Bureau of Land Management 17-state Vegetation Management Plan/EIS

Comments submitted by Restore Native Ecosystems Coalition

Comments submitted by Californians for Alternatives to Toxics

Comments submitted by California Oak Foundation

Comments submitted by California Indian Basketweavers Association

Comments submitted by California Native Plant Society

Comments submitted by Center for Biological Diversity

Comments submitted by Natural Resources Defense Council and National Wildlife Federation

TIMELINE OF RESTORE NATIVE ECOSYSTEMS COALITION PARTICIPATION IN DEVELOPMENT OF BLM VEGETATION TREATMENTS EIS/PER (November 2006)
DATE	OCCURRENCE/ EVENT	DOCUMENT	DETAIL	THE "LOWDOWN"
Oct. 12, 2001	The Bureau of Land Management (BLM) issues first scoping notice of intent to prepare an environmental impact statement "for the conservation and restoration of vegetation, watershed, and wildlife habitat treatments on public lands…"	Federal Register Notice 66 Fed. Reg. 52148 "Notice of Intent To Prepare an Environmental Impact Statement for the Conservation and Restoration of Vegetation, Watershed, and Wildlife Habitat Treatments on Public Lands Administered by the Bureau of Land Management in the Western United States Including Alaska"	Action: Notice of intent to prepare a national, programmatic environmental impact statement. Summary: … the BLM will prepare a national, programmatic EIS and conduct public scoping meetings on (1) management opportunities and treatment methods for noxious weeds and other invasive species, and (2) the conservation and restoration of native vegetation, watersheds, and wildlife habitat. The EIS will cover the public lands administered by BLM in eleven western States, including Alaska.	The BLM issued a public notice of its intent to develop a single document pursuant to NEPA to analyze the effects of various treatments to control non-native vegetation and reduce the risk of wildfire on BLM lands in 16 western states, including "the conservation and restoration of native vegetation, watersheds, and wildlife habitat." The new environmental impact statement would analyze "restoration activities" including, but not limited to, "prescribed fire; riparian restoration; native plant community restoration; invasive plants and noxious weeds treatments; under-story thinning; forest health treatments; or other activities related to restoring fire adapted ecosystems."
January 2, 2002	The BLM extended the public comment period and scheduled dates for public scoping meetings for the proposed vegetation management EIS	Federal Register Notice 67 Fed. Reg. 101 "Notice of Extension of Public Comment Period and Schedule of Public Scoping Meetings for the Environmental Impact Statement for the Conservation and Restoration of Vegetation, Watershed, and Wildlife Habitat Treatments on Public Lands Administered by the Bureau of Land Management in the Western United States, Including Alaska"	Action: Notice of extension of public comment period for scoping; and dates and locations for public scoping meetings. Summary: … the BLM will prepare a national, programmatic EIS and conduct public scoping meetings on (1) management opportunities and treatment methods for noxious weeds and other invasive species, and (2) the conservation and restoration of native vegetation, watersheds, and wildlife habitat. The EIS will cover the public lands administered by BLM in 16 western states, including Alaska. The period for initial scoping comments from the public has been extended to March 29, 2002.	This second scoping notice restated all information contained in the first notice, and included the following disclaimer: "The EIS is not a land-use plan or a land-use plan amendment. It will provide a comprehensive programmatic NEPA document to allow effective tiering and serve as a baseline cumulative impact assessment for other new, revised or existing land use and activity level plans that involve vegetation, wildlife habitat and watershed treatment, modification or maintenance."
Jan. 22, 2002	The BLM changed its schedule for public scoping meetings and restated the purposes for the proposed vegetation management EIS.	Federal Register Notice 67 Fed. Reg. 2901 "Changes to the Schedule and Scope of Public Scoping Meetings for the Environmental Impact Statement for Vegetation Treatments, Watersheds and Wildlife Habitats on Public Lands Administered by the Bureau of Land Management in the Western United States, Including Alaska"	Action: Supplemental Notice to Change to Dates for Public Scoping Meetings and change the scope of the EIS. Summary: … the BLM will prepare a national, programmatic EIS and conduct public scoping meetings on BLM's use of prescribed burning, biological control, cultural practices, mechanical, and chemical treatment of vegetation, including noxious weeds and other invasive species in public lands management. These methods will continue to be integrated into BLM's efforts to conserve and restore native vegetation, watersheds and wildlife habitats to protect people, sustain natural resources and provide for longterm multiple uses. The EIS addresses public lands administered by BLM in 16 western states, including Alaska. The public may submit comments during the initial scoping period through March 29, 2002.	This third scoping notice increased the number of acres to be treated under the proposed vegetation management EIS on BLM lands from 4 to 5 million acres annually to more than 6 million acres, and identified new issues for consideration, including effects of vegetation management on "American/Alaskan Native subsistence practices" and "the effects of treatments on vegetation, soils, watershed and water quality."
March 29, 2002	The Restore Native Ecosystems Coalition sent a letter to the responsible official at BLM confirming previous communications that RNEC could submit a citizens' alternative for the proposed vegetation management EIS after the deadline for scoping comments had passed.	Restore Native Ecosystems Coalition, scoping letter to Brian Amme, BLM Restore Native Ecosystems Alternative - Outline	The [signed] organizations request that the Bureau of Land Management include an alternative we are drafting in the Draft Environmental Impact Statement for Vegetation Treatments, Watersheds and Wildlife Habitats on Public Lands Administered by the Bureau of Land Management in the Western United States, Including Alaska (DEIS). The alternative focuses on preventing and treating the spread of invasive species and restoring native ecosystems. A summary outline of our alternative, entitled the "Restore Native Ecosystems Alternative," is attached. In telephone conversations with Caroline Cox and Mark Salvo, you indicated that we could submit an outline of our alternative by the end of the scoping period, and submit our full alternative within the next 4-6 weeks (when the BLM is expected to complete its own alternatives). We will forward our full alternative by April 28, or when the BLM is has prepared its alternatives, whichever comes later.	The Restore Native Ecosystems Coalition (RNEC) was created to develop an alternative for the proposed BLM vegetation management EIS that identifies the causes of weed spread and fire fuel build-up and prescribes measures to prevent conditions that favor invasive species and hazardous forest fuel loads, and restore sites that would be sprayed, burned, chained, or logged by BLM to reduce invasive species and fuel loads on public lands. RNEC's scoping letter described why the Restore Native Ecosystems Alternative (RNEA) was within the scope of the EIS and was a "reasonable" alternative under NEPA. An outline of the RNEA was attached to the letter, which was signed by twenty-six organizations.
April 29, 2002	RNEC submitted a complete Restore Native Ecosystems Alternative to BLM, including supporting science documents and annotated bibliography.	Restore Native Ecosystems Coalition, cover letter to Brian Amme, BLM Attachment 1: Restore Native Ecosystems Alternative (ver. 1) Attachment 2: Annotated Bibliography for Restore Native Ecosystems Alternative	The Restore Native Ecosystems Alternative emphasizes prevention, treatment, conservation, and restoration as a means to restore ecosystem resilience and function, enhance diminished native plant and wildlife populations, and provide for future generations of visitors to BLM lands. In this sense, the Restore Native Ecosystem Alternative differs from other alternatives discussed by BLM, but seeks to achieve the same ends. Therefore, we respectfully request that the Bureau of Land Management (BLM) fully analyze this alternative in the draft and final environmental impact statement (EIS) for the project. As you know, we have worked closely with BLM for the last two months in developing this alternative in a timely manner that will not delay BLM's analysis, and in a manner that will make the alternative useful as BLM moves forward with the NEPA process.	RNEC submitted the RNEA (ver. 1) to BLM along with a cover letter that described the legal basis for analyzing the full alternative in the vegetation management EIS, more than 100 science documents supporting contentions and management prescriptions in the RNEA, and an annotated bibliography of those documents. Forty-three organizations signed the cover letter to BLM.
May 7, 2002	The BLM lead for the vegetation management EIS communicated with RNEC about his concerns that the RNEA is outside the scope of the EIS.	Brian Amme, BLM, electronic mail to Mark Salvo, American Lands Alliance, re: "Restore Native Ecosystems Alternative"	Basically, [BLM's] alternatives address a range of acreages and methods of treatments to be considered and employed. It appears the RNE "alternative" is more of a management strategy than a true alternative for analysis in this EIS. In many ways it resembles a strategy that might be considered in an effort such as the ICBEMP in Idaho. I assume [RNEC] would have attended the scoping meetings, and therefore you would know that this EIS is not that type of planning effort.	The BLM responded that much of the RNEA is outside the scope of the vegetation management EIS.
June 14, 2002	The BLM lead for the vegetation management EIS reviewed and commented on the RNEA (ver. 1).	Brian Amme, BLM, electronic mail to Mark Salvo, American Lands Alliance, re: "Restore Native Ecosystems Alternative re-draft" BLM Comments on Restore Native Ecosystems Alternative (ver. 1)	…please consider that the scope of this project has been determined and there are specific areas which will not be addressed. I believe that your coalition needs to truly take a hard look at what it is that you want to propose for analysis. The [RNEA] appears to be a smorgasboard of nice to do things and existing policy, and in some areas contradicts itself or needs better definition. As it is, there is not a lot of difference between what is proposed and what the BLM is already doing or proposing to do.	After reviewing the RNEA (ver. 1), the BLM responded that much of the alternative is redundant with existing BLM policies or outside the scope of the EIS.
July 2002	BLM published first EIS newsletter	Vegetation EIS Update (BLM newsletter) Vol. 1 No. 1 "BLM Continues Work on Vegetation Treatments Programmatic Environmental Impact Statement"
January 2003	BLM published second EIS newsletter	Vegetation EIS Update (BLM newsletter) Vol. 2 No. 1 "BLM Vegetation EIS Efforts Focus on Human Health and Ecological Risk Assessments"	The BLM engaged in a "long and challenging process" of assessing the human health and ecological risks of several chemical herbicides it will propose to use on public lands in the forthcoming EIS.	From the newsletter, p. 1: "Unless new information is available to indicate the need for additional studies, herbicides approved for use in ... earlier EISs will not be evaluated in this EIS. However, the BLM does propose the use of four new herbicides--Diquat ... Fluridone ... Imazapic ... and Diflufenzopyr ... and is conducting human health and ecological risk assessments to determine the risks to humans, fish, and wildlife from the use of these herbicides." Does NEPA require tabula rasa review of all herbicides proposed for use on public lands, including herbicides that were analyzed in previous EISs? What if the previous EISs did not adequately assess the risks of herbicides approved for use on public lands?
August 26, 2003	RNEC submitted a revised RNEA (ver. 2) to BLM for consideration for the vegetation management EIS, based on comments received from BLM.	Restore Native Ecosystems Coalition, cover letter to Brian Amme, BLM Attachment 1: Restore Native Ecosystems Alternative (ver. 2) Attachment 2: Response to the Bureau of Land Management's Claims Regarding Existing Authorities and Policies for Invasive Species Management Attachment 3: Additional Documents Relevant to Analysis of Alternatives in the Bureau of Land Management Sixteen-state Vegetation Management Plan Draft Environmental Impact Statement (Annotations) Attachment 4: BLM Comments on Restore Native Ecosystems Alternative (ver. 1)	[The RNEC has] considered your comments and hope that continued dialogue during the development of the Bureau of Land Management's programmatic environmental impact statement for vegetation treatments leads to the development of a credible and viable approach to vegetation problems. We are sympathetic to the challenges faced by the BLM in remedying massive vegetation problems across 262 million acres. However, we have deep concerns about the agency's approach and understanding of its legal obligations pursuant to, inter alia, the National Environmental Policy Act of 1969 and the Federal Land Policy and Management Act of 1976. We believe the BLM's approach is well intended but flawed with consequent significant negative implications for public lands.	RNEC submitted a revised RNEA (ver. 2) to BLM based on the agency's comments on the first version of the alternative. The alternative was redrafted to accommodate BLM's preferred format to the extent consistent with the RNEA's fundamental principles. RNEC also submitted additional supporting materials for the RNEA to BLM, including our response to certain claims by BLM about the agency's existing authority to manage invasive species and an additional annotated bibliography of science documents that support the contentions and management prescriptions in the RNEA. Thirteen organizations joined the cover letter conveying the revised RNEA to BLM.
March 2005	BLM published third EIS newsletter announcing that the vegetation management EIS will be split into two documents.	Vegetation EIS Update (BLM newsletter) Vol. 3 No. 1 "BLM Plans Spring Publication of Draft Documents on Vegetation Treatment in Western United States"	The BLM originally planned to develop a single Programmatic EIS that would analyze the impacts of annual vegetation treatments on up to 6 million acres. A variety of methods, including prescribed fire, application of herbicides and biological control agents, and mechanical and manual removal would be evaluated. The BLM decided it would be more effective to prepare two documents to assess vegetation treatment activities on public lands: 1. Vegetation Treatment Using Herbicides Programmatic EIS to address the BLM's use of herbicides on public lands, and 2. Vegetation Treatments Programmatic Environmental Report to describe the environmental impacts of using non-herbicide treatment methods, including fire and mechanical, manual or biological controls.	Why will non-herbicide treatments be split off into a second document?
November 2005	BLM published draft documents to manage vegetation on BLM lands in 17 western states.	I. Draft Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact Statement (PEIS) II. Draft Vegetation Treatments on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Report (PER)	The PEIS is described as an independent land use plan and is not an amendment to existing land use plans. (Land use plans are documents comprised of management decisions for use of public lands.) It provides baseline cumulative impact assessments that local BLM offices can use as they work with local, state and national stakeholders to develop local plans throughout the western states and Alaska. It also provides a comprehensive analysis of the BLM's use of chemical herbicides in various vegetation treatment programs related to hazardous fuels reduction, noxious weed and invasive terrestrial plant species management, and resource rehabilitation following fire and other disturbances on up to 1 million acres of public land per year. The PER provides an assessment of the expected impacts of "other" vegetation treatment methods (fire, mechanical, manual, and biological) on up to 5 million acres of public land a year.	Why two documents? Has BLM violated NEPA by splitting its vegetation management plan into two documents? Has BLM adequately addressed the effects of herbicides on native flora and fauna? Has the agency recommended using fewer, less, and/or less-toxic herbicides in the PEIS? What is a "programmatic environmental report"? Why isn't the PER analyzed under NEPA? Is the RNEA included in either or both documents? Has the agency adequately addressed the causes of invasive species spread in addition to prescribing chemical and other treatments for controlling invasive species?
February 2006	Conservation organizations submitted substantive comments on the PEIS and PER.	Comments submitted by Restore Native Ecosystems Coalition Comments submitted by Californians for Alternatives to Toxics Comments submitted by California Oak Foundation Comments submitted by California Indian Basketweavers Association Comments submitted by California Native Plant Society Comments submitted by Center for Biological Diversity Comments submitted by Natural Resources Defense Council and National Wildlife Federation
June 2007	BLM published final documents to manage vegetation on BLM lands in 17 western states.	I. Final Vegetation Treatments Using Herbicides on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Impact Statement (PEIS) II. Final Vegetation Treatments on Bureau of Land Management Lands in 17 Western States Programmatic Environmental Report (PER)	Very little is changed between the draft and final PEIS and PER.

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