Tri-State Fuel Breaks Project Draft EIS Volume 1

U.S.
Department of the Interior

Bureau of Land Management
Tri-state Fuel Breaks Project

Draft Environmental Impact Statement (Volume 1)
DOI-BLM-ID-B000-2015-0001-EIS
October 2019
Boise District Office

3948 Development Ave.
Boise, Idaho 83705
Vale District Office

100 Oregon St.
Vale, Oregon 97918
Estimated Lead Agency Total Costs

Associated with Developing and
Producing This DEIS
$1,408,000
The Bureau of Land Management’s multiple-use mission
is to sustain the health and productivity of the public lands
for the use and enjoyment of present and future
generations. The Bureau accomplishes this by managing
such activities as outdoor recreation, livestock grazing,
mineral development, and energy production, and by
conserving natural, historical, cultural, and other resources
on public lands.
Executive Summary
Introduction
This draft environmental impact statement (DEIS) evaluates creating and maintaining a system of roadside
fuel breaks to improve suppression coordination and response across the Tri-state area where southeastern
Oregon, southwestern Idaho, and northern Nevada converge. This area contains the largest expanse of intact
sagebrush steppe in North America, an ecosystem that supports diverse wildlife and is critically imperiled by
the threat of wildland fire. The project area encompasses 3.6 million acres across the southeastern corner of
Oregon and southwestern corner of Idaho. The proposed fuel breaks would connect to existing fuel breaks
within northern Nevada to improve firefighting coordination across jurisdictional and state boundaries and
better protect this threatened landscape.
Purpose and Need

The purpose of the action alternatives is to provide a network of safe areas and strategic opportunities to
enable wildland fire suppression resources in the Tri-state area to more rapidly and effectively protect natural
and cultural resources and socioeconomic values from wildfires. The Wildland Fire Directive (2017),
Executive Order 13855 (2018), and Department of Interior Secretarial Order (SO) 3372 (2019) instruct the
Department of Interior to incorporate active fuels management into resource-management planning to
prevent and combat catastrophic wildfires. Through its consideration of action alternatives, the BLM seeks to
leverage fuel treatments to meet this goal.
Public Involvement and Issues

In the spring of 2016, the Boise District and Southeast Oregon Resource Advisory Councils (RACs) formed
a subcommittee (RAC subcommittee) that held a series of meetings regarding the BLM’s proposal to identify
issues and inform the development of action alternatives. The BLM considered public responses provided
during three scoping meetings held in Boise, Idaho, Murphy, Idaho, and Jordan Valley, Oregon in January
2017. It also considered public comments submitted during the scoping period and input from cooperating
agencies and Tribes. For more information on the scoping process, see section 1.4.
Issues such as direct and indirect costs and consequences of the project, impacts on wildlife and special
status species, impacts on known and unknown cultural sites of significance, and the potential for the
introduction or spread of invasive plants were identified during scoping and are addressed in this DEIS. For
the full list of issues analyzed, see section 1.4.
Decision to Be Made
The BLM will decide whether to construct and maintain a fuel break network across 1,539 miles of existing
roads in southeastern Oregon and southwestern Idaho in order to provide safe spaces and strategic
opportunities for wildland firefighters to protect the sagebrush steppe from catastrophic wildfire. Each of the
action alternatives evaluated in this DEIS would directly result in construction of roadside fuel breaks on
BLM-administered lands, as well as State-managed lands where authorized, and approve maintenance of
these fuel breaks in perpetuity.
Alternative 1 (No Action)

Under the No Action Alternative, a strategic fuel break network connecting the Tri-state area would not be
developed and maintained.
Alternative 2 (Proposed Action)

Alternative 2 contains all roads that BLM fire suppression experts recommended for the fuel break network
based on their accessibility and strategic importance to suppression resources. It would result in up to 67,559
Tri-state Fuel Breaks Project Draft EIS

DOI-BLM-ID-B000-2015-0001-EIS Page ES-1
acres of roadside mowing and/or seeding treatments and a total fuel break network of 73,920 acres1 along
1,539 miles of established roads. Up to 950 miles of roads could require blading to remove vegetation within
the roadbed.
Alternative 3 (Social/Cultural Emphasis)

Alternative 3 incorporates criteria developed by the RAC subcommittee to limit impacts to cultural
resources, wilderness study areas, and lands with wilderness characteristics. Under this alternative, the BLM
would mow and/or seed up to 45,872 roadside acres to create a total fuel break network of up to 51,127 acres
along 1,063 miles of established roads. Up to 585 miles of roads could require blading to remove vegetation
within the roadbed.
Alternative 4 (Wildlife Habitat Emphasis)

Alternative 4 also incorporates criteria from the RAC subcommittee and emphasizes avoiding important
wildlife habitat, including greater sage-grouse nesting habitat. Under this alternative, the BLM would mow
and/or seed up to 38,044 roadside acres to create a total fuel break network of up to 43,833 acres along 910
miles of established roads. Up to 399 miles of roads could require blading to remove vegetation within the
roadbed.
Impact Analysis
For a detailed analysis of impacts by method and alternative, see Chapter 3.The following general impacts
would be expected under the action alternatives in this DEIS:
• Safer and more effective wildland firefighting within the project area. Reduced fire behavior within fuel
breaks would allow for a more rapid and effective suppression response upon arrival to an incident.
• Reduced wildfire size and intensity related to increased fire suppression opportunities and decreased
potential for wildfire spread across fuel breaks when firefighters are present. This would result in
increased protection for native habitats and restoration projects.
• Vegetation modification and soil disturbance caused by fuel break creation and maintenance, which
would exist for the life of the fuel breaks.
• Potentially long-term wildlife habitat impacts caused by development of fuel breaks depending on the
current vegetation community. For example, in treatment areas where there is more sagebrush than
invasive annual grasses, sagebrush would be mowed to a height of 6 to 10 inches, reducing cover and
forage for wildlife within the area of the fuel break.
• Impacts to greater sage-grouse. Greater sage-grouse are a BLM sensitive species and an indicator species
for the sagebrush steppe ecosystem. Landscape cover of sagebrush is a strong predictor of persistence for
sage-grouse. Action alternatives are designed to better protect vast expanses of sagebrush from
catastrophic wildfire, however fuel breaks would reduce landscape cover of sagebrush along roads in the
fuel break network.
Collaboration and Coordination
The BLM is the lead agency for this DEIS. Organizations, state, local, and tribal governments, and other
agencies invited to participate as cooperating agencies and consulting parties can be found in section 4.2. A
more detailed summary of the BLM’s consultation and coordination efforts can also be found in Chapter 4.
1
For all action alternatives, total acres of the fuel break network exceed acres recommended for treatment because the BLM
would not treat certain areas within the fuel break network. These areas either already meet fuel break criteria (e.g., areas
with low or no vegetation) or would be avoided (e.g., riparian areas).

DOI-BLM-ID-B000-2015-0001-EIS Page ES-2
Volume 1: Executive Summary, Chapters 1 through 5
Table of Contents
Executive Summary .........................................................................................................................ES-1

1.0 Introduction................................................................................................................................1
1.1 Need for and Purpose of Action.....................................................................................................2
1.2 Fire Behavior and Fuel Breaks ......................................................................................................3
1.3 Conformance with Applicable Land Use Plans and Other Related Documents ............................5
1.4 Scoping and Development of Issues ..............................................................................................5
2.0 Description of the Alternatives ..................................................................................................7
2.1 Features Common to All Action Alternatives ...............................................................................7
2.1.1 Fuel Break Treatments ....................................................................................................9
2.1.2 Methods .........................................................................................................................10
2.2 Alternative 1 – No Action Alternative .........................................................................................15
2.3 Alternative 2 – Maximum Fire Suppression Emphasis (Proposed Action) .................................15
2.4 Alternative 3 – Social/Cultural Emphasis ....................................................................................17
2.5 Alternative 4 – Wildlife Habitat Emphasis ..................................................................................18
2.6 Comparison of Action Alternatives .............................................................................................19
3.0 Affected Environment and Environmental Consequences ......................................................21
3.1 Fire and Fuels Management .........................................................................................................22
3.1.1 Affected Environment ...................................................................................................22
3.1.2 Environmental Consequences .......................................................................................25
3.1.3 Cumulative Impacts.......................................................................................................32
3.2 Soils .............................................................................................................................................35
3.3 General Vegetation including Noxious and Invasive Weeds.......................................................47
3.4 Sensitive Plants ............................................................................................................................65
3.5 Wildlife/Special Status Animals ..................................................................................................70
3.6 Cultural Resources .....................................................................................................................101
3.6.1 Affected Environment .................................................................................................101
3.6.2 Environmental Consequences .....................................................................................105
3.6.3 Cumulative Impacts.....................................................................................................114
3.7 Paleontological Resources .........................................................................................................117
3.8 Wilderness Study Areas .............................................................................................................126

DOI-BLM-ID-B000-2015-0001-EIS i
3.9 Lands with Wilderness Characteristics ......................................................................................133
3.10 Visual Resource Management ...................................................................................................141
3.11 Irreversible and Irretrievable Commitments of Resources ........................................................148
4.0 Consultation and Coordination ..............................................................................................149
4.1 Tribal Consultation ....................................................................................................................149
4.2 List of Agencies, Organizations and Individuals Consulted ......................................................150
5.0 Literature Cited .......................................................................................................................... i
Tables
Table 2-1. Resilience and resistance (R&R) acres for fuel breaks................................................................... 10
Table 2-2. Herbicides proposed for use. .......................................................................................................... 13
Table 2-3. Alternative 2 recommended primary vegetation treatments. .......................................................... 16
Table 2-6. Comparison of seedbed preparation treatments in action alternatives............................................ 19
Table 2-7. Comparison of primary treatments in action alternatives. .............................................................. 20
Table 3-1. Impact descriptors. .......................................................................................................................... 21
Table 3.1-1. Fire regime groups. ...................................................................................................................... 23
Table 3.1-2. Estimated historical fire return intervals. ..................................................................................... 23
Table 3.1-3. Invasive annual threat. ................................................................................................................. 24
Table 3.1-4. Resistance and resilience. ............................................................................................................ 25
Table 3.1-5. Fire behavior fuel models. ........................................................................................................... 25
Table 3.1-6. Average miles of fuel break and fire intersections modeled by alternative. ................................ 28
Table 3.1-7. Fuel break impacts to sage-grouse habitat compared to modeled impacts of wildfire. ............... 29
Table 3.1-8. Fire suppression and ESR costs of large fires (2018 dollars). ..................................................... 30
Table 3.1-9. Total costs of fuel break by action alternative*. .......................................................................... 31
Table 3.2-1. Affected environment: Potential for erosion by wind.................................................................. 37
Table 3.2-2. Affected environment: Potential for erosion by water................................................................. 37
Table 3.3-1. R&R acres in the affected environment. ...................................................................................... 49
Table 3.3-2. R&R for the major vegetation groups in the fuel break and buffer. ............................................ 50
Table 3.3-3. Acres of no treatment recommended in major vegetation groups by alternative. ....................... 57
Table 3.3-4. Alt. 2: Acres of recommended primary treatment methods in major vegetation groups. ............ 58
Table 3.3-5. Alt. 3: Acres of recommended treatments in major vegetation groups. ...................................... 60
Table 3.3-6. Alt. 4: Acres of recommended treatments in major vegetation groups. ...................................... 61
Table 3.5-1. Affected BLM Special Status Wildlife Species (SSW) and analysis group (bold). .................... 70
Table 3.5-2. Acres of designated sage-grouse habitats in the Sage-Grouse Analysis Area (SGAA) and action
alternative footprints. ....................................................................................................................................... 73
Table 3.5-3. Occupied or pending sage-grouse leks and lek complexes in project area and Sage-grouse
Analysis Area (SGAA)..................................................................................................................................... 74

DOI-BLM-ID-B000-2015-0001-EIS ii
Table 3.5-4. Acres of sage-grouse nesting habitat within the project area and SGAA by alternative. ............ 74
Table 3.5-5. Distribution of leks within the SGAA by landscape cover of sagebrush, and likelihood of
persistence. ....................................................................................................................................................... 75
Table 3.5-6. Acres of suitable and priority pygmy rabbit habitat by type and alternative. .............................. 76
Table 3.5-7. Big Game (Bighorn Sheep, Pronghorn Antelope, Mule Deer, Elk) habitat in the project area*
and treatment areas by action alternative. ........................................................................................................ 79
Table 3.5-8. Potential direct and indirect effects to wildlife from project implementation. ............................ 82
Table 3.5-9. Number of leks and lek complexes affected by Alternative 2 and miles of fuel breaks within
nesting habitat around occupied or pending leks. ............................................................................................ 89
Table 3.5-10. Acres of occupied sage-grouse habitat* in subpopulations and acres impacted by each action
alternative. ........................................................................................................................................................ 90
Table 3.5-11. Proposed mineral material sites - Distance from leks. ............................................................... 91
Table 3.6-1. Acres of cultural resource inventories by alternative and management agency. ....................... 102
Table 3.6-2. Summary of NRHP-Eligibility of cultural resource sites within the fuel break treatment area of
each alternative............................................................................................................................................... 103
Table 3.6-3. Miles of NRHP-eligible or potentially eligible roads and trails within the fuel break treatment
area of each alternative................................................................................................................................... 103
Table 3.7-1. Potential Fossil Yield Classification (PFYC) categories. .......................................................... 118
Table 3.7-2. Number of acres of PFYC Class in project area. ....................................................................... 119
Table 3.7-3. Acres of PFYC classes on BLM & State lands within the direct effects analysis areas for each
alternative.1..................................................................................................................................................... 119
Table 3.7-4. Number of known paleontological localities per alternative by state. ....................................... 120
Table 3.8-1. Wilderness characteristics of WSAs in project area. ................................................................. 127
Table 3.9-1. Summary of inventory units classified as lands with wilderness characteristics within or
overlapping the analysis area in Oregon. ....................................................................................................... 134
overlapping the analysis area in Idaho. .......................................................................................................... 135
Table 3.10-1. VRM Class crossed by Proposed Action. ................................................................................ 146
Table 3.10-2. VRM Class crossed by Alternative 3. ...................................................................................... 146
Table 3.10-3. VRM Class crossed by Alternative 4. ...................................................................................... 146
Volume 2: Appendices
Appendix A: Fire Behavior and Fuel Breaks – Great Basin Examples
Appendix B: Fire Behavior, Weather, and Fuel Modeling
Appendix C: Conformance with Applicable Land Use Plans
Appendix D: Issues Raised But Not Fully Analyzed
Appendix E: Alternatives Considered but Not Fully Analyzed
Appendix F: Rationale for Width of the Fuel Treatment Zone
Appendix G: Design Features
Appendix H: Monitoring and Adaptive Management Plan
Appendix I: Project Modeling – Recommended Primary Treatments
Appendix J: Cultivars Adapted to Conditions in Treatment Area & Vegetation and SSP Tables
Appendix K: Herbicide Characteristics and SOPs

DOI-BLM-ID-B000-2015-0001-EIS iii
Appendix L: Prescribed Fire - ARMPA Conformance
Appendix M: WSAs
Appendix N: Cumulative Actions
Appendix O: FSPro Analysis
Appendix P: Draft Programmatic Agreement
Appendix Q: Maps
Appendix R: List of Preparers, Acronyms & Glossary

DOI-BLM-ID-B000-2015-0001-EIS iv
1.0 Introduction
The convergent area (Tri-state) of southwest Idaho, southeast Oregon, and northern Nevada is one of the
largest intact strongholds of greater sage-grouse (GRSG) habitat in the Northern Great Basin (Knick and
Hanser 2011). The shrub-steppe ecosystem within this area is one of the most endangered ecosystems in the
United States. This area has been identified in the Greater Sage-Grouse Wildfire, Invasive Annual Grasses
and Conifer Expansion Assessment (Fire and Invasive Assessment Team [FIAT] 2014) as a Priority Area
of Conservation (PAC) to address the threat of wildfires, invasive annual grasses, and conifer expansion.
Management of wildfire has been identified as one of the key issues in maintaining sage-grouse populations
in sagebrush-dominated landscapes.
The accelerated invasion of non-native annual grasses, in particular cheatgrass and medusahead rye, across
the sagebrush-steppe ecosystem has led to an increased threat of rangeland fires to the sagebrush landscape.
The 2010 Rapid Eco-regional Assessment of the Northern Basin and Range and Snake River Plain
identified the Tri-state area as high risk for large-scale wildfires. This growing risk threatens not only
sagebrush-obligate wildlife like the sage-grouse, but also the ranchers, livestock managers, sportsmen, and
outdoor recreation enthusiasts who work, hunt and recreate across the sagebrush steppe.
The Tri-state project area (Figure 1-1) has experienced a significant number of wildfires within the past
decade. Map 2 (Appendix Q) shows the wildfires within and adjacent to the project area within a 48 year
period for the Boise District and a 38 year period for the Vale District. From 2016 through July 2018, over
4 million acres of sage-grouse habitat burned from wildfires nationwide (NIFC 2018a). Predictions for the
Great Basin are that 34-95% more area will burn by 2050 compared to 2006 (Zhu and Reed 2012).
Estimates of annual wildfire scenarios (Map 3, Appendix Q) illustrate the high potential for wildfire within
and adjacent to the project area (Short et al. 2016).
Wildfires in this remote area can grow quickly and affect hundreds of thousands of acres of sagebrush
habitat within a period of hours or a matter of days. Wildfires in the Tri-state area generally result from
region-wide dry lightning events. These events often lead to multiple, simultaneous ignitions that quickly
exhaust fire suppression resources. Because of the area’s remoteness, high potential for large wildfires,
long firefighter response time, and limited sites for firefighters to establish safe anchor points to engage
wildfires, strategic measures must be taken to protect one of the last remaining large, contiguous sage-
grouse habitats.
Through this project, the BLM proposes to reduce fuel loading along established roads2 through a variety
of methods over a 3.6 million-acre project area within the BLM Vale and Boise Districts. To enhance fire
suppression efforts across district and state boundaries in the Tri-state area, the proposed system of fuel
breaks would complement an existing fuel break network in BLM Elko and Winnemucca Districts in
northern Nevada. Strategically placed linear fuel breaks would provide wildland firefighters safer tactical
and logistical opportunities to engage fires. These opportunities would extend to Rangeland Fire Protection
Associations (RFPA) and rural fire departments that partner with the BLM districts to achieve the fire
suppression mission.
2
Roads proposed for fuel breaks include interstates, state highways, county roads, BLM-administered roads, and primitive
roads. Primitive routes within lands with wilderness characteristics or Wilderness Study Areas are not proposed for fuel
breaks.

DOI-BLM-ID-B000-2015-0001-EIS Page 1
Figure 1-1: Tri-state Fuel Break Proposed Project Area.
1.1 Need for and Purpose of Action

The Wildland Fire Directive (2017), Executive Order 13855 (2018), and Department of Interior Secretarial
Order (SO) 3372 (2019) instruct the Department of Interior to incorporate active fuels management into
resource-management planning to prevent and combat catastrophic wildfires. Through its consideration of
action alternatives, the BLM seeks to leverage fuel treatments to meet this goal. The sagebrush steppe of
the project area is especially at risk from wildfire, as invasive annual grasses often outcompete native plant
species in the wake of catastrophic fire, converting burned landscapes to annual grass ecosystems that can
no longer support their historic diversity of plant and animal species. A risk-based, landscape-scale fuels
treatment strategy is therefore necessary to protect the health of the sagebrush-steppe ecosystem (USDI
2015). In order to protect this threatened landscape as well as the wildlife and multiple uses it supports, the
BLM proposes constructing a strategic system of linear fuel breaks along a network of existing roads
spanning southeastern Oregon and southwestern Idaho using vegetation management techniques informed
by the best available science. The proposed system of fuel breaks would maximize the wildfire
management benefits of existing physical features (i.e., roadways), as directed in SO 3372 (2019). These
objectives must be met in accordance with all other relevant BLM policies.
The purpose of the action alternatives is to provide a network of safe areas and strategic opportunities to
enable wildland fire suppression resources in the Tri-state area to more rapidly and effectively protect

natural and cultural resources and socioeconomic values from wildfires. Action alternatives would
improve firefighter safety and efficiency by providing established anchor points 3, reducing flame lengths,
and slowing the spread of fast-moving fires. They would also increase suppression efficacy by enabling
firefighters to engage wildfires over a larger area. The proposed network would include fuel breaks along
boundary roads of Wilderness Study Areas and lands with wilderness characteristics to improve protection
of wilderness characteristics and post-fire restoration investments from wildfire and avert or combat further
conversion of these landscapes to invasive grasses. Ultimately, this proactive approach would allow the
BLM to better safeguard firefighter and public safety and to better protect and conserve one of the few
remaining large areas of intact sagebrush-steppe habitat.
1.2 Fire Behavior and Fuel Breaks

Fire behavior is influenced by fuels (i.e., vegetation), weather, and topography. Because land managers
cannot alter weather or topography, their only option to manipulate fire behavior is to modify the fuels in
the fire environment, such as through the use of fuel breaks (Moriarty et al. 2016). By altering vegetation to
disrupt fuel continuity, fuel breaks reduce flame lengths, slow the spread of fast moving wildfire, and
reduce spotting potential, providing more opportunities for firefighters to gain control of, or contain, a fire
(Syphard et al. 2011a; Moriarty et al. 2016).
Research and decades of fire suppression experience indicate that reducing or removing fuel loading and
disrupting fuel continuity alters fire behavior (Monsen and Memmott 1999; Moriarty et al. 2016; Syphard
et al. 2011a; Andrews 2014). Firefighters successfully used fuel breaks to help control several wildfires in
recent years in Idaho and Nevada, such as the Southsim fire in 2011, Cox’s Well and MM86 fires in 2012,
and Centennial, Oil Well, and Snowstorm fires in 2017. See Appendix A for details.
The critical priority established for federal agencies engaged in fire suppression is the protection of human
life, while the protection of community infrastructure, property, and natural and cultural resources are
secondary priorities (NIFC 2018b). During multiple outbreaks, wildfires outside of the wildland-urban
interface (WUI) cannot always receive sufficient suppression resources to extinguish the fire. An integrated
fuel break system would provide fire suppression resources with reliable, pre-existing fire breaks without
the need to create or augment fuel breaks during suppression (Moriarty et al. 2016). The result would be
improved firefighting efficiency and increased tactical options for suppression resources. By reducing the
time needed to construct fuel breaks and fire lines at the time of the fire, fuel breaks increase firefighting
efficiency, allowing suppression resources greater flexibility to respond to multiple priority fires based on
threats to life, property, and natural and cultural resources. Fuel breaks act as a force multiplier, allowing
fire resources to more safely and rapidly engage wildfires across a larger area (Moriarty et al. 2016).
The National Wildfire Coordination Group (NWCG) defines a fuel break as “a natural or manmade change
in fuel characteristics which affects fire behavior so that fires burning into them can be more readily
controlled” (NWCG 2015). For the purpose of this document, the primary components of an effective fuel
break (Figure 1-2) are:
1) A non-vegetated roadbed. In the event of an approaching wildfire, a vegetated roadbed

provides a fuel source that encourages fire spread across the roadway. A roadbed free of
vegetation provides a hard break in fuel continuity to serve as the backbone of fuel treatments.
3
An anchor point is an advantageous location, usually a barrier to fire spread, from which to start constructing a fireline.
An anchor point minimizes the chance of being flanked by the fire while the line is being constructed.

2) Fuel treatment zone. Vegetative fuels along both sides of the roadbed must be reduced or
modified in order to change the fire behavior as the fire burns into the fuel break. Reducing fuel
and fuel continuity reduces flame length, rate of spread, fireline intensity, and spotting distance
of an encroaching fire. This reduced fire behavior creates a safer working environment that
allows firefighters to be more effective.
Figure 1-2. A fuel break.
Wildland fuels that occur naturally across the landscape as well as fuels that have been manipulated (e.g.,
by mowing brush) have been grouped into standard sets of fuel types. These fuel types are used as inputs to
predictive models to help predict flame length, rate of spread, and fire line intensity and are the industry
standard for wildland fire (Scott and Burgan 2005). The fuels that the BLM would target in the fuel
treatment zone are best represented by grass-shrub (GS2) and tall grass (GR4) fuel types, where the
primary carriers of fire are grasses and shrubs. In these fuels, a fire can spread quickly with flame lengths
that exceed eight feet, limiting suppression resources to indirect attack methods. Desired fuel conditions
within the fuel treatment zone are best represented by sparse grass (GR1) and low shrub (SH1) fuel types,
where the primary carriers of fire are sparse grasses or shrub litter. A fire spreads more slowly through
desired fuel types with flame lengths under five feet. Within the fuel break, this altered fire behavior would
provide suppression resources with reliable anchor points.
The graphs below compare fire behavior in existing fuel types to fire behavior in desired fuel types after a
fuels treatment using the Rothermel surface fire spread model in the Behave Plus program (Andrews 2014).
The paired graphs show significantly reduced flame lengths and rates of spread in desired sparse grass
(GR1) and low shrub (SH1) fuel types compared to current grass-shrub (GS2) and tall grass (GR4) fuel
types. Appendix B provides a detailed analysis of fire behavior expected under existing conditions and fire
behavior expected with implementation of the Proposed Action using predictive models.

Figure 1-3: Comparison of flame length and rate of spread 4
between existing fuel beds and desired (fuel treatment zone) fuel beds. The yellow and green lines indicate fire behavior of
fuel types targeted for treatment. The red and fuchsia lines indicate fire behavior of treated fuels. The y-axis demonstrates
flame length in the left graph and rate of spread in the right graph. The x-axis for both graphs shows midflame wind speed.
The Fuels Characteristic Classification System (FCCS), another Rothermel based fire model, utilizing fuel
bed manipulation also produces similar results of dramatic changes in fire behavior. Reducing the average
flame length below eight feet allows firefighters to change tactics from indirect to direct attack and
effectively reduce the size of the fire. Appendix B describes these models in greater detail and includes
charts, tables, and photographs illustrating these concepts.
1.3 Conformance with Applicable Land Use Plans and Other Related
Documents
The construction and maintenance of fuel breaks and mineral material sites is consistent with the relevant
land use plans, applicable BLM policy, and management objectives found under Appendix C.
1.4 Scoping and Development of Issues

In the spring of 2016, a subcommittee formed from the Boise District and Southeast Oregon Resource
Advisory Councils (RACs) held a series of meetings regarding the BLM’s proposal to surface issues and
inform development of action alternatives. The BLM published a Notice of Intent in the Federal Register
and posted a scoping package on the BLM’s NEPA register (ePlanning) on December 8, 2016. The scoping
package provided a general description of the Proposed Action, design criteria, and map showing the
project area’s outline. Public scoping meetings were held on January 3, 2017 in Boise, Idaho, on January 4,
2017 in Murphy, Idaho, and on January 24, 2017 in Jordan Valley, Oregon.
The BLM received comment letters from 6 individuals and 16 organizations during public scoping. The
BLM reviewed the letters and identified all substantive comments. Substantive comments included those
that challenged the accuracy of the information present in the scoping package; challenged the methods that
would be implemented as part of the Proposed Action or alternatives; presented new information
considered relevant to the NEPA analysis; or suggested reasonable alternatives (including mitigation)
beyond those that were presented in the scoping package. The BLM used substantive comments and RAC
subcommittee input, as well as internal scoping, to identify issues and develop alternatives found in this
Draft Environmental Impact Statement (DEIS). Issues identified during scoping that were considered but
4
Rate of spread is expressed in chains per hour (ch/hr). One chain per hour is equivalent to 66 feet per hour or .02 feet per
second.

not analyzed in detail are discussed in Appendix D. Based on internal and public scoping and RAC
subcommittee input, the following issues are addressed in this DEIS:
Resource Issue
• How do fuel breaks modify fire behavior and fire size under typical and extreme fire weather
Fire and Fuels conditions?
Management • What are the costs and benefits (i.e., suppression and post-fire rehabilitation cost savings) of
fuel break implementation and maintenance?
• What are the impacts to fragile/erodible soils from establishing fuel breaks (i.e., disking,
mowing, seeding, herbicide, targeted grazing, prescribed fire, and clearing selected roads of
Soils vegetation) and mineral material sites?
• How would establishment and maintenance of fuel breaks and mineral material sites affect
biological soil crusts?
• How would special status plants be impacted by the use of prostrate kochia, a non-native
Special species, in seeded fuel breaks?
Status/Sensitive
plants • What are the impacts to special status plants from the other treatment methods (e.g., mowing,
seeding native species, targeted grazing, and herbicide application)?
• What is the potential for introduction and/or spread of invasive and noxious plants from fuel
Invasive and noxious break establishment and maintenance ((i.e., disking, mowing, seeding, herbicide, targeted
plants grazing, prescribed fire, and clearing selected roads of vegetation) and mineral material sites?
What are the impacts?
• What are the impacts to vegetation communities from fuel break development (i.e., by
removing or manipulating vegetation in fuel breaks, including roads)?
o How would targeted grazing impact perennial and other vegetation?
General vegetation
• What are the impacts to vegetation communities from mineral material sites?
• How would potential use of the fuel break by wildlife and livestock (e.g., browsing, grazing
not associated with a targeted grazing treatment) impact perennial herbaceous vegetation?
• How would equipment use, herbicide application, and disturbance during project
implementation affect wildlife?
Wildlife • How would implementation of fuel breaks affect habitats of greater sage-grouse and other
sagebrush obligate wildlife species (e.g., habitat modification, loss, or fragmentation)?
• How would the development and operations of mineral material sites affect wildlife?
• What is the potential for fuel break implementation and maintenance and mineral material site
development to adversely impact the characteristics of known cultural resource sites that
make them eligible, or potentially eligible, for listing on the National Register of Historic
Places?
o What are the impacts from fuel break implementation to historic roads and trails
Cultural resources that are potentially eligible for listing on the National Register of Historic Places?
• What are the potential impacts to unknown cultural sites, including buried sites, from fuel
break implementation and maintenance and mineral material site development?
• How would fuel break implementation and maintenance and mineral material site
development affect Tribal practices, traditional use areas, and sites of cultural significance?
• What is the potential for implementation and maintenance of fuel breaks to adversely impact
known scientifically significant paleontological sites?
Paleontological • What are the potential impacts to unknown scientifically significant paleontological sites
resources (e.g., buried sites, etc.) from fuel break implementation and maintenance?
• What is the potential for the development and operations of mineral material sites to
adversely impact known and unknown scientifically significant paleontological localities?
• How would implementing and maintaining fuel breaks and mineral material sites affect
Wilderness Study
Wilderness Study Areas (size, naturalness, outstanding opportunities for solitude and
Areas
recreation)?

Resource Issue
Lands with • How would implementing and maintaining fuel breaks and mineral material sites impact
Wilderness lands with wilderness characteristics (size, naturalness, outstanding opportunities for solitude
Characteristics or primitive and unconfined recreation)?
Visual Resource • How would implementing and maintaining fuel breaks and mineral material sites affect visual
Management resources within the project area?
2.0 Description of the Alternatives

The following section describes the No Action Alternative (i.e., no fuel breaks), Proposed Action
(Maximum Fire Suppression Emphasis), and two alternatives to the Proposed Action (Social/Cultural
Emphasis and Wildlife Habitat Emphasis, respectively). Several alternatives for fuel break development
were considered but not analyzed in detail; for a summary of these alternatives and the reasoning behind
their exclusion from further analysis, see Appendix E.
2.1 Features Common to All Action Alternatives

The three action alternatives would be implemented with the same specifications: maximum width of the
fuel treatment zone, treatment methods, implementation period, monitoring, and maintenance. The BLM
would only implement fuel breaks on BLM-administered lands and state-managed lands where authorized,
so acres and road miles of fuel breaks proposed in each action alternative include only those lands. 5 No fuel
breaks would be constructed in Wilderness, Areas of Critical Environmental Concern (ACECs), or
Research Natural Areas (RNAs). Although no fuel breaks would be constructed in Wilderness, fuel breaks
may be established adjacent to Wilderness along the opposite side of Wilderness boundary roads (on the
non-Wilderness side of the roadway). Fuel breaks may be established on both sides of boundary roads of
Wilderness Study Areas (WSAs) and lands with wilderness characteristics. 6 No fuel breaks would be
established on any interior route (i.e., a primitive route or way) within a WSA or wilderness inventory unit
possessing wilderness characteristics.
All fuel breaks would be implemented on existing roads that include interstates, state highways, county
roads, BLM-administered roads, and primitive roads. The roads in each fuel break network under
consideration vary in width from 10 to 30 feet. The fuel treatment zone would extend up to, but no farther
than, 200 feet from both sides of these roadways (see Appendix F). However, environmental constraints
such as adjacent vegetation, terrain, soil type, and/or resource concerns would dictate fuel treatment zone
width (≤200 feet) and/or treatment type in a given area. Where necessary to create a hard break in fuel
continuity, BLM would remove vegetation in the roadbed in addition to treating roadside fuel treatment
zones.
Project implementation would occur as expeditiously as possible; depending on funding availability,

implementation would likely occur over 10 to 15 years. All fuel break methods would be implemented
under the constraints of design features outlined in Appendix G. The BLM would maintain fuel breaks
using the same methods and design features proposed for initial construction, and maintenance would occur
over the life of the project (i.e., implementation over a period of up to 15 years with maintenance of fuel
breaks in perpetuity). Monitoring for treatment implementation, effectiveness, and proper maintenance is
5
The fuel break networks shown in Appendix Q include some private roads that would not be treated. The networks
presented reflect how firefighters would move across the network.
6
In Oregon, fuel breaks in lands with wilderness characteristics would be implemented with design features (Appendix G)
to meet requirements of an in-force settlement agreement between BLM and Oregon Natural Desert Association (ONDA).
These design features would not be applied in lands with wilderness characteristics in Idaho. See section 3.9 for details.

described in Appendix H. Maintenance schedules would vary on a site to site basis based on the treatment
objectives described in Appendix H.
Road Maintenance
Road maintenance in the project area would continue to occur separately from the Tri-state Fuel Breaks
Project. Such maintenance could include grading, road resurfacing and culvert replacement on roads within
and outside the fuel break network. Because roads may be maintained to the full extent consistent with and
under the authority of current approved road maintenance prescriptions and travel management decisions,
road maintenance is not analyzed in this DEIS. In Oregon, maintenance of BLM roads within the project
area is addressed in the Vale District Road Maintenance Environmental Analysis Record (USDI BLM
1975) and Decision Record signed March 14, 1975. In Idaho, maintenance of BLM roads within the project
area is addressed in the Boise District Road Maintenance EA (USDI BLM 1994) and Decision Record
signed February 14, 1994. None of the actions proposed in this DEIS would result in road maintenance
actions or levels beyond those previously analyzed in these documents (USDI BLM 1975; USDI BLM
1994). The effects of ongoing and future road maintenance under these plans are addressed in Chapter 3 in
the cumulative effects analysis for those resources impacted by road maintenance and proposed fuel breaks.
The BLM would construct and maintain roadside fuel breaks along both maintained and unmaintained
roads. Where road maintenance has not occurred (i.e., primitive roads) or is not taking place regularly
within the fuel break network, vegetative overgrowth may be present in the roadbed. To create a hard break
in fuel continuity, the BLM may remove this vegetation by blading or hand cutting. This action would be
limited to vegetation removal to ensure fuel breaks are effective.
In the Oregon portion of the project area, some of the roads within the fuel break network have not received
proper approved maintenance (i.e., gravel application) in several years as a result of their distance from
mineral sources, hindering the reliable use of these roads by fire suppression resources. Therefore, in order
to more rapidly and effectively protect the sagebrush steppe and associated values from wildfires, BLM
Vale District proposes development of four mineral material sites (rock pits) with accompanying water
wells within the project area for aggregate production. By making approved road maintenance more
logistically and economically feasible, these developments would contribute to the safety and dependability
of suppression routes in the Oregon portion of the fuel break network.
The development of four new rock pits would occur in sites identified for mineral material extraction (Map
4, Appendix Q) consistent with the Southeastern Oregon RMP (USDI BLM 2002), as amended. All sites
would be accessible from existing roads. The proposed surface disturbance for each rock pit would be
confined to a designated boundary up to 20 acres in size. Within the 20-acre perimeter of each site, a quarry
pit would be created by first clearing an area of vegetation, excavating the overburden and topsoil, and
stockpiling this material on site for use in reclamation and revegetation. BLM Vale District would initiate a
blasting and rock crushing campaign at each site upon project authorization and every five to ten years
thereafter based on the need for material. Blasting would be supervised by a licensed blasting professional
and occur over a period of a couple of days. An air-track drill rig would be used to construct 50-100 holes
to depths of 20 to 40 feet, which would be subsequently loaded with blasting agent. The blasting agent
would consist of ammonium nitrate and fuel oil. Subsequent to blasting, rock would be produced of a size
fraction amenable to loading operations (typically 15-18 inches in diameter). The fragmented rock would
be pushed by a bulldozer into a pile and then loaded into a portable crushing unit to reduce the rock
material to a size required for road surfacing. Crushing would occur over a period of a couple of months
during normal working hours on weekdays. During rock crushing, water from onsite wells would be used
for dust abatement. Processed material would be stockpiled on site until needed for road maintenance

purposes. A berm would be constructed on the edge of the rock pit to prevent vehicles and foot traffic from
falling in the pit.
The life of each site and intermittent operations would depend upon the amount of rock available for use
within each footprint, and would likely extend 20 to 30 years. Interim reclamation would occur after each
blasting and rock crushing campaign to stabilize the soil and control for invasive plants, after which the site
may remain dormant for five to ten years until additional aggregate is needed. Upon final pit exhaustion,
reclamation would consist of burial of all remaining over-sized material, re-contouring the pit walls to
minimize erosion, ripping and scarifying the pit floors, spreading the stockpiled topsoil over the pit area,
and seeding the area with a BLM Vale District approved seed mixture appropriate to site conditions.
A water supply well would be drilled at each site for use in rock crushing operations and dust abatement.
The well would be drilled utilizing a rotary drill and would be dug to a depth of approximately 700
feet. Approximately two smaller diameter test wells would be drilled to determine the best location of the
well. Testing locations would be based on a hydrologic analysis of the area. The wells would consist of a
twelve inch diameter well-head and a twelve inch diameter vertical steel pipe that would rise above ground
no more than three feet. The well would produce approximately two acre feet of water per year for use in
the process of crushing the rock. Pumps would be submersed within the well head, powered by a generator,
and a holding tank on an elevated stand would also be on site during an active rock crushing session. The
well would be secured with a locking cap that makes it inaccessible when not utilized by BLM during rock
crushing operations.
The newly developed mineral material sites would not be designated as BLM community
pits, because their use would be restricted to periodic agency use only. All seasonal restrictions, best
management practices, and design features for protection of resource values would be applied during
implementation and operation of the Oregon mineral material site developments (see All Treatments and
Mineral Material Sites in Appendix G).
2.1.1 Fuel Break Treatments
2.1.1.1 Modeling Existing Vegetation In Proposed Fuel Breaks

The BLM modeled susceptibility to invasive annual grasses across the fuel break network to inform the
recommended treatments for project implementation and maintenance (Appendix I). Vegetation
communities were grouped (generalized to 1 acre) into categories ranging from a low to high threat of
conversion to invasive annual grass. Areas modeled with higher cover of annual than perennial vegetation
were then recommended for stabilizing (i.e., seeding) treatments to promote resistance to invasive plants,
while areas with higher cover of perennial than annual vegetation were recommended for mowing only.
The outcome of the model indicated areas where mowing only, mowing with follow-up seeding (native and
non-native), and seeding only (native and non-native) were recommended (Appendix I). Areas of no
treatment were also recommended. Acres in the “no treatment” category mainly include riparian areas,
wetlands and water, and areas already meeting criteria for an effective fuel treatment zone. In other words,
these are areas that would either not be treated in order to follow resource guidelines or best management
practices, or would not be treated by any method because shrub cover is low and herbaceous perennial
plants are dominant (i.e., meeting fuel break criteria).
Acres of recommended treatments are provided in tables under each action alternative. Appendix I provides
the treatment matrix and a more thorough discussion of the process for deriving recommended treatments.

Resilience and Resistance
Resilience is a plant community’s ability to regain its functional processes and components following a
disturbance, and resistance is the capacity of a plant community to retain functional processes and
components despite ongoing disturbance (Chambers et al. 2014). The ability of plant communities to be
resilient to disturbance and resistant to annual grass invasion increases with moisture, productivity, and
elevation (Chambers et al. 2014; Miller et al. 2014). Conversely, plant communities in lower elevation
areas with lower annual precipitation tend to be less resilient to disturbance and less resistant to invasive
annual plants; these areas commonly include cheatgrass or other invasive annual plants in the plant
community (Chambers et al. 2014).
Resilience and resistance (R&R) data was used to select appropriate cultivars (i.e., native vs. non-native)
for treatment areas in transition between perennial- and annual-dominated states. In areas mapped as high
or moderate R&R, native seeding may be successful and is therefore recommended. In areas mapped as
low R&R, non-native seeding is recommended to promote effective establishment of seeded species.
The proposed fuel breaks for each alternative have been classified into High, Moderate, or Low resilience
and resistance (R&R) categories (Table 2-1 and Map 5, Appendix Q).
Table 2-1. Resilience and resistance (R&R) acres for fuel breaks.
Alternative R&R category Fuel break acres Proportion of treatment area*
High 17,443 24%

2 – Maximum Fire Moderate 13,225 18%
Suppression Emphasis
Low 42,990 58%
Untreated Wetland/Riparian† 198 <1%
High 12,423 24%
3 – Socio/Cultural Moderate 8,999 18%
Emphasis
Low 29,541 58%
High 8,562 20%
4 – Wildlife Habitat Moderate 5,557 13%
Emphasis
Low 29,524 67%
*Percentages were rounded to the nearest percent.
†
These areas are not assigned a resistance/resilience value; however, riparian areas and wetlands tend to be resilient
(recover quickly) due to moisture availability. Unmapped acres are included here and range from 3 to 5 acres.
2.1.2 Methods
The methods for fuel break creation and maintenance analyzed in this DEIS include mowing, seeding,
roadbed vegetation removal, seedbed preparation techniques, chemical treatment (i.e., herbicide), hand
cutting, prescribed fire (e.g., pile burning), and targeted grazing. Refer to Appendix B for a description of
pre- and post-treatment fire behavior.
2.1.2.1 Primary Methods

Primary methods to achieve and maintain desired fuel characteristics include roadbed vegetation removal,
mowing, and seeding. The primary vegetation treatments, mowing and seeding, are recommended across
the fuel treatment zone based on the existing vegetation’s resistance to invasive annual grasses (Appendix

I). In areas recommended for seeding, site characteristics would determine seedbed preparation techniques
(e.g., disking, prescribed fire).
Roadbed Vegetation Removal

Some sections of the fuel break network would require removal of vegetation within the roadbed to create
the hard break in fuel continuity necessary for an effective fuel break. These sections are generally dirt
roads with vegetation along the centerline. This roadbed vegetation typically consists of early seral species
and invasive annual grasses, but can include brush on less trafficked routes. To remove vegetation in these
areas, the BLM would blade the roadbed, or where terrain or resource concerns limit the use of heavy
equipment, use less-impacting manual methods (e.g., hand cutting or herbicide). These activities would
serve the limited purpose of removing roadbed fuels to support effective fuel breaks. Table 2-8 presents the
roads BLM has identified that may contain vegetation in the roadbed; these BLM and State roads may be
infrequently maintained or unmaintained. Roadbed vegetation removal may occur periodically throughout
the useful life of the fuel break network under each action alternative.
In most areas identified, the BLM would use heavy equipment to blade the road surface as necessary to
remove fuels within the roadbed. Blading would occur only within the footprint of existing roads and
would remove the top layer of soil across the roadbed as minimally necessary to displace vegetation.
Bladed soil and vegetation would be deposited along the side of the road. The BLM would manually
remove vegetation (i.e., using hand tools) in areas where the use of heavy equipment is infeasible,
restricted, or has the potential to widen the existing road. Cut vegetation would be deposited along the side
of the road. Cleared roadbeds would require periodic retreatment using the original treatment method (i.e.,
blading or manual vegetation removal) and/or herbicide to maintain a roadbed free of vegetation (see Table
2-2 below). The BLM anticipates that re-blading or follow-up manual vegetation removal would occur
every five to seven years, while herbicide treatments would occur annually where needed.
Mowing
Shrubs taller than 12 inches with >1% cover 7 (i.e., includes a range of areas with widely scattered shrubs to
dense shrub cover) within the treatment zone would be mowed to a height of 6 to 10 inches. Shrubs mowed
to this height would resemble the desired sparse grass (GR1) fuel model (Appendix B). Operators would
use a deck mower (or any mechanical equipment designed to mow brush) attached to a rubber-tired tractor
where road conditions, terrain, and vegetation allow. Mowing would occur during cooler seasons (outside
of sage-grouse nesting period) when fire risk is low and would follow seasonal design features (Appendix
G). Retreatment to maintain fuel breaks would occur every three to seven years, depending on vegetation
regrowth rates, to preserve effectiveness.
Seeding
Based on site conditions (Appendix I), fuel breaks may be seeded with native, non-native, or a mixture of
native and non-native species to promote plant composition that meets fuel break objectives, including
competition against annual invasive species. The most desirable characteristics for creating effective fuel
breaks include plants that are adapted or adaptable to the site, are competitive with annual grasses and
forbs, are easy to establish, are low statured with an open canopy, are resilient and able to regrow/resprout
after disturbance, reduce fuel accumulation and volatility, and retain moisture and remain green through the
fire season (St. John and Ogle 2009).
7
Based on cover class bins from the Homer et al. 2012 model.

Seed adapted to the region would be used to best promote establishment success and long-term durability
(Appendix J). Establishment of fuel break-specific vegetation may require reduction or elimination of
existing vegetation to decrease competition (i.e., seedbed preparation).
Seeded Fuel Break Seeding Techniques

Drill or broadcast seeding during the fall, winter, or spring (depending on the species) would be used to
establish a fuel break consisting of desirable perennial vegetation.
Drill seeding using rangeland drills or no-till drills may be employed to seed proposed grasses after
seedbed preparation (e.g., herbicide, disking). The rangeland drill was developed to seed rough rangeland
sites. The rangeland drill is typically used in open, relatively flat topography that is fairly absent of larger
rocks (8-10" or more in diameter). This method works well in most soil types within the project area and is
the primary seeding method that would be used. Minimum-till or no-till drills may be utilized where less
rocky conditions allow, or where resource constraints require their use. The advantage to using the no-till
drill is less soil disturbance; however, no-till drills may not be readily available and are most effective in
non-rocky soils. The drill seeding method has the greatest probability of seeding success among various
seeding tools and methods.
Broadcast seeding would be used for prostrate kochia seeding and where the terrain is not conducive for
drill seeding. Broadcast seeding would be followed with a cover treatment using a harrow, culti-packer or
roller packer implement wherever possible to improve seed contact with mineral soil. Broadcast seeding
may be aerial or ground-based using mechanized means (e.g., UTV, ATV, or tractor) and/or hand
spreaders.
Newly seeded fuel breaks may require protection from livestock grazing adjacent to the fuel break to
promote establishment of seeded species to meet fuel break objectives. Primary methods for protection of
seeded fuel breaks would involve herding, avoidance during trailing, shutting off water sources, and
removal of salt or mineral sources. Temporary protective fencing may be used to protect newly seeded fuel
breaks from livestock grazing when primary protection methods (active herding, etc.) are not feasible. The
BLM would work with affected permittees to minimize impacts to permittees. Temporary/short-term
protective fencing would remain in place until seeded species are adequately established to tolerate grazing
(i.e., two growing seasons or seeding objectives in Appendix H are met).
2.1.2.2 Supplemental Methods

The BLM has identified methods supplemental to the primary treatments to enhance the effectiveness of
the fuel break system. The BLM would use supplemental methods 1) to prepare seedbed, 2) to provide
treatment alternatives (e.g., hand cutting) to accommodate site conditions and design features, and 3) on a
site-specific basis when determined appropriate by an authorized officer. These methods would be
implemented in combination with primary treatments as necessary to create the fuel break system, but
could be implemented as standalone treatments to maintain fuel breaks.
Chemical Treatment
Herbicides would be used primarily in the fuel treatment zone for seedbed preparation and maintenance to
control invasive plants. Herbicides could also be used to reduce invasive annual grasses and other weeds in
stands of perennial grass to give desirable species a competitive advantage, and/or to return interspaces in
perennial grasses to a more naturally bare state. This would have the effect of maintaining fuel breaks by
reducing the amount of fuel available. Lastly, herbicides would be used for control of noxious weeds and
invasive plants at mineral material sites.

Herbicide would be applied by truck, tractor, or utility terrain vehicle/all-terrain vehicle (UTV/ATV)
mounted with a sprayer, and/or by aerial application methods. Spot treatments may be completed using a
backpack sprayer. Herbicide may be applied before or after other treatments (e.g., mowing or seeding)
depending on the target species and type of herbicide. Chemical application to establish or maintain fuel
breaks may also require re-vegetation to prevent the loss of soil.
For the control and treatment of target species, this DEIS tiers to the Records of Decision for the Vegetation
Treatments Using Herbicides on BLM Lands in the 17 Western States Programmatic Environmental Impact
Statement (2007 PEIS) (USDI BLM 2007a); the Final Programmatic Environmental Impact Statement for
Vegetation Treatments Using Aminopyralid, Fluroxypyr, and Rimsulfuron on BLM Lands in 17 Western
States (2016 PEIS) (USDI BLM 2016a); the Vegetation Treatments Using Herbicides on BLM Lands in
Oregon Final Environmental Impact Statement (Oregon EIS) (USDI BLM 2010a); decision records for the
Boise District’s Noxious Weed and Invasive Plant Management Environmental Assessment (USDI BLM
2018a); and the Vale District’s Integrated Invasive Plant Management Environmental Assessment (USDI
BLM 2016b). All herbicide treatment activities would follow the applicable standard operating procedures
(SOPs) (Appendix K) and Conservation Measures identified in these documents, as well as all herbicide
label specifications.
The herbicides proposed for seedbed preparation, maintenance, roadbed vegetation removal, and noxious
weed control are presented in Table 2-2 (see Table J-2 in Appendix J for a list of the primary noxious
weeds and invasive annual grasses). Herbicides designed for uptake through root systems would be applied
to the soil to reduce competition from other plants, prevent germination, and remove mature plants. Contact
(foliar) herbicides applied to live plant tissue would be used to control established plants and reduce
competition. For more detail, see Appendix K.
Table 2-2. Herbicides proposed for use.

Herbicide Recommended Use
2,4-D Seedbed preparation; noxious weed treatment; roadbed vegetation removal
Aminopyralid Seedbed preparation; noxious weed treatment; roadbed vegetation removal
Chlorsulfuron Noxious weed treatment; roadbed vegetation removal
Clopyralid Noxious weed treatment; roadbed vegetation removal
Dicamba Noxious weed treatment; roadbed vegetation removal
Fluroxypr Seedbed preparation; roadbed vegetation removal
Glyphosate Seedbed preparation; noxious weed treatment; roadbed vegetation removal
Imazapic Seedbed preparation; noxious weed treatment; roadbed vegetation removal
Metsulfuron methyl Noxious weed treatment; roadbed vegetation removal
Picloram Noxious weed treatment; roadbed vegetation removal
Rimsulfuron Seedbed preparation; roadbed vegetation removal
Triclopyr Noxious weed treatment; roadbed vegetation removal
Seedbed Preparation
Seedbed preparation, such as disking, herbicide application, prescribed burning, and targeted grazing,
reduces competition prior to planting desirable species and facilitates germination success. Where
necessary, multiple seedbed preparation treatments may be used.

Disking would be done using a bulldozer or rubber tired tractor for pulling disks to remove vegetation and
expose bare mineral soil. Disking would be followed by seed application (and possibly herbicide treatment,
then seeding). Seedbed preparation may occur over multiple seasons to ensure proper site conditions. These
bare areas of soil would also serve as temporary fuel breaks in their un-vegetated state.
Herbicides such as imazapic, or other approved and applicable herbicides, may be used for seedbed
preparation to control invasive plants and noxious weeds to remove or reduce competition and promote
germination and establishment of seeded species. Herbicides may also be applied following a seeding to
promote establishment of seeded species, and periodically thereafter as warranted for maintenance
purposes. For more information on how herbicides would be used, see the description of herbicide use
above.
Prescribed fire may be used for seedbed preparation in areas dominated by annual grasses and forbs to
remove dense mats of accumulated dry biomass, especially associated with medusahead, and to maximize
subsequent herbicide exposure to soil or foliar contact. For more information on how prescribed fire would
be used, see the description of prescribed fire below.
Targeted grazing could be used as a tool in areas dominated by annual grass to reduce litter accumulation
prior to broadcast herbicide applications to allow herbicide to be taken up into the soil as opposed to being
intercepted by cheatgrass litter. For more information on how targeted grazing would be used, see the
description of targeted grazing below.
Hand Cutting
Rugged and/or steep terrain or resource concerns may restrict the use of mechanized equipment such as a
tractor with a mower, so that hand cutting of shrubs within the fuel break is preferable. Shrubs taller than
12 inches with ≥ 1% cover would be cut by hand to a height of 6 to 10 inches. Shrubs cut to this height
would resemble the desired GR1 fuel model (Appendix B). Shrubs would be cut with chainsaws or loppers.
Shrub material would be scattered on the ground or piled and burned where large amounts of residual
debris remain (see prescribed burning below), or removed by hauling away or chipping to reduce ground
fuels.
Prescribed Fire
Prescribed fire may be required to prepare a seedbed in areas dominated by annual grasses to remove dense
mats of accumulated biomass, especially associated with medusahead, to maximize herbicide exposure to
soil or foliar contact. Without the use of prescribed fire to remove the thatch of invasive grasses, herbicide
treatments would not sufficiently reach the soil surface and would not be effective.
In addition, prescribed fire within the fuel treatment zone may be necessary occasionally to burn debris
from hand piles or to remove accumulations of weeds/brush along fence lines, draws or ditches. These
weed/fuel concentrations would be burned to maintain the effectiveness of fuel breaks. Pile burning and
burning of fuel accumulations along fence lines, draws or ditches would be accomplished with the use of
handheld drip torches or a vehicle-mounted terra torch.
Burning would take place from the late fall through early spring when conditions allow only the targeted
concentration of treated fuels to be burned and not the surrounding live vegetation. Environmental
conditions that prevent the spread of fire outside of treated fuels include snow covered or frozen ground,
recent measurable rainfall, or substantial green-up of grasses with minimal fine dead fuels (grasses)
present.

Site-specific prescribed burn plans would be developed to describe parameters and address safety and
smoke management. Burning prescriptions would strategically reduce undesirable effects on vegetation or
soils (e.g., minimize mortality of desirable perennial plant species including sagebrush and reduce risk of
annual grass invasion). All prescribed burning would be coordinated with state and local air quality
agencies to ensure that local air quality is not significantly impacted by BLM activities. Appendix L
addresses the rationale for the use of prescribed fire in sage-grouse habitat in conformance with the
Southeastern Oregon RMP as amended by the 2015 and 2019 Oregon Greater Sage-Grouse Approved
Resource Management Plan Amendments and with the Bruneau MFP and Owyhee RMP as amended by the
2015 Idaho & Southwestern Montana Greater Sage-Grouse Approved Resource Management Plan
Amendment and the 2019 Idaho Greater Sage-Grouse Approved Resource Management Plan Amendment.
Targeted Grazing
Targeted grazing is the purposeful application of a specific species of livestock at a determined season,
duration, and intensity to accomplish defined vegetation or landscape objectives (ASI 2006). All proposed
treatment acres could be treated via targeted grazing where site conditions warrant treatment to maintain
fuel breaks. Targeted grazing may be used to treat annual grasses of any height or perennial grasses
exceeding 24 inches in height.
In selected locations, targeted grazing would use cattle at a high intensity over a short duration to remove
fine fuels, and to achieve the desired fire behavior characteristic of the sparse grass (GR1) fuel model
described in Appendix B. Herding would be non-motorized and water haul sites and supplements would be
placed adjacent to roads within the fuel break and moved regularly. Cattle would be contained within the
treatment footprint through control measures such as temporary fencing or active herding. Operators must
provide site-specific control measures in an implementation plan to be approved or modified by an
authorized officer (Appendix G). Treatments may occur throughout the year in a manner to ensure
objectives (identified below) are achieved by June 30.
Targeted grazing in areas dominated by annual and/or non-native perennial grass would result in an average
residual height (or “stubble height”) of two inches or less (≤2 inches) to significantly reduce fuel continuity
in dense, fine, flashy fuels. In areas dominated by native perennial grass, targeted grazing would be
implemented only where grass heights are on average twenty-four inches or greater (≥24 inches), resulting
in an average stubble height of 6-12 inches. A 6-12-inch perennial grass stubble height would maintain fuel
break effectiveness due to the bare interspaces and reduced fuel continuity in these communities (i.e.,
patchy, discontinuous fuels).
2.2 Alternative 1 – No Action Alternative

A fuel break network would not be created. Fuels adjacent to roadways would not be treated to reduce fuel
accumulations and disrupt fuel continuity in order to modify fire behavior, increase firefighter safety and
efficiency, and protect sagebrush-steppe ecosystems. Fire suppression personnel would utilize existing
paved and other improved BLM and county roads and natural topographic features to hold and control
wildfire. The BLM would not develop the proposed mineral material sites or water wells in Oregon. Roads
in the Tri-state area could be maintained to the full extent consistent with and under the authority of the
appropriate approved road maintenance prescriptions and travel management decisions.
2.3 Alternative 2 – Maximum Fire Suppression Emphasis (Proposed Action)

The BLM Vale and Boise Districts propose establishing a strategic system of fuel breaks across 73,920
acres spanning state and district boundaries within an approximately 3.6-million-acre area. This system of
fuel breaks would connect to the existing fuel break network in the BLM Elko and Winnemucca Districts in

northern Nevada to enhance fire suppression capabilities across the Tri-state area. The roads depicted in
Map 6 (Appendix Q) were selected by BLM fire suppression experts because they are currently accessible
and/or strategically located to maximize availability of wildland fire engines and other suppression
equipment. The Proposed Action was developed to provide the greatest opportunity for firefighter safety
and firefighting efficiency in order to reduce the spread of wildfire across the sagebrush-steppe ecosystems
within the project area. This alternative contains the highest number and density of fuel breaks of all action
alternatives.
Under this alternative, the BLM would implement and maintain a 73,920-acre fuel break network along
approximately 1,539 miles of existing roads; 35,043 acres along 731 miles in Idaho, and 38,876 acres along
808 miles in Oregon. Roadbed vegetation removal, using either blading or manual methods, would occur
across up to 412 miles of roads in Idaho and up to 537 miles of roads in Oregon, for a total of up to 950
miles of roads cleared (Map 7, Appendix Q).
Table 2-3 presents the acres recommended under this alternative for each primary vegetation treatment
method (mowing only, mowing and seeding, seeding only, and no treatment) by state as well as combined
totals. 8
Table 2-3. Alternative 2 recommended primary vegetation treatments.

Recommended Treatment Method Idaho Acres Oregon Acres
Mowing Only 26,971 18,533
Total Mowing Only 45,504 acres (62%)
Mowing and Native Seeding 1,137 1,345
Total Mowing and Native Seeding 2,482 acres (3%)
Mowing and Non-Native Seeding 3,894 14,781
Total Mow and Non-Native Seeding 18,674 acres (25%)
Native Seeding only 6 2
Non-Native Seeding only 38 853
Total Seeding Only 899 acres (1%)
Total Treatments 32,046 35,513
Grand Total All Treatments 67,559 acres (91%)
No Treatment* 2,997 3,363
Total No Treatment 6,360 acres (9%)
GRAND TOTAL 73,920 acres
*Includes wetland/riparian areas, areas with <1% shrub cover with dominant perennial understory (i.e., meeting
fuel break criteria), and areas not mapped.
The seedbed preparation techniques (i.e., disking, herbicide, prescribed fire, targeted grazing) described in
section 2.1.2 Methods could occur across all 22,055 acres recommended for native or non-native seeding
to promote effective establishment. Herbicide could additionally be used anywhere within the treatment
footprint where necessary to control invasive and noxious weeds and maintain cleared roadbeds free of
vegetation. In addition to its use as a seedbed preparation technique, prescribed fire could be used
anywhere within the treatment footprint to burn debris from hand piles or to remove accumulations of
8
Due to mapping constraints, vegetation treatment acreages for all action alternatives include the roads within the fuel
break network and therefore reflect the maximum area in which project actions would occur. However, for the purpose of
modeling and analysis, they are used to guide and evaluate actions proposed in the fuel treatment zone.

weeds/brush along fence lines, draws or ditches. In addition to its use as a seedbed preparation technique,
targeted grazing could be used anywhere within the treatment footprint to treat annual grasses of any height
or perennial grasses exceeding 24 inches in height. Hand cutting could occur anywhere within the treatment
footprint to achieve desired fuel type characteristics where the terrain demands it or design features limit
the use of mechanized equipment (Appendix G).
2.4 Alternative 3 – Social/Cultural Emphasis

This alternative to the Proposed Action was developed to protect natural resources and socioeconomic
values from large wildfires while minimizing impacts to social and cultural resources. Alternative 3
incorporates criteria proposed by the RAC subcommittee (see section 1.4 Scoping and Development of
Issues), and emphasizes limiting impacts to cultural resources and special management areas (e.g.,
Wilderness Study Areas), as well as lands with wilderness characteristics. The BLM considered the
following factors to develop this alternative:
• Tribal concerns and areas of cultural significance.

• Known significant historic properties or high site probability based on predictive models.
• Whether roads are significant historic routes.
• Known significant paleontological resources.
• Whether a road would require significant road improvement or maintenance (i.e., the road is
reclaiming itself due to lack of use, or has significant vegetation growth down the centerline) to
become a viable fuel break easily accessible by fire suppression equipment.
• Whether the route repeatedly crosses private property or begins or ends on private property.
• Concern for increasing access to remote areas.
• Whether the route is a trail or road heading into a steep canyon.
• Impacts to lands with wilderness characteristics and Wilderness Study Areas (WSAs).
• Whether a road, due to an adjacent route’s elimination based on the above factors, is no longer
connected to the fuel break system (i.e., orphaned routes no longer part of a contiguous system of
fuel breaks).
As a result of the above considerations, the fuel break network under Alternative 3 would consist of 51,127
acres along 1,063 miles of existing roads; 24,264 acres along 505 miles in Idaho and 26,864 acres along
558 miles in Oregon (Map 8, Appendix Q and Table 2-3). Roadbed vegetation removal would occur across
up to 218 miles of roads in Idaho and up to 367 miles of roads in Oregon, for a total of up to 585 miles of
roads cleared (Map 9, Appendix Q).

Recommended Treatment Idaho Acres Oregon Acres
Mow Only 18,388 12,781
Total Mow Only 31,168 acres (61%)
Mow and Native Seeding 856 955
Total Mow and Native Seeding 1,811 acres (4%)
Mow and Non-Native Seeding 3,019 9,634
Total Seeding Only 239 acres (<1%)
Total All Treatments 22,291 23,581
GRAND TOTAL 51,127 acres
*Includes wetland/riparian areas, areas with <1% shrub cover with dominant perennial understory (i.e., meeting fuel break
criteria), and areas not mapped.
to promote effective establishment. The conditions for use of supplemental treatment methods across the
treatment footprint would be identical to those described for Alternative 2 in section 2.3 Alternative 2 –
Maximum Fire Suppression Emphasis (Proposed Action).
Under this alternative, fuel break placement would avoid WSAs except where necessary to maintain
adequate connectivity in the fuel break network. Fuel breaks within lands with wilderness characteristics
would also be minimized in this alternative.
2.5 Alternative 4 – Wildlife Habitat Emphasis

The emphasis of Alternative 4 is to provide protection to wildlife and its habitat while providing a network
of fuel breaks that meets the purpose and need. Alternative 4 also incorporates criteria proposed by the
RAC subcommittee (see section 1.4 Scoping and Development of Issues), and emphasizes avoidance of
important wildlife habitat. The BLM considered the following factors to develop this alternative:
• Avoid treatments within 2 miles (3.2 km) of occupied or pending sage-grouse leks (Connelly et al.
2000) to maintain nesting habitat, in accordance with RAC criteria.
• All high use roads (paved or graveled) were included regardless of proximity to leks due to the
existing disturbance already present on the landscape.
• Routes in areas with high sage-grouse breeding probability and high landscape resistance/resilience
(R&R) were minimized, because these areas provide quality habitat for sage-grouse and are more
likely to recover after fire in comparison with low R&R areas.
• Routes in areas with a high probability of flame lengths greater than 6 feet were given priority to be
considered for fuel break development, regardless of R&R.
• Routes in high R&R areas were compared by (a) the number of leks, (b) the size of leks, and (c)
priority habitats for sensitive species, including pygmy rabbit and dark kangaroo mouse. Routes
were minimized in these areas.

As a result of these considerations, the fuel break network under Alternative 4 would consist of 43,833
acres along 910 miles of existing roads: 21,652 acres along 460 miles in Oregon and 22,180 acres along
450 miles in Idaho (Map 10, Appendix Q and Table 2-4). Roadbed vegetation removal would occur across
up to 175 miles of roads in Idaho and up to 224 miles of roads in Oregon, for a total of up to 399 miles of
roads cleared (Map 11, Appendix Q).

Recommended Treatment Idaho Acres Oregon Acres
Mow Only 15,437 8,239
Total Mow Only 23,676 acres (54%)
Mow and Native Seeding 733 425
Total Mow and Native Seeding 1,157 acres (3%)
Mow and Non-Native Seeding 2,894 9,523
Total Seeding Only 794 acres (2%)
Total All Treatments 19,101 18,942
GRAND TOTAL 43,833 Acres
*Includes wetland/riparian areas, areas with <1% shrub cover with dominant perennial understory (i.e., meeting fuel break
to promote effective establishment. The conditions for use of supplemental treatment methods across the
treatment footprint would be identical to those described for Alternative 2 in section 2.3 Alternative 2 –
Maximum Fire Suppression Emphasis (Proposed Action).
2.6 Comparison of Action Alternatives

Table 2-6. Comparison of seedbed preparation treatments in action alternatives.
Alternative 2
Alternative 3 Alternative 4
Max Fire Suppression
Maximum Treatment Social/Cultural Emphasis Wildlife Habitat Emphasis
Emphasis
Footprint
Idaho Oregon Idaho Oregon Idaho Oregon
Acres Acres Acres Acres Acres Acres
Seedbed preparation
5,074 16,981 3,903 10,800 3,665 10,703
techniques*
GRAND TOTAL 22,055 14,703 14,368
*Disking, herbicide, prescribed fire, targeted grazing

Table 2-7. Comparison of primary treatments in action alternatives.
Alternative 2 Alternative 3 Alternative 4
Max Fire Suppression Social/Cultural Wildlife Habitat
Recommended Treatment Emphasis Emphasis Emphasis
Idaho Oregon Idaho Oregon Idaho Oregon
Acres Acres Acres Acres Acres Acres
Mow only ≥10% Shrub Cover 18,930 11,516 12,921 8,334 10,243 4,601
Mow only 1-10% Shrub Cover 8,042 7,017 5,467 4,447 5,194 3,638
Total Mow Only 26,971 18,533 18,388 12,781 15,437 8,239
Grand Total Mow Only 45,504 31,168 23,676
Mow ≥10% Shrub Cover and
742 533 540 403 461 119
Native Seeding
Mow 1-10% Shrub Cover and
395 812 316 552 272 306
Native Seeding
Total Mow and Native Seeding 1,137 1,345 856 955 733 425
Grand Total Mow and Native
2,482 1,811 1,157
Seeding
Mow ≥10% Shrub Cover and
1,626 6,309 1,188 4,182 1,038 3,296
Non-Native Seeding
Mow 1-10% Shrub Cover and
2,267 8,472 1,831 5,452 1,856 6,226
Non-Native Seeding
Total Mow and Non-Native
3,894 14,781 3,019 9,634 2,894 9,523
Seeding
Grand Total Mow and Non-
18,674 12,653 12,417
Native Seeding
Native Seeding only 6 2 5 2 5 0
Non-Native Seeding only 38 853 23 208 33 755
Total Seeding Only 44 855 28 211 38 755
Grand Total Seeding Only 899 239 794
Total Treatment 32,046 35,513 22,291 23,581 19,101 18,942
Grand Total Treatment* 67,559 45,872 38,044
No Treatment† 2,997 3,363 1,973 3,283 2,551 3,238
GRAND TOTAL 73,920 Acres 51,127 Acres 43,833 Acres
*Supplemental treatment methods would be used as necessary within acres recommended for treatment as described in
section 2.3 Alternative 2 – Maximum Fire Suppression Emphasis (Proposed Action).
†Includes wetland/riparian areas, areas with <1% shrub cover with dominant perennial understory (i.e., meeting fuel break
Table 2-8. Comparison of miles of roads proposed for vegetation removal in action alternatives.
Alternative Idaho (mi) Oregon (mi) Total (mi)
Alternative 2 412 537 950

3.0 Affected Environment and Environmental Consequences
This section provides an evaluation of the baseline condition of the environment (i.e., resources identified
during internal and external scoping as requiring analysis) potentially affected by implementation of the
alternatives. The evaluation is a description of the current condition (affected environment) of identified
resources and consequences or effects expected from implementing each alternative (environmental
consequences).
Direct and Indirect Effects

After reviewing the Proposed Action and alternatives relative to the project area, the Interdisciplinary Team
determined that several elements of the human environment and/or issues could potentially be affected or
required detailed discussion. These elements and issues and the expected direct and indirect impacts to the
environment are discussed in the environmental consequences sections that follow. The impact descriptors
most commonly used in analysis are defined in Table 3-1.
Table 3-1. Impact descriptors.

Descriptor Meaning
Short-term Changes to the environment during and following ground-disturbing activities that revert to pre-
disturbance conditions, or nearly so, immediately to within five years following the disturbance
are considered short-term.
Long-term Changes to the environment following ground-disturbing activities that are expected to be present
for five years or more are considered long-term.
Major Major effects have the potential to cause substantial change or stress to an environmental resource
or resource use. Effects generally would be long-term and/or extend over a wide area.
Moderate Moderate effects are apparent and/or would be detectable by casual observers, ranging from
insubstantial to substantial. Potential changes to or effects on the resource or resource use would
generally be localized and short-term.
Minor Minor effects could be slight but detectable and/or would result in small but measurable changes
to an environmental resource or resource use.
Negligible Negligible effects have the potential to cause an immeasurable and/or insignificant change or
stress to an environmental resource or use.
No Effect No effect means an action would produce no discernable effect.
Assumptions
Several assumptions were made during analysis to provide a standard basis for comparison between
alternatives. However, all treatments, including implementation and maintenance, are subject to federal
budgets. Assumptions include:
• All treatments would be fully implemented and maintained as proposed.

• Not all fuel break areas analyzed would require treatment. In some fuel treatment zone areas, no
modification of vegetation in the fuel treatment footprint would be necessary because fuel
characteristics already meet desired conditions (low sagebrush scabland, wet meadow, etc.).
• Seeding treatments would be successful, although some areas may require multiple seedings to
establish a successful treatment due to environmental variability.
• Implementation of fuel break segments would occur at an anticipated rate of approximately 2,000
acres or 41 miles per year, depending on funding availability.
• New seedings associated with fuel break establishment would be evaluated on a case by case basis
to determine if any rest from normally scheduled livestock grazing is required.

• For targeted grazing, control measures (e.g., active herding, temporary fencing) would successfully
keep livestock within the 200-foot-wide fuel treatment zone, so grazing impacts would be confined
to that area.
• For seeding, control measures (e.g., active herding, temporary fencing) would successfully keep
livestock from entering newly seeded fuel breaks.
• Unless otherwise noted, most direct and indirect effects of fuel breaks are anticipated in the fuel
break corridor (200-foot-wide fuel treatment zone on either side of 10- to 30-foot-wide existing
roads).
Cumulative Impacts
Cumulative effects describe impacts of the Proposed Action and alternatives when added with other past,
present, and reasonably foreseeable future actions (40 CFR 1508.7). For the purposes of the analysis in this
DEIS, the impacts of past activities within the proposed project area were considered to be reflected in
existing resource conditions (i.e., the affected environment). The impacts of any specific past action may be
difficult or impossible to individually quantify and disclose due to issues like inconsistent data collection
methodology in the past, data that have become lost or missing over time, and the lack of data in the case of
unplanned events such as wildfire. Therefore, this analysis does not attempt to quantify specific impacts for
each past activity within the proposed project area, but rather uses current and scientifically accurate data
available to identify the existing condition of each resource.
Present and reasonably foreseeable future actions within the cumulative impact analysis area (CIAA) are
addressed in the cumulative impacts analysis for each resource. In each cumulative impacts analysis, a
specialist 1) determines the geographic and temporal extent of analysis; 2) evaluates past, present, and
reasonably foreseeable actions and trends that are likely to affect the resource; 3) considers the baseline
conditions of the resource (affected environment) and the impacts anticipated; and 4) considers the
incremental contribution of each alternative’s impact to the overall regional and temporal pattern of
impacts to the resource.
In general, cumulative actions that are occurring in the vicinity and are likely to continue into the
foreseeable future include livestock grazing, road maintenance, vegetation treatments, fuels treatments, and
land and realty actions. Table N-1 in Appendix N provides an overview of these actions and descriptions of
their general location within, or in proximity to, the project area. Because cumulative actions impact
resources to different degrees and/or extents and vary dependent on the spatial and temporal scope of
analysis for a given resource, some cumulative actions in Table N-1 may not contribute to cumulative
impacts on a particular resource (i.e., these actions would not interact with the project’s impacts to produce
any effects beyond those of the individual actions when considered separately). Only those actions that may
have a potential cumulative effect on a resource are evaluated in the analysis for that resource.
3.1 Fire and Fuels Management

3.1.1 Affected Environment
The affected environment for wildfire management is the proposed project area. Sagebrush steppe fire
regimes within the project area historically burned less frequently and at low to mixed severity (Crawford
et al. 2004). Prior to European settlement, fire return intervals in the sagebrush steppe varied between 60-
100 years. Stand replacing wildfires produced homogenous landscapes of sagebrush, but vegetation
recovery was not yet under the threat of invasive annual conversion (Whisenant 1990). Due to the
introduction of non-native invasive species, alterations to the historic fire ecology of the area have resulted
in larger fires occurring at shorter return intervals (Whisenant 1990). As the fire return interval becomes
shorter, seed banks become depleted and native shrub and perennial bunchgrasses cannot recover, resulting

in an area dominated by invasive annual grasses (West 2000). Conversely, when intervals become too long,
native shrubs become overly dense and decadent and reduce the health and productivity of the native
herbaceous understory (Chambers et al. 2007; Mensing et al. 2006; Miller and Heyerdahl 2008).
Ecologists use the concept of fire regimes and fire regime groups to characterize the relationship between
fire frequency and fire severity and their ecological implications (Barrett et al. 2010). Large landscapes can
be described by fire regime groups. Two main factors to determine the historic range of the associated fire
regime group are frequency and fire severity.
Table 3.1-1. Fire regime groups.

Group Frequency Severity Severity Description
Generally low-severity fires replacing less than 25% of the dominant
I 0 to 35 years Low/mixed overstory vegetation; some mixed-severity fires that replace up to
75% of the overstory in patches of varying size, but usually small
II 0 to 35 years Replacement High-severity fires replacing greater than 75% of the dominant
overstory vegetation
III 35 to 200 years Mixed/lowGenerally mixed-severity fires; some low-severity fires
IV 35 to 200 years
Replacement High-severity fires
Replacement,
V 200+ years
Any Severity Generally replacement severity; some of any severity type
Source: LANDFIRE Fire Regime Groups Data Dictionary (https://www.landfire.gov/DataDictionary/frg.pdf).
Fire occurs at various intervals (fire return intervals) in different vegetation types (Miller and Rose 1999;
Miller and Tausch 2001; Crawford et al. 2004). Under historical conditions, in the absence of fuels such as
cheatgrass, intervals between fires were longer in sagebrush landscapes like the project area (Bukowski and
Baker 2013). Studies performed on fuels similar to those in the affected environment have estimated
historical fire return intervals as shown in Table 3.1-2. More information about these ecosystems can be
found in section 3.3 General Vegetation including Noxious and Invasive Weeds.
Table 3.1-2. Estimated historical fire return intervals.

Historical Fire Return Interval
Vegetation Citation
In years*
Wyoming big sagebrush/perennial grass 30–100, 35–100 Crawford et al. 2004; Brown and Kapler
2000
Miller and Rose 1999; Crawford et al.
Low sagebrush >150, 100–200
2004
Mountain big sagebrush/perennial grass 15–25 Crawford et al. 2004
Miller and Rose 1999; Miller and
Mountain big sagebrush/western juniper 12–15, 12–25, 12–15
Tausch 2001; Crawford et al. 2004
*Multiple intervals refers to each cited reference under “Citation.”
Factors that determine fire regimes include the long-term frequency, intensity, and extent of fire events,
which are all largely dependent on climate and weather patterns (Krebs et al. 2010). Alterations in natural
fire regimes have greatly influenced the distribution, composition, and structure of rangeland and forest
vegetation. In many locations, the frequency of fire has decreased because of fire suppression activities and
removal of fine burnable fuels (grasses) by grazing (Cole 1981; Keane et al. 2002; Zimmerman and
Neuenschwander 1984). Changes resulting from decreased fire frequency include the following:
• encroachment of conifers, including western juniper into non-forested vegetation at forest-steppe

boundaries (Miller and Rose 1999);

• increased tree density in former savannah-like stands of western juniper (Miller and Rose 1999;
Miller et al. 2000), and
• increased density or coverage of big sagebrush and other shrubs, with an accompanying loss of
herbaceous vegetation (Baker 2006).
In contrast, fire frequency has increased in drier locations where invasive annual grasses have established
themselves (see section 3.3 General Vegetation including Noxious and Invasive Weeds). These changes
in fire regimes have caused greater homogeneity of many landscapes (Whisenant 1990).
Current Conditions
Current conditions for the affected environment can be described by using an invasive annual grass threat
state-and-transition model (Boyd et al. 2014). The model describes certain vegetation states and transitional
phases based on the amount of sagebrush cover and the cover ratio between invasive annual grasses and
perennial grasses (Figure I-1, Appendix I). Map 12 (Appendix Q) and Table 3.1-3 show the acres within
each state and transitional phase within the project area. These state-and-transition acreages quantify the
current extent of vegetation communities dominated by invasive annual grasses (C and D), vegetation
communities in transitional phases that may be targeted for stabilizing intervention (A-C, B-D), and
vegetation communities least threatened by invasive annual grasses (A and B). They also relate the quality
and type of sage-grouse habitat present. Acres within state A, and transitional phase A-C provide year
round suitability for sage-grouse. Acres within state C and B provide seasonal habitat. Acres within B-D
transitional phase and state D indicate non-suitable habitat. Degraded habitat can be directly correlated to
frequent wildfire occurrence and low resistance and resilience (Chambers et al. 2014).
Table 3.1-3. Invasive annual threat.

State or Transition Acres
A 1,746,295
B 690,268
A-C 256,315
C 283,245
B-D 323,554
D 248,915
Unmapped 68,784
Another way to describe the current conditions within the project area is the concept of resistance and
resilience (R&R) (Chambers et al. 2014). Resilience is the capacity of an ecosystem to regain its
fundamental structure, processes, and functioning when altered by stresses and disturbances. Resistance is
the capacity of an ecosystem to retain its fundamental structure, processes, and functioning despite
stressors, disturbances, or invasive species. Resilience and resistance are highly correlated with soil
temperature and moisture regimes (Chambers et al. 2014). For example, warm, dry, lower elevation sites
like those in the Snake River Plains are less resilient to disturbance and less resistant to invasion by
invasive plant species such as cheatgrass. In contrast, higher elevation cool, moist sites are both resilient
and resistant. Map 5 (Appendix Q) and Table 3.1-4 show acres in each classification of resistance and
resilience in the project area. As shown, over half (55%) of the project area has low R&R, indicating these
ecosystems are particularly vulnerable to poor recovery and conversion to invasive grasses after
disturbance by wildfire.

Table 3.1-4. Resistance and resilience.
Resistance and Resilience Classification Acres
Wetland/Riparian 11,140
Low 1,979,877
Moderate 746,591
High 877,926
The project area can also be described using fire behavior fuel models (Scott and Burgan 2005). Fuel
models can help predict fire behavior over the landscape and are widely used to predict flame length, rate
of spread, and fire extent on a landscape. A full description of fuel models can be found in Appendix B.
Acres of each fuel model within the affected environment are shown in Map 13 (Appendix Q) and Table
3.1-5 (LANDFIRE 2014). Most fuel models within the project area are grass, grass-shrub, shrub, and
timber. Grass-shrub (GS2) and tall grass (GR4) fuel models, which account for 37% of the project area,
have fire behavior profiles with high flame lengths and rates of spread. They would therefore be targeted
for treatment.
Table 3.1-5. Fire behavior fuel models.

Fuel Model 40 Intersected with Tri-state
Fuel Type Acres
GR1 (sparse grass) 15,099.72
GR2 (low grass) 1,554,822.07
GR4 (tall grass) 3,020.55
GS1 (low grass-shrub) 286,325.44
GS2 (grass-shrub) 1,310,034.08
SH1 (low shrub) 2,5126.05
SH2(moderate shrub) 310,508.77
SH3 (moderate humid shrub) 6,460.79
SH7 (tall, dense shrub) 25,155.53
TL3 (conifer litter) 2150.19
TU1 (timber-grass-shrub) 39,865.45
Other burnable fuel models 465.58
Grand Total (acres) 3,579,034.43
3.1.2 Environmental Consequences
3.1.2.1 Issue Statement(s)

• How do fuel breaks modify fire behavior and fire size under typical and extreme fire weather
conditions?
• What are the costs and benefits of fuel break implementation and maintenance?
3.1.2.2 Indicators
• Changes to fire behavior (e.g., flame length, rate of spread)
• Efficiency of fire control (e.g., reduced fireline intensity)
• Miles of fuel break and wildfire intersection averaged from 10 FSPro wildfire simulations

• Acres of GRSG habitat impacted by fuel breaks versus modeled wildfire
• Estimated costs of suppression and post-fire rehabilitation
• Estimated costs of a fuel break network
3.1.2.3 Assumptions
• Fire behavior was modeled as a 95th percentile event to represent extreme fire behavior.
• Costs are only estimates and based on past, present and ongoing plans. Maintenance would occur
approximately every 3 to 7 years in response to treatment monitoring (Appendix H).
3.1.2.4 No Action Alternative

The No Action Alternative would not modify fire behavior or fire size because the proposed fuel breaks
would not be constructed or maintained. Fire suppression resources would continue to be slowed by poorly
maintained roads in the Oregon portion of the project area. Large wildfires would continue to burn
sagebrush and convert vegetation to invasive annual grasslands. Firefighter efficiency and areas to safely
engage wildfire would not increase. Constructing safe firelines would require more time than in the action
alternatives and would result in localized ground disturbance from the heavy equipment required to do so.
The No Action Alternative would not contribute to an implementation or maintenance cost beyond existing
and planned fuel breaks in the project area (i.e., Bruneau fuel breaks) because no additional fuel breaks
would be constructed. No benefit or potential suppression cost savings would be realized as a direct result
of this alternative, however other unrelated actions could still take place that could lead to suppression and
post-fire rehabilitation cost savings over time (e.g., prioritization of deployment of firefighting resources,
development of new water sources, educational outreach on human ignitions). Districts and Resource Areas
may still decide to construct additional fuel breaks within the CIAA at a smaller scale, as was done in
connection with the Soda Fire under the Soda Fire Fuel Breaks Project. However, the probability of a more
comprehensive network that is integrated across this portion of Oregon, Idaho and Nevada is extremely
low, and the development of any fuel breaks under such a project would likely take longer to implement.
3.1.2.5 General Effects of Action Alternatives

Issue 1. How do fuel breaks modify fire behavior and fire size under typical and extreme fire weather
conditions?
Efficacy of Fuel Breaks

All action alternatives include the construction and maintenance of fuel breaks designed to modify fire
behavior and make fires easier to control and contain. During typical and extreme conditions, fuel breaks
modify fire behavior by reducing the rate of spread, flame length, intensity, and continuity of available
fuels (Appendix B). Fuel break research and monitoring demonstrates that fuel breaks can change fire
behavior by limiting spread and intensity. Modeling of fuel break treatment and non-treatment conditions
has shown that fuel break networks can result in meaningful reductions in area burned and burn probability.
Using simulation modeling, Oliveira et al. (2016) found that a proposed fuel break network in southern
Portugal would reduce fire size by up to 17% and burn probability between 4% and 31%. In another study,
researchers examined the efficacy of fuel breaks over 28 years including 144 wildfire intersections in
Chaparral shrublands on the Angeles, Los Padres and San Bernardino Forests in California (Syphard et al.
2011a). Over that period, fuel breaks were able to stop fires up to 49% of the time. Firefighter access was
shown to directly improve the outcome of fire suppression on all three forests (Syphard et al. 2011a,
Syphard et al. 2011b). No similar research yet exists for fuel breaks within sagebrush landscapes, where
limitations in data collection have precluded quantitative study of fuel breaks’ effects on fire behavior
(Shinneman et al. 2018).

The best available information on interactions of fire and fuel treatments within sagebrush ecosystems is
available from the Fuel Treatment Effectiveness Monitoring (FTEM) program. Although FTEM reports are
qualitative, they demonstrate that firefighters on the ground in sagebrush-dominated landscapes uniformly
perceive fuel breaks to be effective aids to modify and control fire behavior (Moriarty et al. 2016). Results
from monitoring show fuel treatments to be 97% effective in changing fire behavior and 95% effective in
controlling wildfire in Oregon, Idaho, and Nevada on BLM rangelands between 2006 and 2014 (Moriarty
et al. 2016). 9 Several local fires have shown fuel break effectiveness, including the Centennial Fire in 2018
(Appendix A).
Limitations of Fuel Breaks

During extreme fire behavior, fuel breaks may be breached by spot fires that cross the roadway. Spotting
occurs when winds carry burning embers from the flaming front across the fuel break or roadway (control
line) into a receptive fuel bed. Spotting in sparse grass (GR1) and low shrub (SH1) fuel types is short range
and short duration as compared to the existing grass-shrub (GS2) fuel type prior to treatment. Spot fires that
start or grow beyond the treated footprint of the fuel break may become more difficult to extinguish,
however suppression resources would benefit from the access and safe anchor point provided by the fuel
break and road. Fuel treatments may also be less effective in areas where the configuration of fuel breaks
changes abruptly (e.g., due to changes in property ownership). For information on past fuel treatments’
interactions with recent fires in the Great Basin, see Appendix A. The proposed design of Tri-state fuel
breaks incorporates lessons learned from these experiences.
Direct Benefits to Suppression Resources

By moderating fire behavior under typical and extreme conditions, firefighters can actively engage a
wildfire within a safer working environment and have greater opportunities to reduce fire size. Reducing
fuels within fuel breaks provides firefighters with the following benefits during suppression activities:
• Reduced fireline intensity. As fire spreads from grass-shrub (GS2) and tall grass (GR4) fuel types into
treated fuel breaks with sparse grass (GR1) or low shrub fuel types (SH1), fire intensity is reduced,
thereby increasing the safety margin for suppression resources (Appendix B). The fuel break adjacent
to the road would increase the area and duration in which fire behavior would be reduced and fire
intensity lowered. This would increase the margin of success for fire suppression resources.
• Reduced spotting distance. Changing the fuel type within the fuel break from a sagebrush type to a
grass fuel type would reduce spotting distance. Because of their fineness and short consumptive time,
grasses produce fewer embers that remain hot when they return to the ground (Werth et al. 2011).
• Increased ability to patrol and suppress spot fires across the line. Detection and extinguishment of spot
fires would increase in areas where fuels have been mowed or reduced. When fire spotted into a treated
area of reduced fuels, suppression resources would need less equipment, water, and fire retardant to
extinguish it. In the absence of fuel breaks, spot fires could remain undetected in tall sagebrush until
well established and more difficult to suppress.
• Decreased fire residence time. The residence time of flaming fuels would be greatly reduced in fuel
breaks due to the reduced fuels in the fuel treatment zone and roadbed. Suppression resources would
have greater mobility to move up and down a fireline (fuel break) more quickly, holding and
controlling the fire in fine fuels versus heavy sagebrush fuels. This would allow firefighters to hold and
secure larger expanses of line with fewer resources.
9
When comparing these results to the Syphard et al. (2011a) study in Chapparal shrublands, the difference in recorded
success rate likely arises from two main factors: 1) modification of fire behavior includes a wider range of scenarios than
stopping a fire, and 2) during the period under review, FTEM monitoring reports were not systematically recorded for every
instance in which a fuel break met a fire.

• Increased effectiveness of fire retardant. Fire retardant could more completely coat treated fuels rather
than being isolated to the sagebrush canopy, where fire could creep through fine fuels underneath the
sagebrush.
Although aerial resources often provide critical assistance in suppression, all fires must be engaged by
ground resources to completely extinguish a wildfire. To safely access and engage fires, ground resources
rely on roadways, which provide quick ingress and egress in case of emergencies associated with changing
fire conditions. The roads in the fuel break network would allow for the maintenance of fuel breaks and
serve as a 10- to 30-foot hard break in fuel continuity.
A fuel treatment zone width of 200 feet on both sides of the road would create a 410- to 430-foot corridor
of modified fire behavior, allowing firefighters the time and space to more safely attack a fire coming from
any direction. As fire moves into the fuel breaks, reduced herbaceous fuel continuity would modify fire
behavior by reducing flame length and rate of spread. The 200-foot vegetation treatment on both sides of
the road would significantly increase the area in which reduced or modified fire behavior exists, thereby
increasing the time and space firefighters have to anticipate and respond to the changing fire environment.
For additional information, refer to Appendix B.
Comparison of Action Alternatives for Issue 1

Although there is currently no practical fire behavior program that shows the effectiveness of a fuel break
as a wildfire passes through the treated fuel bed, a fire spread probability scenario can show how many
miles of fuel breaks would intersect a potential wildfire based on each alternative. We can then use these
modeled intersections as a proxy to estimate the extent of strategic opportunities for suppression activities
provided in each network under different fire spread probabilities.
We used the fire spread probability program FSPro to model fuel break effectiveness of the action
alternatives. Ten FSPro scenarios were created using 250 fire simulation runs to mimic a large wildfire
within the project area with similar environmental conditions to the Long Draw Fire in 2012 (Map 14,
Appendix Q). Weather conditions for the Long Draw 2012 fire were selected because this fire exhibited the
type of extreme fire behavior the action alternatives are designed to address. Fire starts were chosen at
random within the project area and simulations lasted 7 days. A detailed description of FSPro methods can
be found in Appendix O. The FSPro model created two main outputs for analysis, fire spread probability
and fire size based on the 250 runs for each of the wildfire simulations. Below is a table showing the miles
of fuel breaks that intersected the fire spread probability outputs within the project area for each alternative
(Table 3.1-6).
Table 3.1-6. Average miles of fuel break and fire intersections modeled by alternative.
Fire Spread Maximum Fire Miles of Intersection
Probability Probability Zone (ac) Alt 2 Alt 3 Alt 4
0.2 - 4.9% 468,884.12 194.05 134.49 91.79
5 - 19% 159,659.93 80.40 59.60 32.84
20 - 39% 71,237.32 38.39 30.12 15.84
40- 59% 32,205.21 19.04 14.79 9.06
60 - 79% 14,163.95 9.70 7.23 4.34
80 - 100% 5,060.55 3.88 2.33 1.81
Based on the FSPro wildfire simulations, Alternative 2 would provide on average 1.39 times as many miles
of fuel break intersection as Alternative 3 and 2.24 times as many miles of fuel break intersection compared
to Alternative 4. Thus Alternative 2 would provide 1.39 and 2.24 times as many safe opportunities to
engage in suppression actions compared to Alternatives 3 and 4, respectively. Alternative 2 provides the

greatest opportunities for engagement in the highest probability, most likely wildfire scenarios, as well as in
the lowest probability, largest fire growth potential scenarios. As a result of the increased firefighting
efficiency associated with fuel breaks, Alternative 2 would have the highest likelihood of smaller fires,
followed by Alternative 3, Alternative 4, and lastly the No Action Alternative. Although reductions to fire
size cannot be empirically quantified, the number of miles of fuel break interaction differ substantially
across the alternatives. These intersections allow the BLM to estimate the scale of differences in strategic
opportunities among alternatives and to identify Alternative 2 as most substantially increasing the odds for
successful suppression during the rare and extreme large fires that pose the greatest threat to the sagebrush
steppe.
Issue 2. What are the costs and benefits of fuel break implementation and maintenance?
Costs and benefits can be defined by quantitative and qualitative measures. Some costs and benefits can be
quantified, including impacts to sage-grouse habitat and costs of treatments. Other costs cannot be
quantified and require a qualitative approach. For this issue, two measures were analyzed quantitatively:
direct impacts to sage-grouse habitat and monetary costs of fuels treatments, fire suppression, and post-fire
rehabilitation.
Impacts to Sage-grouse Habitat

The Long Draw wildfire scenario (Map 14, Appendix Q) was used to compare the acres of fuel break
treatment by alternative to acres of sage-grouse habitat burned within the modeled fire spread perimeters
(Table 3.1-7). As the potential fire spread gets larger, the comparable impacts of each alternative to sage-
grouse habitat decreases. In the worst case scenario incident where a fire may grow to 482,603 acres, only
1.96%, 1.27%, and 0.87% of this area would be proposed for fuel break treatments under Alternatives 2, 3,
and 4 respectively. In the most common scenario, where the fire spread probability is reached at least 80%
of the time, 4.68%, 2.69% and 1.76% of a given wildfire area would be proposed for fuel break treatments
under Alternatives 2, 3, and 4 respectively. In sum, the impacts from fuel breaks would not exceed 5% of
the landscape as compared to a wildfire in a modeled scenario based on the Long Draw fire weather. As
shown in Table 3.1-7, the impacts of any wildfire in sage-grouse habitat in Long Draw conditions (hot, dry
and windy) greatly outweigh the impacts from a fuel break. This analysis illustrates the scale of direct
impacts of action alternatives to sage-grouse habitat in comparison to the direct impacts of a future extreme
fire to sage-grouse habitat in the No Action Alternative. Although fires would continue to occur under
action alternatives in sage-grouse habitat, fire spread would be more limited as suppression resources
gained strategic opportunities for engagement.
Table 3.1-7. Fuel break impacts to sage-grouse habitat compared to modeled impacts of
wildfire.*
Sage-grouse
Sage-grouse habitat acres treated Percent fuel break disturbance
habitat acres
under proposed fuel break compared to wildfire simulations
burned*
Max. Fire
Fire Spread
Probability Alt 2 Alt 3 Alt 4 Alt 2 Alt 3 Alt 4
Probability
Zone
0.2 - 4.9% 482,603 9,469 6,112 4,188 2% 1% 1%
5 - 19% 156,795 3,865 2,740 1,614 2% 2% 1%
20 - 39% 69,858 1,795 1,387 792 3% 2% 1%
40- 59% 30,606 969 672 433 3% 2% 1%

Sage-grouse
Sage-grouse habitat acres treated Percent fuel break disturbance
habitat acres
under proposed fuel break compared to wildfire simulations
burned*
Max. Fire
Fire Spread
Probability Alt 2 Alt 3 Alt 4 Alt 2 Alt 3 Alt 4
Probability
Zone
60 - 79% 12,793 416 331 212 3% 3% 2%
80 - 100% 4,124 193 111 73 5% 3% 2%
*based on FSPro wildfire scenarios.
Costs of Fuel Breaks, Fire Suppression and ESR

Costs of large wildfires similar to the FSPro wildfire simulations can be described in terms of wildfire
suppression and post-fire Emergency Stabilization and Rehabilitation (ESR) spending. Table 3.1-8 below
shows large wildfires within and adjacent to the project area in recent years and their associated
suppression costs and planned ESR costs. Among these wildfires, the average cost of fire suppression and
planned ESR is $30,778,969. These figures however only reflect estimates of direct costs to federal
agencies that are easily quantifiable and are not comprehensive estimates of the fires’ total costs. Impacts to
permittees, to recreationists, to the local community, and to ecosystem services are more ambiguous and
difficult to calculate. While case studies have more fully estimated such losses for individual fires, this total
cost remains unknown for most fires.
Table 3.1-8. Fire suppression and ESR costs of large fires (2018 dollars).
Costs of Large Fires: Suppression and ESR
Year Fire Acres Location Suppression ESR Costs Total
Costs (estimated)*
2012 Long Draw 558,198 Vale $2,469,973 $27,182,000 $29,651,973
2012 Holloway 460,811 Vale/ Burns/ $8,461,946 $36,421,000 $44,882,946
Winnemucca
2012 Miller Homestead 160,801 Burns $2,930,492 $9,033,000 $11,963,492
2014 Buzzard 395,747 Vale/Burns $12,691,719 $10,863,000 $23,554,719
2015 Soda 279,366 Vale/Boise $7,892,848 $71,390,000 $79,282,848
2017 Snowstorm 156,014 Elko $3,321,164 $4,524,000 $7,845,164
2018 Martin 435,912 Winnemucca/Elko $9,424,429† $30,872,000 $40,296,429
2018 South Sugarloaf 233,607 Elko $8,204,186† $550,000 $8,754,186
Total Costs $55,396,756 $190,835,000 $246,231,756
Source, suppression costs: DOI Office of Wildland Fire; USDA Forest Service, Albuquerque Service Center.
Source, ESR estimated costs: Emergency Stabilization and Rehabilitation (ESR) Plans.
*Because estimates of ESR costs are drawn from planning documents, actual expenditures may differ.
†
Total suppression costs for 2018 fires may be incomplete at the time of reporting.
The anticipated expense associated with fuel break implementation and maintenance is presented below in
Table 3.1-9. The costs of fuel break implementation and maintenance vary from $8.5 million to $14.5
million. For the life of the fuel break network, maintenance would occur every 3 to 7 years as needed to
meet treatment objectives. Table 3.1-9 provides an illustration of the estimated cost of implementation and
two maintenance cycles; it does not reflect an implementation schedule. In practice, initial treatment may
occur over several years and maintenance treatments would vary dependent on monitoring for treatment
objectives. Maintenance would continue to occur beyond this period if the fuel break network continues to
meet the purpose and need.

Table 3.1-9. Total costs of fuel break by action alternative*.
Alternative 2 Alternative 2 Alternative 3 Alternative 3 Alternative 4 Alternative 4
Treatment Year (ac) Costs (ac) Costs (ac) Costs
Implementation
Year 0 67,559 $7,899,630 45,871 $5,354,402 38,044 $4,658,340
Maintenance
Year 5 67,559 $3,341,535 45,871 $2,269,955 38,044 $1,932,950
Maintenance
Year 10 67,559 $3,267,075 45,871 $2,215,625 38,044 $1,898,240
Total $14,508,240 $9,839,982 $8,489,530
*
Estimates do not reflect monitoring, failed seedings, clearing roadbed vegetation, or mineral material sites. The
approximate cost of mineral material sites is unknown at this time, but would be the same for each action alternative. Costs
associated with monitoring and failed seedings would vary and are therefore difficult to accurately estimate, but would
roughly correspond to the treatment footprint of each action alternative. Roadbed vegetation removal would cost
approximately $250 to $500 per mile, however some sections of roads selected for vegetation removal may require no
treatment.
The total estimated investment associated with the largest fuel break network under consideration,
including maintenance, is $14.5 million, a figure less than half of the average cost of suppression and ESR
associated with a single large fire, based on large fires within and adjacent to the project area in recent
years (Table 3.1-9; Table 3.1-8). For further comparison, this expenditure would equal about six percent of
the $246 million committed to suppression and planned ESR for the fires outlined in Table 3.1-8.
Cost Effectiveness of Fuel Breaks

The benefits associated with a fuel break network would include avoided suppression and ESR costs,
avoided habitat loss, and safer working conditions for firefighters. Because these benefits are difficult to
impossible to measure empirically, any cost-benefit analysis would include numerous assumptions
regarding the scale of avoided suppression and ESR costs anticipated and the monetary value of safer
suppression operations, and would not necessarily lead to a better-informed decision. Therefore, each
alternative should be evaluated in light of its estimated costs (Table 3.1-9) and anticipated effectiveness
(Table 3.1-6) in providing benefits.
Comparison of Action Alternatives for Issue 2

Alternative 2 would provide the greatest opportunity to reduce fire size and provide the greatest firefighter
safety benefit. Reducing fire size would aid in fire exclusion and increase fire return intervals, and would
provide restoration opportunities to mimic lower intensity wildfire with prescribed fire and result in lower
severity disturbance. Alternative 3 and 4 implementation costs would be lower than those for Alternative 2.
Alternative 3 would have the least impacts to social and cultural values. Alternative 4 would be the least
impacting to wildlife, both in terms of adverse impacts as a result of fuel break creation and maintenance
and beneficial impacts from improved opportunities to protect habitat. Alternative 2 provides the greatest
cost effectiveness among action alternatives through providing the greatest number of modeled
intersections between a fire and the fuel break system (i.e., opportunities for suppression) and the greatest
potential for reduced suppression and ESR costs. Alternative 2 also provides the greatest latitude for
adaptive management: with decision authority on the greatest number of pre-planned fuel breaks,
management can more easily shift priorities based on future wildfires and other disturbance outcomes.
Alternatives 3 and 4 are more limiting and have less flexibility to adjust fuel break placement based on
future disturbance.

3.1.2.6 Alternative 2
The fuel break network would extend across 1,539 miles of existing roads in Idaho and Oregon, providing
fire suppression crews with critical infrastructure to more rapidly and effectively engage with large fires
across the sagebrush steppe. An effective fuel break network would allow suppression crews to limit the
spread of wildfires over the long term; this would counteract conversion to invasive annual grasslands by
protecting areas with high and moderate R&R as well as active and future restoration treatments. In
addition, a strategic fuel break network would help return the project area to a longer fire return interval
more in line with its historical fire regime. The direct impacts to sage-grouse habitat associated with fuel
breaks represent a small fraction (2%) of the potential habitat loss modeled in a large wildfire scenario
(Table 3.1-8) and design features would avoid or minimize disturbance to sage-grouse. Based on the extent
to which Alternative 2’s fuel breaks intersected modeled wildfire scenarios, implementation of Alternative
2 would provide the greatest potential for enhanced firefighting operations and protection of sagebrush
steppe over the life of the project, by providing over twice (2.24 times) as many miles of intersection as
Alternative 4 and 39% more miles of intersection as Alternative 3.
The fuel break network would extend across 1,063 miles of existing roads in Idaho and Oregon. Effects
would be similar to those described for Alternative 2, however the benefits of improved firefighting
efficiency and protection of sagebrush steppe would be significantly less. Alternative 3 provides more
limited strategic infrastructure for suppression crews compared to Alternative 2, but improved strategic
infrastructure over Alternative 4, therefore future suppression and ESR costs are expected to fall between
costs projected for Alternatives 2 and 4. In the wildfire scenarios modeled for this analysis, Alternative 3
provides 28% fewer opportunities on average for suppression resources to engage a fire compared to
Alternative 2.
The fuel break network would extend across 910 miles of existing roads in Idaho and Oregon. Effects
would be similar to those described for Alternative 2, however the benefits of improved firefighting
efficiency and protection of sagebrush steppe would be significantly less. Because Alternative 4 provides
more limited strategic infrastructure for suppression crews compared to the other action alternatives under
consideration, future suppression and ESR costs are expected to be greatest under Alternative 4 of the
action alternatives considered. This alternative was designed to minimize the impacts of fuel break
treatments to wildlife, however it would provide an average of 55% (Alternative 2) and 38% (Alternative 3)
fewer strategic opportunities for wildfire protection of sagebrush-steppe ecosystems than the other action
alternatives considered.
3.1.3 Cumulative Impacts
3.1.3.1 Scope of Analysis

The cumulative impact analysis area (CIAA) consists of the proposed project area and nearby roadside fuel
break projects in Idaho, Oregon, and northern Nevada to capture direct and indirect impacts to the fire
environment and suppression operations. The timeframe of analysis is the life of the system of fuel breaks
to capture the potential long-term effects of the project and all of the reasonably foreseeable future actions
within the geographic scope.

3.1.3.2 Past, Present, and Reasonably Foreseeable Future Actions
Past, present, and reasonably foreseeable future actions that have had, are having, and/or are expected to
affect fuel break efficiency and cost/benefit analysis within the CIAA include fuel breaks, ESR, noxious
weed management, vegetation treatments including juniper treatment, and livestock grazing.
Fuel Breaks
Four other roadside fuel break projects are currently being implemented within the CIAA to protect the
sagebrush steppe, as described in Appendix N. 10 The Bruneau Fuel Breaks Project in Idaho currently
includes 1,522 acres of mown fuels treatments, with up to 2,836 acres of treatments authorized. These fuel
breaks would be completely or mostly absorbed into the Tri-state fuel break network if Alternative 2 or
Alternative 3 is authorized, respectively. The Soda Fire Fuel Breaks Project includes treatment of 12,986
acres of vegetation as roadside fuel breaks in and near the footprint of the 2015 Soda Fire in Idaho and
Oregon. In Nevada, fuel breaks neighboring the project area are being constructed as part of the Owyhee
Roads Fuel Break Project and Owyhee Desert Sagebrush Focal Area Fuel Breaks. The Nevada projects
include approximately 6,400 acres of roadside vegetation treatments. These fuel breaks would increase
firefighting efficiency in the areas directly adjacent to them.
In addition, the BLM recently issued a Programmatic EIS (PEIS) for Fuel Breaks in the Great Basin. This
PEIS proposes and evaluates a system of fuel breaks across up to 11,000 miles of roads within the Great
Basin. Although the PEIS will not directly result in the construction of new fuel breaks, its analysis will
streamline the NEPA process for future fuel break projects in Idaho, Oregon, Nevada, northern California,
Utah, and eastern Washington. After the PEIS Record of Decision is issued, BLM Field Offices proposing
construction of fuel breaks will more quickly complete project-specific NEPA documents by incorporating
(i.e., tiering to) its analysis of the regional impacts of fuel breaks. If all resource impacts associated with a
proposed fuel break project were adequately analyzed within the PEIS, BLM Field Offices may issue a
Determination of NEPA Adequacy (DNA) to implement the project.
Vegetation Treatments (ESR, Noxious Weed, and Juniper Removal)

Within the CIAA, ESR treatments have occurred regularly in response to fires and will continue to occur.
For a description of the planned and currently ongoing ESR projects within the CIAA, see Appendix N.
Other actions occurring in the CIAA include the Pole Creek and Trout Springs juniper treatments around
Juniper Mountain, Owyhee County, Idaho, which involve juniper cutting and broadcast burns covering
approximately 38,000 acres. In addition, the Bruneau Owyhee Sage-Grouse Habitat (BOSH) Project will
reduce up to 617,000 acres of early stage western juniper encroachment from sage-grouse habitat across a
1.67 million project area. Excluding sagebrush planting, vegetation management treatments including ESR
would have a positive effect on fire suppression efficiency. Although sagebrush planting increases fuel
loading, it generally occurs in localized treatment areas away from roadways, and should therefore have
negligible to no effects on fire suppression. Weed treatments would reduce the potential of large fire
growth and further invasive annual conversion. Native and non-native seedings would also reduce the
potential of large fire growth. Native and non-native seedings would reduce the potential of large fire
growth; whereas annual grasses (fine, flashy fuels) typically result in homogenous burn patterns that
hamper rehabilitation after a fire, native plant communities contribute to a beneficial mosaic burn pattern
(due to patchier mixed fuels). Juniper reduction treatments would also positively impact fire suppression
efficacy by removing live and dead fuels within the project area, effectively reducing fuel bed height and
spotting distance.
10
Previously implemented fuel breaks within the CIAA and their ongoing maintenance contribute to the affected
environment described in section 3.1.1.

Livestock Grazing
In the short term, livestock grazing may positively affect fire suppression efficiency and contribute to
modifying fire behavior in grass dominated areas, but would likely play a minor role in shrub-dominated
areas (Launchbaugh et al. 2008; Schachtschneider 2016). Although historically grazing disturbance has
been associated with conversion to invasive annual grassland, livestock grazing on BLM lands is managed
to meet the Standards for Rangeland Health (RHS) and would not contribute to further conversion.
Allotments that do not meet these standards for a period of time may contribute to pockets of degraded
landscape within the proposed project area until standards are achieved. If an area is found not to meet
RHS, the BLM must implement appropriate corrective action no later than the start of the next grazing year
(43 CFR 4180).
3.1.3.3 No Action Alternative – Cumulative Impacts

Although fire suppression resources would benefit from the system of fuel breaks currently being
implemented under the Bruneau Fuel Breaks Project, the Owyhee Roads Fuel Break Project, and the
Owyhee Desert Sagebrush Focal Area Fuel Breaks, the No Action Alternative would not contribute any
additional firefighting efficiencies to existing fuel breaks. Because the proposed system of fuel breaks
would not be established, fuel break treatments in the planning and early implementation stage within the
CIAA would be limited to 22,261 acres.
Response times would continue to be lengthy for fires that threaten the sagebrush steppe, both because
many locations in the CIAA are remote and because firefighters must prioritize threats to human life and
property, which generally occur elsewhere (i.e., WUI). If a future fire in the sagebrush steppe of the CIAA
does not intersect available fuel breaks, fire suppression crews would need to construct a fireline before
engaging in attack, a precondition for safe suppression operations. Constructing firelines would result in
ground disturbance from bulldozers and mechanized equipment and could occur anywhere across the
landscape. Given these circumstances and wildfire projections for the Great Basin (Zhu and Reed 2012),
significant loss of sagebrush communities to wildfire would be expected in locations outside these smaller
fuel break networks.
Increasing fire size, intensity, and frequency would lead to a concomitant rise in ESR costs associated with
increased geographic scope, extent and failure rates of treatments. Current and future vegetation treatments
would help to improve landscapes’ resiliency to fire by reducing annual invasive grasses and seeding native
shrubs, grasses, and forbs. However, investments in ESR and other vegetation treatments may be
adequately protected from wildfire only when near or adjacent to the fuel breaks described above. It is
unlikely that vegetation treatments and fuel breaks currently being implemented would shift the fire return
interval of sagebrush communities in the CIAA toward historical conditions (i.e., less frequent fires) given
their limited geographic footprints. Livestock grazing is expected to have a limited benefit to fire
suppression efficiency overall given the large expanses of shrublands within the CIAA.
3.1.3.4 All Action Alternatives – Cumulative Impacts

The cumulative effects of all action alternatives for fire suppression resources arise from the direct and
indirect effects of the fuel breaks described across the CIAA. Direct effects of fuel breaks (i.e., fewer
resources needed and safer working conditions for firefighters) would lead to indirect effects over time,
such as the preservation of intact stands of sagebrush, as well as suppression and ESR cost savings.
Cumulative effects of each action alternative would differ dependent on the scale of the fuel break network;
the largest fuel break network (Alternative 2) would provide the greatest cumulative benefit. For
firefighting and fuels management, the primary cumulative impacts of action alternatives would be

• Improved coordination across jurisdictional boundaries to better protect the threatened sagebrush
steppe from wildfire.
• Transitioning sagebrush communities in the CIAA to a fire return interval more in line with
historical conditions.
• Improved protection of agency investments in ESR and other vegetation treatments.
In combination with vegetation treatments, a strategic network of fuel breaks in the CIAA would help
transition sagebrush communities to a fire regime that is more in line with historical conditions by
interrupting the invasive/fire cycle. Response times would continue to be lengthy for fires that threaten the
sagebrush steppe, however where future fires in the CIAA intersect available fuel breaks, fire suppression
crews would be able to quickly establish anchor points without constructing firelines from scratch. This
would reduce the resources needed to fight fire and greatly reduce the ground disturbance otherwise
necessary for safe suppression operations.
3.1.3.5 Alternative 2 – Cumulative Impacts

Under Alternative 2, current and future vegetation treatments would benefit from increased protection from
wildfire due to an additional 67,559 acres of fuel break treatments that suppression resources could utilize.
Within the CIAA, fire suppression resources would benefit from a combined total of 87,022 acres of
roadside fuel break treatments.


3.2 Soils
The affected environment for soils is the footprint of the proposed fuel break project and mineral material
sites because soil disturbing activities would only occur within this area (Map 4; Maps 6-11, Appendix Q).
Soil information is derived from the Soil Surveys of Owyhee and Canyon County Area, Idaho (USDA
NRCS 2015a; USDA NRCS 2015b) and Malheur County, Oregon (USDA NRCS 2018 Provisional).
Major landforms include lava plateaus, foothills, tablelands and mountains; fan remnants and structural
benches are also found throughout the area. Occasional rock outcrops are a distinct feature of this
landscape. Generally, these soils are derived from volcanic rock including rhyolite, welded tuff, and
basalts. Most soils in the analysis area are well drained; depth to a root restrictive layer ranges from 20 to
greater than 60 inches of loams, gravelly loams, and sands.
Idaho common soils to the north and east include Willhill-Cottle gravelly loam association, with 3 to 35
percent slopes on hills and plateaus that formed in alluvium and residuum derived from rhyolitic tuff. The
center of the project area consists of Wickahoney-Monasterio-Yatahoney gravelly loam association, 1 to 20

percent slopes formed from volcanic ash and colluvium over bedrock derived from volcanic rock and
Monasterio-Wickahoney stony sandy loam complex, and 1 to 20 percent slopes on structural benches,
foothills, and tablelands. Troughs-Owsel stony loam complex with 1 to 10 percent slopes and Troughs-
Sugarcreek stony loam association with 2 to 15 percent slopes on structural benches and plateaus are to the
east as well. To the west is Bedstead-Arbidge stony silt loam association with 2 to 15 percent slopes on
foothills and tablelands that formed from volcanic ash over slope alluvium over bedrock derived from
volcanic rock. To the southwest are Arbidge-Hunnton silt loams with 1 to 8 percent slopes and Arbidge-
Owsel-Gariper complex with 1 to 15 percent slopes on fan terraces and tablelands that formed from
colluvium over bedrock derived from basalt, igneous rock, or welded tuff.
Oregon common soils to the north include Bogusrim ashy silt loam with 2 to 8 percent slopes on lava
plateaus that formed in mixed volcanic ash and loess over residuum weathered from volcanic rock. The
south and southeast consists of Snowmore ashy silt loam and Snowmore gravelly ashy very fine sandy
loam with 2 to 15 percent slopes on plateaus and mountains that formed in loess over residuum from basalt
and rhyolite. To the east are Babala ashy silt loam with 2 to 8 percent slopes on lava plateaus and Drice
ashy silt loam with 2 to 8 percent on hills and plateaus that formed in mixed volcanic ash and loess over
residuum weathered from basalt and volcanic rock are common. The west consists of Nevador ashy fine
sandy loam with 2 to 15 percent slopes on fan remnants and Zevadez gravelly ashy loam with 2 to 15
percent slopes on fan remnants, hills and plateaus that formed in alluvium derived from mixed rocks, loess,
and volcanic ash.
Erosion Potential
Wind Erodibility
The majority of the affected environment is beneath 6,000 feet in elevation and in an 8-13 inch
precipitation zone. In the Oregon portion of the project area, numerous and repeated wildland fire events
have occurred over the last 20 years, exposing topsoil to erosional forces until vegetation reestablishes. The
Idaho portion of the project area has experienced wildfire much less frequently. Wind erosion usually
occurs in the first nine to ten months after a wildfire when the soils are bare and the vegetation has yet to
recover. In 2012, a haboob (an intense dust storm) traveled with the outflow of a collapsing thunderhead
from the 560,000 acre Long Draw fire in southeast Oregon and northwest Nevada and delivered record
particulate matter levels to a three-county area (Germino et al. 2015). Threshold amounts of plant cover for
wind erosion have been determined for sagebrush steppe for only one site (Sankey et al. 2009), and several
indicators suggest that the type of vegetation before and after fire is important. Sites where shrubs existed
before fire produce the greatest erosion, but intact shrub stands provide significant protection from erosion
(Sankey et al. 2012).
The wind erodibility group (WEG) is used to quantify the susceptibility of soil to blowing. Wind erodibility
groups range from 1 through 8. The WEGs are based on properties of the soil surface horizon. There is a
close correlation between soil blowing and the size and durability of surface clodiness, fragments, organic
matter, and the calcareous reaction. The soil properties that are most important with respect to soil blowing
are (1) soil texture, (2) organic matter content, (3) effervescence due to carbonate reaction with HCl, (4)
rock and pararock fragment content, and (5) mineralogy. Soil moisture and the presence of frozen soil also
influence soil blowing (USDA NRCS 2018). Soils assigned to Group 1 are the most susceptible to wind
erosion, and those assigned to Group 8 are the least susceptible. The acres and proportions of each category
present within the project footprint (none, low, moderate, and high) are presented in Table 3.2-1.

Table 3.2-1. Affected environment: Potential for erosion by wind.
Erosion Susceptibility WEG Acres Portion of Footprint
None* Not assigned 4,164 6%
Low 8 555 1%
Moderate 3-7 59,452 80%
High 2-1 9,778 13%
*Soils in some map units (e.g., rock outcrops, rubbleland, and water) are not assigned to a WEG. Soil surfaces in this
category include cobbles, stones, boulders, and bedrock and are not susceptible to erosion by wind.
Water Erodibility
The K factor or soil erodibility factor (Kw) is used to quantify soil detachment by runoff and raindrop
impact. The Kw applies to the whole soil, including rock fragments. For this analysis, it specifically refers
to soil properties of the surface horizon. A wide range of soil types can be eroded, regardless of their sand
or clay content, degree of particle aggregation (slaking, or aggregate breakdown in water), or “K” value
assigned to the soil mapping unit in the USDA Natural Resources Conservation Service, Web Soil Survey
and Soil Data Viewer (USDA NRCS 2017). The lower the Kw value, the more resistant that soil is to
erosion by water. The acres and proportions for each category (none, low, moderate, and high) are
presented in Table 3.2-2.
Table 3.2-2. Affected environment: Potential for erosion by water.

Erosion Susceptibility Kw Range Acres Portion of Footprint
None* No Kw 4,162 6%
Low 0.02 to 0.19 12,845 17%
Moderate 0.20 to 0.40 35,576 48%
High 0.41 to 0.69 21,366 29%
*Soils in some map units (e.g., rock outcrops, rubbleland, and water) are not assigned a K factor. Soil surfaces in this
category include cobbles, stones, boulders, and bedrock and are not susceptible to erosion by water.
Other Soil Properties

Biological Soil Crusts
Biological soil crusts play an important role in protecting and stabilizing soils in arid communities in the
project area. Biotic soil crusts, physical crusts, and gravel or other highly aggregated soil surface conditions
inhibit erosion (Ravi et al. 2011). They function as living mulch by retaining soil moisture and
discouraging annual weed growth. They reduce wind and water erosion, fix atmospheric nitrogen, and
contribute to soil organic matter (Belnap et al. 2001). Biological soil crusts also protect interspatial surface
areas from various forms of erosion. By occupying the area between larger plants, these crusts enhance soil
stability, soil moisture retention, and site fertility (by fixing atmospheric nitrogen and contributing organic
matter). Biological soil crust condition and spatial extent are indicators of the ecological health of the plant
community; they influence site fertility; increase soil productivity; and aid in soil moisture retention and
soil surface stability (USDI BLM 2001).
Biological soil crusts are present throughout the proposed treatment area; however, the extent of these
crusts on the Vale and Boise Districts is not mapped as no comprehensive inventory has been conducted.
Distribution is a function of seven factors that interrelate with one another: elevation, soils and topography,
disturbance, timing of precipitation, vascular plant community structure, ecological condition, and
microhabitats (USDI BLM 2001). The most critical physical factor for biological soil crust establishment is
the presence of fine-textured surface soils such as silts, silt loams, and non-shrink/swell clays (USDI BLM
2001). Dominant shrub types and herbaceous plant density and form also contribute to crust establishment.

The treatment area is dominated by plant communities that have a high potential for biological soil crusts.
However, sites where the vegetation structure has been modified by invasive plants have a reduced
potential for biological crusts.

• What are the impacts to fragile/erodible soils from establishing fuel breaks (i.e., disking, mowing,
seeding, herbicide, targeted grazing, prescribed fire, clearing selected roads of vegetation) and
establishing mineral material sites?
• How would establishment and maintenance of fuel breaks and mineral material sites affect
biological soil crusts?
3.2.2.2 Indicators
• Acres of disturbance associated with the Tri-state Fuel Breaks Project
• Potential for large wildland fire
3.2.2.3 Assumptions
• Fragile and erodible soils are those that are moderately to highly susceptible to wind or water
erosion (WEG and Kw, respectively).
• Short-term is < 3 years; long-term is 5-10+ years.
• Biological soil crusts are present throughout the proposed treatment area.
3.2.2.4 Alternative 1 – No Action Alternative

Under the No Action Alternative, fuel breaks and mineral material sites would not be constructed;
therefore, soils within the proposed fuel breaks (67,559 acres, 45,872 acres, or 38,044 acres, respectively)
and mineral material site footprints (80 acres total) would not be disturbed or altered. No treatments would
occur under this alternative to reduce the scale of wildfire within the analysis area. Large wildfires would
continue to occur, removing protective vegetation and damaging biological crust. The magnitude of change
occurring during a fire would depend largely upon the severity of fire, combustion and heat transfer,
magnitude and depth of soil heating, proximity of the soil property to the soil surface, and the threshold
temperatures at which the different soil properties change (Neary 2005). These impacts would reduce soil’s
ability to resist the erosional forces of wind and water and expose soils to thermal extremes. Following the
Long Draw fire on Vale District in 2012, intense dust plumes and a haboob developed over the burned area,
causing substantial loss of top soil. Dust or sand storms such as these result in major soil lofting and
movement.
Indirect effects of an increase in fires and subsequent fire suppression activities (e.g., bulldozer lines)
include fire damage to biotic crusts, reduction of vegetation cover, and increases in both wind and water
erosion on exposed soil surfaces. In the year following a wildland fire, increases and/or dominance of
invasive annual grasses and forbs would likely occur. Annual grass biomass/roots contribute very limited
amounts of organic matter into the soil profile and have less extensive root systems compared to perennial
grasses. Annual grass biomass, which widely fluctuates from year to year, can provide some protection
from wind erosion in sufficient quantities, but offers little resistance to water erosion and off-site soil
movement during thunderstorm events due to its small limited root systems. Further decreases and/or
compositional changes in soil organisms and biological soil crusts would occur over time in areas
dominated by annual grasses and forbs. Increases in soil erosion and decreases in soil organisms and

biological soil crusts would lower site productivity over the long term. Large-scale surface soil erosion is
anticipated under this alternative because of expected future fires resulting from current conditions on the
landscape.
3.2.2.5 General Impacts of Action Alternatives

Soils within the fuel breaks (i.e., fuel treatment zones and cleared roadways) and mineral material sites
would be directly affected, while indirect effects would occur adjacent to the fuel breaks and mineral
material sites within the analysis area. By design, soils within the footprint of the fuel breaks would be
affected in the areas recommended for treatment (up to 67,559 acres). High levels of soil disturbance (e.g.,
disking), and periodic, repeated treatment (e.g., targeted grazing) are examples of design treatments that
have soil disturbance factors associated with implementation of the Action Alternatives. By facilitating
improved suppression opportunities in the project area, fuel breaks would result in fewer acres burned over
the long term, protecting unburned soils from adverse impacts associated with severe wildfire (e.g., loss of
native perennial vegetation and biological soil crusts, increased susceptibility to wind erosion, and reduced
water infiltration [i.e., hydrophobic soils]).
Mowing and Hand Cutting

Short-term effects of mowing or hand cutting to the soil resource would be very minimal. When mowing
sagebrush using a rubber tired tractor, compaction of the surface soil horizons would be a minor short-term
effect. Compaction decreases the number and size of pores in the soil matrix, potentially affecting water
infiltration, permeability, and air exchange. This effect would be more pronounced on fine textured soils
(i.e., silts and clays). Normally, only one pass with a tractor would be made in the same location during
implementation, so disturbance to the soil surface horizons, including biological soil crusts and
compaction, would be very minimal and confined to those areas where the tractor tires make contact with
the soil surface. Due to the absence of heavy equipment, hand cutting would be even less impacting to the
soil resource including biological soil crusts than mowing. Sagebrush and the herbaceous understory would
be left at a height of at least six inches and the remaining cut debris would be left on-site. For these reasons,
soil erosion from wind or water in mowed or hand cut areas would not be expected to increase above
normal levels. No long-term adverse effects to the soil resource from mowing or hand cutting would be
expected, nor would any indirect adverse impacts be expected. The monitoring program would evaluate
vegetation changes post-treatment. Maintenance mowing or hand cutting would occur infrequently (every 3
to 7 years) and therefore long-term effects to soils due to compaction or erosion from mowing or hand
cutting would not be expected.
Seeding & Seedbed Preparation

Erosion by wind would be the primary short-term impact from drill seeding using a standard rangeland
drill. Depending on the type of vegetation present on-site during implementation, some or all of the
vegetation cover and biological soil crusts would be removed. Soil surface horizons to a depth of 2-4 inches
(Asher and Eckert 1973) would be disturbed, altering soil aggregates and making the soil susceptible to
wind erosion (and water erosion on steeper terrain) as well as increases in temperature and dryness for a
year or more until planted species become established.
In areas where cheatgrass or medusahead are the dominant herbaceous species, drill seeding would remove
most to all of the vegetation cover. Perennial bunchgrasses and sod forming grasses, where they exist,
would likely survive a drill seeding disturbance and would provide partial vegetation cover, thereby
limiting short-term increases in temperature, dryness, and erosion potential. Use of a minimum-till drill for
seeding would substantially decrease the depth and extent of soil disturbance, making increases to soil
temperature, dryness, and erosion potential a minor effect. Increased erosion potential would last until
seeding establishment is adequate to prevent soil movement by wind and water, approximately one to three

years for each treated area. Soil movement due to wind in the linear treatment areas could blow onto roads
or adjacent untreated areas. This impact is expected to be sporadic, corresponding with wind events. While
most of the proposed fuel break segments occur on relatively flat topography, water erosion could occur in
treatment areas that occur on slopes, resulting in formation of rills and soil deposition at the bottom of the
slope. This impact is expected to be sporadic, corresponding with high intensity rain events. An indirect
effect of drill seedings would include reduced potential for larger wildland fires and increased capability to
protect existing biological crusts and soils from erosional factors after seedling establishment.
Disking
Wind erosion would be the primary short-term effect to the soil resource when disking with a plow. Water
erosion could also occur on steeper terrain (> 20% slope). Disking as a means of creating a bare ground
fuel break would remove existing vegetation cover and disturb the soil surface horizons up to a depth of
nine inches, altering soil aggregates and making the soil susceptible to erosion for as long as the fuel break
is maintained. This effect would be more pronounced on coarse textured soils (i.e., sands). The
microclimate of treated soils would change, increasing in temperature and dryness.
Disking would result in the immediate disturbance of biological soil crusts (mosses and lichens) where they
exist and could affect the presence and abundance of soil microorganisms (cyanobacteria, fungi, etc.) that
contribute to overall soil quality. Soil organisms living close to the soil surface would be exposed to
desiccation and predation. The removal or destruction of biological soil crusts could adversely affect soils
over time by increasing susceptibility to erosion, encouraging weed establishment, and reducing nitrogen
inputs and water infiltration (Belnap 1995; Belnap 1996; Evans and Belnap 1999; Belnap and Gillette
1997; Belnap and Gillette 1998). Recovery rates are generally species dependent, and can range from 14 to
35 years for cyanobacteria, 45 to 85 years for lichens, and 20 to 250 years for mosses (Belnap et al. 2001).
Use of rangeland seed drills, chaining or harrowing can impact the soil surface and influence erodibility,
but longer term enhancement of perennial vegetation and reduced fire may offset the initial erosion risks
posed by these treatments. Use of species with larger and heavier seed, combined with seed burial, may
result in less seed redistribution by wind after seeding. Also, perennials that tiller or form adventitious roots
may be more adapted to shifting soils (e.g., western wheatgrass) (Germino 2015).
Seeded Species
On lower elevation Wyoming big sagebrush sites, where revegetation success is relatively low and the
threat of annual grass invasion is high, use of non-native bunchgrass species, such as crested wheatgrass,
may represent a prudent interim revegetation alternative from an ecological standpoint (Asay et al. 2001).
The benefits of using crested wheatgrass in lower elevation revegetation must be weighed against the
potential for inhibition of native plant diversity. While restoration of crested wheatgrass communities to
native plant dominance remains problematic (Hulet et al. 2010; Fansler and Mangold 2011), maintenance
of soil resources and ecological processes associated with introduced perennial plant communities suggests
that this transition would be much easier than restoring native vegetation on annual grass-dominated sites
(Cox and Anderson 2004; Ewel and Putz 2004). Establishing some form of perennial grass is key to
preventing invasion by exotic annual grass species (Eiswerth and Shonkwiler 2006; Davies 2008) and
associated degradation of ecosystem function. On Wyoming big sagebrush ecological sites, establishment
of crested wheatgrass is substantially higher than native species (Robertson et al. 1966; Hull and Klomp
1974; Boyd and Davies 2010). Current native and nonnative perennial grasses will shorten the number of
months that soils are bare and exposed to wind while the seeded species become established.

Chemical Treatment
When herbicides are used for seedbed preparation, noxious weed and invasive plant management, and
maintaining roadways clear of vegetation, a temporary increase in soil surface temperature, dryness, and
wind erosion potential (and water erosion potential on steeper terrain) would occur due to the reduction
and/or elimination of existing vegetation cover. Cleared roads may require repeated application of
herbicide to maintain a roadbed free of vegetation, making highly susceptible soil areas subject to erosion
by wind and water over time. Currently, there is very little information on the effects of herbicides on
biological soil crusts. One study addressed the effects of glyphosate on moss-dominated biological soil
crusts and determined there were no short-term adverse effects on bryophyte cover (Youtie et al. 1999).
Additionally, there is little information on repeated applications or long-term effects from glyphosate or
other herbicides (Youtie et al. 1999). Herbicides affect few soil organisms directly (USDA NRCS 2004).
However, there is only limited research on the toxicity of many herbicides to most soil organisms. Of the
herbicides proposed for use, three (chlorsulfuron, picloram, and metsulfuron methyl) have some adverse
effect on soil organisms, generally reducing but not eliminating local populations for a limited period.
Targeted Grazing
Utilizing cattle to create and maintain fuel breaks would disturb and/or remove both target and non-target
vegetation from the treatment footprint within the targeted grazing treatment area. Effects are expected to
be concentrated within the 200-foot treatment area along existing roads. Direct short-term effects to the soil
resource from hoof action during targeted grazing would include removal of vegetation cover and
disturbance of the soil surface horizon (including biological soil crusts where they exist), soil compaction,
and a subsequent increase in temperature, dryness, and wind erosion potential (and water erosion potential
on steeper terrain). The depth of the disturbance to the soil profile from targeted grazing, which is less than
1 inch on dry soils and approximately 1-2 inches on wet soils, is less than that associated with either
disking or drill seeding. The potential for soil loss through erosion due to hoof action is therefore
considerably less compared to disking or drill seeding.
Proper management of targeted grazing activities and design features are described in Appendix G. Over
the long term, targeted grazing without additional treatment methods would need to occur on a yearly basis
over the same area to be an effective fuel break, making the soil surface horizon vulnerable to erosional
processes for as long as the fuel break is maintained. When combined with established vegetated fuel
breaks, vegetation would help protect soil surface horizons and biologic crusts where they exist, reducing
short-term disturbance, temperature increase, drying, and wind and water erosion. Continued reductions in
disturbance and associated erosional processes are expected under long-term targeting grazing.
Management of grazing activities that maintain sufficient vegetation cover (2 inch stubble height) would
help to ensure that erosion levels are kept to minimal levels. When used to prepare seedbed (see section
2.1.2 Methods), control measures (e.g., active herding, temporary electric fencing) would limit livestock to
the treatment area. If used in this manner, effects described above would be temporary until seeded species
became established. Indirect effects could include sedimentation of adjacent creeks and water ways through
runoff. Management of grazing activities that maintain sufficient vegetation cover would help to ensure that
erosion levels are kept to sustainable levels.
Prescribed Fire
Prescribed fire as a seedbed preparation method to remove annual grass standing litter, thatch, and weeds
would most often be short duration, causing little to no subsurface heating of the soil and therefore little to
no short- or long-term effects to the soil resource. Where medusahead thatch and/or weeds are thick (~10
inches or greater) or thinned and piled sagebrush debris and tumbleweeds are burned, short-term effects
may include the consumption of organic matter in the soil surface horizon and subsequent loss of some
nutrients (e.g. nitrogen) through volatilization. Biological soil crusts (particularly mosses and lichens), if

present, could be damaged or killed by prescribed fire. Removal of vegetation and soil crusts would
increase the soil surface temperature and erosion potential over the short term until fuel break vegetation is
reestablished. Prescribed fire would most often be followed up with an herbicide treatment to control
invasive annual plants and a seeding treatment to reestablish fuel break vegetation. Prescribed fire control
lines may be disked in with a tractor. These additional treatments would further disturb the soil resource,
making it more susceptible to wind erosion (and water erosion on steeper terrain) over the short term. Over
the long-term, planted fuel break vegetation would become established, protecting the soil from erosional
forces. Burning would be done in spring when surrounding green vegetation would decrease duration, fire
intensity, and rate of spread, decreasing damage to biological soil crusts.

Blading and manual clearing of selective existing roads could increase wind erodibility on highly
susceptible soils with a WEG of 1 and 2, causing some wind erosion due to the disturbance of the soil
surface. Depending on the type of equipment used to blade roads free of vegetation, soil disturbance would
be minimal for soils at or above a WEG of 3. Blading and manual clearing of selected existing roads could
increase water erodibility on highly susceptible soils with Kw ranges of 0.41 to 0.69, causing some water
erosion due to the disturbance of the soil surface. During precipitation events, storm water flowing down
the center of the road structure may moderately increase erosion and soil loss in these areas. Wind and
water erosion could be increased in highly susceptible soils, or WEG 1 and 2, due to vegetation removal
and movement of the soil surface layer. The overall impact of blading will be higher than that of manual
vegetation removal due to the removal of the surface soil, including the displacement of biological soil
crusts. Although biological soil crusts are not likely to be present in roads that receive regular use,
biological soil crusts may be present in the roads selected for vegetation removal due to lower levels of
disturbance (i.e., low use, rarely maintained or unmaintained).
Manual removal of vegetation with the use of hand tools may be necessary in areas where the use of heavy
equipment is infeasible, restricted by design features, or has the potential to widen the existing road.
Manual vegetation removal would result in minimal soil disturbance and less wind and water erosion of
biological soil crusts. Biological soil crusts could be reduced due to an increase in exposure to the elements
after the manual removal of vegetation.
Oregon Mineral Material Sites

Soil impacts from development of new material sources in the Oregon portion of the project area would be
limited to the footprint of each 20 acre material source (up to 80 acres total). Soils that are removed from
each material site would be stockpiled on site. After periods of use (i.e., blasting, crushing, stockpiling and
hauling at the site), interim reclamation would reestablish some vegetation to stabilize soils at the site.
After the useful life of a mineral material site has been exhausted, the growth median would be re-
contoured and distributed to blend in with the natural landscape. A BLM Vale District approved seed mix
would then be used for site revegetation based on the conditions of each specific ecological site.
At the White Chicken site, the surrounding soils should be minimally impacted by the development of the
new material source due to the site’s location on lava flows. The site would be somewhat susceptible to
wind and water erosion due to the silt content of the A horizon. The Minveno section of the map unit would
not be directly affected by the material source development. Biological crusts are not readily present on
lava flows and will therefore not be affected at this site.
At the Antelope Reservoir site, removal of the top soil would greatly impact the erodible soils at the site of
the pit and around the edge of this site, from the soil surface to the duripan layer, which will maintain its
structure in the pit face. The site would be somewhat susceptible to wind and water erosion due to the sand

content of the A horizon. Biological crusts would be greatly affected at this site due to the removal of the
top soil.
At the Big Antelope Creek and Deadman Waterhole sites, the removal of the top soil would greatly impact
the erodible soils at the site of the pit and around the edge of this site, from the soil surface to the duripan
layer, which will maintain its structure in the pit face. The sites would be somewhat susceptible to wind and
water erosion due to the silt content of the A horizon. Biological crusts would be greatly affected at these
sites due to the removal of the top soil.
Under Alternative 2, roughly 73,920 acres of fuel breaks along 1,770 miles of roads would be created, and
vegetation would be removed from up to 950 miles of roads. The majority (81 percent) of these fuel breaks
would be located in areas identified as having moderate to low susceptibility to wind erosion. In areas
highly susceptible to wind erosion (i.e., WEG 1-2; 13% of fuel breaks), design features would minimize
soil disturbance to avoid the potential for significant wind erosion. In addition, 65 percent of these soils
would have moderate to low susceptibility to water erosion. Wind erosion of the surface soil horizon is a
problem in dry shrub and grassland communities following vegetation and biological crust disturbance. In
addition to vegetation, biological soil crusts play an important role in protecting and stabilizing soils in
these arid communities. Removal of vegetative cover or biological crust by events such as fire, wildlife and
livestock grazing, or recreation exposes the soil surface to temperature extremes, wind and rain, and may
result in some level of soil erosion.
The Proposed Action would result in short-term disturbance (1 to 5 years) to soil resources through an
increase in wind erosion susceptibility in the fuel break (200-foot-wide fuel treatment zone on each side of
a 10-30-foot road) after disking, herbicide, drill seeding, and targeted grazing, and in bladed roads as
described above. Effects of prescribed fire and mowing to the soil resource would be minor and short-term.
Long-term impacts would be reduced when compared to Alternative 1 because the size of wildfires would
be reduced due to fuel breaks. As perennial vegetation and biological soil crusts recover, long-term soil
productivity and resistance to disturbance would improve. Mowing maintenance treatments are not
anticipated to result in increased soil surface erosion once seeded species are established.
Under Alternative 3, approximately 51,127 acres and 1,694 miles of roads would be developed into fuel
breaks, and vegetation would be removed from up to 585 miles of roads. This represents a decrease in soil
resource disturbance of over 30 percent compared to the Proposed Action. General direct and indirect
effects related to vegetated and mowed fuel breaks would be similar to those described for Alternative 2
(Proposed Action). Implementation of this alternative would result in reduced short-term soil resource
impacts when compared to the Proposed Action, due to a reduction in the amount of ground-disturbing
activities. Over the long term, adverse impacts to soils due to wildfire and wildfire suppression activities
would be greater than for the Proposed Action. This increase in anticipated effects from wildfire would be
proportional to the anticipated decrease in fuel break effectiveness from reduced fuel break miles.
Under Alternative 4, approximately 43,803 acres and 1,057 miles of roads would be developed into fuel
breaks, and vegetation would be removed from up to 399 miles of roads. This represents a decrease in soil
resource disturbance of over 60 percent compared to the Proposed Action. Due to the anticipated decrease
in fuel break effectiveness from reduced fuel break miles, a proportionate increase in detrimental soil
impacts from wildfire would be expected. General direct and indirect effects related to vegetated and

mowed fuel breaks would be similar to those described for the Alternative 2 (Proposed Action).
Implementation of this alternative would result in reduced short-term soil resource impacts when compared
to the Proposed Action, due to a reduction in the amount of ground-disturbing activities. Over the long
term, adverse impacts to soils due to wildfire and wildfire suppression activities would be greater than for
the Proposed Action. This increase in anticipated effects from wildfire would be proportional to the
anticipated decrease in fuel break effectiveness from reduced fuel break miles.

The 3.6 million acre Tri-state project area boundary serves as the cumulative impact analysis area (CIAA).
The project area spans portions of numerous watersheds including the Owyhee River and Bruneau River.
The project area is generally bordered by the Owyhee Mountains to the north, Bruneau River to the east,
Nevada state border to the south, and U.S. Highway 95 to the north and west. The temporal scale for
cumulative impacts to soil resources is 15 years, which includes implementation of future ESR plans as
well as land and realty actions. Of the actions identified for consideration of cumulative effects, wildfire
rehabilitation and livestock grazing have shown to have the greatest potential for impact because these are
chronic impacts, occurring year after year.
The CIAA is appropriate because it captures the total area in which fuel breaks would facilitate
opportunities to protect the soil resource. Although these indirect beneficial effects to soils and biological
soil crusts from the proposed project are expected to be generalized across the project area, direct effects to
soils would be mostly localized in nature and cumulative effects to soils due to other activities would also
be mostly localized. Soil erosion by wind and water (predominantly wind) could indirectly affect adjacent
areas through soil deposition.
Past, present, and foreseeable future actions within the project area would continue to have moderate
impacts to the soil resource through disturbance of soil structure, biological crusts, and subsequent
exposure of the upper soil horizons to erosional forces resulting in soil loss and decreased productivity.
Direct and indirect adverse effects to soils would dissipate once vegetation is established in the fuel breaks.
The action alternatives would only slightly increase the cumulative impacts to the soil resource while
providing treatments to reduce the long-term effects of erosion from large burned areas on the landscape
from frequent wildland fire.

Past actions to be considered include livestock grazing, livestock trailing, road construction and right of-
way maintenance, vegetation treatment projects (including post-fire ESR projects and noxious weed
management), fire suppression activities, off-highway vehicle (OHV) use, and agriculture. The collective
effect of past actions has contributed to the existing condition of soils described in the Affected
Environment section above. Current and foreseeable future activities with cumulative impacts to soils
include: livestock grazing, livestock trailing, road construction and maintenance, wildland fire suppression
and associated ESR projects, fuel break construction on private lands, noxious weed management, and
agriculture.
Livestock Grazing
Permitted livestock grazing affects soils by altering mechanical and biological attributes. Livestock grazing
would likely continue to result in temporally and spatially variable areas of soil surface degradation and
plant community alterations that cause minor to moderate effects to soils (e.g., soil compaction, increased

exposure to erosional forces, damage to biological soil crusts, and reduced nutrient input). These effects
would be greatest in localized areas adjacent to gates, watering, and dietary supplement areas. Because
current livestock grazing permits include terms and conditions to ensure allotments achieve or make
significant progress toward meeting Standards for Rangeland Health (USDI BLM 1997a; USDI BLM
1997b), ongoing and future livestock grazing management would maintain soil conditions outside such
localized congregation areas.
Roads and Rights-of-Way

Road and ROW maintenance along roads (improved and primitive) will continue to cause minor to
moderate soil erosion and displacement within maintained buffers. These effects are generally spatially
restricted to existing locations and occur over a continuous temporal scale. Road maintenance actions
would represent permanent soil surface disturbance and compaction across the road surface. In areas with a
high percentage of silt and clay in the road surface, aggregate may be applied to roadway surfaces to harden
surfaces, improving road safety and durability.
Fuel Breaks
The Bruneau Fuel Breaks Project will implement treatment of 2,836 acres as fuel breaks within the CIAA.
This project would have no incremental impact on the CIAA under Alternative 2 because the Tri-state
project would expand its existing fuel break widths; impacts would be as described above in environmental
consequences where these projects overlap. In addition, a Programmatic EIS (PEIS) For Fuel Breaks in the
Great Basin was recently issued. Although the PEIS itself will not result in the construction of new fuel
breaks, its analysis will streamline the NEPA process for future fuel break projects in Idaho, Oregon,
Nevada, northern California, Utah, and eastern Washington.
Areas identified for vegetated fuel breaks may or may not require seeding and mechanical seedbed
preparation such as disking. Where disking would be necessary, erosion by wind would be the primary
short-term effect to the soil resource. Short-term soil erosion by water could also occur on steeper terrain (>
20% slope) until seeded vegetation establishes and helps protect soils from erosion. Over the long term,
fuel breaks would better protect the soil resource from adverse effects of wildfire.
Vegetation Treatments
ESR treatments (seedings and herbicide application) would produce an overall benefit to sagebrush
communities (i.e., habitat) in the CIAA. Depending on drill equipment (e.g., rangeland and minimum
till/Truax drills), short-term increases in soil disturbance and displacement will occur during drill seeding
operations associated with ESR projects. Successful aerial seeding would help limit short-term soil erosion
and stabilize watersheds over the long term; successful drill seeding would stabilize soils over the long
term, as well.
Juniper treatments associated with the BOSH Project and Trout Springs and Pole Creek permit renewals
would result in minor short-term disturbance to soils, primarily associated with the use of heavy machinery,
but over the long term, would improve soil structure and reduce erosion risk. Noxious and invasive weed
treatments could result in localized, short-term exposure of soils to erosion until other species become
established in treated areas. By preventing the loss of native habitats through weed control, the BLM
expects that overall, long-term soil loss from erosional forces would be negligible to minor.

Recreational OHV Use
The spatial and temporal extent of OHV activities is difficult to quantify. However, OHV use could affect
the soil resource by disrupting soil surfaces, biological soil crusts, and enlarging gaps between vegetation,
particularly if users travel cross-country (i.e., off-trail). Susceptibility to erosion and weed invasion or
expansion would increase in these areas.
Agriculture
The majority of agricultural croplands in this area occur under 5,000 feet elevation where soils are exposed
to erosional forces during plowing operations and until crops are established. During and after plowing
operations, soil structure is disturbed and topsoil is exposed to erosional forces (particularly wind) until
crops are established.

Past, present, and foreseeable future actions within the CIAA are having and would continue to have
moderate impacts to the soil resource through disturbance of soil structure, biological crusts, and
subsequent exposure of the upper soil horizons to erosional forces resulting in soil loss and decreased
productivity. Soil compaction has occurred and would continue to occur in areas of heavy and frequent use
by vehicles, heavy equipment, and livestock. Soil impacts from livestock grazing would be the largest
impact and would largely be dispersed, although concentrated impacts occur especially near gates, water
troughs, mineral supplementation sites, and where trailing occurs.
Cumulative effects to soils due to other activities would be mostly localized. Recreation impacts are largely
from dispersed activities and with the phased in implementation of the project, no cumulative impacts
would be expected. Soil erosion and displacement due primarily to wind during and for several weeks
following the plowing of agricultural fields would continue to occur.
During years of high wildland fire activity, the extent of exposed soil would increase dramatically. Without
functioning fuel breaks in place beyond the existing Bruneau fuel breaks, large and/or frequent wildland
fires would continue to occur given the extent of annual grass dominated vegetation within the project area,
as well as high ignition potential. Large acreages would continue to experience exposed topsoil and
increased potential for soil loss for a year or more following each fire until vegetation reestablishes.
However, revegetation and erosion control treatments completed as part of the current ESR plans and other
future ESR plans would benefit soil in the long term by promoting perennial vegetation establishment and
controlling surface water flow.
3.2.3.4 Alternatives 2-4 – Cumulative Impacts

Past, present, and foreseeable future actions within the CIAA would continue to have moderate impacts to
the soil resource through disturbance of soil structure, biological crusts, and subsequent exposure of the
upper soil horizons to erosional forces resulting in soil loss and decreased productivity, as described in
section 3.2.3.3. Because these impacts are widespread and ongoing, any of the action alternatives would
only slightly increase adverse cumulative impacts to the soil resource when considered with other past,
present, and foreseeable future actions. In the long run, any action alternative would be a net benefit to the
soil resource by reducing wildland fire size and reducing the potential for soil erosion from large burned
areas. Smaller and less intense fires would limit vegetation and biological crust damage, helping protect
soils from exposure to climate extremes and wind and water erosion.

3.3 General Vegetation including Noxious and Invasive Weeds
The affected environment for vegetation is the maximum footprint of the fuel break system (i.e.,
Alternative 2) with a 200-foot buffer (i.e., outer buffer) beyond the 200-foot fuel treatment zone (Map 15,
Appendix Q) and the footprint of the mineral material sites. This area was selected for analysis because it
captures the extent of direct and indirect effects of the fuel break network and mineral material sites and all
other action alternatives are subsets of this area. For the fuel break network, direct effects would be limited
to the treated areas within the fuel break (i.e., roads proposed for vegetation removal and 200-foot fuel
treatment zone). Indirect effects of the fuel break network (i.e., increased susceptibility to noxious and
invasive species) would be negligible past the outer buffer. Direct and indirect effects to vegetation in
mineral material sites would be limited to each respective site’s footprint. The fuel break treatments and
buffer comprise roughly 147,000 acres. The four 20-acre mineral material sites comprise 80 acres. The
affected environment encompasses roughly 70,000 acres in Idaho and 77,080 acres in Oregon.
Vegetation
The 2014 LANDFIRE dataset was used for vegetation analysis because it covers both Idaho and Oregon
providing consistency, and is the most current dataset for the region. This data set includes vegetation, fire,
fuel, and topography data that describe existing vegetation composition and structure based on
georeferenced field plot data, satellite imagery, and simulation models (Zahn 2015). The Group and
Vegetation Type level classifications were selected for discussion and are presented in Table J-1.
Shrubland
The majority (67% of affected environment) of vegetation community types are in the shrubland group.
Shrublands are dominated by shrub communities: primarily big sagebrush (a mosaic of basin, xeric, and
Wyoming big sagebrush; silver sagebrush and/or bitterbrush may also occur) with bluebunch wheatgrass,
Wyoming big sagebrush communities, and low sagebrush communities (Table J-1). Other shrublands
include bluegrass scabland (Sandberg bluegrass communities with sagebrush), mountain big sagebrush, salt
desert shrub, and saltbush with greasewood.
Exotic Herbaceous
Exotic herbaceous vegetation (i.e., introduced upland herbaceous vegetation) is also common (23% of
affected environment), particularly in Oregon which contains 80% of the acres in this category. Introduced
upland herbaceous species include non-native perennial plants (e.g., crested wheatgrass) and non-native
invasive annual plants (e.g., cheatgrass). Approximately 97% of introduced upland herbaceous vegetation
is made up of invasive annual grasslands, namely cheatgrass, and often includes non-native invasive annual
forbs such as Halogeton 11 and Russian thistle; 3% is comprised of introduced perennial herbaceous species
(e.g., crested wheatgrass seedings).
Developed, Riparian, Grassland, and Various

The remaining 10% of the affected environment is developed (6%), riparian (mainly cottonwood with
willow) (2%), grassland (mainly rough fescue with bluebunch wheatgrass), and various other groups (2%)
including conifer (mainly western juniper woodlands), sparsely vegetated, water, and barren (Table J-1).
The vast majority (85%) of the developed category includes three classifications: roads, low intensity
development, and upland herbaceous development. These classifications include several classes of roads
ranging from paved highways to two-track native surface roads with vegetation in the center, and
11
Halogeton is considered a noxious species by Oregon Department of Agriculture; see noxious species section below and
Table J-2.

constructed sites such as campgrounds, day use areas, and boat launches with vegetation planted for
recreation, erosion control, or aesthetic purposes.
Riparian vegetation ranges from woody species such as cottonwoods (e.g., black cottonwood) and willows
(e.g., Pacific willow) to herbaceous species including rushes (e.g., Baltic rush), sedges (e.g., Bolander’s
sedge), and forbs (e.g., monkeyflower). Types of species depend on the amount and timing of water
availability (i.e., perennial vs. intermittent vs. ephemeral), type of riparian area (e.g., stream vs. meadow)
and disturbance regime. This group is included in the affected environment; however, no treatments would
occur in riparian areas (per avoidance buffers detailed in Appendix G).
The majority of the grassland group (rough fescue and bluebunch wheatgrass associations which include
Idaho fescue and tall forbs) may have been primarily sagebrush steppe with patches of grassland in the
past, but due to post-settlement land use history, they have been converted to grassland‐dominated areas.
These areas are dominated by large perennial bunchgrasses with forbs, sometimes with a sparse shrub layer
(<10% cover). Treatments, mainly mowing, would occur where shrubs are present (>1% cover) in this
vegetation type. The tall forb community type is dominated by mesic perennial forbs (e.g., nettleleaf giant
hyssop, columbine, larkspur, cinquefoil, and coneflower) with a small percentage (usually <10%) of
perennial grasses (e.g., mountain brome), and shrubs are rarely present.
The various groups (conifer, hardwood, water, barren, sparsely vegetated, agriculture) are made of minor
communities that would not be treated (e.g., aspen, juniper woodland, curl-leaf mountain mahogany), could
not be treated (e.g., open water, agriculture), or do not require treatment (e.g., barren, sparsely vegetated).
The vegetation at the proposed mineral material sites is primarily introduced upland vegetation, bluegrass
scabland, and sparsely vegetated areas. Introduced upland vegetation and bluegrass scabland are common
vegetation communities in the affected environment. The sparsely vegetated areas in proposed site
locations are livestock congregation sites.
Noxious Species
A noxious weed is any plant designated by federal, state, or county government as injurious to public
health, agriculture, recreation, wildlife, or property (Sheley and Petroff 1999). The Idaho State Department
of Agriculture (ISDA) designates species as noxious, administers State Noxious Weed Law, and maintains
the list of Idaho noxious species (ISDA 2018); the Oregon Department of Agriculture (ODA) Noxious
Weed Control Program and the Oregon State Weed Board carry out these duties in Oregon (ODA 2018).
Noxious weeds spread by dispersal of seeds or plant parts in a variety of ways: wind, water, animals,
machinery, and people transport seed and plant parts from one location to another. These species produce
abundant seeds, and many have hooks, barbs, or sticky resins that facilitate their dispersal. Highways,
roads, trails, transmission and power lines, and river corridors serve as routes of initial establishment and
weeds may advance from these corridors into new areas (ISDA 2005). Noxious weeds are capable of
invading and dominating disturbed areas (roadsides, areas burned by wildfire, etc.) over a wide range of
precipitation regimes and habitats (Sheley and Petroff 1999). Noxious weeds pose major threats to
biological diversity, second only to direct habitat loss and fragmentation. They can alter ecosystem
functions such as nutrient cycles, hydrology, and wildfire frequency, and can outcompete and exclude
native plants and animals.
The Boise and Vale Districts’ weed control programs survey for and treat weed infestations using chemical,
mechanical, and biological control techniques, or a combination of these (integrated weed management).
The BLM also collaborates with Cooperative Weed Management Areas (CWMAs) that include federal,

state, county, and private entities to combat noxious weeds across ownership boundaries. The Eastern
Owyhee, Jordan Valley, and Northwest Owyhee CWMAs fall within the project area.
District noxious weed specialists identified 12 primary noxious species listed by ODA and ISDA at risk of
encounter and/or spread during project implementation (Table J-2). These species vary in density and
distribution in the project area. Most of the recorded weed occurrences are located along or near roads (i.e.,
disturbed areas along major roads and two-track roads) and/or are largely associated with mesic (moist) or
seasonably wet sites, though many may expand into and occupy drier sites. The majority of mapped sites
have been chemically treated one or more times in the last 10 years.
Cheatgrass, medusahead, and Ventenata are listed as noxious by Malheur County, OR. Medusahead is also
on the ODA noxious weed list. Because of their wide distribution, all three are species of concern, but are
considered and treated as invasive annual grasses (rather than noxious weeds) by the Vale District (Table J-
3). None of these species are listed as noxious in Idaho, but all are considered invasive species, and all are
species of concern for the Boise and Vale Districts. For the purpose of this DEIS, these invasive annual
grasses are discussed and analyzed as invasive species below.
Invasive Species
Invasive species are introduced (exotic/non-native) plants that tend to thrive and spread aggressively
outside their native ranges (USDA 2018), but are generally not listed as noxious by ISDA or ODA.
Invasive species generally have larger, more widespread infestations than noxious species and mostly have
not been treated. Cheatgrass is the most ubiquitous invasive annual species in the affected environment.
Approximately 20% of the affected environment is invasive annual grassland dominated by cheatgrass
(Table J-1 and Table J-3); see vegetation descriptions above for more detail. Cheatgrass and other invasive
annual species (e.g., medusahead and Russian thistle) are also present to varying degrees in other
vegetation communities, as well.
Resilience and Resistance (R&R) Considerations

Plant communities with moderate to high R&R values are less vulnerable to spread of invasive annual
grasses species than those with low R&R (Chambers et al. 2014). Greater effective precipitation at higher
elevations (or in more northern or north-facing sites) often results in greater perennial plant cover that is
better at resisting weed invasion (Miller et al. 2014). At lower elevations with lower precipitation, plant
communities tend to be less resistant and resilient to disturbance and have higher frequencies of noxious
and invasive plants (Miller et al. 2014). Plant communities with low R&R are at high risk of noxious and
invasive plant expansion (Chambers et al. 2014).
Elevations in the affected environment range from 3,000 feet to 6,500 feet. Over half of the plant
communities in the affected environment are categorized as low R&R (Table 3.3-1). Nearly one quarter
(24%) of plant communities are high R&R, and 18% are moderate R&R.
Table 3.3-1. R&R acres in the affected environment.

R&R category* Max Fuel Break 200’ Outer Buffer Mineral Site Footprint
acres† acres acres
High 17,443 (24%) 16,932 -
Moderate 13,225 (18%) 13,275 -
Low 42,990 (58%) 42,387 80
Wetland/Riparian/Unmapped 202 (<1%) 169 -

*Wetland/Riparian areas are not assigned a resistance/resilience value; however, riparian areas and wetlands tend to be
resilient (recover quickly) due moisture availability. Unmapped acres are included here and range from 3 to 5 acres.
†Percentages were rounded to the nearest percent.
The Shrubland and Exotic Herbaceous vegetation groups combined make up 90% of the affected
environment (Table J-1), and are the groups with the most acres recommended for treatment (i.e., most
likely to be directly affected) (see section 3.3.2 below). As the most prevalent groups, R&R values for the
vegetation communities in the Shrubland group and the Exotic Herbaceous group are presented in Table
3.3-2.
Table 3.3-2. R&R for the major vegetation groups in the fuel break and buffer.
Vegetation Group Vegetation Community High R&R Moderate Low R&R Total acres*
acres R&R acres acres
Big Sagebrush-Bluebunch
Wheatgrass 5,077 4,887 10,020 20,019
Wyoming Big Sagebrush 3,275 2,668 11,420 17,378
Low Sagebrush 4,398 1,947 376 6,754
Shrublands
Bluegrass Scabland 665 1,600 2,312 4,591
Salt Desert Shrub 111 12 386 511
Mountain Big Sagebrush 404 56 9 477
Chokecherry-Serviceberry-Rose 45 31 1 78
Shrubland Total 13,977 11,201 24,524 49,807
Introduced Upland Vegetation -
Exotic Herbaceous Herbaceous 1,492 1,562 13,798 16,863
GRAND TOTAL 15,471 12,764 38,357 66,715
*Total acres include 124 acres of Riparian/Wetland/Unmapped not presented separately in the table.
3.3.2.1 Issues
• What is the potential for introduction and/or spread of invasive and noxious plants from fuel break
establishment and maintenance (i.e., disking, mowing, seeding, herbicide, targeted grazing,
prescribed fire, and clearing selected roads of vegetation) and mineral material sites? What are the
impacts?
• What are the impacts to vegetation communities from fuel break development (i.e., by removing or
manipulating vegetation in fuel breaks, including roads)?
o How would targeted grazing impact perennial and other vegetation?
• What are the impacts to vegetation communities from mineral material sites?
• How would potential use of the fuel break by wildlife and livestock (e.g., browsing, grazing not
associated with a targeted grazing treatment) impact perennial herbaceous vegetation?
3.3.2.2 Indicators
• Acres and proportion of each major vegetation group/community type in proposed fuel breaks and
type of recommended treatment; acres of no treatment in each major vegetation group
• Acres of fuel break treatments in low, medium, and high R&R
• Distribution/abundance of noxious and invasive species
3.3.2.3 Assumptions
• Targeted grazing could be applied anywhere in the recommended treatment areas (67,559 acres in
Alternative 2; 45,872 acres in Alternative 3; or 38,044 acres in Alternative 4) where conditions and

criteria warrant this method (see section 2.2.1 Methods). Therefore, for the purpose of analysis, the
entire treatment area is considered.
• Targeted grazing in native perennial dominated sites would not exceed moderate utilization levels
(i.e., 41-60% biomass removed 12) and is considered synonymous with the 6-12 inch stubble height
objective.
• “Invasive plants” refers mainly to cheatgrass, a widespread invasive annual grass.

Fuel breaks would not be constructed and mineral material sites would not be established; therefore,
vegetation within the recommended treatment areas proposed under the action alternatives would not be
disturbed or altered. No additional weed seeds would be transported and no ground disturbance would
occur damaging or removing vegetation and creating openings for noxious and invasive species to colonize.
The existing noxious weeds would continue to propagate and expand through natural (wind, water, and
animals) and other means (wildfire, recreationists, etc.), particularly in less resilient and disturbed plant
communities, and areas burned by wildfire would continue to be at high risk for expansion of noxious and
invasive species (USDA FS 2008). However, the Boise District and Vale District weed programs would
continue ongoing surveys for and treatments of noxious weeds, helping to control their proliferation.
Without a strategic network of fuel breaks to facilitate fire containment and reduce the amount of acres
burned annually, large and/or frequent wildfires are expected to occur across the project area based on
wildfire trends over the past 30 years. Leaving sagebrush-steppe vegetation communities unprotected by
fuel breaks could have major consequences: vegetation type conversion to annual-dominated systems;
abbreviated fire return intervals; and an eventual loss of native plant diversity. Indirect effects of an
increase in wildfires include leaving open niches for establishment of noxious and invasive species.
These impacts would be greatest in areas of low R&R (42,990 acres, 58% of the maximum fuel break area)
which include 24,559 acres of shrubland vegetation (mainly Wyoming big sagebrush) and 13,798 acres of
exotic herbaceous vegetation (mainly cheatgrass) (Table J-3 and Table 3.3-1). Impacts would be less
prevalent in areas of moderate R&R (13,225 acres, 8% of the maximum proposed treatment footprint)
which include 11,202 acres of shrubland vegetation (mainly Wyoming big sagebrush and some low
sagebrush). Vegetation in areas of high R&R (17,443 acres, 24% of the maximum proposed treatment
footprint) which includes 13,979 of shrubland communities (mainly Wyoming big sagebrush and low
sagebrush) would be the most likely to withstand these impacts and recover.

The impacts to vegetation from each treatment method described in this section would be common to all
action alternatives. The extent of these impacts would vary based upon the number of acres treated to create
fuel breaks in each alternative. However, the nature of the impacts, both adverse and beneficial, would be
the same. The extent of these impacts is presented by alternative in the three subsequent sections.
Vegetation within the fuel breaks would be directly affected; indirect effects would also occur in the fuel
break and could extend into the 200-foot outer buffer. By design, existing vegetation within the fuel
treatment zone would be replaced (e.g., by seeding with desirable fuel break species) or modified (e.g., by
mowing shrubs) in the areas recommended for treatment (up to 67,559 acres). In addition, existing
vegetation within the roadbed would be removed across up to 950 miles of roads.
12
Utilization as it relates to ingestion or removal of biomass of herbaceous plants (USDI 1996).

Seeded species would replace remnant native species and non-native invasive annual species to ensure fuel
breaks consist of low statured, competitive, fire resilient perennial species. Existing native vegetation
would not survive treatments in locations involving high levels of soil disturbance (e.g., disking), and
would be degraded in locations involving periodic, repeated treatment (e.g., targeted grazing). The primary
adverse impact is that disturbance created by treatments could expedite the spread of non-native invasive
annual grasses in and adjacent to the fuel break, particularly where these species are present/common.
However, periodic herbicide treatments and other fuel break maintenance to control invasive and noxious
species (see Appendix H) would mediate this risk. Overall, the BLM anticipates that the benefit of
protecting existing plant communities from large and more frequent wildfires over the long term is greater
than the impact of modifying or replacing vegetation within the treatment footprint.
Targeted Grazing
Utilizing livestock to create and maintain fuel breaks would damage and/or remove vegetation from the
treatment footprint. The magnitude of effects would depend on timing, area, intensity, frequency, and
duration of grazing, plant species’ tolerance to grazing, and pre-treatment condition (Hendrickson and
Olson 2006). Cattle prefer grasses, but eat most vegetation if confined for an extended period of time,
and/or with high animal numbers (Burritt and Frost 2006).
Vegetation would be directly impacted (e.g., trampled, damaged, broken, and/or removed by herbivory in
the short and long term) by grazing cattle, water hauls, and around water tanks and sites with nutritional
supplements. Indirect impacts include risk of invasive annual grasses spreading into adjacent intact plant
communities by increasing gaps between perennial plants (Reisner et al. 2013). In instances where
temporary electric avoidance fencing is used (i.e., to protect sensitive resources or new seedings), impacts
to vegetation from the fence would be negligible. These impacts would increase in intensity and duration if
targeted grazing occurs every year or multiple times in a given year. Proper management of targeted
grazing activities, design features (Appendix G), and monitoring (Appendix H) would minimize
disturbance and potential for weed and invasive species spread. Targeted grazing can be an effective tool at
reducing flame lengths and rate of spread, particularly in low shrub cover (e.g., a mowed site or a grass
dominated site) (Schachtschneider 2016). Long-term, targeted grazing that meets fuel break objectives
would reduce the potential for larger wildfire and provide firefighters with increased capability to protect
adjacent plant communities (e.g., sagebrush habitat).
Trampling
Trampling of perennial herbaceous plants would reduce their productivity and could result in direct
mortality or seedbank mortality over the long term, particularly if a given area is grazed annually or
repeatedly more than once in a year to meet fuel break objectives. Livestock could also produce indirect
short-term benefits to vegetation by dispersing native seeds and creating microhabitats for native species
through localized soil disturbance (Burkhardt 1996); however, this benefit would likely be negligible.
Conversely, non-native, invasive seeds could also be dispersed in this manner. Trampling of shrubs could
deform mature individuals and kill immature shrubs (Owens and Norton 1990). Trampling of invasive
annual plants during the growing season could result in mortality and/or seedbank reductions. Therefore,
trampling of shrubs and grasses could help meet fuel break objectives in the short term. However, repeated
damage to perennial plants would reduce the plant communities’ overall productivity and competitiveness
and could create niches for noxious and invasive plants to occupy.
Ingestion
In general, livestock graze preferentially on perennial grasses. Targeted grazing in annual grass dominated
sites could impact Sandberg bluegrass and bottlebrush squirreltail, where present, because those perennial
species germinate and grow in the spring when cheatgrass is green and actively growing (Murray 1971).

Palatability and rapid growth of cheatgrass is typically earlier than the rapid growth phase for larger
perennial grasses (e.g., bluebunch wheatgrass). If cheatgrass is available, cattle would eat more cheatgrass
in the early spring, giving these larger perennials a better chance to maintain or establish themselves.
Annual targeted grazing prior to cheatgrass seed dispersal could reduce the density and cover of this
invasive annual grass over the long term (Finnerty and Klingman 1962).
Perennial grasses are most susceptible to grazing impacts during their critical growth periods (i.e., from
seed stalk emergence to seed dissemination). Utilization during periods when plants are withdrawing
reserves from roots for growth, during re-growth, or during seed formation would impact perennial grasses
more than the same level of utilization when the plant is not actively growing (generally late summer
through early spring). Generally, perennial grass vigor can be sustained with repeated light utilization
(<40% removal of biomass), while repeated moderate to heavy utilization (41-60% and >61% removal of
biomass, respectively) reduces photosynthetic tissue and can diminish vigor.
Targeted grazing in perennial grass dominated communities may be implemented where grasses exceed 24
inches to reduce grass height to 6 to 12 inches (i.e., moderate utilization levels). Moderate utilization could
weaken these grasses if targeted grazing occurs annually or multiple times in a year during critical growth
periods. Weakened perennial components of a plant community may, in turn, open niches for noxious and
invasive plants to exploit.
Therefore, where invasive annual grass is the target for fuels reduction, impacts to perennial grasses that
are phenologically similar to cheatgrass could be moderate to major, and impacts to larger perennial grasses
would be negligible to minor. Where perennial grasses are the target for fuels reduction, impacts to these
grasses would likely be moderate, particularly since this treatment would not exceed moderate levels (41-
60%) of biomass removal. The threat of invasive species spreading within the fuel break (and/or into the
outer buffer) would be lowest in areas of high R&R or areas with low or no cheatgrass nearby, and highest
in areas of low R&R or near cheatgrass dominated sites. However, design features, monitoring, and follow
up treatments and maintenance (i.e., herbicide application and/or seeding) would mitigate the risk. While
perennial grasses in the fuel break could be impacted, a functional fuel break would facilitate long-term
protection of perennial plant communities across the project area.
Temporary Fence
Impacts to vegetation from temporary (take down) electric fencing are considered for the vegetation
immediately outside of the fence; impacts inside of the fence are as described above (i.e., via trampling and
ingestion). Short-term impacts such as trampling by ATV or other machinery used during installation
would damage, or eliminate, vegetation. Over the long term, native perennial vegetation would recover.
Grasses and re-sprouting shrubs (e.g., rabbitbrush or bitterbrush) would recover more quickly than shrubs
that do not re-sprout (e.g., Wyoming big sagebrush). Non-native invasive annual species could spread
where native vegetation has been disturbed or eliminated. Because targeted grazing and regularly permitted
grazing would not coincide, supplemental fencing (i.e., temporary electric fence) would not be in place
during regularly permitted grazing, so there would be no additional fence line impacts (e.g., cattle trailing
along fence trampling or removing vegetation).
Mowing
Shrubs mowed to 6-10 inches would initially resemble a low sagebrush site. Removal of the shrub canopy
often results in a short-term increase in seedlings following treatment. Repeated mowing would result in a
decrease in shrub vigor over the long term and these plants may eventually die off. Opening the shrub
canopy through mowing can result in a release of herbaceous plants in the short term, especially cheatgrass
(Davies et al. 2011 and Pyke et al. 2014). Other potential impacts related to mowing include breakage or

removal of herbaceous plants and soil disturbance creating openings for noxious and invasive plants to
occupy.
Shrublands comprise the largest proportion of the affected environment. The shrub communities in this
group would respond differently to treatments (mowing, in particular). Mountain big sagebrush tends to re-
grow more readily after breakage or cutting than Wyoming big sagebrush. Therefore, mowing of mountain
big sagebrush would have to occur more frequently to maintain the fuel break than for Wyoming big
sagebrush. Consequently, impacts associated with mowing may be more pronounced; however, these
impacts would be tempered because most of the mountain big sagebrush communities are high R&R, and
mountain big sagebrush makes up only a small portion of the affected environment (Table J-1).
Where non-native invasive annual plants are present in the fuel break, there is the potential for these plants
to spread into adjacent vegetation communities where the ground is disturbed by mowing equipment,
particularly areas of low R&R or some existing level of disturbance. Herbicide application and seeding
would be required in some areas to control noxious and invasive species and reduce the potential for spread
into adjacent sites. Mowing would also help minimize the potential for larger wildfires and facilitate the
protection of native plant communities by reducing flame lengths, giving fire suppression resources an edge
in catching wildfire.
Hand Cutting
The direct effect of hand cutting shrubs using chainsaws or loppers to create fuel breaks would be the
reduction in density and canopy cover of shrubs within the treatment footprint. As with mowing, effects
would include a release of herbaceous plants in the short term and the potential for these plants to spread
into adjacent vegetation communities. Hand cutting would also reduce the potential for larger and/or more
frequent wildland fires similar to mowing. Because these treatments would be executed on foot, secondary
impacts described for mowing (e.g., breaking or removing vegetation and disturbing soils) would be
negligible.

Seedbed preparation such as disking and/or chemical treatments may be used to reduce competition prior to
planting. Potential impacts from disking and chemical treatments are described below. Depending on the
type of equipment used to establish fuel break vegetation, soil disturbance would create conditions
conducive to weed establishment and spread, particularly in the first two years or until seeded species
become established. Design features such as equipment cleaning, pre-, and post-implementation herbicide
treatments of noxious weed infestations, and invasive annual grass and forb control would reduce this
potential. Reducing noxious weed infestations would limit indirect impacts to vegetation communities
adjacent to the fuel breaks, as well as improving potential future firefighting efforts.
Temporary protective fencing may be necessary where regularly permitted livestock grazing would impact
seedling establishment in fuel breaks. Direct impacts to vegetation from temporary fencing (installation and
removal) include breakage, trampling, and/or removal, but these impacts would be short-term and
vegetation should recover once the fence is removed. Again, all design features (Appendix G) would apply
to temporary fencing to minimize impacts.
Following fuel break treatments, particularly after mowing or seeding, perennial herbaceous cover may
increase and grazing livestock and foraging wildlife may be drawn to such fuel break segments, increasing
use of these sites. However, any increased use of the fuel breaks by livestock and wildlife would be
incidental and dispersed depending upon comparative vegetation quality and height within and outside the
fuel break. At a localized level, increased use by grazing livestock could remove, damage, or diminish

vigor of seeded grasses in the manner described above under Targeted Grazing (i.e., ingestion and
trampling effects), but to a lesser extent because the grazing would not be as concentrated. Monitoring and
maintenance of fuel breaks and design features to protect seedings would mitigate possible grazing impacts
(Appendix H and Appendix G, respectively). Any impacts to vegetation from use of the fuel breaks by
wildlife could be similar (e.g., ingestion, breakage) in comparison to grazing livestock. Effects of both
wildlife use and regularly permitted grazing to vegetated fuel breaks are anticipated to be negligible in
comparison to targeted grazing, because adverse impacts to perennial herbaceous vegetation within the fuel
break from grazing livestock and foraging wildlife would be limited and highly localized based upon the
comparative vegetation quality outside the fuel break.
Seeding (other than prostrate kochia)

Perennial plants proposed for seeding fuel breaks are presented in Appendix J. Seeding perennial species
would change plant community composition and structure within the treatment footprint by replacing
annual grasses and forbs, or native perennial grasses, forbs, and shrubs with perennial species that meet fuel
break criteria. Species identified for this project have shown to be effective, or have potential to be
effective, at competing with invasive annual species (Appendix J). The non-native perennial grasses,
crested wheatgrass and Siberian wheatgrass, propagate by seed dissemination and rhizomes (continuously
growing underground stems); however, the potential for non-native seeded species to spread beyond the
fuel break is low (USDA NRCS 2002). Design features to identify and treat introduced plants that spread
beyond the treatment footprint are described in Appendix G.
Prostrate Kochia Seeding

The direct effect of seeding prostrate kochia would be the replacement of current vegetation creating
monotypic or near monotypic prostrate kochia stands in the treatment footprint. The primary benefit of
seeding prostrate kochia would be its vegetative characteristics (e.g., low stature, green into fire season,
etc.; see Appendix J) and its ability to outcompete with invasive annual grasses (Tilley et al. 2012). The
primary adverse indirect effect of this treatment would be the potential for prostrate kochia to spread
outside of the treatment footprint.
The Paradigm Fuel Break Project EA (DOI-BLM-ID-2011-0060-EA; USDI BLM 2015b), hereby
incorporated by reference, provides an in-depth discussion of the pertinent literature regarding the spread
potential for prostrate kochia. While prostrate kochia may spread into existing sagebrush and perennial
bunchgrass stands with open and available niches, spread has been most strongly correlated with higher
levels of soil disturbance in the surrounding area, lack of competition from other vegetation, and open
spaces or bare soils surrounding established prostrate kochia plants (McArthur et al. 1990, Clements et al.
1997, Harrison et al. 2000, Harrison et al. 2002, Sullivan et al. 2013, Gray and Muir 2013).
Gray and Muir (2013) reported that prostrate kochia’s capacity to spread was greater than previously
supposed. However, there has been some dispute over their findings due to limitations in sampling methods
and seeding boundary delineation. Ott et al. (2017) attempted to resolve these limitations by refining the
study design and adding a temporal component to better quantify dispersal rates of prostrate kochia. Ott et
al. (2017) found that the average and maximum distances recorded for dispersal rates of kochia were lower
than the Gray and Muir (2013) findings. For example, for kochia that was seeded between 1986 and 2007,
the average distance to the recruitment margin for kochia was 10 meters (vs. 30 meters) and the average
distance to the farthest plant was 88 meters (vs. 208 meters); the maximum distance to the farthest plant
was 461 meters (vs. 710 meters).
Spread of prostrate kochia from the fuel break is possible where remnant stands of shrubs with little
herbaceous cover in the understory and interspaces occur, or where soils have been disturbed leaving open

niches for kochia to occupy. There is also a risk for kochia to spread into sites that are naturally open with
little vegetation, such as playas (i.e., Davis’ peppergrass habitat; see section 3.4 Sensitive Plants). Based
on Ott et al. (2017), the average recruitment margin for kochia in these areas could be 10 meters. Design
features limiting its use (i.e., avoidance buffers up to 0.5 mile around sensitive plant occurrences) and
monitoring and subsequent control measures in the event spread is detected would minimize impacts
(Appendix G and Appendix H, respectively).
Disking
The direct effects of disking for seedbed preparation would be the removal of existing vegetation, including
remnant shrubs, from the treatment footprint. This disturbance could temporarily (1-3 years) increase
invasive annual grasses and forbs and/or noxious weeds while seeded species become established,
increasing the need for herbicide treatments in the short term to control these species. Removed vegetation,
invasive species, and/or noxious weeds would be replaced by seeded species that meet fuel break criteria
within one to three years.
Herbicide Treatment
General effects to vegetation by individual herbicides are described in the Vegetation Treatments using
Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental
Impact Statement (USDI BLM 2007a), the Final PEIS for Vegetation Treatments Using Aminopyralid,
Fluroxypyr, and Rimsulfuron on BLM Lands in 17 Western States (USDI BLM 2016a), and the Treatments
Using Herbicides on BLM Lands in Oregon Final Environmental Impact Statement (2010a) and Record of
Decision (2010b).
Herbicides could be used to prepare the seedbed for a seeding, to maintain a fuel break by reducing the
amount of fuel available for wildfire, to maintain cleared roads free of vegetation, and to reduce the
prevalence of annual grasses in stands of perennial grass. As a fuel break maintenance treatment and for
annual grass reduction, target vegetation would include invasive annual grasses and forbs and noxious
weeds. To maintain cleared roads free of vegetation, any regrowth of vegetation in the roadbed would be
targeted.
The primary effect of herbicides to create and maintain fuel breaks is the control of undesirable annual
grasses and forbs. Subsequently, existing or seeded desirable fuel break (perennial herbaceous) species
would increase in density and vigor due to lowered competition levels. Herbicide treatments to eradicate
target vegetation and the extent of disturbance to non-target vegetation would vary by the type of chemical
pathway employed (foliar vs. soil), the timing of application (growing season vs. dormant season), as well
as plant community composition and soil types in the area (Cox and Anderson 2004, Sheley et al. 2005,
Nyamai et al. 2011).
Off-site movement (drift) is a risk associated with herbicide application and may reduce seed germination,
decreasing plant vigor, or stunt the growth of non-target vegetation. Harming or killing non-target
vegetation could occur over the long-term with repeated chemical treatments to control noxious and
invasive species in the fuel breaks. The risk would be minimized through strict adherence to label direction
and standard operating procedures (USDI BLM 2007a and 2016a; and Appendix K), and design features
developed for resource protection (Appendix G).
Prescribed Fire
Direct effects of prescribed fire would include the removal of accumulated dry biomass created by deposits
of wind-dispersed invasive species such as Russian thistle, as well as the dry biomass of any perennial or
annual plants on-site. Often only the seeds in the uppermost layer of the soil surface are destroyed by

prescribed fire (Diamond et al. 2012). The BLM expects that burning only 1) in spring when vegetation
surrounding the burn treatment area is green, or 2) in fall when fuel moistures are high outside the burn
treatment area should limit or prohibit the spread of prescribed fires beyond targeted areas.
No Treatment Recommended
Some sections within the fuel treatment zone of the fuel break network are not recommended for treatment
because they currently meet fuel break objectives or do not warrant treatment (e.g., water, riparian areas,
barren areas). Some of these areas may be treated in the future (e.g., shrublands or exotic herbaceous
vegetation) if monitoring indicates that they are no longer meeting fuel break objectives (due to other
disturbance such as fire, etc.). However, other areas (e.g., barren areas, water, riparian areas, mountain
mahogany) would not be treated for the life of the project. Overall, the BLM anticipates no or negligible
direct or indirect impacts to these acres of non-treatment, presented by alternative in Table 3.3-3 below.
Table 3.3-3. Acres of no treatment recommended in major vegetation groups by alternative.

No Treatment Acres
Vegetation Group Alt 2 Alt 3 Alt 4
Shrubland 957 615 350
Exotic Herbaceous 1,050 441 725
Other 4,339 4,190 626
TOTAL 6,346 5,246 1,701
Roadbed Vegetation Clearing

The direct effect of roadbed vegetation clearing is the removal of existing vegetation along the centerline of
the road. Where present, roadbed vegetation primarily consists of early seral species (herbaceous), though
some remnant shrubs may be present on roads with infrequent or low use. Blading or manually removing
vegetation may be required every five to seven years while herbicide treatments would occur annually
where needed.
Depending on the type of equipment used to blade roads free of vegetation, soil disturbance would create
conditions conducive to weed establishment and spread. Effects are anticipated to be moderate as design
features such as equipment cleaning, pre-, and post-implementation herbicide treatments of noxious weed
infestations, and invasive annual grass and forb control would reduce this potential. Reducing noxious
weed infestations would limit indirect impacts to vegetation communities adjacent to the fuel breaks.
Manual removal of vegetation with the use of hand tools may be necessary in areas where the use of heavy
equipment is infeasible, restricted by design features, or has the potential to widen the existing road.
Minimal soil disturbance would occur, reducing conditions that would promote weed establishment and
spread. Effects are anticipated to be minor to negligible as post-implementation herbicide treatments would
be used to control the spread of noxious weeds and invasive annual grasses and limit indirect impacts to
adjacent vegetation communities.
Mineral Material Sites

Vegetation impacts from development of new mineral material sites in the Oregon portion of the project
area would be limited to the footprint of each 20 acre site, or approximately 0.1% of the maximum
treatment area for the project. Direct effects of the four 20-acre new mineral material sites would be the
partial removal of vegetation from 80 acres. In the short and long term, each site would be subject to a
partial loss of vegetation until final reclamation occurs in 20 to 30 years. Interim site reclamation after
periods of use, however, would reestablish vegetation in the disturbed areas in the intervening years that
sites remain dormant, reducing these long-term impacts. Because the vegetation that would be removed

(i.e., introduced upland vegetation, bluegrass scabland) is common throughout the project area, interim and
final reclamation would reestablish vegetation at the sites, and each site would be treated periodically to
control for invasive plants, impacts to general vegetation from the proposed mineral material sites would be
negligible.
The fuel break network would be comprised of 73,920 acres. Approximately 6,360 of those acres either
currently meet fuel break objectives or do not warrant treatment (e.g., water, riparian areas, barren areas,
etc.) and would not be treated. To create fuel breaks, the Proposed Action is to modify up to 67,559 acres
of vegetation: namely shrublands (45,461 acres), exotic herbaceous grasslands (primarily invasive annuals)
(15,813 acres), and an array of other vegetation communities (3,064 acres) (Table 3.3-2). Therefore, direct
and indirect impacts would occur to these 67,559 acres in the fuel break (i.e., roadbed and surrounding 200-
foot-wide fuel treatment zones). Within the 200-foot outer buffer surrounding the project area, indirect
effects could occur to an additional 67,559 acres. Negligible direct and indirect effects to vegetation are
also anticipated from the partial removal of vegetation on 80 acres associated with proposed mineral
material sites in the Oregon portion of the project area, as outlined in section 3.3.2.5, General Effects of
Action Alternatives.
Vegetation
Mowing only (62% of treatment area) and mowing with seedings (28% of treatment area) are the
predominant treatments recommended for creating fuel breaks; approximately 1% of the treatment area is
recommended for seeding only. The remaining 9% of the fuel break will receive no treatment. The vast
majority of shrublands would be mowed and/or mowed and then seeded (Table 3.3-4); impacts to these
roughly 48,200 acres would be as described above (section 3.3.2.4 General Impacts of Action Alternatives).
Similarly, the majority of the approximately 15,000 acres of exotic herbaceous communities would be
mowed and/or mowed and seeded. Targeted grazing would impact shrubs, perennial grasses, and invasive
annual grasses where applied; a maximum of 67,559 acres could be impacted (e.g., decreasing plant vigor
and survivability from trampling and removal). Seeding would occur on approximately 19,592 acres.
There may be increased use by wildlife and livestock in these areas but it would be limited and highly
localized based upon the comparative vegetation quality outside the fuel break.
Table 3.3-4. Alt. 2: Acres of recommended primary treatment methods in major vegetation groups.
Vegetation Group Mow Only Mow/Seed Mow/Seed (non- Seed Only† Total Treatment
Acres (native) Acres native) Acres Acres Acres
Shrubland 35,971 1,546 10,688 68 48,273
Exotic Herbaceous 7,150 447 7,397 819 15,813
Other* 2,340 145 567 12 3,064
TOTAL 45,461 (62%) 2,138 (3%) 18,652 (25%) 899 (1%) 67,150
*Other refers to developed, grassland, and other groups besides shrublands, and exotic herbaceous where the model
detected conditions appropriate for treatment (see section 2.1.1 Fuel Break Treatments).
†Native seeding only and non-native only seeding have been combined because native seeding recommendation applies to
so few acres (8 acres).
Noxious and Invasive Species

The direct and indirect effects to vegetation would be as described above in General Impacts, particularly
the potential for noxious and invasive species to spread, would be greatest under this scenario
(approximately 73,920 acres of fuel breaks; 67,559 acres of treatments; up to 950 miles of roadbed
vegetation removal). Fuel break establishment could increase susceptibility for noxious and invasive
species establishment on the 67,559 acres recommended for treatments and roads treated to remove
vegetation. Over the long term, noxious and invasive species that establish within the fuel break have the

potential to spread into the 200-foot outer buffer in areas that have been disturbed or degraded (as a result
of impacts unrelated to project implementation), and/or where R&R is low, but this risk would be
minimized by project design features (Appendix G) and maintenance (Appendix H).
In general, the vegetation communities with high R&R (16,932 acres, 24% of the treatment area) would be
at low risk for expansion of noxious and invasive species. Approximately 13,275 acres (18% of the
treatment area) with moderate R&R would be at moderate risk for noxious and invasive species expansion,
and 42,387 acres (58% of the treatment area) with low R&R would be at high risk (Table 2-1). More
specifically, 49% of shrublands and 82% of exotic vegetation (i.e., the two prevalent vegetation groups) are
in low R&R. Design features detailed in Appendix G (e.g., avoidance, monitoring, inventory, cleaning
vehicles and machinery), ongoing weed treatments (via chemical, mechanical and biological means), and
fuel break maintenance (i.e., herbicide application) to control invasive annual grasses would substantially
limit the spread of noxious weeds and invasive species.
The disturbance created through the development of the mineral materials site would create an environment
conducive to the introduction and spread of invasive species. Because all proposed mineral sites would be
constructed in areas with low R&R, these sites are also at high risk for noxious and invasive species
expansion. However, periodic monitoring and treatment of invasive and noxious plants would reduce the
risk of introduction and spread of those species (Appendix H).
Conclusion
Implementation of this alternative would directly and indirectly impact the most vegetation (up to 67,559
acres as fuel breaks and 80 acres as mineral material sites) of the three action alternatives. However, based
on wildfire trends and predictions of more frequent and large wildfires in the area, this alternative would
also provide the most opportunities for fire suppression in the 3.6 million-acre project area. In turn, this fuel
break system would protect the most habitat from the effects of wildfire and prevent spread of invasive
annual species into burned areas that could further alter the fire cycle (i.e., shorten fire return intervals)
offsetting adverse impacts over the long term.
Impacts to vegetation would be similar to Alternative 2, but to a lesser extent because 21,687 fewer acres
would be treated as fuel breaks. The fuel break network would be comprised of 51,127 acres.
Approximately 5,256 of those acres currently meet fuel break objectives or do not warrant treatment (e.g.,
water, riparian areas, barren areas, etc.) and would not be treated. To create fuel breaks, this alternative
would modify 45,872 acres of vegetation: namely shrublands (33,900 acres), exotic herbaceous grasslands
(primarily invasive annuals) (9,260 acres), and an array of other vegetation communities (1,982 acres)
(Table 3.3-7). Therefore, direct and indirect impacts would occur to these 45,872 acres in the fuel break
(i.e., roadbed and surrounding 200-foot-wide fuel treatment zones); within the 200-foot outer buffer
surrounding the project area, indirect effects could occur to an additional 45,872 acres. Negligible direct
and indirect effects to vegetation are also anticipated from the partial removal of vegetation on 80 acres
associated with proposed mineral material sites in the Oregon portion of the project area, as outlined in
section 3.3.2.5, General Effects of Action Alternatives.
Vegetation
predominant treatments recommended for creating fuel breaks; less than 1% of the treatment area is
recommended for seeding only. Similar to Alternative 2, the majority of shrublands would be mowed
and/or mowed and then seeded (Table 3.3-5); impacts to these roughly 33,859 acres would be as described
above (Section 3.3.2.4 General Impacts of Action Alternatives). The vast majority of exotic herbaceous

communities would also be mowed and/or mowed and seeded, impacting these approximately 9,065 acres.
Targeted grazing could impact shrubs, perennial grasses, and invasive annual grasses where applied (up to
45,872 acres) in the manner described in General Impacts (Section 3.3.2.4). Seeding would occur on
approximately 14,679 acres, this is 4,913 acres less than Alternative 2. Similar to Alternative 2, there may
be increased use by wildlife and livestock in these areas but it would be limited and highly localized based
upon the comparative vegetation quality outside the fuel break.
Table 3.3-5. Alt. 3: Acres of recommended treatments in major vegetation groups.

Vegetation Group Mow Only Mow/Seed Mow/Seed (non- Seed Only† Total Treatment
Acres (native) Acres native) Acres Acres Acres
Shrubland 25,544 811 7,504 41 33,900
Other* 1,606 127 249 2 1,982
TOTAL 31,124 (69%) 1,140 (3%) 12,641 (28%) 238 (<1%) 45,144

The direct and indirect effects of fuel break treatments as described above in General Impacts, particularly
the potential for noxious and invasive species to spread, would be similar to Alternative 2, but roughly
21,700 fewer acres would be treated under this scenario. Approximately 45,872 acres recommended for
treatment and up to 585 miles of roads recommended for vegetation clearing would become more
susceptibile to the establishment of noxious and invasive species. Similar to Alternative 2, but to a smaller
degree, noxious and invasive species have the long-term risk of spreading into the 200-foot outer buffer in
areas that have been disturbed or degraded (as a result of impacts not related to project implementation)
and/or where R&R is low, but this risk would be minimized by project design features and maintenance
described in Appendix G and Appendix H.
In general, 12,423 acres (24% of the treatment area) would be at the low risk for expansion of noxious and
invasive species, 8,999 acres (18% of the treatment area) would be at moderate risk, and 29,541 acres (58%
of the treatment area) would be at high risk (Table 2-1). Avoidance, monitoring/inventory, cleaning
vehicles and machinery, ongoing weed treatments (via chemical, mechanical and biological means), and
Conclusion
Implementation of this alternative would directly and indirectly impact fewer acres than Alternative 2 and
slightly more acres than Alternative 4. However, this alternative would provide fewer opportunities for fire
suppression to protect habitat in the project area than Alternative 2, although slightly more opportunities
than Alternative 4.
Alternative 4 would result in the smallest fuel break system (43,833 acres) and smallest fuel break
treatment footprint (38,044 acres) of the action alternatives; approximately 29,515 fewer acres of
vegetation than Alternative 2 and 7,828 fewer acres than Alternative 3 would be treated. The magnitude of
direct and indirect impacts to vegetation described under General Impacts would also be lowest under this
scenario, but would be very similar to Alternative 3. Similar to the other action alternatives, shrubland and
exotic herbaceous groups (mainly invasive annual grasslands/cheatgrass) would be the primary targets for

treatment (25,744 acres and 9,967 acres, respectively), and array of other vegetation (1,742 acres).
Therefore, impacts would occur to these 38,044 acres in the fuel break (i.e., roadbed and surrounding 200-
foot-wide fuel treatment zones). Within the 200-foot outer buffer around the project area, an additional
38,044 acres could be indirectly impacted. Negligible direct and indirect effects to vegetation are also
anticipated from the partial removal of vegetation on 80 acres associated with proposed mineral material
sites in the Oregon portion of the project area, as outlined in section 3.3.2.5, General Effects of Action
Alternatives.
Vegetation
predominant treatments recommended for creating fuel breaks; 2% of the treatment area is recommended
for seeding only. Similar to Alternative 2, the vast majority of shrublands would be mowed and/or mowed
and then seeded (Table 3.3-6); impacts to these roughly 25,686 acres would be as described for mowing
and seeding in General Impacts (Section 3.3.2.4). The majority of exotic herbaceous communities would
also be mowed and/or mowed and seeded, impacting these approximately 9,244 acres. Targeted grazing
could impact shrubs, perennial grasses, and invasive annual grasses where applied (up to 38,044 acres) in
the manner described in General Impacts (Section 3.3.2.4). Seeding would occur on approximately 14,076
acres, this is 5,516 acres less than Alternative 2 and 603 acres less than Alternative 4. Similar to other
action alternatives, there may be increased use by wildlife and livestock in these areas but it would be
limited and highly localized based upon the comparative vegetation quality outside the fuel break.
Table 3.3-6. Alt. 4: Acres of recommended treatments in major vegetation groups.

Vegetation Group Mow Only Mow/Seed Mow/Seed (non- Seed Only Total Treatment
Acres (native) Acres native) Acres Acres† Acres
Shrubland 17,991 456 7,239 58 25,744
Other* 1,319 91 320 12 1,742
TOTAL 23,673 (63%) 580 (2%) 12,407 (33%) 793 (2%) 37,453

The potential for noxious weeds and invasive plants to spread would be the lowest of all action alternatives.
Approximately 38,044 acres recommended for treatment and up to 399 miles of roads recommended for
vegetation removal would have increased susceptibility for noxious and invasive species becoming
established. Similar to the other action alternatives but to a lesser degree, noxious and invasive species have
the potential to spread into the 200-foot outer buffer in disturbed or degraded areas and/or where R&R is
low, but this risk would be minimized by project design features and maintenance.
In general, 8,562 acres (24% of the treatment area) would be at low risk for expansion of noxious and
invasive species, 5,557 acres (18% of the treatment area) would be at moderate risk, and 29,524 acres (58%
of the treatment area) would be at high risk (Table 2-1). Avoidance, monitoring/inventory, cleaning
vehicles and machinery, ongoing weed treatments (via chemical, mechanical and biological means), and

Conclusion
Implementation of this alternative would directly and indirectly impact the fewest acres of vegetation of the
action alternatives. This alternative would provide fewer safe opportunities for fire suppression to protect
habitat in the project area than Alternative 2 and 3 but would be similar to Alternative 3.

The cumulative impact analysis area (CIAA) for vegetation, including noxious and invasive species, is the
3.6 million-acre project area (Map 1, Appendix Q; Table J-4). This area was selected because it captures
the total area in which fuel breaks would facilitate opportunities to protect vegetation. The CIAA contains
similar plant community components, conditions are similar, and land uses are comparable. Direct effects
to vegetation from the proposed project are mostly localized in nature and cumulative effects to vegetation
due to other activities would also be localized. As fuel breaks facilitate suppression activities to better
protect vegetation from wildfire and the ground disturbance associated with constructing firelines, indirect
beneficial effects to vegetation from the proposed project are expected to be generalized across the project
area. The effects are expected to occur over the life of the project.
Shrubland is by far the largest vegetation group (over 2.6 million acres); the vast majority of this group is
composed of Wyoming big sagebrush (over 1 million acres) and big sagebrush with bluebunch wheatgrass
(just under 1 million acres) communities. Low sagebrush and bluegrass scabland communities are the next
most abundant (370,000 and 170,000, respectively), followed distantly by salt desert shrub, mountain big
sagebrush, saltbush greasewood communities, and chokecherry with serviceberry and wild rose. Exotic
herbaceous vegetation, of which 98% is introduced/invasive annual grassland, is also common in the
project area, comprising over 700,000 acres. Conifer (90% is western juniper with big sagebrush and
bluebunch wheatgrass), riparian, grassland, and other minor groups make up the remaining acres.
Noxious weeds and invasive annual grasses are widely scattered throughout the project area to varying
degrees and densities (limited to common) with expansion risk ranging from low to high depending on
species (Table J-5). District noxious weed specialists identified Canada thistle, leafy spurge, and poison
hemlock as priorities for cumulative effects analysis in addition to the primary species for the affected
environment. Canada thistle, leafy spurge, and poison hemlock are common in/near riparian areas and
wetlands. Therefore, these species are not present in areas where fuel breaks are proposed for this project,
but where other actions may cause impacts (e.g., livestock grazing).

The collective effect of past actions (i.e., anthropogenic activities) have contributed to the current
assemblages and condition of vegetation communities and to the frequency and distribution of noxious and
invasive species. Ongoing and future actions that could cumulatively affect vegetation include the
following: fuel break projects (Soda Fire Fuel Breaks and Bruneau Fuel Breaks); road maintenance; realty
actions (ROW); vegetation treatments including ESR treatments (Jackie’s Butte Fire and Bowden Fire
vegetation rehabilitation – seedings, seedling plantings, weed treatments), general noxious weed treatments,
and juniper removal (BOSH juniper removal project); livestock grazing; and prescribed burning of
tumbleweed accumulations (see Appendix N).
Fuel Breaks
The Soda Fire Fuel Breaks Project (Soda Project) will not directly affect vegetation in the CIAA because it
borders the Tri-state project area with no overlap. However, it could produce indirect effects by vectoring

noxious or invasive species where the Soda project abuts the CIAA. These impacts would be negligible
with the application of project design features and maintenance. Under the Proposed Action, the Bruneau
Fuel Breaks Project will have no impact on the CIAA because the Tri-state project would expand existing
fuel break widths; impacts would be as described above in environmental consequences where these
projects overlap. Effects of the Bruneau fuel breaks would be as described for mowing and seeding
treatments in section 3.3.2.5 General Effects. The Programmatic EIS (PEIS) For Fuel Breaks in the Great
Basin will not directly result in the construction of new fuel breaks, however its analysis will streamline the
NEPA process for future fuel break projects in Idaho, Oregon, Nevada, northern California, Utah, and
eastern Washington.
Road Maintenance and ROW

Road or ROW (access roads, powerlines, and pipelines) construction and subsequent ongoing maintenance
(e.g., blading, grading, and/or spraying) along these features will continue to affect upland vegetation
within and adjacent to maintained buffers. Blading and grading of roads in rights-of-way disturb soils and
vegetation and often create conditions conducive to noxious and invasive species establishment. Periodic
herbicide application to these sites helps to keep these species relatively restricted in the maintained
buffers, or to a minimum. As a result, vegetation is often sparse in these locations and tends to be early
seral species (e.g., annual mustards).
Vegetation Treatments (ESR, noxious weeds, juniper removal)

Seedings, shrub seedling planting, and herbicide application associated with ESR treatments and other
vegetation treatments would produce an overall benefit to sagebrush communities (i.e., habitat) in the
CIAA. Past and ongoing noxious weed treatments have, to some extent, reduced their potential
establishment and spread. However, noxious weeds would continue to establish where not aggressively
treated, particularly in the wake of large, frequent wildfires. The BLM’s noxious weed programs and
CWMAs continue noxious weed inventories and treatments (herbicide application and biological and
mechanical control) to minimize their spread. Removal of western juniper per the proposed BOSH project
is expected to benefit over 617,000 acres of sagebrush communities in the short and long term. Similarly,
removal of western juniper associated with the Pole Creek and Trout Springs permit renewals will benefit
approximately 38,000 acres of sagebrush communities in the short and long term.
Livestock Grazing
Current livestock grazing permits include terms and conditions to ensure allotments achieve or make
significant progress toward meeting the Idaho Standards for Rangeland Health and Guidelines for
Livestock Grazing Management (USDI BLM 1997a) and the Standards for Rangeland Health and
Guidelines for Livestock Grazing Management for Public Lands Administered by the Bureau of Land
Management in the States of Oregon and Washington (USDI BLM 1997b). As such, ongoing and future
livestock grazing management is projected to maintain or improve upland vegetation on the whole.
However, livestock grazing would continue to result in plant community alterations, particularly in
localized areas adjacent to fences, gates, and livestock facilities (e.g. troughs and supplement sites). While
implementation of targeted grazing could add to livestock grazing impacts, it would be minor at most with
application of design features (Appendix G), and monitoring and control described in Appendix H. Overall,
cumulative impacts to vegetation would be negligible when considered in the context of the 3.6 million-
acre vegetation CIAA.
Burning of Tumbleweed Accumulations and Burn Piles

Direct effects of prescribed fire include the removal of accumulated biomass created by deposits of wind-
dispersed tumbleweeds, as well as the biomass of any perennial or annual plants beneath accumulations. An
indirect effect of this treatment is the reduced potential for larger and/or more frequent wildland fire, and

increased capability to protect existing native plant communities and past and future vegetation treatments.
Burning tumbleweed accumulations would have an overall positive effect by allowing native vegetation to
germinate where it may have been previously suppressed; this benefit would be confined to areas where
tumbleweeds are successfully removed Because burning would be done in spring when surrounding green
vegetation would slow fire spread, or in the fall when surrounding live fuel moistures are high enough to
slow fire spread outside of targeted prescribed fire areas, prescribed fires are not expected to spread from
targeted areas. Overall, surrounding vegetation is not expected to be affected by burning in this manner.
Vegetation immediately adjacent to burned areas may suffer some heat damage, but effects would be short-
term.
Mining
Past mining activity has resulted in some loss of vegetation across the project area. Localized mining
activity at active mineral leases is ongoing and may contribute to the spread of invasive and noxious plants
near these sites. Due to the limited extent of current mining activities, additional loss of vegetation is not
anticipated.

Under the No Action Alternative, the effects of past, present, and foreseeable actions in the CIAA are
expected to continue current trends for vegetation as described in the previous section (3.3.3.2).

Creating a 73,920-acre fuel break network (2% of the project area) would add to impacts beyond existing
cumulative impacts to vegetation across the landscape by altering 67,559 acres of vegetation to meet fuel
break objectives/criteria. In addition, the four new mineral material sites would increase the number of such
sites 13 in the Oregon portion of the CIAA from approximately 15 to approximately 19. These sites
primarily risk introducing invasive and noxious species to previously undisturbed communities, particularly
in sites with low R&R.
The fuel break system could help protect ESR treatments (e.g., seedings and seedling plantings) and
vegetation recovering from wildfire, as well as vegetation threatened by conversion to annual invasive
grasses. A fuel break network of this magnitude to facilitate protection of sagebrush and other vegetation
communities from future wildfire would provide a major benefit to these habitats over the long term, both
by lengthening the duration between fires to more closely mirror the historical fire return interval and by
limiting the fire-invasive cycle to smaller burn footprints. In addition, although a fuel break system would
result in further direct impacts to vegetation, those impacts would be analyzed and minimized through
design features, unlike the impacts of suppression activities, which although localized can result in heavy
ground disturbance and a corresponding potential for noxious and invasive weeds. By improving wildfire
suppression, the Tri-state fuel break system would limit future wildfires in the project area, which in turn,
would limit the spread of invasive annual species; these species readily spread into burned areas and can
lead to more frequent wildfires.

Creating a 51,127-acre system of fuel breaks (1.3% of the project area) would add to impacts beyond
existing cumulative impacts (described in section 3.3.3.2) by manipulating 45,872 acres of vegetation to
13
Only known mineral material sites that are outside of the Highway 95 right-of-way corridor are analyzed for cumulative
impacts to vegetation. Although numerous, sites associated with the Highway 95 right-of-way corridor are not analyzed as
they generally occur in the footprint of preexisting disturbance associated with the highway corridor.

meet fuel break objectives/criteria. Similar to Alternative 2, there would be increased opportunity to protect
vegetation communities in the project area from wildfire over the long term, but less than under Alternative
2 as fewer acres would be converted to fuel breaks. Cumulative effects of current and proposed remote
mineral material sites would be identical to Alternative 2.

Similar to Alternative 3, this alternative - creating a 43,833-acre network of fuel breaks (1.1% of the project
area) by treating 38,044 acres to meet fuel break objectives/criteria - would add negligible impacts across
the landscape when considered with the other cumulative impacts. As described under Alternative 2, the
long-term benefits to vegetation communities of enhanced protection from wildfires would far outweigh the
impacts of implementing a fuel break network, but to a lesser extent than the other action alternatives.
Cumulative effects of current and proposed remote mineral material sites would be identical to Alternative
2.
3.4 Sensitive Plants

Special status plants (SSP) include rare and uncommon vascular plants, lichens, bryophytes, and fungi that
either 1) are federally listed or proposed for listing as threatened or endangered under the Endangered
Species Act (ESA), or 2) have been designated Sensitive by BLM State Directors following BLM Manual
6840 – Special Status Species Management Policy (USDI BLM 2008). State Directors maintain, update,
and issue lists of SSP (from federally-listed species to state-listed/sensitive species) (USDI BLM 2015c).
There are no federally-listed species or species proposed for listing in the affected environment or in the
larger project area. The SSP in the affected environment designated as Sensitive are discussed below.
In Idaho, SSP are given a numeric ranking (from 1 to 4) according to scarcity and risk of extinction. Any
ESA-listed species are assigned a ranking of Type 1. Those SSP with a lower threat of extinction (i.e.,
sensitive plant species) are assigned a ranking of Type 2, 3, or 4 as described below:
• Type 2 - Range-wide / Globally Imperiled Species - High Endangerment

• Type 3 - Range-wide / Globally Imperiled Species - Moderate Endangerment
• Type 4 - Species of Concern
In Oregon, rare or uncommon plants other than federally listed species are designated as Sensitive or
Strategic by the BLM State Director in cooperation with the U.S. Forest Service. Strategic species are
recorded and tracked in the corporate Oregon/Washington BLM database for special status species,
although they are not managed as special status plants. Therefore, only SSP designated as Sensitive are
presented here.
To analyze direct effects to sensitive plants, the BLM identified a direct effects analysis area: the maximum
fuel break treatment area plus a 200-foot outer buffer and the four mineral materials sites (20 acres for each
site). The 200-foot outer buffer is consistent with the minimum avoidance buffer for sensitive plants (see
Appendix G) and the BLM does not anticipate direct impacts to sensitive plants beyond this point. To
analyze indirect effects to sensitive plants, the BLM identified the project area as its indirect effects
analysis area; this area was chosen to fully analyze the impact that wildfires may have on sensitive plants in
the project area if fuel breaks are not implemented. There are 51 occurrences of 19 sensitive plant species
in the direct effects analysis area and 291 occurrences and 27 species in the indirect effects analysis area in
Idaho (Table J-6). In Oregon, there are 35 sites and a total of 20 sensitive plant species in the direct affects
analysis area and 53 sites and 24 species in the indirect affects analysis area (Table J-7). There are no

known sensitive plant sites within or adjacent to the proposed mineral materials sites. For Idaho, an
occurrence/site was considered unique if separated by 1 kilometer or greater, per NatureServe’s standard
separation distance (NatureServe 2004), and occurrences spanning the Idaho-Oregon border were split by
this political boundary; data ranked as “extirpated” were excluded. For Oregon, an occurrence/site was
considered unique if separated by 300 feet per Geographic Biotic Observations (GeoBOB), the
Oregon/Washington BLM database for Special Status Plants.

• How would sensitive plants be impacted by the use of prostrate kochia, a non-native species, in
seeded fuel breaks?
• What are the impacts to sensitive plants from the other treatment methods (mowing, seeding of
native species, targeted grazing, and herbicide application)?
• How would fuel breaks protect sensitive plant habitat from wildfire?
3.4.2.2 Indicators
• Number and type of sensitive plant species within the fuel break (direct impact zone) and number
and type of sensitive plan species within the 200-foot buffer beyond the fuel break (indirect impact
zone).
• Number of sensitive plant populations in high, moderate, and low R&R.
• Acres of fuel breaks implemented.
3.4.2.3 Assumptions
• Assumptions are identical to those described for Vegetation (Section 3.3.2.2).

A fuel break network would not be created and fire suppression personnel would utilize existing paved and
county roads and natural topographic features to hold and control wildfire. If no action is taken, none of the
86 SSP occurrences/sites in the proposed fuel break would be directly impacted by the establishment of
fuel breaks. However, based on trends in the region over the past 30 years, the BLM anticipates large scale
fires will continue to burn throughout the project area. Over the short and long term, this trend would
continue to adversely modify sensitive plant habitats by degrading plant communities and limiting the
potential for population recovery for the 432 SSP occurences/sites within the project area (i.e., in the direct
and indirect effects analysis areas).
Wildfires would result in changes to structure and composition of plant communities, such as loss of shrub
cover and dominance by non-native invasive annual plants or perennial grasses seeded to impede invasive
species in areas with low resistance and resilience. These changes would be accompanied by modification
in the amount and arrangement of open plant interspaces, areas shaded and exposed to sunlight, and
seasonal and daily moisture distribution. Thus, structural and compositional changes post-fire could change
both the physical environment, as well as competition between plants for resources. However, sensitive
plants that thrive in harsh soils where there is little vegetation present would be less affected (e.g., white-
margined wax plant, spine-noded milkvetch, Barren Valley collomia, Ibapah wavewing, and Leiberg’s
clover) (Table J-6 and Table J-7). Plants in high and moderate R&R communities would be more likely to
maintain viability and persist than those in low R&R communities. Of the sensitive plant sites in the
project area, 56% are within low R&R communities and are therefore most likely to be adversely impacted
by wildfires.

Activities associated with fire suppression and post-fire stabilization and rehabilitation within the proposed
project area, such as creating bulldozer lines, can cause soil surface disturbance, resulting in damage or
mortality of sensitive plants or their seed banks. These activities may also increase the potential for
invasive species in these areas of disturbance creating an indirect impact to sensitive plant viability over the
long term. Current and on-going post-fire stabilization and rehabilitation projects attempt to emulate pre-
fire plant community structure and composition to the degree possible, so the extent that they are successful
would influence sensitive plant community condition over the long term.
In addition, exposure to frequent, repeated fires can result in areas of soil loss and deposition that can
modify habitats in both burned and adjacent unburned areas. This could result in plant or seed burial or
exposure, as well as changes in soil physical and chemical characteristics. These changes could make
habitats unsuitable for continued occupation, negatively impacting plants’ long-term viability. As a result,
wildfires could cause a downward trend in one or more sensitive plant populations.

General impacts to sensitive plants from each treatment method would be as described for vegetation
(section 3.3.2.5, General Impacts of Action Alternatives). However, avoidance buffers and other design
features to protect sensitive plants described in Appendix G would eliminate impacts to these species and
their immediate habitats. The type of impacts to SSP would be the same under all action alternatives;
however, the extent of indirect impacts would vary based on the miles of fuel break in the analysis area for
each alternative.
Direct Impacts of Action Alternatives

Absent project design features, direct impacts to sensitive plants could include trampling, breakage, and
removal of plants via fuel break treatments (mowing, seeding, targeted grazing, disking, herbicide,
prescribed fire, and clearing of roadbed vegetation). Impact magnitude would depend on the number of
plants affected within an occurrence/site. Trampling and breakage impacts would be short-term (0-3 years);
individual plants would recover within that timeframe providing the damage was not major, there are no
additional or repeated impacts, and precipitation is within normal range (compared to 30-year average).
Impacts to an occurrence/site or population from removal of plants would be long-term (3-10 years);
recovery would depend on prevalence of noxious or invasive species, on-going disturbances, and sensitive
plant seed bank extent and viability. However, avoidance buffers described in Appendix G would eliminate
these impacts because treatments other than herbicide would not occur within the protection buffer.
Where herbicides are applied, there is a potential for reducing sensitive plant vigor and productivity;
however, implementation of design features in Appendix G (e.g., avoidance buffers and wind speed
restrictions) would eliminate these impacts. If application is considered necessary to control invasive and
noxious species within avoidance buffers, the BLM would use hand sprayers near sensitive plant
occurrences/sites and select herbicides that do not persist in the soil to avoid affecting future generations of
plants or seeds. Benefits of herbicide application include enhancing sensitive plant habitat by decreasing
invasive annual plant biomass and seed sources. Risks include a decrease in native forbs, which may affect
forage for potential pollinators.
Indirect Impacts of Action Alternatives

One particular concern is the potential for prostrate kochia to spread into sensitive plant habitat, particularly
those habitats largely devoid of other vegetation (e.g., Davis’ peppergrass) or containing species that are
globally and regionally rare (e.g., Type 2 species like Mulford’s milkvetch). In such instances, avoidance
buffers would be increased up to 0.5 mile and native species (e.g., Sandberg bluegrass) would be seeded to
create fuel breaks (see Appendix G). Over the long term, a system of fuel breaks to enhance fire

suppression would protect these plants and their habitat from wildfires, maintaining habitat condition,
productivity, and viability in unburned areas.
As described above, fuel breaks (including roads) would have no direct adverse impacts to sensitive plants.
The numerous design features (e.g., avoidance buffers) to protect sensitive plants would eliminate potential
adverse impacts to these species (Appendix G) and would not trend any sensitive species toward federal
listing.
Up to 432 sensitive plant occurrences/sites (342 in Idaho and 90 in Oregon) could benefit from enhanced
wildfire protection associated with the fuel break treatments (Table J-6 and Table J-7). Fuel breaks provide
opportunities for firefighting engagement. This reduces the size of the wildfire, which reduces adverse
changes to vegetation communities (shrub loss, increases in cheatgrass) and habitat disturbance (soil
deposition). Smaller wildfires would lead to fewer acres of fire rehabilitation that may disturb plant sites.
Therefore, the implementation of fuel breaks would reduce the adverse effects of wildfires to sensitive
plants and indirectly benefit them.
Because this fuel break network is the largest of the action alternatives (67,559 acres recommended for
treatment to create a 73,920-acre network), the long-term benefit for sensitive plant habitat protection by
improving fire suppression would be greatest under this scenario.
The direct and indirect impacts to sensitive plants are the same as described in Alternative 2. Alternative 3
has 45,872 acres of treatment creating a 51,127 acre-network, which is 24% smaller than Alternative 2.
This alternative would provide fewer opportunities for fire suppression to protect habitat in the project area
than Alternative 2, but slightly more opportunities than Alternative 4.
The direct and indirect impacts to sensitive plants are the same as described in Alternative 2. Alternative 4
has 38,044 acres of treatment creating a 43,833-acre network, which is 35% smaller than Alternative 2 and
14% smaller than Alternative 3. This alternative would provide fewer opportunities for fire suppression to
protect habitat in the project area than the other two action alternatives, but would be substantially similar
to Alternative 3.

The cumulative impact analysis area (CIAA) for sensitive plants is the 3.6 million-acre project area (Map 1,
Appendix Q and Table J-6 and Table J-7). Like the vegetation section (3.3), this area was selected because
it captures the total area in which Tri-state fuel breaks would facilitate opportunities to protect SSP. It
contains similar plant community components, conditions are similar, and land uses are comparable. There
are no direct effects to sensitive plants in the project area associated with the project due to design features
(Appendix G). However, as fuel breaks facilitate suppression activities, the size of wildfires may be
reduced, protecting SSP and their habitat. Smaller wildfires would also lessen the need for post-fire
restoration activities. These indirect beneficial effects to SSP from the proposed project are expected to be
generalized across the project area, and would occur over the life of the project.

Sensitive plant species in the CIAA are the same as those in the indirect effects analysis area (Table J-6 and
Table J-7 in Appendix J).

The collective past actions (i.e., anthropogenic activities) that have contributed to the current assemblages
and condition of sensitive species are described in section 3.4.1 Affected Environment. Present and
reasonably foreseeable future actions and their impacts are similar to those described for vegetation,
Section 3.3.3.2. Present and reasonably foreseeable future actions include: livestock grazing, road
maintenance, recreation, weed treatments, Pole Creek and Trout Springs juniper treatments, current and
ongoing ESR plans, BOSH Project, tumbleweed burning, Soda Fire and Bruneau fuel breaks14, rights-of-
way, and mining (see Appendix N). These activities are localized in nature and some have design features
to protect sensitive plants similar to this project. For example, the Soda fuel breaks project has a 200-foot
SSP buffer, the Bruneau fuel breaks use a 100-foot buffer for playas to protect Davis perpperweed, and the
BOSH project buffers SSP dependent on treatment type and site conditions (USDI BLM 2017, pp. 22-23;
USDI BLM 2013b, p. 17; USDI BLM 2018c, p. 24). Future fuel break projects that may occur in response
to the Great Basin Fuel Breaks PEIS would likely have similar protective design features. The Pole Creek
and Trout Springs juniper treatments allow juniper cutting and prescribed burning within sensitive plant
sites. The Trout Springs EA described the impacts of these treatments as follows: “Effects are moderately
high within probably small patches of occupied habitat. There would be short-term (<3 years) disturbance
of individual plants, mid-term (3-20 years) effects would create more open habitat, improving localized
habitat for sun-loving species (e.g., Mud Flat milkvetch, rabbitbrush goldenweed, short-lobed penstemon).”
The mining projects are the other activity without design features for sensitive plants. However, a search of
the active and foreseeable mining operations within the project area revealed there are no sensitive plant
sites affected by these projects.

The effects of past, present, and foreseeable actions in the cumulative impact analysis area (CIAA) are
expected to continue current trends for sensitive plants and associated habitat because of protective design
features for most ongoing and reasonably foreseeable agency actions. Successful vegetation treatments
(e.g., ESR seedings and noxious weed control) would help maintain habitat or improve sensitive plant
viability. The Pole Creek and Trout Springs juniper treatments would have short-term adverse impacts to
sensitive plants, but provide a long-term benefit for sun loving species (e.g., Mud Flat milkvetch) by
creating more open habitat. The No Action Alternative would indirectly add to the cumulative impacts to
sensitive plants by allowing large scale fires to continue to burn throughout the project area. Over the short
and long term, this trend would continue to adversely modify sensitive plant habitats by degrading plant
communities and limiting the potential for population recovery.

The past, present and foreseeable actions within the CIAA are the same as the No Action Alternative.
Alternative 2 does not add any adverse cumulative impacts to sensitive plants as design features have been
developed to eliminate potential adverse impacts from any action alternative. This alternative would create
and maintain a 73,920-acre fuel break network to facilitate protection of sagebrush and other vegetation
communities, including sensitive plants and habitat, from future wildfire and would provide the most
14
Although outside the project area, the Soda Fire Fuel Breaks abut the project area and are therefore included in this
analysis as they may provide some protection to project area SSP. Because they are not expected to contribute to protection
of SSP in the project area, the Owyhee Roads Fuel Break Project and Owyhee Desert Sagebrush Focal Area Fuel Breaks
are not included in this analysis.

benefit to these habitats over the long term compared to the other alternatives. Project area sensitive plants
would be protected by approximately 80,545 total acres of fuel break treatments associated with the
Bruneau Fuel Breaks Project, the Soda Fire Fuel Breaks Project, and the Tri-state Fuel Breaks Project.

Alternative 3 does not add adverse cumulative impacts to sensitive plants as design features have been
developed to eliminate potential adverse impacts from any action alternative. Under a 51,127-acre fuel
break network, there would be increased opportunity to protect vegetation communities, including sensitive
plants and habitat, in the project area from wildfire over the long term, but less opportunity than under
Alternative 2 because fewer acres would be converted to fuel breaks. Project area sensitive plants would be
protected by approximately 58,858 total acres of fuel break treatments associated with the Bruneau Fuel
Breaks Project, the Soda Fire Fuel Breaks Project, and the Tri-state Fuel Breaks Project.

Alternative 2 does not add adverse cumulative impacts to sensitive plants as design features have been
developed to eliminate potential adverse impacts from any action alternative. The long-term benefits to
vegetation communities of enhanced protection of sensitive plants and their habitat from wildfires would be
less than under the other action alternatives as the fuel break network would be limited to 43,833 acres.
Project area sensitive plants would be protected by approximately 51,030 total acres of fuel break
treatments associated with the Bruneau Fuel Breaks Project, the Soda Fire Fuel Breaks Project, and the Tri-
state Fuel Breaks Project.
3.5 Wildlife/Special Status Animals

The project area lies within the Northern Basin and Range ecoregion (U.S. EPA 2013) and is dominated by
the sagebrush steppe ecosystem, one of the most imperiled ecosystems in North America. A total of 61
BLM special status wildlife (SSW) species have been documented in the project area, including 31 birds, 3
species of fish, 20 mammals, and 7 herpetofauna. Some of these species are also species of greatest
conservation need (SGCN) in the State of Idaho and/or a sensitive species (SEN) in the State of Oregon.
None of these species are federally listed. The kit fox is listed as threatened under the Oregon Endangered
Species Act. Eighteen of the 61 BLM SSW species are analyzed in the DEIS (Table 3.5-1). Six of the BLM
SSW species are sagebrush obligates: they require sagebrush for some part of their life cycle. These are
sage-grouse, black-throated sparrow, Brewer’s sparrow, sagebrush sparrow, sage thrasher, and pygmy
rabbit. The other 12 SSW species are associated with sagebrush steppe ecosystems but may occur in
habitats such as salt desert scrub, mountain scrub, sagebrush-juniper ecotone, or grasslands.
Table 3.5-1. Affected BLM Special Status Wildlife Species (SSW) and analysis group (bold).
Taxa Species Habitat Association ID- OR- Analysis Group
SGCN* SEN*
California Bighorn Sheep Shrub-steppe X Big Game
Dark Kangaroo Mouse Shrub-steppe X Small Mammals
X/T† Small Mammals
Mammals Kit Fox Shrub-steppe
Piute Ground Squirrel Shrub-steppe or Grassland Small Mammals
Pygmy Rabbit Sagebrush Obligate X X Small Mammals

Taxa Species Habitat Association ID- OR- Analysis Group
SGCN* SEN*
Black-throated Sparrow Sagebrush Affinity Sagebrush Birds
Brewer’s Sparrow Sagebrush Obligate Sagebrush Birds
Burrowing Owl Shrub-steppe or Grassland X X Raptors
Ferruginous Hawk Shrub-steppe or Grassland X X Raptors
Golden Eagle Shrub-steppe or Grassland X Raptors
Grasshopper Sparrow Grassland X Sagebrush Birds
Birds Greater Sage-grouse Sagebrush Obligate X X Sagebrush Birds
Green-tailed Towhee Sagebrush Affinity Sagebrush Birds
Loggerhead Shrike Sagebrush Affinity Sagebrush Birds
Long-billed Curlew Grassland X X Sagebrush Birds
Sagebrush Sparrow Sagebrush Obligate X X Sagebrush Birds
Sage Thrasher Sagebrush Obligate X Sagebrush Birds
Short-eared Owl Shrub-steppe or Grassland X Raptors
* ID-SGCN: species of greatest conservation need; OR-SEN: sensitive
†
Kit fox is listed as a threatened species under the Oregon Endangered Species Act.
The 18 BLM SSW analyzed in this DEIS are grouped by similar habitat requirements and movement and
dispersal abilities. The analysis focuses on one focal species within each Analysis Group (Table 3.5-1), and
in greater detail for sage-grouse. Sage-grouse is considered an umbrella species for the sagebrush steppe
ecosystem, meaning that conserving sage-grouse habitat also benefits other wildlife species, particularly
sagebrush-obligate bird species (Hanser and Knick 2011, Donnelly et al. 2017), small mammals (Rowland
et al. 2005), and mule deer (Copeland et al. 2014). Potential project impacts for many BLM SSW would be
similar to those anticipated for sage-grouse.
The analysis area for direct impacts to wildlife is the treatment area, i.e., the fuel break, which includes the
road and 200-foot-wide vegetation treatments on each side of the road. The fuel break treatment area would
total 73,920, 51,127, or 43,833 acres for Alternatives 2, 3, or 4, respectively. The indirect impacts analysis
area (IIAA) would be the overall project area (i.e. approximately 3.6 million acres) in order to include
effects due to disturbance as well as habitat degradation and fragmentation (Map 16, Appendix Q). Direct
and indirect impacts were evaluated by overlaying the project footprint and analysis area with the best
available information on species distribution, occurrences, and habitats (IFWIS 2017; ODFW 2018).
Effects to sage-grouse were analyzed at multiple spatial scales to account for potential disturbance to leks,
impacts to nesting habitat within four miles of leks, landscape cover of sagebrush around leks, and impacts
to habitat within subpopulations. Disturbance to leks, impacts to nesting habitat, and landscape cover of
sagebrush around leks were analyzed using the Sage-grouse Analysis Area (SGAA), a 4-mile buffer around
the project area which also includes a buffer of ≥ 4 miles around leks within the project area. In Oregon,
where seasonal habitats for sage-grouse have not yet been mapped, the Greater Sage-Grouse Approved
Resource Management Plan Amendments (ARMPA) for Oregon require the use of 4-mile buffers around
leks for analyzing potential impacts (USDI BLM 2015a; USDI BLM 2019a). In Idaho, seasonal habitats
have been mapped (Map 17, Appendix Q) and the ARMPAs provide required design features and best
management practices specific to certain seasonal habitats (USDI BLM and USDA FS 2015; USDI BLM
2019b). For the analysis and consistency across state lines, 4-mile buffers around leks were used to
describe sage-grouse habitat, particularly nesting habitat which was quantified as acres with ≥10%
sagebrush cover (Homer et al. 2012). The 4-mile lek buffers would reflect any effects to > 75% of nesting

habitat around occupied or pending leks (Manier et al. 2014). All occupied 15 and pending leks (i.e.,
communal strutting grounds used for breeding) were used in the analysis (IDFG 2018a; ODFW 2018).
Due to the importance of sagebrush cover across the landscape for sage-grouse, a moving window analysis
(3.1-mile or 5-km radius; Knick et al. 2013) was used to quantify existing landscape cover for each lek
within the SGAA. For the purposes of analyzing potential impacts due to habitat fragmentation, sagebrush
cover within the fuel break was assumed to be reduced to zero and landscape cover of sagebrush was then
re-calculated for each lek. This analysis seeks to address the maximum potential impacts of key
components of habitat fragmentation, specifically the availability and connectivity of sagebrush across the
landscape (Bennett and Saunders 2010; Stiver et al. 2015). However, it does not capture impacts to patch
size or edge effects, such as increased predation, which are also associated with habitat fragmentation but
are more difficult to quantify.
To capture potential impacts to sage-grouse movement between seasonal habitats, additional analysis
considered affected subpopulations based on fine-scale habitat according to the Sage-Grouse Habitat
Assessment Framework (HAF; Stiver et al. 2015). The HAF assesses sage-grouse habitat at multiple spatial
scales, including fine-scale habitat, which delineates habitat used by a subpopulation reflecting movements
among seasonal habitats (i.e., breeding, summer, and winter), topographic barriers and landscape features.
The project area falls within six subpopulations: Cow Lakes, Soldier Creek, Louse Canyon, Owyhee
Desert, Owyhee Canyonlands, and Antelope Ridge (Map 18, Appendix Q).
Greater Sage-grouse
Current Status and Management
Sage-grouse is dependent on the sagebrush steppe ecosystem and population declines have been
concomitant with the loss, degradation, and fragmentation of sagebrush steppe habitat (Knick et al. 2003;
Davies et al. 2011). In southwest Idaho and southeast Oregon, primary threats to sage-grouse habitat are
wildfire, change in fire frequency and intensity, and the invasion of non-native annual grasses (USDI FWS
2010a). After wildfire, native vegetation, particularly in areas with low R&R, is often converted to invasive
annual grasslands which in turn increases the risk of fire (Balch et al. 2013). Drought exacerbates the
increased presence of invasive annual grasses in the understory and risk of fire and subsequent conversion
to invasive annual grasslands (Chambers et al. 2014).
There are several policies pertaining to land management and sage-grouse conservation, including Oregon
ARMPAs (USDI BLM 2015a and USDI BLM 2019a) and Idaho ARMPAs (USDI BLM and USDA FS
2015 and USDI BLM 2019b). The ARMPAs identify and incorporate appropriate conservation measures
into land use plans (LUP) in order to conserve, enhance, and restore sage-grouse habitat by avoiding,
minimizing or compensating for unavoidable impacts to sage-grouse habitat. Conservation measures are
more conservative or restrictive in habitats with the highest conservation value for sage-grouse, i.e.,
Priority Habitat Management Areas (PHMA), followed by Important Habitat Management Area (IHMA),
and General Habitat Management Area (GHMA). In Oregon, PHMA mostly coincides with Priority Areas
for Conservation (PAC) identified by USDI FWS (2013a) as areas needed for maintaining sage-grouse
populations, diversity, and distribution across the landscape and the species’ range. There is no IHMA in
Oregon. Due to management concerns about sage-grouse, groups of leks or populations are monitored for
counts and trends within biologically significant units (BSU). In Oregon, BSUs are synonymous with
Oregon Priority Areas for Conservation (Oregon PAC). Within the project area, BSUs include two BSUs in
15
In Idaho, a lek is considered occupied when ≥ 2 male sage-grouse have attended a lek for at least one of the last 5 years.
(IDFG 2018a). In Oregon, an occupied lek is defined as ≥ 1 male in at least one of the last 7 years at regularly visited leks,
whereas pending means a male was detected in at least one year but the lek is not routinely surveyed (USDI BLM 2015a).

the West Owyhee Conservation Area in Idaho (one each for PHMA and IHMA), and the Soldier Creek and
Louse Canyon Oregon PACs (Map 19, Appendix Q).
Most (91%) of the project area contains designated sage-grouse habitat, of which 77% is PHMA, 2%
IHMA, and 22% GHMA (Map 19, Appendix Q; Table 3.5-2).
Table 3.5-2. Acres of designated sage-grouse habitats in the Sage-Grouse Analysis Area (SGAA) and
action alternative footprints.
Acres in SGAA and No Action Alternative* Acres by Alternative†
Sage-grouse habitat
type Idaho Oregon Total Alt 2 Alt 3 Alt 4
PHMA 1,814,614 1,014,096 2,828,710 49,385 33,846 24,720
IHMA 121,954 --- 121,954 693 692 466
GHMA 301,552 708,779 1,010,331 15,618 10,455 10,576
Total 2,238,120 1,722,875 3,960,995 65,696 44,993 35,762
*
Acreages were assessed prior to the 2019 ARMPAs and will be updated in the final EIS to reflect the most recent
management designations.
†
Includes fuel break treatment acres and footprint of three mineral material sites in Oregon.
Sage-grouse Biology and Habitat

From March to early May, sage-grouse typically congregate on leks. The nesting season occurs soon after,
generally extending from May through June, but may start earlier depending on elevation, weather, and
plant phenology. Hens typically nest within 4 miles of leks (Aldridge and Boyce 2007; USDI BLM 2015a).
In Idaho and Oregon, the majority (~80%) of sage-grouse hens nest within 4 to 6 miles from leks where
they were captured (ODFW 2011; Connelly et al. 2013; Manier et al. 2014; USDI BLM and USDA FS
2015).
Sage-grouse prefer habitat with at least 10% sagebrush cover during spring, summer and winter (Stiver et
al. 2015); therefore, the conservation of sagebrush landscapes is crucial. The best habitat conditions for
nesting are 10-25% sagebrush cover and sagebrush 12-31” tall (USDI BLM 2015a; USDI BLM and USDA
FS 2015). These sites also have perennial grasses in the understory and a diversity of forbs.
Sage-grouse are sensitive to landscape change, configuration, and fragmentation (Stiver et al. 2015). The
species requires large, contiguous patches of sagebrush in areas with little anthropogenic disturbance and
often utilizes interconnected, seasonal habitats. Typically at least 40% of the landscape cover is sagebrush
within 3.1 miles (5 km) of an active lek (Knick et al. 2013). As sagebrush cover increases across the
landscape, particularly over 65%, sage-grouse leks are more likely to persist (Aldridge et al. 2008; Wisdom
et al. 2011; Knick et al. 2013; Chambers et al. 2014).
Habitat fragmentation can lead to increased distances moved among seasonal habitats, lower survival and
recruitment, changes in nest site selection and nest initiation, reduced winter habitat, reduced lek
attendance, avoidance of otherwise suitable habitat, and lek abandonment (Schroeder and Rob 2003;
Aldridge and Boyce 2007; Walker et al. 2007; Doherty et al. 2008). Due to the loss and fragmentation of
sagebrush habitat over the past 200 years, sage-grouse distribution has shrunk by half (Schroeder et al.
2004). Wildfire and the subsequent loss and degradation of sagebrush habitat, fragmentation and landscape
changes have resulted in lek abandonment, including in the project area, and the extirpation of several sage-
grouse populations within the species’ range (Coates et al. 2015; Coates et al. 2016).

Status in Project Area
The project area lies within the Northern Great Basin (NGB) population of the Snake River Plain
Management Zone (MZ IV) which includes portions of northern Nevada, southeastern Oregon,
southwestern Idaho, and northwestern Utah. The BSUs and PACs in the project area and within the NGB
population are considered a stronghold for sage-grouse; they exhibit high lek counts and density, lek
connectivity, and likelihood of persistence based on sagebrush cover. The NGB population is also a high
landscape-level priority area for sage-grouse (Crist et al. 2015).
Sage-grouse populations fluctuate annually and hence long-term trends are monitored. In Idaho, male
counts on lek routes in all habitat management areas (PHMA, IHMA, GHMA) were up 18% from 2016 to
2017, but the 3-year averages for lek routes in PHMA and IHMA were down 1% from the 2011 baseline
(IDFG 2017a). In the West Owyhee Conservation Area, male counts on the 8 lek routes in PHMA were up
39% in 2017 compared to the 2011 baseline, but leks in IHMA have declined since the Soda Fire. In
Oregon, the estimated sage-grouse population for 2017 was down 8% compared to the 2016 estimate
(ODFW 2017). In the BLM Vale District, which contains 40% of the Oregon sage-grouse population, the
number of individuals increased by 1% between 2016 and 2017, but male attendance at lek complexes
declined by 5%.
A total of 241 occupied or pending leks exist in the project area, plus an additional 24 leks within the
SGAA (Table 3.5-3). The 265 leks are within 223 lek complexes, including 133 in Idaho and 90 in Oregon.
Leks within 1-1.2 miles of each other are considered a lek complex, because an individual sage-grouse may
attend several of these leks during a breeding season. Of the 265 occupied or pending leks in the analysis
area, 135 leks were active in 2018 (Idaho: 105; Oregon: 30).
Table 3.5-3. Occupied or pending sage-grouse leks and lek complexes in project area and Sage-
grouse Analysis Area (SGAA).
Leks / Complexes
Area Idaho Oregon Total
Project area* 142 / 128 99 / 78 241 / 206
Within 4 miles of project area (SGAA) 5/ 5 19 / 12 24 / 17
Total in SGAA 147 / 133 118 / 90 265 / 223
* The project area denotes the 3.62 million-acre project area. Oregon data from 2018; Idaho 2018.
Forty-two percent of the project area (Idaho: 52%; Oregon: 29%) consists of sage-grouse nesting habitat, or
areas with ≥10% sagebrush cover (Homer et al. 2012) (Map 20, Appendix Q). Out of 1.91 million acres of
areas with ≥10% sagebrush cover in the SGAA, 1.38 million acres are within 4 miles of occupied or
pending leks, and therefore are likely sage-grouse nesting habitat (Table 3.5-4).
Table 3.5-4. Acres of sage-grouse nesting habitat within the project area and SGAA by alternative.
Acres in SGAA Acres by Alternative*
Area Idaho Oregon Nevada Total Alt 2 Alt 3 Alt 4
Within 2 miles of leks 494,312 221,020 5,684 721,016 -- -- --
Within 4 miles of leks 925,778 422,218 27,183 1,375,179 -- -- --
Project Area 1,035,733 472,142 -- 1,554,290 25,791 17,810 12,965
SGAA 1,279,587 535,544 93,080 1,908,211 -- -- --
* The total acres by Alternative are 73,920, 51,127, and 43,833 acres for Alternatives 2, 3, and 4, respectively.

Most of the landscape within the SGAA has a high percentage of sagebrush land cover, 16 particularly in
Idaho and, to a lesser extent, in the southern and northeastern corners of the Oregon portion of the SGAA
(Map 21). Sixty-nine percent of the leks are located in more than 45% sagebrush land cover and, thus, are
more likely to persist under current conditions (Table 3.5-5). In contrast, 17% of the leks are located in less
than 25% sagebrush land cover and, therefore, have a low probability of persistence (Aldridge et al. 2008;
Wisdom et al. 2011; Chambers et al. 2014). Over half of the leks that occur in low sagebrush land cover are
located in Oregon within, or adjacent to, the footprint of the 2012 Long Draw Fire.
Table 3.5-5. Distribution of leks within the SGAA by landscape cover of sagebrush, and likelihood of
persistence.
Likelihood of Number of Leks by Landscape Cover (average (range) in (%))
Persistence Landscape Cover Sagebrush Removed by Alternative
Landscape
Idaho Oregon SGAA Alt 2 Alt 3 Alt 4
Cover*
Low < 25% 11 35 46 0.18 (0 – 1) 0.02 (0 – 1) 0.04 (0 – 1)
Moderate 25-45% 18 20 38 0.58 ( 0 – 2) 0.39 (0 – 2) 0.26 (0 – 1)
High 45-65% 29 39 68 0.62 (0 – 3) 0.47 (0 – 3) 0.31 (0 – 2)
Very High >65% 89 25 114 1.75 (0 – 5) 1.24 (0 – 4) 0.64 (0 – 3)
* The amount of landscape cover of sagebrush (10-40%) surrounding leks was determined with a 3.1-mile (5-km) moving
window analysis, similar to Knick et al. (2013).
Sagebrush-obligate bird species besides sage-grouse include black-throated sparrow, Brewer’s sparrow,
sagebrush sparrow, and sage thrasher. These species have similar habitat requirements as sage-grouse and
are also sensitive to habitat fragmentation. Green-tailed towhee and loggerhead shrike are associated with
sagebrush steppe, often in ecotones with other habitats. Grasshopper sparrows and long-billed curlews are
found in native grasslands which sage-grouse may use during brood-rearing. Long-billed curlews are also
found in annual grasslands (i.e., former sage-grouse habitat often altered after wildfire).
Pygmy Rabbit
The pygmy rabbit is considered rare across its range in the Intermountain West (USDI FWS 2010b). Due to
its narrow habitat requirements, its distribution is patchy. Similar to sage-grouse, it is a sagebrush obligate
species and depends on sagebrush year-round for food and shelter (Katzner and Parker 1997). It is
threatened by habitat loss, degradation, and fragmentation, mostly due to wildfire, conversion to
agriculture, juniper encroachment, and invasive annual grasslands.
Pygmy rabbits are typically found in tall, dense sagebrush cover with deep soils suitable for burrowing.
Mean sagebrush cover around burrows is dense at > 40% sagebrush cover (Katzner and Parker 1997; Burak
2006; Larrucea and Brussard 2008). Pygmy rabbit burrows are typically placed under tall sagebrush, i.e. >
24 inches (Rachlow et al. 2005; Burak 2006) often surrounded by shorter sagebrush (Larrucea and Brussard
2008). Understory biomass and cover has also been shown to be important, partly since perennial grasses
and forbs may make up to half of their diet during the summer (Schmalz et al. 2014). Areas with cheatgrass
in the understory are often avoided (Larrucea and Brussard 2008).
Pygmy rabbit home ranges vary by site, age, gender, and season. Average home ranges consist of a 308-
640-ft radius around a burrow (Sanchez and Rachlow 2008), but may range from 177 feet for a female
(Crawford 2008) to 925 feet for a male (Burak 2006). Pygmy rabbits spend most of their time in core areas
16
Based on a 3.1-mile or 5-km moving window analysis (Knick et al. 2013).

within 140-200 feet of their burrows (Heady and Laundré 2005; Burak 2006). Female natal burrows (i.e.,
separate burrows dug for raising young) may be outside these core areas, often more than 100 feet from
active burrow systems (Rachlow et al. 2005).
Based on their small size and short movement and dispersal distances, pygmy rabbits are generally
considered a species with limited movement ability; they are unwilling to cross open areas without cover
(USDI FWS 2010b). This may be in part due to low survival, as predation is the primary cause of mortality
(Crawford 2008). Occasionally, pygmy rabbits will cross gravel roads and creeks (Estes-Zumpf and
Rachlow 2009). Dispersal distances are generally short (i.e. < 0.3 miles), with a maximum distance of 7.4
miles reported (Crawford 2008, Estes-Zumpf and Rachlow 2009).
Distribution of the pygmy rabbit is not well known across its range as populations can be isolated.
Information on pygmy rabbit distribution in the project area is limited, mainly due to the logistical
difficulties with implementing surveys across broad landscapes. In Oregon, surveys on State lands found no
pygmy rabbits at 12 sites in Malheur County (Hagar and Lienkaemper 2007). In Idaho, the BLM conducted
pygmy rabbit surveys in 2014-2016 along 209 miles of proposed fuel breaks in priority pygmy rabbit
habitat, as identified by a draft model developed by the BLM Boise District. Burrows were clustered, and
found along approximately half of the miles surveyed. A total of 240 burrows were found, consisting of
approximately 166 burrow systems (i.e., burrows < 50 feet apart) or territories.
The best currently available information on pygmy rabbit habitat in the project area is based on a range-
wide pygmy rabbit distribution model being revised by the University of Idaho (Smith et al. 2018). Based
on this model, there are 1.5 million acres of suitable pygmy rabbit habitat in the project area (Idaho: 1.1
million acres; Oregon: 411,000 acres), with 73% of the suitable habitat in Idaho (Table 3.5-6; Map 22,
Appendix Q). However, based on the low accuracy of soil data, the model likely overestimates pygmy
rabbit habitat.
Table 3.5-6. Acres of suitable and priority pygmy rabbit habitat by type and alternative.
Pygmy Rabbit Habitat Type* Alt 1 or Project Area Alt 2 Alt 3 Alt 4
Suitable 945,126 20,484 14,166 9,565
Priority 560,427 13,632 8,320 6,513
Total 1,505,553 34,116 22,486 16,078
% Removed by Alternative --- 2.3% 33 345
1.5% 1.1%
* Suitable ≥ 0.25; Priority ≥ 0.40. Habitat types were based on modeling results from revised distribution model which
corresponded with mean value (mean: 0.40; SD: 0.13) for 1,277 records of documented pygmy rabbit burrows.
Besides pygmy rabbits, other small mammals and BLM SSW associated with sagebrush habitats are known
to occur within the project area: kit fox, dark kangaroo mouse, and Piute ground squirrel (Map 22,
Appendix Q). They are all fossorial species, meaning that they use burrows. Threats to all of these species
include invasive plants and weeds, loss of sagebrush steppe, and habitat fragmentation.
Kit foxes are listed as a threatened species under the Oregon Endangered Species Act, and are rare in the
project area. Based on 2012-2017 observations in Oregon, their distribution includes the northwestern part
of the project area, but is mostly west of Highway 95 (Map 22, Appendix Q). In Idaho, there are only eight
records (3 from the 1920s, 4 from the 1990s, and 1 from 2003) of kit foxes in the project area. They are
found in sagebrush steppe but also other desert scrub habitats and woodlands. In general, kit foxes occur in
flat to gently rolling terrain, but in Utah, dens have been found in steep terrain adjacent to flatter areas for
foraging (Kozlowski et al. 2008). In southeastern Oregon (Eckrich et al. 2018), kit fox occupancy is not
related to shrublands but sparsely vegetated salt desert scrub and native grasslands. Coyotes, on the other

hand, tend to occur in areas with denser sagebrush. Kit foxes may avoid these areas, as coyotes compete for
similar prey and are the primary predator of kit foxes (Kozlowski et al. 2008). Kit foxes give birth late
January and young may remain in natal dens through August.
A unique subspecies of dark kangaroo mouse (Microdipodops megacephalus atrielictus; IDFG 2017b)
occurs in the project area, restricted to approximately 25 square miles in the Little Owyhee River drainage
(Map 23, Appendix Q). Recent studies have shown population declines and lack of gene flow among
populations, implying that the population in Idaho is isolated and genetically distinct, and may warrant
species status (Hafner and Upham 2011). It is found in sparsely vegetated areas, such as sagebrush and
other desert scrub, with sandy soils, often with gravelly overlay. It is dormant in the winter but is active
from March through October (O’Farrell 1974). The most recent records of dark kangaroo mouse are from
2011.
The Piute ground squirrel subspecies (Spermophilus mollis mollis) occurs south of the Snake River in
sagebrush steppe and grasslands (Yensen and Sherman 2003). They prefer native shrub-steppe habitats, but
may occur at lower densities in annual grasslands or prostate kochia (Tinkle 2016). Piute ground squirrels
are active January to June and hibernate 6-7 months per year in burrows 38 inches deep; although shallower
burrows (16 inches deep) are used in feeding areas for cover (Alcorn 1940).
Golden Eagle
Golden eagles are protected under The Bald and Golden Eagle Protection Act (1940). They are found in a
variety of habitats, but prefer open space or low hills where visibility is good for hunting (Kochert et al.
2002). Golden eagles typically nest on cliff ledges, such as canyons in the Owyhees. They will also nest on
lattice towers from transmission lines, nesting platforms, and tall trees.
Golden eagles feed primarily on mammals, particularly jackrabbits, but also cottontails and ground
squirrels. They will also feed on snakes, birds, and large insects when mammals are unavailable, as well as
carrion, particularly during the winter (Kochert et al. 2002). Black-tailed jackrabbits found in sagebrush
steppe are the primary prey for golden eagles in southwest Idaho (Steenhof and Kochert 1988). White-
tailed jackrabbits, mountain cottontails, and ground squirrels occur in the project area and likely make up
some portion of the eagle’s diet (Kochert et al. 2002). Jackrabbits are important to golden eagles. Their
abundance has been tied to breeding attempts of golden eagles, as well as to reproductive success and
output (Steenhof et al. 1997).
Threats to golden eagles include habitat loss and degradation, mostly due to wildfire and subsequent loss of
native habitats that support prey, or due to conversion to agriculture or urbanization (Kochert and Steenhof
2002). After wildfires in the 1980s in the Snake River Birds of Prey National Conservation Area in
southwestern Idaho, the number of golden eagle territories declined (Kochert et al. 1999). Besides habitat
loss, threats to golden eagle are human-caused or -associated mortalities due to collisions, electrocution,
illegal shooting, and poisoning (Kochert et al. 2002).
The project area contains 42 known golden eagle territories, including 36 in Oregon (30 current, 6 historic)
and 6 in Idaho. There are likely additional golden eagle territories and nests in the project area. For
example, on the Idaho side of the project area, most canyons have not been surveyed for golden eagles due
to the remoteness of the area.
Other raptors and BLM SSW associated with open, shrub-steppe habitats are the ferruginous hawk, short-
eared owl, and burrowing owl (Ehrlich et al. 1988); all of these species occur in the project area. The
ferruginous hawk feeds on similar prey as the golden eagle and nests in similar habitats. Short-eared owls

are found in shrub-steppe, (generally native) grasslands, marshes, and agricultural areas (Wiggins et al.
2006). They feed almost exclusively on voles. Burrowing owls are a semi-colonial species inhabiting
sparsely vegetated habitats, which include sagebrush habitats but more often grasslands, including annual
grasslands, and agricultural areas (Ehrlich et al. 1988). Nests are typically in vacant burrows dug by other
animals (e.g., badgers and ground squirrels) and are active from approximately April-July.
Bighorn Sheep
Big game species in the project area include California bighorn sheep (“bighorn”), mule deer, pronghorn
antelope, and elk. Populations of all four of these species are managed and hunting limits set by the States
of Idaho and Oregon. Bighorn are the only one of the four species that is a BLM SSW. All of these species
depend on healthy, native vegetation and are threatened by wildfire, invasion of non-native vegetation and
noxious weeds, drought, juniper encroachment, roads, human disturbance, and livestock grazing (IDFG
2008; IDFG 2010).
Bighorn are found in rugged, open habitats where they generally are able to elude predators (IDFG 2010).
They graze on grasses, but also rely on forbs and shrubs seasonally. Current populations are limited
primarily by disease (i.e. pneumonia) which can be transmitted by domestic sheep and goats. Human
disturbance, particularly when random in intensity, space and time, may result in increased stress and
displacement of bighorn. This sort of response to human disturbance can be particularly detrimental to
bighorn during critical times of the year, such as lambing, or along migration corridors.
There are a total of 916,997 acres of bighorn sheep habitat in the project area (Table 3.5-7). The project
area overlaps with four bighorn Population Management Units in Idaho, i.e. Bruneau-Jarbidge, Jack’s
Creek, Owyhee Front, and Owyhee River, and three bighorn herds in Oregon, i.e., Rattlesnake/Tenmile
Rim, Upper Owyhee River, and Juniper Ridge (Map 24, Appendix Q). In Idaho, these units comprise 93%
of the estimated 900 California bighorn sheep in Idaho. Each unit consists of 75-350 animals and are
considered stable (IDFG 2010). In Oregon, these herds comprise 6% of the estimated 3,700 animals in the
State (ODFW 2003). All of these herds are stable or increasing with the exception of the Upper Owyhee
River herd.
Mule deer and pronghorn rely on shrubs and forbs instead of grass for forage (Mule Deer Working Group
2003). In the winter, mule deer and pronghorn rely heavily on shrub-steppe habitats. Besides threats
identified above to big game, mule deer populations may also be impacted by predation, over-winter
mortality, vehicle collisions, and fragmentation of habitats and migration corridors (IDFG 2008). Mule deer
are sensitive to changes in cover and forage. OHV use and other human recreation in winter habitat may
result in displacement of big game, including pronghorn (IDFG 2017c) and mule deer (Mule Deer Working
Group 2017).
The mule deer population in the project area is part of the Owyhee Population Management Unit (IDFG
2016) which extends into Oregon and Nevada. Some animals from Idaho overwinter in Oregon, and
animals from northern Nevada overwinter in Idaho. Harvest has increased over the past few years, but there
is no population estimate for the unit in Idaho. In Oregon, an estimated 14,000 mule deer occur in
management units that overlap with the project area (P. Milburn, ODFW, personal communication). Mule
deer have been declining in the Malheur River unit over the past few years. In some areas, juniper
encroachment has resulted in a significant reduction in important browse species, and the number of
wintering deer has declined from several thousand to a few hundred (IDFG 2016).
Recent numbers on pronghorn in the project area are lacking. In the northeast part of the project area,
hundreds of pronghorn used to overwinter, but numbers have declined since 2010-2012 wildfires (IDFG

2017c). In Oregon, pronghorn have declined in the Owyhee Game Management Unit due to the harsh
2016-2017 winter and poor fawn recruitment (P. Milburn, ODFW, personal communication). Pronghorn in
the Whitehorse Game Management Unit are either stable or declining slightly.
Elk have been increasing in southwest Idaho since approximately the 1990s, partly due to rapidly growing
population in northern Nevada (IDFG 2017d). Accurate population estimates are not available because
animals move across state lines. In the southeast corner of the project area, west of the Bruneau River,
2,120 elk were observed during the last aerial survey in February 2017 along the Nevada border. In
Oregon, the 2018 estimate for elk in the High Desert Region was a stable population with 1,700 animals (P.
Milburn, ODFW, personal communication).
Table 3.5-7. Big Game (Bighorn Sheep, Pronghorn Antelope, Mule Deer, Elk) habitat in the project
area* and treatment areas by action alternative.
Project Area Acres Treatment Acres
Big Game Species Habitat Idaho Oregon Total Alt 2 Alt 3 Alt 4
Bighorn Sheep 508,112† 408,886 916,997 11,725 7,884 5,229
Pronghorn Antelope ‡
705,255 n/a 705,255 31,874 22,681 18,264
Mule Deer Winter Range 198,388 477,230 675,618 16,124 13,925 9,331
Elk 615,749 92,964 708,713 16,038 13,212 7,614
*
The project area denotes the 3.62-million-acre project area. Oregon data from 2018; Idaho 2018.
†
Acres in Idaho include 90,755 acres in lambing areas.
‡
Acres for pronghorn antelope in Idaho only; no habitat mapped in Oregon.

• How would equipment use, herbicide application, and disturbance during project implementation
affect wildlife?
• How would implementation of fuel breaks affect habitats of greater sage-grouse and other
sagebrush-obligate wildlife species (e.g., habitat modification, loss, or fragmentation)?
• How would the development and operations of four mineral material sites in Oregon affect
wildlife?
3.5.2.2 Indicators
• Acres of existing habitat for each focal species within the analysis area(s)
• Acres of habitat impacted by each action alternative for each focal species
• Miles of fuel breaks within habitat for each focal species
• Number of occupied or pending sage-grouse leks impacted by each action alternative, i.e., leks
within 2 and 4 miles from fuel breaks
• Amount and change in landscape cover of sage-grouse nesting habitat by each action alternative
within 3.1 miles (5 km) of each lek
• Number of golden eagle territories impacted by each action alternative, i.e., territories within 2
miles of fuel breaks
3.5.2.3 Assumptions
Treatment types as modeled (Table 2-2) based on cover of sagebrush and perennial and annual grasses
(Homer et al. 2012) could change over the life of the project (i.e., 10-15 years). For the analysis of impacts

to wildlife and BLM SSW, the BLM assumed that any treatment type would degrade or remove habitat for
species analyzed, although some treatment areas may retain some habitat functionality in some years.

Under the No Action Alternative, a network of fuel breaks would not be constructed and vegetation in or
adjacent to the proposed fuel breaks would not be removed or altered by the project. There would be no
disturbance associated with fuel break implementation and maintenance or development of mineral
material sites. However, without a strategic network of fuel breaks to facilitate fire containment, the
support for fire suppression efforts would be reduced. As a result, under the No Action Alternative
wildfires would be more likely to turn into large, catastrophic fires.
Wildfire frequency and intensity have been increasing in the Great Basin, including in the project area, and
are predicted to increase further with warmer temperatures and less precipitation (Balch et al. 2013).
Models predict that in the Great Basin an average 66% (range: 34-95%) more area will burn by 2050
compared to 2006, or 2.1 vs. 1.2 million acres per year (Zhu et al. 2012). After fire, sagebrush steppe is
often converted to annual grasslands and invasive or noxious weeds. Bulldozer lines created during fire
suppression efforts can add to the erosion and establishment of invasive species. Another effect of wildfire
is direct mortality of wildlife, particularly slow-moving animals, young, or nests, which are unable to move
out of harm’s way. Wildfire also immediately reduces forage and cover, thus affecting reproduction and
survival. These effects would be short-term. However, over the long term, larger and/or more frequent
wildfires would result in further mortality, reduced reproduction and survival, and habitat loss and
fragmentation for numerous wildlife species, particularly those dependent upon or associated with
sagebrush steppe.
Over the next 30 years, 56% of existing sagebrush in the Great Basin is at moderate to high risk of
conversion to annual grasslands, particularly at lower elevations in warmer and drier landscapes, which are
lower in landscape resistance and resilience (R&R) and more susceptible to invasion by non-native plant
species (Miller et al. 2011; Chambers et al. 2014). Effects from the No Action Alternative could be
moderate to major for wildlife and BLM SSW, depending on the species and extent and locations of
wildfires.
Greater Sage-grouse
Sage-grouse populations are negatively affected by large wildfires due to the loss of sagebrush that is
crucial for nesting, brood cover, and wintering. Sagebrush can also take a long time to recover after large
fires, if at all, in the absence of intentional seeding or planting efforts. Most sagebrush does not resprout
after fire and habitat may take 25-120 years to provide suitable cover again for sage-grouse, depending on
sagebrush species and growing conditions (Baker 2011). Sagebrush habitats that become converted by
homogeneous burn patterns to annual grasslands (i.e., non-habitat) are of particular concern, as they can be
expensive to rehabilitate, are unsuitable for sage-grouse, and allow future fires to spread more quickly
across the landscape. Due to the habitat loss and degradation associated with wildfires, sage-grouse habitat
would become increasingly fragmented. After large wildfires, lek attendance may decline (Johnson et al.
2011), leks may be abandoned (Knick and Hanser 2011), recruitment may decrease, and eventually sage-
grouse populations would likely suffer serious declines (Coates et al. 2016). In the short term, wildfires
may also result in mortality of individual sage-grouse, in particular chicks or nests, reduced cover and
forage and, thus, lower survival and reproduction.
Under the No Action Alternative, significant losses of sagebrush steppe and sage-grouse habitat are likely
to continue. Over the past 30 years, 18.1 million acres of sagebrush and sage-grouse habitat have burned
(Brooks et al. 2015) and total acres burned has increased by 37,807 acres per year (Coates et al. 2015). In

2016-2018 alone, approximately 4 million acres of sage-grouse habitat were lost due to wildfire, including
almost 1 million acres in Idaho and Oregon combined (Idaho: 783,000 acres; Oregon: 233,000 acres)
(NIFC 2018a). Another very large fire in the project area and surrounding area, such as the 2007 Murphy
Fire (675,000 acres), 2012 Long Draw Fire (582,000 acres), the 2015 Soda Fire (279,000 acres), or the
2018 Martin Fire (436,000 acres) could have major impacts on sage-grouse in the SGAA and the NGB
population. Based on rangewide models, over the next 30 years, 22-32% of sagebrush within 3.1 miles of
leks is likely to be lost to fire, and 48-70% of leks may be abandoned, with the greatest impacts to leks in
areas with low landscape R&R (Coates et al. 2015) or where landscape cover of sagebrush is low (Knick et
al. 2013; Chambers et al. 2014). Within the SGAA, these predictions based on the rangewide models
(Coates et al. 2015) would translate to the loss of 275,922 acres (Idaho: 180,234 acres; Oregon: 96,688
acres) of sage-grouse nesting habitat (i.e., ≥10% sagebrush cover within 3.1 miles of leks) and 57% (Idaho:
56%; Oregon: 60%) or 152 of the 265 leks in the SGAA. Rangewide, if wildfire frequency and intensity
continues unabated, sage-grouse populations would likely be reduced by 57% over the next 30 years
(Coates et al. 2016). Therefore, at the current frequency and intensity of wildfires, or even higher as
projected, effects to sage-grouse would be moderate to major under the No Action Alternative, depending
on the amount and type of habitat lost to wildfire. Effects to other sagebrush-obligate and associated bird
species in terms of habitat loss and fragmentation would be similar to those for sage-grouse. The exception
would be any species that also uses annual grasslands, such as the long-billed curlew. Impacts to this
species would be negligible or even beneficial.
Pygmy Rabbit
Pygmy rabbits would be affected in a similar manner as sage-grouse under the No Action Alternative.
Direct impacts from wildfire and indirect impacts from habitat loss and fragmentation of patches of suitable
pygmy rabbit habitat would be more severe for pygmy rabbits than sage-grouse due to their narrower
habitat requirements and limited mobility. Eventually, these changes in distribution of suitable habitat
could result in the isolation of populations. Effects to the pygmy rabbit would be moderate to major under
the No Action Alternative, depending on the area and amount of habitat lost to wildfire.
Under the No Action Alternative, effects to kit fox and dark kangaroo mouse would depend on overlap of
wildfire and the species’ small distribution. In areas without overlap, effects to kit fox and dark kangaroo
mouse would be negligible, whereas effects from wildfire could be major for these two species when it
overlaps with the small area(s) where they occur and, thus potentially be detrimental to the population or
even the species distribution within the region. In contrast, impacts to the Piute ground squirrel would be
negligible to minor since they occur in associated habitats including annual grasslands, albeit at lower
densities. They may persist in areas where perennial grasses or forbs remain for forage.
Golden Eagle
The continued loss of sagebrush would reduce the availability of golden eagle’s preferred prey, black-tailed
jackrabbits, and thus wildfire would negatively affect golden eagles because occupancy and reproductive
success are related to jackrabbit abundance (Steenhof et al. 1997). In a long-term study in southwestern
Idaho, golden eagles continued occupying the same territories after wildfire when they could expand their
home range into vacant, adjacent territories, but reproductive success declined (Kochert et al. 1999).
Therefore, the continued loss of sagebrush due to wildfires would have minor to moderate effects on golden
eagles. Short-eared owls would be affected similarly to golden eagles since they typically do not inhabit
annual grasslands (Miller et al. 2017). Impacts to ferruginous hawk and burrowing owls would be
negligible to minor since the Piute ground squirrel, a common prey item of both species, is often able to
colonize areas converted to annual grasslands.

Bighorn Sheep
Under the No Action Alternative, effects in terms of habitat loss and degradation would be similar for
bighorn sheep and other big game species as for sage-grouse. These species depend on healthy native
vegetation and are threatened by wildfire and invasion of non-native vegetation and noxious weeds, among
other threats. New and recurring wildfires in the project area would further reduce native vegetation and
suitable big game winter habitats. Areas that remained intact would become degraded from increased use
and pressure of big game and other browsers or grazers. Effects would be greatest for mule deer and
wintering pronghorn because they depend on shrublands for forage and cover. Therefore, depending on
species and location, impacts would be minor to moderate.

Treatment objectives would be to modify existing vegetation within the fuel break to create and maintain a
network of fuel breaks. Methods would include mowing, hand cutting, seeding, prescribed fire, targeted
grazing, chemical treatment, roadbed vegetation removal, or development of mineral material sites.
Treatments would result in direct and indirect impacts to wildlife.
Direct effects to wildlife during project implementation may include anthropogenic disturbance and noise
from equipment or operators, crushing or trampling of individuals or nests due to equipment or livestock
trampling, and direct spray or contamination by herbicide. Most of these impacts would be minimized or
avoided with design features (Appendix G) that include seasonal or timing restrictions, disturbance buffers
for breeding and wintering sage-grouse, big game seasonal habitat, and active raptor nests, as well as
measures to prevent burrow collapse for BLM SSW, such as pygmy rabbits. Occasionally, treatment and
equipment use may be necessary during the spring for seedbed preparation (e.g., after fall herbicide
application, noxious weeds may sprout in the spring).
Indirect effects to BLM SSW, including sage-grouse, pygmy rabbit, golden eagle, and bighorn sheep, from
the action alternatives would include habitat loss, degradation, and fragmentation; decreased food or prey;
decreased cover; increased predation; decreased reproductive success; habitat avoidance; and potential
movement barriers (Table 3.5-8). Once established, vegetation within the fuel break could provide cover
for some small mammals, reptiles, and ground-nesting birds such as horned larks. Other wildlife may use
these areas only temporarily for feeding or travel. Some species, in particular sagebrush obligates, may
avoid treatment areas short-term or completely due to lack of appropriate cover or food.
Table 3.5-8. Potential direct and indirect effects to wildlife from project implementation.
Type of Treatment Method(s) Impacts on Wildlife Design Features to Avoid or
Effect Minimize Impacts *
Direct All (Disking, Mowing, Visual and acoustic disturbance from Seasonal and Timing Restrictions;
Hand-cutting, Seeding, human activity and equipment noise Avoidance buffers
Herbicide, Prescribed during critical life stages may result in
Fire, Roadbed Vegetation stress, reduced survival, nest
Removal, Mineral abandonment.
Material Site
Development)
All except Chemical Ground disturbance, including Seasonal and Timing Restrictions;
Treatment vegetation removal, may result in Avoidance buffers
mortality of individuals, loss of nests,
or burrows. Potential collision of sage-
grouse with temporary fencing.
Chemical Treatment Direct spray of individuals or Where feasible, avoid application
prey/food, indirect contamination during critical life stages. Use SOPs
from prey, loss of food for herbivores

Type of Treatment Method(s) Impacts on Wildlife Design Features to Avoid or
Effect Minimize Impacts *
for herbicide application. Avoidance
buffers.
Targeted Grazing Trampling of Use collision markers on any
individuals/nests/burrows and reduced temporary fencing within 1.2 miles
cover and forage. Human activity and of occupied leks. Surveys for BLM
disturbance associated with set-up and SSW. Seasonal restrictions and
maintenance of stock tanks and avoidance buffers. Use bird ladders
supplements. Potential collision of in stock tanks.
sage-grouse with temporary fencing.
Drowning in stock tanks.
Indirect All Habitat loss, habitat degradation, Avoidance of priority wildlife
habitat fragmentation; but some habitats during development of
benefit of habitat preservation and Alternative 4.† Treatment monitoring
protection (for non-native plants) and follow-up
herbicide application. Place stock
tanks and supplements in areas with
existing disturbance. Conduct
prescribed burns when soils are
frozen or moist.
*
Design features are described in Appendix G.
†
See section 2.5 for a description of measures considered during development of Alternative 4.
In addition to loss of habitat within the fuel break, action alternatives could contribute to habitat
degradation and fragmentation. Areas in or adjacent to the fuel break could become degraded by invasion
of non-native vegetation, although these effects would likely be negligible due to chemical treatments
following treatment monitoring, where needed. Overall, fuel breaks would add to habitat fragmentation of
sagebrush habitats, particularly where fuel breaks are dominated by non-native vegetation or bare to low
ground cover. Effects to habitat connectivity and animal movement would be greatest along hard habitat
edges, such as sagebrush next to annual grassland, agricultural areas, or juniper, but effects to connectivity
and movement would be less along soft habitat edges of the different types of native habitats that sage-
grouse use (e.g., perennial grasslands or riparian areas). For some animals that require cover for movement
and are at high risk of predation in areas without cover, such as the pygmy rabbit, even soft habitat edges,
including fuel breaks remaining as native vegetation, have the potential to affect movements and habitat
connectivity. For example, effects would be greatest for these animals in sagebrush communities within the
fuel break that are intersected by narrow two-track roads (approximately 10 feet wide), which would be
manipulated (i.e., removal of roadbed vegetation plus mowing or seeding up to 200 feet on each side of the
road). Effects would be significantly lower along well-traveled roads (e.g., paved or gravel) where there is
existing fragmentation associated with road disturbance. Habitat fragmentation would negatively affect
wildlife due to increased predation risk along corridors of replacement habitat or habitat edges, reduced
fitness (survival, reproduction), and, in extreme cases, could isolate populations (Bennett and Saunders
2010). However, as a result of large wildfires and landscape conversion to annual grasslands, habitat
fragmentation is already occurring at a much larger spatial scale than that of the proposed fuel breaks.
Over the long term, establishment of fuel breaks as specified in the action alternatives is expected to
improve fire suppression activities, reduce fire size, and protect remaining sage-grouse habitat and other
important BLM SSW habitats. Creating a strategic network of fuel breaks would also meet identified
management objectives for sage-grouse (Governor’s Task Force 2012; FIAT 2014). By reducing the
potential for large fires and protecting recovering vegetation and restoration areas from future fires, fuel
breaks may improve the recovery and successful restoration of natural and seeded plant communities that

mostly consist of sagebrush steppe. In the long run, the action alternatives could improve habitat restoration
efforts for wildlife species that require or favor sagebrush steppe habitats for breeding, hiding, thermal
cover, and foraging. The fuel break network may also protect areas of intact habitat by reducing large
wildfires and subsequent conversion to non-native annual grasslands, followed by habitat loss and
fragmentation of sagebrush steppe.
Targeted Grazing
Targeted grazing would be limited to cattle to avoid the risk of respiratory disease transmission to bighorn
sheep. Topographic barriers, herding, or temporary electric fencing would keep cattle out of adjacent
habitats and avoid potential impacts due to trampling or reduced nesting cover. Design features (Appendix
G) would minimize potential human disturbance associated with stock tank placement and maintenance.
Due to their heavy bodies and small wings, sage-grouse are at higher risk of collision with fences compared
with other bird species (Bevanger 1998; Stevens et al. 2012; Hovick et al. 2014). However, design features
would avoid and minimize sage-grouse collisions by avoiding temporary fencing within 1.2 miles of
occupied leks and, where needed, the placement of collision diverter devices (Appendix G). Generally,
fencing does not lead to an increase in predation risk for sage-grouse or other wildlife (Trombulak and
Frissell 2000). This would be particularly true for temporary fencing where perch opportunities are limited
for avian predators.
Cattle may trample individual animals or, nests, or cause the collapse of burrows, particularly where
livestock would be concentrated around stock tanks or supplements. The degree to which breeding success
of ground-nesting birds or other fossorial species may be impacted by cattle depends on stock density,
existing vegetation conditions (e.g. low vs. high annual precipitation), soils, and the species biology and
behavior (Redmond and Jenni 1986; Holmes et al. 2003; Clarke 2006). Sage-grouse nests are rarely
affected by trampling since nests are typically placed under sagebrush (Schroeder et al. 1999). Sage-grouse
would not likely be affected by targeted grazing since treatment plans would restrict cattle to the fuel break,
where habitat would be unsuitable for sage-grouse nesting due to reduced sagebrush cover and height
and/or the amount of non-native vegetation. Impacts from targeted grazing to individuals, nests, or burrows
of BLM SSW would be unlikely due to design features to protect occupied burrows for species such as
burrowing owl, pygmy rabbit, or dark kangaroo mouse. Bird ladders would be required for stock tanks in
order to reduce associated bird, bat, rodent, and other small mammal mortalities.
Mowing
Most direct impacts to wildlife due to mowing would be avoided with seasonal restrictions (i.e., February 1
through July 31) to protect nesting sage-grouse, migratory birds, and other sagebrush-obligate or associated
wildlife in or adjacent to the fuel break. However, for small animals, such as lizards or small mammals,
which may use the fuel break year-round, mortality may occur if they are unable to move out of the way of
equipment or they may be permanently displaced. Equipment noise and human activity associated with
mowing could impact wildlife in and adjacent to the fuel break due to visual and audible disturbance.
While the response differs by species and among individuals, it is anticipated that human activity could
cause stress or temporary displacement. Overall, design features include applicable timing, seasonal, and
spatial restrictions and would avoid mortalities or loss of nests and reduce disturbance, stress, and
temporary displacement of BLM SSW and big game, particularly during critical life stages (Appendix G).
In addition, within 328 feet of occupied pygmy rabbit territories, initial treatment at least one year before
mowing would consist of hand cutting to avoid burrow collapse and potential mortality from use of heavy
equipment.

Lowering and/or removing the shrub canopy would impact most wildlife species by reducing habitat, as
well as possibly degrading native habitat. Mowing would reduce shrub cover and height to 6-10 inches,
making areas marginal to unsuitable for sage-grouse and other sagebrush-obligate species. With the
immediate removal of shrub cover, available hiding and thermal cover would be reduced, as well as forage.
After a growing season, grasses and forbs would recover and provide some cover and forage. However,
after several growing seasons, fuel break maintenance would involve re-mowing, again reducing the
sagebrush cover and height.
Over the long term, some species would benefit from reduced shrub cover and others may avoid these
areas. Generally, mowing sagebrush does not result in habitats that meet sage-grouse guidelines (Hess and
Beck 2012) or criteria for suitable habitat for pygmy rabbits (Rachlow et al. 2005). Even several years after
treatment, shrub cover would be at least 14-24% lower (Dahlgren et al. 2006, Swanson et al. 2016).
Sagebrush cover and height would be reduced each time the fuel break is maintained and shrubs removed.
Species that would benefit from mowing are those that prefer more open habitats or edges. For example,
jackrabbit and cottontail rabbits may increase along newly created habitat edges of fuel breaks (Pierce et al.
2011). Predators would benefit from improved foraging efficiency due to better visibility (with reduced
cover) and movement corridors along roads and fuel breaks.
Mowing may release herbaceous vegetation, resulting in an increase in perennial grasses (Dahlgren et al.
2006; Swanson et al. 2016), which some species would utilize for forage and cover. However, in other
areas, particularly where annual grasses are present in the understory, mowing may increase annual grass
cover (Davies et al. 2012). An additional effect of mowing includes the potential for invasive species to
establish or spread within the fuel break and into adjacent wildlife habitat. Generally this results in reduced
or lost habitat function for most wildlife species. However, these effects are expected to be temporary and
short-term and would be minimized with treatment monitoring and subsequent application of herbicides
and revegetation efforts. Over time, impacts to wildlife may be offset by the benefits of fuel breaks to
sagebrush-obligate species by augmenting the ability of firefighters to contain and control wildfires,
thereby potentially reducing the number of acres of sagebrush habitat lost to future fires and subsequent
conversion to invasive annual grasslands.
Hand Cutting
Hand cutting would be used in rugged terrain or close to other sensitive resources to reduce canopy cover
and height of shrubs within the treatment footprint, similar to mowing. Hand cutting would also be used
around occupied pygmy rabbit territories in order to reduce the likelihood of burrow collapse while still
meeting treatment objectives. Direct impacts, such as disturbance or mortality, would be avoided with
seasonal restrictions (Appendix G). Indirect effects of hand cutting would be the reduction in available
forage, hiding and thermal cover, similar to mowing. Functionality of shrubland habitat would be reduced
in these areas but to a lesser extent than with mowing, because ground disturbance would be minimal and
some intact stands would be maintained. The potential spread of annual plant species (due to release of
shrub cover) would have similar effects as those described for mowing, but would likely be less due to the
lower impacts on soils. The benefits associated with protecting habitat and restoration investments would
be similar to those described for mowing.
Chemical Treatment
Chemical treatments may occur during seedbed preparation, as part of roadbed vegetation removal
activities in order to maintain bare soils, or after any treatment method to control the spread of invasive
plant species and noxious weeds. Impacts from chemical treatments on wildlife vary depending on the type
of herbicide and duration and mechanism of exposure, as well as species’ diet. Effects from herbicide
application on wildlife are described in previous documents which are hereby incorporated by reference

(USDI BLM 2007a; USDI BLM 2007b; USDI BLM 2010a; USDI BLM 2016a; USDI BLM 2016b; USDI
BLM 2018a). These documents include SOPs, BMPs, and conservation measures to reduce impacts on
wildlife. Risks include direct spray and spills, indirect contact with foliage after direct spray, and ingestion
of contaminated food items after direct spray. Ingestion of contaminated food is generally low or non-
existent for terrestrial fauna, with few exceptions, particularly for mammalian herbivores and pollinating
insects. Birds, mammals, or insects consuming grass sprayed with herbicides and birds and mammals
consuming insects have relatively greater risk for harm than animals foraging on other vegetative material,
because herbicide residue is higher on grass. Potential effects from herbicide application would depend on
location, species with restricted movements, and individuals who primarily use treatment areas for
foraging, as well as the type of herbicide. At typical application rates, most herbicides pose no to low risk
for herbivores, insectivores, and avian or mammalian predators (USDI BLM 2007a). For herbicides which
pose moderate to high risk to herbivore or insectivores, i.e. 2,4-D and triclopyr, spot spraying and/or timing
restrictions would minimize impacts to BLM SSW (Appendix G).
Human activity and anthropogenic disturbance (e.g., tractors) would result in temporary disturbance to
wildlife. Wildlife response to disturbance would be similar to that described for mowing. Overall, design
features would reduce potential exposure or contamination during critical life stages and reduce disturbance
to wildlife through seasonal and timing restrictions as well as disturbance buffers. In some cases, herbicide
application would be necessary during critical life stages (i.e., the breeding season). During these time
periods, disturbance to species such as raptors has the potential to result in nest failure or abandonment.
When spring chemical treatments are needed, project leads would work with a biologist to reduce potential
impacts through visual barriers, nesting phenology, duration and timing of disturbance, and follow FWS
recommendations (USDI FWS 2008). Any herbicide application within sage-grouse nesting habitat would
follow existing guidance (USDI BLM 2015a; USDI BLM 2019a; USDI BLM and USDA FS 2015; USDI
BLM 2019b).
While the level of risk from herbicides is low, adverse effects to wildlife could occur. Although chemical
treatments may sometimes be necessary during the breeding season (e.g., to control sprouting invasive
species or noxious weeds), areas requiring such treatment would likely provide little forage or habitat value
to wildlife, thus reducing contamination risk to wildlife. In addition, herbicides which pose moderate to
high risk to wildlife would be avoided when possible. When the use of herbicides that pose a moderate to
high risk to wildlife is required, these herbicides would be applied by spot spraying at typical application
rates (Appendix G). Over the long term, reducing the negative impacts from non-native vegetation and
noxious weeds (i.e., habitat reduction or degradation) would lead to improved conditions for wildlife across
the landscape. The benefits of using herbicides as proposed outweigh the associated risks and would help
avert future habitat loss and degradation associated with wildfire. These general effects apply to all the
wildlife species discussed below.

Fuel breaks may or may not require seeding and/or seedbed preparation such as disking or chemical
treatments to reduce competition prior to planting. Just as with the other treatment methods, human activity
and anthropogenic disturbance from equipment could disturb wildlife. However, design features with
seasonal restrictions and disturbance buffers would reduce impacts to sage-grouse, migratory birds, raptors
and other BLM SSW within or immediately adjacent to treatment areas. Seasonal restrictions for disking
would also reduce impacts to BLM SSW that use burrows. Immobile young would not be affected since
disking would occur outside of the breeding season. Adults would either move out of harm’s way by
escaping, retreating into deeper burrows, i.e. farther than the 6” deep from disking or seeding, or dig their
way out of deeper burrows. Potential impacts to wildlife resulting from herbicide application are discussed
in the previous section on Chemical Treatment.

Temporary fencing to protect seeded plants in fuel breaks during seedling establishment may be necessary
in cases where conflicts with regularly permitted livestock are unavoidable. Use of a wildlife friendly fence
design that employs a smooth bottom wire would reduce injuries to wildlife. Temporary fences would be
avoided within 1.2 miles of occupied or pending sage-grouse leks and would comply with all designated
wildlife standards (USDI BLM 2015a; USDI BLM 2019a; USDI BLM and USDA FS 2015; USDI BLM
2019a).
Changes in vegetation resulting from seeding may benefit some wildlife and harm others. Increasing
perennial grass cover in mowed areas, for example, would benefit a variety of species. Big game and small
mammals, such as the pygmy rabbit, may benefit from increased forage and cover. It would also reduce the
risk of invasion of annual grasses and forbs. On the other hand, planting non-native vegetation would
generally have negative impacts on wildlife by reducing native habitat, providing limited forage, and
reducing cover. In contrast to crested wheatgrass, prostrate kochia is one of the non-native plants proposed
for seeding which may be used by some wildlife for food and cover, including pronghorn and Piute ground
squirrels. While planting non-native vegetation may reduce native wildlife habitat, these treatments are
proposed to maximize the local efficacy of a fuel break.
Prescribed Fire
Seasonal restrictions would minimize disturbance to important big game habitats (wintering,
calving/fawning/lambing), and breeding sage-grouse and other sagebrush-obligate species, as well as
raptors (Appendix G). Treatment would occur when the surrounding vegetation has a high enough live fuel
moisture content to prevent further spread of the fire, typically in the late fall/winter or spring; thus
reducing the likelihood of prescribed fire burning into adjacent vegetation. Wildlife species are likely to
temporarily avoid areas associated with prescribed fire activities; however, this disruption is anticipated to
be minimal and short in duration, with little effect on a majority of wildlife species. Where prescribed fire
activities may overlap with nesting season of raptors, disturbance buffers would be maintained as described
in Appendix G, thereby minimizing any impacts on nesting raptors. After a prescribed burn, follow up
treatments, such as chemical treatment and/or seeding, would prevent the invasion of annual grasses.

Most direct impacts to wildlife due to roadbed vegetation removal would be avoided with applicable
timing, seasonal, and spatial restrictions. These restrictions would avoid mortalities or loss of nests and
reduce disturbance, stress, and temporary displacement of BLM SSW and big game, particularly during
critical life stages (Appendix G). Outside of the seasonal and timing restrictions, equipment noise and
human activity associated with roadbed vegetation removal could impact wildlife in and adjacent to the fuel
break due to visual and audible disturbance resulting in stress or temporary displacement. Most wildlife
species, except small animals that may utilize the fuel break year-round, would be able to move out of
harm’s way of any equipment or associated human activity and would be only temporarily displaced.
The degree of indirect impacts to wildlife due to roadbed vegetation removal would depend on the type and
extent of existing vegetation within the roadbed, species’ habitat requirements, as well as the type of
equipment and methods used to remove vegetation, e.g. blading vs. hand cutting. For example, removing
roadbed vegetation with little existing habitat value would have no impacts to sage-grouse, while treating
roads with sagebrush cover with some habitat value would have an impact commensurate with the extent of
sagebrush removed. These impacts would only occur once with the initial treatment and creation of a hard
habitat edge, after which the roadbed would be periodically maintained. A few wildlife species would
benefit from the reduced cover and improved movement corridors, while other species may avoid these
areas or experience reduced survival or nest success.

Use of roads may increase in localized areas where roadbed vegetation previously limited drivability,
resulting in an increase in human presence, recreation, and motorized vehicles. Wildlife would be
temporarily (flush response) or permanently (avoidance) be displaced due to human or motorized
disturbance (Knight and Gutzwiller 1995). Disturbance due to human presence, particularly motorized
vehicles, would result in increased stress levels for some wildlife species and would be greatest during
critical life stages (i.e. breeding/nesting, winter). Impacts on wildlife from any increased use of roads
associated with roadbed vegetation removal would vary with location, season, and existing roadbed
vegetation. Any increases in use would likely reflect existing seasonal variability in use patterns, occurring
mostly in the fall during hunting season.
Due to soil disturbance, roadbed vegetation removal may make areas vulnerable to the establishment and
spread of invasive species within the fuel break and into adjacent habitat. Invasive or non-native species
would reduce or degrade habitat for many wildlife species, particularly those dependent on native
vegetation, such as sage-grouse. However, these effects are expected to be temporary and short-term and
would be minimized with treatment monitoring and subsequent application of herbicides. Effects of
herbicide application on wildlife are discussed above, under Chemical Treatment. Over time, cleared roads
in the fuel break network would contribute to better protecting habitat and restoration efforts from wildfire
by providing reliable, safe anchor points for wildland firefighters.

Mineral material sites would only be developed in Oregon. Potential impacts to wildlife would include
habitat loss and visual and audible disturbance due to human activity and equipment noise during
operations. The total footprint of the mineral material sites, which consist of degraded vegetation due to the
2012 Long Draw Fire, is 80 acres, and less than 1% of any BLM SSW or big game habitat within the
project area. While the response differs by species and among individuals, it is anticipated that human
activity could cause stress or temporary displacement. Blasting and crushing activities are anticipated to be
the most disruptive to wildlife due to the human presence and associated noise, but would be temporary to
short-term, i.e. several days for blasting and a few months at a time for crushing. Most wildlife species are
likely to avoid areas associated with rock pit operations, and any disruption is anticipated to be short-term,
with little effect on the majority of wildlife species. Slow-moving animals, such as lizards and small
mammals, and fossorial species, such as ground squirrels, could be crushed by equipment or experience
burrow collapse, or be permanently displaced. However, potential impacts to fossorial species are unlikely
since the mineral material sites were selected due to their rocky soils which are not conducive to digging
burrows. Overall, disturbance associated with operations or crushing due to equipment use would be short-
term. In the long term, rehabilitation efforts would include revegetating disturbed areas where small
animals may become reestablished. Overall, impacts to BLM SSW would be avoided and minimized with
design features, including seasonal and timing restrictions as well as disturbance buffers for nesting raptors
(Appendix G).
All treatment methods may be used under Alternative 2. General impacts to wildlife are described in
section 3.5.2.5, Effects Common to All Action Alternatives and include direct (e.g. disturbance, collision)
and indirect impacts. Long-term impacts would include habitat loss, habitat degradation, increased
predation, habitat fragmentation, and avoidance. Some areas would not contribute to habitat loss or
fragmentation, such as riparian areas or treated areas which would remain native vegetation, would not be
treated.

Greater Sage-Grouse
An estimated 242 occupied or pending leks (91 percent), or 200 lek complexes, lie within 4 miles of the
fuel breaks under Alternative 2 (Table 3.5-9), mostly in Oregon. Fuel break construction and maintenance
may adversely affect the core areas17 of 181 leks or 150 lek complexes, or 68% of leks within the SGAA
(Idaho: 64%; Oregon: 72%). Approximately 35% and 72% of the proposed fuel breaks would be within 2
and 4 miles of leks, respectively.
Table 3.5-9. Number of leks and lek complexes affected by Alternative 2 and miles of fuel breaks
within nesting habitat around occupied or pending leks.
Leks / Complexes * Miles of Fuel Breaks †
Distance from Leks
Idaho Oregon Total Idaho Oregon Total
2-miles 96 /84 85 / 66 181 / 150 270 267 537
4-miles 126 / 112 116 / 88 242 / 200 507 605 1,112
*
There are a total of 265 leks and 223 lek complexes in the SGAA.
†
Total miles of fuel breaks under Alternative 2: 1,539 miles.
Under Alternative 2, a total of 65,636 acres of designated sage-grouse Habitat Management Areas (HMAs)
would be removed or altered, or 2% of the 4 million acres of HMA in the SGAA, including 49,385 acres of
PHMA (Table 3.5-2). On average, 4% and 2% of potential nesting habitat 18 would be affected within 2
miles and 4 miles of occupied or pending leks, respectively (Table 3.5-4). In terms of landscape cover of
sagebrush around leks, an average of 1% of nesting habitat would be removed under Alternative 2, but not
more than 5% of the landscape for any given lek (Table 3.5-5). The amount of landscape cover that would
be removed under Alternative 2 would be lowest for areas with < 25% sagebrush cover with an average of
0.2% and highest for areas with >65% sagebrush cover, i.e. 1.8%.
Design features, such as timing restrictions during lekking and seasonal restrictions on mechanized use
during breeding seasons and in winter habitat, would avoid or reduce the potential adverse effects of fuel
break construction and maintenance (Appendix G). In Oregon, treatments would not occur in sage-grouse
late brood-rearing habitat. In addition, design features for herbicide application would minimize potential
disturbance to nesting sage-grouse (Appendix G).
Indirect effects to sage-grouse resulting from fuel break implementation would vary depending on several
factors: existing levels of disturbance and habitat fragmentation, existing vegetation and condition,
treatment method and timing, and location. For example, adding fuel breaks along paved or well-traveled
gravel roads (minimum width of 20-30 ft) with existing levels of disturbance and habitat fragmentation
would have negligible to minor impacts. Ten percent of routes in Alternative 2 (i.e. 151 out of 1539 miles)
are along paved roads Highway 51 in Idaho and Highway 95 in Oregon. Habitat suitability along heavily
used roads is reduced and results in avoidance behavior and reduced lek attendance (Holloran 2005) as well
as lower nest initiation rates (Lyon and Anderson 2003). In contrast, implementing a fuel break along a
narrow, vegetated two-track road close to a sage-grouse lek and replacing native vegetation with non-native
vegetation or bare soils would reduce and further fragment sage-grouse habitat. Under Alternative 2, up to
63% of the roads within the project area may require roadbed vegetation removal, or 419 of 731 miles in
Idaho and 558 of 808 miles in Oregon.
17
Core areas for sage-grouse are within a two mile radius of leks, as defined by the RAC subcommittee and Connelly et al.
(2000).
18
Potential sage-grouse nesting habitat: areas with ≥10% sagebrush cover (Homer et al. 2012).

Where native vegetation remains, sage-grouse may use established fuel breaks during foraging (Graham
2013; Michael McGee, BLM Biologist, Personal Observation 2015), but tend to stay close to treatment
edges where there is cover (Dahlgren 2006). Native grasses and forbs in the fuel breaks may provide forage
for sage-grouse, but overall cover would be reduced. During the first growing season following treatment,
adult sage-grouse and particularly young chicks would be vulnerable to predation within the fuel breaks
due to reduced cover. Any nests close to habitat edges may experience higher levels of predation (Aldridge
and Boyce 2007; Graham 2013), due to the likely increased presence of predators using the expanded
corridors for travel and foraging (Forman and Alexander 1998).
Alternative 2 would have moderate short- and long-term impacts on sage-grouse, resulting in habitat loss
and fragmentation, habitat degradation, avoidance behavior, increased predation, and to a lesser extent
disturbance, i.e. during herbicide application and any treatments in winter habitat. Alternative 2 would
reduce landscape cover of sage-grouse nesting habitat by an average of 1%. Targeted grazing could affect
sage-grouse due to collisions with temporary fencing or invasion of non-native vegetation when stock tanks
or supplements are placed outside areas of existing disturbance or in sage-grouse habitat. Generally, these
types of potential impacts due to targeted grazing would be avoided with design features (Appendix G).
Overall, Alternative 2 is not likely to affect sage-grouse populations because the potential effects on the
amount of sage-grouse habitat is small compared to the amount of available habitat within 4 miles of
occupied or pending leks within the SGAA, i.e. 2% of nesting habitat potentially affected. Furthermore,
only 2% of all designated sage-grouse habitat in the SGAA would be affected under Alternative 2,
including 2% of PHMA (Table 3.5-2), and the reduction of sagebrush landscape cover under Alternative 2
would be minimal.
Under Alternative 2, less than 2% of sage-grouse nesting habitat would be affected within each
subpopulation (based on fine-scale HAF; Table 3.5-10). Changes to habitat edges and, thus, fragmentation,
patch size, and connectivity would primarily occur where native vegetation is replaced with non-native
vegetation during fuel break implementation, and to a lesser extent, where native vegetation remains but
with less vegetative cover and reduced heights. This would likely be less than 29% of the fuel breaks within
the project area (Table 2-2). Densities of linear features currently range from 0.27 miles per square mile in
the Owyhee Canyonlands subpopulation to 1.03 miles per square mile in the Cow Lakes subpopulation.
Under Alternative 2, densities of linear features would not increase, since fuel breaks would be constructed
along existing roads. Over the long term, the establishment of a fuel break network is expected to protect
larger patches of sage-grouse habitat from future wildfire and may reverse the trend in loss of sagebrush
habitat in the SGAA and in the subpopulations.
Table 3.5-10. Acres of occupied sage-grouse habitat* in subpopulations and acres impacted by each
action alternative.
Acres % of Acres
Occupied
Subpopulation Occupied Habitat in Alt 2 Alt 3 Alt 4
Total
(Fine-scale HAF) Habitat SGAA
Cow Lakes 1,320,032 211,901 4 0 0 0
Soldier Creek 1,219,707 157,386 82 2,673 2,483 786
Louse Canyon 2,181,685 168,588 43 1,593 804 455
Owyhee Desert 1,213,777 85,986 21 92 70 59
Owyhee Canyonlands 1,877,252 549,528 96 8,277 4,687 3,730
Antelope Ridge 517,684 149,521 30 860 860 494
Total 8,330,137 1,322,910 -- 13,495 8,904 5,524

*
Occupied sage-grouse habitat was determined by overlaying occupied sage-grouse habitat from subpopulations (based on
fine-scale HAFs) and ≥10% sagebrush cover (Homer et al. 2012).
The construction of mineral material sites would cause an additional loss (less than 1% of the GHMA
within the SGAA) of potential sage-grouse habitat. Three of the four material sites are within GMHA and
one is outside of designated sage-grouse habitat. One site is 2.6 miles from an occupied pending lek and the
other three sites range in distance from leks from 3.7 miles to 5.2 miles (Table 3.5-11). Together, the three
sites in GHMA would disturb up to 60 acres of potential sage-grouse habitat. The selection of the sites was
based on the presence of surface rocks and gravels that are usually accompanied with sparse vegetation and
not high quality sage-grouse habitat. Additionally, all four material sites were burned in the 2012 Long
Draw fire (Map 25, Appendix Q). The fire burned sagebrush and reduced the habitat quality for sage-
grouse and other sagebrush-obligate wildlife. Due to the type of habitat and lack of sagebrush following the
2012 fire, sage-grouse or sagebrush obligates are unlikely to use the proposed material sites as habitat, and,
therefore, impacts would be minimal. Design features, such as timing restrictions during lekking and
seasonal restrictions on mechanized use would avoid or reduce potential adverse effects (Appendix G).
Table 3.5-11. Proposed mineral material sites - Distance from leks.

Site Distance in miles
Antelope Reservoir 5.2
Big Antelope Creek 4.4
Deadman Waterhole 3.7
White Chicken 2.6
Pygmy Rabbit
Direct and indirect effects to pygmy rabbits would be similar to impacts to sage-grouse in terms of habitat
loss, degradation, and fragmentation. However, pygmy rabbits have narrower habitat requirements than
sage-grouse. Thus, reducing suitable pygmy rabbit habitat may have more localized impacts on pygmy
rabbits than similar reductions in sage-grouse habitat would have on sage-grouse. Impacts due to habitat
fragmentation would also be more pronounced than for sage-grouse due to the pygmy rabbit’s small body
size, limited mobility, high predation risk, and small home ranges. Overall, Alternative 2 would potentially
impact 34,116 acres of suitable pygmy rabbit habitat, or 2% of suitable pygmy rabbit habitat in the project
area (Table 3.5-6).
In order to reduce impacts from fuel break implementation (i.e. mowing, herbicide), surveys would be
conducted prior to project implementation and limited disturbance buffers would be established within 100
m (328 ft) of occupied pygmy rabbit burrows. Within this 100 m buffer, fuel breaks would be handcut
rather than mowed during initial treatment (Appendix G). Since roads do not comprise habitat for pygmy
rabbits and may act as movement barriers, buffers around occupied burrows would be restricted to one side
of the road. While this design feature would prevent burrow collapse and mortality from equipment, the
reduction in sagebrush cover and height would render habitat in these areas unsuitable for pygmy rabbits.
Indirect impacts to pygmy rabbits would include habitat loss and habitat fragmentation. The reduction of
sagebrush in the fuel break due to mowing or hand cutting would result in loss of food availability and
cover. Similarly, in two track roads with suitable habitat (i.e., high sagebrush cover), roadbed vegetation
removal would result in the loss of occupied pygmy rabbit habitat in order to create the hard break in fuel
continuity necessary for an effective fuel break. In response to a reduction in cover and suitable habitat,
pygmy rabbits may try to disperse from the treatment areas. Some individuals may be able to establish a
territory or burrow system in unoccupied areas adjacent to the fuel break. However, due to the species’

limited mobility and high predation risk, it is uncertain whether affected individuals may successfully
disperse.
Habitat fragmentation may affect pygmy rabbits due to avoidance of habitat edges and increased predation,
potentially restricting their movements. In addition, due to their limited movement and dispersal abilities,
they are particularly sensitive to connectivity of sagebrush habitats. In general, pygmy rabbits are
considered a species with limited movement ability and unwilling to cross open areas without cover (USDI
FWS 2010b), but occasional crossings of gravel roads and creeks have been documented (Estes-Zumpf and
Rachlow 2009). In Utah, pygmy rabbit occupancy and abundance were lower within 100 meters (328 feet)
of habitat edges after mechanically treating sagebrush versus areas further away from habitat edges (Pierce
et al. 2011). Predators and competitors, such as jackrabbits and cottontails, were numerous along habitat
edges. Generally, pygmy rabbits avoided treatment areas or stayed close to cover at the edge of treatments
(Wilson et al. 2011). It is not clear whether pygmy rabbits would persist within 100 m of treatment areas or
whether these areas would be avoided by pygmy rabbits. To some extent, this may depend on connectivity
with adjacent sagebrush habitat and suitable pygmy rabbit habitat. Furthermore, it is unknown whether the
reduced cover within the fuel breaks would constitute a movement or dispersal barrier for pygmy rabbits,
although any effects would most likely be limited to the first year post-treatment.
Idaho only supports 27% of the habitat for the entire range of pygmy rabbits and the project area is not
considered a core area for the species (Smith et al. 2019). Based on the habitat model (Smith et al. 2018),
there are 945,126 acres of pygmy rabbit habitat in the project area and of those acres, 34,116 acres or 2% of
pygmy rabbit habitat could be impacted by the proposed action. Impacts would include loss and
fragmentation of habitat. Rabbits in the treatment area would be more vulnerable to predation due to loss of
cover and during dispersal from treated areas. The likelihood of direct mortality to rabbits is negligible due
to design features (Appendix G).
While the model identifies 2% of the proposed treatment area as suitable habitat, past surveys for pygmy
rabbits indicate a patchy and discontinuous distribution within the proposed project area. Therefore,
although 2% of the treatment area is identified as pygmy rabbit habitat, the actual percentage of suitable
pygmy rabbit habitat that could be impacted from the proposed treatment is less than 2%. Because such a
low percentage of modeled habitat would be impacted and based on the findings of past surveys, population
level impacts would not result from implementation of the proposed action. Furthermore, surveys for
pygmy rabbits will continue to better identify their actual distribution, which will allow for design features
to be implemented in occupied habitat. Over the long term, the establishment of a fuel break network is
expected to protect larger patches of sagebrush and pygmy rabbit habitat from future wildfire and may
reverse the trend in loss of sagebrush habitat in the analysis area. Any future large wildfires in pygmy
rabbit habitat have a much higher likelihood of isolating patches of pygmy rabbit habitat and affecting
movement, dispersal, and pygmy rabbit populations than the proposed fuel breaks.
For other small mammals and BLM SSW, impacts would be similar to those for sage-grouse and pygmy
rabbit. Suitable kit fox habitat would also be reduced. Loss of sagebrush cover would not be a concern for
kit fox, but an increase of coyotes is possible along existing road corridors (widths from 10-30 feet) and
adjacent 400-ft wide fuel breaks which could impact kit fox. Overall, little is known about dark kangaroo
mouse habitat requirements. It likes sparsely vegetated areas with sandy soils, but has been found in
sagebrush steppe. Therefore, it is possible that treatment areas would retain dark kangaroo mouse habitat
functionality. Conversely, it is possible that with soil disturbance and compaction, burrows could be
impacted, habitat degraded, and eventually habitats fragmented in the subspecies’ small range. For Piute
ground squirrels, treatment impacts would be negligible to minor, as the species would likely be able to
adapt to vegetation changes. For all species, disking would occur outside of their breeding season.

The four mineral material sites in Oregon are not in known or modeled pygmy rabbit or dark kangaroo
mouse habitat and thus would not affect these species. Additionally, all four material sites were burned in
the 2012 Long Draw fire (Map 25, Appendix Q). One site is within known kit fox range. However, burrows
of kit foxes and other burrowing animals are not likely to be impacted, because the selection of the sites
was based on the presence of surface rocks and gravels that are not usually associated with the soil type
suitable for burrowing animals. Some wildlife may be negatively impacted by the increased noise and
human presence during rock pit operations, but those impacts would be temporary to short-term and most
wildlife would avoid these areas.
Golden Eagle
The main effects to golden eagles would include possible reduction of prey and disturbance (human
activity, equipment, etc.). For example, in localized areas the loss of sagebrush may reduce the availability
of golden eagle’s preferred prey, black-tailed jackrabbits, which is closely tied to the reproductive success
of golden eagles. Jackrabbits may decline with the reduction of sagebrush habitat. Conversely, jackrabbits
may increase along the new habitat edges of the fuel breaks (Pierce et al. 2011). Overall, treatments are not
likely to affect prey abundance within an eagle territory. In addition, some individuals may be able to adapt
by switching prey and/or expanding their home ranges.
Under Alternative 2, treatments would intersect core areas 19 of 33 known golden eagle territories, including
26 current and 6 historical territories in Oregon, and 1 in Idaho. Given the habitat and remoteness of the
project area, there are likely additional territories in Idaho. To the extent feasible, there would be no
anthropogenic disturbance (e.g. tractor, chainsaws, etc.) within 1.0 mile of active nests during the breeding
season. However, in some instances, spring treatment would be necessary. Fourteen (including 11 current)
of the 33 known territories mentioned above are within the 1-mile disturbance buffer, but many of these
nests are in canyons where birds would not see fuel break activities and thus would perceive little or no
disturbance. Fuel breaks may be visible from four of these territories (current: 2; historic: 2), depending on
exact nest locations. Disturbance associated with spring herbicide treatment or prescribed fire would be
temporary and only potentially affect these territories. Any reduction in the 1-mile disturbance buffer
would require consultation with FWS (Appendix G). Therefore, impacts would be negligible to minor to
golden eagles. In the long term, the proposed network of fuel breaks would benefit golden eagles and other
wildlife by minimizing the spread of invasive vegetation and reducing further habitat loss and
fragmentation affecting their prey. Impacts to other BLM SSW raptors would be similar to those for the
golden eagle.
All four mineral material sites in Oregon are located farther than 4.5 miles from any known golden eagle
nest. The effects from mineral material site activities would be similar to those described for pygmy rabbit,
with the addition of increased anthropogenic disturbance. Golden eagles may avoid the mineral material
site locations during the operating hours while blasting and crushing activities are taking place. Due to the
sites’ distance from known nests, any disturbance to eagles would be during foraging and individuals
respond by flushing and leaving the area temporarily.
Bighorn Sheep
Impacts to big game species may include the loss of cover and forage, particularly shrubs, forbs, and
grasses. In some areas, treatment response to mowing may be a short-term increase in perennial grasses,
which would increase forage for at least bighorn sheep and possibly other big game species. Overall,
Alternative 2 would result in the reduction or alteration of the following big game habitat: 11,725 acres
bighorn sheep habitat, 16,124 acres mule deer winter range, 16,038 acres of elk habitat, and at least 31,874
19
Core areas for golden eagles are within a 2 mile (3 km) radius of nests or territory centers (Kochert et al. 2002).

acres of pronghorn habitat (Table 3.5-7). In addition, due to an increased presence of predators along the
fuel break corridor, fawn, lamb, and/or calf survival could be reduced in some areas. However, overall, the
project would only affect 1-2% of habitat for each species in the project area, except for pronghorn in Idaho
where the project would affect 5% of pronghorn habitat. Impacts would be less than for sage-grouse or
pygmy rabbit due to the large home ranges and mobility of big game species. Disturbance in the winter
associated with project implementation would be localized and generally avoided with design features
(Appendix G). Therefore, impacts to big game species under Alternative 2 would be negligible to minor
due to the relatively small amount of habitat affected in the project area.
Impacts to bighorn sheep and other big game from the four Oregon mineral material sites are expected to
be negligible due to the small size of sites and site locations that are outside of critical big game habitat.
Although sites are not within critical big game habitat, big game animals may currently pass through these
locations. After site development, however, big game animals are expected to easily move around the 20-
acre sites to avoid the associated noise and human presence during periods of use.
In general, effects to wildlife would be similar for Alternative 3 as described under Alternative 2. The
effects from the Oregon material sites would be the same as described under Alternative 2. There would be
476 fewer miles of fuel breaks and 22,793 fewer acres impacted within fuel breaks. Therefore, impacts to
wildlife from fuel break implementation would generally be less than under Alternative 2 due to fewer
treatment acres and less resultant habitat loss and fragmentation, as well as lower risk of mortality, reduced
survival and reproduction, associated anthropogenic disturbance, and avoidance. Under Alternative 3, up to
38% of the roads within the project area may require roadbed vegetation removal, or 218 of 731 miles in
Idaho and 367 of 808 miles in Oregon. Compared to Alternative 2, 25% fewer miles of roads would require
roadbed vegetation removal under Alternative 3. However, long-term benefits of protecting larger patches
of sagebrush steppe would also be lower under Alternative 3 due to the smaller network of fuel breaks.
Greater Sage-Grouse
Under Alternative 3, there would be impacts to a total of 210 occupied or pending leks or 176 lek
complexes within 4 miles of the fuel breaks (Table 3.5-12), or 79% of occupied or pending leks within the
SGAA (Idaho: 80%; Oregon: 79%). There would be potential impacts to core areas around 144 leks or 118
lek complexes, or 54% of leks within the SGAA (Idaho: 55%; Oregon: 55%). In terms of miles of fuel
breaks, 34% and 72% of the proposed fuel breaks would be within 2 and 4 miles of leks, respectively.
Distance from Leks
2-miles 82 /72 62 / 46 144 / 118 188 173 360
4-miles 117 / 105 93 / 71 210 / 176 359 401 760
*
†
Total miles of fuel breaks under Alternative 3: 1,063 miles.
Compared to Alternative 2, within the SGAA, 14% and 12% fewer leks within 2 and 4 miles of fuel breaks,
respectively, would be impacted under Alternative 3. Compared to Alternative 2, 20,703 fewer acres of
sage-grouse habitat management areas would be affected (44,933 total acres HMA), including 15,539
fewer acres of PHMA (Table 3.5-2). In terms of potential nesting habitat, 7,981 fewer acres of potential
nesting habitat (17,810 total acres) would be affected within 4 miles of occupied or pending leks (Table
3.5-4). Alternative 3 would impact fewer leks and less sage-grouse habitat. In addition, Alternative 3 would

affect 0.3% less landscape cover of sagebrush compared to Alternative 2, averaging 0.7% (range: 0-4% per
lek; Table 3.5-5). Under Alternative 3, slightly less sage-grouse nesting habitat within each subpopulation
(based on fine-scale HAF; Table 3.5-9) would be affected compared to Alternative 2, ranging from <1% to
2% for the Soldier Creek subpopulation. Overall, impacts would be less compared with Alternative 2,
including impacts due to habitat loss, degradation, and fragmentation; landscape cover of sagebrush;
predation risk; and reduced survival and reproduction. Fewer acres of treatment would also mean fewer
potential fence collisions or other potential ground disturbance or habitat degradation due to targeted
grazing. However, with a smaller fuel break network, long-term benefits of protecting large patches of
sagebrush steppe may also be reduced. Overall, impacts on sage-grouse would be moderate, depending on
location and treatment method.
Pygmy Rabbit
Under Alternative 3, 22,486 acres of suitable pygmy rabbit habitat would be reduced or removed, or 2% of
suitable habitat in the project area (Table 3.5-6). This would be 11,630 fewer acres of pygmy rabbit habitat
removal compared to Alternative 2. Any differences in the level of impacts for Alternative 3 compared to
Alternative 2 to kit fox, dark kangaroo mouse, and Piute ground squirrel would be similar to those for sage-
grouse and pygmy rabbit. Impacts would be minor to moderate, depending on location and treatment
method.
Golden Eagle
Under Alternative 3, treatments would intersect core areas of 23 known golden eagle territories, including
14 (including 12 current) nests within the 1-mile disturbance buffer. Since the majority of these are in
canyons, only three of these territories and nest sites (current: 2; historic: 1) would be in viewing distance
of the proposed fuel breaks. This would be a slight reduction in potential impacts to golden eagles
compared to Alternative 2, and impacts would be negligible to minor to golden eagles. Any differences in
the level of impacts for Alternative 3 compared to Alternative 2 to ferruginous hawk, short-eared owl, and
burrowing owl would be similar to those for golden eagle. In the long term, the proposed network of fuel
breaks may benefit golden eagles and other wildlife by protecting large patches of sagebrush steppe from
future fires, minimizing the spread of invasive vegetation, and reducing further habitat loss and
fragmentation.
Bighorn Sheep
Alternative 3 would result in the following reduction of the affected big game habitats: 7,884 acres bighorn
sheep habitat, 13,925 acres mule deer winter range, 13,212 acres of elk habitat, and at least 22,681 acres of
pronghorn habitat (Table 3.5-7). Comparing these impacts to the habitat reduction expected under
Alternative 2, Alternative 3 would affect 33%, 14%, 18%, and 28% fewer acres of bighorn, mule deer, elk,
and pronghorn habitats, respectively. This would mean a 1% reduction in bighorn, 2% in mule deer and elk
habitats, and 3% in pronghorn habitat in Idaho. Therefore, impacts to big game species would be negligible
to minor. Any differences in terms of the extent of long-term benefits to big game realized under
Alternative 3 compared to Alternative 2 would be similar to those for sage-grouse and pygmy rabbit: fewer
acres treated and thus a smaller network of fuel breaks may provide less protection of large patches of
sagebrush steppe from future fires.
In general, effects to wildlife would be similar for Alternative 4 as described under Alternatives 2 and 3.
The effects from the Oregon material sites would be the same as described under Alternative 2. There
would be 629 and 153 fewer miles of fuel breaks compared to Alternatives 2 and 3, respectively, and
30,087 or 7,294 fewer acres impacted within fuel breaks. As a result, impacts to wildlife would be less
compared with Alternatives 2 or 3, but long-term benefits (i.e., protection of sage steppe habitat) may also

be lower due to the smaller network of fuel breaks. Under Alternative 4, up to 26% of all roads within the
project area may require roadbed vegetation removal, or 176 of 731 miles in Idaho and 230 of 808 miles in
Oregon. Compared to Alternatives 2 or 3, 37 or 8%, respectively, fewer miles of roads would require
roadbed vegetation removal under Alternative 4.
Potential impacts to BLM SSW, particularly sage-grouse, pygmy rabbit, and dark kangaroo mouse, were
considered during development of Alternative 4. Specifically, Alternative 4 minimized the number of fuel
breaks 1) in high quality sage-grouse habitat (i.e., PHMA or areas with high breeding density of sage-
grouse), 2) in areas with high R&R, and 3) in priority pygmy rabbit habitats, while maintaining a network
of fuel breaks throughout the project area. Roads with existing levels of disturbance (i.e., paved and well-
traveled gravel roads) were given priority for the fuel break network. Road segments within two miles of
occupied or pending leks were avoided where possible.
Greater Sage-Grouse
Under Alternative 4, there would be impacts to a total of 179 occupied or pending leks or 158 lek
complexes within 4 miles of the fuel breaks (Table 3.5-13), or 68% of occupied or pending leks within the
SGAA (Idaho: 70%; Oregon: 64%). There would be potential impacts to core areas around 101 leks or 91
lek complexes, or 38% of leks within the SGAA (Idaho: 43%; Oregon: 31%). In terms of miles of fuel
breaks, 25% and 62% of the proposed fuel breaks would be within 2 and 4 miles of leks, respectively.
Distance from Leks
2-miles 65 / 57 36 / 34 101 / 91 131 101 231
4-miles 103 / 93 76 / 65 179 / 158 277 290 567
*
†
Total miles of fuel breaks under Alternative 4: 910 miles.
Compared to Alternatives 2 and 3, 30% and 16% fewer leks in the SGAA that are within 2 miles of fuel
breaks would be affected under Alternative 4, and 23% and 11%, fewer leks would be affected within 4
miles of fuel breaks, respectively. A total of 35,702 acres of sage-grouse HMA would be reduced or
altered, or 29,934 or 9,231 acres less HMA than Alternatives 2 or 3, respectively (Table 3.5-2). In terms of
PHMA, 24,720 acres would be affected under Alternative 4, or 24,665 and 9,126 acres less than
Alternatives 2 or 3, respectively. Under Alternative 4, a total of 19,965 acres of potential sage-grouse
nesting habitat18 would be impacted within 4 miles of occupied or pending leks, or 12,826 and 4,845 fewer
acres than under Alternatives 2 or 3, respectively (Table 3.5-4). In addition, Alternative 4 would affect 0.6
or 0.3% less landscape cover of sagebrush compared with Alternatives 2 or 3, respectively. Landscape
cover of sagebrush would be reduced by an average of 0.4% (range: 0-3% per lek; Table 3.5-5). Under
Alternative 4, slightly less sage-grouse nesting habitat within each subpopulation (based on fine-scale
HAF; Table 3.5-9) would be affected compared to Alternatives 2 or 3, totaling <1% for each subpopulation.
Overall, compared to Alternative 2, Alternative 4 would affect approximately half of the acres of PHMA,
half of the acres of sage-grouse nesting habitat, and 56% of the leks within two miles of the fuel breaks.
Due to the avoidance of some leks and fewer acres of sage-grouse habitat impacted, impacts would be
reduced, including but not limited to impacts due to habitat loss and fragmentation, predation risk, fence
collisions, disturbance, and reduced survival and reproduction. Overall, impacts would still be moderate.
However, the long-term benefits would be reduced to the smaller network of fuel breaks under Alternative
4, thus the protection of large patches of sagebrush steppe may also be reduced due to the smaller network
of fuel breaks.

Pygmy Rabbit
Under Alternative 4, 16,078 acres of suitable pygmy rabbit habitat would be reduced or removed, or 1% of
suitable habitat in the project area (Table 3.5-6). This would be approximately half as much pygmy rabbit
impacted compared to Alternative 2, or 18,038 fewer acres. Compared to Alternative 3, 6,408 fewer acres
would be removed. In addition, some fuel breaks in priority pygmy rabbit habitat with known occurrences
were dropped during development of Alternative 4 and would thus be avoided for treatment. Therefore,
impacts to pygmy rabbits would be reduced to minor.
Any differences in the level of impacts for Alternative 4 compared to Alternatives 2 or 3 to kit fox, dark
kangaroo mouse, and Piute ground squirrel would be similar to those for sage-grouse and pygmy rabbit.
During alternative development, two route segments were dropped to avoid bisecting and potentially
fragmenting known locations with dark kangaroo mouse and the species’ small range. Thus, impacts would
be significantly lower for dark kangaroo mouse under Alternative 4 compared to Alternatives 2 or 3 and
reduced to negligible to minor. Any differences in long-term benefits for pygmy rabbits, kit fox, dark
kangaroo mouse, and Piute ground squirrel under Alternative 4 would be the same as for sage-grouse.
Golden Eagle
Under Alternative 4, treatments would intersect core areas of 21 known golden eagle territories, including
10 nests within the 1-mile disturbance buffer. This would be a reduction of 12 or 2 territory core areas
compared to Alternatives 2 or 3, respectively, and a reduction of 4 nests within the 1-mile disturbance
buffer compared to Alternatives 2 and 3. Since the majority of the 8 current nests (i.e., 8 of 10 nests within
the 1-mile disturbance buffer) are in canyons, only three of these nest sites (current: 2; historic: 1) would be
in viewing distance of the proposed fuel breaks. This would be a slight reduction in potential impacts to
golden eagles compared to Alternative 2, but less so compared to Alternative 3. Overall, impacts would be
negligible to minor to golden eagles. Any differences in the level of impacts for Alternative 4 compared to
Alternatives 2 or 3 for ferruginous hawk, short-eared owl, and burrowing owl would be similar to those for
golden eagle. Therefore, impacts to golden eagles and other BLM SSW raptors would be negligible to
minor. Long-term benefits from the proposed network of fuel breaks would be similar as for sage-grouse.
Bighorn Sheep
Alternative 4 would result in the reduction or alteration of the following big game habitat: 5,229 acres
bighorn sheep habitat, 9,331 acres mule deer winter range, 7,614 acres of elk habitat, and at least 18,264
acres of pronghorn habitat (Table 3.5-7). This would be 45%, 58%, 47%, and 57% of acres of bighorn,
mule deer, elk, and pronghorn habitats, respectively, reduced under Alternative 2. Under Alternative 4, any
differences in the level of long-term beneficial impacts for big game species in comparison with
Alternatives 2 and 3 would be similar to those for sage-grouse. Fewer treatment acres compared to
Alternatives 2 or 3 would mean less habitat loss and degradation, and less disturbance associated with any
treatments, but also a smaller network of fuel breaks and thus less potential to protect large patches of
sagebrush from future fires. The level of negative impacts due to changes in cover and forage, habitat
fragmentation, and, to a lesser extent, increased predation, would be lower under Alternative 4 compared
with Alternatives 2 or 3. Overall, Alternative 4 would impact less than 1% of bighorn sheep, mule deer, and
elk habitat in the project area, and 3% of pronghorn habitat in Idaho. Therefore, impacts to big game would
be negligible.

The cumulative impact analysis area (CIAA) varies in spatial extent depending on the wildlife species
analyzed and habitat requirements to meet their life history needs throughout the year. For most species, the

CIAA would be the same as the project area and reflect large home ranges of raptors and big game. Sage-
grouse is a landscape species with habitat requirements at multiple spatial scales. Cumulative impacts for
sage-grouse would be analyzed from the SGAA out to the subpopulations, based on fine-scale HAF (Stiver
et al. 2015). The project area falls within six subpopulations: Cow Lakes, Soldier Creek, Louse Canyon,
Owyhee Desert, Owyhee Canyonlands, and Antelope Ridge (Map 18, Appendix Q).

affect wildlife in their defined CIAAs include fuel breaks; ESR, noxious weed management, vegetation
treatments; juniper treatments; livestock grazing; recreation; road maintenance; lands and realty actions;
and mining. These are described in more detail in Appendix N. Potential cumulative impacts that may
affect wildlife species are addressed by actions below.
Fuel Breaks
Establishing fuel breaks reduces habitat for sagebrush-obligate and associated wildlife species, particularly
the year following treatment. Fuel breaks also reduce cover and forage for some wildlife, such as mule deer
and pronghorn. Treatments would reduce vegetation height and cover and increase corridors along existing
roads, thus potentially contributing to habitat fragmentation, particularly for treatments that include
planting non-native vegetation. However, in the long term, fuel breaks may also benefit sagebrush-obligate
species by reducing acres of sagebrush habitat lost to future fires.
Juniper Treatments
Juniper encroachment affects sage-grouse distribution, breeding, and survival (Coates et al. 2017; Miller et
al. 2017), and treatments can improve sage-grouse habitats and survival (Severson et al. 2017a; Severson et
al. 2017b). Past, ongoing, and future juniper projects focusing on early encroachment would likely benefit
sagebrush-obligate species, particularly sage-grouse, for 30 years or longer if the treatment areas are
maintained. Juniper treatments would also benefit raptors, such as the golden eagle, by improving habitat
for preferred prey species, e.g. jackrabbits, as well as increasing visibility during hunting. Juniper
encroachment reduces forage for big game species and has resulted in a reduction of mule deer in the
project area (IDFG 2016). Therefore, big game would also likely benefit from juniper treatments.
ESR treatments and noxious weed treatments benefit wildlife by preventing further habitat degradation and
protecting restoration efforts. Other ESR treatments are ongoing in the project area (see Table 3.0) or
planned south of the project area, in particular for the large 2018 fires in northern Nevada, i.e. the 435,569-
acre Martin Fire and 233,462-acre South Sugarloaf Fire. Any disturbance associated with these activities
and potential impacts to wildlife would be temporary and short-term. In the long term, vegetation and weed
treatments would benefit wildlife by maintaining or improving habitat (USDI BLM 2016a).
Livestock Grazing
Ongoing and future livestock grazing is projected to maintain or improve upland vegetation condition by
following terms and conditions of grazing permits and meeting the Idaho and Oregon Standards of
Rangeland Health and Guidelines for Livestock Grazing Management. Grazing has the potential to alter
site-specific vegetation, including sagebrush habitats and riparian areas, and could have localized impacts
on wildlife. However, permits would require adjustments to grazing allotments not meeting rangeland
health standards or habitat objectives for sage-grouse, such as changing the timing, frequency, intensity, or
duration of grazing and well as utilization limits.

Other potential impacts associated with grazing are disturbance, nest destruction, predation due to loss of
cover around a nest, and fence collisions. Sage-grouse are at risk of fence collisions, particularly in
proximity to leks, and efforts are ongoing by the BLM and other agencies to mark fencing and reduce this
risk (Stevens et al. 2012). Impacts to wildlife, e.g., disturbance, and possible loss of nests would vary
across the CIAA. Any localized impacts due to habitat objectives not being met, or fence collisions, would
be short-term and addressed with adjustments to grazing permits; they would not rise to effects across the
CIAA.
Recreation
The types of recreation that occur in the CIAA are numerous and will likely increase in the future due to
population growth and interest in recreational opportunities in the area. Those recreational activities most
likely to negatively impact wildlife, particularly big game, are OHV use and hunting. In addition, mountain
biking, hiking, recreational climbing, and bird watching during the breeding season can disturb wildlife and
cause stress or displacement, although generally temporarily (Knight and Gutzwiller 1995; Canfield et al.
1999).
There is little documentation of direct mortality to wildlife from OHVs and other motorized recreation,
although physical impairment and stress does occur from increased metabolic rates, escape responses,
reduced reproductive output, and disruptions to foraging (Knight and Gutzwiller 1995). OHV use can lead
to habitat degradation, reduced patch size, reduced nest success, population declines, and cause disturbance
from both noise and presence (Havlick 2002; Wisdom et al. 2004; Brooks and Lair 2005; Ouren et al. 2007;
Steenhof et al. 2014). Motorized vehicles, including OHVs, may result in wildlife collisions, even
mortality, particularly for small animals (Forman and Alexander 1998). Disturbance and increased stress
levels from human presence, but particularly motorized vehicles, would be greatest in winter habitats,
either big game winter range or sage-grouse winter habitat, when animals are already struggling to survive
(Canfield et al. 1999; Mule Deer Working Group 2017). Effects from recreation would occur into the
foreseeable future under current management.
Road Maintenance
Road improvement and maintenance would include heavy equipment to blade or grade existing roadways,
surface areas with gravel, and periodic maintenance. Past and ongoing road maintenance may disturb and
increase stress levels to wildlife species during critical life stages (i.e. breeding or wintering). However,
most wildlife species are able to move out of harm’s way during road maintenance and are only temporarily
displaced.
Where roads have not been regularly maintained, road maintenance has the potential to increase access to
some remote areas within the project area. In these affected areas, this could result an increase in human
presence, recreation, and motorized vehicles, particularly during the hunting season. Wildlife would be
temporarily (flush response) or permanently (avoidance) displaced due to human or motorized disturbance
(Knight and Gutzwiller 1995). Due to human presence, motorized vehicles, and disturbance, impacts from
road maintenance on wildlife would vary with location, season, and type of road maintenance.
Lands and Realty

The Gateway West Transmission Line comprises 1,103 miles of electrical transmission lines from
Glenrock, WY, to Hemingway Butte, ID. Segments 8 (16.1 miles) and 9 (17 miles) are outside of the
project area and general CIAA for wildlife, but pass through the CIAA for sage-grouse. Within the Cow
Lakes and Antelope Ridge sage-grouse subpopulations, neither of these Gateway West segments are within
occupied sage-grouse habitat and lack ≥10% sagebrush cover. Pygmy rabbit habitat and important big
game habitat would not be affected, and raptors may benefit from the transmission line due to increased

nesting and perching opportunities. Therefore, any cumulative impacts from the Gateway West
transmission line would be negligible for wildlife.
To the south of the project area, the 680-mile Ruby Pipeline, a natural gas pipeline, extends from Opal,
WY, across Utah and Nevada, to Malin, OR. Project implementation included clearing a 115-feet right-of-
way which started in 2010, followed by digging a trench. Construction was completed in 2011. In Nevada,
the majority of the pipeline went through sagebrush steppe and potential pygmy rabbit habitat (Larrucea
2017). Overall, cumulative effects to wildlife would be beneficial due to the revegetation of the right-of-
way. An exception would be for occasional pipeline maintenance or repair which would likely involve
vegetation removal at a localized level, which in turn would mean negligible to minimal cumulative effects
to wildlife.
Mining
Past mining activity has resulted in some habitat loss and fragmentation. Kinross Delamar Mine west of
Silver City, ID is currently being rehabilitated and reclaimed. There is some additional localized mining
activity at active mineral leases on state lands. Due to the limited extent of current mining activities, no
significant additional mining activity is reasonably foreseeable within the area. Due to the relatively small
extent of current mining activity and past habitat loss, cumulative effects would be negligible to wildlife.

Past, present, and foreseeable actions within the CIAA are having and would continue to have negligible to
moderate impacts on wildlife due to habitat loss, degradation, and fragmentation, and disturbance from
human activities, equipment, and motorized vehicles. Roads with motorized use may contribute to wildlife-
vehicle collisions and habitat avoidance. Negative impacts would be mostly due to wildfire, but also
recreation, road maintenance, and ongoing and reasonably foreseeable fuel break projects described in
Appendix N. The intensity of these impacts would vary by location, action, and species present. By
reducing the number of acres of sagebrush habitat lost to fire and subsequent conversion to invasive annual
grasslands, existing fuel breaks may offset their adverse impacts on sagebrush-obligate species; however
absent the Tri-state fuel break network, spared habitat would likely be limited to localized areas, as existing
fuel breaks are scattered rather than connected throughout the project area. Juniper, vegetation, and noxious
weed treatments along with ESR would benefit all wildlife species. Where recreational use increases as a
result of road maintenance, this would affect all species, but mostly small mammals through vehicle
collisions and big game through increased disturbance and hunting pressure, particularly in winter range.
Cumulative impacts from mining and lands and realty actions are negligible.

Similar to the No Action Alternative, past, present, and foreseeable actions within the CIAA are having and
would continue to have negligible to moderate effects to wildlife due to habitat loss, degradation, and
fragmentation, and disturbance from human activities, equipment, and motorized vehicles. These would be
additive with impacts under Alternative 2. The four new material sites would increase the number of such
material sites 20 in the Oregon portion of the CIAA from approximately 15 to approximately 19 sites. The
total acreage of these 19 material sites is less than 1% of the total acres of sage-grouse, pygmy rabbit,
golden eagle, or bighorn sheep habitat within the Oregon portion of the CIAA. Juniper, vegetation, noxious
weed, and other restoration treatments along with ongoing and future ES&R would benefit most wildlife
and to some extent may offset adverse impacts to habitat from the Proposed Action described in section
20
Only mineral material sites in relatively remote areas are anticipated to have cumulative effects to wildlife because they
may create disturbance in quality habitat. Mineral material sites along major travel corridors (e.g., Highway 95) are not
analyzed as they are unlikely to further affect wildlife beyond existing disturbance levels associated with the travel corridor.

3.5.2. Over the long term, the Proposed Action would provide long-term benefits, including improved fire
suppression and protecting sagebrush habitats from catastrophic wildfire.

Cumulative effects of implementing this alternative would be similar to those described under Alternative
2. Cumulative effects from Oregon material sites would be the same as those described in Alternative 2.
The overall magnitude of impacts, both negative from habitat disruption and beneficial from long-term
protection, would be slightly less than under Alternative 2, as fewer acres would be treated but fewer fuel
breaks would be implemented.

Cumulative effects to wildlife from implementing this alternative would be similar to those described under
Alternative 2. Cumulative effects from Oregon material sites would be the same as those described in
Alternative 2. However, the overall magnitude of impacts would be less than Alternatives 2 or 3, since
fewer acres would be impacted from fuel break implementation. In addition, some priority habitat for
several BLM SSW, including sage-grouse, pygmy rabbit, and dark kangaroo mouse, would not be impacted
since these areas would be avoided by Alternative 4. On the other hand, since fewer fuel breaks would be
established, the network of fuel breaks would be smaller and, therefore, the long-term benefits of improved
fire suppression and protecting sagebrush habitats from catastrophic wildfire would also be reduced in
comparison to Alternatives 2 and 3.
3.6 Cultural Resources

Background
Cultural resources are locations of human activity, occupation, or use. They include expressions of human
culture and history in the physical environment, such as pre-contact or historic archaeological sites,
buildings, structures, objects, and districts. 21 Cultural resources can also include natural features, plants,
and animals that are considered to be important to a culture, subculture, or community, or that allow the
group to continue traditional lifeways and spiritual practices.
Generally, cultural resources are considered to be “historic properties” under the National Historic
Preservation Act (NHPA) if they are they are listed or eligible for listing on the National Register of
Historic Places (NRHP). A historic property is a significant cultural resource associated with an important
event, associated with a person significant in our past, or embodying a distinct characteristic, method of
construction or artistic value, or likely to yield information important to prehistory or history. In addition to
being significant, cultural resources must possess the integrity to convey their association with an important
historic context in order to be historic properties. Cultural resources also include places such as sacred sites
or Native American plant gathering areas that have cultural importance, but may not meet the criteria to be
listed in the NRHP.
History
The project area is within the northern Great Basin cultural region and is within the ethnographic territories
of the Northern Paiute and Northern Shoshone and Bannock. Archaeological evidence indicates that people
21
A district possesses a significant concentration, linkage, or continuity of sites, buildings, structures, or objects united
historically or aesthetically by plan or physical development (USDI, National Register Bulletin No. 15, p. 5).

have lived in the area for 9,500 years or more. Pre- and post-European contact site types known in the
project area include temporary or seasonal campsites, procurement localities, battle sites and rock art.
Explorers and fur trappers began to explore southwestern Idaho and southeastern Oregon in the early
nineteenth century, often utilizing trails created by Native Americans. In the mid-1830s westward
migration along the Snake River began with the Whitman-Spaulding missionary party who traveled along
the Snake River on their way to Oregon (Peterson 1995 p.132). Over the next 25 years approximately
50,000 people would make the trek through the Snake River Plain heading west. The primary westward
route, the Oregon Trail, is located at least 47 miles (75 km) north of the project area. Few, if any, people
stayed in southwestern Idaho or southeastern Oregon due to the dry, hot, barren conditions.
By the late 1880s, Idaho and Oregon were largely settled by emigrants who sought their fortune in gold or
land. The success of the mining industry was dependent upon a transportation network and associated
support for the mines and miners. Eventually smaller communities, ranching, and agricultural areas
developed along these roads to support the mining industry. By 1900, grazing, intensive agriculture, and
timber production were the primary economic drivers in the region. Historic site types related to settlement
of the project area may include roads and trails, short-term camp sites, mining sites, and ranches.
Formal cultural resource inventories in the BLM have been ongoing since the 1970s. Within the
approximately 3.6-million-acre project area, approximately 264,697 acres (7.8%) of BLM-administered
lands and state lands in Idaho and Oregon haves been inventoried for cultural resources. The following
table shows the number of acres inventoried for cultural resources for each action alternative by
management agency.
Table 3.6-1. Acres of cultural resource inventories by alternative and management agency.
State Alternative BLM BLM Surveyed State State Surveyed Total BLM &
Project Acres/% Project Acres/% State Surveyed
Acres Acres Acres/%
Project Area 1,755,940 125,527 (7.2%) 117,198 4,326 (3.7%) 129,853 (6.9%)
Alternative 2 32,662 7,369 (22.6%) 2,358 71 (3.0%) 7,440 (21.3%)
Idaho
Alternative 3 22,526 4,718 (21.0%) 1,721 52 (3.0%) 4,770 (19.7%)
Alternative 4 20,043 5,803 (29.0%) 1,596 52 (3.3%) 5855 (27.1%)
Project Area 1,414,241 125,272 (8.8%) 79,221 9,572 (12.1%) 134,844 (8.9%)
Alternative 2 37,463 3,951 (10.6%) 1,385 328 (23.7%) 4,279 (11.0%)
Oregon
Alternative 3 25,646 3,148 (12.3%) 1,198 328 (27.4%) 3,476 (13.0%)
Alternative 4 20,894 3,041 (14.6%) 1,271 310 (24.4%) 3,351 (15.1%)
Identified Cultural Resources
Within the larger project area, there are a total of approximately known 2,184 cultural resource sites on
BLM-administered lands in Idaho as well as approximately 199 sites on Idaho State managed lands. Sites
include Native American related campsites, rockshelters and rock art, rock features, a WWII bombing
range, historic roads, rock features, ranches, homesteads and both historic and prehistoric artifact scatters,
and the National Register of Historic Places listed Camas/Pole Creek Archaeological District. In Oregon,
there are 356 recorded sites on BLM-administered lands and seven sites on Oregon State managed lands.
Sites include the Dirty Shame Rockshelter, prehistoric campsites, rockshelters, rock art, rock features,
historic homesteads, stage and telegraph stations, and both historic and prehistoric artifact scatters. There
are also 216 miles (347 km) of historic wagon roads within the project area, including the Winnemucca to
Silver City, Oregon Central Military, Jordan Valley, and Fort Harney to Fort McDermitt roads. The project
area provides the context for the specific resources within the proposed fuel breaks. Cultural landscapes are
geographic areas, including both cultural and natural resources and the wildlife or domestic animals

therein, associated with a historic event, activity, or person or exhibiting other cultural or aesthetic values
(Birnbaum 1994). These landscapes may connect cultural sites within the proposed fuel breaks to cultural
sites in the larger project area.
Direct effects to cultural resources would most likely occur within the fuel break (i.e., 200-foot-wide
vegetation treatments on each side of roads clear of vegetation), and mineral material sites for the chosen
alternative. The BLM has used the data from previously conducted cultural resource inventories and
recorded resources, as well as likely resource types in areas that have not been inventoried, in order to
determine the potential for each alternative to impact cultural resources. The number of known sites
potentially affected are listed for each alternative in the tables below.
Table 3.6-2 summarizes the NRHP eligibility of the cultural resources within the proposed fuel breaks of
each alternative. The fuel break treatment area of Alternative 2 has been 16.2% surveyed for cultural
resources, Alternative 3 has been 16.4% surveyed, and Alternative 4 has been 21.1% surveyed. Additional
resources may exist in areas that have not been previously surveyed or in areas that were surveyed with
poor ground surface visibility. Table 3.6-3 summarizes the miles of NRHP-eligible or potentially eligible
roads and trails within the fuel break treatment area of each Alternative.
Table 3.6-2. Summary of NRHP-Eligibility of cultural resource sites within the fuel break treatment
area of each alternative.
Idaho Idaho Oregon Oregon
Alternative NRHP Eligibility Total
BLM State BLM State
Alternative 2 Eligible 40 4 3 0 47
Not Eligible 72 5 13 0 90
Unevaluated 62 7 34 0 103
Unknown 1 0 0 0 1
Total Sites: 175 16 50 0 241
- - - - - - -
Unknown 1 0 0 0 1
Total Sites: 114 11 37 0 162
- - - - - - -
Unknown 0 0 0 0 0
Total Sites: 113 12 38 0 163
Table 3.6-3. Miles of NRHP-eligible or potentially eligible roads and trails within the fuel break
treatment area of each alternative.
Idaho Idaho Oregon Oregon
Alternative Total
BLM State BLM State
Alternative 2 112 11 155 13 291
Alternative 3 78 10 83 13 185
Alternative 4 98 10 105 13 226

Table 3.6.4. Number of sites that cross roads proposed for vegetation clearing (Includes linear
features) 22
Idaho Oregon
Alternative NRHP Eligibility Total
BLM/State BLM
Alternative 2 Eligible 8 0 8
Not Eligible 15 2 17
Unevaluated 23 9 32
Unknown 0 0 0
Total 46 11 57
- - - - -
Not Eligible 7 2 9
Unevaluated 11 5 16
Unknown 0 0 0
Total 20 7 27
- - - - -
Not Eligible 6 0 6
Unevaluated 11 6 17
Unknown 0 0 0
Total 21 6 27
Additional cultural resources inventory would take place prior to project implementation. The details of
inventory design, assessment of identified cultural resources, reporting, and consultation with SHPO(s),
Native American Tribes and other parties will be included in the project Programmatic Agreement (PA)
(Appendix P). A project PA provides alternative procedures that allow agencies to tailor the NHPA Section
106 process to the undertaking in a phased manner to meet Section 106 requirements (36 CFR § 800.14
(a)). Appendix G contains additional details about NHPA and the project PA.
Tribal Interests
The BLM continues to consult with affected Native American Tribes to identify traditional resources (such
as traditional cultural properties and sacred sites) and other concerns Tribes may have regarding the project.
Potentially affected Tribes include the Shoshone-Paiute Tribes of the Duck Valley Indian Reservation, the
Shoshone-Bannock Tribes of the Fort Hall Indian Reservation, the Fort McDermitt Paiute and Shoshone
Tribes of the Fort McDermitt Indian Reservation, and the Burns Paiute Tribe.
State Historic Preservation Office Consultation

The BLM has initiated consultation with Oregon and Idaho SHPOs and will continue to consult with both
SHPOs in developing the programmatic agreement (PA) (Appendix P). Future consultation will follow the
stipulations in the PA.
22
Based on a 15-ft wide corridor. Roads wider than 15 feet are typically mechanically constructed and/or regularly
maintained, and therefore would not require vegetation removal.


• What is the potential for fuel break implementation and maintenance and mineral material site
development to adversely impact the characteristics of known cultural resource sites that make
them eligible, or potentially eligible, for listing on the National Register of Historic Places?
o What are the impacts from fuel break implementation to historic roads and trails that are
potentially eligible for listing on the National Register of Historic Places?
• What are the potential impacts to unknown cultural sites, including buried sites, from fuel break
implementation and maintenance and mineral material site development?
• How would fuel break implementation and maintenance and mineral material site development
affect Tribal practices, traditional use areas and sites of cultural significance?
3.6.2.2 Indicators
The primary factors for assessing the condition of cultural resources are the integrity of the historic
property relative to the characteristics that may qualify the property for listing on the NRHP and/or the
ability of the cultural resource to retain the qualities that give it historical or cultural importance. Factors
that could affect site integrity and qualities of importance include:
• Extent and depth of ground-disturbing activities in areas of known or unknown intact cultural
resources,
• Alteration of the setting of cultural resources,
• Increase in the occurrence of natural processes, such as erosion, that negatively impact cultural
resources,
• Looting, vandalism, and unintentional disturbance of cultural resources through other human
activities, such as recreation, and
• Changes in access or land use that could impair future traditional activities.
Indicators used to compare environmental consequences between alternatives are the number of cultural
resources impacted and the severity of the impact.
3.6.2.3 Assumptions
• Most cultural resources in the project area are not recorded.

• Previously unidentified resources could be exposed by ground-disturbing activities.
• Ground-disturbing activities have the potential to redistribute artifacts within a site.
• Treatments could increase the visibility or exposure of artifacts and this increase in visibility
could lead to an increased potential for looting.
• Avoiding sites could indicate site location through contrast with the rest of the treated area.
• Erosion increases with increased bare soil.
• Setting is important to the integrity of historic roads and trails.
• A Tribe or certain Tribal members may have knowledge crucial to identifying and assessing
impacts to resources significant to that Tribe.

Under the No Action Alternative, a fuel break network would not be created and mineral material sites
would not be constructed. Therefore, impacts to cultural resources associated with this project would not
occur. However, the project area would remain subject to future wildfire incidents which may result in

irreparable damage to, or destruction of, cultural resources. Cultural resources within the project area would
continue to be threatened by fire. Fires can damage or destroy historic and prehistoric archaeological
materials directly resulting in cracking, spalling, melting, sooting, color change, change in chemical or
physical characteristics such as loss of hydration rinds in obsidian, or complete combustion. Indirect
effects, such as post-fire erosion, and effects from fire suppression efforts, such as bulldozer lines, can also
damage or destroy cultural resources (Ryan et al. 2012). Bulldozers are commonly used in fire suppression
in the project area. It is not always possible to avoid known cultural resources or identify new resources
before a fireline is constructed. Fires can make cultural resources more visible by removing concealing
vegetation. This increased visibility may increase the probability of looting. Fires can change site settings
by consuming existing vegetation. If different vegetation grows back, for example, when a sagebrush-
dominated landscape is replaced with an annual grass-dominated landscape, the change in setting could be
long-term. Bulldozer lines can create visual contrasts that affect the settings of cultural resources. Historic
roads, buried sites, areas of tribal significance and tribal practices can all be negatively impacted by fire and
suppression activities. The effects range from negligible to major. In the No Action Alternative, direct fire
effects, post-fire erosion, and ground disturbance from suppression activities would be greatest of all the
alternatives.

Direct negative impacts on cultural resources may occur as a result of the proposed treatments common to
all alternatives. The severity of impacts to cultural resources would depend on the treatment and the nature
of the cultural resource. The cultural resource design features discussed in Appendix G and developed in
the PA (Appendix P) would reduce these impacts to protect the qualities that make a cultural site eligible
for listing on the NRHP or culturally significant to a Tribe. Indirect effects of fuel break construction would
be a reduction in the extent of bulldozer lines or hand lines necessary during a wildfire event. A reduction
in the relative size of fires under the action alternatives would result in impacts to fewer unknown sites. The
modification of vegetation from fuel break treatments would reduce the chances for a wildfire to burn over
large acreages into areas that have not been previously inventoried for cultural resources. As described
below, most impacts from the various vegetated fuel break treatments are expected to be minor to moderate
with implementation of the cultural resource design features. However, these design features apply only to
previously identified resources. Impacts may still occur to unrecorded cultural resources in un-surveyed areas.
Targeted Grazing
Targeted livestock grazing would use cattle at high intensity over short durations to achieve treatment
objectives. The cattle would be confined to the desired areas using control measures such as temporary
fencing or active herding. Watering sites and salt/mineral supplementation sites may also be part of the
targeted grazing treatment. Installations and/or supplements would be placed within the 200-foot-wide fuel
treatment zone. Direct impacts on cultural resources could occur as a result of trampling, particularly when
cattle are concentrated in one area due to salt/mineral or water trough placement or near gates. Trampling
may result in churning of site soils, disturbance or destruction of cultural features and artifacts, and
breakage of artifacts. To avoid impacts to significant cultural resources, sites for supplements and water
troughs would be placed at least 250 feet away from any historic property unless sufficient physical barriers
already exist (Appendix P). Absent this measure, major long-term impacts would be expected to occur
within 200 feet in any direction of water and salt/mineral supplementation sites or fence gates (Coddington
2008). According to Coddington (2008), if a water trough was placed within an archaeological site, the
most severe impacts would occur within 32 meters (105 feet) of the watering trough with a moderate
impact area in the next 32 meters (105 feet) away from the trough. The same would hold true for
salt/mineral sites. Indirect impacts from targeted grazing would include soil erosion and looting of artifacts
that become more visible from reduced vegetation.

Targeted grazing may occur when soils are wet or saturated which could result in major long-term adverse
impacts to cultural resources through trampling and vertical movement of artifacts. If cattle are
concentrated in areas when soils are wet, hoof prints could sink into the ground potentially breaking
artifacts, burying them, and pushing them down into other occupation layers, which would destroy the
chronological context of a site. These impacts would result in compromising a site’s spatial integrity,
adversely affecting the site’s information potential and its potential for listing on the NRHP. Targeted
grazing could also impact buried sites by exposing them or trampling them. Targeted grazing could directly
affect historic roads by destroying features and indirectly subjecting them to increased erosion. Targeted
grazing could negatively impact areas of tribal significance through trampling, or exposure or destruction
of features and artifacts. Targeted grazing could increase the visibility of cultural resource sites by
removing concealing vegetation. Where cultural sites are surrounded by protective fencing (Appendix P),
there would be an obvious contrast in vegetation that might bring attention to the sites. This increased
ground visibility increases the probability of looting unless the sites were already visible from a distance
before treatment.
Improvements associated with targeted grazing, such as fencing, water troughs and mineral supplements,
would be placed no closer than 250 feet from the outside boundary of identified historic properties, unless
there is an existing barrier, such as a rock cliff, that would protect the site (Appendix P). The placement of
water and salt/mineral sites away from sites would decrease, but not eliminate, the impacts to cultural
resources. Repeated use of targeted grazing in the same location (for fuel break maintenance) would have
greater impacts than a single application of targeted grazing (as seedbed preparation).

Development of mineral material sites has the potential to impact cultural resources through physical
destruction, as well as visual and auditory intrusions. NRHP-eligible and potentially eligible sites would be
avoided. The Winnemucca to Silver City wagon road is visible from three of the mineral material sites. The
impact of the mineral material development on the wagon road would be moderate during operations and
minor in the long term due to the visual and auditory changes in the setting of the road. Since the mineral
material sites are small relative to the setting of the wagon road overall, they would result in a relatively
small long-term impact of the mineral material sites. Inventory of cultural resources prior to development
of mineral material sites would occur and would reduce the possibility that cultural sites, including buried
sites, remain unknown. If cultural resources are discovered during development of mineral material sites,
operations would cease until the cultural resource has been evaluated and any necessary consultation has
occurred. Inventory, avoidance, and evaluation of any resources discovered during development would
reduce potential impacts to unknown sites to minor. Mineral material development also has the potential to
affect Tribal practices and resources. The nature of this impact, if any, will be determined through
consultation and minimized or mitigated as detailed in the project PA.
Mowing
Although there is only one known study concerning mowing over archaeological sites (McCormick &
Halford 2003), mowing is generally considered to have minor negative impacts to sites under certain
parameters. McCormick and Halford (2003) conducted a study in soft sandy soils with a rubber-tracked
crawler (18 inches wide tracks which exert 3.0 psi of ground pressure) and an attached brush cutter/mower
deck. The mower height was set at 8 inches and the crawler was not allowed to turn around in the site. In
the study, flakes were displaced more vertically than horizontally and only one flake of ten exhibited
microchipping. The study did not test artifact displacement or breakage on harder, rockier soils.
The use of a rubber tired tractor with relatively small ground pressure should not create significant artifact
breakage, but may push some artifacts into softer soils. Mowers would not turn in known sites, reducing the

potential ground disturbance. Indirect effects of mowing would include exposure of additional artifacts
since the vegetative cover would be removed. Direct effects to sites would include obscuring artifacts by
pushing them into softer soil or by being covered with mowed material. Certain vulnerable artifacts, such as
ceramic or bone, could be permanently damaged from the impact of tires rolling over them. Artifacts or
features taller than the mower blades would also be directly damaged by mowing if the site containing the
artifacts or features is not avoided. If not avoided, the effects on lithic scatter sites23 are still likely to be
negligible. The materials in lithic scatter sites are predominately small fragments of stone found at or below
the ground surface and so would not be affected by the mower blades. However artifacts may be pushed
deeper into soft soils in tire tracks. The effects to other site types could be negligible to moderate depending
on the site’s artifacts and features, and their vulnerability to impacts from tire pressure, rotating mower
blades, and exposure from loss of vegetated cover. For example, historic bottles and cans can be broken or
crushed by vehicle tires. These artifacts may also be more likely to be hit or scattered by mower blades
because the artifacts can be several inches tall and are often piled to be even higher above the ground
surface. Mowing along historic roads would indirectly affect the setting of the road by creating linear visual
contrasts, depending on the existing shrub density. Mowing would have no effect on buried sites. The
Shoshone-Paiute Tribes have indicated that mowing can damage cultural resource sites and they prefer
hand cutting. Preliminary consultations with Tribes in Idaho have also suggested that having differing
mowing heights between cultural resource sites and other treated areas may draw attention to the cultural
resource areas and potentially lead to increased looting. These considerations will be addressed in the
project PA.
Hand Cutting
The cultural resource design features developed in the PA (Appendix P) allow hand cutting of trees and
shrubs within sites on a site by site basis. Within a site, vegetation may be hand cut to reduce fuels so
vegetation would burn with shorter flame lengths and be less susceptible to carry fire during a wildfire.
Piling large amounts of residual debris for burning would not be allowed within historic properties under
the cultural resource design features. Vegetation would either be lopped and scattered or carried off site for
piling. When treatments create a large amount of debris, a chipper may be used. However, large amounts of
chipped material creates a bed of flammable material that, depending on the thickness, could produce high
temperatures over a long duration and could adversely affect certain archaeological materials such as wood,
obsidian or ceramics. Therefore chipping would not be allowed on NRHP-eligible or potentially eligible
sites (Appendix P). Indirect effects from hand cutting vegetation would potentially be an increased
exposure of artifacts but scattering branches may temporarily cover them, making them less visible, and
protecting them from unauthorized collection. Direct impacts to cultural resources from hand cutting would
be considered negligible and would be relatively short-term. An indirect impact of hand cutting and
removing fuel from sites is decreased fire intensity and severity in the site, in the event of a future fire.
Hand cutting along eligible or potentially eligible historic roads would not affect the setting or eligibility of
the road. Hand cutting of vegetation could be designed to heavily thin vegetation while maintaining a more
natural appearance than mowing. Hand cutting would have no effect on buried sites. Hand cutting could
have minor negative to positive impacts to areas of tribal significance, depending on the site. Hand cutting
may have a lower impact to cultural resources sites important to the Tribes compared to mowing.
Chemical Treatment
Application of herbicides may directly impact cultural resources if the herbicide is applied to rock art, or if
herbicide is applied within a Native American plant gathering area. Under the cultural resource design
features, herbicides would only be applied on NRHP-eligible or potentially eligible sites through the use of
hand sprayers, aerially, or from vehicles that stay on existing roads. UTV/ATV-mounted sprayers may also
23
Sites with debris from stone tool manufacture that may also include formed tools such as projectile points.

be used when soils are not wet or saturated and without turning in sites to avoid disturbance of soils.
Herbicides would not be applied where they would affect rock art images or within traditional Native
American plant gathering areas (as identified through consultation with affected Tribes). Herbicides would
not be used in or along a site when complete removal of vegetation is the desired outcome prior to seeding.
Lack of vegetation would indirectly impact cultural resources by potentially exposing artifacts to
unauthorized collection. The exposed soil would be more susceptible to erosion, resulting in artifact
movement and potentially adversely impacting site integrity. Within the fuel treatment zone, herbicides
would only be used to reduce undesirable annual grasses or other undesirable plants within an existing
plant community. Therefore, chemical treatments would have negligible to moderate effects to known
cultural resources. Herbicide use would have negligible effects on historic roads if herbicides are not used
to completely remove vegetation; see Roadbed Vegetation Removal below for effects of herbicide use to
remove vegetation from the roadbed. There would be no effect from herbicides on buried sites. There
would be no effect to plant gathering or plant gathering areas, because these areas would be avoided
(Appendix P). Herbicides could affect the visibility of cultural resource sites by removing concealing
vegetation, but there would not be any contrast to bring attention to the sites.

Although native vegetation is preferred within cultural resource sites and Native American plant gathering
areas, the use of any of the species of plant proposed may be acceptable in these areas, provided the seeds
are dispersed according to the broadcast and drill seeding methods described below. Many of the
archaeological sites that have burned in the past are now covered by highly combustible annual plants that
increase the fire return interval. The growth characteristics of the proposed plant seedings would be
effective in reducing the spread of wildfire and decreasing the fire intensity burning across a resource.
Therefore, the potential for future significant impacts on cultural resources as a result of fire and wildfire
suppression activities could be decreased.
Seeding may require mechanical seedbed preparation such as disking to reduce competition prior to planting.
Other seedbed preparation techniques (herbicides, prescribed fire, targeted grazing) are described under their
respective headings within this section. Indirect effects could also include negligible to major impacts to the
setting or visual aspects of a site through a change in vegetation types, particularly if a native plant
community is replaced with non-native plants. Seeding could also affect the setting by introducing linear
visual contrasts. Seeding and seed bed preparation could have negative impacts on tribal practices and areas
of tribal significance, but specific effects would depend on the site. Avoiding sites during seeding may
increase the visibility of sites as they would be contrasting untreated pockets in a treated matrix (Halford et al.
2016).
Disking
Due to the heavy ground-disturbing nature of disking, the potential for disturbance to cultural resources
from this activity is considered major and long-term. Therefore, design features would not allow disking
within the boundaries of any known NRHP-eligible or unevaluated site within the proposed fuel breaks
(Appendix P). Disking through an unknown, buried cultural resource site would have a direct negative
impact to the site’s vertical and horizontal spatial integrity through churning soil up to nine inches deep.
Disking can permanently destroy features, break artifacts, and either cover or uncover artifacts through soil
movement, thus impacting the site’s integrity and eligibility. After disking, indirect impacts include the
potential for soil erosion where silty or loose soils are prevalent and vegetation has not grown back or the
area has not been immediately seeded. Additionally, linear cultural features, such as wagon trail ruts, would
also be directly impacted by disking through flattening or destruction of features. Disking along an NRHP-
eligible or potentially eligible historic road or trail would have moderate to major effects to the setting of

the road potentially impacting its eligibility. Implementation of cultural resource design features developed
in the PA (Appendix P), would reduce the potential for major impacts.
Drill Seeding
Drill or broadcast seeding would be utilized to establish a fuel break consisting of desirable perennial
vegetation to meet fuel break objectives. Rangeland drills, minimum-till drills or no-till drills would be
utilized, depending on soils and topography. Rangeland drills result in disturbance between 1 and 6 inches
in depth. A minimum-till drill would also result in disturbance, but to a lesser depth. Such disturbances
within a NRHP-eligible or potentially eligible sites could result in direct major long-term impacts through
destruction of features such as hearths or rock rings and more friable artifacts such as bone and ceramic.
A recent study by Halford et al. (2016) of post-fire drill seeding on archaeological resources found that drill
seeding across lithic scatters had no significant effect to the site and would not adversely affect the
characteristics of the site that qualify it to be eligible for listing on the NRHP. This study was limited in
context with the following constraints: it was conducted post-fire where vegetation was predominately
burned off, soils were a mix of loam and clay with few rocks, and the archaeological sites did not have
known features or artifacts that could be easily destroyed. The study found that turning a drill seeder in a
site did create greater soil disturbance, and in wet soils, drill seeding caused more soil clodding, also
increasing the impact to a site. Seeding using a standard rangeland, minimum till or no-till drill would be
allowed within a site on a case-by-case basis, depending on the resource present, soil conditions, and drill
type proposed. To minimize disturbance to historic properties, drill seeding would occur only when soils
are not wet or saturated and seeding vehicles would be pulled by a rubber-tired tractors. Tracked vehicles
would only be used in sites if the displacement factor is shown to be equal to or less than that of rubber-
tired equipment (Appendix P). Additionally, drills would be equipped with depth bands to minimize the
depth of disturbance as appropriate. Drill seeders would not be allowed to turn in a site. Drill seeding could
have minor to major effects on historic roads by damaging features, such as trail ruts, and impacting the
setting of the road. The seeded species would affect the severity of the impact to the setting, with native
species potentially having a beneficial impact and non-native monoculture having the greatest negative
impact on the setting. Drill rows would create a visual impact regardless of seeded species. Drill seeding
would primarily impact the near-surface portions of buried sites, with the deeper potentially intact deposits
unaffected.
Broadcast Seeding
Broadcast seeding using mechanized equipment or hand spreaders, followed by a cover treatment, would
be utilized where the terrain is not conducive to drill seeding or where prostrate kochia is being seeded.
Mechanized equipment would include UTV/ATVs with mounted spreaders or a rubber-tired tractor with a
boom. Mechanized equipment could have moderate to major impacts to sites when turning within a site by
displacing artifacts or damaging features. Certain vulnerable artifacts, such as ceramic or bone, could also
be permanently damaged from the impact of tires rolling over them.
Cover treatments would utilize a harrow, culti-packer, or roller packer implement when possible. These
pieces of equipment would produce less ground disturbance than a drill seeder; however the potential for
direct impacts is present and dependent upon certain variables such as soil composition and cultural
resource type. Use of a harrow would likely result in dragging, displacement and burying of artifacts as
well as damage to features considered significant within NRHP-eligible or potentially eligible sites. The
primary disturbance from the culti-packer and roller packer would occur from the vehicle tires when
turning and possibly from burying and breakage of artifacts. Broadcast seeding using any method would
only occur when soils are firm and not wet or saturated, and vehicles would not turn within sites.
Harrowing, culti-packing and rolling could have major impacts to historic roads if features, such as trail

ruts, are present and not avoided. Harrowing, culti-packing and rolling would primarily impact the near-
surface portions of buried sites, with the deeper potentially intact deposits unaffected.
Prescribed Fire
Many of the cultural resources in the project area have been previously burned, some of them under recent
severe wildfire conditions. In those instances, it is likely that any combustible materials that were present
have been consumed leaving only non-combustible materials. In most cases, prescribed fire would have
minor impacts on previously burned sites. Sites that have not been burned under severe wildfire conditions
may still contain combustible materials. A direct permanent effect from prescribed fire would be
combustion of those artifacts or features. Indirect effects from prescribed fire would result from the
elimination of vegetation on site: artifacts could become more visible, possibly resulting in a potential
increase in unauthorized collection. Rock art can be damaged through sooting, color change or spalling if
tumbleweed piles are burned directly against the rock.
Pile burning in a site can result in high heat for a long duration which can directly impact artifacts through
cracking, spalling and changing the chemical or physical characteristics such as loss of hydration rinds in
obsidian, or complete combustion. Pile burning would not occur within an historic property (Appendix P).
Because prescribed fire for seedbed preparation would be used in areas that have burned recently and are
dominated by annual grasses, the additional direct fire effects would be minor. Fire management activities
have the potential to impact cultural resources through vehicle traffic and ground disturbance.
Surveys for cultural resources in previously un-surveyed portions of tumbleweed burning areas would be
impeded, if not prevented, by the dense tumbleweed accumulation. However, since burning would be done
when live fuel moisture levels are high enough to retard fire beyond the tumbleweed concentrations and no
ground-disturbing activities would be conducted, no impact on unidentified cultural resources, other than
unidentified rock art, is anticipated as a result of tumbleweed burning. Tumbleweeds would be pulled away
from known rock art before burning, as far as needed to avoid potential damage to from sooting, flames and
excessive heat. Where possible, surveys would be conducted prior to burning in areas where previous
surveys have not been conducted. Historic roads and buried sites would have negligible impacts from
prescribed fire. The effects of prescribed fire on areas of tribal significance would depend on the site.

The use of heavy equipment to blade roads free of vegetation has the potential to cause direct long-term
irreversible damages to a cultural site. Each time a road is bladed through a cultural site, it removes a layer
of soil that cuts deeper into the site, removing and displacing artifacts and possibly destroying features.
Therefore, blading through a cultural site will be avoided and all roads that require removal of vegetation
will be surveyed for cultural resources prior to implementation to identify areas requiring manual
vegetation removal. In these areas, less ground-disturbing methods would be employed that include hand
cutting vegetation and/or herbicide treatments to eliminate vegetation in the roadbed. Although these
methods eliminate direct impacts from ground disturbance, they may result in indirect impacts that include
exposure of artifacts in the road that may result in unauthorized collection of artifacts or an increase in
erosion where there is no vegetation to keep soils in place. Collection of artifacts and significant erosion
within a site that would potentially damage features or displace artifacts would cause long-term irreversible
impacts.
Blading NRHP eligible roads that have not been bladed in the past may have an indirect impact on the
setting and feeling of the road. Blading would create berms along the sides of the road where none existed

in the past. Repeated blading may also impact known or unknown historic features constructed in or along
the road by exposing and/or damaging them.
Blading roads free of vegetation may make them more inviting to drive on and may result in increased
access to areas that would not have been as accessible prior to the treatment. Although this increase is not
expected to be substantial, perhaps only limited to those people who already access the area, there may be
an increase in indirect impacts to tribal practices, gathering areas, or traditional use areas from increased
traffic. These impacts would be minor but long-term.
Fuel Break Maintenance

The use of a combination of treatments for fuel break construction and the repeated applications of
treatments for fuel break maintenance or reestablishment increases the impact over a single treatment
application. Multiple treatment applications may have additive effects, but as a particular type of
disturbance increases additional effects would tend to taper off. Where a resource is completely avoided by
a treatment, repeated applications of the treatment with the same avoidance would continue to have no
effect on the resource.
Repeated mowing would increase the likelihood of artifact damage because vehicles would not be driving
in precisely the same locations each time. Repeated mowing would maintain or reestablish the visual
contrast. Several treatments (i.e., chemical treatment, disking, drill seeding, broadcast seeding, and
prescribed fire) open up bare soil and increase the potential for erosion. Use of multiple of these methods or
repeated applications of one of these methods would increase the impacts to cultural resources creating
multiple periods of increased visibility of sites and higher potential for erosion. Repeated disking, drill
seeding or broadcast seeding would have additional impacts that are smaller in magnitude than the original
treatment. For example, the information potential that is lost when disking disturbs an unknown buried site
is greater than the additional information potential that is lost when the site is disked a second time because
the fine scale context and spatial relationships are already disrupted. Repeated prescribed burning of
tumbleweeds could increase impacts to rock art, if the rock art cannot be completely protected. Repeated
hand cutting and pile burning would have no additional impact on cultural resources.
The potential for long-term major impacts on cultural resources is greatest under this alternative, given the
large area of fuel break disturbance and the largest number of known cultural resource sites, as shown in
Table 3.6-2. The vegetation matrix and fuel break objectives recommend treatment on 67,559 acres in
Alternative 2. A total of 11,719 acres have been previously inventoried for cultural resources with 241
cultural sites that would be potentially affected in the inventoried areas. This equates to a site density of
roughly 21 sites per 1,000 acres and an expected 1,379 cultural resource sites within the fuel breaks of this
alternative. Based on the proportions of eligible, ineligible, and unevaluated sites in the inventoried areas,
there is the potential for roughly 269 eligible sites, 514 ineligible sites and 589 unevaluated sites to occur
within the proposed fuel breaks of Alternative 2. The roads selected for roadbed vegetation removal pass
through a total of 57 sites. A total of 291 miles of historic roads and trails eligible or potentially eligible for
listing on the NRHP would be affected by this alternative. The potential impact to unknown or buried sites,
tribal practices, and areas of tribal significance would be greatest under this alternative because it has the
largest area of disturbance.
The implementation of cultural resource design features and additional inventory would reduce the impacts
to cultural resources (Appendix P). Depending on the treatment(s) and cultural resource types, the direct
and indirect effects would range from no effect when sites are avoided by all treatment types to moderate
effects where treatments are conducted in sites with design features applied. As described in section

3.6.2.4, this alternative would result in a reduction in potentially major negative impacts to cultural
resources from fire, fire suppression, and post-fire rehabilitation effects. Negligible to moderate negative
effects are possible from ground disturbance, breakage, or damage of artifacts and features, increased
visibility, erosion, fire effects from prescribed fire, and visual impacts on site setting, depending on the
treatment.
Development of this alternative partially focused on minimizing impacts to known significant cultural
resources, and to areas where the probability of finding significant cultural resource sites, based on a
probability model, is high. Based on the vegetation matrix and fuel break objectives the total number of
acres requiring treatment is 45,872. A total of 8,246 acres have been previously inventoried for cultural
resources with 162 cultural sites found in the inventoried area that would be potentially affected by this
alternative. This equates to a site density of roughly 20 sites per 1,000 acres and an expected 900 cultural
resource sites within the fuel breaks of this alternative. That would be 35% fewer sites than in Alternative
2. Based on the proportions of eligible, ineligible and unevaluated sites in the inventoried areas, there is the
potential for roughly 156 eligible sites, 356 ineligible sites, and 383 unevaluated sites. Under this
alternative, the proportions of NRHP eligible sites would be less than either the Proposed Action or
Alternative 4. The roads selected for roadbed vegetation removal pass through a total of 27 sites. Up to 185
miles of historic roads and trails eligible or potentially eligible for listing on the NRHP would be
potentially affected by this alternative. This is 37% fewer miles affected than in the Alternative 2. The
potential impact to unknown or buried sites, tribal practices and areas of tribal significance would be less
under Alternative 3 than Alternative 2 because it has a smaller area of disturbance and avoids high site
probability areas and areas of known tribal concern.
effects when treatments are conducted in sites with design features applied. As described in section 3.6.2.4,
this alternative would result in a reduction in potentially major negative impacts to cultural resources from
fire, fire suppression and post-fire effects. Negligible to moderate negative effects are possible from ground
disturbance, breakage or damage of artifacts and features, increased visibility, erosion, fire effects from
prescribed fire, and visual impacts on site setting, depending on the treatment.
The emphasis of this alternative is to provide protection to wildlife and wildlife habitat. The vegetation
matrix and fuel break objectives recommends treatments along 38,044 acres of fuel breaks. Under this
alternative 9,206 acres have been inventoried for cultural resources with 163 cultural sites found. This
equates to a site density of roughly 18 sites per 1,000 acres, and an expected 667 cultural resource sites
within the fuel breaks of this alternative. This number of sites is 52% less than in the Proposed Action and
26% less than in Alternative 3 treatment areas. Based on the proportions of eligible, ineligible, and
unevaluated sites, there is the potential for roughly 135 eligible sites, 233 ineligible sites, and 299
unevaluated sites. Although Alternative 4 appears to have less potential impact on cultural resource sites,
there is a higher likelihood that more sites would be considered eligible for listing on the NRHP because
this alternative does not avoid areas that have been modeled as having a high probability of significant
sites. Up to 226 miles of historic roads and trails potentially eligible for listing on the NRHP could be
affected by this alternative. This is 22% fewer miles affected than in the Proposed Action and 22% more
miles than in Alternative 3. The roads selected for roadbed vegetation removal pass through a total of 27
sites. The potential impact to unknown or buried sites, tribal practices and areas of tribal significance would

be less under Alternative 4 than Alternative 2 because it has a smaller area of disturbance. Compared to
Alternative 3, Alternative 4 would likely have a slightly larger impact to unknown or buried sites, tribal
practices and areas of tribal significance because this alternative does not avoid high site probability areas
and areas of known tribal concern.
effects when treatments are conducted in sites with design features applied. As described in section 3.6.2.4,
this alternative would result in a reduction in potentially major negative impacts to cultural resources from
fire, fire suppression and post-fire effects. Negligible to moderate negative effects are possible from ground
disturbance, breakage or damage of artifacts and features, increased visibility, erosion, fire effects from
prescribed fire, and visual impacts on site setting, depending on the treatment.

For cultural resources, the cumulative impact analysis area (CIAA) consists of both the project area
(affected environment) and fuel breaks (direct effects area), which must be considered in terms of
cumulative impacts, visual, cultural, and scientific relationships between sites in the region, and the
interface between cultural resources and historic landscapes. The project area (affected environment)
provides the context for the specific resources within the proposed fuel breaks. Cultural landscapes may
connect sites within the proposed fuel breaks to sites in the larger project area. The temporal scope is the
life of the project to capture the potential long-term effects of the project and all of the reasonably
foreseeable future actions within the geographic scope.

Those past, present, and reasonably foreseeable projects and trends in the CIAA considered likely to
contribute to the cumulative impact on cultural are discussed below. The Soda Fuel Breaks Project,
Bruneau Fuel Breaks Project, Bruneau-Owyhee Sage-grouse Project, the Trout Springs and Pole Creek
juniper projects described in Appendix N will not have adverse effects to cultural resources due to
implementation of project design features, which include site avoidance for treatments (e.g., jackpot
burning) and limitations on vehicle use and other activities in sites (USDI BLM 2012a p. 13; USDI BLM
2013 p. 15; USDI BLM 2017 pp. 26-27; USDI BLM 2018c pp. 20-21). The Gateway West Electrical
Transmission Line, Owyhee Roads Fuel Breaks, and Owyhee Desert Sagebrush Focal Area Fuel Breaks are
not in the CIAA for cultural resources.
Recreation
Although the impacts of most recreational activities on cultural resources are addressed through both the
NEPA process and the NHPA Section 106 process 24 when developed recreation sites are proposed, certain
dispersed recreational activities may have an adverse impact on cultural sites. Dispersed recreation may
impact known and unknown sites through ground-disturbing actions or unauthorized collection of artifacts.
It is not uncommon for people to collect historic or prehistoric artifacts, use grinding stones in campfire
rings, use wood from historic structures or features as firewood, or dig pits and trenches in campsites.
These actions could destroy the integrity of a site by moving artifacts from their original location,
24
Section 106 of the National Historic Preservation Act requires federal agencies to take into account the effect of an
undertaking on historic properties and afford the opportunity for comment. The implementing regulations at 36 CFR § 800
outline the procedures that federal agencies use to meet their statutory responsibilities.

degrading or destroying features, and disturbing the integrity of subsurface resources. Because there is no
way to know exactly where dispersed camping may take place, it is difficult to determine whether there
would be any cumulative effects from dispersed recreational activities.
Off-highway vehicle (OHV) use outside of designated trails can also adversely impact sites. OHV use on
an archeological site could damage the site through loss of soil and vegetation, gullying, deflation of
cultural deposits, and displacement and damage to artifacts and features (Sampson 2007). These impacts
are typically the result of repeatedly driving through a site; the magnitude of impacts is dependent upon soil
types and the type of resource being impacted. These impacts could range from short-term to long-term and
could range from no effect to major effects dependent upon the artifacts or features present on the site.
Livestock Grazing
Several studies indicate that livestock grazing can have adverse direct and indirect impacts on archeological
sites (Coddington 2008; USDI BLM 2006). “Direct impacts include trampling, chiseling, and churning of
site soils, cultural features, and cultural artifacts including artifact breakage. Impacts occurred from
standing, leaning, and rubbing against historic and prehistoric structures and features including rock art
panels. Indirect impacts included soil erosion and gully formation and increased access from roads and
trails that attract higher recreational use and vandalism. The studies concluded that areas of livestock
concentration could cause substantial ground disturbance and cumulative, long-term, irreversible adverse
effects to historic properties” (USDI BLM 2006).
Authorized livestock grazing is managed under grazing permits, and would continue to impact sites when
livestock congregate around gates, corrals, salt licks, troughs, water gaps and wet areas. Livestock
congregation areas typically result in trampling of sites and churning soils and loss of vertical spatial
integrity. These impacts could range from short-term to long-term and could range from no effect to major
effects, depending on the intensity of livestock grazing in the area, and on the artifacts and/or features
present on the site.
Weed Treatments
Effects of weed treatments in the Boise District were analyzed in the Boise District Noxious Weed and
Invasive Plant Management EA (USDI BLM 2018a), which is hereby incorporated by reference. This EA
determined that weed treatments would have minimal adverse impacts to cultural resources with the
applied design features, which include tribal consultation to minimize herbicide impacts to traditional
cultural properties and native plant gathering areas (USDI BLM 2018a, p. 32; 80). Limitations to off-road
vehicle use for spraying weeds reduces the chance of adversely impacting any cultural site. In the Vale
District, effects of weed treatments were analyzed in the Integrated Invasive Plant Management for the
Vale District EA (USDI BLM 2016b). This EA determined weed treatments would have a net beneficial
effect on cultural resources, including culturally important plants, in the long term (USDI BLM 2016b, p.
234). Avoidance of NRHP eligible or potentially eligible sites during ground-disturbing activities and
coordination with Tribes reduces potential adverse effects.
Lands and Realty

Energy, mineral and infrastructure development can cause irreparable damage to or destruction of cultural
resources. Past, present and foreseeable actions would have been or would be subject to the NHPA’s
Section 106 requirements of either avoiding adverse effects to cultural resources or mitigating for adverse
effects. Actions on adjacent private property could result in cumulative negative effects to a site where a
cultural site crosses property boundaries and NHPA compliance does not apply.

Road Maintenance
Road maintenance can have adverse impacts to cultural resource sites when roads through sites are
maintained through blading, grading, installing culverts or cattle guards, reconstructing or creating borrow
and wing ditches and rolling dips, and resurfacing roads with gravel. Direct impacts include scraping off a
layer of intact cultural deposits and redepositing them in another area, breaking artifacts, and destroying
features by using heavy equipment. Resurfacing a road with gravel of a different color than the surrounding
soil can create new visual contrasts and change the setting and feeling of the road itself and nearby
resources. Road maintenance that removes vegetation from the shoulders of roads can increase the potential
for erosion if vegetation does not quickly reestablish. Road maintenance on public lands may also
indirectly promote increased use by the public for recreational purposes due to easier access, increasing the
potential for illegal collection of artifacts and human-caused disturbances to cultural resources. Increases in
access and use can be detrimental to sensitive tribal resources, sites, and practices.
Current and ongoing ESR Plans

There are no expected adverse effects to cultural resources from the current and ongoing ESR plans in the
CIAA due to design features that include avoiding cultural resource sites during drill seeding (USDI BLM
2005a, p. 28; USDI BLM 2005b, p. 13). The landscape stabilization resulting from the ESR treatments will
benefit cultural resources by decreasing the potential for post-fire erosion and its effects.
Tumbleweed Burning (ongoing)

While fire can damage or destroy cultural resources, conducting tumbleweed burning limits fire intensity
and effects when live fuel moisture levels are high enough to retard fire beyond the tumbleweed
concentrations. Unidentified sites with combustible materials and rock art are the site types that could be
most negatively affected by tumbleweed burning. Owyhee Canyon has several known rock art sites.

Under the No Action Alternative, wildfires, recreation, livestock grazing, land and realty actions, and road
maintenance will continue to have negative impacts on cultural resources including NRHP eligible and
potentially eligible sites, historic roads, buried sites, and areas of tribal significance. Tumbleweed burning
may also have negative impacts to some rock art sites. ESR activities and weed treatments will help
stabilize landscapes, including cultural resources. Together, the past, present, and reasonably foreseeable
actions may have site-specific impacts ranging from major negative effects to negligible or stabilizing
effects. Major negative effects are expected to be uncommon. The No Action Alternative has the greatest
potential of all the alternatives for adverse impacts from fire and fire suppression activities to cultural
resources.

The incremental impact of Alternative 2 would be to decrease wildfire, fire suppression, and post-fire
rehabilitation impacts to cultural resources compared with the No Action Alternative. With both targeted
grazing and permitted grazing, the effects of grazing would be greater in Alternative 2 compared with the
No Action Alternative. Both the positive and negative impacts of Alternative 2 would be greater than in
Alternatives 3 and 4, because Alternative 2 proposes the greatest mileage of fuel break creation and
maintenance.
NRHP eligible and potentially eligible sites within the fuel breaks may experience negligible to moderate
negative direct impacts from treatments in addition to the impacts of the present and reasonably foreseeable
future actions. NRHP eligible and potentially eligible sites within mineral material sites would be avoided
and therefore experience no to negligible impacts. If the fuel breaks function as designed, both known and

unidentified sites within the larger project area would have a lower risk of fire due to fuel breaks decreasing
potential for fire spread. The incremental impact of Alternative 2 on the settings and features of historic
roads would likely be negative and may be a relatively large part of the cumulative impacts. The
incremental impact of Alternative 2 on buried sites would generally be small and negative. The incremental
impact of Alternative 2 on tribal practices and areas of tribal importance would be site-specific.

The incremental impact of Alternative 3 would include the same types of impacts as Alternative 2. Both the
positive and negative impacts of Alternative 3 would be less than in Alternative 2 because Alternative 3
was designed to minimize impacts to significant cultural resources by avoiding areas with a high
probability of containing cultural resource sites. Cumulative effects from development of mineral material
sites on cultural resources would be identical to those described for Alternative 2.

The incremental impact of Alternative 4 would include the same types of impacts as Alternative 2. Both the
positive and negative impacts of Alternative 4 would be less than in Alternative 2 because Alternative 4
proposes creation and maintenance of fewer miles of fuel breaks. With fewer miles of fuel breaks in
Alternative 4 compared with Alternative 3, both known and unidentified sites within the larger project area
would be at a slightly higher risk of wildfire. The number of estimated sites within fuel breaks is lowest in
Alternative 4, but Alternative 4 does not avoid areas modeled as having a high probability of significant
sites. Thus, the incremental impact of Alternative 4 on significant sites would be greater than in Alternative
3. Alternative 4 would have a greater incremental impact on the settings and features of historic roads and
trails than Alternative 3, because more miles of historic roads and trails were removed from Alternative 3.
The incremental impact of Alternative 4 on areas of tribal importance would be greater than in Alternative
3 because more significant cultural resource sites would be affected. Cumulative effects from development
of mineral material sites on cultural resources would be identical to those described for Alternative 2.
3.7 Paleontological Resources

Paleontological resources (fossils) have long been recognized for their scientific, educational, and
recreational value. A fossil is any evidence of past life, and includes body fossils such as shells and bones,
as well as trace fossils such as footprints, burrows, trails, or other evidence of an organism’s presence.
Fossils are preserved in rocks and are usually discovered when they are eroding out of the rock at the
surface, or during ground-disturbing activities such as road grading or trenching. Most individual
organisms that lived in the past did not die in such a way as to have their remains fossilized, and fewer still
will be collected and studied before they erode away. Therefore fossils are considered rare and
nonrenewable and are protected under the Paleontological Resources Preservation subtitle of the Omnibus
Public Land Management Act of 2009, otherwise known as the Paleontological Resources Preservation Act
(PRPA), and its future regulations.
In 2016, the BLM developed the Potential Fossil Yield Classification (PFYC) system to make initial
assessments for the potential of significant paleontological resources to be found in a mapped geological
unit in order to analyze potential effects from a Proposed Action under NEPA. In the PFYC system,
geologic units are assigned a class based on the relative abundance of significant paleontological resources
and their sensitivity to adverse impacts. The following classes were designed to be used as guidelines rather
than strict definitions (Table 3.7-1). See BLM IM 2016-124 (https://www.blm.gov/policy/im-2016-124) for
the full text of the PFYC system.

Table 3.7-1. Potential Fossil Yield Classification (PFYC) categories.
Class Paleontological Concerns Inventory Needed
Potential
Class 1 Very Low Negligible paleontological concerns No further assessment needed
Class 2 Low Generally low concerns unless known Only needed where known
paleontological resources paleontological resources occur
Class 3 Moderate Significant paleontological resources Mitigation based on Proposed
is low Action in known occurrences
Class 4 High Significant paleontological resources Field assessment by qualified
documented but vary in occurrence & paleontologist is normally needed
predictability
Class 5 Very High Significant paleontological resources Field survey by qualified
have been documented and occur paleontologist is almost always
consistently needed
Class U Unknown Potential Geological units suggest significant Lacking other information field
paleontological resources could be surveys are normally necessary
present but little information exists especially prior to ground-
disturbing activities
Class W Water Water bodies do not normally contain Consider shorelines and reservoirs
paleontological resources where resources may be uncovered
or transported
Class I Ice Receding glaciers and melting snow Consider exposed lateral and
fields may expose paleontological terminal moraines for potential to
resources yield resources
The geology within the 3.6-million-acre project area is predominately a mix of igneous and sedimentary
rocks ranging in age from the Cretaceous Period (~85 million years old) to the recent. The geology units as
mapped were ranked in the PFYC system. Based on the descriptions of the rock units from existing maps,
much of the project area is ranked with an unknown potential. Many of the mapped units could be ranked
as Class 1 based on their igneous origin. Whereas fossils are very unlikely to be preserved in igneous rock,
they do occur in subsequent deposits that occur on or within igneous rocks, as in the case of caves or
crevices that can contain fossil remains. Thus, even rocks ranked as very low in potential cannot be
discounted completely. For example, the Sucker Creek Formation in southwestern Idaho is classified as
very low under the PFYC system, however, a component of the formation is classified as having a high
potential (PFYC 4A) for significant fossils based on a known paleontological locality (Winterfeld & Rapp
2009, p. 134).
Many of the other rock units mapped in the area are sedimentary in origin, mostly of Neogene age (23
million to 2.6 million years old) or Quaternary (2.6 million to the present). The deposits include tuffaceous
sedimentary rocks, playa lake deposits, alluvium and alluvial terrace deposits, landslides, and other similar
units. Across the project area there are known paleontological localities that have yielded a wide variety of
fossil organisms. A summary of the known fossils from the area include bivalves, gastropods, ostracods,
turtle, rodent, horse, giant ground sloth, camel, elephant and elephant-like species including mammoth and
mastodon, rhinoceros, cats, dogs, fish, birds and plants. An inventory of fossil resources was made for the
Boise District in Idaho (Winterfeld and Rapp 2009), and localities in Oregon were reported by Walker and
Repenning (1966).
For the purposes of this analysis, the affected environment is considered the project area. Direct effects
would occur within the fuel breaks. Indirect effects would occur throughout the larger project area.
Construction of fuel breaks may lessen the potential for a large scale catastrophic wildfire that could do
irreparable harm to fossil resources either through direct fire damage to fossils or indirectly through

wildfire suppression activities. Within the larger project area, there are a total of 129 known paleontological
locations in Idaho and 47 in Oregon. The project area was classified according to the PFYC class and the
results are shown on Table 3.7-2.
Table 3.7-2. Number of acres of PFYC Class in project area.

PFYC Class Acres in Idaho Acres in Oregon Total Acres
1 704,501 507,961 1,212,462

2 28,819 108,392 137,211
Unknown 1,255,468 1,006,658 2,262,126
Water 1,144 2,481 3,625
Total - - 3,615,424
Direct effects to fossil resources would occur within the footprint of the fuel break for the chosen
alternative. The number of acres per PFYC that may potentially be affected are listed for each alternative in
the Table 3.7-3. The BLM has used the data from previously recorded resources and the best available
geological data in order to determine the PFYC. Analysis of the entire project area revealed that the only
PFYC classes were Class 1, 2, U (unknown) and W (water).
Table 3.7-3. Acres of PFYC classes on BLM & State lands within the direct effects analysis areas for
each alternative.1
Alternative PFYC Class Idaho Acres Oregon Acres Total Acres
1 11,605 9,026 20,631
2 2 1,187 1,315 2,502
Unknown 22,218 28,502 50,720
Water 2 0 2
Total - - - 73,856
- - - - -
1 7,122 6,419 13,541
3 2 1,072 508 1,580
Unknown 16,046 19,911 35,957
Water 2 0 2
Total 51,080
- - - - -
1 5,971 5,011 10,982
4 2 668 348 1,016
Unknown 14,991 16,802 31,793
Water 2 0 2
Total - - - 43,793
1
Acres are generated from the best available data and may not match acres proposed for treatment in each alternative.
Known paleontological localities within the fuel break foot print of the alternatives are given in Table 3.7-
4.

Table 3.7-4. Number of known paleontological localities per alternative by state.
Alternative Number of Paleontological Localities Total
2 Idaho 5
16
Oregon 11
- - - -
Idaho 4
3 Oregon 7 11
- - - -
Idaho 4
4 Oregon 8 12
The Antelope Reservoir and Deadman Waterhole proposed mineral material sites are in areas with a PFYC
of 1: very low. The White Chicken and Big Antelope proposed sites have a PFYC class of unknown. There
are no known paleontological localities at any of the proposed mineral material sites.
As specific areas for implementation are identified, paleontological inventories would be conducted prior to
ground-disturbing activities in areas where the potential for significant fossils is greatest based on the
PFYC class and the knowledge of existing fossils. Fossil localities would be assessed as to
recommendations for avoidance or appropriateness for treatments.

• What is the potential for implementation and maintenance of fuel breaks to adversely impact known
scientifically significant paleontological localities?
• What are the potential impacts to unknown scientifically significant paleontological localities (e.g.,
buried localities, etc.) from fuel break implementation and maintenance?
• What is the potential for the development and operations of mineral material sites to adversely
impact known and unknown scientifically significant paleontological localities?
3.7.2.2 Indicators
The primary factors for assessing the condition of paleontological resources are the integrity of the site and
the ability of the locality to answer important scientific research questions. Factors that could affect the
integrity of the locality include:
• Fossils damaged through breaking or burning.
• Unauthorized collection of scientifically unique fossils.
• An increase in the occurrences of natural processes (e.g., erosion) that results in the loss of
resources.
3.7.2.3 Assumptions
• Most paleontological resource locations in the project area are not known.
• Previously unidentified resources could be exposed by ground-disturbing activities.
• Ground-disturbing activities within the treatment areas have the potential to redistribute and
damage fossils.
• Treatments could increase the visibility or exposure of fossils.

Under the No Action Alternative, a fuel break network would not be created. Therefore, impacts to
paleontological resources would not occur as a result of fuel break construction (i.e., ground disturbance).
However, the project area would remain subject to future fire incidents, which may result in direct
irreparable damage to, or destruction of, paleontological resources through high intensity fires and
indirectly through wildfire suppression activities, such as the creation of bulldozer lines, that may occur
during an incident. Direct impacts of fire on fossils can create discoloration or fracturing depending on the
severity of the fire. Indirect impacts from fire would include destruction of fossils or digging up intact
fossil deposits from bulldozer constructed lines, loss of vegetation resulting in exposure of artifacts and
potential unauthorized collection, and an increase in erosion that would result in movement of artifacts
from their original locations. Direct and indirect impacts to paleontological resources from wildfire would
range from negligible to major. Without the proactive construction of fuel breaks, the risk of large fires and
associated suppression activities to paleontological resources would be highest in the No Action
Alternative.

Direct and indirect impacts to paleontological resources are generally similar to those discussed for
Cultural Resources (See section 3.6.2.4). Ground-disturbing activities associated with vegetated fuel breaks
may have significant impacts on paleontological localities through breakage of fossils, movement of fossils
from intact deposits, and exposing buried fossils resulting in weathering or unauthorized collection.
Appropriate treatment types within a fossil locality would be determined on a site-by-site basis to minimize
adverse impacts. As described below, most impacts from the various vegetated fuel break treatments are
expected to be negligible to minor with implementation of the paleontological design features. However,
these design features apply only to previously identified resources. Impacts may still occur on unrecorded
fossil localities in un-surveyed areas. Over the long term, action alternatives are expected to limit damage and
destruction of paleontological resources associated with high intensity fires, fire suppression, and post-fire
rehabilitation by reducing the acres burned in wildfires.
Targeted Grazing
Direct impacts on paleontological resources would occur as a result of trampling, particularly when cattle
are concentrated in one area due to salt/mineral or water trough placement or near gates. Trampling may
result in churning of soils and disturbance, destruction, or breakage of fossils. Direct impacts would be
considered long-term and moderate to major. Indirect impacts from targeted grazing would include soil
erosion and unauthorized collection of fossils that become more visible from reduced vegetation. Major
long-term impacts would be expected to occur within 200 feet in any direction of water and salt/mineral
supplementation sites or fence gates. Targeted grazing could also impact buried fossils by exposing them or
trampling them, particularly when soils are wet or saturated. Repeated use of targeted grazing in the same
location (e.g., as the primary treatment method) would have greater impacts than a single application of
targeted grazing (e.g., as seedbed preparation). Design features (Appendix G) for sites where significant
paleontological resources are exposed on the surface would minimize ground-disturbing activities like
targeted grazing.

New material source development would not impact any known paleontological localities. Unknown
paleontological resources, if present, could be destroyed by material source development. Paleontological
inventory in locations with unknown PFYC would reduce the likelihood of impacting unknown or buried
paleontological resources to negligible. Impacts to any newly discovered paleontological resources from

development of new material sources would be avoided through project design. No material source sites
would be developed in a manner that would impact a significant paleontological resource.
Mowing
Direct effects to fossils would include obscuring them by pushing them into softer soil or by being covered
with mowed material. The use of a rubber tired tractor with relatively small ground pressure should not
create significant fossil breakage, but may push some fossils into softer soils; certain vulnerable fossils
could be permanently damaged from the impact of tires rolling over them. Indirect effects of mowing would
include exposure of fossils to increased weathering and potentially unauthorized collection due to removal
of the vegetative cover. Mowing would have no effect on buried fossils. Design features (Appendix G) for
sites where significant paleontological resources are exposed on the surface would minimize ground-
disturbing activities like mowing.
Hand Cutting
Within a fossil locality, vegetation may be hand cut to reduce fuels and fire intensity during a wildfire.
Vegetation would either be lopped and scattered or carried off site for piling. Piling large amounts of
residual debris for burning would not be allowed on a fossil locality. Where large amounts of debris exist
following treatments, a chipper may be used. Large amounts of chipped material create a bed of flammable
material that, depending on the thickness, could produce high temperatures over a long duration and could
create a moderate to major effect to fossils that includes discoloring and fracturing of the fossil depending
on the fire intensity. Chipped materials would not be spread over fossils that are exposed on the surface.
Direct impacts to fossils from hand cutting would be considered negligible and would be short-term.
Indirect effects from hand cutting vegetation would potentially be an increased exposure of fossils, but
scattering branches may temporarily cover them, making them less visible and protecting them from
unauthorized collection. An indirect impact of hand cutting and removing fuel from fossil localities is
decreased fire intensity and severity in the site, in the event of a future fire. Hand cutting would have no
effect on buried fossils.
Chemical Treatment
Herbicides would only be applied through the use of hand sprayers, aerially, or from vehicles that stay on
existing roads. UTV/ATV-mounted sprayers may also be used when soils are not wet or saturated and
without turning in fossil localities to avoid disturbance of soils. Direct effects to fossils would come from
breakage of fossils due to tire impacts from UTV/ATVs. These impacts would be negligible to minor.
Herbicides would not be used in or around a fossil locality when complete removal of vegetation is the
desired outcome prior to seeding, even if temporary. Lack of vegetation would be an indirect impact by
potentially exposing fossils to unauthorized collection and increased weathering, and exposed soil would be
more susceptible to erosion, resulting in fossil movement that would adversely impact the integrity of the
fossil locality. Herbicides would only be used to reduce undesirable annual grasses or other undesirable
plants within an existing plant community in the fuel treatment zone. Therefore, chemical treatments would
have negligible to minor effects to known fossil locations. There would be no effect from herbicides on
buried fossils.

The characteristics of the proposed plant seedings would be effective in reducing the spread of wildfire and
decreasing fire intensity burning across a resource. Therefore, the potential for future direct and indirect
impacts on fossils as a result of fire and wildfire suppression activities could be decreased.
Seeding may require mechanical seedbed preparation such as disking to reduce competition prior to planting.
Other seedbed preparation techniques (herbicides, prescribed fire, targeted grazing) are described under their

respective headings within this section. Avoiding fossil localities during seeding may increase the visibility of
their locations as they would be contrasting untreated pockets in a treated matrix (Halford et al. 2016).
Disking
Within any known paleontological site, design features (Appendix G) would prevent disking. Due to the
heavy ground-disturbing nature of disking, the potential for disturbance to unknown fossils from this
activity is considered major and long-term. Disking through a fossil locality would have a direct negative
impact to the site’s vertical and horizontal spatial integrity through churning soil up to nine inches deep.
Disking can permanently break fossils, and either cover or uncover fossils through soil movement. After
disking, indirect impacts include the potential for soil erosion where silty or loose soils are prevalent and
vegetation has not grown back or the area has not been immediately seeded. Indirect impacts from erosion
would expose fossils potentially resulting in unauthorized collection, increased weathering or moving
fossils from their original locations negatively impacting their integrity. These impacts could be minor to
major. With implementation of the paleontological design features, the potential for major impacts to
known paleontological localities would be reduced to negligible (Appendix G).
Drill Seeding
Rangeland drills, minimum-till drills or no-till drills would be utilized, depending on soils and topography.
Rangeland drills result in disturbance between 1 and 6 inches in depth. A minimum-till drill would also
result in disturbance, but to a lesser depth. Such disturbances within a fossil locality could result in direct
major long-term impacts through breakage of fossils and movement from their original location thereby
negatively affecting the locality’s integrity. Turning a drill seeder could also have direct impacts from soil
disturbance associated with turning. An indirect impact would include increased soil exposure and churning
up previously buried fossils thus exposing them to unauthorized collection and increased weathering.
Indirect impacts could include erosion from loosened soil resulting in movement of fossils.
Broadcast Seeding
Mechanized equipment, such as UTV/ATVs with mounted spreaders or a rubber-tired tractor with a boom,
could have moderate to major impacts to fossil localities when turning within a site by displacing or
damaging fossils. Some fossils could also be permanently damaged from the impact of tires rolling over
them. Cover treatments would utilize a harrow, culti-packer, or roller packer implement when possible.
These pieces of equipment would have less ground disturbance than a drill seeder; however the potential
for direct impacts is present and dependent upon certain variables such as soil composition and the fossil
type. Use of a harrow would likely result in dragging, damaging, displacement and burying of fossils. The
primary disturbance from the culti-packer and roller packer would occur from the vehicle tires when
turning and possibly from burying and breakage of artifacts. Broadcast seeding would only occur when
soils are firm and vehicles would not turn within fossil localities.
Prescribed Fire
Burning vegetation in areas with paleontological resources would be considered on a site-by-site basis.
Research has shown that fossil specimens that come into contact with burning fuel will be directly affected
through discoloration and fracturing depending on the intensity of the fire (Benton and Reardon 2006). In
addition to the direct effects, the reduction of vegetation on a paleontological locality may indirectly result
in an increased exposure of fossils that may result in unauthorized collection and increased weathering of
fossils.
Pile burning in a fossil locale can result in high heat for a long duration which can directly impact exposed
surface fossils and buried fossils close to the surface through fracturing and discoloration. Thus pile
burning would not occur where fossils are visible on the surface or shallowly buried (Appendix G).

Roadbed Vegetation Clearing
The use of heavy equipment to blade roads free of vegetation has the potential to cause direct long-term
irreversible damages to a significant paleontological locality. Each time a road is bladed through a fossil
locality, it removes a layer of soil that cuts deeper into the deposits, possibly removing, displacing, and
fracturing fossils. Therefore, blading through a significant paleontological locality would be avoided.
Roads that require removal of vegetation would be surveyed for paleontological resources prior to
implementation if the road falls within a PFYC Class 3-5 or the treatment area is located near known
occurences to identify areas requiring manual vegetation removal. In these areas, less ground-disturbing
methods would be employed that include hand cutting vegetation and/or herbicide treatments to eliminate
vegetation in the roadbed. Although these methods eliminate direct impacts from ground disturbance, they
may result in indirect impacts that include exposure of fossils in the road that may result in unauthorized
collection of fossils, or an increase in erosion where there is no vegetation to keep soils in place. Collection
of fossils and significant erosion within a locality that would potentially damage or displace fossils would
cause long-term irreversible impacts.
Fuel Break Maintenance

The use of a combination of treatments for fuel break construction and the repeated application of
treatments for fuel break maintenance or reestablishment increases the impact to paleontological resources
over a single treatment application. Multiple treatment applications may have additive effects, but as a
particular type of disturbance increases, additional effects would tend to taper off. Where a resource is
completely avoided by a treatment due to design features (Appendix G), repeated applications of the
treatment with the same avoidance would continue to have no effect on the resource. The design features
would therefore reduce the impact of fuel break maintenance on paleontological resources to negligible to
minor.
The potential for long-term major impacts under this alternative is greater than the other alternatives given
the larger area of fuel break disturbance. The vegetation matrix and fuel break objectives recommend
treatment on 67,559 acres in the Proposed Action. Although the number of known paleontological localities
is fairly low (16) and the PFYC classifications are mainly low and unknown within the proposed treatment
area, there are significant fossil locations that would be affected by fuel break treatments. Under this
alternative, there is one known paleontological locality in Idaho that has a road proposed for blading
passing through it.
Additional surveys would be required where significant fossils would be expected. Adherence to the design
features would limit impacts, reducing impact severity from major to negligible (Appendix G).
The potential for long-term major impacts under this alternative is less than the other action alternatives
since the location of concentrations of significant fossil locations were avoided during development of the
alternative. The vegetation matrix and fuel break objectives recommend treatment on 45,872 acres in
Alternative 3. Although the number of known paleontological localities is fairly low (11) and the PFYC
classifications are mainly low and unknown within the proposed treatment area, there are significant fossil
locations that would be affected by fuel break treatments. Under this alternative, no known paleontological
localities are present in roads proposed for blading.
features would limit impacts reducing impact severity from major to negligible (Appendix G).

The potential for long-term major impacts under this alternative is less than Alternative 2 but slightly
greater than Alternative 3, since the location of concentrations of significant fossil locations were avoided
during development of Alternative 3. The vegetation matrix and fuel break objectives recommend
treatment on 38,044 acres in Alternative 4. Although the number of known paleontological localities is
fairly low (12) and the PFYC classifications are mainly low and unknown within the proposed treatment
area, there are significant fossil locations that would be affected by fuel break treatments. Under this
alternative, there is one known paleontological locality in Idaho that has a road proposed for blading
passing through it.
features would limit impacts, reducing impact severity from major to negligible (Appendix G).

The geographic scope of analysis for cumulative effects on paleontological resources (i.e., cumulative
impact analysis area) is the project area. The project area provides context for the direct and indirect effects
of the fuel breaks by including the extent of the fossil-bearing geologic formations potentially affected by
the alternatives. The temporal scope is the life of the project to capture the potential long-term effects of the
project and all of the reasonably foreseeable future actions within the geographic scope.

Present and reasonably foreseeable future actions in and near the project area are presented in Appendix N.
The Soda Fuel Breaks Project, Bruneau Fuel Breaks Project, Bruneau-Owyhee Sage-grouse Habitat
Project, the Trout Springs and Pole Creek juniper projects, weed treatments, and land and realty actions
will not have adverse effects to paleontological resources due to implementation of design features,
including avoidance (USDI BLM 2017 pp. 26-27; USDI BLM 2018c pp. 20-21).
Recreation, livestock grazing, road maintenance, current/ongoing ESR plans, and ongoing tumbleweed
burning could result in cumulative impacts to fossils similar to those discussed under the cumulative effects
section for cultural resources (3.6.3.2). Any ground-disturbing activities, such as road maintenance, OHV
use outside of designated trails, livestock grazing, seeding, and reduction of vegetation through burning,
disking, or mowing, could expose fossils to erosion, breakage, or unauthorized collection, particularly
unknown localities. Unidentified fossil-bearing outcrops against which tumbleweeds accumulate could be
most negatively affected by tumbleweed burning through fracturing and discoloring of fossils, reducing the
likelihood of accurate species identification and scientific analysis.

In the absence of fuel break construction, impacts to paleontological localities would continue from
wildfires, dispersed recreation, livestock grazing, and road maintenance. Under this alternative, the greatest
potential for adverse impacts would be from large and/or more frequent wildfires and associated
suppression and post-fire rehabilitation actions. Impacts to paleontological resources would be short- to
long-term and range from negligible to major.

Cumulative impacts to paleontological resources may occur from dispersed recreation, wildfires, livestock
grazing, road maintenance, construction and maintenance of fuel breaks (200-foot-wide mowed and/or

seeded fuel treatment zones with roadbed vegetation removal on some roads), and development of mineral
sites with water wells in Oregon. Paleontological resources may be damaged, dispersed, or collected
resulting in long-term irreversible impacts; however Alternative 2 includes design features that would
reduce impacts to paleontological resources to negligible to minor (Appendix G). Alternative 2 would have
minor adverse cumulative impacts to paleontological resources with implementation of the proposed design
features. Within areas that were avoided by wildfire due to improved suppression response facilitated by
fuel breaks, any existing paleontoligical localities would remain undisturbed.

Cumulative impacts would be similar to those discussed under Alternative 2, however, development of this
alternative took into account paleontological resources and removed roads with known localities of
significant fossils. Because 21,687 fewer acres would be treated under this alternative, there would
potentially be fewer paleontological localities in the project area. With fewer localities and implementation
of the design features, Alternative 3 would result in minor adverse cumulative impacts to paleontological
resources.

Cumulative effects would be similar to those discussed under Alternatives 2 and 3, however this alternative
did not take into account localities of significant paleontological resources. Under this alternative 7,828
fewer acres than Alternative 3 and 29,515 fewer acres than Alternative 2 are proposed for treatment. With
fewer localities than Alternative 2 and implementation of the design features, there would be minor adverse
cumulative impacts to paleontological resources associated with Alternative 4.
3.8 Wilderness Study Areas

Section 603(a) of the Federal Land Policy and Management Act of 1976 (FLPMA) directs the BLM to
review areas found to possess wilderness characteristics and recommend to the President those areas
suitable for preservation as wilderness by Congress. In order to be identified as having wilderness
characteristics, a roadless area must (1) meet the minimum size requirement (5,000 acres or adjacent to
Wilderness or a Wilderness Study Area), (2) possess naturalness (i.e., generally appear to be affected by the
forces of nature, with the evidence of humans substantially unnoticeable), and (3) provide outstanding
opportunities for solitude or primitive and unconfined recreation. Areas recommended for preservation as
wilderness are Wilderness Study Areas and managed to maintain suitability for designation as wilderness
by Congress.
The Tri-state Fuel Breaks Project area contains no Wilderness Study Areas (WSAs) in Idaho. In Oregon,
the proposed project area contains portions of four Wilderness Study Areas: Bowden Hills, Lookout Butte,
Owyhee River Canyon, and Upper West Little Owyhee. Each WSA is summarized briefly in Table 3.8-1
and in greater detail in Appendix M. Complete descriptions of each WSA are available in Volume 1 of
Oregon BLM Wilderness Study Report (1999). Until acted upon by Congress, the BLM manages
Wilderness Study Areas in accordance with BLM Manual 6330 - Management of Wilderness Study Areas
(USDI BLM 2012b).

Table 3.8-1. Wilderness characteristics of WSAs in project area.
WSA Total Size Wilderness Criteria Met
[Y: Yes; N: No]
Size Naturalness Solitude Recreation Supplemental

Values
Bowden Hills 59,031 Y Y Y N Y
Lookout Butte 66,194 Y Y Y N N
Owyhee River Canyon 187,344 Y Y Y Y Y
Upper West Little Owyhee 61,489 Y Y Y Y Y
Prior to the effects of industrialized humans and the introduction of non-native annual grasses, the
landscape in these WSAs consisted entirely of native species, predominately bluebunch wheatgrass and
miscellaneous forbs and native sagebrush species. The ratio of bluebunch wheatgrass to sagebrush in any
given location was an ever changing mosaic; in the absence of fire, sagebrush stands dominated. Wildfires
transitioned burned areas to native grasslands, then sagebrush would slowly, naturally reestablish, and the
cycle would start over with the next lightning strike.

How would implementing and maintaining fuel breaks and mineral material sites affect Wilderness Study
Areas (size, naturalness, outstanding opportunities for solitude and recreation, or supplemental values)?
3.8.2.2 Indicators
To ensure the Congressional mandate to manage Wilderness Study Areas "so as not to impair the suitability
of such areas for preservation as wilderness" will be met, BLM Manual 6330 (USDI BLM 2012b) provides
guidance to protect Wilderness Study Areas’ existing wilderness characteristics:
• Size. Inventory unit boundaries are formed by wilderness inventory roads, property lines,
developed rights-of-ways, or other substantially noticeable imprints of human activity.
• Naturalness. Affected primarily by the forces of nature, and any human work must be
substantially unnoticeable. Naturalness is defined as apparent naturalness. Apparent naturalness
refers to whether or not an area appears natural to the average visitor who is not familiar with
the biological composition of natural ecosystems.
• Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation. Factors
influencing the opportunities for solitude are size, configuration, topographic screening and
vegetative screening.
• Supplemental Values. Ecological, geological, or other features of scientific, educational,
scenic, or historical value. These values may be present in an area with wilderness
characteristics, but they are not required.
3.8.2.3 Assumptions
• The visual impacts to naturalness would vary depending on the point of observation and
topography.
• Vegetation treatments have the potential to create a visual contrast line that would impact
naturalness in Wilderness Study Areas. The effects of some treatments would diminish within a
single season, while the impact from mowing could persist for a minimum of 5-7 years.

The No Action Alternative would result in no fuel breaks being constructed in the project area (i.e., no
modification of vegetation in the fuel treatment footprint). There would be no direct impact to Wilderness
Study Areas. However, the long-term trend of conversion of native grasslands to invasive annual grasslands
resulting from disturbances such as recurring wildfire would continue, decreasing the biological naturalness
of these lands. Potential impacts to WSA values due to fire and associated fire suppression include
blackened vegetation and soil, as well as bulldozer lines. The visual impacts of bulldozer lines would
remain apparent until the regrowth of vegetation masked the disturbance. With proper post-fire
rehabilitation techniques, this could take 5 to 7 years. Because fuel breaks would not facilitate an improved
suppression response to reduce acres burned, future costs associated with post-fire rehabilitation in the four
affected WSAs (Table 3.8-1) would likely be highest under this alternative.

• Size. No action proposed in this project would add or alter wilderness inventory roads, property
lines, or developed rights-of-way. There would be no impact to the size of any WSA.
• Naturalness. When analyzing “naturalness” in the context of wilderness characteristics, it is
important to note “naturalness” is defined as apparent naturalness. Apparent naturalness refers to
whether or not an area looks natural to the average visitor who is not familiar with the biological
composition of natural ecosystems. “Naturalness” in this context considers primarily visual impacts
to the landscape. Naturalness would be impacted by the proposed project and is discussed by
specific methods below.
• Outstanding Opportunities for Solitude or Primitive Unconfined Recreation. The proposed
project would not impact size, configuration, or topographic screening. Bowden Hills, Owyhee
River Canyon, and Upper West Little Owyhee WSA do not list vegetative screening as a
component contributing to solitude. Lookout Butte WSA does list vegetative screening, in
combination with size and topographic screening. Vegetative screening (i.e., brush) that is greater
than 12 inches in height would be mown to a height of between 6-10 inches. The amount of brush
being removed within the fuel breaks (1.1% of total acreage in Lookout Butte WSA) is negligible
when compared to the brush across the landscape. In addition, most outstanding opportunities for
solitude and primitive and unconfined recreation are located farther from wilderness inventory
roads in the interior of WSAs, where the road and treatment would not be visible. The project
would therefore have no effect on the opportunities for solitude or primitive and unconfined
recreation in affected WSAs.
• Wildfire Protection. Effects from implementation of a fuel break network would contribute to the
protection of the wilderness characteristics of the WSAs, naturalness, outstanding opportunities for
solitude and recreation, and supplemental values. Because construction of fire lines during fire
events in WSAs is an emergency action, it is not always feasible to minimize impacts to wilderness
characteristics associated with suppression response. Design features would minimize direct effects
of fuel breaks to wilderness characteristics of WSAs. Over time, fuel breaks would help reduce
acres burned in WSAs, thereby preventing or combating conversion of native vegetation to invasive
annual grasslands in these areas. By protecting current and future rehabilitation and restoration
projects in WSAs from wildfire, fuel breaks would contribute to maintaining or enhancing existing
ecosystems. The reduction of acres burned through the implementation of fuel breaks is only one
tool to help meet the overall goal of bringing ecosystems in the affected WSAs back to the point
where natural processes can resume.

• Ongoing Detectable Effects. Effects from fuel break maintenance for Alternatives 2, 3, and 4
would be detectable for the life of the project.
Mowing
Mowing would cut shrub branches and foliage to a height of 6-10 inches within the treatment footprint. A
visual contrast would be created at the interface where mown vegetation meets unmown vegetation. There
would be a slight difference in color between the treatment footprint and the untreated landscape. This
color difference would be due to the new growth of the mown sagebrush, which would differ slightly in
color from the older sagebrush outside the treatment footprint. In the short term, impacts to naturalness
from mowing would be minor but easily detectable directly after initial treatment and subsequent
maintenance. Newly mowed fuel breaks would be visible to the casual observer, however their visual
impact is expected to be insubstantial with a feathering design feature that would create a more apparently
natural gradient between the mowed area and the adjacent landscape (Appendix G). Over the long term,
impacts to naturalness would become only slightly detectable as the fuel break treatment fades and the
mowed fuel break appears increasingly integrated with its surrounding landscape as a result. The cyclic
nature of mowing’s visual impacts changing between maintenance intervals from easily detectable to
slightly detectable would go on for the life of the project.
Hand Cutting
Hand cutting of vegetation would be used when rugged and/or steep terrain or resource concerns restrict the
use of mechanized equipment. The effects to naturalness from hand cutting would be less than mowing, as
hand crews could more easily blend the line than could be done mechanically. This blending would create a
more natural appearance. This visual contrast would create minor short- and long-term impacts to
naturalness.
Seeding & Seeded Fuel Break Preparation

Similar to all above methods, seeding would create a visual contrast at the interface between seeded and
non-seeded landscape. Herbicides would be used before or after seeding to inhibit the germination of
noxious weeds and invasive annual grasses. This visual contrast would be most noticeable at the time of
treatment and fade over time as vegetation at the contrast line starts to blend. A contrast could also develop
seasonally as differing grasses cure at different rates. Annual grasses tend to cure earlier in the season than
the perennial grasses that would be planted in the treatment footprint. All grasses inside and outside the
treatment footprint would be green in the spring, but as grasses cured at differing rates throughout the
spring and into the summer, some visual contrast in color may become apparent. In the fall, grasses inside
and outside the treatment footprint would be cured and again be similar in color. Overall, the visual contrast
introduced by seeded fuel breaks would create minor short- and long-term impacts to naturalness. Effects
from fuel break maintenance for all seedbed preparation and maintenance treatments (i.e., herbicide,
disking, prescribed fire, targeted grazing) would be detectable for the life of the project.
Visual drill rows would be an unacceptable visual impact in a WSA. Design features (Appendix G) such as
broadcast seeding, no-till drills, or modified range drills would be used. The planting of prostrate kochia
would not be allowed in a WSA because of the high visual contrast the plant could introduce.
Chemical Treatment
Herbicides could be used to prepare the seedbed for a seeding, to maintain a fuel break by reducing the
amount of fuel available for wildfire, and to reduce the prevalence of annual grasses in stands of perennial
grass. A linear feature would be created at the interface between treated and untreated foliage when used
for seedbed preparation; this contrast would be most noticeable right after treatment and fade with time as
desired species repopulate the treatment footprint. This linear feature would create moderate short-term

impacts to naturalness. In the long term, adverse impacts to naturalness associated with herbicide would be
minor. Where used to treat invasive annual grass and noxious weeds, herbicide would contribute to
naturalness over the long term by improving the competitiveness of native vegetation.
Targeted Grazing
For the duration of the targeted grazing treatment, temporary fencing, temporary water haul sites, and
mineral supplements would be visible imprints of human activity, however they would be removed within
48 hours of the end of the treatment (Appendix G). A linear feature would be created where livestock graze
up to the temporary fence line. The contrast would be created by the differing height of the grazed
vegetation in the treatment footprint and the ungrazed vegetation outside the treatment footprint. This
contrast would be most noticeable right after livestock were removed. The following spring, vegetation
would regrow and treatment would be repeated. The visual impact to naturalness would change seasonally
as livestock remove vegetation and regrowth occurs. This linear feature would create minor short-term
impacts to naturalness that would fade with regrowth, recur with additional treatment, and remain
detectable for the life of the project.

As they pertain to WSA and lands with wilderness characteristics, there are two types of roads or routes:
Wilderness inventory roads are transportation linear features that have been improved and maintained by
mechanical means to insure relatively regular and continuous use. These roads create the boundary of a
unit. They are external to the WSA or lands with wilderness character unit.
Primitive routes include any transportation linear feature located within areas that have been identified as
having wilderness characteristics that does not meet the definition of a wilderness inventory road. These
routes were generally established or have been maintained solely by the passage of vehicles. These routes
are internal to the WSA or lands with wilderness character unit.
No primitive routes within WSAs are proposed for fuel break implementation in any of the action
alternatives. Where a WSA is bounded by a road, the WSA boundary is the edge of disturbance of that road
that existed at the passage of FLPMA. No roadbed vegetation removal would occur within any WSA in the
project area.

Because no mineral material sites are proposed in WSAs, no impacts to WSAs are anticipated from their
development and operations.
3.8.2.6 All Action Alternatives

To meet the FLPMA Sec 603(c) mandate, the BLM developed the “non-impairment standard” to ensure its
actions within WSAs minimally disturb the landscape. The BLM reviews all proposals for uses and/or
facilities within WSAs to ascertain whether the proposal would impair the suitability of the WSA for
preservation as wilderness. Unless excepted under section 1.6.C.2 of BLM’s Management of Wilderness
Study Areas Manual (Manual 6330, USDI BLM 2012b), all uses and/or facilities must be both temporary
and create no surface disturbance in order to meet the non-impairment standard. Because fuel break
implementation and maintenance would result in periodic surface disturbance (associated with seeding,
mowing, prescribed fire and targeted grazing) over the long term, action alternatives would not meet the
non-impairment standard. Therefore, the BLM evaluated whether an exception to the non-impairment
standard would be appropriate to construct and maintain fuel breaks on the designated side of boundary
roads of WSAs.

Manual 6330 (USDI BLM 2012b, p. 1-11) describes seven classes of allowable exceptions to the non-
impairment standard. Exception F (USDI BLM 2012b, p. 1-12), Protect or enhance wilderness
characteristics or values, is most directly applicable to the proposed Tri-state Fuel Breaks Project: “Actions
that clearly benefit a WSA by protecting or enhancing their wilderness characteristics are allowable even if
they are impairing; although they must still be carried out in a manner that is least disturbing to the site.”
Under the non-impairment standard or one of the exceptions, BLM may conduct fuel treatments to replace
wildfire only if the treatments meet one of three conditions below (USDI BLM 2012b, p. 16):
A. Prescribed fire in the WSA will inevitably cause unacceptable risks to life, property, or natural
resources outside the WSA; or
B. Natural successional processes have been disrupted by past human activity to the extent that
intervention is necessary in order to return the ecosystem to a condition where natural processes can
function; or
C. Non-native species have altered the fire regime so that wildland fires pose an undue risk to the
native ecosystem.
In each action alternative, the BLM would invoke exception F and condition C in all four affected WSAs –
Bowden Hills, Lookout Butte Owyhee River Canyon, and Upper West Little Owyhee WSA – in order to
construct fuel breaks on the designated side of boundary roads of these WSAs. The BLM’s rationale for
invoking these exceptions in each affected WSA is explained further in Appendix M. All fuels treatment
within WSAs would be done with the least impacting tool (Appendix G), and would be done to protect
wilderness characteristics from large scale wildfire and wildfire suppression impacts.
No WSA’s size, outstanding opportunities for solitude or primitive and unconfined recreation, or
supplemental values would be affected by any action alternative. However, action alternatives would result
in some effects to wilderness characteristics: a slight linear contrast between the fuel treatment zone and
surrounding vegetation on the perimeter of WSAs would be present, although design features would avoid
a visible hard edge by blending the treatment into the surrounding natural landscape. Over the long term,
proposed fuel breaks would allow suppression resources to be more responsive to wildfires within the
affected WSAs, resulting in improved protection of the wilderness resource and existing ESR treatments
due to decreased burn footprints and fewer acres converted to invasive annual grasses. In Alternatives 3 and
4, impacts and benefits to WSAs would be limited to smaller treatment areas, but would otherwise be
identical to those described above.
Fuel breaks would be developed along 232 miles of WSA boundary roads in Oregon under this alternative.
Developing fuel breaks on these boundary roads would affect 5,213 acres of vegetation within four separate
WSAs (Bowden Hill, Owyhee River Canyon, West Little Owyhee River, and Lookout Butte). This
alternative would have the greatest impact among alternatives, however it also would provide the most fire
protection to WSAs’ values by reducing the extent of burned acres within WSAs, associated suppression
disturbance (e.g., bulldozer lines), and post-fire rehabilitation activities (i.e., seeding).
Alternative 3 would minimize impacts to WSAs by reducing the number of WSA boundary roads where
fuel breaks are implemented. Impacts to WSAs that are described in Alternative 2 would apply to 2,084
acres of WSA along 97 miles of WSA boundary roads, or 3,129 acres less than the Proposed Action. The
WSAs in the project area would benefit from the implementation of this alternative because of fuel break
development, but not to the extent they would benefit under Alternative 2.

Impacts to WSAs that are described in Alternative 2 would apply to 2,450 acres of WSAs along 101 miles
of WSA boundary roads, or 2,764 acres less than Alternative 2. The difference in acres of WSAs affected
under Alternatives 3 and 4 is not anticipated to be meaningful for either adverse impacts of fuel break
creation and maintenance or increased fire protection. Therefore, Alternatives 3 and 4 would be expected to
cause similar impacts and benefits to WSAs.

The cumulative impact analysis area (CIAA) consists of the four affected WSAs within the Vale District.
The timeframe of analysis would be for the life of the project.

Present and reasonably foreseeable future actions that have had, are having, and/or are expected to affect
WSAs are primarily vegetation treatments.
Current ongoing and proposed ESR treatments are described in Appendix N. These ESR treatments would
generally improve WSAs within the CIAA over the long term. Cumulatively, vegetation treatments are a
small percentage of the overall size of the CIAA. It is unclear whether vegetation projects would be
implemented concurrently. Depending on the timing of each project’s implementation, cumulative adverse
impacts to the naturalness of WSAs could be moderate in the short term as vegetation treatments create
localized imprints of human activity. In the long term, as treatments and restoration projects become
integrated into the landscape, these actions would result in cumulatively beneficial impacts to the
naturalness of WSAs.

Without the addition of a new system of fuel breaks, cumulative impacts to WSAs would likely continue
current trends driven by vegetation treatments as described above. Within the CIAA, zero acres would be
treated as fuel breaks, and wilderness characteristics would therefore be at a higher risk of impacts
associated with wildfire and related suppression activities. Compared to action alternatives, existing post-
fire rehabilitation projects would be exposed to a greater threat from recurring wildfire. In addition, future
post-fire rehabilitation costs associated with larger burn footprints may preclude other actions, such as
restoration projects, that could benefit wilderness characteristics.

Cumulative impacts to WSAs would continue current trends driven by vegetation treatments as described
above. Within the CIAA, a total of 5,213 acres of fuel break treatments would occur under Alternative 2.
Across treated acres, the incremental impact of Alternative 2 would extend traces of human activity from
roadways to the 200-foot-wide fuel treatment zone and provide firefighters with established anchor points
from which to fight fire in WSAs. Design features would prevent substantially noticeable imprints of
human activity in the fuel treatment zone. Effects from fuel break maintenance would be detectable for the
life of the project across this treatment footprint.


3.9 Lands with Wilderness Characteristics

Lands with wilderness characteristics are areas that are outside of existing Wilderness Study Areas and
designated Wilderness areas that BLM has identified as having wilderness characteristics. In order to be
identified as having wilderness characteristics, the area must (1) meet the minimum size requirement (5,000
acres or one of the size exceptions), (2) possess naturalness (i.e., generally appear to be affected by the
forces of nature, with the evidence of humans substantially unnoticeable), and (3) provide outstanding
opportunities for solitude or primitive and unconfined recreation. The inventory and management of lands
with wilderness characteristics are governed by BLM Manual 6310 and 6320 respectively.
Oregon
In Oregon, until the BLM Vale District Office completes a land use plan amendment and environmental
impact statement (EIS) addressing management of lands possessing wilderness characteristics, a settlement
agreement (ONDA v. BLM, No. 05-35931 (9th Cir. 2010) prohibits projects that would diminish the size of
an inventory unit determined by the BLM to possess wilderness characteristics, or cause the entire BLM
inventory unit to no longer meet the criteria for wilderness characteristics. The settlement agreement further
requires that in preparing project level analyses for actions in areas with lands with wilderness
characteristics, that, “Such analysis shall include an alternative that analyzes both mitigation and protection
of any BLM-identified wilderness character that exists within the project area.” 25 For this reason, project
design features in lands with wilderness characteristics in Oregon are proposed under each of the action
alternatives.
Idaho
25
The Vale District is currently preparing a draft RMP Amendment and Draft EIS that will address management of lands
with wilderness characteristics and other settlement agreement issues. Unlike in designated Wilderness or designated
Wilderness Study Areas, through a land use plan amendment or land use plan revision, the BLM has the discretion to
determine how to manage lands found to have wilderness characteristics. This management can range from the protection
of the wilderness characteristics of an area to prioritizing other multiple uses (BLM Manual 6320).

In Idaho, until a land use plan amendment or land use plan revision designates use and/or protection of
these areas, the BLM manages the wilderness resource present in lands with wilderness characteristics like
any other resource under FLPMA. Impacts to lands with wilderness characteristics resulting from an action
are evaluated during NEPA analysis if necessary to make a reasoned choice among alternatives and/or if
the potential for significant impacts to lands with wilderness characteristics exists.
Lands with Wilderness Characteristics Inventory Updates

Oregon
The Vale District Office completed the wilderness characteristics inventory update process for all areas
within the proposed project area in 2012. Final wilderness characteristics determinations are available to
the public on the BLM Vale District website at https://www.blm.gov/programs/planning-and-nepa/plans-in-
development/oregon-washington/vale-wci.
The project area contains portions of 16 wilderness inventory units totaling 378,213 acres in Oregon that
possess wilderness characteristics (Table 3.9-1).
overlapping the analysis area in Oregon.
Name Total Maximum Wilderness Criteria Met
Size (Alt 2) [Y: Yes; N: No]
(acres) Treatment
Acres
(% of Unit) Size Naturalness Solitude Recreation Supplemental
Values
Alcorta Rim 53,602 0 (0) Y Y Y Y N
Big Grassy 45,192 714 (1.6) Y Y Y Y Y
Black Butte 12,048 142 (1.2) Y Y Y Y Y
Cairn C 8,946 265 (3.0) Y Y Y N Y
Cherry Well 8,251 341 (4.1) Y Y Y N Y
Coyote Wells 7,147 220 (3.1) Y Y Y N Y
Dead Horse 63,399 805 (1.3) Y Y Y N Y
Deer Flat 12,266 190 (1.5) Y Y Y N Y
Grassey 12,104 142 (1.2) Y Y Y Y N
Hanson Canyon 16,476 481 (2.9) Y Y Y Y Y
Little Groundhog 5,272 60 (1.1) Y Y Y Y Y
Reservoir
Oregon Butte 32,010 340 (1.1) Y Y Y N Y
Owyhee River 7,718 44 (0.6) Y Y Y Y Y
Cont.
Rattlesnake 66,079 1,089 (1.6) Y Y Y Y Y
Creek
Sacramento Hill 9,568 469 (4.9) Y Y Y N Y
Twin Butte 18,135 361 (2.0) Y Y Y N Y
Idaho
In Idaho, 12 wilderness inventory units that possess wilderness characteristics totaling 251,326 acres fall
within or overlap the proposed project area in the BLM Boise District (Table 3.9-2). All wilderness
inventory units in the Boise District were delineated and inventoried during the mid-1970s to early 1980s.
Unit boundaries were created, similar to Oregon, using roads, rights-of-way, and public ownership
boundaries. Per BLM Manual 6310 (USDI BLM 2012c), the BLM conducted wilderness inventory updates
for the 12 lands with wilderness characteristics units in the project area between 2011 and 2013.

overlapping the analysis area in Idaho.
Name Total Maximum Wilderness Criteria Met
Size (Alt 2) [Y: Yes; N: No]
(acres) Treatment
Acres
(% of Unit) Size Naturalness Solitude Recreation Supplemental
Values
Buncel Basin 15,961 120 (0.8) Y Y Y Y Y
D Bar Basin 29,142 199 (0.7) Y Y Y N Y
Deep Creek – 49,280 286 (0.6) Y Y Y Y Y
Nickel Creek
Horsehead Spring 6,462 0 (0) Y Y Y Y Y
Henry Lake 11,748 178 (1.5) Y Y Y Y Y
Meridian 15,493 295 (1.9) Y Y Y N Y
Middle Fork 17,739 0 (0) Y Y Y Y Y
Owyhee River
Rock Spring 17,759 163 (0.9) Y Y Y N Y
Squaw Creek 21,193 156 (0.7) Y Y Y Y Y
Canyon
West Fork Red 31,732 109 (0.3) Y Y Y Y Y
Canyon
Wildhorse Spring 17,487 371 (2.1) Y Y Y N Y
Yatahoney Creek 17,331 54 (0.8) Y Y Y Y Y

How would implementing and maintaining fuel breaks and mineral material sites impact lands with
wilderness characteristics (size, naturalness, outstanding opportunities for solitude or recreation)?
3.9.2.2 Indicators
• The BLM evaluates potential changes to the wilderness characteristics of lands with wilderness
characteristics as a result of its planned actions using the same indicators described for WSAs:
size, naturalness, and outstanding opportunities for solitude or primitive and unconfined
recreation.
3.9.2.3 Assumptions
• Assumptions are identical to those described for Wilderness Study Areas (section 3.8.2).
3.9.2.4 Alternative 1 – No Action Alternative

The No Action Alternative would result in no fuel breaks being constructed in the project area. There
would be no direct impact to lands with wilderness characteristics. The long-term trend of conversion of
native grasslands to invasive annual grasslands resulting from disturbances such as recurring wildfire
would continue, decreasing the biological naturalness of these lands. Potential direct impacts to lands with
wilderness characteristics due to fire and associated fire suppression include blackened vegetation and soil,
as well as bulldozer lines. The visual impacts of bulldozer lines would be apparent until the regrowth of
vegetation masked the disturbance. With proper post-fire rehabilitation techniques, this could take 5 to 7
years.

In Oregon and Idaho, with or without design features, the action alternatives 1) would result in minor
impacts overall to the naturalness of any inventory unit in the project area found by the BLM to possess
wilderness characteristics, 2) would not diminish the size of any such inventory unit, and 3) would not
cause any such inventory unit to no longer meet the minimum criteria for wilderness characteristics, as
explained further below.
• Size. Inventory unit boundaries are formed by wilderness inventory roads, property lines,
developed rights-of-way, or other substantially noticeable imprints of human activity. No action
proposed in this project would add or alter wilderness inventory roads, property lines,
developed rights-of-way, or wilderness inventory unit boundaries. Without design features, fuel
break creation and maintenance would result in substantially noticeable imprints of human
activity on the perimeter of lands with wilderness characteristics, however the project would not
alter their existing boundaries. 26 Therefore, no action alternative would diminish the size of any
BLM-identified lands with wilderness characteristics in either Oregon or Idaho.
• Naturalness. The area must appear to have been affected primarily by the forces of nature, and any
work of human beings must be substantially unnoticeable to the average visitor. Without design
features, fuel breaks would add an apparent linear feature or imprint of human activity to the
perimeter of each affected unit, however impacts to the naturalness of any affected unit overall
would be minor. Because treatments make up less than five percent of each affected unit’s acreage
and would not reduce the area possessing naturalness below 5,000 acres in any unit, this project
would not cause any BLM-identified lands with wilderness characteristics to no longer meet the
naturalness criterion. Treatments proposed in lands with wilderness characteristics would be
substantially noticeable to the average visitor where edges of a treated area are evident, abrupt, or
strongly defined. Although altered, these areas would remain part of each affected inventory unit
and would not reduce the total acres posessing naturalness in any inventory unit below the
threshold acreage for a unit to possess naturalness (5,000 acres). Therefore, no changes in the
naturalness overall of any unit would result. Although treated areas would fade with time (3-5
years) to become a barely visible linear feature, noticeable effects would recur with each
maintenance treatment for the life of the fuel break network. In Oregon, project design features
would reduce the visible impacts to wilderness characteristics. For example, a “feathered” mowing
technique at the edge of the fuel break and a prohibition on seeding kochia are proposed in Oregon
to avoid a discrete visual linear contrast from treatments along boundary roads (Appendix G).
• Outstanding Opportunities for Solitude or Primitive Unconfined Recreation. The proposed
project would not affect size, configuration, or topographic screening in any lands with wilderness
characteristics. In some areas, vegetative screening (i.e., brush) that is greater than 12 inches in
height would be mown to a height between 6-10 inches, however the amount of brush proposed for
manipulation in the fuel break is negligible when compared to the amount of brush across the
landscape. None of the action alternatives would have an effect on opportunities for solitude or
primitive unconfined recreation.
• No Changes to Eligibility of Affected Lands with Wilderness Characteristics. The criteria
required to maintain an area’s wilderness characteristics are size, naturalness, and outstanding
opportunities for solitude or primitive and unconfined recreation. Because action alternatives would
26
The imprints of human activity in a wilderness inventory unit may change over time. For example, post-fire
rehabilitation treatments may appear unnatural for a few years before blending into the natural landscape. Therefore, in
each successive inventory, the BLM may find some previously unnatural areas appear natural (e.g., due to vegetative
growth), while some previously natural areas appear unnatural (e.g., due to new activity). Because of the fluid nature of
such changes to the landscape, the BLM does not use them to alter or delineate inventory unit boundaries.

not affect the size of any unit in the project area or any unit’s outstanding opportunities for solitude
or primitive unconfined recreation, and would result in minor impacts to the naturalness overall of
affected units, the BLM has determined none of the action alternatives would alter the minimum
wilderness characteristics of any affected unit possessing wilderness characteristics. Therefore, no
action alternative would cause an entire BLM-identified unit to no longer meet the criteria for
wilderness characteristics.
• Wildfire Protection. Implementation of a fuel break network would contribute to the protection of
wilderness characteristics, including naturalness, outstanding opportunities for solitude and
recreation, and supplemental values, from wildfire as described for WSAs in section 3.8.2.
• Ongoing Detectable Effects. Although fuel breaks are expected to result in collectively minor
effects to the overall naturalness of each affected unit possessing wilderness characteristics, some
effects from fuel break maintenance for Alternatives 2, 3, and 4 would be visible for the life of the
project.
Mowing
In lands with wilderness characteristics in Oregon, effects of mowing would be identical to those described
for WSAs in section 3.8.2.
In lands with wilderness characteristics in Idaho, mowing would create a distinct linear contrast between
treated and untreated vegetation on the perimeter of these areas that would be a noticeable imprint of
human activity. The visible linear contrast of a mowing treatment would fade in the short term, but would
recur with subsequent maintenance mowing. Because these effects would be limited to a small footprint on
the outer boundary of these inventory units, the mowing treatment would have minor effects overall to the
naturalness of any affected inventory unit.
Hand Cutting
In Oregon, hand cutting may be used to blend the mowing treatment into the surrounding landscape under
design features to minimize effects to naturalness in treatment areas. In both Oregon and Idaho, hand
cutting may be used where resource concerns or terrain preclude mowing.
In lands with wilderness characteristics in Oregon and Idaho, effects of hand cutting would be identical to
those described for WSAs in section 3.8.2.

In lands with wilderness characteristics in Oregon, effects of seeding and seedbed preparation would be
identical to those described for WSAs in section 3.8.2.
In the short term, visual drill rows would present the highest level of visual contrast of any treatment
associated with the Tri-state Fuel Breaks Project; therefore, design features (Appendix G) would require the
use of broadcast seeding, no-till drills, or modified range drills in lands with wilderness characteristics in
Oregon. Disking and the planting of prostrate kochia would also be prohibited in lands with wilderness
characteristics units in Oregon, because these methods may introduce greater visual contrast between
treated and untreated areas. These design features would reduce the visual impact of fuel break treatments
to further minimize any minor impacts to naturalness associated with action alternatives.
The above design features would not be applied to lands with wilderness characteristics in Idaho. In lands
with wilderness characteristics in Idaho, seeding would create a linear contrast between the treated and
untreated footprint on the perimeter of these areas. The visual impact of drill rows would be noticeable in
the short term and fade with the successful establishment of seeded species. The linear contrast in

vegetation created by seeded fuel breaks would exist for the long term; in addition to the linearity of the
treatment, the texture and color of prostrate kochia, particularly in the fall when the plant turns red, would
highlight the treated area as altered. These effects of a seeded fuel break would be limited to areas on the
outer boundary of inventory units and would remain for as long as the fuel break is maintained. Seeding
and seedbed preparation would have minor effects overall to the naturalness of any affected inventory unit
due to its limited extent; all Idaho lands with wilderness characteristics would maintain the required 5,000
or more acres of naturalness.
Targeted Grazing
Effects to lands with wilderness characteristics from targeted grazing would be identical to those described
for WSAs in section 3.8.2.

Roadbed vegetation removal (including by blading, hand cutting, and herbicide use) may occur on
wilderness inventory roads that act as the boundary of lands with wilderness characteristics. No primitive
routes within lands with wilderness characteristics are proposed for fuel break implementation in any of the
action alternatives, therefore no roadbed vegetation removal would occur within any inventory unit
possessing wilderness characteristics in the project area.

Because no mineral material sites are proposed in lands with wilderness characteristics, no impacts to lands
with wilderness characteristics are anticipated from their development and operations.
As described in section 3.9.2.5, Alternative 2 would not affect the size or outstanding opportunities for
solitude or primitive and unconfined recreation of any affected wilderness characteristic unit. The project
would however result in minor effects to naturalness over the short and long term in affected wilderness
inventory units. These effects would be limited to the perimeter of units, and are discussed in greater detail
below.
Fuel breaks up to 200 feet wide along both sides of 224 miles of boundary roads (generally 15-20 feet
wide 27) totaling 7,595 acres would be implemented and maintained in lands with wilderness characteristics
in Oregon and Idaho (Maps 6-7, Appendix Q). A visual contrast would be created at the interface where
treated vegetation meets untreated vegetation. The primary contrast in these areas would be created by the
200-foot-wide vegetated strips on both sides of the road, which would have a slightly different color and
texture compared to the adjacent area. The contrast would be most visible right after treatment and fade
with time as vegetation regrows. In Idaho, the linear nature of fuel break treatments on the perimeter of
these lands would be apparent to the average visitor, however effects to the naturalness of any affected
inventory unit overall would be minor, because treated acres are a small percentage of each unit and would
not decrease any unit’s total acres possessing naturalness below 5,000. In Oregon, the treatment edge
would be softened by “feathering” the mowing treatment where it meets the untreated vegetation in lands
with wilderness characteristics. Minor effects to naturalness from fuel break maintenance would be visible
for the life of the project. This alternative would have the greatest impact among methods considered,
however it would also provide the most fire protection to lands with wilderness characteristics.
27
Boundary roads of lands with wilderness characteristics are generally 15-20 feet wide, although other roads within the
fuel break network may be up to 30 feet wide.

Impacts to lands with wilderness characteristics that are described in Alternative 2 would apply to 4,346
acres of lands with wilderness characteristics, or 43 percent fewer acres less than Alternative 2. In Idaho,
the linear nature of fuel break treatments on the perimeter of these lands would be apparent to the average
visitor, however effects to the naturalness of any affected inventory unit overall would be minor, because
treated acres are a small percentage of each unit and would not decrease any unit’s total acres possessing
naturalness below 5,000. In Oregon, the treatment edge would be softened by “feathering” the mowing
treatment where it meets the untreated vegetation in lands with wilderness characteristics. Minor effects to
naturalness from fuel break maintenance would be visible for the life of the project.
Impacts to lands with wilderness characteristics that are described in the Alternative 2 would apply to 3,303
acres of lands with wilderness characteristics, or 57 percent fewer acres than Alternative 2. In Idaho, the
linear nature of fuel break treatments on the perimeter of these lands would be apparent to the average
visitor, however effects to the naturalness of any affected inventory unit overall would be minor, because
treated acres are a small percentage of each unit and would not decrease any unit’s total acres possessing
naturalness below 5,000. In Oregon, the treatment edge would be softened by “feathering” the mowing
treatment where it meets the untreated vegetation in lands with wilderness characteristics. Minor effects to
naturalness from fuel break maintenance would be visible for the life of the project.

The cumulative impact analysis area (CIAA) consists of the lands with wilderness characteristics within the
project area to capture all effects to wilderness characteristics of these areas. The timeframe of analysis
would be for the life of the project to capture the potential long-term effects of the project and all of the
reasonably foreseeable future actions within the geographic scope.

Past trends have generally been positive for lands with wilderness characteristics: since the original
wilderness inventory was conducted from 1978 to 1981, lands with wilderness characteristics have
approximately doubled in size, increasing by about 1.2 million acres. This has occurred under basic
stewardship in the absence of special protections. This increase can be attributed to changes in land
management practices over the past several decades and the passage of time. 28 Present and reasonably
foreseeable future actions that have had, are having, and/or are expected to affect lands with wilderness
characteristics within the CIAA are primarily vegetation treatments and fuel break projects.
In Idaho, the Pole Creek and Trout Springs juniper treatments involve juniper cutting and broadcast burns
covering approximately 38,000 acres around Juniper Mountain, Owyhee County. The inventory units
Squaw Creek Canyon, Middle Fork Owyhee River, West Fork Red Canyon, and Horsehead Spring are
28
Through the 1960s, extensive rangeland seedings were commonly planted to improve rangeland health. As the visual
impacts of rangeland drill rows has diminished over time, the affected land often returns to a state of apparent naturalness.
In other cases, roads may have been reclaimed by vegetation and reduced to routes, removing a boundary that may have
previously limited the size of the area to under 5,000 acres. Any substantially noticeable change to the landscape that has
not been maintained over time may fade or disappear, increasing the likelihood of a wilderness characteristics
determination.

being treated under the Pole Creek and Trout Springs juniper treatments. 29 Treatment activities associated
with these projects will create noticeable short-term impacts during treatment and until vegetation
reestablishes. Over the long term, the regrowth of sagebrush communities will return the treated areas to a
state of apparent naturalness.
ESR treatments would generally improve lands with wilderness characteristics within the CIAA over the
long term. Impacts to naturalness from vegetation treatments are greatest immediately after treatment
(short-term). It is unclear whether projects would be implemented concurrently. In the short term,
cumulative impacts could be moderate, depending on the timing of each project’s implementation. In the
long term, cumulative impacts would fade to minor.
Fuel Breaks
In Oregon, no fuel breaks currently exist in lands with wilderness characteristics in the project area. In
Idaho, the Bruneau Fuel Breaks Project overlaps the Wildhorse Spring inventory unit. 30 The Programmatic
EIS (PEIS) For Fuel Breaks in the Great Basin will not directly result in the construction of new fuel
breaks, but its analysis will streamline the NEPA process for future fuel break projects that may overlap
lands with wilderness characteristics in Idaho, Oregon, Nevada, northern California, Utah, and eastern
Washington. The PEIS analyzes construction of fuel breaks within lands with wilderness characteristics
managed to emphasize other multiple uses, but not those managed to maintain or enhance wilderness
characteristics.

Cumulative effects of present and reasonably foreseeable vegetation treatments and fuel breaks would
continue as described above. Post-fire rehabilitation treatments would continue to occur in units affected by
wildfire, and in comparison to action alternatives, the footprint of treatments may be larger, as firefighters
would not have access to pre-established anchor points on the perimeter of units. Suppression activities
may also result in greater impacts to wilderness characteristics compared to action alternatives, as it may
not be feasible to select the least impacting tool during an incident. Four inventory units would undergo
juniper cutting and broadcast burns part of the Trout Springs and Pole Creek juniper treatments: Squaw
Creek Canyon (14,548 acres), Middle Fork Owyhee River (5,773 acres), West Fork Red Canyon (34 acres)
and Horsehead Spring (3,646 acres). The Wildhorse Spring inventory unit would undergo 56 acres of
treatment as part of the Bruneau Fuel Breaks Project. The locations of any future fuel break projects
associated with the Great Basin Fuel Breaks PEIS are unknown, however, where lands with wilderness
characteristics that are managed for protection of those characteristics may be significantly affected,
project-specific impacts to wilderness characteristics would continue to be evaluated through the NEPA
process before a decision is reached.
29
Although within the project area, the Bruneau Owyhee Sage-Grouse Habitat (BOSH) Project will not treat lands with
wilderness characteristics.
30
Outside the CIAA, the Owyhee Desert Sagebrush Focal Area Fuel Breaks and the Owyhee Roads Fuel Break Project
include no treatments on lands with wilderness characteristics. The Soda Fuel Breaks Project includes 12,986 acres of
treatments, of which 541 acres are planned in lands with wilderness characteristics in Oregon. The Soda Fuel Breaks
Project’s design features avoid treatments that would be noticeable to the casual observer in these areas (USDI BLM 2017,
p.30).

3.9.3.4 All Action Alternatives – Cumulative Impacts
Cumulative effects of present and reasonably foreseeable vegetation treatments would continue as
described above. When added to present and reasonably foreseeable actions, the incremenetal impact of
any action alternative would not affect the size or overall eligibility for protection of wilderness
characteristics of any affected inventory unit. Under each action alternative, the Pole Creek and Trout
Springs juniper treatments would remain the only actions affecting wilderness values in the Middle Fork
Owyhee River and Horsehead Spring inventory units. Under each action alternative, treated acres under
Tri-state would add to both the short-term adverse and long-term beneficial effects of existing juniper
treatments to naturalness in the Squaw Creek Canyon and West Fork Red Canyon inventory units.
For all inventory units in which Tri-state fuel breaks would be constructed and maintained, the incremental
impact of any action alternative would provide firefighters strategic, preestablished anchor points on the
perimeter of inventory units, allowing improved protection of wilderness characteristics from wildfire. As a
result of this increased firefighting efficiency, future burn footprints in affected units may be reduced,
resulting in fewer adverse impacts to wilderness characteristics from intense wildfire, and lower post-fire
rehabilitation costs. These benefits would correspond to the treatment acreages in each action alternative,
with the greatest benefit under Alternative 2 and the most reduced benefit under Alternative 4.

In most inventory units in the project area, the Tri-state Fuel Breaks Project would be the only known
action affecting wilderness characteristics (Tables 3.9-1 and 3.9-2). In the Wildhorse Spring unit, treated
acres under Tri-state would absorb all the existing Bruneau fuel breaks.

In most affected inventory units, the Tri-state Fuel Breaks Project would be the only known action affecting
wilderness characteristics (Tables 3.9-1 and 3.9-2). In the Wildhorse Spring inventory unit, treated acres
under Tri-state would absorb most, or about 70 percent, of the existing Bruneau fuel breaks. Five inventory
units that would be affected by Alternative 2 would not be treated under Alternative 3. These include the D
Bar Basin, Meridian, and Rock Spring inventory units in Idaho and the Black Butte and Sacramento Hill
inventory units in Oregon.

In most affected inventory units, the Tri-state Fuel Breaks Project would be the only known action affecting
wilderness characteristics (Tables 3.9-1 and 3.9-2). In the Wildhorse Spring inventory unit, treated acres
under Tri-state would absorb about 20 percent of the existing Bruneau fuel breaks. Seven inventory units
that would be affected by Alternative 2 would not be treated under Alternative 4. These include the D Bar
Basin, Meridian, and Rock Spring inventory units in Idaho and the Cairn “C”, Deer Flat, Sacramento Hill,
and Twin Butte inventory units in Oregon.
3.10 Visual Resource Management

The affected environment for visual resource management is the proposed project area, because project
impacts to visual resources would not extend beyond this boundary (Map 1, Appendix Q). Visual or scenic
values of BLM-administered lands are considered whenever any physical actions are proposed, as directed
by the Owyhee RMP (1999) and the Bruneau MFP (1983), as amended by the Greater Sage-Grouse
Resource Management Plan Amendment for Idaho and Southwestern Montana (2015) and the Idaho
Greater Sage-Grouse Resource Management Plan Amendment (USDI BLM 2019) in Idaho, and by the
Southeastern Oregon RMP (2002), as amended by the Oregon Greater Sage-Grouse Resource Management

Plan Amendments (2015; 2019) in Oregon. This guidance also designated the spatial extent of four Visual
Resource Management (VRM) Classes. BLM Manual H-8410-1 (USDI BLM 1986a) describes Visual
Resource Class objectives as follows:
Class I – The objective of this class is to preserve the existing character of the landscape. This class
provides for natural ecological changes; however, it does not preclude very limited management activity.
The level of change to the characteristic landscape should be very low and must not attract attention. There
are 647,391 acres designated as VRM Class I in the proposed project area.
Class II – The objective of this class is to retain the existing character of the landscape. The level of change
to the characteristic landscape should be low. Management activities may be seen, but should not attract the
attention of the casual observer. Any changes must repeat the basic elements of form, line, color, and
texture found in the predominant natural features of the characteristic landscape. There are 415,920 acres
designated as VRM Class II in the proposed project area.
Class III – The objective of this class is to partially retain the existing character of the landscape. The level
of change to the characteristic landscape should be moderate. Management activities may attract attention,
but should not dominate the view of the casual observer. Changes should repeat the basic elements found in
the predominant natural features of the characteristic landscape. There are 525,366 acres designated as
VRM Class III in the proposed project area.
Class IV – The objective of this class is to provide for management activities which require major
modifications of the existing character of the landscape. The level of change to the characteristic landscape
can be high. These management activities may dominate the view and be the major focus of viewer
attention. However, every attempt should be made to minimize the impact of these activities through
careful location, minimal disturbance, and repeating the basic elements of form, line, color, and texture
found in the predominant natural features of the characteristic landscape. There are 1,593,395 acres
designated as VRM Class IV in the proposed project area.
Most of the proposed fuel break segments would occur in areas classified as VRM Class IV. However,
some portions of segments would occur in areas with more restrictive VRM classifications. Acreage figures
provided above are for public lands administered by the BLM only, as VRM is not classified for military,
State of Idaho, State of Oregon, or private lands. All proposed mineral material sites are also located in
VRM Class IV areas.

• How would implementing and maintaining fuel breaks and mineral material sites affect visual
resources within the project area?
3.10.2.2 Indicators
BLM Manual 8431 (USDI BLM 1986b) defines a contrast rating system to assess the degree to which
management activities affect the visual quality of a landscape. This process evaluates the visual contrast
between the existing landscape and a proposed management action, and aids in identifying measures to
mitigate or minimize impacts, using the following general indicators of contrast:

• Form. Contrast in form results from changes in the shape and mass of landforms or structures.
The degree of change depends on how dissimilar the introduced forms are to those continuing
to exist in the landscape.
• Line. Contrasts in line results from changes in edge types and interruption or introduction of
edges, bands, and silhouette lines. New lines may differ in their subelements (boldness,
complexity, and orientation) from existing lines.
• Color. Changes in value and hue tend to create the greatest contrast. Other factors such as
chroma, reflectivity, color temperature, also increase the contrast.
• Texture. Noticeable contrast in texture usually stems from differences in the grain, density,
and internal contrast. Other factors such as irregularity and directional patterns of texture may
affect the rating.
3.10.2.3 Assumptions
• Linear vegetation treatments have the potential to create a visual contrast line with adjacent stands
of untreated native vegetation to some degree. All impacts from fuels treatments would be
minimized through the use of project design features (Appendix G).

Under the No Action Alternative, no short- or long-term impacts to visual resources would occur due to
project implementation. However, not implementing the proposed project may increase other short- and
long-term impacts associated with wildfire and fire suppression. Such potential impacts to visual resources
would include bulldozer lines, construction of safety zones, and red coloration from retardant drops.

Targeted Grazing
A slight but visible linear feature would be created where livestock graze up to the temporary fence line.
The contrast would be created by the differing height of the grazed vegetation in the treatment footprint and
the un-grazed vegetation outside the treatment footprint. This contrast would be detectable right after
livestock are removed, and fade with vegetation regrowth. Design features for WSAs (Appendix G)
prohibit cross-country travel when implementing targeted grazing to meet VRM Class I visual objectives.
In the short and long term, visual impacts of targeted grazing would be minor.
Mowing
Mowing would cut shrub branches and foliage to a height of 6-10 inches within the treatment footprint.
Herbicides could be used before or after mowing to inhibit the germination of invasive weeds and grasses.
A linear feature would be created at the interface where mown vegetation meets unmown vegetation. The
contrast would be most noticeable right after treatment and fade with time as vegetation regrows. There
would be a slight difference in color between the treatment footprint and the untreated landscape. The new
growth of the mown sagebrush would be a slightly different color from the older sagebrush outside the
treatment footprint. In WSAs and lands with wilderness characteristics in Oregon, this linear contrast
would be softened by “feathering” the treatment where it meets the unmown shrubs (Appendix G). In these
areas, feathered mowing would create a more apparently natural gradient between the mowed area and the
adjacent landscape. In the short term, impacts to visual resources from mowing would be minor but easily
detectable directly after initial treatment and subsequent maintenance. Over the long term, impacts to
naturalness would become only slightly detectable as the fuel break treatment fades and the mowed fuel
break appears increasingly integrated with its surrounding landscape as a result. The cyclic nature of

mowing’s visual impacts changing between maintenance intervals from easily detectable to slightly
detectable would go on for the life of the project.
Hand Cutting
Hand cutting of vegetation would be used when rugged and/or steep terrain or resource concerns restrict the
use of mechanized equipment. Herbicides could be used before or after cutting to inhibit the germination of
invasive weeds and grasses. The visual contrast at the treatment interface would be less noticeable than
mowing, as hand crews could more easily blend the line than could be done mechanically. In the short and
long term, visual impacts would be minor.

Similar to all other methods discussed above, seeding would create a visual contrast line at the interface
between the seeded and non-seeded landscape. This visual contrast would be most noticeable at the time of
seeding and fade over time as seeded vegetation starts to blend at the contrast line with untreated
vegetation. This fading would occur where seeding and mowing are recommended together, or in the
majority of areas recommended for seeding, as the vegetation in the fuel treatment zone would maintain
some of its existing vegetation. In the up to two percent of the treatment area selected for seeding only, the
visual contrast line associated with seeding would not fade, as vegetation within and outside the fuel break
would remain distinct for the life of the fuel break network. Visual drill rows would be an unacceptable
visual impact in lands managed to VRM Class I objectives (i.e., WSAs). Design features (Appendix G)
such as broadcast seeding, no-till drills, or modified range drills would therefore be used in WSAs,
reducing visual impacts in lands managed to VRM Class I objectives. Design features for lands with
wilderness characteristics in Oregon similarly reduce the potential for visual contrast associated with
seeding treatments; as a result, visual impacts would be minimized in those VRM Class II, III, and IV areas
that are within wilderness inventory units in Oregon.
A visual contrast could also develop seasonally as differing grasses cure at different rates. Annual grasses
tend to cure earlier in the season than the perennial grasses that would be planted in the treatment footprint.
All grasses inside and outside the treatment footprint would be green in the spring, but as grasses cured at
differing rates throughout the spring and into the summer, the visual contrast would increase. In the fall,
grasses inside and outside the treatment footprint would be cured and again appear similar in color. In fuel
breaks seeded with prostrate kochia, a slight color contrast would be apparent in the late summer and fall
when the kochia develops a red tint while surrounding vegetation is tan or gold. Because of these
considerations, design features (Appendix G) prohibit the planting of prostrate kochia along roads within
WSAs and lands with wilderness characteristics in Oregon to avoid the seasonal color contrast the plant
species would create between treated fuel breaks and the adjacent landscape. In the short and long term,
visual impacts of seeding and seedbed preparation would be minor for all VRM Classes. However, effects
from fuel break maintenance for all seedbed preparation and maintenance treatments (i.e., herbicide,
disking, prescribed fire, targeted grazing) would be visible for the life of the project, although they would
not attract the attention of the casual observer.

Removal of vegetation within the roadbed would replace scattered or centerline vegetation in the roadbed
with a strip of bare soil. As a result, visual contrasts (linear, color, and texture) between the road and the
surrounding area would increase. These contrasts would be most apparent in areas bladed free of
vegetation, where a berm of removed vegetation and topsoil would remain along the side of the road. In
areas where hand tools and/or herbicide are used to clear vegetation in the roadbed, cut vegetation would be
deposited along the side of the road. The visual contrast created by vegetation removal would be minimized
in these areas due to the absence of ground disturbance from blading equipment and associated berms.

The four proposed Oregon mineral material sites are all located in areas managed to VRM Class
IV. Although major impacts to visual resources are allowed within these areas, the proposed mineral
material sites as described in section 2.1 Features Common to All Action Alternatives would not impact
visual resources to the maximum extent allowed in VRM Class IV, as they would not dominate the
landscape. They would however result in minor impacts to visual resources within the twenty acre footprint
of surface disturbance within each site (Map 4, Appendix Q). Within this footprint, the visual disturbance
of each rock pit would be apparent due to the presence of the pit and stock piled aggregate. Associated
mechanized equipment (i.e., drill rig, crushing unit, and excavator) would also be visible on each site for
approximately two to three months at a time intermittently for the 20- to 30-year useful life of each site.
Minor impacts to visual resources are expected within approximately a quarter mile perimeter of each site,
within which the surface disturbance of the rock pits may be noticeable to the casual observer, but would
not dominate the view or be a major focus of viewer attention.
Implementation of the Proposed Action would result in short-term and long-term impacts to visual
resources (Table 3.10-1). Across the fuel break network, short-term impacts would consist of linear areas of
visual contrast adjacent to roads resulting from vegetation removal, mechanical treatments, seeding, and
targeted grazing. The visual contrast resulting from this disturbance would be greatest after initial treatment
and subsequent maintenance. Visible drill rows may attract the attention of the casual observer to seeded
treatment areas; therefore, in the short term, fuel breaks may not meet the VRM objectives of Class II
treatment areas (7 percent of proposed treatment acres). After establishment of seeded species, these areas
would present a lower level of linear contrast that, though visible, would not draw attention from the
natural elements of the landscape. Design features for WSAs (VRM Class I) would minimize the short-
term visual contrast associated with seeding by requiring use of minimum or no-till drills or techniques to
obscure drill rows (e.g., tire dragging); however treatments, including maintenance treatments, may not
meet VRM Class I objectives initially. The primary contrast in seeded treatment areas would be created by
the 200-foot-wide vegetated strips on one or both sides of the existing road (10-30 feet wide), which would
have a slightly different color and texture compared to the adjacent area. In fuel breaks seeded with
prostrate kochia, this contrast would be most obvious in late summer and fall, when the kochia turns red
and the surrounding vegetation is tan or gold in color. Design features for WSAs (VRM Class I) and lands
with wilderness characteristics in Oregon (Appendix G) would avoid planting of prostrate kochia and other
treatments with the potential to create high visual contrast (e.g., disking) in these areas. As lands with
wilderness characteristics in Oregon occur across VRM Classes II, III, and IV, these areas of reduced visual
contrast would be dispersed across VRM Classes I through IV.
In areas managed to VRM Class I, II, III, and IV objectives, mowed areas would result in minor short-term
impacts to visual resources that would be easily detectable directly after initial treatment and subsequent
maintenance. In areas managed to VRM I (i.e., WSAs), newly mowed fuel breaks would be visible to the
casual observer, however their visual impact would be minimized due to a feathering design feature that
would create a more apparently natural gradient between the mowed area and the adjacent landscape. Over
the long term, impacts to naturalness would become only slightly detectable as the fuel break treatment
fades and the mowed fuel break appears increasingly integrated with its surrounding landscape as a result.
The cyclic nature of mowing’s visual impacts changing between maintenance intervals from easily
detectable to slightly detectable would go on for the life of the project. Most, or 84%, of the proposed fuel
breaks would occur in areas managed to VRM Class III and IV; therefore visual impacts would be greatest
to those classes in which management actions may attract attention or dominate the view.

Implementation of the Proposed Action would be consistent with objectives for VRM Classes II, III and
IV. The level of visual contrast may not be consistent with VRM Class I objectives. Therefore, in areas
where the project crosses lands managed for VRM Class I objectives, on a site-specific and method-
specific basis, the visual resource contrast rating process outlined in BLM Manual 8431 (USDI BLM
1986b) would be used as a project assessment tool and visual design tool to ensure the project meets VRM
Class I objectives within 3 to 5 years of initial treatment.
Table 3.10-1. VRM Class crossed by Proposed Action.

VRM Class Acres Crossed by Proposed Action
Class I 5,762
Class II 4,922
Class III 20,109
Class IV 35,974
Under Alternative 3, short- and long-term visual impacts from the fuel breaks would be identical to those
described for the Proposed Action, however, the geographic extent of visual resource impacts would be
reduced compared to the Proposed Action due to treating 19,059 fewer acres across all VRM classes. Most,
or 86%, of the proposed fuel breaks would occur in areas managed to VRM Class III and IV; therefore
visual impacts would be greatest to those classes in which management actions may attract attention or
dominate the view.
Table 3.10-2. VRM Class crossed by Alternative 3.

VRM Class Acres Crossed by Alternative 3
Class I 2,524
Class II 4,178
Class III 16,117
Class IV 24,889
Under Alternative 4, short- and long-term visual impacts from the fuel breaks would be identical to those
described for the Proposed Action, however, the geographic extent of visual resource impacts would be
reduced compared to the Proposed Action due to treating 26,550 fewer acres across all VRM classes. Most,
or 85%, of the proposed fuel breaks would occur in areas managed to VRM Class III and IV; therefore
visual impacts would be greatest to those classes in which management actions may attract attention or
dominate the view.
Table 3.10-3. VRM Class crossed by Alternative 4.

VRM Class Acres Crossed by Alternative 4
Class I 2,883
Class II 2,994
Class III 15,398
Class IV 18,962

The cumulative impact analysis area (CIAA) consists of the proposed project area. The timeframe of
analysis would be for the life of the project.

affect visual resource management within the CIAA include fuel breaks, road maintenance, and vegetation
treatments.
Fuel Breaks
In addition to the Bruneau Fuel Breaks Project currently being implemented in the CIAA, the
Programmatic EIS (PEIS) for Fuel Breaks in the Great Basin will streamline the NEPA process for future
fuel break projects in Idaho, Oregon, Nevada, northern California, Utah, and eastern Washington, as
described in Appendix N. The Bruneau Fuel Breaks Project would contribute visual impacts across the
2,836 acres of treatment, with no treatments occurring in WSAs (i.e., VRM Class I). Only 8 percent of
Bruneau fuel breaks would occur in VRM Class II. Because 92 percent of Bruneau fuel breaks would occur
in VRM Classes III and IV, cumulative effects to visual resources in the CIAA managed to VRM Class I or
II objectives from the Bruneau fuel breaks are expected to be minor. Action alternatives would overlap the
Bruneau treatments significantly to reduce their cumulative impact to VRM to negligible if Alternative 2 or
Alternative 3 is approved. Cumulative effects to visual resources managed to VRM Classes III and IV
would be moderate in the short and long term.
Road Maintenance
Where new material is applied on roads, a visual contrast could be created that could have a temporary
minor effect. However, this visual effect would diminish within one to two seasons of use as newly
maintained surfaces weather and become less visually apparent.
The vegetation treatments described in Appendix N would need to meet the objectives of the VRM class in
which they are implemented. Juniper treatments associated with the BOSH Project, Trout Springs, and Pole
Creek may occur across 139,296 acres within the project area. Within the project area, none of these
treatments are planned in VRM Class I, 28% are planned in VRM Class II, and the remaining 72% are
planned in VRM Classes III and IV. These treatments comprise a small percentage of the overall size of the
project area. Impacts from vegetation treatments are greatest immediately after treatment (short-term). It is
unclear whether these projects would be implemented concurrently. Depending on the timing of each
project’s implementation, cumulative impacts would be moderate in the short and long term.

Without a strategic network of fuel breaks to facilitate improved suppression, visual impacts of fire events
and suppression activities would likely occur over larger areas compared to action alternatives. Cumulative
impacts to visual resources would otherwise continue current trends as described above. Within the CIAA,
a combined total of 142,132 acres would be affected by the Bruneau Fuel Breaks Project (2,836 acres) and
juniper treatments associated with the Trout Springs and Pole Creek allotments, as well as the BOSH
Project (139,296 acres). The Bruneau fuel breaks would extend traces of human activity from roadways to
treated acres for the life of the fuel breaks by creating a linear feature between treated and untreated
vegetation. Juniper treatments (i.e., cutting and prescribed fire) could result in moderate short-term adverse
impacts to VRM, but could enhance VRM over the long term as areas become apparently natural
sagebrush-steppe habitat.

Within the CIAA, cumulative impacts to visual resources from vegetation treatments and road maintenance
would continue current trends as described above. Under Alternative 2, a combined total of 67,577 acres of

fuel break treatments (i.e., Bruneau and Tri-state fuel breaks) would occur along existing roads in Idaho
and Oregon in the CIAA. The incremental impact of an additional 67,559 acres of fuel break treatments
associated with the Tri-state Fuel Breaks Project to visual resources would generally extend traces of
human activity from roadways to treated acres for the life of the fuel breaks by creating a linear feature
between treated and untreated vegetation.
Cumulative impacts of 80 acres of mineral material sites to visual resources are additive to the visual
impacts of actions discussed above. Although a nearby wagon road is visible from three sites, these areas
do not currently attract visitors interested in viewing the road, so cumulative impacts to visual resources
associated with the wagon road would be negligible. Because the four sites would not impact the setting of
any viewsheds managed to VRM Class I, II, or III objectives, they would not result in any cumulative
impacts to these VRM classes. They would result in minor cumulative impacts to the affected viewsheds
managed to VRM Class IV.

and Oregon in the CIAA. This would reduce the combined total of treated acres by 24% compared to
Alternative 2. The incremental impact of an additional 45,872 acres of fuel break treatments associated
with the Tri-state Fuel Breaks Project would generally extend traces of human activity from roadways to
treated areas for the life of the fuel breaks by creating a linear feature between treated and untreated
vegetation. Cumulative impacts of development of mineral material sites would be identical to those
described for Alternative 2.

and Oregon in the CIAA. This would reduce the combined total of treated acres by 34% compared to
Alternative 2. The incremental impact of an additional 38,044 acres of fuel break treatments associated
with the Tri-state Fuel Breaks Project would generally extend traces of human activity from roadways to
treated acres for the life of the fuel breaks by creating a linear feature between treated and untreated
vegetation. Cumulative impacts of development of mineral material sites would be identical to those
described for Alternative 2.
3.11 Irreversible and Irretrievable Commitments of Resources

Some commitments of resources associated with implementation and maintenance of the proposed fuel
break network would be irreversible (i.e., permanent) or irretrievable (i.e., precluding other potential uses
of the land). 31 Irreversible impacts would include the potential loss of or damage to paleontological or
cultural resources during fuel break construction or maintenance. The alteration of vegetation and soil
disturbance along roadsides where fuel breaks are constructed and maintained as well as the loss or
31
Irreversible commitments apply primarily to nonrenewable resources, such as cultural resources, and to resources that are
renewable only over long periods of time, such as soil productivity. A resource commitment is considered irretrievable
when the use or consumption of the resource is neither renewable nor recoverable for future use. Irretrievable commitment
applies to the loss of production, harvest, or natural resources.

alteration of wildlife habitat and travel/migration patterns related to the construction and maintenance of
fuel breaks would be irretrievable for the life of the fuel break network.
4.0 Consultation and Coordination

4.1 Tribal Consultation
The BLM is required to consult with Native American tribes to “help assure (1) that federally recognized
tribal governments and Native American individuals, whose traditional uses of public land might be
affected by a Proposed Action, will have sufficient opportunity to contribute to the decision, and (2) that
the decision maker will give tribal concerns proper consideration” (USDI BLM 2016c). Tribal coordination
and consultation responsibilities are implemented under laws and executive orders that are specific to
cultural resources, which are referred to as “cultural resource authorities,” and under regulations that are
not specific, which are termed “general authorities.” Cultural resource authorities include: the National
Historic Preservation Act of 1966, as amended (NHPA); the Archaeological Resources Protection Act of
1979 (ARPA); and the Native American Graves Protection and Repatriation Act of 1990, as amended
(NAGPRA). General authorities include: the American Indian Religious Freedom Act of 1979 (AIRFA);
the National Environmental Policy Act of 1969 (NEPA); the Federal Land Policy and Management Act of
1976 (FLPMA); Executive Order 13007-Indian Sacred Sites; and Secretarial Order 3317-DOI Policy on
Consultation with Indian Tribes. The Proposed Action is in compliance with the aforementioned
authorities.
Southwest Idaho and southeast Oregon is the homeland of the Northern Shoshone and the Northern Paiute,
two culturally and linguistically related tribes. Three federally-recognized Northern Paiute and Shoshone
Tribes – the Shoshone-Paiute Tribes of the Duck Valley Indian Reservation, the Fort McDermitt Paiute and
Shoshone Tribes of the Fort McDermitt Indian Reservation, and the Burns Paiute Tribe – have ties to the
project area.
In the latter half of the 19th century, a reservation was established at Duck Valley on the Nevada/Idaho
border west of the Bruneau River. The Shoshone-Paiute Tribes residing on the Duck Valley Reservation
today actively practice their culture and retain aboriginal rights and/or interests in this area. The Shoshone-
Paiute Tribes assert aboriginal rights to their traditional homelands as their treaties with the United States,
the Boise Valley Treaty of 1864 and the Bruneau Valley Treaty of 1866, which would have extinguished
aboriginal title to the lands now federally administered, were never ratified.
A second reservation was established on the Nevada/Oregon border at Fort McDermitt in the late 19th and
early 20th century for the Paiute and Shoshone Tribes who had settled near the fort. The Fort McDermitt
Reservation directly borders the project area.
An executive order on September 12, 1872, established the 1.8 million acre Malheur Reservation north and
east of Burns, Oregon, opening the remainder of the southeastern Oregon to non-Indian settlement. The
Malheur Reservation went through numerous geographic changes and the Northern Paiute largely left the
area during the Bannock War in 1878. The reservation was terminated by executive orders in 1882-1883
and opened to settlement. The Burns Paiute have a reservation near Burns, Oregon and received federal
recognition in 1972.
The Bannock Tribe also has ties to southwest Idaho. In 1867 a reservation was established at Fort Hall in
southeastern Idaho for the Northern Shoshone Tribe and the Bannock Tribe. The Fort Bridger Treaty of
1868 applies to the BLM’s relationship with the Shoshone-Bannock Tribes.

Consultation and coordination with the Shoshone-Paiute Tribes occurred on the following dates at the
Boise District BLM Wings and Roots Native American Campfire Meetings during scoping and preparation
of the DEIS:
• June 19, 2014

• May 21, 2015
• March 17, 2016
• November 17, 2016
• February 16, 2017
• March 15, 2018
• June 21, 2018
The Boise District BLM met with the Shoshone-Bannock Tribes of the Fort Hall Indian Reservation on
May 17, 2017, December 7, 2017 and June 14, 2018.
The Vale District BLM sent letters to the Fort McDermitt Paiute and Shoshone Tribes and the Burns Paiute
Tribe on March 27, 2018 and then followed up with phone calls on July 12, 2018.
All of the Tribes were also invited to participate in developing a Programmatic Agreement to govern how
the BLM will meet its National Historic Preservation Act (NHPA) Section 106 compliance responsibilities
associated with the action alternatives presented in this DEIS.
4.2 List of Agencies, Organizations and Individuals Consulted
State and Federal Agency Stakeholders Non-Agency Stakeholders

• Idaho Governor’s Office of Species • Affected land owners and permittees
Conservation • Boise District Resource Advisory Council
• Idaho Department of Lands • Southeast Oregon Resource Advisory
• Idaho Department of Fish and Game Council
• Idaho State Historic Preservation Office • The Nature Conservancy
• Oregon Department of State Lands • Idaho Cattle Association
• Oregon Department of Fish and Wildlife • Owyhee Cattlemen’s Association
• Oregon State Historic Preservation Office
• Advisory Council on Historic
Preservation
• U.S. Fish and Wildlife Service
• U.S. Department of Agriculture Natural
Resource Conservation Service

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Department of the Interior

Tri-state Fuel Breaks Project

Boise District Office

Vale District Office

Estimated Lead Agency Total Costs

Purpose and Need

Public Involvement and Issues

Alternative 1 (No Action)

Alternative 2 (Proposed Action)

Tri-state Fuel Breaks Project Draft EIS

Alternative 3 (Social/Cultural Emphasis)

Alternative 4 (Wildlife Habitat Emphasis)

Tri-state Fuel Breaks Project Draft EIS

Executive Summary .........................................................................................................................ES-1

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS

1.1 Need for and Purpose of Action

Tri-state Fuel Breaks Project Draft EIS

1.2 Fire Behavior and Fuel Breaks

1) A non-vegetated roadbed. In the event of an approaching wildfire, a vegetated roadbed

Tri-state Fuel Breaks Project Draft EIS

Figure 1-2. A fuel break.

Tri-state Fuel Breaks Project Draft EIS

1.4 Scoping and Development of Issues

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS

2.0 Description of the Alternatives

2.1 Features Common to All Action Alternatives

Project implementation would occur as expeditiously as possible; depending on funding availability,

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS

2.1.1 Fuel Break Treatments

2.1.1.1 Modeling Existing Vegetation In Proposed Fuel Breaks

Tri-state Fuel Breaks Project Draft EIS

High 17,443 24%

2.1.2.1 Primary Methods

Tri-state Fuel Breaks Project Draft EIS

Roadbed Vegetation Removal

Tri-state Fuel Breaks Project Draft EIS

Seeded Fuel Break Seeding Techniques

2.1.2.2 Supplemental Methods

Tri-state Fuel Breaks Project Draft EIS

Table 2-2. Herbicides proposed for use.

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS

2.2 Alternative 1 – No Action Alternative

2.3 Alternative 2 – Maximum Fire Suppression Emphasis (Proposed Action)

Tri-state Fuel Breaks Project Draft EIS

Table 2-3. Alternative 2 recommended primary vegetation treatments.

Tri-state Fuel Breaks Project Draft EIS

2.4 Alternative 3 – Social/Cultural Emphasis

• Tribal concerns and areas of cultural significance.

Tri-state Fuel Breaks Project Draft EIS

2.5 Alternative 4 – Wildlife Habitat Emphasis

Tri-state Fuel Breaks Project Draft EIS

Table 2-5. Alternative 4 recommended primary vegetation treatments.

2.6 Comparison of Action Alternatives

Tri-state Fuel Breaks Project Draft EIS

Tri-state Fuel Breaks Project Draft EIS