yoakum (2004) provided is not the entire 

document, and the characterizations attributed to these 

authors do not appear in the copy provided. This omission of 

records does not permit reasonable analysis and comment by 

the reviewing public.

Chapter 3 with respect to pronghorn was revised in the Final 

EIS. O’Gara and Yoakum (2004) is a published document. The 

book could be obtained online or requested through an 

interlibrary loan. 

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 states: “The 

availability of forbs in shrub steppe habitats may have 

important implications for pronghorn because they are rich in 

nutritional values required for reproduction (Pyrah, 1987).”

However, the copy of Pyrah (1987) provided is not the entire 

document. This omission of records does not permit 

reasonable analysis and comment by the reviewing public. The 

Draft RMP/EIS’s reliance on Pyrah (1987) is not appropriate, 

because its work is specific to the Yellow Water Triangle of 

central Montana. The Draft RMP/EIS erroneously represents 

Pyrah (1987). 

Pyrah (1987) is a published document that is available online. 

However, the Final EIS updated the pronghorn section in 

Chapter 3 using information from southeastern Oregon, which

has similar climate and vegetation to the planning area rather 

than Pyrah (1987). The revision also included information on 

research on pronghorn conducted within the planning area.

Wildlife Chapter 3 of the Draft RMP/EIS, on p. 3-24, states, “Idaho 

Department of Fish and Game (IDFG) and Nevada Department 

of Wildlife (NDOW) provided updated maps to depict the 

distribution of big game winter range in the planning area (Map 

19).” Map 19 is found in Draft RMP/EIS Volume 3, p. M-20. 

However, the Draft RMP/EIS is wrong in failing to report what 

criteria IDFG and NDOW used to describe and display “Big 

Game Winter Range” and what criteria were used to “update” 

the mapping of big game winter range. For example, were 

actual occupancy, the average winter snow depth, vegetation 

characteristics, some “model”, or some other criteria and 

method used to describe and display “Big Game Winter 

Nevada Department of Wildlife (NDOW) used more than 10 

years of winter flight information with the locations of mule deer 

and elk observations. They used field information from their staff. 

Idaho Department of Fish and Game (IDFG) used winter flight 

information in which they collected locations of wintering mule 

deer, pronghorn and elk. They also used field information from 

their staff. Neither NDOW nor IDFG designated separate mule 

deer or pronghorn winter range due to the presence of two or 

more species of big game in the same general area.

Information from IDFG or NDOW was not available to identify by 

species, spring, summer or fall areas. 
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-676

Category Comment Response

Range”? This lack of transparency makes it impossible to 

comment on the reliability (or any lack thereof) of Map 19 as it 

relates the Affected Environment.

The Draft RMP/EIS errs in not identifying the spring, summer, 

fall, and winter habitat areas for each of the wildlife big game 

species.

The Final EIS updated the bighorn sheep section in Chapter 3 

and added Map 27 “Bighorn Sheep Habitat and Distribution” to 

delineate bighorn sheep habitat for the planning area consistent 

with the IDFG bighorn management plan.

Wildlife Chapter 3 of the Draft RMP/EIS, on p. 3-24, states, “Snow 15 

to 18 inches deep can preclude use of an area by mule deer 

(Gilbert et al., 1970; Poole and Mowat, 2005).” However, the 

BLM should not rely upon these two sources, because the 

study areas are different from conditions found within the 

planning area. 

However, to the extent the BLM wishes to rely upon these two 

sources, (Gilbert et al., 1970; Poole and Mowat, 2005) 

conclude that mule deer prefer not to use areas of deeper 

snow (above 18 inches and above 15 inches, respectively). It 

is important to note that deer are mobile creatures that readily 

move to lower elevations, and to topographic features with 

lower snow cover, when they are unsatisfied with accumulating 

snow. 

The Final EIS revised the winter range section of Chapter 3. The 

differences in study areas do not change the general statement 

that snow depth can preclude mule deer use of habitat during 

winter (MacKie et al., 2003). In general, as snow depth increases 

energy needed for movement increases and available 

herbaceous forage decreases.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 states: 

“Increases in energy use for movement (Parker et al., 1984), 

thermoregulation, and basic metabolic function during the 

winter are factors in increased mortality for mule deer fawns 

when compared to adult females (Hobbs, 1989).” As to Parker 

et al., 1984: This sentence infers that Parker and others (1984) 

assessed mortality in deer fawns and adult females as it is 

affected by energy use by the animals. Contrary to this 

inference, Parker and others (1984) did not study mule deer 

mortality. The sentence also infers that energy use by deer is a 

singular cause of increased mortality, which is also an incorrect 

inference. 

The sentence did not infer Parker and others (1984) studied 

mortality, but clearly indicated they studied energy use for 

movement (locomotion). The Final EIS revised the Chapter 3 

discussion for winter range and energy use. 

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 states, “Although 

rabbit brush may be eaten by wintering big game, it generally 

has less nutritional value than other browse....Rabbit brush, 

which responds by re-sprouting following burning (Tirmenstein, 

1999a and 1999b), is prevalent on some winter ranges.”

This section in the Draft RMP/EIS was about big game winter 

range to provide a general background, which included a brief 

discussion on structure, cover, and forage. The Final EIS revised 

Chapter 3 to identify rubber rabbit brush and green rabbit brush 

species present on some winter ranges, and added a brief 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-677

Category Comment Response

However, the Draft RMP/EIS does not specify what species of 

rabbit brush was/were identified within the “Big Game Winter 

Range”, and does not identify which subspecies of either 

species was identified. This is an important consideration, of 

which the Draft RMP/EIS lacks any discussion or recognition. 

This is an important consideration because Tirmenstein (1999a 

and 1999b) states that the importance to wildlife and livestock, 

palatability, nutritional value, and use by different wildlife 

species, can vary considerably depending upon which 

subspecies is/are present, and depending on season of use: 

“In general, wildlife and livestock forage only lightly on this 

species during the summer, but winter use can be heavy in 

some locations (80).... The forage value of rubber rabbit brush 

varies greatly among subspecies and ecotypes.

discussion of nutritional variation within browse species. Timing 

of the browse surveys precluded the identification of subspecies 

of rabbit brush. Several studies have documented nutritional 

value varies within a variety of shrub species with some 

ascensions within shrub subspecies being more nutritional than 

others. However, BLM does not collect nutritional information on 

browse or other plants for the planning baseline. 

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 states, “The BLM 

conducted big game winter range evaluations in the southern 

portion of the planning area in 2006 and 2007. The evaluations 

indicated chokecherry, Utah serviceberry, and four-wing 

saltbush was most heavily utilized, although it is unknown what 

portion of this use is attributed to big game or fall and winter 

livestock grazing (Klott et al., 2007).” However, the Draft 

RMP/EIS errs in suggesting or stating that Klott and others 

(2007) monitored utilization in terms of removal of current 

year’s production. Klott and others (2007) did not monitor 

utilization in terms of removal of current year’s production, but 

rather monitored (among other types of information) “percent 

nipping” information using the Extensive Browse Method. 

Relative to use of the forage, this Method only asks whether a 

twig was un-nipped or nipped, but does not assess the degree 

of annual forage removed.

The Final EIS revised the Chapter 3 discussion on big game 

winter range in the Wildlife section to indicate browsing or 

nipping rather than utilization.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 states (still referring 

to Klott et al., 2007): “The evaluation also showed moderate 

hedging within most Wyoming big sagebrush and antelope 

bitterbrush sites.”

This statement infers some degree of concern (it should be 

noted that “hedging” means “form class”, not “browsing” or 

“utilization”), and the Draft RMP/EIS fails to clarify that 

moderate hedging is the norm, not an issue of concern. This is 

ignored by the Draft RMP/EIS, but verified by Klott and others 

The statement was only intended to convey information not infer 

a concern. The Final EIS revised the Chapter 3 Wildlife section 

to note that moderate hedging was expected on big game winter 

ranges.
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(2007) p. 51: “Browse on the winter range was generally 

considered all available and moderately hedged. Moderate 

hedging is usually expected on big game winter range.” 

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 states (still referring 

to Klott et al., 2007), “Relatively high amounts (10% to 29%) of 

rabbit brush in winter ranges classified as salt desert shrub, 

low sagebrush, Wyoming big sagebrush, mountain big 

sagebrush, and mountain shrub indicate higher disturbance 

sites; these disturbances can include fire, livestock grazing 

management, or use by wildlife. However, the Draft RMP/EIS 

fails to report that rabbit brush is a natural component of the 

vegetation types discussed (See Tirmenstein, 1999a and 

1999b) and fails to report the “natural” or “undisturbed” range 

for the species and subspecies. 

The Final EIS revised the Chapter 3 Wildlife section to note the 

role of rabbit brush in natural systems. BLM is not aware of a 

“natural” range for amounts of rabbitbrush. In general 

rabbitbrushes are usually a minor (rare of absent) component in 

late seral and climax shrub communities. However, rabbitbrush

may dominate disturbed sites. Within the planning area usually 

rabbitbrush increases following fire if it was present prior to the 

burn.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-24 states (still referring 

to Klott et al., 2007), “The majority of shrubs observed in the 

winter range evaluations were classified as mature; however, 

more than 20% of Wyoming big sagebrush was categorized as 

decadent or dead in most habitats. This may indicate 

sagebrush in winter range is old.”

The Draft RMP/EIS appropriately recognizes that decadence is 

a natural component of the life cycle of shrubs, but the Draft 

RMP/EIS infers some concern, which is not a rational 

inference. 

The Draft RMP/EIS did not intend to infer concern. The Final EIS 

revised the Chapter 3 Wildlife section to include that young 

shrubs are expected to replace old shrubs over time.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-25 states, “Gray 

partridge, quail, and chukar numbers commonly experience 

short-term fluctuations, but have been generally stable 

throughout the planning area since the mid-1980s (Hayden et 

al., 2006).”

However, this representation of stable populations of these 

species is the same misrepresentation that the Analysis of the 

Management Situation stated. The Draft RMP/EIS does not 

correctly report the Affected Environment relative to these 

species and their population trends over time.

The Final EIS revised the upland game portion in Chapter 3 to 

reflect estimated hunter harvest and added a table including 

pheasant, chukar, gray partridge and quail harvest from 1985 to 

2009. The indicates a substantial increase in California quail, 

chukar, and gray partridge harvest.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-25 states, “Late fall 

and winter livestock grazing (Leptich, 1992) combined with 

increases in livestock water sources in allotments adjacent to 

farmland and wildlife tracts also may reduce available winter 

and nesting cover for pheasants (Leptich, 1992) and gray 

The Final EIS revised the discussion on pheasant in Chapter 3 

to provide information on the existing environment and removed 

the discussion and reference regarding late fall and winter 

grazing (Leptich, 1992).
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partridge.” However, the attribution and inferred attribution to 

Leptich, 1992 are wrong, and the BLM should not otherwise 

rely upon Leptich, 1992. The Draft RMP/EIS discussion of 

Leptich, 1992 does not describe the affected environment.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-25 states: “No 

significant population trend has been detected for mourning 

doves in the western United States, including the entire State 

of Idaho, over the last 10 years; however, significant declines 

have occurred over the entire 42-year monitoring period 

(Dolton et al., 2007).” However, the Draft RMP/EIS does not 

accurately report Dolton and others (2007). Dolton and others 

(2007) does not report that Idaho showed the same population 

trends as the “western United States” “Population Trends: 10 

and 42-year.—Unit-wide, no significant trend in numbers of 

doves heard was indicated over the most recent 10 years 

although a significant decline was apparent over 42 years 

(Table 1). Analyses of doves seen showed the same pattern 

(Table 2).” Dolton and others (2007), p. 7. The Draft RMP/EIS 

discussion of Dolton and others (2007) does not accurately 

describe the affected environment.

The Final EIS revised Chapter 3 to reflect 10-year and 46-year 

mourning dove population trends for Idaho based on the most 

recent monitoring report (Seamans et al., 2011). There was no 

apparent mourning dove population trend in Idaho for the last 10 

years, but there was a declining trend over the last 46 years. 

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-27 lists at Table 3-16 

“Species of Greatest Conservation Need (Non-Special Status) 

Observed in the Planning Area”. While the Draft RMP/EIS 

assigns these species to “habitat guilds” this does not 

adequately describe either their specific habitat needs or other 

information particular to each of the species. In this manner, 

the Draft RMP/EIS errs in the same manner as the Analysis of 

the Management Situation. In Idaho, Cicindela plutonica is 

mainly found in alpine habitat over 2700 meters (8500 feet), 

although it may not be completely restricted to alpine habitats. 

However, the planning area does not extend to these 

elevations; therefore, discussion of this species is irrelevant to 

the affected environment.

The Final EIS revised the Species of Greatest Conservation 

Need in Chapter 3. The RMP was not intended to be a detailed 

overview of habitat use, abundance, ecology for all sensitive 

species. Due to a lack of observations for Cicindela plutonica in 

the Idaho Department of Fish and Game natural heritage 

database in the planning area, the Final EIS removed this 

species from Chapter 3. The current distribution of this species 

in Idaho shows Cicindela plutonica present in Bruneau Dunes 

State Park, near Hot Creek south of Bruneau, and north of the 

Snake River near Hammett. These locations are all at low 

elevations (3,000 feet to 4,000 feet). 

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-28 states: “Based on 

soil site descriptions, sagebrush steppe plant communities 

were historically the dominant over story vegetation on 93% of 

the planning area. Throughout the planning area, wildland fire 

and historic vegetation manipulation projects have resulted in a 

substantial loss of sagebrush steppe habitat. Since 1987, 

a. The Final EIS revised the sagebrush section of Chapter 3. 

Past disturbances (including wildfire, rodent/rabbit 

population/insect eruptions, disease, created mosaics of native 

plant communities.

b. The Draft RMP//EIS made no statement regarding any 
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723,000 acres of sagebrush steppe habitat in the planning 

area has burned. This has altered the amount and distribution 

of sagebrush steppe habitat, particularly in the northern portion 

of the planning area. The Murphy Complex Fire burned roughly 

500,000 acres in 2007. Of this, roughly 200,000 acres was 

sagebrush steppe....” 

a. However, soil site descriptions cannot describe what the 

historical dominant over story vegetation was; they can only 

inform as to the potential vegetative community (assuming 

range site descriptions are rationally based upon soils alone). 

Because of constant disturbance on the landscape, whether by 

lightning-set wildfire, by Asian-immigrant-set fire, by European 

immigrant-set fire, by insects, by wildlife or livestock grazing, 

by drought, by flood, or by other disturbances, it is extremely 

unlikely that the area was ever, historically or prehistorically, 

actually dominated by late-seral or pristine sagebrush steppe 

plant communities over 93% of the planning area. 

b. This Draft RMP/EIS passage also infers that the classical 

theories of secondary succession apply (e.g. “remove the 

disturbance, and the landscape will change back toward the 

‘pristine’”). These theories are now widely recognized as being 

outdated or at least not universally applicable across the 

landscape. The Draft RMP/EIS at this passage completely 

ignores the reality of “states and transitions”, even though 

much of the planning area has already crossed one or more 

thresholds into different stable states (e.g. Annual vegetation 

class). 

c. Moreover, the Draft RMP/EIS is wrong in failing to report that 

over 35% of the rangeland in the early 1980s was in a 

vegetative state other than “native”, and most of the “native” 

range was in “poor” ecological condition. The Draft RMP/EIS 

also fails to discuss that the BLM planned (and decided in 

1987) that the planning area landscape would look, in large 

part, as it does today. 

successional pathway. The Final EIS revised the Chapter 3 

Wildlife section. The Upland Vegetation section lists tools 

available to reach goals by Vegetation Management Area. Due 

to the complexity and differing opinions across successional 

theory (linear, cone, states and transitions succession models, 

identification of thresholds) including a discussion on 

successional theory within the Wildlife or Upland Vegetation

sections was not pertinent or fitting as it would lead to confusion 

for the reader as to how Goals and Objectives were going to be 

reached for each alternative. The Upland Vegetation section of 

Chapter 2 in the Final EIS presented a desired vegetation 

condition and management actions that will be used to reach this 

condition. The Upland Vegetation section of Chapter 3 described 

the current vegetation condition.

c. The projected vegetation treatments outlined in the 1987 

Jarbidge RMP are not relevant to the baseline for the new RMP 

due to the large amount of the planning area burned in wildfires. 

The existing environment presents the current conditions not the 

1987 RMP projected conditions. The 1987 Jarbidge RMP 

proposed brush control on totally of approximately 48,000 acres 

in Multiple Use Areas 11, 12, 13, 15, and 16. They 1987 

Jarbidge RMP prescribed the maintenance of a total of 

approximately 350,000 acres of seedings in MUAs 6, 7, 10, 11, 

12, 13 and 15. The decrease in shrublands which has occurred 

was substantially different than envisioned by the 1987 RMP. 

The Draft RMP/EIS and Final EIS used data to represent the 

current baseline, not a baseline envisioned in the previous RMP.
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Wildlife Chapter 3 of the Draft RMP/EIS on pp. 3-29 to 3-30 states: 

“Heavy browsing of aspen sprouts by ungulates including elk 

(Bartos et al., 1994), mule deer (Kay and Bartos, 2000), or 

livestock (Kay and Bartos, 2000) after fire or cutting decreases 

the number of aspen sprouts and may result in elimination of 

aspen stands (Bartos et al., 1994).”

However, the inference relative to livestock is not supported by 

either study. 

The Final EIS revised the aspen portion of Chapter 3 to only 

present the basic aspen information for the planning area.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-44 states: “There are 

nearly 200,000 acres of sagebrush steppe habitat within 1 mile 

of a livestock water source and 3 miles of an active or status 

unknown sage-grouse lek, There are 0.9 miles of fence and 

nearly 0.4 miles of water pipelines per square mile in sagegrouse habitat within 3 miles of sage-grouse leks. Hundreds of 

miles of fences, water pipelines, routes and other infrastructure 

for management of livestock are present in the planning area, 

which contributes to habitat fragmentation (Freilich et al., 

2003).” However, the Draft RMP/EIS should not rely upon 

Freilich and others (2003) for a number of reasons:

1) Freilich and others (2003) is not a research paper, but is 

rather an opinion “forum” paper expressing the personal, not 

professional, views of the authors;

2) The authors’ focus is on the Great Plains, with Wyoming in 

particular, not the Jarbidge Field Office;

3) The authors’ “baseline” by which they compare the 

“ecological costs of ranching” consists of real or imagined 

conditions before European settlement of the West;

4) While these authors purport to discuss the “ecological 

effects of ranching”, they purport to do so in 6 narrative pages.

The Draft RMP/EIS errs in omitting these facts, and thereby 

errs in reporting the affected environment.

The Final EIS revised Chapter 3 removing any reference to 

Freilich, and others, 2003). However, the reduction and 

separation of sagebrush habitats (fragmentation) was a concern 

identified by the public in the planning area. 

Wildlife Chapter 3 of the Draft RMP/EIS (p. 3-44) states: “Piute and 

Wyoming ground squirrels are found in both sagebrush and 

grassland habitats. During a drought period and prolonged 

winter in southern Idaho between the summer of 1992 and the 

1992/1993 winter, ground squirrel populations were more 

Piute ground squirrels were classified as Townsend ground 

squirrels during the Van Horne and others (1997) study. 

However, Piute ground squirrels have since been elevated to 

species level based on genetic analyses. Steenhof et al., (2006) 

also noted that sagebrush habitats provide more stable habitat 
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stable in sagebrush habitat than in grassland habitat (Van 

Horne et al., 1997).”

However, to the extent the BLM wishes to rely upon research 

on Townsend’s ground squirrels to describe the affected 

environment of Piute and Wyoming ground squirrels, the Draft 

RMP/EIS fails to report that the conditions which Van Horne 

and others (1997) studied weren’t just any run-of-the-mill 

drought, but instead “spanned a drought near the extreme of 

the 130-yr record followed by prolonged winter conditions.” 

However, “130-year drought followed by prolonged winter 

conditions” does not represent the affected environment within 

the planning area. The Draft RMP/EIS does not address the 

norm as reported by Van Horne and others (1997). Note that 

the Van Horne and others (1997) study showed that the 

populations in both shrubland and grassland persisted into the 

following years, and neither population was extirpated.

Therefore, since Piute and Wyoming ground squirrels are 

found in both grasslands and shrub lands, in the climatically 

normal environment it should be expected that grasslands 

would support higher densities of these species than are 

supported by shrub lands. Fires in sagebrush stands would 

expand those populations and enhance the quantity of highest 

quality habitat within the planning area, whereas restoration of 

sagebrush stands would be expected to diminish the quantity 

of highest-quality habitat.

and stable populations for Piute ground squirrels in southern 

Idaho. Piute ground squirrels in sagebrush habitats were also 

larger (Steenhof et al., 2006). The Final EIS revised Chapters 3 

and 4 with respect to Piute ground squirrels.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-47 reports the 

purported status of bighorn sheep, citing Idaho Department of 

Fish and Game (IDFG, 2007b). However, IDFG (2007b) does 

not address bighorn sheep; it is the 2007 Idaho Hunting 

Seasons and regulations. Draft RMP/EIS Chapter 3, p. 3-47.

The Draft RMP/EIS reports that the current number of bighorn 

sheep, estimated to be 200 animals. We note that this currently 

estimated population is also at, or very near, the potential for 

the area. The Idaho Bighorn Sheep Management Plan (IDFG, 

2010a) states, relative to the Bruneau/Jarbidge Population 

The citation in the Draft RMP/EIS was in error. The Final EIS 

revised Chapter 3 to incorporate updated information. Idaho 

Department of Fish and Game Bighorn Sheep Management Plan 

(IDFG, 2010a) notes the habitat model estimated the carrying 

capacity of 759 for the Bruneau/Jarbidge Population 

Management Unit. IDFG state the model needs to be refined for 

desert habitat. The refinement would likely reduce the estimate 

of potential population size (p. 89). They report survey data 

indicates the area was capable of supporting >200 bighorn (p. 

89). Stating bighorn are currently at carrying capacity is 

speculative. The sharp population decline following counts in 
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Management Unit: “Given previous survey data, the BruneauJarbidge area seems capable of supporting ≥200 bighorn 

sheep.”

A carrying capacity of around 200 head also seems 

reasonable, since bighorn populations in the Population 

Management Unit declined from over 200 animals in 1997 to 

under 200 animals in 1998, and declined from over 200 

animals in 1999 to under 200 animals in 2000. The population 

is presently estimated to be 212 animals. See IDFG (2010a) 

pp. 89, 90.

Therefore, bighorn sheep potential numbers (carrying capacity) 

has been attained under the current RMP management, 

including livestock authorization and related livestock 

management practices.

1997 coincided with domestic sheep and goats on private lands 

at Murphy Hot Springs.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-47 states: Bighorn 

sheep use canyon habitats and seasonally forage on adjacent 

plateaus and avoid areas with conifers (Krausman and 

Bowyer, 2003; Tilton and Willard, 1982).

a. However, these authors did not characterize or study the 

planning area or the Bruneau/Jarbidge bighorn sheep 

Population Management Unit. 

b. As to Tilton and Willard (1982), these researchers did not 

find that bighorns avoid areas with conifers. They studied 4 

cover types: Rockland (nonbryoid canopy cover, <25%), shrub 

and grassland (canopy cover of 0-24% for conifers and 25-

100% for shrubs and grasses), open forest (conifer canopy 

cover, 25-75%), and closed forest (conifer canopy cover, 

>75%). Therefore, even the shrubland-grassland that these 

authors studied had a component of canopy cover by Douglas 

fir. These authors found: “Sheep selected against upper 

elevations, drainage bottoms, upper slopes on ridges, and 

areas with a slope steepness of 10-35%, east and southeast 

aspects, areas greater than 320 m from steep terrain, and 

closed forests. Preferences (P< 0.1) were shown for cliffs, 

areas with slope steepness greater than 80% and closer than 

a. There has been no research conducted in the 

Bruneau/Jarbidge population of California bighorn sheep. 

Krausman and Bowyer (2003) was a summary article in a peer 

reviewed scientific reference Wild Mammals of North America: 

biology, management and conservation (2nd edition), which 

provides an overview of bighorn sheep life history and ecology in 

a variety of areas and habitats and was an appropriate general 

citation. The bighorn sheep portion of Chapter 3 has been 

revised based on information for California bighorn in 

southeastern Oregon. Although the topography was different, the 

overall vegetation communities are similar to those found in the 

planning area.

b. The Final EIS removed Tilton and Willard (1982) as a 

reference. Chapter 3 did not purport that winter bighorn range 

extended one mile from canyon rims. Chapter 4 contained

analysis-comparing alternatives that had restrictions within 1-

mile of bighorn sheep habitat, such as SS-VI-MA- 8, which 

states, “New troughs, reservoirs, permanent fences, and corrals 

would be located at least 1-mile from bighorn sheep habitat.” 

Data collected by Idaho Fish and Game from aerial surveys and

bighorn radio telemetry data in Owyhee County, showed the vast 

majority of all bighorn sheep locations are within 1 mile of 
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320 m to steep terrain or cliffs, and shrub land-grassland and 

open forest vegetation types.”

Therefore, these researchers found that bighorn sheep winter 

habitat avoided areas greater than 320 m, or 1050 feet (0.2 

mile) from escape terrain. The bighorns also avoided areas 

with greater than 75% tree canopy cover, but sheep selected 

for (meaning they used it in greater proportion than its 

availability on the landscape) tree canopy cover of less than 

75% and also selected for areas less than 320 meters from the 

steep terrain.

Further, while we recognize that Chapter 4 purports that winter 

bighorn range extends one mile from the edge of the canyon, 

such one-mile area is unwarranted. These researchers found 

wintering sheep remained within less than 1⁄4 mile of escape 

terrain (which in this case would be the canyons of the 

Bruneau/Jarbidge). It should also be noted that bighorn sheep 

lambing areas do not extend out of the canyon lands (see, e.g. 

Draft RMP/EIS p. 3-75), as bighorns lamb on steep slopes, 

usually a ledge on a cliff that provides good visibility. Such 

lambing habitat would obviously not extend onto the plateau, 

and certainly not 1 mile out onto the plateau.

bighorn sheep habitat.

Management for that 1-mile area included the vast majority of 

habitat used by bighorn sheep.

Page 3-75 of the Draft RMP/EIS stated “the canyon lands 

provide secure lambing habitat.” This did not imply that lambing 

habitat was 1 mile from the canyon rims.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-47 states: “The tiger 

beetle population in the planning area appears to have been 

extirpated by 2008. Monitoring conducted in the 1990s 

indicated this species was declining since the early 1990s 

(Baker and Munger, 2000). The tiger beetle habitat within the 

nominated Area of Critical Environmental Concern has been 

invaded by cheatgrass and Russian thistle (Baker and Munger, 

2000) and planted with crested wheatgrass, reducing habitat 

for tiger beetle larvae.”

a. However, the Draft RMP/EIS provides no rational basis for 

the claim of extirpation by 2008, 

b. and provides no explanation for the purported planting of 

crested wheatgrass, which Baker and Munger (2000) did not 

find.

a. The Final EIS revised the section on Bruneau Dunes tiger 

beetle in Chapter 3. The Idaho Conservation Data Center 

conducted inventory for the Bruneau Dunes tiger beetle between 

2007 through 2009 including the Windmill Site. They only found 

Bruneau Dunes tiger beetles near the main dune in Bruneau 

Dunes State Park (Bosworth et al., 2010).

b. Following wildfire in the 1970’s, crested wheatgrass was 

planted over the burned area, which included the Windmill Site. 

The Draft RMP/EIS did not intend to infer the planting was 

recent.

c. Specific to the Windmill site Baker and Munger (2000) wrote, 

“The data indicate that plant species, especially cheatgrass, are 

invading the areas normally used for reproduction by this 

species.”
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c. Baker and Munger, 2000 reported cheatgrass, Russian 

thistle, and tumble mustard, but not crested wheatgrass, at 

“site C”. These authors also reported that, in response to 

increased annual invasive, the beetles were moving to other 

locations. They also report that declines in the mid-90 were 

believed to be due to drought. 

d. They noted that their 1998 count at “Windmill site” occurred 

after a soaking rain, which may have adversely affected the 

counts of the burrows.

They reported that a general survey at that time showed most 

of the other sites of occupation were still being used (the Site C 

and Windmill sites are not the only sites occupied by the 

species). 

e. Further, Baker and Munger (2000) do not report the 

presence or trailing by livestock at the Windmill site in 1998, or 

that such trailing or presence was having any effect on the 

species. They do report that “Site C” is not subject to livestock 

grazing.

d. Baker and Munger (2000) were referring rain possibly being a 

factor in not being able to detect recently hatched larvae (2 mm

burrows). They indicated if the larvae entered diapause earlier 

than previous years the burrows would have been closed. Baker 

and Munger (2000) state the counts for the larger burrows 

dropped for three years. No obvious explanation for the drop in 

larval numbers can be given at this time.

e. Livestock trails and cross-country motorized vehicle tracks 

were documented through formerly occupied larval habitat at the 

Windmill site during the 2006 field season.

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-48 discusses “habitat 

fragmentation”, citing Faaborg and others (1995) and Franklin 

and others (2002) for the definition, and citing Davis (2004) 

regarding “edge to interior habitat ratio”.

The Draft RMP/EIS does not rationally compare and contrast 

the existing Affected Environment which contains various 

vegetation types - and which has had further vegetation type 

changes as a result of wildfires – for the different plant and 

animal species in the planning area. Instead, the Draft 

RMP/EIS simplistically and erroneously “lumps” groups of 

species as though they all have the same habitat and habitat 

needs. This is not a rational description of the existing Affected 

Environment.

Chapter 3 in the Draft RMP/EIS only intended to provide a 

simple overview of fragmentation for the general public, not a 

detailed account of fragmentation processes or wildlife 

responses. The Final EIS revised the habitat fragmentation and 

infrastructure overview in Chapter 3. 

Grouping wildlife into groups is one method used for large scale 

analysis. The species included for each group were revised in 

the Final EIS. Although wildlife within groups may use the same 

habitat differently (sage sparrow and least chipmunk), large 

increases in habitat would have a similar impact on the species

within the group. For example, long-term increases in sagebrush 

steppe would increase habitat for sagebrush voles, pygmy 

rabbits, sage thrashers etc. and would be appropriate for 

landscape scale analysis. 
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Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-48 states, “The 

probability of successfully raising young may be reduced as 

the size of the habitat patch decreases or amount of edge or 

infrastructure increases (Davis, 2004; Humple and Holmes, 

2006; Vander Haegen et al., 2002).”

As to Davis (2004) this author did not document nesting or 

rearing success, but rather studied adult bird abundance. 

As to Humple and Holmes (2006) these authors did not relate 

nesting success to any kind of infrastructure, but rather to the 

effects of a fire affecting their study area. 

As to Vander Haegen and others (2002) these authors did not 

relate nesting success to any kind of infrastructure (utility lines, 

roads, pipelines, water troughs, etc.) in a rangeland setting 

similar to the planning area. Rather, these authors assessed 

nest predation near agricultural areas in eastern Washington 

State.

These authors attributed higher nest predation in patches 

within the agricultural area to the Common Raven. 

The Final EIS reduced the habitat fragmentation and 

infrastructure discussion in Chapters 3. The Davis (2004) and 

Humple and Holmes (2006) citations were removed. With 

respect to the Draft RMP/EIS, in some cases citations were 

moved to the end of the sentence during editing. Vander Haegen 

and others (2002) examined nest success in areas of contiguous 

shrub steppe (sagebrush) and well as sagebrush areas 

fragmented by agriculture. This was similar to conditions in the 

northern portion of the planning area (Bell Rapids, Blue Gulch, 

and Roseworth).

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-48 states, “In Florida, 

researchers found isolated reptile populations are vulnerable to 

extirpation by localized catastrophic events, whereas 

extirpation risk is less when populations are not isolated (Hokit 

and Branch, 2003). This could apply to the isolated population 

of black collared lizards in the lower Bruneau Canyon.” 

However, Hokit and Branch, 2003 found no such thing. 

The Final EIS updated the habitat fragmentation discussion in 

Chapter 3 and the Hokit and Branch (2003) citation was 

removed.

Wildlife Chapter 3 of the Draft RMP/EIS on pp. 3-48 to 3-49 states,

“Although infrastructure developments (e.g., roads, fences, 

power lines) usually do not create physical barriers to wildlife 

movements, disturbance associated with human use of 

infrastructure developments and behavioral avoidance of manmade structures can displace wildlife from otherwise suitable 

habitat (Andrews and Gibbons, 2005; Barton and Holmes, 

2007; Connelly et al., 2004; Lyon and Anderson, 2003; Pitman 

et al., 2005; Rost and Bailey, 1979; Sheldon et al., 2006).”

The Final EIS revised the Chapter 3 Wildlife section regarding 

infrastructure.

a. A few studies have attempted to directly assess the 

physiological response in wildlife (e.g. increased heart rate) of 

stressors (jet aircraft noise) in some game species. Heart rates 

recovered in less than 10 minutes.

b. Anecdotal observations (e.g. deer, bighorn, sage-grouse 

walking into yards) often lack context and should not be used to 
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With regard to roads, fragmentation can result from traffic and 

habitat edge avoidance (Ingelfinger and Anderson, 2004).

Roads, pipelines, and fences may create pathways, which 

facilitate movements for some predators (Frey and Conover, 

2006; James and Stuart-Smith, 2000), increasing the potential 

for predation in close proximity to the road, pipeline, or fence.

We concur that these features do not usually create physical 

barriers.

a. However, as to behavioral avoidance, this is a natural 

response to many things in the natural setting, which include 

stress, habitat differentiation, and micro-niche selection among 

individuals of a species and between different species. Wildlife 

species are adapted to these natural settings and stresses.

b. At the same time, wildlife often displays behavior that does 

not avoid human contact and/or changes from the “natural” 

habitat. Mule deer, bighorn sheep, and sage-grouse have 

walked onto people’s lawns and yards and strolled down smalltown streets in rural areas, when no need to do so is apparent. 

c. As to at least some of the cited publications, the applicability 

to the planning area is questionable, if not erroneous: Andrews 

and Gibbons (2005) studied snakes’ willingness to cross a twolane paved highway in South Carolina. However, neither twolane paved roads nor South Carolina snakes (such as the 

cottonmouth) are ubiquitous in the planning area. 

indicate the observed behavior or habitat use was typical for the 

species as a whole or provides a benefit. For example, one 

study showed that sage-grouse in agricultural fields had

increased mortality from the application of insecticides.

c. The intent was not to suggest cottonmouth were present in the 

planning area, but vehicles influence the behavior of snakes on 

roads. The Final EIS revised the use of literature in the Wildlife

and Special Status Wildlife sections of Chapters 3 and 4 to 

reflect research on snakes and roads in sagebrush habitat in 

southern Idaho when possible. There are some two-lane paved 

roads in portions of the planning area. Paved roads within the 

planning area include the Three Creek Highway and roads to 

Grindstone Farms, Bell Rapids, Blue Gulch, Magic Waters, and 

Roseworth (two-lane paved roads approximately 20 feet in total 

width). The same behaviors that snakes use while crossing 

paved roads are expected to apply to dirt roads. Snakes use 

both paved and maintained dirt roads to aid in thermoregulation 

in the morning during spring and fall, a portion of which are 

struck by vehicle tires. 

Wildlife Chapter 3 of the Draft RMP/EIS on p. 3-49 states, “Disturbance 

areas (e.g. ditches, ruts, or other areas where vegetation has 

been reduced or removed) associated with infrastructure 

development can also serve as corridors and starting points for 

the expansion of non-native invasive plants (Trombulak and 

Frissell, 2000).”

The Draft RMP/EIS then ties this statement to Map 22 (Volume 

3, p. M-23), which depicts a 1-mile radius (2-mile diameter) 

zone around water sources, and the Draft RMP/EIS then ties 

this “buffered” area to purported use by livestock. This 

The splitting of habitat into smaller parcels is a form of 

fragmentation. In some instances, roads are non-habitat and 

have associated disturbances that provide sites for invasive nonnative plants. The Final EIS did not include the Draft RMP/EIS 

Map 22 “Areas within 1 Mile of Water Developments” nor any 

reference to Trombulak and Frissell (2000) in the abbreviated 

discussion of habitat fragmentation.
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erroneously infers a fragmenting of the landscape of the 

planning area.

However, Trombulak and Frissell (2000) made no such 

statement relative to ditches, ruts, or other areas where 

vegetation has been reduced or removed, and especially not 

by grazing within the planning area. 

Wildlife Chapter 3 of the Draft RMP/EIS (p. 3-50) states, “Rehabilitation 

or restoration treatments, such as seeding burned or otherwise 

disturbed areas with native or non-native perennial vegetation, 

reduce potential for introduction and spread of noxious weeds 

and invasive plants (Evans and Young, 1978; Thompson et al., 

2006).”

a. However, Evans and Young (1978) did not seed native 

species; they seeded crested wheatgrass and intermediate 

wheatgrass. 

b. Further, Thompson and others (2006) did not study seeding 

of any species; they studied habitat use and productivity of 

early brood sage-grouse. While they recommended enhancing 

forb cover within sage-grouse habitat, they cautioned against 

decreasing sagebrush cover to do so. They did not make any 

recommendations whether to use native forbs or non-native 

forbs.

a. The Draft RMP/EIS used Evans and Young 1978 citation only 

to support the use of non-native species. The Final EIS has 

moved the citation to provide clarity. 

b. There should have been two Thompson and others (2006) 

references. Thompson and others (2006a) Fire rehabilitation 

using native and introduced species: a landscape trial. 

Rangeland Ecology and Management 59(3):237-248; Thompson 

and others (2006b). Early brood-rearing habitat use and 

productivity of Greater sage-grouse in Wyoming. Western 

Northwest Naturalist 66(3):332-342. The reference for the article 

on fire rehabilitation was accidently omitted from the works cited 

in the Draft RMP/EIS and this was corrected in the Final EIS. 

Wildlife As an overall statement, many of the literature references in 

Chapter 4 continue the same kind of irrational, erroneous, or 

unwarranted misinterpretation and misapplication of what the 

researchers actually found, or present circumstances that is 

unusual to, or not found in, the planning area.

One such example is reference to Bissonnette and Steinkamp 

(1996) to assess predicted changes in bighorn sheep 

movement because of proximity to cattle. However, these 

authors studied a newly introduced herd of bighorn, not an 

established herd as is found in the planning area. 

Bissonnette and Steinkamp (1996) was the only peer-reviewed 

article, which attempted to directly examine potential 

cattle/bighorn interactions. Thirteen of the bighorn had been 

present for at least 1.5 years another 10 bighorn had been 

present for at least 0.5 years prior to the study in 1988. The 1988 

bighorn release was in November at least 6 months prior to the 

start of 1989 field season. This should have provided time for 

bighorn to adjust to the area particularly when other bighorn 

were already present. Bissonnett and Steinkamp observed 

bighorn for 3 months in 1988 and 3 months in 1989. Only once 

(14 -16 August 1989 for 40 hours) did they hold 5 cattle in a 0.8 

km2 area in close proximity to bighorn using riders. The effect on 

bighorn was more extreme than occurred when livestock were 

free moving. The Final EIS revised the bighorn discussion in 
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Chapter 3 to provide clarity. 

Wildlife Chapter 4 of the Draft RMP/EIS, on p. 4-402 states,

“The relationship between livestock grazing and impacts to 

sage-grouse and their habitat are complex and influenced by 

numerous factors including but not limited to time of year, 

distribution of livestock, utilization levels, grass species 

present, and plant growth as influenced by weather. One of the 

hypothesized links is the relationship between residual cover 

(vegetation height) available during nesting and early brood 

rearing (Connelly et al., 2000). Connelly and others 

recommended that residual herbaceous cover average 18 

centimeters (about 7 inches) to provide adequate cover for 

sage-grouse nesting and early brood rearing. Hausleitner and 

others (2005) reported that grass height increased 2 inches or 

more between nest initiation to hatch in Colorado due to grass 

growth.

However, the Draft RMP/EIS entirely misrepresents the 

findings that Hausleitner and others made. Connelly’s residual 

height recommendations are based primarily on measurements 

made post hatch, and the purpose of the Hausleitner research 

was to determine residual heights that nest initiating hens are 

selecting for at the time of nest initiation, rather than after-thefact measurements.

Hausleitner and others observed successful nest locations one 

year, and measured the residual heights at the same locations 

before nest-initiation the following year (sage-grouse hens 

show high fidelity to the same nest-bush in repeated years). 

Hausleitner and others determined that residual heights of 3-4 

inches were available at these preferred nest sites at the time 

of nest initiation, which then grew another 2 inches by post 

hatch, closely resembling the 7 inches post hatch that Connelly 

and others had recommended based on post-hatch 

measurements. 

The entire analysis of residual stubble heights and livestock 

authorized utilization levels focuses on Connelly and others 

(2000) (post hatch). This does not represent the current state 

of the science, since Hausleitner and others (2005) 

Herbaceous cover averaging 7 inches, the Connelly and others 

(2000) guidelines, in height has been identified as an important 

characteristic at successful sage-grouse nests (Wakkinen 1990, 

Gregg et al.,1994; Connelly et al., 2011a). Hausleitner and 

others’ (2005) research mentioned in the Draft RMP/EIS 

accurately disclosed the >2 inch growth of grass between nest 

initiation and hatch. Further, Hausleitner and others cautioned, 

"These results represent a single year of sampling and need to 

be verified under different climatic conditions and geographical 

locations within the Greater sage-grouse range." Hausleitner and 

others conducted the research in Moffat County, Colorado, 

which receives an average of 17.9 inches of precipitation yearly, 

which was substantially more than the majority of the planning 

area. These are not the same conditions as most of the planning 

area. Sandberg bluegrass, needle and thread and Western 

wheatgrass are present in both areas. However, the planning 

area also contains areas with Idaho fescue, bluebunch 

wheatgrass, squirreltail and Thurber’s needlegrass, which 

Hausleitner and others did not report. Although female sagegrouse exhibit fidelity to general nesting areas, (Connelly et al., 

2011a) the reuse of the same nest shrub has not been 

documented. Connelly and others continue to recommend 

adequate residual cover for sage-grouse nesting.
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demonstrated that nest-initiation residual heights at successful 

nests were in the range of 3-4 inches, not 7 inches. 

Wildlife Map 14 in the Draft RMP/EIS shows existing fence areas. The 

BLM stratified allotments, and randomly selected points in an 

elaborate scheme based in part on existing fences. However, 

this new reference fencing scheme must be much simplified we 

can foresee BLM claiming that the exact configuration of 

fences must be maintained because the reference areas are 

based on the current configuration. The burden of additional 

fencing hazards to sage-grouse, raptors, antelope and other 

big game would be much reduced if the BLM did not fence 

areas in lands where grazing was to be removed at the same 

time as significantly reducing the Footprint of fencing in the 

lands that remain open to grazing.

Map 14 “Reference Areas in Alternative V” in the Draft RMP/EIS 

was expressly for Alternative V and displays the current pasture 

boundaries, which would require no additional fence 

construction. Retention or removal of other fences within the 

references areas could occur (e.g. fences resource protection or 

bordering private land). Removal or modification of fences could 

be done to reduce impacts to sensitive species including sagegrouse (see SS-CA-MA-12, SS--MA-6, SS-II-MA-4, and SS-IVMA-6). Additional specific management actions were included in 

Chapter 2 for Alternative VI (Proposed RMP) of the Final EIS 

(see SS-VI-MA-9).

Wildlife Page 2-142. Livestock facility management actions will only 

exacerbate sage-grouse and other wildlife declines. The BLM 

must focus on removing spring developments, and other 

facilities - not on building even more. 

Alternative VI (Proposed RMP) addressed range infrastructure 

around springs and in special status species habitat with the 

following management actions; SS-CA-MA-12, SS-VI-MA-5, SSVI-MA-9, LG-CA-MA-1, LG-VI-MA-14. These management 

actions allow for the construction, modification, or removal of 

spring developments, water developments, range infrastructure, 

and other facilities as necessary to maintain or enhance special 

status species and their habitat.

Wildlife It is inappropriate for the BLM to rely on lumping so many 

important species into guilds.

The Final EIS replaced the term guild with group to be more 

accurate. The adoption of groups was intended to simplify the 

analyses for the general public and help reduce document 

length. Identified groups in the Draft RMP/EIS and Final EIS 

generally align with habitats outlined in Idaho and Nevada State 

wildlife conservation plans. Both State plans include a general 

overview of habitats within their respective states. However, the 

State identified habitats do not use identical terminology. The 

Final EIS added Table 3-22 showing the crosswalk between the 

State wildlife conservation plans and the habitat groups used in 

Chapter 3 for the Final EIS. A number of the habitats listed in 

both State plans are either not present in the planning area (any 

of the coniferous forest types, etc.) or are not managed by the 

BLM (large open water reservoirs). Idaho Department of Fish 

and Game was a cooperating agency and believed the groups 

were appropriate. 
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For example the loss of extensive acreage of sagebrush would 

have a similar impact to sagebrush voles, least chipmunk, 

pygmy rabbit, sage-thrashers, sage sparrows, Brewer’s sparrow, 

and sage-grouse. Wisdom and others (2000) Source habitats for 

terrestrial vertebrates of focus in the Interior Columbia Basin 

Broad scale trends and management implications Volume 1 - 

Group 33) also lumped pygmy rabbit, Brewer’s sparrow, sage 

sparrow and sage-grouse together. 

Wildlife The BLM claims for analysis purpose, all treatments would be 

implemented in 5 years. It is very difficult to believe the BLM 

will act with this much speed. The BLM needs to analyze an 

expanded range of alternatives with significant animal unit 

month cuts. Yet it appears that the BLM is going to try to tie 

cuts to treatments/restoration. 

The BLM acknowledged that implementing the RMP was 

contingent on a number of factors including funding and staff to 

prepare the project/site specific environmental analyses. The 

Draft RMP/EIS and Final EIS provided for a range in livestock 

grazing animal unit months (AUMs) which varied by alternative 

for analysis. Alternative II had the most AUMs analyzed and 

Alternative V had the least AUMs analyzed.

Wildlife The BLM's trends table on p. 4-249 is not based on adequate 

baseline and supporting information and analysis for anyone to 

understand if the arrow directions and predicted changes are 

accurate. For example, the massive fuels actions in Alternative 

II could well result in a large-scale loss of habitat.

Alternative III has more fuels treatments including unvegetated 

fuel breaks compared to Alternative II. Table 4-97 in the Chapter 

4 Wildlife section on p. 4-251 of the Draft RMP/EIS displayed 

anticipated impacts to the reader. In the Final EIS, the BLM used 

geographic information systems to quantify changes in acreage 

in association with vegetation treatments. Tables depicting 

expected trends with arrows were removed from the Final EIS.

Wildlife Table 4-97 points out the failure and refusal of the BLM to 

develop any real conservation alternatives. Because of 

subterfuges in claiming Alternative V would have less shrub 

recovery because the BLM purposefully structured Alternative 

V to have no shrub planting (active restoration) and just 

passive restoration.

The development of Alternative V focused on passive restoration 

that would display impacts from achieving restoration goals and 

objectives using primarily natural rates of recovery. However, 

Alternative V provides for some active restoration. UV-V-MA-21 

emphasized restoration of sage-grouse habitat in all Vegetation 

Management Areas. UV-V-MA-22 listed the tools used to 

implement vegetation treatments. UV-V-MA-25 prescribed the 

use of native species or cultivars of native species for upland 

vegetation treatment. Including primarily passive restoration in 

one of the alternatives helped provide for a range in the 

alternatives.

Wildlife The BLM uses indicators like acres of habitat for wildlife guilds, 

fragmentation due to habitat patches and distance between 

patches, miles of riparian areas in proper functioning condition, 

yet there is no reasoned analysis of all the data required to 

make such predictions. There is also no risk assessment. 

The analyses were at the broad landscape scale. As such, only 

generalizations regarding relative changes in patch size, 

distance between patches, etc. can be made. As the Final EIS 

indicated, there would be some lag time between when an area 

was treated and when the restored community would be 

functional.
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Wildlife What happens if the tools in the toolbox (like targeted grazing 

or herbicides) fail?

The BLM would use adaptive management in order to achieve 

the desired outcome. This could involve changes in resource 

management, incorporating new technologies, or applying 

different tools.

Wildlife Mountain lions are native predators -lumping them in with big 

game masks their biological role, life history requirements and 

relegates them to a "commodity" rather than an animal that 

serves a critical role in predator-prey relations. 

The Final EIS revised the mountain lion discussion in the Wildlife

section in Chapter 3 to acknowledge the predator role of 

mountain lions. However, the Idaho and Nevada State wildlife 

agencies categorized mountain lions as big game. The inclusion 

of mountain lion as big game was appropriate.

Wildlife On p. 3-23 of the Draft RMP/EIS, it is impossible to believe that 

Idaho Department of Fish and Game has no data on mule 

deer. The BLM forgets how dire the situation is for pronghorn - 

as shown in the Analysis of the Management Situation. Now 

with more fires and alternatives that would impose even more 

fencing, and maintain near-status quo use (allocations and 

Temporary Non-renewable Authorizations) there is no clear 

path for protection of big game species and their habitats. 

Idaho Department of Fish and Game (IDFG) data for mule deer 

within the planning area was generally limited to location data 

collected on occasional flights in the winter and spring. No radio 

telemetry studies had been conducted for mule deer or 

pronghorn by IDFG. The Final EIS updated the Wildlife section 

of Chapter 3 to include current information on pronghorn, mule 

deer, and elk. Because the available information covers areas 

larger (Hunt Units 46 and 47 in Idaho) than just the planning 

area direct comparisons cannot be made. The Final EIS 

analyzed a range of alternatives for big game habitat 

management. Alternative VI (Proposed RMP) provided general 

direction for habitat management for mule deer, pronghorn, 

bighorn sheep, and elk. The State wildlife agencies are expected 

to continue to manage game populations according to their State 

plans and subsequent game plan revisions. 

Wildlife How is BLM reducing livestock competition with elk? The Final EIS provided some general information elk in Chapter 

3. Elk were not specifically analyzed in Chapter 4, which focused 

on indicators for wildlife groups. Competition between elk and 

livestock were believed low due to stocking rates and amount of 

available forage. In northern Nevada, Beck and Peek (2005) 

noted a potential for forage competition mule deer and elk if elk 

number reached moderate to high density. They did not mention 

competition between elk and livestock.

Wildlife The BLM's small mammal and other animal inventories found 

large-scale absence of nearly all native species over large 

areas. So by the BLM placing the one species that was 

abundant, the disturbance related deer mouse, which is a 

species that thrives in a devastated landscape, in its 

sagebrush guild, the BLM created biases in the RMP 

alternatives.

The 2006 inventory documented presence and relative 

abundance of small mammals in areas sampled. The Final EIS 

revised Chapter 3. Deer mice are a generalist wildlife species 

found in all terrestrial habitats in the planning area and were 

removed from the sagebrush or any other wildlife group.
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Wildlife Why is the badger in a grassland guild and not a sagebrush 

guild? Burrowing owls occupy sagebrush communities, too - 

they are not only grassland species. Why is Brewer's blackbird 

in the grassland guild?

The Draft RMP/EIS (page 3-26) stated a wildlife species may be 

listed in one guild habitat the species may occur in other guild 

habitats. Final EIS revised the Wildlife section in Chapter 3. In 

the revision, the BLM acknowledged even though a species was 

listed in one habitat group they can and often do occur in other 

group habitats. The lists of species in tables for group habitats 

were modified and the badger was removed from the grassland 

group. The intent of the listing wildlife with a group was not to list 

every species to within every group, but to give the general 

public an idea of which species tend to be associated with a 

habitat. 

Wildlife These lists fail to take into account elevation changes, and 

vegetation change with elevation. 

Brewer’s sparrows are found in big sagebrush habitats in the 

planning area from the Snake River Plain to Monument Springs 

across an elevational gradient of nearly 4,000 feet. Other wildlife 

that are present in a group habitat across the elevation gradient 

include sage-grouse, least chipmunk, white-throated swift, 

canyon wren, cliff swallow, horned lark and other species.

Wildlife Why are golden eagles in a canyon land guild, but not a 

sagebrush guild? Yes, they nest in canyons but require vast 

areas of sagebrush inhabited by jackrabbits to flourish.

Golden eagles were placed in the canyon group because that 

was where the majority nest. Golden eagles forage in a variety of 

habitats not just sagebrush and consume a variety of prey 

species during the year and between years as the prey base and 

conditions change.

Wildlife Page 3-26 describes guilds for various habitats. The Draft 

RMP/EIS is woefully lacking in honest detail and analysis of the 

loss of many of these species across vast areas of the 

planning area. 

The Final EIS revised the analysis in Chapter 4. The Alternatives 

vary in the amount and type of habitat restoration. The analysis 

focused on the amount and type of future habitat restoration. 

Wildlife The Draft RMP/EIS on p. 3-31 admits that less than 1 % of the 

planning area should be grassland, where shrub cover is less 

than 2%, yet 33% is mapped as grassland. It appears that this 

percentage of 33% does not reflect the current reality and does 

not adequately take into account the aftermath of the Murphy 

Fire. If it does not, then the percentage is likely 60-70%. Map 

10 shows around 33% non-native perennial, and perennial and 

annual grassland. This map has nearly one-third of the 

planning area shown as Unvegetated - i.e. the Murphy 

Complex. If a reader closely scrutinizes the following Map, Map 

10 (p. M-ll), the Projected 2012 Vegetation, it appears that, 60-

70% of the Field Office is grassland. 

The Draft RMP/EIS was based on soil surveys which indicated a 

small amount of the planning area would have been grassland at 

climax. The Final EIS notes wildland fires which burned 

sagebrush habitats would have functioned as grassland until 

shrubs re-established. The Final EIS updated vegetation maps 

from the Draft RMP/EIS. The new maps are Map 9 “Existing 

Vegetation of 2011” and Map 10 “2016 Projected Vegetation”. 

Areas previously classified as Unvegetated, which were Recent 

Burn, were assigned to a Vegetation Sub-Group category to 

create the 2016 Projected Vegetation map.
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Wildlife Mountain mahogany avian species would be much at risk for 

wind farm development - since so much of the remaining 

mahogany habitat is in the China Mountain area. The BLM in 

all instances must analyze impacts to species of its 

allocations/alternatives. In addition, why does this list include 

pinyon jay as a species in the mahogany guild?

The Final EIS updated Chapter 4 to show the amounts of habitat 

in areas allocated for wind development for all alternatives. In 

the Final EIS a table (Table 4-132) was included which shows 

the amount of each group habitat present in areas of expected 

wind energy development. Analysis for specific projects would 

be conducted at the time the project was proposed. Over the 

years the only observation of pinyon jay within the planning area 

was in mountain mahogany habitat, thus its inclusion in this 

group for the planning area.

Wildlife The BLM lumps sagebrush species together that were not 

combined in the Wisdom Interior Columbia Basin Ecosystem 

Management Plan analyses. In fact, salt desert and lower 

elevation sagebrush species were analyzed separately from 

other sagebrush species.

In order to keep the document short, the Final EIS wildlife groups 

are generally broader than those used by Wisdom and others 

(2000). The Interior Columbia Basin Ecosystem Management 

Plan and Land Use Plan are different types of analyses for 

different purposes. The identified groups were appropriate to the 

scale of the analysis in the Final EIS. Salt desert shrub 

communities in the planning area contain some amount of 

Wyoming big sagebrush and black sagebrush. Sagebrush 

steppe group wildlife in salt desert shrub, would be respond 

similarly to sagebrush steppe wildlife in mountain big sagebrush. 

black sagebrush, and low sagebrush to fire, the primary factor 

influencing wildlife habitat or habitat restoration.

Wildlife The BLM erroneously claims, "limited information is available" 

for special status wildlife (including sage-grouse that are 

lumped in with the guild). This is not true. There are many 

studies available especially for some species (sage-grouse, 

pygmy rabbit), and numerous studies on loggerhead shrike 

and other migratory bird species, as well as raptors.

The Final EIS updated Chapters 3 and 4. The context f in the 

Draft RMP/EIS of “limited information being available” was 

regarding the local populations, population trends, and 

distribution of many of sensitive species. Much of the information 

was anecdotal observations, rather than intensive systematic 

inventory and long-term population monitoring.

While there have been a number of articles in peer reviewed 

scientific journals regarding habitat use, ecology and impacts 

from fire, and land uses for some of the sensitive species (sagegrouse, pygmy rabbit, Brewer’s and sage sparrow) but much 

less information was available on other species (spotted bat, 

ferruginous hawk, Piute ground squirrel, Great Basin collaredlizard, Western ground snake).

Wildlife The statement that 1,277,000 acres historically contained 

sagebrush, and "currently 463,000 acres of sagebrush steppe 

remain". How much less is that now following more fires? 

Some of the areas that the BLM has mapped as native shrub 

The Final EIS updated sage-grouse habitat and vegetation 

information through the 2011 fire season in Chapter 3. 
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land in M-ll have very little sagebrush or other shrubs.

Wildlife The BLM uses old and outdated information on sage-grouse 

nesting in relation to leks. The BLM knows that grouse, in the 

planning area, may move considerable distances to nest, and 

exhibit a degree of nest site fidelity.

The Final EIS revised Chapter 3, Special Status Wildlife section 

to include sage-grouse movement data collected in the planning 

area. Connelly and others (2011a, 2011b) was also reviewed for 

movements of sage-grouse in general and site fidelity.

Wildlife Artificially segregating habitat and analysis into Vegetation 

Management Areas meaningless to sage-grouse and serves 

no purpose other than to complicate matters.

Vegetation Management Areas (VMAs) were based primarily on 

the potential natural community, elevation, and mean annual 

precipitation (described in Chapter 3, Upland Vegetation section) 

in the Final EIS, not sage-grouse habitat. The VMAs are useful 

in assessing and prioritizing restoration of habitat for wildlife 

including sage-grouse. 

Wildlife Please provide detailed analysis of the current military 

disturbances and stresses on ecosystems. This must include 

direct, indirect and cumulative effects. For example, sagegrouse in the planning area are subject to extreme plane noise 

disturbance for several hours a day, and at nighttime too 

during periods of intensive training. How do the sounds from 

these activities affect sage-grouse? Bighorn sheep? Other 

wildlife? Recreational users?

BLM has no authority to regulate military activities. The effects of 

military operations were included in the cumulative impacts 

analysis in the Wildlife and Special Status Wildlife sections of 

Chapter 4 in the Final EIS. 

Wildlife There is a very large and unexamined footprint of military 

actions that have direct (vehicle-caused mortality of migratory 

birds, reptiles, and other wildlife, for example), indirect and 

cumulative impacts on habitats and populations of wildlife 

species.

Chapter 4 included a brief cumulative impacts analysis regarding 

military activities in the Special Status Wildlife section of Chapter 

4 in the Final EIS. 

Wildlife What actions can the BLM take at some level to mitigate the 

severe adverse impacts of near non-stop noise and visual 

disturbances from low-flying aircraft on sage-grouse, bighorn 

sheep, and other wildlife?

Although BLM was not mitigating impacts from military 

operations, Restoration proposed in the some of the Alternatives 

in the Final EIS including Alternative VI (Proposed RMP) in and 

away from the military operating areas, which would benefit 

wildlife mitigating some potential effects of military activities. In 

the planning area, noise from military aircraft is often for short 

duration with longer periods of minimal noise. Research on the 

noise from jet aircraft in other areas indicated mule deer, 

pronghorn and bighorn sheep apparently habituated to low level 

jet noise in those studies.

Wildlife These lands provide critically important bighorn sheep habitat, 

why does the BLM only provide coarse-scale mapping for 

some big game species?

The Final EIS included Map 27 “Bighorn Sheep Habitat and 

Distribution” for the planning area. This map included the 

population management unit boundary in the 2010 Idaho 

Bighorn Management Plan (IDFG, 2010a).
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Wildlife Provide a detailed mapping and analysis of conflicts between 

land uses/disturbances and bighorn sheep, mule deer, 

pronghorn antelope, elk, and all aspects of livestock grazing. 

This includes loss of structural complexity of hiding and thermal 

cover, loss of fawning/birthing habitats, fence hazards and 

barriers, disturbance from livestock during periods when young 

animals are present.

The BLM used a geographic information system to determine 

acreages of baseline conditions and impact analyses. Part of the 

baseline was key sage-grouse habitat, big game winter range, 

etc. Part of the analyses in Chapter 4 included overlaying the 

baseline maps with areas allocated for various resource uses. 

The analysis between land uses/disturbances and bighorn 

sheep, mule deer, pronghorn antelope, elk, and livestock grazing 

was revised in Chapter 4 in the Final EIS.

Wildlife What exactly does the BLM mean when it labels maps for big 

game restoration?

General areas for habitat restoration for big game include those 

where wildfires have reduced or eliminated desirable browse

species, including sagebrush, has been reduced or eliminated. 

Shrubs establishment would occur by planting seedlings or 

seeding the desired shrub species.

Wildlife We request that non-BLM outside biologists/ecologists with US

Geological Survey or some other impartial entity be brought in 

to produce a scientifically valid and tenable management 

document.

Through regulation and policy, the BLM was charged with land 

use planning. In some instances BLM contracts land use plans 

to be prepared by others. 

Wildlife The BLM must clearly define what Key Habitat means. The BLM used the definition contained in the Conservation Plan 

for Greater Sage-grouse in Idaho (Idaho Sage-grouse Advisory 

Committee, 2006) which generally defines key habitat as "Areas 

of generally intact sagebrush that provide sage-grouse habitat 

during some portion of the year." The Final EIS added the 

definition to the Chapter 3 Special Status Wildlife section and the 

Glossary. 

Wildlife What toll is wind development on private lands in the area of 

these wildlife tracts taking on wildlife? Aren't these tracts now 

more important than ever?

Nearly all of the wildlife tracts burned between 2003 and 2011. 

Wind energy was developed in the area over a similar time 

frame confounding the effects of wind energy development. The 

Cumulative impacts analysis considered wind energy projects on 

private land. BLM did not locate any information regarding bird or 

bat collisions with wind turbines on private land at the northern 

part of the planning area.

Due to public comments, the Final EIS addressed the wildlife 

tracts in more detail in Chapters 2 and 4. Allocations and 

management actions (Chapter 2 Wildlife section) were refined or 

added and restoration and habitat improvements were analyzed 

in the Chapter 4 Wildlife section. 
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

A-697

Category Comment Response

Wildlife Provide an overlay of native vegetation, critical and key sagegrouse and other wildlife habitats, and restoration-focused 

lands as a basis for the BLM developing a set of alternatives 

that remove developments on an orderly and scheduled basis 

where removal is important to achieve wild lands and wildlife 

habitat restoration goals.

The Final EIS analyzed a range of alternatives, which have a 

variety of objectives, goals, allocations, and management 

actions. Alternative VI (Proposed RMP) included new 

management actions (SS-CA-MA-12, SS-VI-MA-5) which helped 

prioritize, modifying or removing some types of infrastructure in 

sage-grouse habitat. The Upland Vegetation section outlined 

restoration priorities and general areas. Native vegetation, sagegrouse, and other wildlife habitat were considerations in 

prioritizing broad restoration areas (see SS-CA-MA-11, SS-CAMA-13, SS-CA-MA-14, SS-VI-MA-6, and SS-VI-MA-9).

Wildlife Alternative IV has a seasonal restriction for big game winter 

habitat protection of 509,000 acres. Yet sage-grouse get a 

mere 248,000 acres for sage-grouse habitat protections in 

Alternative IV-B.

The big game seasonal restriction covers a different time period 

(winter) than the sage-grouse seasonal restriction (breeding and 

nesting periods). Big game winter range overlapped the majority 

of remaining sage-grouse habitat providing protection for 

wintering sage-grouse. New guidance resulted in changes to 

seasonal periods for wintering big game (November 15 - April 30 

as well as sage-grouse breeding and nesting periods (March 1 - 

June 30). BLM calculated new acreages for key sage-grouse 

habitat (311,000 acres) and the sage-grouse management area 

(990,000 acres).

Wildlife There is no evidence whatsoever that all of the areas shown 

on map 95 are indeed critical mule deer habitat.

Map 95 “Leasable Mineral Allocations in Alternative IV-B (the 

Preferred Alternative)” in the Draft RMP/EIS depicted areas 

allocated for Leasable Minerals in Alternative IV-B, not critical 

mule deer winter range. Maps 92 through 96 in the Draft 

Plan/EIS portrayed areas with various restrictions for the 

leasable minerals by alternative, not critical winter mule deer 

winter range. In coordination with State wildlife agencies, big 

game winter range was identified, which accounted between 

year use and variation by wintering mule deer, pronghorn, and 

elk. The 1987 RMP only identified crucial winter range for mule 

deer and pronghorn.

Wildlife BLM fails in all parts of the Draft RMP/EIS to provide adequate 

baseline information, mapping and analysis to understand the 

severity of impacts and threats from grazing, fire, energy, and 

other activities that sage-grouse and other species of concern 

face across the biome, region, and area of relevance to local 

populations. See Knick and Connelly (2009).

Chapter 3 of the Final EIS described baseline information for

livestock grazing, wildland fire ecology and management, land 

use authorizations, wildlife, special status species, etc. Chapter 

4 analyzed expected changes to the base line for the 

alternatives. Maps were provided for existing range 

infrastructure, existing routes, areas allocated as available or not 

available for some resource uses.
Appendix P: Response to Comments from the Draft RMP/EIS Jarbidge Proposed RMP/Final EIS

A-698

Category Comment Response

Wildlife The Draft RMP/EIS must determine the relative value to the 

public of bighorn sheep recovery vs. one sheep operation. We 

have included a map showing the relationship of existing 

bighorn sheep populations and domestic sheep operations.

Chapter 4 Economic Condition section included hunting in 

recreation for the analysis but did not separate the values for 

each big game species. The economic section did not separate 

the value of animal unit months into domestic sheep, horses, or 

cattle. At this time, there are 3 livestock grazing operations, 

which include domestic sheep. The cumulative impacts analysis 

contains information on domestic grazing allotments and bighorn 

habitat.

Wildlife The US Fish and Wildlife Service (FWS) recommends 

conservation measures of similar or greater conservation value 

for listed, proposed, and candidate species be incorporated 

into the Final EIS. In addition, although the Idaho spring snail, 

the Utah valvata snail, and the bald eagle currently have no 

status under the Act, we encourage the inclusion of 

conservation measures for these species in the Final EIS as 

described in the 2006 Conservation Agreement between our 

agencies.

The FWS recommends the inclusion of land use plan-specific 

conservation measures for all candidate species (Columbia 

spotted frog, yellow-billed cuckoo, and Greater sage-grouse) in 

the Final EIS.

The Draft RMP/EIS indicated that all current conservation 

measures in biological opinions and letters of concurrence 

would be followed. However, our 2006 Conservation 

Agreement for multiple species and our 2009 Conservation 

Agreement for the slickspot peppergrass state that 

programmatic direction for listed, proposed, or candidate 

species "will be included in the new or revised Land Use Plan 

or amendment, and the Conservation Agreement or portions 

thereof, in the case of programmatic amendments, will no 

longer apply to the planning area."

The FWS recommended that the Final EIS attach individual 

species-specific conservation measure tables similar to those 

developed for the 2006 and 2009 conservation agreements to 

provide adequate information in order to complete section 7 

consultation on the final plan. In addition, similar conservation 

Management direction was provided for listed, proposed and 

candidate species in Chapter 2 of the Final EIS in the Special 

Status Species section. Alternative VI (Proposed RMP) listed 

following specific management actions. SS-C-MA-1 and SS-CAMA-4 addressed the BLM commitment specific to following 

conservation measures identified in conservation strategies, 

biological opinions, and consultation. SS-CA-MA-1 addressed 

critical habitat for listed and proposed species and SS-CA-MA-7 

addressed minerals impacts to special status species and their 

habitat. SS-CA-MA-9 and SS-CA-MA-10 addressed 

communication sites and other rights-of-way; SS-VI-MA-7 

addressed BLM sensitive raptor nest sites. A number of 

management actions are specific to sage-grouse and their 

habitat including SS-CA-MA-11, SS-CA-MA-12, SS-CA-MA-18, 

and SS-VI-MA-6. Other management actions associated with 

limiting impacts of fire, restoration and land uses (land use 

authorizations, minerals, livestock grazing, etc.) are found in 

those sections. The Aquatic and Riparian Management Strategy

indirectly addressed Columbia spotted frog through water quality 

and riparian improvement. 

Appendix E: Conservation Measures in the Final EIS included 

the various conservation measures for species from the various 

consultations and agreements in more detail.
Jarbidge Proposed RMP/Final EIS Appendix P: Response to Comments from the Draft RMP/EIS

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Category Comment Response

measure tables for recently identified listed, proposed, or 

candidate species such as the Greater sage-grouse should 

also be developed for inclusion in the Final EIS. 

Wildlife The US Fish and Wildlife Service encourages the BLM to 

incorporate additional conservation measures into the Final 

EIS to further address the survival and recovery of listed 

species such as the Bruneau hot spring snail, and to further 

enhance the conservation of candidate species such as the 

Greater sage-grouse, especially in the Browns Bench area.

The Final EIS updated Alternative VI (Proposed RMP) included 

more conservation measures that protect sensitive species. For 

example, see SS-C-MA-1 states “follow conservation measures 

in biological opinions and letters of concurrence. Conservation 

measures can be updated, revised, or replaced through future 

consultation with the US Fish and Wildlife Service”. See also LAVI-A-4, which would not allow commercial wind and solar energy 

development inside the sage-grouse management area. 

Wildlife The Final EIS for the planning area should place an emphasis 

on habitat protection and non-destructive activities.

The Final EIS analyzed a range of alternatives based on general 

focuses. Alternative II was the least restrictive while Alternative V 

was most restrictive regarding development and land uses. 

Alternative VI (Proposed RMP) focused on actively restoring the 

resiliency of ecosystem structure and function while balancing 

uses within the planning areas. All activities proposed in the 

planning area will undergo a more specific NEPA analysis to 

determine potential impacts.

Wildlife I hope you will act to protect ground-dwelling birds and other 

wildlife in the Jarbidge Foothills area, particularly by banning 

off-road vehicle use there, which is very damaging to grounddwelling birds and other natural values.

In Alternative VI (Proposed RMP), the focus of the Jarbidge

Foothills Travel Management Area was on increasing core 

habitat size for sage-grouse and big game, while providing for 

motorized and non-motorized recreation experiences. Motorized 

travel would be limited to designated routes in this area. The 

travel and transportation planning process will designate specific 

routes.
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