United States Department of the Interior Bureau of Land Management

Programmatic Environmental Assessment for Vegetation Treatments and Installation of Stabilization/Erosion Control Structures in Northwest Colorado ______

DOI-BLM-CO-N000-2017-0001-EA

U.S. Department of Interior Bureau of Land Management Northwest Colorado District Office 2300 River Frontage Road Silt, Colorado 81652

September 2017

TABLE OF CONTENTS

1. Introduction 9 1.1. Identifying Information 9 1.2. Background 9 1.3. Purpose and Need for Action 11 1.4. Decision to be Made 11 1.5. Conformance with the Land Use Plans 11 1.6 Relationship to Laws, Regulations and Other Plans 15 2. Public involvement 16 2.1. Scoping 16 2.2. Public Comment 19 3. Proposed Action and Alternatives 19 3.1. Proposed Action 19 3.2. No Action Alternative 41 3.3. Alternatives Considered but Eliminated from Detailed Analysis 41 4. Issues 44 4.1. Issues Analyzed 44 5. Affected Environment and Environmental Consequences 46 5.1. Air Quality and Climate Change 46 5.1.1. Affected Environment 46 5.1.2. Environmental Consequences – Proposed Action 48 Direct and Indirect Impacts 48 Cumulative Impacts 51 5.1.3. Environmental Consequences – No Action Alternative 52 Direct and Indirect Impacts 52 Cumulative Effects 52 5.1.4. Mitigation Measures and Residual Impacts 53 5.2. Soil Resources 53 5.2.1. Affected Environment 53

5.2.2. Environmental Consequences – Proposed Action 58 Direct and Indirect Impacts 58 Cumulative Impacts 60 5.2.3. Environmental Consequences – No Action Alternative 61 Direct and Indirect Impacts 61 Cumulative Impacts 61 5.3. Surface and Ground Water Quality, Floodplains and Water Rights 61 5.3.1. Affected Environment 61 5.3.2. Environmental Consequences – Proposed Action 68 Direct and Indirect Impacts 68 Cumulative Impacts 70 5.3.3. Environmental Consequences – No Action Alternative 71 Direct and Indirect Impacts 71 Cumulative Impacts 71 5.4. Aquatic Wildlife 72 5.4.1. Affected Environment 72 5.4.2. Environmental Consequences – Proposed Action 72 Direct and Indirect Impacts 72 Cumulative Impacts 73 5.4.3. Environmental Consequences – No Action Alternative 73 Direct and Indirect Impacts 73 Cumulative Impacts 73 5.5. Vegetation, Wetlands and Riparian Zones 74 5.5.1. Affected Environment 74 5.5.2. Environmental Consequences – Proposed Action 80 Direct and Indirect Impacts 80 Cumulative Impacts 82 5.5.3. Environmental Consequences – No Action Alternative 83 Direct and Indirect Impacts 83 Cumulative Impacts 83 5.6. Invasive, Non-Native Species 83 5.6.1. Affected Environment 83 3

5.6.2. Environmental Consequences – Proposed Action 85 Direct and Indirect Impacts 85 Cumulative Impacts 85 5.6.3. Environmental Consequences – No Action Alternative 86 Direct and Indirect Impacts 86 Cumulative Impacts 86 5.7. Migratory Birds 86 5.7.1. Affected Environment 86 5.7.2. Environmental Consequences – Proposed Action 88 Direct and Indirect Impacts 88 Cumulative Impacts 89 5.7.3. Environmental Consequences – No Action Alternative 90 Direct and Indirect Impacts 90 Cumulative Impacts 90 5.8. Terrestrial Wildlife 90 5.8.1. Affected Environment 90 5.8.2. Environmental Consequences – Proposed Action 91 Direct and Indirect Impacts 91 Cumulative Impacts 94 5.8.3. Environmental Consequences – No Action Alternative 94 Direct and Indirect Impacts 94 Cumulative Impacts 94 5.9. Special Status Animal Species 94 5.9.1. Affected Environment 95 5.9.2. Environmental Consequences – Proposed Action 99 Direct and Indirect Impacts 99 Cumulative Impacts 103 5.9.3. Environmental Consequences – No Action Alternative 103 Direct and Indirect Impacts 103 Cumulative Impacts 104 5.10. Special Status Plant Species 104 5.10.1. Affected Environment 104 4

5.10.2. Environmental Consequences – Proposed Action 118 Direct and Indirect Impacts 118 Cumulative Impacts 119 5.10.3. Environmental Consequences – No Action Alternative 119 Direct and Indirect Impacts 119 Cumulative Impacts 119 5.11. Areas of Critical Environmental Concern 120 5.11.1. Affected Environment 120 5.11.2. Environmental Consequences – Proposed Action 123 Direct and Indirect Impacts 123 Cumulative Impacts 124 5.11.3. Environmental Consequences – No Action Alternative 124 Direct and Indirect Impacts 124 Cumulative Impacts 125 5.12. Cultural Resources 125 5.12.1. Affected Environment 125 5.12.2. Environmental Consequences – Proposed Action 126 Direct and Indirect Impacts 126 Cumulative Impacts 128 5.12.3. Environmental Consequences – No Action Alternative 129 Direct and Indirect Impacts 129 Cumulative Impacts 129 5.12.4. Mitigation Measures and Residual Impacts 129 5.13. Native American Religious Concerns 129 5.13.1. Affected Environment 129 5.13.2. Environmental Consequences – Proposed Action 130 Direct and Indirect Impacts 130 Cumulative Impacts 130 5.13.3. Environmental Consequences – No Action Alternative 130 Direct and Indirect Impacts 130 Cumulative Impacts 131 5.13.4. Mitigation Measures and Residual Impacts 131 5

5.14. Visual Resources 131 5.14.1. Affected Environment 131 5.14.2. Environmental Consequences – Proposed Action 133 Direct and Indirect Impacts 133 Cumulative Impacts 133 5.14.3. Environmental Consequences – No Action Alternative 134 Direct and Indirect Impacts 134 Cumulative Impacts 134 5.15. Lands with Wilderness Characteristics 134 5.15.1. Affected Environment 134 5.15.2. Environmental Consequences – Proposed Action 137 Direct and Indirect Impacts 137 Cumulative Impacts 138 5.15.3. Environmental Consequences – No Action Alternative 139 Direct and Indirect Impacts 139 Cumulative Impacts 139 5.16. Rangeland Management 139 5.16.1. Affected Environment 139 5.16.2. Environmental Consequences – Proposed Action 142 Direct and Indirect Impacts 142 Cumulative Impacts 142 5.16.3. Environmental Consequences – No Action Alternative 143 Direct and Indirect Impacts 143 Cumulative Impacts 143 5.17. Wild Horses 143 5.17.1. Affected Environment 143 5.17.2. Environmental Consequences – Proposed Action 144 Direct and Indirect Impacts 144 Cumulative Impacts 145 5.17.3. Environmental Consequences – No Action Alternative 145 Direct and Indirect Impacts 145 Cumulative Impacts 145 6

5.18. Recreation 145 5.18.1. Affected Environment 145 5.18.2. Environmental Consequences – Proposed Action 146 Direct and Indirect Impacts 146 Cumulative Impacts 147 5.18.3. Environmental Consequences – No Action Alternative 147 Direct and Indirect Impacts 147 Cumulative Impacts 147 5.19. Fire and Fuels Management 147 5.19.1. Affected Environment 147 5.19.2. Environmental Consequences – Proposed Action 149 Direct and Indirect Impacts 149 Cumulative Impacts 149 5.19.3. Environmental Consequences – No Action Alternative 149 Direct and Indirect Impacts 149 Cumulative Impacts 150 5.20. Colorado Standards for Public Land Health 150 5.20.1. Standard 1 – Upland Soils 150 5.20.2. Standard 2 – Riparian Systems 150 5.20.3. Standard 3 – Plant and Animal Communities 151 5.20.4. Standard 4 – Special Status Species 151 5.20.5. Standard 5 – Water Quality 151 6. Supporting Information 152 6.1. Interdisciplinary Review 152 6.2. Tribes, Individuals, Organizations, or Agencies Consulted 152 6.3. References 154 Attachment A: Project Maps 166 Attachment B: Photos of equipment described in proposed action 166 Attachment C: Seasonal habitat objectives for greater sage-grouse 166 Attachment D: Glossary 166 Attachment E: Chambers et. al. 2016 four step process 166 Attachment F: Colorado Noxious Weeds List 166 7

Attachment G: Response to Public Comments 166

1. INTRODUCTION 1.1. Identifying Information

Project Title: Programmatic Environmental Assessment for Vegetation Treatments and Installation of Stabilization/Erosion Control Structures in Northwest Colorado NEPA Document Number: DOI-BLM-CO-N000-2017-0001-EA 1.2. Background Throughout the West, sagebrush shrublands have been and continue to be lost, fragmented, or altered due to invasive plants, changes in fire regimes, pinyon and juniper encroachment, climate change, overgrazing, and land use impacts including oil and gas developments, roads, croplands, and other human developments (Paige 1999).

Pinyon and juniper woodlands have increased dramatically across the Intermountain West over the last 150 years, likely due to a combination of fire suppression, periods of favorable climatic conditions, and historic overgrazing by livestock. Pinyon and juniper trees have encroached into sagebrush sites that did not support trees previously, gradually shifting the land cover type from sagebrush steppe to woodland in many areas. Encroaching conifers can absorb large amounts of water, making it unavailable to other plants, alter soil acidity, shade out understory plants, and compete with understory plants for nutrients, eventually degrading conditions for wildlife that depend on sagebrush sites (Maestas et al. 2015, Miller et al. 2011, Tausch et al. 2009).

Classification of pinyon and juniper stands are based on the phase of woodland development (i.e., early, mid, and late successional) following the guidelines developed by Miller and others (Miller et al. 2005). Phase I stands support dispersed trees, but shrubs and herbaceous vegetation are the dominant vegetation influencing ecological processes. Phase II stands support co-dominant trees, shrubs, and herbaceous vegetation, but the understory grasses and forbs important for sage- grouse, many other wildlife species, and livestock are declining. In Phase III stands, trees are dominant and the primary plant layer influencing ecological processes. Shrubs begin to disappear during Phase III, and these sites support a different array of birds and plants than Phase I and II stands (Maestas et al. 2015, Tausch et al. 2009, Miller et al. 2005).

Targeting pinyon and juniper removal in Phase I and II stands can be the most effective for restoring and sustaining wildlife habitat as these sites still have enough sagebrush and herbaceous understory to achieve the most predictable results for the least cost. Phase III sites have greater risks (e.g., increased invasive weeds) associated with treatment and often require more resources (e.g., seeding, extensive weed control, heavy slash removal) (Maestas et al. 2015, Tausch et al. 2009).

Many of the riparian ecosystems within the project area have also been altered and sometimes degraded through climate change, overgrazing, and land use impacts including oil and gas developments. Installation of erosion control structures can help restore degraded riparian areas by allowing precipitation to infiltrate the soil, which can then help increase plant cover, reduce evaporation, reduce turbidity and reduce soil loss (Zeedyk 2009). Focusing work in these areas can increase habitat for a host of plants and animals and help the landscape as a whole increase diversity and overall health.

This EA is being prepared in order to streamline the process by which the planned vegetation treatments and installation of erosion/stabilization structures could be approved and implemented on BLM-managed lands.

The BLM would conduct an additional site-specific review of individual vegetation treatment projects using a Determination of NEPA Adequacy (DNA) worksheet to determine if all resource concerns have been adequately addressed in this programmatic EA or if additional environmental analysis would be required.

Project Location The project area is designed to encompass the areas identified in the POW, described in more detail below in the Background section.

The project area includes all BLM-managed lands within the Northwest District and the Grand Junction Field Office that are mapped as the following vegetation types:

▪ Colorado Plateau Mixed Low Sagebrush ▪ Inter-Mountain Basins Big Sagebrush Shrubland Shrubland ▪ Inter-Mountain Basins Mixed Salt Desert ▪ Inter-Mountain Basins Montane Scrub Sagebrush Steppe ▪ Inter-Mountain Basins Semi-Desert ▪ Rocky Mountain Subalpine –Montane Shrub Steppe Riparian Shrubland ▪ Rocky Mountain Subalpine Mesic ▪ Wyoming Basins Low Sagebrush Meadow Shrubland ▪ Recently Burned Areas ▪ Colorado Plateau Pinyon-Juniper ▪ Colorado Plateau Mixed Low Sagebrush Woodland Shrubland

The BLM understands that the Geographic Information Systems (GIS) data used to identify the vegetation types above may not be perfectly accurate. All proposed projects would need to be ground-truthed to confirm that the vegetation in question is actually present on the proposed project site. Some proposed projects may fall outside of the areas mapped in this 10

Environmental Assessment (EA). It is assumed that the impacts for projects that fall outside of the areas mapped would be very similar, if not the same as the impacts that will be disclosed in this EA for the projects that do fall within the areas already mapped.

See Attachment A for a map of the project area.

1.3. Purpose and Need for Action The purpose of the Proposed Action is to take a programmatic approach to vegetation treatments and installation of erosion/stabilization structures to work towards the vegetation management goals of the GJFO, KFO, WRFO, CRVFO, and LSFO RMPs to promote healthy, productive, and diverse vegetation communities. The need for the Proposed Action is that some portions of vegetation communities within these field offices are not meeting RMP vegetation objectives due to invasive weeds, lack of natural disturbance regimes (e.g., historic fire suppression), etc. Using a landscape approach to consider vegetation management fulfils the need to prioritize vegetation and restoration treatments throughout the Northwest District and the Grand Junction Field Office and results in standard methods to be used across these vegetation communities. 1.4. Decision to be Made Based on the analysis contained in this EA, the Northwest District Manager will decide whether to approve or deny the Proposed Action, and if so, under what terms and conditions. Under the NEPA, the BLM must determine if there are any significant environmental impacts associated with the Proposed Action warranting further analysis in an EIS. The Northwest District Manager is the responsible officer who will decide one of the following: ▪ To approve the specific types of treatment methods and design features analyzed; ▪ To analyze the effects of Proposed Action in an EIS; or ▪ To deny the Proposed Action.

1.5. Conformance with the Land Use Plans The Proposed Action is subject to and in conformance with the following plans (43 CFR 1610.5- 3(a), BLM 1617.3):

Name of Plan: Colorado River Valley Record of Decision and Approved Resource Management Plan (RMP)

Date Approved: 2015

Decision Language: VEG-GOAL-01. Maintain healthy, productive plant communities of native and other desirable species at viable population levels commensurate with the species and habitats potential. Ensure that 11

plants and animals at both the community and population level are productive, resilient, diverse, vigorous, and able to reproduce and sustain natural fluctuations and ecological processes (Land Health Standard 3).

VEG-OBJ-01. Manage for a healthy diversity of native plant communities in a variety of successional stages consistent with the ecological site’s potential and the natural range of variability.

Name of Plan: Kremmling Record of Decision and Approved RMP

Date Approved: 2015

Decision Language: Goal - Maintain healthy, productive plant communities of native and other desirable species at viable population levels commensurate with the potential for the species and the habitats. Ensure that plants and animals at both the community and population level are productive, resilient, diverse, vigorous, and able to reproduce and sustain natural fluctuations and ecological processes (Public Land Health Standard 3, See Appendix J).

Objective - Manage sagebrush steppe, where needed, to transition from homogenous stands of old sagebrush in order to create a more diverse age-class structure across the landscape, and to improve diversity and cover of understory species.

Name of Plan: Little Snake Record of Decision and Approved RMP

Date Approved: 2011

Decision Language: Wildland Fire Management - page RMP-27 Give first priority to protection of life or property. Objectives for achieving this goal include: ▪ Identify and reduce hazardous fuels, with an emphasis on urban interface areas. Create an integrated approach to fire and resource management to meet land health standards. Objectives for achieving this goal include: ▪ Reduce fire hazards in ecosystems and restore ecological community functions. ▪ Use mechanical or other vegetation treatments to reduce fire

hazards, when appropriate.

Vegetation – page RMP-15 Collaborate with stakeholders and resource users in providing an array of habitats, suitably distributed across the landscape, that support biodiversity and viable populations of native plant and animal species. Objectives for achieving this goal include: ▪ Manage for a diversity of seral stages within plant communities. ▪ Manage for connections between varieties of plant communities on a landscape scale. ▪ Manage for juniper and other large woody species within their historic range of natural variability. ▪ Restore natural disturbance regimes, such as fire, and use vegetation treatments to accomplish biodiversity. Sustain the integrity of the sagebrush biome in order to support viable populations of greater sage-grouse and other sagebrush obligate species. Objectives for achieving this goal include: ▪ Maintain large patches of high-quality sagebrush habitats, consistent with the natural range of variability for sagebrush communities in northwest Colorado. ▪ Maintain connections between sagebrush habitats on a landscape scale, as allowed by the range site condition. Identify and initiate restoration and rehabilitation of sagebrush habitat while maintaining a mosaic of canopy cover and seral stages. Objectives for achieving this goal include: ▪ Reconnect large patches of sagebrush habitat, consistent with the natural range of variability for sagebrush communities in northwest Colorado. ▪ Reduce the encroachment of juniper and other large woody species into the sagebrush habitat. ▪ Restore a diversity of seral stages within sagebrush communities. ▪ Restore the quantity, species composition, and species diversity 13

of sagebrush understories.

Special Status Species – page RMP-22 Sustain the integrity of the sagebrush biome to maintain viable populations of greater sage- grouse and other sagebrush obligate species, consistent with local conservation plans. Objectives for achieving this goal include: ▪ Maintain large patches of high-quality sagebrush habitats consistent with the natural range of variability for sagebrush communities in northwest Colorado. ▪ Maintain connections between sagebrush habitats on a landscape scale. Identify and initiate restoration and rehabilitation of sagebrush habitat while maintaining a mosaic of canopy cover and seral stages. Objectives for achieving this goal include: ▪ Reconnect large patches of sagebrush habitat consistent with the natural range of variability for sagebrush communities in northwest Colorado. ▪ Reduce the encroachment of juniper and other large woody species onto sagebrush habitat.

Name of Plan: White River Record of Decision and Approved RMP, as amended Date Approved: 1997 Decision Language: Objective – maintain healthy, diverse and sustainable rangeland and woodland communities. Sustain a landscape composed of plant community mosaics that represent successional stages and distribution patterns that are consistent with natural disturbance and regeneration regimes, and compatible with the goals identified in Standard 3 of the Standards for Public Land Health.

Name of Plan: Grand Junction Record of Decision and Approved RMP Date Approved: 2015 Decision Language: VEG-GOAL-01: Restore and maintain healthy, productive plant communities of native and other desirable species at self-sustaining population levels commensurate with the species and habitats’ 14

potentials. Ensure plants and animals at both the community and population level are productive, resilient, diverse, vigorous, and able to reproduce and sustain natural fluctuations and ecological processes (based on Land Health Standard 3). Name of Plan: Northwest Colorado Greater Sage-grouse Approved RMP Amendment Date Approved: 2015 Decision Language: Objective VEG-1: (1) Use habitat restoration as a tool to create and/or maintain landscapes that benefit GRSG; (2) Use Integrated Vegetation Management to control, suppress, and eradicate, where possible, noxious and invasive species per BLM Handbook H- 1740-2; and (3) In PHMA, the desired condition is to maintain all lands ecologically capable of producing sagebrush (but no less than 70 percent) with a minimum of 15 percent sagebrush cover or as consistent with specific ecological site conditions. The attributes necessary to sustain these habitats are described in Interpreting Indicators of Rangeland Health (BLM Technical Reference 1734- 6) (BLM 2005).

Objective FIRE-2: Manage the fuels program to avoid GRSG habitat loss and restore damaged habitat.

1.6 Relationship to Laws, Regulations and Other Plans Federal Land Policy and Management Act of 1976 (FLPMA)

FLPMA requires that an action under consideration be in conformance with the applicable BLM land use plans, and be consistent with other federal, state, and local laws and policies to the maximum extent possible. The Proposed Action is in consistent with the FLPMA.

Colorado Parks and Wildlife Colorado West Slope Mule Deer Strategy, November 2014

The plan identifies landscape-scale habitat management to improve habitat quality as a strategic priority. Components of implementation include: use of mechanical treatments (e.g., hydro axe, roller-chop) and prescribed fire (when feasible) to manage habitat for mule deer, and enhance coordination and partnerships with public and private land managers to improve landscape management for deer and to secure additional funding for habitat enhancement. The Proposed Action is consistent with the goals and objectives in the Mule Deer Strategy.

Greater Sage-Grouse Conservation Objectives: Final Report

This report, written by the U.S. Fish and Wildlife Service, is the result of a collaborative approach to develop range-wide conservation objectives for the greater sage-grouse. The peer- reviewed final report compiled by the U.S. Fish and Wildlife Service delineates objectives, based on the best scientific and commercial data available at the time of its release, for the conservation and survival of the greater sage-grouse. This report would aid the BLM in planning treatments to address threats to greater sage-grouse in the project area.

Upper Colorado River and Northwest Colorado Fire Management Units Fire Management Plans

The BLM is currently in the process of completing comprehensive fire management plans for the two fire units that overlap the project are: Upper Colorado River Valley and Northwest Colorado. These fire management plans provide direction for how fire management strategies and tactics will protect values and provide tools to meet resource goals and objectives on public lands. The Proposed Action is consistent with the direction in each of these fire management plans.

Vegetation Treatments on BLM lands in 17 Western States Programmatic Environmental Report (PER)

This document describes the environmental impacts of using non-herbicide vegetation treatment methods on public lands, including prescribed fire treatments, manual treatments, mechanical treatments and biological treatments. The Proposed Action is consistent with this PER.

2. PUBLIC INVOLVEMENT 2.1. Scoping Public scoping is an opportunity to introduce and explain the interdisciplinary approach and solicit information on issues and concerns. The principal goals of scoping are to allow public participation to identify issues, concerns, and potential impacts that require detailed analysis.

Internal Scoping Summary: The Proposed Action was introduced to a Northwest District core interdisciplinary team at a face-to-face meeting on November 3, 2016. Staff members representing most programs that are analyzed in this document were present. Issues identified during internal scoping included: impacts to cultural resources, impacts to wildlife (including special status species and aquatic wildlife), impacts to mature pinyon juniper woodlands, and impacts to wild horses.

External Scoping Summary: The Proposed Action for this EA was posted on the project’s 16

ePlanning website for a public scoping period from December 21, 2016 to January 19, 2017: http://bit.ly/2qTB7Yy

In addition, a press release was issued on December 21, 2016 notifying the public that the BLM was accepting public scoping comments on the proposed project.

The BLM received 10 comments on the Proposed Action during the public scoping period from the following individuals/groups/governments:

▪ Chad Kurtenbach ▪ Colorado Parks and Wildlife ▪ Focused on the Forest, LLC ▪ High Lonesome Ranch, Mule Deer Foundation, Theodore Roosevelt Conservation Partnership, and North American Grouse Partnership ▪ Moffat County ▪ Western Energy Alliance ▪ Western Watersheds Project ▪ White River and Douglas Creek Conservation Districts ▪ WildLands Defense ▪ Wilderness Society and Conservation Colorado

External Issues Identified: For the purpose of BLM’s NEPA analysis, an “issue” is a point of disagreement, debate, or dispute with a Proposed Action based on some anticipated environmental effect.

Issues identified during external scoping included, but were not limited to:

NEPA Analysis

. How would the BLM reach a Finding of No Significant Impact (FONSI) with this EA?

. How do the alternatives meet the Purpose and Need?

. Should the BLM include an alternative that would allow pinyon-juniper reduction treatments using only hand cutting with chainsaws, with all materials left onsite to decompose naturally to protect the soils?

. How would the BLM address the issue of climate change in the analysis?

Baseline Information/Prioritization of Treatments

. How would the BLM use the Assessment, Inventory and Monitoring Protocol (AIM) and the 17

Habitat Assessment Framework (HAF) when prioritizing treatment projects?

. Would the BLM adopt objective habitat recovery standards for GRSG habitat?

. How would the BLM identify areas of encroaching pinyon-juniper for treatment?

. How would the BLM utilize the vegetation guidelines in the 2008 Colorado GRSG Plan?

. How would the BLM consider fluid mineral lease status when planning projects?

. How would the BLM plan the treatments?

Lands with Wilderness Characteristics

▪ How would the Proposed Action impact lands with wilderness characteristics?

▪ What types of treatments would be allowed in areas that are managed for wilderness characteristics or areas that have been found to have wilderness characteristics?

Wildlife

▪ How would the Proposed Action impact wildlife that inhabits pinyon juniper woodlands?

▪ How would the Proposed Action affect big game?

▪ How would the Proposed Action ensure that treatments benefit sagebrush communities?

▪ How would the BLM coordinate with CPW on treatments to benefit big game?

Greater Sage-grouse

▪ How would the BLM ensure that other species outside of greater sage-grouse benefit from the Proposed Action?

▪ How would the Proposed Action address impacts from livestock grazing on GRSG habitat?

▪ How would the BLM coordinate with CPW on treatments in GRSG habitat?

Livestock Grazing

. How would the BLM coordinate with livestock grazing permitees on treatments?

. How would the BLM ensure that project areas are rested for adequate periods before 18

allowing cattle to graze on them?

Prescribed Fire

. How would the BLM manage prescribed fires to benefit the resources?

. How would the BLM help ensure that prescribed fires do not introduce non-native species?

2.2. Public Comment The Preliminary EA and the unsigned Finding of No Significant Impact (FONSI) were available for a 30-day public review and comment period between June 8th and July 9th, 2017 on the project ePlanning website: http://bit.ly/2qTB7Yy

The BLM received five comments on the Preliminary EA. The interdisciplinary team considered all of the substantive comments and addressed those within the scope of the analysis. Public comments were received from the following individuals and groups during the public comment period:

. Craig Downer . Gus Connelly, Mountain Pine Manufacturing . Nancie McCormish . White River and Douglas Creek Conservation Districts . The Wilderness Society, Audubon Rockies and Conservation Colorado

Substantive comments and their associated responses can be found in Attachment G.

3. PROPOSED ACTION AND ALTERNATIVES

This chapter describes and compares the Proposed Action and No Action Alternative, and alternatives considered but dismissed from detailed analysis.

The Proposed Action seeks to analyze vegetation treatments and installation of erosion control structures using various methods on a Northwest District-wide level (plus the Grand Junction Field Office) versus not completing these types of projects under the no action alternative.

If the no action alternative were selected, vegetation treatment activities would not occur in the project area. No change from current management would occur.

3.1. Proposed Action

Background Information for the Proposed Action The project area has been designed to encompass the vegetation types that would support sagebrush obligate species, as well as habitat types that might be encroaching onto habitat for those species, for example Pinyon-Juniper Woodlands, and to include all of the projects identified in the BLM’s 2016 and 2017 POW. The project area encompasses approximately 3.4 million acres of BLM-managed surface lands in the Grand Junction, Colorado River Valley, Little Snake, Kremmling and White River Field Offices.

Table 3.1 depicts how many acres of BLM-managed lands in the project area occur in each county:

Table 3.1 - Project Area Acres by County

Acres of BLM-managed County lands Eagle 197,200 Garfield 336,400 Grand 90,500 Jackson 158,300 Larimer 19,300 Mesa 190,900 Moffat 1,418,700 Pitkin 10,900 Rio Blanco 942,100 Routt 40,800 Summit 900 TOTAL 3,406,000 Source: BLM GIS 2017

The primary goal of the Proposed Action would be to complete projects in the most resistant and resilient locations, using the most appropriate methods. Consultation with CPW would be critical to designing projects that would benefit not only GRSG, but big game species and other sagebrush obligate species as well.

The Proposed Action would aim to improve ecosystem health by improving the quantity and quality of sagebrush habitat and increasing understory vegetation to benefit sagebrush obligate species. The Proposed Action would also aim to expand on previously implemented habitat treatments and make progress toward meeting the larger landscape-level goal of expanding sagebrush habitats, where appropriate, in Colorado.

To determine project location and treatment type the BLM would utilize the Sagebrush Management Resilience and Resistance Tool (SMRRT) decision support tool (Chambers et al. 2016). This tool utilizes the concepts of resilience and resistance for sagebrush ecosystems (based on soil temperature and moisture content) to come up with a matrix (Table 4, Chambers

et al. 2016). This matrix can be used to identify appropriate management strategies (Table 5, Chambers et al. 2016) for a wide range of persistent sagebrush ecosystem threats including non- native invasive species, conifer encroachment, wildfire, energy development, and climate change. This analysis would only address those persistent ecosystem threats.

The resistant and resilient concepts would assist land managers in identifying areas where the BLM should apply vegetation treatment projects across the landscape. Once potential project areas are identified then specific treatment types can be identified and employed at these smaller scales to improve ecosystem integrity and habitat connectivity for focal species such as greater sage-grouse and Brewer’s sparrow. This decision support tool would be used to identify those areas where high quality sagebrush communities (healthy sagebrush, high diversity grass/forb component, and relatively weed free) exist and where vegetation treatments generally should be avoided to prevent ecosystem degradation. Identifying these avoidance areas may be more important than those areas where treatments are proposed.

To use this decision support tool the BLM would answer the following questions:

. Where the areas of sagebrush are located?

Use best available data and on-the-ground monitoring to determine where sagebrush is located in NW Colorado.

. Where the most resistant and resilient areas of sagebrush are located?

Evaluate soil temperature and soil moisture regimes to determine areas of high, moderate and low resistant and resilient areas.

. What is the landscape scale breeding habitat probability for greater sage-grouse and other sagebrush obligate species?

. How does resistance and resilience vary across the sagebrush in NW Colorado?

Evaluate resistance and resilience across NW Colorado in the sagebrush biome to determine whether sagebrush is equally distributed, or if it favors areas of high or moderate resistance and resilience.

. Where the areas of invasive species are?

Use best available data and on-the-ground monitoring to determine where invasive species, such as cheatgrass (Bromus tectorum) occur within sagebrush communities.

. Where the areas of Pinyon-Juniper encroachment are?

Use best available data and on-the-ground monitoring to determine areas where PJ is encroaching into sagebrush-dominated communities and where PJ is likely to expand into sagebrush-dominated communities in the future.

. Where anthropogenic development has occurred?

Calculate anthropogenic disturbance across sagebrush communities in NW Colorado using a variety of tools and data (excluding agriculture) to determine how intact the sagebrush communities are. Determine where development occurs in relation to sagebrush communities.

. What the fire risk in the area is?

Evaluate burn probability in sagebrush communities in NW Colorado.

. Estimate where PJ is likely to encroach into sagebrush habitat.

Use best available data to determine areas within sagebrush communities where PJ is likely to encroach due to low resilience and resistance.

. Estimate where sagebrush would be most likely to grow into the future.

Use best available data and on-the-ground monitoring to estimate where sagebrush would be most likely to grow in the future, based on soil moisture regimes and precipitation regimes.

. How climate change may affect any treatment.

Use best available data to determine how climate change may affect species recovery and expansion (such as PJ expansion and contraction).

This information would be used in conjunction with information from and consultation with partner agencies such as the US Forest Service and Colorado Parks and Wildlife to determine the best possible locations to implement vegetation treatments to benefit sagebrush obligate species.

When planning fuels management projects or other restoration projects using fire, there are several questions to be answered during a four-step process that would help determine if that type of treatment would be appropriate in the chosen location (See Attachment E for a description of the four-step process).

For projects in Greater Sage-grouse (GRSG) habitat, the BLM would use the methods described in the document Using Resilience and Resistance Concepts to Manage Threats to Sagebrush Ecosystems, Gunnison Sage-grouse and Greater Sage-grouse in Their Eastern Range: A 22

Strategic Multi-Scale Approach (Chambers et al. 2016).

Included in this document are several tools to determine appropriate treatments at a general scale. GIS data layers and tools for evaluating target areas for GRSG management include: Priority Areas for Conservation (PACs), Breeding habitat probabilities and population indices, resilience to disturbance and resistance to nonnative invasive annual grasses and habitat threats

Some projects in the POW would take place in areas that are mapped as ecological sites that would support sagebrush. Some projects are designed to take place in other vegetation types with the goal of expanding sagebrush habitat for sagebrush obligate species and to maintain or improve overall land health in these habitats.

It is important to note that treatments would not occur on all 3.4 million acres of BLM-managed lands in the project area. Individual treatments would take place within the boundaries of the project area, but would not cover the entire project area.

Table 3.2 depicts a year-by-year estimate of number of acres to be treated, and the types of projects that may be completed. Some projects could be reprioritized based on several factors, including: success of similar treatments in similar ecological sites, adaptive management report, application of criteria from Chambers et. al. 2016, weather patterns and funding sources. Pursuant to the Antideficiency Act, this estimate is based on funding and staffing levels and could change at any time.

Table 3.2 - Planned Vegetation Treatments Associated with the BLM’s Program of Work

Acres of Types of Projects Field Offices where Fiscal Year Treatments Planned Treatments are Planned Planned (Approx.) ▪ Pinyon Juniper ▪ CRVFO removal ▪ GJFO ▪ Invasive species 2017 16,700 ▪ KFO reduction ▪ LSFO ▪ Fuel breaks ▪ WRFO

▪ Pinyon Juniper Removal ▪ CRVFO ▪ Invasive Species ▪ GJFO Reduction 2018 18,200 ▪ KFO ▪ Fuel Breaks ▪ LSFO ▪ Riparian restoration ▪ WRFO and habitat protection

▪ Pinyon Juniper ▪ CRVFO 2019 21,300 Removal ▪ GJFO ▪ Invasive Species ▪ KFO 23

Reduction ▪ LSFO ▪ Fuel Breaks ▪ WRFO ▪ Riparian habitat protection

▪ Pinyon Juniper Removal ▪ CRVFO ▪ Invasive Species ▪ GJFO Reduction 2020 16,300 ▪ KFO ▪ Fuel Breaks ▪ LSFO ▪ Riparian habitat ▪ WRFO protection

▪ Pinyon Juniper Removal ▪ Invasive Species ▪ CRVFO Reduction ▪ GJFO 2021 16,800 ▪ Fuel Breaks ▪ LSFO ▪ Riparian habitat ▪ WRFO restoration and protection TOTAL Acres of Treatments Planned through 89,300 2021 (Approx.)

Source: BLM 2017

Assessment, Inventory and Monitoring (AIM) Protocol and the Habitat Assessment Framework (HAF)

Recently, the BLM has moved toward more integrated data collection to allow for improved management and accessibility. The Assessment, Inventory and Monitoring (AIM) protocol was developed to meet these needs. The Habitat Assessment Framework (HAF) was developed as a temporal and spatial method for evaluating suitability of greater sage-grouse habitat in sagebrush habitats

To effectively manage renewable resources, the BLM needs information at multiple scales about resource extent, condition and trend, stressors, and the location and nature of authorized uses, disturbances, and projects (Toevs et al. 2011). To address this need, the BLM developed the Assessment, Inventory, and Monitoring (AIM) Strategy (Toevs et al. 2011) by working with multiple partners to create a program with consistent monitoring methods across ecosystems, statistically valid sampling designs, and data management protocols. The BLM currently is working with the USGS on developing a streamlined process to monitor vegetation treatments

using tools they have developed. This tool, called the Disturbance automated reference toolset (DART), could be applied to each treatment to determine success for vegetation treatments. The DART toolset monitors land surface impacts using soil type and ecological context (Nauman et al. 2017). DART would identify reference locations based on similar soils, topography, and geology and would compare the disturbance condition to a reference area condition based on a satellite vegetation index to determine the overall success of the treatment.

The BLM would utilize the AIM Strategy throughout the project area to determine resource condition and trends of vegetation communities, soils, and ecological site potential of each plot. Vegetation and soil data collected using the AIM Core Methods (MacKinnon et al. 2011) provide habitat indicator values necessary to complete the Sage-Grouse Habitat Assessment Framework (HAF) (Stiver et al. 2015). The Western Association of Fish and Wildlife Agencies (WAFWA) published the HAF to create a unified method between states to evaluate suitability of sage-grouse habitat at various landscape scales.

The HAF deliberately incorporated the AIM Core Methods into the assessment framework to provide consistent collection of unbiased data across all sage-grouse habitat. AIM also allows for supplemental indicators to be collected when sampling in sagebrush vegetation types. Completing the HAF in a project area prior to any treatment would provide estimates on the amount and extent of suitable, marginal, and unsuitable sage-grouse habitat.

The AIM Strategy and the HAF would be used to help identify and monitor treatment areas where this data is available. Whenever possible, pretreatment and post-treatment effectiveness monitoring should use the AIM Core Methods and the appropriate supplemental methods, and complete a site-scale HAF. AIM data can also help inform the current community phase of ecological types in the state-and-transition models identified in Chambers et al. 2016 and appropriate actions to achieve greater resistance and resilience in sagebrush systems.

Methodology and Design Features of the Proposed Action The BLM is proposing to complete vegetation treatments by a variety of methods, as described in detail below.

Design Features Common to All Vegetation Treatment Tools and Methods:

Special Status Plant Species

1. The appropriate field office ecologist would be consulted the growing season prior to any treatments to determine if special status plant species (SSPS) surveys would be required. If surveys are required they must be completed according to the SSPS protocol prior to the beginning of any treatment. If listed, proposed, or candidate plants are found during the surveys, those areas would be avoided.

2. Occupied habitat for threatened, endangered, proposed, and candidate species would be 25

avoided. Surface disturbing activities would also be avoided within 200 meters of occupied plant habitat where geography and other resource concerns allow.

3. Hand thinning projects in listed plant habitat would not be allowed within 200 meters of occupied habitat.

Soils

4. When using mechanical fuels reduction treatments, limit tractor and heavy equipment use to periods of low soil moisture or when the ground is frozen/under snow to reduce the risk of soil compaction and disturbance. If this is not practical, evaluate sites following treatment and if necessary, implement appropriate remediation as part of the operation.

5. When saturated soils conditions existing on access roads or location, or when road rutting becomes deeper than 3 inches, construction shall be halted until soil material dries out or is frozen sufficiently for construction to proceed without undue damage and erosion to soils, roads and locations.

6. Surface disturbing actions would be minimized in areas near the Colorado River Corridor in areas of saline soils.

Water Resources

7. Fueling and maintenance activities would not be conducted within 100 feet of any drainage or watercourse. All spills of fuel and lubricants would be reported to the BLM and should be cleaned up promptly. Fueling of machinery and storage of fuel would be accomplished through established BLM procedures.

Wildlife

8. All treatments would be coordinated with CPW in order to prioritize, decide best methods, share data regarding big game and GRSG populations and use patterns, and to help meet the objectives in the CPW Mule Deer Strategy (CPW 2014).

9. Coordinate with CPW to determine the best timing and operation procedures to limit any possible impacts to big game winter range.

10. A raptor survey may be required if project area habitat is capable of supporting nesting functions may potentially be involved. Should an active nest be located the appropriate timing limitations (species dependent) may be applied:

Listed, proposed, and candidate threatened or endangered species and BLM sensitive species (not including bald eagle or ferruginous hawk): No activities would be allowed 26

from February 1 – August 15 within 0.50 miles of an identified nest.

All other raptor species: No activities would be allowed from February 1 – August 15 within 0.25 mile of an identified nest.

11. Vegetation treatments would not occur between May 15 and July 15 to protect nesting migratory birds. An exception may be granted if it is determined that the treatment can be conditioned so as not to interfere with habitat function or compromise migratory bird nesting functions.

12. Those sites classified as pinyon-juniper, currently in Phase II or III stage with an ecological site potential indicating a pinyon juniper site would be avoided.

13. For projects in all GRSG habitat: Use vegetation guidelines in Colorado Greater Sage-grouse Conservation Plan (CPW 2008) as one tool to evaluate canopy cover, density and height in GRSG habitat.

o a risk assessment to address how potential threats to GRSG habitat would be minimized o why alternative techniques were not selected as viable options o how GRSG goals and objectives would be met by its use o how the COT report objectives would be addressed and met

14. For projects in all GRSG habitat: Vegetation treatments would not occur within 4 miles from active leks or in known nesting or early brood-rearing habitats between March 1 and July 15 to protect lekking, nesting and early brood-rearing.

15. For treatments in greater sage-grouse PHMAs and GHMAs where fuels reduction is a priority, up to 50% of the sagebrush may be mowed or masticated, providing this would still meet sage-grouse habitat objectives found in Table 2-2 of the Greater Sage-grouse Approved LUPA. The amount of sagebrush treatment allowed on any one project would be determined in consultation with the Field Office wildlife biologist and CPW.

16. Vegetation treatments would not occur from April 15 to June 30 in mapped big game production areas in order to reduce behavioral disruption during parturition and the early young rearing period.

17. Vegetation treatments would not occur from December 1 to April 30 in mapped big game crucial winter habitat in order to reduce behavioral disruption during the winter season, unless consultation with CPW warrants an exception.

18. Surveys for midget faded rattlesnakes would be required if suitable habitat exists within the treatment area. If occupied den/hibernacula are located, activity (vegetation removal, 27

heavy equipment use) would not be permitted within 200 meters of the den from April 15 – August 1.

19. Any known roosts or hibernaculum for bat species would be avoided.

20. Treatments would not occur in any listed species designated critical habitat.

Vegetation/Weeds/Range

21. Unless other agreements have been documented, any treatment requiring rest or exclusion from livestock grazing shall require at least one year notice for the livestock operator to make alternative arrangements or adjustments for when their allotment(s) is closed to grazing.

22. Mechanical treatments that have little ground disturbance may not require grazing rest. These treatments would be evaluated on a case-by-case basis.

23. Temporary electric fencing could be constructed to prevent livestock use in treatment areas where applicable.

24. All machinery used within the project boundary would be cleaned prior to working within the project, to help reduce the spread of noxious weeds.

25. Range improvement projects within each given project area would be identified and measures taken to prevent damage or to replace the improvement in order to maintain its purpose and function.

26. Coordination with grazing permittees would occur prior to any treatment.

27. Vegetation treatments would be monitored for noxious weed infestation for a minimum of 3 years post-treatment. Any infestations identified would be eradicated by the BLM as needed.

28. Power wash all vehicles and equipment involved in fuels management activities prior to entering the area to minimize the introduction of undesirable and/or invasive plant species.

29. Restore annual grasslands to a species composition characterized by perennial grasses, forbs and shrubs.

30. Emphasize the use of native plant species recognizing that non-native species may be necessary depending on the availability of native seed and prevailing site conditions.

31. The BLM would not conduct vegetation treatments in years where the Palmer Drought 28

Severity Index for the area is rated severe or extreme.

Recreation

32. Project implementation during big game rifle seasons would be coordinated with CPW.

Wild Horses

33. During the spring foaling period (March 1 – June 30), if it is determined that wild horses are in the vicinity of the treatment, activities would be delayed or modified.

34. To minimize the incidents of young foals becoming dislocated from their mares, project crews would be required to slow or stop when wild horses are encountered, allowing bands to move away at a pace slow enough so that the foals can keep pace and are not separated.

35. Should the project occur simultaneous with a wild horse gather, all project-related activities would be coordinated through the field office and the gather contractor.

Cultural/Heritage Resources

36. Once an area has been identified for a vegetation treatment, an appropriate level of cultural resources assessment and/or inventory would be determined and completed prior to project implementation. Consultations with the State Historic Preservation Officer (SHPO), Native American tribes, or other affected/interested parties also may be required.

37. Work performed off roads and routes with heavy equipment may only occur when the ground is dry or frozen in order to reduce the risk of damage to surface or shallowly buried artifacts.

38. Consultation efforts with Native American tribes would continue through project implementation. Inventories in project areas would attempt to locate any sites that the tribes have identified as sensitive, and efforts would be made to protect those values.

39. For any action or treatment, the Standard Discovery Stipulations apply:

o Any cultural and/or paleontological (fossil) resource (historic or prehistoric site or object) discovered by the BLM, or any person working on its behalf, on public or Federal land shall be immediately reported to the authorized officer. The BLM shall suspend all operations in the immediate area of such discovery until written authorization to proceed is issued by the authorized officer. An evaluation of the discovery would be made by the authorized officer to determine appropriate actions to prevent the loss of significant cultural or scientific values. The BLM would be responsible for the cost of evaluation and the authorized officer would make any 29

decision as to proper mitigation measures after consulting with the appropriate BLM archaeologist.

o The BLM would be responsible for informing all persons who are associated with any treatment that they would be subject to prosecution for knowingly disturbing historic or archaeological sites, or for collecting artifacts. If historic or archaeological materials are encountered or uncovered during any project activities, the BLM would immediately stop activities in the immediate vicinity of the find and immediately contact the authorized officer (AO) of the appropriate Field Office. Within five working days, the AO would inform the BLM project lead as to whether the materials appear eligible for the National Register of Historic Places.

The mitigation measures the operator would likely have to undertake before the identified area can be used for project activities again; and

Pursuant to 43 CFR 10.4(g) (Federal Register Notice, Monday, December 4, 1995, Vol. 60, No. 232) the holder of this authorization must notify the AO, by telephone, and with written confirmation, immediately upon the discovery of human remains, funerary items, sacred objects, or objects of cultural patrimony.

Further, pursuant to 43 CFR 10.4(c) and (d), you must stop activities in the vicinity of the discovery and protect it for 30 days or until notified to proceed by the authorized officer.

Paleontological Resources

40. Areas that contain geologic formations that are PFYC 3, 4, and 5, for which new surface disturbance is proposed on or adjacent to bedrock (native sedimentary stone), including disturbance that may penetrate protective soil cover and disturb bedrock, may be subject to an inventory that shall be performed by a BLM permitted paleontologist and approved by the appropriate field office specialist. Surface disturbing activities in many areas including PFYC 4 and 5 may also require monitoring by a permitted paleontologist. The risks of damage or degradation by human-caused impacts could be lowered if the area of the treatment is covered by extensive soil and vegetative cover. It should be noted that even in areas with a PFYC of 1 or 2 mapped as Quaternary deposits there is the possibility for the presence of isolated Pleistocene fossils and these, like archaeological sites, may be close to the surface. Depending on previous information on the presence of Pleistocene fossils in the area a preliminary ground survey prior to treatment may be warranted.

41. Any paleontological resource discovered during treatments shall be immediately reported to the BLM Authorized Officer of the appropriate field office. Operations shall be suspended in the immediate area of such discovery until authorization to proceed is issued 30

by the Authorized Officer of the appropriate field office and the discovery shall be protected from damage or looting. Activities may not be required to be suspended if activities can be adjusted to avoid further impact to a discovered locality or be continued elsewhere. The Authorized Officer of the appropriate field office would evaluate or would have evaluated, such discoveries as soon as possible, but not later than 10 working days after being notified. Appropriate measures to mitigate adverse effects to significant paleontological resources would be determined by the Authorized Officer of the appropriate field office after consulting with the BLM project manager. Within 10 days, the BLM project manager would be allowed to continue vegetation treatment operations through the site, or would be given the choice of either (1) following the Authorized Officer’s instructions for stabilizing the fossil resource in place and avoiding further disturbance to the fossil resource, or (2) following the Authorized Officer’s instructions for mitigating impacts to the fossil resource prior to continuing vegetation treatment through the project area. An evaluation of the discovery would be made by the Authorized Officer to determine appropriate actions to prevent the loss of significant paleontological or scientific values. If excavation is warranted to remove the fossil work may continue in other areas if it can be done safely.

42. In anticipation of an inadvertent discovery of fossils which may need to be collected, a repository to house the fossils should be identified in advance of the project, an agreement with the repository to accept the specimens should be in place, and contingency funds to cover the costs for preparation and curation should be set aside, if possible.

Lands with Wilderness Characteristics

43. All project activities that could affect lands inventoried and found to contain wilderness characteristics and lands managed for the protection of wilderness characteristics would minimize surface disturbing activities such that the natural quality of the area is maintained. Ground disturbing mechanical treatments, such as the use of motorized equipment, would be allowed if the project enhances the wilderness characteristics of the area.

Realty Authorizations

44. Projects would only involve private land where the landowner is a willing participant and an agreement has been signed.

45. Projects would be designed to avoid or otherwise ensure the protection of authorized rights-of-way and other facilities located on the public lands, including coordination with holders of major rights-of-way and communication sites.

46. The actions of any fire management practice shall not destroy, deface, change, or remove to another place any monument or witness tree of the Public Land Survey System (PLSS). 31

Prior to commencing any ground or vegetation disturbing activities, evidence of the PLSS would be marked for protection. Cadastral Survey staff shall be consulted to assist with providing data, searching for and evaluating evidence, and locating and protecting monuments of the PLSS from destruction.

Visual Resources

47. All treatment projects would include mitigation measures applied as needed to mitigate impacts to visual resources.

48. Edges of mechanical treatments would be designed to repeat natural lines of similar vegetation contrast and to avoid creating straight lines on the edge of the treatments. These measures should be taken in Visual Resource Management (VRM) Class III areas and must be taken in VRM Class I and Class II areas.

49. The edges of the treatment boundary would be feathered in VRM Class I and Class II mechanical treatment areas with dense vegetation. This means that the vegetation would be thinned from the edge of the treatment in a less dense to more dense thinning gradient that mimics natural vegetation patterns in the treated area.

Fluid Mineral Resources

50. Fluid mineral lease status would be considered when planning treatments.

51. Coordination with fluid mineral leaseholders, if applicable, would occur prior to any treatment.

Travel Management

52. No new roads would be created as a result of any treatment and all projects would be in compliance with all existing travel management plans.

Monitoring

53. Project areas would be monitored prior to any treatment.

54. Project areas would be monitored by the BLM for three to five years after the project is completed. Projects would be monitored to: (1) determine if project objectives were met, (2) establish the need for additional treatments, and (3) document monitoring results for future projects. Methods used to monitor the treated area may include field observation, photographic plots, cover transects utilizing point-intercept and density plot methods.

Mechanical Vegetation Treatments Mechanical vegetation treatments may be implemented using the following tools/methods (see the Glossary for definitions):

▪ Mastication equipment ▪ Mower ▪ Brush Beater ▪ Dixie Harrow ▪ Railing ▪ Chaining ▪ Chipper ▪ Bull hog ▪ Cut and Pile ▪ Lop and Scatter ▪ Chainsaw ▪ Road ripping ▪ Hand tools (loppers and hand saws)

Through mechanical fuels reduction in specific target areas (individual treatment sites), the BLM would:

▪ Identify sites where pinyon-juniper is encroaching into sagebrush habitat. ▪ Remove up to 90 percent of pinyon-juniper invading sagebrush ecosystem types while limiting sagebrush mortality in those treatment areas to less than 50 percent. ▪ Limit mortality in mature pinyon-juniper woodlands to less than 30 percent.

Hand Thinning Methods This type of treatment would typically occur primarily in Phase I encroachments areas that are mapped as sagebrush vegetation types. Chainsaws would be used to limb or remove undesirable trees and branches and the slash would be placed in piles and burned later in the fall or winter or simply lopped and scattered. Piles would not be placed on known cultural sites, or rare plant occurrences.

Tree Mastication Methods This is typically done with a large tractor (similar to a skidder) with a 6 foot to 8 foot hydraulically powered mowing or mulching head attached to the front (See Attachment B). Tracked units with a similar masticating head may also be used on smaller sized projects or trees as they are typically smaller machines. These machines are capable of shredding trees up to 12 inches in diameter and 15 feet tall as well as mowing brush like a conventional brush beater. Whole trees would be reduced to small branches and pieces of wood from pencil size up to bowling ball size (See Attachment B). The mulch is scattered across the surface but would be deeper in the immediate vicinity of the tree.

Brush Mowing Methods This technique involves a heavy duty mower pulled behind a tractor (See Attachment B for a photo). It is typically used in flat to gently rolling sagebrush areas. Brush would be mowed to a height of 3 to 4 inches (See Attachment B). Perennial herbaceous vegetation is also mowed during this process but all vegetation is likely not killed and some perennial plants may recover from damage. Treatments would typically be done in a mosaic fashion leaving 30 to 60 percent of the target area untreated.

Design Features for Mechanical Vegetation Treatments All mechanical vegetation treatments would utilize the following design features:

1. No wheeled equipment would be used on slopes greater than 30 percent. Chainsaws would be used on slopes greater than 30 percent.

2. Vegetation removed with chain saws would be either: Lopped and scattered to a depth of no greater than 18 inches; Piled and burned following agency policy; Chipped and dispersed; Provided along roadsides for public firewood use if applicable.

3. Edges of the mechanical treatments would be designed to repeat natural lines of similar vegetation contrast and avoid creating straight lines on the edge of the treatments. These measures should be taken in Visual Resource Management (VRM) Class III areas and must be taken in VRM Class I and II areas.

4. All water sources would be buffered from treatment by a minimum of 100 feet from the edge of any wetland vegetation, unless the field office RMP specifies that a different buffer be used.

5. Fueling and maintenance activities would not be conducted within 100 feet of any drainage or watercourse. All spills of fuel and lubricants would be reported to the BLM and should be cleaned up promptly. Fueling of machinery and storage of fuel would be accomplished through established BLM procedures.

6. All road, telephone, and power line rights-of-way and facilities would be located to ensure protection prior to commencement of the project to assure that no damage would occur.

7. Survey monuments would be located and flagged (brass cap monuments, bearing trees, private monuments) for protection in the project area.

8. Areas to be avoided by equipment to protect other resource values would be flagged prior to project implementation.

Prescribed Fire Treatments Prescribed fire vegetation treatments would be implemented using the following tools/methods:

Types: ▪ Broadcast ▪ Slash Pile Burns

Methods: ▪ Ground Ignition ▪ Aerial Ignition

Tools: ▪ Fuses ▪ Drip Torches ▪ Flares ▪ Stubbies ▪ UTV torches ▪ Terra torches ▪ Plastic sphere dispenser (PSD) ▪ Helitorch

Through prescribed fire and fuels reduction projects in specific areas (individual treatment sites) the BLM would:

. Remove up to 90 percent of pinyon-juniper encroaching into sagebrush ecosystem types.

. Remove 60 to 100 percent of basin big sagebrush which dominates ephemeral drainages (with a tolerable deviation of 10 percent due to the unpredictability of using fire).

Prescribed fire would be implemented in areas where the native vegetation response to fire has proven to be positive. This includes sagebrush, mountain shrub, and open encroaching pinyon/juniper stands with sagebrush intermixed. The primary factor to a positive response is an adequate understory of perennial herbaceous vegetation. Pinyon/juniper stands or other areas lacking sufficient perennial herbaceous vegetation would not be targeted unless seeding after burning could be done. Areas targeted for prescribed burning typically utilize roads and natural barriers to the extent possible in order to reduce preparation costs, escape potential, and ground disturbance caused by fire line construction.

Prescribed burn season typically occurs in the spring and fall.

Ignition may be done with ground based equipment including drip torches, fuses, or truck mounted terra-torch; or aerial firing equipment including the plastic sphere dispenser or helitorch.

Pile burning following mechanized tree and brush cutting, thinning, and limbing would be an alternative burning method considered under the umbrella of prescribed burning. Woody material such as limbs, stems, cut boles and other slash greater than two feet in length would be placed in piles up to 12 inches in diameter and 8 feet tall. Piles would be burned after the material has had time to cure in order to promote complete combustion and reduce smoldering. Burning typically occurs during the late fall, winter, or early spring when there is snow on the ground to prevent fire spread away from the piles.

Prescribed burning must be and would be carried out in accordance with the Interagency Prescribed Fire Planning and Implementation Procedures Guide (National Wildfire Coordinating Group, 2014). This guide requires that a prescribed burn plan be completed that describes how and under what conditions prescribed burning would occur in order to meet stated resource and fire management goals and objectives. Prescribed fire projects would also be conducted in accordance with the State of Colorado Smoke Management Plan and MOU, and would be regulated under Colorado Department of Public Health and Environment, Air Pollution Control Division. The Air Pollution Control Division would issue an open burning permit, which specifies smoke dispersal conditions and other stipulations under which burning may occur.

Design Features for Prescribed Fire Treatments All prescribed fire vegetation treatments would utilize the following design features:

1. Existing roads and trails would be used by agency personnel to eliminate development of new routes and trails. When driving off roads, personnel would avoid repeatedly driving back and forth via the same route.

2. All burn units inside of the project area would be created to match existing vegetation openings in the surrounding environment.

3. Areas within riparian zones that have been completely burned with an intense fire would be reseeded to achieve vegetation objectives.

4. Prescribed fires would be conducted by qualified personnel and with a pre-approved prescribed fire plan.

5. Prescribed fires would be monitored to ensure that objectives are achieved and the fire would not exceed the prescription.

6. All prescribed fire would be conducted in accordance with the State of Colorado Smoke Management Plan and Memorandum of Understanding (MOU), and would be regulated under 36

Colorado Department of Public Health and Environment, Air Pollution Control Division.

7. To protect soil productivity, burning would be conducted under conditions when a light burn can accomplish stated objectives. Burning would occur when soil and duff are moist for fragile soils and soils with landslide potential in the effort to maximize moisture retention in duff layers.

8. The BLM would not burn piles of slash within 100 feet of riparian areas or springs. If riparian areas are within or adjacent to the prescribed burn unit, piles would be scattered prior to burning.

9. When preparing the unit for burning, the BLM would avoid piling concentrations of large logs and stumps; pile small material (3 to 8 inches in diameter). Piles would be burned when soil and duff moisture are high.

10. The location and construction of containment lines would implement methods that result in minimal surface disturbance while effectively controlling the fire. Hand crews shall locate lines to take full advantage of existing land features that represent natural fire barriers. Whenever possible, containment lines should follow the contour of the slope to protect the soil, provide sufficient residual vegetation to capture and retain sediment, and maintain site productivity.

11. Surface disturbances created for containment lines would be rehabilitated by building water bars on slopes greater than 35 percent, replacing topsoil and spreading woody debris as possible. Water bars would be located to minimize future channeling of runoff and direct the runoff toward areas of natural vegetative filters.

Additional Design Features for Prescribed Fire Treatments in all designated Greater Sage- grouse habitat All prescribed fire vegetation treatments in GRSG habitat would utilize the following design features:

12. Where applicable, design fuels treatment objectives to protect existing sagebrush ecosystems, modify fire behavior, restore native plants and create landscape patterns to address other values-at-risk.

13. Use fire prescriptions that minimize undesirable effects on vegetation or soils (e.g., minimize mortality of desirable perennial plant species and reduce risk of hydrophobicity).

14. Ensure sagebrush treatments are planned with interdisciplinary input from BLM staff and CPW biologists and that treatment acreage is conservative in the context of surrounding GRSG seasonal habitats and landscape.

15. Where appropriate, ensure that treatments are configured in a manner that promotes use by

GRSG (Connelly et. al. 2000).

16. Where applicable, incorporate roads and natural fuel breaks into fuel break design.

17. Design vegetation treatment in areas of high fire frequency to facilitate firefighter safety, reduce the risk of extreme fire behavior, reduce the potential of acres burned, and to reduce the fire risk to key GRSG habitats. Additionally, develop maps for GRSG habitat that spatially display current fuels treatment opportunities for suppression resources.

18. Give priority for implementing specific GRSG habitat restoration projects in annual grasslands first to sites which are adjacent to or surrounded by GRSG key habitats. Annual grasslands are second priority for restoration when the sites are not adjacent to key habitat, but within 2 miles of key habitat. The third priority for annual grasslands habitat restoration projects are sites beyond 2 miles of key habitat. The intent is to focus restoration outward from existing, intact habitat. ______

Plant Material Treatments Plant material treatments would be implemented using the following tools/methods:

▪ Aerial seed application ▪ Drill seeding ▪ ATVs and/or UTVs ▪ Hand application ▪ Hand planting shrubs, plugs, poles, and other vegetation types (upland and riparian)

Whenever considering the use of plant materials (i.e., seeds, plants, and other propagules) for restoration/reclamation purposes the BLM would first determine the availability of what materials are the most appropriate and their source. The first consideration would determine if locally adapted native species or cultivars of native species are available. Over the past several years, the BLM has been actively collecting native plant materials (primarily seed) for restoration purposes. Partnerships with USDA plant material centers, such as the Upper Colorado Environmental Plant Center have grown out these materials to produce bulk amounts of plant materials. Non-invasive, non-native species could also be used, but only after considering the availability of native species and the risk of spread into adjacent plant communities.

Through applying plant material treatments in the specific target area, the BLM would aim to return the landscape to, or maintain, its desired ecological condition. Seeding of wildland fires and prescribed fires can help reduce fuel loads by re-establishing native plant species vs. invasive (e.g., cheatgrass).

Seeding would typically be done in burned areas that had little native herbaceous plant cover. Native species that are endemic to the area would be utilized if possible. Non-native species would only be used if native species are unavailable or would not be able to achieve the desired ecosystem maintenance or restoration goal, and in conformance with each land use plan decision. Seeding rates would vary by species and application method but would typically about 8 – 12 lbs. pure live seed (pls) per acre. All seed must be certified noxious weed free for the 11 western states in order to be used on BLM land.

Design Features for Plant Material Treatments All plant material treatments would utilize the following design features:

1. Analyze and determine the correct seed mixture based upon the surrounding vegetation and ecological condition. Apply appropriate standard or modified BLM seed mix based on the range site and or Desired Plant Community (DPC) for the treatment area (e.g., in a rolling loam site, BLM standard seed mix 2 would be used) to meet specified management objectives (e.g., special status plants) and in conformance with the appropriate field office RMP.

2. In all designated GRSG habitat, require use of native plant seeds for vegetation treatments based on availability, adaptation (site potential), probability for success (Richards et al. 1998), and the vegetation management objectives for the area covered by the treatment. Where probability of success or native seed availability is low, use species that meet soil stability and hydrologic function objectives as well as vegetation and GRSG habitat objectives (Pyke 2011).

3. At least one native forb species must be included in all seed mixes to benefit pollinators.

4. For all plant material treatments, consider climate change when selecting species to use in the treatment. ______

Installation of Stabilization/Erosion Control and Wetland Improvement Structures Installation of stabilization/erosion control structures may include any of the following (definitions of these can be found in the Glossary):

▪ Zeedyk structures (e.g., one-rock dams, micro-catchments and rock bowls, rock and/or log lines meant to induce meandering) ▪ Gabions basket ▪ Vegetation Mats (e.g., willow) ▪ Straw waddles and bales, mats and mulch (certified weed free)

The use of “soft engineering” would be used to restore riparian degradation and erosion. Soft engineering is the use of hay bales, rock, and other natural products for erosion control. All soft 39

engineering work would be based on the guidelines and methods described in: An Introduction to Erosion Control, by Bill Zeedyk and Jan Willem-Jansens, A Joint Publication from Earth Works Institute, The Quivira Coalition, and Zeedyk Ecological Consulting. Third Edition April 2009.

The objectives of the installation of these structures are to reconnect the water table to nearby dry meadows, slow the water flow, sequester sediment, vegetate down-cutting drainages, and improve wetland habitats for a host of species that utilize these habitats for forage, water and shelter.

Design Features for Installation of Stabilization/Erosion Control and Wetland Improvement Structures All installation projects would utilize the following design features:

▪ Rock and other materials for construction would be sourced from weed free locations. ▪ Rock and other material staging areas would be located along existing routes in previously disturbed areas.

Protection of Road and River Systems

1. Armor culvert inlets or bridge abutments

2. Provide drainage with water bars on constructed road and dozer lines.

3. Place water bars, 20-40 degrees perpendicular to the fall line, where natural drainage occurs.

4. Ensure each water bar has a direct outlet and drains into a vegetation or rock filter.

5. To reduce sedimentation, drainage from disturbed areas would be confined or directed to minimize erosion. Runoff flowing into intermittent or perennial streams without first passing through sediment-trapping mechanisms such as bales or waddles would be avoided when possible.

6. To reduce sedimentation to stream channels, implement the use of straw bales, check dams, and straw wattles in or above the stream channels. In areas where runoff is an issue, these structures shall remain until the area is properly revegetated.

7. Cover disturbed or eroding areas with limbs, tree tops and woody debris such as logging slash placed on contour and mashed down to achieve good contact with the soil.

8. Apply grass seed and mulch to barren erosive soil areas or closed road surfaces. Mulch material may be straw, wood chips, bark, brush, leaves and limbs.

9. Apply erosion control structures before rainy season begins and immediately following treatments.

10. When hand felling is performed, slash lopped and scattered would be placed perpendicular to the slope. If rilling and water movement were observed on treated hillslopes, additional erosion control would be required to stabilize the slope.

11. Spread slash such as tree limbs and branches on the soil to reduce raindrop impact. If branches are cut small enough (slashed) they would come into contact with the soil, and help disperse overland water flow and reduce runoff and erosion.

12. Install contour log terraces to provide a barrier to runoff from heavy rainstorms. Dead trees are felled, limbed, and placed on the contour perpendicular to the direction of the slope. Logs are placed in an alternating fashion so the runoff no longer has a straight down slope path to follow. The water would be forced to meander back and forth between logs, reducing the velocity of the runoff, and giving water time to percolate into the soil.

13. Silt fences would be used in areas where runoff is more dispersed over a broad flat area. Silt fences are not suitable for concentrated flows occurring in small rills or gullies.

3.2. No Action Alternative Under the No Action alternative, vegetation treatments and installation of stabilization/erosion control structures would not be analyzed at a programmatic level for the defined planning area (See Attachment A) and would not be completed. Current management under the respective RMPs would continue under this alternative.

3.3. Alternatives Considered but Eliminated from Detailed Analysis Vegetation Treatments using Herbicides

The ID Team considered including an alternative that addressed: (1) Using herbicides to treat weeds and (2) using herbicides to manipulate native vegetation (as an alternative to fire or mechanical vegetation treatments. Since the BLM published the Record of Decision for Vegetation Treatments using Aminopyralid, Fluroxypyr and Rimsulfuron on Bureau of Land Management Lands in 17 Western States 41

Programmatic Environmental Impact Statement in August of 2016 (BLM 2016), which analyzed the use of herbicides to treat weeds and manipulate vegetation on public lands, the BLM would be able to utilize that analysis when proposing any vegetation treatments that would utilize herbicides. Therefore, this alternative was eliminated from detailed analysis. Hand Cutting Only A hand-cutting alternative that would not include the use of heavy equipment (e.g., hydro-ax, Fecon Bull Hog) was suggested by Western Watersheds in their scoping comments and was considered but determined not to be feasible.

It was determined that only hand-cutting trees in the Project area would be extremely difficult due to the size and density of many of the encroaching pinyon and juniper, would result in a much longer duration of disturbance from equipment and humans (months rather than weeks) than the Proposed Action, and would produce large quantities of limbs and trunks from trees greater than six inches diameter breast height that could take many years to break down.

Conversely, the Proposed Action includes a hand cutting component and would result in work being completed in a much shorter amount of time (when used in combination with mechanical equipment) and the mulch produced by heavy equipment would break down more quickly and be less visible (i.e., scattered and not remaining in piles greater than eight inches deep) than large tree limbs and trunks that could be visible above the sagebrush. Therefore, the hand-cutting only alternative was not analyzed in detail.

Exclude all lands with wilderness characteristics managed for protection from vegetation treatments

The Wilderness Society, Audubon Rockies and Conservation Colorado submitted an alternative that would exclude all lands with wilderness characteristics managed for protection from vegetation treatments. Vegetation treatments are not prohibited on lands managed for the protection of wilderness characteristics. The BLM will follow existing policy and procedures regarding management of lands managed to protect wilderness characteristics, as well as prescriptions laid out in the field office RMPs where areas are currently being managed to protect wilderness characteristics. Therefore, this alternative was not analyzed in detail.

Exclude mechanical treatments in BLM-identified land with wilderness characteristics units until overall management decisions are made in a land use plan

The Wilderness Society, Audubon Rockies and Conservation Colorado submitted an alternative that would exclude mechanical treatments in BLM-identified land with wilderness characteristics units until overall management decisions are made in a land use plan. Mechanical vegetation treatments are not prohibited on lands identified by the BLM as containing wilderness characteristics. The BLM will follow existing policy and procedures regarding management of lands managed to protect wilderness characteristics, as well for lands that have been identified to 42

contain wilderness characteristics until overall management decisions are made in a land use plan. Therefore, this alternative was not analyzed in detail.

Prioritize areas outside of inventoried lands with wilderness characteristics for vegetation treatments

The Wilderness Society, Audubon Rockies and Conservation Colorado submitted an alternative that would prioritize areas outside of inventoried lands with wilderness characteristics for vegetation treatments. The BLM will follow existing policy and procedures regarding management of lands managed to protect wilderness characteristics, as well for lands that have been identified to contain wilderness characteristics. In addition, the BLM will prioritize areas for vegetation treatments based on the procedures laid out in the Sagebrush Management Resilience and Resistance (SMRRT) decision support tool and in consultation with CPW and local field office biologists. Therefore, this alternative was not analyzed in detail. See page 20 of the Final EA for additional discussion.

Apply a disturbance cap or phased approach to implementing vegetation treatments in lands with wilderness characteristics

The Wilderness Society, Audubon Rockies and Conservation Colorado submitted an alternative that would apply a disturbance cap or phased approach to implementing vegetation treatments in lands with wilderness characteristics. The BLM will follow existing policy and procedures regarding management of lands managed to protect wilderness characteristics and for lands that have been identified to contain wilderness characteristics, as well as prescriptions laid out in the field office RMPs where areas are currently being managed to protect wilderness characteristics. Therefore, this alternative was not analyzed in detail. Conduct NEPA with public comment opportunity for each project that may impact lands with wilderness characteristics

The Wilderness Society, Audubon Rockies and Conservation Colorado submitted an alternative that would include conducting NEPA with public comment opportunity for each project that may impact lands with wilderness characteristics. This Programmatic EA will go through all stages of public comment opportunity, as required by NEPA. The BLM would conduct an additional site- specific review of individual vegetation treatment projects using a Determination of NEPA Adequacy (DNA) worksheet to determine if all resource concerns have been adequately addressed in this programmatic EA or if additional environmental analysis (and public comment opportunity) would be required. Therefore, this alternative was not analyzed in detail.

Use of MB-906 as a vegetation treatment option

The White River and Douglas Creek Conservation Districts submitted an alternative that would include the use of MB-906 (the bacteria Pseudomonas fluorescens), a soil inoculant with a proprietary blend of microorganisms as a vegetation treatment option. The trade name of this soil amendment is currently D7®. Studies are currently underway to determine if D7® and other products that contain Pseudomonas fluorescens would be an effective treatment for the eradication of cheatgrass (Bromus tectorum). These products are currently undergoing review by the Environmental Protection Agency (EPA) to be registered as bioherbicides. Since these products have not yet been registered with the EPA, this alternative was not analyzed in detail.

4. ISSUES

The CEQ Regulations state that NEPA documents “must concentrate on the issues that are truly significant to the action in question, rather than amassing needless detail” (40 CFR 1500.1(b)). While many issues may arise during scoping, not all of the issues raised warrant analysis in an environmental assessment (EA). Issues are analyzed below if: 1) an analysis of the issue is necessary to make a reasoned choice between alternatives, or 2) if the issue is associated with a significant direct, indirect, or cumulative impact, or where analysis is necessary to determine the significance of the impacts. The following sections list the resources considered and the determination as to whether they require additional analysis. 4.1. Issues Analyzed The table below lists the resources considered and the determination as to whether they require additional analysis.

Determination1 Resource Rationale for Determination Physical Resources Air Quality and Climate PI See analysis below. Change The treatments are not expected to affect mineral or NP Geology and Minerals geologic resources associated with the project area. PI Soil Resources* See analysis below. Surface and Ground Water PI Quality*, Floodplains, See analysis below. Hydrology, and Water Rights Biological Resources Wetlands and PI See analysis below. Riparian Zones* PI Vegetation* See analysis below.

PI Invasive, Non-native Species See analysis below.

Special Status PI See analysis below. Animal Species* Special Status PI See analysis below. Plant Species* PI Migratory Birds See analysis below.

PI Aquatic Wildlife* See analysis below.

PI Terrestrial Wildlife* See analysis below.

PI Wild Horses See analysis below. Heritage Resources and the Human Environment PI Cultural Resources See analysis below. Paleontological None of the treatment types would be expected to NI Resources impact paleontological resources. Native American Religious PI See analysis below. Concerns PI Visual Resources See analysis below. Potential hazardous materials that may occur would be associated with the vehicles and equipment typically Hazardous or Solid used in vegetation treatments. While they hold varying NI Wastes amounts of fuels, lubricants and other materials these would be considered de minimis and would not expected to impact resources in the project area. PI Fire and Fuels Management See analysis below. It is anticipated that there would not be any substantial Social and Economic NI changes to local social or economic conditions resulting Conditions from implementation of the Proposed Action. Most treatments would be conducted in remote areas, NP Environmental Justice and would not be expected to have disproportionate impacts to minority or low income populations. Resource Uses Rangeland PI See analysis below. Management Rights-of-Way are present in the project area; however, NI Realty Authorizations no impacts would be expected. PI Recreation See analysis below. Access and The Proposed Action would not change access to or NI Transportation across public lands. There are no impacts to prime and unique farmlands NP Prime and Unique Farmlands anticipated due to the Proposed Action. Special Areas Areas of Critical PI See analysis below. Environmental Concern

Treatments would not be conducted in Wilderness NP Wilderness Areas or Wilderness Study Areas. Lands with Wilderness PI See analysis below. Characteristics The treatment types are not expected to impact NI Wild and Scenic Rivers Wild and Scenic Rivers. The treatments are not expected to affect scenic byways NI Scenic Byways associated with the project area. 1 NP = Not present in the area impacted by the Proposed Action or Alternatives. NI = Present, but not affected to a degree that detailed analysis is required. PI = Present with potential for impact analyzed in detail in the EA. * Public Land Health Standard

5. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

5.1. Air Quality and Climate Change 5.1.1. Affected Environment As stated in the purpose and need, the analysis area encompasses some 3.4 million acres of BLM managed surface throughout a majority of what was the northwest district field office’s (GJFO was re-allocated to the southwest district in FY 2017). Air quality within this region is currently attaining the National Ambient Air Quality Standards (NAAQS) for all criteria pollutants (carbon monoxide (CO), nitrogen dioxide (NO2), ozone (O3), particulate matter (PM10 and PM2.5), sulfur dioxide (SO2), and lead (Pb)), as defined by U.S. Environmental Protection Agency (EPA - https://www.epa.gov/criteria-air-pollutants/naaqs-table%20). Compliance with the NAAQS is demonstrated by monitoring for pollutant concentrations in the form of the standards (averaging periods, etc.) at ground level using specialized and programmatically maintained instrumentation and methods. Fielding and maintaining monitoring equipment is an expensive commitment. The various agencies that sponsor monitoring, including EPA, BLM, USFS, NPS, and the CDPHE, have limited resources to provide for it, and as such not all pollutants are monitored for in all areas. In general, the U.S. EPA provides monitoring guidelines that states must follow to protect populated areas. Other sponsoring agencies provide monitoring to serve their own enacting legislative drivers, and as such have a bit more flexibility for providing monitoring when resources allow for it. The US EPA maintains a data repository online at https://www.epa.gov/outdoor-air-quality-data/monitor-values-report, which provides public access to all of the available monitoring data for Colorado.

The following text describing western Colorado's climate is an abbreviated version of the narrative found on the Western Regional Climate Center's website. The rugged topography of western Colorado causes large variations in climate within short distances, and few climatic generalizations apply to the whole area. At the summits of mountains, temperatures are low, averaging less than 32°F over the year. Snow-covered mountain peaks and valleys often have

very cold nighttime temperatures in winter, when skies are clear and the air is still — occasionally to 50°F below zero. Summers in the mountains are cool, with typical mountain stations averaging 60°F in July. The highest temperatures are usually in the seventies and eighties, but may reach 90°F to 95°F. Above 7,000 feet, the nights are quite cool throughout the summer, while bright sunshine makes the days comfortably warm. The lower western valleys of the State are protected by surrounding high terrain, and have a greater uniformity of weather than the eastern plains. They experience high summer temperatures, comparable to those of the eastern plains, while average winter temperatures are somewhat lower than at similar elevations in the plains. Precipitation west of the Continental Divide is more evenly distributed throughout the year than on the eastern plains. For most of western Colorado, the greatest monthly precipitation occurs in the winter months, while June is the driest month. In contrast, June is one of the wetter months in most of the eastern portions of the State due to summer thunderstorms.

Lukas et al. (2014) summarizes Colorado’s climate and using climate models projects what the climate may be over the next 50 years. Over the last 30 years the statewide annual average temperature in Colorado has increased by 2.0 degrees Fahrenheit. This is attributed to an increase in the daily minimum temperature. While there is no long-term trend in precipitation during this time frame snowpack has generally been below average and the timing of snowmelt and peak runoff has shifted, on average, between 1-4 weeks earlier. This can be attributed to more rain on snow events that accelerates the runoff.

Based on climate modeling the projections for Colorado tend to show an additional temperature increase between 2.5 and 5.0 degrees Fahrenheit by 2050 (Colorado Water Conservation Board). This increase can be attributed to a forecast of summer temperatures warming more than winter temperatures. The models indicate no real trends in precipitation but with warming temperatures more rain on snow events are likely to occur, especially in the spring. This warming is likely to see a trend in an increase in winter precipitation since warmer temperatures are able to hold more moisture. Even with more winter precipitation, it is expected that the timing of peak spring runoff will shift even earlier in the spring. With an increase in summer temperatures, Colorado is expected to experience more heat waves, more prolonged and intense seasonal droughts (even the possibility of multi-year mega-droughts). This will likely increase the length and intensity of the wildfires within the analysis area.

Many scientists believe that human actions are changing the chemical composition of Earth’s atmosphere. Activities such as fossil fuel combustion, industrialization, deforestation, and other changes in land use are resulting in the accumulation of trace greenhouse gases (GHGs) such as carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), and several industrial gases in the Earth’s atmosphere.

The driver for the buildup in heat within the climate system is best described in terms of radiative forcing (RF). The term describes the energy balance that would occur (i.e., heating (+) or cooling (-)) in units of W m–2. The total anthropogenic RF for 2011 relative to 1750 was 2.29 [1.13 to 3.33] W m−2 (includes both heating and cooling parameter estimates). For well mixed 47

GHG’s the total positive forcing is estimated to be 2.83 [2.54 to 3.12] W m–2. The largest contribution to total radiative forcing since 1750 is caused by the increase in the atmospheric concentration of CO2. Emissions of CO2 alone caused an RF of 1.82 [± 0.19] W m–2 (64%), while CH4 caused an RF of 0.48 [± 0.05] W m−2 (17%). The data highlights methane’s important role as a potent greenhouse gas, given its RF value in relation to its atmospheric loading trend, approximately 556 Tg yr–1 (64% anthropogenic, 36% natural) and relatively short atmospheric lifetime (12 years). N2O has the third largest forcing of the anthropogenic gases, at 0.17 [± 0.03] W m–2 (6%). Collectively the three GHG’s of concern account for approximately 87% of the positive forcing within the climate system.

5.1.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Relative to the Proposed Action, the rest of this section is primarily focused on providing a qualitative analysis of potential affects. The broad geographic region is not conducive to providing for a refined air quality analysis, as the necessary information to support that level of effort is currently lacking. However, in general terms it is highly likely that future individual actions having such detail would not require or warrant any additional analysis beyond what is contained here.

Emissions from the Proposed Action activities would be from equipment and vehicle exhausts, dust from equipment operations, and smoke from prescribed fire. Burning produces reactive organic compounds, nitrogen oxides, carbon monoxide, inhalable particulate matter (PM10), fine particulate matter (PM2.5), and greenhouse gas pollutants. Vehicle and machine engine combustion also produces the same categories of emissions as prescribed fire. In addition, vehicle use on unpaved roads and cross-country travel generate fugitive dust that contains PM10 and PM2.5 particulates.

In order to quantify potential emissions, district staff provided state office air resource specialists a list of activities and the total acres planned for a variety of treatments that could occur over the life of the proposed active analysis timeframe (2017 – 2021). This information was used to estimate emissions inventories on an annual and cumulative basis utilizing tools capable of producing emissions estimates with limited input details. In general, the BLM used the activity with the highest emissions intensities as a surrogate for the given acres to produce worst case conservative emissions estimates. The particulate matter emissions output was scaled back to correct for a general overestimation created by the emissions tool, which assumes ground breaking disturbance types of operations for the total acres provided. For overland operations that can occur for a majority of the Proposed Action activities the ground is NOT typically disturbed in this manner, and thus the outputs are far too high to estimate a typical impact. For the purposes of the disclosed inventory and for screening, the BLM assumed a tenth of the acres would be disturbed to such a degree. Several other reasonable assumptions were made to fill in the necessary details to provide for these estimates, and include the following:

▪ The maximum treatment area in any year would be 21,300 acres (2,130 acres of disturbance) ▪ All remote off road travel and land disturbance would not provide for any dust control (i.e., watering) for inventory purposes ▪ There would be a maximum of 20 site specific projects per year ▪ Each project would typically have a duration of one week (5 business days) ▪ The average one way commute to project areas would be 50 miles ▪ Treatment equipment (multiple units, light and heavy duty) would be utilized for 8 hours per project day ▪ The maximum Rx fire acres would be approximately 9,600 (primarily juniper) for any project year

Table 5.1 - Total Estimated Worst Case Annual Emissions

According the USEPA’s AP-42 emissions factors report for prescribed burning, emissions of CO2 from fire are considered to be part of the carbon cycle, such that they are typically not included in greenhouse gas emission inventories, and thus that is why the Rx burning CO2 emissions are shown as 0 tons.

Considering the size of the planning area and that on an annual basis the total emissions presented in the table above would be distributed across a broad geographical area and would vary in temporal occurrence, it would be highly unlikely that any single future site specific project would contribute significantly to air quality degradation at localized or regional scales. There could be minor localized impacts that would be short lived (i.e., while the activity is occurring) in the vicinity of the project area. However, careful execution planning and the use of best management practices could be used on a case by case basis to mitigate impacts to nearby receptors if they exist. As shown the majority of the estimated emissions are driven by the use of prescribed fire. All planned ignitions would need to be done in accordance with CDPHE open burn permitting requirements. The BLM maintains a prescribed fire management plan and MOU with CDPHE concerning the use of prescribed fire as a management action, and would comply with all of the permitting requirements issued by CDPHE when this action is selected as an appropriate management option. The goal of the prescribed fire permitting program is to provide for minimized impacts to nearby receptors and to ensure compliance with the NAAQS, such that

impacts would not be considered to have any significant impact if the permitting requirements issued by CDPHE are adhered to.

To provide further context for the estimated non-fire related emissions the BLM provides a screening level analysis for a typical Proposed Action project using the BLM emissions screening tool developed by State Office Air resource specialists. The BLM Colorado near-field modeling tool uses the EPA AERMOD modeling system for estimating ambient air concentrations at a given downwind distance from a potential sensitive receptor. Five years (2008-2012) of Colorado-based surface and upper-air meteorology are used to predict possible air quality impacts for various model source types (point, volume, and road ways). Because actual project locations are unknown, the tool was iterated over at various downwind distances to predict the point where an exceedance of the NAAQS would not occur. Please note that the term “exceedance” does not mean a violation of the NAAQS nor does it represent a significant impact threshold at any potential downwind receptor. Only refined analysis can support these determinations and such analysis is beyond the scope of this document given the available data. In general, this analysis can be used at execution time to determine what NEPA instrument could be used to authorize the project with respect to air resources (ex. DNA, Tier, EA, etc.).

The results indicate that project level NAAQS can easily be achieved at downwind distances shown in the table below. The model was run to produce an impact of approximately 80% of the NAAQS which provides that the remaining 20% would account for any potential ambient background concentration (which is conservative given that these projects are not anticipated to be in highly anthropogenic influenced areas). The distances were derived for the averaging period and the form of each applicable standard. For the 1-hour NO2 and 24-hour PM2.5 standards, a 98th percentile value (the level of the standard) would only occur if the project lasts longer than 7 days, thus for disclosure purposes the distances for these values are very conservative given our project level assumptions (typical project would last 5 days at maximum intensity).

Table 5.2 - Downwind Distances to NAAQS Level

Rau et al. (2012) asserted that woodland expansion reduces perennial herbaceous vegetation, 50

which provides a food source for many species. They also found that increases in pinyon-juniper woodlands may enable higher intensity wildfires and invasion of non-native species such as cheatgrass (Bromus tectorum) that may eventually lead to decreases in carbon sequestration in the ecosystem. However, the vegetation removal planned under the Proposed Action would not be expected to release a substantial amount of carbon into the atmosphere thus contributing to climate change. At this time no analysis tools exist to evaluate project level contributions to predicted climate change (disclosed in cumulative effects below), and therefore the degree to which this project could potential effect change given that climate patterns (regional and global scales) are wholly influenced / dependent on cumulative actions in the global context is not known. However, based on the premise that emissions are a surrogate for impacts, it is certain that this project would not be significant. Given that the majority of the GHG emissions are the result of fire, and fire related emissions are considered to be part of the carbon cycle, it would be reasonable to assume that the net effect would be negligible over timeframes that lend themselves to climate analysis (i.e., decades).

Cumulative Impacts As described above, the emissions from the eventual execution of multiple site specific projects would be expected to occur annually from 2017 through 2021. Over this timeframe the sources of emissions would be expected to be the same as those described above. The BLM has prepared a cumulative emissions inventory to disclose the total estimated emissions over the Proposed Action activity period. Several reasonable assumptions were made to fill in the necessary details to provide for these estimates, and include the following:

▪ Cumulative emissions for non-fire related activities were derived by scaling the maximum annual emissions ▪ The cumulative scaling factor is the ratio of the cumulative acres (89,300) divided by maximum annual acres (21,300) ▪ The cumulative prescribed fire area over the life of the Proposed Action would be approximately 27,700 acres

Table 5.3 - Total Estimated Worst Case Cumulative Emissions

Cumulatively, the impacts would not be expected to be any greater than the annual impacts disclosed above.

All climate model projections indicate future warming in Colorado. Statewide average annual temperatures are projected to warm by +2.5°F to +5°F by 2050 relative to a 1971–2000 baseline under RCP4.5. Under the high emissions scenario (RCP8.5), the projected warming is +3.5°F to +6.5°F and would occur later in the century as the two referenced scenarios diverge. Summer temperatures are projected to warm slightly more than winter temperatures, where the maximums would be similar to the hottest summers that have occurred in past 100 years. Precipitation projections are less clear, with individual models showing a range of changes by 2050 of -5% to +6% for RCP 4.5%, and -3% to +8% under RCP8.5. Nearly all of the models predict an increase in winter precipitation by 2050, although most projections of snowpack (April 1 SWE) show declines by mid-century due to the projected warming. Late-summer flows are projected to decrease as the peak shifts earlier in the season, although the changes in the timing of runoff are more certain than changes in the amount of runoff. In general, the majority of published research indicates a tendency towards future decreases in annual streamflow for all of Colorado’s river basins. Increased warming, drought, and insect outbreaks, all caused by or linked to climate change, would continue to increase wildfire risks and impacts to people and ecosystems. However, the Proposed Action is not expected to contribute to any of these changes.

5.1.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the no action alternative, none of the direct effects of the Proposed Action would be planned or authorized in the future. The estimated emissions from treatments and installation of erosion control/stabilization structures would not occur. Any impacts that would be adverse or beneficial to climate change from the Proposed Action would not occur. Cumulative Effects Under the no action alternative, none of the cumulative effects resulting from any future Proposed Action would occur. The estimated emissions from such actions over the Proposed Action timeframe would not be emitted. 52

Given the insignificance of the greenhouse gas emissions and landscape changes / recovery that would have accompanied the eventual projects from the Proposed Action, all of the predicted climate change impacts as a result of global cumulative impacting actions would occur regardless of any actual implementation.

5.1.4. Mitigation Measures and Residual Impacts ▪ Provide for compliance with any / all prescribed burning permit requirements. ▪ Use best management practices to avoid excess fugitive dust transport from land disturbance activities, such as watering when practical and in consideration of nearby receptors if they exist. ▪ Avoid operations on high wind days that could result in offsite transport of visible plumes of fugitive dust.

5.2. Soil Resources 5.2.1. Affected Environment Soil types in the project area vary due to the influences of parent material, climate, biotic communities, and the geomorphic processes of the region. The project area is divided by three ecoregions in which soils can be characterized, the Southern Rockies to the east, the Colorado Plateau to the west and the Wyoming Basin to the north.

Many of the soils in the Colorado Plateau ecoregion have developed from alluvium that was deposited over time as the major rivers and their tributaries eroded through the surrounding mountain ranges.

Soil types on the Colorado Plateau vary due to the influences of parent material, climate, biotic communities, and geomorphic processes of the region. Soils of the plateau are predominantly alkaline, except in mountainous areas where greater precipitation rates and abundance of organic material results in acidic soils. Entisols and Aridisols are typical soil orders, with mostly mesic and frigid soil temperature regimes and aridic and ustic soil moisture regimes (Griffith 2010). The geology and soils of the Southern Rocky Mountain Ecoregion are a complex geologic mix with Precambrian metasedimentary, metavolcanic, and intrusive rocks, Tertiary and Cretaceous sedimentary rocks, and Tertiary volcanic rocks. Alfisols, Entisols, and Mollisols are the primary soil orders, with mostly frigid and cryic soil temperature regimes and udic and ustic soil moisture regimes (Griffith 2010).

The Wyoming Basin Ecoregion geology and soils are mostly Tertiary and Cretaceous sandstone, claystone, shale, and some limestone. Entisols and Aridisols are dominant soil orders, with frigid and mesic soil temperature regimes and aridic and ustic soil moisture regimes (Griffith, 2010).

Overall, the dominant soil orders in these ecoregions are alfisols, aridisols, entisols, inceptisols, 53

mollisols, and vertisols (USDA 2000). Alfisols are formed in semi-arid regions and found mostly under forest vegetation. Aridisols typically occur in hot and cold desert climates and contain salt, gypsum and carbonates. Entisols are found in unstable environments such as steep slopes in dry climates. Inceptisols are commonly found in mountain regions and generally contain clay, salts, and organic material. Mollisols are considered fertile mineral soils and are commonly found on grasslands and in vegetation with fibrous root systems. Vertisols are high in clay content inducing swelling and shrinking upon wetting. They are typically found in semi- arid climates where natural vegetation is grass, savanna, open forest, or desert shrub. A map of these soil orders for the project area are shown in a map included in Attachment A.

Soil productivity within the project area varies widely due to the diversity of soils and characteristics at each site. Soil temperatures affect chemical and biologic reactions that release plant nutrients from minerals within the soils. Soil temperatures within the project area yield low rates of biologic activity, resulting in slow rates of decomposition, seed germination, and root growth (BLM 2015). When these factors are combined they result in low soil fertility. In valley bottoms, soils can have a dark, thick, fertile surface that supports a variety of vegetation. However, these locations are generally outside of the project area.

Soil characteristics are highly variable within the project area, exhibiting alkaline, sandy, and clay loams, as well as rock outcrop complexes. Permeability of the soils range from very slow to moderate with erosion hazard for many of the soils rated as moderate to severe. These soils are also generally classified as having high runoff potential. Some of these soils are highly saline, specifically within the western portion of the project area.

The Natural Resource Conservation Service (NRCS) soil survey manuscripts and NRCS Web Soil Survey were used for the characterization of soil conditions within the project area. The treatment areas for the Northwest District were broken into BLM lands within the treatment area. Assessment of soil conditions were conducted within each field office boundary. The general soil series referenced by the NRCS were used to summarize the dominant soil conditions for the area and are described below and displayed in a map included in Attachment A.

Colorado River Valley Field Office (CRVFO)

Taxonomic Class Name (NRCS 1992,1985)

▪ Parachute-Irigul Series: This soil unit is found in elevations from 7,500 to 8,700 ft. These soils are underlain and formed in material weathered from Green River shale and Uinta sandstone. Parachute soils are found on ridges and mountain sides, are moderately deep and well drained. Irigul soils are on crests and sides of ridges, are shallow and well drained. These soils are in hydrologic group B exhibiting moderate infiltration and runoff rates. These soil series provide suitable conditions for grazing and vegetation supporting wildlife habitat for deer, elk, mountain lion, and grouse.

▪ Lamphier Series: This soil unit is formed in mixed alluvial and colluvial material derived from sandstone, shale, and basalt. Lamphier soils exist on fans and mountainsides and are deep and well drained. This soil is in hydrologic group B exhibiting moderate infiltration and runoff rates. This soil provides suitable conditions for grazing and wildlife habitat for deer, elk, mountain lion and grouse.

▪ Brownsto Series: This soil unit is found on steep slopes up to 50 percent. This soil exists in elevations from 6,400 to 8,500 ft and is well drained. Brownsto series is in hydrologic group B exhibiting moderate infiltration and runoff rates. The vegetation on this soil is mainly woody shrubs, grasses, forbs, pinyon, and juniper. This soil provides suitable conditions for vegetation providing habitat to mule deer, birds of prey, sage grouse and elk.

Grand Junction Field Office (GJFO)

Taxonomic Class Name (NRCS 2003, 1978)

▪ Parachute Series: This soil unit is found in elevations from 7,500 to 8,700 ft. These soils are underlain and formed in material weathered from Green River shale and Uinta sandstone. Parachute soils are found on ridges and mountain sides and are moderately deep and well drained. These soils are in hydrologic group B exhibiting moderate infiltration and runoff rates. The recommended use for these soil conditions are grazing and providing conditions supporting wildlife habitat such as deer, elk, mountain lion, and grouse.

▪ Tosca Series: This soil unit is found on mountain side slopes. They are formed in colluvium derived from Green River shale, is deep and well drained. This soil is in hydrologic group B exhibiting moderate infiltration and runoff rates.

▪ Youngstown Series: This soil unit is found on alluvial fans, valley bottoms, and low terraces. This soil is exists on low angle slopes 1 to 6 percent, is deep and well drained. This soil is in hydrologic group B exhibiting moderate infiltration and runoff rates.

Kremmling Field Office (KFO)

Taxonomic Class Name (NRCS 1992, 1983)

▪ Tiagos Series: This soil unit is found on rolling and hilly uplands, outwash terraces, alluvial fans, and till plains. This soil exists on slopes from 2 to 20 percent, are deep and well drained. This soil is in hydrologic group B exhibiting moderate infiltration and runoff rates. This soil is most suitable for supporting grazing and grass pastures.

▪ Waybe Series: This soil unit is found on elevations from 7,500 to 8,500 ft on steep to 55

very steep slopes. This soil exists on mountainsides and ridges, originates from shale and mudstone and are shallow and well drained. This soil is in hydrologic group D, which exhibits very slow infiltration rates. The suitability for this soil to support wildlife winter range is fair with sagebrush management needed.

▪ Eachuston Series: This soil unit is found in high mountain valleys on low gradient hillslopes and low terraces. This soil is very poorly drained with slow runoff and part of hydrologic group D. The primary vegetation type for these soils are grasses.

Little Snake Field Office (LSFO)

Taxonomic Class Name (NRCS 2004)

▪ Gretdivid Series: This soil unit is found in elevations from 6,200 to 7,300 ft, on summits, shoulders, and backslopes on 10 to 30 percent slopes. This soil type is deep, well to excessively drained and in hydrologic group B, which exhibit moderate infiltration and runoff rates. It is derived from sandstone with fine-loamy texture.

▪ Bulkley Series: This soil unit is found in elevations from 6,200 to 8,300 ft on summits, backslopes, and toeslopes on 12 to 25 percent gradients. This soil is derived from alluvium and colluvium derived from shale, is very deep and well drained.

▪ Teagulf Series: This soil unit is found in elevations from 6,000 to 7,300 ft on erosional uplands and alluvial fans on low gradient hillslopes 0 to 8 percent. This soil is moderately deep and well drained with coarse-loamy texture. Teagulf series is in hydrologic soil group C exhibiting slow infiltration rates and moderate runoff. This soil is suitable for vegetation such as sagebrush, grasses and pricklypear cactus.

▪ Pinelli Series: This soil unit is found at elevations from 5,500 to 7,800 ft on alluvial fans and valley sideslopes ranging from 0 to 30 percent. Pinelli Series is very deep, well drained, exhibits rapid runoff, and is within hydrologic soil group B. Vegetation suitable for this soil is sagebrush, western wheatgrass and Sandberg bluegrass.

White River Field Office (WRFO)

Taxonomic Class Name (NRCS 2004, 1982)

▪ Parachute Series: This soil unit is found in elevations from 7,500 to 8,700 ft. These soils are underlain and formed in material weathered from Green River shale and Uinta sandstone. Parachute soils are found on ridges and mountain side, are moderately deep and well drained. These soils are in hydrologic group B exhibiting moderate infiltration and runoff rates. These soil series provide suitable conditions for grazing and vegetation 56

supporting wildlife habitat for deer, elk, mountain lion, and grouse.

▪ Moyerson-Rock Outcrop Series: This soil unit is found in elevations from 5,300 to 7,600 ft. These soils exist on 2 to 90 percent hillslopes on foothills and uplands. They are shallow, well drained and part of the hydrologic soil group D exhibiting high runoff potential. Vegetation that is suitable for this soil series are pinyon, juniper and understory shrubs. This vegetation provides habitat for mule deer, bobcat, coyote, grouse, and birds of prey.

▪ Massadona Series: This soils unit is found in elevations from 4,700 to 6,300 ft on hills, toeslopes, and alluvial fans on 0 to 12 percent gradients. This soil is very deep, well drained and exhibits very high runoff potential. Vegetation that is supported by this soil is Nuttal saltbush, sage, and wheatgrass, which provide suitable conditions for rangeland use and wildlife habitat.

Biological Soil Crusts

In semi-arid regions, vegetative cover is generally sparse with open spaces existing between vegetation. Within these open spaces, biological soil crusts form from living organisms and their by-products, creating soil particles bound together by organic materials. The types of biological soil crusts are known as cryptogamic, microbiotic, cryptobiotic, and microphytic and indicate the common features of the organisms that compose the crusts. These crusts are a complex makeup of cyanbacteria, green algae, lichens, mosses, microfungi and other bacteria (BLM 2015).

In the Colorado Plateau, cyanbacteria composes the vast majority of the biological crust structure followed by lichens and mosses. In areas composed of soils high in acidity, green algae is more likely to be found. The organism that dominates the crust is partly determined by microclimate and may represent different successional stages in crust development (Belnap et al. 2001).

Biological crusts play an important role in soil health as their location is concentrated in the top few centimeters of the soil surface and affect processes that occur at the soil/air interface. Biological crusts affect soil stability, erosion, atmospheric nitrogen fixation, nutrient cycling, water infiltration and plant growth. Once formed, biological soil crusts help bond soil particles, therefore increasing the resistance to wind and water erosion which protect fragile soils in semi- arid regions. Furthermore, biological crusts function as a water regulating mechanism increasing infiltration rates and slowing erosion processes.

Biological crusts were modeled during the BLM’s Rapid Ecoregional Assessment (REA) to identify important resource values and environmental change. One of the maps included in Attachment A shows the potential for soil crusts to exist within a portion of the project area on the Colorado Plateau, however no data exists for the Southern Rocky Mountain or Wyoming Basin ecoregions. Although data does not exist for the entire project area, this model helps identify the likelihood of encountering biological soil crusts. 57

5.2.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Soils are complex in their make-up and supply nutrients, water, and physical support to sustain plant life and ecological function. Increasing tree cover in sagebrush ecosystems can lead to a detrimental decrease in herbaceous understory biomass (Suring et al. 2005). Landscapes with high tree density and compromised understory vegetation are susceptible to catastrophic wildfire and exotic grass invasions (Chambers 2005).

Soil disturbing activities can impact the function and sustainability of soils that take time to renew themselves. Vegetation treatments for this project consist of prescribed fires, slash pile burning, mechanical thinning, and hand thinning. The effects that these treatment methods on soil erosion and sediment yield depend on localized site characteristics and should be assessed in more detail for each localized treatment. One of the maps included in Appendix A shows the soil erosion ratings for the project area. The following section describes treatment methods and their general impacts to soils.

Broadcast Burn

All methods of prescribed burning results in soil heating, which can alter soil properties and functions. The major factor that determines the effects of burning on soil health and erosion is the extent of disturbance to the surface of organic material. Changes in soil fertility, organic matter content, water infiltration, soil mineralogy, and nutrient availability are among the many potential responses to burning that may either benefit or degrade soil quality (Busse et al. 2014).

Prescribed fires can create a highly variable mosaic of burn severity, duff composition and unburned area (Robichaud, 2000). High burn severity increases the likelihood of creating hydrophobic soil conditions leading to increased sheet flow, rill formation, sediment supply, and erosion.

Biological crusts are generally killed by hot ground fires, resulting in loss of biomass and visible cover (Johansen et al. 1993). Frequent fires would prevent the ability for biological crusts to reestablish as it takes years for this to occur. Low intensity fires typically do not remove all of the crust structure, which would allow for regrowth without significant soil loss. Full recovery of crusts is a slow process with some recovery occurring within five years, however, full recovery of well-formed soil crusts can take up to 50 years. Management of these areas post treatment while limiting the area of disturbance that contains biological soil crusts is an important aspect to consider during the planning phases of treatments.

Measures should be taken when implementing prescribed fire treatments to avoid uniform, high intensity burning in an effort to minimize soil quality impacts. Creating a mosaic of burn severity would help manage and minimize the spatial extent of erosion, nutrient loss, and soil quality impacts. Furthermore, avoiding steep slopes greater than 30% would help minimize 58

erosion potential within the treatment areas.

Implementing prescribed burns when soil and duff layers are moist would help limit the severity of heating and ultimately the impact on soils. Low to moderate burning typically results in minimal damage from soil heating, nutrient loss, erosion potential and microbial mortality. Vegetation recovery after prescribed burns are generally rapid, with erosion rates dropping to pre-fire levels within 1 to 2 years (Busse et al. 2014). Overall, impacts to long-term soil health and intactness are expected to be short in duration as a result of recommended design features.

Slash Pile Burning

Slash pile burning would be implemented in areas that have been mechanically and hand thinned where felled trees and slash are piled and burned. Soil heating is the primary concern in relation to slash pile burning. When heating is concentrated over small areas under slash piles, soil temperatures can remain elevated for several days. Changes to the soils physical, chemical, and biological properties are likely under burn piles and can be significant if not properly conducted. The severity of heating under slash piles depends on the complexity and size of fuels as well as the size of the piles.

In order to reduce impacts on soil health from slash pile burning, actions should be taken to avoid burning piles that contain a high percentage of large wood (>10 inches), instead, a mixture of fuel diameter sizes is best. Busse et al. (2014) recommend that pile diameters should not be greater than 20 ft and pile spacing should be kept to 15% ground cover within a treatment area (roughly 250 piles per acre). If slash piles occur at a higher density than 15% of the treatment area, soil impacts such as erosion can be greater. Design features that are described for this project regarding slash pile burning would help limit soil damage.

Mechanical Thinning

The primary impact to soils resulting from mechanical thinning is compaction by heavy machinery. As mechanical treatments are employed to reduce pinyon-juniper cover, direct soil impacts include soil disturbance and loss resulting from increased erosion and surface compaction. Surface compaction can alter soil site productivity. Soils are at the highest risk for detrimental impacts when soil moisture is near field capacity (ie. wet, but not saturated). Detrimental soil compaction can occur when deep rutting of soils from mastication equipment is experienced. Areas that contain clay are most prone to detrimental compaction (Busse et al. 2014). Soils that are poorly drained also have a higher potential to experience higher compaction and rutting. A common soil characteristic within the treatment area, however, are well drained soils which would help mitigate rutting potential.

Biological soil crusts are well adapted to severe growing conditions, however not adapted well to compressional disturbances that could result from overland travel. This kind of disturbance breaks down the bonds and reduces the ability of the soil organisms to function. The impacts of 59

a given disturbance to a biological soil crusts depends on the severity, frequency, timing, and type combined with climatic conditions during and after the disturbance. Compaction disturbance varies with the type of compaction. Vehicle use would have a larger effect on soil disturbance compared to foot travel. Additionally, vehicle tracks often leave shallow ruts which would channel water off-site and slow or prevent recovery (Webb and Wilshire 1983).

Equipment used for the project would involve a masticator or mower that is mounted on a tracked or large rubber-tired tractor, either of which would help reduce soil compaction. Design features, such as limiting work to when soils are dry or frozen would help minimize compaction and rutting potential and reduce formation of new overland flow patterns. Furthermore, masticated mulch would increase ground cover over soils, reducing soil erosion and increasing infiltration. This would provide organic matter and nutrients for the soils within treatment areas. Overall, soils would be largely protected post-treatment, as woody debris, grasses, forbs, and shrubs would help reduce erosion from wind and water.

Manual Thinning

Manual treatments involve the use of hand tools and hand operated power tools to cut, clear, or prune herbaceous and woody species. Treatments include cutting undesired plants and trees and scattering (e.g., Lop and Scatter) branches to either be burned or left in place on the landscape.

Manual treatment has the lowest soil disturbance of all activities due to low impact foot travel to and within treatment sites. In areas with sensitive or highly erosive soils, hand treatments can be utilized to minimize overland travel impacts. Additionally, in areas with higher gradient hillslopes and sensitive soils, hand thinning treatments would have the capability to strategically place slash across gradient to help reduce erosion potential. When slash is placed perpendicular to gradients, overland flow would be slowed which would allow for infiltration into the soils. Direct and indirect impacts from manual treatment would be minimal. Cumulative Impacts Past, present, and reasonably foreseeable future actions and conditions within the Project area that have affected and would be likely to continue to affect soil resources are mineral development, livestock grazing, infrastructure development, vegetation treatments, wildfires, recreation, and travel and transportation activities.

Mineral development, including oil and gas, coal, and other minerals, could cause localized impacts on soils. Mechanical vegetation treatments likely have and would continue to impact soils resources locally, but they would increase vegetation cover, and thus soil health, over the long term. Past livestock grazing has impacted soil resources. Active management of grazing allotments has led to improvements in soil health over time in the Project area.

Fuel management treatments are generally needed every 10 to 20 years and the associated cumulative effects occur during each access and treatment cycle (Elliot et al. 2010). Single

treatments within an area that are allowed to recover for 1 to 2 years before additional treatments have shown positive soil recovery rates. Hillslope erosion rates post fuel treatments from low severity burning and thinning have shown quick recovery rates as well.

The cumulative effect of vegetation treatment activities is generally related to their location and concentration within a given watershed as well as the degree and frequency of disturbance for each activity.

Erosion control design features for this project should minimize long term impacts to soil health and sediment yield. Cumulatively, vegetative treatments and installation of stabilization/erosion control structures should benefit soil retention capacity by increasing quality and quantity of plant diversity and cover from the reduction of forest canopies that are currently out competing understory vegetation.

5.2.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, no treatments would occur and present soil erosion rates could increase. As sagebrush shrublands experience further encroachment by pinyon and juniper trees, species that would help stabilize the soil, such as grasses forbs and shrubs would be outcompeted. This could result in increased soil erosion. If the BLM does not install erosion/stabilization structures, degraded soil conditions in some riparian areas would continue. Cumulative Impacts See description of past, present and reasonably foreseeable future actions above.

Under the no action alternative, short-term soil conditions would remain the same and vegetation structure would continue to change as a result. Over the long term, soil conditions would likely degrade as understory grasses and shrubs are out competed and eliminated, therefore reducing soil stability and health. Present soil erosion rates would likely increase over time as pinyon-juniper canopies further encroach and out-compete soil stabilizing grasses, forbs, and shrubs.

5.3. Surface and Ground Water Quality, Floodplains and Water Rights 5.3.1. Affected Environment Water resources on public lands are regulated by the Clean Water Act, Safe Drinking Water Act, Public Land Health Standards, the Watershed Conservation Practices Handbook and other laws, regulations, and policy guidance at the federal, state, and local levels (BLM 2015). These acts and standards necessitate preservation and restoration of the physical, biological, and chemical qualities of waters. The primary control mechanism recognized by the BLM for management of pollution are best management practices and conservation methods.

Water resources within the treatment area include surface and groundwater sources, for example, streams, water bodies, springs, riparian areas, and wetlands. Surface water resources and flows are impacted by the amount of precipitation and runoff, water storage and withdrawals, soil erosion, and overall conditions of the uplands and riparian areas.

The treatment area is split into several hydrologic units seen in the table below. The treatment area covers two hydrologic regions and six sub regions. The hydrologic unit sub regions contain various water resources within them and are generally defined by the dominant water resource.

Table 5.3 - Hydrologic Units within the Project Area

Region (HUC 2) Sub Region (HUC4) Missouri North Platte Missouri South Platte Upper Colorado Colorado Headwaters Upper Colorado Great Divide-Upper Green Upper Colorado White-Yampa Upper Colorado Lower Green Source: USGS 2016

In semi-arid western Colorado, freshwater is a limited resource. The primary source of fresh water in the project area comes from surface water. The major sources of surface water are the Colorado River, North Platte River, Canadian River, Illinois River, Yampa River, Little Snake River, Green River, and the White River. Aside from these large water sources, there are many smaller surface water sources within the treatment area, including streams that are intermittent and ephemeral. These sources convey water only during certain times of the year under event based inputs.

Surface water flow volumes vary throughout the year and across the project area. In naturally flowing rivers and streams there are large seasonal variations in flow volumes. The largest flows typically occur during spring or early summer as a result of snowmelt and summer rainstorms.

These seasonal inputs provide the major source of runoff for perennial streams, with groundwater inflow being a contributor during the remainder of the year. Perennial streams typically contain water all year long. Intermittent streams in the project area are common and generally flow from late spring to mid-summer. Ephemeral streams are also common in the project area carrying water during times of large precipitation events. These systems are found in lower elevation landscapes and are characterized by active incision and erosion. The spatial extent of surface water sources within the treatment area are shown in the table below and Attachment A.

Table 5.4 - Surface Water Stream Miles

Surface Water Type Total Miles Perennial Streams/Rivers 1,340 Intermittent Streams 19,128 Ephemeral Streams 1,634 Source: USGS 1999

Surface water quality varies throughout the treatment area primarily as a function of flow and land use upland of water corridors. Factors that alter water quality include, but are not limited to the following: agricultural use, oil and gas development, vegetation structure/cover, ground water interaction, soil chemistry, point and non-point pollution sources, recreational use, and other surface disturbing activities.

Water quality in ephemeral and intermittent stream channels is dependent upon the amount of constituents that accumulate in dry stream channels between flow periods. These accumulations can be attributed to the physical properties of the watershed such as geology, climate, plant cover, land use, and seasonal fluctuations in temperature and precipitation. Periodic flushing of accumulated salts, trace elements, and sediments occurs during large flash flow events (BLM 2015).

The Colorado Department of Health and Environment (CDPHE) establishes water quality classifications to maintain and improve surface water quality in Colorado. These classifications are based on current conditions and the beneficial uses of each particular river or stream as seen in the table below. The latest listing for impaired watersheds was published in 2016 by the CDPHE and indicates waters as impaired (303d) or in need of further monitoring and evaluation (M&E). Within the treatment area, there are 874 miles of rivers/streams listed on the 303(d) list and 1,452 miles of rivers/streams listed on the M&E list.

Table 5.5 - CDPHE Water Use Descriptions

State- Designated State-Designated Use Description Use These surface waters are suitable or intended to become suitable for irrigation of crops usually Agriculture grown in Colorado and which are not hazardous as drinking water for livestock. These are waters that (1) currently are capable of sustaining a wide variety of cold water biota, Aquatic Life including sensitive species, or (2) could sustain such biota but for correctable water quality Cold Water- conditions. Waters shall be considered capable of sustaining such biota where physical habitat, Class 1 water flows or levels, and water quality conditions result in no substantial impairment of the abundance and diversity of species. Aquatic Life These are waters that are not capable of sustaining a wide variety of cold water biota, including Cold Water- sensitive species, due to physical habitat, water flows or levels, or uncorrectable water quality Class 2 conditions that result in substantial impairment of the abundance and diversity of species. Aquatic Life These are waters that (1) currently are capable of sustaining a wide variety of warm water biota, Warm Water- including sensitive species, or (2) could sustain such biota but for correctable water quality 63

Class 1 conditions. Waters shall be considered capable of sustaining such biota where physical habitat, water flows or levels, and water quality conditions result in no substantial impairment of the abundance and diversity of species. Aquatic Life These are waters that are not capable of sustaining a wide variety of warm water biota, including Warm Water- sensitive species, due to physical habitat, water flows or levels, or uncorrectable water quality Class 2 conditions that result in substantial impairment of the abundance and diversity of species. Recreation These surface waters are suitable or intended to become suitable for recreational activities in or on Primary the water when the ingestion of small quantities of water is likely to occur. Such waters include but Contact are not limited to those used for swimming, rafting, kayaking and water-skiing. Recreation These surface waters are suitable or intended to become suitable for recreational uses on or about Secondary the water which are not included in the primary contact subcategory, including but not limited to Contact fishing and other streamside or lakeside recreation. These surface waters are suitable or intended to become suitable for potable water supplies. After Domestic receiving standard treatment (defined as coagulation, flocculation, sedimentation, filtration, and Water Source disinfection with chlorine or its equivalent) these waters would meet Colorado drinking water regulations and any revisions, amendments, or supplements thereto. Source: EPA 2014

The following is a breakdown of the major water quality issues existing within each field office and project area. These sources would be considered when planning treatment area boundaries on a local level in order to minimize impacts to impaired waters. Attachment A contains a map that shows the spatial locations of impaired watersheds within the treatment area.

CDPHE Water Quality Impairment Listings for 2016 in the Project Area

Table 5.6 - Colorado River Valley Field Office

Use Segment ID Description 303d Listing M&E Listing Classification Colorado Headwaters Agriculture Mainstem of the Colorado River Aquatic Life Aq Life Cold 1 COUCUC03 from Lake Grandy to the Roaring Temperature Dissolved Recreation E Fork River Oxygen Water Supply Agriculture Tributaries to Colorado River, Temperature Aq Life Cold 1 COLCLC04a Se Roaring Fork to Parachute Creek S04 Recreation E Water Supply Agriculture Aq Life Cold 1 COUCEA06 Tributaries to Eagle River As Recreation E Water Supply Agriculture East Rifle Creek, West Rifle Creek, Aq Life Cold 1 COLCLC10 Rifle Creek and Tributaries from As E.Coli Recreation E Rifle Gap to Colorado River Water Supply Abbreviations: As: Arsenic 64

S푶ퟒ: Sulfate Se: Selenium Source: CDPHE 2016

Table 5.7 - Grand Junction Field Office

303d Use Segment ID Description M&E Listing Listing Classification Parachute-Roan Agriculture COLCLC14 Clear Creek from Tom Creek to E. Coli Aq Life Cold 1

b Roan Creek and tributaries Fe(trec) Recreation P Water Supply Agriculture Mainstem of Roan Crk and Fe(Trec) Aq Life Warm 1 COLCLC14c tributaries from Kimball Crk to As Mn Recreation P Colorado River Water Supply Colorado Headwaters-Plateau Agriculture Plateau Creek and tributaries from Aq Life Warm 1 COLCLC16 Fe(Trec) Buzzard Crk to Colorado River Recreation E Water Supply Abbreviations: As: Arsenic Fe: Iron Mn: Manganese Source: CDPHE 2016

Table 5.8 - Kremmling Field Office

Use Segment ID Description 303d Listing M&E Listing Classification North Platte Headwaters Agriculture Fe COUCNP04 Fe Aq Life Cold 1 Canadian River E.Coli a Recreation E Mn Water Supply Agriculture COUCNP04 Aq Life Cold 1 Illinois River As Mn b Recreation E Water Supply Agriculture Cu COUCNP05 Aq Life Cold 1 Main stem of Michigan River As Fe b Recreation N Mn Water Supply Colorado Headwaters COUCUC03 Mainstem of the Colorado River As Lake Grandy to Gore Canyon 65

Blue Mainstem of Blue River from COUCBL17 Green Mountain Reservoir to Temperature Colorado River Abbreviations: As: Arsenic Cu: Copper Fe: Iron Source: CDPHE 2016

Table 5.9 - Little Snake Field Office

Use Segment ID Description 303d Listing M&E Listing Classification Little Snake Agriculture Little Snake River from Power Aq Life Cold 1 COLCLY16 Sediment Wash to Yampa River Recreation N Water Supply Vermilion Mainstem of Vermillion Crk Agriculture and tributaried from Aq Life Cold 1 COLCLY22a Colorado/Wyoming border to Aquatic Life Recreation N confluence with Talamantes

Crk Upper Yampa Agriculture Tributaries to Fortification Crk Mn Aq Life Warm 2 COLCLY06 from confluence of North and S04 Recreation P South Forks to Yampa River Water Supply Lower Yampa Agriculture Yampa River from Oak Crk to Temperature COLCLY03b Aq Life Warm 2 Elkhead Crk As Recreation P Abbreviations As: Aresenic Mn: Mangenese S푶ퟒ: Sulfate Source: CDPHE 2016

Table 5.10 - White River Field Office

Use Segment ID Description 303d Listing M&E Listing Classification Lower White Agriculture White River from confluence Aq Life Warm COLCWH12 with Piceance Crk to Douglas As 1 Crk Recreation E 66

Water Supply Agriculture Mainstem of East Douglas Aquatic Life Aq Life Cold 1 COLCWH23 Crk and West Douglas Crk Sediment Recreation E and Tributaries Temperature Water Supply Mainstem of the White River COLCWH21 from Douglas Crk to As Colorado/Utah Border Piceance-Yellow Agriculture Mn Aq Life Warm COLCWH13b Mainstem of Yellow Crk from Aquatic Life 2 source to Barcus Crk S04 Recreation P Water Supply Tributaries to Piceance Crk Agriculture from confluence of Dry Aq Life Warm COLCWH16b E. Coli Thirteen Mile Crk to White 2 River Recreation N Agriculture Mainstems of Black Sulphur Aquatic Life Aq Life Cold 1 COLCWH20 Creek to Piceance Crk source As Recreation P Water Supply Upper White Agriculture Sulfur Crk and tributaries Aq Life Cold 2 COLCWH09b from source to White River Se Recreation N

Water Supply Abbreviations: As: Arsenic Mn: Manganese S푶ퟒ: Sulfate Se: Selenium Source: CDPHE 2016

Groundwater and Water Rights

Within the project area, ground water exists within large bedrock and alluvial aquifers. The bedrock aquifers consist of the Eagle, Middle Park, North Park, Piceance, and Sand Wash Basins. Each type of aquifer has different grain size and pore space characteristics changing the hydraulic conductivity and the capacity of an aquifer to store and transmit water. The location, movement and chemical makeup of groundwater is determined by the geologic conditions of an area. Groundwater resources would be impacted by the recharge, withdrawal, and infiltration of contaminants. Bedrock aquifers exist underneath the majority of the project area and are recharged from precipitation and mountain front runoff. Alluvial aquifers within the project area are present along the larger perennial rivers and are typically composed of sand and gravel 67

deposits.

Alluvial aquifers serve as recharge and discharge zones for underlying bedrock aquifers. These aquifers contribute to year round discharge to rivers and maintain base flow conditions during low flow times of the year. Groundwater discharge occurs as a result of permeability changes at or near the ground surface as a surface expression of faults, fractures, or joints in underlying bedrock aquifers (BLM 2015). Springs and seeps are prevalent in the project area and represent groundwater delivery to the land surface. The residence time for a water molecule within these different geologic areas influences the water quality of these springs and seeps.

Throughout the project area, water rights are held on springs and are applied to beneficial uses such as wildlife and livestock watering. The Colorado Division of Water Resources (CODWR) administers and enforces the use and permitting of ground and surface water resources throughout Colorado and the project area. Using the CODWR geodatabase, one of the maps included in Attachment A shows the record of water rights for springs, wells, diversions, and developments within the project area. Some of the water rights that exist on springs have been developed into range improvements and are used for livestock watering.

Floodplains

Floodplains exist along river and stream corridors and represent an area of land that is inundated with water during peak discharge events. Floodplains support diverse vegetation habitat sustaining communities of riparian vegetation. They are essential to the proper functioning of riverine systems as riparian vegetation provides bank stability by decreasing water velocities, thereby reducing erosion. Healthy riparian vegetation contained in floodplains also help to provide suitable habitat conditions for aquatic species by providing shade to maintain appropriate water temperatures.

5.3.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts The general premise of vegetation treatments and hydrologic responses to tree removal is that favorable canopy and ground cover following tree removal would eventually reduce runoff and erosion and enhance site productivity. Amplified soil loss from woodlands occurs primarily due to interconnected runoff areas on degraded surface soils (Davenport et al. 1998). Conditions in encroaching pinyon-juniper forests promote degraded surface soils by out competing understory vegetation leaving soils free of herbaceous cover. Poor infiltration in the interspaces between trees that have outcompeted understory vegetation promotes runoff generation that concentrates into high velocity flow paths. This results in the incision of degraded surface soils and becomes a mechanism for downslope movement of precipitation and flow detached sediment. These detached sediments would be eroded into stream channels and impact water quality. Each treatment method proposed in this project has slightly different impacts on water resources and are described below. 68

Prescribed Burning

Burning activities would decrease canopy cover, therefore, limiting interception of precipitation. Reduced interception may temporarily elevate soil erosion potential due to raindrop impact associated with high intensity convective events. Furthermore, prescribed fire would consume litter and large woody debris currently contributing to surface soil stabilization. Decreased soil stabilization elevates potential sedimentation to area streams, which may deteriorate water quality. Site-specific conditions per treatment area would be identified and mitigations would be applied to reduce potential water quality impacts from increased nutrient and sediment loading near streams indicated on CDPHE water quality listings.

To minimize potential sediment and nutrient transport to nearby drainages, treatments would avoid steep slopes and drainages as stipulated in the design features. Additionally, it is anticipated that burn intensities would be moderate to low based on the fuel compositions, therefore, minimizing soil burn severity and hydrophobicity. Impacts to water quality depends on the connectivity of the treatment areas and runoff paths to nearby streams. Treatment type and erosion control design features would help minimize the effects and connectivity to stream channels. Buffers around streams and riparian vegetation are also in place to reduce water resource impacts.

Based on the distance of the treatment from area drainages, the existing slope angles where treatments would occur, and vegetative cover reestablishing post treatment, it is unlikely that sediment, contaminants, and nutrients would be transported to area water. Any potential negative impacts to water quality would be short duration and localized, making water quality degradation minimal.

Mechanical Treatments

Mechanical treatment activities would remove vegetation and could alter soil conditions through compaction and displacement associated with vehicles and equipment. These impacts would result in an increase in erosion potential, offsite sedimentation, and potential nutrient loading in area water bodies.

Mechanical treatments are expected to influence hydrology primarily by compaction and displacement of soils. Increased surface runoff from compaction may increase the potential for rilling and gullying in previously unchanneled areas and additional incising of streams channels. This process can impact water quality through sediment loading resulting in impacts to the width to depth ratios and channel substrates. Buffering stream channels per design features would help reduce the effects to water resources resulting from soil compaction and increased surface runoff. Furthermore, vegetation that is left on the ground and mulched would help catch precipitation, spread overland flow, and increase infiltration in areas where canopies have been removed. This would have a positive impact on groundwater resources as recharge would 69

increase as water infiltrates the subsurface.

Water Rights

Considering the treatments proposed for this project (e.g., prescribed burning) some of the water right developments and structures could potentially be at risk. However, with water resources buffered per design features these developments and structures should remain unaffected. Inventory of these structures before treatments should be completed in order to properly buffer them.

Floodplains

Within the project area, miles of perennial, intermittent, and ephemeral stream channels exist, of which, many of these having well established and functioning floodplains. Using a 100-year floodplain geospatial dataset, some large floodplains exist within the project area. The KFO has floodplains on the Fraser and Colorado River that are within the project area. The CRVFO has large floodplains that exist along the Colorado and Eagle Rivers.

Given the type of vegetation that typically resides in floodplains, these areas are not likely to be treated with proposed methods. Targeted vegetation such as pinyon-juniper forests do not reside in these areas, rather in upland vegetation zones, which should leave floodplains unaffected. Furthermore, the buffer for water corridors set in the design features would exclude floodplains and riparian vegetation from being burned or cut down. Cumulative Impacts Fires in late successional woodlands commonly burn at high severity, consume nearly 100% of sagebrush and herbaceous cover, reduce surface soil seed banks and cause extensive tree mortality (Pierson et al. 2015). Sagebrush in high severity fires would not resprout and can require as long as 20 years to recover post fire (Miller and Heyerdahl 2008). However, providing vegetation treatments would reduce the likelihood of high severity fires from occurring in these areas. Furthermore, according to Miller et al. (2013), fire surrogate treatments (e.g., mechanical tree mastication and cutting) can reduce shrub and herbaceous treatment related mortality. A combination of these methods would improve overall watershed and habitat conditions.

In portions of the project area, plant community transitions from sagebrush to pinyon-juniper woodlands lie within snow dominated precipitation regimes. Wind and topography in these uplands interact to redistribute falling snow, while vegetation reduces wind velocities (Marks and Winstral 2001). The encroachment of pinyon-juniper woodlands can alter catchment water balances by altering snow deposition patterns, the timing of melt, and the delivery of water to the soil. Kormos et al. (2017) state that sagebrush dominated catchments produce substantially more streamflow than juniper dominated catchments. Considering the pinyon-juniper treatments described in this project, sagebrush vegetation would expand, thus changing the snow 70

distribution patterns resulting in a greater amount of water available to soils and surface water sources. In the long term, restoring sagebrush habitat would enhance water availability within these upland catchments enhancing soil water availability and surface water flows.

Cumulative impacts of the project would be dependent upon site-specific characteristics and the severity of disturbance. Vegetation treatments in the form of prescribed fires, mechanical thinning and hand thinning have been observed to increase the amount of runoff, reduce travel times, and increase sediment loads to streams, thereby impacting water quality. It is expected that, initially following treatments, soil erosion would increase, which can impact water quality and fluvial processes. Furthermore, surface disturbing activities such as surface compaction and burning of soils would impact water infiltration characteristics, thereby impacting groundwater recharge. However, over time, thinning of pinyon-juniper canopies have shown to increase intercanopy herbaceous cover, thereby reducing erosion rates and increasing infiltration potential. By implementing design features, suitable vegetation recovery, and erosion control mitigation, erosion rates typically return to pre-treatment conditions within 1 to 2 years (Elliot et al. 2010). Therefore, despite initial short-term impacts, the long-term sustainability of sagebrush communities and the water resources nearby would benefit from these treatments.

5.3.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action alternative, water resources present in the Project area would be expected to degrade, resulting in poorer water quality. Short term negative impacts to water resources resulting from prescribed fire and heavy machinery within treatment areas would not occur and long term benefits to water quality resulting from the Proposed Action would not occur. . Cumulative Impacts Past, present, and reasonably foreseeable future actions and conditions within the Project area that have affected and would be likely to continue to affect water resources are mineral development, livestock grazing, infrastructure development, vegetation treatments, wildfires, recreation, and travel and transportation activities.

Potential cumulative impacts on water resources in the Project area would result from alteration of functional vegetative communities and could lead to increased runoff and sediment/contaminant delivery. Activities with impacts on water resources include management actions attributed to the alteration of natural vegetative communities (e.g., pinyon-juniper invasion and cheatgrass), historic grazing practices, surface-disturbing actions in areas of low reclamation potential, conversion of native rangelands to irrigated agricultural lands (on non- BLM-administered and non-National Forest System lands), improper maintenance of transportation facilities, spills/leaks of substances used to develop mineral resources, and recreational use.

These activities cause surface disturbances by removing vegetation cover, displacing and

compacting soils, and altering soil structure and chemistry. The result is exposed surfaces that increase the potential for runoff and erosion, which delivers sediment and contaminants to nearby waterways. Sedimentation in waterways can cause changes in water chemistry as well as geomorphic adjustments that could have negative effects on stream function.

Under the no action alternative, short-term water quality would remain the same, continuing with a similar disturbance regime. Over the long-term, water quality would likely degrade as understory grasses and shrubs are outcompeted and eliminated, increasing the long term erosional processes, thereby, impacting water quality. As erosion continues over time, fluvial geomorphic conditions within streams could degrade impacting the shape and function of the stream. These changes could impact habitat for aquatic and riparian species. An additional risk of the no action alternative is the increased likelihood for large, high intensity fires in these areas. Large scale and high intensity fires pose a threat to the health of watersheds and water quality. 5.4. Aquatic Wildlife 5.4.1. Affected Environment Aquatic wildlife species and their habitats are limited to perennial streams and some intermittent streams. Aquatic wildlife present in the project area varies from water birds, to amphibians, mollusks, gastropods (snails), bivalves (mussels and clams), and native and non-native fish.

Federally listed and BLM sensitive fish species are addressed in Section 5.10, Special Status Animal Species. 5.4.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Mechanical treatments have the potential to crush, alter, or directly remove riparian vegetation. Similarly, prescribed fires may result in the direct loss or modification of riparian vegetation. Removal or modification of riparian vegetation could influence channel stability (lead to increased sedimentation, increased bank erosion, etc.) and may indirectly influence some aquatic species (see discussion in Section 5.10 Special Status Animal Species) if habitat quality or prey availability is negatively influenced. Installation of stabilization/erosion control structures, seeding, and weed treatments would be buffered to protect existing riparian vegetation.

Installation of erosion control structures and wetland improvement structures would impact aquatic wildlife in the short-term and the long-term. In the short-term, aquatic wildlife may be displaced from project areas due to human presence, activity and noise while the projects are implemented. However, in the long-term, aquatic wildlife would be expected to benefit from installation of erosion control and wetland improvement structures through increases in habitat, decreases in sedimentation and turbidity.

Projects would be reviewed at the site-specific level and surface disturbance buffers would be applied for compliance with individual field office RMPs and would vary depending on the type

of resource being protected.

Design features incorporated into each treatment would be expected to minimize impacts to riparian communities. Any sedimentation following treatments would be captured and stabilized by the underlying vegetation growing up through it or removed by successive runoff events.

If it is determined that there are additional impacts to aquatic species, additional design features may be applied. Cumulative Impacts Past, present and reasonably foreseeable actions that have affected and would likely continue to affect aquatic wildlife in the project area include mineral exploration and development, industrial development, recreation, livestock grazing, wildland fires and drought.

Many of the activities described above can alter habitat conditions, which then create other habitat changes. Vegetation and habitat treatments have offset some of these effects by improving habitat productivity and health.

Cumulative removal or modification of riparian vegetation from various activities in the Project area could result in increased erosion, loss of stream bank cover, an increase in water temperature due to loss of shading, reduction in prey availability, and a reduction in stream habitat quality due to an increase in sediment loading. Cumulative beneficial impacts could also occur due to installation of erosion and wetland improvement structures that would decrease erosion, increase stream bank cover, decrease water temperatures and overall improve habitat quality for aquatic wildlife.

5.4.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Vegetation treatments and installation of erosion control/stabilization structures would not occur under this alternative. Current conditions and vegetation trends would continue to occur, which over time would continue to degrade riparian areas and wetland communities where aquatic wildlife reside. Conditions would continue to be degraded and would likely result in increased erosion, loss of stream bank cover, an increase in water temperature due to loss of shading, reduction in prey availability, and a reduction in stream habitat quality due to an increase in sediment loading under the No Action alternative. Cumulative Impacts Past, present, and reasonably foreseeable future actions and conditions within the project area that have affected and would be likely to continue to affect aquatic wildlife are mineral exploration and development, residential and industrial development (including power lines and other ROWs), forestry, grazing, recreation, road construction, water diversion and withdrawals, weed invasion and spread, prescribed and wildland fires, land planning efforts, vegetation 73

treatments, habitat improvement projects, insects and disease, and drought.

Many of the activities described above can change habitat conditions, which then cause or favor other habitat changes. For example, wildland fire removes habitat, and affected areas are more susceptible to weed invasion, soil erosion, and sedimentation of waterways, all of which degrade habitats. In general, resource use activities have cumulatively caused habitat removal, fragmentation, noise, increased human presence, and weed spread. Land planning efforts and vegetation, habitat, and weed treatments have offset some of these effects by improving habitat connectivity, productivity, diversity, and health.

Climate change could cause an increase or decrease in temperatures and precipitation, which would affect soil conditions, vegetative health, and water flows and temperature. Such changes would alter habitat conditions, potentially creating conditions that could favor certain species or communities, weeds, or pests.

Cumulative impacts from the No Action would likely result in increased impacts to aquatic wildlife through weed invasion and soil erosion, as well as increased degradation of riparian areas and wetlands where aquatic wildlife reside.

5.5. Vegetation, Wetlands and Riparian Zones 5.5.1. Affected Environment Vegetation serves multiple purposes on the landscape and provides many ecosystem benefits and services. Vegetation stabilizes soils, prevents erosion, uses carbon dioxide, releases oxygen, sequesters carbon, increases species diversity, and provides habitat and food for animals and products for human use.

Many of BLM’s land management policies are directed toward maintenance of healthy vegetation communities. Vegetation can generally be characterized by ecological provinces, and more specifically characterized by plant communities. A plant community (sometimes "phytocoenosis" or "phytocenosis") is a collection or association of plant species within a designated geographical unit, which forms a relatively uniform patch, distinguishable from neighboring patches of different vegetation types. The components of each plant community are influenced by soil type, topography, climate and human disturbance

The project area is characterized by mid-level elevations where vegetation is dominated by pinyon-juniper woodlands and sagebrush shrublands. The Wyoming Basin ecoregion is a broad intermontane basin interrupted by hills and low mountains and dominated by grasslands and shrublands. The Colorado Plateau ecoregion is an uplifted, eroded, and deeply dissected tableland with mesas, cliffs, and canyons. It has large low-lying areas with saltbush-greasewood, and more pinyon-juniper and Gambel oak (Quercus gambelii) woodlands compared to the Wyoming Basin.

A number of different vegetation communities exist within the project area, including sagebrush shrublands, riparian areas and wetlands, mountain shrub, desert shrub/scrub, grasslands, and pinyon-juniper woodlands.

Sagebrush Shrublands

Sagebrush conditions within the planning area are generally split between upper and lower elevations, with 7,000 feet representing the approximate dividing line. The higher-elevation sagebrush communities are usually composed of mountain big sagebrush (A. tridentata ssp. pauciflora) or subalpine sagebrush (A. tridentata ssp. vaseyana), sometimes in pure stands but often with serviceberry (Amelanchier spp.), mountain snowberry (Symphoricarpos rotundifolius), green rabbitbrush (Chrysothamnus viscidiflorus), or antelope bitterbrush (Purshia tridentata). The higher-elevation sagebrush tends to be very productive, shows little evidence of decadence (mature shrubs where approximately 25 percent or more of plant is dead), and shows good recruitment of young sage.

Common grass and grass-like species found in the sagebrush community include bluebunch wheatgrass (Pseudoroegneria spicata), thickspike wheatgrass (Elymus lanceolatus), Sandberg bluegrass (Poa secunda), muttongrass (Poa fendleriana), Indian ricegrass (Achnatherum hymenoides), needle and thread (Hesperostipa comata), threadleaf sedge (Carex filifolia), green needlegrass (Nassella viridula), Columbia needlegrass (Achnatherum nelsonii), wild onion (Allium spp.), and Indian paintbrush (Castilleja spp.) (BLM 2007b).

Lower-elevation sagebrush communities [Wyoming big sagebrush (A. tridentata ssp. wyomingensis) and xeric mountain big sagebrush (A. tridentata ssp. vaseyana)] consist of older stands of sagebrush that show more signs of decadence (mature shrubs where approximately 25 percent or more of plant is dead) and little recruitment. These communities often have less herbaceous cover and diversity, especially forbs, and are highly susceptible to cheatgrass (Bromus tectorum) invasion. The forb component may vary considerably with recent precipitation amounts and timing.

Sagebrush shrublands and pinyon-juniper woodlands typically exist in a dynamic equilibrium characterized by phases of invasion and dieback. These phases may be driven by any number of factors, including: fire, insect and disease infestations, grazing, and climate patterns. Pinyon- juniper woodlands tend to expand into sagebrush habitat during periods of wetter climatic conditions, during long intervals between fires or other natural disturbances, or as a result of heavy grazing which reduces competition from the grass and forb component (Eisenhart 2004).

Riparian Area and Wetlands

The riparian community includes wetlands and is associated with and depends on the presence of water during some part of the growing season. This community provides the link between aquatic and upland (dry) habitats across all elevations. Typical riparian areas are lands along, 75

adjacent to, or contiguous with perennially and intermittently flowing rivers, streams, and shores of lakes and reservoirs with stable water levels. Excluded are such sites as ephemeral streams or washes that do not exhibit vegetation dependent on free water in the soil (BLM 2004a).

Wetlands are areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support a prevalence of vegetation typically adapted for life in saturated soil conditions under normal circumstances. Wetlands include marshes, shallows, swamps, lakeshores, bogs, muskegs, wet meadows, estuaries, springs, seeps, and riparian areas (BLM 2004a).

Riparian areas and wetlands in the project area are generally small and account for a small proportion of the total acreage, but are highly productive and provide forage and cover for nearly all wildlife species at some point in their life cycle. A variety of vegetation types containing riparian zones and wetlands exist with the project area, such as: deciduous dominated forests and woodlands, tall willow shrublands, short willow shrublands, non-willow shrublands, and herbaceous vegetation (Carsey et al. 2003).

Riparian areas and wetlands are important because they improve water quality in watersheds by buffering open waterways from surface runoff that could contain sediment, toxicants, or other undesirable constituents.

The steeper-gradient riparian systems in the project area typically support aspen, willows (Salix sp.), red-osier dogwood (Cornus sericea), thinleaf alder (Alnus incana ssp. tenuifolia) and currant. Lower-gradient streams and lakes support predominantly herbaceous communities of sedges (Carex spp.), rushes (Juncus spp.), tufted hairgrass (Deschampsia cespitosa), and redtop with some narrowleaf cottonwood trees (Populus angustifolia).

Mountain Shrub

Mountain shrub communities typically include large stands of Gambel oak and other more diverse associations with Gambel oak, mountain mahogany (Cercocarpus spp.), mountain snowberry (Symphoricarpos spp.), and serviceberry (Amelanchier spp.), with scattered sagebrush, rabbitbrush, bitterbrush, kinnikinnick (Arctostaphylos spp.), currant (Ribes spp.), shrubby cinquefoil (Dasiphora fruticosa), and skunkbush sumac (Rhus trilobata).

The most common areas where mountain shrub vegetation communities are found are on northern exposures in snow pockets and along drainages where moisture is not a limiting factor. These areas are frequently located about mid-slope and may be associated with steep topography.

Although thinly scattered, mountain shrub vegetation communities provide vital forage and habitat for wildlife and livestock. Grasses typically found in this community include needle and thread, basin wildrye (Leymus cinereus), Indian ricegrass, green needlegrass, Columbia needlegrass, thickspike wheatgrass, Idaho fescue, Thurber’s fescue (Festuca thurberi), mountain 76

muhly (Muhlenbergia montana), prairie junegrass (Koeleria macrantha), slender wheatgrass (Elymus trachycaulus), Sandberg bluegrass, Kentucky bluegrass (Poa pratensis), letterman’s needlegrass (Achnatherum lettermanii), bottlebrush squirreltail, western wheatgrass (Pascopyrum smithii), beardless bluebunch wheatgrass, brome (Bromus spp.), and muttongrass.

Common forbs found in this community often include arrowleaf balsamroot (Balsamorhiza sagittata), buckwheat, Indian paintbrush, lupine (Lupinus spp.), penstemon, sego lily (Calochortus nuttallii), wild onion, larkspur (Delphinium spp.), violet (Viola spp.), bluebells (Mertensia spp.), and prickly pear cactus (BLM 2015a).

Desert Shrub/Scrub

This vegetation community is comprised of arid to semi-arid shrublands on lowland and upland sites usually at elevations between 5,000 and 7,000 feet. Sites can be found on all aspects. Slopes are typically gentle to moderately steep but are sometimes unstable and prone to surface movement. Many areas within this system are degraded due to erosion and may resemble “badlands.” Soil surface is often very barren in occurrences of this system. The interspaces between the characteristic plant clusters are commonly covered by a microphytic crust.

Dominant shrubs found in this community are drought tolerant and include Gardner’s saltbush (Atriplex gardneri), fourwing saltbush (Atriplex canescens), birdfoot sagebrush (Artemisia pedatifida), bud sagebrush (Picrothamnus desertorum), spiny hopsage (Grayia spinosa), greasewood (Sarcobatus vermiculatus), broom snakeweed (Gutierrezia sarothrae), Basin big sagebrush, rabbitbrush, and winterfat (Krascheninnikovia lanata) (BLM 2007b).

Grasses associated with these sites are Indian ricegrass, bottlebrush squirreltail, Sandberg bluegrass, bluebunch wheatgrass, needle and thread, and western wheatgrass (BLM 2007b).

Forbs include wild onion, biscuitroot (Lomatium spp.), woody aster (Xylorhiza spp.), globemallow, and prickly pear cactus (BLM 2015a).

Grasslands

Native grasslands within the project area generally consist of dry grasslands. The dry grasslands are found in small isolated areas, often on exposed ridges or hilltops, where winds reduce available moisture and prevent shrub growth. Soils at these sites are generally very shallow and include a high percentage of rocks or cobbles. Most of these areas are actively grazed by livestock and wildlife and are dominated by grasses like Colorado wildrye (Leymus ambiguus), saline wildrye (Leymus salinus), Indian ricegrass, bottlebrush squirreltail, western wheatgrass, beardless bluebunch wheatgrass, Sandberg bluegrass, brome, arrowleaf balsamroot, buckwheat, and penstemon. Many lower-elevation grasslands are degraded and are dominated by cheatgrass (BLM 2015a).

Pinyon-juniper Woodlands

Pinyon-juniper woodlands are mostly found between 5,200 and 8,000 feet on somewhat xeric ridgetops. These woodlands vary from an open to closed canopy with a highly variable understory of shrubs and herbaceous plants. Old growth pinyon-juniper and areas with a greater dominance of juniper generally have less understory vegetation. Dominant plants in this community include pinyon pine, Utah juniper, Gambel oak, sagebrush, mountain mahogany, and many of the herbaceous species listed under the sagebrush steppe community (BLM 2015a).

Table 5.11 lists a description of the specific plant communities present in the project area in each field office below.

Table 5.11 – Vegetation Communities by Field Office in the Project Area

BLM-Managed Acres Vegetation Community CRVFO WRFO GJFO LSFO KFO Total Pinyon- Juniper 198,200 636,200 539,900 261,100 7,000 1,642,400 Woodland

Sagebrush 86,700 456,600 83,900 387,500 270,700 1,285,400 shrubland

Mountain 65,900 102,300 160,700 154,400 500 483,800 shrubland Gambel oak 49,000 0 0 0 0 49,000 woodlands Grasslands 12,200 74,400 0 11,800 5,900 104,300 Desert 2,400 100,400 174,700 435,600 600 713,700 Shrublands Riparian areas 4,000 9,500 9,800 6,800 2,900 33,000 and Wetlands

TOTAL 418,400 1,379,400 969,000 1,257,200 287,600 4,311,600

Source: BLM 2017

Colorado River Valley Field Office

In the CRVFO, there are seven general plant communities targeted in the Proposed Action. The table below shows each of the pertinent plant communities in CRVFO as well as an approximate acreage breakdown. The CRVFO portion of the project area is dominated by pinyon-juniper 78

woodland and sagebrush shrubland.

A detailed description of each of these plant communities and their current description are described in the CRVFO Proposed RMP and Final EIS (BLM 2015c) and in the Roan Plateau Planning Area Proposed RMP Amendment and Final EIS (BLM 2016b) and are incorporated here by reference.

White River Field Office In the WRFO, there are six general plant communities targeted in the Proposed Action. The table below shows each of the pertinent plant communities in the WRFO as well as an approximate acreage breakdown. The WRFO portion of the project area is dominated by pinyon-juniper woodland and sagebrush shrubland.

A detailed description of the plant communities within the field office is described in the White River Field Office Proposed Resource Management Plan Amendment and Final Environmental Impact Statement for Oil and Gas development (BLM 2015f) and is incorporated here by reference.

Grand Junction Field Office In the GJFO, there are five general plant communities targeted in the Proposed Action. The table below shows each of the pertinent plant communities in the GJFO as well as an approximate acreage breakdown. The GJFO portion of the project area is dominated by pinyon- juniper woodland and salt-desert shrubland.

A detailed analysis of each of the vegetation communities and associated species is described in the Grand Junction Field Office Proposed Resource Management Plan and Final Environmental Impact Statement (BLM 2015e) and is incorporated here by reference.

Little Snake Field Office In the LSFO, there are six general plant communities targeted in the Proposed Action. The table below shows each of the pertinent plant communities in the LSFO as well as an approximate acreage breakdown. The LSFO portion of the project area is dominated by salt- desert shrubland and pinyon-juniper woodland.

A detailed description of the vegetation communities and associated species is described in the Little Snake Proposed RMP Final Environmental Impact Statement (BLM 2007b) and is incorporated here by reference.

Kremmling Field Office In the KFO, there are six general plant communities targeted in the Proposed Action. The table below shows each of the pertinent plant communities in the KFO as well as an approximate acreage breakdown. The KFO portion of the project area is dominated by sagebrush shrubland and pinyon-juniper woodland. 79

A detailed description of the vegetation communities and associated species is described in the Kremmling Field Office Proposed Resource Management Plan and Final Environmental Impact Statement (BLM 2013) and is incorporated by reference.

5.5.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Impacts from the Proposed Action would include the direct loss of vegetation from mechanical treatments and/or prescribed fire as well as trampling and crushing of vegetation during project implementation. Mechanical treatments are generally targeted more at woody species such as pinyon-juniper, big sagebrush, and various mountain shrubland species.

Impacts to herbaceous vegetation would generally be limited to impacts from trampling and crushing from equipment. Prescribed fire is usually less targeted and would burn all vegetation types during implementation. However, in the long-term, prescribed fire would be expected to benefit the local vegetation.

Targeted mechanical treatments on woody species would be expected to eliminate them from the site for 15-30 years for shrub species and 30-40 years for pinyon-juniper. In sites where pinyon- juniper is present, it may take 100+ years for the pinyon-juniper to return to pre-treatment levels. Herbaceous species impacted by prescribed fire would generally start to re-establish almost immediately following treatment depending on the time of year the fire occurred and generally would reach pre-treatment level within 2-5 years following the treatment assuming the community is healthy and has an adequate amount of native vegetation, and sufficient seed bank prior to the treatment. In instances where the plant community is not as healthy and there is a strong component of annual invasive species prior to treatment, the site would quickly become dominated by annual invasive species and there is a risk of that area becoming a monoculture of undesirable species.

Where pinyon-juniper trees have encroached into sagebrush shrublands, they tend to suppress grass, forb, and shrub growth under the tree canopy. The mulching equipment would be mounted to a rubber-tired tractor. Mulching would not occur when the soils are saturated, so that surface disturbance and damage to non-target vegetation would be minimized. In the mechanical treatment areas, the woody mulch created by mastication of the trees would bury some herbaceous plants in the vicinity of the trees which may result in some mortality. This loss of vegetation would be temporary and short-term in nature.

Residual mulch piles would retain moisture and provide suitable microclimates for seedling establishment. Forbs, grasses, and sagebrush have been observed growing in the mulch from masticated pinyon and juniper trees the first growing season following fall/winter treatments. Furthermore, the mulch would be expected to begin to decompose within a year or two following treatment and the removal of competition from the encroaching trees should promote a long-term 80

increase in the cover of grasses, forbs and shrubs in the area.

In the areas identified for hand-cutting, pinyon and juniper trees would be cut and lopped with chainsaws which should result in minimal soil disturbance and therefore, should create negligible damage to any non-target plants in the area. Some plants may be buried by the downed trees. As the needles fall off the trees and the woody material begins to decompose, the understory plants are expected to increase.

Post-treatment seeding would be expected to improve the recovery of treated sites, especially in areas when there are concerns about the pre-treatment conditions of the site due to the presence of invasive annual species. During seeding operations, there is the potential for vegetation to be crushed from drill seeders or other ground seeding methods, however, these areas would expect to experience a net gain in vegetation cover and production from seeding.

Installation of stabilization and erosion control structures would cause impacts to wetlands and riparian zones through soil compaction from machinery and foot traffic. A minimal loss of riparian vegetation would also occur during the installation of Zeedyk structures, when rocks and other native materials are anchored into the channel. These impacts would be expected to be short-term in nature. Long-term, wetlands and riparian zones would benefit from decreased erosion and would be expected to experience an increase in species richness due to the expected increases in water saturation.

Drought conditions could cause more severe soil-moisture deficits which would reduce vegetative vigor, therefore making vegetation more susceptible to secondary effects such as insect infestation or disease. Deferring implementation of vegetation treatments until more conducive conditions persist would make the projects more successful in meeting defined project goals and objectives and could re-prioritize funding to other projects where drought would not decrease project effectiveness.

Removal of vegetation from prescribed burning could result in wetlands and riparian zones being more susceptible erosion/excessive soil loss. If there is a heavy precipitation event following a treatment, large amounts of sediment could potentially runoff the project area and be deposited into riparian systems and wetlands. Large sediment loads deposited into riparian systems could crush and cover riparian species and put the system out of balance leaving the system susceptible to future precipitation events and reducing bank stability in the riparian system. Design features buffering treatments from riparian areas and limiting vegetation treatments on steep slopes would help to minimize impacts to riparian systems.

In general, vegetation treatments would temporarily remove vegetation from project areas creating a short-term decrease in overall production. However, long-term benefits from the removal of decadent vegetation, woody species, seeding activities and installation of erosion and stabilization structures would provide an increase of overall plant community health and production if sites are carefully selected, and follow-up seedlings and weed treatments are 81

completed to ensure recovery of the plant community. Cumulative Impacts Past and present impacts to vegetation communities in the project areas are primarily related to industrial development, travel and transportation, recreation, historic vegetation manipulations (e.g., chaining, prescribed burns, and mechanical treatments) and improper livestock grazing. These projects would all be expected to continue into the future and would continue to impact vegetation communities in the by creating conditions that cause vegetation changes, locally or potentially at a landscape scale. For example, wildland fire could cause a large-scale conversion of native vegetation to non-native invasive species.

Many of these activities could create conditions that would cause or favor other vegetation changes. For example, wildland fire causes vegetation removal, which makes affected areas more susceptible to weed invasion and soil erosion.

Drought conditions could reduce vegetative health, which would make vegetation prone to insect infestation or disease. In general, resource use activities have cumulatively caused vegetation removal, fragmentation, weed spread, soil compaction, and erosion, whereas land planning efforts and vegetation and weed treatments have countered these effects by improving vegetative connectivity, productivity, diversity, and health.

Climate change within the cumulative impact analysis area could cause an increase or decrease in temperatures and precipitation, which would affect soil conditions, vegetative health, and water availability. Such changes would alter the conditions to which vegetative communities are adapted, potentially creating conditions that could favor certain species or communities, weeds, or pests.

Warmer temperatures and uncertain annual precipitation amounts associated with climate change could have profound impacts and could either change or re-arrange plant community species composition. Including “climate-smart” concepts where potential future conditions of vegetation communities are considered would reduce impacts over the long term. For example, it may be necessary to facilitate or assist the movement of species across the landscape as plant communities change.

Cumulative impacts from the Proposed Action would include short-term losses in herbaceous cover and more long-term impacts to shrublands and pinyon-juniper woodlands; however, the long-term impacts of vegetation treatments by reducing old decadent vegetation from the plant communities would create a more diverse age-class structure and lead to an overall increase in overall plant health and productivity.

5.5.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the no action alternative, no vegetation treatments or installation of erosion control/stabilization structures would occur. No impacts or benefits to vegetation would be realized. As the current activities continued, the project area would become more degraded.

Cumulative Impacts See the description of past, present and reasonably foreseeable future actions above.

Cumulative effects for the No Action Alternative would be greater than those described above for the Proposed Action. Cumulative impacts from the No Action would include continued degradation of sagebrush communities, riparian areas and wetlands. It is anticipated that past and present impacts from activities such as mineral development, recreation, and livestock grazing would continue to occur, causing continued impacts to vegetation, wetlands and riparian zones in the project area. 5.6. Invasive, Non-Native Species 5.6.1. Affected Environment The Colorado Noxious Weed Act classifies species into three categories; List A, List B, and List C. List A species are designated by the commissioner for eradication (CWMA 2009). List B noxious weeds have, or would have, a state noxious weed management plan developed to stop their spread. List C species are species which parties will develop and implement state noxious weed management plans designed to support the efforts of local governing bodies to facilitate more effective integrated weed management on private and public lands. The goal of such plans would not be to stop the continued spread of these species but to provide additional education, research, and biological control resources to jurisdictions that choose to require management of List C species.

Grand Junction Field Office In 2000, GJFO began a comprehensive inventory for noxious weeds throughout the resource area. By the end of the 2004 field season, GJFO had completed the process with the exception of Gunnison and Dolores River floodplains. The survey revealed approximately 20 species of noxious weeds present within the field office in approximately 8,000 locations scattered throughout the field office.

As of 2008, the GJFO has treated 15,000 sites for noxious weeds. This figure is higher than the original 8,000 sites discovered because weed crews are continuously finding more sites as they thoroughly go through sites to treat for noxious weeds.

A detailed description of the noxious weeds present and treatment methods approved in the 83

GJFO can be found in the Grand Junction Field Office Proposed Resource Management Plan and Environmental Impact Statement (BLM 2015e) and is incorporated by reference into this EA.

White River Field Office Plants identified as invasive, non-native plant species (INPS) are invasive and not indigenous to the area. Typically, INPS are detrimental to native ecosystems and human welfare. Of the 72 species identified by the state of Colorado as noxious weeds under the Colorado Noxious Weed Act, 22 of those species are known to occur within the WRFO.

The WRFO manages weeds using the tools analyzed in the Vegetation Treatments Using Herbicides on Bureau of Land Management Land in 17 Western States Programmatic Environmental Impact Statement (BLM 2016), and the White River Field Office Integrated Weed Management Plan (BLM 2010).

A detailed description of affected environment for noxious and non-native weeds within the WRFO is described in the White River Field Office Proposed Resource Management Plant Amendment and Final Environmental Impact Statement for Oil and Gas development (BLM 2015f), and is incorporated here by reference.

Little Snake Field Office A systematic weed inventory has not yet been completed in the LSFO; however, downy brome (cheatgrass) is the most common noxious weed found in the LSFO. Downy Brome is present throughout the field office at varying levels in all plant community types. Hoary cress and Canada thistle are the most abundant List B noxious weeds within the LSFO along with Russian knapweed, leafy spurge, houndstongue, dalmation toadflax, yellow toadflax, spotted knapweed, and various biennial thistles.

A comprehensive description of the affected environment is found in the Little Snake Field Office Integrated Weed Management Plan (BLM 2009a) and is incorporated here by reference.

Colorado River Valley Field Office The CRVFO’s treatment of invasive and noxious weeds is guided by the BLM’s Final Programmatic Environmental Impact Statement for Vegetation Treatment on Bureau of Land Management Lands in 17 Western States (BLM 2016) and the Integrated Weed Management Plan and Programmatic Environmental Assessment for the Glenwood Springs Field Office (BLM 2009b) and the Colorado Noxious Weed Act.

Inventories for, and treatment of noxious weeds are an ongoing activity for CRVFO. Currently, the CRVFO treats approximately 800 acres/year for noxious and invasive weeds.

A detailed description of the affected environment for noxious and invasive weeds within CRVFO is outlined described in the Colorado River Valley Field Office Proposed RMP and Final EIS (BLM 2015c) and is incorporated here by reference. 84

Kremmling Field Office The KFO has been contracting and cooperating with Eagle, Grand, Jackson, and Larimer counties for weed inventory and control efforts. The KFO routinely works with each county on weed inventory and control efforts through cooperative agreements and contracts.

There are widely scattered invasive plants throughout the KFO portion of the project area that are increasing in area and density but, in general, their presence is limited to small infestations.

Some of the more common weeds found in the KFO include Musk thistle, Canada thistle, Houndstongue, Corn chamomile, Black henbane, Diffuse knapweed, Leafy spurge, Whitetop, Oxeye daisy, bindweed, Platte thistle, Orange hawkweed, Dalmatian toadflax, Russian knapweed and Bull thistle.

A detailed description of the affected environment and weeds present within the KFO is discussed in the KFO Proposed Resource Management Plan and Environmental Impact Statement (BLM 2013) and the Weed Management for the Kremmling Field Office Environmental Assessment (CO-12-2008-31-EA, Pg. 18) and is incorporated here by reference. 5.6.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Any treatment projects that would disturb native vegetative communities that compete with noxious and invasive weeds would provide an opportunity for undesirable species to establish and proliferate in the project area. There is also the possibility for noxious and invasive weed seeds and propagules to be introduced to project areas on equipment and vehicles used for the project.

Seeding efforts would directly affect non-native vegetation by introducing native vegetation species to compete for resources.

Non-native, invasive species often act as fine, flashy fuels that would rapidly spread and intensify a fire. Reductions of these species as part of any proposed treatment would help reduce wildland fires and help contain wildland fires that may occur.

If left unmanaged, undesirable species can quickly become established and become a significant part of the plant community and in extreme circumstances can form a monoculture of noxious and/or invasive weeds (e.g., cheatgrass).

The design feature described in the Proposed Action would minimize the risk of weed establishment and proliferation in the project area. Cumulative Impacts Past, present and reasonably foreseeable future actions that have affected and would likely 85

continue to affect non-native and invasive species include: wildfires, surface-disturbing activities, increased recreational demands, and protections for sensitive resources.

While protections are in place such as Integrated Weed Management plans, early detection rapid response (EDRR), washing of equipment, as development for oil and gas activities, increased recreational demands, and livestock grazing continue, it is expected that new infestations of noxious weeds would continue to occur within the project area, especially immediately adjacent to high use areas.

Continued monitoring and management, including integrated weed management approaches and monitoring of treatments prior to and after treatment would need to continue to manage the spread of noxious weeds. The Proposed Action would cumulatively have more impacts to invasive species through treatments designed to increase the number and diversity of grass, forb and shrub species in sagebrush communities, riparian areas and wetlands. 5.6.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, no treatments would occur. There would be no new opportunities for weed invasion in the project area. No direct impacts to invasive, non-native species would be expected to occur. Cumulative Impacts See the description of past, present and reasonably foreseeable future projects above under section 5.6.2.

Cumulative effects for the No Action Alternative would be expected to be greater than those cumulative effects described above for the Proposed Action. Impacts from non-native species invasions would continue to occur under the No Action alternative, combined with impacts from activities such as mineral development, recreation, and livestock grazing which would continue to occur providing opportunity for the continued establishment and spread of noxious weeds in the project area.

5.7. Migratory Birds 5.7.1. Affected Environment The Migratory Bird Treaty Act (MBTA) provides protections to native birds, with the exception of certain upland fowl managed by state wildlife agencies for hunting. Within the context of the MBTA, migratory birds include non-migratory resident species as well as true migrants. For most migrant and resident species, nesting habitat is critical for supporting reproduction in terms of both nest sites and food. Also, because birds are generally territorial during the nesting season, their ability to access and utilize sufficient food is limited by the quality of the occupied territory. During non-breeding seasons, birds are generally non-territorial and able to feed across

a larger area and wider range of habitats.

The project area provides cover, forage, breeding, and/or nesting habitat for a variety of migratory birds that summer, winter, or migrate through the area. Migratory bird species that are federally listed or classified by the BLM as sensitive species are addressed in the Special Status Animal Species Section.

BLM Instruction Memorandum No. 2008-050 provides guidance toward meeting the BLM’s responsibilities under the MBTA and the Executive Order 13186. The guidance directs BLM field offices to promote the maintenance and improvement of habitat quantity and quality and to avoid, reduce or mitigate adverse impacts on the habitats of migratory bird species of conservation concern to the extent feasible, and in a manner consistent with regional or statewide bird conservation priorities.

The 1988 amendment to the Fish and Wildlife Conservation Act mandates the USFWS to “identify species, subspecies, and populations of all migratory nongame birds that, without additional conservation actions, are likely to become candidates for listing under the Endangered Species Act (ESA) of 1973.” The Birds of Conservation Concern 2008 (USFWS 2008) is the most recent effort to carry out this mandate. Northwest Colorado is within the Northern Rockies Conservation Region 10 and Southern Rockies/Colorado Plateau Bird Conservation Region 16.

The project area includes the following plant communities and potentially associated migratory bird species.

Pinyon-juniper Woodlands. Pinyon and juniper trees provide food, cover and nest sites for numerous migratory birds. Species on the Birds of Conservation Concern (BCC) list that occur in the project area and are associated with pinyon-juniper woodlands include the pinyon jay (Gymnorhinus cyanocephalus), juniper titmouse (Baeolophus ridgwayigra) and Ferruginous Hawk (Buteo regalis). Other migratory species associated with this plant community within the project area include the broad-tailed hummingbird (Selasphorus platycercus), black-chinned hummingbird (Archilochus alexandri), Say’s phoebe (Sayornis saya), ash-throated flycatcher (Myiarchus cinerascens), gray flycatcher (Empidonax wrightii), Townsend’s solitaire (Myadestes townsendi), American robin (Turdus migratorius), Western bluebird (Sialia Mexicana), mountain bluebird (S. currucoides), bushtit (Psaltriparus minimus), blue-gray gnatcatcher (Polioptila caerulea), plumbeous vireo (Vireo plumbeus), Western scrub-jay (Aphelocoma californica), Clarks’s nutcracker (Nucifraga columbiana), black-throated gray warbler (Dendroica nigrescens), Virginia’s warbler (Oreothlypis virginiae), chipping sparrow (Spizella passerina), lesser goldfinch (Spinus psaltria) and house finch (Haemorhous mexicanus). Winter visitors to pinyon-juniper habitats include the Cassin’s finch (Carpodacus cassinii), a BCC species, which typically nests in montane and subalpine forests, though occasionally nests in pinyon-juniper woodlands.

Sagebrush Shrublands. Sagebrush and the associated native perennial grasses and forbs provide 87

food, cover and nest sites for migratory birds. Sagebrush obligates that potentially occur in northwest Colorado include the sagebrush sparrow (Artemisiospiza nevadensis), sage thrasher (Oreoscoptes montanus) and Brewer’s sparrow (Spizella breweri), a BCC species. Other migratory species associated with sagebrush shrublands include the western kingbird (Tyrannus verticalis), western meadowlark (Sturnella neglecta), green-tailed towhee (Pipilo chlorurus), vesper sparrow (Pooecetes gramineus) and lark sparrow (Chondestes grammacus). Some species are associated with both pinyon-juniper woodlands and sagebrush shrublands, including the Say’s phoebe and gray flycatcher.

Mountain Shrublands. The vegetation of mixed mountain shrublands varies substantially depending on elevation, slope, aspect, and soil. More mesic (moist) sites such as on north-facing slopes and along minor drainages are typically dominated by Gambel’s oak and serviceberry, while more xeric (dry) sites such as south-facing slopes are typically dominated by mountain- mahogany, bitterbrush, snowberry, and sagebrush. The dense cover, tall height, and abundant acorns and berries of mesic oak-serviceberry stands provide cover, forage, and nesting habitat for numerous species including spotted towhees (Pipilo maculatus), Virginia’s warblers (Oreothlypis virginiae), black-headed grosbeaks (Pheucticus melanocephalus), black-billed magpies (Pica hudsonia), broad-tailed hummingbirds (Selasphorus platycercus), green-tailed towhees (Pipilo chlorurus), mourning doves (Zenaida macroura), Western scrub-jays (Aphelocoma californica) and lazuli buntings (Passerina amoena).

Raptors. Many raptors forage over wide areas, so even if they aren’t known to nest in a specific area, they may still fly over searching for food. Raptors on the BCC list that occur in northwest Colorado include the golden eagle (Aquila chrysaetos), Bald Eagle (Haliaeetus leucocephalus), Ferruginous Hawk (Buteo regalis), prairie falcon (Falco mexicanus), peregrine falcon (F. peregrinus) and flammulated owl (Psiloscops flammeolus). Prairie falcons nest on rocky ledges and cliffs and hunt in grasslands and semi-desert shrublands. Peregrine falcons hunt near nest sites and along rivers and lakes, but can be found in nearly any open vegetation community during migration and winter. Flammulated owls typically nest in ponderosa pine and aspen forests, but have been found nesting in mixed forests, and reportedly use old-growth pinyon- juniper woodlands.

A variety of raptors not on the BCC list are known to occur in northwest Colorado including the American kestrel (Falco sparverius), northern harrier (Circus cyaneus), Cooper’s hawk (Accipiter cooperii), sharp-shinned hawk (Accipiter striatus), red-tailed hawk (Buteo jamaicensis), long-eared owl (Asio otus), great horned owl (Bubo virginianus), northern pygmy owl (Glaucidium gnoma) and northern saw-whet owl (Aegolius acadius). The northern goshawk (Accipiter gentilis), a BLM sensitive species, is an occasional winter visitor to pinyon-juniper woodlands from its nesting habitat in montane and subalpine forests. 5.7.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Since project activities would not be permitted during the nesting period (May 15 – July 15), 88

there would be little chance of take from the treatments. Individual birds would likely be displaced from the area during project implementation due to machinery, noise, smoke, and human presence. This disturbance would be minimal and short in duration.

Some migratory bird species use local habitats dominated by sagebrush for portions of their seasonal needs. The removal of encroaching pinyon and juniper trees would help maintain contiguous blocks of sagebrush habitat. Besides improving conditions for greater sage-grouse, increases in distribution and local abundance could be expected for sagebrush sparrows, sage thrashers, and Brewer’s sparrows as well as other species that nest and rear young in sagebrush- dominated habitats (Braun 2005).

Any birds remaining in the project areas during the vegetation treatments would likely be temporarily displaced to nearby habitats due to machinery, noise, smoke, and human presence. Young of the year and adults would be expected to avoid the machinery. Heavy equipment could incidentally crush some plants while moving through the project area. Although there is potential for short-term impacts to sagebrush, sagebrush shrubland habitat would increase over time, improving conditions for species using this habitat.

The removal of pinyon-juniper trees could have some negative impacts to pinyon-juniper obligate species, such as pinyon jay, gray vireo, and juniper titmouse. However, these Phase I and Phase II trees (Miller et. al. 2008) targeted for mechanical treatment would most likely be younger, smaller and encroaching into areas that were historically dominated by sagebrush. Birds using pinyon and juniper trees in the project areas would be displaced to nearby pinyon- juniper woodlands. Old growth pinyon-juniper woodlands that likely exist adjacent to treatment areas and provide more suitable habitat for these species. The removal of scattered encroaching trees should minimally impact migratory birds, as species selecting pinyon and juniper trees typically prefer mature woodlands that produce seed crops and provide better security.

Raptors should not be affected as an abundance of upland foraging habitat exists in the general area. Individual project areas would be surveyed for raptor nests prior to implementation. Suitable raptor perch trees would be removed, but this should have no measurable impact to wide-ranging raptors.

Due to the timing of any treatment, short-term impacts from machinery, noise, and human presence would be minimal and not affect migratory bird populations. Mechanical mastication work should be completed prior to May 15, the start of the core breeding period for the majority of migratory birds in the project areas. Bird surveys would be conducted prior to any surface disturbing activities conducted between May 15 and July 15 to avoid the destruction of active nests for Birds of Conservation Concern. Cumulative Impacts Past, present, and reasonably foreseeable future actions and conditions within the project area that have affected and would be likely to continue to affect migratory birds include: mineral

exploration and development, residential and industrial development (including power lines and other ROWs), forestry, grazing, recreation, road construction, water diversion and withdrawals, weed invasion and spread, prescribed and wildland fires, land planning efforts, vegetation treatments, habitat improvement projects, insects and disease, and drought.

The treatments under the Proposed Action would be expected to provide long-term cumulative benefits to migratory birds through overall improvements to sagebrush shrublands, riparian areas and wetlands. These improvements would benefit migratory birds through increases in cover, nesting habitat and food sources. 5.7.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, no treatments would occur, and no impacts, whether they are short-term disturbances such as human presence and noise, or long-term benefits such as improved riparian habitats and increases in grass and forb density, to migratory birds would occur. Cumulative Impacts See the description of past, present and reasonably foreseeable future actions that could impact migratory birds above in Section 5.7.2. The No Action would be expected to result in cumulative adverse impacts to migratory birds through the continued degradation of sagebrush shrublands and riparian areas. 5.8. Terrestrial Wildlife 5.8.1. Affected Environment The Proposed Action spans a wide array of vegetation types and elevation ranges. In general, the project area is largely comprised of basin, Wyoming, and to a lesser extent mountain big sagebrush communities, mountain shrub communities (chokecherry, serviceberry, snowberry, 90

Gambel oak, bitterbrush), pinyon-juniper woodlands (see Vegetation section for a more detailed description). Each habitat type provides food, cover and shelter for a variety of mammal, bird and reptile species common to northwest Colorado.

Big Game Mule deer (Odocoileus hemionus), Rocky Mountain elk (Cervus elaphus nelsonii), moose (Alces alces) and pronghorn (Antilocapra americana) are recreationally important species that occur in the project area. BLM managed lands provide a large portion of the undeveloped habitat for big game in Colorado. Mule deer and elk typically occupy higher elevation, forested areas during summer and migrate to lower elevation sagebrush-dominated ridges and south-facing slopes during winter. CPW maintains maps of habitat for big game and other wildlife species. Winter range is often considered the most limiting habitat type for mule deer, so effective management of these areas is particularly important to the health of deer populations.

Other Mammals Numerous small mammals could reside within the planning area, including mice, woodrats, ground squirrels, chipmunks, bats, rabbits and hares, skunks, raccoons, and porcupines. Many of these mammals are prey for raptors and larger carnivores. Larger carnivores expected to occur include fox (Vulpes vulpes), bobcats (Lynx rufus), coyotes (Canis latrans), mountain lion (Puma concolor), and black bear (Ursus americanus).

Reptiles Reptile species most likely to occur in the planning area include sagebrush, prairie, plateau, tree lizards, gopher snakes or bull snakes (Pituophis catenifer sayi) and western terrestrial garter snakes (Thamnophis elegans). Gopher snakes can be found throughout Colorado in most plant communities, including riparian areas, semidesert and mountain shrublands, pinyon-juniper woodlands, and ponderosa pine and other montane woodlands. Western terrestrial garter snakes occur throughout most of western Colorado, usually below 11,000 feet. Smooth green snakes (Opheodrys vernalis) can be present in riparian areas, but in western Colorado, may also be common in mountain shrublands far from water (Hammerson 1999). 5.8.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Impacts to terrestrial wildlife would vary depending on the size and location of the treatment area, habitat type involved and the type and timing of the treatment.

Big Game Big game distribution and habitat use varies greatly throughout the year and across summer, winter and transitional ranges. As a result, CPW manages big game herds in geographic areas DAUs (data analysis units) that represents the year-around range of a mule deer or elk herd and includes all of the seasonal ranges of that specific herd.

The BLM would work with CPW when designing treatment projects to ensure consistency with 91

the West Slope Colorado Mule Deer Strategy (CPW 2014).

Effects of Conifer Encroachment on Hydrology and Deer Forage. Pinyon and juniper encroachment into sagebrush shrublands can negatively impact mule deer and elk as well as other wildlife species that use sagebrush shrublands because the woodlands can (1) alter on-site hydrologic processes (e.g., surface runoff, soil infiltration and moisture, evaporation, and transpiration) as well as (2) reduce the production of shrub and herbaceous species.

Encroaching conifers can absorb large amounts of water, making it unavailable to other plants, alter soil acidity, shade out understory plants, and compete with understory plants for nutrients, eventually reducing forage for big game and other wildlife (Sage Grouse Initiative 2014). Dense conifer canopies can prevent snow from reaching the ground, minimizing moisture that would otherwise be available from snowmelt (Watkins et al. 2007).

Recent research suggests that removing encroaching conifer stands from sagebrush ecosystems can improve water availability. Snow typically has a more uniform distribution with less drifting in a conifer-covered landscape. Conversely, snow distribution is more varied in sagebrush dominated landscapes. This is because as wind blows across a sagebrush dominated landscape, the varied topography causes snow to drift in some places, while other areas are more windswept and accumulate less snow. Areas with drifted snow hold water for longer periods of time in most years, resulting in more diverse grasses and forbs and higher quality forage and habitat for many wildlife species. Wintering big game can access sagebrush in windswept areas, and during summer, benefit from greater forage diversity and quality in areas where snow drifted and water was retained longer into the spring (Kormos et al. 2016, Sage Grouse Initiative 2016).

Big Game Thermal and Escape Cover. Pinyon and juniper woodlands provide important thermal and escape cover for mule deer, and the Proposed Action would result in the removal of these trees from some of the Project area. However, pinyon and juniper woodlands and oakbrush are abundant throughout the Project area. Although there would be less thermal and hiding cover in the treated areas, mule deer and elk would be expected to benefit from improved forage.

Big Game Displacement. Big game and other wildlife could temporarily disperse to nearby areas in response to the mechanical equipment, noise, and human presence during project implementation. However, observations by landowners, CPW staff and BLM staff have indicated that deer and elk will feed in close proximity to mechanical equipment during winter months. Tracks in the snow indicate that animals also use these areas at night. Therefore, the diurnal use of heavy equipment is not expected to deter wintering big game from the any project area for the duration of project implementation. Treatments would not start until coordination with CPW has occurred regarding Colorado big game rifle hunting season, so impacts to big game hunting would be expected to be minimal.

Damage to Sagebrush Shrublands. Although heavy equipment can damage sagebrush, post- treatment monitoring has observed only minimal damage in past treatments. 92

Pinyon-juniper woodlands and mountain shrub communities (e.g., Gambel oak) that provide hiding and thermal cover are abundant across the Project area. Although the removal of some encroaching pinyon and juniper trees would convert some thermal and hiding cover to foraging areas, the benefits of increasing the quality and quantity of foraging areas, particularly in big game winter range and severe winter range, would outweigh the loss of some cover. It is unlikely that abundant thermal and hiding cover was available historically in sagebrush shrublands experiencing Phase I and Phase II conifer encroachment. Cover would still be readily available in mature pinyon-juniper woodlands and other untreated areas. This type of vegetation treatment is consistent with the CPW Mule Deer Strategy.

Terrestrial Wildlife in General

Mechanical Treatments Mechanical treatments, and to a lesser extent, stabilization/erosion control structures, seedings, and weed treatments, would remove or alter vegetation. This would affect forage and cover availability for a variety of terrestrial wildlife species. Machinery, noise, and human presence would displace wildlife using the area, but the displacement would be localized and short term. In most cases wildlife would be expected to return to the surrounding area once the treatment is complete.

Generally, sagebrush communities can vary in the time it takes for them to return to a state functionally capable of providing cover or forage for terrestrial wildlife, but treatments would be aimed at restoring these communities as fast as possible, so that beneficial impacts to terrestrial wildlife could be realized.

Mechanical treatments would likely result in the crushing of herbaceous vegetation, but would not be expected to result in a substantial loss of ground cover.

Prescribed Burning In general, fuels treatments can have short term and long-term impacts on terrestrial wildlife by removing or degrading habitat, displacing wildlife, causing avoidance of otherwise functional habitats in close proximity to the treatment area and causing changes in movement patterns. There would also be potential for injury or mortality, particularly to slow-moving species. Conversely, fuels treatments may provide short-term benefits to those species that depend on younger seral stages. In the long term, treatments may lead to an increase in herbaceous plant productivity and diversity, resulting in additional or better quality forage and cover resources for both big game and other wildlife species.

The invasion of undesirable plant species would be of concern for both fire and mechanical treatments. Noxious and invasive plant species are generally of lower value to wildlife nutritionally and functionally (i.e., as a form of cover). Design features outlined in the Proposed Action would be expected to reduce the spread of noxious weeds and other annual species.

Design features of the Proposed Action that would avoid treatments during critical timeframes (big game calving and winter periods, etc.) would minimize impacts to terrestrial wildlife. Cumulative Impacts Activities currently occurring, that have occurred in the past and that would reasonably continue into the future that would impact terrestrial wildlife in the project area include: oil and gas exploration and development, grazing, and recreational uses such as hunting.

Treatments would be expected to provide both short-term cumulative impacts and long term cumulative benefits to terrestrial wildlife depending on the species. Cumulatively across the DAUs, the viability of big game herds would not be reduced or jeopardized due to slight overall changes in the cover/forage ratios. 5.8.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action alternative, terrestrial wildlife would not be impacted either negatively or beneficially because none of the treatments or installation of erosion control/stabilization structures would occur. Cumulative Impacts See description of past, present and reasonably foreseeable future actions above in Section 5.8.2. Cumulative impacts to terrestrial wildlife would be expected to be greater than those from the Proposed Action because treatments to benefit terrestrial wildlife such as big game would not occur. Sagebrush shrublands and riparian areas would continue to trend downward in terms of habitat health and species diversity.

5.9. Special Status Animal Species

5.9.1. Affected Environment Table 5.12 below shows a list of Threatened and Endangered animal species that was generated for the project area by the USFWS Information, Planning and Conservation System (IPAC) and refined through informal consultation with USFWS:

Table 5.12 - Listed, Proposed, or Candidate Terrestrial Wildlife Species in the Project Area

Occurrence/ Species and Habitat/Range Summaries Potentially Status Impacted

This secretive species occurs in mature riparian forests of cottonwoods and other large deciduous trees with a well-developed understory of tall riparian shrubs. Western cuckoos breed in large Yellow-billed blocks of riparian habitats, particularly woodlands with cuckoo (Coccyzus cottonwoods (Populus fremontii) and willows (Salix sp.). Critical Possible/No americanus) Habitat has been designated along the Yampa River from Hayden to Craig and along the Colorado River from Palisade to Fruita. Threatened There would be no treatments authorized in Critical Habitat under this EA.

Bonytail chub prefer backwaters with rocky or muddy bottoms and flowing pools, although they have been reported in swiftly moving water. They are mostly restricted to rocky canyons today, but were historically abundant in the wide downstream sections of rivers. This fish species experienced the most abrupt decline of any of the Bonytail Chub long-lived fishes native to the main-stems of the Colorado River system and, because no young individuals have been found in (Gila elegans) Absent/No recent years, has been called functionally extinct. Bonytail chubs Endangered were one of the first fish species to reflect the changes that occurred in the Colorado River basin after the construction of Hoover Dam; the fish was extirpated from the lower basin between 1926 and 1950. Critical Habitat has been designated as the Yampa River from the boundary of Dinosaur National Monument to the confluence with the Green River.

The Colorado pikeminnow is endemic to the Colorado River basin, where it was once widespread and abundant in warm-water rivers Colorado and tributaries. Wild populations of Colorado pikeminnow are Possible/No Pikeminnow found only in the upper basin of the Colorado River (above Lake Powell). Three wild populations of Colorado pikeminnow are 95

(Ptychocheilus found in about 1,090 miles of riverine habitat in the Green River, Lucius) upper Colorado River, and San Juan River sub basins. Critical Habitat has been designated as the 100-year flood plain of the Endangered Yampa River from Craig to the confluence with the Green River and the White River from the Rio Blanco Lake Dam to the confluence with the Green, and the Colorado River from Rangely to Lake Powell in UT. There would be no treatments authorized in Critical Habitat under this EA.

The greenback cutthroat trout is the subspecies of cutthroat trout native to the Platte River drainage on the eastern slope of Colorado. The USFWS is advising federal agencies to consider green lineage Green Lineage cutthroat trout on the Western Slope of Colorado as threatened until Cutthroat Trout such time as review and interpretation of recent genetics and meristic research has been completed. Green lineage cutthroat (Oncorhynchus Possible/No trout inhabit cold water streams and lakes with adequate spawning clarki stomias) habitat present in the spring of the year. Although no Critical Threatened Habitat has been determined for this species, protection of presently occupied habitat would be avoided by applying buffers analyzed in the Resource Management Plan for each BLM field office and the most current available population information.

The humpback chub evolved in seasonally warm and turbid water and is highly adapted to the unpredictable hydrologic conditions that occurred in the pristine Colorado River system. Adults require Humpback Chub eddies and sheltered shoreline habitats maintained by high spring flows. Humpback chub live and complete their entire life cycle in (Gila cypha) Possible/No canyon-bound reaches of the Colorado River mainstem and larger Endangered tributaries. Critical Habitat has been designated as the Yampa River from the boundary of Dinosaur National Monument to the confluence with the Green River. There would be no treatments authorized in Critical Habitat under this EA.

Habitats required by adults in rivers include deep runs, eddies, Razorback Sucker backwaters, and flooded off-channel environments in spring; runs and pools, often in shallow water associated with submerged (Xyrauchen sandbars in summer; and low-velocity runs, pools and eddies in Possible/No texanus) winter. Critical Habitat has been designated as the 100-year flood Endangered plain of the Yampa River from Cross Mountain Canyon to the confluence with the Green River and the Colorado River from Rangely to Lake Powell in UT. There would be no treatments

authorized in Critical Habitat under this EA.

Many BLM sensitive species are known to inhabit the project area including: greater sage- grouse, Brewer’s sparrow, midget faded rattlesnake, desert and Rocky mountain bighorn sheep, and a variety of fish, amphibians, raptors, and bats.

Greater Sage-grouse (Centrocercus urophasianus) The BLM and Colorado Parks and Wildlife recognize six greater sage-grouse (GRSG) populations in northwest Colorado; they are 1) Parachute-Piceance-Roan, 2) North-Eagle/South Routt, 3) Meeker/White River, 4) Middle Park, 5) North Park and, 6) NW Colorado. These populations are distinctive with respect to habitat, moisture regimes, population size, concerns/issues, and potential strength of population persistence. In addition, linkages between these populations contain crucial habitats necessary for movement between these populations.

Greater sage-grouse populations generally require large expanses of intact sagebrush habitat (Connelly et al. 2004). Sage-grouse nests are generally found under shrubs with larger canopies and within of stands greater shrub canopy cover (Connelly et al. 2000). Height and structure of herbaceous vegetation is an important component in nesting habitat and can influence nest site selection, nest success, and chick survival. Habitat requirements typically vary depending on season of use. GRSG begin nesting from mid-April through mid-May with chicks appearing from mid-May through mid-July; peaking from mid to late June.

Based on recent (2012) CPW mapping efforts, sage-grouse habitat on BLM-administered lands has been classified into two types: 1) priority habitat management areas (PHMA) and 2) general habitat management areas (GHMA). PHMA represents areas having the highest conservation value in maintaining sustainable sage-grouse populations, including breeding, later brood- rearing, and winter concentration areas. GHMA areas of seasonal or year-round habitat outside of priority habitat where some special management would apply to sustain GRSG populations (BLM 2015a). These two habitat categories conform well to former mapping that emphasized suitable habitat within 4 miles of current or recently active leks.

Brewer’s Sparrow (Spizella breweri) Brewer’s sparrows are common and widely distributed in virtually all big sagebrush, and are sometimes found in greasewood, saltbush, and mixed brush communities throughout the Project area. These birds are most abundant in extensive stands of sagebrush. Typical of most migratory passerines in this area, nesting activities normally take place between mid-May and mid-July. These birds would be expected to be found in sagebrush habitats throughout the project area, and are considered a sagebrush obligate species.

Midget Faded Rattlesnake (Crotalus viridis concolor) The midget faded rattlesnake (MFR) is the smallest member of the western rattlesnake species complex. The entire range of the midget faded rattlesnake lies within the Green River Formation 97

of Wyoming, Utah, and Colorado (Parker 2003). In general, midget faded rattlesnake habitat can be defined as high, cold desert dominated by sagebrush and with an abundance of rock outcrops and exposed canyon walls. Midget faded rattlesnakes occur in small discrete groups and exhibit classic metapopulation distribution. These snakes display strong fidelity to and remain closely associated with hibernacula for overwintering and reproductive activities. These snakes emerge from their dens in late April or early May and remain in close proximity to the den until late May/early June. Gravid females and juveniles remain within 200 meters of dens throughout the year, while mature males and nongravid females disperse an average of 1,000 meters from dens from June through September (Travsky and Beauvais 2004). Concentrated year-round association with the den sites makes these snakes particularly vulnerable to vehicle-caused mortality. This species has been documented within the project area.

Desert bighorn sheep (Ovis canadensis nelsoni) and Rocky mountain bighorn sheep (Ovis canadensis) The project area contains both desert bighorn sheep and Rocky Mountain bighorn sheep. The desert bighorn sheep is a BLM sensitive species. Desert bighorn sheep typically inhabit steep, mountainous or hilly terrain dominated by grasses, low shrubs and rock cover. They can also be found in areas near open and escape cliff retreats. In the Project area, bighorn sheep are mostly concentrated along major river corridors and canyons.

Sensitive Aquatic Species Some perennial and intermittent streams located throughout the project area and provide habitat for BLM sensitive bluehead suckers (Catostomus discobolus), flannelmouth suckers (C. latipinnis), mountain suckers (C. platyrhynchus), roundtail chubs (Gila robusta), Colorado River cutthroat trout - blue lineage (Oncorhynchus clarkii pleuriticus), as well the boreal toads (Bufo boreas boreas) and northern leopard frogs (Rana pipiens).

Sensitive Raptor Species Ferruginous hawks (Buteo regalis) occur in grassland ecosystems and shrub-steppe habitats. This species can be found in the Project area mostly in the fall and winter months and does not commonly nest locally. Ferruginous hawks avoid anthropomorphic disturbances and prolonged human disturbance have resulted in decreased nesting success and abandonment of previously occupied territories (Ward 2001).

Golden Eagles (Aquila chrysaetos) range throughout the West and occupy grasslands, and open sagebrush steppe, and pinyon-juniper habitats, where they forage for small mammals such as jackrabbits, cottontails, ground squirrels and prairie dogs (Wickersham 2016). Though golden eagles prefer cliffs for nesting, they occasionally use ponderosa, pinon, or juniper trees.

Northern Goshawks primarily occupy conifer and mixed conifer-aspen forests and less frequently pinyon-juniper and montane shrublands. They typically nest in mature forest stands. They forage over a diverse habitat including forests, sagebrush-steppe, and riparian areas (Wickersham 2016). Treatments would not occur in conifer and mixed conifer woodlands. 98

Sensitive Bats Northwest Colorado provides habitat for Townsend’s big-eared, spotted, and fringed myotis bats. These bats typically use caves, mines, bridges, and unoccupied buildings for night, nursery, and hibernation roosts, but in western Colorado, single or small groups of bats use rock crevices and tree cavities. Rock outcrops and mature conifers that could serve as temporary daytime roosts for small numbers of bats are widely available in the project area, as well as relatively extensive riparian communities used for finding prey. Birthing and rearing of young for these bats occur in May and June, and the young are capable of flight by the end of July (CBWG 2017). 5.9.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Since habitat for the Threatened and Endangered Species encompassed by the project area boundary would not be targeted for treatment, there would be few and very minor impacts to these species from the Proposed Action. There would be no treatments authorized in Critical Habitat under this EA.

Impacts to special status animal species would vary depending on the size and location of the treatment, habitat type, species involved, and the type and timing of the treatment. In general, impacts to special status species would be similar to those discussed in the Migratory Bird and Terrestrial Wildlife sections. Mechanical treatments would result in direct habitat loss or alteration of predominantly woody vegetation with minimal ground cover removal. Prescribed burns would result in the loss of both woody and herbaceous types (as a forage or cover source). Impacts to special status animal species can be both short term and long term and would greatly depend on the species and vegetative community involved. Individual special status wildlife species will be discussed in further detail below.

Greater sage-grouse All treatments Treatments in GRSG habitat would be designed to meet the seasonal habitat requirements for grouse outlined in the Seasonal Habitat Desired Conditions for GRSG Table 2-2 of the ARMPA (See Attachment C) and would be in conformance with the ARMPA. The habitat objectives for sage-grouse are a list of indicators and values that describe sage-grouse seasonal habitat conditions. The values for the indicators were derived using a synthesis of current local and regional sage-grouse habitat research and data and reflect variability of ecological sites. The type of habitat involved (breeding, brood-rearing, or winter) would determine the treatment method used. All treatments within PHMA and GHMA would have identified GRSG habitat objectives and should consider existing sagebrush communities, site conditions and site potential in treatment design.

Mechanical treatments Pinyon and juniper encroachment into sagebrush shrublands is detrimental to greater sage-grouse and other sagebrush-dependent species because it results in the loss, degradation or 99

fragmentation of sagebrush habitat (Gillihan 2006). Encroaching conifers can also reduce water availability, alter soil acidity, shade out other plants, compete with understory grasses and forbs for water and nutrients, and eventually reduce food and cover for greater sage-grouse, other wildlife, and livestock (Sage Grouse Initiative 2014). This expansion is believed to be slowly reducing the effectiveness of the habitat available for greater sage-grouse and creating perching locations for raptors and corvids that prey on greater sage-grouse. Pinyon and juniper expansion has been identified as a problem for greater sage-grouse populations throughout Colorado (USFWS 2013).

The mechanical removal of pinyon and juniper trees from sagebrush shrublands can be an effective management tool for improving greater sage-grouse habitat (Connelly et al. 2000). This technique is the least disruptive to existing sagebrush and the grass/forb understory. Raptor and corvid perching sites would be removed within and adjacent to greater sage-grouse habitat. Historically, sagebrush shrublands did not contain high perches (e.g., tall or dead trees) from which raptors and corvids could launch predatory attacks. If birds are in the area, they could be temporarily displaced to adjacent sagebrush shrublands by mechanical equipment, noise, and human presence. Habitat conditions would begin to improve for greater sage-grouse as soon as encroaching trees are removed. Understory vegetation would be expected to gradually improve over time following project implementation.

Prescribed Fire Prescribed fire in sagebrush ecosystems would be used primarily to limit the size and intensity of wildfires by modifying the structure of vegetation. It is unlikely that the BLM would conduct prescribed fire activities in GRSG habitat, but if these types of activities were planned, they would have to be in conformance with the GRSG ARMPA. The BLM would coordinate with CPW before proposing any prescribed fire activities in GRSG habitat, and no activities would be allowed during lekking, nesting and early brood-rearing (March 1 –August 31).

Prescribed fire activities could temporarily displace GRSG, and in some cases this displacement could be permanent. The presence of humans and machines, as well as active fire could temporarily disturb GRSG. However, anticipated results of prescribed fire, including increases in native grasses and forbs would be expected to be beneficial to GRSG populations in the long- term.

Installation of stabilization/erosion control structures Installation of stabilization/erosion control structures would be expected to impact GRSG in the short term through displacement. The presence of humans and machines as well as loud noises could temporarily disturb GRSG. However, over the long term, installation of these structures would be expected to benefit GRSG through overall increases in riparian area habitat quality that would create healthy late brood-rearing habitat. Increases in riparian area habitat quality would benefit GRSG through increases in insects and native forbs as a food source for mothers and chicks during the late brood-rearing life phase.

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Brewer’s Sparrow This species selects mature sagebrush, which it uses almost exclusively during the breeding season. Because pinyon and juniper encroachment into sagebrush shrublands degrades and fragments Brewer's sparrow habitat over time, the Proposed Action, specifically treatments designed to remove pinyon and juniper, would be expected to improve habitat conditions for this species. Holmes et al. (2017) found that Brewer’s sparrow density was greater in areas where pinyon and juniper had been removed versus untreated areas. Additional impacts to Brewer’s sparrow would be similar to those discussed for other migratory bird species in the Migratory Bird section.

Midget Faded Rattlesnake Impacts to rattlesnakes would be similar to those discussed in the Terrestrial Wildlife section. In general, treatments that take place in or around MFR denning/hibernacula sites would be avoided during the reproductive period (generally April 15 – August 1). Surveys would be required if the treatment occurs in habitats capable of supporting MFR.

Desert bighorn sheep (Ovis canadensis nelsoni) and Rocky mountain bighorn sheep (Ovis canadensis) The Proposed Action is not likely to directly impact desert or Rocky mountain bighorn sheep, since most, if not all of the projects would take place in areas outside of habitat for these species. However, the Proposed Action could result in indirect effects to both species of bighorn sheep in the form of increased grasses and forbs after mechanical and prescribed fire treatments and increases in water sources after installation of stabilization/erosion control structures. If bighorn sheep are in any treatment area (which is unlikely), they could be temporarily displaced by any of the treatment types in the vicinity of the treatment due to human presence and noise. This could cause short-term, site-specific impacts in the form of energy expenditure or exposure to predation. These impacts, if they occurred at all, would be expected to be minimal.

Sensitive Aquatic Species Fire intensities are generally low with prescribed burns so impacts to aquatic habitats, particularly from sedimentation would be minimal. Design features outlined in the Proposed Action and compliance with site-specific buffers should limit impacts to riparian habitats and aquatic systems that support aquatic wildlife.

Removal or modification of riparian vegetation during installation of erosion control structures could result in temporary increased erosion, temporary loss of stream bank cover, an increase in water temperature due to loss of shading, temporary reduction in prey availability, and a temporary reduction in riparian area habitat quality due to an increase in sediment loading. Impacts would vary depending on the species, with some being less tolerant to change than others. For example, trout are extremely vulnerable to changes in water temperature and quality as they rely on clean, cold water. Increases in water temperature may affect survivorship and reproduction for certain aquatic species with little impact to others.

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Over the long-term, however, installation of erosion control structures in riparian areas would be expected to benefit sensitive aquatic wildlife through decreased erosion, increases in bank stability, increases in shading and overall increases in riparian area habitat quality.

Removal or alteration of upland vegetation (particularly resulting from a fire) may lead to increased runoff, and an increase in erosion and sediment loading. Increased sediment could silt in spawning areas, fill in pools, and reduce productivity of macroinvertebrates that serve as prey for many aquatic species. Impacts to aquatic species and habitats would vary greatly depending on fire intensity, proximity to the stream, slope etc.

Sensitive Raptors Impacts to ferruginous hawks, golden eagles, and northern goshawks would be similar to those discussed with the raptors in the Migratory Birds section. In addition, it is unlikely that nests of any of these species would be impacted through the application of timing limitations and surveys of treatment areas. Many of these species would also be unlikely to nest in the project area, so impacts to these species would be unlikely to occur.

Sensitive Bats Bats forage and roost in pinyon-juniper forests and sagebrush steppe (Gitzen et al. 2002, Chung- MacCoubrey 2003, Snider et al. 2013) and conversion of these native systems via wildland fire, wildland fire suppression, mechanical manipulation, and improper grazing practices could lead to a loss of vegetative structure that may impact bats. Native, healthy sagebrush habitats provide essential insect prey for other wildlife species (Connelly et al. 2000), including bats, so it is likely that alterations to these habitats would increase bat insect prey abundance and diversity. Installation of stabilization/erosion control structures would also be expected to impact sensitive bats by increasing insect populations through increased health of riparian and wetland habitats.

Sensitive Species in General Some species in the project areas during the vegetation treatments would likely be temporarily displaced to nearby habitats due to machinery, noise, smoke, and human presence. Young of the year and adults would be expected to avoid the machinery. Heavy equipment could incidentally crush some plants while moving through the project areas. Although there is potential for short- term impacts to sagebrush, sagebrush shrubland habitat would increase over time, improving conditions for species using this habitat.

Timing limitations would mitigate many short-term impacts from the treatments. Invasive species can occupy areas following disturbance. Design features for monitoring, evaluating and reseeding post treatment would be expected to minimize the potential for invasion of annual species.

Overall, the treatment types would be expected improve habitat for several BLM sensitive species and would likely increase use of sagebrush and mixed mountain shrub in the treated areas. 102

Cumulative Impacts Past, present, and reasonably foreseeable future actions and conditions within the Project area that have affected and would be likely to continue to affect special status wildlife species include: mineral exploration and development, forestry, grazing, recreation, road construction, water diversion and withdrawals, weed invasion and spread, prescribed and wildland fires, land planning efforts, vegetation treatments, habitat improvement projects, insects and disease, and drought.

Under the Proposed Action, cumulative impacts to special status animal species are expected to be less than those for the No Action alternative, since the Proposed Action would benefit special status animal species over the long-term. 5.9.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, Current conditions and vegetation trends would continue to occur, which over time would benefit species that prefer pinyon-juniper woodlands. Conditions would continue to be degraded for species that prefer sagebrush shrublands. Risk of catastrophic fire in these habitats would increase.

Greater sage-grouse and Brewer’s sparrow Treatments would not occur. No short-term disturbances or benefits as a result of any treatment type would occur. Habitat conditions for these species would continue to decline as pinyon and juniper tree density and canopy cover gradually increase. For GRSG, raptor and corvid perches in the form of pinyon and juniper trees encroaching into sagebrush habitats would be retained and increase over time.

Midget faded rattlesnake, Desert bighorn sheep Treatments would not occur under the No Action alternative and therefore no indirect impacts to

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these species would occur.

Sensitive aquatic species Since treatments would not occur under this alternative, short-term impacts due to installation or stabilization/erosion control structures such as temporary increased erosion, temporary loss of stream bank cover and temporary increases in water temperature would not occur. Beneficial impacts from these activities on sensitive aquatic species including decreased erosion, increases in bank stability, increases in shading and overall increases in riparian area habitat quality would also not occur under this alternative.

Sensitive raptors Under the No Action alternative, no treatments would be performed, and no impacts to sensitive raptors would be expected to occur.

Sensitive bats Under this alternative, no treatments would occur. Insect populations would not be expected to increase, and no beneficial impacts to sensitive bats from these treatments would be expected to occur. Cumulative Impacts See description of past, present and reasonably foreseeable future actions above.

Under the No Action Alternative, cumulative impacts are expected to be greater on sensitive animal species since treatments to benefit these species would not occur.

5.10. Special Status Plant Species 5.10.1. Affected Environment Special status plant species and the ecosystems upon which they depend require special management consideration to promote their conservation on BLM-administered lands. Species may be designated as special status species for variety of reasons: because they are species that are naturally occurring rare species, or due to consequences of habitat loss or modification, competition, disease, predation, overharvest. Such species may or may not be legally protected by federal or state agencies. BLM land management practices are intended to sustain and promote species that are legally protected by the Endangered Species Act (ESA) or similar state laws and prevent species that are not yet legally protected from needing such protection.

Plant species discussed in this section have been listed by the USFWS under the ESA, listed by the State of Colorado (by Colorado Parks and Wildlife) or placed on the Colorado BLM State Director’s Sensitive Species List (Manual 6840, BLM 2008a).

The BLM Special Status Species Manual defines Special Status Species as:

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▪ Species listed, or proposed for listing, under the ESA; and

▪ Species requiring special management consideration in order to promote their conservation and to reduce the likelihood and need for future listing under the ESA, which are designated as BLM Sensitive by the BLM State Director(s).

It is BLM policy to provide BLM Sensitive plant species with the same level of protection that is given federal candidate species. The major objective of this protection is to preclude the need for federal listing.

Of particular importance are federally listed species. In cooperation with staff from the local USFWS office, the BLM identified the following federally listed species within the project area that could be impacted by the Proposed Action:

▪ Colorado butterfly plant (Gaura neomexicana v. coloradoensis) ▪ Colorado hookless cactus (Sclerocactus glaucus) ▪ Debeque phacelia (Phacelia submutica) ▪ Dudley bluffs bladderpod (Physaria congesta) ▪ Dudley bluffs twinpod (Physaria obcordata) ▪ North Park phacelia (Phacelia formosula) ▪ Kremmling Osterhout milkvetch (Astragalus osterhoutii) ▪ Parachute beardtongue (Penstemon debilis) ▪ Penland beardtongue (Penstemon penlandii).

A description of the special status plant species found in each field office that may be impacted by the Proposed Action is found below.

Grand Junction Field Office There are twenty-five species that are on the Colorado BLM State Director’s sensitive species list and three federally listed species that occur within the GJFO.

Table 5.13 below lists the BLM sensitive plant species that occur on lands managed by the GJFO in the project area along with the Colorado Natural Heritage Program (CNHP) global/state ranking and habitat description.

Table 5.13 – Special Status Plant Species known to occur in the GJFO

CNHP Common Global/ State Species Name Status Habitat Description Name Ranking (G_/S_)1 Narrow-stem Aliciella Typically found associated with clay Sensitive G3/S1 gilia stenothyrsa hills.

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CNHP Common Global/ State Species Name Status Habitat Description Name Ranking (G_/S_)1 (Gilia stenothyrsa) Powder-blue flowers bloom in May. Jones’ Amsonia Sensitive G4/S1 Runoff-fed draws on sandstone, desert bluestar jonesii steppe. Purple flowers bloom from late April to May. Varicolored, fine textured, seleniferous, saline soils of the Wasatch Formation-Atwell Gulch DeBeque Astragalus Sensitive G2/S2 Member. Barren outcrops of dark clay milkvetch debequaeus interspersed with lenses of sandstone. Elevation ranges from 5,100 to 6,400 feet. Endemic to Colorado, in the Colorado River Valley near DeBeque Flowers from early May to June. Horseshoe Astragalus Typical habitat consists of sagebrush, Sensitive G5T1/S1 milkvetch equisolenis shadscale, horsebrush, and other mixed desert shrub communities Flowers from early May to June, has grass-like leaves. Grows on the Chinle Grand Astragalus and Morrison Formations, with Junction Sensitive G3Q/S3 linifolius pinyon-juniper and sagebrush on milkvetch canyon sides. Elev. 4,800 to 6,200 feet. Endemic to Colorado Flowers from late April to early June. Gullied bluffs, knolls, benches and open hillsides; in pinyon-juniper woodlands or desert shrub (sagebrush) Ferron Astragalus Sensitive G3/S1 communities, mostly on shale, milkvetch musiniensis sandstone, or alluvium derived from them. Elev. 4,700 to 7,000 feet. Endemic to Colorado (Mesa and Garfield Counties) and Utah. Flowers from April to June. Sandstone mesas, ledges, crevices and slopes in Naturita Astragalus Sensitive G2G3/S2S3 pinyon-juniper woodlands. Elev. 5,000 milkvetch naturitensis to 7,000 feet. Found in Mesa, Montrose, and Montezuma Counties. Fisher Pale lilac flowers bloom from late Tower’s Astragalus April to early June. Sandy, sometimes Sensitive G1?/S1 milkvetch piscator gypsiferous soils of valley benches and (named for gullied foothills. Elev. 4,300 to 5,600

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CNHP Common Global/ State Species Name Status Habitat Description Name Ranking (G_/S_)1 Fisher feet. Endemic to Colorado and Utah, Towers, Utah) Dolores River Valley.

White or pale purple flowers bloom from late April to early June. Gullied hills, washes, and talus under cliffs; in San Rafael Astragalus Sensitive G3Q/S1 seleniferous clayey, silty, or sandy milkvetch rafaelensis soils. Elev. 4,400 to 6,500 feet. Endemic to Colorado and Utah, Dolores Canyon bottom. Grand Camissonia Flowers in early spring. Adobe hills in Junction Sensitive G2/S1 eastwoodiae the lower valleys. suncup Gypsum Oreocarya Typically associated with Gypsum Sensitive G1G2/S1S2 Valley cateye revealii outcrops. Cryptantha Small sized plant. Flowers from April Osterhout osterhoutii to early June. Dry, barren sites, in Sensitive G3/S1S2 cryptanth (Oreocarya reddish-purple decomposed sandstone. osterhoutii) Elev. 4,500 to 6,100 feet. Kachina daisy, Kachina Flowers from May to July. Saline soils fleabane Erigeron in alcoves and seeps in sandstone Sensitive G2/S1 (named for kachinensis canyon walls. Elev. 4,800 to 5,600 Kachina feet. Endemic to Colorado and Utah. Natural Bridge, Utah) Flowers from May to August. Mancos Shale badlands, with shadscale and Grand Eriogonum other salt desert shrub communities. Sensitive G3/S2 buckwheat contortum Elev. 4,500 to 5,100 feet. Endemic to Colorado and Utah, Colorado River Valley Tufted green Frasera Sensitive G4/S1 Endemic to Colorado, Mesa County. gentian paniculata Flowers from June to early July. Shale outcrops of the Green River Piceance Lesquerella Formation, on ledges and slopes of Sensitive G2/S2 bladderpod parviflora canyons in open areas. Elev. 6,200 to 8,600 feet. Endemic to Colorado, in Garfield, Mesa, and Rio Blanco

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CNHP Common Global/ State Species Name Status Habitat Description Name Ranking (G_/S_)1 Counties.

Flowering from April/May to early June. Pinyon-juniper and desert shrub Canyonlands Lomatium communities; sandstone ledges and biscuitroot, latilobum canyons in sandy soils derived from Sensitive G1/S1 Wideleaf (Aletes the Entrada Formation or the contact biscuitroot latilobus) point of the Wingate and Chinle Formations. Elev. 5,000 to 7,000 feet. Endemic to Colorado and Utah. Dolores River Lygodesmia Endemic on the benches of the Dolores Sensitive G1G2/S1 skeleton plant doloresensis River Valley. Mentzelia Flowers from late June to July/August. Roan cliffs rhizomata (M. Steep eroding talus slopes of shale, blazingstar, argillosa, Sensitive G2/S2 Green River Formation. Elev. 5,800 to Southwest Nuttallia 9,000 feet. Endemic to Colorado and stickleaf argillosa) Utah, Parachute Creek drainage. Flowers from late July to early Eastwood’s Mimulus September. Shallow caves and seeps Sensitive G3G4/S1 monkeyflower eastwoodiae on steep canyon walls. Elev. 4,700 to 5,800 feet Aromatic Pediomelum Typically found in mixed pinyon- Indian Sensitive G3/S2 aromaticum juniper communities. breadroot Flowers June-July/July-August. Found in open sunny sites on sparsely vegetated, steep shale slopes of the Sun-loving Thalictrum Sensitive G2/S2 Green River Formation. Elev. 6,300 to meadowrue heliophilum 8,800 feet. Endemic to Colorado, Garfield, Mesa, and Rio Blanco Counties. Flowers mid-June to mid-July. Sparsely vegetated, south facing, steep, white shale talus of the Parachute Parachute Creek Member of the Green Penstemon, Penstemon Threatened G1/S1 River Formation. Soils are a mixture Parachute debilis of thin shale fragments and clay. beardtongue Typical elev. 8,000 to 9,000 feet, but can occur down slope. Endemic to Colorado, Garfield County.

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CNHP Common Global/ State Species Name Status Habitat Description Name Ranking (G_/S_)1 An annual plant with small cream flowers that bloom late April- June/May-June. Late in the summer, submutica shrivels up and may be washed or blown away. Sparsely vegetated, steep slopes; chocolate- DeBeque Phacelia Threatened G4T2/S2 brown or gray clay; Atwell Gulch and Phacelia submutica Shire Members of the Wasatch Formation. Soils often have large cracks because of the high shrink- swell potential of the clays. Elev. 4,700 to 6,200 feet. Endemic to Colorado, Garfield and Mesa Counties. Flowers April to May. Plants are Not assigned usually only visible when flowering. Colorado Sclerocactus yet after Rocky hills, mesa slopes, and alluvial hookless Threatened glaucus taxonomy benches; in desert shrub communities. cactus change Elev. 4,500 to 6,000 feet. Endemic to Colorado. Source: (BLM 2015e). 1CNHP ranking system is as follows: 1 = Critically Imperiled (Example: G1 = Globally Ranked Critically Imperiled; critically imperiled species are shown in bold font) 2 = Imperiled (Example: N2 = Nationally Ranked Imperiled) 3 = Vulnerable to Extirpation (Example: S3 = State Ranked Vulnerable to Extirpation) 4 = Apparently Secure 5 = Demonstrably Widespread, Abundant, and Secure T = Gives the rank of a separate taxon (i.e., the rank of a subspecies or a variety) ? = Inexact or Uncertain rank. See CNHP’s Rare Plant Field Guide for a full description of ranks (CNHP 1997)

A detailed description of the special status plants within the GJFO is described in the Grand Junction Field Office Proposed Resource Management Plan and Environmental Impact Statement (BLM 2015e) and is incorporated here by reference. Since signature of the GJFO RMP, the Strigose Easter-daisy (Townsendia strigosa) (G4/S1) was added to the species list.

Colorado River Valley Field Office There are three federally listed plant species known to occur within the CRVFO in the project area and five BLM sensitive Species. Special Status plant species are all listed below in Table 5.14 along with their listing status and habitat description.

Table 5.14 - Special Status Plant Species known to occur in the CRVFO

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CNHP Global/ Common Species Status State Habitat Description Name Name Ranking (G_/S_)1 Flowers April to May. Plants are Not assigned usually only visible when flowering. Colorado Sclerocactus yet after Rocky hills, mesa slopes, and alluvial Threatened hookless cactus glaucus taxonomy benches; in desert shrub communities. change Elev. 4,500 to 6,000 feet. Endemic to Colorado. An annual plant with small cream flowers that bloom late April- June/May-June. Late in the summer, submutica shrivels up and may be washed or blown away. Sparsely vegetated, steep slopes; chocolate- DeBeque Phacelia Threatened G4T2/S2 brown or gray clay; Atwell Gulch and Phacelia submutica Shire Members of the Wasatch Formation. Soils often have large cracks because of the high shrink- swell potential of the clays. Elev. 4,700 to 6,200 feet. Endemic to Colorado, Garfield and Mesa Counties. Flowers mid-June to mid-July. Sparsely vegetated, south facing, steep, white shale talus of the Parachute Parachute Creek Member of the Green Penstemon, Penstemon Threatened G1/S1 River Formation. Soils are a mixture Parachute debilis of thin shale fragments and clay. beardtongue Typical elev. 8,000 to 9,000 feet, but can occur down slope. Endemic to Colorado, Garfield County. Found in open sunny sites on sparsely vegetated, dry shale slopes. Soils usually consist of Green River Shale Cathedral Thalictrum Formation. Associated vegetation is Bluffs Sensitive G2/S2 heliophilum usually very sparse, but may consist of meadowrue rabbit brush, and snowberry. Typical elevation ranges approximately 6,000 to 9,000 feet. Purple flowers bloom from late April to May. Varicolored, fine textured, DeBeque Astragalus seleniferous, saline soils of the Sensitive G2/S2 milkvetch debequaeus Wasatch Formation-Atwell Gulch Member. Barren outcrops of dark clay interspersed with lenses of sandstone. 110

CNHP Global/ Common Species Status State Habitat Description Name Name Ranking (G_/S_)1 Elevation ranges from 5,100 to 6,400 feet. Endemic to Colorado, in the Colorado River Valley near DeBeque Usually found in open sagebrush Harrington’s Penstemon Not currently Sensitive shrublands on gentle slopes between penstemon harringtonii ranked. 6,400 and 9,400 feet. Typically occurs on sandstone ledges, crevices of sandstone bedrock, dry Naturita Astragalus Sensitive G2G3/S2S3 rock mesas, ledges, and detrital slopes milkvetch naturitensis Typical elevation range: 5,000-7,000 feet. Known only from steep, shaley talus slopes derived from the Parachute Roan cliffs Mentzelia Sensitive G2/S2 Creek Member of the Green River blazing star rhizomata Formation. Typical elevation range: 5,000 – 9,000 feet. Source: (BLM 2015c) 1CNHP ranking system is as follows: 1 = Critically Imperiled (Example: G1 = Globally Ranked Critically Imperiled; critically imperiled species are shown in bold font) 2 = Imperiled (Example: N2 = Nationally Ranked Imperiled) 3 = Vulnerable to Extirpation (Example: S3 = State Ranked Vulnerable to Extirpation) 4 = Apparently Secure 5 = Demonstrably Widespread, Abundant, and Secure T = Gives the rank of a separate taxon (i.e., the rank of a subspecies or a variety) ? = Inexact or Uncertain rank. See CNHP’s Rare Plant Field Guide for a full description of ranks (CNHP 1997)

A detailed description of each of the species, their current status, as well as their habitat description can be found in the Colorado River Valley Field Office Proposed RMP/Final EIS (BLM 2015c), and is incorporated here by reference.

White River Field Office There are two federally listed plant species that occur on lands managed by the WRFO in the project area. These two wild mustards are found exclusively in the Piceance Basin of Rio Blanco County, Colorado and lie in the heart of several recent and ongoing natural gas field expansions.

There are also thirteen BLM sensitive plant species that may occur in the project area that also include federal candidate species and delisted species in the five years following delisting. Table 5.15 (below) lists the species along with BLM status, CHHP global/state rank, and general habitat description.

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Table 5.15 - Special Status Plant Species known to occur in the WRFO

CNHP Global/ Common Species Name Status State Ranking Habitat Description Name (G_/S_)1 Barren, white shale outcrops of the Dudley Bluffs Physaria Threatened G1/S1 Green River and Uinta Formations bladderpod congesta (6,000-6,700 feet). Barren, white outcrops and steep Dudley Bluffs Physaria slopes of the Parachute Creek Member Threatened G1G2/S1S2 Twinpod obcordata of the Green River Formation (5,900- 7,500 feet). Pinyon/juniper and mixed desert shrub, often on rocky soils ranging from Debris Astragalus Sensitive G3/S2 sandy clays to sandy loams. Also milkvetch detritalis alluvial terraces with cobbles (5,400- 7,200 feet). Pinyon/juniper woodland and desert Duchesne Astragalus Sensitive G3/S1S2 shrub, around sandstone or shale milkvetch duchesnensis outcrops (4,600-6,400 feet). Bolophyta Ligulate ligulata Sensitive G3/S2 Barren shale knolls (5,400-6,500 feet). feverfew (Parthenium ligulatum) Cryptantha Sparsely vegetation shale knolls, with Tufted caespitosa pinyon/juniper or sagebrush; usually Sensitive G4/S2 cryptantha (Oreocarya with other cushion plants (5,500-8,100 caespitosa) feet). Cryptantha White shale slopes of the Green River Rollins rollinsii Formation, in pinyon/juniper or cold Sensitive G3/S2 cryptantha (Oreocarya desert shrub communities (5,300-5,800 rollinsii) feet). Shale and clay flats of slopes in Ephedra Eriogonum Sensitive G3/S1 saltbush, sage and pinyon/juniper buckwheat ephedroides habitats (4,900-6,900 feet). Cathedral Barren shale knolls and slopes of the Gentianella Bluff dwarf Sensitive G3?/S1 Green River Formation (8,500-10,800 tortuosa gentian feet). Alciella Grassland, sagebrush, mountain Narrow-stem stenothyrsa mahogany or pinyon/juniper; silty to Sensitive G3/S1 gilia (Gilia gravelly loam soils of the Green River stenothyrsa) formation (6,200-8,600 feet). Shale outcrops of the Green River Piceance Lesquerella Formation, on ledges and slopes of Sensitive G2/S2 bladderpod parviflora canyons in open areas (6,200-8,600 feet).

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CNHP Global/ Common Species Name Status State Ranking Habitat Description Name (G_/S_)1 Seasonally wet areas in meadows, Flaming depressions or along arroyos and Gorge Oenothera Sensitive G2/S2 mixed conifer forest to sagebrush, on evening acutissima sandy gravelly or rocky soils (5,300- primrose 8,500 feet). Talus slopes and knolls of the Green Graham’s Penstemon River Formation in sparsely vegetated Sensitive G2/S1 beardtongue grahamii desert scrub and pinyon/juniper (5,800- 6,000 feet). Sparsely vegetated shale slopes of the Penstemon White River Green River Formation Desert in shrub scariosus var. Sensitive G4T1/S1 beardtongue and pinyon/juniper communities albifluvis (5,000-7,200 feet). Cathedral Sparsely vegetated, steep shale talus Thalictrum Bluff Sensitive G2/S2 slopes of the Green River Formation heliophilum Meadow- rue (6,300-8,800 feet). Source (BLM 2015f) 1CNHP ranking system is as follows: 1 = Critically Imperiled (Example: G1 = Globally Ranked Critically Imperiled; critically imperiled species are shown in bold font) 2 = Imperiled (Example: N2 = Nationally Ranked Imperiled) 3 = Vulnerable to Extirpation (Example: S3 = State Ranked Vulnerable to Extirpation) 4 = Apparently Secure 5 = Demonstrably Widespread, Abundant, and Secure T = Gives the rank of a separate taxon (i.e., the rank of a subspecies or a variety) ? = Inexact or Uncertain rank. See CNHP’s Rare Plant Field Guide for a full description of ranks (CNHP 1997)

A detailed description of all the WRFO special status plant species is located in the WRFO Proposed Resource Management Plan Amendment and Final EIS for Oil and Gas Development (BLM 2015f) and is incorporated here by reference.

Little Snake Field Office There are twenty three special status plant species known to occur in the project area within or near the LSFO, including two species that are candidates for listing under ESA and two species that are federally threatened.

Table 5.16 (below) lists the plants known to occur within or near the LSFO along with the listing status.

Table 5.16 - Special Status Plant Species known to occur in the LSFO

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CNHP Global/ Scientific Common Name Status State Habitat Description Name Ranking (G_/S_)1 Not Typically found in dry, rocky areas Astragalus Cushion milkvetch Sensitive currently with little precipitation. aretoides ranked. Found in barren habitats in pinyon- juniper and mixed desert shrub Astragalus communities, often in rocky soils Debris milkvetch Sensitive G3/S2 detritalis ranging from sandy clays to sandy loams, and on alluvial terraces with cobbles. Found in pinyon-juniper woodlands and desert shrub communities Astragalus Duchesne milkvetch Sensitive G3 around sandstone or shale outcrops. duchesnensis Typical elevation range: 4,600 – 6,400. Found on dry hilltops, gullied bluffs, and barren ridges or river Starveling Astragalus terraces, on tuff, shale, sandstone, Sensitive G3/S1 milkvetch jejunus or clays. Uncommon in sandy or clay soil, often with sagebrush or juniper, 6500-7000 ft. Typically occurs in gullies and flats Astragalus Nelson milkvetch Sensitive G3 in seleniferous soils between 6,000 nelsonianus and 7,000 feet. Typically occurs in juniper, sagebrush and riparian communities in gravelly, alluvium, Cirsium Ownbey’s thistle Sensitive G3 talus or sandy slopes. Often ownbeyi associated with alcove seeps and abandoned stream channels between 5,500 and 6,200 feet. Found almost exclusively on barren clay soils or "adobe hills" that are derived from shales of the Mancos or Wasatch formations. Associated Rocky Mountain Cirsium G2G3/S2S Sensitive plant communities have been (Adobe) thistle perplexans 3 described as pinyon-juniper woodlands, and sagebrush, saltbrush, and mixed shrublands between 4,800 and 8,300 feet. Occurs on sparsely vegetated shale Tufted cryptanth/ Cryptantha Sensitive knolls with pinyon-juniper or Caespitose cat’s eye caespitosa G4 sagebrush, usually with other 114

CNHP Global/ Scientific Common Name Status State Habitat Description Name Ranking (G_/S_)1 cushion plants between 6,200 and 8,100 feet. Occurs in cold desert shrub, Uinta Basin spring- Cymopterus sagebrush and juniper communities Sensitive G3 parsley duchesnesis in sandy clay soils between 4,700 and 6,800 feet. Found on barren hillsides in fine Single-stemmed Eriogonum particle soils, often with sagebrush Sensitive G3/S1 wild buckwheat acaule or saltbush between 5,700-6,900 feet. Found in mixed desert shrub communities and pinyon-juniper Woodside Eriogonum Sensitive G3Q woodlands, on rocky outcrops on buckwheat tumulosum sedimentary gravels or clays between 5,800 and 6,300 feet. Typically found on sandy or silty flats or clay slopes and hills in Duchesne/Clay hill Eriogonum Sensitive G4Q/SH saltbush or sagebrush communities buckwheat viridulum or in pinyon-juniper woodlands between 5,600 and 6,000 feet. Not Occurs on rocky slopes and talus, Minutaria Nuttall’s sandwort Sensitive currently especially associated with nuttallii ranked. limestone. Typically found in sagebrush, Nama Not pinyon-juniper woodland, yellow Leafy fiddleleaf densum var. Sensitive currently pine forest and lodge pole pine parviflorum ranked. forest. Typically occurs on sandy, gravelly and rocky soils in seasonally wet Narrowleaf evening Oenothera areas, in meadows, depressions or Sensitive G2/S2 primrose acutissima along arroyos in mixed conifer forest to sagebrush scrub between 5,300 and 9,100 feet. Occurs on barren outcrops of white shale and sandstone of the Brown's Park Formation. It is commonly found growing in very fine textured Gibbin’s Penstemon Sensitive G1G2/S1 sandy clay soils with gravel and beardtongue gibbensii cobbles, and is often associated with cryptobiotic crusts. It is predominantly found on steep slopes that are highly susceptible to 115

CNHP Global/ Scientific Common Name Status State Habitat Description Name Ranking (G_/S_)1 erosion between 5,400 and 5,700 feet. Occurs on talus slopes and knolls of Green River Formation shales in Graham Penstemon Candidate G2/S1 sparsely vegetated desert shrub and beardtongue grahamii Species pinyon-juniper communities between 5,100 and 6,300 feet. Parthenium Found on barren shale knolls Ligulate feverfew Sensitive G3 ligulatum between 5,400 and 6,500 feet. Found in mixed desert shrub and pinyon-juniper communities on Penstemon sparsely vegetated white shale White River Candidate scariosus var. G4T1/S1 slopes. Occurs on fine-textured beardtongue Species albifluvis calcareous soils that are shallow, and usually mixed with fragmented shale between 5,700 and 6,700 feet. Found in Barren, white shale outcrops of the Green River and Physaria Uinta Formations. Outcrops are Dudley Bluffs Threatene congesta, G1/S1 exposed along drainages through bladderpod d Dudley bluffs erosion from downcutting of streams between 6,100 and 6,500 feet. Found on Barren white outcrops and steep slopes exposed by creek downcutting. Restricted to the Dudley Bluffs Physaria Threatene G1G2/S1S Parachute Creek Member of the oil twinpod obcordata, d 2 shale bearing Green River Formation between 5,900 and 7,600 feet. Typically occurs on dry rocky Spaeromeria Rock-tansey Sensitive G3 slopes between 6,700 and 7,200 capitata feet. Typically found in sandy or clay Strigose Easter- Townsendia Sensitive G4/S1 soil of dry, open places between daisy strigosa 5,000 and 9,000 feet. Occurs in dry sandy loam washes Trifolium Mountain clover Sensitive G3/S1 and exposed ridges and rocky hills andinum between 5,000 and 7,200 feet. Source: (BLM 2007b). 1CNHP ranking system is as follows: 1 = Critically Imperiled (Example: G1 = Globally Ranked Critically Imperiled; critically imperiled species are 116

shown in bold font) 2 = Imperiled (Example: N2 = Nationally Ranked Imperiled) 3 = Vulnerable to Extirpation (Example: S3 = State Ranked Vulnerable to Extirpation) 4 = Apparently Secure 5 = Demonstrably Widespread, Abundant, and Secure T = Gives the rank of a separate taxon (i.e., the rank of a subspecies or a variety) ? = Inexact or Uncertain rank. See CNHP’s Rare Plant Field Guide for a full description of ranks (CNHP 1997)

A detailed description of the special status plants within the LSFO is located in the LSFO Proposed RMP and Final EIS (BLM 2007b) and is incorporated here by reference.

Kremmling Field Office There are two species that are listed as threatened known to occur within the Project area in the KFO that may be affected by the Proposed Action. Additionally there are four plant species on the Colorado BLM State Director’s Sensitive Species list that occur within the project area. Table 5.17 (below) lists theses special status species along with their designation, ranking and habitat description.

Table 5.17 - Special Status Plant Species known to occur in the KFO

CNHP Scientific Global/State Common Name Status Habitat Description Name Ranking (G_/S_)1 Typically occurs on poorly vegetated exposures of the North Park Phacelia Coalmont Formation. Steep- Endangered G1/S1 phacelia formosula sided ravines, low sandy hills and bluffs between 7,900 and 8,300 feet. Occurs on highly seleniferous, grayish-brown clay soils derived from shales of the Niobrara, Kremmling Astragalus Pierre, and Troublesome Osterhout Endangered G1/S1 osterhoutii formations. On moderate slopes, milkvetch sometimes found growing up through sagebrush between 7,300 and 8,000 feet. Occurs in fens, wet meadows and Slender Eriophorum Sensitive G5 pond edges between 8,100 and cottongrass gracile 12,000 feet. Typically occurs on calcareous Carex Green sedge Sensitive G3 fens between 8,700 and 9,200 viridula feet.

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CNHP Scientific Global/State Common Name Status Habitat Description Name Ranking (G_/S_)1 Occurs in wet meadows often where ample fresh, often Pale blue-eyed Sisyrinchium Sensitive G3/S2 standing water is available at grass pallidum least through June or early July between 6,300-9,700 feet. Usually found in open sagebrush Harrington’s Penstemon Sensitive G3/S3 shrublands on gentle slopes penstemon harringtonii between 6,400 and 9,400 feet.

Found in Rocky clay loam soils Middle Park Penstemon Sensitive G3G4/S2 of sagebrush hills and flats Penstemon cyathophorus between 7,000 and 8,500 feet. Strongly seleniferous clay-shales of the Troublesome Formation; Penland Penstemon Endangered G1/S1 on steep barrens with sparse beardtounge penlandii plant cover, sagebrush badlands. Elevation of 7,500-7,700 feet. 1CNHP ranking system is as follows: 1 = Critically Imperiled (Example: G1 = Globally Ranked Critically Imperiled; critically imperiled species are shown in bold font) 2 = Imperiled (Example: N2 = Nationally Ranked Imperiled) 3 = Vulnerable to Extirpation (Example: S3 = State Ranked Vulnerable to Extirpation) 4 = Apparently Secure 5 = Demonstrably Widespread, Abundant, and Secure T = Gives the rank of a separate taxon (i.e., the rank of a subspecies or a variety) ? = Inexact or Uncertain rank. See CNHP’s Rare Plant Field Guide for a full description of ranks (CNHP 1997)

A detailed description of each of the species, their current status, as well a more detailed narrative of their habitat description can be found in the Kremmling Field Office Proposed Resource Management Plan and Final Environmental Impact Statement (BLM 2013), and is incorporated by reference. 5.10.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Direct impacts to special status plants would be similar to those described in the vegetation, wetlands and riparian zones section (Section 5.5) of the EA. These impacts include crushing/trampling of plants, plants being ripped out of the ground, and burning of plants from prescribed fire. Seeding also has the potential to impact special status plants if aggressive sod forming grasses are introduced into areas where special status plants occur.

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If vegetation treatments were unsuccessful, the introduction of cheatgrass, and subsequent habitat conversion could directly impact special status species through a loss of suitable habitat.

Indirect impacts to special status plants could arise from fugitive dust production. Fugitive dust created during treatment activities could have adverse impacts on gas exchange, water budgets, productivity, and reproduction of plants (Farmer 1993; Padgett et al 2007; Sharifi et al 1997). Fugitive dust created by machinery could also affect pollinator species by clogging their respiratory system (Tepedino 2009). Cumulative Impacts Past and present impacts to special status plant species include impacts from industrial development, livestock grazing, dispersed recreation and road development, and historical vegetation manipulation projects. These types of impacts would be expected to continue into the future in the Project area with the potential to impact special status plant populations.

Many of the activities listed above can change habitat conditions, which then can cause or favor other habitat changes. For example, wildland fire removes habitat, and affected areas are then more susceptible to weed invasion, soil erosion, and sedimentation of waterways, all of which degrade habitats for special status species. In general, resource use activities have cumulatively caused habitat removal, fragmentation, noise, increased human presence, and weed spread, whereas land planning efforts and vegetation, habitat, and weed treatments have countered these effects by improving habitat connectivity, productivity, diversity, and health. Climate change could cause an increase or decrease in temperatures and precipitation, which would affect soil conditions, vegetative health, and water flows and temperature. Such changes would alter habitat conditions, potentially creating conditions that could favor certain species or communities, weeds, or pests. Since special status plant species often inhabit very specific microhabitats, small changes could cause increased effects on these species.

The Proposed Action includes design features that would avoid all special status plant populations, so cumulative impacts to special status plants from the Proposed Action would be less than those expected for the No Action Alternative because the treatments would be expected to improve habitat for special status plants and restore overall ecosystem health.

5.10.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, no treatments would be performed. No direct impacts or benefits to special status plant species would result. No crushing or trampling of special status plants and no settling of fugitive dust would occur because of the treatments and habitat improvement for special status plants would not occur. Cumulative Impacts See the discussion above in Section 5.10.2 for a description of past, present and reasonably 119

foreseeable future actions.

Cumulative impacts to special status plants would be greater under the No Action Alternative, since no improvement of habitat or restoration of ecosystem health would occur.

5.11. Areas of Critical Environmental Concern 5.11.1. Affected Environment The BLM uses the ACEC designation to highlight areas where special management attention is necessary to protect and prevent irreparable damage to important historic, cultural, and scenic values; fish or wildlife resources; or other natural systems or processes [43 CFR 1610.7-2(b)]. The ACEC designation may also be used to protect human life and safety from natural hazards.

ACEC designation also serves as a reminder that these values must be considered when evaluating future proposals.

There are 46 ACECs on BLM-managed lands in the project area (See Attachment A for a map of the ACECs in the project area). Each BLM ACEC is designated for the purpose of protecting unique values in that area. Table 5.18 (below) depicts the name of each ACEC that overlaps the project area, the field office that manages each ACEC, the acres of each ACEC and the relevant and important values the ACEC was designated to protect.

Table 5.18 - ACECs within the Project Area

Field ACEC Acres Relevant and Important Values Office

Rare plants, rare plant communities, scenic, Irish Canyon ACEC LSFO 11,257 geologic and cultural values

Barger Gulch Heritage Research and preservation of cultural and KFO 533 Area ACEC paleontological resources

Kinney Creek ACEC KFO 145 Wildlife (fish)

Kremmling ACEC KFO 677 Rare plants, wildlife

Kremmling Cretaceous KFO 196 Paleontology, wildlife Ammonite RNA ACEC

Laramie River ACEC KFO 1,585 Rare plants

North Park Research KFO 4,460 Rare plants Natural Area ACEC 120

Field ACEC Acres Relevant and Important Values Office

North Sand Hills ACEC KFO 185 Rare plants

Troublesome Creek KFO 996 Rare plants, wildlife ACEC

Scenic, geologic, wildlife and botanic Anvil Points ACEC CRVFO 4,307

Blue Hill ACEC CRVFO 3,603 Cultural, historical, and natural hazards

Bull Gulch ACEC CRVFO 8,689 Scenic, rare plants

Deep Creek ACEC CRVFO 2,884 Cave, Karst, Ecology, Scenic

East Eagle Ridge ACEC CRVFO 780 Rare plants

East Fork Parachute CRVFO 5,943 Rare plants, wildlife Creek ACEC

Glenwood Springs Debris CRVFO 893 Natural hazards Flow ACEC

Grand Hogback ACEC CRVFO 367 Scenic, Geologic, Cultural Values

Hardscrabble- Mayer CRVFO 2,511 Rare plants Gulch ACEC

Lyons Gulch ACEC CRVFO 401 Rare plants

Magpie Gulch ACEC CRVFO 1,119 Scenic, wildlife and natural processes

McCoy Fan Delta ACEC CRVFO 1,308 Paleontological, geologic

Mount Logan Foothills CRVFO 1,933 Rare plants ACEC

Sheep Creek Uplands CRVFO 3,570 Rare plants ACEC

Thompson Creek ACEC CRVFO 2,043 Scenic, Geologic, Historic, Botanical, Ecological 121

Field ACEC Acres Relevant and Important Values Office Values

Rare plants, wildlife, remnant vegeation associations (RVAs) Trapper Creek ACEC CRVFO 6,030

Blacks Gulch ACEC WRFO 765 Paleontological values

Coal Draw ACEC WRFO 1,009 Paleontological values

Small aspen clones and other biologically Coal Oil Rim ACEC WRFO 2,338 diverse plant communities & riparian habitats

Rare plants & remnant vegetation associations Deer Gulch ACEC WRFO 991 (RVAs)

Duck Creek ACEC WRFO 3,345 Rare plants & Cultural resources

Rare plants and remnant veg associations Dudley Bluffs ACEC WRFO 1,556 (RVAs)

E. Douglas Creek/Soldier Biologically diverse plant communities, riparian WRFO 27,812 Creek ACEC habitat & Colorado River Cutthroat trout habitat

Lower Greasewood Creek Rare plants & remnant vegetation associations WRFO 193 ACEC (RVAs)

Moosehead Mountain Biologically diverse plant communities, riparian WRFO 8,960 ACEC habitat & cultural resources

Oil Spring Mountain Spruce-fir and important biologically diverse WRFO 14,435 ACEC plant communities

Rare plants, sensitive plants & RVAs, Raven Ridge ACEC WRFO 2,790 Paleontological values

Ryan Gulch ACEC WRFO 1,260 122

Field ACEC Acres Relevant and Important Values Office Rare plants

South Cathedral Bluffs WRFO 842 Sensitive plants & RVAs ACEC

Biologically diverse plant communities, bald White River ACEC WRFO 184 eagle roosts, Colorado River Squawfish (Pike minnow)

Yanks Gulch/Upper Rare plants, sensitive plants & remnant WRFO 2,635 Greasewood Creek ACEC vegetation associations (RVAs)

Atwell Gulch ACEC GJFO 2,448 Rare plants, paleontological and cultural

Badger Wash ACEC GJFO 1,228 Long term scientific study site

Mount Garfield GJFO 698 Scenic values

Pyramid Rock ACEC GJFO 716 Rare plants, Cultural, Paleontological

Roan and Carr Creeks GJFO 12,547 Wildlife

South Shale Ridge ACEC GJFO 20,051 Rare plants, Scenic

Source: BLM GIS 2017 5.11.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Some of the relevant and important values within ACECs are sensitive to wildfire: cultural resources, special status plant habitat, and remnant vegetation associations. Irreparable harm could be done if wildfire were to destroy irreplaceable resources, such as wickiup villages or remnant vegetation associations (RVAs).

All treatment types would have the potential to alter the unique qualities of each ACEC, but they would also have the potential to provide long-term benefits by increasing vegetative cover and reducing catastrophic wildfire risks.

Vegetation treatments such as the types and methods included in the Proposed Action would have short-term impacts on ACECs by temporarily reducing vegetative cover and increasing soil

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erosion, especially ACECs designated for scenic quality values. However, over the long term, treatments conducted at the appropriate times of year would be expected to enhance the values of the ACEC by increasing plant vigor, vegetative cover and species diversity.

Fuels treatments such as prescribed burns would likely be conducted in the spring or fall and would create a vegetation mosaic of different age classes and fuel types. These types of treatments would be aimed at reducing fuel loads and reducing the risk of a catastrophic fire in the future, which would benefit the values for which the ACECs have been designated, including rare plants and wildlife. The need for emergency fire suppression activities, which would have the potential to impact ACECs in a variety of ways, including increased surface disturbance from use of fire-fighting equipment, would also be reduced.

Restoration of riparian areas using the methods and tools described in the Proposed Action would temporarily impact ACECs due to presence of equipment and temporary surface disturbance in some cases. Over the long-term, however, restoration of riparian areas would be expected to enhance the values of the ACECs by improving riparian area health.

The unique characteristics of each ACEC would be considered when preparing plans for treatment activities. Cumulative Impacts Past, present and reasonably foreseeable future actions that have affected and would likely continue to affect ACECs include: wildfires, surface-disturbing activities, increased recreational demands, and protections for sensitive resources.

While protections exist within ACECs, population growth, development, and recreation throughout the project area may, over time, encroach upon ACECs, causing potential degradation of the important and relevant resources, such as through displacement of species, habitat fragmentation, and changes to the visual landscape that could indirectly affect resources within ACECs. Impacts would be greater in areas where recreation areas, such as Special Recreation Management Areas (SRMAs) or Extensive Recreation Management Areas (ERMAs) or development were adjacent to an ACEC.

Cumulative impacts from the Proposed Action would be expected to have a beneficial impact on ACECs through overall restoration of habitats and vegetation communities. 5.11.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, the treatments would not occur. There would be no temporary impacts to ACEC values, and there would be no beneficial impacts to ACECs such as restoring ecosystem health.

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Cumulative Impacts For a description of past, present and reasonably foreseeable future actions, see Section 5.11.2 above.

Cumulative effects for the No Action Alternative would be expected to be greater than those for the Proposed Action. Under the No Action Alternative, impacts to ACECs such as an increased risk of wildfire would be greater than the Proposed Action, which would aim to reduce the risk of wildfire. 5.12. Cultural Resources 5.12.1. Affected Environment Nearly 8,000 cultural resource inventories have occurred within the project area resulting in the coverage of 500,000 acres, or 14.7% of the project area (this includes not-to-standard and to- standard Class II [sampling] and Class III [intensive] inventories). Approximately 15,500 cultural resources (cultural resource sites and isolated finds) have been identified within the project area, of which approximately 4,100 are considered eligible, unevaluated, or “needs data” sites. Unevaluated and “needs data” sites are typically managed in the same way as eligible sites until a determination of eligibility is made and are therefore included in this discussion of historic properties. The cultural resources in the project area include all periods and cultural affiliations typically found in northwestern Colorado. Sites date from the Paleoindian period to the historic period and include prehistoric open or sheltered camps and habitations, open or sheltered lithic sites, open or sheltered architectural sites, wickiups/wickiup villages, brush fences, game drives, kill/butchering sites, ceremonial/sensitive sites, rock art, quarries, and culturally modified trees; and historic camps, habitations, homesteads/ranches, towns, roads, pipelines, ditches, mines, railroads, bridges, cattle trails, cemeteries, brush fences and corrals, water control features, rock art, and transmission lines.

Eleven properties within the project area are listed on the National or State Register of Historic Places:

Nine properties listed on the National Register:

▪ 5EA484: a prehistoric open campsite; unknown Native American affiliation

▪ 5GA3827: Barger Gulch Quarry- Locality B; Paleoindian, Archaic, and late Prehistoric quarry and open campsite

▪ 5GF654: Havemeyer-Wilcox Canal Pumphouse and Forebay; historic Euroamerican; HAER documentation has been completed for this site

▪ 5RB53: Duck Creek Wickiup Village; Ute habitation site

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▪ 5RB106: Carrot Men Pictograph Site; Archaic and Fremont rock art

▪ 5RB344: Fremont Lookout Fortification Site; Fremont masonry structure

▪ 5RB820: Collage Shelter Site; Fremont rock art and sheltered camp

▪ 5RB982: Battle of Milk River Site, Thornburgh Monument; historic battle site and marker; Ute, Euroamerican, and African American affiliations

▪ 5RB984: Canyon Pintado National Historic District; hundreds of sites, known for Fremont and Ute rock art, also associated with Dominguez-Escalante Expedition; 16,000- acre district within the White River Field Office.

Two properties listed on the State Register:

▪ 5LR1884: Wurl Ranch; historic Euroamerican ranch

▪ 5RT1401: Boor Ranch, Redmond Ranch; historic Euroamerican ranch

5.12.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Direct and indirect effects to cultural resources vary depending on the type of vegetation treatment. Ground-disturbing mechanical vegetation treatments and drill seeding (methods that utilize heavy machinery and vehicles) have the potential to modify the spatial relationships of artifacts and break or chip artifacts (Bryan et al. 2011; Halford et al. 2016; Odess and Robertson 2007). Impacts to artifacts vary depending on soil type, soil moisture, vegetation type(s), and equipment type (Lewarch and O’Brien 1981; Talmage and Chesler 1977). Ground disturbing mechanical treatments can also disrupt subsurface cultural deposits, though level of impact would vary depending on soil type, soil moisture, vegetation type(s), and equipment type (vehicle mass, speed, maneuver, dynamic load on wheel, etc.) (Li et al. 2007; Liu et al. 2010; Odess and Robertson 2007).

Mechanical treatments also have potential to compact soils; when soil compaction occurs on an archaeological site, it can alter the sediments and in some instances artifacts themselves (Wildesen 1982). Research indicates, however, that lithics embedded in a soil matrix are largely immune to stresses under 87 PSI (McBride and Mercer 2012); conventional forestry equipment typically exert stresses in the range of 7-43 PSI on surface soils (Halford et al. 2016). While compaction and damage to sites from equipment or vehicles is a potential concern, any compression or disturbance incurred through one episode of vehicle activity related to mechanical treatments or drill seeding may not be significant to artifactual constituents of a site (Halford et al. 2016).

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Hand thinning methods, including use of chainsaws, lop and scatter, and cut and pile, would not cause the same impacts as mechanical treatments. These methods have the potential to impact aboriginal wooden structures, culturally modified trees, brush fences, or other cultural features which utilize vegetative materials by inadvertently altering or removing these types of cultural resource features. These impacts, however, can be avoided through project design.

Likewise, seeding methods that do not involve machinery or ground disturbance (aerial or hand application and hand planting) are not likely to impact cultural resources. In fact, seeding could provide an overall benefit to cultural resources by stabilizing soils. Project design would mitigate impacts by allowing for identification and avoidance of sensitive cultural resources.

Use of fire as a treatment has the potential to impact cultural resources to varying degrees, depending on fuels, terrain, site types and cultural materials present, fire intensity, duration of heat, and penetration of heat into soil (Traylor et al. 1983; Winthrop 2004). Impacts to features and artifacts increase with temperature, exposure, and fuel loads (Buenger 2003; Deal 2012). Prescribed fire has the potential to affect or destroy flammable cultural resource artifacts and features if these types of historic properties are not identified and avoided. Organic artifacts on the ground surface are likely most heavily impacted by fire. Intense heat and burning can destroy analytical data from bone, pollen, or botanical specimens, though these impacts vary and appear to lessen if artifacts or specimens are subsurface (Oster et al. 2012).

Fire also has the potential to impact flaked and ground stone artifacts resulting in spalling, discoloration, cracking, changes in color or luster, loss of hydration rinds (obsidian), and changes in morphology (Deal 2012; Winthrop 2004). Rock art or rock surfaces can also spall or stain due to fire (Kelly and McCarthy 2012), and other non-flammable artifacts (e.g., ceramics) can be impacted by heat from fire through breakage, sooting, or loss of analytical data (Rude and Jones 2012; Winthrop 2004; see also various chapters from Ryan et al. 2012).

Following fires, other processes can also indirectly impact cultural resources. These include increased surface runoff and erosion, increased tree mortality, increased borrowing rodent and insect populations, and increased looting (Christensen 1992; Ryan et al. 2012). Sheet erosion can relocate cultural materials and localized, heavy downpours are capable of produced a puddling effect, concentrating flaked-stone debitage into pools that might later be mistaken for activity areas. Trees killed or severely weakened by fire are susceptible to collapse. If cultural resources are located near or among a stand of weakened trees, any collapse could cause severe damage by the upheaval of root systems, or crushing by the trunk or main branches.

Finally, fire can distort the chronometric and functional analysis of surficial and subsurface artifacts and features by heating soils and artifacts and by depositing modern and/or old wood charcoal, thereby obscuring results of thermoluminescence, radiocarbon, obsidian hydration, or archaeomagnetic dating (Oster et al. 2012; Winthrop 2004; see also various chapters in Ryan et al. 2012). 127

Some of the erosion control methods presented in the Proposed Action could potentially affect cultural resources. Soil disturbing erosion control methods (e.g., trenching for Zeedyk structures, constructing water bars) have the potential to impact subsurface deposits or displace artifacts. Impacts would be avoided by the design features allowing for historic property identification prior to implementation.

Lastly, removal of vegetation in a manner that allows for more ground visibility can have the indirect effect of increased intentional or inadvertent looting. Improved access and mobility in these areas and increased visibility of artifacts puts cultural resources at a higher risk of vandalism or looting.

Overall, some treatment methods in the Proposed Action could benefit cultural resources. Vegetation management measures can be compatible with cultural resource management goals and preservation. Many of the measures would reduce the potential for erosion of cultural sites, maintain and improve soil health, maintain or restore the historic setting, and protect plant resources that may be important to Native American communities. Additionally, vegetation treatments and periodic low-intensity and low-duration prescribed fires help to reduce fuel loads and prevent future catastrophic fires without causing significant damage to artifacts and features (Deal 2012; Winthrop 2004). The design features incorporated into the Proposed Action would allow identification of historic properties prior to implementation. Cumulative Impacts Performing appropriate vegetation treatments around and in historic properties is better for long- term preservation of data potential than allowing vegetation to build up year after year and becoming susceptible to catastrophic fire (Smith 1999). Excluding archaeological sites from vegetation treatment activities can sometimes do more harm than good over the course of time. That is because the differences between the treated and untreated areas may be pronounced, such as when “tree islands” are left around sites. As a result, the sites may become more visible to the public and more likely to be looted or vandalized. Appropriate, non-ground disturbing vegetation treatments (e.g., hand thinning) within buffers around site boundaries would reduce potential cumulative effects by not creating these “tree islands.”

Depending on the type of vegetation treatment, specifically treatments that could reduce ground cover and root development such as fire, erosion could increase and cause modification to cultural resource sites, compounding over time. Erosion (such as sheet-washing or down-cutting) following these types of treatment can cause deflation or disturbance of features or displacement of artifacts unless mitigation measures are taken to control erosional processes after a vegetation treatment occurs.

Erosion control would typically cause an overall positive cumulative effect to cultural resources by preventing loss of surficial or subsurface data. Erosion control stabilizes soils within sites, disallowing for movement of artifacts or loss of features, in turn maintaining the integrity of

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sites. 5.12.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under this alternative, there would be no project-related direct and indirect effects to cultural resources on BLM-administered lands from vegetation treatments. Cumulative Impacts The cumulative impacts of the No Action Alternative could include the build-up of vegetation in and around sites, which can lead to more catastrophic or higher intensity fire. Longer duration, more intense fires can cause more harm to cultural resources than low-intensity and low-duration fires (Ryan et al. 2012; Winthrop 2014). If the No Action Alternative is selected, erosion of some cultural resource sites could also increase over time. 5.12.4. Mitigation Measures and Residual Impacts Project activities would avoid adverse effects to historic properties through project design, redesign, relocation of activities, or by other means in a manner consistent with the State Protocol Agreement Between the Colorado State Director [SD] of the Bureau of Land Management [BLM] and the Colorado State Historic Preservation Officer [SHPO] Regarding the Manner in which the BLM would Meet its Responsibilities Under the National Historic Preservation Act [NHP] and the 2012 National Programmatic Agreement [National PA] among the BLM, the Advisory Council on Historic Preservation [ACHP], and the National Conference of State Historic Preservation Officers [NCSHPO] (Protocol).

Mitigation of effects through testing, data recovery, or other means would only occur if avoidance were not feasible. In avoiding or mitigating effect of projects tiered to this EA, the BLM, in consultation with the SHPO, shall determine the precise nature of effects to historic properties identified in the area of potential effect for each individual project, using the Protocol as guidance. The BLM shall consult with the SHPO, Tribes and other consulting parties for any portion of the undertaking resulting in an adverse effect determination. Resolution of effect and specific mitigation needs would be determined through consultation on a case-by-case basis and would account for direct, indirect, and cumulative impacts.

5.13. Native American Religious Concerns 5.13.1. Affected Environment American Indian religious concerns are legislatively considered under several acts and Executive Orders, namely the American Indian Religious Freedom Act of 1978 (PL 95-341) (AIRFA), the Native American Graves Protection and Repatriation Act of 1990 (PL 101-601) (NAGPRA), and Executive Order 13007 (1996; Indian Sacred Sites). In summary, these require, in concert with other provisions such as those found in the NHPA and ARPA, that the federal government carefully and proactively take into consideration traditional and religious Native American

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culture and life and ensure, to the degree possible, that access to sacred sites, the treatment of human remains and associated cultural items, the possession of sacred items, the conduct of traditional religious practices, and the preservation of important cultural properties are considered and not unduly infringed upon. In some cases, these concerns are directly related to “historic properties” and “archaeological resources.” In some cases, elements of the landscape without archaeological or other human material remains may be involved. Identification of these concerns is normally completed during the land use planning efforts, reference to existing studies, or via direct consultation. Sites and landscapes of importance to tribes are known to exist in the general project area.

Previous consultation has occurred for vegetation treatment projects implemented under the National Fire Plan with tribes who traditionally used the project area. Concerns identified at that time-included eradication of sage, impacts to medicinal plants, and general modern intervention in the natural processes. Tribal consultation was initiated via correspondence in December of 2016 and repeated through telephone calls, email, and face-to-face meetings. As of the date of this analysis, the Ute Mountain Ute Tribe, Ute Indian Tribe of the Uintah and Ouray Reservation, Southern Ute Indian Tribe, Northern Cheyenne Tribe, Northern Arapaho Tribe, and Eastern Shoshone Tribe of the Wind River Reservation have not expressed concerns about the project. 5.13.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts The direct and indirect effects analyzed in the Cultural Resources section apply to archaeological sites or historic properties that may be of special interest to the tribes. In addition, vegetation treatments have the potential to change the setting and feeling of landscapes and could impact traditional use areas by altering the landscape from its historical appearance. Depending on vegetation treatment type, impacts could occur to plant populations valuable to Native American practices. In some cases, however, vegetation treatments may restore landscapes to the historic vegetative communities in the area.

The Proposed Action would not prevent access to sacred sites, prevent the possession of sacred objects, or interfere or otherwise hinder the performance of traditional ceremonies and rituals pursuant to AIRFA or EO 13007. Cumulative Impacts Cumulative effects to archaeological sites or historic properties that may be of special interest to the tribes are the same as analyzed in the Cultural Resources section. Other cumulative effects would be the same as those described above. 5.13.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, there would be no known direct or indirect impacts to Native American Religious Concerns. 130

Cumulative Impacts Under the No Action Alternative, there would be no known cumulative impacts to Native American Religious Concerns. 5.13.4. Mitigation Measures and Residual Impacts The Proposed Action is not known to physically threaten the integrity of any traditional cultural properties, prevent access to sacred sites, prevent the possession of sacred objects, or interfere or otherwise hinder the performance of traditional ceremonies and rituals pursuant to AIRFA or EO 13007. There are currently no known threats to human remains associated cultural items that fall within the purview of NAGPRA or ARPA. Although none have been identified, any heretofore unidentified effect of the Proposed Action to Native American Religious Concerns is expected to be negligible in both the short and long term. Tribal representatives have consulted with the BLM on previous vegetation treatment projects in this area and provided instructions for the protection of culturally sensitive sites, should any be discovered during treatments. In addition to the stipulations for the protection of Cultural Resources, if new information is brought forward, any site-specific Native American mitigation measures suggested during previous notification/consultation would be considered during the implementation of the Proposed Action. If new information is provided by Native Americans, additional or edited terms and conditions for mitigation may have to be negotiated or enforced to protect resource values.

5.14. Visual Resources 5.14.1. Affected Environment Visual resources are the visible physical features on a landscape, such as soils, geomorphic features, water, vegetation, and human-made structures that contribute to the landscape’s scenic or visual quality and appeal. A visual impact is created when a perceptible contrast is created that affects the scenic quality of a landscape. The degree of visual impact as perceived by an individual or group depends on a variety of factors or conditions, including personal experience, time of day, and weather or seasonal conditions.

As required by the FLPMA, the BLM must consider scenic quality as part of its management of public lands. To carry out this mandate, the BLM uses the VRM system. VRM involves the identification and evaluation of scenic values. The BLM’s VRM system helps to ensure that actions taken on public lands would benefit the visual qualities associated with the described landscape.

Table 5.19 - BLM Visual Resource Management Class Descriptions

VRM Class Class Objective Preserve landscape character. This class provides for natural ecological changes, but I does not preclude very limited management activity. The level of change to the characteristic landscape should be very low and must not attract attention. 131

Retain existing landscape character. The level of change to the characteristic landscape should be low. Management activities may be seen, but should not attract a casual observer’s attention. Any changes must repeat the basic elements of line, form, II color, and texture found in the predominant natural features of the characteristic landscape.

Partially retain existing landscape character. The level of change to the characteristic landscape should be moderate. Management activities may attract attention, but III should not dominate a casual observer's view. Changes should repeat the basic elements found in the predominant natural features of the characteristic landscape.

Provide for management activities that require major modification of the landscape character. The level of change to the characteristic landscape can be high. Management activities may dominate the view and be the major focus of viewer IV attention. However, every attempt should be made to minimize the impact of these activities through careful location, minimal disturbance, and repetition of the basic landscape elements.

The visual landscape across the project area varies greatly but is generally consistent with the broader landscape features found throughout the western Colorado plateau. Landscape characteristics that contribute to the proposed project area’s scenic conditions include mountains, ridges, narrow and broad river valleys, rolling hills, numerous lakes and reservoirs, sand dunes, and diverse vegetation regimes. Over time, volcanic activity, seismic forces, and erosion have produced unique ridges, isolated mountain peaks, rock outcrops, and waterways.

Table 5.20 - Approximate Acres of VRM Classes in the Project Area

Field Office Class I Class II Class III Class IV

Colorado River 22,300 184,300 82,000 78,800 Valley

Grand Junction 32,200 111,000 117,000 73,400

Kremmling 600 76,000 167,000 39,900

Little Snake 69,800 141,600 850,000 164,100

White River 36,300 309,000 735,400 114,300

Total 161,200 821,900 1,951,400 470,500

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Source: BLM GIS 2017

Development in the project area consists of oil and gas development, urban centers, utility infrastructure, dispersed ranches, recreation areas and range improvements such as fencing and water developments. Urban development is largely situated along major roadways. Taken together, these features create a variety of landscape compositions. Overall, public lands in the project area serve as important scenic backdrops and visual open space. 5.14.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Vegetation treatments, whether removal of pinyon juniper, prescribed fire seeding or installation of erosion control structures can alter the appearance of the vegetation and may contrast with adjacent vegetation by creating openings and obvious changes in color and texture due to the changes in plant height or community (e.g., expanding a riparian area). The treatment types and tools included in the Proposed Action are aimed at restoring the local landscape to include a natural mosaic of vegetation types.

Treatments in VRM Class I, II and III areas would be designed to repeat natural lines of similar vegetation contrast to avoid creating straight lines on the edges of treatments. Undulating edges or feathering would incorporated into treatments where practicable to break up any distinct lines created in the landscape. The proposed treatments do have the potential to temporarily alter the landscape, causing impacts to visual resources, but at the same time, the proposed treatments also have the potential to improve visual quality.

Removal of pinyon juniper trees could change the landscape to clearly appear altered by man. For example, mastication and brush mowing may create a visual contrast that makes human intervention apparent on the landscape. Design features, including feathering and undulating edges would likely reduce these impacts.

Mechanical vegetation treatments would result in short-term adverse visual impacts. For example slash piles would create short-term visual impacts until piles are burned and the burned spots are seeded. These treatments would reduce the potential for negative long-term visual impacts associated with a larger scale fire. Design features such as feathered fuel breaks and treating areas in a mosaic pattern would help reduce the visual impact of prescribed burns.

In general, the Proposed Action would have short-term negative effects and long-term positive effects on visual resources. Over the long term, the Proposed Action would likely cause no changes in the basic landscape elements of form, line, color, and texture that would attract the attention of the casual observer. Cumulative Impacts Past and present habitat treatment projects, along with other disturbances and development (livestock grazing, oil and gas development, utility infrastructure, etc.) in the proposed project 133

area have resulted in visual impacts that can be seen by viewers. The treatment types included in the Proposed Action would create minimal visual impacts until the disturbed lands have been successfully restored.

Other projects on public and private land within and outside of the proposed project area boundary could produce long- term cumulative impacts on visual resources. Reasonably foreseeable future actions such as urbanization, wildfires, livestock grazing, oil and gas development and other surface disturbing activities could have adverse impacts on visual resources. 5.14.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, treatments would not occur. Continued degradation of sagebrush and riparian ecosystems could impact visual resources in the project area. Many areas would be left untreated and would continue to degrade and possibly become dominated by invasive species. Visual resources would not be expected to improve over time and impacts from catastrophic fires would be greater under this alternative. Cumulative Impacts See Section 5.14.2 above for a description of past, present and foreseeable future actions in the project area that could affect visual resources. Under the No Action Alternative, cumulative impacts to visual resources would be expected to be greater since areas would be left untreated and would experience degradation and possibly invasion by invasive species.

5.15. Lands with Wilderness Characteristics 5.15.1. Affected Environment Lands with wilderness characteristics provide a range of uses and benefits in addition to their value as settings for solitude or primitive and unconfined recreation. Section 201 of FLPMA requires the BLM to maintain an inventory of all public lands and their resources and other values, including wilderness characteristics. It also provides that the preparation and maintenance of the inventory shall not, of itself, change or prevent change of the management or use of public lands.

As part of the original FLPMA-mandated inventories, many inventories were conducted during recent RMP revisions and other planning efforts, and through other various lands with wilderness characteristics inventory updates that have recently taken place. Inventories for wilderness characteristics were conducted for each field office, including some ongoing inventories and reflect the most up-to-date lands with wilderness characteristics baseline information for this project area.

For inventories that were conducted after 2011, findings were documented following guidance in

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BLM Instruction Memorandum 2011-154, Requirement to conduct and Maintain Inventory Information for Wilderness Characteristics and to Consider Lands with Wilderness Characteristics in Land Use Plans, which is now encompassed in BLM Manual 6310 (BLM 2012a) and BLM Manual 6320 (BLM 2012b).

Lands with wilderness characteristics in the project area may fall into one of the following categories:

. Lands that have been inventoried by the BLM and have been found to have wilderness characteristics, regardless of management decision.

. Lands that have been inventoried by the BLM and found to have wilderness characteristics where the BLM has decided to manage those lands to protect the wilderness characteristics through and land use planning process.

. Lands that have been inventoried by the BLM and found to have wilderness characteristics where the BLM has decided to minimize impacts to the wilderness characteristics while allowing other uses through a land use planning process.

. Lands that have been inventoried by the BLM and found to have wilderness characteristics where the BLM has decided to prioritize other uses over protection of wilderness characteristics through a land use planning process.

. Lands for which citizens’ inventories have been submitted to the BLM detailing the wilderness characteristics of the area, but for which the BLM has yet to conduct a corresponding inventory and response to the citizens’ submission.

The table below (Table 5.19) depicts the status of Lands with Wilderness Characteristics inventories for those field offices that manage lands in the project area.

Table 5.21 - Status of Lands with Wilderness Characteristics Inventories in the Project Area

Field Office Status of Lands with Wilderness Characteristics Inventories

CRV has completed all inventories for the entire field office. New information from the public was received on five units that are currently Colorado River Valley being inventoried and updated. Updates to other units based on new information submitted by the public will continue as needed.

Grand Junction Twenty-three units in the Grand Junction Field Office have been 135

identified for further inventory for wilderness characteristics. The results of this inventory process are currently underway and results are expected during the late summer of 2017.

Inventories for lands with wilderness characteristics were conducted across the Kremmling Field Office as part of the RMP revision in 2010. Several areas have since been identified by the public as possibly Kremmling containing wilderness characteristics. Inventory work in the field office is is ongoing. Updates to the inventories based on new information submitted by the public will continue as needed.

Little Snake Field Office completed lands with wilderness characteristics inventory for the majority of the field office over the 2011-2012 field seasons. Several new areas have been identified as lands that may qualify Little Snake as lands with wilderness characteristics. Inventory work in the field office is ongoing. Updates to the inventories based on new information submitted by the public will continue as needed.

White River Field Office completed lands with wilderness characteristics inventory over the 2011-2013 field seasons. There have been a few White River updates to the boundaries since then based on approved NEPA actions and new information submitted by the public. Updates to the boundaries will continue as needed.

Source: (C. Schneckenburger personal communication, April 5, 2017)

The BLM’s wilderness characteristics assessment is designed to answer the following question: Does the area meet the overall criteria for wilderness character? The assessment reflects current conditions and is used to update wilderness inventories. The process entails the identification of wilderness inventory units, an inventory of roads and wilderness character, and a determination of whether or not the area meets the overall criteria for wilderness character (naturalness, sufficient size, outstanding opportunities for solitude and primitive and unconfined types of recreation). Units found to possess such character are evaluated during the land use planning process to address future management. The following factors are documented:

▪ Size: Must be a roadless area with over 5,000 acres of contiguous BLM land or contiguous with designated wilderness or WSAs (or the equivalent. A roadless area of less than 5,000 acres may be considered if it is demonstrated that the area is of sufficient size to make practicable preservation and use in an unimpaired condition.

▪ Naturalness: Lands and resources exhibit a high degree of naturalness when affected primarily by the forces of nature and where the imprint of human activity is substantially

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unnoticeable. An area’s naturalness may be influenced by the presence or absence of roads and trails, fences or other developments; the nature and extent of landscape modifications; the presence of native vegetation communities; and the connectivity of habitats. Wildlife populations and habitat are recognized as important aspects of naturalness and would be actively managed.

▪ Outstanding Opportunities for Solitude or Primitive and Unconfined Types of Recreation: Visitors may have outstanding opportunities for solitude, or primitive and unconfined types of recreation when the sights, sounds, and evidence of other people are rare or infrequent, where visitors can be isolated, alone or secluded from others, where the use of an area is through non-motorized, nonmechanical means, and where no or minimal recreation facilities are encountered.

▪ Supplemental Values: Does the area contain ecological, geological or other features of scientific, educational, scenic or historical value?

The table below (Table 5.20) depicts the acres by field office of lands that have been inventoried, lands that have been found to have wilderness characteristics, and lands that are being managed for wilderness characteristics.

Table 5.22 - Acres of Lands Inventoried and Managed for Wilderness Characteristics Acres Managed for Wilderness Field Office Acres Meeting Minimum Criteria1 Characteristics Colorado River Valley 236,229 29,992 Grand Junction 148,377 0 Kremmling 24,860 0 Little Snake 719,504 146,862 White River 249,633 55,850 TOTAL 1,378,603 Acres 232,704 Acres Source: BLM GIS 2017 1 Roadless, greater than 5,000 acres or contiguous with a Wilderness Area or Wilderness Study Area (WSA)

5.15.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts In general, all of the treatments and methods would have short-term negative effects on lands with wilderness characteristics, but would be expected to have long-term positive effects on those areas.

If treatments were to be planned in areas managed for wilderness characteristics, the treatment would minimize surface disturbing activities such that the natural quality of the area is maintained. In addition, ground disturbing mechanical treatments, such as the use of motorized equipment would be allowed in these areas if the project enhances the wilderness characteristics of the area.

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In the short-term, mechanical treatments that use heavy equipment and prescribed burning would create vegetation and soil disturbance that could degrade the naturalness of lands with wilderness characteristics. In addition, the presence of people and the noise from the equipment and vehicles, as well as smoke, would negatively impact opportunities for solitude and primitive recreation. These impacts would be expected to last for the duration of the treatment, but would be temporary in nature. When the treatments would be completed, opportunities for solitude and primitive recreation would be expected to return to the areas impacted.

Most vegetation treatments would likely occur in areas where pinyon-juniper woodlands have encroached in to sagebrush habitats. These types of treatments could result in evidence of disturbed vegetation, which could impact the naturalness of these areas. Over time, these types of impacts would eventually become unnoticeable as vegetation returns to a more natural state.

Reducing fuels through prescribed burns would be also be expected to impact naturalness and solitude in the short-term through presence of equipment, people and smoke in these areas. The areas could also appear managed by man through burn scars. However, over the short term, lands with wilderness characteristics would benefit from prescribed burns through decreased chance of catastrophic wildfires in the future.

Restoration of riparian areas through installation of erosion control structures would be expected to benefit the naturalness of lands with wilderness characteristics over the long-term. In the short-term, impacts to lands with wilderness characteristics would be the same as described in the paragraph above.

In the long-term, restoration of vegetation communities to a more natural composition of grasses, forbs, shrubs and trees could result in a more natural vegetation community, which would benefit the lands with wilderness characteristics. Cumulative Impacts Past, present, and reasonably foreseeable future actions in the project area that have affected and would be likely to continue to affect lands with wilderness characteristics include wildland fires, wildland fire management activities, mining, energy development, noxious weed invasion, urban and suburban sprawl, and road construction.

Continued residential development in the project area would likely increase visitor use on BLM- administered lands including lands with wilderness characteristics, potentially impacting wilderness characteristics by reducing opportunities for solitude.

Development of energy and minerals resources could introduce sights, noises, and infrastructure in or adjacent lands with wilderness characteristics, which could degrade their wilderness characteristics. Vegetation management activities on public lands (such as the treatments included in the Proposed Action) and private lands may alter landscape appearance and setting in

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the short and long term, protecting or degrading wilderness characteristics depending on the activity.

Noxious weed infestations could degrade wilderness characteristics over time in the project area. Impacts on lands with wilderness characteristics would be mitigated where those lands are managed to protect their wilderness characteristics and where management actions governing other resources complement wilderness characteristics. 5.15.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, impacts to lands with wilderness characteristics would be similar to the impacts described under the Proposed Action, but they would be more delayed and spaced out over time as NEPA analysis documents are developed for each individual project. Cumulative Impacts Cumulative effects to lands with wilderness characteristics under the No Action Alternative would be the same as those described above for the Proposed Action. 5.16. Rangeland Management 5.16.1. Affected Environment The BLM authorizes livestock grazing on BLM-managed lands under the authority of the Taylor Grazing Act of June 28, 1934, as amended, and the FLPMA of 1976, as amended by the Public Rangelands Improvement Act of 1978. The BLM manages lands available for grazing in conformance with current law, regulation, and policy.

Management practices for livestock grazing have been focused on achieving land health standards and meeting objectives for other resources (for example, vegetation and soils) established for allotments. This has been accomplished by better conformance with the guidelines for livestock management, such as changing the duration of grazing use and season of use, reducing animal units, and improving grazing distribution. Reducing the duration of grazing use, including rest or deferment grazing plans, and improving livestock distribution are generally the keys to meeting rangeland objectives, particularly those associated with riparian areas.

Grazing management on BLM-administered lands has evolved over time for a variety of reasons, including: adjustments in grazing permits (including adding terms and conditions designed to maintain or improve riparian zones and wetlands, utilization, herding and riding requirements, and placing salt and supplemental feed away from riparian zones), construction of water developments and pasture fencing, and ensured compliance with maintenance of range improvements and grazing permits.

Little Snake Field Office About 98 percent (1,282,590 acres) of the BLM-administered lands within LSFO are allocated to

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livestock grazing allotments, which are managed in accordance with the 2011 Little Snake RMP. The allotments are an outgrowth of the grazing districts and permitting system established to manage livestock grazing in these districts by the 1934 Taylor Grazing Act. Unallotted acreage in the field office includes small isolated parcels not included within existing allotment boundaries and areas withdrawn specifically for other uses. The livestock that graze on lands within the LSFO are primarily cattle, but also include sheep and some domestic horses.

There are 348 allotments in the LSFO that are made up of BLM-administered land and land managed by other federal agencies, the State of Colorado, and private entities. These allotments are used by 197 permittees. The allotments are used for grazing cattle (59 percent of the allotments), sheep and horses (17 percent of the allotments), or sheep exclusively (12 percent of the allotments), with the other 12 percent of the allotments grazed by some combination of these species. A detailed description of the affected environment in the LSFO can be found in the Little Snake Field Office Proposed RMP and Final Environmental Impact Statement (LSFO RMP/EIS 2010, Pg. 3-109) and is incorporated by reference.

White River Field Office The WRFO administers livestock grazing on 156 grazing allotments totaling approximately 2,020,300 acres. These grazing allotments contain 1.443,000 acres of public land that are permitted for 121,000 animal unit months (AUMs). The WRFO permits livestock grazing for cattle, sheep, and horses.

The season of use for each allotment varies but most are a combination of spring, summer, or fall. Winter use generally occurs in the lower elevation desert and pinyon/juniper allotments that are often utilized in the spring and fall, too. Most of the livestock grazing permits in the WRFO Planning Area are for cattle operations that run cow/calf pairs. Calving generally occurs on private land before operators move into an allotment.

In the 1997 White River RMP and ROD, grazing allotments were placed into one of three management categories that define the intensity of management and concentrate funding and on the ground management efforts on those allotments where actions are most needed to improve the resources or resolve serious resource conflicts (BLM 1997). Each grazing allotment fits into one of three management categories that define general rangeland management objectives: (1) improve; (2) custodial; and (3) maintain.

Minimum rest periods have been identified for most allotments where no livestock grazing occurs for a period of time to restore plant vigor, improve watershed conditions, and improve rangeland health according to the Colorado Public Land Health Standards and Guidelines for Livestock Grazing Management (BLM 1997).

Colorado River Valley Field Office Approximately 489,566 acres of the CRVFO are within grazing allotment boundaries, which are managed in accordance with the 2015 RMP (BLM 2015b). Unallotted acres include (1) small 140

isolated parcels not included within existing allotment boundaries, and (2) areas within allotment boundaries that have no permitted livestock grazing. The livestock that graze on CRVFO lands are primarily cattle but also include sheep and some domestic horses. The relative numbers of these kinds of livestock have not varied much over the last 10 years. Total permitted numbers change frequently due to conversions of the class of livestock and changes in allotment or livestock management. The allotments are used for grazing cattle (88 percent of the allotments), sheep and cattle (5 percent of the allotments), or sheep (7 percent of the allotments). Three of these allotments also have horse permits.

The season of use within the CRVFO decision area is generally from May through October, with much of the use in spring (May and early June). Spring use occurs on the lower benches and is designed to coordinate with the end of calving on private lands, and transitions from private land to Forest Service permits. Summer and fall use (late June through October) generally occurs at higher elevations. A detailed description of affected environment for the CRVFO is located in the CRVFO Proposed RMP and Final EIS (CRVFO RMP/EIS, Pg. 3-145) (BLM 2015c) and is incorporated by reference.

Grand Junction Field Office Approximately 978,600 acres of BLM-administered lands are open to grazing within grazing allotment boundaries and are managed by the GJFO. Approximately 13,000 acres of BLM- administered lands are not currently allocated. Approximately 48,800 acres of BLM- administered lands are closed to livestock grazing on Sewemup Mesa and the Little Book Cliffs Wild Horse Range (LBCWHR).

There are 207 allotments managed by the GJFO and of these allotments, 186 are permitted for livestock grazing and 21 are vacant. Total active preference (permitted use) is 61,360 animal unit-months (AUMs), with an additional 24,344 AUMs in suspension. Total permitted numbers adjust occasionally due to conversions of the class of livestock, changes in allotment boundaries or livestock management, and changes to meet carrying capacities, as determined by vegetative inventories and monitoring.

Of the 207 grazing allotments managed within the RMP planning area, 203 are used for cattle grazing, primarily cow/calf operations. The Woods and Snyder Flats allotments are used for both sheep and cattle, and the 4-A Mountain and Upper Brush Mountain allotments also include a small amount of domestic horse use. A detailed description of rangeland management in the GJFO can be found in the Grand Junction Field Office Proposed Resource Management Plan and Environmental Impact Statement (BLM 2015d) and is incorporated by reference into this EA.

Kremmling Field Office Within the KFO, a total of 337,414 acres, or 89 percent, of BLM-managed public lands are allocated for livestock grazing. These public ranges are permitted at a level of 35,239 AUMs of forage and 4,447 AUMs of suspended use, for a total allocation of 39,686 AUMs. Within the Planning Area, there are 41,080 acres, or 11 percent, of BLM-managed public lands that are not 141

allocated for livestock use.

In the KFO, there are 254 allotments, composed of 121 permittees and 143 permits/leases. In 2005, 99 percent of the AUMs were allotted for cattle grazing; and 1 percent allocated for sheep and horse grazing. 251 of the allotments are grazed by individual operators; 3 allotments are grazed by two operators.

The season of use is generally from May through October, with much of the use in spring (May and early June). Spring use occurs on the lower benches, and is designed to coordinate with the end of calving on private lands. Generally, summer and fall use (late June through October) occurs at higher elevations. A detailed description of the affected environment for rangeland management in the KFO is located in the KFO Proposed Resource Management Plan and Environmental Impact Statement (BLM 2013) and is incorporated here by reference.

5.16.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Direct impacts to livestock operators would primarily be related to temporary losses in forage and/or grazing as a result of grazing deferment related to the vegetation treatments. Depending on the treatment and situation, temporary electric fencing could be constructed to keep livestock out of treatment areas, or livestock operators could be required to find alternate grazing for a portion or all of their livestock during the deferment period depending on the size and scope of the treatment project.

Short-term losses in forage would often be off-set in the long-term by increased forage amounts following the vegetation treatments by removing old decadent woody species and allowing the herbaceous understory to develop free from competition of large woody species.

Other impacts to livestock operators include potential damage to range improvements (fences, water developments etc.) that may occur during implementation of the vegetation treatments, and changes in livestock dispersal. The design features developed in the Proposed Action would minimize the impacts to livestock operators by providing advanced notification of projects and protecting range improvements to the maximum extent possible. Cumulative Impacts Past, present and reasonably foreseeable actions that have occurred in the analysis area include oil and gas development, dispersed recreation, and livestock grazing, and it is anticipated these projects would continue into the future.

Cumulative impacts from the Proposed Action are expected to primarily be related to short-term losses in forage for livestock operators during the deferment period after projects have been implemented. These impacts could be exacerbated by long-term losses in forage from other resource development primarily related to oil and gas development.

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Losses in forage due to vegetation treatment however, would generally be short-term and likely would result in long-term increases in forage by reducing decadent woody vegetation and allowing herbaceous forage to fully express itself. Therefore, the Proposed Action would more beneficial cumulative impacts than the No Action Alternative. 5.16.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts If the No Action Alternative were selected, the continued degradation of sagebrush shrublands in the project area would be expected to reduce herbaceous vegetation and therefore would reduce livestock forage over time. Cumulative Impacts Past, present and reasonably foreseeable effects would be the same as those described above in Section 5.15.2. Future impacts for livestock operators would include continued long-term loss of forage primarily associated with oil and gas development, weed invasion, wildfires and wild horse management on public lands. Cumulative impacts from the No Action would be expected to be greater than those for the Proposed Action since under the No Action there would be continued degradation of sagebrush shrublands, and, consequently, a loss of livestock forage over time.

5.17. Wild Horses 5.17.1. Affected Environment The BLM protects, manages, and controls wild horses in accordance with the Wild Free- Roaming Horses and Burros Act of 1971 (PL 92-195, as amended by Congress in 1976, 1978, 1996, and 2004). The FLPMA directs the BLM to manage wild horses and burros as one of numerous multiple uses including mining, recreation, domestic grazing, and fish and wildlife. Wild horse and burro management is governed by 43 CFR subpart 4700. One of the BLM’s top priorities is to ensure the health of the public lands so that the species depending on them, including the nation’s wild horses and burros, can thrive. The BLM policies and regulations also direct that wild horses and burros are to be managed as self-sustaining populations of healthy animals.

Following passage of the Wild Free-Roaming Horses and Burros Act, herd areas were identified. Herd areas are locations where wild horse and burro populations were found when the Act was passed. HMAs are areas within the herd areas where it was decided through LUPs that there was enough forage, water, cover, and space to support a healthy wild horse or burro population.

Five herd areas (HAs) fall within the project area: West Douglas, Little Book Cliffs, North Piceance, Piceance-East Douglas and Sand Wash.

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Three herd management areas (HMAs) fall within the project area: Little Book Cliffs, Piceance- East Douglas and Sand Wash. Table 5.21 depicts the acres of herd areas and herd management areas that overlap the project area.

Table 5.23 - Acres of Herd Areas and Herd Management Areas that overlap the Project Area

HA/HMA Name Field Office Acres West Douglas White River 96,106 Little Book Cliffs Grand Junction 23,559 North Piceance White River 68,483 Piceance-East Douglas White River 138,046 Sand Wash Little Snake 153,131 Source: BLM GIS 2017

The BLM strives to manage wild horse populations in HMAs within appropriate management levels (AML) and corresponding forage allocations (Animal Unit Months, or AUMs) as laid out in the RMPs for each field office. The AML for each HMA is expressed as an acceptable range. Forage allocations for horses in the HMA are based on the maximum number of the appropriate management level range. Appropriate management levels, as well as the boundaries of each HMA, were established through each offices’ RMP to ensure that public land resources, including wild horse habitat, are maintained in satisfactory, healthy condition and that unacceptable impacts on these resources are minimized. 5.17.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts Proposed treatments such as prescribed burns and mechanical shrub removal could cause temporary displacement of wild horses for the short-term due to the presence of fire, human activity and loud noise. However, there would be beneficial impacts in the long- term for wild horses because they would also benefit from the anticipated outcomes of the treatments (e.g., increased grasses and forbs). Anticipated increases in grasses and forbs could also increase the carrying capacity of the HMAs. Many HMAs are currently overburdened with wild horse populations that exceed the appropriate management level.

Wild horses would have a greater chance of being displaced if treatments are planned in their range extent. However, it is very unlikely that a treatment would be planned that would cover their entire range extent, since they are wide ranging and the HMAs are all more than 20,000 acres in size.

Areas of prescribed burns may temporarily reduce available forage for wild horses, but in the long-term these actions are expected to benefit wild horses by increasing available grasses and forbs. Prescribed burns may also help reduce the risk of future catastrophic fire wildfires, which would also benefit wild horse populations. Uncontrolled, high intensity wildfires could remove

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forage from large tracts of rangelands, reducing the suitability for grazing by wild horses.

Installation of erosion control devices intended to expand riparian habitats would also be expected to cause temporary displacement of wild horses due to human activity, but would be expected to benefit wild horses for the long term by increasing available water sources.

Design features included in the Proposed Action such as delaying or modifying projects if they occur during the spring foaling period should help minimize impacts to wild horses from any type of treatment. Cumulative Impacts Past, present and reasonably foreseeable future actions that have affected and would be likely to continue to affect wild horses in the project area include: urbanization, wildfires, livestock grazing, surface-disturbing activities, oil and gas development, the presence and abundance of grazing wildlife, and increased recreational demands.

All of these future actions could impede herd movement and reduce the amount of land available for wild horses to roam. Livestock and wild horses often directly compete for and congregate in areas with high quality forage or water, including wetland and riparian areas. As these native habitats are impacted, they provide openings for invasive species to invade, which reduces available forage to an even greater extent.

Wild horses would directly benefit from the Proposed Action in the long-term, but would be displaced from project areas for the short term. They may be displaced by many different activities on the landscape at a time. 5.17.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, impacts to wild horses would include losses of forage and water sources through continued degradation of sagebrush shrublands, riparian areas and wetlands. Cumulative Impacts See Section 5.16.2 above for a description of the past, present and reasonably foreseeable future actions that could impact wild horses in the project area. The No Action Alternative is expected to have more cumulative impacts to wild horses than the Proposed Action through decreases in available forage over time, and increased wildfire risk. 5.18. Recreation 5.18.1. Affected Environment BLM recreation management focuses on three basic components of recreation opportunities on public lands: 1) types of recreation opportunities and experiences that are provided, 2) the character of recreation setting within which they occur and retaining that character, and 3) 145

services that can be provided by the BLM and its collaborating partners.

Typical recreational activities within the project area include camping, hiking, horseback riding, mountain biking, OHV use, and cross-country skiing. Migrating and resident wildlife provide plentiful opportunities for hunting, photography, and observation. Renowned local rivers, streams, and lakes offer boating and cold-water fishing opportunities. Recreation visitors to the project area come from national and international locations, the Denver metropolitan area and Colorado’s Front Range, and other local communities. For Colorado visitors, the region is an easily accessible weekend getaway with a diversity of outdoor activity offerings and recreation settings.

Motorized recreation is an increasingly popular activity within the project area. Popular OHV recreation areas within the project area include the Wolford Mountain Special Recreation Management Area (SRMA) in the Kremmling Field Office and the Grand Valley Off Highway Vehicle (OHV) SRMA in the Grand Junction Field Office.

Hunting is also a popular recreational activity in the project area. Hunters come from all over the world to hunt for big game and other species that are found within the project area. Boating and camping are other popular activities within the project area. 5.18.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts In general, the treatments included in the Proposed Action would have short-term negative impacts and long-term positive impacts on recreation.

While treatments are being completed, there would be some scenic degradation and distractions to users in the form of, for example, noise from machinery. In most cases, recreationists would be able to find alternative sites offering the same amenities, but they could have a lessened recreation experience if concentrated use occurred on these alternative sites.

Dispersed recreation in non-developed areas would potentially be affected to a greater degree than recreation in developed sites, since vegetation treatments would most likely be planned in undeveloped, remote, dispersed areas.

Impacts to recreation in areas with a greater abundance of recreational opportunities would be greater than in areas with less abundance of those opportunities. However, over the long-term, recreationists would benefit from the treatments. Treatments that would reduce the risk of wildfires would reduce the likelihood that recreationists would be displaced from favorite hunting, fishing, camping and biking sites by wildfires.

Over the long-term, the treatments would have a positive effect on recreation. Treatments would aim to restore public lands, which many recreationists would likely value over more degraded areas. Prescribed burns would reduce the probability of a catastrophic wildfire, thereby reducing 146

the chance that prime recreation opportunities would be affected. Vegetation treatments aimed at increasing grasses, forbs and riparian vegetation would enrich fish and wildlife habitats, which would benefit hunters, birdwatchers and fishers. Cumulative Impacts Past, present, and reasonably foreseeable future actions in the project area that have affected and would likely to continue to affect recreation are increased visitation (especially from residents within the project area and those from the surrounding region), urbanization of communities in northwest Colorado, advances in outdoor recreation equipment, management in existing Recreation Management Areas, and energy development.

Reasonably foreseeable trends that would result in cumulative impacts on recreation include continued growth patterns in demand for all recreation experiences, increased demand for close- to-home recreation opportunities for local residents, continued and increased visitation from a growing regional population, and increased popularity of adjacent public lands.

The Proposed Action would be expected to have cumulative beneficial impacts to recreation through reduced chance of catastrophic wildfires and increased health of fish and wildlife habitats. 5.18.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, impacts to recreation would include increased risk of displacement due to wildfire and continued degradation of fish and wildlife habitats that many recreationists use and enjoy. Cumulative Impacts See Section 5.17.2 above for a description of past, present and reasonably foreseeable future actions that would affect recreation in the project area.

Cumulative effects to recreation under the No Action Alternative would be greater than those described above for the Proposed Action, since continued degradation of fish and wildlife habitat and increased risk of wildfire would be likely to occur.

5.19. Fire and Fuels Management 5.19.1. Affected Environment Within the BLM’s Northwest and Southwest Colorado Districts, there are active wildland fire management programs as well as a hazardous fuels reduction programs. Wildland fire activity has occurred in all months of the year within the planning area; however, most fire activity occurs during the months of April through October with fire activity reaching its peak in July and August. There has been an increase in the number of fires and acres burned annually over the last 10 years. The fires that occur are relatively small with 82% of the wildland fires burning 10 147

acres or less. Conditions do exist within the planning area for large, catastrophic wildfires that can result in loss of life, property and resources. The fuels management programs have implemented a number of fuels mitigation and other vegetation treatment projects to reduce hazardous fuels and improve wildlife habitat. Most of these treatments have been mechanical projects. Mechanical treatments methods allow for the creation of a mosaic of vegetation patterns and types in different successional stages throughout the landscape. Treatment methods include the use of large machines including masticators, roller choppers, and other machines for commercial harvest. These methods are utilized in areas where fuel conditions and topography would allow for treatment with minimal ground disturbance and resource impacts. Mastication has been the most frequently utilized method in previous projects. It is effective in vegetation types including piñon juniper, ponderosa pine, mixed conifer, and shrub species (i.e., oak and mountain mahogany). Hand thinning with chainsaws (lop and scatter) is another method that is commonly used for treatments. Hand thinning is most effective in areas where terrain is difficult (rocky, steep, etc.), access is limited and where slope is often greater than 30%. Hand thinning treatments are accomplished with both agency funded in-house “force account” crews as well as contract crews. The project area is within the Northwest Colorado Fire Management Unit and the Upper Colorado River Fire Management Unit boundaries. Fuel treatment considerations for these units are as follows: ▪ Utilize Fire and non-fire fuels treatments (mechanical treatments) to achieve desired resource management objectives and to reduce hazardous effects of unplanned wildland fire. ▪ Attempt to provide the protection of life and property through vegetation management. ▪ Manage vegetation and unplanned ignitions (wildfires) for resource benefits. Applicable prescriptive vegetation treatment goals for these FMU’s include: ▪ Reduce hazardous fuel loading and the risks of wildland fire escaping public lands. ▪ Improve the quantity and quality of sagebrush habitat and increasing understory vegetation to benefit Greater Sage-Grouse and big game species.

▪ Maintain a diversity of vegetation types and vegetation cover. ▪ Maintain or restore sagebrush communities by reducing the encroachment of Pinyon- Juniper into sagebrush ecosystems. ▪ Reduce the risks of large-scale fires in critical watershed areas, areas of cultural concerns and other sensitive sites. 148

5.19.2. Environmental Consequences – Proposed Action Direct and Indirect Impacts The Proposed Action is consistent with the BLM’s Northwest and Upper Colorado River Fire Management Plans. Fire behavior would be expected to decrease because of reduced fuel loading, arrangement and continuity. Future natural fires would likely be less extensive and smaller in size. Smaller wildfires would be easier to manage, reducing the risk to multiple natural resources, private lands, physical structures associated with right-of-ways and aesthetic values. The danger of large, catastrophic wildfires would be reduced under this alternative.

Indirectly, the interruption of continuous fuel beds would enhance the ability for fire suppression resources to protect agricultural lands, residences, communication sites, oil and gas facilities, and infrastructure scattered throughout the unit when threatened by public land fires. Desired effects could be accomplished through a combination of managing naturally ignited fires, conducting prescribed fires, and implementing mechanical treatments. Cumulative Impacts Past and present management actions and natural events within the cumulative impact analysis area have altered the condition of vegetation and natural fire regimes across the landscape. These include fire suppression, vegetation treatments, grazing, noxious and invasive weed spread, drought, and insect and disease outbreaks. In some cases, areas have become more prone to large intense fires.

Rather than following administrative boundaries, wildland fires burn based on fuels, weather, and topography. Because of continuous fuels and historic high fire occurrence, northwest Colorado fire management activities could affect fire management and resources outside of the project area.

Urban development and recreational activities in the project area are expected to increase over the next several years, creating additional potential ignition sources and the probability of wildland fire occurrence. Of these two factors, urbanization, especially the expansion of residential areas, is expected to be the larger contributor on cumulative wildland fire impacts.

Under the Proposed Action, sagebrush ecosystems would be restored to pre fire suppression status. Not only would this benefit the sagebrush obligate species, but these treatments would act as fuel breaks for any future fire suppression activities. By reducing the fuel loading in these sites fires would be expected to be smaller in size, easier to manage, and safer for fire suppression resources. This would not only provide for greater protection of life and property, but would more cost effective as well. 5.19.3. Environmental Consequences – No Action Alternative Direct and Indirect Impacts Under the No Action Alternative, impacts to fire and fuels management would include a greater 149

risk of catastrophic wildfires if prescribed burns were not allowed in the project area. Cumulative Impacts See Section 5.18.2 above for a description of past, present and reasonably foreseeable future actions associated with fire and fuels management in the project area.

The No Action alternative would have more cumulative impacts than the Proposed Action through the allowance of continued degradation of sagebrush shrublands that could lead to more catastrophic wildfires in these ecosystems in the future.

5.20. Colorado Standards for Public Land Health In January 1997 (BLM 1997a), the Colorado BLM approved the Standards for Public Land Health. These standards cover upland soils, riparian systems, plant and animal communities, special status species, and water quality. Standards describe conditions needed to sustain public land health and relate to all uses of the public lands. If there were the potential to impact these resources, the BLM would note whether or not the project area currently meets the standards and whether or not implementation of the Proposed Action would impair the standards.

5.20.1. Standard 1 – Upland Soils The entire project area has not been formally assessed for standards, but is generally considered to be meeting the upland soil standard. The design features contained in the Proposed Action would help reduce potential soil impacts, and the area would be expected to continue to generally meet the standard. As each treatment project is developed, an evaluation of upland soil health on the site would occur, and appropriate mitigation would be applied, or development of a new NEPA document if conditions on the site would warrant. Under the No Action Alternative, no treatments would occur and present soil erosion rates could increase. As sagebrush shrublands experience further encroachment by pinyon and juniper trees, species that would help stabilize the soil, such as grasses forbs and shrubs would be outcompeted. This could result in increased soil erosion. If the BLM does not install erosion/stabilization structures, degraded soil conditions in some riparian areas would continue.

5.20.2. Standard 2 – Riparian Systems Most riparian systems in the project area are considered to be meeting the standard, although there are some areas where invasive species are present. The design features contained in the Proposed Action would help reduce impacts to riparian systems, and most areas would be expected to continue meeting the standard. As each treatment project is developed, an evaluation of riparian systems on the site would occur, and appropriate mitigation would be applied or development of a new NEPA document if conditions on the site warranted. Under the no action alternative, no vegetation treatments or installation of erosion 150

control/stabilization structures would occur. No impacts or benefits to vegetation would be realized. As the current activities continued, the project area would become more degraded..

5.20.3. Standard 3 – Plant and Animal Communities Vegetative and animal communities within the project area are generally meeting standards, however, there are some areas where invasive species are present. These types of areas may lack adequate species diversity and may provide limited soil stability and forage value for livestock and native ungulates. Most animal communities in project area are considered to be meeting the standard. As each treatment project is developed, an evaluation of plant and animal communities on the site would occur, and appropriate mitigation would be applied or development of a new NEPA document if conditions on the site warranted. Under the No Action alternative, plant and animal communities would not be impacted either negatively or beneficially because none of the treatments or installation of erosion control/stabilization structures would occur. .

5.20.4. Standard 4 – Special Status Species The Proposed Action would be expected to benefit Special Status Species such as the listed and BLM-sensitive fishes, greater sage-grouse and midget faded rattlesnake over the long term. There is no information to suggest that implementation of the Proposed Action would negatively impact the abundance or distribution of these species. The design features contained in the Proposed Action would help reduce potential impacts to Special Status Species, and the area would be expected to continue to generally meet the standard. As each treatment project is developed, an evaluation of Special Status Species populations on the site would occur, and appropriate mitigation would be applied, or development of a new NEPA document if conditions on the site would warrant. Under the No Action Alternative, Current conditions and vegetation trends would continue to occur, which over time would benefit species that prefer pinyon-juniper woodlands. Conditions would continue to be degraded for species that prefer sagebrush shrublands and healthy riparian areas and wetlands.

5.20.5. Standard 5 – Water Quality The entire project area has not been formally assessed for the water quality standard, but is generally considered to be meeting the water quality standard. The design features contained in the Proposed Action would help reduce potential impacts to water quality, and the area would be expected to continue to generally meet the standard. As each treatment project is developed, an evaluation of water quality on the site would occur, and appropriate mitigation would be applied, or development of a new NEPA document if conditions on the site would warrant. Under the No Action alternative, water resources present in the project area would be expected to

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degrade, resulting in poorer water quality. Short term negative impacts to water resources resulting from prescribed fire and heavy machinery within treatment areas would not occur and long term benefits to overall water quality resulting from the Proposed Action would not occur.

6. SUPPORTING INFORMATION 6.1. Interdisciplinary Review Table 6.1 displays the list of BLM staff who assisted in preparation of this document.

Table 6.1. List of Preparers

Name Title Area of Responsibility Office Cultural Resources, Paleontological Grand Junction Natalie Clark Archaeologist Resources, Native American Religious Field Office Concerns Grand Junction Douglas Diekman GIS Specialist Map preparation, GIS calculations Field Office Wetlands and Riparian Zones, Rangeland Management Vegetation, Invasive Non-native White River Field Matthew Dupire Specialist/Ecologist Species, Special Status Plant Species, Office Rangeland Management NEPA Compliance, Wild Horses, Planning & Recreation, Areas of Critical Northwest District Erin Jones Environmental Environmental Concern, Visual Office Coordinator Resources, Lands with Wilderness Characteristics NWCO Fire Mgmt Unit & Robert Klages, Fuels Specialists Fire and Fuels Management Upper Colorado Jeffrey Phillips River Fire Mgmt Unit Soil Resources, Surface and Ground Colorado River Chad Mickschl Hydrologist Water Quality, Floodplains, Valley Hydrology and Water Rights Field Office Colorado State Chad Meister Physical Scientist Air Quality, Climate Change Office Planning & Colorado State Roger Sayre Environmental NEPA oversight Office Coordinator Special Status Animal Species, Little Snake Field Shawna Wiser Wildlife Biologist Migratory Birds, and Aquatic and Office Terrestrial Wildlife

6.2. Tribes, Individuals, Organizations, or Agencies Consulted Endangered Species Act Section 7 Consultation To comply with Section 7(c) of the Endangered Species Act (ESA), the BLM consulted US Fish and Wildlife Service (USFWS) early in the EA process. An iPAC (Information, Planning and 152

Conservation System) report listing threatened and endangered species in the project area was generated on October 26, 2016. The BLM coordinated with USFWS to develop a list of threatened, endangered, proposed and candidate species likely to inhabit the project area, which is included in Section 5.10, Special Status Animal Species and Section 5.11, Special Status Plant Species. An analysis of the impacts to these species is also included in Section 5.10 and 5.11. The BLM prepared a consultation memorandum to evaluate impacts to federally listed or proposed threatened or endangered species. The BLM reached a “May Affect, Not Likely to Adversely Affect” determination for all of the species in the project area. The BLM’s determination is based on the finding that impacts to threatened and endangered species are expected to minimal, since designated critical habitats would be avoided and the Proposed Action contains several design features that would reduce impacts to special status species further. The BLM submitted the consultation memorandum to USFWS on July 14, 2017. The USFWS responded to the BLM’s memo on August 17, 2017 and concurred with the BLM’s finding. Tribal Section 106 Consultation The BLM began tribal consultation for cultural resources for this EA through a consultation initiation letter that was sent to the following tribes on December 20, 2016: ▪ Eastern Shoshone (Shoshone Business Council) ▪ Northern Arapaho ▪ Northern Cheyenne ▪ Southern Ute Tribe ▪ Ute Indian Tribe ▪ Ute Mountain Ute Tribe Government-to-Government consultation will continue throughout the EA process to ensure that tribal groups’ concerns are considered during EA development. In February and April of 2017, the BLM also initiated consultation with the six Tribes regarding participation in the NHPA process and development of a Programmatic Agreement to comply with Section 106. Consultation is ongoing and the Tribes have yet to identify if and at what level they would like to participate (either as a concurring party or invited signatory). The final EA and associated documents will be provided to the tribes concurrently with their release to the public. Colorado State Historic Preservation Officer Consultation

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Cultural resource consultation with the Colorado State Historic Preservation Officer (SHPO) began with a consultation initiation letter that was sent on December 20, 2016. The letter notified the SHPO of the proposed project scoping period and requested participation in the NHPA and EA process. The SHPO and BLM determined the need for the development of a Programmatic Agreement (PA) for the purposes of Section 106 compliance of the NHPA. On February 23, 2017, the BLM initiated consultation with the SHPO on a draft PA. Consultation regarding the PA will continue with SHPO and interested Native American Tribes and other parties throughout the EA process. The PA was signed by the following parties in August and September of 2017: the State Historic Preservation Officer, the BLM Grand Junction Field Office Manager and the BLM Northwest Colorado District Manager. The Final EA and associated documents will be provided to the SHPO concurrently with their release to the public. 6.3. References

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ATTACHMENT A: PROJECT MAPS ATTACHMENT B: PHOTOS OF EQUIPMENT DESCRIBED IN PROPOSED ACTION ATTACHMENT C: SEASONAL HABITAT OBJECTIVES FOR GREATER SAGE-GROUSE ATTACHMENT D: GLOSSARY ATTACHMENT E: CHAMBERS ET. AL. 2016 FOUR STEP PROCESS ATTACHMENT F: COLORADO NOXIOUS WEEDS LIST

ATTACHMENT G: RESPONSE TO PUBLIC COMMENTS

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