Chapter 4.0:


Consultation and Coordination


4.1 Public Notices, External and Internal 

Input 

BLM consulted other resource management agencies as well 

as its partners in fire suppression to determine the appropriate 

approach to a fire management update. 

Extensive public and internal input was also invited through 

letters to the public and meetings with BLM Field Office 

staff. Each Field Office identified a contact for this planning 

effort, and the project leader scheduled interdisciplinary team 

meetings with staff from each Field Office. During these 

meetings, Field Office staffs identified preliminary issues 

and special areas of concern; discussed appropriate methods 

of consultation and coordination; and discussed preliminary 

expectations for alternatives and impacts. These efforts are 

summarized below. 

4.2 Consultation and Coordination 

A Federal Register Notice of Intent to prepare a NEPA 

document and RMP amendments related to fire management 

planning was published (9/98). 

Letters were sent to 115 federal, state, and local agencies 

to announce the fire management planning process and 

offering to coordinate as appropriate (10/21/98). 

Agencies were contacted to identify issues and gather 

information. These included Northern Rockies Coordinating 

Representatives (3/18, 2/4/98), Forest Service (4/7/98), 

Montana Department of Fish, Wildlife, and Parks 

(MDFW&P) (4/16/98), Montana Fire Wardens (5/1-3/98), 

DNRC (5/1-3/98), Western States Air Resource Council (5/ 

13-15/98), MDFW&P (5/18/98), and DNRC (5/18/98) 

The BLM met with Black Hills National Forest to discuss 

opportunities for BLM/FS coordination around the South 

Dakota Exemption Area (11/1/00). 

Consultation with the USFWS on the Biological Assessment 

(BA) indicated that a finding of May Affect and Is Likely to 

Adversely Affect was appropriate for some species. Formal 

consultation with the service was initiated on December 20, 

2002. 

5,067 letters were sent to the general public announcing 

the fire management planning process and asking for issues, 

concerns, and a response from those who want to stay on 

mailing list (10/98). 

The MT congressional staffs were briefed about fire 

management planning (9/9/98). Briefings and materials were 

provided to the offices of the Congressional delegation (8/ 

13/01). 

Staffs of the SD Congressional delegation were briefed 

(8/16/01). 

Letter sent to 48 fire wardens announcing the fire 

management planning process and asking for issues and 

concerns (10/30/98). 

Letters sent to County Commissioners from each Field 

Office Manager announced fire management planning and 

offered to provide a briefing (10/98). Lewistown FO briefed 

Petroleum County Commissioners (12/2/98), Chouteau 

County Commissioners (12/7/98), Fergus County 

Commissioners (12/8/98), and Blaine County 

Commissioners (1/12/99). Lewistown FO sent letters, maps, 

and briefing statements to Hill County and Judith Basin 

County (12/98) 

Responses from initial letters and contacts include: 

general public (524), agencies (47), counties (1), fire wardens 

(17), and county commissioners (6) (12/15/98). These 

people and agencies requested to be on the mailing list. 

Field Office interdisciplinary team meetings with field 

specialists and managers included Billings (4/20/98, 5/28,29/ 

02), SD (4/27/98, 6/17,18/02), Butte and Missoula (5/7/98), 

Dillon (5/26/98, 7/22/02), Lewistown, Great Falls, Malta 

(5/28/98, 6/10/02), Miles City, ND (6/10/98, 5/30,31/02), 

Missoula (6/3-5/02), Butte (6/6/02), 

Communities at risk from wildland fire were identified 

for Montana and South Dakota, and the lists were sent to 

Montana DNRC (3/14/01) and South Dakota Department 

of Forestry (3/08/01) for coordination with other agencies. 

A final list of communities at risk in SD, ND, and MT was 

compiled and sent to each Field Office and the National 

Interagency Fire Center (NIFC) (3/21/01). 

BLM Fire Management Officers (FMOs) completed fire risk 

assessments for Montana/Dakotas (4/9-13/01) 

The Montana Association of Counties was briefed at the 

Mid-Winter Meeting in Helena Montana. Field Manager 

Tim Murphy discussed “The Federal Wildland Fire Policy 

and the Eastern Montana Experience” (2/24/99). 

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A fuels reduction coordination meeting in Lead, South 

Dakota included Interdisciplinary (ID) team members, 

representatives from BLM, Black Hills Power and Light, 

NIFC, the logging industry, SDRC, Lead Fire Dept., 

Homestake Mining Company, Lead Fire Chief, Lawrence 

County Fire Board, State of South Dakota Forestry, Pope 

and Talbot (10/31/00). 

Fire management officers conducted fire risk assessment 

for Montana/Dakotas (4/9-13/01). 

Internal BLM management briefings and meetings 

included BLM post fire conference (11/4/98), State 

Management Team (SMT) (12/15/98, 1/23/01, 7/26/01, 4/ 

24/02, 5/02/02), spring Fire Operations Meeting (5/12/99), 

and State Director Briefing (3/17/03). 

ID team developed preliminary guidelines for managing 

wildland fire and prescribed burning in sagebrush and other 

wildlife habitats (2/8/01). 

Guidelines for identifying fuels reduction projects were sent 

to each Field Office (5/31/01). 

The SMT endorsed additional meetings with field office 

resource specialists to comply with IM-2002-034 (4/24/02). 

The Preliminary EA and Fire Management Plans were 

sent to each Field Office for internal review (6/8/01). Review 

comments were due (7/2/01). Briefing packages were sent 

to each Field Office (7/31/01). A conference call with Field 

Offices discussed the status and process for public review 

(8/2/01). 

The Fire Management Plan/EA was sent to the public (8/ 

10/01). Copies were distributed to the Lawrence County Fire 

Advisory Board (8/14/01). The Billings Gazette published 

a Notice of Availability (8/15/01). A Great Falls Tribune 

story and Notice of Availability of the Fire Management 

Plan was run (8/27/01). The original comment period ended 

(9/17/01). Cards were sent to mailing list explaining the 

comment period extension (9/21/01). The extended comment 

period ended (11/16/01). 

4.3 Initial Public Input 

Through letters and contacts with the public, agencies, and 

state and local officials, BLM asked for initial comments 

and concerns by November 30, 1998. Comments from the 

public included the following: 

•	 Concerns about fuels build-up and suggestions for more 

timber sales 

•	 Prescribed fire is a good management tool that should 

be used to manage ecosystems 

• Prescribed burns should be used more often to control 

fuels build-up and pine seedlings 

• BLM should pay local fire departments to fight fires 

•	 Dams should be fixed to provide a source of water to 

fight fires 

• Farmers and ranchers should be allowed to fight fires 

• BLM should provide more equipment 

County commissioners and fire wardens expressed general 

interest in fire management planning and specific interest 

in fuels build-up around Lead, South Dakota. 

4.4 Public Comments on the Fire 

Management Plan/Plan Amendment 

Environmental Assessment 

During the August 2001 comment period following the 

release of the EA, the National Wildlife Federation requested 

a 60-day extension of the comment period in order to 

adequately review the Plan and contact specialists who might 

provide additional insight through comments. The Acting 

Associate State Director granted the extension and sent a 

card to those on the mailing list, explaining the extension 

and establishing the new deadline for submitting comments 

(November 16, 2001). 

Fourteen letters were received by November 16. An 

additional 19 letters were received after the end of the 

comment period. Five letters were from agencies, six 

were from interest groups/organizations, and 22 were 

from individuals. All comments received have been 

considered. 

A summary of the comments follows. The comments were 

grouped into four categories: NEPA Adequacy, 

Environmental Effects, Fuels Management, and Agency 

Comments. 

4.4.1 Comment Summary 

4.4.1.1 NEPA Adequacy 

A number of the comments stated that the Environmental 

Assessment (EA) failed to adequately comply with all the 

NEPA guidelines and requirements. Some of the common 

concerns were: 

• The need for action is not identified. 

• The range of alternatives is too small. 

• Analysis of potential impacts is incomplete. 

• Cumulative impacts are not discussed. 

•	 The best available science was not considered, used or 

cited in the analysis of impacts. 

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•	 The actions described in the EA are major federal 

actions and constitute an EIS. 

Response: The need for the action is specified in section 

1.2 Need for the Proposed Action. The two alternatives 

analyzed in this document represent alternative ways of 

meeting the purpose and need described in sections 1.1 and 

1.2. The proposed action (Alternative B) was developed to 

respond to national policy and hazardous fuels conditions 

in Montana and the Dakotas. Alternative A (the no-action 

alternative) represents continuation of current management 

and provides a basis for comparison of alternatives and 

impacts. Some issues have been raised that are beyond the 

scope of this analysis. These are described in section 1.4.4 

Issues eliminated from further study. Alternatives that would 

be tied to these issues were not analyzed because they were 

outside the scope of analysis or they were considered to be 

of speculative feasibility. Other alternatives emerged from 

internal analysis or from public comments. 

These were carefully considered but eliminated from detailed 

study for the reasons summarized in section 2.4. Finally, 

some issues and concerns were raised that resulted in 

modifications to the proposed action. Modifying the 

proposed action was more appropriate than specifying and 

analyzing a new alternative. Specifying a separate alternative 

in response to those issues would result in alternative(s) with 

impacts that are indistinguishable from those impacts of the 

proposed action. 

Analysis of environmental impacts, including cumulative 

impacts, has been revised in response to comments, 

additional information, and subsequent BLM guidance 

concerning fire and fuels management. References cited in 

comments have been studied. Revisions have been made to 

include relevant new and additional information where 

appropriate. See chapter 3 for analysis of environmental 

impacts. 

No significant impacts were indicated by the impact analysis. 

Documentation, including the rationale for the Finding of 

No Significant Impact (FONSI), is attached at the end of 

this analysis. 

4.4.1.2 Environmental Effects 

Letters from groups and individuals were primarily 

concerned with the environmental effects of fuels 

management, and especially prescribed burning, on 

ecosystems, wildlife and their habitats, and wilderness areas. 

Sagebrush Ecosystems and Sage Grouse Habitat


Each of the 22 letters from individuals addressed the plan’s


potential adverse effects on wildlife and their habitats. Ten


of these letters specifically addressed the sagebrush


ecosystem, and the wildlife species that depend on that


ecosystem. The primary concern was over sage grouse, but


several letters mentioned the sage habitat’s importance to 

pronghorn antelope, mule deer, and golden eagles. 

This area of concern appeared in 14 of the comment letters. 

Some cited historically low fuel loads in sage/grassland 

habitats, and questioned the need for fuels management in 

these land cover types. Other comments addressed the 

adequacy of the effects analysis. 

“The plan proposes to ignite ‘prescribed’ fires on public 

lands in several western states, which would cause the 

needless destruction of millions of acres of already 

dwindling sage/grassland habitat.” 

Six of the 14 letters also stated that adverse effects on the 

sage grouse could require their listing under the Endangered 

Species Act. 

“...this action has the potential to adversely affect sage 

grouse, and possibly result in the need for listing under 

the ESA.” 

Two comment letters referred to the Western Association of 

Fish and Wildlife Agencies (WAFWA) Memorandum of 

Understanding signed by the BLM. The WAFWA MOU 

was not mentioned in the EA and no reason was provided 

for the departure from the WAFWA guidelines for sage 

grouse conservation. 

Another concern expressed was whether or not prescribed 

burning would be beneficial in sagebrush ecosystems. A 

letter challenged the conclusion in the EA stating that the 

long-term benefit of burning sagebrush ecosystems is greater 

perennial grass production. A study of big sagebrush 

ecosystem recovery by C.L. Wambolt et. al. is cited. 

“The Wambolt research would indicate that the benefits 

of fire to forage production are short-term while having 

long term detrimental effects on sagebrush obligates.” 

Response: BLM responded to these comments by clarifying 

the following portions of the EA: 

•	 Anticipated Level of Activity: It is anticipated that 3 

percent or less of BLM shrublands would be treated 

with prescribed fire or mechanical treatments. Also only 

a portion of these shrublands would be sagebrush. 

•	 Management Common (section 2.5.1) clarifies the 

intent of treating shrublands. 

•	 Purpose and Need indicates that Condition Class 2 and 

3 areas would be the primary focus of fuels reduction 

treatments. 

A description of the affected environment of terrestrial 

species and habitat as well as environmental consequences 

is available in section 3.2. This includes analysis of 

sagebrush ecosystems and sage grouse habitat. The impact 

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analysis is based on the anticipated fire suppression actions 

and fuel reduction treatments on 3 percent or less of 

shrublands per decade with either alternative. The primary 

purpose of these treatments would be to control encroaching 

conifers. See the description of treatments in section 3.1.1.3. 

Wilderness


One of the letters expressed concern over how some of the


forest acres were categorized. It was stated that more acres


could have been categorized under Categories C and D,


which allows for more prescribed fire use and wildfire may


be desired.


“It would have been ideal to have more acreage fall into 

the Category C and D, where wildfires will be allowed to 

burn, and prescribed fire would have a large role.” 

One of the letters that expressed concern over the use of 

prescribed fire in sagebrush ecosystems commented 

specifically in support of the conclusions contained in 

comment letter #8. 

“We feel there is a much more significant ecological role 

for fire in forest habitats comprised of fire adapted species 

in contrast to shrub-steppe habitats where climax species 

such as sagebrush are killed by fire. We would support 

an analysis of more prescribed fire and less fire 

suppression in forested wilderness and wilderness study 

areas.” 

Another letter expressed that wild, untouched forested areas 

have more natural defenses to fire than developed areas. It 

was stated that fire suppression or fuels reduction activities 

could increase fire severity in these areas. 

Response: WSA polygon categories were re-evaluated to 

determine whether natural ignitions could be allowed to burn 

in wildland areas. The categorization of one polygon (which 

included three WSAs) was changed from B to C. Reasons 

for not changing the categorization of other fire management 

zones are described in section 2.4.2. 

An estimated 85 percent of forestlands in Montana are in 

condition class 2 or 3. It is anticipated that with both 

alternatives, over 60 percent of all the areas treated would 

be forestlands compared to less than 17 percent for 

shrublands. 

Vegetation


One comment letter suggested a more specific discussion


of the various vegetation types present in Montana and the


Dakotas and how they respond to fire.


“No descriptions, analysis or even conclusions are 

presented concerning the anticipated effects of 

Alternatives A and B on grasslands, shrublands and 

forestlands.” 

Response: See section 3.2. Grasslands are analyzed in 

section 3.2.1, shrublands are analyzed in section 3.2.2, and 

forestlands are analyzed in section 3.2.3. 

Wildlife


The same letter indicated that the EA’s discussion on wildlife


including T&E and BLM sensitive species was also


inadequate, and should be more specific to Montana.


“The discussion of effects on fish and wildlife should 

address how the alternatives might be expected to affect 

the distribution and abundance of habitats for these [mule 

deer] and other species.” 

As discussed above, all 22 comment letters from individuals 

addressed wildlife. Ten of the 22 specifically mentioned 

sagebrush ecosystems and species, and the remaining 12 

expressed concern over potential adverse effects on wildlife 

and their habitats. Eleven of these letters identified that an 

EIS is the desired level of analysis. 

Response: The affected environment and anticipated 

environmental consequences on aquatic habitats and species 

are analyzed in section 3.6, terrestrial species and habitats 

(including Special Status Species) are analyzed in section 

3.7, and federally threatened, endangered, and proposed 

species are analyzed in section 3.8. 

4.4.1.3 Fuels Management 

The EA proposes to reduce hazardous fuels by prescribed 

fire, mechanical and other means. Comments regarding fuels 

management ranged from questioning the need for fuels 

management in some areas to stating that the EA should 

more clearly indicate guidance on where and what type of 

fuels management would be used. 

Another letter indicated that it is structure ignitability that 

is responsible for structure loss and not fuels buildup. The 

letter states, 

“The NEPA document must provide scientific support that 

vegetation treatments will decrease susceptibility to 

wildfires.” 

The same letter continued, 

“An unnatural fire policy (even on grasslands) could 

prevent fire from playing its natural role, and may turn 

out to be just another ill-conceived form of vegetation 

manipulation.” 

An organization expressed concern with the discussion about 

what types of fuels treatments would be used and some 

suggestions were made. 

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“The EA vaguely refers to a number of actions that could 

be taken to reduce fuels.” 

“Thinning [in ponderosa pine forests] may improve forest 

structure and productivity, benefit wildlife habitat and 

reduce some fire risk.” 

The letter also indicated that thinning may not be necessary 

in high elevation forests and that the BLM field offices 

should received guidance on how best to use fuels treatments 

in a variety of habitat types. 

Response: The need to reduce hazardous fuels is a major 

component of the National Fire Plan. See section III (Key 

Elements of the Administration’s Wildland Fire Management 

Policy), subsection B (Reducing Hazardous Fuel 

Accumulations) of A Report to the President in Response to 

the Wildfires of 2000 (http://www.fireplan.gov/ 

president.cfm). This section references several examples 

where fuels treatments mitigated the severity of wildfires 

that later occurred on treated areas, including an example 

from the Jasper Fire in South Dakota. 

Table 4 and 5 indicate the anticipated levels and types of 

treatments (prescribed fire, mechanical, and chemical weed 

treatments) that may be used within the different fire 

management categories and on different types of vegetation. 

This is also used as a basis for impact analysis. 

Specific decisions on where and how fuels treatments would 

be used will be made at the project level. 

4.4.1.4 Agency Comments 

Comments from other agencies focused primarily on how 

their management directions would be affected by actions 

described in the BLM’s Fire Management Plan/Plan 

Amendment Environmental Assessment. Some of the 

agencies also provided clarification on boundaries and “on 

the ground” conditions, and suggested adjustments where 

appropriate. For example, one agency comment questioned 

the need for prescribed burning in the Missouri River Breaks 

Uplands fire management zone, which is managed by the 

Malta Field Office. 

“Another justification for prescribed burning in the 

Missouri Breaks Uplands is to create a mosaic of habitat 

types to benefit wildlife; however, such a mosaic already 

exists as stated in your Area Description.” 

One agency comment was similar to those comments 

described in sections 4.4.1.1 and 4.4.1.2, regarding NEPA 

adequacy and potential effect on the sage grouse. 

Specifically, the comment indicated that increasing use of 

prescribed fire could represent a possible significant impact 

on the human environment, and that an EIS-level analysis 

may be more appropriate based on potential effects on 

wildlife species and sage grouse in particular. 

The agency indicated that effects of the proposed action 

could not be determined without knowing the locations of 

priority interface areas referenced in the EA. 

Response: See response to comments in sections 4.4.1.1 

and 4.4.1.2. Map 2 shows communities/areas at risk from 

wildland fire that are near BLM lands. 

4.5 Public Comments on Revised EA 

The EA was revised and re-released for public review and 

comment in May 2003. BLM received four comments on 

the revised EA. These comments are summarized below. 

The Montana State Historic Preservation Officer suggested 

clarifications to the resource protection guidance included 

in the proposed action (section 2.5.3.1). 

The Montana Department of Transportation clarified the 

notification requirements if MDT rights-of-way are needed 

for access during projects. 

Montana Fish, Wildlife & Parks noted concern with burning 

in sagebrush-grassland in relation to the needs of sage 

grouse, pygmy rabbits, and other obligates of the sagebrush 

steppe habitat type. FWP acknowledged the reference to 

BLM’s Special Status Species policy, which is to “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.” 

Stephen J. Flynn, Resource Manager of Louisiana-Pacific 

Corporation, commented that the RPZ recommendation 

included in Alternative B is excessive, and that the 

Streamside Management Zone is adequate. 

Response: Slight modifications were made to the guidance 

(section 2.5.3.1) to respond to the comments from the MT 

SHPO. The RPZ concept was included in the design features 

under Alternative B to avoid significant impacts to aquatic 

resources. See section 3.6 and Appendix D for the rationale 

for including RPZ approaches in the proposed action. 

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