Ann: BLM Issues Draft Environmental Impact Statement, page-9

Considering the herbivore attack in 2020 that significantly affected Tiehm’s Buckwheat, the analysis of project alternatives under the DEIS should take into account the resilience of the species to unexpected natural events.

Summary of Alternatives Impacting Tiehm’s Buckwheat-

**No Action Alternative**

This alternative involves no project development and hence no direct disturbance to the habitat from construction activities. However, it also means no active management measures are put in place to prevent or mitigate future herbivore attacks, which previously resulted in substantial damage to the plant population.

**Proposed Action**

This would proceed with full development, potentially leading to significant habitat loss. The development could exacerbate the species' vulnerability by possibly increasing herbivore access and reducing the plants' ability to recover from such events, given their reduced habitat space.

**Reduced Footprint Alternative**

While this reduces the development area, it might still not adequately address the risk of herbivore attacks without specific management strategies focused on this issue.

**Conservation Management Alternative**

This alternative seems most promising for enhancing long-term protection, particularly if it includes targeted measures to guard against herbivore damage, such as protective barriers around critical habitats or managed relocations of herbivore populations. This approach would aim to balance habitat preservation with proactive management to both mitigate development impacts and enhance the species' resilience to natural threats.

## Comparative Analysis and Long-Term Protection

The 2020 herbivore attack highlights the vulnerability of Tiehm’s Buckwheat to natural disturbances, underscoring the importance of incorporating adaptive management strategies into any development plan. Given this, the **Conservation Management Alternative** could offer the best long-term protection strategy, as it not only mitigates the direct impacts of construction but also implements specific measures to prevent future herbivore attacks.

This alternative would likely be more beneficial than the **No Action Alternative**, which, while preserving the current habitat, does not proactively address the demonstrated threat from herbivores or improve the ecological resilience of the species.

Therefore, when evaluating the alternatives in the context of both development impact and natural disturbances, the Conservation Management Alternative, with its dual focus on mitigating development impacts and enhancing species resilience, could provide the most comprehensive long-term protection for Tiehm’s Buckwheat.