United States Department of the Interior

Bureau of Land Management

Environmental Assessment

DOI-BLM-CO-S090-2018-0001-EA

July 2018

North Fork of Escalante Creek Barrier Implementation

 Location: North Fork of Escalante Creek

T51N, R14W, S34. UTM 12S 0725104 4279597

U.S. Department of the Interior

Uncompahgre Field Office

2465 South Townsend Avenue 

Montrose, CO 81401

Phone: (970) 240-5300
U.S. Department of the Interior

Bureau of Land Management

Uncompahgre Field Office

2465 South Townsend Avenue

Montrose, CO 81401

ENVIRONMENTAL ASSESSMENT

NUMBER: DOI-BLM-CO-S090-2018-0001 EA

PROJECT NAME: North Fork of Escalante Creek Barrier Implementation

LEGAL DESCRIPTION: T51N, R14W, S34. UTM 12S 0725104 4279597

APPLICANT: BLM

INTRODUCTION and BACKGROUND

The Colorado River cutthroat trout (Oncorhynchus clarkii pleuriticus ; CRCT) is designated as a 

sensitive species by the Bureau of Land Management (BLM) and species of special concern by 

the Colorado Parks and Wildlife (CPW). Factors such as loss of habitat and introduction of nonnative fish have contributed to the reduction in the number and distribution of this species. 

Specifically, hybridization with non-native rainbow trout have caused displacement of CRCT in 

many systems.

The North Fork of Escalante Creek is located within the Dominguez-Escalante National 

Conservation Area (NCA). The current conservation population of CRCT within the North Fork

of Escalante Creek is located upstream from a population of non-native rainbow trout. 

Population monitoring conducted found that hybridization of non-native trout was occurring with 

native CRCT. The hybridization of non-native trout with genetically pure CRCT poses a direct

threat to the survival of the CRCT conservation population located within the North Fork of 

Escalante Creek. There are currently only 360 conservation populations of CRCT, occupying 

less than 1 percent of their historic range. As a result, the immediate construction of a barrier is 

needed to protect the North Fork of Escalante Creek CRCT conservation population currently 

located upstream from the main population of non-native trout, and prevent further hybridization 

between the two trout species.

BLM is a signatory to The Interagency Conservation Agreement for CRCT. The agreement

stresses the importance of a collaborative and cooperative partnership among resource agencies 

and conservation groups when designing and implementing restoration activities. Project 

planning, funding, and implementation would be conducted cooperatively between CPW, the 

Forest Service, and interested partners. The interagency Conservation Agreement for CRCT 

provides direction to “secure and if necessary enhance all known and suspected genetically pure 

CRCT populations. These efforts might include, but are not limited to...Restricting introduction 

of non-native fish species...[and] constructing in-channel barriers...” (CRCT Coordination 

Team 2006). 

PURPOSE AND NEED FOR THE ACTION: 
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The purpose of the action is to protect the existing North Fork of Escalante Creek conservation 

population of CRCT that is currently being threatened by hybridization with non-native rainbow 

trout. The need for the action is to adhere to The Interagency Conservation Agreement for 

CRCT.

Decision to be made: The BLM will decide whether or not to implement a fish barrier and also a

post and cable barrier.

ISSUES AND CONCERNS

Primary issues and concerns of this project are impacts to cultural resources and species listed 

under the Endangered Species Act.

DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES

Proposed Action: The proposed action is driven by the potential loss of the existing North Fork 

of Escalante Creek CRCT conservation population due to interbreeding with non-native trout.

CPW, Trout Unlimited, the Forest Service and BLM are working cooperatively to construct a 

barrier on the North Fork of Escalante Creek upstream of the current primary population of 

rainbow trout.

The proposed action would consist of three key elements:

1. Construct a concrete fish barrier.

2. Utilize on-site rock resources for streambank rehabilitation and stabilization.

3. Install a post and cable fence within the adjacent campsite.

Design Features: 

1. To prevent non-native rainbow trout from hybridizing with the upstream native CRCT

conservation population, a fish barrier will be installed on the North Fork of Escalante 

Creek.

2. The barrier will prevent the upstream movement of fish at all possible streamflow levels.

3. The barrier will be installed upstream of the current primary population of non-native

rainbow trout.

4. Rocks from the immediate surrounding area will be utilized to rehabilitate and stabilize 

streambanks post barrier construction.

5. A post and cable fence will be installed on the adjacent campsite’s edge to prevent 

vehicular traffic from causing streambank erosion.
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No Action Alternative: Under the no action alternative, the current Resource Management Plan 

(RMP) would continue to guide management of the project area; however, the current RMP lists 

management actions to improve native trout populations and habitat. Under the no action 

alternative there would be no action taken to meet the guidelines of the RMP relating to the 

protection and conservation of the special status native trout. There would be no action taken to

limit the interbreeding of CRCT with non-native rainbow trout. The result would be:

• The native CRCT conservation population of the North Fork of Escalante Creek could be 

lost, and the population would consist of hybrid fish.

• Recovery efforts outlined in the Conservation Agreement for CRCT would not occur in 

the North Fork of Escalante Creek.

• Some current and future opportunities for partnerships on the North Fork of Escalante 

Creek, with private, non-profit, State, and/or other Federal agencies, would be lost.

PLAN CONFORMANCE REVIEW: The Proposed Action is subject to and has been 

reviewed for conformance with the following plan (BLM/CO/PL-17/005)
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Name of Plan: Dominguez-Escalante National Conservation Area Record of Decision 

and Approved Resource Management Plan

Date Approved: January 2017

Decision Number, Page, and Decision Language:

Colorado Hookless Cactus, (Dominguez- Escalante NCA) pg. 34,

SSS-CHC-GOAL-01, pg. 34,

Conserve, protect and promote recovery of the Colorado hookless cactus.

All Other Special Status Species and Communities (Dominguez- Escalante NCA) pg. 35,

SSS-OTH-GOAL-01, pg. 35,

Manage special status species and their habitats to provide for their conservation and 

restoration as part of an ecologically healthy system, and support the goals contained in 

Standard 4 of the Colorado Standards for Public Land Health (BLM 19973 and Appendix 

D).

SSS-OTH-OBJ-01, pg. 35,

Maintain, restore, and enhance special status fish, wildlife and plant 

populations/communities and associated habitats by applying mitigation measures on 

allowable uses and by prohibiting or limiting activities that would be detrimental to 

subpopulations, populations or habitats.

Fish and Wildlife (Non-Special Status), (Dominguez-Escalante NCA) pg.37,

F&W-GOAL-01, pg.37,

Promote and conserve native species by managing aquatic and terrestrial habitats to 

emphasize ecosystem diversity, productivity, viability, and natural processes.

F&W-OBJ-02, pg.37,

Work cooperatively with CPW and USFWS to actively manage to eliminate non-native, 

invasive fish and wildlife.

F&W-MA-02, pg.37,

Reduce risk of introduction and expansion, and work to eradicate invasive fish and 

wildlife in the D-E NCA through appropriate measures in coordination with CPW and 

other appropriate entities (e.g., removal of non-native rainbow trout and restocking with 

native cutthroat trout).

F&W-MA-03, pg. 37,

Remove non-native aquatic competitors (e.g., bull frogs) from active native aquatic 

breeding grounds in coordination with CPW and other appropriate entities.

F&W-OBJ-03, pg. 38,

Manage to prevent the introduction and spread of wildlife diseases into the D-E NCA

F&W-MA-06, pg. 38,

Coordinate with the State of Colorado to prevent the spread of whirling disease and nonnative aquatic organisms.

F&W-MA-08, pg. 38,

Any introduction or augmentation of fish or wildlife populations must come from healthy 

population sources.

ACEC-GOAL-01, pg. 72,

Protect the integrity of sensitive and/or unique areas within the D-E NCA through the 

designation of ACECs.

ACEC-OBJ-02, pg. 72,
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Protect the unique and sensitive plant, fish, and wildlife resources of Escalante Canyon, 

while educating the public about the areas unique and natural hazards, plants, wildlife, 

fish geological and cultural resources.

AFFECTED ENVIRONMENT and ENVIRONMENTAL 

CONSEQUENCES/MITIGATION 

This chapter provides a description of the human and environmental resources that could be 

affected by the Proposed Action and presents comparative analyses of the direct, indirect and 

cumulative effects on the affected environment stemming from the implementation of the 

Proposed Action.

Potential effects to the resources/concerns were evaluated to determine if detailed analysis is 

necessary. Consideration of some elements is to ensure compliance with laws, statutes, 

regulation or Executive Orders that impose certain requirements upon all Federal actions. Other 

items are relevant to the management of public lands in general or to the BLM Uncompahgre 

Field Office (UFO) in particular. Any element not affected by the proposed action will not be 

analyzed.

 

ENDANGERED, THREATENED, LISTED SPECIES

Affected Environment

The Endangered Species Act (ESA), as amended (16 U.S.C. 1531-1534) mandates the protection 

of species listed as threatened or endangered of extinction, and the habitats which they depend. 

Section 7 of the ESA clarifies the responsibility of federal agencies to utilize their authorities, to 

carry out programs for the conservation of listed species. In addition, federal agencies must 

consult with the U.S. Fish and Wildlife Service (FWS) to ensure that any action authorized, 

funded, or carried out by the agency is “...not likely to jeopardize the continued existence of any 

endangered species, or threatened species, or result in the destruction, or adverse modification of 

habitat of such species...”. The Uncompahgre Field Office (UFO) utilizes the U.S. Fish and 

Wildlife Service Information, Planning, and Conservation System (IPaC), to generate the most 

current species list, to analyze the effects the Proposed Action and alternatives on threatened, 

endangered, and candidate species, and designated critical habitat for these species. Additionally, 

the BLM has a state-wide list of Sensitive Species for management consideration. In 

accordance, with BLM Manual 6840, the goal of management of these species is to prevent a 

trend toward federal listing or loss of viability.

The North Fork of Escalante Creek is located within the Escalante Canyon, which has been 

designated an Area of Critical Environmental Concern (ACEC). The Escalante ACEC is home to 

a number of BLM special status plants, and rare plant associations. The Escalante ACEC restricts 

camping and motorized recreation away from these unique and rare plants, and plant 

associations, including the designated BLM Sensitive Species CRCT, and the Federally 

Endangered Colorado hookless cactus. 

Environmental Consequences:

Direct and Indirect Effects of the No Action Alternative

Colorado River Cutthroat Trout
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Without the construction of a fish barrier, non-native rainbow trout would continue moving 

upstream, breeding with native trout, and eventually eliminating the genetically pure CRCT 

conservation population. Thus this alternative would be considered a negative, direct and indirect 

effect to CRCT by maintaining suitable conditions for the expansion of non-native trout.

Colorado Hookless Cactus

No Colorado hookless cactus are located within 200 meters of the proposed site, therefore taking 

no action will not impact the species.

Direct and Indirect Effects of the Proposed Action

Colorado River Cutthroat

The project would have a positive, direct and indirect effect to the native CRCT conservation 

population by stopping the further invasion of non-native trout. These actions would eliminate a 

current threat to this conservation population and meet direction outlined in the Conservation 

Agreement for CRCT and the current RMP.

Colorado Hookless Cactus

The proposed project site is not within Colorado hookless cactus habitat. No Colorado hookless

cactus are located within 200 meters of the proposed site, the proposed action would not impact 

the species.

Cumulative Effects of the Proposed Action

Colorado River Cutthroat

Construction a fish barrier will have positive, direct and indirect effect to the native CRCT 

conservation population by preventing the upstream expansion of non-native trout, eliminating 

non-native and native trout from hybridizing. The overall effects would maintain a genetically 

pure CRCT conservation population within the North Fork Escalante of Creek.

Colorado Hookless Cactus

The project area is not located in hookless cactus habitat and therefore would not impact the 

plant populations.

INVASIVE, NON-NATIVE SPECIES

Affected Environment

The proposed action would involve excavation and redistribution of soil and streambed materials 

in and adjacent to areas with possible non-native, invasive species, and project timing 

(September) would coincide with the seed set for populations in the project area. Soil 

disturbance, and especially redistribution, can accelerate population expansion and increase 

population density of these undesirable species by spreading and planting the seeds.

Environmental consequences:

Direct and Indirect Effects of No Action Alternative

Taking no action would have no impacts directly or indirectly on invasive plant species in the 

proposed project area. There would be no change to the existing plant associations within the 
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proposed project area, and immediate vicinity.

Direct and Indirect Effects of the Proposed Action

The proposed action would involve ground disturbance, which can allow invasive or non-native 

species to establish post-construction. Proper mitigation and monitoring will be conducted to 

ensure no invasive or non-native species are brought to the site, or establish post-construction.

Cumulative Effects of the Proposed Action

The proposed action would have positive cumulative effects to the proposed project area, 

removing invasive and non-native plant species, and preventing their reestablishment postconstruction. Proper mitigation will be taken to ensure construction materials do not introduce 

invasive or non-native species to the site. Post-construction monitoring will be conducted to 

ensure no invasive or non-native species establish.

CULTURAL RESOURCES

Affected Environment

The proposed project area is situated within a river corridor on surfaces that are subject to regular 

erosion and deposition. In these circumstances, cultural resources are rarely preserved for any 

length of time, and cultural sits in floodplains are usually of an ephemeral nature. The Escalante 

Canyon is, however home to fair number of formative age occupations, agricultural sites, and 

archeological sites. Sites away from the actual river floodplain may contain evidence of human 

activity and will not be impacted by the fish barrier installation. Surveys were completed and no 

sites were found within the project area. Therefore, no effect to cultural resources under either 

alternative has been determined.

HYDROLOGY

Affected Environment:

The potential direct and indirect effects to water quality of project alternatives were analyzed 

using the following indicators:

• Risk of increased stream turbidity

• Risk of adverse wetland and riparian area impacts

• Risk of adverse channel change

Effects of the connected actions were considered in the analysis of the proposed action. 

Environmental consequences:

Direct and Indirect Effects of the No Action Alternative

If the no action alternative was selected there would be no disturbance of the floodplain, 

vegetation, or channel banks or bed. Therefore, the no action alternative would produce no 

adverse effects to water quality, wetlands, or channel change in Waters of the United States over 

either the short- or long-term timeframes. 

Direct and Indirect Effects of the Proposed Action

Risk of Increased Stream Turbidity

The proposed action would be expected to increase stream turbidity within and downstream of 

the proposed site. Where the floodplain, vegetation, wetlands, and the channel would be 

disturbed, fine sediment would be more likely to be mobilized to the stream during precipitation 

and runoff events. Excavation that would occur in moist soils in and immediately adjacent to the 

channel would increase turbidity. While streamflow would be piped to bypass the barrier site 
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during construction, turbidity would temporarily increase when flows were first returned to the 

channel. Overall, the magnitude of expected disturbance is modest and short in duration.

Revegetation of disturbed sites would reduce increases in stream turbidity. In the short-term, any 

disturbed herbaceous vegetation would be expected to fully recover, and seeding and willow 

plantings would facilitate revegetation of disturbed soils.

Risk of Adverse Wetland and Riparian Area Impacts

The proposed action would produce some direct impacts on riparian areas resulting from the 

expected 0.15 acres of ground disturbance and removal of vegetation from sixty linear feet of 

stream bank. However, the magnitude of this disturbance would be modest and would be 

rehabilitated with seeding and planting. Thus, impacts are not anticipated beyond the short-term.

Risk of Adverse Channel Change

The proposed action would produce direct channel change resulting from excavation and 

construction of the barrier structure. Barrier construction may in turn alter bedload transport due 

to reduced bed slope and produce indirect channel change manifested in rise in stream bed due to 

deposition of sediment immediately downstream of the barrier structure. However, effects would 

not extend beyond the project area, and processes such as bank erosion or down cutting are not 

anticipated as a result of barrier construction.

Cumulative Effects of the Proposed Action

The proposed action would not contribute significantly to cumulative effects. While some 

floodplain, vegetation, and stream bank and bed disturbance would occur, it would be 

minimized, rehabilitated, and would thus not produce turbidity or adverse channel change 

beyond the short-term. There are minimal past or reasonable foreseeable future activities that 

could contribute additional adverse effects, and therefore total cumulative effects would be 

minimal. 

SOILS

Affected Environment:

The soils in the analysis area are sedimentary deposits. The analysis area is dominated by sandy 

coarse-textured soils with high percentages (by volume) of rock fragments in the profile. Most 

soils in the riparian areas are composed of reworked alluvium, have poor drainage, and are 

frequently saturated during periods of spring and summer snowmelt. They are not particularly 

prone to high levels of compaction but are more susceptible to degradation when inundated, 

particularly in riparian areas with large organic deposits and a high water table.

Environmental consequences:

Direct and Indirect Effects of the No Action Alternative

The proliferation of undesirable aquatic species would have little to no effect on the soil resource 

and conditions in the project area would remain in their current, mostly natural, state.

Direct and Indirect Effects of the Proposed Action

The proposed action would involve excavation and redistribution of soil in riparian corridors. 

Soil disturbance associated with project activities and site access would temporarily lead to a 

decline in soil productivity. Compaction from heavy equipment would be present along access 

routes. Erosion from excavated sites would be expected to be present, but minimal.

Cumulative Effects of the Proposed Action
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There would be minimal effects from cumulative actions, the area is of nominal extent, and 

recovery from project implementation disturbance would be expected within five years. 

Therefore, cumulative effects, although adverse, would be negligible. 

WILDLIFE

Affected Environment:

Construction of the fish barrier may initially disrupt foraging or reproductive behaviors for 

terrestrial wildlife present; however, affected species are expected to quickly disperse when 

threats are perceived and once out of range of threats (human presence) will resume normal 

behaviors. While these impacts may occur they are not expected to result in mortalities or 

disruption of major life processes that could result in population declines.

Environmental consequences:

Direct and Indirect Effects of the No Action Alternative

Under the no action alternative, current management would continue. This alternative would 

result in no impacts to terrestrial threatened, endangered, or sensitive species.

Direct and Indirect Effects of the Proposed Action

Based upon the minimal size of the proposed project, location on the landscape, type and 

duration of project construction, and impacts to habitat, no long-term impacts to wildlife are 

expected.

Cumulative Effects of the Proposed Action

No meaningful contributions to effects from past, present, and reasonably foreseeable actions 

were identified. Therefore, cumulative effects are considered to be those resulting from direct 

and indirect effects of the project, and are considered negligible.

TRANSPORATION

Affected Environment:

The primary right of way through Escalante Canyon is a 15 mile county road, named Escalante 

Canyon Road. The proposed project site, as well as the adjacent campsite are only accessible via 

this county road.

Environmental consequences:

Direct and Indirect Effects of the No Action Alternative

Taking no action will have no direct or indirect effects on the Escante Canyon Road, or 

transportation within Escalante Canyon.

Direct and Indirect Effects of the Proposed Action

The proposed project will require the transportation of construction equipment to the proposed 

site. No road closures, or delays are expected with the transportation of construction equipment, 

or during the construction process. The proposed post and cable barrier will limit vehicular 

access within the adjacent campsite. 

Cumulative Effects of the Proposed Action
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There are no cumulative impacts to transportation associated with the construction of the 

proposed fish barrier. Construction equipment will utilized Escalante Canyon Road to access the 

proposed project site, however, no delays or road closures are expected. The installation of a post 

and cable barrier will limit vehicular access within the adjacent campsite.

RECREATION

Affected Environment:

Escalante Canyon contains numerous forms of recreational activities. The proposed fish barrier 

will require a temporary closure of the adjacent campsite.

Environmental consequences:

Direct and Indirect Effects of the No Action Alternative

Taking no action would have no direct or indirect effects on recreational activities within the 

Escalante Canyon.

Direct and Indirect Effects of the Proposed Action

The proposed action would require the temporary closure of the campsite adjacent to the 

proposed fish barrier. The campsite would remain closed during construction activities, and reopened once all construction activities had ceased.

Cumulative Effects of the Proposed Action

The proposed action would impact recreation with the temporary closure of the campsite 

adjacent to the proposed fish barrier. The campsite would remained closed throughout the 

construction process. Overall the cumulative effects to recreation within Escalante Canyon are 

minor, only requiring the closure of one recreational campsite for a short construction period.

PERSONS / AGENCIES CONSULTED 

Trout Unlimited

Colorado Parks and Wildlife

U.S. Forest Service 

INTERDISCIPLINARY REVIEW: The following BLM personnel have contributed to and have 

reviewed this environmental assessment. 

 Name Title Area of Responsibility

Name Title Area(s) of Responsibility

Ken Holsinger Ecologist Wetlands and Riparian Areas

Threatened, Endangered and 

Sensitive Plant Species

Jedd Sondergard Hydrologist/NEPA coordinator NEPA Coordinator

Lands, Authorizations

NEPA Floodplains

Water Quality

Hydrology and Water Rights

Soils

Air Quality
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Neil Perry Wildlife Biologist Migratory Birds

Threatened, Endangered and 

 Sensitive Species

Terrestrial Wildlife

Lynae Rogers Rangeland Management Specialist Invasive, Non-Native Species

Upland Vegetation

Rangeland Management

A. Leavitt-Reynolds Archaeologist Cultural Resources

Native American Religious

 Concerns

Russell Japuntich Fisheries Biologist Aquatic Wildlife

Julie Jackson Recreation Planner Wild and Scenic Rivers

Wilderness

Lands with Wilderness 

Characteristics

Access and Transportation

Recreation

Visual Resources

Jana Moe Realty Specialist Lands Authorizations

References

CRCT Coordination Team. 2006. Conservation agreement for Colorado River cutthroat trout 

(Oncorhynchus clarkii pleuriticus) in the States of Colorado, Utah, and Wyoming. Colorado 

Division of Wildlife. 10pp.

Bureau of Land Management (BLM). 2017. Record of Decision and Approved Resource 

Management Plan Dominguez-Escalante National Conservation Area.

Bureau of Land Management (BLM). 2008. 6840 Special Status Species Management

United States. (1983). The Endangered Species Act as amended by Public Law 97-304 (the 

Endangered Species Act amendments of 1982). Washington :U.S. G.P.O.,

U.S. Fish and Wildlife Service (FWS). 2010a. Recovery Outline for the Colorado hookless 

cactus (Sclerocactus glaucus). Colorado Ecological Services Field Office (April 2010), Grand 

Junction, CO. 17pp.

U.S. Forest Service (Forest Service). 2017. Toponas Creek Barrier and Reclamation Project 

Environmental Assessment