Final Comprehensive Conservation Plan and Environmental Impact Statement Charles M. Russell National Wildlife Refuge UL Bend National Wildlife Refuge Volume 2—Comments and Responses for the Draft Plan and Environmental Impact Statement

              Final Comprehensive Conservation Plan
and Environmental Impact Statement
Charles M. Russell National Wildlife Refuge
UL Bend National Wildlife Refuge
Volume 2—Comments and Responses for the Draft Plan
and Environmental Impact Statement
Montana
April 2012
Prepared by
U.S. Fish and Wildlife Service
Charles M. Russell National Wildlife Refuge
Airport Road
Lewistown, Montana 59457
406 /538 8706
and
Region 6, Mountain–Prairie Region
Division of Refuge Planning
134 Union Boulevard, Suite 300
Lakewood, Colorado 80228
303 / 236 8145
CITATION
U.S. Fish and Wildlife Service. 2012. Final comprehensive conservation plan and environmental impact statement: Charles M.
Russell National Wildlife Refuge, UL Bend National Wildlife Refuge. Volume 2—Comments and responses for the draft plan and
environmental impact statement. Lakewood, Colorado: U.S. Department of the Interior, Fish and Wildlife Service, Mountain–Prairie
Region. 458 p.
ContentsAbbreviations ................................................................................. VCHAPTER 1—Introduction .................................................................... 1CHAPTER 2—Comments from Agencies and Organizations ..................................... 3CHAPTER 3—Comments from Individuals ...................................................... 303How to Find Responses to Individual Comments .................................................. 303Most Common Concerns or Issues .............................................................303Summary of Form Letters .....................................................................313Responses to Individual Comments ............................................................3151000—Purpose and Need ..................................................................3152000—Refuge History, Vision, and Goals ....................................................3163000—Alternatives and Objectives ..........................................................3164000—Affected Environment and Environmental Consequences. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3285000—Planning and NEPA Processes and the Draft CCP and EIS .............................333CHAPTER 4—Public Hearing Testimony ....................................................... 335Billings; September 28, 2010 ...................................................................336Bozeman; September 29, 2010 .................................................................354Great Falls; September 30, 2010 ................................................................370Lewistown; October 12, 2010 ..................................................................381Jordan; October 13, 2010 .....................................................................395Glasgow; October 14, 2010 ....................................................................413Malta; October 14, 2010 .......................................................................427Bibliography ..................................................................................439Table 1. Number of individual comments by grouped comment codes and comment descriptions .........303 Abbreviations
ADAAmericans with Disabilities ActAPFAmerican Prairie FoundationAUManimal unit monthBLMBureau of Land ManagementCCPcomprehensive conservation planCFRCode of Federal RegulationsDEISdraft environmental impact statementDNRCMontana Department of Natural Resources and ConservationDOIU.S. Department of the InteriorEISenvironmental impact statementEnhancement ActTitle VIII of the Water Resources Development Act of 2000FEISfinal environmental impact statementFWPMontana Department of Fish, Wildlife and ParksFWSU.S. Fish and Wildlife ServiceGISGeographic Information SystemGPSglobal positioning systemGSGeneral Schedule (employment type)HDPheight-density plotHMPhabitat management planIMPLANImpact Analysis for PlanningImprovement ActNational Wildlife Refuge System Improvement Act of 1997MDEQMontana Department of Environmental QualityMFWPMontana Department of Fish, Wildlife and ParksMOAmemorandum of agreementNEPANational Environmental Policy ActNGOnongovernmental organizationNRCSNatural Resources Conservation ServiceNWRnational wildlife refugePILTpayment in lieu of taxesPWAproposed wilderness areaRefuge SystemNational Wildlife Refuge SystemRegion 6Mountain–Prairie Region of the U.S. Fish and Wildlife ServiceRLGISRefuge Land Geographic Information SystemSDHUSilver Dollar Habitat UnitServiceU.S. Fish and Wildlife ServiceTEA–211998 Transportation Equity Act for the 21st CenturyVI Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
TESthreatened and endangered speciesTMDLtotal maximum daily loadUSACEU.S. Army Corps of EngineersU.S.C.United States CodeUSDAU.S. Department of AgricultureUSDA–APHISUSDA–Animal and Plant Health Inspection ServiceUSFSUSDA Forest ServiceUSGSU.S. Geological SurveyWGwage grade (employment type)WSAwilderness study areaCHAPTER 1—Introduction
The U.S. Fish and Wildlife Service (Service) has developed this volume 2 of the final comprehensive conservation plan and environmental impact state­ment (FEIS) for the Charles M. Russell National Wildlife Refuge and the UL Bend National Wild­life Refuge. This companion document for the FEIS includes the following components:
■■copies of comment letters from Federal, State, and local government agencies and organizations with Service responses
■■comments from individuals with Service responses
■■summaries of form letters received
■■copies of the transcripts from seven public hear­ings
The draft comprehensive conservation plan and environmental impact statement (DEIS) was released to the public for review and comment on September 7, 2010. A 60-day comment period for the document closed on November 16, 2010, and was ex­tended through December 10, 2010. In addition, the Service held seven public hearings in fall 2010.
Throughout the comment period, the Service received more than 1,700 comments from 919 indi­viduals (primarily emails, letters, and oral comments during public meetings), 53 letters from Federal, State, and local government agencies and organiza­tions, and 19,627 form letters.
The purpose of this volume is to address the sub­stantive comments received on the draft CCP and EIS. As defined by National Environmental Policy Act (NEPA) compliance guidelines, comments are considered substantive if they:
■■question, with reasonable basis, the accuracy of the information in the document;
■■question, with reasonable basis, the adequacy of the environmental analysis;■■present reasonable alternatives other than those presented in the environmental impact state-ment;■■cause changes or revisions in the proposal.This volume contains the Service’s responses to substantive comments on the DEIS. Comments, with responses, are divided into two chapters. Chap-ter 2 has copies of the comments made by Federal, State, and local government agencies and organiza-tions that qualify as tax-exempt, nonprofit entities. Chapter 3 summarizes the comments made by the public or other entities.In compliance with the spirit of the Privacy Act of 1974, it is the policy of the U.S. Fish and Wildlife Service, Mountain–Prairie Region, to not publish the names, addresses, or other personal information of individuals (agencies, business, and organizations are excluded). Rather than print every letter from indi-viduals and redact (black out) all personal informa-tion, and because many of the comments are similar in nature, the Service has summarized the general nature of the comments received and tracked the number of individuals that expressed each general comment. This is also consistent with the Paperwork Reduction Act of 1995.The Service responded to each substantive com-ment. Where appropriate, the text of the FEIS has been revised to address comments. Some of the comments do not meet the definition of “substan-tive” (as defined previously), and those are shown as “comment noted.” In some instances, the Service has opted to respond to specific nonsubstantive com-ments where the public displayed a strong interest. CHAPTER 2—Comments from Agencies
and Organizations
The Service received formal comments from the fol­lowing Federal, State, and local government agen­cies and organizations:
1. U.S. Army Corps of Engineers (USACE), page 4
2. Bureau of Land Management, Malta, p. 8
3. Bureau of Land Management, Miles City, p. 10
4. U.S. Environmental Protection Agency, p. 14
5. National Park Service, p. 31
6. Fort Peck Tribes, p. 33
7. Montana Fish, Wildlife and Parks, p. 34
8. Montana State Historical Preservation Society, p. 38
9. Fallon County Commissioners, p. 39
10. Fergus County Commissioners, p. 40
11. McCone County Commissioners, p. 57
12. Petroleum County Commissioners, p. 63
13. Phillips County Commissioners, p. 65
14. Powder River Commissioners, p. 78
15. Missouri River Council of Conservation Districts, p. 79
16. Garfield County Conservation Districts, p. 93
17. McCone County Conservation Districts, p. 97
18. Phillips County Conservation Districts, p. 103
19. Valley County Conservation Districts, p. 105
20. American Prairie Foundation, p. 108
21. Backcountry Hunters and Anglers, p. 110
22. Blue Goose Alliance, p. 114
23. Central Montana Wildlands Association, p. 118
24. Defenders of Wildlife, p. 138
25. Gallatin Wildlife Association, p. 146
26. Helena Hunters and Anglers, p. 148
27. Hellgate Hunters and Anglers, p. 150
28. Lund Law (represents counties), p. 152
29. Maryland Ornithological Society, p. 179
30. Missouri River Stewards, p. 184
31. Montana Association of Oil, Gas, & Coal Counties, Inc., p. 187
32. Montana Audubon, p. 188
33. Montana Farm Bureau, p. 193
34. Montana Mountain Bike Alliance, p. 197
35. Montana Petroleum Association, p. 199
36. Montana Pilots Association, p. 202
37. Montana Seaplane Pilots Association, p. 203
38. Montana Stockgrowers Association, p. 204
39. Montana Wilderness Association, p. 207
40. Montana Wildlife Federation, p. 216
41. Mosby Musselshell Watershed Group, p. 221
42. National Wildlife Federation, p. 223
43. National Wildlife Refuge Association, p. 236
44. Phillips County Livestock Association, p. 246
45. South and North Phillips County Cooperative State Grazing District, p. 251
46. The Nature Conservancy, p. 252
47. The Wilderness Society, p. 256
48. Western Watersheds Project, p. 270
49. Wildlife Conservation Society, p. 290
50. World Wildlife Fund, p. 292
51. Yellowstone Buffalo Foundation, p. 299
52. Yellowstone Safari Company, p. 300
53. Yellowstone Valley Audubon Society, p. 301
Letters from these agencies and organizations are shown in the following pages. Beside each repro­duced letter is the Service’s response, numbered to correspond to specific comments in the letter. The Service reviewed all supporting attachments; howev­er, such attachments are not included in this volume.Comment
Number
number Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana Response
44 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
1–1. 1–1. Thank you for your comments. The Service and the habi-tat
and wildlife it protects for the American public benefits
from our relationship and how we manage public lands. We
acknowledge your expectation that management of the refuge
should provide quality opportunities and experiences than
generally available on other public lands managed for multiple
use purposes.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 5
Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana
1–2.
1–3.
1–4.
It is unfortunate USACE staff were unable to participate
-
cause it resulted in substantial changes in big game objectives
from an earlier draft of the DEIS. Based on public comment
and a reevaluation, we revised the big game objectives in the
FEIS to meet or exceed objectives in established Montana
game
management plans. In cooperation with all partners, we will
-
tat management plans tailored to local habitat conditions and
There was an error in the DEIS and the objective for big-bighorn
and
1–2. Comment noted.
1–3.
at the August 2010 meeting with cooperating agencies be
Department of Fish, Wildlife, Parks (MFWP) big
develop specific abundance and composition objectives in habi
The DEIS wording for objective D4 for
. There was no intent to limit the
-
years old.
potentials.
1–4.
horn sheep was supposed to state a minimum average age of
6.5
sheep (page 89) is also in error
total population on the refuge to around 225, but rather to set
a population objective of around 225 for the currently occupied
sheep habitat in hunting district 622. The FEIS clarifies that
additional bighorn sheep may be established in suitable habi
tat. See also response 1–3.
Comment
Number
6 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana Response
1–5.
-
The FEIS clarifies the objectives and connects the im-
Ser
other
the
enhance
a place
“The mission of
the refuge is
than
protect, and
important
them.
conserve,
with
others to
, biomass, or cover of many species
species
with
bird
fish, wildlife, and plants and their habitats for the continuing
American people.” Thus,
populations are not more
working
portant
benefit of the
that supports a variety of plant life as well as habitat for fish
and wildlife. Habitats are an essential necessity for wildlife.
plant
is
1–5.
vice
Sentinel
plant species, but they do provide an early warning indicator
of habitat degradation for other plants and for wildlife.
There are several hundred species of plants on the refuge.
, frequency
focal
Thus, the density
is immeasurable. Also, changes in population numbers would
not be readily detectable due to the tiny numbers and vast
sampling needed. We will measure demographic information at
randomly selected remnant sites to determine if the plants are
doing well or poorly. This can be accomplished and would be
immediately useful for adaptive management.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 7
Letter #1: U.S. Army Corps of Engineers–Omaha District, Fort Peck, Montana
1–6.
1–7.
1–8.
-
1–6. We made several changes to the proposed wilderness
alternatives after considerable review from the public and
others. Slight changes were made to the acreage in alternative
B and D due to mapping errors in the DEIS. In addition, we
determined there is not sufficient justification for recommend
ing deletion of any existing proposed wilderness area.
Comment noted.
Comment noted; see also responses for 1–3, 1–4, and 1–5.
-
-
1–7.
1–8.
We plan to emphasize habitat as the essential necessity of di
ildlife includes thou
and invertebrate animal species. Plants are
verse and abundant wildlife populations. W
sands of vertebrate
equally important and are the foundation of vibrant habitat.
We revised the FEIS to better connect the important focal
species, particularly bird species, with the habitat objectives.
Comment
Number
8 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #2: Bureau of Land Management, Malta, Montana Response
2–1. Specific monitoring protocol for upland sentinel species is
being developed (DEIS page 191). In the development of those
monitoring efforts, the Service does use the historical plant
community information in the Natural Resources Conserva-tions
Service (NRCS) ecological site descriptions and many
other sources of information (strategies for upland objectives
D1–9 DEIS page 68). We principally employ this information
in sentinel species designation and management rather than
similarity indexes.
2–2. We believe that effective communication can bridge some
of the differences between how our agencies approach riparian
health monitoring. However, given that we have different mis-sions;
monitoring protocols will not be the same.
2–1.
2–2.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 9
Letter #2: Bureau of Land Management, Malta, Montana
2–3.
2–4.
2–3. The developing monitoring standards for the refuge will
incorporate many of the same methods and considerations out-lined
in TR 1734–6 including current plant community versus
desired or potential, overall plant cover and distribution. We
use the historical plant community information in the NRCS
ecological site descriptions and many other sources of informa-
The riparian health assessment has a well established
tion.
2–4.
monitoring effort in place (DEIS pages 196–197). By using
consistent and well-established trend data, the refuge can
track effects of management changes on riparian habitats.
The detailed descriptions of the studies are provided through
the citations in the bibliography (the papers by Paul Hansen,
DEIS page 441).
Comment
Number
10 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #3: Bureau of Land Management, Miles City, Montana Response
3–1. threat-
-
that
e do not propose realignment of any BLM fences. A
boundary
wildfire
order
any
ens to burn off the refuge, and there is not a goal or objective
to allow any fire to burn off of the refuge and affect neigh-boring
land. Reference DEIS pages 80–82 and note several
Fur-
use in-would
lands.
would
that
to neighboring
tensive suppression strategies where perimeter areas are
threatening to burn of the refuge.” Refer to DEIS page 82
,
areas
“The Service
to delineate
be appropriate for various fire management options. See re
executive
suppresses
impacts
states,
actively
page 81
cooperators
mitigating
with
references to
DEIS
working
thermore,
about
sponse 3–4 about predator control.
be constructed on the
Service
W
may
3–1. The
3–2.
fence
but no alterations are planned or can be made to existing BLM
fences and their locations. There would be no effect to BLM
lands. Refer to the responses that follow for other detailed
responses to your comments.
3–2.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 11
Letter #3: Bureau of Land Management, Miles City, Montana
3–3.
3–4.
3–5.
3–5.
3–5.
3–5.
3–5.
3–6.
3–7.
3–8.
3–9.
There appears to be confusion with the take of coyotes
as part of an established hunting season versus the action of
-
-
predator control. Along with a signed compatibility determi
nation, a refuge must have an approved hunting season for
ildlife Refuge System
Act of 1997. (Improvement Act) established six
core wildlife-dependent recreational activities, one of which is
hunting. An established hunting season on coyotes is in line
with that legislation. Predator control simply for the reduction
of populations is not compatible with the mission of the Service
because all predators are a vital part of a functioning ecosys
tem. Specific control measures may be carried out on a case-
These appear to be comments on the discussion about
our strategic plan for climate change, which was finalized in
2010, and not on specific actions in the DEIS. Although the
no
-
3–3. Comment noted.
3–4.
the take of coyotes. The National W
Improvement
by-case basis if wolves enter the landscape (DEIS page 99).
effects,
so there is
cumulative
was cited, we cited the first sentence
3–5.
paragraph
confusion where the statement came from.
3–6. You are correct that there could be
but the reality is that cumulative impacts would be negligible.
. While wildlife can migrate
Nonetheless, we have addressed this in the FEIS.
3–7. The Service disagrees. The EPA’s scoping comments
suggested we identify the analysis area, and they did not take
issue with it in their comments on the DEIS. The primary
purpose of the analysis area was to identify the primary areas
where we looked for foreseeable activities outside the decision
area and where any direct, indirect, or cumulative impacts con
, most effects would occur within the
nected to our actions would occur
outside the boundary
analysis area.
Comment
Number
12 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #3: Bureau of Land Management, Miles City, Montana Response
3–8. The provision for livestock grazing under Executive
Order 7509 specifically states that it can only occur if it re-mains
compatible with the primary purposes of the refuge. As
outlined by the establishing legislation, the primary purpose
and
-
-
grouse
, the natural
of sharp-tailed
depend
a maximum number
pronghorn and secondary non predatory species in such num
bers as to maintain a balanced wildlife population. Subsequent
priority of wildlife on national
Fish and
species.
(U.S.
on the
integrity policy
would
reinforced the
biological
efforts
The
recovery
s habitat.
legislation has
refuges.
to sustain
ildlife Service [FWS] 2001), which resulted from the pas
Additional
is
wildlife
W
sage of Improvement Act, directs that livestock grazing on
refuges is permissible only when prescribed in plans to meet
wildlife or habitat management objectives and only when more
natural methods, such as fire or grazing by native herbivores,
cannot meet refuge goals and objectives. Generally
processes of fire and grazing by native herbivores meets the
management objectives for wildlife and habitat on the refuge.
3–9.
A primary objective in the CCP is to increase the resiliency of
the refuge’
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 13
Letter #3: Bureau of Land Management, Miles City, Montana
3–10.
3–11.
3–12.
3–13.
3–14.
3–15.
3–16.
species (particularly threatened
and endangered) are a priority on the refuge. Any paleontolog-
-
ers on the refuge would have to consider and mitigate potential
impacts to achieving the primary refuge purposes and would
There
-
tool that can
for the various
-
states,
-
research
-
-
and
years.”
universities
a
15
listed current and
done by
and plant
work
All wildlife
archaeological
be outlined during the permitting process.
read “over
and grazing is
to
were disclosed
FEIS
targeted
grazing
e updated the
objective
of livestock
We updated the FEIS to read “over 15 years.”
W
or
The DEIS made no statements that any specific ar
3–10.
ical
3–11.
3–12.
has not been a comprehensive bird monitoring program on the
refuge. Information about lek locations for sharp-tailed grouse,
greater sage-grouse, and other species is detailed in chapter 4.
3–13.
eas would not be grazed outside of any exclusion areas. If an
Grazing”)
is
be used (in this case, improving and maintaining prairie dog
habitat), then grazing could be implemented by prescription.
The effects
alternatives in the DEIS (“Chapter 5—Environmental Conse
DEIS (page 264 under “Livestock
quences,” page 269).
3–14. The
“With defined habitat objectives, livestock grazing can stimu
late new plant growth and increase the vigor of plant com
munities.” The FEIS has more discussion about the benefits of
prescriptive grazing.
See response 3–4.
The list provided is an example of current conservation
and
3–15.
3–16.
organizations that may seek a partnership on land conserva
management projects. While we
identifiable
tion
likely partnerships, there certainly could be others.
Comment
Number
14 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–1. 4–1. Thank you for your comments.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 15
Letter #4: Environmental Protection Agency, Helena, Montana
4–2.
4–3.
4–4.
4–5.
4–6.
4–7.
The Service notes your concern about open roads and
motorized use. Based on those comments and others we have
revised alternative D in the FEIS to include additional sea-sonal
closures to improve hunting opportunities and to provide
-
to assess any water quality impairments that may be related
to refuge land management practices as part of an effort to
Montana
-
e added discussion in the FEIS on water quality im
pairments on some of the drainages mentioned in your letter.
There is an extensive list of objectives and strategies that
would improve the health of riparian areas on the refuge. In
addition to the list in the DEIS (pages 73–74), we have pri-oritized
some of the restoration work and added a strategy
fire activities would comply with
W
4–2.
additional security habitat on the refuge.
4–3.
improve riparian health on the refuge.
All prescribed
smoke management regulations. In the FEIS, we added this
requirement to the elements common to all alternatives (DEIS
page 32).
We made several changes to the proposed wilderness
4–4.
4–5.
alternatives after considerable review from the public and
others. Slight changes were made to the acreage in alternative
B and D due to mapping errors in the DEIS. In addition, we
determined there is not sufficient justification for recommend
ing deletion of any existing proposed wilderness area.
4–6. The modifications made for the FEIS should address
many of your concerns.
4–7. Comments noted.
Comment
Number
16 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–8. 4–8. Thank you for your comments.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 17
Letter #4: Environmental Protection Agency, Helena, MontanaComment
Number
18 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–9.
4–9. Road management for the Charles M. Russell Refuge
received considerable public comment, as referenced in the
DEIS. We considered all perspectives in preparing the FEIS
and final CCP and the balance for vehicular access was a hy-brid
version of road management that incorporated elements
from each alternative. In the FEIS, we made some modifica-tions
to the preferred alternative to address displacement of
wildlife off some key ridges during hunting season.
We recognize the effects of roads and motorized uses and
concur that there are increasing demands for recreational
iewing Area or
, most of the roads are lightly
TVs on refuge roads or using
. Nonetheless, we
use in some areas on the refuge like the Elk V
winter
popular fishing sites. However
used outside of hunting season and much of the refuge remains
inaccessible during the winter months or during wet periods.
In addition, there has historically been good compliance with
our regulations for operating A
snowmobiles to access the lake in the
recognize that more data is needed to assess transportation
management and its impacts on refuge resources and that
a transportation plan should be developed before making
any substantial new recommendations about road closures.
Closing a road in one place can result in unintended impacts
and consequences elsewhere.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 19
Letter #4: Environmental Protection Agency, Helena, Montana
4–10. e actively
TVs, are
-created routes. W
vehicles, including A
There are no additional user
illegal off-road travel. All
4–10.
enforce
required to stay on numbered routes. Overall, there is good
compliance by users on the refuge.
Comment
Number
20 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–11.
ater Quality
4–11. We made a number of changes in the FEIS, which should
address your comments and questions by adding a section in
“Chapter 4—Affected Environment” under “W
Monitoring” to elaborate on the impaired surface waters men-tioned
and referenced the MDEQ website as a source for more
information. There are currently no known abandoned mine
sites located within the refuge boundaries. Livestock grazing
is not permitted in most riparian areas found on refuge lands.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 21
Letter #4: Environmental Protection Agency, Helena, MontanaComment
Number
22 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–13.
e have included an assessment of current water qual-s
boundaries that are within our control (FEIS chapter
quality
e plan to
-
. A properly functioning riparian
.
s
etland Research Program, Ecological Solutions
. Paul Hanson were contracted to inventory and
-
-
water
alteration in
cover
the
high vegetative
quality by reducing
See response 4–4 about the use of smoke management
e have noted or added the literature that
A,
anessa Hinkle concurred with our
.
Much of
maintaining
ater Quality Monitoring”).
help improve water
and
, Ms. V
W
4–12. W
ity impairments, likely causes, and percent of area within the
refuge’
4, “4.2
impairments originate upstream, off the refuge. W
continue to work with our neighbors and within our boundar
ies to improve water quality
area will
streamside vegetation
The FEIS includes an extensive discussion of riparian health
on the refuge. From 1995 to 1997, the University of Montana’
Riparian and W
Group, and Dr
assess riparian health. In 2009, the assessment was repeated
and it was determined that riparian health improved greatly
since 1995. (A more indepth analysis of the findings is in chap
ter 4, “4.3 Livestock Grazing and Riparian Monitoring”). The
Service plans to coordinate with the MDEQ on any impound
ment removals to assure consistency with total maximum daily
loads and water quality restoration plans.
4–13.
plans on all fires. W
you reference into the FEIS. In discussions we had with EP
Region 8 in Denver
assessment that the smoke management plan addresses your
concern, and a visibility analysis is not necessary
4–12.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 23
Letter #4: Environmental Protection Agency, Helena, Montana
4–14.
In the FEIS, we have additional notations about smoke
management in chapter 3 (“3.2 Elements Common to All Al-ternatives”)
which should address your concerns. Additional
discussion of potential impacts to air quality was added in the
4–14.
FEIS.
The Service is a member of the Montana/Idaho Airshed
Group. The air shed group is composed of State, Federal,
tribal, and private member organizations who are dedicated
to the preservation of air quality in Montana and Idaho. These
agencies work cooperatively to prevent negative smoke effects
while using fire to accomplish land management objectives.
Each member who conducts a prescribed burn in Montana is
required to have a burning permit issued by MDEQ. Under
all alternatives, the use of prescribed fire on the refuge will
continue to follow protocol and guidelines established in the
Montana/Idaho Airshed Operating Guide (MIAG 2010).
Critical smoke concerns are addressed in each individual
prescribed burn plan. These plans are very thorough and
discuss specific smoke issues, measures to reduce impacts,
downwind receptors, and smoke vector maps. The Service
obtains clearance from the Montana/Idaho Airshed Group
before conducting any prescribed fire. An air shed coordinator
and meteorologist evaluate each prescribed fire information air
shed by air shed to anticipate cumulative smoke effects. Key
direction, type
other
and
any
burn elevation, wind speed
of burn, proximity to smoke-sensitive features, anticipated
pertinent
effects cannot be
burners, and
conducted if negative
nonmember
information made available at the time of the decision. A
is not
include
burn
from
factors
impacts
prescribed
mitigated.
Comment
Number
24 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–15. See response 4–5.
We added your recommendations for best management
4–15.
4–16.
practices in the FEIS.
4–16.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 25
Letter #4: Environmental Protection Agency, Helena, MontanaComment
Number
26 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–17. 4–17. We already employ many of the suggestions for reducing
transportation of weeds onto the refuge, but have added some
of your suggestions to the discussion in the FEIS.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 27
Letter #4: Environmental Protection Agency, Helena, Montana
4–18. We added the suggestion of increasing more riparian ar-
, funding and
4–18.
eas to proper functioning condition. Unfortunately
legal rights to historic flows drives our ability to fully restore
some of these areas.
4–19. Climate change is a major area of emphasis for the Ser-vice.
(DEIS page 7).
4–19.
Comment
Number
28 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency, Helena, Montana Response
4–20. 4–20. The FEIS has more information about our sentinel plant
work, including additional monitoring data and references
to reports. We are in the process of working with ecologists,
statisticians, and experts in other scientific disciplines (DEIS
page 67) to develop monitoring protocols. In the FEIS, we
clarified that monitoring protocols would be peer reviewed in
accordance with our quality guidelines. Monitoring data will be
relationship with the tribes and described
available on request.
4–21. We value our
our consultation efforts including what we learned from our
discussions with them (DEIS pages 239 and 354). We have
reached out several times to the tribes during the process and
heard from one tribe during the comment period for the DEIS
(letter #6).
4–21.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 29
Letter #4: Environmental Protection Agency, Helena, Montana
4–22. None of the actions in the DEIS will cause an adverse
e discussed the
327) and
access.
DEIS (page
or low-income popula-impact
on public
in the
which regulates harvest and
e have incorporated this response
to livestock permittees
would have little
Montana,
road closures
the State of
4–22.
effect on human health and the environment. W
impacts
expanded the discussion in the FEIS. While there are certainly
families within the analysis area that are low income or even
poverty level, our habitat and wildlife management actions will
not disproportionately impact minorities
tions. For example, we do not charge for public use activities,
and
We discussed the factors that could determine the impact of
livestock production on the refuge (DEIS page 326).
While the tribes would like to see increased opportunities
for tribal hunting, those are issues that have to be addressed
through
licensing (DEIS page 239). W
into the discussion of the effects on environmental justice in
the FEIS.
Comment
Number
30 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #4: Environmental Protection Agency Response
, Helena, MontanaComment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 31
Letter #5: National Park Service–Intermountain Region, Denver, Colorado
5–1.
5–2. -
Thank you for your comment.
The Service agrees that there should be careful consider
5–1.
5–2.
ation of visual and audible impacts near the Lewis and Clark
National Historic Trail. We have added more description about
the siting of any energy facilities and have included a picture of
the existing turbine at the Lewistown headquarters building
depicting its small footprint (FEIS chapter 4).
Comment
Number
32 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #5: National Park Service–Intermountain Region, Denver, Colorado Response
5–3. The trail name was corrected to its full name in the FEIS.
Thank you for your comments.
5–3.
5–4. 5–4.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 33
Letter #6: Fort Peck Tribes, Poplar, Montana
6–1. 6–1. Thank you for your comments. The Service appreciates
the input by the Fort Peck Tribes.
Comment
Number
34 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana Response
s input in developing the
ratios for
The Service appreciates MFWP’
DEIS and agree that the objectives in the DEIS and FEIS are
productivity
achievable. For the last 10–20 years, male-to-female
both mule deer and elk have averaged substantially above the
Several comments were received about big game
management for natural and diverse age structures to
support quality big game hunting, viewing experiences, and
to be consistent with the natural ecological processes theme
of alternative D. Many commenters expressed that hunters
generally
Public
, and
, hunting
refuge not
Montana.
on the
eastern
experience
in
conditions,
levels proposed in the DEIS.
on other public lands
expect
found
comments questioned why the big game objectives proposed
in the DEIS were lower standards than have been achieved in
the past, and in some cases, lower than objectives in approved
MFWP plans. In response to public and agency comments on
the DEIS, big game objectives were adjusted in the FEIS
to assure that big game management on the refuge meets or
exceeds objectives in approved State conservation plans.
In accordance with national policy striving to the extent
practicable to achieve consistency with State management
objectives and regulations, refuge-specific abundance and
population composition objectives may be established
through stepdown habitat management plans and will be
habitat
unique, quality
to regional
a
7–1.
tailored
other considerations. Those objectives will consider naturally
functioning ecosystem processes, biological integrity
opportunities, and quality of recreational experiences.
7–1.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 35
Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana
generalization
that a shorter mule deer hunting season on portions of the ref-uge
has been the cause of increased hunting pressure. Based
s hunter survey information, patterns in the number
of mule deer hunters in the Missouri Breaks and surrounding
areas have been variable. The number of mule deer hunters
has steadily increased throughout the Missouri Breaks and
surrounding areas since the late 1990s, as has the mule deer
A requirements, the CCP planning process
e note that MFWP
-
-
ated effects of management with an emphasis on providing for
public and economic uses and less on wildlife. Comment letters
from many individuals, nongovernmental organizations, and
-
e agree with MFWP that hunter harvest is generally
the primary factor affecting the abundance of mature males in
296)
, but overall the impact on hunting
-
other agencies supported the objectives and management ap
, no take
-
oppose the big game objectives in alternative B, but it ex
plores and evaluates an emphasis focused on abundant wildlife
populations and less on public or economic uses. Similarly,
-
objectives proposed under alternative C explored and evalu
and
(page
levels,
e look to existing State regulations on which
e agree with
DEIS
the
the
harvest
support
in
not
comment
data does
but
available
on MFWP’
population.
proaches in alternative B.
populations,
The
must explore a range of alternatives. W
and trends,
the
population status
To satisfy NEP
W
game
s concerns on mountain lion monitoring and expect the
7–2.
7–4.
Federal law prohibits take of all wildlife on national wild
7–3.
big
was taken out of context, which stated that limiting harvest
rates could be necessary
would be negligible.
7–5.
life refuges, unless specifically authorized. Currently
of furbearers or mountain lions is permitted on the refuge.
To open those species for public harvest, preparation and ap
proval of a new hunting package is required. After internal re
view and approval of a proposal, public input is solicited before
a final decision is made. Each new hunt package must include
justification,
monitoring. W
hunt packages are developed for consideration. W
MFWP’
results of ongoing research, and future collaborations, will lead
to a joint management and conservation of mountain lions.
7–2.
7–3.
7–4.
7–5.
7–6.
7–7.
Comment
Number
36 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana Response
7–6. Any public take of wolves on the refuge would have to
follow the same development and approval of a new hunt pack-e
clarified this in the
-
age, as referenced in response 7–5. W
FEIS. In addition, we recognize the role MFWP has in manag
ing resident wildlife. However, we also have a responsibility
for managing wildlife within the refuge and will work with
MFWP in on this issue.
7–7. Greater sage-grouse has been identified as a focal species
in the FEIS and will be monitored. When the draft CCP and
EIS was written, the determination on the sage-grouse list-ing
had just been published. The guidance that the National
Wildlife Refuge System (Refuge System) received from the
Service’s national sage-grouse coordinator about the public
harvest of sage-grouse is that hunting is not an issue provided
that habitat remains in good condition and populations are
healthy. In areas where populations have declined, it may
be sensible to close the season. Conditions could vary across
national wildlife refuges. On the refuge, sage-grouse popula-
. Harvest levels likely
, influence on population dynamics. In the
tions are generally robust and healthy
have limited, if any
absence of new information, we will adopt State-recommended
harvest management strategies for sage-grouse. This was
updated in the FEIS.
7–8. Access is open to all hunting recreationists in proposed
wilderness areas, along with everywhere else on the refuge
except the 1,200 acre elk viewing area and a small administra-ildlife
Station. In compli-
ilderness Act and national policy, motorized
tive area around the Sand Creek W
ance with the W
access is not allowed within proposed wilderness areas. We are
unaware of any data showing road or proposed wilderness area
management on the refuge has caused greater elk depredation
on private lands or overbrowsing of important shrub species
and would be interested in reviewing the data used to support
Charles M. Russell Refuge
that generalization.
Road management on the
received considerable public comment, as referenced in the
DEIS. Many expressed a desire to see fewer open roads, while
others wanted to maintain status quo or to open additional
7–8.
7–9.
7–10.
7–11.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 37
roads, primarily for hunting access and game retrieval. Others
felt that any closure was unacceptable. We considered all
perspectives on road management in finalizing the preferred
alternative and the balance for vehicular access was a hybrid
version that incorporated elements from each alternative.
We made several changes to the proposed wilderness
alternatives after considerable review from the public and
others. Slight changes were made to the acreage under
alternative B and D due to mapping errors in the DEIS. In
addition, we determined there is not sufficient justification for
recommending deletion of any existing proposed wilderness
Comments noted.
We look forward to continued collaborative and coopera-area.
7–9.
7–10.
tive work on aquatic species.
7–11. Thank you for your comments.
Letter #7: Montana Fish, Wildlife, and Parks, Glasgow, Montana
Comment
Number
38 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #8: Montana Historical Preservation Society, Helena, Montana Response
8–1. 8–1. Thank you for your comments. The Service will continue
to consult on undertakings found in Section 106 of the National
Historic Preservation Act and will consult on the proposed
sensitivity model.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 39
Letter #9: Fallon County Supervisors, Baker, Montana
9–1.
-
9–1. The Service disagrees that the DEIS should be with-drawn
for further analysis. In the FEIS, we have clarified
that only the U.S. Congress can make a withdrawal order
permanent, but we see no impact on the human environment
by advocating for a permanent withdrawal on the refuge. The
benefits of such a withdrawal on the biological resources and
special areas designations are referenced in the FEIS chapter
5 and further clarified in chapters 3 and 4), specifically about
the extension of the 20-year withdrawal. Also, we are not
aware of any active mining or exploration that has occurred
on the refuge; therefore, we do not believe there is direct, in
direct, or cumulative impact on the socioeconomic environment
as a result of seeking a permanent withdrawal for locatable
minerals on a national wildlife refuge. The primary purpose of
the refuge is to protect wildlife values. Seeking a permanent
withdrawal is consistent with the mission of the Refuge Sys-tem
and the primary purposes of the refuge.
Comment
Number
40 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 41
Letter #10: Fergus County Commissioners, Fergus County, Montana
This plan lacks significant scientific data. You are basing your decisions on a single study instead of researching
additional studies that might have opposing findings.
The counties can’t support Strategies For Partnerships C1 – C4 & D1 – D5 – Develop management procedures
that will benefit livestock operations and select wildlife species because the management you
have in this plan in no way is going to benefit livestock permittees. The counties would support
partnerships on Alt A1 – A3.
Pg. 419 J. Neher Duffield – socioeconomic impacts of Valley and Phillips counties prepared for the
Prairie Foundation by Bioeconomics inc.
Economic data is not complete. The data prepared for the Prairie Foundation was used but the counties were not
consulted.
The six counties met with USGS once. At that meeting they stated that they would come to the individual
counties and talk with the county commissioners to gain better knowledge of the economics of
the counties. That never happened.
The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS meet
four elements: a.) quality; b) utility (referring to the usefulness of the data for its intended
purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d) integrity.
Private Land
Pg. 191 No mention of private lands under the “State and Private Lands” caption.
MFWP has indicated that less than 50 percent of the wildlife habitat is within the CMR boundary. There are
areas on the south side of the river which the CMR has less than 15 percent of the habitat. With
wildlife numbers at their current levels and if permitted to expand, the majority of these game
animals are going to be impacting private lands.
Any change to grazing allotments with private lands within them would greatly affect the private landowner and
their private property rights.
Minerals
Mineral development should be included in both Alternatives B and D on a case-by-case
basis, taking into consideration accessibility, type of mineral extraction, opportunity for
revenue to offset the cost of refuge management to the taxpayers, amount of disturbance or
lack thereof to the habitat and/or wildlife, etc. Research into each development proposed
must be accurate as to actual disturbance and not politically acceptable “science”.
10–1.
10–2.
10–3.
10–4.
10–5.
10–6.
10–7.
10–8.
10–9.
The comment does not provide information as to the
, what data was not scientific, or offer examples
-
-
-
e
e did not receive further communication or
-
, the
-
-
10–1.
page, the study
of other studies that should have been reviewed.
It is not clear the exact reasoning for the opposition to
alternatives C and D. When the plan is carried out, livestock
permittees who can adjust their operations and work with the
refuge in achieving habitat objectives would benefit.
10–3. The U.S. Geological Survey (USGS) consulted numer
ous sources in conducting the socioeconomic analysis. Several
observations from the counties were cited in the DEIS (page
251). In July 2011, we provided the counties with emails and
data sources used by USGS in the economic analysis and of
fered a willingness to expand further discussions of the af
fected environment if there was data that was left out. W
gave the counties until August 15, 2011, to provide us with
additional data. W
data on this topic. The sources USGS used were cited exten
sively in the document including data from Federal, State, and
local agencies, as well as private landowners. Additionally
socioeconomic analysis went through extensive peer review
before the release of the DEIS.
Although individual meetings with the county commis
USGS staff did attend all local community meetings.
10–4.
sioners did not occur following the initial meeting with the six
counties,
The information gained from these meetings, combined with
additional background data and research, provided a strong
foundation for the socioeconomic analysis. One of the most
respected economists on livestock grazing from the University
aylor, wrote the section on the livestock
s policy for meeting the Data
yoming, Dr. D. T
10–2.
of W
grazing analysis.
10–5. In a review of the Service’
Quality Act (Information Quality Guidelines, FWS 2011a), the
guidelines affirm the importance of disseminating and present
e consider all requests to correct
information following its guidelines and work with the author
of the material in question. Of interest in the comment is the
in DEIS violates the Data Quality
ing quality information. W
implication that the data
Comment
Number
42 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Response
Act and is not supported by credible science; the guidelines
state that the burden is on the requester to show what infor-mation
needs correction as well as to the type of modification
being sought. It is also up to the requestor to show supporting
et, there is no specificity in the implication made
, no explanation of why the
information is incorrect, or how it should be corrected. For
clarification, integrity refers to the security and protection of
-
information as opposed to how it is used in a scientific sense.
e inadvertently left out the acreage for private lands in
the DEIS (page 191) and modified the title in the FEIS. How-
, we did identify the acreage of private lands elsewhere in
168–169, and
acknowledged the impacts that could occur for some permit
tees (DEIS pages 319 and 326–329). This discussion has been
expanded further in the FEIS. None of the actions in the
CCP and EIS prevent access to existing inholdings within the
It is unclear what the statement, “less than 50% of the
,” means. All land
charac-e
suspect the
(about 40,000 acres), pages
reference meant the refuge comprises a relatively small and
-
. Those hunting districts contain
evidence. Y
here. There is no page number
10–6. W
ever
the DEIS on page 26
refuge.
10–7.
can
variable proportion of administrative hunting district boundar
continuous wildlife habitat on and adjacent to the refuge. We
density.
Over time, these factors would be variable as native ungulates
, seasons,
and a variety of other factors. Managing lands within the
refuge primarily for native wildlife should result in fewer
In the DEIS upland objective D4 (page 66) there is
a provision to work with permittees in developing habitat
management plans so they can make adjustments in their
toward
its
or
on
wildlife habitat is within the CMR boundary
considered wildlife habitat, depending
teristics and management use by humans. W
wildlife distribution
ies as established by MFWP
on
clarified this in the FEIS.
The letter offers no data
are mobile and respond to habitat conditions, weather
the impact that moving
impacts to adjacent lands.
e acknowledged
10–8.
operations. W
be
Letter #10: Fergus County Commissioners, Fergus County, Montana
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 43
a greater reliance on prescriptive grazing could have a major
effect on some permittees (DEIS pages 326–331). However, as
noted in the compatibility determination (DEIS page 372), for
grazing to be considered a compatible activity on the refuge, it
needs to be a comprehensive prescriptive program.
10–9. We are pursuing an extension of the mineral withdrawal
for Charles M. Russell Refuge on the locatable minerals (UL
Bend Refuge has a permanent withdrawal) and would advo-cate
for a permanent withdrawal of minerals. Only the U.S.
Congress can designate a permanent withdrawal. We have
clarified the information in the FEIS about mineral develop-ment.
Letter #10: Fergus County Commissioners, Fergus County, Montana
Comment
Number
44 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
Grazing
Pg 330 All of the alternatives would likely result in negligible to minor cumulative benefits to local
communities by increasing income, jobs and (under B&D) additional opportunities for recreation
and tourism.
Pg 333 There would be some increases in the level of visitation, particularly in C&D but they would be
minor to moderate differences over existing conditions.
Pg.330 Alt D would generate $2 million more in local output, 25 additional jobs and $569.6 thousand
more in labor income compared to Alt A (excluding grazing operations)
Pg. 324 proposed staff for Alt D includes all current staff positions and seven additional positions
Considering that they are saying that there will be some increases in visitation the only economic increase
would be the seven additional positions for the CMR. They are not looking at impacts from grazing operations.
Pg. 330 Under existing conditions (Alt A) at 34% of the refuge would be prescriptive grazed and this
would not change unless units become available through the sale to a third party, or when
habitat conditions dictated a change.
Pg. 64 & 65 Upland C3- continuing the practice of holding grazing permits as ranches sell their land to
outside parties.
Pg. 33 Summary Alt A (current)– There would be gradual move to prescriptive grazing only when units
became available or habitat evaluations are completed and when prescriptive grazing is identified
as necessary to meet wildlife or habitat objections.
There already is an option to move to prescriptive grazing as necessary to meet wildlife and habitat objections.
The counties object to pushing to have 75% of the Refuge under prescriptive grazing with no
data to back it?
Pg. 190 Livestock numbers on the Refuge are currently lower than any time in the past century.
740,000 acres potential grazing, 409,849 (annual), 252,706 (prescriptive), 77,475 (non-grazed)
The document should have scientific data that proves that non-grazed and prescriptive grazing is any better
condition than the grazed allotments. There is no scientific data shown in this document that you will meet your
objectives by removing cattle or going to prescriptive grazing. There is no documentation of the differences
between grazed units that have recovered verses non-grazed or prescriptive grazed units.
Pg. 39 Summary of Alt B – within 4-7 years a prescriptive livestock grazing plan would be developed
for 50-75% of the refuge.
Pg. 63 Rationale for Alt B – the service estimate that only 75% of the refuge would convert to
prescriptive grazing.
Pg. 52 Summary of Alt D – Generational transfer of permits would continue; however, grazing would
be on a prescriptive basis.
Pg. 67 Rationale for Alt D – This alternative calls strongly for the return of the evolutionary forces of
fire and herbivory (grazing by wildlife) that shaped this landscape during the past 6,000 years.
10–10.
10–10. The economic analysis considered impacts from grazing
operations and direct and secondary effects (DEIS table 35,
page 317). Economic increases would occur from more refuge
jobs and increased visitation (DEIS page 326). There would
also be increased spending by the additional refuge employees
as well as increased spending by nonlocal visitors. As prescrip-tive
grazing is implemented across 50–75 percent of the refuge,
the level of grazing could be reduced from the current level,
but it could increase for short periods. Operators who could
change their operations to help the refuge meet its wildlife
objectives would benefit. Changes to refuge grazing would not
be significant for the six-county economy, but it could affect in-dividual
ranches with refuge grazing permits (DEIS page 326).
Though the no-action alternative enabled us to progress
-
10–11.
toward improving forage resources, particularly where grazing
is absent, the annual grazing program does not meet Service
policies, nor is it a comprehensive wildlife management pro
gram. In addition continued implementation would not achieve
many of the goals set for the project (DEIS page 322). The
1986 EIS specifically noted that it was meant to be a resource
management plan and not a comprehensive management plan.
There are both legal mandates and substantial literature re-
-
garding the compatibility and use of prescriptive grazing. We
added more information to the FEIS on these topics.
10–12. The direction cited in the Improvement Act instructs
us that if we are going to use livestock grazing, it needs to be
done prescriptively for the benefit of wildlife resources (FWS
2000a, FWS 2001). The data describing differences between
annual grazing and ungrazed conditions is described in the
DEIS (pages 191–193). In the FEIS, we clarified and added in
formation on our legal mandates and data collected on various
-
sites on the refuge as well as more information about how pre-scriptive
grazing would work. The use of prescriptive grazing
under this plan would differ depending on the wildlife species,
weed species, native plant species, or specific habitat condition
the prescription is designed to affect. Rest would also be a con
dition that is prescribed to benefit wildlife, and the CCP would
facilitate these kinds of prescriptions.
10–11.
10–12.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 45
Letter #10: Fergus County Commissioners, Fergus County, Montana
Total ungulate effects and fire effects on plant communities would be measured with diagnostic
species (sentinel species).
When declining trends are found or when competition for resources results in habitat damage,
livestock numbers would be reduced or eliminated before wild ungulates. The Service estimates
it could convert about 75% of the refuge to prescriptive grazing due to the need to add or
eliminate fences. If funding and resources permitted, more of the refuge could convert to
prescriptive grazing over 15 years.
This plan is aimed at making it non beneficial for permittees to graze cattle within the CMR boundary. You are
going to a system that has not been proven for any length of time (agreed to by Barron Crawford October 12,
2010) and are setting goals that will be unattainable. You are going experiment to see if your plan will work at
the permittees expense. You will never be able to get the amount of some forbs back that you plan considers
successful implementation of objectives.
You already have the option to change to prescriptive grazing when habitat conditions dictated a change?
Pg. 329 If permittees no longer desired to retain their grazing permits, the Service would work with
DNRC to assume permits, providing funding exists.
Pg. 187 The reduction in population of (palatable forbs) is likely due to constant selective grazing fire
suppression and competition from less palatable native species or invasive species. Palatable forb
populations historically benefitted from fire and periods of less grazing pressure.
• The document states that economic uses would be limited when they are injurious to
ecological process.
Any wording that says likely due or the possibility of is not based on scientific data. The counties object that
your are speculating on what might happen.
Pg. 373 Grazing monitoring cost: refuge personnel currently spend approximately 25 to 35 percent of
their time issuing permits, monitoring for trespass livestock and habitat conditions.
Pg. 373 No monitoring costs for recreational hunting
Pg. 373 No monitoring cost for camping
Pg. 371 ATV and snowmobiles – The cost of monitoring the use of the refuge is the most expensive cost
we incur.
The counties question the accuracy of this. There is no way that 25-35 percent of the entire CMR staff’s time is
spent on grazing allotments with ATV and snowmobiles most expensive and no time on hunters
or campers. We request documentation of the accuracy of this statement be implemented in the
plan or sent to the counties.
Pg. 331 However, considering that the refuge currently supplies less than 1% of all AUM’s in the region,
the regional cumulative effect of the refuge management actions, when combined with the economic effects of
other land management changes would be negligible.
MFWP has indicated that less than 50 percent of the wildlife habitat is within the CMR boundary. There are
areas on the south side of the river which the CMR has less than 15 percent of the habitat. With
wildlife numbers at their current levels and if permitted to expand, the majority of these game
animals are going to be on private and BLM lands. The land they occupy have substantially
higher AUM’s than CMR lands. This would indicate that the management on both private and
BLM lands is adequately maintaining range and habitat conditions without prescriptive grazing.
10–13.
10–14.
10–15.
10–16.
12,
taken
-
October
were
of the public transcripts from
Barron Crawford’s remarks
In a review
2010, it appears that
out of context (Lewistown transcript pages 38–40). Mr. Craw
10–13.
ford stated, “the sentinel plant concept is not a new concept.”
The concept is new for this refuge, and he emphasized that
the Service is supposed to manage for wildlife habitat and
not range. The intention is not to return to historical condi-
tions, but to promote biological diversity, heterogeneity, and
resilience.
The plan is not aimed to make it not beneficial for
permittees to graze on the refuge (DEIS upland objective
D4, page 66). It would bring the refuge into compliance
with the Improvement Act, our compatibility policy, and
biological integrity policy by ensuring that grazing is used
to accomplish habitat and wildlife objectives. There is
considerable science on the use of prescriptive grazing. In the
FEIS, we added more information and citations in the upland
habitat section. Refer to comment 10–11 about the use of
A document is a
common practice in describing what impact could occur in the
, projections are
based on a combination of professional opinions made by read-ings
of scientific literature, past experiences, and from field
observations. The observation made in the DEIS (page 187) is
and the professional
The compatibility determination in the DEIS (page
entire refuge staff spends
25–35 percent of their time on these activities, but the field
personnel who are directly responsible for managing these
operations spend about that much time. Administrative staff,
, and others also
-
prescriptive grazing in alternative A.
10–14. The use of the word “likely” in a NEP
future. While there is not absolute certainty
work on the refuge
opinions of several biologists (DEIS page 350).
infer that the
field
mean to
, the deputy project leader
based on direct
10–15.
373) did not
the project leader
spend considerable time in administering the grazing pro
gram. This is clarified in the FEIS.
10–16. See response 10–7.
Comment
Number
46 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
Pg. 14 You say that AUM’s will not be addressed, however throughout this document everything is
being blamed on livestock grazing and justifies the reduction of AUM’s. Throughout the entire
document you refer to grazing continually. Therefore the counties believe that grazing should be
included in the Pg. 11 1.8 Significant issues to address.
Pg. 68 Strategies for Upland D1-D9 - If sentinel plants populations continue to decline after elimination
of livestock grazing, explore opportunities to promote periods of rest or abandonment for
sensitive areas. If sentinels continue to decline due to herbivory pressure, work with MFWP to
reduce the numbers of large ungulates throughout the Missouri River Breaks to levels lower than
objectives in MFWP’s management plans.
Counties oppose your Alt B & D and support Alt C
Pg. 64 C-1 – includes fencing for better livestock distribution, water development, rotational
grazing, and other management techniques designed to improve range condition.
C-2 – support surveys and scientific data to measure residual cover.
C C-4 – support using fire where physical features allow for efficient use of fire as management tool.
C-5 – support because coordination will occur with local ranchers and federal agencies.
C-6 – support evaluating process of prescriptive grazing and measuring success through a
comprehensive monitoring program. This will provide scientific data to develop adaptive management changes
if sentinel plants continue to decline.
Under Alternatives B, C and D, there is much discussion about prescriptive grazing. What is not
understood by the Service is that this action would generate a negative economic benefit to
permittees and counties. Permittees require a stable grazing allotment on which they can depend
from year to year. Without that insurance, their operations will not be sustainable and they will
have to sell part or their entire herd. This situation would become markedly critical during years
of drought. As a result, counties also, are impacted negatively through loss in taxable revenue
and potentially, population.
We included livestock grazing as part of the larger sig-issue
of habitat and wildlife management (DEIS page
10–17.
nificant
11, first bullet under habitat and wildlife management). This
the same as
strategy is used for meeting habitat objectives.
Upland objective D5 is
326–330) acknowledged the negative
-
10–18. Comment noted.
upland objective C–6.
The DEIS (pages
can arrange in their operations for future grazing needs.
10–19.
effects increased prescriptive grazing would have on some per
mittees (DEIS page 326), and we added to this in the FEIS.
We would work with permittees (DEIS page 66) during the
development of the habitat management plans to see where
they
Every effort will be made during that process to give ranchers
time to plan for their operations. Livestock operators who are
willing to work with us in achieving the wildlife and habitat
goals and objectives will benefit.
10–17.
10–18.
10–19.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 47
Letter #10: Fergus County Commissioners, Fergus County, Montana
Weeds
• In regard to the management of noxious and invasive species under Alternative B, it is stated
that the Service would collaborate with others to combat invasive plants on the shorelines. It
must be noted that for many years travelers through lands managed by the Service have
observed first-hand that there are many species of noxious weeds recognized as such by
various Montana departments and agencies, as well as the Bureau of Land Management that
occur in many parts of the Refuge other than just the shorelines.
• It has also been the case that observations of the after-effects of fires, appearing in the first
new re-growth have been an abundance of noxious weeds. This should be considered and
weighed carefully when any management decision is made using prescribed fire and should
be taken into consideration in Alternatives B and D.
• The Service, historically, has been notorious for allowing invasive species (noxious weeds)
to flourish on CMR managed lands. This has become a serious reverse economic impact to
counties and adjacent landowners. Nowhere in the CCP has this reverse economic impact
been measured or noted.
• One of the most serious examples of inattention on the part of the Service has been the
unchecked proliferation of Canada Thistle. This noxious weed has spread without
recognition by the Service of the devastation it causes to rangeland for both the wildlife and
livestock.
Pg. 83 Continue to work with the Service’s invasive species strike team, county weed boards, neighbors and
conservation organizations to maintain and update mapping of weed infestation.
•
Pg. 83 Continue to work with the Service’s invasive species strike team, county weed boards, neighbors
and conservation organizations to maintain and update mapping of weed infestation.
We would like the word continue removed. Nothing has been done to work with the county’s weed boards on
invasive species. Should read work with.
10–20.
10–21.
10–22.
10–23.
10–24.
The DEIS (pages 199–200) references what is known
about invasive species and the efforts to reduce their spread.
In all of the action alternatives (B, C, and D), we would in-crease
our efforts to combat invasive and noxious weed spe-
e agree that any management decision to use pre-
. In the first regrowth
after fire, noxious weeds do not occur unless the land has a
history of overgrazing by livestock or other disturbance result-ing
in high populations of weeds already present. For example,
Japanese brome (a noxious weed), is replaced by a healthy
a pre-species
after
the
native collection of plants a few years
W
diverse
10–20.
cies.
10–21.
and
scribed fire. It is not possible to generalize on the response of
on
scribed fire should be weighed carefully
weeds to wildfire or prescribed fire. It depends
of weed, the species of native plants present, the soil, moisture
conditions before and after the fire, the time of year the fire
-
occurs, the intensity of the fire, and more.
10–22. See response 10–20 about action alternatives. Saltcedar
has been pointed out as the primary invasive species of con
cern during the planning process. It flourishes below the high
water mark along the shoreline of Fort Peck (DEIS page 200).
In areas where there has been disturbance, other invasive spe-cies
have also flourished. In other disturbance areas, invasive
, the refuge has been on
-
been
-
species have also flourished. Further
the receiving end of invasive species from adjacent lands.
outbreaks of Canada thistle occur in dis
the shoreline. Their extent has not
Most of the
areas along
10–23.
turbed
mapped (DEIS page 199).
10–24. Invasive species control projects continue to be ac
complished around the refuge. The Service has worked with
county extension agents, the Mussellshell River Working
Group, USACE, BLM, and others (DEIS page 200).
Comment
Number
48 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
Water
Pg. xvii Wildlife populations, both on and off the Refuge, are affected by water quality and access to
water. Livestock grazing has degraded habitat, particularly near water sources.
wildlife are also using the water sources. Again you blame livestock grazing for all the degrading
of the habitat on the Refuge. The counties support more water resources to disperse cattle and
wild ungulates to mitigate the damages of habitat near water sources.
Most of the wildlife and habitat are off the Refuge, which is outside your jurisdiction.
The plan lists no scientific data on the water resources that have been damaged outside the CMR
boundary. This document needs to show monitoring data of water sources off the refuge.
Pg. 72 Riparian Area and Wetland B2 (same as D) – Over 15 years remove all reservoir and stock
ponds that do not support species of concern and adhering to any permit requirements, initiate
restoration of the natural hydrology of the drainage. Determine if additional stock ponds are
needed to meet requirements of target species.
Oppose removing all reservoirs and stock ponds that do not support species of concern. Wildlife would be
concentrated on the river causing damage to the habitat and hunter conflicts. The counties
support more water resources to disperse cattle and wild ungulates to mitigate the damages of
habitat near water sources. It must be noted that stock ponds notably benefit migratory
waterfowl.
Support C-2 Riparian Area and Wetland.
Pg 40 &57 Water quality is mentioned throughout on grazing in summary of Alt B & D water quality is
specifically blamed on grazing? The plan needs to show data on the effects that prescriptive
grazing and burning (natural and prescriptive) have on water quality.
There is no information presented as to what water
effects of
.
. See response 10–7.
noted the
We note the counties’ opposition to any stock pond
-
ildlife does not require human-made impound-e
-
found. W
prescrip
have normally been
beneficial
would not
Comment noted.
we
that
FEIS,
numbers
In the
10–25.
resources have been damaged from refuge management. Most
of the water resources on the refuge are downstream of the
refuge boundary
10–26.
removal. Looking at potential impacts to migratory waterfowl,
we reviewed the national hydrology data set on the number
of waterbodies that exist outside the refuge but within the
scope of analysis. There are more than 1,200 water bodies (av
eraging 18 acres) and the overall effect would be negligible for
waterfowl. Removal of constructed reservoirs and stock ponds
within the refuge will not concentrate wildlife on the Missouri
River to any great degree. Once artificial impoundments are
removed, prairie stream functions would be restored along
with corresponding riparian areas. As riparian areas develop,
beaver would naturally return and beaver ponds would become
reestablished. W
ments (Krausman 2006), and any benefits are often outweighed
by the adverse effects caused by concentrating wildlife in areas
and at
added information to the FEIS on this topic.
10–27.
10–28.
tive grazing on water quality and clarified information about
the use of prescribed fire and water quality
10–25.
10–26.
10–27.
10–28.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 49
Letter #10: Fergus County Commissioners, Fergus County, Montana
Roads
Pg. 334 MFWP would like to see the Service reopen a number of refuge roads that have been closed in
the past, including those within proposed wilderness units.
Pg. 334 The counties are also concerned about a number of issues related to roads and particularly about
recognizing rights of way under RS 2477 or where they believe they have a valid county
petitioned right of way.
While the CCP advises that determining the legal validity of roads within the CMR is outside of the scope of the
CCP and that the Service has no control over determining legality, the Service appears overzealous in
discussing the closure of 106 miles of road under Alternative B and 23 miles of road under Alternative D.
There are legal procedures involved in closing legally petitioned county roads, which the Service has chosen to
ignore. Montana Road Law has been ignored. Before any roads are closed, the six counties insist that Montana
Road Law be included in the decisions.
The total number of miles closed prior to the CCP should be acknowledged.
The counties are opposed to permanently closing road 315 in Petroleum county. It is presently seasonally closed
which accomplishes wildlife protection needs.
Pg. 119 The counties support Access C1 – C4, D3 & D4
The counties are requesting that language be put in this document that emergency services are allowed to use
closed roads to rescue lost, injured or incapacitated hunters, hikers, bird watchers or others who
may be miles from an open road.
The counties support additional access for elderly and disabled.
Wildlife/Bison
The Department of Interior Bison Conservation Initiative, October 28, 2008, states Charles M. Russell National
wildlife refuge is in the early stages of considering devoting part of the refuge to bison habitat with adjoining
landowners including the BLM.
This document contradicts everything that the CMR has stated about introducing bison on the refuge.
Pg. 63 Rationale for Alt B is the only mention of bison is that Murie identified evidence of earlier
occupation of bison.
Pg. 92 The International Union for Conservation of Nature established the Bison Specialist group that
was charged in 2005 with developing a “North American strategy for Bison Conservation”. That
comprehensive plan is expected to be released in the near future and will provide scientifically
based guidelines for proponents interested in restoring bison at an ecologically functional scale.
The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS meet
four elements: a.) quality; b) utility (referring to the usefulness of the data for its intended
purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d) integrity.
Reintroduction of Big Horn Sheep has been discussed under Alternatives B, C, and D, with the
addition of “promoting private conservation easements and conservation incentives to benefit
species diversity or restore extirpated species and cooperating with MWFP to consider other
species reintroductions or expansion of species when there is adequate habitat to support the
species” included in Alternative D. In plain language, the latter is interpreted to include the
Wildlife/Bison cont.
10–29.
10–30.
10–31.
10–32.
10–33.
10–34.
10–35.
that are
W
should be
roads
policy.
CCP is to identify the
necessary for habitat and wildlife management and public
uses. This is consistent with the guidance found in the Im-Service’s
planning e agree
that old rights-of-way disputes are important issues, but the
e work with local
governments to address rights-of-way as we did in Petroleum
County (DEIS page 231). Given there is substantial variance
by the six counties, these issues
e have incorporated in the FEIS and CCP a number of
suggestions that the counties made. For example, we included
winter access for ice fishing and improvements to the Knox
.
In defining the no-action alternative (alternative A), we
reviewed the existing guide map (last revised 2002), earlier
guide maps, old files, wilderness studies, and other information
we could find on refuge roads. In doing so, we have not found
any inconsistencies in our interpretation of the no-action
alternative as it is portrayed in the DEIS. Past road closures,
some dating back more than 30 years, are not relevant to the
ith 670 miles of roads open on the
, there are few
changed to
its wildlife
road 838 is
accomplish
with
e can
junction
W
the
of the
and
role
Act
315 from its
The
CCP is not the tool for resolving them. W
records kept
provement
in the
addressed at the county level.
Road
10–29.
W
Ridge road, as suggested by Fergus County
no-action alternative. W
refuge and boat access from the lake and river
places on the refuge that cannot be accessed within a mile of
existing access.
10–30.
a seasonal closure in the FEIS.
objectives through a seasonal closure while allowing seasonal
Through communication and cooperation, whatever
access.
10–31.
actions are needed to rescue a visitor will be accommodated.
Under all alternatives, the Service will carry out management
actions through cooperation and collaboration with Federal,
State and local governments. Existing facilities should be
universally accessible and conform to accessibility standards;
however, as noted in the DEIS (page 232), there are hundreds
of miles of open refuge roads that are available for hunters of
all abilities in addition to the accessible hunting blind.
Comment
Number
50 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
been
bison
-
and
The
-
-
have
play in
habitat
there
should
for
process
consider
, the refuge is not in
refuge
planning
the
bison
role
Comment noted.
the
what
From early
management. Many citizens and stakeholder groups have
expressed a desire for bison restoration, and this was identi
to
or wolf reintroduction.
significant issues
olves and bison are specifically dis
in
conversations about
of the
. We clarified the discussion in the FEIS under this
fied one
the lead role in any bison restoration proposal. This message
extends to include
10–32.
any stage of devoting considerable refuge habitat to bison,
although there is one permittee on the south side of the refuge
that has grazed bison for years.
10–34. The comment makes no reference to any specific data.
We disagree that this summary statement in the DEIS
58)
10–33.
as
wildlife. Since the Service began drafting alternatives, with
county representatives participating in those discussions, we
have been consistent in our message that the State should play
did not change in the DEIS. Currently
10–35.
(page
statement refers to conservation efforts at a landscape level
through partnerships. W
cussed in the DEIS (pages 92–94 and 99). There are no propos
als to reintroduce wolves, but it is possible they may arrive
naturally and refuge management needs to prepare for that
possibility
section. See also response 10–33 about bison.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 51
Letter #10: Fergus County Commissioners, Fergus County, Montana
reintroduction of free-ranging bison and/or wolves and a serious threat to the continuation of the
agricultural economic base of the entire plains counties of Montana. An in-depth economic
study of the impact of introducing free-ranging bison and/or wolves on the CMR must be
completed prior to any such action.
Even though the MFWP and others have invested time and effort trying to produce brucellosis
free bison herd as stock to establish herds managed for conservation and ecological purposes
elsewhere, the counties would request that bison are brucellosis free beyond a reasonable doubt.
Pg. 93 The Service would cooperate with MFWP, BLM, DNRC, conservation organizations and others
to conduct the necessary biological, social and economic research to determine the feasibility of
such a proposal. (Bison restoration)
It is inappropriate to name partners such as the World Wildlife Fund, the American Prairie
Foundation, and the International Union for Conservation of Nature, whose vast ability to
amass funds extends to many other countries other than the United States. It is estimated that
80% of the members of such organizations are not citizens of the U.S. Because the Refuge is
owned and maintained by United States taxpayers under the federal estate, world-wide plans
for the future of our refuge to include free-ranging bison must not be based on outside
(residents from other countries) objectives. Therefore the counties oppose the wording of
listing individual conservation groups and referring to the counties and neighboring
landowners as others.
We oppose bison on the CMR. Bison are not currently considered a wildlife species outside of Yellowstone
Park and therefore should not be addresses as such.
Phillips county passed a resolution 2010-08 that states all buffalo in Phillips County will be considered
domestic livestock, regardless of origin.
During public meetings orchestrated by the MFWP, vast numbers of residents of the six counties
within which the CMR exists, attended to voice their adamant opposition to the idea of free-ranging
bison because of their concerns that their livelihood would be negatively impacted.
Pg. 88 Rationale for Alt B reference to Murie’s observations from 1935 – 75 years ago when he
believed that the west end of the refuge could support 2,000 -2,500 elk and he predicted that
mule deer would continue to flourish in the pine uplands.
Things change in 75 years and this is another reason this plan is setting unattainable goals. The plans places a
lot of emphasis on one person’s observations to do this. Murie’s observations were based on
beliefs and not scientific data.
Pg. 88 Cooperation with landowners and wildlife managers is necessary to ensure that big game
populations are healthy to support wildlife dependent recreational activities.
They want the landowners to cooperate for the benefit of wildlife but are making it non beneficial for livestock
permittees to graze on the CMR.
Counties support mountain lion hunting on the CMR
10–36. See response 10–33. We collaborate with a wide array
of national and international partners to protect wildlife. For
example, the DEIS (page 6) describes international partner-ships
to protect birds. The purpose of the reference in the
DEIS (page 92) was to provide context for the interest in bison
Comments noted.
restoration.
None of the alternatives rely solely on Murie’s observa-
10–37.
10–38.
tions and report. It is true that many things have changed
during the last 75 years, many of them to the benefit of wildlife
and wildlife habitat. Much of his report focused on big game
species and most are now more widespread and abundant than
the conservative estimates and distribution he envisioned dur-ing
his assessment, which he made during the bleak times just
after the Great Depression and Dust Bowl era of the “dirty
thirties.” Olaus Murie was an accomplished naturalist and
pioneer in the field of wildlife biology who did ground-breaking
field research on a variety of mammals. We used his report,
based on site visits throughout the refuge and conversations
with numerous residents, as an expert reference of the time.
Comment noted.
Comment noted.
10–39.
10–40.
10–36.
10–37.
10–38.
10–39.
10–40.
Comment
Number
52 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
Fire
Pg. 333 Alt C would not promote fires natural role while B & D would. All alternatives would
protect private property.
Considering the geographic size and shape of the CMR. Fires have a significant chance
of leaving the CMR and burning adjoining lands.
Pg. 329 Under all alternatives the Service would extend agreements that are already in place
for aggressive fire suppression activities on DNRC lands.
Should state aggressive fire suppression on private lands.
Pg. 331 The use of prescribed fire would improve plant vigor and health, but there could be
some temporary losses of soil. Major wildfires could lead to severe soil erosion.
The plan needs to show data on the effects that burning (natural and prescriptive) have on water quality.
Pg. 39 Alt B – Wildfire would be used to protect, maintain and enhance resources and where
possible, be allowed to function in its natural ecological role.
Pg. 57 Alt D – The service would restore the natural fire regime through increased use of prescribed
fire to increase the viability of fire dependent plant species.
Pg. 81 Wildfire C-2 support but add when the potential exists to threaten state or private properties.
With federal budgets being strained how can you have a plan that will greatly increase the management costs
by implementing prescribed fires? It is not fiscally responsible to implement a plan that can’t be
carried out because of budget restraints.
Executive Order 13514 signed by President Obama in Section 9. Recommendations for greenhouse gas
accounting and reporting subsection (iii) consider and account for sequestration and emissions
of greenhouse gases resulting from Federal land management practices. Contrary to what was
stated by Barron Crawford, there is no evidence that carbon from prescribed fires is sequestered
in the ground. The study by TH DeLuca was paid by a biased group and does not meet the
criteria.
The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS
meet four elements: a.) quality; b) utility (referring to the usefulness of the data for its
intended purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d)
integrity.
10–41. This was added to the discussion of unavoidable adverse
effects in the FEIS.
10–42. We agree and have clarified this information in the
FEIS. The goal for fire management specifically states we will
-
protect values at risk (DEIS page 30).
10–43. More information was added about fires and water qual
ity in the FEIS.
10–44. It is not unusual for an action alternative to require
substantial additional money to implement, and this was noted
inside cover and in the DEIS (page 1). All funding is
In the FEIS, our policy for adhering to Executive Or-on
the
based on annual appropriations.
10–45.
der 13514 (565FW1) was added to the section under climate
change in the DEIS (pages 84–85 and in appendix D). All of the
suggestions identified in the DEIS (pages 84–85) are consistent
with the new Executive Order. We note Fergus county’s op-position
to the study by DeLuca, but we stand by the study.
Under all alternatives, we would be required to adhere to
Executive Order 13514. Carrying out any specific action in the
alternatives will negligibly affect climate change, and all alter-natives
will provide many benefits for carbon sequestration
due to the large amount of vegetated land the refuge provides.
It is not clear from the comment as to why you see the DeLuca
and Aplet study as biased or not meeting the criteria under the
Data Quality Act. We note that the DeLuca and Aplet study
Fergus County refers to was part of a larger discussion under
the rationale for climate change (DEIS page 86). None of the
actions were specifically derived from that study, nor was it
used in the analysis under “Environmental Consequences” in
chapter 5. See response 10–5 about the Data Quality Act.
10–41.
10–42.
10–43.
10–44.
10–45.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 53
Letter #10: Fergus County Commissioners, Fergus County, Montana
Wolves/Predators
Pg xxiii Predators would be managed to benefit the ecological integrity of the refuge.
The counties support a year round coyote hunting season.
Pg. 99 Alt B & D We oppose no hunting season for wolves on the Refuge. You should work with the
FWP in setting a season. Again you not taking into account how the decision you make on the
refuge is going to affect the adjoining landowners and the economies of the counties. No
hunting of wolves will also negatively affect the wildlife on and off the refuge.
An in-depth economic study of the impact of allowing wolves on the CMR must be
completed prior to any such action.
We oppose wolves on the CMR.
Phillips County passed a resolution 2003-03 stating that “wolves are deemed an
unacceptable species” and prohibit the presence, introduction or reintroduction of wolves
within the boundaries of Phillips County.
Phillips County passed resolution #2003-02 “unacceptable species” prohibiting the presence,
introduction or reintroduction of any animals which pose a threat to public, health, safety and
livelihood within the boundaries of Phillips County and shall take any and all actions
necessary to protect its citizens.
Fergus County passed resolution #6-2003 deeming wolves an unacceptable species
Climate Change
Pg. 84 the Great Plains is projected to experience increases in temperature, evaporation, and drought
frequency. The average temperature is expected to increase 2-4 degrees F by the year 2020 in
the plains. The final CCP will be in place in 2020.
A great deal of the CCP is devoted to researching the CMR’s response to climate change.
The scientific community has become increasingly divided on this issue. While we agree
that climate change is taking place, just as the sun comes up every morning, it is our
contention that not enough valid scientific data exists to preclude that during the fifteen
year projected lifespan of this CCP, anyone is going to observe any great change in the
habitat or subsistence of any of the wildlife currently populating the CMR. Less emphasis
should be put on researching climate change.
All of the climate objectives came from the one publisher, U.S. Global Change Research
Program (Karl et al 2009).
Executive Order 13514 signed by President Obama in Section 9. Recommendations for greenhouse gas
accounting and reporting subsection (iii) consider and account for sequestration and emissions
of greenhouse gases resulting from Federal land management practices.
10–46.
10–47.
10–48.
10–49.
10–50.
-
resilience of the refuge’s ecological sys
Comment noted.
s role.
We have modified the language in the FEIS to reflect
10–46.
10–47.
the State’
We do not have plans to reintroduce wolves.
As noted in the DEIS (page 7), response to climate
10–48.
10–49.
change is a top priority for the Department of Interior and
the Service. The objectives reflect this priority (DEIS pages
84–86). Improving the -
tems (DEIS page 66) is key to managing the refuge in a chang
ing climate. The focus would be on research, monitoring, and
management of the following: carbon sinks and sources; black
-
carbon; climate sentinel plants; dependent animals; and eco-logical
processes and the food web that uses them, beginning
with pollinators (DEIS page 86).
10–50. We added the new Executive Order in the FEIS. The
U.S. Global Change Research Program coordinates and inte
grates Federal research on changes in the global environment.
It was mandated by the U.S. Congress in the Global Change
Research Act of 1990 (Public Law 101–606), which called for
a “comprehensive and integrated United States research pro-gram,
which will assist the Nation and the world to under-stand,
assess, predict, and respond to human-induced natural
processes of global change.”
Comment
Number
54 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
Environmental Consequences
Pg. xxiv The degree of effect was quantified using known numeric or modeled estimates or where
extensive monitoring or research provided the information. Where sufficient numeric
information was not available, qualitative or relative assessments were made using scientific
literature or professional field experience.
This plan should not be based on estimates or literature that is based on scientific data from areas outside of the
CMR.
The Data Quality Act (DQA). 66 Fed. Reg. 49719 requires that the data used and published by the FWS meet
four elements: a.) quality; b) utility (referring to the usefulness of the data for its intended
purpose; c) objectivity (the data must be accurate, reliable and unbiased) and d) integrity.
Wilderness
We support Alternative A - There would be no additions or subtractions to the acreages of the proposed
wilderness units.
We oppose expanding wilderness boundaries to the edges of open roads or the CMR boundary. This would
negative impact on the counties economies.
Public comment has indicated the solitude of the area. By expanding wilderness to the edge of the road it will
take away from the current solitude.
-
10–51. The language in the DEIS is consistent with NEPA,
U.S. Department of the Interior (DOI) regulations, the Im
provement Act, and our planning policy in using available
science when other data does not exist. The comment does
not provide specifics about what scientific information is inac-curate
or how it should be corrected. See response 10–5.
10–52. The small expansions of the wilderness boundary would
have negligible effects on access, solitude or the economies of
the counties. We made several changes to the proposed wilder-ness
alternatives after considerable review from the public and
others. Slight changes were made to the acreage in alternative
B and D due to mapping errors in the DEIS. In addition, we
determined there is not sufficient justification for recommend-ing
deletion of any existing proposed wilderness area.
10–51.
10–52.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 55
Letter #10: Fergus County Commissioners, Fergus County, Montana
Economics
Pg. 317 Alternative A – one job for every 1,350 AUM’s of livestock grazing
Current level of AUM’s actually used on refuge would generate 14 jobs in local economy
(6 counties – Table 35)
AUM’s % Jobs $775,500 of Production $1.5 million total econ output
Fergus 359 1.9 .27 $14,735 $28,500
Garfield 6,839 36.2 5.1 $280,731 $543,000
Petroleum 468 2.5 .35 $19,387 $37,500
Phillips 4,849 25.7 3.6 $199,303 $385,500
McCone 2,726 14.4 2. $111,672 $216,000
Valley 3,631 19.2 2.7 $148,896 $288,000
If you look at the figures straight from the CMR, there are definitely more than negligible effects on the
counties if the AUM’s were lost.
Pg. xxiv While the overall economic effects of any alternative would be positive, implementation of new
grazing and habitat management approaches in Alt B and D would result in impacts to individual
livestock permitees.
As stated above the impacts would affect more than just the individual permittees. Overall impacts of any
alternatives would not be positive.
Pg. 12 This draft CCP and EIS addresses the following aspects of the socioeconomic issue: Range of
alternatives and effects of those alternatives on the local economy and community.
From the statements in the CCP it is obvious that the actual impacts to the economy and communities is not
truly understood. Economic data is not complete. The data prepared for the Prairie Foundation
was used but the counties were not consulted.
The six counties met with USGS once. At that meeting they stated that they would come to the individual
counties and talk with the county commissioners to gain better knowledge of the economics of
the counties. That never happened.
Under Alternatives B, C and D, there is much discussion about prescriptive grazing. What is not understood by
the Service is that this action would generate a negative economic benefit to permittees and counties.
Permittees require a stable grazing allotment on which they can depend from year to year. Without that
insurance, their operations will not be sustainable and they will have to sell part or their entire herd. This
situation would become markedly critical during years of drought. As a result, counties also, are impacted
negatively through loss in taxable revenue and potentially, population.
The data on visitor numbers is questionable. It is mathematically impossible to have the number of visitors that
you are referencing in the document.
10–53.
10–54.
10–55.
10–56.
See response 10–4. The USGS social scientists met with
-
the
-
related to
Representa
issues
2008.
economic
on June 4,
and
not available through State and
See response 10–10.
their social
refuge headquarters
discuss
the
more information
10–53.
10–54.
several of the local county commissioners and representa
to
at
tives
CCP
tives from Phillips and McCone Counties provided copies of
fact sheets and suggestions for local contacts at the meeting.
The USGS followed up with the local contacts in an attempt
to gather
national data sources. Krystal Steinmetz from the Bear Paw
Development Corporation provided demographic information
about Phillips County and the communities of Malta, Saco, and
Dodson, but the data were all from existing national and State
data sources. Anne Boothe from the Phillips County Economic
Growth Council was not exactly sure what she had that was
not generated through census materials. The USGS was able
to locate additional socioeconomic profiles for the local counties
completed by Headwater Economics, Economic Profile Sys-tem.
Databases used for the Economic Profile System county
profiles are from national sources: Bureau of the Census includ-ing
County Business Patterns; Bureau of Labor Statistics; and
the Regional Economic Information System of the Bureau of
Economic Analysis, U.S. Department of Commerce. To use
consistent and the most up-to-date data across the counties,
the USGS pulled the most recent demographic and economic
county-level data directly from the national and State sources.
These data sources were the same as those used in the reports
provided by the counties but were more up to date. In July
2011, we provided the counties with emails and data sources
used by USGS in the economic analysis and offered a willing-ness
to expand further discussions of the affected environment
until
e did not
there was data that was left out. We gave the counties
The DEIS acknowledges the moderate to major impacts
if
August 15, 2011, to provide us with additional data. W
receive further communication or data on this topic.
10–55.
to some permittees as greater reliance on prescriptive grazing
occurs (pages 326–33).
Comment
Number
56 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #10: Fergus County Commissioners, Fergus County, Montana Response
Subject seilstadt emai
Laurie Shannon, Planning Team Leader
U.S. Fish and Wildlife Service
134 Union Boulevard
Lakewood, CO 80228
ph: (303) 236-4317
fax: (303) 236-4792
"Life isn't about how to survive the storm, but how to dance in the rain" --Unknown
----- Forwarded by Laurie Shannon/R6/FWS/DOI on 08/01/2011 06:51 AM -----
"Carl Seilstad"

12/01/2010 03:41 PM
To 
cc 
Subject
Laurie,
I am sending you these additional comments per our phone conversation on the 24th of November.
As I mentioned to you I do not believe the counties concerns were addressed in the planning process for
the CCP.
We have opposed the aggressive approach to prescriptive grazing in Alternative D. As it currently stands
you have that ability to go towards prescriptive grazing in Alternative A, Pg 330. We outlined this under
our comments under Grazing. What we did not put in our comments was that our permittee would be
putting cattle in a new pasture without the cattle or their owners knowing where the water sources are.
Anyone that raises cattle will tell you until if a cow is not accustomed to their environment their calves will
wean at a lighter weight. Having to transport cattle beyond what the permittee is doing now would also
be an economic factor. Once these producers gather there their cattle what kind of facilities will there be
for loading and transporting them home? If they move into a new pasture is the CMR going to assure the
permittee that the fences will hold their cattle, or are you going to make them fence every pasture you
force them into. All of these concerns will make economically unfeasible to graze the CMR. If you stayed
with Alternative A at least there would be sound science to back prescriptive gazing. We also feel that
your economic analysis is incorrect if you take the aggressive approach to prescriptive grazing.
The counties met with the USGS at one of the planning meeting and we were told they would get with
each individual county to gain better knowledge of the economics of the counties. However you used
economic data from the Prairie Foundation the Counties were never consulted.
I also suggested that before a final document is released that the cooperating agencies have a final
meeting with the CMR CCO planning team.
These are just a couple of the issues we brought up in our comments. I would suggest you look closely at
not only our comments but the comments submitted by Lund Law as this firm is representing the six
counties. We will look to see at that time if our comments were actually used.
Thank you
Carl Seilstad
s estimates of current visitation figures
come from a variety of sources including traffic counters, phys-ical
counts, and hunter permits. The estimates of increased
visitation over 15 years are modest numbers (see previous
responses 28–49), and the rationale behind those numbers was
explained (DEIS pages 105–107 and 112–114). The comment
does not provide facts as to why the data is inaccurate. In the
FEIS, we have clarified the information in the DEIS (page
consistent
to
is
227) about how we estimated visitation numbers.
In the FEIS, we added more discussion about the use
of prescriptive grazing throughout the document. We acknowl-
edge there could be important considerations for some opera-tors
who are used to turning their cattle out at the beginning
of the grazing season. Even under alternative A, we would
For
which
of increased fees
example of this.
grazing
in spite
good
prescriptive
with our legal mandates. It would likely exceed 50 percent
transport their cattle frequently
implementing
ithin the Refuge System, there are many examples of
operators who
new pastures based on the requirements of a prescriptive
grazing program. These operators find it is worth their while
refuge
a
wildlife
The refuge’
within 15 years, given the Service has progressed from 0–34
provides
percent in 20 years.
national
Ranch
on a
and transportation costs. In northeastern Montana, many
Matador
10–56.
10–57.
continue
W
livestock
to graze
livestock operators transport their cattle to other grazing
some operators, these would not be insurmountable issues,
and some of the concerns raised could be worked out during
development of the habitat management plans.
10–58. See response 10–4.
10–59. Thank you for your comments.
areas.
10–57.
10–58.
10–59.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 57
Letter #11: McCone County Commissioners, McCone County, Montana
Thank you for your comments. The Service has valued
toward prescrip-
-
s contributions in the CCP.
greater transition
11–1.
McCone County’
11–2. We recognize that a
tive grazing from current conditions (34 percent) could nega
tively affect some permittees (DEIS page 326–331). Even
under alternative A, the amount of prescriptive grazing is
likely to be closer to 50 percent or greater for more than 15
years, depending on ranch sales or other factors. As stated in
the DEIS (page 66), we would communicate with the permit-tees
in developing the habitat management plans so ranchers
can make arrangements for future grazing needs. The habitat
management plans are where specific prescriptions for a given
habitat management unit would be developed.
11–3. All of the action alternatives would result in increased
efforts toward reducing invasive and noxious weeds. We will
continue to work with cooperators to limit the introduction and
spread of invasive and noxious weeds in the refuge, including
nearby lands.
11–1.
11–2.
11–3.
Comment
Number
58 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #11: McCone County Commissioners, McCone County, Montana Response
-
e agree that any management decision to use pre-
, but do not agree that
there is an abundance of noxious weeds in the first new re-growth
after a fire, unless the land has a history of overgrazing
by livestock resulting in high populations of weeds already
present. Japanese brome, for example, decreases for a few
years after fire on most sites when a healthy and diverse na-tive
collection of plants occurs on the site. It is not possible to
generalize on the response of weeds to wildfire or prescribed
fire. It depends on the species of weed and native plants that
are present; soil types; moisture conditions before and after the
fire; time of year the fire occurs; and the intensity of the fire.
e agree that the proliferation of invasive species is an
important issue, but we disagree that the refuge bears sole re
, which has been pointed
of concern
invasive species
an issue
scribed fire should be weighed carefully
sponsibility for its causation. Saltcedar
many of the local communities as
has flourished below the high watermark along the shoreline
of Fort Peck, but we do not control water levels on the lake
(DEIS
-
man-
-
-
mapped
areas,
extent has not been
s ecological systems is key to
other disturbance
Its
200). In
W
W
page
11–4.
11–5.
out by
(DEIS
have also flourished.
Most Canada thistle outbreaks occur in disturbed areas
the shoreline.
page 199).
11–7. Comment noted and acknowledged (DEIS page 220).
Response to climate change is a top priority for the De
11–6.
along
11–8.
partment of the Interior and the Service (DEIS page 7). The
objectives reflect this priority (DEIS pages 84–86). Improving
the resilience of the refuge’
aging the refuge in a changing climate (DEIS page 66).
11–9. We note the counties’ opposition to any stock pond re
moval. There are more than 1,200 water bodies (averaging
18 acres) within the scope of analysis and the overall effect
of stock pond removal would be negligible for waterfowl. Re
moval of human-made reservoirs and stock ponds within the
refuge would not concentrate wildlife on the Missouri River to
11–4.
11–5.
11–6.
11–7.
11–8.
11–9.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 59
Letter #11: McCone County Commissioners, McCone County, Montana
any great extent. Once artificial impoundments are removed,
prairie stream functions would be restored along with cor-responding
riparian areas. As riparian areas develop, beaver
-
-
e
-
-
-
become re
ildlife does not require human-made impound
ments (Krausman 2006) and any benefits are often outweighed
by the adverse effects caused by concentrating wildlife in areas
found. W
There are no plans to introduce wolves or bison onto the
See response 11–10. From early in the planning process
there have been conversations about what role the refuge
-
-
-
stake
address
and
would
been
ponds
normally
and beaver
not have
naturally return
that would
would
established. W
and at numbers
have added information to the FEIS on this topic.
play in bison management. Many citizens
11–10.
refuge.
11–11.
should
holder groups have expressed a desire for bison restoration;
this was identified as one of the significant issues to consider
under habitat and wildlife. Since we began drafting alterna
tives, we have been consistent in our message that the State
should play a lead role in any bison restoration proposal that
goes forward. This message did not change in the DEIS. Cur
rently, the refuge is not devoting considerable refuge habitat
to bison, although there is one permittee on the south side of
e cooperate and partner with a wide array of national
e agree that they are important is
the refuge that has grazed bison for years.
and international partners to protect wildlife (DEIS page 6,
describes international partnerships to protect birds). The
discussion in the DEIS (page 92) provides the context behind
the interest in bison conservation.
Comment noted.
The role of the CCP is to identify roads that are neces
11–13.
11–14.
sary for habitat and wildlife management and public uses. This
is consistent with the guidance found in the Improvement Act
and our planning policy. W
11–12.
sues, but the CCP is not the proper tool to resolve them. For
we have worked with Petroleum County in
W
example,
11–10.
11–11.
11–12.
11–13.
11–14.
Comment
Number
60 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #11: McCone County Commissioners, McCone County, Montana Response
ing rights-of-way (DEIS page 231). Given there is substantial
variance in the records kept by the six counties, these issues
o the extent that the counties have provided suggestions
about what is needed for habitat, wildlife, and public uses, we have
incorporated their suggestions in the CCP and EIS. For example,
we included allowing seasonal access for ice fishing as suggested
by Fergus County and improvements to the Knox Ridge road.
Road 315 in Petroleum County will remain open as a seasonally
are several examples
with the counties for
, as noted in the DEIS (page 232), there are hundreds
of miles of open refuge roads that are available for hunters of
all abilities in addition to the accessible hunting blind.
The small expansions of wilderness areas would have
a negligible effect on access, solitude, or the economies of the
-
road maintenance, and those arrangements would continue.
Through communication and cooperation, whatever
actions are needed to rescue a visitor will be accommodated.
Under all alternatives, the Service will carry out management
actions through cooperation and collaboration with Federal,
State and local governments. Existing facilities should be
universally accessible and conform to accessibility standards;
The economic impacts of revenue sharing were dis
e currently buy inholdings
-
should be addressed at the county level.
T
opened road in alternative D. There
in the DEIS about agreements
Comment noted.
discussed
11–15.
however
11–16.
11–17.
counties.
11–18.
cussed in the DEIS (page 313). W
from willing sellers and this would not change under any al
ternative. We have clarified this in the FEIS. The location
and timing of future land acquisitions are based on unforeseen
opportunities and market conditions. Therefore, changes in
-
property tax revenue and revenue sharing payments of poten-tial
future land acquisitions would be speculative at this time.
For refuge lands, there is a refuge revenue sharing payment.
T) do not apply to refuge lands
the counties’ con-
Payments in lieu of taxes (PIL
(DEIS pages 14 and 313). We understand
cerns on the amount of these payments in recent years. Our re
cords show McCone County was paid $1606 in fiscal year 2001.
11–15.
11–16.
11–17.
11–18.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 61
Letter #11: McCone County Commissioners, McCone County, Montana
-
-
11–19. We are pursuing an extension of the mineral with
drawal for locatable minerals on the Charles M. Russell Ref
uge (UL Bend Refuge has a permanent withdrawal). Under
several alternatives we will advocate for a permanent with-Only
the U.S. Congress can designate a permanent
e have clarified the information in the FEIS
drawal.
withdrawal. W
about mineral development and its potential.
We cooperate with several national and international
-
(page 92) provides the context behind the interest in
11–20.
partners to protect wildlife (DEIS page 6, describes inter
national partnerships to protect birds). The discussion in the
DEIS
bison restoration.
11–21. Thank you for your comments.
11–19.
11–20.
11–21.
Comment
Number
62 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #11: McCone County Commissioners, McCone County, Montana Response
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 63
Letter #12: Petroleum County Commissioners, Petroleum County, Montana
12–1.
12–2.
12–3.
12–4.
12–5.
12–6.
The mineral estate for locatable minerals was withdrawn
for 20 years on Charles M. Russell Refuge and permanently on
e are seeking another
20-year mineral withdrawal on the Charles M. Russell Refuge
and further clarified this in the FEIS. Although we are seeking
a permanent withdrawal, only the U.S. Congress can make this
In the FEIS, we changed road 315 to a seasonally closed
road from the junction of road 838 to its end. This will improve
late summer and winter wildlife habitat and at the same time
popu-
-
within,
e have
, the
a
future
cannot
of
to
CCP
refuge boundary, we
inholdings from willing sellers when there is available funding.
. This would
access
currently buy
in revenue
willing sellers
deficit
and
the UL Bend Refuge (DEIS page 173). W
the road for vehicle
ater Resources Development Act of
2000 (Enhancement Act) (Public law 106–541) gives the Ser
and timing
any
FEIS
from
location
make up
of
lar fishing area along the shore.
The
to
Comment noted.
Comment noted.
Comment noted.
use
ithin the authorized
itle VIII of the W
for
to acquire lands
refuge using funds derived from the sale of
authorized
determination.
land acquisitions are based on unforeseen opportunities and
The
W
be the same regardless of the alternative selected. W
payment.
FEIS.
e understand the concerns of the counties
seasonal
authority
this in the
for
scheduled
the
or adjacent to, the
cabin sites within the executive order boundary
market conditions. W
about declining revenue-sharing payments. Ultimately
Congress is
12–1.
12–2.
12–3.
12–4.
12–5.
allow
12–6.
Also, T
vice
clarified
U.S.
payments between the amount available in the fund and the
amount
make a commitment to dispose of Federal land elsewhere.
Comment
Number
64 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #12: Petroleum County Commissioners, Petroleum County, Montana Response
12–7. 12–7. The Service appreciates Petroleum County’s contribu-tions
to the planning process.
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 65
Letter #13: Phillips County Commissioners, Malta, Montana
13–1.
13–2.
13–3.
13–4.
13–5.
The comment provides no information as to the page, the
, why it is not scientific, or what other studies should have
It is not clear the exact reasoning for the opposition to
alternative C and D. When the plan is carried out, livestock
permittees who can adjust their operations and work with the
The USGS consulted multiple sources for the socioeco-nomic
analysis. The wide variety of data, which were cited
extensively in the document, included sources from other Fed-
The
USGS social scientists met with several of the local county
commissioners and representatives to discuss their social and
economic issues related to the CCP at the refuge headquarters
McCone
Counties provided copies of fact sheets and suggestions for
the
not
-
the
-
-
most up-
-
from
and
refuge in achieving the habitat objectives could benefit.
landowners.
with
and
up
information
County
Phillips
followed
private
more
Phillips
and local agencies, and
from
USGS
gather
Representatives
about
The
o use consistent and the
meeting.
to
county-level data directly
attempt
the
an
information
and economic
2008.
at
in
State,
June 4,
contacts
contacts
demographic
13–1.
study
been reviewed.
13–2.
13–3.
eral,
on
local
local
available through State and national data sources. Krystal
Steinmetz from the Bear Paw Development Corporation pro
vided
communities of Malta, Saco, and Dodson, but the data were all
from existing national and State data sources. Anne Boothe
from the Phillips County Economic Growth Council was not
exactly sure what she had that was not generated through
census materials. The USGS was able to locate other socioeco
nomic profiles for the local counties completed by Headwater
Economics, Economic Profile System. Databases used for the
Economic Profile System county profiles are from national
sources: Bureau of the Census including County Business Pat
terns; Bureau of Labor Statistics; and the Regional Economic
Information System of the Bureau of Economic Analysis, U.S.
Department of Commerce. T
to-date data across the counties, the USGS pulled the most re
cent demographic
the national and State sources. These data sources were the
same as those used in the reports provided by the counties but
were more up-to-date. In addition, the socioeconomic analysis
Comment
Number
66 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Response
went through extensive peer review before to the release of
the DEIS. In July 2011, we provided the counties with emails
and data sources used by USGS in the economic analysis and
offered a willingness to expand further discussions of the af-fected
environment if there was data that was left out. We
gave the counties until August 15, 2011, to provide us with
e did not receive further communication or
-
-
Although individual meetings with the county commis
sioners were not feasible, USGS staff attended all the local
these
of increased visita
(DEIS
clarified
from
explained
have
information gained
meetings, combined with more background data and research,
provided a strong foundation for the socioeconomic analysis.
Furthermore, a respected economist on livestock grazing from
-
was
aylor, wrote the analysis
FEIS, we
. D. T
s estimates of current visitation figures come
additional data. W
for the livestock grazing.
13–5. The refuge’
from a variety of sources including traffic counters, physical
The estimates
yoming, Dr
counts, and hunter permits.
tion over 15 years are modest numbers (see response 28–49)
numbers
The
those
112–114). In the
meetings.
the University of W
the rationale behind
data on this topic.
13–4.
community
and
pages 105–107 and
the information about visitation versus visits and how we esti
mated visitation numbers (DEIS page 227).
Letter #13: Phillips County Commissioners, Malta, Montana
Comment Response
Number
VOLUME 2, Chapter 2—Comments from Agencies and Organizations 67
Letter #13: Phillips County Commissioners, Malta, Montana
13–6.
13–7.
13–8.
13–9.
13–10.
of the mineral withdrawal
for Charles M. Russell Refuge on the locatable minerals (UL
Bend Refuge has a permanent withdrawal) and would advocate
-
,
DEIS
further
.”
-
-
-
-
relatively small and
-
U.S. Con
e have clarified
contain
e have
the
, seasons,
in
correct that
later
expanded
districts
Only the
commenter is
of minerals.
lands
e suspect the commenter in
gress can designate a permanent withdrawal. W
the information in the FEIS about mineral development.
e inadvertently left out the acreage for private lands in
the DEIS (page 191) and was corrected in the FEIS. However
been
a
hunting
extension
private
discussion has
refuge includes
Those
are pursuing an
a permanent withdrawal
of
the
MFWP.
The
acreage
This
that
by
the
the refuge.
326–329).
We
W
identify
depiction of private lands ( DEIS pages 168–169), and acknowl
319,
13–6.
did
for
13–7.
we
(page 26, which references about 40,000 acres), provided a
edged the impacts that could occur for some permittees (DEIS
pages
in the FEIS. None of the actions in the CCP prevent access to
existing inholdings within the refuge.
13–8. It is unclear what the commenter means by saying “less
than 50% of the wildlife habitat is within the CMR boundary
All land can be considered “wildlife habitat” depending on its
, and refuge personnel during winter 2005–2006).
characteristics and management. W
tended to suggest
variable proportion of administrative hunting district boundar
as established
continuous wildlife habitat on and next to the refuge. W
land contained within the refuge boundary for each hunting dis
are mobile and respond to habitat conditions, weather
and a variety of other factors. Managing lands within the refuge
primarily for native wildlife should result in fewer impacts to
adjacent lands as native ungulates would increase the time
spend on
ies
updated information in the FEIS showing the percentage of
trict, for elk habitat (as described by MFWP), and estimates of
the number of elk found on the refuge (based on aerial observa
tions by MFWP
Wildlife distribution is variable over time as native ungulates
they
more animal unit months (AUMs) per unit area are grazed by
livestock on lands next to the refuge, which may be a factor
contributing to the relatively high proportion of elk found on
the refuge compared to the relatively small proportion of the
total elk habitat on the refuge.
Comment
Number
68 Final CCP and EIS, Charles M. Russell and UL Bend National Wildlife Refuges, Montana
number Letter #13: Phillips County Commissioners, Malta, Montana Response
13–11.
pre-
13–9.
jobs and increased visitation (DEIS page 326). There would
added refuge employees,
Comment noted.
Comment noted.
Economic increases would occur from additional refuge
as
by nonlocal visitors. As
13–10.
13–11.
also be increased spending by the
well as the increased spending
scriptive grazing is carried out across 50–75 percent of the
,
refuge, the level of grazing could be reduced from current lev-els,
but may also increase for short periods. Changes to refuge
grazing would not be significant for the six-county economy
but it could affect individual ranches with refuge grazing per-mits.
The only effect in alternative A is the direct production of
refuge AUMs (DEIS page 326).
Although the no-action alternative has enabled us to
toward improvement of forage resources,
13–12.