Updated BLM Sensitive Species List for Nevada & Statewide BLM Nevada Special Status Species (BLM NV SSS) Observation Form

Instruction Memorandum

1340 Financial Boulevard
Reno, NV 89502
United States

In Reply Refer To:

6840 (930) P

To:District and Field Office Managers, Nevada
From:Jon K. Raby State Director
Subject:Updated BLM Sensitive Species List for Nevada & Statewide BLM Nevada Special Status Species (BLM NV SSS) Observation Form
Program Area:6840 Special Status Species Management

The purpose of this Instruction Memorandum (IM): 1) Replace expired IM-NV-2018- 003, Updated BLM Sensitive Species List for NV, which listed sensitive plant and animal species that occur on BLM administered lands in NV consistent with Manual Section 6840 and current WO-230 guidance; 2) Provide BLM NV SSS Observation Form for statewide data collection, storage, and management.

Administrative or Mission Related:

Mission Related.


Attached is the BLM NV Special Status Species List (Attachment 1) which includes an updated list of BLM sensitive species for Nevada, as designated by the State Director. The BLM NV SSS list was developed using the criteria set forth in BLM Manual Section 6840, Special Status Species Management. This IM also provides a geospatial tool, the BLM NV SSS Observation Form (Survey123), for statewide special status species data collection, storage, and management in BLM NV.

Management of BLM-designated sensitive species follows the Special Status Species policy as identified in BLM Manual 6840 (12/12/2008).

BLM NV SSS observation data shall be recorded using the BLM NV SSS Observation Form and data will be stored/managed centrally in BLM NV’s statewide geospatial dataset. Quality control (i.e., Passed, Incomplete) will be required for observation data by Districts by November 15, 2024, and subsequent years under this IM.

The BLM NV SSS list does not replace the need to use the USFWS’ IPaC (https://ipac.ecosphere.fws.gov/) to obtain a list of species (endangered, threatened, proposed) and/or critical habitat under the Endangered Species Act of 1973, as amended (ESA). USFWS’ designated candidate species are included on the BLM NV SSS list as BLM Sensitive (BLM Manual Section 6840).

If a species changes status and meets BLM NV SSS criteria and is not currently on the BLM NV SSS list, then the species may be added to the current BLM NV SSS list until an updated BLM sensitive species list is issued by the State Director. The 1170 Program Lead will provide this notification in the interim until an BLM NV SSS list is updated (every 5 years or less).

Species that are listed as “known” on a BLM District reflects the best available science of the species’ distribution at the time of this BLM NV SSS list update. However, if suitable habitat exists in a District Office’s jurisdiction, then the suitable habitat should be surveyed to assess species distribution. If detected as present, the species should be analyzed in the NEPA document for proposed project effects to reduce the likelihood and need for future listing under the ESA (BLM Manual Section 6840).

Habitat accounts provided in this BLM NV SSS list were derived from Nevada Division of Natural Heritage (NDNH) and Nevada Department of Wildlife (NDOW) at the time of the BLM NV SSS list update. Districts are responsible for obtaining and incorporating current habitat accounts at the time of their NEPA analyses and decisions.


This list is effective immediately.

The BLM NV SSS list will remain in place until the next list update (recommended every 1-3 years but no more than five) except for changes relating to USFWS listing status which becomes effective as of the effective date in the Federal Register Notice. Similarly, newly designated Federal candidate species are immediately considered BLM sensitive (if not already sensitive) on BLM Districts where the species is documented or suspected to occur.

Budget Impact:



The BLM Manual (6840) directs BLM to manage special status species and their habitats to minimize or eliminate threats affecting the status of the species or to improve the condition of the species’ habitat. For clarity, special status species broadly describes two categories of conservation status: (1) species listed or proposed for listing under the Endangered Species Act (ESA), and (2) species requiring special management consideration to promote their conservation and reduce the likelihood and need for future listing under the ESA, which are designated as BLM sensitive by the State Director(s). The Manual describes the following mandate and procedure for designating BLM sensitive species:

In compliance with existing laws, including the BLM multiple-use mission as specified in the Federal Land Policy and Management Act of 1976, the BLM shall designate BLM sensitive species. BLM also implements measures to conserve these species and their habitats, including ESA proposed critical habitat, to promote their conservation and reduce the likelihood and need for such species to be listed pursuant to the ESA. All federally designated candidate species, proposed species, and delisted species in the 5 years following their delisting shall be conserved as BLM sensitive species.

State Directors shall designate species within their respective states as BLM sensitive using the following criteria. For species inhabiting multiple states, State Directors shall coordinate with one another in the designation of BLM sensitive species so that species status is consistent across the species’ range on BLM administered lands, where appropriate.

Species designated as BLM sensitive must be native species found on BLM administered lands for which the BLM has the capability to significantly affect the conservation status of the species through management, and either:

  1. There is information that a species has recently undergone, is undergoing, or is predicted to undergo a downward trend such that the viability of the species or a distinct population segment of the species is at risk across all or a signification portion of the species’ range, or
  2. The species depends on ecological refugia or specialized or unique habitats on BLM administered lands, and there is evidence that such areas are threatened with alteration such that the continued viability of the species in that area would be at risk.

Criteria for Determining Update of BLM NV SSS list:

For taxon to be included, it must potentially occur or be known to occur on BLM-administered lands. BLM must have the capability to significantly affect the conservation status of the taxon through management. Taxon must be a native and resident for a portion of the year and not strictly migratory through Nevada.

For taxa considered under the Endangered Species Act, as amended, to be included on the BLM NV SSS list, one of the following criteria must be met within the state:

  1. All U.S. Fish and Wildlife Service (USFWS) Listed and Proposed species.
  2. All taxa receiving a positive 90-day finding within the state documented on BLM administered lands until the publication of a 12-month finding.
  3. Candidates are considered Sensitive within the state where suitable habitat exists on BLM-administered lands.
  4. All de-listed USFWS taxa within the last five years are within the state where suspected or documented on BLM-administered lands or for the duration of their delisting monitoring plan.

For all other taxa, at least one of the following criteria must be met:

  1. Taxa with a global rank of G3 or below.
  2. Taxa with a state rank of S3 or below.
  3. Taxa with a trinomial rank of T3 or below.
  4. Taxa have stressors/threats and/or declining population trends.
  5. Taxa on BLM-administered lands negatively affected by changes in water quality or quantity.
  6. Endemism – taxa occurring in a single geographic location (e.g., spring/spring complex, valley, mountain range), and thus, have a higher risk of extinction/extirpation.

NatureServe Network Global (G), State (S), Trinomial (T) Ranks:

1 = Critically imperiled
2 = Imperiled
3 = Rare and uncommon; vulnerable
4 = Not rare and apparently secure
5 = Secure

NatureServe Rank Qualifiers:
#X# = Range rank - A numeric range rank (e.g., G2G3, G1G3) is used to indicate uncertainty about the exact status of a taxon

Taxa include vertebrates, invertebrates, and non-animal kingdoms.

This updated BLM NV SSS list replaces the prior list and reflects the following changes:

  1. District occurrence information is updated.
  2. Taxonomic information is updated.
  3. Species’ listing status under the ESA is updated.
  4. Species removed = 27 due to increased distribution and conservation status.
  5. Species added = 190 species, primarily due to increase of endemic species. New list has a total of 604 species which is an increase from prior list of 414; however, list is now comprised of 49% endemic species.
  6. The Cactus family (Cactaceae) is added due to their vulnerability to poaching and the requirement of a Forest Product Permit System. However, the Cactus family is not required to be analyzed in the NEPA process unless a specific species is included in the BLM NV SSS list.
  7. Swamp Cedar Population of Rocky Mountain Juniper is included for awareness of cultural significance to local Tribal Nations.
Manual/Handbook Sections Affected:

This IM supersedes IM-NV-2018-003, Updated Bureau of Land Management (BLM) Sensitive Species List for Nevada


For questions or comments, contact Quinn Young, 1170 Program Lead and State Lead for Threatened & Endangered and Special Status Species Programs, (775) 861-6475, qyoung@blm.gov.


The updated list was coordinated with BLM Nevada, Regional BLM Solicitor, partners including U.S. Fish and Wildlife Service (Migratory Birds and Ecological Services), Nevada Division of Forestry, Natural Division of Natural Heritage, Nevada Department of Wildlife, and other federal and state agencies along with local and nonprofit organizations.