Chapter 2.0:
 

Alternatives Including the Proposed Action
 

2.1 Introduction 

“Alternatives Including the Proposed Action” is the heart 

of this EA. This chapter describes the alternatives. 

Consideration of the Proposed Action is then based on 

comparison to the No Action alternative and on the analysis 

presented in Chapter 3.0 (Affected Environment and 

Environmental Consequences). 

The comparison of the alternatives highlights differences 

between current fire management policies/strategies and the 

direction provided by the 2001 Review and Update of the 

Federal Wildland Fire Management Policy (2001 Federal 

Fire Policy). 

This chapter identifies how existing land use plan decisions 

could be amended to reduce accumulations of wildland fuels 

and help achieve resource objectives. 

2.2 History of the Planning and Alternative 

Development Process 

The alternative development process began in January 1998. 

The following narrative summarizes the alternative 

development process; a full accounting, including dates, is 

found in Chapter 4.0 

•	 BLM staff initiated public participation by asking 

representatives from other groups, agencies, and 

organizations to identify issues and concerns. The State 

Director, State Fire Management Officer, and Project 

Leader also mailed letters to potentially interested/ 

affected agencies, groups, and individuals asking for 

issues and concerns. See Sections 1.4.1 and 4.2. 

•	 Alternative development was initiated with a series of 

Interdisciplinary (ID) Team meetings. Resource and 

resource use staff from the Billings, Butte, Dillon, 

Lewistown, Great Falls, Malta, Miles City, Missoula, 

North Dakota, and South Dakota BLM Field Offices 

participated in these meetings. 

•	 The ID Teams fully developed two alternatives 

(including the No Action) to consider in response to 

the goals identified in Section 1.3, within the constraints 

imposed by existing policy and guidance. 

After the EA was released for public comment in August 

2001, several changes to the alternatives were made, 

including: 

•	 Preferred Alternative: One Fire Management Zone 

category was changed in response to public comment. 

•	 Preferred Alternative: Specific RMP amendments to 

improve BLM’s ability to implement the National Fire 

Plan and Federal Fire Policy were identified. 

•	 Both Alternatives: Broad levels of treatment and 

guidelines for fire management to protect other 

resources were identified. 

2.3 Alternative Design, Evaluation, and 

Selection Criteria 

The following goals and objectives guided development of 

the alternatives. Key elements of the Federal Fire Policy 

are also summarized. Alternatives were developed to satisfy 

these goals, objectives and policy statements. 

In some cases, the wildland fire itself may create conditions 

that would compromise these goals and objectives. Also, 

human life and safety would be prioritized above the 

achievement of any of these goals/objectives. 

Goals related to fire and fuels management 

•	 Fire: protect human life and property, reduce the risk 

and cost of severe wildland fire, sustain ecological 

health and function of fire-adapted ecosystems, 

minimize adverse effects of wildland fire suppression, 

and use fuels management methods to reduce hazardous 

fuels while meeting other resource objectives 

•	 Fish and Wildlife, including Special Status Species 

(Federally Threatened, Endangered, Proposed, and 

Candidate Species, BLM Sensitive Species and State 

Species of Concern): protect, maintain, preserve, and/ 

or restore habitats necessary for the conservation of 

species, and the ecosystems upon which they depend, 

to maintain viable and diverse populations of native 

plant, animal, and aquatic species including special 

status species 

•	 Vegetation: improve ecosystem health and maintain or 

restore the range of ecological conditions in which 

native aquatic, vegetative, terrestrial and special status 

species evolved 

•	 Cultural, Paleontological: protect high value cultural 

and paleontological resources 

9
 
•
	 Designated Special Areas: protect the characteristics 

that warranted designation of Areas of Critical 

Environmental Concern (ACECs), Wild and Scenic 

River corridors, Outstanding Natural Areas (ONAs), 

Special Recreation Management Areas (SRMAs), 

historic sites, Wilderness Areas, and Wilderness Study 

Areas (WSAs) 

• Recreation: protect developed recreation facilities 

Natural and biological resource objectives: 

Fire and fuels management related actions will: 

•
	 Air: meet federal and state air quality standards and 

comply with the Montana/Idaho Airshed Group 

Operating Guide. 

• Fish and Wildlife: 

-	 Threatened and Endangered Species: Ensure that 

BLM actions will not reduce the likelihood of 

survival or recovery of any listed species or destroy 

or adversely modify designated critical habitat. 

•
	 Water: meet federal and state water quality standards 

and prevent degradation. 

•
	 Visual: meet established Visual Resource Management 

(VRM) class objectives. 

•
	 Uplands, Riparian Areas, Wetlands, Water, Air, Native 

Plant and Animal Species, Threatened, Endangered, 

and Candidate Species: meet Standards for Rangeland 

Health. 

Resource use objectives: 

Fire and fuels management related actions will: 

•
	 Vegetation: reduce the amount of forest, shrub, and grass 

lands that are characterized as condition class 2 and 3 

(where fire regimes have been moderately to 

significantly altered from their historical ranges, where 

there is a moderate to high risk of losing key ecosystem 

components, where fire return frequencies have 

departed from historical frequencies by more than one 

return interval, and where vegetation attributes have 

been significantly altered from their historical range.) 

•
 Special designations objectives: Fire and fuels 

management actions will: 

•	 Wilderness/Wilderness Study Areas: meet the 

wilderness non-impairment mandate and avoid 

unnecessary impairment of suitability for 

preservation as wilderness (Wilderness Study Areas 

(WSAs)). 

2.4 Alternatives Considered but Eliminated 

from Detailed Study 

2.4.1 Prescribed Fire Alternative 

The BLM considered its ability to achieve fuels reduction 

solely through the use of prescribed fire on public lands 

throughout Montana and the Dakotas. Field Office and fire 

management personnel indicated that prescribed fire would 

pose a very real danger in some areas where vegetation is 

far beyond its natural fire cycle, without some form of pretreatment. In conjunction with the amount of private 

property in and around these areas, this fuels accumulation 

creates an unacceptable risk to human life and resources. 

This would also be inconsistent with agency guidance 

regarding the Federal Wildland Fire Management Policy 

(IM-2002-034). 

2.4.2 Re-categorization of Wilderness Study Areas 

(WSAs) 

In response to public comment, BLM re-evaluated WSA 

polygon categorizations to determine whether more natural 

ignitions could be allowed to burn in wildland areas. Field 

Office staff re-evaluated the categorizations, and changed 

the category of one fire management zone (Pryor Mountains) 

from a B to a C category area. This fire management zone 

contains three WSAs (Burnt Timber Canyon, Pryor 

Mountain, and Big Horn Tack On). Since the changes were 

made to only one polygon, the changes were incorporated 

into the preferred alternative rather than becoming a separate 

alternative. Other WSA category designations could not be 

changed at this time because the WSAs exhibit 

characteristics such as those listed below: 

• Small size 

•	 Moderate to heavy fuel loads that would not allow 

natural ignitions to burn safely 

• Adjacent to land with other ownerships 

•	 High potential for fires to cause undesired impacts to 

other resources and values 

2.4.3 Treatment of all BLM-administered Lands in 

Condition Class 2 and 3 in Montana and the Dakotas 

While 1.3 million BLM-administered acres are currently 

classified as being in Condition Class 2 or 3 (where the 

frequency of fire regimes have been moderately or 

significantly altered) in Montana and the Dakotas, it was 

not considered feasible to treat all these acres within the 

next 10 years. Current (and likely) future funding, planning, 

and staffing levels could not support this level of treatment. 

Further, treating some acres of Condition Class 2 and 3 may 

cause serious resource management conflicts and conflict 

with other RMP decisions. This approach would not allow 

for the efficacy of fuels treatments and the impacts on 

10
 
resources to be evaluated periodically as individual projects 

are completed. See the glossary for a definition of Condition 

Class 2 and 3. 

2.5 Description of the Alternatives 

This section describes the similarities and differences 

between the alternatives. A key difference between the 

alternatives is whether land use plans include the decisions 

necessary to implement the 2001 Federal Fire Policy and 

the National Fire Plan. These decisions are judged 

“necessary” because they have appeared in recent BLM 

planning handbook guidance, or because they have been 

identified as necessary by BLM resource and fire specialists. 

Section 2.5.1 includes management elements common to 

both alternatives; this section allows the differences of each 

alternative to be clearly defined in sections 2.5.2 and 2.5.3. 

2.5.1 Management Common to All Alternatives 

This section refers back to section 1.6, Applicable Legal 

Regulatory Restraints and Coordination. BLM would 

comply with the laws, regulations, acts, Executive Orders, 

policy, and formally adopted agreements described in section 

1.6 under both alternatives. 

This section also includes protection measures (based on 

current policy, guidance, direction, acts, and laws—section 

2.5.1.1); and describes the nature of the fuels treatments 

that would be completed under both alternatives (section 

2.5.1.2). 

2.5.1.1 Protection measures common to both alternatives 

These protection measures are based on existing policy, 

direction, law, and regulation. They are described here to 

emphasize the portions of policy that are relevant to this 

proposed action. 

•	 Air Quality: Prescribed fire will conform with the 

provisions of state regulations and implementation plans 

as specified in BLM manual section 9210-Fire Planning 

and (in Montana) the Montana Airshed Group Operating 

Guide. 

•	 Chemical Use: Label directions, BLM Manual 9011, 

and H9011-1 Chemical Pest Control Guidance will 

guide the use of chemicals on individual projects. 

•	 Cultural: Prior to implementing fire projects, the BLM 

will do an appropriate level of Native American 

consultation according to the guidance in BLM Manual 

8160 and Handbook H-8160-1 to identify potential 

religious or cultural concerns. 

•	 Cultural: If Native American human remains are 

discovered on public lands during fire suppression, 

rehabilitation, or fuels reduction activities, the BLM 

will follow procedures identified in the Native American 

Graves Protection and Repatriation Act (NAGPRA) and 

43 CFR part 10. If BLM fire suppression or reclamation 

activities extend onto private or state land, and burials 

are discovered, the provisions of the appropriate state 

burial law will be followed. 

•	 Cultural: The protective measures that guide the 

placement of dozer lines and other surface disturbing 

fire-related activities will be followed unless the 

authorized officer determines that due to adverse fire 

behavior, implementation of a particular measure is not 

feasible and prudent. In those cases, the measure may 

be waived or modified to address crucial safety issues, 

i.e., imminent threats to life and/or property. The SHPO 

will be notified if such measures are waived or modified 

in accordance with existing agreements or 36 CFR 800. 

Also, unless critical safety issues prevent a cultural 

resource inventory from being conducted, the provisions 

regarding post-fire cultural resource inventory cannot 

be waived or modified. If inventory is waived or 

modified by the authorized officer the SHPO will be 

consulted consistent with existing agreements or 36 

CFR 800. 

•	 Special Status Species (SSS): Under BLM Special 

Status Species policy (BLM Manual 6840), BLM shall 

ensure that actions authorized, funded, or carried out 

by the BLM do not contribute to the need for listing a 

candidate or BLM sensitive species under the 

Endangered Species Act. 

•	 Threatened and Endangered Species: Areas of occupied 

and/or suitable habitat, important for species expansion 

and recovery, would be protected from adverse effects 

resulting from fire/fuels management related activities. 

•	 Wilderness and Wilderness Study Areas (WSAs): 

Activities in wilderness areas and WSAs, including all 

fuels management activities, must not impair wilderness 

values. Inclusion of a WSA in a polygon does not 

automatically enable all types of treatments and 

prescribed burning associated with the category to be 

completed within the WSA. Treatment will not impair, 

and will in fact enhance, wilderness values. Minimum 

Tool and Minimum Requirement concepts must be 

reviewed. 

•	 Visual: In order to ensure that the objectives of each 

visual resource management class is met, contrast 

ratings are required for all major projects (prescribed 

burning, mechanical and chemical pre-treatments) on 

public lands that fall within VRM Classes I and II, and 

11
 
Class III areas which have high sensitivity levels. 

Actions must not exceed the VRM objectives 

established for the management class. 

2.5.2 Alternative A (No Action Alternative ) 

The No Action Alternative is for BLM to continue to 

implement current wildland fire suppression policy and to 

implement fuels management actions through project plans 

that are largely consistent with existing RMPs. Some fuels 

management actions would continue to be constrained by 

the Powder River and Big Dry RMPs. 

The BLM would also implement the National Fire Plan 

(NFP) and Federal Wildland Fire ManagementPolicy (2001 

Federal Fire Policy) to the fullest extent possible. 

However, implementation of the NFP and 2001 Federal Fire 

Policy would be restricted by existing RMP decisions where: 

•	 RMP decisions do not allow specific actions associated 

with fire and fuels management (e.g., some methods 

for mechanically treating hazardous fuels), or 

•	 RMP decisions allow necessary activities but do not 

provide sufficient direction to guide fire and fuels 

management (e.g., have not applied fire management 

categories). 

See Table 1 for a summary of current RMP decisions related 

to fire and fuels management. Under the No Action 

Alternative, these decisions would continue to guide, and 

in some cases limit, fire suppression and fuels management 

on BLM-administered public lands. 

2.5.3 Alternative B (Proposed Action) 

Under the proposed action, BLM would amend all RMPs 

covering BLM-administered lands in Montana and North 

and South Dakota, to include the following new decisions 

recommended in BLM planning guidance (Handbook H1601-1) for fire management: 

1.	 Fire management categorization: Four consistent fire 

management category descriptions are included in H1601-1. Selecting one of these designations provides 

broad fire and fuels management direction based on 

ecological, social, economic, and political 

considerations. The guidance provided by 

categorization would be applied to all BLMadministered public lands within the boundaries of 

designated fire management zones. This guidance 

would not apply to private, state, or federal lands 

administered by another agency that also happen to fall 

within the boundaries. 

See Table 2 for a description of the management 

associated with each category. See Table 3 for the 

name, categorization, and acreage of each of these fire 

management zones associated with this alternative. See 

Appendix A, Maps 3-10 for the fire management zone 

boundaries and categories for each Field Office. 

2.	 Broad Levels of Treatment: Broad levels of treatment 

are considered as a basis for analysis. Fuels treatments 

would include prescribed burns and mechanical 

(including manual) methods. Chemical weed treatments 

are also anticipated. Total acres by treatment type and 

category are listed in Table 2, and are further qualified 

by vegetation type in Chapter 3 for the purpose of 

analysis. 

3.	 General guidance for fire management (including both 

wildfire suppression and fuels management) needed to 

protect other resource values: This guidance provides 

additional protection for resources sensitive to an 

expanded level of treatment where existing policy does 

not provide sufficient protection. See section 2.5.3.1 

for mandatory measures and Appendix B for available 

design features for wildlife. 

BLM would also revise the following existing decisions in 

individual RMPs, based on recommendations from BLM 

specialists: 

•	 The Powder River RMP would be amended to allow 

prescribed fire to be used on more than 20 acres per 

year. 

•	 The Big Dry RMP would be amended to allow 

commercial timber harvest as a mechanical treatment 

method in the Big Dry planning area. 

•	 Decisions in the JVP, West HiLine, and Billings RMP 

would be qualified so that any timber harvested for the 

purpose of fuel reduction would not count toward 

established Allowable Sale Quantities (ASQs) or annual 

cuts for those areas. 

See Appendix C for the text of the proposed amendments. 

12
 
Table 1 - Summary of Current Fire Management Guidance (No Action Alternative) 

Wildland Fire Suppression Guidance Current Prescribed Fire/Fuels Reduction Guidance 

Control, during first burn period, all wildfires on or 

threatening public land. 

• North Dakota RMP (67,571 acres). 

• Headwaters RMP (311,337 surface acres; includes a 

portion of Lewistown FO): modified suppression 

recognized. 

• Powder River RMP (1,080,675 acres): modified 

suppression recognized. Protection priority goes to 

highest-value resources. 

All wildfires fires receive initial attack unless a 

modified suppression plan is developed and in effect: 

• West HiLine RMP (626,098 acres) Also establishes 

criteria for identifying limited suppression areas. 

• South Dakota RMP (280,672 acres). No fires are 

allowed to burn unless covered by an approved 

prescribed burn plan or modified suppression plan. 

Intensive and Conditional Suppression, by Area: 

Fires will be intensively suppressed in areas with high 

resource value, structures, improvements, developments, 

commercial forest values, sagebrush and juniper areas, 

fire sensitive woody riparian areas, and cultural areas. 

Conditional suppression will be applied to areas with 

resources low in value or not warranting initial action/ 

high costs: 

• Judith RMP (867,591 acres) and Phillips RMP 

(1,084,960 acres): Allowable burn acreages 

established. 

• Valley RMP (1,134,644 acres). 

• Big Dry RMP (1,703,830 acres): Intensive areas 

require immediate suppression. Varying response 

in conditional areas. Requires rehabilitation plans if 

more than 25 acres burn. 

Respond to all fires on or threatening public lands: 

• Billings RMP (431,676 surface acres). 

Use a modified suppression plan for wilderness areas, 

primitive areas, and selected areas. Control and 

confinement areas identified. 

• Dillon MFP (902,528 acres). 

Develop a Fire Management Plan to identify areas for 

the appropriate actions of control or confinement. 

• Garnet RMP (145,660 acres). 

Prescribed Burning 

Prescribed burning is currently allowed on 8.2 million 

acres, with: 

No limitations 

• Headwaters RMP, Dillon Management Framework 

Plan (MFP), North Dakota RMP, and South Dakota 

RMP. 

Annual acreage limitation 

• Within the Powder River planning area, prescribed 

burning may be used on about 20 acres per year. 

Prescribed Burning Restrictions in WSAs 

Prescribed fire will not be used in WSAs in the JudithValley-Phillips planning area. Other RMPs do not 

mention whether prescribed fire is allowed in WSAs. 

Existing policy, however, does provide guidance on 

limited situations when the use of prescribed fire could 

be considered in WSAs. (This analysis does not 

consider new RMP decisions for expanded use of 

prescribed fires in WSAs). 

Prescribed Burning Restrictions on Certain 

Landcover Types: 

Garnet RMP: Prescribed fire is not allowed on 5,820 

acres adjacent to stream channels and recreation sites. 

(This analysis does not consider expanded use of fire in 

these areas). 

Other Management Limitations 

Six plans do not limit prescribed burning but do limit 

timber management options, which affect BLM’s ability 

to effectively implement mechanical hazardous fuels 

reduction projects under the National Fire Plan and 2001 

Federal Fire Policy. 

• Big Dry RMP: No sale of sawtimber except 

salvage harvest ponderosa pine. Wood product sales 

are only allowed in Knowlton, Pine Unit, and 

Missouri Breaks areas. Mechanical treatments are 

limited to 15 percent or less slopes. 

• Billings RMP: Annual cut limited to 70 thousand 

board feet (MBF) per year over a 10-year period. 

• Judith-Valley-Phillips (JVP) RMP: Allowable Sale 

Quantity (ASQ) of forest products limited to 650 

MBF per year over a 10-year period. 

• West HiLine RMP: ASQ of forest products limited 

to 300 MBF per year over a 10-year period. 

13
 
5 

Table 2 Comparison of Fire Management Categories (H-1601-1 Land Use Planning Handbook and 

Category A: Fire is not desired at all (38,000 acres) 

Category B: Unplanned fire is likely to 

cause negative effects (81 .million acres) 

Category C: Fire is desired to manage 

ecosystems, but current 

vegetative condition creates constraints 

on use (2.52 million acres) 

Cat

con

acr

Fire Management Activities • Mitigation and suppression required 

• Fire should not be used to manage 

fuels 

Fire Management Activities • Suppression required 

• Fire and non-fire fuels treatments may 

be used 

Fire Management Activities: • Suppression may be required • Fire and non-fire fuels treatments may 

be used 

Fir• S

• B

cou

Rationale for Categorization: 

• Direct threats to life or property 

• Ecosystems not fire dependant • Long fire return intervals 

Rationale for Categorization: 

• Unplanned ignitions would have 

negative effects on ecosystems unless 

mitigated 

Rationale for Categorization: 

• Significant ecological, social, or 

political constraints 

Rat

• F

pol• Le

Fire Suppression Considerations: 

• Emphasis on prevention, detection, 

and rapid suppression response and 

techniques 

Fire Suppression Considerations: 

• Emphasis on prevention/education 

and suppression 

Fire Suppression/Use Considerations: 

• Emphasis on reducing unwanted 

ignitions, resource threats, and fuels 

accumulations 

Fir

• E

unp

obj

Multiple Fire Priority: 1 Highest 

Multiple Fire Priority:1 

High 

Multiple Fire Priority: 1 

Medium 

Mu

Low

Anticipated type and level of fire/fuels 

treatments: • <1,000 acresmechanical 

Anticipated type and level of fire/fuels 

treatments, including treating areas 

that were previously treated: 

• 105,000 acres prescribed fire 

• 74,000 acres mechanical • 37,000 acres chemical weed treatment 

Anticipated type and level of fire/fuels 

treatments, including treating areas that 

were previously treated: 

• 192,000 acres prescribed fire 

• 84,000 acres mechanical • 149,000 acres chemical weed treatment 

Anttrea• 2

fire 

14
 

1 If multiple fires were burning, Categories A and B would generally receive priority for fire management resources. 
Table 3 Montana/Dakotas Fire Management Zones1 

Field Office Fire Management Zone Category Size (acres) BLM acres 

(approximate) (approximate) 

Billings 1. Billings Grasslands B 9,025,800 263,500 

(see Map 3) 2. Roundup B 853,000 86,700 

3. Pryor Mountains C 138,600 50,100 

4. Big Timber/Absaroka B 768,200 11,500 

5. Twin Coulee WSA B 12,700 7,100 

6. Pompey’s Pillar B 500 500 

Butte 1. Absaroka Foothills C 67,700 3,900 

(see Map 4) 2. Big Belt Mountains C 360,300 7,200 

3. Big Hole River Corridor C 68,800 11,100 

4. Blackfoot (See Missoula FO) C 340,800 0 

5. Boulder River B 264,400 14,300 

6. Clancy/Marysville C 299,600 28,200 

7. Elkhorn Mountains C 482,900 68,900 

8. Fleecer Mountains C 284,300 18,100 

9. McCartney/Rochester C 273,600 28,100 

10. North Hills B 33,900 6,300 

11. Pipestone C 369,300 41,000 

12. Scratchgravel Hills B 126,900 7,900 

13. Sleeping Giant/Sheep Creek C 82,600 20,500 

14. Spokane Hills and North B 156,500 6,800 

15. Three Forks C 485,000 31,200 

16. Wise River Townsite B 10,100 1,400 

17. Bozeman/Livingston Scattered Tracts A 1,714,300 7,300 

Dillon 1. Beaverhead Mountains B2 743,300 27,100 

(see Map 5) 2. Beaverhead/Jefferson A2 556,400 14,900 

3. Big Hole River Corridor C2 68,800 6,900 

4. Big Sheep/Medicine Lodge Backcountry Byway B2 96,100 46,500 

5. Blacktail Mountains C2 34,600 21,400 

6. Blacktail/Horse Prairie C2 593,300 236,100 

7. Centennial C2 505,800 131,800 

8. East Madison C2 320,600 9,800 

9. Gravelly Mountains C2 556,600 34,300 

10. Madison Valley A2 410,200 23,300 

11. McCartney/Rochester C2 273,600 89,600 

12. North Rubys D2 26,800 13,700 

13. SE Foothills/Pioneers C2 969,100 91,500 

14. Sweetwater/Ruby C2 295,300 81,500 

15. Tendoy Mountains C2 131,700 52,500 

16. Tobacco Root Mountains C2 289,900 29,300 

Lewistown 1. Timber/Mountain Range B 262,200 37,900 

(see Map 6) 2. Range/Grasslands B 19,401,800 707,800 

3. Breaks C 1,463,700 670,400 

4. Front Range C 82,800 14,600 

Malta 1. Timber/Mountain Range B 65,200 30,100 

(see Map 7) 2. Range/Grasslands B 4,913,700 1,853,800 

3. Breaks C 376,300 247,700 

Miles City 1. Cedar Breaks B 122,000 60,400 

(see Map 8) 2. Vicinity of Custer National Forest C 1,804,500 136,100 

3. Knowlton-Locate C 36,200 11,700 

4. Missouri-Musselshell River Breaks C 483,000 178,900 

5. Mixed Grass Prairie Sagebrush B 23,020,300 2,240,300 

6. Rural Interface B 232,700 30,400 

7. Special Management Areas C 95,000 94,200 

Missoula 1. Blackfoot C 357,000 71,100 

(see Map 9) 2. Clark Fork Front B 223,600 15,900 

3. Flintrock B 529,300 21,500 

4. Hoodoo C 389,400 31,600 

North Dakota 1. North Dakota Resource Area B – 59,600 

South Dakota 2. Exemption Area B 22,400 5,400 

(see Map 10) 3. Fort Meade Recreation Area ACEC B 6,700 6,500 

4. Remainder of South Dakota Field Office B – 263,900 

1

 Category and associated treatments only apply to BLM land within each zone 

2

 Likely categories within the Dillon Field Office. Final category decisions will be made in the Dillon RMP/EIS 

15
 
2.5.3.1 Direction for fire management (including both fire 

suppression and fuels management) to protect other 

resource values 

The following direction would be used when developing 

and updating field office fire management plans, when 

responding to wildland fires, and when developing sitespecific fuels projects. This direction would not be 

mandatory during wildland fire suppression if using it would 

compromise protection of life or property. 

Aquatic Species (including Special Status Species) and	


Habitat	


Fuels Management	


•	 To provide additional protection of aquatic species 

beyond Streamside Management Zone (SMZ) 

boundaries, Riparian Protection Zones (RPZs) would 

be identified to protect the following specific key 

ecological functions: 

· water quality, to a degree that provides for stable 

and productive riparian and aquatic ecosystems; 

·	 stream channel integrity, channel processes, and 

the sediment regime (including the elements of 

timing, volume, and character of sediment input 

and transport) under which the riparian and aquatic 

ecosystems developed; 

·	 instream flows to support healthy riparian and 

aquatic habitats, the stability and effective function 

of stream channels, and the ability to route flood 

discharges; 

· natural timing and variability of the water table 

elevation in meadows and wetlands. 

· diversity and productivity of native and desired 

non-native plant communities in riparian zones. 

•	 The width necessary to protect stream and riparian area 

structure and function should be determined from watershed and site-specific analysis. Interim RPZ boundaries described below should be considered default 

boundaries until final boundaries are determined by 

watershed or site-specific analysis. Final RPZ boundaries may be narrower or wider, depending on local 

conditions and results of the project specific analysis. 

•	 Interim RPZ boundaries within forested zones would 

be: 

· Streams, ponds, lakes containing Special Status 

Fish Species: two site-potential tree heights 

· Other fish-bearing streams: one site-potential tree 

height 

·	 Ponds, lakes, and wetlands greater than 1 acre: the 

RPZ consists of the body of water or wetland and 

the area to the outer edges of the riparian vegetation, 

or to the extent of the seasonally saturated soil, or 

to the extent of moderately and highly unstable 

areas, or to a distance equal to one site-potential 

tree height (whichever is greatest) 

• 	 Interim RPZ boundaries for non-forested rangeland 

ecosystems would consist of the body of water or 

wetland and the area to the outer edges of the riparian 

vegetation, or to the extent of the seasonally saturated 

soil, or to the extent of moderately and highly unstable 

areas, or (in segments where trees are present) to a 

distance equal to one site-potential tree height 

(whichever is greatest). 

•	 Fuels treatments could occur within these RPZs; 

however, riparian values would receive primary 

management emphasis during fuels treatments. 

•	 All proposed fuels treatments within RPZs should 

analyze particular risk from wildfire and fuels 

management projects to isolated, depressed populations 

in degraded habitats without access to local or regional 

refugia. Proposed treatments should incorporate 

specific design features to avoid any further degradation 

of habitat. 

•	 If RPZ boundaries are narrower than SMZ boundaries, 

fuels treatments would still comply with applicable state 

laws and Water Quality/Forestry Best Management 

Practices that BLM has adopted. 

•	 See Appendix D for more complete development of the 

RPZ strategy. 

• The following conservation measures would be 

applied to protect Threatened and Endangered fishes: 

Pallid Sturgeon (Endangered) 

•	 No aerial retardant should be applied within 

300 feet of the Yellowstone River below the 

mouth of the Powder River or within 300 feet 

of the Upper Missouri River (above Fort Peck 

Dam). 

•	 Restrict livestock grazing of riparian 

vegetation, especially cottonwood stands 

along the Upper Missouri River (above Fort 

Peck Dam), and Yellowstone River below the 

mouth of the Powder River, where that 

vegetation has been recently affected by fire 

or other catastrophic events (blowdown, ice 

shear, flood etc.) until successful regeneration 

of vegetative components occurs. 

Bull Trout (Threatened) 

•	 Projects shall be designed using the guidance 

set forth in the “Interim Bull Trout Habitat 

Conservation Strategy.” 

•	 BLM would comply with the Terms and 

Conditions in the Biological Opinion from 

FWS. 

16
 
Cultural and Paleontological Guidance 

Fire Suppression 

•	 The following guidance is recommended for the 

protection of cultural and paleontological resources 

during fire suppression, stabilization, and restoration 

activities. These guidelines should be incorporated into 

Montana’s existing Protocol in consultation with the 

MT SHPO. The ND Field Office and the SD Field 

Office should consult with their respective SHPOs on 

implementation of these recommended guilelines. A 

Programmatic Agreement may be the appropriate 

instrument for their implementation: 

·	 Fire suppression tactics would limit surface 

disturbance to protect cultural resource values in 

designated cultural Areas of Critical Environmental 

Concern (ACEC), archeological districts, and other 

areas known or suspected to contain cultural 

resources, including historic structures and 

features. Use of earth moving/tillage equipment 

should be avoided for wildland fire suppression in 

areas with special designations to protect cultural 

resources and values, archeological districts, and 

other areas known to possess cultural resources. 

The use of heavy equipment and off-road vehicles 

should be limited to existing roads and trails within 

these areas during rehabilitation. 

·	 The aerial application of fire retardant would be 

restricted over areas that contain petroglyphs and 

pictographs. 

·	 Fire camps and fire staging areas should be placed 

outside and sufficiently distant from known or 

identified cultural resources. Use of off-road 

motorized vehicles outside of fire camp and staging 

areas should be avoided to prevent inadvertent 

impacts to cultural resources. 

·	 An intensive cultural resource inventory (Class III) 

as described in BLM Manual 8110 should be 

completed on areas disturbed by suppression 

activities, e.g., fire lines, fire camp areas, and 

staging areas before starting rehabilitation. Cultural 

resources discovered in or near disturbed areas 

should be protected from further damage during 

rehabilitation. Where cultural resources have been 

disturbed by suppression activities stabilization 

work may be implemented. This may entail a 

careful return of the berm over the site, seeding, or 

covering the site with protective mesh and 

culturally sterile material. These emergency actions 

should be considered on a case-by-case basis at 

the discretion of the archaeologist assigned to the 

fire. Consultation with the SHPO would be done 

in accordance with existing agreements or 36 CFR 

800. 

·	 A BLM resource advisor would be on site during 

suppression and rehabilitation activities. A 

qualified archeologist (BLM, federal, or consulting 

archeologist will be requested to give guidance and 

ensure compliance with the guidelines and 

decisions established to protect cultural resource 

values. Cultural resource input and involvement 

by the archeologist should be at the initiation of 

the fire emergency and throughout the process of 

suppression, stabilization, and restoration activities. 

·	 The archaeologist assigned to the fire would work 

with the rehabilitation team to ensure that cultural 

resources, including historic structures and 

features, are considered during fire suppression 

restoration actions. Site treatment plans would be 

prepared for historic properties that have been 

damaged by fire suppression and require more 

detailed stabilization efforts. These treatment plans 

would protect the site from secondary effects of 

the fire and fire suppression activities. 

·	 Monitoring of sensitive site areas would be 

conducted when fire suppression rehabilitation 

plans are within close proximity to historic 

properties, or could have an indirect effect on an 

existing resource. 

·	 If stabilization/protective measures were employed 

for cultural resources a report summarizing those 

actions should be submitted to an appropriate 

SHPO. The report should include a description of 

the fire impacts, fire suppression and rehabilitation, 

and salvage activities. It should also include the 

number and types of sites affected and stabilized. 

In Montana, BLM would provide a summary of 

activities performed as part of the annual report 

instead of immediate notification of fire emergency 

related activities. 

·	 In accordance with the existing agreements or 36 

CFR 800, the SHPO would be notified of a fire 

emergency and the suppression efforts associated 

with the emergency. Adjustments to these 

procedures may be made in response to comments 

from consulting parties; e.g. the SHPO, either 

programmatically through existing agreements or 

on a case-by-case basis where no agreement exists. 

·	 Surface disturbance should be limited within 

designated ACECs and formations known to 

contain significant fossil resources to protect 

paleontological values. In these areas with 

designated paleontological resources, the use of 

heavy equipment and off-road vehicles would be 

limited to existing roads and trails during 

rehabilitation. 

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·	 Fire camps and fire staging areas should be placed 

outside and sufficiently distant from known or 

identified fossil localities. Use of motorized 

vehicles outside of fire camp and staging areas in 

known fossil producing formations should be 

avoided to prevent inadvertent impacts to fossil 

resources. 

·	 Significant fossils that are exposed by suppression 

activities or would be damaged by rehabilitation 

work should be recovered by a qualified 

Paleontologist. 

Cultural and Paleontological Guidance 

Fuels Management 

•	 Develop protocol with ND and SD SHPOs similar to 

that described in IM MT No. 99-032 for Montana. This 

would allow for a sample inventory instead of a Class 

III intensive survey of an entire target area. Until that 

protocol is developed, prescribed fire projects in ND 

or SD would require consultation with the appropriate 

SHPOs to develop a prescribed fire survey and 

protection strategy. The inventory strategies developed 

for these two states should be similar to guidance 

provided in IM no. MT-99-032. 

•	 If a class III inventory is used instead of the sample 

inventory described in IM No. MT 99-032, no additional 

consultation with SHPO would be required. 

•	 Where known cultural resources are present or are 

suspected and the area cannot be avoided, hand tools 

should be used instead of motorized vehicles or heavy 

equipment to remove brush and tree cover. Also, where 

cultural resources are combustible, prescribed fire 

treatments should not be used. In these cases, hand 

tools and mechanical removal is the appropriate 

methods to ensure site protection and reduction of fuel 

load objectives. 

•	 Where known fossil resources are suspected but 

unknown and where the area cannot be avoided the 

following measures would be employed: 1. Conduct 

an inventory to identify the presence or absence of fossil 

resources employing a qualified paleontologist, 2. in 

areas where fossil resources are suspected or have been 

identified avoid using surface disturbing motorized 

vehicles, heavy equipment, or hand tools, and 3. advise 

fire personnel and others to refrain from collecting 

fossils on public lands. 

•	 An archeologist, and to the extent possible, a 

paleontologist will be used during fuels treatment 

planning, to assess the risk of damages and to 

recommend ways to minimize damage to fossil 

resources resulting from implementation of fuels 

treatments. 

Terrestrial Wildlife Species (including Special Status 

Species) and Habitat Direction common to both Wildland 

Fire Management and Fuels Management 

• 	 The following conservation measures would be 

applied to protect Threatened and Endangered terrestrial 

wildlife species: 

Interior Least Tern (Endangered) 

· No human disturbance within 1/4 mile of least tern 

nest site from May 15 to August 15; 

· No prescribed burning activities within 1 mile 

upwind of least tern nest sites. 

· 	 No helicopter/aircraft activity or aerial retardant 

application within 1/2 mile of least tern nest sites 

between May 15 and August 15; 

· 	 No prescribed burning activities within 1 mile 

upwind of nest sites between May 15 and August 

15. 

Whooping Crane (Endangered) 

·	 No human disturbance within 1/2 mile of occupied 

whooping crane habitat or potential habitat where 

whooping cranes have been identified within the 

past three years from April 1 to August 31 

·	 No helicopter/aircraft activity or aerial retardant 

application within _ mile of occupied whooping 

crane habitat or potential habitat where whooping 

cranes have been identified within the past three 

years from April 1 to August 31. 

Black-footed Ferret (Endangered) 

·	 No heavy equipment operation off of existing roads 

within 1/4 mile of prairie dog towns with 

documented occurrence of black-footed ferret 

·	 No aerial retardant application within 1/4 mile of 

prairie dog towns with documented occurrence of 

black-footed ferret 

·	 No surface disturbance (fire line construction) 

should occur in prairie dog towns with documented 

occurrence of black-footed ferret. 

Gray Wolf (Endangered) 

·	 No human disturbance or associated activities 

within 1 mile of a den or rendezvous site from April 

15 to June 30. 

Bald Eagle (Threatened) 

· No human disturbance within 1/2 mile of bald eagle 

nests from February 1 through August 15; 

·	 No human disturbance within 1/4 mile of a winter 

roost from November 1 through March 1 or, if 

within 1/4 mile, activity should be restricted to a 

period of 9 am to 3 pm; 

·	 No helicopter/aircraft activity or aerial retardant 

application within 1/2 mile of known bald eagle 

nest sites from January 1 through August 15; or 

within 1/4 mile of a winter roost from November 1 

through March 1; 

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·	 No prescribed burning activities within 1 mile 

upwind of nest sites from January 1 through August 

15; or within 1 mile upwind of a winter roost 

between November 1 and March 1. 

Piping Plover (Threatened) 

·	 No human disturbance within 1/4 mile of any 

occupied nest sites from April 1 to July 31 

·	 No prescribed burning within one mile upwind of 

any occupied nest sites from April 1 to July 31 ; 

·	 No helicopter/aircraft activity or aerial retardant 

application within 1/2 mile of piping plover nest 

sites between April 15 and July 31. 

Canada Lynx (Threatened) 

·	 Activities shall not cause a greater than 30 percent 

temporary loss or 15 percent permanent loss of 

suitable habitat in a decade. In addition, 10 percent 

of the Lynx Assessment Unit (LAU) shall remain 

in denning habitat in patches larger than five acres; 

·	 Processes used to reduce fuel levels, prepare sites 

for planting or for reintroduction of fire shall 

preserve the majority of large standing dead trees 

and large woody debris (denning habitat); 

·	 Precommercial thinning or introduction of fire into 

lynx habitat shall only occur when the forest stand 

no longer provides snowshoe hare habitat. This 

occurs when self-pruning processes have 

eliminated snowshoe hare cover and forage 

availability. 

·	 Following disturbance such as blowdown, fire, 

insects, and disease that could contribute to lynx 

habitat, do not salvage harvest when the affected 

area is smaller than 5 acres (exceptions would 

include areas such as developed campgrounds). 

Where larger areas are affected, retain a minimum 

of 10 percent of the affected area per LAU in 

patches of at least 5 acres; 

·	 Design burn prescriptions to create snowshoe hare 

habitat (e.g. regeneration of aspen and lodgepole 

pine); 

·	 Minimize construction of temporary roads, 

firebreaks, machine lines, etc. on ridges, saddles, 

or areas that would create permanent travel ways 

that could facilitate increased access by competitors 

(e.g. coyote, bobcat); 

·	 Restrict livestock grazing of fire created openings, 

aspen stands, willow carrs, and other potential lynx 

habitat until successful regeneration of shrub and 

tree components occurs. 

Grizzly Bear (Threatened) 

·	 Within the Recovery Zone, as defined in the Grizzly 

Bear Recovery Plan (USFWS 1993), any off-road 

vehicular travel or vehicular travel on restricted 

roads shall adhere to access standards/direction as 

provided in local or regional interagency 

agreements, Biological Opinions, or local Land Use 

Plans; 

·	 All activities requiring overnight stays or 

establishment of a base camp shall be limited to 

fewer than 20 individuals and less than 5 days 

duration within the Recovery Zone (defined in 

Grizzly Bear Recover Plan (USFWS 1993)); 

·	 Firewood collection within the Recovery Zone 

(defined in Grizzly Bear Recovery Plan (USFWS 

1993)) shall be limited to roadside hazard tree 

removal, road maintenance, or campground 

maintenance activities; 

·	 Activities within the Recovery Zone (defined in 

Grizzly Bear Recover Plan (USFWS 1993)) in 

Riparian, Meadows, and Stream Corridors 

including restoration and improvement projects 

must not occur between April 1 and July 1 or must 

be completed in one day; 

·	 Within the Recovery Zone (defined in Grizzly Bear 

Recover Plan (USFWS 1993)) projects that would 

significantly change the vegetative community 

should not be implemented in huckleberry 

producing sites; 

·	 In order to minimize the potential for habituation 

or human conflict, activities within the Recovery 

Zone (defined in Grizzly Bear Recover Plan 

(USFWS 1993)) will adhere to Interagency Grizzly 

Bear Guidelines or local interagency grizzly bear 

standards for sanitation measures or storage of 

potential attractants; 

·	 Within the Recovery Zone (defined in Grizzly Bear 

Recover Plan (USFWS 1993)) activities will not 

involve planting or seeding of highly palatable 

forage species near roads or facilities used by 

humans. 

Mountain Plover (Proposed) 

· No human disturbance within 1/4 mile of occupied 

mountain plover nest sites from April 1 to July 31; 

·	 No helicopter/aircraft activity or aerial retardant 

application within 1/2 mile of occupied mountain 

plover nest sites; 

·	 No prescribed burning within 1 mile upwind of any 

occupied mountain plover nest sites from April 1 

to July 31. 

•	 BLM would adhere to Terms and Conditions as 

provided in Biological Opinions from the FWS. 

•	 BLM would consider applying conservation and 

protection measures contained in Conservation 

Strategies, Recovery Plans, and Biological Opinions, 

where similar habitats or habitat needs exist elsewhere 

on BLM- administered lands in Montana/Dakotas. 

Vegetation Direction 

Wildland Fire Suppression 

•	 The following conservation measures would be 

applied to protect Threatened plant species: 

19
 
Western Prairie Fringed Orchid, Water Howellia, Ute
 

Ladies’-tresses (Threatened)
 

· 	 All proposed action areas within potential habitat
 

shall be surveyed by a botanically qualified 

biologist, botanist, or ecologist to determine the 

presence/absence of the species; 

·	 No action that would potentially affect the species 

will be taken within suitable habitat if surveys are 

not completed to determine the presence or absence 

of the species; 

·	 Areas of occupied habitat within a proposed project 

area will have a “site specific” no activity buffer 

established by a qualified botanist, biologist, or 

ecologist, to protect occupied habitat; 

· Best Management Practices should be applied to 

protect the area from invasive plant species; 

· Non-native species should not be used in 

revegetation of suitable habitat. 

· BLM would comply with the Terms and Conditions 

in the Biological Opinion from FWS. 

Visual Direction
 

Wildland Fire Suppression
 

•	 The use of heavy equipment and retardant for wildland 

fire suppression should be avoided in designated VRM 

Class I and Class II areas unless the impact of the fire 

would more severely impact the VRM values than the 

impact of equipment and retardant. 

•	 Fire rehabilitation of VRM Class I and II areas should 

be coordinated with a VRM specialist. 

Fuels Management 

•	 Fuels management projects should be coordinated with 

a VRM specialist. 

2.5.3.2 Additional Guidance to protect resource values 

•	 Additional guidance included in Appendix B would be 

recommended when planning and implementing fire 

and fuels treatment projects. 

2.6 Summary Comparison of Alternatives 

Table 4 summarizes the guidance for fire and fuels 

management that is available under both alternatives, and 

the new guidance that would become available under the 

proposed alternative. 

2.7 Identification of the Preferred 

Alternative 

Alternative B is BLM’s Preferred Alternative. 

20
 
Table 4 Summary Comparison of Fire/Fuels Management Alternatives 

Alternative A 

(No Action-Current Land Use Plan Direction) 

Alternative B 

(Proposed fire/fuels management/ Plan Amendments) 

Current Sources for fire and fuels Management direction and guidance: 

• National Policy (e.g., National Fire Plan, 2001 Federal Fire Policy) 

• Departmental, Bureau, and program guidance 

• BLM land use plans (RMP decisions) 

Protection measures based on current laws, regulation, and policy (see section 2.5.1) 

Priorities for treatment: 

1. Protect human life and property (e.g. interface), 

2. Reduce the risk and cost of severe wildland fires (e.g. hazardous fuels reduction), 

3. Sustain the ecological health and function of the ecosystem (e.g. restore degraded fish/wildlife habitat) 

Categorization of BLM lands would not 

guide fire management. Additional fire 

management direction would not be provided. 

Categorization of BLM lands would guide fire management: 

• Category A: Fire is not desired (38,000 acres) 

• Category B: Unplanned fire would cause negative effects 

(5.81 million acres) 

• Category C: Fire is desired to manage ecosystems, but 

current vegetative condition creates constraints on use (2.52 

million acres) 

• Category D: Fire is desired; few or no constraints on its use 

(27,000 acres) 

Anticipated level of treatment per decade: 

• 158,000 acres prescribed fire 

• 35,000 acres of mechanical treatments 

• 3,500 acres of chemical weed treatments 

Anticipated level of treatment per decade: 

• 299,000 acres of prescribed fire (Category B: 105,000 

acres. Category C: 192,000 acres. Category D: 2,000 acres) 

• 158,000 acres of mechanical treatments (Category A: 

<1,000 acres. Category B: 74,000 acres. Category C: 

84,000 acres) 

• 185,000 acres of chemical treatment (Category B: >37,000 

acres. Category C: >149,000 acres) 

Additional guidance to protect other 

resource values would not be provided. 

Additional guidance to protect other resource values (see 

sections 2.5.3.1 and 2.5.3.2) would be provided for: 

• Aquatic species and habitat (including special status 

species), cultural and paleontological resources, visual 

resources, and terrestrial wildlife species and habitat 

Fire and fuels management would be subject 

to existing RMP decisions 

ü Commercial timber harvest would not occur 

in the Big Dry RMP area. 

ü Prescribed fire in the Powder River RMP 

area would proceed at 20 acres/year. 

ü Fuels treatments would count toward ASQs 

and annual cuts in Billings, JVP, and West 

Hi Line RMPs. 

Specific RMP decisions would be amended: 

ü Commercial timber harvest could be used as a fuels 

management tool in the Big Dry planning area. 

ü Use of prescribed fire would not be limited to a level of 20 

acres per year in the Powder River planning area. 

ü Fuels treatments would not count toward established ASQ 

levels or annual cuts in the Billings, Judith-Valley-Phillips 

(JVP), and West HiLine RMPs. 

21