Orchard Rommey Beck & Associates Inc.

We are very concerned that, af
ter years of public input and an
alysis, the BLM has considered
neither invasive species management that addresse
s the root causes of th
e spread of destructive
invasive species, nor integrated systems of pa
ssive and active restoration of sites occupied by
invasive species. Citizens’ organizations (inc
luding many of the organizations signed below)
previously submitted the Restore Native Ecosys
tems Alternative (“Restoration Alternative”;
DEIS App. G) to the BLM during the scoping proce
ss in 2002 as an alternative for the proposed
vegetation management EIS. The Restorati
on Alternative prescribed measures to
prevent
conditions
 that favor invasive species and
hazardous forest fuel loads; and
restore
 invaded sites
to native ecosystems with both passive and act
ive treatments. We are disappointed that the
Restoration Alternative was not considered as an
 integrated comprehensive alternative in the
DEIS/PER. We incorporate the Re
storation Alternative,
 and all previous communications with
the BLM regarding the Restoration
Alternative, and associated a
nnotated bibliographies here by
reference. These comments also incorporate by
reference comments submitted on the DEIS/PER
by the California Indian Basketweavers Association, California Native Plant Society, California
Oak Foundation, Center for Biologi
cal Diversity, National Wildlife
 Federation and the Natural
Resources Defense Council.  
We are further concerned that the DEIS and PE
R that BLM has produced are contrary to the
National Environmental Policy Act (NEPA). There is
 a direct link – cause and effect – between
some land uses (such as livestock grazing), the
spread of invasive species and the need for
“vegetation treatments” (e.g., manipulation, burning,
herbicide spraying).
It is folly not to
address these links in the DE
IS/PER. Furthermore, splitting out non-chemical vegetation
treatments from herbicides (while avoiding the is
sue of passive restoratio
n altogether) into two
separate documents (one of which is an EIS and
the other a “report”) is
“segmentation,” which is
disallowed under NEPA.