Cat Pasture Corral Line Shack

United States Department of the Interior Bureau of Land Management

Environmental Assessment DOI-BLM-UT-0300-2017-0068 June 2018

Location: Salt Lake Meridian, Kane County, Utah Township 38 South, Range 6 East, Section 28, NE 1/4

Applicant/Address: Marty Gleave &Robby Gleave Lower Cattle Grazing Allotment # 06017 Permittees

Grand Staircase-Escalante National Monument 669 South Highway 89A Kanab, UT 84741 Phone: (435) 644-1200 Fax: (435) 644-1250

Cat Pasture Corral Line Shack DOI-BLM-UT-0300-2017-0068

CHAPTER 1 INTRODUCTION AND NEED FOR THE PROPOSED ACTION

INTRODUCTION AND BACKGROUND The Bureau of Land Management (BLM), Grand Staircase-Escalante National Monument (GSENM) is considering a request from the Lower Cattle Grazing Allotment Permittees to construct a new line shack, a term for a cabin used by cowboys when they are working cattle on the rangeland. The location of the proposed project is approximately 25 miles southeast of Escalante, Utah in Kane County on the south side of the Hole-In-The- Rock Road next to the Cat Pasture Corral (See Appendix B—Project Area Map). If approved, construction of the line shack would start after the completion of the Environmental Assessment (EA).

Under a livestock grazing permit, a Permittee is allowed to maintain temporary quarters on the allotment to facilitate livestock management; this is a permissible and common practice in the Monument. The Permittees currently pull decrepit trailers to the site and leave them for a grazing season or more. Construction of a line shack, to be used by allotment Permittees, would provide shelter during inclement weather when they are working their livestock. A line shack is more closely aligned with the cultural values and traditional uses on the area. A line shack could facilitate improved livestock management by allowing the Permittee to respond quicker to trespass cattle and to spend more time working their livestock. Line shacks are considered one type of range improvements that have been used by Permittees on the Monument. Range improvements, as defined by the BLM Grazing Manual H-4120-1 (pg. 6), are “structures, developments, and treatments [used] in concert with grazing management to rehabilitate, protect, and improve the public land.”

PURPOSE AND NEED FOR THE PROPOSED ACTION The purpose and need for the BLM action is to respond to a request from Marty and Robby Gleave (Lower Cattle Allotment Permittees) to construct a line shack on public lands managed by Bureau of Land Management. The line shack would provide temporary quarters for the permittees, while they are working their cattle, who live over two hours away from the allotment. Decision to be Made Following the analysis in this EA the BLM GSENM Manager will decide whether or not to allow construction of the Cat Pasture Corral Line Shack.

CONFORMANCE WITH BLM LAND USE PLAN(S) The proposed action is in conformance with the Grand Staircase-Escalante National Monument Plan (MMP), effective February 2000. In the MMP under the purpose and need for action section it says that “The Monument was created to protect a spectacular array of historic, biological, geological, paleontological, and archaeological objects”. In the History section of the MMP it says “Early Mormon pioneers left many historic objects. These include trails, inscriptions, remnants of old towns (such as the Old Pahreah town site), cabins, and cowboy line camps”. Line shacks are in alignment with objects that were historically used within the Monument and help tell a story about the life of the early ranchers in this arid remote area.

GSENM Proclamation, September 18, 1996 VER-8 “The Proclamation states that “grazing shall continue to be governed by applicable laws and regulations other than this proclamation,” and says that the Proclamation is not to affect existing permits for, or levels of, livestock grazing within the Monument. Other applicable laws and regulations govern changes to existing grazing permits and levels of livestock grazing in the Monument, just as in other BLM livestock grazing administration programs.”

FAC-6 All facilities and parking areas will be designed to be unobtrusive and to meet the visual resource objectives (see the Visual Resource Management section for related decisions).

RELATIONSHIPS TO STATUTES, REGULATIONS AND OTHER PLANS The proposed action complies with federal environmental laws and regulations, Executive Orders, and Department of Interior, BLM, and GSENM policies and is consistent with state laws and local and county ordinances and plans, including the following:

Omnibus Public Land Management Act of 2009 The Omnibus Public Land Management Act (OPLMA) established the National Landscape Conservation System (NLCS) in order to conserve, protect, and restore nationally significant landscapes that have outstanding cultural, ecological, and scientific values for the benefit of current and future generations. The Act goes on to require that NLCS units, of which GSENM is one, be managed in a manner that protects the values for which the components of the system were designated. The NLCS includes National Monuments, Wilderness Study Areas, and Wild and Scenic Rivers. This project conforms to the OPLMA.

Federal Lands Policy and Management Act of 1976 The Federal Land Policy and Management Act (FLPMA) (43 U/S.C. 1701-1712) directs the development of land use plans for BLM lands. Once land use plans are developed, any approved project must be provided in the land use plan or be consistent with the terms, conditions, and decisions in the approved land use plan. As noted above, this project conforms to the land use plan.

National Historic Preservation Act of 1966 The National Preservation Act requires federal agencies to take into account the effect of any undertaking on historic resources and to provide the Advisory Council on Historic Preservation a reasonable opportunity to comment on the undertaking. Federal agencies must determine whether the undertaking is a type of activity that could affect historic properties. Historic properties are ones that are included on the National Register of Historic Places or that meet the criteria for inclusion on the National Register. If the agency determines that it has no undertaking, or that its undertaking is a type of activity that has no potential to affect historic properties, the agency has no further Section 106 obligations.

Taylor Grazing Act of 1934 The Taylor Grazing Act of 1934(43 USC 315) intended to “stop injury to the public grazing lands by preventing overgrazing and soil deterioration; to provide for the orderly use, improvement, and development; to stabilize the livestock industry dependent upon the public range. The proposal will provide for orderly use of public grazing lands.

BLM Manual 6220 – National Monuments, National Conservation Areas, and Similar Designations (2012)

(I)(2) Livestock Grazing

Grazing management practices will be implemented in a manner that protects Monument and National Conservation Area objects and values unless otherwise provided for in law. Kane County Resource Management Plan (2014) “Kane County supports efficient and responsible full development within the Escalante Region Multiple Use/Multiple Functions Grazing Zone of all permitted, existing and future grazing resources, and other uses compatible with grazing activities.” (page 5)

43 Code of Federal Regulations The proposed action is in conformance with the following regulations contained in 43 Code of Federal Regulations (CFR) pertaining to range improvements on public lands.

CFR 43§4120.3-1 Conditions for range improvements. (a) Range Improvements shall be installed, used, maintained, and/or modified on the public lands or removed from these lands, in a manner consistent with multiple- use management. (e) A range improvement permit or cooperative range improvement agreement does not convey to the permittee or cooperative range improvement agreement does not convey to the permittee or cooperator any right, title, or interest in any lands or resources held by the United States. (f) Proposed range improvement projects shall be reviewed in accordance with the requirements of the National Environmental Policy Act of 1969 (42 U.S.C. 4371et seq.). The decision document following the environmental analysis shall be considered the proposed decision under subpart 4160 of this part.

CFR 43§4120.3-2 Cooperative range improvements agreements

(a) The Bureau of Land Management may enter into a cooperative range improvement agreement with a person, organization, or other government entity for the installation, use maintenance, and/or modification of permanent range improvements or range developments to achieve management or resource condition objectives. The cooperative range improvement agreement shall specify how cost or labor, or both, shall be divided between the United States and cooperators(s).

CHAPTER 2

DESCRIPTION OF ALTERNATIVES

INTRODUCTION This Environmental Assessment (EA) reviews a No Action Alternative and the Proposed Action. The No Action Alternative provides a baseline for comparison of the impacts of the Proposed Action.

PROPOSED ACTION The proposed action is to construct a 20’ by 24’ (approximately 480 square feet) line shack on the south side of the Cat Pasture Corral (See Appendix B-Project Area Map). The line shack will be approximately five feet to the south of the corral. The proposed line shack construction (see Appendix C – Site Design) would include the following:  4 – 8’ tall walls (2 walls measuring 16’ in length running approximately east and west, 2 walls measuring 24’ in length running approximately north and south). A storage room will be built on the east side approximately 4’ by 12’ in size.  Gabled roof covered in metal or shingles.  Three windows (one on the east wall and two on the west wall).  Two doors (one on the west wall for the entrance to the line shack and one on the north wall near the rear to access the storage area).  Covered porch with four post.  A set of wood stairs to go into the line shack (one to two steps in total).  Exterior of the line shack would be covered in wood slats stained dark gray or brown.  Interior would be sheeted with 7/16” OSB.  A wood stove would be installed with a chimney. All materials used to construct the line shack would be of colors that blend with the natural landscape and are non-reflective. No light or bright colored materials would be used. Some ground leveling work would be done using a skid loader or a backhoe. Leveling work would not exceed 12” in depth. Post holes would be approximately 3-4’ deep. The foundation would be built on the post to raise the cabin off the ground. If concrete is used to hold post in ground it will be poured in the hole up to the level of the ground. The Allotment Permittees would provide labor, equipment and material for the construction as well as perform all future maintenance at the Permittees expense. GSENM Resources

Division staff would provide some labor during the construction. If the proposed action were approved, construction would occur in April or May 2018 or shortly after and is expected to take three weeks to complete depending on the weather. Maintenance will be done by permittees as needed to maintain the appearance of a functional well-kept facility. Trash and waste will be hauled out upon leaving the premises. The buildup of equipment or materials (debris, trash, etc.) will not be tolerated. A porta toilet will be brought in to deal with human waste during extended use of the line shack. When permittees leave the line shack the porta toilet will be taken and human waste will be disposed of properly. If permittees do not bring a porta toilet than all human waste will need to be bagged, hauled off and disposed of properly. If needed, signage would be used to inform and educate the public to help reduce vandalism.

NO ACTION Under the no action alternative, the BLM would not approve construction of the line shack as proposed. The Permittees would make other arrangements for overnight accommodations or continue to use old trailers which could be left in place.

CHAPTER 3 AFFECTED ENVIRONMENT

INTRODUCTION The interdisciplinary team considered and analyzed the affected environment as documented in the Interdisciplinary Team Checklist (see Appendix A). The checklist indicates which resources of concern are either not present in the project area or would not be impacted to a degree that requires detailed analysis. Resources that could be impacted to level requiring further analysis are described in Chapter 3 and impacts on these resources are analyzed in Chapter 4. The proposed line shack site is located on the south side of the Hole-In-The-Rock Road (#200) next to the Cat Pasture Corral approximately 25 miles southeast of Escalante, Utah in Kane County. The site borders the Lower Cattle and Black Ridge allotments. The straight cliffs of the Fifty Mile Mountain can be seen to the east. The Escalante River is approximately 15 miles to the west. When this EA was initiated the line shack was within the GSENM. However, during the development of this document, Proclamation 9682, which was issued on December 8, 2017, changed the boundaries and size of the GSENM. Based on the revised boundaries, the line shack location falls outside the GSENM. The location of the proposed line shack still remains on federal land which is now administered by the Kanab Field Office. General Setting A brief environmental setting description of the proposed site is as follows:  Physiographic Province: Colorado Plateau  Elevation: 4800 to 4900 feet above sea level  Geology: Middle and Upper Jurassic Carmel formation  Ecological Site: Semi-desert shallow loam  Hydrology: Located in the Escalante Watershed. The Dry Fork drainage is typically intermittent and flows into the Escalante River, which then empties into Lake Powell and the Colorado River system.  Soil Type: Fine sandy loam  Landform: Structural Benches  Typical Uses: Livestock grazing, hunting, and recreation  Management Zone: Passage Zone  Special Recreation Management Area: Escalante Canyons  Wilderness Study Areas: Scorpion WSA to the east and the Fifty Mile Mountain WSA to the west.  Visual Resource Management: Class II

Resource A: Livestock Grazing The analysis area for livestock grazing is the Lower Cattle Allotment and is approximately 81,368 acres. The analysis area was chosen based on the location of the project and also the Permittees that have requested the project run livestock on the allotment.

The Lower Cattle allotment is located approximately 17 miles southeast of Escalante, Utah. The allotment consists of federal public lands located within the newly aligned Kanab Escalante Resource Area (RERA) and the Glen Canyon National Recreation Area (GCNRA). The allotment runs from the straight cliffs on the west to the Escalante River on the east. The northern boundary is Twenty-five Mile Wash and the Dry Fork of Coyote Gulch and Coyote Gulch on the south. Some of the allotment (18,481 acres) lies within GCNRA. The Bureau of Land Management (BLM) has administrative responsibility for managing livestock grazing on the combined total of 81,368 acres that make up this allotment. Currently there are 7,488 active AUM’s on the Lower Cattle Allotment. Livestock grazing occurs from October 1st to April 15th.

The Lower Cattle Allotment is a “common allotment” with individual Permittees holding grazing permits on this allotment. Two of the six Permittees are requesting the line shack, however, all Permittees would have access and use of the line shack.

Resource B: Visual Resources Characteristic Landscape The Straight Cliffs rise dramatically to the west where the Escalante Desert transitions eastward to the Escalante Canyons. The proposal includes constructing a line shack at Cat Pasture adjacent to an existing corral and water development which are to either side of Hole-In-The-Rock Road in a disturbed area surrounded by low rolling landforms with a meandering ephemeral wash.

There are cottonwood trees and other riparian vegetation in the wash; pinyon/juniper and black brush scattered on the rolling hills; and snakeweed and other low shrubs and grasses in random patches throughout. The vegetation covers a full range of greens (dark to bright to gray) with golden seasonal changes; it ranges from fine to coarse in texture. The built elements in this immediate landscape include roads, fencing, corral, water trough, signs and intermittently parked camp trailers and vehicles. Of these the roads, corral, trailers and vehicles are the more noticeable elements.

The proposed development would be in a naturally enclosed landscape surrounded by rounded landforms. The predominant lines are horizontal and rounded created by landform edges. The roads add distinct bands across the landscape that are created by the removal of vegetation which creates a contrast in color and texture to the existing scene and that directs the eye along their alignments. The predominant colors of this landscape are reds, tans, gold, grays and greens due to the landforms and vegetation. The texture of the landscape varies from fine associated with patches of shrubs and rounded topography, to coarse due to the cottonwoods trees.

Figure 1: Image of site location for proposed action to provide context and sense of surrounding landscape characteristics. Line shack would be located between corral and trailer. Truck is parked adjacent to the Hole in The Rock Road.

The proposed action would occur in a classic southern Utah, canyon country landscape with exposed reddish soils and desert vegetation similar to other areas within the Colorado Plateau. This area is used primarily by recreationists and allotment Permittees. Those using the area for recreation are typically engaged in hiking and backpacking, scenic and heritage touring, OHV activities, and photography. This range of individuals defines the casual observer. The season of use when the most people are present is spring through fall; the Permittees use the area from fall to early spring.

Visual Resource Management Classes and Objectives The proposed Cat Pasture Line Shack would be located in Visual Resource Management (VRM) Class II. The objective for VRM Class II 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 found in the predominant natural features of the characteristic landscape.

Resource C: Lands with Wilderness Characteristics The Wildcat Corral is located directly adjacent to Hole-In-The-Rock Road and was built in 1944. The corral is used by six ranching operations during the grazing season. The immediate area in and around the corral is located within Unit 8 (approximately 10,800 acres) and is identified as having wilderness characteristics in the 1999 inventory, however, the area in and around the corral, does not contain wilderness characteristics as cattle operations are evident. Figure 2 identifies Unit 8 in its entirety; Figure 3 identifies the planning area. The red polygon (Figure 2) represents the disturbed area from cattle operations equaling approximately 6.54 acres. The line shack would be placed within the 6.54 acre polygon. The unit was inventoried and identified in the Utah Wilderness Inventory in 1999.

Unit 8 is contiguous to the Fifty Mile Mountain WSA (UT-040-080). Portions of Unit 8 lack wilderness character due to substantially noticeable impacts. A well-used vehicle route, generally trending north/south, west of the Hole-In-The-Rock Road, is a substantially

noticeable impact. There is considerable evidence of mineral exploration work on the Fifty Mile Bench above Batty Caves. An earthen stock pond and associated access in the northern portion of the Unit were also considered substantially noticeable.

In the immediate area of the corral and proposed line shack, wilderness characteristics are absent. Cattle operations and associated impacts are evident as the casual observer would be aware of the corral and loss of vegetation in the project area. Immediately to the west of the corral, historical earthwork and fill material are noticeable. Most evident in the project area is the lack of naturalness.

The areas outside of the project area retain their wilderness character. To the casual observer the area appears natural.

Figure 2: LWC Unit 8 highlighted in light blue

Figure 3: Project Area – Wildcat Corral (LWC).

CHAPTER 4 ENVIRONMENTAL IMPACTS

DIRECT AND INDIRECT IMPACTS

PROPOSED ACTION This section analyzes the impacts of the proposed action to those potentially impacting resources described in the affected environment Chapter 3.

Resource A: Livestock Grazing The analysis area for livestock grazing is the Lower Cattle Allotment. Livestock grazing occurs on approximately 81,000 acres. Grazing dates are from October 1st to April 15th.

Past Actions Livestock grazing was largely unregulated from the 1870s to 1934 until the passage of the Taylor Grazing act. While exact numbers of cattle grazing prior to 1934 are impossible to know, it is likely that the levels of grazing during that period were substantially higher than today. The 1957 range survey determined the carrying capacity to be 6,857 Animal Unit Months (AUMs) on Federal range. There was an additional 413 AUMs on State lands. A reduction was implemented in 1959 and afterwards ten permittees were authorized to graze 909 cattle from October 15th to June 15th. In 1967, the season of use was changed to October 1st to April 15th, the authorized use was 7,248 AUMs, and eight permittees were allowed to graze 1,161 cattle.

Present Actions Currently, the Lower Cattle Allotment is used by six permittees who are authorized to graze cattle from October 1st to April 15th for a total of 7,488 AUMs.

Reasonably Foreseeable Actions There are no reasonably foreseeable actions planned in this area.

Proposed Action Direct impacts from the construction of the line shack would require the use of vehicles/equipment to construct the line shack, which would result in the leveling out and possibly removing a small amount of soil. Due to the size and location of the proposed line shack vegetation removal if any would be very minimal and would have very little if any measurable impact to available forage for livestock grazing.

After construction, indirect impacts to be expected include:  Permittees utilizing the line shack and vehicles parking in the area in front of the line shack would impede the growth of vegetation in the small project area (approx. 100’ X 100’).  Due to the drive time of the requesting Permittees a line shack would allow them to stay and work longer with their cattle. This would allow them to make sure cattle are where they are supposed to be and also allow more time to take care of any trespass cattle.

 A line shack would also give the Permittees more time on the allotment to improve or maintain range improvements. Functioning and well maintained range improvements help facilitate better livestock management through better distribution, handling and making sure cattle are in the appropriate pasture or allotment. Grazing would likely continue with the same timing and intensity for future decades as determined by allocations set forth in the respective grazing permits. Available AUM’s would not be adjusted and permit levels would remain the same.

Resource B: Visual Resources Visual Resource Management has a standardized system to review lands actions for resource management plan conformance. Visual contrast rating worksheets are completed to determine if a project conforms to the resource management plan. In order to evaluate the environmental consequences of the alternatives for this proposed project, two linear key observations points (KOPs), one along Hole-In-The-Rock Road and another along Early Weed Bench Road, were established as part of completing the contrast rating worksheets.

Linear KOP #1 is along Hole-In-The-Rock Road going in both directions with a posted travel speed of 35 MPH; linear KOP#2 is along Early Weed Bench Road travelling west at an estimated 20 MPH or less due to narrow road width. These low travel speeds allow the casual observer to fixate on something in the landscape more so than when travelling at higher rates of speed.

Along KOP #1 (Figure 4), the proposed action would be less than 250 feet from the edge of the road above a wash in a naturally enclosed portion of the landscape that is somewhat screened by landforms. From the southbound approach the line shack would first be visible a bit less than 1/2 mile away and for less than 45 seconds. Due to landform screening when travelling northbound, the line shack would not be visible on the approach, then it would only be seen for less than 10 seconds when immediately adjacent to the line shack. The southbound angle of observation would be from a slightly elevated position and the northbound would be mostly level - equating to the project being more visible to those travelling southbound.

Figure 4: KOP 1 – View of proposed site along Hole in the Rock Road, traveling south

Along KOP #2 (Figure 5), the proposed action would be visible intermittently for up to five minutes from approximately 1.5 miles away to within one tenth of a mile of the site. Cottonwood trees and landforms would intermittently screen the development from view when travelling along the road. The angle of observation along this KOP would be from an elevated position allowing the structure’s roof and the ground around it to be seen.

Figure 5: KOP 2 – View of proposed site along Early Weed Bench Road, traveling west.

Proposed Action During construction, temporary visual impacts would result from the visibility of construction equipment and site work. Post construction, long-term weak visual contrasts would be created in form, line and texture created by the addition into this landscape of a permanent boxy and angular form with vertical, horizontal, and diagonal edges. The line shack would be sided with brown or gray wood siding and the roof and chimney would be dark-colored to match surroundings and non-reflective to prevent glare. The windows would be under the porch and on the back side facing the hill – also reducing or screening glare

from the glass. When fires are burning in the wood stove, the smoke created would be visible. Being located in a naturally enclosed area provides for landform screening to reduce visibility except when in close proximity to the site.

By constructing the project according to the outlined design features, the changes to the existing character of the landscape would meet the visual resource management objectives of the area.

Resource C - Lands with Wilderness Character The effected environment is approximately seven acres of the 10,800 acres within the LWC Unit 8. Approximately 10,793 acres would remain in Unit 8 to be managed for wilderness characteristics.

Past Actions Policy and guidance for conducting wilderness characteristics inventories is under Section 201 of The Federal Land Policy and Management Act of 1976 (FLPMA). Section 201 requires the BLM to maintain on a continuing basis an inventory of all public lands and their resources and other values, which includes wilderness characteristic. BLM must maintain and update as necessary, its inventory of wilderness resources on public lands. This includes but is not limited to a project that may impact wilderness characteristics undergoing NEPA analysis.

Present Actions This proposed action would remove approximately seven acres from Unit 8. In addition, the 2015 Dry Fork Slot Canyon Environmental Assessment (DOI-BLM-UT-0300-2015-0038- EA) reviewed Unit 8 for the development of a parking area approximately one mile to the southeast of the Wildcat Corral. The disturbance was estimated at one-half acre for a parking area and roadway and is documented in that EA. These two projects combined would remove approximately eight acres out of a 10,800 acre unit leaving the unit with sufficient acreage to be managed for wilderness characteristics.

Presently BLM (GSENM and Kanab Field Office) are starting a new land use planning effort. Lands with Wilderness Characteristics are being inventoried and reevaluated. Upon evaluation LWC units may be enlarged or reduced in size depending on the finding in the inventory.

Reasonably Foreseeable Actions Reasonably foreseeable actions area unknown at this time. It can be expected with increase recreational visitation along Hole-In-The-Rock Road future recreation needs and facilities would be developed and may reduce lands managed for wilderness character. LWC in the immediate area are of sufficient size or are contiguous to an adjacent WSA.

Proposed Action Direct effects of the proposed action would reduce the acreage in Unit 8 by approximately eight acres including the Dry Fork Parking Area EA. The reduction in acres would not limit BLM’s ability or authority to manage for wilderness characteristics.

Indirect effects may include future recreation developments, road maintenance, water pipelines, grazing developments not associate with this project. The land use planning effort may change BLM’s LWC boundaries and could reduce in acreage LWC managed units around ranching developments for future expansion.

NO ACTION The No Action Alternative would not meet the purpose and need of the proposed action, the Permittees would not construct a line shack at the proposed location. There would be no environmental impacts from the proposed action because it would be denied.

Resource A: Livestock Grazing Under the No Action Alternative, the direct impact related to the construction of the line shack as soil and vegetation removal would not occur. Permittee’s would have to travel the long distance home, decreasing time spent on the allotment working their cattle or improving range improvements.

Resource B: Visual Resources Under the No Action alternative, the proposed action would not be constructed. Camp trailers would likely continue to be used during the grazing season and would be visible when within close proximity to the site. They would create similar visual contrast as intermittent use of camp trailers by the recreating public though the duration would be longer than recreational use. This alternative would meet VRM objectives for the area because of the scale, screening and duration.

Resource C - Lands with Wilderness Character Under the No Action alternative, the proposed action would not reduce the acreage (10,800) identified in 1996 inventory in Unit 8. The impacts to the inventoried wilderness character would remain without the development of a line shack. The corral was developed in 1944 and cattle operations would continue. The current land use planning effort may add or subtract acreage to the LWC units along Hole-in-The- Rock Road. The impacts to wilderness characteristics are expected to remain the same.

CUMULATIVE IMPACTS Cumulative impacts are those impacts resulting from the incremental impact of an action when added to other past, present, or reasonable foreseeable actions regardless of what agency or person undertakes such actions. Ongoing uses and activities in the area include road repair and maintenance, water trough and pipeline construction and/or maintenance, and recreation activities. Livestock Grazing: Cumulative Impact Area (CIA) The cumulative impact area of analysis for livestock grazing is the Lower Cattle Allotment. This area was chosen because past and present land uses in this analysis area are similar in nature to the project area and have had similar effects on the livestock grazing program.

Cumulative Impact Analysis The cumulative impacts to the livestock program from past, present, and reasonably foreseeable actions include road maintenance, water pipeline construction, rangeland improvements, and recreation traffic. Grazing has and will most likely continue at the same time and with the same intensity as it has for many decades. Recreation in the area will most likely continue to increase annually. Taking past, present and reasonably foreseeable future actions into consideration, the construction of the Cat Pasture Line Shack would not affect the livestock program on a measurable level. Visual Resources: Cumulative Impact Area (CIA) Visual Resources - The cumulative impact area of analysis for Visual Resources is the view shed along the approximately 60 mile Hole-In-The-Rock Road.

Cumulative Impact Analysis The cumulative impacts to visual resources from past, present, and reasonably foreseeable actions include livestock grazing management facilities (line shacks, corrals, fences, water developments, storage buildings, etc.), recreational facilities (trailheads, day use areas, etc.), and general recreational use, sign installation, and road construction and maintenance activities. Some noted actions began in the CIA beginning in the mid-1800s and are projected to continue into the future, with recreational use and demand for additional supporting infrastructure likely to increase based on current trends. The following is a list of existing and planned range and recreation developments within the CIA: 1. Ten mile: corrals and water development 2. Devil’s Garden Day Use Site: parking area, picnic facilities and vault toilet 3. Twenty mile: corrals, line shack, storage structure and water development 4. Sunset Flat: exclosure fence 5. Cat Pasture: corrals and water development 6. Dry Fork Slot Canyons trailheads: two parking areas and vault toilets (planned) 7. Red Well: corrals, line shack, storage structure and water development 8. Willow Tank: corral and water development 9. Dance Hall Rock Historic Site: parking area and vault toilet 10. Forty mile: corrals, line shack, storage structure and water development The Twenty Mile line shack is located about 9 miles north of the proposed project and the planned Dry Fork Trailheads are within less than 2.5 miles south of it. Some of previously implemented actions as well as the currently planned actions within the viewshed were designed to protect the visual character. Most of the line shacks in the CIA were constructed decades ago, are small and rustic. The effect of past and present uses and actions has altered the undeveloped landscape character to some degree, but most casual observers would consider the viewshed along Hole-In-The-Rock Road to be mostly undeveloped and natural appearing. The proposed action would be constructed of materials that blend with the landscape and would be screened from view by landform on the approaches until within close proximity. Hole-In-

The-Rock Road runs for more than 60 miles from north to south through a viewshed that encompasses a landscape of 100,000s of acres. This development would be similar to other line shacks in that CIA in that it would be rustic and small in scale within this grand scale landscape. However, consideration should be given to the threshold at which the additional development of range, recreation or other improvements would cumulatively shift the landscape character in the CIA beyond one perceived to be mostly undeveloped.

Lands with Wilderness Characteristics: Cumulative Impact Area (CIA) The cumulative impact area of analysis for wilderness character is Unit 8 of the Fifty Mile Mountain WSA, however, only the project area would be impacted. The project area was identified based on the proposed action. Cumulative Impact Analysis The cumulative impacts to LWC managed lands from past, present, and reasonably foreseeable actions include road maintenance, water pipeline construction, rangeland improvements, and recreation traffic. Grazing will likely continue at the same time and with the same intensity as it has for many decades. Recreation in the area will most likely continue to increase annually. Taking past, present and reasonably foreseeable future actions into consideration, the construction of the Cat Pasture Line Shack would reduce lands managed for wilderness characteristics by seven acres. This reduction in acres would not affect Unit 8 from being managed as land with wilderness character.

CHAPTER 5 PERSONS, GROUPS, AND AGENCIES CONSULTED

Table 5.1. List of Preparers

BLM Preparers

Name Title Responsible for the Following Section(s) of this Document

Allysia Angus Land Use Planner, Visual Resources Landscape Architect

Dana Backer Planning and Document review and compliance Environmental Coordinator

Jason Bybee Range Conservationist Livestock Grazing, Project Lead

Jabe Beal Outdoor Recreation Lands with Wilderness Characteristics Planner

Matt Zweifel Archeologist Cultural Resources

Table 5.2 Comment Analysis Comment Analysis Cat Pasture Corral Line Shack (DOI-BLM-UT-0300-2017-0068)

Outside Decided Addressed scope of by law or Irrelevant Issue Commenter Summary in EA analysis policy to decision Comment Analysis Response Kane County would like the Bureau of Land Management (BLM) to allow the permittees (Lower Cattle allotment) to Kane County construct a line shack at Cat Pasture Corral along the Resource Hole-In-The-Rock Road area – acreage that has been Management Support of excluded from the monument and is now a part of the Jason, Project Kanab Field Office. X Thank you for your support of this project. Dana

Kane County We agree. Once constructed the Line Shack would remain Resource The BLM might consider leaving the line shack up instead in place from year to year and would not be deconstructed Proposed Management of requiring it’s deconstruction at the end of the grazing after the grazing season. It would be considered a Jason, Action season. X X permanent range improvement. Dana The EA indicated from the key observation points that the Kane County line shack would not be obvious to the casual observer, Resource but if it were, perhaps a sign could be posted that We agree. In Chapter 2 of the EA under the proposed Management mitigated intrusion (one that directed people to the nearest action it states that If needed, signage would be used to Jason, Signage rest stop). X inform and educate the public to help reduce vandalism. Dana Kane County would like to see more developments along Kane County Hole-In-The-Rock Road in terms of Trailhead markers, We appreciate your comment. The scope of this project Resource Future water developments, parking areas (for viewing) and rest was to analyze the impacts of constructing a line shack. No Jason, Management Developments stops. X X other projects where considered in the EA. Dana In Handbook H-1790-1 National Environmental Policy Act, Grand Staircase section 8.2 "you must notify the public of the availability of a Escalante completed EA and FONSI (40 CFR 1506.6(b)). In addition, Partners #1 some FONSIs must be available for a 30-day public Comment GSEP objects to the drastically shortened time period for review". The review period opened May 4, 2018 and Jason, Period public comments relative to the proposed project. X X ended June 4, 2018. Dana

GSEP objects to the failure of the project documents to fully and Grand completely analyze the likely environment l impacts of the project, Staircase including resource damage that may result from grazing in the area under We appreciate your comment. The scope of Escalante the current conditions of drought and forage failure. The documentation this project was to analyze the impacts of Partners #2 should have also included a thorough description of the permittees actual constructing a line shack. Grazing and its grazing history in the vicinity of the line shack, and a description of the impacts to the land are outside the analysis of Grazing current actual grazing conditions on the adjacent sections of the allotment. X X the project. Jason We appreciate your comment. The BLM was Grand responding to a request from the permittees Staircase to construct a line shack. Alternatives were Escalante The documentation should have included an analyzed additional developed based on the purpose and need to No Action Partners #3 reasonable alternatives, including "no action", and "removal of the line address the request from the permittee's. A alternative shack". X X no action alternative was analyzed in the EA. Jason, Dana Holding the decision until after the completion Grand of the RMP would not change the impacts on Staircase the ground, mitigate potential impacts, nor Escalante GSEP respectfully requests that a final decision on this project be are cattle operations expected to cease in the Postpone Partners #4 postponed until the judicial challenges to the 12/4/17 Proclamation are allotment. Therefor the EA appears timely project resolved, and until the current new RMP planning process is completed. X X and relevant to the application. Jason, Dana

In order to comply with FLPMA and Manual 6320, BLM must assess Southern whether the proposed project will impact the wilderness characteristics, An LWC review was completed for this Utah i.e. naturalness, solitude, and opportunities for primitive and unconfined project. It is estimated that 7 acres of Wilderness recreation, of the lands in this proposed project area. As currently previously disturbed area around the corral Alliance proposed, the project includes surface-disturbing activities within 6.54 would be removed from the LWC unit 8. This Lands with (SUWA) #1 acres of lands with wilderness characteristics within Unit 8 of the Fifty-mile would leave approximately 10,792 acres Wilderness Mountain Wilderness Inventory Unit. See 1999 Utah Wilderness Inventory, within the unit and would allow the unit be characteristics 50. X retained for its wilderness characteristics. Jabe

Two contrast rating worksheets were completed for the proposed project. One along the linear KOP of Hole in the Rock The project EA must fully analyze the project’s impacts to visual resources Road and another along linear KOP Early and BLM must seek to retain the existing character of the landscape. The Weed Road. From both KOPs it was SUWA #2 EA must consider alternatives that ensure the project does not degrade determined that weak contrast in form, line the current level of visual resources in the project area. VRM Class II and texture would result by implementation of areas must be managed to retain the existing character of the natural this project (addition of a permanent structure landscape. To proceed in in compliance with FLPMA, the project should where one currently does not exist). That Visual not be approved until BLM establishes that it will not adversely impact level of contrast meets the objectives of VRM Resources visual resources in the project area. x Class II. Allysia

The proposed project’s purpose and need statement must adequately inform the public as to BLM’s purpose and need for the proposed action We appreciate your comment. The BLM was SUWA #3 and must sufficiently analyze a wide range of reasonable alternatives. In responding to a request from the permittees doing so, BLM cannot narrowly define the purpose of the proposed project to construct a line shack. Alternatives were Purpose and in such a way as to make construction of the line shack the only developed based on the purpose and need to Need alternative that meets BLM’s purpose and need. X address the request from the permittee's. Jason, Dana An action and no action alternative was analyzed for a project site that has been developed as a cattle corral since 1944. The immediate area adjacent to the corral, where the proposed cabin is to be placed, has been impacted from years of cattle operations. The alternatives addresses the proposed action and maintaining wilderness characteristics in Unit 8. Two contrast rating worksheets were SUWA #4 completed for the proposed project. One along the linear KOP of Hole in the Rock Road and another along linear KOP Early Weed Road. From both KOPs it was To comply with NEPA’s mandate, BLM must consider and fully analyze a determined that weak contrast in form, line range of reasonable alternatives, including an alternative that would avoid and texture would result by implementation of or minimize impacts to lands with wilderness characteristics by removing this project (addition of a permanent structure Range of surface-disturbing activities within those identified areas, and an where one currently does not exist). That reasonable alternative that would fully conform to the project area’s VRM Class II level of contrast meets the objectives of VRM Alternatives visual resource objectives. X Class II. Jabe/Allysia

BLM should consider an actual range of alternatives, including actions The BLM was responding to a request from SUWA #5 other than building a line shack that would accomplish the general goals of the permittees to construct a line shack. the proposed action: providing shelter when ranchers are out working their Alternatives were developed based on the Range of livestock. Currently, the objectives are so narrowly defined that the purpose and need to address the request Alternatives applicants’ proposed project is the only real alternative considered. X from the permittee's. Jason, Dana The Cat Pasture Cabin EA must take a hard look at cumulative impacts SUWA #6 from past, present, and reasonably foreseeable actions on BLM-managed Cumulative public lands within the project area, surrounding area, and in the larger Impacts region. X Cumulative Impacts were analyzed in the EA. Jason, Dana The EA, in chapter 4, does address and disclose the indirect impacts of the proposed project. Indirect effects, are effects which are caused by the action and are later in time or further removed in distance, but are still reasonably foreseeable. Any reasonably foreseeable effects are analyzed in chapter 4 of the EA. 40 CFR 1508.8(b) states that SUWA #7 "Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population density or growth rate, and related effects on air and water and other natural systems, including ecosystems." The above listed The Cat Pasture Cabin EA must take a hard look at indirect effects of the indirect effects "may" be included and not Indirect proposed project, including growth inducing effects, changes in the pattern "must" be included in the EA as stated by the Effects of land use, and related effects on natural systems, including ecosystems. X CFR's. Jason, Dana

The project, as currently proposed, is to be sited within an area currently The EA, in chapter 4, does address and SUWA #8 designated by BLM as containing wilderness characteristics. Pursuant to disclose the direct, indirect, and cumulative Wilderness NEPA, BLM must analyze and disclose the direct, indirect, and cumulative impacts of the proposed project to lands with characteristics impacts of the proposed project to lands with wilderness characteristics. X wilderness characteristics. Jabe

Two contrast rating worksheets were completed for the proposed project. One along the linear KOP of Hole in the Rock Road and another along linear KOP Early Weed Road. From both KOPs it was SUWA #9 determined that weak contrast in form, line and texture would result by implementation of this project (addition of a permanent structure where one currently does not exist). That Visual The Cat Pasture Cabin EA must take a hard look at impacts to visual level of contrast meets the objectives of VRM Resources resources. X Class II. Allysia Unit 8 was inventoried in 1999 and identified to have wilderness characteristics at that time. The immediate area next to the corral does not have wilderness characteristics as cattle operations have impacted the area. Although the area in question was included in The Draft EA for the Cat Pasture Cabin project approves surface Unit 8 and identified to have LWC, a field disturbing activity that may result in the loss of BLM-identified lands with survey identified the area does not have wilderness characteristics. In turn, this limits the ability of those lands to be wilderness character. Based on the field SUWA #10 managed for wilderness characteristics in the forthcoming revised RMP survey the disturbed area was removed from (i.e. managed as “natural areas”). Thus, the Draft EA proposes an activity Unit 8 reflecting the actual wilderness that will reduce the analysis of a range of management alternatives characteristics of the unit. Holding the available to BLM in the RMP planning process. Both NEPA implementing decision until after the completion of the RMP regulations and BLM guidance make clear that BLM should remove the would not change the impacts on the ground, proposed project from all lands with wilderness characteristics where a mitigate potential impacts, nor are cattle Lands with management decision for those lands has yet to be made as part of the operations expected to cease in the Wilderness RMP revision process, or defer action until the RMP revision process is allotment. Therefor the EA appears timely characteristics complete. X and relevant to the application. Jabe

A cultural resource inventory and report have been completed, and will be submitted to SHPO with our next batch of quarterly reports, as per the Small-Scale Undertakings Programmatic Agreement (2014) w/SHPO. No cultural resource sites were found in the project area. Because no archaeological SUWA #11 Pursuant to the NHPA, BLM must initiate consultation with the SHPO, sites were found, Native American relevant and affected Tribes and other interested parties, and must consultation will be included in the annual conduct a Class III cultural resource inventory of the area of potential GSENM/Native American consultations, effects of the proposed Cat Pasture Cabin. Meaningful rather than specifically for this project, as per consultation must be conducted prior to issuing and decision and BLM their request in cases such as this where no Cultural must seek ways to avoid and protect any and all cultural resources that it Native American sites will be threatened or Resource discovers. X adversely impacted. Matt Z.

This is generally an excellent EA. Kudos to those who prepared it. My only concern is that one feasible alternative was not addressed in the EA: use We appreciate your comment. The purpose of a temporary trailer in lieu of construction of a permanent structure. of the EA was to address a request from the MR. Richard There is a photo in the EA of a trailer next to the corral. This raises the permittees to construct a line shack. Spotts question of whether a travel trailer could be used by the permittees. A Currently the permittees use trailers as temporary trailer could be moved to different locations, may be cheaper temporary quarters and they would like than building a structure, already has a bathroom so no need for a porta something more permanent. The no action pottie, and would not be a permanent and prominent structure. Please alternative addresses the continued use of Alternative consider this alternative. Thank you very much for your consideration. X trailers as temporary quarters. Jason, Dana

APPENDICES

APPENDIX A INTERDISCIPLINARY TEAM CHECKLIST

Project Title: Cat Pasture Corral Line Shack NEPA Log Number: DOI-BLM-UT-0300-2017-0068 Project Leader: Jason Bybee

Article I. DETERMINATION OF STAFF: (Choose one of the following abbreviated options for the left column) NP = not present in the area impacted by the proposed or alternative actions NI = present, but not affected to a degree that detailed analysis is required PI = present with potential for impact that needs to be analyzed in detail NC = (DNAs only) actions and impacts not changed from those disclosed in the existing NEPA documents cited in Section D of the DNA form.

The rationale column may include NI and NP discussions.

Article II. RESOURCES AND ISSUES CONSIDERED (INCLUDES SUPPLEMENTAL AUTHORITIES APPENDIX 1 H-1790-1)

Determi- Resource Rationale for Determination* Signature Date nation The proposed action would not have measurable impacts on Air Quality air quality. During construction some particulates would be NI /s/ J. Bybee 11/14/2017 (Bybee) released into the air, but they would quickly disperse and be unmeasurable. Areas of Critical There are no Areas of Critical Environmental Concern NP Environmental Concern designated within Grand Staircase-Escalante National /s/ J. Beal 11/21/2017 (Beal) Monument. The proposed action is located within a previously disturbed Biological Soil Crusts NI area therefore not impacting any existing biological soil /s/R. Brinkerhoff 1/8/18 (Brinkerhoff) crusts. BLM Natural Areas The proposed project are not within a designated Natural NP /s/ J. Beal 11/21/2017 (Beal) Area within GSENM. A cultural resource survey of the proposed line shack location Cultural Resources has been completed, and no cultural resource sites were NP /s/ M. Zweifel 12/7/2017 (Zweifel) found. A report will be completed and forwarded to SHPO with our next quarterly report. Greenhouse Gas The proposed action would not impact greenhouse gas emissions. The construction phase will use some equipment, NI Emissions /s/ J. Bybee 11/14/2017 but the time frame would be very short. The emissions (Bybee) generated would disperse quickly and be unmeasurable.

Determi- Resource Rationale for Determination* Signature Date nation As defined in EO 12898, minority, low-income populations and disadvantaged groups may be present within the county and may use the analysis area. Individual proposed actions Environmental Justice NP within the analysis area would not cause any /s/ D. Backer 11/29/2017 (Hughes) disproportionately high and adverse effects on minority or low-income populations. (Individually or collectively). Members of the public would still use the analysis area. Prime farmland is described as farmland with resources available to sustain high levels of production. In Utah, it normally requires irrigation to make prime farmland. In general, prime farmland has a dependable water supply, a favorable temperature and growing season, acceptable levels Farmlands (Prime or of acidity or alkalinity, an acceptable content of salt and NP Unique) /s/ D. Backer 11/29/2017 sodium, and few or no rocks. Unique farmland in Utah is (Hughes) primarily in the form of orchards. Based on these definitions, no prime or unique farmlands exist within the Monument. (see NRCS 1997 Results - Cropland Utah accessed at: http://www.nrcs.usda.gov/wps/portal/nrcs/detail/ut/technical/ dma/nri/?cid=nrcs141p2_034092 on 2/6/2014.) The area was surveyed for nesting habitat and dens on Fish and Wildlife 11/27/2017. No suitable habitat or nests and dens of sensitive Excluding USFW species and migratory birds was found within the proposed NI /s/ T. Tolbert 11/30/2017 Designated Species project boundaries or within adjacent areas. The area is (Tolbert/McQuivey) mostly bare dirt with some weedy plant species scattered throughout the site. Floodplains NP The prosed project is not within a floodplain. /s/ K. Bradshaw 12/11/2017 (Bradshaw) Fuels/Fire Management The proposed Action would not increase or decrease fuels NI /s/A. Bate 12/18/2017 (Bate) and fire management within the proposed line shack location. Geology / Mineral No scenic or significant economic geologic features are in the Resources/Energy immediate area. Construction of a building would not affect NI /s/ Alan Titus 12/11/2017 Production geological resources or mineral or energy production. This (Titus) should not change even if the area is open to leasing again. The proposed project would not substantially impact hydrologic conditions. The footprint of the line shack is approximately 560 sq. feet and only an area slightly larger Hydrologic Conditions than that footprint would be leveled to construct the NI /s/ K. Bradshaw 12/11/2017 (Bradshaw ) foundation if necessary. The proposed location of the line shack is also in a previously disturbed area near existing corrals so there would not be an overall increase in compacted area due to the proposed action. Invasive Species/Noxious The proposed action would not increase the threat or spread NI Weeds (EO 13112) /s/R. Brinkerhoff 1/8/18 of invasive/noxious weeds therefore having no impact. (Brinkerhoff) Project as described will have no impact on realty-related issues. Review of available BLM databases determined that there are no realty-related valid existing rights in or near the Lands/Access project area. The project would not impact land tenure, NI /s/ Mark Foley 11/21/2017 (Foley) access, or adjacent private property. As with all projects on public land, construction should take care to preserve survey markers, bearing tress, and witness corners which may be present in the project area. The proposed action would positively affect cattle grazing on Livestock Grazing PI the Lower Cattle allotment. Impacts would be analyzed in /s/ J. Bybee 1/3/2018 (Bybee) the EA.

Determi- Resource Rationale for Determination* Signature Date nation A cultural resource survey of the proposed line shack location has been completed, and no cultural resource sites were Native American found. A report will be completed and forwarded to SHPO NP Religious Concerns /s/ M. Zweifel 12/7/2017 with our next quarterly report. This project will be included (Zweifel) in the annual GSENM/Native American consultations, but no comments are anticipated. The bedrock geological units in the area of the Proposed Action are entirely middle Jurassic sabkha and other coastal Paleontology deposits with very low fossil potential. The building itself NI /s/Alan Titus 12/7/2017 (Titus) would be located on alluvial deposits. No significant impact to fossil resources would be expected from its construction and maintenance. Rangeland Health The proposed project location is small in size and adjacent to NI Standards the Cat Pasture Corral and will not affect Rangeland Health /s/ Sean Stewart 12/11/17 (Stewart) Standards. Recreational use in the proposed area is heavy along Hole-in- the-Rock Road. Cat Pasture corrals are directly along Hole- in-the-Rock Road and provides a disturbed area for people to stop, however the site is not next to a high recreational user destination area and therefor recreational use at the corral is minimal. Signage instalments at the proposed project area are designed to reduce user conflicts at the project area. The Dry Recreation NI Fork Parking Area Environmental Assessment DOI-BLM- /s/ J. Beal 11/21/2017 (Beal) UT-0300-2015-38 proposes two new parking areas to the Dry Fork Slot canyons. One parking area is 1 mile south of Cat Pasture corral. The Dry Fork project will direct recreational use and parking away from Cat Pasture Corral minimizing recreational / grazing conflicts. No other recreational issues were identified for this proposed project. Therefore, recreation will not be carried forward for analysis in this EA. Socio-Economics Quantifiable additional or decreased economic impact to the NP /s/ D. Backer 11/29/2017 (Hughes) local area would not be affected by the proposed action. The proposed project would not substantially impact soils. The footprint of the line shack is approximately 560 sq. feet and only an area slightly larger than that footprint would be Soils NI leveled to construct the foundation if necessary. The /s/ K. Bradshaw 12/11/2017 (Bradshaw) proposed location of the line shack is also in a previously disturbed area near existing corrals so there would not be an overall increase in compacted area due to the proposed action. Threatened, Endangered or Candidate Plant The proposed action would not impact any threatened, NP /s/R. Brinkerhoff 1/8/18 Species endangered or candidate plant species. (Brinkerhoff) Threatened, Endangered The area for the proposed project is not within suitable habitat or Candidate Animal NP for any of the Threatened, Endangered or Candidate species /s/ T. Tolbert 11/30/2017 Species that occur in Kane County. (Tolbert/McQuivey) Wastes There will be no industrial wastes or toxic substances used 12/14/17 NP (hazardous or solid) /s/ B. Pierson /s/ B. Pierson or generated.

(Pierson) The proposed project would not substantially impact water resources. The nearest well to the proposed project location Water Resources/Quality is for livestock water, is approximately 350 feet away, and is NI (drinking/surface/ground) /s/ K. Bradshaw 12/11/2017 not expected to be impacted. The wash near the proposed (Bradshaw) project area is ephemeral and would not be expected to be impacted.

Determi- Resource Rationale for Determination* Signature Date nation

Wetlands/Riparian Zones There is no wetland/riparian zones within the proposed NP /s/R. Brinkerhoff 1/8/18 (Brinkerhoff) project area. Wild and Scenic Rivers NP WSR are not present in the proposed project area. /s/ J. Beal 11/21/2017 (Beal) Wilderness/WSA Wilderness and WSA are not present in the proposed project NP /s/ J. Beal 11/21/2017 (Beal) area. Woodland/Forestry No wood or Forestry species would be removed or utilized NI /s/A.Bate 12/18/2018 (Bate) for this project. Vegetation Excluding USFWS Designated The proposed action is located within a previously disturbed NI /s/ R. Brinkerhoff 1/8/18 Species area therefore not impacting any existing vegetation. (Brinkerhoff) The proposed action is located in VRM Class II. A Visual Resources PI contrasting analysis is needed to determine potential impacts /s/A. Angus 12/7/2017 (Angus) and conformance with VRM objectives. Wild Horses and Burros There are no Wild Horse and Burro Herd Management Areas NP /s/ S. Stewart 12/11/17 (Stewart) within GSENM. Lands with Wilderness The project area lies within the 50 Mile Mountain LWC unit. PI Characteristics /s/ J. Beal 11/21/2017 This resource will be inventoried and analyzed in the EA. (Beal)

Article III. FINAL REVIEW

Reviewer Title Signature Date Comments

Environmental Coordinator 6/28/18

Authorized Officer -GSENM 9/7/18

Authorized Officer -KFO 6/29/18

APPENDIX B

Project Area Map

APPENDIX C Site Design