Is it a good idea to burn America's pine nut forests?

PROGRAMMATIC ENVIRONMENTAL ASSESSMENT FOR THE
ELY DISTRICT MANAGED NATURAL AND PRESCRIBED FIRE PLAN
EA NV-040-00-020
United States Department of the Interior
Bureau of Land Management
Ely Field Office
November 17, 2000
 
 

ENVIRONMENTAL ASSESSMENT FOR MANAGED NATURAL FIRE AND
PROGRAMMATIC ANALYSIS FOR PRESCRIBED FIRE FOR THE
ELY DISTRICT

EA NV-040-00-020
I. BACKGROUND INFORMATION
This Environmental Assessment (EA)/Programmatic Analysis examines the effects of managed
natural and prescribed fires as proposed in the Ely District Managed Natural and Prescribed Fire
Plan (MN&PF Plan). To fully understand the proposed action and analysis of impacts it is
necessary to read both documents. Managed natural and prescribed fires are being addressed in
the same environmental document because the impacts are similar. This document will serve as
the site-specific analysis for implementation of managed natural fire, and if supported by the
analysis, a Decision Record and Finding of No Significant Impact (DR/FONSI) will be issued for
managed natural fires. This document will also serve as a programmatic analysis for prescribed
fire. A site-specific EA will be written for each prescribed fire, incorporating this document by
reference. A separate DR/FONSI will then be prepared for each prescribed fire.
A. Need for the Proposal
Concern with the health of the ecosystem and the effects of fire on the ecosystem led the federal
government to review its fire management policy. The Federal Wildland Fire Management
Policy and Program Review, dated 1995, concluded, "Catastrophic wildfire now threatens
millions of wildland acres, particularly where vegetation patterns have been altered by past land-use
practices and a century of fire suppression." In addition it states, "Wildland fire, as a critical
natural process, must be re-introduced into the ecosystem." and " Every area with burnable
vegetation will have an approved Fire Management Plan." The MN&PF Plan is needed to
comply with national policy and to improve the health of the ecosystem in the Ely District.
B. Relationship to Planning
The MN&PF Plan is in conformance with, and would implement approved decisions from: the
Caliente Management Framework Plan (MFP), 1981; the Schell Resource Area MFP, 1983; and
the Egan Resource Management Plan (RMP) 1987. The Caliente Resource Area became a part
of the Ely District in 1996. The Caliente MFP Step 3 Decision R-6.1 states, "Develop a
comprehensive fire management plan for the entire planning unit based on vegetative type,
ecological relationships, the effect of different suppression techniques, and human use patterns."
The Schell MFP Step 3 Decision FR-1.1 states, "Develop a Fire Management Plan for the
Resource Area that would identify where initial attack and subsequent suppression would be
actively pursued and areas where fire suppression would be modified, dependent on resource
objectives, fuel, and weather conditions." The Record of Decision (ROD) for the Egan RMP
states, "A resource area-wide fire management plan will be developed which allows a broad2
spectrum of uses. Fire would be used as a tool when it is the most effective and efficient method
for improving habitat and increasing available forage."
The MN&PF Plan would also implement specific management goals identified in various
activity plans such as allotment management plans/evaluations, habitat management plans, elk
management plans, and the District Fire Management Plan (1998).
The MN&PF Plan is consistent with the Lincoln County Policy Plan for Public Lands (December
5, 1984), the White Pine County Policy Plan for Private and Public Lands (March 18, 1998), and
the Nye County Policy Plan for Public Lands (April 3, 1985). The proposed plan would assist in
meeting the Standards developed by the Mojave-Southern Great Basin and Northeastern Great
Basin Resource Advisory Councils. Specifically, the Mojave-Southern Great Basin Guideline
3.8 states, "Vegetation manipulation treatments may be implemented to improve native plant
communities, consistent with appropriate land use plans, in areas where identified Standards
cannot be achieved through proper grazing management practices alone. Fire is the preferred
vegetation manipulation practice on areas historically adapted to fire; treatment of native
vegetation with herbicides or through mechanical means will be used only when other
management techniques are not effective." The Northeastern Great Basin Guideline 3.4 states,
"Where grazing practices alone are not likely to achieve habitat objectives, land treatments may
be designed and implemented as appropriate."
C. Major Issues
No major issues which impact the human environment have been identified. Resources which
may be impacted are listed in Section III of the MN&PF Plan.
II. DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVE
A. Proposed Action
The proposed action is to implement the MN&PF Plan (see Plan for details). The short-term
goal is to re-introduce fire using managed natural and prescribed fire. Natural fires would be
managed based on constraints identified in the plan. More prescribed fires would be
implemented than occurred in the past. The long-term goal is to allow fire to resume a more
natural ecological role within the plan area. In addition, another long-term goal is to reduce fire
suppression costs and acres requiring rehabilitation. The life of the plan is 20 years. This plan
encompasses 3.6 million acres of the 11.7 million acres of public land within the Ely District
(Figure 1 of the MN&PF Plan).
The proposed action would reduce fuel loads on approximately 1,250,000 acres (35% of the
proposed plan area, or approximately 10% of the land managed by the Ely District) of various
vegetative communities (section II.B. MN&PF Plan) through managed natural and prescribed2
spectrum of uses. Fire would be used as a tool when it is the most effective and efficient method
for improving habitat and increasing available forage."
The MN&PF Plan would also implement specific management goals identified in various
activity plans such as allotment management plans/evaluations, habitat management plans, elk
management plans, and the District Fire Management Plan (1998).
The MN&PF Plan is consistent with the Lincoln County Policy Plan for Public Lands (December
5, 1984), the White Pine County Policy Plan for Private and Public Lands (March 18, 1998), and
the Nye County Policy Plan for Public Lands (April 3, 1985). The proposed plan would assist in
meeting the Standards developed by the Mojave-Southern Great Basin and Northeastern Great
Basin Resource Advisory Councils. Specifically, the Mojave-Southern Great Basin Guideline
3.8 states, "Vegetation manipulation treatments may be implemented to improve native plant
communities, consistent with appropriate land use plans, in areas where identified Standards
cannot be achieved through proper grazing management practices alone. Fire is the preferred
vegetation manipulation practice on areas historically adapted to fire; treatment of native
vegetation with herbicides or through mechanical means will be used only when other
management techniques are not effective." The Northeastern Great Basin Guideline 3.4 states,
"Where grazing practices alone are not likely to achieve habitat objectives, land treatments may
be designed and implemented as appropriate."
C. Major Issues
No major issues which impact the human environment have been identified. Resources which
may be impacted are listed in Section III of the MN&PF Plan.
II. DESCRIPTION OF THE PROPOSED ACTION AND ALTERNATIVE
A. Proposed Action
The proposed action is to implement the MN&PF Plan (see Plan for details). The short-term
goal is to re-introduce fire using managed natural and prescribed fire. Natural fires would be
managed based on constraints identified in the plan. More prescribed fires would be
implemented than occurred in the past. The long-term goal is to allow fire to resume a more
natural ecological role within the plan area. In addition, another long-term goal is to reduce fire
suppression costs and acres requiring rehabilitation. The life of the plan is 20 years. This plan
encompasses 3.6 million acres of the 11.7 million acres of public land within the Ely District
(Figure 1 of the MN&PF Plan).
The proposed action would reduce fuel loads on approximately 1,250,000 acres (35% of the
proposed plan area, or approximately 10% of the land managed by the Ely District) of various
vegetative communities (section II.B. MN&PF Plan) through managed natural and prescribed4
IV. ENVIRONMENTAL CONSEQUENCES
The following critical elements of the human environment are either not present or are not
affected by the proposed action or alternative: Prime or unique farmlands, flood plains, Areas of
Critical Environmental Concern (ACEC), wild and scenic rivers, drinking water, environmental
justice, paleontological resources, and hazardous and solid wastes.
During development of the MN&PF Plan, fire management polygons were delineated and
allowable burned acres were identified to minimize impacts to a variety of resources (see section
V.A. in MN&PF Plan). In addition, impacts would be lessened because of the locations and
conditions under which fire would be allowed to burn.
For purposes of this analysis the impacts of managed natural and prescribed fire are the same
unless otherwise noted. The short-term is less than five (5) years and the long-term is more than
twenty (20) years.
A. Impact Analysis
Fire Behavior
Proposed Action
Fire would be re-introduced as a natural component of the ecosystem and would be allowed to
function as nearly as possible as an ecological process in a healthy ecosystem. Fires would be
less intense in the short- and long-term. The reasons for this are discussed in section V.B.2. of
the MN&PF Plan. In the short- and long-term there would be more prescribed fires planned and
implemented as described in V.C.2. of the MN&PF Plan.
There would be more natural and prescribed fires which would reduce fuel loading and
continuity within the various vegetation communities. This would result in smaller fires in the
long-term.
No Action
Continued full suppression would limit the role of fire as a natural component of the ecosystem.
Fires would escalate in intensity and size due to increased fuel loading and fuel continuity. The
current trend toward larger and hotter fires would be expected to continue (Table 1).5
Table 1. Ely District Fire History
Years Number of Fires BLM
Acres
Burned
Number of
Fires Between
1,000 - 5,000
Acres
Number of
Fires Greater
than 5,000
Acres
1985-1989 928 38,634 8 1
1990-1994 806 91,806 10 3
1995-1999 1,074 128,201 16 8
2000 (single year) 271 33,935 5 2
Total 3,078 292,576 39 14
Fire Management
Proposed Action
The fire management staff would use the process described in Section V.B.2. of the MN&PF
Plan to decide if the desired conditions are met for a managed natural fire. The proposed action
would improve public and firefighter safety, reduce costs of fire suppression, and reduce the
burned acres requiring rehabilitation. Firefighter safety would be improved during managed
natural fires because the need for direct attack fire suppression actions would be reduced.
Natural and man-made barriers, such as ridge tops and roads, would be used to control fires
reducing the need for constructed fire lines. This would also reduce the costs of fire suppression.
In the long-term, there would be less need for national resources (i.e., air tankers and overhead
teams) because fires would generally be smaller, and less intense. National resources would be
available for higher priority fires.
Under the proposed action fewer burned acres would require rehabilitation because managed
natural fires would be less intense. In the long-term as plant diversity improves in the different
vegetation communities, natural rehabilitation would more readily occur, reducing the need to
seed burned areas.
No Action
Managed natural fire would not occur. Firefighting would be more dangerous because more fires
would require direct attack fire suppression actions (handlines, dozer lines, engine crews) and
less use of natural and existing man-made barriers. Public safety would be at a greater risk due
to larger, faster moving fires. The costs of suppressing such fires would continue to increase.
There would be a need for more national resources (i.e., air tankers and overhead teams) that
could be used for higher priority fires. Higher intensity fires damage or kill more vegetation,
therefore, more burned acres would require rehabilitation.6
Air Quality
Proposed Action
There are no non-attainment areas within the Ely District as explained in the Clean Air Act,
Section 176(c). Within and adjacent to the plan area are numerous sensitive receptors, such as
communities (i.e., Caliente, Ely, Panaca, and Pioche), highway corridors (i.e., U.S. Highways 6,
50, and 93, and State Highway 318), and recreation areas. For managed natural and prescribed
fire, impacts to air quality would be taken into account in accordance with Appendix G and
Appendix H of the MN&PF Plan.
There would be some short-term impacts to air quality resulting from smoke which may last from
several hours to several days. In brush and grass vegetation types, smoke would dissipate rapidly
and should be gone shortly after the fire. In pinyon-juniper, curlleaf mountain mahogany,
ponderosa pine, and mixed conifer communities, there would be some residual smoke for
approximately one to five days after active burning. Unforeseen weather changes may carry the
smoke toward sensitive receptors such as communities, residences, highway corridors, and
recreation areas. There would be a reduction of total smoke emissions because of smaller less
intense fires resulting from reduced fuel loading in the long-term. This would result in less
degradation of air quality.
No Action
Short-term impacts would be similar to those described above. Continued suppression of all fires
would lead to further accumulation of fuels in the long-term, increasing the chance of more large,
hot fires. The amount of smoke produced by uncontrolled wildland fires would exceed that
produced by managed and prescribed fires. The chance of sensitive receptors also being
impacted would increase. In the long-term there would be greater degradation of air quality.
Soils
Proposed Action
Appendix A of the MN&PF Plan provides a description of the affected environment and impacts
on soils. The short-term impacts would vary depending on the soil type, soil moisture
conditions, and fire severity. Vegetation and microbiotic crust would be removed during a fire
resulting in the potential for increased runoff and soil erosion. Soil temperature would increase
during a fire. The effects of soil heating would vary according to how hot the fire burns. Soil
heating impacts would be the greatest in vegetation types where there is a heavy duff buildup.
This can be found in the mixed conifer, curlleaf mountain mahogany, closed-canopy pinyon-juniper,
and mountain brush communities. As a result of heating the soil, chemical and physical
changes occur. Nitrogen fixation would be temporarily reduced. Some available nitrogen would
be volatilized or bound up during root decomposition of dead plants. This would be offset by7
nutrient release from burned vegetation.
After a fire, the presence of burned organic material or ash on the surface would cause solar
heating of the soil to be faster than vegetated or bare soil. Heating stimulates vegetative growth,
particularly with sufficient moisture. Heating would also desicate the soil surface. Burns could
cause reduced infiltration, and increased carbon, potassium, phosphorus, and nitrogen levels in
the soil during the first year. Runoff could carry some of these nutrients off-site.
Soil characteristics would improve in the long-term. Because future fires would be smaller and
less intense, there would be less heating of the soil, chemical changes would not be as great and
vegetation would re-establish sooner and at a higher density. Surface area of cryptogamic crusts
would increase. Infiltration would improve resulting in reduced runoff.
The greatest potential impact would be the loss of soil productivity through erosion. This would
occur under certain conditions such as short duration high intensity thunderstorms and sudden
snow-melt runoff. Smaller, less intense fires over the long-term would lessen erosion potential.
Following the re-establishment of herbaceous vegetation, wind and water erosion would be
reduced.
No Action
Short-term effects of fire on soils are similar to those discussed above except erosion potential
would be higher than in the proposed action. Because wildland fires would be larger and burn
hotter under the no action alternative the re-establishment of vegetation would take longer. This
would result in a potential increase in soil erosion.
Water Quality and Quantity
Proposed Action
Immediately after any fire, surface runoff would increase because of the loss of vegetation and
surface litter. Intermittent and perennial streams would experience greater peak flows. Overland
flows would increase for one or two years after the fire, or until the vegetation re-established. In
the long-term, there would be an increase in infiltration because of the increase in herbaceous
cover resulting in a reduction of overland flow. Intermittent streams would flow for a longer
period. Perennial streams and springs within affected watersheds would increase in flow.
High intensity thunderstorms and/or rapid snow-melt may cause water quality in the burned
watershed to deteriorate. This could result in reduced oxygen levels due to increased sediment
load. This condition would last until vegetation recovers, usually within one to two years after a
fire. In the short- and long-term water quality would improve due to decreased sediment loading
because fires would be smaller and less intense.8
No Action
In the short- and long-term surface runoff would increase more than under the proposed action
because the fires would be larger, thus there would be more continuous areas without vegetation.
The increase in runoff would last longer because rehabilitation would not occur as quickly after
these hotter fires.
Short-term impacts to water quality would be similar to those discussed in the proposed action.
Water quality would deteriorate in the long-term due to more large, hot fires.
Vegetation
Proposed Action
Fire is an integral and important naturally occurring ecological process within many of the Great
Basin's vegetative communities (Appendix B of the MN&PF Plan). Wildland fire, started either
by natural processes or by native peoples, has been a major element in the development of
ecosystems in the western United States. Many of the vegetation communities developed under a
regime of intermittent fire, and are adapted in some way to fire. The historic (natural) fire
regimes ranged from cooler surface fires to infrequent canopy fires. Normal fire return intervals
by vegetation communities within the plan area are shown in Table 1 of the MN&PF Plan.
Managed natural and prescribed fires would burn under conditions where fire would be less
intense (i.e. higher soil and fuel moisture, higher relative humidity, and lower temperatures).
Native vegetation would re-establish and the need for rehabilitation would be less than present
levels. Vegetation communities would be converted to an earlier successional stage, stimulating
new growth. In the long-term, total plant productivity would increase.
In sagebrush communities, the density and canopy cover of sagebrush would be reduced.
Herbaceous species such as bluebunch wheatgrass, bottlebrush squirreltail, Indian ricegrass,
basin wildrye, Sandberg bluegrass, muttongrass, Nevada bluegrass, and Canby bluegrass would
increase in density and production. In addition, perennial forbs would also increase.
Encroachment of pinyon and juniper into sagebrush communities would be reduced.
In pinyon-juniper communities, decadent stands of trees would be opened allowing for
regeneration of grasses, forbs, shrubs, and young trees. This would increase plant diversity and
age classes over the entire area.
In the mountain brush communities, certain species of shrubs resprout vigorously after fire.
Serviceberry, snowberry, and ribes species would increase in the northern mountain brush
community, while desert bitterbrush, Gambel oak, and Turbinella oak would increase in the
southern mountain brush community. Resprout of antelope bitterbrush, an important wildlife
browse species in the northern brush community, depends on soil moisture and fire intensity.
Decreased fire intensity under this alternative would allow antelope bitterbrush to resprout.9
Aspen communities which are dependent on fire for regeneration, would be enhanced. Burning
these communities would allow for more young aspen suckers to sprout resulting in a more
diverse age class of trees.
Fuel loading and fuel continuity would be reduced in mixed conifer communities. This would
reduce the chance of large, stand-replacing fires. Species composition would increase. Overall
forest health of mixed conifer communities would improve.
In the long-term, there would be a mosaic of vegetative communities which would result in fires
being smaller and less intense.
No Action
In the short-term large hot fires would kill grasses, forbs and shrubs reducing the chance for
natural rehabilitation compared to the proposed action. The need for seeding burned areas would
continue to increase.
Fuel loading would continue to increase within the different vegetation communities. Density
and canopy cover of sagebrush, mountain brush species, pinyon and juniper trees would continue
to increase. Herbaceous vegetation (i.e. grasses and forbs) would decrease. Aspen communities
would continue to be replaced by mixed conifers. Litter and ladder fuels would continue to
build-up in mixed conifer stands. This increase in fuel loading would lead to more large hot fires
and a reduction in the mosaic of vegetative communities throughout the entire plan area.
Noxious and Invasive Weeds
Proposed Action
There would be little risk that noxious weeds would increase because known areas of noxious
weed occurrence were specifically excluded from the fire management polygons. The lack of
proximity to seed source would minimize the establishment and spread of noxious weeds.
Invasive species, such as cheatgrass, are found within the plan area. The proximity of their seed
source could facilitate the spread of these invasive species, depending on the health of the
understory vegetation prior to the fire.
The Managed Fire Implementation Team (MFIT) or the site-specific EA for each prescribed fire
would consider the potential for the spread of noxious and invasive weeds. For managed natural
fires the MFIT would determine what appropriate management response would be implemented.
The risk of weed introduction would be reduced after fire with the re-establishment of perennial
grasses, forbs, and shrubs creating an environment where noxious and invasive weeds would be
less competitive. This would reduce the potential for the spread of noxious and invasive weeds
into the burned areas over the long-term.
10
No Action
In the short-term, the risks of noxious weed increase would be the same as in the proposed
action. Invasive species, in the short-term could increase due to more large, hot fires. Cheatgrass
would be more likely to become established or expand its range. This would potentially increase
fire frequency and size due to the flammability of cheatgrass. There would be continued
escalation and expansion of the annual grass re-burn phenomenon (The Great Basin: Healing the
Land, Bureau of Land Management, April 2000).
The impacts from prescribed fires would be the same as in the proposed action because the site
specific potential for the spread of noxious and invasive weeds would be considered in the EA
for each prescribed fire.
In the long-term the frequency of large, hot fires would continue to increase. Larger burned areas
and fewer unburned islands within the burn would lead to longer recovery periods following the
fire. Natural regeneration processes for species which do not resprout after a fire would take
longer due to the size of the burned area. This would decrease the edge effect for airborne seed
establishment of native vegetation and result in longer periods of vulnerability to noxious and
invasive species. This would increase the potential for the spread of noxious and invasive weeds
into the burned areas over the long-term.
Riparian Areas/Wetlands
Proposed Action
There would be a temporary deterioration of lentic and lotic riparian areas and wetlands because
of the loss of vegetation and the increase in sediment load. The vegetation should grow back
quickly. With increased water flows (see Water Quality/Quantity section), these riparian areas
should expand under the proposed action. Prescribed fires can be used as a tool to meet proper
functioning conditions at riparian areas that have been encroached by upland species (i.e, pinyon,
juniper, and sagebrush).
No Action
Impacts to lentic riparian areas would be similar to those in the proposed action in the short- and
long-term. Lotic riparian areas would deteriorate in the long-term because of increased stream
bank erosion and headcutting. This is the result of a larger area being intensely burned in the
affected watershed. Prescribed fires could still be used as a tool to meet proper functioning
conditions at riparian areas.
Special Status Species (Threatened, Endangered and Sensitive Species)
Proposed Action
Federally designated threatened and endangered species (Appendix C of the MN&PF Plan) or
critical habitat would not be impacted by use of managed natural and prescribed fires. These
impacts would be avoided because of the screening which has already been completed for
        11
identification of the polygons that make up the plan area, and the pre-planning which would be
conducted prior to any managed natural fire or prescribed fire.
Nevada BLM sensitive species (Appendix C of the MN&PF Plan) could be impacted by the
proposed action. Impacts would be minimal because any sensitive species would be identified
and protected during the planning of managed natural and prescribed fires. This planning would
include considerations such as potential impacts to habitats for special status species. Individual
plants and animals could be lost in a fire, but this would not affect the local population or the
species in the long-term. Immediately after any fire, there could be a loss of habitat for sensitive
animal species. The species would be displaced until the habitat is restored.
Sage grouse, a Nevada BLM sensitive species, are found throughout the MN&PF Plan area.
Screening of the polygons has resulted in fewer than 12 known leks (less than 6 percent of the
total leks in the District) being located within the plan area. In addition, the plan area includes
nesting, brooding, and summer habitat for sage grouse. Generally, they prefer open sagebrush
stands with an understory of perennial grasses and forbs as well as riparian areas.
The management objectives of the MN&PF Plan is to burn 35 percent of sagebrush communities
within the plan area over the life of the plan. This is approximately 15 percent of the sagebrush
community within the entire Ely District. This would increase plant diversity and would result in
differing age classes of sagebrush. This would benefit sage grouse in the long-term. Burning
would be done in accordance with the Draft Management Guidelines for the Greater Sage Grouse
and Sagebrush-Steppe Ecosystems for BLM-Administered Lands in Nevada. In addition, sage
grouse would benefit from expansion of riparian areas (Riparian Areas/Wetlands section).
No Action
The chance of impacting federally designated threatened and endangered species and Nevada
BLM sensitive species (Appendix C in MN&PF Plan) or habitat could be increased because of
the potential for more large uncontrolled wildland fires in the short- and long-term.
Prescribed burning would be used on a limited basis to improve sage grouse habitat over the
long-term. This would increase plant diversity and would result in differing age classes of
sagebrush. Burning would be done in accordance with the Draft Management Guidelines for the
Greater Sage Grouse and Sagebrush-Steppe Ecosystems for BLM-Administered Lands in
Nevada. Sage grouse would benefit from expansion of riparian areas but to a lesser extent, than
under the proposed action.
Wildlife
Proposed Action
Boundaries of polygons within the plan area were identified and allowable burned acres within
each polygon were specified to reduce potential impacts to wildlife (Table 6 of the MN&PF
Plan). In most cases, animals would be able to escape managed natural and prescribed fires.
        12
However, some individuals could perish. There would be direct and indirect impacts on resident
wildlife because of the loss of vegetative cover within the burned area. This impact would be
minimal because wildlife would move into adjacent unburned areas.
In the long-term, wildlife habitat conditions would improve as a result of managed natural and
prescribed fires. The increase in understory vegetation (i.e., perennial grasses and forbs), and the
increase in species diversity on burned areas would benefit most species of wildlife. Decreased
fire intensity under this alternative would allow more antelope bitterbrush, an important wildlife
browse species, to resprout. Over a large area, the mosaic of different vegetation communities
and age-class structures within those communities, would provide a variety of habitats for
wildlife. The distribution of wildlife species would shift accordingly.
Appendix D of the MN&PF Plan shows the obligate and dependent bird species for various
habitat types in the plan area. In the short-term, habitat for these species would be burned;
however, there is abundant unburned habitat available nearby. Individual birds could relocate.
Because fires would be smaller in the long-term, there would be less impacts to local bird
populations.
No Action
In most cases, animals would be able to escape wildland fires. However, some individuals could
perish. There would be direct and indirect impacts on resident wildlife because of the loss of
vegetative cover within the burned area. These impacts would increase under this alternative
because there would be more large, hot fires due to continued build-up of fuels.
The long-term benefits to wildlife habitat as described under the proposed action would not
occur. The vegetative response after most large, hot fires is a decrease in perennial grasses,
forbs, and shrubs. The mosaic created under the proposed action would not be realized.
In the short-term, habitat for obligate and dependent bird species would be burned. There would
be unburned habitat available nearby. In the long-term, habitat for these species would
deteriorate to a greater extent than under the proposed action (see Vegetation section above).
Because fires would burn larger blocks of contiguous habitat, local bird populations would have
more difficulty relocating.
Wild Horses
Proposed Action
Direct and indirect impacts to wild horses would be minimized because of the pre-planning
which would be conducted prior to any managed natural fire (Appendix G in MN&PF Plan) or
during the preparation of an EA for each prescribed fire. Wild horses would be temporarily
displaced. In the long-term wild horse habitat conditions would be improved (see Vegetation,
Water Quantity and Quality, and Wildlife sections above).
13
No Action
Wild horses would be temporarily displaced. In the long-term wild horse habitat conditions
would continue to deteriorate because of more large, hot fires (see Vegetation section above).
Livestock Grazing
Proposed Action
The Managed Fire Implementation Team (MFIT) or the site-specific EA for each prescribed fire
would consider the potential for damage to range improvements (i.e., corrals, fences, pipelines).
Damage to range improvements on a managed natural fire could impact the livestock permittee.
Rebuilding these projects would take time and money.
There would be a short-term impact to livestock grazing. Livestock would be restricted from the
burn area until resource management objectives have been met (Appendix F of the MN&PF
Plan). Subsequent to a managed natural fire, the livestock permittee could work with the BLM to
find other potential grazing areas and/or alternative methods (i.e., fencing, herding, watering) to
keep livestock off the burned areas.
The majority of fires within the Ely District occur in the pinyon-juniper vegetation communities,
and where pinyon and juniper trees are encroaching into the sagebrush and mountain brush
communities. Currently these communities produce very little forage for livestock grazing
because of the dense overstory of trees and shrubs. After a fire there would be an increase in
understory vegetation (i.e., perennial grasses and forbs) resulting in additional forage. This
forage could be available to livestock as well as wildlife and wild horses.
No Action
The site-specific EA for each prescribed fire would consider the potential for damage to range
improvements (i.e., corrals, fences, pipelines). More range improvements could be damaged or
destroyed from uncontrolled wildland fires and need to be replaced.
Impacts to livestock grazing in the short-term would be greater due to the anticipated increase in
more large, hot fires. Livestock would be restricted from the burn area until resource
management objectives have been met. Larger areas would have to be rested from grazing and
likely for a longer period of time to allow the vegetation to recover after these fires.
In the long-term livestock forage conditions would continue to deteriorate because of more large,
hot fires (see Vegetation section above).
Cultural Resources
Proposed Action
Appendix E of the MN&PF Plan describes fire effects on cultural resources. The MFIT or the
14
team assigned to each prescribed burn would obtain recommendations from an archeologist to
reduce potential for damage to cultural resources. Impacts would be lessened because of smaller,
less intense, managed natural and prescribed fires. Ground disturbing activities (e.g., bulldozers,
handlines and cross country vehicle travel during wildfire events) which could result in the
destruction of cultural resources would be less necessary under this alternative (see Fire
Management section above). Post-fire effects resulting from erosion would be reduced because
of smaller, less intense fires (see Soils section above).
During the life of the plan, an unknown number of additional archeological resources and historic
properties may be identified and protected from damage or destruction. This would result in a
greater number of archeological and historical resources added to the database within the Ely
District and an increased knowledge of locations and types of cultural resources.
No Action
Because there would be more uncontrolled large, hot fires more archeological resources and
historic properties would be damaged or destroyed over the long-term. Impacts within each
prescribed burn would be the same as described for the proposed action. More ground disturbing
activities associated with suppression of uncontrolled wildland fires would result in damage or
destruction of cultural resources. Post-fire effects resulting from erosion would be increased
because of more large, hot fires. There would be fewer archeological resources and historic
properties added to the database within the Ely District because less acres would be inventoried.
Native American Religious Concerns
Proposed Action
No known religious sites have been identified in the plan area. Traditional values and use areas
may be impacted by managed natural and prescribed fire. Certain plants, such as pinyon trees,
juniper trees, sagebrush and willows used by Native Americans would be burned. The long-term
goal of allowing fire to resume a more natural ecological role may be preferable to the Native
American communities, based on pasted discussions (Native American Concerns MN&PF Plan).
No Action
Traditional values and use areas may be impacted by uncontrolled wildland fire and prescribed
fire. While no known religious sites are identified in the plan area, there would be increased
impacts to the vegetation (and other natural values) associated with religious sites and traditional
values and use areas because there would be more large, hot fires (see Vegetation section above).
Continuation of full suppression may be less acceptable to traditional Native American
communities because this does not allow fire to resume a more natural ecological role.
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Recreation
Proposed Action
The use of managed natural and prescribed fires would result in displacing dispersed recreation
users from the burned areas. Depending on the type of recreational activity, this impact may last
up to several years after the fire. Fire near developed recreation sites could affect the quality of a
visitor's experience due to smoke. Using prescribed fire to create fire breaks could be beneficial
in protecting developed recreation sites. Consumptive (such as hunting) and non-consumptive
(such as wildlife viewing) wildlife activities would increase because of the improvement in
wildlife habitat resulting from the proposed action (see Wildlife section above). In the long-term,
vegetative mosaics from managed natural and prescribed fires could enhance the visitor's
experience.
No Action
The impacts to recreation would be similar to those for the proposed action except that wildlife
habitat would not improve to the same degree and there would be an increase risk to the public
because of more large, hot fires.
Visual Resource Management
Proposed Action
The use of managed natural and prescribed fire would result in line, color and texture contrasts.
In general, these contrasts would be of small scale associated with the landscape. Line contrasts
would result from fingers of burned areas within a landscape of generally small, irregular patches
of vegetation, soil and rock outcrops. Natural and man-made barriers such as ridge tops and
roads would be used to control fires reducing the need for constructed fire lines. This would
reduce the line and color contrasts introduced on the landscape. Fire blackened, dead vegetation
interspersed with areas of unaltered, live vegetation would create color contrasts. This would
remain noticeable to the casual observer for at least three years. Changes in texture would
depend primarily on viewing distance.
As the revegetation of grasses and shrubs occurs, the fire's visual effects could change. This
change would add greater visual diversity to the landscape. Visual Resource Management
(VRM) classes have been established for the Ely District (VRM section of the MN&PF Plan).
VRM Class I objectives would be met because the action would preserve the existing character
of the landscape by allowing for natural ecological change.
No Action
In the long-term there would be a need for more ground disturbing fire suppression activities
resulting in line and color contrasts. Impacts would be similar to those described in the proposed
action except that more large, hot fires would create larger scale contrasts in the landscape.
VRM Class I objectives would be met because the standard operating procedures for "Light-hand
16
on the Land" fire suppression methods would preserve the existing character of the landscape.
Wilderness Values
Proposed Action
There are portions of sixteen wilderness study areas (WSAs), and one instant study area (ISA)
(Hereafter referred to collectively as "WSAs") and one wilderness designated within the plan
area (Figure 2 of the MN&PF Plan). Fire suppression within wilderness and WSAs will be in
accordance with the approved wilderness management plan and the Interim Management Policy
for Lands Under Wilderness Review, respectively. Table 5 Wilderness Areas and Table 4
Wilderness Study Areas of the MN&PF Plan lists acreage within the plan area. Fires within
wilderness and WSAs would be evaluated regarding the potential for fires to maintain wilderness
values (i.e. solitude, naturalness, primitive and unconfined recreation).
Removal of visual screening provided by tree cover would make it more difficult for wilderness
visitors to avoid the sights, sounds, and the evidence of other visitors (i.e. solitude) within the
wilderness or WSA. The magnitude of this impact would depend on the size and location of the
fire, and the vegetative community burned.
In the long-term use of managed natural and prescribed fires would help maintain the plant
diversity in fire-dependent ecosystems in wilderness and WSAs. This would enhance the
naturalness of these areas through the restoration of native plant communities and normal
(historic) fire return intervals (Table 1 of the MN&PF Plan). If rehabilitation is necessary after a
managed natural fire, only native seed will be used in WSAs in accordance with the Interim
Management Policy for Lands Under Wilderness Review. Managed natural and prescribed fires
would also increase vegetative mosaics and reduce fuel loading and continuity. The effects of
fire within a wilderness area or WSA may be visually evident for decades.
Primitive and unconfined types of recreational use may be affected within burned areas. In the
short-term visitors may avoid a burned area. Visitors may be attracted to burned areas as re-vegetation
occurs.
No Action
Fire suppression within wilderness and WSAs will be in accordance with the approved
wilderness management plan and the Interim Management Policy for Lands Under Wilderness
Review, respectively. Because full suppression would be used on all fires within wilderness and
WSAs, there would be a continuation of fuel build-ups which would result in more large, hot
fires. The short-term impacts would be similar to those described in the proposed action.
The long-term impacts on wilderness values as described under the proposed action, would not
occur. The longer that fire is absent from these areas, the greater the potential for stand replacing
fires within the woodland communities. This could reduce wilderness values (i.e., solitude,
naturalness, primitive and unconfined recreation) for some users.
17
Mining
Proposed Action
Mining claim posts would be burned in a managed natural fire. These claims would then need to
be restaked and/or resurveyed. This would be an economic burden on the claimant. It is also
possible, but less likely, that claim posts would be burned in a prescribed fire. Affected mine
claimants will be identified and notified prior to implementation of prescribed fires. There
would be no impacts to mining facilities and operations.
No Action
Impacts would be similar to those described in the proposed action.
Woodland Products
Proposed Action
Woodland products that are harvested for personal and commercial use include firewood, pine
nuts, fenceposts, and Christmas trees. The impacts on the availability of these woodland
products would be inconsequential. The supply of these products, except for pine nuts, exceeds
demand. The pinyon-juniper woodland contains an estimated 20 million cords of firewood
within the District, while firewood permits sold throughout the District total less than 5,000
cords per year. Pine nut production is a function of climatic conditions, which are beyond the
scope of this document.
No Action
The impacts would be similar to the proposed action.
B. Cumulative Impacts
According to BLM handbook Guidelines For Assessing and Documenting Cumulative Impacts
(1994), the amount of analysis that is necessary can be greatly reduced by limiting cumulative
analysis only to those issues and resource values identified during scoping that are of major
importance. The resource values of major importance which will be analyzed are: 1) re-introduction
of wildland fire into the ecosystem, and 2) vegetation health (i.e. cover and
composition) in the plan area.
Past actions
Past land use practices have altered vegetation communities. Livestock grazing has occurred in
the plan area since the mid 1800s with an increase in intensity until the 1930s. This resulted in a
decrease of grasses and forbs and an increase in shrubs and trees. The change in vegetation
increased the frequency of large, stand replacing fires.
18
Woodland products were extensively harvested throughout eastern Nevada in the late 19 th century
for the mining industry. These practices removed the trees and reduced fuel loading within these
vegetation communities. Since 1900 pinyon and juniper trees have re-established on these sites
and expanded into adjacent vegetation communities.
Beginning in the 1930s the federal government started managing public lands which included fire
suppression. BLM placed more emphasis on suppressing fires. As a consequence, vegetation
cover and composition changed. Shrub and tree densities increased as well as canopy cover.
Grasses and forbs decreased as a result of competition for light, space and nutrients. Vegetation
communities became less diverse and more even-aged. Woody species (i.e., shrubs and trees)
increased fuel loading which resulted in more large, hot fires.
Human caused climatic change has also altered vegetation cover and composition. Increases in
carbon dioxide levels have been detected globally. Research has shown higher carbon dioxide
levels favor the growth of woody species as well as some invasive weeds.
In the past 40 years, approximately 274,000 acres of vegetation conversion projects have been
completed in the Ely District, most of which occurred in the plan area. These projects were
designed to reduce the cover of sagebrush or pinyon and juniper trees, and increase the
herbaceous vegetation through seeding grasses and forbs. Trees and shrubs have re-established
in many of these sites. Prescribed fire was the primary method used to maintain these projects.
In the past prescribed fire was also used on a limited basis to enhance riparian areas.
Present actions
The trend toward more large, hot fires continued in 2000 (see Table 1). Current fire management
practices and policies perpetuate fuel loading.
Current land management is focused on improving vegetative condition within the plan area.
Permitted use by livestock and appropriate management levels for wild horses are being
established. Vegetation conversion projects (e.g., mechanical treatments and prescribed fire) are
being implemented to create openings within even-aged stands of shrubs and trees. Efforts to
inventory and minimize the spread of noxious and invasive weeds are continuing.
Reasonably forseeable future actions
It is anticipated that the number of natural fire ignitions will be similar to previous years.
Prescribed fires will continue to be used on a limited basis.
Livestock grazing will continue to be managed to meet Resource Advisory Council Standards.
Wild horses will be managed at appropriate levels. Wilderness designations within the plan area
will occur. Wilderness management plans will be written which will consider fire management.
Urban interface will continue to be a concern in the management of fires within the plan area.
Efforts to detect and control noxious and invasive weeds will increase.
19
The Great Basin Restoration Initiative has been proposed to restore vegetation communities in
this ecosystem. In the Ely District this would be implemented as the Eastern Nevada Landscape
Restoration Project which would provide the funding to implement approved activity plans (e.g.,
Fire Management Plans, Allotment Management Plans, Elk Management Plans, Habitat
Management Plans). In the foreseeable future, approximately 100,000 acres within the Ely
District are being proposed for treatment annually to improve the health of vegetation
communities.
Conclusion-Cumulative effects
Proposed Action
Managed natural and prescribed fire would be used, as one of several methods, to reduce fuel
build-up within the plan area. Acres burned under the MN&PF Plan would contribute to the
100,000 acres being proposed for treatment annually within the Ely District. The cumulative
impact would be a mosaic of vegetation communities throughout the plan area allowing fire to
resume a more natural role in the ecosystem.
No Action
Managed natural fires would not occur, therefore substantially less than 100,000 acres would be
treated annually. There would be an increase in fuel loading which would lead to more large, hot
fires and a reduction in the mosaic of vegetative communities throughout the entire plan area.
Fire would not be allowed to resume a more natural role in the ecosystem.
V. PROPOSED MITIGATING MEASURES
Mitigating measures to minimize impacts are part of the proposed action and are included in the
Standard Operating Procedures (Appendix F of the MN&PF Plan). No additional mitigation is
proposed in response to anticipated impacts.
VI. SUGGESTED MONITORING
The Ely District Managed Natural and Prescribed Fire Plan establishes monitoring procedures
and reporting requirements for fire, vegetation, watershed, and human resource management
objectives. These procedures can be found in Section VI of the MN&PF Plan. No additional
monitoring is suggested as a result of the analysis of anticipated impacts.
VII. CONSULTATION AND COORDINATION
Intensity of Public Interest and Record of Contacts
In 1995, the Ely District began to implement the Federal Wildland Fire Management Policy and
20
Program Review. A technical review team (TRT) was formed to prepare a fire management plan
which would allow fire to resume a more natural ecological role for all lands within the Ely
District. The Ely District Fire Management Plan was approved in August 1998, and an
environmental assessment analyzing the impacts of managed wildland fires within the Snake
Mountain Range was prepared in October 1998. It was determined that the scoping done for
these two documents was adequate in identifying issues pertaining to the proposed action in the
Programmatic Environmental Assessment for the Ely District Managed Natural and Prescribed
Fire Plan.
Appendix 1 lists all representatives from American Indian Tribal governments, state agencies,
local government entities, and affected and interested publics who were notified of the
availability of the draft Ely District Managed Natural and Prescribed Fire Plan and the
preliminary Environmental Assessment for Managed Natural Fire and Programmatic Analysis for
Prescribed Fire for the Ely District. These documents were also posted on the Ely Field Office's
Home Page (http://www.nv.blm.gov/Ely) for review beginning on May 18, 2000.
Comments were received from the following:
Kraig Beckstrand and Mike Scott, NDOW Southern Region
Steve Foree, NDOW Eastern Region
John Hiatt, Audubon Society, Red Rock Chapter
Kevin Kirkeby, White Pine County Board of County Commissioners
Jerry Miller, Natural Resources Conservation Service
Rebecca Palmer, NV State Historic Preservation Officer
Steve Smith, NSO BLM
Rose Strickland, Toiyabe Chapter, Sierra Club
Glenn Terry, Public Land Users Advisory Committee, White Pine County
All respondents generally supported the use of managed natural and prescribed fire in the Ely
District. Extensive written comments regarding plan implementation and the NEPA analysis
were received from the Audubon Society and the Sierra Club. These comments and the BLM's
responses are included in Appendix 2.
Internal District Review
Mark Barber Riparian Areas and Special Status Species
Lynn Bjorklund Minerals
Shane DeForest Noxious Weeds and Wild Horses
Gene Drais Assistant Field Manager-Nonrenewable Resources
Bill Dunn Fire Management Officer
Mark Henderson Archeology and Historic Preservation
Susan Howle Environmental Coordination, Recreation, Wilderness and
Visual Resource Management
Eric Luse Associate Field Manager
Mike Main (Team Leader) Fire Ecology
Gary Medlyn Soil, Water, Air
21
Jim Perkins Assistant Field Manager-Renewable Resources
Paul Podborny Range and Wildlife
Jacob Rajala Planning and Environmental Coordination
Curtis Tucker Native American Consultation
Matt Wilkin Geographic Information Systems (GIS)
22
Appendix 1
Notifications Sent
Lincoln County Commissioners
Nye County Commissioners
White Pine County Commissioners
State of Nevada, Office of the Attorney General c/o Mr. Wayne Howle
American Horse Protection Association
Animal Protection Institute of America
The Humane Society of the United States
Commission for the Preservation of Wild Horses
National Mustang Association, Inc.
National Wild Horse Association
Wild Horse Organized Assistance c/o Mrs. Dawn Lappin
Nevada Division of Wildlife State Headquarters c/o Mr. Stan Stiver
Nevada Division of Wildlife State Headquarters c/o Mr. Doug Hunt
Nevada Division of Wildlife Eastern Region
Nevada Division of Wildlife Southern Region
Nevada Division of Wildlife c/o Mr. Mike Podborny
Nevada Division of Wildlife c/o Mr. Mike Scott
Nevada Division of Wildlife c/o Mr. Curt Baughman
U. S. Fish and Wildlife Service (Reno)
Nevada State Clearinghouse (Carson City)
Sierra Club, Toiyabe Chapter c/o Ms. Rose Strickland
Sierra Club, Toiyabe Chapter c/o Mr. Glen Miller
23
Sierra Club, Toiyabe Chapter c/o Ms. Marjorie Sill
Duckwater Tribal Council c/o Mr. Jerry Millet
Moapa Business Council c/o Mr. William Anderson
Te-Moak Tribe of Western Shoshone c/o Ms. Christine Stones
Ely Shoshone Tribe c/o Mr. Authur Kammassee
Goshute Tribal Council c/o Mr. David Pete
The Nevada State Historic Preservation Office c/o Ms. Rebecca Lynn Palmer
The Wilderness Society (Washington DC)
The Wilderness Society CA/NV Regional Director c/o Mr. Jay T. Watson
The Wilderness Society c/o Mr. Norbert Riedy
Friends of Nevada Wilderness c/o Mr. Pat Dingle
Friends of Nevada Wilderness (Las Vegas)
Friends of Nevada Wilderness c/o Mr. Tom Myers
Audubon Society, Red Rock Chapter c/o Mr. John Hiatt
Nevada Outdoor Recreation Association c/o Mr. Charlie Watson
Nevada Wildlife Federation c/o Mr. Gale G. Dupree
Bureau of Land Management Washington Offices Wilderness c/o Mr. Jeff Jarvis
Bureau of Land Management Wilderness c/o Mr. Steve Smith
Department of Conservation and Natural Resources Division of Environmental Protection
Great Basin National Park
USFS Ely Ranger District
Nature Resource Conservation Service c/o Jerry Miller
Ms. Kathryn Ataman Northeastern Great Basin Resource Advisory Council
Mr. Bob Edwards Northeastern Great Basin Resource Advisory Council
24
Mr. Vince Garcia Northeastern Great Basin Resource Advisory Council
Mr. Robert McGinty Northeastern Great Basin Resource Advisory Council
Mr. Dave Tattam Northeastern Great Basin Resource Advisory Council
Mr. Larry W. Barngrover Northeastern Great Basin Resource Advisory Council
Mr. Scott Egbert Northeastern Great Basin Resource Advisory Council
Dr. Hudson A. Glimp Northeastern Great Basin Resource Advisory Council
Mr. Jon L. Muller Northeastern Great Basin Resource Advisory Council
Ms. Patsy Tomera Northeastern Great Basin Resource Advisory Council
Ms. Teresa A. Conner Northeastern Great Basin Resource Advisory Council
Mr. Brent Eldridge Northeastern Great Basin Resource Advisory Council
Mr. Merlin McColm Northeastern Great Basin Resource Advisory Council
Mr. F. Deloyd Satterthwaite Northeastern Great Basin Resource Advisory Council
Mr. Bill W. Upton Northeastern Great Basin Resource Advisory Council
Ms. Marta Agee Mojave-Southern Great Basin Resource Advisory Council
Mr. Maurice Frank Mojave-Southern Great Basin Resource Advisory Council
Mr. Gary Hollis Mojave-Southern Great Basin Resource Advisory Council
Mr. Steve Mellington Mojave-Southern Great Basin Resource Advisory Council
Mr. Duane L. Whiting Mojave-Southern Great Basin Resource Advisory Council
Ms. Colleen Beck Mojave-Southern Great Basin Resource Advisory Council
Mr. Jerry Helton Mojave-Southern Great Basin Resource Advisory Council
Mr. Alan N. Levinson Mojave-Southern Great Basin Resource Advisory Council
Ms. Susan Selby Mojave-Southern Great Basin Resource Advisory Council
Mr. Mike Wickersham Mojave-Southern Great Basin Resource Advisory Council
25
Ms. Barbara Callihan Mojave-Southern Great Basin Resource Advisory Council
Mr. Jonh E. Hiatt Mojave-Southern Great Basin Resource Advisory Council
Mr. Robert W. Maichle Mojave-Southern Great Basin Resource Advisory Council
Mr. Stanley Smith Mojave-Southern Great Basin Resource Advisory Council
Keith Gibson
Mr. Glenn Terry