Laserfiche WebLink
-! <br /> _1 <br />Species as well as an evaluation of whether current management objectives for Special Status <br />Species are being met. ' <br />The BLM must also analyze population trends, migration patterns, and detemtine whether _ <br />management objectives are being met. The BLM must refer to and analyze existing data ' <br />collected for Special Status Species over the past several years to make a determination on these <br />issues. Without referring to the existing baseline data collected for these species, the BLM will <br />be unable to determine what conservation strategies, plans, and measures aze and aze not ' <br />working. Consequently, without understanding what is and is not working, the BLM will be <br />unable to make reasonable determinations of the strategies and measures they should implement <br />to conserve species for the project at hand. <br />b. Surveys for Sensitive plant and animal species conducted in the past need to be <br />updated , <br />The surveys and monitoring conducted by the BLM for special status plant and animal species to <br />determine occurrence, distribution, abundance, condition, population dynamics, habitat condition ' <br />and needs, current threats, and whether management objectives aze being met need to be <br />updated. In most cases, the surveys and monitoring for these species is either nonexistent or <br />outdated making it obsolete. In order for the BLM to adequately understand the impact that the <br />proposed project will have on special status species, the agency must update its survey and <br />monitoring data for these species that occur in the projects azea. Specifically, the BLM must <br />monitor for the elements listed above. , <br />c. BLM must develop conservation strategies and management plans for special <br />status species , <br />The BLM is required to develop and implement conservation strategies for Special Status <br />Species.b To date, the BLM's Grand Junction Field Office has failed to adopt, much less ' <br />implement, conservation strategies for any of the federally listed, state-listed, and BLM Special <br />Status Species other than the Razorback sucker and Uinta basin hookless cactus. For Special <br />Status Species, including Sensitive species, the BLM Land Use Planning Handbook states that <br />the agency must: <br />Identify strategies and decisions to conserve and recover special status species. ' <br />Given the legal mandate to conserve threatened or endangered species and BLM's <br />policy to conserve all Special Status Species, land use planning strategies and <br />decisions should result in a reasonable conservation strategy for these species. , <br />Land use plan decisions should be clear and sufficiently detailed to enhance <br />habitat or prevent avoidable loss of habitat pending the development and <br />implementation of implementation-level plans. This may include identifying ' <br />stipulations or criteria that would be applied to implementation actions. <br /> <br />e BLM Manual §§ 6840.06(C)(2)(b), 6840.06(E). <br />r BLM Land Use Planning Handbook H-1601-I, Appendix C at 5. ' <br />Center for Native Ecosystems Page 6 of 24 <br />Scoping Comments for the Proposed Red Cliff Coal Mine <br /> <br />