National Elk Refuge

P.O. Box 510

Jackson, WY 83001

nationalelkrefuge@fws.gov

www.fws.gov/nationalelkrefuge

307 / 733 9212

April 2016
The mission of the National Wildlife 

Refuge System is to administer a 

national network of lands and waters 

for the conservation, management, 

and, where appropriate, restoration of 

the fish, wildlife, and plant resources 

and their habitats within the United 

States for the benefit of present and 

future generations of Americans.

The mission of the U.S. Fish and 

Wildlife Service is working with others 

to conserve, protect, and enhance fish, 

wildlife, plants, and their habitats for 

the continuing benefit of the American 

people.

Cover photograph of the National Elk Refuge, Wyoming.

Ann Hough / FWS

The mission of the National Wildlife 

Refuge System is to administer a 

national network of lands and waters 

for the conservation, management, 

and, where appropriate, restoration of 

the fish, wildlife, and plant resources 

and their habitats within the United 

States for the benefit of present and 

future generations of Americans.

The mission of the U.S. Fish and 

Wildlife Service is working with others 

to conserve, protect, and enhance fish, 

wildlife, plants, and their habitats for 

the continuing benefit of the American 

people.
Prepared by

National Elk Refuge

675 E. Broadway

Jackson, Wyoming 83001

307 / 733 9212

U.S. Fish and Wildlife Service

Region 6, Mountain-Prairie Region

Branch of Refuge Planning

134 Union Boulevard, Suite 300

Lakewood, Colorado 80228

303 / 236 8145

CITATION

U.S. Fish and Wildlife Service. 2016. Comprehensive conservation plan—National Elk Refuge, Wyoming. Lakewood, Colorado: 

U.S. Department of the Interior, Fish and Wildlife Service, Mountain-Prairie Region. 333 p.

Noreen Walsh, Regional Director Date

U.S. Fish and Wildlife Service, Region 6

Lakewood, Colorado

Comprehensive Conservation Plan

National Elk Refuge

Wyoming

April 2016

Approved by

Concurred with by

Michael Blenden Date

Refuge Supervisor, Region 6

U.S. Fish and Wildlife Service

Lakewood, Colorado

Will Meeks Date

Assistant Regional Director

U.S. Fish and Wildlife Service, Region 6

National Wildlife Refuge System

Lakewood, Colorado

Submitted by

Steve Kallin Date

Refuge Manager

National Elk Refuge

Jackson, Wyoming

Comprehensive Conservation Plan

National Elk Refuge

Wyoming

SUMMARY. 

ABBREVIATIONS. .

CHAPTER 1—Introduction.

1.1 Purpose of and Need for the Plan.

The Decision Made.

1.2 The U.S. Fish and Wildlife Service and the Refuge System.

U.S. Fish and Wildlife Service.

National Wildlife Refuge System.

1.3 National and Regional Mandates.

1.4 Refuge Contributions to Regional and National Plans.

Conserving the Future.

Partners in Flight.

Pacific Flyway Management Plan for the Rocky Mountain Population of Trumpeter Swans .

North American Waterbird Conservation Plan.

North American Waterfowl Management Plan.

Recovery Plans for Federally Listed as Threatened or Endangered Species.

Wyoming State Wildlife Action Plan.

Wyoming Greater Sage-Grouse Conservation Plan.

Bison and Elk Management Plan.

Greater Yellowstone Coordinating Committee.

Responding to Accelerating Climate Change.

1.5 Landscape-Scale Conservation.

Strategic Habitat Conservation.

Landscape Conservation Cooperatives. 

1.6 The Planning Process. 

Coordination with the Public. 

State Coordination. 

Tribal Coordination. 

Teton County Coordination. 

Results of Scoping. 

The Draft Plan. 

The Final Plan. 

CHAPTER 2—The Refuge. 

2.1 Establishment, Acquisition, and Management History. 

Establishment. 

Acquisition History. 

Management History. 

2.2 Purposes. 

2.3 Vision. 

2.4 Goals. 

Habitat and Wildlife Management Goal. 

Contents
VI Comprehensive Conservation Plan—National Elk Refuge, Wyoming 

Cultural Resources Goal. 

Visitor Services Goal. 

Visitor and Employee Safety and Resource Protection Goal. 

Administration Goal. 

2.5 Special Values. 

Intact Ecosystem. 

High Scenic Quality. 

Undeveloped Habitat. 

Quality Water Resources. 

Variety and Abundance of Wildlife. 

Abundant Visitor Opportunities. 

Rich Cultural History. 

2.6 Planning Issues. 

Unknown Effects of Climate Change. 

Landscape-Scale Conservation Needs. 

Big Game Management Effects on Wildlife Habitat. 

Invasive Plants Replacing Native Habitat. 

Flat Creek Enhancement. 

Conserving Wide-Ranging Wildlife. 

Managing Habitat for Migratory Birds. 

Wildlife Disease. 

Insufficient Research, Inventory, and Monitoring. 

Human–Wildlife Conflicts. 

Hunting Management. 

Increasing Demand for Environmental Education and Interpretation. 

Operational Efficiency of the Jackson Hole and Greater Yellowstone Visitor Center. 

Management of Other Uses. 

Access. 

Public Outreach Opportunities. 

Miller House Restoration. 

Lack of Resources to Administer the Refuge. 

Stronger Programs Through Partnerships. 

Refuge Management Effects on the Jackson Economy. 

Issues Outside the Scope of the CCP. 

CHAPTER 3—Refuge Resources and Description. 

3.1 Physical Environment. 

Climate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36

Land Features. 

Soils. 

Water Resources. 

Air Quality. 

Visual Resources. 

3.2 Biological Resources. 

Plant Communities. 

Wildlife. 

Federally Listed Species and State Species of Greatest Conservation Need. 

3.3 Management Tools. 

Irrigation. 

Farming. 

Fencing. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .70

Wildland Fire Management. 

3.4 Human History and Cultural Resources. 

Indigenous People of Western Wyoming. 
Contents VII 

Historical Euro-Americans. 

Ethnographic Resources. 

Archaeological Resources in Jackson Hole. 

Cultural Resources on the Refuge. 

3.5 Special Management Areas. 

Wilderness Review. 

Important Bird Area. 

3.6 Visitor Services. 

Hunting. 

Fishing. 

Wildlife Observation and Photography. 

Environmental Education and Interpretation. 

Jackson Hole and Greater Yellowstone Visitor Center. 

Other Uses. 

Access. 

3.7 Socioeconomic Environment. 

Population, Ethnicity and Education. 

Regional Employment and Income. 

Economic Contributions of the Refuge. 

3.8 Operations. 

Funding and Staff. 

Facilities. 

Elk Refuge Road. 

Partnerships. 

CHAPTER 4—Management Direction. 

4.1 Management Focus. 

4.2 Overview of Goals and Objectives. 

4.3 Climate Change. 

Climate Change Objective 1. 

Climate Change Objective 2. 

Climate Change Objective 3. 

4.4 Landscape-Scale Conservation. 

Landscape-Scale Conservation Objective 1. 

Landscape-Scale Conservation Objective 2. 

Landscape-Scale Conservation Objective 3. 

Landscape-Scale Conservation Objective 4. 

Landscape-Scale Conservation Objective 5. 

Landscape-Scale Conservation Objective 6. 

4.5 Habitat and Wildlife Goal. 

Native Grasslands Objective. 

Sagebrush Shrublands Objective 1. 

Sagebrush Shrublands Objective 2. 

Wetlands Objective 1. 

Wetlands Objective 2. 

Wetlands Objective 3. 

Riparian Woodlands and Aspen Woodlands Objective 1. 

Riparian Woodlands and Aspen Woodlands Objective 2. 

Riparian Woodlands and Aspen Woodlands Objective 3. 

Flat Creek Enhancement Objective 1. 

Flat Creek Enhancement Objective 2. .

Flat Creek Enhancement Objective 3. .

Invasive Species Objective 1. .
VIII Comprehensive Conservation Plan—National Elk Refuge, Wyoming 

Invasive Species Objective 2. .

Migratory Birds Objective. .

Aquatic Species Objective. .

Disease Management Objective 1. .

Disease Management Objective 2. .

Disease Management Objective 3. .

Federally Listed Species and State Species of Greatest Conservation Need Objective 1. .

Federally Listed Species and State Species of Greatest Conservation Need Objective 2. .

Research and Monitoring Objective. .

4.6 Cultural Resources Goal. .

Cultural Resources Objective. .

4.7 Visitor Services Goal. .

Hunting Objective 1. .

Hunting Objective 2. .

Hunting Objective 3. .

Hunting Objective 4. .

Hunting Objective 5. .

Hunting Objective 6. .

Fishing Objective 1. .

Fishing Objective 2. .

Fishing Objective 3. .

Wildlife Observation and Photography Objective 1. .

Wildlife Observation and Photography Objective 2. .

Environmental Education and Interpretation Objective 1. .

Environmental Education and Interpretation Objective 2. .

Visitor Center Objective 1. .

Visitor Center Objective 2. .

North Park Objective. .

Other Uses Objective. .

Special Use Permit Objective 1. .

Special Use Permit Objective 2. .

Public Outreach Objective. .

4.8 Visitor and Employee Safety and Resource Protection Goal. .

Visitor and Employee Safety Objective 1. .

Visitor and Employee Safety Objective 2. .

Visitor and Employee Safety Objective 3. .

Visitor and Employee Safety Objective 4. .

Resource Protection Objective 1. .

Resource Protection Objective 2. .

4.9 Administration Goal. .

Funding and Staff Objective 1. .

Funding and Staff Objective 2. .

Facilities Objective 1. .

Facilities Objective 2. .

Elk Refuge Road Objective 1. .

Elk Refuge Road Objective 2. .

Elk Refuge Road Objective 3. .

Partnerships Objective. .

4.10 Staff. .

4.11 Stepdown Management Plans. .

4.12 Monitoring and Evaluation. .

4.13 Plan Amendment and Revision. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .123
Contents IX 

APPENDIXES

Appendix A

Key Legislation and Policy. . 

Appendix B

List of Preparers and Contributors. .

Appendix C

Public Involvement. .

Appendix D

Species Lists. .

Appendix E

Compatibility Determinations. .

Appendix F

Environmental Compliance. .

Appendix G

Intra-Service Section 7 Consultation. .

FIGURES

Figure 1. Vicinity map of the National Elk Refuge, Wyoming.

Figure 2. The strategic habitat conservation process. 

Figure 3. Map of the Great Northern Landscape Conservation Cooperative in North America. .

Figure 4. Process steps for comprehensive planning and associated environmental analysis. 

Figure 5. Base map of the National Elk Refuge, Wyoming. .

Figure 6. Map of land tracts composing the National Elk Refuge, Wyoming. .

Figure 7. Map of areas and feedgrounds on the National Elk Refuge, Wyoming. .

Figure 8. Map of waterfowl flyways in North America. .

Figure 9. Map of management units and surface hydrology of the National Elk Refuge, Wyoming. .

Figure 10. Map of plant communities on the National Elk Refuge, Wyoming. .

Figure 11. Map of irrigated areas on the National Elk Refuge, Wyoming. .

Figure 12. Map of visitor services on the southern end of the National Elk Refuge, Wyoming. . 

Figure 13. Map of the elk hunting program on the National Elk Refuge, Wyoming. . 

Figure 14. Map of the bison hunting program on the National Elk Refuge, Wyoming. . 

Figure 15. The adaptive resource management process. . 

TABLES

Table 1. Summary of the comprehensive conservation planning process for the National Elk Refuge, Wyoming. .

Table 2. Land acquisition history for the National Elk Refuge, Wyoming. .

Table 3. Average values of selected water quality factors in or near the National Elk Refuge, Wyoming, 1996–2002. .

GLOSSARY. .

BIBLIOGRAPHY. .
X Comprehensive Conservation Plan—National Elk Refuge, Wyoming 

Table 4. Water rights owned by the National Elk Refuge, Wyoming. .

Table 5. Plant community types on the National Elk Refuge, Wyoming. .

Table 6. Estimates of forage production on the National Elk Refuge, Wyoming. .

Table 7. Noxious weed species on the National Elk Refuge, Wyoming. . 

Table 8. Winter elk population objectives and actual population estimates for the Jackson elk herd and wintering areas from 

2011–2013. .

Table 9. Small mammals that occur in various habitats on the National Elk Refuge, Wyoming. .

Table 10. State and county population estimates. .

Table 11. State and county income, unemployment, and poverty statistics. .

Table 12. Employment by sector, 2011, in Teton County, Idaho, and Teton County, Wyoming. .

Table 13. Current and proposed staff at the National Elk Refuge, Wyoming. . 

Table 14. Stepdown management plans for the National Elk Refuge, Wyoming. . 
after a 9-year public process. This comprehensive 

conservation plan will complement, not replace, the 

Bison and Elk Management Plan.

A stepdown management plan is currently being 

drafted for the Bison and Elk Management Plan. 

This plan will outline, consistent with the Bison and 

Elk Management Plan, guidance to adaptively manage bison and elk herds to meet the goals and objectives outlined in the Bison and Elk Management 

Plan. Public comments will be solicited before the 

stepdown management plan is finalized.

The Refuge

The National Elk Refuge was established in 

response to severe elk starvation in Jackson Hole. 

The development of the town of Jackson and settlement of the valley by cattle ranchers substantially 

reduced historical elk winter range and led to masNestled in the valley known as Jackson Hole in 

northwestern Wyoming, the National Elk Refuge is 

one of the oldest national wildlife refuges—established in 1912 as a “winter game (elk) reserve.” Over 

the years, its purpose has been broadened to include 

“refuges and breeding grounds for birds, other big 

game animals, the conservation of fish and wildlife, 

and the protection of natural resources and conservation of threatened or endangered species.” As the 

U.S. Fish and Wildlife Service, we manage this 

24,777-acre national wildlife refuge as part of the 

National Wildlife Refuge System. 

We have developed this comprehensive conservation plan for the National Elk Refuge to provide longterm guidance for management decisions, help 

achieve the goals needed to accomplish the purposes 

of the refuge including the enhancement of Flat 

Creek, and describe our best estimate of future 

needs. We will use this plan, along with the Bison and 

Elk Management Plan (2007), as guidance for managing the refuge over the next 15 years. The Bison and 

Elk Management Plan was finalized in April 2007 

Elk

Tony Hough / FWS

Summary
XII Comprehensive Conservation Plan—National Elk Refuge, Wyoming 

swans and other waterfowl. The Flat Creek wetlands 

provide habitat for the highest density of nesting 

trumpeter swans in the Greater Yellowstone area.

The Jackson core population area for greater 

sage-grouse as defined by the State of Wyoming 

Greater Sage-Grouse Core Area Protection Executive Order 2011-5 overlaps the refuge. 

The grizzly bear is federally listed as threatened 

under the Endangered Species Act, and the greater 

sage-grouse is a candidate for listing; we have documented both species on the refuge. Refuge grassland 

and sagebrush shrubland communities support 

breeding populations of Wyoming species of greatest 

conservation need, including long-billed curlew and 

Brewer’s sparrow.

The refuge is the terminus of seasonal migrations 

for four celebrated large mammal species. Part of the 

Jackson bighorn sheep herd spends the winter on the 

refuge on Miller Butte and around Curtis Canyon 

and migrates to summer range in the Gros Ventre 

Mountains. Portions of the Jackson elk herd migrate 

from their summer range in Yellowstone National 

Park to winter on the refuge. The refuge hosts the 

Jackson bison herd during the winter months, one of 

only three remaining free-roaming bison herds in 

North America. Pronghorn summer on the refuge 

and winter south of Pinedale, Wyoming, making one 

of the longest mammal migrations in the Western 

Hemisphere.

Visitation

The National Elk Refuge is considered one of the 

“crown jewels” of the Refuge System because of its 

spectacular scenery, closeness to two iconic national 

parks (Grand Teton and Yellowstone), and large charismatic populations of seasonal wildlife—especially 

elk and bison—that people want to stop and watch. 

The most prominent view of the refuge, which is seen 

by several million visitors annually as they drive to 

and from the town of Jackson on U.S. Highway 26/89, 

is the expansive Flat Creek wetland. Flat Creek’s 

proximity to town, its easy access, and the large 

average fish size makes it a popular Wyoming creek 

and nationally recognized fishery.

The Miller House, built in 1898, was one of the 

early homesteads in the valley. Listed on the 

National Register of Historic Places in 1969, much of 

the original house has been restored to period standards and aesthetics, and it is open for tour by the 

public during the summer.

Our visitor services staff offers year-round programs to incorporate wildlife viewing, photography, 

interpretation, and environmental education into the 

Red-winged Blackbird visitor experience.

BJ Baker / FWS

sive elk starvation during the winters of 1909 and 

1910. At the request of the State of Wyoming, the 

U.S. Congress first appropriated $20,000 on March 4, 

1911, for “feeding, protecting and removing elk in 

Jackson Hole and vicinity.”

Habitat and Wildlife

The refuge lies in the Greater Yellowstone Ecosystem, which is one of the last remaining nearly 

intact ecosystems in the northern temperate zone. 

The Gros Ventre River is the largest watercourse on 

the refuge and is among the river segments designated as wild and scenic by the Craig Thomas Snake 

Headwaters Legacy Act of 2008. 

Flat Creek and its associated marshlands are 

integral for the natural recruitment of native trout 

for the Snake River watershed. Flat Creek provides 

a native fishery of Snake River cutthroat trout and 

provides a walk-in and trophy Snake River cutthroat 

trout fishery. No stocking occurs in Flat Creek, making natural recruitment the only source of native 

trout. Both Flat and Nowlin Creeks are important 

spawning and recruitment streams for native trout, 

and these creeks along with the Gros Ventre River 

are managed as wild Snake River cutthroat trout 

fisheries and are important habitat for other native 

fish species. 

Flat Creek Marsh is also an important migratory 

stopover for waterfowl and shorebird species in the 

Pacific flyway and breeding habitat for trumpeter 
Summary XIII 

Goals

We developed this comprehensive conservation 

plan to address management of the refuge. The draft 

plan and environmental assessment, released in 

August 2014, gave the public a chance to review and 

comment on our evaluation of management alternatives to meet the following refuge goals. These goals 

will direct our work in achieving the vision and purposes of the refuge and outline approaches for managing the refuge’s resources.

Habitat and Wildlife Management 

Goals

Adaptively manage bison, elk, and other wildlife 

populations and habitats as outlined in the Bison and 

Elk Management Plan and the CCP. Contribute to 

the conservation of healthy native wildlife populations and their habitats. Restore and sustain a native 

fishery that provides quality fishing opportunities.

Cultural Resources Goal

Preserve and interpret cultural resources in a 

way that allows visitors to connect to the area’s rich 

history and conservation heritage. 

Visitor Services Goal

Enable a diverse audience to understand and 

appreciate the refuge’s wildlife conservation role in 

Jackson Hole, while safely enjoying year-round 

opportunities for wildlife-dependent recreation. 

Visitor and Employee Safety and 

Resource Protection Goal

Provide for the safety, security, and protection of 

visitors, employees, natural and cultural resources, 

and facilities throughout the refuge.

Nestled below the majestic Teton Range, 

adjacent to the historic gateway town of 

Jackson, the National Elk Refuge 

provides crucial big game wintering 

habitat in the Greater Yellowstone 

Ecosystem. Across the refuge’s grassland, 

wetland, woodland, and sagebrush 

shrubland communities, visitors view 

wintering elk and other wildlife 

populations that are balanced with their 

habitats. The public enjoys quality 

hunting and fishing as well as year-round 

interpretative opportunities. 

Effective outreach and strong public and 

private partnerships ensure 

understanding and protection of refuge 

resources for future generations.

Vision Statement

Uinta Ground Squirrel
XIV Comprehensive Conservation Plan—National Elk Refuge, Wyoming 

Management Direction

The comprehensive conservation plan directs the 

management of the National Elk Refuge to meet the 

purposes of the refuge and to address issues.

The plan is intended to be a broad umbrella of 

general concepts and specific objectives for the refuge over the next 15 years. As the plan is implemented, we will develop stepdown plans with details 

for carrying out actions needed to achieve 

objectives.

Administration Goal

Provide facilities and effectively use and develop 

staff resources, funding, partnerships, and volunteer 

opportunities to maintain the long-term integrity of 

habitats and wildlife resources of the refuge.

BJ Baker / FWS

Historic Miller House 
Abbreviations

Bison and Elk 

Management Plan

Bison and Elk Management Plan: 

National Elk Refuge, Grand Teton 

National Park, and John D. Rockefeller, 

Jr. Memorial Parkway 

B.P. Before present

CCP Comprehensive conservation plan

CFR United States Code of Federal 

Regulations

EA Environmental assessment

EIS Environmental impact statement

FTE Full-time equivalent (position) 

FWS United States Fish and Wildlife Service

GIS Geographic Information System

GPS Global Positioning System

GL General Schedule classification and pay 

system for law enforcement officers

GS General Schedule classification and pay 

system

Improvement Act National Wildlife Refuge System 

Improvement Act of 1997

LCD Landscape Conservation Design

LCC Landscape Conservation Cooperative

LIDAR Light detection and ranging

NPS National Park Service

Refuge System National Wildlife Refuge System

Region 6 Mountain-Prairie Region of the U.S. Fish 

and Wildlife Service

RRS Refuge Revenue Sharing Act

Service United States Fish and Wildlife Service

SGCN Wyoming’s Species of Greatest 

Conservation Need

Trumpeter Swan 

Management Plan

Pacific Flyway Management Plan for the 

Rocky Mountain Population of Trumpeter 

Swans (Subcommittee on Rocky Mountain 

Trumpeter Swans 2012)
XVI Comprehensive Conservation Plan—National Elk Refuge, Wyoming 

U.S. United States

U.S.C. United States Code

USDA Forest Service United States Department of Agriculture, 

Forest Service

USGS United States Geological Survey

visitor center Jackson Hole and Greater Yellowstone 

Visitor Center 

WG Wage Grade classification and pay system

WGFD Wyoming Game and Fish Department

A glossary of these and other terms follows chapter 4.
This CCP specifies the necessary actions to 

achieve the purposes and vision of the refuge. Wildlife 

and habitat are the primary priorities in refuge management, and public use (including wildlife-dependent 

recreation) is allowed and encouraged as long as it is 

compatible with the purposes of the refuge. 

The CCP will serve as a working guide for management programs and activities throughout the 

National Elk Refuge over the next 15 years. 

Although this document contains management direction for the refuge, detail will be provided in stepdown management plans as part of implementing the 

final CCP.

This chapter introduces the process for development of the CCP, including descriptions of our 

involvement and that of the State of Wyoming, the 

public, and others. Chapter 1 also describes the conservation issues and the national, regional, State, and 

local plans that affect the refuge. 

As the United States (U.S.) Fish and Wildlife Service, we manage the National Elk Refuge in northwestern Wyoming (see figure 1). This 24,777-acre 

national wildlife refuge is nestled in the valley known 

as Jackson Hole and is part of the National Wildlife 

Refuge System (Refuge System). The refuge lies centrally in the Greater Yellowstone Ecosystem, a 

mosaic of Federal, State, and private lands totaling 

18 million acres that encompass the largest concentration of wild ungulates (hoofed mammals) and large 

carnivores in the lower 48 States.

We developed this comprehensive conservation 

plan (CCP) to provide a foundation for the management and use of the National Elk Refuge. To address 

the long-term management of the refuge, we developed a draft CCP and environmental assessment 

(EA), which was released in August 2014, for the 

public to review our evaluation of management 

alternatives.

Bison

FWS

Chapter 1—Introduction
2 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Figure 1. Vicinity map of the National Elk Refuge, Wyoming.
Chapter 1—Introduction 3 

The mission of the U.S. Fish and Wildlife 

Service, working with others, is to conserve, protect, and enhance fish and wildlife and their habitats for the continuing 

benefit of the American people.

The Decision Made

The Regional Director for the Mountain-Prairie 

Region of the Service has chosen a preferred alternative for management of all refuge programs; this 

alternative has guided completion of the final CCP. 

The management direction in this final CCP will not 

conflict with management approved in the Bison and 

Elk Management Plan.

1.2 The U.S. Fish and Wildlife 

Service and the Refuge 

System

The U.S. Fish and Wildlife Service is the principal 

Federal agency responsible for fish, wildlife, and 

plant conservation, and the National Wildlife Refuge 

System is one of our major programs.

U.S. Fish and Wildlife Service

In the late 19th and early 20th centuries, America’s fish and wildlife resources were declining at an 

alarming rate, largely because of unrestricted market hunting. Concerned citizens, scientists, and hunting and fishing groups came together and generated 

the political will for the first significant conservation 

measures taken by the Federal Government. These 

actions included the establishment of the Bureau of 

Fisheries in the 1870s and, in 1904, passage of the 

first Federal wildlife law—the Lacey Act—which 

prohibited interstate transportation of wildlife taken 

in violation of State laws. Beginning in 1903, President Theodore Roosevelt created more than 50 

national wildlife refuges across the Nation.

The remaining chapters contain the information 

we used and the results of our analysis that are the 

foundation of the CCP:

■ Chapter 2 describes the refuge and planning 

issues.

■ Chapter 3 describes the physical, biological, 

and social environment of the refuge.

■ Chapter 4 describes objectives and strategies for all aspects of managing the refuge.

1.1 Purpose of and Need for the 

Plan

The purpose of the CCP is to describe the role that 

the National Elk Refuge will play in support of the mission of the Refuge System and to provide long-term 

guidance for managing programs and activities. The 

CCP is needed to help us achieve the following:

■ communication with the public and other 

partners in efforts to carry out the mission 

of the Refuge System

■ a clear statement of direction for managing 

the refuge

■ an understanding by neighbors, visitors, 

and government officials of our management 

actions on and around the refuge

■ management actions on the refuge that are 

consistent with the mandates of the 

National Wildlife Refuge System Improvement Act of 1997 (Improvement Act)

■ management of the refuge that is consistent 

with Federal, State, and county plans

■ a basis for development of budget requests 

for the refuge’s operation, maintenance, and 

capital improvement needs

In addition, the final CCP incorporates an analysis of the Flat Creek enhancement project, a large 

effort to improve the creek’s habitat and the fishery 

it supports, as proposed under alternative D. 

Sustaining the Nation’s fish and wildlife resources 

is a task that can be accomplished only through the 

combined efforts of governments, businesses, and 

private citizens.
4 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

The Improvement Act states that each national 

wildlife refuge (meaning every unit of the Refuge 

System including wetland management districts and 

conservation areas) must be managed to do the 

following:

■ fulfill the mission of the Refuge System

■ fulfill the individual purposes of each refuge

■ consider the needs of fish and wildlife first

■ support the biological integrity, diversity, 

and environmental health of the Refuge 

System

■ recognize that wildlife-dependent recreation activities including hunting, fishing, 

wildlife observation, photography, environmental education, and interpretation are 

legitimate and priority public uses

■ retain the authority of refuge managers to 

determine compatible public uses

■ fulfill the requirement of developing a CCP 

for each unit of the Refuge System and fully 

involve the public in preparation of these 

plans

In addition to the mission for the Refuge System, 

the wildlife and habitat vision for each unit of the 

Refuge System supports the following principles:

■ Wildlife comes first.

■ Ecosystems, biodiversity, and wilderness 

are vital concepts in refuge management.

■ Habitats must be healthy.

■ Growth of refuges must be strategic.

The Refuge System serves as a model for habitat 

management with active participation from other 

interested parties. Following passage of the 

Improvement Act, the Service immediately began to 

carry out the direction of the new legislation including preparation of CCPs for all national wildlife refuges and wetland management districts. Consistent 

with the Improvement Act, the Service prepares 

CCPs in conjunction with public involvement.

People and the Refuge System

The Nation’s fish and wildlife heritage contributes 

to the quality of American lives and is an integral 

The mission of the National Wildlife Refuge 

System is to administer a national network 

of lands and waters for the conservation, 

management, and where appropriate, 

restoration of the fish, wildlife and plant 

resources and their habitats within the 

United States for the benefit of present and 

future generations of Americans.

Over the next three decades, the United States 

ratified the Migratory Bird Treaty with Great Britain, and Congress passed laws to protect migratory 

birds, establish new refuges, and create a funding 

source for refuge land acquisition. In 1940, the U. S. 

Fish and Wildlife Service was created within the 

U.S. Department of the Interior, and existing Federal wildlife functions including law enforcement, fish 

management, animal damage control, and national 

wildlife refuge management were combined into a 

single organization for the first time.

Today, we enforce Federal wildlife laws, manage 

migratory bird populations, restore nationally significant fisheries, conserve and restore vital wildlife 

habitat, protect and recover endangered species, and 

help other governments with conservation efforts. In 

addition, we administer a Federal aid program that 

distributes hundreds of millions of dollars to States 

for fish and wildlife restoration, boating access, 

hunter education, and related programs across the 

United States.

National Wildlife Refuge System

In 1903, President Theodore Roosevelt designated the 5.5-acre Pelican Island in Florida as the 

Nation’s first national wildlife refuge for the protection of native nesting birds. This was the first time 

the Federal Government had set aside land for wildlife. This small but significant designation was the 

beginning of the National Wildlife Refuge System.

One hundred years later, the Refuge System has 

become the largest collection of lands in the world 

specifically managed for wildlife, encompassing more 

than 150 million acres within 560 refuges and more 

than 3,000 small areas for waterfowl breeding and 

nesting. Today, there is at least one refuge in every 

State and in Puerto Rico and the U.S. Virgin Islands.

Mission

The Improvement Act established a clear mission 

for the Refuge System:
Chapter 1—Introduction 5 

Improvement Act requires the Service to monitor 

the status and trends of fish, wildlife, and plants in 

each national wildlife refuge and wetland management district.

A detailed description of these and other laws and 

Executive orders that may affect the CCP or the Service’s implementation of the CCP is in “Appendix 

A—Key Legislation and Policy.” Service policies for 

planning and day-to-day management of refuges and 

districts are in the “Refuge System Manual” and the 

“Fish and Wildlife Service Manual.”

1.4 Refuge Contributions to 

Regional and National Plans

The National Elk Refuge contributes to the conservation efforts outlined in the various State and 

national plans described here.

Conserving the Future

“Conserving the Future: Wildlife Refuges and the 

Next Generation” lays out 24 recommendations that 

9 implementation teams are charged with fulfilling. 

The implementation of these recommendations is currently underway and can be followed online (FWS 

2011).

Conserving the Future will deliver on three outcomes: articulate the important work and future of 

the Refuge System in a vision document, raise the 

awareness of conservation on refuges, and foster new 

leaders for us and the Refuge System as well as for 

the conservation community.

Partners in Flight

The Partners in Flight program began in 1990 

with the recognition of declining population levels of 

many migratory bird species. The challenge is to 

manage human population growth while maintaining 

functional natural ecosystems in the face of human 

population growth. To meet this challenge, Partners 

in Flight worked to identify priorities for landbird 

species and habitat types. Partners in Flight activity 

has resulted in 52 bird conservation plans covering 

the continental United States.

In 2001, participants in Wyoming Partners In 

Flight, the State working group of Partners In 

Flight, developed the Wyoming Bird Conservation 

part of the country’s greatness. Wildlife and wild 

places have always given people special opportunities 

to have fun, relax, and appreciate the natural world.

Whether through birdwatching, fishing, hunting, 

photography, or other wildlife pursuits, wildlife recreation contributes millions of dollars to local economies. In particular, money generated from a tax on 

the sale of sporting arms and ammunition and the 

sale of fishing equipment that is authorized by the 

Pittman-Robertson and Dingell-Johnson Acts, 

respectively, has generated tens of millions of dollars. 

Distributed by us, this money has been used by 

States to manage wildlife and fish populations, 

expand habitat, and provide education for hunters 

across the Nation. Approximately 35 million people 

visited the Refuge System in 2006, mostly to observe 

wildlife in their natural habitats (Caudill and Henderson 2005). Visitors are most often accommodated 

through nature trails, auto tours, interpretive programs, and hunting and fishing opportunities. Substantial economic benefits are being generated for the 

local communities that surround refuges and wetland 

management districts. Economists report that Refuge System visitors contribute more than $1.7 billion 

annually to local economies.

1.3 National and Regional 

Mandates

Refuge System units (national wildlife refuges, 

wetland management districts, and conservation 

areas) are managed to achieve the mission and goals of 

the Refuge System along with the designated purpose 

of the refuges as described in establishing legislation, 

Executive orders, or other establishing documents. 

The key concepts and guidance for the Refuge System 

are in the National Wildlife Refuge System Administration Act of 1966, Title 50 of the U.S. Code of Federal Regulations (CFR), the “Fish and Wildlife 

Service Manual,” and the Improvement Act.

The Improvement Act amends the Refuge System 

Administration Act by providing (1) a unifying mission for the Refuge System, (2) a new process for 

determining compatible public uses on refuges and 

districts, and (3) a requirement that each refuge and 

district be managed under a CCP. The Improvement 

Act states that wildlife conservation is the priority 

on Refuge System lands and that the Secretary of 

the Interior will make sure that the biological integrity, diversity, and environmental health of refuge 

lands are maintained. Each refuge must be managed 

to fulfill the Refuge System’s mission and the specific 

purposes for which the unit was established. The 
6 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

quality wetland habitats for breeding and wintering 

swans; and (6) monitor the population.

Trumpeter swans are year-round residents on 

refuge wetlands. During the planning process we 

considered the Pacific Flyway Management Plan for 

the Rocky Mountain Population of trumpeter swans 

and developed an objective in the CCP to institute a 

monitoring program to evaluate the effects of habitat 

management activities on trumpeter swans.

North American Waterbird 

Conservation Plan

The “North American Waterbird Conservation 

Plan” (Kushlan et al. 2002) provides a contiguous 

framework for conserving and managing colonialnesting waterbirds including 209 species of seabirds, 

coastal waterbirds (gulls, terns, and pelicans), wading birds (herons and ibises), and marshbirds (certain 

grebes and bitterns). The geographic scope of the 

plan covers 28 countries from Canada to Panama as 

well as islands and near-shore areas of the Atlantic 

and Pacific Oceans, the Gulf of Mexico, and the Caribbean Sea. As with Partners in Flight and other 

migratory bird plans, the North American Waterbird 

Conservation Plan has a goal to establish conservation action and exchange information and expertise 

with other bird conservation initiatives. The plan also 

calls for establishment of “practical units for planning” for terrestrial habitats; the National Elk Refuge is located within the Intermountain West.

North American Waterfowl 

Management Plan

Written in 1986, the North American Waterfowl 

Management Plan (FWS and Canadian Wildlife Service 1986) envisioned a 15-year effort to achieve landscape conditions that could sustain waterfowl 

populations. Specific plan objectives are to increase 

and restore duck populations to the average levels of 

the 1970s: 62 million breeding ducks and a fall flight 

of 100 million birds (FWS and Canadian Wildlife Service 1986). Recognizing the importance of waterfowl 

and wetlands to North Americans and the need for 

international cooperation to help in the recovery of a 

shared resource, the United States and Canadian 

Governments developed a strategy to restore waterfowl populations through habitat protection, restoration, and enhancement. The plan is innovative 

Plan as part of the international Partners In Flight 

effort. Bird species found in Jackson Hole that are 

designated as level 1 (conservation action) and confirmed on the National Elk Refuge follow: Brewer’s 

sparrow, greater sage-grouse, trumpeter swan, longbilled curlew, peregrine falcon, bald eagle, and 

Franklin’s gull.

Pacific Flyway Management Plan 

for the Rocky Mountain Population 

of Trumpeter Swans 

The “Pacific Flyway Management Plan for the 

Rocky Mountain Population of Trumpeter Swans” 

provides broad direction to the States, the Service, 

and other interests engaged in cooperative management of this population. The plan has been periodically updated to address evolving management 

challenges and to incorporate new information. The 

Pacific Flyway Council approved the most recent 

revision in 2012. 

Trumpeter swans are native only to North America. Although no historical estimates of their abundance are available, by 1900 they had been 

eliminated from most of their historical range in the 

United States and Canada. Through habitat conservation, protection from illegal shooting, supplemental 

winter feeding, and re-introduction and translocation 

efforts, trumpeter swans have increased from a few 

hundred birds to nearly 35,000. To facilitate monitoring and management, the Service and the Canadian 

Wildlife Service designated three populations: the 

Pacific Coast, Rocky Mountain, and Interior. The 

Rocky Mountain Population increased from fewer 

than 200 in the early 1930s to 4,701 in February 2007.

The goal of the management plan is to restore the 

Rocky Mountain Population as a secure and primarily migratory population, sustained by naturally 

occurring and agricultural food resources in diverse 

breeding and wintering sites. Management objectives are: (1) continue to encourage swans to use wintering areas outside of the core Tri-state Area while 

reducing the number of wintering swans in the core 

Tri-state Area to a maximum of 1,500; (2) rebuild 

U.S. nesting flocks by year 2013 to at least 165 nesting pairs (birds that display evidence of nesting) and 

718 adults and subadults (white birds) that use natural, diverse habitats; (3) expand the breeding range 

in order to enhance the connectivity of breeding 

flocks; (4) increase the abundance of desirable submerged macrophytes in the Henry’s Fork of the 

Snake River in and near Harriman State Park; (5) 

promote the restoration and development of high 
Chapter 1—Introduction 7 

the Endangered Species Act. The Wyoming State 

Wildlife Action Plan is part of a national framework 

of plans that are required by each State to receive 

State Wildlife Grant money, which is a program 

enacted by Congress in 2001 and that we 

administer.

The 2010 State wildlife action plan identifies 180 

“species of greatest conservation need” (SGCN) in 

Wyoming: 56 birds, 46 mammals, 30 fish, 8 amphibians, 21 reptiles, 5 crustaceans, and 14 mollusks. Many 

of these species are nongame species that have 

received little conservation attention in the past and 

for which species data may be unavailable. The action 

plan describes the modeled distribution and abundance of these species and uses a three-tier system to 

rank them according to conservation priority.

In addition to SGCN, the Wyoming State Wildlife 

Action Plan identifies five leading conservation challenges in the State: (1) rural subdivision and development; (2) energy development; (3) invasive species; (4) 

climate change; and (5) the disruption of natural disturbance regimes. Additionally, the action plan identifies and makes conservation recommendations for 

11 terrestrial habitat types and 6 aquatic basins in 

Canada Goose Gosling

Ann Hough / FWS

because of its international scope and its implementation at the regional level. 

The plan’s success depends on the strength of 

partnerships called joint ventures, which involve 

Federal, State, provincial, tribal, and local governments; businesses; conservation organizations; and 

individual citizens. Joint ventures are regional, selfdirected partnerships that carry out science-based 

conservation through a wide array of community 

participation. Joint ventures develop implementation 

plans that focus on areas of concern identified in the 

plan. 

The National Elk Refuge lies within the Intermountain West Joint Venture. Throughout the planning process, we considered the North American 

Waterfowl Management Plan and the supporting 

efforts of the Intermountain West Joint Venture, 

which the CCP supports and promotes.

Recovery Plans for Federally 

Listed as Threatened or 

Endangered Species

One species that is federally listed as threatened, 

grizzly bear, and one candidate species, greater sagegrouse, have been documented at the National Elk 

Refuge. To make sure that the conservation of listed 

and candidate species is adequately considered in 

this document, we conducted a biological evaluation 

of their actions per section 7 of the Endangered Species Act.

If, during the life of this CCP, listed species are 

discovered on the refuge or new species are listed, 

we will make sure that the refuge takes part in any 

approved recovery plans. We will also conduct an 

Intra-Service Section 7 Consultation on refuge management activities that might affect the listed or 

candidate species. 

Wyoming State Wildlife Action 

Plan

The Wyoming Game and Fish Commission 

adopted the State’s Comprehensive Wildlife Conservation Strategy in 2005. The Wyoming Game and 

Fish Department (WGFD) revised the strategy in 

2010 (WGFD 2010a), at which time it became known 

as the Wyoming State Wildlife Action Plan. The 

action plan is a broad strategy designed to coordinate 

efforts to maintain the health and diversity of wildlife in Wyoming and to prevent future listings under 
8 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Bison and Elk Management Plan

Approved in 2007, the “Bison and Elk Management Plan: National Elk Refuge, Grand Teton 

National Park, and John D. Rockefeller, Jr. Memorial 

Parkway” (FWS and NPS 2007a) is referred to 

throughout this document as the Bison and Elk Management Plan. The purpose of the plan is to provide 

managers with goals, objectives, and strategies for 

managing elk and bison on the National Elk Refuge 

and in Grand Teton National Park. Goals and strategies were developed for the following: 

■ habitat conservation

■ sustainable populations

■ numbers of elk and bison

■ disease management

In general, the plan moves elk and bison management toward reduced reliance on supplemental feeding and, at some future time, total reliance on natural 

forage. Management actions taken to date have 

focused on disease monitoring, reducing elk and bison 

herd sizes through public hunting, and increasing 

natural, standing winter forage through expanded 

irrigation. Management goals and actions approved 

in the Bison and Elk Management Plan apply to the 

National Elk Refuge, and we refer to them throughout the final CCP. Because the CCP will supplement 

the Bison and Elk Management Plan, we do not 

repeat the plan’s objectives in the CCP.

Greater Yellowstone Coordinating 

Committee

The refuge has been a member of the Greater Yellowstone Coordinating Committee since 2002. Members include national wildlife refuge managers, 

national park superintendents, and national forest 

supervisors for units within the ecosystem. A memorandum of understanding provides a vehicle for cooperation and coordination in the management of 

Federal lands in the Greater Yellowstone Ecosystem. 

The committee’s land managers periodically identify 

resource management issues where coordination 

across the Greater Yellowstone Ecosystem is 

desirable.

Wyoming in terms of the SGCN that may be found 

there. Important habitat types in Jackson Hole identified in the action plan include wetlands, riparian 

areas, aspen and deciduous forests, foothill shrublands, montane and subalpine forests, mountain 

grasslands, and sagebrush shrublands.

Important terrestrial SGCN found in Jackson 

Hole are peregrine falcon, long-billed curlew, Lewis’s 

woodpecker, black tern, white-faced ibis, merlin, Caspian tern, harlequin duck, bald eagle, trumpeter 

swan, big brown bat, fringed myotis, little brown 

myotis, long-eared myotis, long-legged myotis, boreal 

toad, moose, wolverine, Canada lynx, dwarf shrew, 

and vagrant shrew. Important aquatic SGCN found 

in Jackson Hole are bluehead sucker, mountain 

sucker, mountain whitefish, and Snake River cutthroat trout.

Wyoming Greater Sage-Grouse 

Conservation Plan

On March 5, 2010, we concluded that the greater 

sage-grouse warrants protection under the Endangered Species Act, but listing is precluded by the 

need to take action on other species facing more 

immediate and severe extinction threats. In 2008, we 

adopted the “Upper Snake River Sage-Grouse Conservation Plan” (WGFD 2014) and provide the framework for local working groups to guide management 

efforts directed at halting long-term population 

declines. Our refuge staff takes part in local working 

group meetings, and we consider the recommended 

management practices in the plan when developing 

management practices and plans on the refuge.

The National Elk Refuge lies within the Jackson 

core population area of the Jackson greater sagegrouse as designated by the State of Wyoming 

Greater Sage-Grouse Core Area Protection Executive Order (2011–5), signed by Governor Matt Mead 

in June 2011. Executive Order 2011–5 was issued by 

Governor Mead to update the process and policy 

embodied in former Governor Dave Freudenthal’s 

Executive Order 2008–2 and Executive Order 2010–4. 

The State established core population areas, in addition to stipulations for development on lands within 

those core areas, to build a statewide strategy to 

conserve the greater sage-grouse across Wyoming 

and to prevent the species from being listed for protection under the Endangered Species Act.
Chapter 1—Introduction 9 

Figure 2. The strategic habitat conservation process.

■ Global Approach—Be a leader in national 

and international efforts to meet the climate 

change challenge.

1.5 Landscape-Scale 

Conservation

In the face of escalating challenges such as land 

use conversion, invasive species, water scarcity, and 

refuge complex issues that have been amplified by 

accelerating climate change, our ecosystem approach 

of thinking about conservation has evolved to developing a broader vision—strategic habitat conservation. Landscape conservation cooperatives will 

facilitate how we carry out strategic habitat 

conservation.

Strategic Habitat Conservation

A cooperative effort between us and the U.S. Geological Survey culminated in a report by the National 

Ecological Assessment Team (USGS 2006). The 

report outlines a unifying adaptive resource management approach for conservation at a landscape scale 

for the entire range of a target species or suite of 

species. This is strategic habitat conservation—a 

way of thinking and doing business by incorporating 

biological goals for target species populations, by 

making strategic decisions about the work needed, 

and by constantly reassessing (figure 2).

Responding to Accelerating 

Climate Change

We expect that accelerating climate change may 

have profound effects on the Nation’s fish, wildlife, 

and plant resources. While many species will continue to thrive, some may decline and in some 

instances go extinct. Others will survive in the wild 

only through direct and continuous intervention by 

managers. In 2010, we finalized a strategic plan 

(FWS 2010) to address climate change for the next 50 

years. This strategic plan employs three key strategies: adaptation, mitigation, and engagement. In 

addition, the plan acknowledges that no single organization or agency can address climate change without allying itself with others in partnership across 

the Nation and around the world. This plan is an 

integral part of the U.S. Department of the Interior’s 

strategy for addressing climate change as expressed 

in Secretarial Order 3289 (September 14, 2009).

The Department of the Interior’s Climate Change 

Adaptation Policy (523 DM 1) was issued in December 2012 in response to the need to prepare for the 

impacts of climate change. The policy articulates and 

formalizes the Department’s approach to climate 

change adaptation and provides guidance to bureaus 

and offices for addressing climate change impacts on 

the Department’s mission, programs, operations, and 

personnel. The new policy also establishes clear 

Departmental leadership responsibilities for climate 

change adaptation implementation.

We use the following guiding principles from this 

strategic plan in responding to climate change:

■ Priority Setting—Continually evaluate priorities and approaches, make difficult 

choices, take calculated risks, and adapt to 

climate change.

■ Partnership—Commit to a new spirit of 

coordination, collaboration, and interdependence with others.

■ Best Science—Reflect scientific excellence, 

professionalism, and integrity in all our 

work.

■ Landscape Conservation—Emphasize the 

conservation of habitats within sustainable 

landscapes, applying our strategic habitat 

conservation framework.

■ Technical Capacity—Assemble and use 

state-of-the-art technical capacity to meet 

the climate change challenge.
10 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

habitats in Montana, Idaho, Wyoming (including the 

upper Green River Basin in southern Wyoming and 

small parts of Colorado and Utah), and parts of the 

Interior Columbia Plateau reaching into Oregon and 

Washington westward to the Cascade Range. The 

Great Northern Landscape Conservation Cooperative also covers the international landscapes of interior British Columbia and Alberta, Canada, and 

covers the entirety of the northern Rocky Mountains 

and midcontinent lowlands of the Interior 

Northwest.

The landscape conservation cooperative has identified the following priority species: bull trout, grizzly 

bear, Lewis’s woodpecker, trumpeter swan, westslope cutthroat trout, Arctic grayling, wolverine, willow flycatcher, greater sage-grouse, burrowing owl, 

and Columbia spotted frog. Two of these species, 

trumpeter swan and greater sage-grouse, use the 

refuge.

As the Great Northern Landscape Conservation 

Cooperative continues to develop, an overarching 

priority is to serve as a convening body to bring 

together partners to address existing and future 

issues related to climate change and landscape-scale 

conservation.

We used this framework as the basis to locate the 

first generation of landscape conservation cooperatives. These cooperatives are conservation-science 

partnerships between us and other Federal agencies, 

States, tribes, nongovernmental organizations, universities, and others. Designed as fundamental units 

for planning and science, the cooperatives have the 

capacity to help us carry out the elements of strategic 

habitat conservation—biological planning, conservation design and delivery, and monitoring and 

research. Coordinated planning and scientific information strengthens our strategic response to accelerating climate change.

Landscape Conservation 

Cooperatives

Strategic habitat conservation is a means of 

applying adaptive resource management across large 

landscapes. The National Elk Refuge lies within the 

Service’s Great Northern Landscape Conservation 

Cooperative (figure 3). This landscape conservation 

cooperative covers the mountain and transitional 

Figure 3. Map of the Great Northern Landscape Conservation Cooperative in North America.
Chapter 1—Introduction 11 

Figure 4. Process steps for comprehensive planning and associated environmental analysis.

tors included other Service divisions, the WGFD, 

Teton County, and the National Park Service (refer 

to “Appendix B—List of Preparers and Contributors”). During preplanning, the team developed a 

mailing list and identified internal issues and the 

unique qualities of the refuge (refer to section “2.5 

Special Values” in chapter 2). The planning team 

identified and reviewed current programs, compiled 

and analyzed relevant data, and identified the purposes of the refuge.

Public scoping started with a notice of intent to 

prepare the draft CCP and EA that we published in 

the Federal Register on October 22, 2010 (75 Federal 

Register 65370). We distributed information through 

news releases, issuance of the first planning update, 

and a public meeting held January 11, 2011, at Snow 

King Resort in Jackson, Wyoming, from 4 p.m. to 

7 p.m.

The planning team encouraged public comment 

during the planning process through the development and release of the draft CCP and EA. This CCP 

project complies with public involvement requirements of the National Environmental Policy Act, and 

the planning team incorporated public input throughout the planning process. During the planning process, the team collected available information about 

the resources of the refuge and surrounding areas. 

1.6 The Planning Process

The Improvement Act requires us to develop a 

CCP for each national wildlife refuge. This final plan 

for the National Elk Refuge will guide the management of the refuge for the next 15 years.

We prepared the draft CCP and EA in compliance 

with the Improvement Act and part 602 (National 

Wildlife Refuge System Planning) of the “Fish and 

Wildlife Service Manual.” The actions described in 

the draft CCP and EA meet the requirements of the 

Council on Environmental Quality regulations that 

implement the National Environmental Policy Act of 

1969. 

Additional requirements and guidance are contained in the Refuge System’s planning policy issued 

in 2000. The policy established requirements and 

guidance for refuge and district plans, including 

CCPs and stepdown management plans, to make sure 

that planning efforts follow the Improvement Act. 

The planning policy identified several steps of the 

CCP and environmental analysis process (figure 4).

We began the preplanning process in August 2010 

with the establishment of a planning team comprised 

primarily of staff from the National Elk Refuge and 

the Region 6 Division of Refuge Planning. Contribu-
12 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Table 1. Summary of the comprehensive conservation planning process for the National Elk Refuge, Wyoming.

Date Event Outcome or purpose

August 4–5, 2010 Preplanning meeting

We discussed the initial planning team list, started 

the mailing list, and discussed the planning schedule 

and data needs.

October 22, 2010 Notice of intent We published our notice of intent to prepare a CCP 

in the Federal Register.

December 10, 2010 Planning team invitations

The Regional Director invited tribal nations, 

National Park Service, USDA Forest Service, 

WGFD, and Teton County to join the planning team.

January 11–12, 2011 CCP kickoff and vision and goals 

meeting

The planning team reviewed the refuge purposes, 

identified refuge qualities and issues, and developed 

a draft vision statement and goals for the refuge.

March 14, 2011 Work plan We completed the work plan of planning tasks.

January 2011 Planning update

We sent Planning Update 1 to people and 

organizations on the mailing list. The update 

described the planning process and announced the 

upcoming public scoping meeting.

January 11, 2011 Public scoping meeting

We held a public meeting in Jackson. The public had 

an opportunity to learn about the CCP process and 

provide comments.

February 1–

June 7, 2011

Five planning team conference 

calls

The planning team summarized public comments, 

identified issues to be addressed in the planning 

process, and began developing a range of 

management alternatives for the refuge.

December 13–15, 2011 Alternatives development 

meeting

The planning team met in Jackson to discuss 

management alternatives.

March 19–21, 2012

Environmental consequences 

and selection of proposed action 

workshop

The planning team met in Jackson to review the 

environmental consequences for the alternatives and 

select a proposed action alternative.

June 19–21, 2012 Objectives and strategies work 

session

The planning team began writing objectives and 

strategies for the proposed action alternative.

September 2012–July 2013 Draft plan preparation The planning team prepared the draft CCP and EA.

December 2013 Draft plan internal review

The planning team and other staff reviewed the 

draft CCP and EA and provided comments to help 

clarify the analyses and provide consistency.

August 2014 Draft plan preparation The planning team completed the draft plan for 

distribution to the public for review.

September 9, 2014 Notice of availability We published the notice of availability of the draft 

CCP and EA in the Federal Register.

September 2014 Planning update

We mailed the third planning update to those on our 

mailing list. The update announced the upcoming 

public meeting.

September 25, 2014 Public meeting

The public meeting was held in Jackson. The public 

had an opportunity to meet with refuge staff and 

provide comments on the draft plan.

November 2014–June 2015 Public comments review The planning team reviewed the public comments 

and determined needed changes for the final CCP.

September 2015 Decision on preferred 

alternative

The Regional Director selected the preferred 

alternative and signed the finding of no significant 

impact.

October–April 2016 Final plan preparation The planning team finished revising and editing the 

final CCP for printing and distribution.
Chapter 1—Introduction 13 

Written comments were due February 10, 2011. 

We received more than 230 comments orally and in 

writing during the scoping process. There were letters from eight organizations (Concerned Citizens for 

the Elk, Defenders of Wildlife, Friends of Pathways, 

Greater Yellowstone Coalition, Jackson Hole Chamber of Commerce, Jackson Hole Conservation Alliance, Jackson Hole Public Art Initiative, and The 

Wildlife Society) and four agencies (National Park 

Service, Teton Conservation District, Teton County, 

and WGFD). The planning team considered all of the 

comments throughout the planning process.

State Coordination

At the start of the planning process, our Regional 

Director (Region 6) sent a letter to WGFD, inviting 

them to join in the planning process. Two representatives from the WGFD are participating on the planning team.

We sent Planning Update 1 to the offices of the 

U.S. Representative Cynthia Lummis and U.S. Senators John Barrasso and Mike Enzi to tell them about 

the planning process and invite them to attend a public scoping meeting and provide comments on issues 

to be addressed during the planning process. In addition, we sent the planning updates to Wyoming Governor Matt Mead; Wyoming State Senators Leland 

Christensen and Dan Dockstader; and Wyoming 

State representatives Keith Gingery, Ruth Petroff, 

and Jim Roscoe. In addition, we made phone calls 

during the scoping period inviting the elected offiThis information is summarized in “Chapter 3—Refuge Resources.” Table 1 lists the specific steps in the 

planning process to date for the preparation of the 

draft CCP and EA and the final CCP.

Coordination with the Public

We prepared a mailing list of more than 90 names 

during preplanning. The mailing list has private citizens; local, regional, and State government representatives and legislators; other Federal agencies; and 

interested organizations (refer to “Appendix C—

Public Involvement”). The first planning update was 

distributed through refuge email mailing lists and at 

the public scoping meeting in January 2011. Information was provided on the history of the refuge and 

the CCP process and included an invitation to attend 

the public scoping meeting being held in January. The 

planning update contained information on how to be 

placed on the CCP mailing list, and the planning 

update provided opportunities for submitting 

comments. 

The Service held a public scoping meeting January 11, 2011. Forty people attended the meeting, 

which was an open-house format with stations set up 

around and our staff attending each station to provide information and answer questions. We encouraged attendees to ask questions and offer comments. 

We recorded verbal comments and gave each 

attendee a comment form to submit other thoughts or 

questions in writing.

Flat Creek Marsh

Lori Iverson / FWS
14 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

that we resolve or give priority to issues with the 

greatest effect on the refuge resources and programs 

over the life of the final CCP. Chapter 2 contains the 

issues we identified, along with a discussion of effects 

on resources. In addition, we considered suggested 

changes to current refuge management presented by 

the public and other groups.

The Draft Plan

Availability of the draft CCP and EA for the 

National Elk Refuge was announced in the Federal 

Register on September 9, 2014, and comments on this 

document were collected through October 24, 2014. A 

public meeting to discuss this plan was announced in 

a planning update released in September 2014. A 

meeting was held September 25, 2014, in the local 

community of Jackson, Wyoming. Meeting attendees 

were given the opportunity to submit comments. 

Comments were also collected online, by email, and 

by mail. 

The public commented on the draft CCP and EA 

during a review period. We recorded all comments, 

oral and written. The planning team then reviewed 

them. Some modifications were made to this final 

CCP based on the public review. Appendix C has 

more detail about our involvement with the public, 

including responses to substantive public comments 

on the draft CCP and EA.

The Final Plan

The plan is intended to be a broad umbrella of 

general concepts and specific objectives for the refuge over the next 15 years. As the plan is implemented, we will develop stepdown management plans 

with details for carrying out actions needed to 

achieve objectives.

cials to attend the upcoming scoping meeting for the 

CCP; three local elected officials attended the meeting at the Snow King Resort in Jackson, Wyoming, 

on January 11, 2011.

Tribal Coordination

Early in the planning process, our Regional 

Director (Region 6) sent a letter to tribes identified 

as possibly having a cultural and historical connection to the area in which the National Elk Refuge is 

located. The letters went to the following tribal councils: Assiniboine and Sioux Tribes of Fort Peck, 

Cheyenne and Arapaho, Cheyenne River Sioux, Crow 

Creek Sioux, Lower Brule Sioux, North Arapaho, 

Northern Cheyenne, Oglala Sioux, Rosebud Sioux, 

Santee Sioux, Shoshone, Shoshone-Bannock, and 

Standing Rock Sioux. The tribal councils did not submit responses to the Region 6 letter; nevertheless, 

we gave the councils opportunities to comment 

throughout the planning process.

Teton County Coordination

At the start of the planning process, our Regional 

Director (Region 6) sent a letter to the Teton County 

Board of Commissioners inviting them to join in the 

planning process. A representative of Teton County 

and the City of Jackson is participating on the planning team.

Results of Scoping

We used the comments, collected from scoping 

meetings and correspondence, in the development of 

a final list of issues that are addressed in the final 

CCP. We decided which alternatives could best 

address these issues. The planning process ensures 
established in 1912 as a “winter game (elk) reserve,” 

but over the years, its purpose has been broadened to 

include “refuges and breeding grounds for birds, 

other big game animals, the conservation of fish and 

wildlife, and the protection of natural resources and 

conservation of threatened or endangered species.”

Acquisition History

When the U.S. Congress appropriated $20,000 on 

March 4, 1911, for “feeding, protecting and removing 

elk from the Jackson Hole and vicinity,” it also 

assigned E.A. Preble, scientist for the Bureau of Biological Survey, the task of making a preliminary 

investigation of the Jackson Hole elk situation. Preble 

was assisted by D.C. Nowlin (who became the first 

refuge manager) in assessing the Jackson elk herd 

and its needs.

Preble and Nowlin conducted an evaluation of that 

part of the Snake River Valley known as Jackson 

This chapter explains the establishment, management history, purposes, and special values of the 

National Elk Refuge in northwestern Wyoming along 

with the final vision and goals and a discussion of the 

planning issues.

2.1 Establishment, Acquisition, 

and Management History

The following section describes the refuge’s establishment, acquisition, and management history.

Establishment

The National Elk Refuge is one of the oldest refuges in the Refuge System (see figure 5). It was 

Trumpeter Swans

Ann Hough / FWS

Chapter 2—The Refuge
16 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Figure 5. Base map of the National Elk Refuge, Wyoming.
Chapter 2—The Refuge 17 

Table 2. Land acquisition history for the National Elk Refuge, Wyoming.

Date of acquisition Tract number Final acres Means of acquisition

3/16/1914 9e, 9f, 9g 1,205.25 Purchase

4/21/1915 1 4,322.27 Primary withdrawal

10/18/1915 121 360 Purchase

10/22/1915 118 160 Purchase

9/26/1927 119, 119a 1,757.38 Donation

7/20/1936 59 240 Purchase

7/21/1936 39 802.74 Purchase

7/23/1936 52 140 Purchase

7/23/1936 68 796 Purchase

7/23/1936 30, 30–I 470.13 Purchase

7/30/1936 7 279.82 Purchase

7/30/1936 58 240 Purchase

7/30/1936 61 160 Purchase

10/31/1936 54 320 Purchase

lands and Teton Ranch subdivisions. Land values in 

Teton County, especially next to the refuge, began to 

skyrocket in the 1990s and reached multiple millions 

of dollars per acre by 2007. These exorbitant land 

values have prevented all fee-title land acquisition 

since 1992. Today, the refuge has completely filled its 

approved acquisition boundary and is 24,778 acres in 

size. Table 2 summarizes the history of land acquisition for the refuge, and figure 6 shows locations of the 

land tracts. The refuge is bounded by the town of 

Jackson on the south, the Gros Ventre River on the 

north, Highway 89 on the west, and the BridgerTeton National Forest on the east. Because much of 

the refuge was comprised from homesteads, areas of 

the refuge have retained some of these historical 

names, as shown on figure 7.

Management History

The National Elk Refuge was established in 

response to severe elk starvation in Jackson Hole. 

The development of the town of Jackson and settlement of the valley by cattle ranchers substantially 

reduced historical elk winter range and led to massive elk starvation during the winters of 1909 and 

1910. At the request of the State of Wyoming, the 

U.S. Congress first appropriated $20,000 on March 4, 

1911, for “feeding, protecting and removing elk in 

Jackson Hole and vicinity.“

Feeding hay to elk wintering in Jackson Hole was 

one of the first management activities to occur on 

what is now the National Elk Refuge. No-feeding 

years have occurred irregularly and infrequently. 

Hole, which extends from Jackson Lake on the north 

to the mouth of the Hoback River on the south. They 

also evaluated the Buffalo River and Gros Ventre 

River valleys. Preble and Nowlin’s population estimate was 20,000 elk with an estimated winter mortality of 2,000–2,500. Preble concluded his report 

with the statement, “The Biological Survey looks on 

the establishment of one or more winter refuges as 

the best solution of the problem of properly caring for 

the elk in winter.” He recommended winter elk refuges either in the Gros Ventre River valley or in the 

Snake River Valley near the town of Jackson. Residents in Jackson strongly opposed the Gros Ventre 

River valley site but generally supported a location 

near their town.

On August 10, 1912, the U.S. Congress appropriated $45,000 to buy lands and pay for maintenance of 

a “winter game (elk) reserve” (37 Stat. 293). The first 

tract for the National Elk Refuge was bought in 1914. 

Since that time, we have acquired land primarily 

through purchase with a few tracts obtained through 

exchange, donation, or condemnation. Several noteworthy acquisitions have occurred. In 1927, the Isaac 

Walton League of America donated 1,757 acres, 

which increased the size of the refuge at that time by 

30 percent. The top-priority acquisition listed in our 

1965 refuge master plan was an 80-acre tract that 

occupied a 2.75-mile-long area along the eastern side 

of State Highway 89. We acquired this tract to prevent any commercial or residential development next 

to the refuge that would “block and disfigure” the 

“breathtaking view of the land.”

By 1950, the refuge had expanded in size to 23,001 

acres. More acquisitions occurred in 1978 and 1986 to 

prevent the completion of the adjacent Teton High-
18 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Table 2. Land acquisition history for the National Elk Refuge, Wyoming.

Date of acquisition Tract number Final acres Means of acquisition

10/31/1936 117 320 Purchase

11/7/1936 56 320 Purchase

1/14/1937 24 237.36 Purchase

4/2/1937 9, 9a, 9b, 9c, 9d 1,471.03 Purchase

4/13/1937 27, a, a–1, a–2, b, c, e 825.97 Purchase

4/28/1937 22 400 Purchase

5/11/1937 25 438.56 Purchase

5/12/1937 44 143.3 Purchase

5/17/1937 72 320 Purchase

5/17/1937 116 160 Purchase

5/17/1937 53, 53a, 53b 800 Purchase

5/24/1937 8 320 Purchase

5/24/1937 40 120.12 Purchase

6/7/1937 58a 160 Purchase

6/8/1937 28 640 Purchase

7/9/1937 34 160 Purchase

12/27/1937 8a 678.64 Condemnation

12/271937 113 160 Condemnation

1/5/1938 11 626.12 Purchase

6/9/1938 120 0.98 Purchase

7/25/1938 36 80 Purchase

11/3/1938 55 230 Purchase

11/21/1939 31, 31a, 31c 42.38 Donation

6/11/1940 2 320 Purchase

11/15/1941 51 220 Purchase

12/16/1949 206, 206a 2,712.97 Donation

2/6/1959 42 160 Land exchange

3/17/1965 122a 460 Land exchange

2/7/1972 123 80.12 Purchase

12/20/1974 124, 124a 111.51 Purchase

8/26/1975 124b 26.07 Purchase

4/18/1977 132 10.31 Purchase

11/16/1978 137 11.78 Purchase

12/14/1978 133, a, b, c, d 245.17 Purchase

9/6/1979 143 16.97 Purchase

7/21/1980 128 5.18 Purchase

2/8/1986 131 5.01 Purchase

3/28/1986 122b 354.26 Primary withdrawal

5/2/1986 154 41.03 Purchase

10/1/1986 130 5 Purchase

10/22/1986 125 50 Purchase

8/5/1991 155 20 Purchase

9/2/1992 124c 10 Purchase

10/1/1992 156 3.87 Purchase
Chapter 2—The Refuge 19 

Figure 6. Map of land tracts composing the National Elk Refuge, Wyoming.
20 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Figure 7. Map of areas and feedgrounds on the National Elk Refuge, Wyoming.
Chapter 2—The Refuge 21 

Nestled below the majestic Teton Range, 

adjacent to the historic gateway town of 

Jackson, the National Elk Refuge provides 

crucial big game wintering habitat in the 

Greater Yellowstone Ecosystem. Across the 

refuge’s grassland, wetland, woodland, and 

sagebrush shrubland communities, 

visitors view wintering elk and other 

wildlife populations that are balanced with 

their habitats. The public enjoys quality 

hunting and fishing as well as year-round 

interpretative opportunities. Effective 

outreach and strong public and private 

partnerships ensure understanding and 

protection of refuge resources for 

future generations.

■ In 1921, all lands included in the refuge or 

that might be added in the future were 

reserved and set apart as “refuges and 

breeding grounds for birds” (Executive 

Order 3596), which was affirmed in 1922 

(Executive Order 3741). 

■ In 1927, the refuge was expanded to provide 

“for the grazing of, and as a refuge for, 

American elk and other big game animals” 

(44 Stat. 1246, 16 U.S.C. 673a).

These purposes apply to all or most of the lands 

now within the refuge. Several parcels have been 

added to the refuge specifically for the conservation 

of fish and wildlife (Fish and Wildlife Act of 1956), 

opportunities for recreational development oriented 

to fish and wildlife, the protection of natural 

resources, and the conservation of threatened or 

endangered species (Refuge Recreation Act of 1962, 

16 U.S.C. 460k–l).

2.3 Vision

A vision is a concept, including desired conditions 

for the future, that describes the essence of what we 

are trying to accomplish at a refuge. The following 

vision for the National Elk Refuge is a future-oriented statement designed to be achieved through 

refuge management throughout the life of the CCP 

and beyond:

Since the refuge was established in 1912, there have 

been 9 years when no feeding was provided. The last 

such winter was in 1980–81. The length of the supplemental winter feeding program has ranged from no 

feeding to a maximum of 147 days; elk are fed an 

average of 70 days annually. We have fed hay to elk 

during at least a part of most winters from 1912 to 

1975. In 1975, after several years of testing, we made 

a switch to alfalfa pellets (Smith and Robbins 1984).

Hunting is the primary management tool used to 

control the size of the Jackson elk herd. The first 

hunting season on the National Elk Refuge was in 

1943, but hunting did not become an annual event 

until 1955.

Members and descendants of a small display herd 

of bison that escaped from Grand Teton National 

Park in the late 1960s discovered the refuge’s winter 

supplemental feeding program in 1980. This source of 

winter nutrition enabled the bison herd size to 

increase almost exponentially to 1,250 animals by the 

fall of 2007. To reduce herd size to objective levels in 

the Bison and Elk Management Plan, bison hunting 

became an annual activity on the refuge in 2007 and 

has been the primary tool used to control the size of 

the Jackson bison herd.

2.2 Purposes

Every national wildlife refuge has a purpose for 

which it was established. The purpose is the foundation on which to build all refuge programs—from 

biology and public use to maintenance and facilities. 

No action that we or the public undertake may conflict with this purpose. The refuge purposes are 

found in the legislative acts or executive actions that 

provide the authorities to either transfer or acquire a 

piece of land for a refuge. Over time, an individual 

refuge may contain lands that have been acquired 

under various transfer and acquisition authorities, 

giving the refuge more than one purpose. 

The goals, objectives, and strategies in the CCP 

(refer to chapter 4) are intended to support the individual purposes for which the National Elk Refuge 

was established:

■ The National Elk Refuge was established in 

1912 as a “winter game (elk) reserve” (37 

Stat. 293, 16 United States Code [U.S.C.] 

673).

■ In 1913, the U.S. Congress designated the 

area “a winter elk refuge” (37 Stat. 847). 
22 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Visitor Services Goal

Enable a diverse audience to understand and 

appreciate the refuge’s wildlife conservation role in 

Jackson Hole, while safely enjoying year-round 

opportunities for wildlife-dependent recreation.

Visitor and Employee Safety and 

Resource Protection Goal

Provide for the safety, security, and protection of 

visitors, employees, natural and cultural resources, 

and facilities throughout the refuge.

Administration Goal

Provide facilities and effectively use and develop 

staff resources, funding, partnerships, and volunteer 

opportunities to maintain the long-term integrity of 

habitats and wildlife resources of the refuge.

2.5 Special Values

Early in the planning process, our planning team 

and the public identified the outstanding qualities or 

special values of the National Elk Refuge. These special values are characteristics and features of the refuge that make it special to the public, valuable for 

wildlife, and worthy of refuge status. It was important 

to identify and describe the special values of the refuge to recognize its worth and to make sure they are 

conserved, protected, and enhanced through the planning process. These special values can be unique biological resources as well as something as simple as a 

quiet place to see a variety of birds and enjoy nature.

Intact Ecosystem

The refuge lies in a nearly intact ecosystem. The 

Greater Yellowstone Ecosystem is one of the last 

remaining nearly intact ecosystems in the northern 

temperate zone. As human population pressure and 

development degrade natural systems worldwide, 

large nearly intact areas such as the Greater Yellowstone Ecosystem sustain some of the last remaining 

populations of large carnivores, support some of the 

Lori Iverson / FWS

Collaring elk is a regular and useful activity.

2.4 Goals

A goal is a descriptive, broad statement of desired 

future conditions that conveys a purpose but does not 

define measurable units. The goals direct efforts 

toward achieving the vision and purposes of the refuge and outline approaches for managing refuge 

resources. We developed five goals for the refuge 

based on the Improvement Act, the purposes of the 

refuge, and information developed during planning.

Habitat and Wildlife Management 

Goal

Adaptively manage bison, elk, and other wildlife 

populations and habitats as outlined in the Bison and 

Elk Management Plan and the CCP. Contribute to 

the conservation of healthy native wildlife populations and their habitats. Restore and sustain a native 

fishery that provides quality fishing opportunities. 

Cultural Resources Goal

Preserve and interpret cultural resources in a 

way that allows visitors to connect to the area’s rich 

history and conservation heritage.
Chapter 2—The Refuge 23 

Quality Water Resources

The Gros Ventre River drains approximately 600 

square miles of eastern Jackson Hole and the adjacent Gros Ventre Range to the east. The river is the 

largest watercourse on the refuge and is among the 

river segments designated as wild and scenic by the 

Craig Thomas Snake Headwaters Legacy Act of 

2008.

Overall, the refuge experiences a relatively natural, annual hydro-regime (waterflows occur without 

substantial human-constructed controls or alterations), which promotes healthy aquatic ecosystem 

processes, supports robust populations of aquatic 

invertebrates (animals without a backbone), and sustains native Snake River cutthroat trout populations. 

However, the diversion of irrigation water from the 

Gros Ventre River into Flat Creek is sustaining 

higher than normal summer flows and is not a “natural, annual hydro-regime.” The Gros Ventre River 

irrigation diversion is conveyed through a ditch dug 

across the glacial moraine complex separating the 

river from Flat Creek. The lowermost portion of this 

ditch failed catastrophically in 1932, producing a 

massive erosion event in the moraine material. A 

deep gully developed, which delivered a large amount 

of sediment to the valley floor and directly to Flat 

Creek.

Water-level contours show that ground water 

from higher elevations flows to the southwest 

through the valley toward the Snake River. Data for 

the valley aquifer (permeable rock storing underground water) indicate excellent water quality, supporting use for drinking water supplies, recreation, 

and other commercial uses.

Variety and Abundance of Wildlife

The National Elk Refuge harbors a wide variety 

of wildlife. Unlike most national wildlife refuges, it is 

the abundance of big game animals, including the 

refuge’s namesake, rather than birds that makes the 

refuge biologically unique. The refuge habitat is critical to sustain regional populations of these species, 

supporting unparalleled hunting and wildlife-viewing 

opportunities in Jackson Hole.

Federally Listed Species and Wyoming 

Species of Greatest Conservation Need

The National Elk Refuge is home to Federal and 

State species of concern. The grizzly bear is federally 

listed as threatened under the Endangered Species 

longest ungulate migrations in North America, and 

contain some of the largest areas of undeveloped wilderness in the lower 48 States. A contiguous system 

of national park, national wildlife refuge, and national 

forest lands has conserved the relative integrity of 

the Greater Yellowstone Ecosystem.

High Scenic Quality

The National Elk Refuge is considered one of the 

“crown jewels” of the Refuge System because of its 

spectacular scenery, closeness to two iconic national 

parks (Grand Teton and Yellowstone), and large charismatic populations of seasonal wildlife—especially 

elk and bison—that people want to stop and watch. 

The refuge, along with vast expanses of undeveloped national forest and national park land surrounding the refuge, offers spectacular scenic views of the 

Teton and Gros Ventre Ranges, the Sleeping Indian 

(Sheep Mountain), Jackson Peak, Cache Peak, Snow 

King Mountain, East Gros Ventre Butte, and the 

Gros Ventre Hills in the northern part of the refuge. 

The refuge’s location along a heavily traveled highway leading to and from the Grand Teton and Yellowstone National Parks and its vast expanses of 

scenic open space are integral to the visual experiences of visitors. The visual appearance of a landscape is often the first thing to which a viewer 

responds. The most prominent view of the refuge, 

which is seen by several million visitors annually as 

they drive to and from Jackson on U.S. Highway 

26/89/191, is the expansive Flat Creek wetland.

Undeveloped Habitat

“Habitat” is a species-specific concept that refers 

to the resources necessary to sustain populations of a 

given species or communities of species. Each wildlife organism has particular space, food, water, and 

thermoregulation needs that influence whether that 

species can exist in an area, and these requirements 

define the habitat of that species.

The National Elk Refuge represents one of the 

last undeveloped low-elevation areas in Jackson Hole. 

The refuge provides important habitat for species 

that depend on limited snow cover, open grasslands, 

sagebrush shrublands, or wetlands. Important refuge 

habitats include (1) winter range for elk, bison, 

moose, and bighorn sheep; (2) breeding habitat for 

grassland birds such as long-billed curlew; (3) wintering and breeding habitat for greater sage-grouse; 

and (4) wetland habitat for trumpeter swans, amphibians, and cutthroat trout.
24 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Migratory Birds

Parts of the refuge were established to protect 

and provide habitat for migratory birds that cross 

State lines and international borders; these bird species are by law a Federal trust responsibility. The 

refuge contains significant wetland and grassland 

communities that are important to migratory birds, 

and the value of these habitats is enhanced by the 

restricted human access, which prevents disturbance 

during nesting and other critical periods in their life 

cycle. The refuge contains one of the largest wetlands 

in northwestern Wyoming—Flat Creek Marsh—

which is an important migratory stopover for waterfowl and shorebird species in the Pacific flyway 

(figure 8) and breeding habitat for trumpeter swans 

and other waterfowl.

Fish

Flat Creek, a spring-fed stream augmented by 

irrigation, originates north of the town of Jackson, 

runs through town, and ends at the Snake River 

south of town. This stream is integral to Jackson 

Hole and the natural recruitment of native trout for 

the Snake River. No stocking occurs in Flat Creek, 

making natural recruitment the only source of native 

Snake River cutthroat trout. The Gros Ventre River 

contains Snake River cutthroat, rainbow trout, and 

hybridized fish species.

Amphibians

The Gros Ventre River, Flat Creek, and Nowlin 

Creek riparian areas with their associated ponds and 

wetlands provide essential habitat for regional 

amphibian populations. Boreal chorus frogs are the 

most widespread species. Columbia spotted frogs are 

locally abundant in the Nowlin Creek drainage in two 

large breeding areas. In addition, boreal toads are 

locally abundant in two main breeding areas in the 

Nowlin Creek and Gros Ventre River drainages. 

Tiger salamanders, although common in the region, 

are thought to be rare on the refuge.

Abundant Visitor Opportunities

Visitor surveys conducted by the Jackson Hole 

Chamber of Commerce have consistently documented 

that 80–90 percent of valley tourists identify natural 

resource-based activities as their primary reason for 

visiting Jackson Hole. Hunting, fishing, wildlife 

observation, photography, environmental education, 

and interpretation are the six priority public uses 

(wildlife-dependent recreational uses) of the Refuge 

Act and the greater sage-grouse is a candidate for 

listing; we have documented both species on the refuge. We have only incidental grizzly bear use documented on the northern parts of refuge. However, 

recent observations in the southern part of Grand 

Teton National Park bordering the refuge suggest 

that increased grizzly bear activity on the refuge 

may be likely in the near future. Greater sage-grouse 

use the refuge year-round, and successful breeding 

has been documented.

There is documented use of the refuge by 35 of 

Wyoming’s SGCN (refer to “Appendix D—Species 

Lists”). We have documentation of breeding on the 

refuge for several of these species: trumpeter swan, 

bald eagle, redhead, lesser scaup, sandhill crane, 

long-billed curlew, Brewer’s sparrow, bobolink, 

moose, bighorn sheep, and river otter. Refuge grassland and sagebrush shrubland communities support 

breeding populations of Wyoming SGCN, including 

long-billed curlew and Brewer’s sparrow. Undoubtedly, other Wyoming-designated SGCN from certain 

taxonomic groups, such as bats and small mammals, 

are also present on the refuge, but we need more survey work to confirm their presence and use of the 

refuge.

Mammals

The refuge is the terminus of seasonal migrations 

for four celebrated large mammal species. Part of the 

Jackson bighorn sheep herd spends the winter on the 

refuge on Miller Butte and around Curtis Canyon 

and migrates to summer range in the Gros Ventre 

Mountains. Portions of the Jackson elk herd migrate 

up to 60 miles from their summer range in Yellowstone National Park to winter on the refuge. The 

refuge hosts the Jackson bison herd during the winter months, one of only three remaining free-roaming 

bison herds in North America. Pronghorn summer on 

the refuge and winter south of Pinedale, Wyoming 

(more than 70 miles away), making this one of the 

longest mammal migrations in the Western 

Hemisphere.

Given the abundance of prey and the lack of 

human disturbance, the refuge has become a haven 

for large carnivores. Gray wolves have been active on 

the refuge since 1999 and have denned on the refuge 

in all but 1 year since 2005. Mountain lion activity has 

occurred on Miller Butte and on the eastern part of 

the refuge. Black bears occasionally use the refuge, 

particularly during the fall season. Coyotes occur at 

high densities, particularly in the winter when they 

scavenge elk carcasses and occasionally kill weak and 

sick elk.
Chapter 2—The Refuge 25 

Figure 8. Map of waterfowl flyways in North America.

Museum, Jackson National Fish Hatchery, and Grand 

Teton National Park.

However, it is the spectacle of thousands of elk and 

hundreds of bison wintering on the refuge’s grasslands that most intrigues the public and makes the 

refuge a national icon. Our visitor services staff offers 

year-round programs to incorporate wildlife viewing, 

photography, interpretation, and environmental education into the visitor experience. Thousands of people each year view elk at close range on the refuge 

while participating in the sleigh ride program. Bison 

are popular with visitors and residents as a symbol of 

the West, and they are central to the culture and traditions of many American Indian tribes. Bison can 

often be viewed along the fence north of the Jackson 

National Fish Hatchery and in the McBride area 

before Flat Creek Road is closed seasonally in 

December. Other ungulates such as bighorn sheep can 

often be easily viewed from Elk Refuge Road and are 

a popular species for winter wildlife viewers. From 

November to May, bighorn sheep can be found on the 

eastern slopes of Miller Butte and in the northern 

refuge near Curtis Canyon. Moose, pronghorn, and 

mule deer also frequent the refuge. 

System, and we provide opportunities for all of these 

activities on the National Elk Refuge.

We allow elk and bison hunting on the refuge to 

help meet herd management objectives and to provide recreational opportunities. Depending on which 

area hunters are in, we allow hunters to use a variety 

of weapons including rifles, archery equipment, and 

designated limited-range weapons such muzzle-loading rifles, shotguns with slugs, and handguns. The 

refuge accommodates hunters with disabilities and 

offers a special elk hunt for young people.

We manage Flat Creek as a trophy class fishery 

for Snake River cutthroat trout. This fish is a unique 

subspecies of cutthroat trout and is the only trout 

native to the area. 

We provide a multiuse pathway to the public 

through a cooperative agreement with Teton County. 

The pathway is available to a wide variety of people 

seeking to experience the refuge on foot or via nonmotorized vehicles, allowing them to enjoy views of 

the refuge and providing wildlife viewing and photography opportunities during three seasons of the 

year. The pathway also allows users to connect to 

destinations such as the National Wildlife Art 
26 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

tial impacts that climate change may have on terrestrial and aquatic habitats and the associated wildlife 

species. Several scientific studies show that, in the 

past century, the climate has become warmer and 

drier in northern Yellowstone National Park (Balling 

et al. 1992a, 1992b). If this warming trend continues, 

it could have far-reaching effects on the plants and 

animals of the Greater Yellowstone Ecosystem 

(Romme and Turner 1991), which includes the 

National Elk Refuge.

Analysis of precipitation records from 1921 to 

2002 gathered at a National Oceanic and Atmospheric Administration weather station in Jackson, 

Wyoming, showed no significant trends, either 

increasing or decreasing (Smith et al. 2004). 

Although temperature readings from 1931 to 2002 

increased, calculations using the 1949–2001 KeetchByram Drought Index values, which evaluate upper 

level soil moisture content, revealed a “minor decline 

in drought conditions” (Smith et al. 2004).

Landscape-Scale Conservation 

Needs

There is increasing residential, commercial, and 

energy development near the refuge and surrounding 

areas. Threats to wildlife associated with development include loss of habitat, habitat fragmentation, 

vehicle collision mortality, loss of wildlife migration 

routes, poaching, and increased infestations of invasive plants, including noxious weeds. As towns, developments, farms, ranches, and roads spread across the 

region, wildland shrinks and is broken into smaller 

fragments. The land surrounding the refuge is 

mostly comprised of federally managed lands (Grand 

Teton National Park and Bridger-Teton National 

Forest) and the town of Jackson. The town of Jackson 

is already intensively developed, leaving little opportunity for further habitat protection in the immediate 

area. The National Elk Refuge, national parks, 

national forests, and State lands in the Greater Yellowstone Ecosystem preserve continuous tracts of 

important habitat and travel corridors for the area’s 

wildlife and for the enjoyment of people.

Big Game Management Effects on 

Wildlife Habitat

Historical evidence suggests that the refuge once 

supported substantial willow, cottonwood, aspen, and 

mountain shrub communities. Because the refuge has 

Rich Cultural History

In prehistoric times, American Indians living on 

surrounding lands used this high-elevation valley 

primarily during the warm months, and no one tribe 

occupied Jackson Hole year-round. Traditional uses 

of the lands included hunting and fishing, collection of 

plants and minerals, and ceremonial activities. We 

have recorded eight prehistoric archaeological sites 

on the refuge, which include roasting pits, stone circles, and a bison kill site. Among the artifacts that 

have been discovered are bones from elk and bison, 

numerous flakes, choppers, scrapers, and projectile 

point pieces. Present-day activity includes the ceremonial bison hunt that the Shoshone-Bannock Tribes 

conduct on the refuge.

The Miller House, built in 1898, was one of the 

early homesteads in the valley. Later, it became one 

of the first land tracts to be bought for the refuge, 

and it was the original office for the refuge. Listed on 

the National Register of Historic Places in 1969, 

much of the original house has been restored to 

period standards and aesthetics, and it is open for 

tour by the public during the summer.

2.6 Planning Issues

We identified several key issues following the 

analysis of comments collected from refuge staff and 

the public and a review of the requirements of the 

Improvement Act and the National Environmental 

Policy Act. As described in chapter 1, section 1.6, we 

used a public meeting, news releases, presentations 

to local agencies and organizations, an announcement 

in the Federal Register, and planning updates to 

solicit public input on which issues the CCP should 

address. We considered the substantive comments 

(those that could be addressed within the authority 

and management capabilities of the Service) when 

formulating the alternatives for future management 

of the refuge. These key issues are summarized 

below.

Unknown Effects of Climate 

Change

Although climate change is a naturally occurring 

phenomenon and temperature and precipitation 

changes are anticipated, there are many unknowns. 

Consequently, we do not fully understand the poten-
Chapter 2—The Refuge 27 

■ Perennial pepperweed

■ Whitetop

■ Bull thistle

■ Houndstongue

■ Russian knapweed

■ Wooly mullein

■ Canada thistle

■ Marsh sow thistle

■ Scentless chamomile

■ Yellow toadflax

■ Common tansy

Many invasive plant infestations on the refuge are 

a direct result of abandoned livestock-feeding areas 

and corrals, old homesites, and roadbeds. These species reduce the diversity and number of native plants 

and change habitats, such as replacing a grass community with a forb community. Studies in Montana 

report that bison and deer reduced their use of a 

particular habitat by 70–82 percent when it was 

invaded by leafy spurge. Elk forage in bunchgrass 

sites on the refuge was decreased by 50–90 percent 

after a spotted knapweed invasion (Teton County 

Weed and Pest District 2002).

Invasive grasses, forbs, and woody species are of 

concern because they diminish the quality and suitability of habitat and reduce its potential to support 

many native wildlife species. Invasive plants also fail 

to protect and hold soil because they generally have a 

shallow root system, leading to increased erosion and 

sedimentation in streams. This in turn affects water 

quality, reduces aquatic habitat, and may lead to 

decreases in fish production.

Flat Creek Enhancement

There is a need to improve the condition of Flat 

Creek to increase aquatic habitat for all age classes of 

the Snake River cutthroat trout. This creek is an 

iconic fixture in Jackson Hole for tourists, anglers, 

and the native cutthroat trout. Flat Creek on the refuge provides a walk-in opportunity for anglers to 

experience a trophy fishery of Snake River cutthroat 

trout. However, the refuge reach of Flat Creek has 

experienced direct and indirect alteration to its 

stream form and function from changes in hydrologic 

and sediment inputs, installation of instream structures and treatments, and nearby land management 

activities. With some enhancement work on Flat 

Creek done in 2013, we need to continue this work 

farther down the refuge reach of Flat Creek to 

improve habitat for cutthroat trout (Biota 2013a, 

2013b).

consistently maintained artificially high numbers of 

elk through supplemental feeding for almost 100 

years, browsing by elk has reduced the spatial extent 

and structural complexity of woody plant communities, particularly on the southern end of the refuge 

(Smith et al. 2004). As a result, habitat for species 

that depend on these communities, such as beaver 

and breeding birds that nest in dense woody vegetation, has been drastically reduced. Furthermore, 

when the large concentrations of wintering elk and 

bison consume streamside woody vegetation, the 

streambanks become unstable and vulnerable to collapse into the stream, sending substantial amounts of 

sand and silt into the stream. Experiments suggest 

that these plant communities have the capacity to 

recover, but only if ungulate numbers are drastically 

reduced or they are excluded from browsing using 

fencing or other physical barriers.

Irrigation is a common habitat management tool 

that we use to increase both the quantity and quality 

of forage available to grazing wildlife. We have used 

irrigation to produce forage for many years on the 

National Elk Refuge as a technique to reduce wintering elk reliance on supplemental feeding. However, 

moving the irrigation system requires dragging the 

lines over the ground, and this activity can potentially have negative effects on the nests of birds such 

as the curlew, which is an important ground-nesting 

bird on the refuge and a bird of special concern to the 

State of Wyoming.

Invasive Plants Replacing Native 

Habitat

An invasive species is defined as a species that is 

nonnative to the ecosystem under consideration and 

whose introduction causes or is likely to cause economic or environmental harm or harm to human 

health (National Invasive Species Council 2008). 

Invasive plant species spread easily, replace native 

habitat, reduce diversity, and cause great expenditure of financial and human resources. Adjacent private lands are often the sources for invasive plants, 

including State-designated noxious weeds.

Common noxious weeds present on the refuge are 

musk thistle and spotted knapweed. There are many 

other invasive plant species on the refuge including 

the following:

■ Bindweed Dalmatian toadflax

■ Oxeye daisy

■ Scotch thistle

■ Black henbane

■ Diffuse knapweed
28 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

as a strategy to reduce brucellosis transmission from 

elk and bison to cattle, yet artificially concentrating 

elk and bison on feedgrounds also maintains higher 

brucellosis seroprevalence in elk and bison (Cross et 

al. 2007, 2010) and puts them at risk for other densitydependent diseases (Smith 2001). As a result, density-dependent ungulate disease is a major concern 

for the refuge. Brucellosis, septicemic pasteurellosis, 

psoroptic mange, necrotic stomatitis, necrotizing 

pododermatitis (foot rot), and helminth and lungworm parasitism have been well documented in the 

Jackson elk herd. Similarly, brucellosis and densityassociated parasitism have been well documented in 

the Jackson bison herd. Brucellosis seroprevalence 

rates of unfed bison in Yellowstone National Park 

fluctuate between 40 and 60 percent (Cheville 1998). 

Jackson bison herd seroprevalence is approximately 

60 percent.

Although the population level effects of these diseases have been minimal for elk and bison, their 

prevalence at the refuge suggests that substantial 

population reductions and other negative wildlife 

health effects are possible if more serious ungulate 

diseases were introduced to the refuge. For example, 

chronic wasting disease, bovine tuberculosis, malignant catarrhal fever, and foot-and-mouth disease 

have not been documented in the Jackson elk herd, 

but could have serious negative population effects at 

current elk densities. Likewise, bovine tuberculosis, 

bovine paratuberculosis, malignant catarrhal fever, 

and foot-and-mouth disease could pose significant 

threats to bison populations on the feedgrounds if 

these diseases were introduced.

During routine monitoring of cutthroat trout in 

2003, tissue samples sent to the WGFD lab tested 

positive for Myxololus cerebralis, the parasite that 

causes whirling disease. Infection levels were low 

and no declines in the cutthroat trout population have 

been documented. 

Amphibian monitoring on the refuge occurs at a 

finer temporal and spatial scale than other amphibian 

monitoring in the region (Patla 2009). As a result, 

amphibian monitoring functions as an early warning 

system for declines in amphibian populations and 

disease outbreaks. These monitoring efforts are particularly important given the detection of chytridiomycosis (chytrid disease) on the refuge. Chytrid 

disease is a fungal skin disease that has been implicated in amphibian population declines worldwide. A 

boreal toad collected on the refuge in 2000 was the 

first documented occurrence of the disease in northwestern Wyoming. Unlike infected amphibian populations in other areas, amphibians in northwestern 

Wyoming have not experienced catastrophic declines. 

However, the effects could be chronic and, therefore, 

continued monitoring is necessary to evaluate the 

effects of the disease on regional populations.

Conserving Wide-Ranging 

Wildlife

The refuge provides habitat for several wideranging wildlife species including elk, bison, bighorn 

sheep, pronghorn, moose, gray wolf, and grizzly bear. 

The refuge supports the preservation of the large 

landscapes that these species require. With longdistance mammal migrations imperiled around the 

globe, the refuge’s importance in sustaining these 

phenomena is critical. The success of wolf restoration 

in the Greater Yellowstone Ecosystem continues to 

be a major issue for many of the citizens of Wyoming. 

The National Elk Refuge provides an excellent location and ideal habitat for seasonal occupation by 

wolves and, in recent years, has hosted a denning 

pack of wolves during the winter, spring, and summer months. These wolves have a large home range 

that contains substantial amounts of nonrefuge Federal, State, and private lands, where they can come 

into conflict with privately owned livestock.

Managing Habitat for Migratory 

Birds

Protecting habitat and managing for a wide variety of migratory birds is a priority for the refuge. 

Waterfowl and other waterbirds, grassland songbirds, and riparian-dependent birds are some of the 

highest priority groups.

Wildlife Disease

The supplemental feeding program has maintained artificially high densities of elk for almost 100 

years and artificially high densities of bison for more 

than 30 years. Biologists from the refuge and WGFD 

evaluate several factors to decide whether feeding is 

needed and, if so, when it should begin and end. The 

feeding start date primarily depends on the amount 

of standing forage that is accessible to elk, which is 

influenced by forage production the previous growing 

season, elk and bison numbers, the timing of migration, winter temperatures, and snow conditions. 

Feeding typically ends within 1 week of the first day 

that snow has completely melted on the southern end 

of the refuge.

Feeding is a strategy designed to support elk 

population objectives and reduce damage to surrounding private lands, but it has unintended management and disease consequences. Feeding is used 
Chapter 2—The Refuge 29 

BJ Baker / FWS

Historic Miller Ranch in the morning.

opment of a multi-use pathway next to Highway 

26/89/191 and its potential impacts on ungulate 

migration, invasive plant species introduction, and 

disturbance of breeding birds; and (3) the ongoing 

effects of the supplemental feeding program on 

breeding bird habitat and wildlife diseases. These 

are valid concerns that would require more staff and 

money to effectively monitor the effects of these management activities over time.

Human–Wildlife Conflicts

Wildlife that winter on the refuge can cause 

human–wildlife conflicts when they venture off the 

refuge and into the developed Jackson area. Of greatest concern are bison, which are large and sometimes 

bold animals that can exhibit aggressive behavior 

and be a serious threat to human safety and property. Elk have left the refuge in the past; in January 

2006, a radio-collared elk left the refuge and went to 

a livestock feedline. Elk can create conflicts, mostly 

as a traffic hazard as they cross heavily used highways or pathways when moving onto the refuge, 

although they can also cause property damage and 

threaten human safety in certain situations.

Insufficient Research, Inventory, 

and Monitoring

Artificial concentrations of high densities of elk 

and bison, because of supplemental feeding and habitat enhancement, provide unique opportunities to 

evaluate the effects of these management activities 

on vegetation, ungulate habitat use, breeding bird 

populations, and wildlife diseases.

The refuge facilitates regionally important cooperative research and monitoring including amphibian 

population monitoring, greater sage-grouse habitat 

use and demography, mountain lion research, bighorn 

sheep habitat selection and migration, and invasive 

plant monitoring. Given potential threats associated 

with climate change and invasive species, more 

inventory work is necessary to assess the baseline 

presence and abundance of certain taxonomic groups 

including invertebrates, rodents, bats and owls. 

Members of the public, representatives from nonprofit conservation organizations, and staff from 

other agencies have expressed concern that inventory and monitoring efforts are insufficient to evaluate the effects of current and proposed management 

activities. Principal concerns are related to (1) the 

irrigation system expansion and its effects on hydrology, amphibians, and ground-nesting birds; (2) devel-
30 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Management of Other Uses

There are several other public uses that demand 

extensive time by our refuge staff to coordinate and 

carefully manage to protect refuge resources and 

keep the public safe.

North Highway 89 Pathway

The North Highway 89 Pathway provides an 

opportunity for the public to enjoy the beauty of the 

National Elk Refuge and observe much of the wildlife 

that makes Jackson Hole so special. Some of the public would like us to extend the use of the bike path by 

eliminating or modifying the seasonal closure. However, the seasonal closure is part of the agreement 

with Jackson Hole Community Pathways to mitigate 

for wildlife disturbance and is believed to be an 

essential requirement for this activity to be compatible with the refuge purposes.

Public Use of North Park

The refuge’s North Park provides a shelter and 

picnic tables to support wildlife-dependent recreation 

at the refuge, for use on a first-come, first-served 

basis. North Park is a small area on the refuge that is 

so close to town that it appears to be part of Jackson. 

In fact, we have a memorandum of understanding 

with Jackson to maintain the lawn, picnic tables, and 

shelter. The memorandum of understanding also 

allows Jackson to conduct a reservation system for 

private use of the shelter for weddings and other 

events; Jackson charges a fee for the reserved use 

and keeps the fee. However, these uses do not support wildlife-dependent recreation, and reserving the 

area may hinder the experience of people visiting the 

refuge for activities such as wildlife observation. 

Special Use Permits

Because of the refuge’s location in the scenic, 

highly visited Jackson Hole, the staff receives a high 

volume of requests for special uses of the refuge. The 

refuge issues approximately 40 special use permits 

annually. Most of these permits are issued to wildlife 

auto-tour companies, fishing outfitters and guides, 

and commercial filmmakers and photographers.

The refuge receives an extensive amount of local, 

regional, national, and international media attention, 

especially during the winter season. Media coverage 

includes print, electronic, and video and film venues. 

Because the area is a focus of media attention and 

millions of people visit this area each year, the 

National Elk Refuge has the opportunity to embody 

our mission as an ambassador for the Refuge System. 

Hunting Management

Although hunting is the primary means of meeting herd objectives, a need was identified to consider 

the negative visual effect of hunters killing elk and 

seeing dead elk as they are transported off the refuge. Some individuals expressed a desire to prohibit 

hunting on the refuge; others desire a limited waterfowl hunt for population control of resident Canada 

geese. Some people would like the CCP to include 

monitoring the use of lead shot for waterfowl hunting 

(if it were allowed) and the subsequent impacts on 

bald eagles. However, mandatory State regulations 

already require the use of lead-free ammunition.

Increasing Demand for 

Environmental Education and 

Interpretation

The refuge cannot meet the high public demand 

for environmental education and interpretation programs with the current staff level. We need more 

interpretative staff and public facilities with adequate program areas.

Operational Efficiency of the 

Jackson Hole and Greater 

Yellowstone Visitor Center

During the peak summer season, visitation can 

reach 2,400 people per day, or roughly 3.6 visitors per 

minute, at the Jackson Hole and Greater Yellowstone 

Visitor Center (visitor center). With only one staff 

member assigned to the facility, staff levels are not 

adequate to maintain, run, and staff the busy visitor 

center. Rather than seasonally increasing Government staff or hiring employees funded through nongovernmental sources to enhance public use 

programs, the refuge solely relies on residential volunteers to provide interpretive and educational services. It is important to have adequate permanent 

refuge staff at the visitor center to guarantee consistent service, to recruit and manage volunteers, and 

to provide interpretive programming. Also, the current building is old and needs to be replaced to meet 

the customer service demand and to comply with the 

Architectural Barriers Act Accessibility Standard 

(United States Access Board 2013). Previous condition assessments identified many of the visitor center’s features as poor or unsafe.
Chapter 2—The Refuge 31 

bicycling. Many pedestrians walk several abreast or 

do not move to the side of the road when vehicles are 

present, causing drivers to move into the oncoming 

lane to pass. 

A regulation panel at the refuge entrance and literature available to the public states that stopping or 

parking a vehicle on Elk Refuge Road is prohibited; 

however, many cars, vans, and trucks park in the 

road when wildlife is present near the roadway 

rather than using the turnouts. In some cases, traffic 

traveling in both directions stop on the road, 

obstructing the free movement of other vehicles and 

creating safety hazards. Furthermore, roadway congestion is a safety concern in bad weather when there 

may be icy road conditions or limited visibility 

because of fog, rain, or snow. 

Access for Boating

Public comment received during the CCP scoping 

process requested that boat use be allowed on Gros 

Ventre River segment upstream from the town of 

Kelly. The northern boundary of the refuge is the 

Gros Ventre River, and the northeastern corner of 

the refuge is used as a takeout point by boaters floating downstream from Slide Lake. Less frequently, 

boat traffic continues downstream to the town of 

Kelly. However, the refuge and the Grand Teton 

National Park consider this part of the Gros Ventre 

River to be closed to boating. The segment of the 

river from the Jump Rock takeout site to the town of 

Kelly was recently designated as scenic under the 

Craig Thomas Snake Headwaters Legacy Act of 

2008. The act requires the refuge and the park to 

create a comprehensive river management plan to 

guide the management of each segment designated 

as wild, scenic, or recreational to protect the “outstandingly remarkable values” of the river. 

The proposed use of boating was reviewed during 

development of the Snake River Headwaters Comprehensive River Management Plan. The prohibition 

against boating on the portion of the Gros Ventre 

River that serves as the common boundary between 

the refuge and the park will be retained.

Access to the National Forest

Because the Bridger-Teton National Forest lies 

adjacent to the refuge, some users want to access the 

forest through the refuge. Open portions of Elk Refuge Road allow the public seasonal access to national 

forest lands, including designated routes to reach the 

forest on foot or by vehicle. Allowing limited access 

to the national forest, either by road or trail, shows 

good cooperation between two Federal agencies and 

extends a convenience to forest users.

The refuge staff has an extensive workload to 

properly evaluate, process, and monitor special use 

permits and filming requests. Because of the volume 

of requests the refuge receives for activities such as 

special access and photography in closed areas, discretion must be used to accommodate a request even 

if the activity is compatible. When considering a special use request, the refuge staff must decide not only 

if the single activity can be accommodated, but 

whether or not it is feasible if multiple parties make 

the same request. Furthermore, there is a need to set 

standards for consistent evaluation of the special use 

requests that we allow and to give groups equal 

opportunities to gain permits. 

Swimming 

At the northeastern corner of the refuge, there is 

a feature known as the Gros Ventre River “jump 

cliff.” Here, swimmers jump off of cliff rocks in 

Grand Teton National Park into the Gros Ventre 

River and into the jurisdiction of the refuge. Technically, when the diver hits the water, they are trespassing onto the refuge and participating in an 

activity that we have not determined as a compatible 

use of the refuge. A further complication is that the 

public does not clearly understand the boundary 

between the park and the refuge. Swimming is not a 

wildlife-dependent recreational use.

Access

The refuge has high demand for various types of 

access as described below.

General Access 

There is a concern that only hunters and anglers 

are allowed access to the refuge, with birdwatcher 

and other user groups not having equal opportunity 

to use the refuge for other wildlife-dependent purposes such as birding and wildlife observation. The 

need to provide free access to the refuge for other 

user groups was identified.

Elk Refuge Road

Elk Refuge Road is the primary access to the refuge and the only legal entrance to the refuge for the 

public. The refuge struggles with management of 

traffic on Elk Refuge Road because of its mixed use 

by pedestrians, vehicles, service trucks, and large 

equipment. Because of the ease of access to the refuge and its proximity to town, local residents use Elk 

Refuge Road extensively for walking, jogging, and 
32 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Bald Eagle

Lori Iverson / FWS

project in the summer of 2007, no substantial work 

has been completed on any of the structures. The 

upper floor of the barn has outstanding potential for 

use as an interpretive site and location for programs 

and events, but the foundation has experienced substantial settling and cracking. Stabilization and restoration will be necessary before the building could 

be used as a site for interpretive programs. We will 

need to find funding opportunities other than the 

refuge’s base funding to restore the historic structure and prevent further deterioration of the 

structure.

Lack of Resources to Administer 

the Refuge

Money and staff are not sufficient to fulfill the 

purposes and meet the goals of the refuge. In addition, visitor numbers and associated demands are 

expected to increase in coming years. Consequently, 

less will get done with a corresponding decline in 

programs, infrastructure, and facilities. The refuge 

has 10.5 permanent full-time equivalent (FTE) positions, a measure indicating the amount of available 

workforce on the refuge, and approximately 0.5 seasonal FTE. Refuge staff needs to identify and set 

Presently, the refuge allows antler hunters to 

park and camp overnight on Elk Refuge Road on 

April 30 to await the lifting of the national forest closure (for wintering wildlife) where the public enters 

the forest to collect antlers. At 8 a.m. on May 1, refuge staff caravans 100 or more vehicles through the 

refuge to the boundary of the national forest. The 

overnight parking creates some resource damage, 

requires us to increase our law enforcement presence, costs us a significant amount of money to manage, and may be an incompatible use of the refuge.

Public Outreach Opportunities

The National Elk Refuge is featured in many 

newspapers, Web sites, and other publications each 

year. These articles are reviewed for accuracy whenever possible; when the media does not directly speak 

to a refuge staff member, or when staff resources are 

insufficient to meet or speak with the media contact, 

erroneous information is common.

People living in or visiting Jackson Hole are easily 

confused about the differences among Federal land 

management agencies and how their missions and 

public use opportunities can greatly vary. Neighboring Grand Teton National Park and Bridger-Teton 

National Forest are areas with many more non-wildlife-dependent recreational opportunities for the 

public such as boating, mountain biking, swimming, 

and hiking. Conflicts can arise when a public use is 

denied or restricted on the refuge, especially when 

the same recreational opportunity is allowed under 

another nearby Federal jurisdiction. Consequently, 

the National Elk Refuge can seem excessively 

restrictive without a better understanding of its mission and the prominence of its “wildlife first” guiding 

principle.

The National Elk Refuge has made it a public outreach goal to continue to write articles, conduct 

interviews, and use other sources to share information about refuge projects or management issues. 

Staff limitations and workloads limit this specific 

type of outreach and have precluded incorporating 

new technologies into information dissemination. The 

visitor services staff bought software to produce 

short video segments, but allocating work time for 

training and production has not yet been a priority.

Miller House Restoration

The historic Miller Ranch has three main structures: the house, the barn, and the USDA Forest 

Service cabin. Other than a 2-week rehabilitation 
Chapter 2—The Refuge 33 

rides are integral to wildlife observation, photography, interpretation, and environmental education 

programs and generate revenue used to enhance 

these programs.

The refuge has enjoyed a 55-year partnership 

with the Jackson District Boy Scouts. In addition to 

clearing much of the refuge of antlers that are a hazard to refuge vehicles, 75 percent of the proceeds of 

the annual Boy Scouts of America Elk Antler Auction are returned to the refuge for habitat management-related expenses.

Refuge Management Effects on 

the Jackson Economy

Employment and nonsalary refuge expenditures 

(maintenance and operations) benefit the local community, county, and State in the form of income, jobs, 

taxes, and personal spending. The refuge plays an 

active, albeit small, role in economic development in 

the local economy. The National Elk Refuge attracts 

many visitors and tourist dollars to the local community of Jackson. The national prominence of the 

refuge and its proximity to Jackson ensures that 

many Jackson Hole visitors either directly or indirectly use the refuge, but actual dollars generated 

from the refuge are minor. However, any changes to 

refuge management are perceived by some people to 

affect the economy of Jackson.

Issues Outside the Scope of the 

CCP

Although the public identified elk and bison management as an issue during scoping for the CCP, the 

issue is outside the scope of this CCP process. Managing elk and bison in this area was recently 

addressed in an interagency process following the 

National Environmental Policy Act that had extensive public involvement; the resulting Bison and Elk 

Management Plan was completed in 2007. The plan 

has goals, objectives, and strategies for managing elk 

and bison on the National Elk Refuge and Grand 

Teton National Park. Supplemental winter feeding of 

the elk herd is addressed in the Bison and Elk Management Plan.

Some people felt the State of Wyoming should 

manage the National Elk Refuge instead of our 

agency. Divestiture of a national wildlife refuge 

requires an act of Congress; therefore, this is outside 

the scope of the CCP.

priorities for unfunded needs to be able to compete 

effectively for more money within our agency and 

from partners and other sources. Creative partnerships and volunteer assistance, although helpful, are 

not a complete or reliable solution and require substantial staff time. With more resources, we could 

accomplish more of the CCP’s goals and objectives.

Stronger Programs Through 

Partnerships

The National Elk Refuge has many opportunities 

for partnerships because of the popularity of Jackson 

Hole and the many nongovernmental organizations, 

tourism operators, and interested public in the area. 

Furthermore, there are several governmental agencies—Teton County, National Park Service, and 

USDA Forest Service—that have land management 

responsibilities around the refuge. Maintaining a 

strong partnership network including private landowners, public agencies, and nonprofit organizations 

is integral to accomplishing our mission of conservation. Partners provide financial assistance, technical 

assistance, and help with planning and implementation. Partnerships and management coordination 

with public and private partners is important 

because refuge operations can have substantial 

impacts on surrounding lands.

The refuge shares the responsibility of managing 

wildlife with the State of Wyoming. Close coordination with WGFD enables refuge programs to complement the State’s wildlife goals and objectives. This is 

especially critical in the management of the migratory elk and bison herds. Collaboration with WGFD 

on harvest goals, permits and licenses, law enforcement, and disease monitoring are important for the 

effective management of these herds.

To enhance Flat Creek for native cutthroat trout 

(Biota 2013a, 2013b), the refuge is collaborating with 

several organizations: WGFD, Jackson Hole Trout 

Unlimited, Rocky Mountain Elk Foundation, and 

Snake River Fund.

The town of Jackson shares its boundary with the 

refuge and both are located within Teton County. 

Regular communication with elected officials from 

the town and county helps diffuse ongoing residential 

development and public service expansion pressures. 

Refuge management actions must consider the residential water facilities for the town and a multi-use, 

nonmotorized pathway for Teton County that are 

located on the refuge.

Winter sleigh ride interpretive tours are conducted through the Grand Teton Association by a 

private concessionaire. The visitor center and sleigh 

National Forest, including the nearby Gros Ventre 

Wilderness.

The National Elk Refuge is 6 miles at its widest 

point and 10 miles from southwest to northeast, with 

elevation ranging from 6,200 to 7,200 feet. The northern half of the refuge consists of steep rolling hills. 

The southern half is glacial washout material, with 

one resistant formation (Miller Butte) rising approximately 500 feet above the valley floor. The refuge, 

along with Grand Teton National Park, John D. Rockefeller, Jr. Memorial Parkway, and Yellowstone 

National Park, is part of a larger area referred to as 

the Greater Yellowstone Ecosystem.

The following sections describe aspects of the 

physical environment that may be affected by implementation of the CCP:

■ climate

■ land features

■ soils

■ water resources

■ air quality

■ visual resources

This chapter describes the characteristics and 

resources of the National Elk Refuge, Wyoming, 

under these topic headings:

3.1 Physical Environment

3.2 Biological Resources

3.3 Management Tools

3.4 Human History and Cultural Resources

3.5 Special Management Areas

3.6 Visitor Services

3.7 Socioeconomic Environment

3.8 Operations

3.1 Physical Environment

Within Teton County, Wyoming, the town of Jackson borders the refuge on the south, and the town of 

Kelly lies near its northern boundary. Lands to the 

south and west are mostly privately owned. East of 

the refuge are lands administered by Bridger-Teton 

Ann Hough / FWS

Bighorn Sheep

Chapter 3—Refuge Resources and 

Description
36 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Carbon sequestration constitutes the primary, 

climate-related effect to be considered in planning. 

One of our activities in particular—prescribed fire—

releases carbon dioxide directly to the atmosphere 

from the biomass consumed during combustion. However, there is no net loss of carbon because new vegetation quickly germinates to replace the burned-up 

biomass. This vegetation sequesters an approximately equal amount of carbon as was lost to the air 

(Dai et al. 2006).

Several scientific studies report that, in the past 

century, the climate is becoming warmer and drier in 

northern Yellowstone National Park (Balling et al. 

1992a, 1992b). If this warming trend continues, it 

could have far-reaching effects on the plants and animals of the Greater Yellowstone Ecosystem (Romme 

and Turner 1991).

Analysis of precipitation records from 1921 to 

2002 gathered by a National Oceanic and Atmospheric Administration weather station in Jackson, 

Wyoming, showed no significant trends, either 

increasing or decreasing (Smith et al. 2004). 

Although temperature readings from 1931 to 2002 

increased, there was a “minor decline in drought conditions,” per calculations using the 1949–2001 

Keetch-Byram Drought Index values that evaluate 

upper-level, soil moisture content (Smith et al., p. 98).

Land Features

The National Elk Refuge is centrally located in 

Jackson Hole in northwestern Wyoming. The refuge 

ranges from 6,200 to 7,400 feet above sea level and is 

bordered by the town of Jackson to the south, private 

ranchlands and subdivisions to the west, Grand 

Teton National Park to the north, and national forest 

lands of the Gros Ventre Mountains to the east. Topographic, hydrologic, and soil features interact to 

influence the species composition of plant communities on the refuge. The refuge comprises seven main 

topographic zones: 

■ Gros Ventre Hills

■ foothills of the Gros Ventre Mountains

■ Miller Butte

■ Poverty Flats alluvial plain 

■ Flat Creek Marsh

■ Flat Creek riparian zone

■ Gros Ventre River riparian zone

The northern third of the refuge is dominated by 

the Gros Ventre Hills. These relatively steep, rolling, 

sedimentary formations range in elevation from 

6,300 to 7,200 feet. The Gros Ventre Hills support 

native wheatgrass and needlegrass communities on 

Climate

The valley known as Jackson Hole is characterized by long, cold winters with deep snow accumulations and short, cool summers. Prevailing winds in 

the valley come from the southwest but strong winds 

are relatively rare.

Temperature

January is the coldest month with an average 

daily maximum temperature of 24 °F and an average 

daily minimum temperature of 1 °F at low elevations. 

Temperature extremes vary from summer highs of 

92–98 °F to winter lows of –40 to –52 °F.

Precipitation

Precipitation levels are relatively steady throughout the year, with a total average annual accumulation of 15.2 inches in Jackson Hole. Average monthly 

precipitation levels range between 1 and 2 inches, 

with May and December being wettest and July and 

February driest. Jackson Hole averages 90 inches of 

snowfall per year, accounting for 60 percent of annual 

precipitation. Snow pack depth of 6–18 inches in 

southern parts of the refuge and 48 inches in the 

northern half are common. Maximum snow depth is 

reached between March 15 and April 1 (Martner 

1977).

Climate Change

The U.S. Department of the Interior issued an 

order in January 2001 requiring Federal agencies 

under its direction that have land management 

responsibilities to consider potential climate change 

effects as part of long-range planning endeavors. The 

U.S. Department of Energy’s report, Carbon Sequestration Research and Development (1999), concluded 

that ecosystem protection is important to carbon 

sequestration and might reduce or prevent loss of 

carbon stored in the terrestrial biosphere. The report 

defines carbon sequestration as “the capture and 

secure storage of carbon that would otherwise be 

emitted to or remain in the atmosphere” (1999).

The increase of carbon dioxide within the earth’s 

atmosphere has been linked to the gradual rise in 

surface temperature, commonly referred to as global 

warming. Vegetated land is a tremendous factor in 

carbon sequestration. Large, naturally occurring 

communities of plants and animals that occupy major 

habitats—grassland, forest, wetland, tundra, and 

desert—are effective both in preventing carbon 

emission and in acting as biological scrubbers of 

atmospheric carbon dioxide.
Chapter 3—Refuge Resources and Description 37 

and sandbar willows. Where Flat Creek flows over 

the western portion of the alluvial plain, only sparse, 

mature narrowleaf cottonwoods exist. The lack of 

regenerating aspen and other understory shrubs in 

this area has been attributed to browsing and rubbing damage from elk and bison (Smith et al. 2004). 

(Note: The above description is paraphrased from 

Smith et al. 2004.)

Soils

More than 20 different soil types are found on the 

National Elk Refuge (Young 1982). Soils at lower 

elevations are alluvial (transported by stream or 

river), generally sandy loam or loam, and are shallow 

and permeable. Soils at higher elevations are also 

loamy, with considerable areas of gravelly soils and 

cobblestone on south-facing slopes and ridges. 

Greyback gravelly loam—a deep, somewhat 

excessively drained soil—occurs in irrigated areas of 

the refuge. About 20 percent of the irrigated area 

has a cobbly loam surface layer but is otherwise similar to Greyback gravelly loam. Permeability is moderately rapid, and available water capacity is low. 

Roots penetrate to a depth of 60 inches or more. On 

0- to 3-percent slopes, the surface runoff is slow, and 

the erosion hazard is slight. On 3- to 6-percent slopes, 

the surface runoff is medium, and the erosion hazard 

is moderate.

south aspects, with mixed communities of mountain 

snowberry, rose, and sagebrush in sheltered draws 

with deeper soils. North aspects support aspen and 

some mixed-conifer stands of Douglas-fir lodgepole 

pine and limber pine. Scattered stands of Rocky 

Mountain juniper grow on some rocky slopes. Lower 

elevation draws are dominated by mountain big sagebrush, threetip sagebrush, and grassland communities. Similar vegetative features are found on 

foothills of the Gros Ventre mountains on the eastern 

border of the refuge and on Miller Butte, a 1,300-acre 

formation on the southern end of the refuge that rises 

500 feet above the valley floor.

A gently sloping alluvial plain, called Poverty 

Flats by early homesteaders because if its poor agricultural potential, is the principal topographic feature in the east-central portion of the refuge. This 

area consists of shallow soils that overlay glacially 

deposited cobble. Before Euro-American settlement, 

the alluvial plain was likely covered by mountain big 

sagebrush and dry native grassland. Currently, the 

area is a mixture of native dry grassland, crested 

wheatgrass, and nonnative cultivated grassland, with 

only small pockets of mountain big sagebrush limited 

to areas of deeper soil and snow accumulation. 

Approximately 2,700 wetland acres form the 

southwestern corner of the refuge. Flat Creek, Nowlin Creek, Twin Creek, and ground water originating 

from porous carbonate rocks to the east of the refuge 

feed the wetlands (Galbraith et al. 1998). In addition 

to these natural sources, the Flat Creek Marsh typically receives irrigation diversion water from the 

Gros Ventre River from May through July via the 

Boyle Ditch, which serves private water users downstream of the refuge. There is an elevation gradient 

to the wetlands of the Flat Creek Marsh that affects 

soil moisture and plant communities. The highest 

elevations next to the alluvial plain host wet meadow 

plant communities of Kentucky bluegrass, tufted 

hairgrass, meadow foxtail, and timothy grasses. Midelevation wetlands are dominated by shrubby cinquefoil, rushes, sedge species, and several species of 

willow. However, willows growing in these areas are 

mostly less than 1.5 feet in height and do not form a 

significant portion of the canopy cover due to browsing by elk and bison (Anderson 2002, Smith et al. 

2004). The lowest elevation areas in the wetland consist of open water and cattail–bulrush marsh.

The riparian zones of the Gros Ventre River and 

the portion of Flat Creek that flows over the alluvial 

plain are characterized by braided stream channels 

and cottonwood woodland plant communities. The 

Gros Ventre River bordering Grand Teton National 

Park and the easternmost portion of Flat Creek on the 

refuge support multi-aged communities of narroweaf 

cottonwood with shrub understories of chokecherry, 

serviceberry, rose, gooseberry, and Bebb, greenleaf 

Lori Iverson / FWS

Elk
38 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

facilities, visitor use, and transportation corridors in 

the recharge areas (parts of the aquifer where water 

moves downward toward the water table).

Gros Ventre River

The Gros Ventre River, which drains approximately 600 square miles of eastern Jackson Hole and 

the mountains farther east, is the largest watercourse on the refuge. The relatively wide river channel is heavily braided in areas where geologic 

materials are of low erosional resistance, as is the 

case on the refuge. The many gravel bars in the river 

channel have little or no vegetative cover because of 

annual flooding and erosion.

Flat Creek

Flat Creek originates in the Gros Ventre Range 

east of the refuge and drains approximately 120 

square miles. The Flat Creek drainage is a broad valley setting with expansive wetlands. The wide valley 

floor has gentle elevation relief and is made of materials deposited from river and lake processes. The 

natural stable stream channels are slightly 

entrenched, meandering, riffle-pool beds. Flows vary 

seasonally because of runoff, input of irrigation water 

diverted from the Gros Ventre River, diversions by 

irrigators, and losses from infiltration. The porous 

nature of refuge soils through which a section of Flat 

Creek flows causes high infiltration losses and results 

in a seasonally dry channel bed in this area. Nowlin 

Creek is a small spring-fed tributary of Flat Creek. 

From the southeastern part of the refuge, the creek 

flows westerly through four constructed impoundments to its confluence with Flat Creek. 

Flat Creek has experienced direct and indirect 

alteration to its stream form and function from 

changes in hydrological and sediment inputs, installation of instream structures and treatments, and 

nearby land management activities. These structures 

from the 1980s are failing and, in some cases, are 

negatively affecting the stream and associated habitats. In cooperation with WGFD (project lead), the 

refuge is planning restoration and enhancement of 

the creek. After completing a categorical exclusion 

(FWS 2013a) under the National Environmental 

Policy Act, in October 2013 the refuge restored 1 mile 

of Flat Creek, as follows:

■ removed 39 deteriorating instream 

structures

■ removed 347 feet of riprap

■ enhanced 23 riffle and 25 pool habitat units

■ removed 300 square feet of reed 

canarygrass

■ installed 4,184 square feet of woody and sod 

vegetation

■ created 19,000 feet of floodplain

Lori Iverson / FWS

Irrigation 

Water Resources

This section describes the hydrology, water quality, and water rights on the refuge.

Hydrology

Surface hydrologic features on the refuge include 

the Gros Ventre River, Cache Creek, Flat Creek, 

Nowlin Creek, and several other small creeks and 

springs (figure 9). The Gros Ventre River flows westerly and forms the northern boundary of the refuge. 

Flat Creek flows east to west and nearly bisects the 

refuge. Water from Cache Creek reaches the refuge 

by way of an underground diversion that surfaces 

into a cistern located near the refuge headquarters. 

In addition to natural watercourses, there are many 

miles of irrigation ditches. Three wells and an 

enclosed water storage reservoir are used by the 

town of Jackson.

Water-level contours show that ground water 

flows from high areas southwest through the valley 

toward the Snake River. Data for the alluvial valley 

aquifer indicate excellent water quality, supporting 

use for drinking water, recreation, and other commercial uses. Much of the aquifer has high permeability and substantial interconnection to the rivers and 

lakes, making it vulnerable to contamination from 
Chapter 3—Refuge Resources and Description 39 

Figure 9. Map of management units and surface hydrology of the National Elk Refuge, Wyoming.
40 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

could be contributing to the elevated nitrate concentrations, but we need further study.

In 2002, the Teton County Conservation District 

implemented source tracking of fecal coliforms. 

Results from DNA analysis showed that 34 percent 

of the coliforms come from rodents, 13 percent from 

bison, 13 percent from elk, 13 percent from unknown 

sources, 7 percent from canines, and 7 percent from 

birds. Farming practices such as disking, seeding, 

sprinkler and drip irrigation, herbicide and fertilizer 

application, and crop harvesting may affect water 

quality and quantity. 

We consider ground water resources to be high 

quality on the refuge as a whole and not subject to 

septic-related pollution concerns except perhaps 

around the Twin Creek subdivision and other inholdings. Residential and commercial development in 

Jackson and elsewhere in Teton County may cause 

local reductions in ground water quality (Jackson and 

Teton County, Wyoming 1994). Although Jackson and 

surrounding areas use centralized wastewater treatment facilities, the perceived major threat to ground 

water supplies elsewhere in Teton County is pollution 

from individual septic systems (Jackson and Teton 

County, Wyoming 1994).

Water Rights

Table 4 displays the refuge’s water rights. 

Air Quality

In general, the air quality of Jackson Hole is high. 

Airborne pollutants generated by industrial activities pose no significant threats to air quality in the 

valley. However, Jackson Hole is a high-elevation valley surrounded by mountains and is particularly susceptible to air quality problems associated with 

temperature inversions. During periods of high 

atmospheric pressure, dense cold air is trapped near 

the valley floor by upper layers of warmer air. Air 

quality in the southern part of the valley next to 

Jackson might decline as a result of pollutants 

trapped in the lower atmosphere during inversions. 

These pollutants include carbon monoxide generated 

mostly by automobile emissions, dust particles, and 

wood smoke. This pattern may persist for several 

days at a time, but pollutant concentrations are dispersed when weather patterns change, especially 

when accompanied with winds.

Air quality on the refuge, although not measured 

or monitored, is considered good to excellent, with 

low concentrations of pollutants throughout the year. 

However, the lower elevations and southern part of 

the refuge may have periods of reduced air quality 

Springs, Ponds, and Other Water Features

Smaller water features include Twin Creek and 

Holland Spring near the southeastern boundary, 

Romney and Peterson Springs in the western part, 

and other miscellaneous springs, like Pierre’s Ponds, 

Sleeping Indian Pond, and Bill’s Bayou, throughout 

the refuge.

Water Quality

Surface water quality in Teton County is believed 

to be high but can be adversely affected by both point 

source pollution (such as a gasoline station along Flat 

Creek) and nonpoint source pollution (such as overland runoff of fecal matter from winter concentrations of livestock). Urban development has little or no 

potential for influencing surface water quality on the 

refuge. Lower Cache Creek, however, flows through 

Jackson, and a diversion from this watercourse (the 

Cache Creek pipeline) enters the refuge where we 

use it for irrigation. This section could be affected by 

urban runoff, potentially affecting downstream 

water quality (Jackson and Teton County, Wyoming 

1994).

There is no information about water quality in 

Cache Creek near the refuge. However, two ongoing 

studies on sections of the creek flowing through Jackson, closer to its confluence with Flat Creek, found 

that petroleum hydrocarbons from vehicles and 

sodium (probably from compounds used by local road 

departments for ice melting) are entering Flat Creek, 

along with city storm water. A similar situation may 

be occurring on Cache Creek. Zinc, the only heavy 

metal found in storm water samples, is also flowing 

into Flat Creek from the town, but we do not know 

its source (R. Norton, personal communication, as 

cited in FWS 1998). Hydrocarbon input might be 

reduced by using storm water retention cisterns.

Another possible nonpoint source of pollution 

affecting refuge water quality, although not documented as a problem, is the large amount of fecal 

material produced by wintering elk and bison. We 

suspect that the high concentration of waterfowl in 

the Nowlin Marsh area is contributing to decreased 

water quality in the lower section of Flat Creek on 

the refuge.

The Teton County Conservation District has conducted water quality sampling on several sites within 

the refuge (refer to table 3). Nitrates are of particular concern. Although data from 1996 to 2002 showed 

nitrate levels consistently below the U.S. Environmental Protection Agency’s drinking water standards (10 parts per million), detected levels in 1997 

and in 2002 were higher than expected for typical 

western Wyoming waters (R. Stottlemeyer, personal 

communication, 2003; Stottlemeyer et al. 2003). Irrigation, fertilization, and elk and bison fecal material 
Chapter 3—Refuge Resources and Description 41 

management of smoke is incorporated into the planning of prescribed fires, and to the extent possible, in 

suppression of wildfires. Sensitive areas will be identified and precautions taken to safeguard visitors and 

local residents.

Visual Resources

The quality of visual resources is an important 

part of the recreational experience (USDA Forest 

Service 1982). The visual appearance of a landscape 

is often the first thing to which a viewer responds.

The National Elk Refuge, the Grand Teton 

National Park, and the vast expanses of undeveloped 

national forest land surrounding the refuge offer 

spectacular scenic views of the Gros Ventre and 

Teton Ranges, Cache Peak, East Gros Ventre Butte, 

Jackson Peak, Sleeping Indian (Sheep Mountain), 

Snow King Mountain, and the Gros Ventre Hills in 

the northern part of the refuge. The Gros Ventre 

River along the northern refuge boundary supports a 

cottonwood-dominated riparian zone.

from winter temperature inversions and concentrations of airborne pollutants generated by Jackson. 

Current refuge management practices do not 

decrease air quality to any measurable degree. 

Vehicular use of unpaved refuge roads during dry 

summer and autumn periods generates dust but will 

likely have only a negligible lowering of overall refuge air quality.

Fire management activities which result in the 

discharge of pollutants (carbon monoxide (CO), Particulate Matter (PM), and other pollutants from fires 

are subject to and must comply with all applicable 

Federal, State, and local air pollution control requirements as specified in Section 118 of the Clean Air 

Act, as amended, 1990. Air quality is regulated by 

the State of Wyoming Department of Environmental 

Quality (DEQ). The State requires that a permit be 

issued by the DEQ prior to initiating a prescribed 

fire.

The area is currently designated as “Attainment” 

for the Criteria Pollutants—Ozone (O3), Carbon Monoxide (CO), Nitrogen Dioxide (NO2), Sulfur Dioxide 

(SO2), Particulate Matter 10 (PM10), Particulate Matter 2.5 (PM2.5), and Lead (Pb)—by the Environmental Protection Agency (EPA) (EPA 2013). The 

Table 3. Average values of selected water quality factors in or near the National Elk Refuge, Wyoming, 1996–

2002.

Values

Flat Creek control 1 

(number of samples 

tested)

Flat Creek 1 2 

(number of 

samples tested)

Nowlin Creek 3 

(number of 

samples tested)

Flat Creek 2 4 

(number of 

samples tested)

Standard

Temperature 

(degrees Fahrenheit, °F)42.2 °F (8) 45.3 °F (10) 46.5 °F (4) 46.2 °F (11) 68 °F

Dissolved oxygen 

(milligrams per 

liter, mg per L)

11.2 mg per L (7) 10.5 mg per L (9) 9.51 mg per L (4) 9.8 mg per L (10) —

Turbidity (nephelometric turbidity 

unit, NTU)

0 NTU (3) 1.1 NTU (4) 1.4 NTU (4) 26.8 NTU (4) —

Acidity or alkalinity, pH (units) 8.29 units (8) 8 units (10) 8.05 units (4) 8.14 units (11) 6.5–9 units

Nitrate as N (mg 

per L)

less than 0.1 mg per L 

(6) 0.14 mg per L (7) less than 0.1 mg per L (5)

less than 0.1 mg 

per L (7) 10 mg per L

April 2000 sample

Fecal coliform (coliform per 100 milliliters, col per 100 ml)

3 col per 100 ml 53 col per 100 ml 55 col per 100 ml 60 col per 100 ml 200 col/100 ml

Escherichia (E.) 

coli (col per 100 ml) 1 col per 100 ml 45 col per 100 ml 49 col per 100 ml 29 col per 100 ml 126 col/100 ml

1 Near the boundary of the refuge with the Bridger-Teton National Forest.

2 North of the Jackson National Fish Hatchery.

3 Below the third pond, next to the barn and corral.

4 Outside the refuge’s southwestern boundary, below the Dairy Queen, and subject to many outside influences (such as a major 

highway and gas station).
42 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 

Table 4. Water rights owned by the National Elk Refuge, Wyoming.

Priority 

date

Water right 

number1

Structure name or 

type Source

Flow rate3

Use Acres 

irrigated cfs gpm

06/10/1883 TP 10329 Holland No. 1 Ditch South Twin Creek 2.28 — Irrigation, 

stock 160

06/01/1887 TP 10173 Carnes Ditch Flat Creek 2 — Irrigation 140

05/15/1888 TP 10306 Robert E. Miller Cache Creek 

Pipeline 2.28 — Irrigation 160

05/15/1888 TP 10307 Grace G. Miller Cache Creek 

Pipeline 2.6 — Irrigation 182

12/31/1888 TP 10317 Territorial ditch South Twin Creek 1.07 — Irrigation 75

12/31/1888 TP 10318 Territorial ditch South Twin Creek 0.02 — Irrigation 2

05/08/1899 2106 Dewey Ditch Flat Creek 1 — Irrigation 70

02/01/1894 642 Robert E. Miller Flat Creek (Cache 

Creek Pipeline) 1.94 — Irrigation 160

05/28/1894 732 Swamp Ditch Swamp Creek 2.07 — Irrigation 145

05/28/1894 732 Swamp Ditch Swamp Creek 1 — Irrigation 70

02/07/1896 1175 Petersen Ditch Flat Creek 2.91 — Irrigation 204

02/07/1896 1175 Petersen Ditch Flat Creek 2 — Irrigation 140

02/07/1896 1176 Longfellow Ditch Flat Creek 3.18 — Irrigation 223

02/07/1896 1176 Longfellow Ditch Flat Creek 1.14 — Irrigation 80

06/05/1896 1230 Crawford Ditch South Twin Creek 

(Holland Creek) 2.28 — Irrigation 160

08/11/1896 1301 Sheep Creek Ditch Sheep Creek 0.24 — Irrigation 17

05/08/1897 1478 M.C. Ditch Flat Creek 1.9 — Irrigation 133

06/26/1897 1517 Lanigan Ditch Flat Creek 1.28 — Irrigation 90

01/23/1900 2446 Adle Ditch Flat Creek 1.42 — Irrigation 100

04/24/1900 2587 Pettigrew Ditch Spring Creek (Gros 

Ventre River) 2.84 — Irrigation 199

06/18/1900 2667 Hanrow Ditch Warm (Seebolm) 

Springs 0.86 — Irrigation 60

06/18/1900 2668 Romeo Ditch Gros Ventre River 0.32 — Irrigation 22.48

02/25/1901 3036 Paulina Ditch

Valdez and Uncle 

Mike Springs 

(Swamp Creek)

0.35 — Irrigation 25

04/22/1901 3129 Wood Ditch Flat Creek 0.42 — Irrigation 30

04/22/1901 3129 Wood Ditch Flat Creek 1.38 — Irrigation 97

10/11/1901 717E M.C. Ditch Enlargement Flat Creek 0.92 — Irrigation 65

11/06/1901 3534 Elk Ditch Swamp Creek 1 — Irrigation 70

01/17/1902 3680 Sunnyside Ditch White Springs 

(Flat Creek) 1.71 — Irrigation 120

01/17/1902 3681 Botcher Spring Ditch Botcher Springs 

(Flat Creek) 0.5 — Irrigation 35

05/26/1902 839E Romeo Ditch 

Enlargement Gros Ventre River 1.633 — Irrigation 114.46

07/28/1902 886E

Pettigrew Ditch 

Enlargement and Cherry 

Flats Ditch

Gros Ventre River 1.57 — Irrigation, 

domestic 110

11/10/1903 5636 Maggie M. Ditch Flat Creek 1.42 — Irrigation 100

07/18/1904 6133 Spencer Ditch Flat Creek 1.08 — Irrigation 76
Chapter 3—Refuge Resources and Description 43 

Lori Iverson / FWS

Romney Ponds

Table 4. Water rights owned by the National Elk Refuge, Wyoming.

Priority 

date

Water right 

number1

Structure name or 

type Source

Flow rate3

Use Acres 

irrigated cfs gpm

09/07/1905 6847 Ben Goe Ditch Flat Creek 1.71 —

Irrigation, 

stock, domestic120

04/14/1906 1519E Crawford Ditch 

Enlargement South Twin Creek 0.34 — Irrigation 24

04/28/1906 1534E Crawford Ditch 

Enlargement No. 2 South Twin Creek 0.12 — Irrigation 9

09/07/1906 1612E Adle Ditch Enlargement Flat Creek 4.2 — Irrigation 294.25

04/23/1907 1712E Longfellow Ditch 

Enlargement Flat Creek 0.86 — Irrigation 60

07/19/1907 1743E Glidden Ditch 

Enlargement No. 2 Gros Ventre River 0.62 — Irrigation 44

07/24/1908 8619 Lost Springs Ditch Flat Creek 4.35 — Irrigation 305

07/24/1908 8619 Lost Springs Ditch Flat Creek 2.21 — Irrigation, 

domestic 155

10/30/1908 2146E M.C. Ditch Enlargement Flat Creek 0.71 — Irrigation 50

10/30/1908 2146E M.C. Ditch Enlargement Flat Creek 0.47 — Irrigation 33

05/02/1909 9892 Harry R. Robinson Ditch Flat Creek 4.2 — Irrigation 294

12/07/1909 2137E Ben Goe Ditch 

Enlargement Flat Creek 0.57 — Irrigation 40

05/20/1910 9900 McInelly Ditch Flat Creek 2.28 — Irrigation, 

domestic 160

06/10/1910 2374E Lost Springs Ditch 

Enlargement Flat Creek 1.71 — Irrigation 120

06/10/1910 2374E Lost Springs Ditch 

Enlargement Flat Creek 2.28 — Irrigation, 

domestic 160

06/20/1910 9990 Sam’s Ditch Sam’s Springs 

(Flat Creek) 0.07 — Irrigation, 

domestic 5

06/02/1911 10924 Ratcliff Ditch Flat Creek 3.43 — Irrigation, 

domestic 240

06/02/1911 10924 Ratcliff Ditch Flat Creek 3.85 — Irrigation 270

06/02/1911 10924 Ratcliff Ditch Flat Creek 4.43 — Irrigation 310

01/06/1912 11137 Garton Springs Ditch Garton Springs 

(Flat Creek) 0.14 — Irrigation, 

domestic 10

04/11/1912 11291 Edith A. Ferrin South 

Twin Creek Ditch South Twin Creek 0.57 — Irrigation, 

domestic 40
44 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Table 4. Water rights owned by the National Elk Refuge, Wyoming.

Priority 

date

Water right 

number1

Structure name or 

type Source

Flow rate3

Use Acres 

irrigated cfs gpm

12/23/1912 11635 Scott and McBride Ditch Flat Creek 3.71 — Irrigation, 

domestic 260

12/23/1912 11635 Scott and McBride Ditch Flat Creek 3.15 — Irrigation, 

domestic 221

06/11/1913 11884 Pecos Ditch Flat Creek 1.46 — Irrigation, 

domestic 102.6

07/13/1914 12549 Pasture Ditch Flat Creek 0.21 — Irrigation, 

domestic 15

01/13/1915 3106E Pecos Ditch Enlargement Flat Creek 0.57 — Irrigation, 

domestic 40

01/26/1915 13001 Pederson Spring Ditch Springs (Gros 

Ventre River) 0.5 — Irrigation 35

02/04/1915 3124E McInelly Ditch 

Enlargement Flat Creek 1.5 — Irrigation 105

04/24/1917 3772E McInelly Ditch 

Enlargement Flat Creek 2.16 — Irrigation 150

12/24/1917 3867E Adle Ditch Enlargement Flat Creek 0.57 — Irrigation 40

12/24/1917 3867E Adle Ditch Enlargement Flat Creek 0.49 — Irrigation 34

03/10/1927 17277 Haight Ditch Flat Creek 1.29 — Irrigation, 

domestic 90

12/06/1927 17319 Three Springs Ditch2 Sheep Creek — — Irrigation, 

domestic 7

09/17/1934 18537 Shortcut Ditch2 Sheep Creek — — Irrigation, 

stock 360

11/10/1937 5084E Sheep Creek Ditch 

Enlargement2 Sheep Creek — Irrigation 277.7

05/13/1977 6643E Hanrow Ditch Enlargement No. 2

Warm (Seebolm) 

Springs 1.23 — Irrigation 86

02/20/1990 9637R Pierre Reservoir No. 1 Spring Creek — — Wildlife —

03/13/1990 9588R Pierre Reservoir No. 2 Spring Creek — — Wildlife —

03/13/1990 10030R Romney No. 1 Reservoir Gros Ventre River — — Fish, wildlife —

03/13/1990 10031R Romney No. 2 Reservoir Gros Ventre River — — Fish, wildlife —

03/13/1990 10032R Romney No. 3 Reservoir Gros Ventre River — — Fish, wildlife —

03/30/1993 7090E Romeo Ditch 

Enlargement No. 2 Gros Ventre River 24.4 — Fish, wildlife, 

reservoir —

03/30/1993 7091E Romey Springs Ditch 

Enlargement Gros Ventre River 8.56 — Fish, wildlife, 

reservoir —

01/13/1994 10054R Elk Park Pond Reservoir Elk Park Drain — — Fish 0

11/14/2000 UW 130740 Sled No. 1 Well Ground water — 25 Domestic —

02/07/2005 UW 165547 Miller/Shop Well No. 1 Ground water — 23 Miscellaneous —

12/11/2009 UW 191934 Shop Well Ground water — 30 Miscellaneous —

1UW=underground well; TP=territorial proof number for rights established before statehood.

2Supplemental supply.

3cfs=cubic feet per second; gpm=gallons per minute.
Chapter 3—Refuge Resources and Description 45 

duction or pasture for livestock or elk. Smooth brome, 

intermediate wheatgrass, meadow brome, and Russian wildrye are common examples of these plant 

communities on the refuge. While some of these communities have adapted to natural conditions where 

adequate soil moisture exists, most are perpetuated 

by irrigation activities. 

For this analysis, we classified vegetative communities on the refuge into one of six general categories: native grasslands, sagebrush shrublands, 

wetlands (marshlands, wet meadows, and open 

water), riparian woodlands and aspen woodlands, 

conifer forests, and cultivated fields (refer to table 5). 

Appendix D lists the plant species that occur on the 

refuge.

Table 5. Plant community types on the National Elk 

Refuge, Wyoming.

Habitat Acres

Native grasslands 8,092

Sagebrush shrublands 8,010

Wetlands 

Marshlands (630 acres)

Wet meadows (1,720 acres) 

Open water (326 acres) 2,676

Riparian woodlands and 

aspen woodlands 3,227

Conifer forests 160

Cultivated fields 2,400

 Total 24,565

Native Grasslands

Native grasslands are important plant communities on the refuge because they provide winter forage 

for elk and bison, which are primarily grazers. 

Native grasslands occur where there is sufficient precipitation to grow grasses but not trees or where 

drought, frequent fires, grazing by large mammals, 

or human disturbance have prevented trees or 

shrubs from becoming established. Native grasslands, including some bluegrass, wheatgrass, and 

needlegrass species, cover approximately 8,092 acres. 

Except for localized areas, native grasslands are in 

good condition, especially in the northern part of the 

refuge (Eric Cole, biologist, U.S. Fish and Wildlife 

Service, Jackson, Wyoming, personal communication, 

2002).

Most native grassland habitats are dominated by 

native perennial bunchgrass species with native 

woody species such as broom snakeweed and green 

rabbitbrush. There is little invasion by tap-rooted 

forbs between grass plants. Soil between grasses is 

The most prominent view of the refuge, which is 

seen by several million visitors annually as they 

drive to and from Jackson on U.S. Highway 26/89, is 

the expansive Flat Creek Marsh. During winter, 

thousands of elk make the refuge an important visual 

and ecological resource for the region. Although 

bison are fed in areas that are not visible to the public, the public can see bison along the fence north of 

the Jackson National Fish Hatchery and in the 

McBride area before Flat Creek Road is closed in 

December. As the bison herd grows, bison are more 

frequently seen in the southern sections of the 

refuge.

Some refuge features that may detract from the 

visual quality of the refuge, include the following:

■ an 8-foot fence that runs for approximately 

8 miles along the southern and western 

boundaries of the refuge keeps elk and bison 

from entering the town or migrating to the 

cattle ranches in Spring Gulch and reduces 

vehicle–wildlife accidents from animals on 

the highway.

■ a power line that parallels Highway 89 

north of Jackson for about 2 miles

■ feed trucks and feed sheds

■ Jackson National Fish Hatchery, Elk Refuge Road, and refuge housing

3.2 Biological Resources

This section describes the biological resources 

that may be affected by the implementation of the 

CCP. Unless otherwise noted, most of the information is from our unpublished data located in files at 

the refuge headquarters. Descriptions of these topics 

follow:

■ plant communities

■ wildlife

■ federally listed species and Wyoming SGCN

Plant Communities

We classified 33 plant community types on the 

National Elk Refuge, 23 of which are dominated by 

native plants and 10 by nonnative grass species (see 

figure 10). Homesteaders or refuge staff planted nonnative grass plant communities to support hay pro-
46 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Sagebrush Shrublands 

Sagebrush shrublands encompass approximately 

8,010 acres and are scattered throughout the refuge, 

with the largest concentrations in the east-central 

and northeastern parts. Sagebrush shrublands are 

generally tall, dense, and comprised of native species 

in the northern half of the refuge, with some small 

areas in the McBride and Peterson management 

units having shorter, lower density sagebrush (Eric 

Cole, biologist, U.S. Fish and Wildlife Service, Jackson, Wyoming, personal communication, 2002). In 

general, sagebrush stands closer to feedgrounds are 

shorter and less dense. In the southern half of the 

refuge, sagebrush stands are in poor condition 

because of overbrowsing by elk and bison and 

mechanical damage by bison, elk, and feed equipment. Good-condition sagebrush shrubland communities in a late stage of succession have a relatively high 

diversity and cover of herbaceous plants. It is possible that late-seral sagebrush shrublands on the refuge are overrepresented because of a history of full 

fire suppression (the benefits of fire were not considered as part of the suppression strategy).

Sagebrush shrublands usually receive more precipitation (or grow on sites with more soil moisture) 

than grasslands, but less than forested areas. Limited areas of basin big sagebrush have extremely tall 

not eroding on most native grasslands on the refuge. 

Other plant species commonly found in native grasslands include rushes, smooth brome, brome snakeweed, yellow salsify, Junegrass, green rabbitbrush, 

fringed sage, and alfalfa. We consider these communities, while heavily used by elk and bison, to be 

largely representative of historical dry, native grassland plant communities and self-sustaining if new 

infestations of invasive plant species are controlled. 

In the southern half of the refuge, the Poverty Flats 

grasslands receive heavy use by elk and Miller Butte 

receives moderate to heavy use. On the southern end 

of the refuge, there is little residual growth on 

bunchgrasses from the previous year of ungulate 

grazing during the grass dormant season. This 

removal can increase the production of some perennial bunchgrass plants, although standing dead plant 

material has been shown to be beneficial to plant 

health by some authors (Briske 1991, Sauer 1978). 

The grasslands on the northern end of the refuge 

receive much less use by elk and bison because of 

deeper snow and hunting disturbance.

The largest continuous segment of native grasslands is in the center of the refuge: (1) northeast of 

the Nowlin Creek marshlands; and (2) northwest, 

west, and east of Flat Creek Road. This area is being 

invaded by crested wheatgrass, a nonnative grass 

that we once planted on the refuge. 

BJ Baker / FWS

A wetland at Miller Ranch.
Chapter 3—Refuge Resources and Description 47 

Figure 10. Map of plant communities on the National Elk Refuge, Wyoming.
48 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

improve water quality by filtering sediment, pollutants, and excess nutrients from surface runoff. As 

one of the most biologically productive ecosystems in 

the world, the nutrient-rich environment of wetlands 

provides food and habitat for a variety of wildlife.

Wetlands on the refuge are some of the most 

diverse and important in Jackson Hole because of 

their water-regulating functions, visual qualities, and 

importance to wildlife, especially resident and migratory birds. Most wetlands receive moderate to heavy 

winter use by elk but vegetation generally recovers 

its dense and tall condition and largely native species 

composition during the growing season. Bison rarely 

used wetlands in the past but recently have begun to 

graze wet areas next to the Poverty Flats 

feedground and wet meadows near the Jackson 

National Fish Hatchery.

Marshlands

Marshlands are low-lying and concave or occur on 

gentle slopes with seepage. They are inundated frequently or continually with water but are most often 

persistently saturated. Marshes are characterized by 

emergent, soft-stemmed vegetation (such as bulrush, 

cattail, rush, and sedge) that is adapted to living in 

shallow water or in moisture-saturated soils. Springinundated sites, which dry by fall, are also included in 

this category. 

Marshland communities occur on approximately 

630 acres of the refuge and are dominated by bulrush, cattail, and sedge species (Eric Cole, biologist, 

U.S. Fish and Wildlife Service, Jackson, Wyoming, 

personal communication, 2002). These stands develop 

to full stature each year dependent on water availability. In marshland habitats, considerable residual 

material remains under the bases of growing plants 

from the previous years’ herbaceous growth, except 

in areas that have been burned. There are few invasive plant infestations in refuge marshlands.

Wet Meadows

Wet meadow habitats occur on approximately 

1,720 acres on the refuge and are comprised of 

shrubby cinquefoil, sedges, and grasses such as foxtail barley, timothy, Kentucky bluegrass, tufted hairgrass, and common horsetail. Approximately 1,450 of 

the 1,720 acres contain willow plants less than 1.5 

feet tall, indicating that mature willow stands have 

been converted to other plant communities because 

of decades of heavy elk browsing (Smith et al. 2004). 

Large numbers of elk on the refuge prevent these 

suppressed willow plants from growing out of the 

browse zone. However, the root systems of these willow plants remain intact and continue to produce 

suckers. This suggests that these areas could still 

support tall, dense willow communities if they were 

protected from ungulate browsing.

sagebrush plants (in excess of 9 feet tall), but most 

sagebrush communities on the refuge are dense, 

mature stands of mountain big sagebrush less than 3 

feet tall. Communities are made up of shrubs and 

short trees and are fairly open, and there is a diversity of native perennial grasses and native forbs 

growing between sagebrush plants. Common species 

in this vegetative grouping are big and three-tipped 

sagebrush, bluegrass species, snowberry, wild rose, 

and smooth brome. Douglas rabbitbrush is found 

throughout the refuge, but occurs as a subdominant. 

Other plant species commonly found in sagebrush 

shrubland communities on the refuge are needlegrass, wheatgrass, snakeweed, and rubber rabbitbrush.

There is conflicting information on the fire-return 

interval and likely historical density of sagebrush 

stands in the western United States. Knight (1994) 

suggested that, on a regional scale, the overall grassland and sagebrush shrubland landscape may be 

remarkably similar today compared to pre-European 

settlement. Periodic fires produced patches of grassland and young sagebrush intermixed with dense 

older stands, and presettlement fire intervals were 

likely every 20–25 years (Tisdale and Hironaka 

1981). Therefore, full fire suppression on the refuge 

has resulted in larger stands of dense, older sagebrush than pre-European conditions. However, more 

recent work by Bukowski and Baker (2013) suggests 

that the historical fire-return interval in mountain 

big sagebrush stands was 137–217 years. Therefore, 

fire suppression in existing old, dense, tall sagebrush 

stands on the refuge might be an appropriate management strategy to protect a rare plant community 

that is important to greater sage-grouse and other 

sagebrush-dependent species.

Most sagebrush plant communities on the refuge 

fall within the greater sage-grouse core area as 

defined by State of Wyoming Greater Sage-Grouse 

Core Area Protection Executive Order 2011–5. The 

core area encompasses all areas on refuge north of 

Flat Creek, slopes east of the Chambers management 

unit, and the bench above the Jackson National Fish 

Hatchery (WGFD 2011). 

Wetlands 

The National Elk Refuge contains approximately 

2,676 acres of wetlands, including marshlands, wet 

meadows, and open water (see figure 10). Wetlands 

function as a natural sponge that stores and 

recharges ground water supplies. Wetlands moderate 

streamflow by releasing water to streams (especially 

important during drought), and they reduce flood 

damage by slowing and storing floodwater. Wetland 

plants protect streambanks against erosion because 

the roots hold soil in place and the plants break up 

the flow of stream or river currents. Wetlands 
Chapter 3—Refuge Resources and Description 49 

Lori Iverson / FWS

Cottonwood

northern hills of the refuge appear to be declining 

slowly, but some aspen communities escape browsing, 

and stand replacement is occurring periodically. 

Aspen recruitment is prevented by heavy elk browsing on aspen suckers that prevents most suckers from 

growing out of the browse zone. 

Many aspen stems are approximately 120 years 

old, which is approaching the maximum lifespan of 

150 years. Most of these stands will eventually convert to sagebrush shrubland habitat, primarily in the 

form of snowberry and rose stands. A few stands 

may convert to native grassland habitat, depending 

on their location and the understory condition. Findings by Keigley et al. (2009) suggest that limitedscale regeneration of aspen has occurred on the 

northernmost parts of the refuge since 2005. Possible 

but untested explanations of this regeneration 

include changes in ungulate distributions or migration patterns, changes in ungulate numbers, or some 

combination of these factors. Cottonwood and aspen 

saplings grow inside exclosures (fenced areas) on the 

upper section of Flat Creek, indicating that these 

trees can replace themselves if ungulates are totally 

excluded.

Riparian woodlands and aspen woodlands include 

stands of quaking aspen, narrowleaf cottonwood, and 

willows. Mountain big sagebrush, bluegrasses, brome 

Wet meadow communities are dominated by 

nearly 100-percent cover of native sedge species and 

water-tolerant grasses. In some wet meadow habitats, shrubby cinquefoil is a major component of the 

cover. There is often little residual cover because of 

heavy grazing by elk. The amount of residual cover in 

wet meadow communities varies from year to year 

depending on the depth of snow cover and grazing 

pressure. There is little invasion from noxious weed 

species; however, invasive species, such as Kentucky 

bluegrass, fowl bluegrass, and clover are present in 

wet meadow habitats.

Open Water

Open water accounts for 326 acres on the refuge 

and consists of stream and river channels and sites 

where standing water persists through most years, 

including pools and ponds.

Riparian Woodlands and Aspen 

Woodlands

Riparian areas and aspen woodland communities 

occur on approximately 3,227 acres of the refuge. 

These habitat types have been declining in condition 

and acreage throughout refuge history. Riparian 

woodlands and aspen woodlands are particularly 

important as wildlife habitat and have been affected 

by elk and bison browsing.

Riparian woodland habitat consists of approximately 300 acres of willow habitat and about 1,090 

acres of cottonwood communities. Riparian woodlands occur along the Gros Ventre River and Flat 

Creek. Decades of winter browsing by elk have 

reduced these willows to remnant plants less than 18 

inches high. There are 1,450 acres of suppressed willow plants in what are now wet meadow communities, 

but were once willow habitat. Elk browsing in cottonwood communities has removed understory, and 

cottonwood trees are not regenerating. Cottonwood 

stands close to the McBride feedground experience 

higher snag density and higher down woody debris 

cover. Cole (2002a, 2002b) did not find a difference in 

the number of woody plant species in stands closer to 

feedgrounds as compared to stands farther away, but 

total woody cover increased with increasing distance 

from feedgrounds (Smith et al. 2004). 

Aspen woodland habitat consists of approximately 

1,850 acres of aspen-dominated communities on hillsides, usually some distance from water. Aspendominated woodlands are scattered on the Gros 

Ventre Hills throughout the northern part of the 

refuge and on the eastern edge of the refuge in the 

south, next to the Gros Ventre Wilderness. Many 

aspen stands are characterized by mature trees, with 

little if any aspen understory. Aspen stands in the 
50 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Regeneration of young conifer trees appears sufficient to replace existing stands, but subdominant 

species in these communities that are much more 

palatable to elk, such as serviceberry and chokecherry, are heavily browsed and are not regenerating. Other plant species common in conifer forests on 

the refuge are bluegrass species, buffaloberry, pinegrass, mountain boxwood, and snowberry. 

Cultivated Fields

Cultivated fields, which we plant specifically to 

augment native forage that is available for elk in the 

winter, are used extensively by elk and bison. The 

refuge chooses cultivated plant species based on their 

palatability, persistence, ability to compete with 

weeds, low probability that they will invade native 

grasslands, and their ability to stand up after a heavy 

snowfall. Only part of the approximately 2,400 acres 

available for cultivation would likely be cultivated in 

any particular year. Most cultivated fields on the refuge are irrigated using the K-Line irrigation system 

that was installed in 2010, with limited flood irrigation in the Ben Goe and Pedersen management units. 

Ten plant community types are in the cultivated 

fields in the southern and central parts of the refuge. 

Dominant plant species include alfalfa, intermediate 

wheatgrass, Kentucky bluegrass, Russian wild rye, 

smooth brome, and meadow brome. Smooth brome, 

the most common species, provides moderate-quality 

standing forage but is undesirable because of its 

inability to remain erect in heavy snow. Smooth 

brome also requires irrigation in drought years and 

may spread to suitable sites in other cultivated fields 

and native grassland habitats. Experiments with 

other plant species are continuing in an effort to find 

palatable grass species that will meet refuge forage 

production objectives and to assess the practicality of 

restoring native species to some areas. 

Forage Production

Forage production is an estimate of the amount of 

food available to elk and bison produced in a given 

growing season. This includes (1) annual growth of 

trees and shrubs that is less than 8 feet from the 

ground, and (2) herbaceous vegetation such as 

grasses, forbs (nonwoody broad-leaved plants), and 

weeds, which are a subcategory of forbs. Annual forage production mostly depends on the species composition of the plant community, precipitation, the amount 

of water available for irrigation, the number of staff 

members available for irrigation activities, and infestation by insect herbivores such as grasshoppers. The 

time of year that precipitation occurs is also important; rain in the spring and early summer increases 

forage production more than later in the year. 

species, Douglas-fir, pinegrass, rose species, sedges, 

and snowberry in some areas may be codominants 

(those species that influence the kinds of other species that may exist in an ecological community). 

Engelmann spruce trees are scattered throughout 

the woodland stands but are subdominant. Other 

plant species common in riparian woodlands and 

aspen woodlands are bearberry honeysuckle, bitterbrush, buffaloberry, chokecherry, horsetail, mountain 

timothy, muhly, needlegrass, rush species, serviceberry, wheatgrass species, and yellow salsify.

Dobkin et al. (2002) state that willow, cottonwood, 

and aspen stands on the refuge have been modified 

by overbrowsing by ungulates; this is based on historical photographs, written records, and an understanding of the ecology of these communities. Dieni 

et al. (2000) and Smith et al. (2004) also note the 

growing experimental evidence that ungulate browsing is the cause of declines in aspen and cottonwood 

communities. Dobkin et al. (2002) also found that willow sites on the refuge were “mostly poorly functioning or nonfunctioning ecologically.” They concluded 

that although willow habitat is influenced by flooding, 

hydrologic conditions, ungulate use levels, fire frequencies, and precipitation patterns, the decline of 

willows on the refuge appears to be mostly related to 

heavy browsing (28- to 55-percent removal of annual 

growth). The decline of willows along Flat Creek in 

the southern part of the refuge has exceeded 95 percent (Smith et al. 2004). Shrubby cinquefoil, a less 

palatable woody species, is abundant in this prior 

range of willows and has probably increased as willows declined. In contrast, willows in the northern 

end of the National Elk Refuge are moderately 

browsed, and only some willow plants reach their full 

height potential. Growth of new willow stems out of 

the browse zone is sporadic, and there is some space 

between most willow clumps. 

Riparian area restoration will be designed to 

modify bank and streambed structure and will not 

address ungulate browsing of willows or facilitate 

their recovery (Biota 2013a, 2013b; FWS 2013a).

Conifer Forests

Conifer forests on the refuge cover 160 acres and 

consist of Douglas-fir, juniper, lodgepole pine, wheatgrasses, and other plant species. Conifer forests 

occur mostly on the extreme eastern edge of the refuge in the north and in the south on hillsides next to 

Bridger-Teton National Forest and on the northern 

slopes of the Gros Ventre Hills. Elk use the refuge 

forests and the adjacent national forest land for cover 

and shelter from winter storms, and they graze on 

palatable understory shrubs and grasses. Bison 

rarely use conifer stands.
Chapter 3—Refuge Resources and Description 51 

availability and fire regime, and depositing chemicals 

into the surrounding soil that prevent other plants 

from successfully growing in those areas. The result 

is large and expanding single-species stands of vegetation that provide little or no benefit to native wildlife and insects.

Many invasive plant infestations on the refuge are 

a direct result of abandoned livestock feeding areas 

and corrals, old homesites, and roadbeds. At least 19 

species of invasive plants are present (table 7). 

Invasive species reduce the diversity and number 

of native plants and change habitats, such as replacing a grass community with a forb community. Invasive plants do not provide quality winter forage for 

elk and other big game and often modify habitat of 

native wildlife and insects. Studies in Montana show 

that bison and deer reduced their use of a particular 

habitat by 70–82 percent when it was invaded by 

leafy spurge. Elk forage in bunchgrass sites 

decreased by 50–90 percent after a spotted knapweed invasion (Teton County Weed and Pest District 

2002). Invasive plants also fail to protect and hold soil 

because they generally have a shallow root system, 

leading to increased erosion and sedimentation in 

streams. This, in turn, affects water quality and 

decreases fish production.

Crested wheatgrass covers approximately 650 

acres. While this nonnative plant is palatable to elk 

and bison in the spring, it has little nutritional value 

to wildlife as winter forage. Its spread is a concern 

Table 6. Estimates of forage production on the National Elk Refuge, Wyoming.

Type of forage and amount in tons

Year Grass Forb Woody Weed Total Herbaceous

1998 17,655 1,849 1,344 170 21,018 19,647

1999 13,904 1,924 3,120 0 18,948 15,850

2000 9,879 1,304 2,189 116 13,488 11,299

2001 7,641 1,353 2,230 65 11,289 9,059

2002 7,980 1,323 4,571 228 14,102 9,531

2003 5,185 1,307 3,923 218 10,633 6,710

2004 16,324 2,927 5,153 345 24,749 19,597

2005 15,881 2,011 3,998 98 21,988 17,990

2006 12,757 2,523 3,505 187 18,972 15,468

2007 10,019 2,310 2,861 45 15,235 12,374

2008 13,087 3,272 4,009 57 20,425 16,414

2009 15,100 2,524 3,809 11 21,444 17,635

2010 11,374 2,241 2,335 37 15,987 13,653

2011 15,677 3,226 2,445 4 21,352 18,907

2012 9,873 1,800 1,844 7 13,524 11,677

Annual average 12,156 2,126 3,156 106 17,544 14,387

Source: National Elk Refuge, Wyoming, 1998–2012.

Table 6 shows estimates of forage production 

between 1998 and 2012. Not all annual forage production on the refuge is available to, or used by, wintering elk. Factors such as topography, location, snow 

accumulation and condition, species preference and 

palatability, growth form of vegetation, hunting pressure, and other factors work in concert to influence 

forage availability and elk use. Higher annual forage 

production often results in shorter supplemental feed 

seasons, but snow conditions and the number of elk 

and bison occupying the refuge also influence the 

length of the feeding season.

Invasive Plants

Invasive plant infestations cover about 1,100 acres 

of the refuge. Invasive plant species (some of which 

are classified as noxious weeds by the State of Wyoming) are major contributors to the loss of quality 

wildlife habitat and rangeland, second in scope only 

to land development. Invasive species are nonnative 

plants that thrive in early succession plant community conditions where their lack of native controls 

(such as wildlife and insect grazers, fungal infections, 

and disease agents) allow them to outcompete native 

species in colonizing disturbed soil sites. After successful site colonization, invasive plants aggressively 

spread into surrounding plant communities, outcompeting native and crop plants by crowding them out, 

changing environmental conditions such as water 
52 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

the refuge have not substantially affected forage conditions, but spotted knapweed and musk thistle invasions in the park are considered serious (S. Haynes, 

biologist, Grand Teton National Park, Moose, Wyoming, personal communication, 2002). 

Control work can be effective at containing an 

infestation to existing areas, but it generally is not at 

the level required to eradicate large infestations. 

Control operations are expensive, requiring designated staff, equipment, and chemicals. By its very 

nature, control is never complete because an infestation is never eradicated, and any lapse in vigilance 

allows the infestation to spread into surrounding 

areas. Yearly control operations are less expensive 

than large-scale eradication programs but, over the 

long term, can be much more expensive. Herbicides 

are the most effective means of control on invasive 

plants, but some people are suspicious of their use 

and concerned about their effects on the 

environment.

Wildlife

Descriptions of habitat and occurrence follow for 

wildlife at the refuge—mammals, birds, reptiles and 

amphibians, and fishes.

because the refuge is a winter range for ungulates. 

Although grassland condition in crested wheatgrass 

areas is good in terms of relative forage production, 

minimal erosion, and vigorous grass growth, the 

cover in these areas of native grass species has been 

reduced by 50–90 percent and replaced by crested 

wheatgrass (Eric Cole, biologist, U.S. Fish and Wildlife Service, Jackson, Wyoming, personal communication, 2002). Therefore, the invasion of crested 

wheatgrass has the potential to modify the condition 

of native grassland habitats on the refuge.

Cheatgrass has invaded an estimated 250 acres of 

native grasslands on the refuge. This annual grass is 

a prolific seed producer and cures out early in the 

summer, producing sharp, pointed seeds that can 

injure the eyes and mouths of grazing animals. 

Cheatgrass may provide forage for elk and bison in 

the spring during greenup, but has little nutritional 

value as winter forage. It is considered a serious 

problem because the dry grass is highly flammable, 

and after a fire cheatgrass spreads quickly. In the 

past, cheatgrass was not considered a problem in 

Jackson Hole because the climate was too wet; the 

recent drought, however, has allowed cheatgrass to 

expand rapidly. 

The refuge and Grand Teton National Park both 

use biological, cultural, chemical, and mechanical 

means to control invasive plants. Invasive plants on 

Table 7. Noxious weed species on the National Elk Refuge, Wyoming.

Scientific name Common name Range of infestation acreage

Cardaria draba Whitetop 5–30

Carduus nutans Musk thistle 35–125

Centaurea maculosa Spotted knapweed 25–120

Centaurea repens Russian knapweed <1 

Centaurent diffusa Diffuse knapweed <1 

Cirsium arvense Canada thistle 0.1–15

Cirsium vulgare Bull thistle <0.5–10 

Convolvulus arvensis Bindweed <0.1 

Cynoglossum officinale Houndstongue 0.2–2

Hyoscyanus niger Black henbane <0.2 

Lepidium latifolium Perennial pepperweed 0.1 

Leucanthemum vulgare Oxeye daisy <0.1 

Linaria dalmatica Dalmatian toadflax 0.2–2

Linaria vulgaris Yellow toadflax <1 

Matricaria perforata Scentless chamomile <0.2 

Onopordum acanthium Scotch thistle 0.1–1

Sonchus arvense Marsh sowthistle 5–20

Tanacetum vulgare Common tansy <0.5 

Verbascum thapsus Wooly mullein 1–15
Chapter 3—Refuge Resources and Description 53 

and (5) snow conditions. Feeding typically ends 

within 1 week of the first day that snow has completely melted on the southern end of the refuge. 

These conditions correspond with new grass growth 

or sufficient residual forage from the previous growing seasons being exposed by melting snow. Since 

1912, the period of supplemental feeding has ranged 

from “no feeding” to a maximum of 147 days, with an 

average of 70 days annually.

The 2014 winter population classification count for 

the Jackson elk herd was 11,423 animals (A. Courtemanch, biologist, WGFD, Jackson, Wyoming, personal communication, 2014). This is within 5 percent 

of the State’s population objective of 11,000 for the 

herd size. Although the Jackson elk herd as a whole is 

near objective, the winter distribution of these elk is 

weighted heavily toward feedgrounds, and subobjectives for the population have not been met. The winter distribution of elk, including how many are on 

feed on the refuge is heavily influenced by annual 

snow conditions. Table 8 shows population objectives 

and actual population estimates from 2011 to 2014 for 

the Jackson elk herd and for segments of the population based on where elk spend the winter. The challenge to managers in meeting these objectives is to 

reduce the number of elk wintering on the refuge 

while increasing the use of native winter range.

Depending on spring conditions, elk begin leaving 

the refuge in late March and early April, and almost 

all elk have left the refuge for calving and summer 

ranges by mid-May. Historically, it was common for 

100–200 elk to summer on the northern portion of the 

refuge, but currently almost no elk exhibit this 

behavior. The decline in summer resident elk on the 

refuge could be linked to hazing activities by refuge 

staff, the relatively recent presence of denning 

wolves on the refuge, changes in refuge hunting seasons, or some combination of these factors. The refuge focus for elk management is to reduce the 

duration of time that elk spend on the refuge to conserve winter forage, minimize the need for winter 

feeding, and reduce disease risk. Therefore, the 

decline in summering elk is viewed as a positive 

development by refuge managers.

Elk summer in five distinct areas: (1) southern 

Yellowstone National Park; (2) Teton Wilderness; (3) 

Bridger-Teton National Forest south of Teton Wilderness; (4) Grand Teton National Park north of Beaver Creek; and (5) Wilson to Beaver Creek, which 

comprises both private and Grand Teton National 

Park lands. Refuge staff have collared cow elk on the 

feedgrounds since 1978. The proportion of elk that 

migrate long distances from Yellowstone National 

Park appears to have declined over time, while the 

proportion of elk that migrate relatively short distances (Wilson to Beaver Creek) has increased dramatically (Cole and Foley et al. 2015). The shift 

Mammals

Forty-eight native species of mammals inhabit the 

refuge:

■ Elk, bison, bighorn sheep, pronghorn, and 

mule deer are the varied large ungulates 

(hoofed mammals) common on the refuge. 

■ Carnivores include coyote, gray wolf, mountain lion, and black bear.

■ Small mammals are abundant in Jackson 

Hole.

■ Large rodents that occur in Jackson Hole 

are yellow-bellied marmots, porcupines, and 

beavers.

■ Midsize predators inhabiting the refuge 

include badger, bobcat, long-tailed weasel, 

ermine, mink, and bobcat. Raccoon, skunk, 

and red fox are uncommon, perhaps because 

of competition with the coyote.

Elk

Elk are the most abundant large mammal species 

occupying the National Elk Refuge, and their conservation is the reason the refuge was established. The 

creation of Yellowstone National Park in 1872 and the 

National Elk Refuge in 1912 was crucial in terms of 

protecting elk and their winter ranges in Jackson 

Hole. The creation of Grand Teton National Park in 

1929, as well as its expansion in 1950, consolidated 

and protected elk summer ranges in Jackson Hole. 

Supplemental feeding of elk wintering on the refuge was started in 1912 to mitigate the loss of natural winter range and prevent elk from eating 

livestock forage on private land next to the refuge. 

By the 1930s, the feeding program had successfully 

stabilized the elk population. Elk were fed baled hay 

during at least part of most winters from 1912 to 

1975. In 1975, after several years of testing, a switch 

was made to alfalfa pellets (Smith and Robbins 1984). 

“No-feeding years” have occurred irregularly and 

infrequently. Since the refuge was established in 

1912, there have been 9 years when no supplemental 

feed was provided for elk; the last such winter was in 

1980–81.

Biologists from the refuge and WGFD evaluate 

several factors to figure out whether feeding is 

needed, and if so, when it should begin and end. The 

feeding start date primarily depends on the amount 

of standing forage that is accessible to elk, which is 

influenced by (1) the amount of forage produced the 

previous growing seasons, (2) elk and bison numbers, 

(3) the timing of migration, (4) winter temperatures, 
54 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Population Goals

■ The refuge set up a new South Unit elk hunt 

on the refuge.

■ The staff developed the online Refuge Hunting Permit Application System to encourage 

broader participation in the refuge elk hunting program.

■ In 2007–12, we provided recommendations 

and participated in the annual process for 

setting the elk season and harvest objectives with WGFD and Grand Teton National 

Park.

Information and Outreach Goals

■ In 2007, refuge staff developed the Sleigh 

Ride Tour Interpretive Manual for the 

sleigh ride concessionaire to cover key messages of the Bison and Elk Management 

Plan and the Refuge System. Annually, 

20,000–25,000 people take this tour.

■ In 2007, we started an interpretive training 

program for the sleigh ride concessionaire’s 

staff to ensure accurate delivery of key messages from the Bison and Elk Management 

Plan. We conduct this training annually.

■ Since 2007, the refuge has presented programs to key community and conservation 

organizations that included explanations of 

management activities and strategies to 

achieve the goals outlined in the Bison and 

Elk Management Plan. Organizations and 

individuals include Grand Teton Association 

Board of Directors; Jackson Hole Historical 

Society; Jackson Hole Rotary; The Nature 

Conservancy; Teton County Commissioners; 

Wyoming Outfitters and Guides Association; Yellowstone Business Partnership; and 

local, State, and Federal elected officials. 

appears to be a long-term population response, 

rather than individual elk switching summer ranges, 

but the causes of this shift remain unclear. We are 

examining data associated with this phenomenon and 

hope to publish these results. Changes in elk use of 

summer range are important to managers because 

long-distance migration by mammals is imperiled 

globally, plus it will be difficult to reach the refuge 

population objective of 5,000 elk with a growing segment of short-distance migrants. Another factor is 

that the Yellowstone National Park and Teton Wilderness segments are economically important to 

hunting guides and outfitters.

Monitoring focuses on evaluating the management 

strategies designed to meet the objectives of the Bison 

and Elk Management Plan. The primary tasks of the 

refuge’s biological staff are to monitor the following: 

(1) elk and bison populations; (2) forage production 

relative to irrigation and other habitat enhancement 

projects; and (3) variables that determine start and 

end dates of the supplemental feeding program. 

The refuge accomplishments below correspond 

with the elk management topics in the Bison and Elk 

Management Plan:

Habitat Goals

■ In 2007, the refuge reseeded 100 acres of 

agricultural fields to increase production of 

nutritious, palatable natural standing winter forage.

■ From 2007 through 2012, refuge staff annually treated approximately 1,000 acres of 

grasslands with a harrow (a farm implement 

used to break up and even plowed ground) 

to break up accumulations of elk and bison 

manure and to promote grass production.

■ In 2010, we installed a new $5.2 million irrigation system to substantially expand and 

improve irrigation capacity to increase winter forage. Water use was reduced and irrigated acres increased from approximately 

900 acres to 3,300 acres annually. 

Table 8. Winter elk population objectives and actual population estimates for the Jackson elk herd and 

wintering areas from 2011 to 2013. 

Winter range area Number of elk

Herd objective 2011 2012 2013 2014 Average

National Elk Refuge on feed 5,000 7,746 7,360 6,285 8,296 7,422

Gros Ventre drainage 3,500 2,775 3,265 2,982 2,377 2,850

Other winter range 2,500 982 894 1,784 750 1,103

Total 11,000 11,503 11,519 11,051 11,423 11,374
Chapter 3—Refuge Resources and Description 55 

Disease Prevention

■ Beginning in 2007, we annually coordinate 

with WGFD each winter to vaccinate elk for 

brucellosis.

■ The refuge provided money from 2007 

through 2013 to WGFD for hiring technicians to collect samples for chronic wasting 

disease on the refuge and vicinity from 

hunter-harvested elk during the hunting 

season. Most years, testing has been at the 

level of 95-percent confidence of detecting 

chronic wasting disease at 1-percent 

prevalence. 

■ Since 2008, as a standard operating procedure, permanent refuge employees carry a 

firearm in the tractor during supplemental 

feeding. They are instructed to immediately 

shoot any elk that exhibit suspected symptoms of chronic wasting disease. We make 

sure that all elk collected are tested for the 

disease. Employees receive training in identifying the symptoms of chronic wasting 

disease and must pass a firearms proficiency 

test. 

■ In 2009, with the Wildlife Health Office in 

Bozeman, Montana (Tom Roffe), the refuge 

started a long-term project to monitor the 

■ Since 2007, we have implemented new visitor programs to highlight refuge management activities and the above topics. 

Programs include roving naturalist, daily 

visitor center program, wildlife caravans, 

and teacher seminars on refuge 

management.

■ Staff conduct school programs designed to 

build a foundational understanding about 

refuge management and basic elk and bison 

ecology for hundreds of school-age children.

■ Refuge staff discuss refuge management 

goals and practices in news releases and 

articles that we send to an email contact list 

of several hundred people, including elected 

officials, media, and local nonprofit 

organizations.

Supplemental Feeding Program

■ With WGFD, the refuge developed criteria 

to coordinate the seasonal start of the supplemental feeding program. We have successfully used this criteria since the 2008 

feeding season (refuge files). The refuge and 

our cooperators are collecting remote sensing and elk nutritional data to develop criteria to determine the seasonal end of the 

supplemental feeding program. 

Lori Iverson / FWS

Sleigh ride tours enhance the information and outreach goals of the refuge.
56 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

that once roamed much of North America. As bison 

continue to inhabit the landscape of what remains of 

the western frontier, a part of the unique American 

experience is preserved for future generations. This 

section describes (1) bison on the refuge, (2) bison in 

the Greater Yellowstone Ecosystem, and (3) Jackson 

Hole Wildlife Park. 

Bison on the Refuge

The free-ranging bison established fairly welldefined movement patterns in Grand Teton National 

Park, spending summers in area of The Potholes, 

Signal Mountain, and the Snake River bottoms and 

wintering in the Snake River bottoms and farther 

south (see the “Jackson Hole Bison Herd Seasonal 

Ranges” map on page 150 of the environmental 

impact statement [EIS] for the Bison and Elk Management Plan [FWS and NPS 2007b]). During the 

early 1970s, the bison wintered in the river bottoms 

north of the community of Moose and in the Kelly 

Hayfields vicinity, east of Blacktail Butte. Since the 

winter of 1975–76, however, most of the herd has wintered on the National Elk Refuge (except during the 

mild winter of 1976–77).

Our agency has jurisdiction over wildlife including bison on the refuge (16 U.S.C. 668dd) and the 

National Park Service has jurisdiction over wildlife 

in Grand Teton National Park (16 U.S.C. 1). In 2002, 

WGFD and the Wyoming Livestock Board defined 

two “wild bison” management areas, one for the 

Absaroka herd and the other for the Jackson herd. 

The State has jurisdiction over bison from the Jackson wild bison herd in “all lands in Lincoln, Sublette 

and Teton Counties west of the Continental Divide, 

excluding Grand Teton National Park, Yellowstone 

National Park and the National Elk Refuge.”

Bison are counted annually on the refuge in the 

winter and in the park in the summer. WGFD also 

conducts annual aerial surveys of bison on native 

winter range. As of February 2006, the herd numbered 948. Between 1969 and 1985, the refuge did 

little to manage bison. We documented the size of the 

herd and its sex and age composition on an opportunistic basis. A study was initiated in 1997 to find out 

more about bison demography, reproduction, and 

effects of brucellosis on the population.

Soon after the bison began wintering on the 

National Elk Refuge, they discovered the supplemental feed put out for the elk. Although the staff tried to 

haze bison away from the elk feeding areas, our 

efforts were largely unsuccessful. Consequently, the 

refuge staff resorted to liberally feeding bison to 

keep them away from elk feed lines and to reduce 

conflicts. We are concerned about bison wintering on 

the refuge because of (1) increased consumption of 

supplemental feed and the associated cost; (2) conflicts with the elk-feeding program and management 

health of elk and bison herds. The purpose 

of the project is to identify the presence and 

prevalence of all diseases in these herds. 

Also, part of the monitoring project is looking at whether management actions cause 

environmental conditions that increase the 

presence or prevalence of diseases. All elk 

collected for this project are tested for 

chronic wasting disease. From 2009 to 2013, 

145 elk were collected and tested for a variety of diseases.

■ In 2008, the refuge established the Chronic 

Wasting Disease Working Group, comprised 

of land and wildlife management agencies 

that have influence on the Jackson elk herd: 

Bridger-Teton National Forest, Grand 

Teton National Park, National Elk Refuge, 

WGFD, and Yellowstone National Park. The 

purpose of this group is to share information. When possible, we leverage efforts to 

detect the presence of the disease and 

reduce the risk of environmental contamination by chronic wasting disease.

■ One of the outcomes from the Chronic Wasting Disease Working Group is a consensus 

about the importance of increased surveillance for the disease. The Grand Teton 

National Park, WGFD, and the refuge will 

all pursue money for more technicians to 

increase samples from hunter-harvested 

elk. The coordination of this effort and 

potential sharing of these technicians 

between agencies was the topic for the 

working group meeting in March 2009. 

■ The WGFD has provided free testing for 

chronic wasting disease to the refuge and 

Grand Teton National Park hunters. We 

anticipate that increased public awareness, 

combined with the ability for hunters to test 

their harvested elk, will increase the sample 

size for testing for chronic wasting disease 

on the refuge and the Grand Teton National 

Park.

Planning

■ Since November 2012, the refuge has been 

developing the Bison and Elk Stepdown 

Management Plan for the Bison and Elk 

Management Plan. 

Bison

The Jackson bison herd is of special importance as 

one of the last remnants of the extensive wild herds 
Chapter 3—Refuge Resources and Description 57 

■ The bison winter population has been 

reduced from approximately 1,250 in 2007 

to approximately 825 in 2014. 

Information and Outreach Goals 

Same as under “Elk” above.

Disease Prevention

■ The refuge denied WGFD’s request to 

administer the brucellosis vaccination to 

700 bison using syringe darts during the 

winter of 2007–8. The effective retrieval of 

used syringes from bison using this 

untested approach was in question. Large 

numbers of unretrieved syringes littering 

the refuge would pose a safety hazard to 

refuge employees, hunters, and other wildlife. The WGFD decided the delivery system 

needed further refinement and did not make 

a similar subsequent request.

■ In 2009, with the Wildlife Health Office in 

Bozeman, Montana (Tom Roffe), the refuge 

started a long-term project to monitor the 

health of elk and bison herds (same as under 

“Elk” above). 

Planning 

Same as under “Elk” above.

Bison in the Greater Yellowstone Ecosystem

The American bison is native to Jackson Hole 

(Ferris 1940, Fryxell 1928, Hall and Kelson 1959, 

Long 1965, Love 1972, McDonald 1981, Skinner and 

Kaisen 1947, Wright et al. 1976). Prehistoric bison 

remains have been found throughout the valley, along 

the Gros Ventre River, on the western slope of the 

Gros Ventre Range, on the National Elk Refuge, and 

along the Snake River south of Jackson (Ferris 1940, 

Fryxell 1928, Love 1972). Historically, bison likely 

lived in the northern areas of Jackson Hole as well, 

especially in summer. Areas where bison remains 

have been found represent key ungulate wintering 

areas, where most bison mortality would be expected 

to occur.

We do not know how many bison once lived in 

Jackson Hole. At least one reference exists, however, 

for an observation of “a large herd of buffalo in the 

valley” in June 1833 (Ferris 1940). The near extinction of the American bison occurred throughout the 

19th century. By the 1820s, bison were confined 

almost exclusively to lands west of the Mississippi 

River. Many of these herds began to decline after 

1830, as market hunting for hides accelerated, and 

prolonged drought in the 1840s further reduced bison 

numbers. After the Civil War, competition from 

guidelines for the refuge; (3) human safety concerns 

near the refuge visitor center, along Elk Refuge 

Road, and in the town of Jackson when bison 

approached the refuge’s southern entrance; and (4) 

property damage such as broken fences and signs. 

Since discovering the elk feed lines on the refuge in 

1980, the bison herd has greatly increased in size. We 

culled 16 bison and conducted a special permit hunt 

(taking 19 bison) in an effort to reduce the herd. However, litigation brought hunting to an end on the 

National Elk Refuge. We had not done any herd 

reductions on the refuge since 1990, and the bison 

population continued to grow at a rapid rate, increasing annually by approximately 10–14 percent. 

In the 1970s and 1980s, bison on private land or 

animals that were a threat to human safety or property were shot. In 1989, the Wyoming Legislature 

authorized a reduction season for wild bison. To slow 

population growth, WGFD reinitiated hunting in 1998, 

outside the National Elk Refuge and the Grand Teton 

National Park, where bison could legally be hunted. 

Few bison have been killed, however, because the animals are mainly distributed within the refuge and 

park lands. The annual number of bison harvested 

ranged from a low of 4 in 1998 to a high of 47 in 2002. 

Bison hunting was initiated under the EIS for the 

Bison and Elk Management Plan (FWS and NPS 

2007b) in 2007. From 2007 to 2013, hunters harvested 

an average of 204 bison per year. This harvest level 

has been enough to prevent further growth of the 

Jackson bison herd, but sustained reduction in the 

population to the objective of 500 bison has not been 

achieved. As of winter 2014, there were approximately 825 bison in the Jackson herd.

The refuge accomplishments below correspond 

with the bison management topics in the Bison and 

Elk Management Plan:

Habitat Goals

Same as under “Elk” above.

Population Goals

■ In 2007, we started an annual, public bison 

hunting season to reduce the population. 

The season length was increased several 

times to maximize harvest. We are offering 

a 157-day season in 2014–2015, from August 

15 through January 18. Annual harvest is 

strongly linked to weather conditions and 

has varied from a high of 266 to a low of 139. 

■ In 2008, we developed the first memorandum of agreement with the Shoshone-Bannock Tribes to conduct a ceremonial bison 

event on the refuge. The tribes have harvested an average of five bison annually 

through this agreement.
58 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Hole from at least 1840 until 1948. That year, 20 animals (3 bulls, 12 cows, and 5 calves) from Yellowstone 

National Park were reintroduced to the 1,500-acre 

Jackson Hole Wildlife Park near the community of 

Moran. This was a private, nonprofit enterprise sponsored by the New York Zoological Society, the Jackson Hole Preserve, Inc., and the Wyoming Game and 

Fish Commission (Simon, no date). Jackson Hole 

Wildlife Park served as an exhibit of important large 

mammals as well as a biological field station for the 

Rocky Mountain area. The 20 bison were considered 

the property of Wyoming.

In 1950, the expansion of Grand Teton National 

Park took in the Jackson Hole Wildlife Park, and 

management of the bison shifted to the National Park 

Service. By 1963, the National Park Service coordinated most management actions with WGFD: winter 

feeding, capturing bison that escaped the confines of 

the wildlife park (which occurred several times annually), and routine brucellosis testing and vaccination. 

The national park kept a population of 15–30 bison in 

a large enclosure until 1963 when brucellosis was 

discovered in the herd. Several months later, the 13 

adults were destroyed to rid the herd of the disease. 

The national park kept four yearlings that had been 

vaccinated against brucellosis as calves and five new 

calves, which had also been vaccinated. In 1964, 12 

certified brucellosis-free bison (6 adult males and 6 

adult females) from Theodore Roosevelt National 

Park were added to the Moran bison population, 

bringing the total number of animals to 21. These 

bison represented the latest in a long line of introductions from several herds (Shelley and Anderson 

1989). In 1968, the population was down to 11 adults, 

all of which tested negative for brucellosis, and 4 or 5 

calves. Later that year, the entire herd escaped the 

confines of the park. In 1969, the National Park Service eventually allowed the herd to range freely, partially because of recommendations contained in a 

report commissioned by the Secretary of the Interior 

on wildlife management in the national parks (Leopold et al. 1963).

Bighorn Sheep

Historically, bighorn sheep on the refuge were 

primarily winter residents that migrated from the 

Gros Ventre Range. From November to May, they 

occurred on the eastern slopes of Miller Butte and in 

the eastern parts of the refuge near Curtis Canyon. 

In recent years, small numbers of sheep have been 

observed on Miller Butte year-round, although peak 

numbers occur in winter, with most still migrating to 

the Gros Ventre Range. As many as 98 bighorn sheep 

were observed during on Miller Butte in 2012, and 62 

sheep were observed in winter 2013. The herd has 

undergone two pneumonia outbreaks in the last 15 

years, the first in 2001–2002 and the second in 2011–

domestic cattle and the greatly intensified market 

hunting for “buffalo” robes and tongues decimated 

the Great Plains herds. Tourists on railroad-shooting 

excursions killed thousands more. A final contributing factor was the introduction of cattle-borne contagious diseases, which reached epidemic proportions 

in 1881 and 1882. The combination of cattle, hunting, 

and epidemic disease all but eradicated the once 

immense western herds. By 1890, only about 300 

bison remained in the United States (Malone et al. 

1976).

Bison were mainly extirpated from the Greater 

Yellowstone Ecosystem, including Jackson Hole, by 

the mid-1880s (Trenholm and Carley 1964). A small 

herd continued to live in Yellowstone National Park 

(Bailey 1930, as cited in Long 1965; Wright 1984). 

While private herds existed throughout the United 

States, by 1902 no more than 23 individual bison 

remained of the thousands that had occupied the Yellowstone area since prehistoric times (Callenbach 

1996). A small group of 8–12 free-ranging bison, 

whose origin is unknown, persisted in west-central 

Wyoming’s Red Desert until the mid-1950s (Love, 

personal communication, as cited in NPS and FWS 

1996).

Jackson Hole Wildlife Park

Except for three Yellowstone National Park bison 

that wandered south into Jackson Hole in 1945 

(Simon, no date), bison were absent from Jackson 

Lori Iverson / FWS

Moose
Chapter 3—Refuge Resources and Description 59 

typically browse on woody vegetation (except near 

feedgrounds), but they rub against trees and seek 

shelter in riparian areas. The decrease in woody vegetation because of large numbers of elk on the refuge 

likely has had a negative effect on moose on the refuge over the long term.

Gray Wolf

Gray wolves were deliberately exterminated from 

the Greater Yellowstone Ecosystem by the 1930s and 

were placed on the Federal endangered species list in 

1973. After years of scientific research and public 

debate, 66 gray wolves from Canada were reintroduced into the Greater Yellowstone Ecosystem (31 

wolves) and central Idaho (35 wolves) in 1995 and 

1996 (FWS et al. 2003). They were classified as a nonessential, experimental population in accordance 

with the Endangered Species Act. This means that 

the species is treated either as proposed for listing in 

a national forest or as threatened in a national park 

or a national wildlife refuge (50 CFR 17). This nonessential, experimental population designation allows 

more flexibility to Federal, State, and tribal agencies, 

and private citizens in managing the wolf population. 

The wolf expanded rapidly under these protections, 

the population exceeded recovery goals, and wolves 

in Wyoming were removed from the Endangered 

Species list in 2012, but were returned to the Endangered Species list after a court case in 2014.

Because of changes in protected status, the wideranging nature of the species, and potential effects of 

wolves on elk numbers and distribution, the refuge 

cooperatively monitors wolf populations with WGFD 

and Grand Teton National Park. Wolves have been 

active on the refuge since 1999, and the first wolves 

denned on the refuge in 2005. The Pinnacle Peak 

pack has consistently denned and produced pups on 

the refuge from 2008 to 2014, and preliminary monitoring suggests that they denned on the refuge in 

2014. Members of the pack are commonly observed 

by refuge visitors on the southern end of the refuge 

during the winter.

Studies in the Greater Yellowstone Ecosystem 

documented that elk compose more than 85 percent 

of wolf kills during the winter (FWS et al. 2003, Jaffe 

2001, Mech et al. 2001). However, preliminary evidence suggests that winter elk mortality has not 

increased since wolves began using the refuge in 

1999. This indicates that wolf activity on the refuge 

has resulted in compensatory rather than additive 

mortality in elk—this means that wolves have mostly 

been killing elk on the refuge that would have died 

anyway.

Coyote

Coyotes are plentiful in the Greater Yellowstone 

Ecosystem, including the refuge. Several family 

2012. The most recent outbreak resulted in an 

approximately 30 percent population reduction.

Pronghorn

As many as 60 pronghorn have summered on the 

refuge in recent years. Occasionally, up to 34 pronghorn have wintered on the refuge, but survival for 

overwintering pronghorn is typically poor due to 

severe winter conditions and predation by coyotes. 

In the past, as many as 450 pronghorn summered 

in Jackson Hole (including the Bridger-Teton 

National Forest, Grand Teton National Park, and 

National Elk Refuge). Although the population 

declined to approximately 175 in the early 2000s, 

recent surveys suggest there are approximately 400 

pronghorn in Jackson Hole. Most pronghorn migrate 

south out of the valley, through the Gros Ventre 

Range, to winter range in the Green River Basin, 

which is about 100 miles one way. 

Mule Deer

In spring through fall, a small number of mule 

deer can be found on the northern part of the refuge 

in the Gros Ventre Hills and along the Gros Ventre 

River. These deer may leave this area at the beginning of elk hunting season in October. Mule deer on 

the refuge winter primarily on Miller Butte, but 

their numbers have greatly declined since the refuge 

closed an old feed shed that allowed deer access to 

alfalfa pellets. No deer were seen on Miller Butte 

during the winters of 2001–2, 2002–3, 2003–4, or 

2004–5; eight were seen in the winter of 2005–6. 

Mule deer in Jackson Hole belong to the deer herd 

in Sublette County (southeast of Teton County), 

whose estimated population averaged 24,528 from 

2007 through 2011, with an estimate of 21,969 for 

2012 (WGFD 2013). The Sublette deer herd ranges 

from the Wind River Range north to the Gros Ventre 

Range, west to the Wyoming Range, southwest to 

the Green River Basin, and southeast to the Little 

Colorado Desert. A small proportion of these deer 

come into Jackson Hole, and they are not counted 

separately from the Sublette herd as a whole. Some 

mule deer winter in Jackson Hole and can often be 

seen in Jackson and on East Gros Ventre Butte.

Moose

The Jackson moose herd was an estimated 500 

animals in winter 2014, with an average of 1,085 

moose from 2007 through 2011 (WGFD 2013). Moose 

range covers the Bridger-Teton National Forest, 

Grand Teton National Park, and National Elk Refuge; however, only 3–14 moose winter on the refuge 

each year. In the past 20–30 years, moose used riparian habitat along the Gros Ventre River on the refuge 

during the winter. Both moose and elk browse on 

willow, aspen, and other woody shrubs. Bison do not 
60 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

to 1992, 22 of 145 radio-collared calves died before 

July 15; black bears were responsible for 11 of these 

mortalities. During the late 1990s, black bears were 

responsible for 16 of 42 calf deaths (B.L. Smith, personal communication, 2003). In a north-central Idaho 

study, black bears killed 38 of 53 marked calves, or 72 

percent (Schlegel 1976). Bison calves are not usually 

vulnerable to black bears because bison cows can 

adequately defend their young. 

Small Mammals

Small mammals in Jackson Hole are abundant. 

Suitable habitat is the most important factor influencing the distribution and abundance of small mammal populations. Many small mammals occupy a wide 

variety of habitats, while others have specific needs 

that limit their distribution (refer to table 9). In general, most species prefer more mesic (neither wet nor 

dry) environments, and edge habitats generally support more species than interior habitats.

Small mammals depend on grasses for forage, as 

well as for cover from predators. Riparian areas and 

aspen typically support a greater abundance of small 

mammals and a greater diversity of species, although 

many of these species can be found in other habitats. 

Browsing by elk and bison has greatly altered some 

small mammal habitats on the refuge, which likely 

has changed the type of species found in affected 

areas. A small mammal study conducted on the refuge in the summers of 2000 and 2001 identified four 

species inhabiting cultivated fields—deer mice, voles, 

shrews, and short-tailed weasels (L. Swanekamp, 

master’s student, Montana State University, Bozeman, Montana, personal communication, 2002).

Overgrazing by large numbers of elk and bison 

can limit the numbers of rodents that can survive in 

grassland and sagebrush shrubland habitats. Irrigation, especially flood irrigation, designed to increase 

elk forage, can have a negative effect on small mammals by flooding burrows. The effects of K-Line 

sprinkler irrigation on small mammal communities 

are unknown, but flooding effects of the K-Line system on small mammal populations are likely to be far 

less than with flood irrigation. The number of floodirrigated acres has been greatly reduced under the 

new system, which could benefit some small mammal 

species and their predators.

Large Rodents

Large rodent species that occur in Jackson Hole 

are yellow-bellied marmot, porcupine, and beaver. 

Elk and bison probably do not affect marmots, but 

the decline of woody vegetation on the refuge 

because of browsing by elk and bison has likely 

reduced the amount of habitat available for porcupines and beavers:

groups live year-round on the refuge, but the number 

increases to nearly 100 as transient coyotes follow the 

elk herds to the refuge in the winter (F. Camenzind, 

biologist, Jackson Hole Alliance, Jackson, Wyoming, 

personal communication, 2003). 

Coyotes are opportunistic predators that readily 

feed on carrion, but they also catch a variety of small 

mammals from mice, squirrels, and rabbits to fawns 

and calves. In addition, coyotes will feed on insects 

and fruit. In winter, elk and occasionally bison carrion on the refuge are an important part of the coyote 

diet. In spring, coyotes may take elk calves during 

the calves’ first month of life. Coyotes rarely have the 

opportunity to kill bison calves because of the presence of the herd and protective mothers.

Mountain Lion

Mountain lions (also known as “cougars” or 

“pumas”) occur throughout the Greater Yellowstone 

Ecosystem, including the refuge. A mountain lion and 

her three kittens were seen frequenting a cave on 

Miller Butte for 2 months during the winter of 1999. 

She was a skilled elk and deer hunter and provided a 

great wildlife-watching opportunity.

Mountain lions feed mainly on ungulates, primarily deer, throughout much of their distribution, but 

they can take elk, moose, and bighorn sheep. Where 

elk are abundant, they can become a large part of the 

mountain lion diet (Ruth 2004). Mountain lions have 

also been known to feed opportunistically on wild 

horses, beavers, porcupines, raccoons, and hares, 

indicating one of the most varied diets of any predator in the Western Hemisphere (Hansen 1992). 

Mountain lions prey mostly on a combination of 

deer and elk in Jackson Hole, relying more on elk 

than in other areas of the country because of the 

large elk herd (Moody, personal communication, 

2002; Quigley et al. 2005). The Teton Cougar Project 

began in January 2001 and is focusing field investigations on mountain lion predation (the Wildlife Conservation Society originally operated the project, 

which is now operated by Craighead Beringia South). 

Information collected shows that elk made up 

approximately 80 percent of 86 mountain lion kills 

from 2000 to 2004 (Quigley et al. 2005).

Black Bear

Black bears rarely occur on the refuge but are 

common in the Bridger-Teton National Forest and 

Grand Teton National Park. While black bear numbers are unknown, their population is considered 

stable. Inhabiting forested areas, they feed on nutritious, succulent vegetation and on grubs, fish, newborn ungulates, and carrion. Elk and bison carrion 

may occasionally provide valuable protein. Black 

bears are known to successfully prey on elk calves. 

Smith and Anderson (1996) reported that, from 1990 
Chapter 3—Refuge Resources and Description 61 

Table 9. Small mammals that occur in various habitats on the National Elk Refuge, Wyoming.

Habitat Common mammals

Native grasslands 

and cultivated fields

Deer mouse

Long-tailed vole

Merriam’s shrew 

Northern pocket gopher 

Sagebrush vole

Uinta ground squirrel

Wyoming ground squirrel 

Yellow pine chipmunk

Sagebrush 

shrublands 

Deer mouse

Dusky shrew

Heather vole

Least chipmunk

Long-tailed vole 

Masked shrew

Meadow vole

Merriam’s shrew

Montane vole 

Northern pocket gopher

Sagebrush vole

Uinta ground squirrel 

Wyoming ground squirrel

Yellow pine chipmunk

Riparian 

woodlands and 

aspen woodlands

Deer mouse

Dusky shrew

Golden-mantled ground 

squirrel

Heather vole

Long-tailed vole 

Masked shrew 

Meadow vole

Montane vole

Muskrat

Northern flying squirrel

Northern pocket gopher

Red squirrel 

Snowshoe hare

Southern red-backed vole

Uinta chipmunk 

Uinta ground squirrel (aspen)

Vagrant shrew

Water shrew

Water vole

Western jumping mouse 

Wyoming ground squirrel

Yellow pine chipmunk

Source: Based on the University of Wyoming, Geographic Information Science Center, Species Atlas, 2003, and cross-referenced 

with the National Elk Refuge wildlife observation database.

■ Beavers are common in the Gros Ventre 

River area and in associated ponds on the 

northern end of the refuge. Historically, beavers occurred on the southern end of the refuge, but as willow habitat along Flat Creek 

declined in acreage and height, the beavers 

disappeared (Smith et al. 2004). Beavers 

inhabit rivers, streams, marshes, lakes, and 

ponds and use the adjacent woody, riparian 

areas. They feed on green plants and the 

bark of certain trees and shrubs, such as 

aspen, cottonwood, and willow. 

■ Marmots occupy rocky slopes of upper elevations, living in burrows in open areas and 

eating a variety of green vegetation. 

■ Porcupines occur in upland shrublands, 

riparian woodlands, and aspen woodlands. 

Porcupines feed on leaves, twigs, and green 

plants during the summer. In the winter, 

they subsist by chewing through the rough 

outer bark of trees to feed on the inner 

bark. 

Ann Hough / FWS

Pronghorn
62 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Nest Predation and Parasitism

Potential nest predators, such as crows, magpies, 

and ravens and foxes, raccoons, and skunks are 

attracted to habitat edges, often preying on eggs and 

young birds in narrow strips of riparian habitat and 

near edges of larger forests (Wilcove 1985, Yahner 

1988). In some forests, this edge-enhanced nest predation has been documented to extend more than 300 

feet into the interior of the forest patch (Wilcove 

1985). Martin (1988, 1993) found that nest predation 

can account for, on average, 80 percent of nesting failures, and Donovan et al. (1997) established that 

where habitats are fragmented, predators gain 

greater access to nests at forest edges.

Brown-headed cowbirds are common in Jackson 

Hole, and cowbird parasitism can reduce productivity 

for many neotropical migratory bird species. Cowbirds lay their eggs in the nests of other birds, often 

removing a host egg before laying one of their own. 

Cowbird chicks hatch earlier and grow faster than 

host chicks, which results in the cowbird young 

receiving most of the food and parental care from the 

foster parents. Female brown-headed cowbirds prefer edge habitats and can lay up to 77 eggs in a single 

season (Jackson and Roby 1992). Edge-tolerant songbird species can often recognize cowbird eggs and 

remove them from the nest, or they may abandon 

parasitized nests. These edge-tolerant species are 

often permanent residents or short-distance 

migrants and can nest several times in a season. This 

increases their chances of raising a successful brood, 

since cowbirds rarely parasitize late-season nests 

(Ehrlich et al. 1988). In contrast, interior-forest 

birds, which are usually long-distance migrants and 

only nest once or twice a year, often fail to raise any 

young of their own when forced to nest in edge habitats because they have not evolved behaviors to cope 

with nest parasitism. As a result, interior-forest species such as the veery and the American redstart 

disappear from small patches of forest habitat, and 

edge-tolerant species such as the American robin and 

house wren greatly increase (Herkert et al. 1993).

Habitat Size

On the refuge, small or narrow patches of riparian 

woodland and aspen woodland habitats often comprise sparse mature trees and lack of shrubs and 

small trees in the understory because of overbrowsing by ungulates. However, even if these patches are 

protected in some manner resulting in dense stands of 

small trees and shrubs, neotropical migratory birds 

may not benefit because of the size and shape of the 

individual patches for the reasons discussed above. To 

benefit tree- and shrub-nesting migratory birds, protection of stands from ungulate browsing should be 

limited to those stands that are large enough to support breeding populations of these species.

Midsize Predators

Other predators inhabiting the refuge include 

badger, bobcat, long-tailed weasel, ermine, mink, raccoons, red fox, and skunk. The presence of large 

predators and high densities of coyotes appears to 

limit the abundance of midsize predators. These species prey on small mammals, and a few may opportunistically feed on elk or bison carrion, but they do not 

depend on it as a food source. Bobcats may take an 

occasional elk calf, but calf-mortality studies show 

that this is not a substantial cause of mortality 

(Smith and Anderson 1996). Mink are not known to 

feed on bison or elk carrion. There have only been 

incidental observations of raccoons and skunks, and 

the absence of these animals potentially reduces nest 

predation on breeding birds. Red fox have increased 

in abundance in the past decade, but still occur at 

relatively low densities compared to surrounding 

areas. 

Birds

Approximately 175 species of birds have been 

observed on the National Elk Refuge. This section 

describes neotropical migratory birds, grouse, waterbirds, and predatory and scavenger birds on the 

refuge. 

Neotropical Migratory Birds

Neotropical migratory birds, which breed in 

North America and spend their winters in the tropics, have been experiencing population declines 

throughout their range (Terborgh 1989, USGS 1999). 

Habitat fragmentation by development, changes in 

plant communities associated with invasive plant species and ungulate herbivory, and destruction of winter range are among the factors believed to be 

responsible for these declines (Dobkin 1994, Dobkin 

and Wilcox 1986, George and Dobkin 2002, Martin 

and Finch 1995).

Many species of neotropical migratory birds are 

declining in North America because of an inability to 

raise young successfully rather than from mortality 

of adult birds (Herkert et al. 1993). Loss of habitat 

has long been suspected as contributing to nest failure and low survival of young birds, but habitat fragmentation plays an important role (Kaufmann 1996). 

In fragmented landscapes, neotropical species suffer 

high rates of nest predation by mammals and birds 

and high rates of nest parasitism by brown-headed 

cowbirds. Researchers have shown that habitat size, 

shape, and the amount and type of edge can all affect 

breeding success. Edge habitats support a larger 

variety and higher density of predators (Lompart et 

al. 1997).
Chapter 3—Refuge Resources and Description 63 

The ecological health of a woody plant community 

can be directly measured by bird species composition, their relative abundance, and breeding success 

(Dobkin et al. 2002). Riparian woodlands and aspen 

woodlands shelter many bird species that have relatively narrow needs for breeding habitat. These species may occur chiefly or exclusively in willow, aspen, 

and cottonwood communities. In the southern part of 

the Greater Yellowstone Ecosystem, ecologically 

intact riparian woodlands or aspen woodlands can 

have 76 species of birds closely associated with it 

during the nesting season, and 23 species (neotropical 

migrants) will be common and relatively abundant 

(Dobkin et al. 2002).

Cattle and wildlife grazing and browsing, especially in arid systems, can greatly affect the quality 

of riparian habitat for neotropical migrants (Ammon 

and Stacey 1997, Roath and Krueger 1982, Saab et al. 

1995, Taylor 1986). Upland aspen has been declining 

in Jackson Hole for the last several decades (Loope 

and Gruell 1973), as well as throughout the West 

(Kay 1998). Fire suppression is a major factor in the 

reduction of aspen (Kay 1998, Loope and Gruell 1973, 

White et al. 1998). On the refuge, ungulate browsing 

has greatly accelerated this decline (Anderson 2002, 

Dieni et al. 2000).

The mixture of riparian and upland aspen habitats found on the refuge is important to a variety of 

species. Anderson (2002) observed 25 bird species in 

riparian woodland habitats and 54 species in upland 

aspen habitat in Jackson Hole. Riparian woodlands 

and aspen woodlands that lack recruitment, such as 

those found on the refuge, are structurally simplified 

and support a less diverse community of bird species. 

Birds found in this simplified habitat generally have 

habitat needs that can be met in a wide variety of 

habitat types. Trabold and Smith (2001) found that 

European starlings on the National Elk Refuge overwhelmingly dominate the cottonwood riparian habitat along Flat Creek. This is typical of highly 

fragmented cottonwood habitat with low numbers of 

bird species (Gutzwiller and Anderson 1987). Many 

native cavity nesters cannot successfully compete 

with the highly aggressive starling. Aspen stands on 

the refuge also have low abundances of native bird 

species that are typically found in aspen, such as rednaped sapsucker and MacGillivray’s warbler (Anderson and Anderson 2001). Some widespread habitat 

specialists are completely absent including broadtailed hummingbird, calliope hummingbird, rufous 

hummingbird, veery, Swainson’s thrush, orangecrowned warbler, black-headed grosbeak, fox sparrow, and song sparrow (Dieni and Anderson 1997).

The decline of woody vegetation on the refuge and 

the resultant decline in neotropical migrants is 

attributed to 100 years of heavy browsing by elk and 

almost 40 years of browsing by bison. Anderson 

An example of a narrow habitat patch would be 

the cottonwood community along upper Flat Creek. 

This long riparian strip may always be too narrow to 

provide interior habitat for neotropical migratory 

birds that require interior-forest conditions for successful nesting. Some species of birds may avoid such 

areas and not attempt to nest, while others may 

make unsuccessful nesting attempts. For those birds 

that attempt nesting but fail to fledge young because 

of high predation and parasitism rates, this area may 

become (or possibly has always been) a “population 

sink.” Nevertheless, small or narrow tracts of riparian woodland and aspen woodland habitats are still 

valuable to a variety of birds as stopover sites during 

migration and have other beneficial effects such as 

preventing streambank erosion and improving fish 

habitat.

Native Grasslands and Sagebrush Shrublands

Grassland and sagebrush shrubland plant communities provide important breeding habitat 

between May and mid-July for some neotropical 

migrant species, and these cover types are abundant 

on the refuge. Typical bird species that nest in sagebrush shrublands are Brewer’s sparrows, sage sparrows, and sage thrashers. Many sagebrush bird 

species are declining as habitat throughout the West 

is converted to farmland and development. As riparian area and aspen habitats on the refuge are converted to sagebrush habitat because of heavy elk and 

bison browsing, more sagebrush shrubland habitat 

will become available to bird species that depend on 

that habitat.

Riparian Woodlands and Aspen Woodlands 

In the arid West, riparian woodland and aspen 

woodland habitats with a shrub understory (1) support the most species-rich communities of breeding 

birds (Dobkin and Wilcox 1986; Knopf et al. 1988; 

Mitton and Grant 1996; Saab et al. 1995; Tewksbury 

et al. 2002), (2) provide important migration habitat 

for migratory landbirds (Dobkin 1994), and (3) are 

centers for biological diversity (Brussard et al. 1998). 

These habitats are crucial for breeding habitat and 

migration stopovers for 80 percent of migratory bird 

species (Krueper 1992), because they are used extensively for feeding, nesting, shelter, and travel corridors. The open canopies allow sunlight to reach the 

ground, producing a rich understory of shrub and 

herbaceous species offering structural diversity. The 

layered structure of these woodlands provides many 

niches for birds. Cavity nesters use snags for nest 

sites, while predatory birds perch on dead trees to 

scan for prey. Neotropical birds nest at different levels, and they feed on the diversity of insects found in 

woodlands.
64 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Lori Iverson / FWS

Bohemian Waxwing

■ Aspen stands on the refuge that received 

high elk use (stands with the longest duration of high elk densities) had a substantially 

lower diversity of birds, and birds were less 

abundant as compared to aspen stands with 

low elk use. When aspen stands are converted to sagebrush shrubland habitat by 

high elk use, there is an exchange of approximately 20–40 bird species for 3–5 bird species that are generally more common than 

those found in aspen stands.

■ Recruitment of willow and aspen was 

extremely rare both on the refuge and near 

the WGFD Gros Ventre feedgrounds.

Smith et al. (2004) corroborated Anderson’s finding through an analysis of historical refuge photographs and experimental monitoring of fenced areas 

where elk and bison were excluded. They estimated 

that 95 percent of potential willow habitat had been 

lost on the southern end of the refuge due to browsing by elk and bison and that most willow, aspen, and 

cottonwood stands on the southern end of the refuge 

had insufficient regeneration to perpetuate 

themselves.

Cultivated Fields

Neotropical migrant species that can be found in 

the cultivated fields on the refuge include Brewer’s 

sparrow, Savannah sparrow, vesper sparrow, and 

western meadowlark (Dieni 2011). These species also 

occur in native grasslands.

Ruffed Grouse

Ruffed grouse are generally widespread and common, occurring in deciduous and mixed woodlands. 

Conifer forests may be used for shelter, while decidu-

(2002) conducted a study in and around Jackson Hole 

specifically to determine the effect, if any, that supplementally fed elk were having on landbird distribution in willow and upland aspen habitats. Anderson’s 

(2002) results are summarized below:

■ Willow habitats that are heavily browsed by 

elk are characterized by (1) lower willow 

volume, (2) lower willow shrub diameter, (3) 

fewer willow habitat bird specialists, (4) 

fewer species that nest in willow, and (5) 

fewer aerially foraging species. 

■ Riparian areas closest to feedgrounds 

receive the heaviest elk use and experience 

the greatest loss in bird species that depend 

on riparian habitat, such as willow flycatcher, yellow warbler, MacGillivray’s warbler, fox sparrow, and song sparrow. Species 

of birds that are abundant near feedgrounds 

include those that typically nest in grasslands or sagebrush shrublands, such as 

Savannah sparrow, vesper sparrow, western meadowlark, and Brewer’s blackbird. 

■ Nest predators, such as common ravens and 

black-billed magpies, were also more common near feedgrounds, possibly because of 

the greater availability of elk carcasses. 

These nest predators may accelerate the 

decline of neotropical migrants. 

■ Aspen woodland habitats that were browsed 

heavily by elk were characterized by (1) less 

understory volume of vegetation, (2) lower 

densities of nonsapling live and dead trees, 

(3) greater proportions of dead aspen trees 

(nonsapling), (4) more regeneration of suckers less than 1.6 feet, (5) less recruitment to 

overstory, (6) a lower density of aspen saplings, (7) a lower proportion of the stands 

with saplings, (8) higher rates of sucker 

browsing, (9) a lower proportion of suckers, 

(10) more damage to bark, (11) a higher density of dead trees, and (12) a higher proportion of the stands with dead aspen trees. 

■ Aspen woodland habitats heavily browsed 

by elk were also characterized by (1) fewer 

species of birds that nest and feed in the 

understory, (2) fewer species of birds that 

nest and feed in forest canopies, (3) fewer 

ground-nesting species, and (4) a greater 

abundance of cavity-nesting birds, probably 

because of the higher rates of aspen decay 

and mortality. 
Chapter 3—Refuge Resources and Description 65 

Predatory and Scavenger Birds

Jackson Hole has many resident species of predatory birds including the following: 

■ golden eagle

■ bald eagle

■ peregrine falcon

■ prairie falcon

■ northern harrier

■ red-tailed hawk

■ Swainson’s hawk

■ American kestrel

■ rough-legged hawk

■ great horned owl

■ short-eared owl

Eagles and hawks are all predators, but their preferred prey varies widely. Small hawks typically feed 

on insects, while the larger hawks feed on birds and 

small mammals. Eagles may take prey as large as 

foxes. Falcons often specialize on birds but may also 

take rodents and insects. Some of these raptors feed 

opportunistically on carrion, especially in winter.

Black-billed magpies and common ravens are 

omnivores that eat a wide variety of insects, rodents, 

lizards, and frogs, as well as eggs and hatchlings of 

other birds. They often feed as scavengers on carrion 

and human garbage. Elk carrion is an important 

source of food in the winter for bird scavengers on 

the refuge.

Reptiles and Amphibians

Only 11 reptile and amphibian species are present 

in Jackson Hole because of the high altitude and its 

associated cool climate. Most species are observed 

throughout the valley floor and foothill regions, especially on the floodplains of the Buffalo Fork of the 

Snake River, main stem of the Snake River, and Gros 

Ventre River. Some reptiles and amphibians inhabit 

the mountains up to 10,000 feet in elevation. 

Several reptile species are rare, with apparently 

restricted distributions, including the northern sagebrush lizard, gopher snake, and valley garter snake. 

The northern sagebrush lizard is found at elevations 

up to 8,300 feet and is commonly associated with 

thermal areas in Yellowstone National Park (NPS 

1998), but has not been found on the refuge. The rubber boa often inhabits riparian zones and could be 

adversely affected by soil compaction or vegetation 

loss. 

Amphibian surveys conducted in 2000–2003 documented the occurrence of five species of amphibians 

in Jackson Hole: blotched tiger salamander, boreal 

chorus frog, boreal toad, Columbia spotted frog, and 

the nonnative bullfrog (Patla and Peterson 2004). 

ous habitats are primarily used for food. Because elk 

browse on the woody vegetation that ruffed grouse 

rely on for their winter diet, changes in woody vegetation can affect ruffed grouse populations on the 

refuge.

Sharp-tailed Grouse

Sharp-tailed grouse were eliminated from the 

refuge by the mid-20th century due to loss of willow 

and aspen habitat (Smith et al. 2004). However, as of 

2001, small numbers of sharp-tailed grouse have 

returned to Jackson Hole, and the birds are occasionally observed in the Flat Creek area and the northern end of the refuge during the winter. Breeding 

has been confirmed for at least one location in Grand 

Teton National Park, which is the likely source of 

these grouse on the refuge. Given the dependence of 

this species on tall, dense deciduous shrub and aspen 

communities and the lack of this habitat on the refuge, it is unlikely that a breeding population of 

sharp-tailed grouse will become established on the 

refuge.

Waterbirds

Species of waterfowl, shorebirds, rails, and cranes 

that use the refuge are diverse and in most cases 

have habitat linked to aquatic or wetland features. 

They are vulnerable to predators because of their 

location on the ground, and they must rely on dense 

vegetation for camouflage or water levels high 

enough to impede nest raiders.

Several species of waterfowl—trumpeter swan, 

Canada goose, mallard, green-winged teal, gadwall, 

American wigeon, common goldeneye, Barrow’s goldeneye, and common merganser—are year-round residents on refuge wetlands. However, most waterfowl 

and shorebird species in Jackson Hole are seasonal 

migrants. Rocky Mountain Canada geese nest on 

wetlands throughout Jackson Hole, and fall populations on the refuge number 300–500, with about 100 

overwintering. Duck populations range from 200 to 

500 annually, with gadwall, mallard, ring-necked 

duck, green-winged teal, cinnamon teal, and Barrow’s goldeneye the largest contributors. Peak numbers of waterfowl in the fall are close to 3,000, and 

about 200–300 birds overwinter on the refuge. 

Common shorebird and rail species that breed on 

the refuge include killdeer, long-billed curlew, willet, 

spotted sandpiper, Wilson’s phalarope, and sora. 

These species occupy a wide range of plant communities from dry grasslands, in the case of the longbilled curlew, to dense cattail–bulrush marsh in the 

case of the sora rail.

The greater sandhill crane nests in small numbers 

in Jackson Hole, and fall concentrations of more than 

150 birds have been observed on the refuge.
66 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

frogs and toads in the National Elk Refuge and, possibly, western Wyoming” (Earl Green, personal communication, as quoted in Patla 2000). 

Live amphibians on the refuge were tested for the 

presence of chytrid fungus on their skin; in 2003, 66 

percent of the sampled amphibians tested positive for 

the fungus and in 2004, 71 percent (Patla 2004a, 

2004b). However, skin tests on live animals may not 

accurately determine whether the amphibian is actually infected. As of the end of summer 2004, chytrid 

disease had not reduced the toad populations at the 

two main breeding sites on the refuge, and no indicators of a population decline on the refuge (such as 

mass mortality events or failed reproduction) have 

been observed (Patla 2004b). Since the discovery of 

chytrid disease on the refuge, chytrid fungus has 

been found in several locations in the Grand Teton 

and Yellowstone National Parks and one location in 

the Bridger-Teton National Forest. 

Given global trends and the patchy distribution of 

amphibian breeding sites on the refuge, all amphibian species on the refuge are vulnerable to decline. 

Protection of breeding sites and continued monitoring of populations is warranted.

Fishes

The fish community in Jackson Hole is typical of 

cold waters. Eighteen species are present: 

■ mountain whitefish

■ Snake River cutthroat trout (the only native 

trout in the area)

■ three introduced trout species and one 

hybrid

■ redside shiner

■ several species of chub, dace, and sucker

Elk and bison can potentially affect fish habitat by 

reducing water quality, eroding streambanks, and 

suffocating spawning beds. Heavy browsing of riparian vegetation by elk and bison may raise water temperatures by removing shady vegetation. However, 

most fish populations in Jackson Hole are doing well, 

and these effects have been relatively minor or 

nonexistent.

Federally Listed Species and State 

Species of Greatest Conservation 

Need

There are several designated plant and animal 

species that we give special consideration: federally 

listed species, Federal candidate species, and WyoRecent surveys conducted in the Flat Creek and 

Gros Ventre River drainages on the refuge have 

documented breeding sites for four amphibians 

(blotched tiger salamander, boreal chorus frog, 

boreal toad, and Columbia spotted frog) and the 

occurrence of the wandering garter snake (Patla 

1998, 2000):

■ Tiger salamanders are rare on the refuge, 

although they are quite common in BridgerTeton National Forest. 

■ The most widespread amphibian on the refuge is the boreal chorus frog, which occurs 

in the Flat Creek and Gros Ventre River 

drainages at multiple sites, but their breeding populations are unexpectedly small and 

scattered (Patla 2000).

■ Boreal toads are widespread on portions of 

the refuge, with breeding populations in the 

Flat Creek and Gros Ventre River drainages (Patla 1998, 2000, 2004b). Although 

boreal toad populations remain high, recent 

tadpole die-offs in Grand Teton National 

Park suggest that continued monitoring is 

warranted (Patla 2012).

■ There are few Columbia spotted frogs in the 

Flat Creek drainage, including a significant 

breeding site on Nowlin Creek, where they 

produced record high numbers of egg masses 

in 2012 (Patla 2012). These frogs are widespread in the Gros Ventre River drainage.

Concentrated numbers of elk and bison can affect 

amphibians and their habitat by decreasing water 

quality, increasing streambank erosion, altering 

marsh and riparian vegetation, and possibly transporting chytrid fungus on their hoofs. Conversion 

from flood irrigation to sprinkler irrigation could 

reduce the amount of standing water available for 

amphibians.

The most significant and disturbing result of the 

amphibian surveys was the discovery in 2000 of 

amphibians on the refuge killed by chytridiomycosis 

(chytrid disease). This was the first time this disease 

had been documented in northwestern Wyoming, and 

boreal toads are particularly susceptible. Chytrid 

disease is caused by an aquatic fungus that has been 

associated with mass die-offs and population declines 

in many areas and may be contributing to the continuing and potentially escalating amphibian declines 

throughout the United State and the world (Patla 

2000). A veterinarian with the U.S. Geological Survey has stated, “The diagnosis of chytridiomycosis 

has potentially dire implications for all species of 
Chapter 3—Refuge Resources and Description 67 

information to adequately assess a species’ status. 

These species do not receive the same degree of protection as endangered or threatened species, 

although decreasing numbers or loss of habitat makes 

them of concern to Federal land management 

agencies.

Grizzly Bear

In the lower 48 States, grizzly bear was listed as 

threatened in 1975. In the 1980s, a recovery plan was 

developed, and in recent years their numbers have 

increased to the point that delisting is expected in 

the near future. 

Grizzly bears widely use the northern two-thirds 

of Grand Teton National Park, but can occur throughout the park and surrounding areas. Previously, grizzly bears had not been observed on the refuge since 

1994, but a sow and three cubs were observed feeding on a bison gut pile in August 2013. We anticipate 

increased use of the refuge by grizzly bears.

Grizzly bears are omnivores that feed on nutritious succulent vegetation, grubs, insects, fish, newborn ungulates, and carrion. By mid-May grizzly 

bears begin preying on newborn elk calves (Gunther 

and Renkin 1990, Singer et al. 1997). Grizzly bears 

dominate other scavengers at carcasses (Servheen 

and Knight 1990), but many carcasses are consumed 

before being found by a bear (Green 1994). Individual 

bears are most likely to get their largest meals from 

adult moose and elk that are prey and from adult 

female bison that are scavenged (Mattson 1997).

In Yellowstone National Park from March 

through May, ungulate carrion (mostly elk and bison) 

is an important food source (Mattson 1997). This is 

not the case in Grand Teton National Park. Elk and 

bison in the Jackson herds have a low winter mortality rate because of the supplemental feeding program 

on the National Elk Refuge and in the Gros Ventre 

Range. Grizzly bears in Grand Teton National Park 

do not appear to depend as heavily on meat in the 

early spring compared to grizzlies that live to the 

north in Yellowstone National Park.

Bald Eagle

The bald eagle was delisted from federally threatened status in July 2007 but is protected under the 

Migratory Bird Treaty Act (16 U.S.C. 703) and the 

Bald Eagle Protection Act (16 U.S.C. 668). It is also a 

priority 2 species of special concern for Wyoming. 

Most nesting territories in Jackson Hole are along 

major rivers or lakes within 3 miles of their inlets or 

outlets, or along thermally influenced streams or 

lakes. Historically, two bald eagle nesting territories 

have occurred on the refuge but no territories are 

active currently. 

ming SGCN. Appendix D shows the federally listed 

species and Wyoming SGCN that have been documented to occur on the refuge. The following sections 

explain the different designations, followed by 

descriptions of the listed species that occur on the 

refuge.

Federally Listed Species

The Endangered Species Act of 1973 requires 

Federal agencies to carry out conservation (recovery) 

programs for listed species and to ensure that agency 

actions are not likely to jeopardize the continued 

existence of listed species or adversely change or 

destroy their critical habitat. Section 7(a) of the act 

requires Federal agencies to evaluate their actions 

with respect to any species that is listed as endangered or threatened and with respect to its critical 

habitat, if any is being designated. Further, regulations implementing the interagency cooperation provision of the act are codified at 50 CFR part 402. 

Section 7(a)(2) requires Federal agencies to make 

sure that activities they authorize, fund, or carry out 

are not likely to jeopardize the continued existence of 

any species listed as endangered or threatened, or to 

destroy or adversely change its critical habitat.

Federal Candidate Species

Candidate species are plants and animals for 

which we have sufficient information on their biological status and threats to propose them as endangered 

or threatened under the Endangered Species Act, 

but for which development of a proposed listing regulation is precluded by higher priority listing activities. A candidate species status is reviewed 

annually.

The Endangered Species Act gives no statutory 

protection to candidate species, and “take” as identified in the act does not apply to these species. However, we encourage the formation of partnerships to 

conserve these species because they are, by definition, species that may warrant future protection 

under the act. Furthermore, our policy requires that 

candidate species be treated as “proposed for listing” 

for purposes of intra-Service section 7 conference 

procedures (FWS 1998).

Species of Greatest Conservation Need

The WGFD has a State Wildlife Action Plan 

(2010a) that identifies 180 SGCN. These are species 

for which we may or may not have sufficient data to 

determine population trends, abundance, distribution, needs, and management actions. The designation as a SGCN can be derived from threats to a 

known population or habitat or a lack of sufficient 
68 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

ment, prescribed burning and wildfire on winter 

range, birds killed by collisions with aircraft at the 

Jackson Hole airport, and browsing and grazing by 

livestock and large numbers of elk and bison. Holloran and Anderson (2004) indicated winter habitat 

was likely a limiting factor for this population based 

on the research conducted from 1999 to 2003. In general, wintering habitat consists of sagebrush plant 

communities that are tall enough to remain uncovered by snow.

Trumpeter Swan

The 2010 Wyoming State Action Plan classifies 

the trumpeter swan as a SGCN, which is a species 

that warrants increased management attention and 

consideration in conservation planning in Wyoming. 

The USDA Forest Service classified the swan as a 

sensitive species in its Regions 2 and 4. The refuge 

manages swan habitat to meet objectives of the 

“Pacific Flyway Management Plan for the Rocky 

Mountain Population of Trumpeter Swans” (Subcommittee on Rocky Mountain Trumpeter Swans 2012). 

The trumpeter swan population on the refuge is 

part of the core Tri-State Area flock. The Tri-State 

Area refers to Idaho and the portions of Montana and 

Wyoming within the Pacific flyway. The core TriState area refers to the following:

■ Idaho: Island Park region, Teton River 

drainage and Teton basin, Henrys and 

South Forks of the Snake River, and Camas 

National Wildlife Refuge

■ Montana: Red Rock Lakes National Wildlife 

Refuge, Centennial Valley, Hebgen Lake, 

and Madison River and tributaries

■ Wyoming: Yellowstone National Park, 

Grand Teton National Park, and the Snake 

River drainage including Jackson Hole 

south to Alpine

Trumpeter swans were likely eliminated from 

Jackson Hole during the late 1800s, but swans were 

reintroduced to the refuge in 1938 from Red Rock 

Lakes National Wildlife Refuge in Montana. Since 

that time, a persistent breeding population has been 

established, although nesting activity seems to fluctuate based on weather conditions. The refuge provides the largest wetland habitat for nesting 

trumpeter swans in the Snake River drainage of 

Wyoming. In general, dry warm spring conditions 

are most favorable for trumpeter swan productivity. 

Most trumpeter swan nesting occurs in Flat 

Creek Marsh southwest of Miller Butte, with occasional nesting activity in the Pierre’s Pond and RomDuring the fall, as many as 100 bald eagles have 

been seen at one time in the cottonwood trees within 

the elk and bison hunting areas on the refuge 

(National Elk Refuge wildlife observation records). 

These eagles feed on the gut piles left by hunters. 

Typically, 5–20 bald eagles may be active on the refuge during the winter, and these birds feed primarily 

on the carcasses of elk that die during the winter.

Bald eagle winter habitat is generally associated 

with areas of open water, where fish or waterfowl 

congregate (Swenson et al. 1986), or ungulate winter 

range where eagles scavenge on carcasses of large 

mammals. Nearby food, suitable perches, and security from human activities are important habitat 

components for both nest and roost sites.

Greater Sage-Grouse

On March 5, 2010, our agency found that the 

greater sage-grouse warrants protection under the 

Endangered Species Act, but listing the species 

under the act was precluded by the need to address 

other listing actions of a higher priority. Therefore, 

the greater sage-grouse is a candidate species (75 

Federal Register 13910). The northern portion of the 

refuge contains significant wintering habitat for 

greater sage-grouse, and much of the north end of 

the refuge falls within the State of Wyoming’s core 

area policy for greater sage-grouse protection (Wyoming Executive Order 2011–5), more specifically, the 

Jackson core population area.

Greater sage-grouse that occupy the refuge are 

part of the Jackson Hole greater sage-grouse population, which is isolated from larger populations in the 

Green River Basin. The refuge collaborates with 

WGFD, Grand Teton National Park, and the Upper 

Snake River Basin Sage-Grouse Working Group to 

monitor population trends in this population by conducting lek counts each spring. The refuge hosts the 

North Gap lek and the Simpson lek, which are 2 of 

the 13 known, occupied breeding sites for the Jackson 

Hole greater sage-grouse population. Although 

grouse use of the Simpson lek has been minimal in 

recent years, maximum numbers of males observed 

on the North Gap lek were 18 in 2012 and 8 in 2013. 

The northern end of the refuge contains valuable 

nesting and wintering habitat for the Jackson Hole 

greater sage-grouse population. Greater sage-grouse 

nest only in sagebrush shrubland habitat, using 

bunchgrasses and sagebrush plants as cover 

(Kaufman 1996). Other important habitats include 

meadows and grasslands close to sagebrush shrubland habitat. In Jackson Hole, Garton et al. (2011) 

estimated that the greater sage-grouse population is 

declining by 2.2 percent annually and is at risk of 

elimination. Factors that may be contributing to this 

local decline are loss of habitat to human develop-
Chapter 3—Refuge Resources and Description 69 

five potential breeding territories for long-billed curlew in the irrigation project areas each season.

Plants

No federally listed plant species occur on the refuge. However, the State of Wyoming has given special status to plant species that occur on the refuge 

(refer to appendix D).

The University of Wyoming’s Wyoming Natural 

Diversity Database maintains lists of Wyoming plant 

species of concern. Inclusion is derived from four 

main factors contributing to the rarity of species: (1) 

restricted geographic range; (2) small population 

size; (3) highly specific habitat requirements; and (4) 

significant loss of habitat or heavy exploitation. 

These lists, which have no status under State legislation, are sometimes cited in development of sensitive 

species lists by Federal land management agencies 

and include 12 plant species that occur on the refuge 

(refer to appendix D).

3.3 Management Tools

Irrigation and farming are important management tools that the refuge uses to provide forage for 

elk and bison.

Irrigation

Irrigation is a common habitat management tool 

that we use to increase both the quantity and quality 

of forage available to elk and bison (see figure 11). We 

have used irrigation to produce forage for many 

years on the National Elk Refuge as a technique to 

reduce the reliance of wintering elk on supplemental 

feeding. Water available for irrigation depends more 

on snowpack than precipitation over the growing 

season. 

In 2010, we upgraded our irrigation capacity by 

installing a state-of-the-art sprinkler system that 

has more than 50 miles of underground water-delivery pipe and an extensive aboveground moveable 

pipe and sprinkler pod system called K-Line. This 

new system can irrigate approximately 4,300 acres 

each year. This increased irrigation capacity will help 

us increase winter forage while decreasing water 

use. The irrigated acres have increased from approximately 900 acres that were flood-irrigated to 3,300 

acres annually. The aboveground sprinkler system 

(170 units) is moved daily to specific locations using 

4×4 utility vehicles. In most areas, the K-Line irriganey Pond complexes on the northern end of the 

refuge. In addition, there may be as many as 200 

trumpeter swans on the refuge during fall migration, 

and 50 trumpeter swans may winter on the refuge. 

During the first 2 weeks in November, hundreds of 

swans congregate on Flat Creek Marsh before freezeup when most swans disperse to other wintering 

sites. Fall staging behavior may play an important 

role in swan social structure offering an opportunity 

for immature swans to initiate pair bonds. Average 

trumpeter swan production in recent decades is 3 

nesting pairs, 7.3 cygnets hatched, and 6.3 cygnets 

fledged per year (Cole 2011b). From 2002 to 2012, 

swan pairs on the refuge produced 66 mature young, 

which composed 43 percent of the total swan production in the Snake River core area of Wyoming 

(WGFD unpublished data).

Long-Billed Curlew

The long-billed curlew is the largest North American shorebird and is listed as a SGCN by the State of 

Wyoming. The high levels of concern are due to the 

loss of the eastern third of the curlews historical 

breeding range, apparent population declines, and 

loss of shortgrass habitat that the birds use to nest 

(Fellows and Jones 2009). Because they breed in 

short dry grasslands common in the refuge’s irrigation project area, we are concerned that irrigation 

activities could disturb nests of this species. As a 

result, the refuge staff surveys the irrigation project 

area to identify breeding pairs and potential nest 

sites each spring. Irrigation activities are delayed 

around potential curlew nest locations until August 

when the birds fledge. Typically, we identify two to 

Tom Koerner / FWS

Greater Sage-grouse
70 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

across the National Elk Refuge occurred in 1879. 

Much of the surrounding forests also burned at the 

same time (Smith et al. 2004). During most of the 

20th century, the National Elk Refuge, along with 

other federal land management agencies in the area, 

suppressed wildfires with the intent to keep wildfires 

small. During the latter stages of the 20th century 

and into the 21st century, federal wildland fire policy 

has evolved to allow the opportunity for wildfires to 

be managed for benefits. Current wildfire management at the National Elk Refuge is to suppress all 

wildfires.

Prescribed fire is not currently used by the refuge. After issuance of this final CCP, completion of a 

revised Fire Management Plan (FMP), which is 

based on the goals and objectives of the CCP, is 

required. 

3.4 Human History and Cultural 

Resources

The human history of the National Elk Refuge 

starts with the indigenous, or native, people who 

lived in the area. The arrival of Euro-Americans had 

a major effect on not only the indigenous people, but 

also on the environment. The remains of sites, structures, or objects used by these peoples in the past are 

cultural resources, which reflect and preserve the 

area’s history and increase our understanding of 

human interactions and development over time. 

Indigenous People of Western 

Wyoming

The most prominent groups that occupied the 

eastern Idaho and western Wyoming area before 

settlement by Euro-Americans were the Bannock, 

Eastern Shoshone, and Northern Shoshone tribes. 

Other American Indian tribal groups have some historical or continued association with lands now 

within the National Elk Refuge: Assiniboine, Athabascans, Comanche, Crow, Gros Ventre, Kiowa, Kootenai, Nez Perce, Salish, Teton Sioux, and Umatilla. 

In addition, the Arapaho, Blackfeet, Cheyenne, and 

other Siouan groups and people of the Plains made 

excursions into the region for hunting, warfare, and 

trade (Walker 2005).

The Bannock are related to the Northern Paiute 

and are Uto Aztecan speakers who migrated from 

Oregon into the Snake River Plains. There they lived 

tion replaces flood irrigation; however, some flood 

irrigation is still used in the Ben Goe and Pedersen 

management units. The refuge needs to retain the 

ability to irrigate with side-roll systems; when new 

areas are cultivated and planted, the use of K-Lines 

is impractical because dragging hoses over disturbed 

soil with utility vehicles is not conducive to grass 

establishment.

Historically, of the water diverted annually for 

flood irrigation, only an estimated 5–10 percent actually reached its destination (John Kremer, personal 

communication, as cited in FWS 1998). This loss was 

due in part to the porosity of refuge soils and to the 

state of disrepair of ditches and headgates. This, as 

well as annual precipitation, staff, other refuge activities, and access to and availability of water affected 

how many acres we irrigated using the old system.

Farming

The refuge conducts farming practices such as 

disking, seeding, sprinkler and drip irrigation, herbicide and fertilizer application, and crop harvesting. 

The refuge annually drags about 3,000 acres using a 

blanket harrow to break up and help decompose 

deposited elk and bison fecal matter and to aerate the 

soil.

Fencing

An 8-foot-tall big game fence is located along the 

western boundary of the refuge and is designed to 

keep elk and bison off Highway 89. Elk “jumps” are 

one-way openings in the fence that allow migrating 

elk to enter the refuge from the west but prevent 

them from traveling back west onto the highway. 

Seven earthen elk “jump” ramps are located on the 

west side of the fence, with a corresponding opening 

in the fence. Migrating elk can walk up the ramps to 

a height of 5–6 feet to the fence opening and jump 

down onto the refuge. Since there is no ramp on the 

east side of the fence, the abrupt height difference 

prevents the elk from getting back through the fence 

opening, which keeps them off the highway.

Wildland Fire Management

Historically wildfires were frequent and widespread but did not burn large expanses of the landscape except under extreme drought conditions 

(Gruell 1980). The last stand replacement fire to burn 
Chapter 3—Refuge Resources and Description 71 

Figure 11. Map of irrigated areas on the National Elk Refuge, Wyoming.
72 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

curtailed. In Ward v. Race Horse (1896), tribal hunting beyond the boundaries of the reservations was 

curtailed because the U.S. Supreme Court reasoned 

that this provision was temporary, and when Wyoming was admitted into the Union, it did so on an 

equal footing with all other States without lands 

within the State being encumbered. 

After additional treaties, congressional acts, 

Executive orders, and agreements, the Bannock and 

Shoshone now occupy the Fort Hall Reservation in 

eastern Idaho and the Duck Valley Reservation in 

southwestern Idaho. The Eastern Shoshone are on 

the Wind River Reservation in west-central Wyoming. At least 15 other American Indian tribal 

groups have some historical or continued association 

with lands now within the National Elk Refuge 

(Walker 2005).

Historical Euro-Americans

John Colter, a member of the Lewis and Clark 

expedition and later an explorer and trader for the 

Manuel Fur Company, might have visited Jackson 

Hole in 1807. Other trappers and traders from the 

Missouri Fur Company trapped the rivers and 

streams of Jackson Hole in 1810–11 (Daugherty 1999). 

During the 1820s and 1830s, Jackson Hole served as 

a crossroads of the fur trade in the northern Rocky 

Mountains.

Except for a few prospectors searching for gold, 

Jackson Hole was virtually deserted by Euro-Americans from the 1840s to the 1880s. However, three 

military surveys passed through the valley in the 

1860s and early 1870s. These military surveys were 

followed by the Hayden surveys (1872, 1877, and 

1878), sponsored by the U.S. Geological Survey, and 

explored the Jackson Hole and Yellowstone country. 

It was during the 1872 Hayden survey that William 

H. Jackson took the first photographs of the Teton 

Range.

In 1884, the first permanent settlers arrived and 

built cabins along Flat Creek inside the boundaries of 

the present-day National Elk Refuge. By 1900, 638 

people resided in Jackson Hole (Daugherty 1999). The 

first homesteaders planted crops and raised cattle on 

small family ranches throughout the valley. Long cold 

winters with deep snows, poor soils, and dry conditions that required digging irrigation ditches to 

water crops made homesteading in Jackson Hole a 

difficult endeavor. By 1900, many of the original settlers had already left the valley (Daugherty 1999). In 

1912, when the U.S. Government allocated money to 

buy up homesteads to set aside land for the National 

Elk Refuge, many homesteaders willingly sold their 

property and moved into town. In other parts of the 

in peaceful cooperation among the Shoshone speakers 

who had arrived from the Plains. The merged Bannock and Northern Shoshone developed a single 

amalgamated culture that exhibited strong Plains 

Indian influences. 

The Bannock and Shoshone–occupied areas are 

designated as eastern Idaho and western Wyoming. 

This area, the upper Snake River Plains, received 

higher rainfall, providing adequate grasses and forage for bison to exist. Bison were by far the greatest 

food resource, providing an endless supply of food, 

clothing and shelter materials, and weapon and tool 

products. Bison were also viewed as an earthly link 

to the spiritual world. For many tribes even today, 

bison represent power and strength. For example, 

the Shoshone believe that spiritual power is concentrated in the physical form of the bison. Many contemporary tribes maintain a spiritual connection 

with bison. Emigration, continuing warfare among 

tribes, and gradual loss of forage after the 1840s limited the amount of bison taken for food supplies. The 

bison herds west of the Continental Divide were 

greatly diminished and decimated by 1850, primarily 

by Euro-American immigrants.

Another principal food was fish, which were taken 

in the spring, when other food supplies were low, and 

were either eaten fresh or preserved by sun-drying 

or smoking. Next in importance to bison and fish 

were elk. As the tribes began to compete for 

resources when emigrations diminished the major 

game on the Plains, they turned to the mountains. 

The mountains still provided game for subsistence, 

whether it was elk, bighorn sheep, moose, or deer. In 

addition, berries were still found along the riverbanks, and roots could still be dug in the surrounding 

hills. Native plants were also important to the prehistoric inhabitants of the Greater Yellowstone Ecosystem. Today, modern tribes still collect and use these 

plants for ceremonial and traditional purposes.

The Shoshone entered into a treaty with the 

United States on July 2, 1863, that set apart for the 

Shoshone Tribe a reservation of 44,672,000 acres 

located in Colorado, Idaho, Utah, and Wyoming. 

However, the Treaty of Fort Bridger of 1868 pared 

this down to less than 2.8 million acres, and the 

treaty established both the Fort Hall Reservation 

(Shoshone–Bannock) in Idaho and the Wind River 

Reservation in (Eastern Shoshone and Northern 

Arapaho) Wyoming. The Bannock and Shoshone 

experienced extreme hardship subsequent to the 

treaties and later agreements that separated them 

from their aboriginal territories. Prohibitions on offreservation hunting, meager rationing, and diseases 

adversely affected the tribal populations and social 

health.

By the end of the 1800s, tribal land bases were 

greatly diminished, and tribal rights to hunt were 
Chapter 3—Refuge Resources and Description 73 

peoples also hunted mule deer, bison, elk, and bighorn 

sheep. Although bone does not preserve well, particularly in shallow soils, bison remains are present in 

13 archaeological sites in Jackson Hole and elk 

remains in 8 locations (Cannon et al. 2001).

Evidence of permanent settlements by American 

Indians has not been found in Jackson Hole. In the 

northern part of Jackson Hole, most evidence indicates that large base camps were established along 

the shores of Jackson Lake, where a band of individuals lived during the spring and early summer 

(Wright 1984). As the weather improved, the band 

would disperse into family groups and move into the 

canyons and higher alpine meadows, following the 

emergence of edible plant species. After using the 

resources of the higher mountains, the entire band 

would move into areas such as Idaho to spend the 

winter. Many tools, fire hearths, and roasting pits 

dating after 5,800 B.P. have been found, particularly 

around Jackson Lake. 

The peoples of southern Jackson Hole entered the 

valley from the Gros Ventre River drainage after 

wintering in the Green River, Wind River, or Big 

Horn basins of northwestern Wyoming. They followed the ripening plants south into the Gros Ventre 

Range and by the following winter had moved into 

the more mild intermountain basins east of Jackson 

Hole (Daugherty 1999).

Cultural Resources on the Refuge

About 20 percent of the refuge has been inventoried for cultural resources. There are 28 known cultural resources on the National Elk Refuge: 8 

prehistoric sites and 20 historic sites. Six sites are 

eligible or potentially eligible for the National Register of Historic Places. Based on cultural resource 

inventories on surrounding lands, we expect that 

more historic and prehistoric resources are on the 

refuge. Although a comprehensive survey of the refuge will be the best method to identify and evaluate 

any unrecorded resources, additional survey is generally done on a project-by-project basis under section 106 of the National Historic Preservation Act. 

This act, in concert with other historic preservation 

laws and regulations, requires that we consider the 

effects our undertakings have on historic properties 

(cultural resources that are eligible for the National 

Register of Historic Places) and that we conduct consultation to identify, evaluate, and manage the significant resources.

The refuge has not been evaluated for the potential for the following:

valley, cattle ranching continued and expanded 

through the 1930s (Daugherty 1999) and remained 

the mainstay of the economy into the 1960s (Charture Institute 2003a).

Before Euro-American settlement, some 

researchers believe that most elk migrated out of 

Jackson Hole in the winter. However, homesteaders 

gradually forced elk off traditional winter ranges 

both inside and outside the valley (Anderson 1958, 

Craighead 1952, Cromley 2000), and then these settlers cut and stacked elk winter forage in Jackson 

Hole to feed domestic livestock. Even before the 

Jackson Hole environment was changed by the 

arrival of homesteaders, early hunters and settlers 

noted that winters of unusually heavy snow caused 

thousands of elk to starve to death. This situation 

ultimately led to the establishment of the National 

Elk Refuge in 1912.

Bison played no role in early settlers’ lives 

because bison had been eliminated from Jackson Hole 

by the 1840s. By 1900, less than 1,000 bison existed 

in the entire United States. Bison were reintroduced 

into Jackson Hole in 1948.

Ethnographic Resources

An ethnographic resource study (a scientific 

description of specific human cultures) is being conducted that pertains to past treaties and traditional 

cultural activities that occurred within the Grand 

Teton National Park, Yellowstone National Park, and 

National Elk Refuge (Walker 2005). The final report 

could influence future cultural resource surveys and 

management on the refuge, and it could yield more 

information on how tribes used the refuge and parks.

Archaeological Resources in 

Jackson Hole

Limited but documented archaeological evidence 

indicates that American Indians have used Jackson 

Hole for at least 11,000 years. Shifting climate patterns and the resulting change in plant and animal 

communities, along with drought and fire, determined how and when the valley was used. From 

11,000 before present (B.P.) to around 5,800 B.P., 

American Indians occupied Jackson Hole sporadically to hunt and to obtain obsidian and other lithic 

(stone) material for tools. These people lived a 

hunter-gatherer lifestyle and traveled in small 

groups. Primarily gathering plants for food, medicine, and manufacturing materials, these prehistoric 
74 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

erty that the Federal Government bought to become 

part of the National Elk Refuge, and Miller House 

served as the original office and home for the first 

refuge manager. 

In 1969, Miller House and the cabin were placed 

on the National Register of Historic Places. The 

National Register nomination was amended in 2001 

to include the Miller Barn. These buildings are the 

only historic structural resources recorded on the 

refuge and listed on the National Register of Historic 

Places (48 TE903).

Although the exterior of Miller House looks much 

as it did during its period of historical significance, 

the interior has undergone at least three major construction events:

■ In 1969, modifications made the house more 

comfortable and energy efficient for its use 

as a Government employee home. 

■ Miller House eventually fell into disrepair 

and, in the 1970s, the decision was made to 

destroy the house by having the local fire 

department burn it. Fortunately, the 

attempt to burn the structure was unsuccessful. Although the house was damaged 

from the attempted razing, it was later 

decided to restore and preserve the house. 

With help from the Grand Teton Association 

and other partners, the refuge restored the 

house to period standards and aesthetics, by 

removing or replacing contemporary fixtures and decorating the building with early 

1900s décor and antique furniture. In the 

1980s and 1990s, refuge staff occupied 

Miller House. 

■ Through a grant with the Community Foundation of Jackson Hole and the use of a specialized volunteer crew, a 2-week 

rehabilitation project in summer 2007 

brought portions of the original house interior closer in feel to the historic period it 

represents.

When refuge employees vacated Miller House in 

April 2005, refuge managers decided that converting 

parts of the house to an interpretive site would be an 

adaptive use related to the goals of the refuge and 

would offer unique education opportunities. We 

opened Miller House to the public 2 months later, and 

the house is open for tour by the public during the 

summer. Eighteen other historic sites on the refuge 

include ditches and associated water-control structures, artifacts and foundations associated with 

homesteads, and the remains of a local schoolhouse. 

The volunteers who staff the Miller House provide 

■ Cultural landscapes—geographical areas 

that are significant because of their distinctive combination of cultural and natural 

features

■ Traditional cultural properties—places 

associated with historical beliefs, customs, 

or practices of a living community

The diverse topography, wildlife, and habitats on 

the refuge along with the rich cultural history of the 

region provide an excellent combination for the existence of both cultural landscapes and traditional cultural properties.

Prehistoric Sites

Eight prehistoric archaeological sites have been 

recorded, which include roasting pits, stone circles, 

and a bison kill site. Tipi rings begin to appear in the 

archaeological record after 5,000 B.P., and a few tipi 

rings can be found on the refuge. Among the artifacts that have been discovered are bones from elk 

and bison, numerous flakes, choppers, scrappers, and 

projectile point pieces.

Historic Sites

The historic sites are primarily ditches and associated water control structures, artifacts and foundations associated with homesteads, and the remains of 

a local schoolhouse. 

The historic Miller Ranch was one of the early 

homesteads in Jackson Hole and has three main 

structures: the Miller House, the Miller Barn, and a 

cabin. Miller House is a log home built in 1898, and 

was one of the first houses in Jackson Hole. Miller 

House and the surrounding land was the first propLori Iverson / FWS

Interior of the historic Miller House.
Chapter 3—Refuge Resources and Description 75 

Chuck Mulcahy / FWS

A history demonstration is given at the Miller House.

3.5 Special Management 

Areas

We manage areas with official designations to 

retain the special features that led to their designation. There is no existing or potential wilderness on 

the refuge, as described under “Wilderness Review” 

below. 

Wilderness Review

A wilderness review is the process we use to 

decide whether to recommend lands or waters to the 

U.S. Congress for designation as wilderness; the 

CCP process requires us to conduct this review. 

Lands or waters that meet the minimum criteria for 

wilderness will be identified in a CCP and further 

evaluated to figure out whether they merit recommendation for inclusion in the Wilderness System. To 

be designated as wilderness, land must meet certain 

criteria as outlined in the Wilderness Act of 1964:

■ generally appears to have been affected primarily by the forces of nature, with the 

imprint of human work substantially 

unnoticeable

■ has outstanding opportunities for solitude or 

a primitive and unconfined type of 

recreation

information and interpretive programming. In addition, the Grand Teton Association runs a seasonal 

sales outlet and bookstore in Miller House that provides merchandise with a historical theme. In 2013, 

the Miller House had 3,762 visitors, which is a 19-percent increase from 2012 and a 245-percent increase 

from 2007. The refuge contracted with the University of Wyoming’s American Studies program to 

develop an initial interpretive and restoration plan 

for Miller House and the related buildings on the 

refuge.

Miller Barn is not open to the public. The barn is 

in fair overall condition, but it requires attention to 

ensure its preservation including foundation stabilization, improved drainage, repair of split or loose 

battens in the walls, and possible roof repairs. Subsequent to the needed rehabilitation, Miller Barn will 

expand the interpretive opportunities by having 

another restored building onsite that the public could 

view and that could be an alternate site for holding 

programs indoors when needed. The upper floor of 

the barn has outstanding potential for use as an 

interpretive site and a location for programs and 

events.

A USDA Forest Service cabin is the third building 

on the Miller Ranch property listed on the National 

Register of Historic Places. The cabin, not open to the 

public now, will need substantial rehabilitation before 

it could be opened to the public including cleaning the 

interior, replacing plaster and floor boards, repairing 

windows and doors, and installing lights.
76 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

■ organizes annual antler collection and sale that 

generates money for refuge habitat projects

■ issues approximately 40 special use permits 

annually for a variety of activities

■ serves an ambassador and leader in the 

community, including extensive involvement 

in a variety of partnerships

■ hosts dignitaries traveling as guests with 

the U.S. State Department

■ organizes special events

■ maintains and updates the refuge Web site 

and social media sites

■ maintains and expands the refuge’s online 

photo gallery

■ responds to extensive media and environmental education requests

■ writes about 10 articles per year about refuge management and public use operations 

for internal and external audiences

■ prepares and sends out 30 or more news 

releases per year

■ manages and operates nine budget accounts 

including both Government and nongovernmental money

■ recruits, trains, equips, and manages a volunteer program that logged more than 

19,000 hours by individuals and volunteer 

groups in 2013

■ provides training to seasonal and volunteer 

staffs

■ collects fees

■ develops and manages publications

Hunting

Hunting is both a wildlife management tool and a 

wildlife-dependent recreational opportunity at the 

refuge. The refuge’s Web site contains a link that 

educates the public on the Service’s position of allowing hunting as a recreational activity. A seasonal 

■ has at least 5,000 acres of land or is of sufficient size to make practicable its preservation and use in an unimpaired condition

■ may also contain ecological, geological, or 

other features of scientific, educational, scenic, or historical value

The refuge is next to the town of Jackson and is 

bordered by a major highway (89). In addition, private land next to the refuge has been developed for 

housing and other recreational purposes. The refuge 

has been altered by roads, ditches, and structures. 

Other development activity includes the refuge irrigating grasslands to provide more forage for wintering elk. 

Although the National Elk Refuge does provide 

visitors with some opportunities for solitude and has 

educational and scenic value, overall the refuge does 

not meet the criteria for wilderness designation and 

we are not recommending any areas for inclusion in 

the Wilderness System.

Important Bird Area

The Flat Creek Marsh and Wetland Complex on 

the National Elk Refuge is recognized as an important bird area by the Audubon Society. Flat Creek 

Marsh is the largest wetland in northwestern Wyoming and the largest calcareous fen in the State. The 

area provides important breeding habitat for Wyoming SGCN such as trumpeter swan, redhead, lesser 

scaup, sandhill crane, and bobolink and is a critical 

migratory stopover for dozens of other bird species.

3.6 Visitor Services

The refuge provides numerous visitor services:

■ oversees a large elk and bison hunting program and fishing program

■ maintains and operates an interagency visitor center and exhibits that had more than 

320,000 visitors in 2010

■ maintains and operates a historic home and 

site that receives seasonal visitation of more 

than 3,000 people per year

■ coordinates a contracted sleigh ride program in 

the winter that averages 22,000 riders per year
Chapter 3—Refuge Resources and Description 77 

total elk numbers as close as possible to the WGFD 

herd objective of 11,000. From 1998 to 2002 about 

2,300 to 3,300 elk were harvested annually from the 

Jackson elk herd, resulting in removal of approximately 16 percent of the prehunt Jackson elk herd 

population each year. Hunter harvest accounted for 

nearly 90 percent of adult mortality in the Jackson 

elk herd during the 1990s (Smith 2000). The 2005 

harvest of 1,776 elk removed about 14 percent of the 

estimated 13,000 elk in the herd. Over the last 20 

years, harvest in the park has contributed about 25 

percent to the total harvest, and harvest on the refuge has contributed about 10 percent. The remaining 

65 percent of the harvest takes place mainly in the 

national forest (Teton Wilderness and the Gros Ventre River drainage). 

Some wildlife managers believe that, in the past, 

the eastern migratory segment of the herd (those elk 

that migrate east of Grand Teton National Park during the fall) were overharvested, largely because of 

increased road and other access on national forest 

lands. At the same time, western migratory segments were believed to have grown, decreasing hunting opportunities as more elk migrated through 

protected park areas. Concerted attempts to 

increase numbers in the eastern segments and to 

reduce numbers in the western segments by regulating hunting seasons and harvest strategies since the 

late 1980s have met with some success. Nevertheless, 

the elk reduction program in the park and hunting on 

the refuge can affect hunting opportunities and numbers of elk outside these areas. Consequently, refuge 

and park staffs work closely with WGFD in developing annual hunting quotas and regulations, so management of the entire herd is based on a holistic 

framework that includes all land and wildlife management responsibilities.

Bison

Bison hunting first occurred on the refuge in 1989 

and ended in 1990, with 39 bison taken during these 

two seasons. Hunting resumed in 2007 and continues 

to be popular on the refuge, attracting nonlocal, 

including out-of-state, hunters. The refuge provides 

one of the few opportunities in the Nation where 

hunters can pursue wild, unconfined bison in a fair 

chase hunt that could be eligible for a Boone and 

Crocket record. Since 2007, the total annual bison 

harvest in Jackson Hole has ranged from a high of 

266 to a low of 139. Most bison cows are harvested on 

the refuge, usually after deep snows move them from 

the protection of the Grand Teton National Park onto 

the refuge. Hunting at current levels on the refuge 

and the national forest has been sufficient to halt the 

exponential growth of the Jackson bison herd. However, Grand Teton National Park is closed to bison 

display in the visitor center also offers information on 

the need and purpose for hunting on refuges. 

Two large and significant hunting programs are 

conducted annually for elk and bison, each with their 

own seasons, regulations, and licensing system. The 

goal of these hunts is twofold: (1) to reduce elk and 

bison populations and achieve herd size objectives as 

specified in the Bison and Elk Management Plan; and 

(2) provide for wildlife-dependent priority public uses 

as legislated in the Improvement Act. 

Jackson Hole is a popular destination for both 

resident and nonresident hunters. The refuge manages the hunts in cooperation with WGFD, and special permits are required. The refuge allows 

permitted elk and bison hunters to access areas of 

the refuge not open to the general public. In addition, 

the refuge has accommodations for hunters with disabilities. Depending on the hunt area, we allow hunters to use a variety of weapons: (1) rifles; (2) archery 

equipment; and (3) designated limited-range weapons 

such muzzle-loading rifles, shotguns with slugs, and 

handguns. 

The best available data suggest that between 20 

and 40 percent of refuge hunters use lead-free ammunition. Research confirms the negative effect that 

lead ammunition has on scavenging bird populations 

such as bald eagles and ravens. The large harvest of 

elk and bison on the refuge and the resultant boon of 

gut piles has altered the migration patterns in bald 

eagles and potentially other raptors, placing a large 

number of these scavengers at risk of ingesting lead 

from bullets in gut piles.

Elk

Hunting is the primary management tool used to 

control the size of the Jackson elk herd. Hunting is 

the herd’s main cause of mortality. The first hunting 

season on the National Elk Refuge was in 1943, but 

hunting did not become an annual event until 1955. 

Refuge hunters apply for and receive refuge-specific 

permits online through a WGFD Web site. We have 

historically designated the first weekend of the season, usually in October, for young hunters (ages of 14 

to 17). Bulls may be taken during the first week; the 

rest of the season is restricted to cow and calf hunting. From 2007 to 2011, WGFD issued an average of 

3,724 hunting licenses for the Jackson elk herd, with 

an average of 1,465 elk harvested each season. In 

2013, WGFD issued 3,082 licenses, and 1,481 elk were 

harvested. Of that total, 186 were harvested on the 

refuge.

Hunting on the refuge and the elk reduction program in Grand Teton National Park, along with harvest in Bridger-Teton National Forest and on 

non-Federal lands, takes place from late September 

to mid-December. These methods are used to bring 
78 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

species and the only trout native to the area. The refuge promotes quality fishing for wild native fish. The 

Flat Creek fishery is managed for a native, wild, and 

trophy-sized Snake River cutthroat trout population. 

Long-time devotees of Flat Creek report a decline in 

the opportunity to fish for large cutthroats. Furthermore, recent fish surveys show that nonnative trout 

(brook, brown, and rainbow) account for almost half 

of the trout population of the stream. 

Lower Flat Creek opens to fishing on August 1 

and is the most popular fishing water on the refuge. 

The section from the Jackson National Fish Hatchery 

to the old Crawford Bridge boundary is the most 

heavily fished area. This piece of stream is renowned 

for holding trophy-sized Snake River cutthroat trout. 

Locally, cutthroats over 20 inches in length are recognized as trophy-sized, and this part of stream 

annually produces fish in the 22- to 24-inch range. 

The stream is crowded with anglers from opening 

day through August, and then use tapers off until the 

October 31 closing.

In 2011, the refuge received two verbal comments 

from anglers about guided fishing trips on lower Flat 

Creek. Both parties believed that guided trips were 

unnecessary and undesirable and contributed to 

streamside crowding. The refuge issued nine permits 

for guided fishing in 2011, which accounted for an 

estimated 135 people (guides and clients) using the 

streamside on lower Flat Creek. Refuge law enforcement contacted three additional guided trips, without 

refuge permits, that included groups of seven, five, 

and three individuals. We do not know the extent of 

the illegal, unpermitted, guided fishing activity. Generally, it seems as if the refuge permit requirement is 

disrespected.

Wildlife Observation and 

Photography

In 2001, the refuge had 780,299 visitors participate in onsite interpretation and nature observation. 

Visitation included 24,664 sleigh riders, 304,987 stops 

at the visitor center, and 439,148 visitors using observational facilities such as auto turnouts. In 2013, 14 

wildlife-viewing companies under special use permit 

made 604 trips with 2,540 clients, as documented in 

the special use reports required of the permittees at 

the end of the season. 

Sleigh rides are a well-established activity and 

have been part of the refuge wildlife observation and 

outreach program for close to 50 years. During the 

2011–12 winter season, ridership reached 20,705. The 

unique wildlife-viewing opportunity raises awareness of the refuge, receives national as well as interLori Iverson / FWS

Fishing is popular on the refuge.

hunting, and this has become a safe zone that bison 

use to avoid harvest. As a result, the bison herd is 

still about 70 percent above the 500 population 

objective. 

Presently, the Shoshone-Bannock Tribes enjoy a 

ceremonial bison hunt on the refuge.

Fishing

The refuge provides fishing opportunities during 

daylight hours as a compatible wildlife-dependent 

recreational opportunity from April 1 through October 31, with fly-fishing being the preferred technique. 

We allow carefully regulated fishing on the refuge to 

the extent that it does not conflict with objectives of 

the refuge and the State of Wyoming. The Gros Ventre River, Flat Creek, lower Nowlin Creek and Sleeping Indian Pond are open to fishing according to 

season dates and regulations set by WGFD. All other 

refuge ponds—Flat Creek downstream from the old 

Crawford Bridge site, and Nowlin Creek upstream 

from the posted fishing boundary—are closed to fishing. The fishing program is popular with local and 

visiting anglers, attracting about 4,500 anglers each 

season. Traffic to refuge waters supports local fishing tackle shops and fishing outfitters. 

Refuge waters support a wild population of Snake 

River cutthroat trout, a unique variety of cutthroat 
Chapter 3—Refuge Resources and Description 79 

Jackson Hole and Greater 

Yellowstone Visitor Center

The Jackson Hole and Greater Yellowstone Visitor Center, on the southern end of the refuge, plays a 

critical role in Jackson’s tourism-based economy, 

serving approximately 300,000 people each year and 

providing a wide range of visitor services. The visitor 

center is often the first place that people stop at for 

information during their visit to the Jackson area, 

and many hotels and businesses, including the chamber of commerce, encourage people to go the visitor 

center to get information. Displays in the visitor center give an overview of the role of Federal lands and 

State wildlife agency partners. The information is 

shared in presentations, talks to key groups, and in 

news releases when possible. 

The visitor center building is more than 40 years 

old and has several maintenance deficiencies, including some that affect visitor safety, and the building 

does not meet requirements of the Architectural 

Barriers Act Accessibility Standard (United States 

Access Board 2013). The visitor center does not have 

space to hold programs for the large number of visitors that we see during peak visitation or for visiting 

youth and school groups.

The visitor center is an interagency facility, 

staffed and supported by area agencies and organizations—Bridger-Teton National Forest, Grand Teton 

Association, Grand Teton National Park, Jackson 

Hole Chamber of Commerce, and National Elk Refuge. Operation of the visitor center helps the partner 

agencies distribute information and permits vital to 

their organizations.

While directly quantifying the economic impacts 

of the visitor center is difficult because of a number of 

factors, the importance of the Center itself, as well as 

the value of the service and information provided to 

visitors by Refuge staff, should not be overlooked or 

discounted.

Other Uses

Areas such as North Highway 89 Pathway and 

North Park have special considerations and management. Also, we manage several commercial and noncommercial activities on the refuge under special use 

permit.

North Highway 89 Pathway

We constructed a multi-use pathway on the eastern side of the refuge that opened to the public on 

national attention, and is frequently listed in 

travel-related articles, Web sites, and publications as 

a top attraction in Jackson Hole during the winter. 

Sleigh drivers are knowledgeable of wildlife viewing 

etiquette and are experienced in recognizing actions 

that cause stress to animals. The sleigh ride contract 

stipulates that the refuge receives a percentage of 

revenue generated by the sleigh ride operation; we 

use this money to hire a seasonal winter naturalist. 

A 2002 survey of refuge sleigh ride visitors found 

that elk viewing was the most frequent local and 

nonlocal visitor activity, followed by sightseeing, 

snow skiing, and pleasure driving (Loomis and 

Caughlan 2004). The survey also asked about the 

overall importance of activities in terms of deciding 

to take recreation trips to Jackson Hole. The numbers reflect the average importance of an activity and 

its relative importance in terms of attracting people 

to Jackson Hole. Viewing the mountains was rated as 

the most important activity by local and nonlocal refuge visitors, followed by viewing elk, other wildlife, 

and bison (Loomis and Caughlan 2004).

Environmental Education and 

Interpretation

Public programming, such as daily talks at the 

visitor center and special events for families, is 

offered year-round. The North Highway 89 Pathway 

gives the refuge staff an area for guided walks to 

interpret wetland values. Refuge staff does extensive 

training and communication with the sleigh ride contractor and staff to make sure the operation offers a 

quality interpretive experience, expresses the mission of the refuge, and does not create conflicts with 

wintering wildlife.

However, the refuge does not have staff to meet 

the high public demand for environmental education 

and interpretation programs. The refuge uses nongovernmental money to hire winter naturalists or 

uses volunteers to meet the demand for environmental education and interpretive programs during the 

school year. During the summer months when visitor 

center visitation peaks, the refuge relies on a large 

residential volunteer workforce as the primary 

means to offer formal and informal interpretation.

Room for program attendees at the visitor center 

is extremely limited during winter or times of 

inclement weather. Further, it lacks sufficient accommodations for persons with physical disabilities and 

does not meet the requirements of the Architectural 

Barriers Act Accessibility Standard (United States 

Access Board 2013).
80 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

age of the revenue generated by the sleigh ride 

operation. This money is collected and deposited into 

an account administered through the Grand Teton 

Association and is a source of nongovernmental 

money that we use to hire a seasonal winter 

naturalist. 

Guided Hunting, Guided Fishing, and Retrieval 

Services

Game retrieval businesses have operated on the 

refuge for decades and provide a convenient service 

to hunters. Starting in 2008, two companies operating under special use permit provided guided hunts 

for elk and bison. In 2010, the refuge issued two permits to operators who each provided guided hunting 

and game retrieval services to hunters.

Commercial Photography and Filming

We require all photographers, videographers, and 

media to obtain a special use permit. Some requesters want access to areas of the refuge not open to the 

public. Permits specify what areas are allowed for 

access including stipulations for use of the areas.

The National Elk Refuge accommodates a large 

number of commercial photographers and film companies each year, especially during the winter. In 

addition, the refuge receives an extensive amount of 

local, regional, national, and international media 

attention. Media coverage includes print, electronic, 

and video and film venues. Responding to media 

requests has become an increasing part of the visitor 

service program’s winter duties. 

Because the refuge is a focus of media attention 

and millions of people visit this area each year, we 

have the opportunity to be an ambassador for the 

Refuge System and the mission of the U.S. Fish and 

Wildlife Service. 

Weddings

A substantial number of people request to hold a 

wedding ceremony at the visitor center, at North 

Park, at Miller House, or on a sleigh ride. Many of the 

couples do not request permission to marry on the 

refuge, but rather show up with a justice of the peace 

or other official to conduct the ceremony.

Weddings in the visitor center can detract from 

other visitors’ experience because the long, linear 

design of the building makes it difficult for groups to 

stand out of the way of people walking through the 

building, looking at the exhibits, or enjoying the 

views or wildlife-viewing opportunities. Depending 

on the size of the wedding party, a wedding at the 

visitor center can result in a loss of available parking 

spaces for visitors using the center to learn about the 

area and get visitor service information.

Occasionally, people hold weddings on the visitor 

center lawn or under a shelter area on the North 

May 1, 2011. The North Highway 89 Pathway runs 

adjacent to the refuge fence from Jackson to the Gros 

Ventre Junction and passes through several types of 

habitat. We do not allow pets on the pathway. Further, the refuge closes the pathway seasonally 

(between November 1 and April 30) to reduce the 

effects on migrating and wintering wildlife. 

North Park

The town of Jackson manages North Park 

(located on the refuge) as a public park under a memorandum of understanding with the refuge. North 

Park is mowed, weeded, and otherwise maintained, 

similar to the way Jackson maintains its public parks. 

Currently, the Teton County Parks and Recreation 

Department uses an online system and collects fees 

for reserving North Park for activities such as weddings; however, reservations and fee collection are 

not in compliance with our agency policy. 

Special Uses

The refuge issues about 50 special use permits per 

year, which the visitor services staff administers. 

The refuge allows several restricted public use activities under special use permit, providing services we 

could not otherwise offer to the public because of 

limited funding and staff. Refuge staff assesses each 

activity for which a special use permit is required 

and develops specific special conditions for that particular activity. Common special uses follow:

■ guided wildlife-viewing tours

■ guided hunting trips

■ guided fishing trips

■ elk and bison retrieval services

■ commercial photography and filming

■ Shoshone–Bannock Tribes ceremonial hunt

■ antler collection (refer to “Partnerships” in 

section 3.8 below)

■ grazing

■ research

Wildlife Viewing

In 2014, 16 wildlife-viewing companies applied for 

special use permits to conduct tours on Elk Refuge 

Road. In addition, the refuge coordinates the winter 

sleigh ride contract. The refuge receives a percent-
Chapter 3—Refuge Resources and Description 81 

the refuge and the Grand Teton National Park to create a comprehensive river management plan to guide 

the management of each segment designated as wild, 

scenic, or recreational for a 15-year period. This public process has been completed and the plan has been 

completed and signed by these agencies.

Access to the National Forest

Winter users of the Goodwin Lake Ski Cabin on 

the Bridger-Teton National Forest have limited 

access across the refuge to reach the national forest 

boundary. The refuge plows a parking area for three 

cars and allows people to cross refuge lands to get to 

national forest lands. Our visitor services staff issues 

special use permits for this access.

3.7 Socioeconomic 

Environment

Jackson is the primary destination for visitor 

activities in Jackson Hole, and Jackson serves as the 

gateway community to the National Elk Refuge, 

Grand Teton National Park, Bridger-Teton National 

Forest, and Yellowstone National Park. Natural and 

scenic resource issues have a direct and profound 

effect on the economic well-being of Jackson Hole. 

Most of the economic activity related to the Refuge is located within the two-county area of Teton 

County, Idaho, and Teton County, Wyoming; therefore, these counties comprise the local economic 

region for this analysis. The refuge is also a partner 

in the establishment and daily operations of the Jackson Hole and Greater Yellowstone Visitor Center 

located just minutes from the Refuge entrance.

Population, Ethnicity and 

Education

Table 10 compares population estimates and 

trends for Teton County, Idaho, and Teton County, 

Wyoming. In 2012, Teton County, Idaho, and Teton 

County, Wyoming, accounted for 0.6 percent and 3.8 

percent of the Idaho and Wyoming populations, 

respectively. From 2000 to 2012, the population 

growth rate for Teton County, Idaho, was 67.6 percent, far outpacing that of the state as a whole (23.3 

percent). The growth rate in Teton County, Wyoming, population was slightly higher than that of 

Wyoming (18.8 percent to 16.7 percent). 

Park lawn without prior consent from the refuge or 

visitor center staff. The visiting public does not recognize the park as refuge property, and there is no 

notice that prohibits weddings on the park’s lawn. 

Consequently, weddings frequently take place on the 

site. Again, this limits other visitors’ opportunities to 

use these areas for other purposes. 

Some of our seasonal employees live in Miller 

House during both the winter and summer seasons. 

Weddings at this location would have a significant 

adverse effect on these employees. In addition, no 

public rest rooms are available at Miller House.

Private sleigh rental to hold a wedding ceremony 

provides an economic benefit for the contractor and 

reduces effects on other refuge activities and users. 

Access

Many visitors are interested in accessing the refuge to enjoy what it offers. Other people want to 

travel through the refuge to access private land or 

other Federal land.

General Access and Elk Refuge Road

Elk Refuge Road, which stems north of the east–

west Broadway Avenue in Jackson, is the primary 

access to the refuge and the only legal entrance to 

the refuge for the public. Teton County has a perpetual easement for the operation, maintenance, and 

improvement of Elk Refuge Road from Broadway 

Avenue to the north side of the Twin Creek subdivision. The purpose of the easement is to provide the 

public and private landowners of property east of the 

refuge with ingress and egress across part of the 

southeast corner of the refuge. Because of the ease of 

access to the refuge and its proximity to town, local 

residents use Elk Refuge Road extensively for walking, jogging, and bicycling.

Access for Boating

The northern boundary of the refuge is the north 

shore of the Gros Ventre River, which places the Gros 

Ventre River on the refuge. Boaters floating down 

the Gros Ventre from Slide Lake are required to exit 

the river at the “jump cliff” site immediately on 

entering the refuge. This long-standing closure of the 

Gros Ventre River on the refuge has been in place 

because of the potential disturbance to wildlife and 

because this is not a wildlife-dependent activity. 

The refuge segment of the Gros Ventre River 

upstream from the town of Kelly was recently designated as scenic under the Craig Thomas Snake River 

Headwaters Legacy Act of 2008. This act requires 
82 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Table 11. State and county income, unemployment, and poverty statistics.

Median 

household income 

(2011)

Percentage of 

individuals below 

poverty (2011)

Percentage 

unemployed 

(2011)

Change in percent 

unemployed 

(2000–2011)

Idaho $46,890 14.3 5.1 1.3

Teton County $52,444 7.2 6.8 4.4

Wyoming $56,380 10.1 3.3 -0.2

Teton County $73,627 7.6 2.9 0.6

Source: (United States Census Bureau 2010a)

Table 10. State and county population estimates.

Residents 

(2012)2

Persons per square 

mile (2012)2

Percent population 

change (2000–2012)2

Percent bachelor’s 

degree or higher1

Idaho 1,595,728 19.1 23.3 24.6

Teton County 10,052 22.3 67.6 33.2

Wyoming 576,412 5.9 16.7 24.2

Teton County 21,675 5.1 18.8 52.7

Source: 1(United States Census Bureau 2012a) 2(United States Census Bureau 2012b).

Regional Employment and Income

Table 11 shows the median household income, poverty, and unemployment rates for the two-county 

study area and corresponding states. As of 2011, 

median household income for Teton County, Idaho, 

was higher than that for Idaho ($52,444 compared to 

$46,890). The household median income of residents 

of Teton County, Wyoming, far exceeded that of the 

state as a whole ($73,627 compared to $56,380) 

(United States Census Bureau 2012a). In 2011, nonlabor income constituted 53.1 percent of total personal income for Teton County, Wyoming, compared 

to 35.7 percent for Teton County, Idaho, and the 

national average of 34.1 percent (Bureau of Economic 

Analysis 2012a).

In 2011, the percent of the population in Teton 

County, Idaho, living below the poverty line was 

lower than both the state and national figures (7.2 

percent compared to 14.3 percent and 15.9 percent, 

respectively). Similarly, the percent of the population 

of Teton County, Wyoming, living below the poverty 

line was below that of Wyoming (7.6 percent compared to 10.1 percent, respectively). From 2000 to 

2011, Teton County, Idaho, experienced a 4.4 percent 

increase in its unemployment rate, compared to a 1.3 

percent increase for the state as a whole. The unemployment rate of Teton County, Wyoming, increased 

slightly by 0.6 percent over the same time period, 

though the unemployment rate of the state of Wyoming declined by 0.2 percent (United States Census 

Bureau 2012a). This is likely due to the high concenThe percentage of the Teton County, Idaho, population aged 25 or older with at least a Bachelor’s 

degree is higher than both the state and national 

averages (33.2 percent compared to 24.6 percent and 

28.2 percent). Over half of the population of Teton 

County, Wyoming, (52.7 percent) aged 25 or older 

holds at least a Bachelor’s degree, while only 24.2 

percent of the population of the state of Wyoming 

holds at least a Bachelor’s degree (United States 

Census Bureau 2012a).

In 2011, 81 percent of the population of Teton 

County, Idaho, self-identified as white, not of Hispanic or Latino origin, compared to 81.6 percent of 

the Teton County, Wyoming, population. Both of 

these figures were lower than the respective state 

averages (83.6 percent for Idaho and 85.5 percent for 

Wyoming). Meanwhile, 17.2 percent of Teton County, 

Idaho, residents (compared to 11.5 for the state of 

Idaho) and 15.4 percent of Teton County, Wyoming, 

residents (compared to 9.4 percent for the state of 

Wyoming) self-identified as of Hispanic or Latino 

origin (United States Census Bureau 2012a).
Chapter 3—Refuge Resources and Description 83 

Table 12. Employment by sector, 2011, in Teton 

County, Idaho, and Teton County, Wyoming.

Industry 2011 Percent 

of Total

Total employment 31,459 

Wage and salary employment 20,600 65.5

Proprietors employment 10,859 34.5

Farm proprietors employment 370 1.2

Nonfarm proprietors employment 10,489 33.3

Farm employment 612 1.9

Private nonfarm employment 27,826 88.5

Forestry, fishing, and related activities 32 0.1

Mining 63 0.2

Utilities * 0

Construction 2,706 8.6

Manufacturing 435 1.4

Wholesale trade 79 0.3

Retail trade 2,401 7.6

Transportation and warehousing 461 1.5

Information 431 1.4

Finance and insurance 1,963 6.2

Real estate and rental and leasing 3,608 11.5

Professional, scientific, and 

technical services 1,902 6

Management of companies and 

enterprises 56 0.2

Administrative and 

waste management services 1,465 4.7

Educational services 415 1.3

Health care and social assistance 1,155 3.7

Arts, entertainment, and recreation 1,456 4.6

Accommodation and food services 6,640 21.1

Other services, 

except public administration 1,423 4.5

Government and 

government enterprises 3,021 9.6

Federal, civilian 462 1.5

Military 160 0.5

State and local 2,399 7.6

Source: (Bureau of Economic Analysis 2012b)

* Not shown to avoid disclosure of confidential information, 

but the estimates for this item are included in the totals.

tration of service-related employment within these 

two counties.

Table 12 shows percent employment by sector for 

the two-county area. The combined two-county area 

had a total employment of more than 31,400 individuals in 2011. Farm employment accounted for nearly 2 

percent of the workforce. The highest percentage of 

total employment was found in the accommodation 

and food service sectors (21.1 percent of non-farm 

employment). The real estate rental and leasing and 

government and government enterprises sectors had 

the second and third largest percentage of total nonfarm employment (11.5 percent and 9.6 percent, 

respectively). Forestry, fishing and related activities 

accounted for less and 1 percent of non-farm employment (Bureau of Economic Analysis 2012b).

Agriculture

In 2007, there were 299 farms in Teton County, 

Idaho, which reflects a decrease of 3 farms since 

2002. Acreage of cropland also fell over this time 

period from 91,979 acres to 85,149 acres (U.S. 

Department of Agriculture 2007). Agricultural sales 

for Teton County, Idaho, in 2007 totaled $33 million 

which represents an increase in sales from the 2002 

figure of $24.1 million. Ranking 26th statewide in 

total agricultural sales in 2007, the top selling products of Teton County, Idaho, were vegetables, melons, 

potatoes, and sweet potatoes ($16.2 million), cattle 

and calves ($3.4 million), and nursery, greenhouse, 

floriculture, and sod ($2.8 million) (U.S. Department 

of Agriculture 2007).

From 2002 to 2007, the total number of farms in 

Teton County, Wyoming, increased from 110 to 180, 

but the county experienced an overall decrease in 

total farmland, from 57,089 acres to 52,930 acres 

(U.S. Department of Agriculture 2007). During the 

same time period, the market value of agricultural 

products sold increased by 24 percent, from $7.4 million to $9.2 million. Cattle and calf sales totaled $5.3 

million in 2007, accounting for more than half of total 

agricultural sales. Other top selling agricultural 

products within the county were, grains, oilseeds, 

dry beans, and dry peas sales worth $747,000 (U.S. 

Department of Agriculture 2007).

Recreation and Tourism

Angling, hunting, and wildlife viewing are popular recreational activities across Wyoming and Idaho 

and within the two-county area. According to our 

2011 report, “National Survey of Fishing, Hunting, 

and Wildlife-Associated Recreation,” approximately 

838,000 and 775,000 residents and nonresidents participated in wildlife-associated activities in Idaho and 

Wyoming, respectively (FWS 2012). All visitors to 
84 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

biling, Nordic skiing, snowshoeing, dog sledding, 

wildlife tours, and scenic flights. Popular summer 

opportunities include hiking, camping, whitewater 

rafting, golfing, horseback riding, mountain biking, 

scenic tours, and wildlife tours. Noteworthy summer 

festivals include the Jackson Hole Art Fair, Grand 

Teton Music Festival, and the Teton County Fair 

(Jackson Hole Chamber of Commerce 2013).

Economic Contributions of the 

Refuge

The refuge contributes to the local economy in 

several ways: 

■ Refuge employees rely and spend money on 

local services in their personal lives. 

■ We locally buy many supplies and services 

to manage the refuge. 

■ The visitors who the refuge brings to Jackson Hole spend money in the area. 

U.S. Fish and Wildlife Service Employment

Refuge employees reside and spend their salaries 

on daily living expenses in the local area, thereby 

generating impacts within the local economy. Household consumption expenditures consist of payments 

by individuals or households to industries for goods 

and services used for personal consumption. 

Current annual salaries total approximately 

$1,021,000. It is estimated that salary spending by 

refuge personnel generates the annual secondary 

effects of three jobs, $120,300 in labor income, and 

$225,200 in value added in the local economy.

Antler Sales

Since the late 1950s, the Jackson District Boy 

Scouts have picked up elk antlers on the refuge each 

spring under a special use permit, and then the 

Scouts sell the antlers. Approximately 75 percent of 

the proceeds from the auction go to the refuge for elk 

management. The amount received in 2012 was 

$90,469 for 7,398 pounds of antlers. The 10-year average is 8,369 pounds of antlers yielding $76,941.

Visitor Spending 

Spending associated with recreational visits to 

national wildlife refuges generates substantial economic activity. The Service report, Banking on 

the refuge who engage in wildlife watching are considered away-from-home participants. In Idaho, residents and nonresidents spent over 3.2 million days 

hunting and over 5.5 million days fishing, with residents of the state accounting for 61 percent of hunting days and 86 percent of angling days. In Wyoming, 

residents and nonresidents spent over 1.7 million 

days hunting and over 5.3 million days fishing. Residents of the state accounted for 64 percent of hunting 

days and 38 percent of angling days. 

For the purpose of the National Survey, wildlife 

watching is categorized into (1) away-from-home 

(activities taking place at least 1 mile from home) and 

(2) around-the-home (activities taking place within 1 

mile of home). In 2011, residents and nonresidents in 

Idaho spent a total of 3.8 million days watching wildlife away from home, with residents accounting for 86 

percent of wildlife watching days. In Wyoming, residents and nonresidents spent 3.1 million days watching wildlife away from home and residents accounted 

for 36 percent of wildlife watching days. 

Across both states, in-state spending associated 

with these activities totaled $5.5 million (2011 dollars), with $3 million spent on trip-related expenditures, $2 million spent on equipment, and $526 

thousand spent on other items (FWS 2012).

Important to the economies of both counties, 

travel- and tourism-related employment accounted 

for 46.8 percent of total private employment in Teton 

County, Wyoming, in 2011, and 15.6 percent of total 

private employment in Teton County, Idaho. The economic sectors comprising this category include retail 

trade, passenger transportation, arts, entertainment 

and recreation, and accommodations and food. Of 

these sectors, accommodations and food services jobs 

accounted for 35.4 percent of total private employment in Teton County, Wyoming, and 11.2 percent of 

private employment in Teton County, Idaho. 

Although a large portion of the employment in these 

counties is in these travel and tourism sectors, average annual wages in travel and tourism sectors were 

substantially lower than mean wages across all private sectors (United States Census Bureau 2013).

Among the major tourist attractions for Teton 

County, Idaho, are downhill and Nordic skiing, snowboarding, and snowmobiling, as well as the Teton 

Valley Great Snow Fest, which takes place in the city 

of Driggs. Teton County, Idaho, also hosts a summer 

festival, which includes a hot air balloon rally, craft 

fair, antique show, rodeo, and parade. Additional 

attractions include fly fishing, golfing, horseback riding, mountain biking, and river sports (Teton Valley 

Chamber of Commerce 2013).

The tourism industry in Teton County, Wyoming, 

benefits from the county’s natural amenities, which 

offer year-round activities for visitors. In addition to 

two local ski areas, winter activities include snowmo-
Chapter 3—Refuge Resources and Description 85 

the refuge had 10 permanent FTE positions, but the 

analysis found that a minimum of 18 permanent FTE 

positions was necessary to conduct the programs—a 

45-percent staff deficit. The current staff level of 10.5 

FTE positions is insufficient to achieve the refuge 

goals. To address this need for staff, we rely on 12.5 

FTEs of volunteers and seasonal staff, counting on 

uncertain nongovernmental money, to conduct refuge 

programs. A list of the additional, nonpermanent 

assistance follows:

■ 1 volunteer for biological program fieldwork 

■ 8 seasonal irrigators

■ 1 seasonal operator for supplemental 

feeding 

■ 8 detailed (from other refuges) law enforcement officers to patrol during the May 1 

national forest opening for antler collection

■ 2 seasonal National Park Service law 

enforcement officers for hunting season 

enforcement

■ 20 volunteers to staff the visitor center and 

Miller House

■ 3 winter naturalists

Nature: The Economic Benefits of National Wildlife 

Refuge Visitation to Local Communities, estimated 

the impact of national wildlife refuges on their local 

economies (Carver and Caudill 2013). More than 46.5 

million people visited the national wildlife refuges in 

fiscal year 2011, which generated $2.4 billion of sales 

in regional economies. Accounting for both the direct 

and secondary effects, spending by national wildlife 

refuge visitors generated over 35,000 jobs and $792.7 

million in employment income (Carver and Caudill 

2013). Additionally, spending on refuge recreation 

generated approximately $342.9 million in tax revenue at the local, county, State, and Federal levels 

(Carver and Caudill 2013).

3.8 Operations

Operations involve the administrative, or logistical, aspects of managing the refuge: money, staff, 

facilities, and partners.

Funding and Staff

In 2008, the Service conducted a nationwide staff 

analysis for all national wildlife refuges. At that time, 

Mike Pfiel / FWS

Local Boy Scouts collect antlers on the refuge every year for an auction that also benefits elk refuge management.
86 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Lori Iverson / FWS

Jackson, Wyoming

only one partner in the visitor center helps with the 

operations or maintenance costs with short-term 

funding. However, in accordance with the Grand 

Teton Association’s establishing mission and guidelines, the nonprofit organization returns a portion of 

sales projects to the refuge for educational and interpretive programs. Routine operational costs, including heating and cooling, cleaning, electricity, gas, 

phone and Internet service, snow removal, and supplies were about $80,000 in 2011. The collaborative 

partnership approach to funding the operation of the 

visitor center enables the refuge to provide important visitor services to more people than it could 

under current budget levels. The visitor center manager is a refuge employee, benefitting the other partner agencies at no cost to their organizations. The 

manager has the following duties:

■ compiling and disseminating a weekly 

schedule for approximately 30 people that 

work at the center

■ training employees and volunteers on all 

aspects of information desk services

■ presenting education and interpretation 

programs

Facilities

We rely on facilities such as the visitor center, 

maintenance buildings, and refuge housing to give 

the public and our staff a safe, inviting place to visit 

and to work, respectively. Other infrastructure, such 

as pathways and roads, let visitors have on-theground experiences in the refuge and help our staff 

efficiently carry out management activities.

Visitor Buildings

Several refuge buildings are more than 50 years 

old and qualify for protection under the National Historic Preservation Act. The continued maintenance, 

use, and staffing of these buildings preserves their 

historic value while providing the public with a connection to refuge history.

The refuge has two primary visitor services facilities: Jackson Hole and Greater Yellowstone Visitor 

Center and Miller House. The maintenance and use 

of these facilities are vital in achieving refuge goals 

for environmental education and interpretation. 

At the Jackson Hole and Greater Yellowstone 

Visitor Center, each partner agency is required to 

provide only minimal staff at the information desk. 

The refuge staff manages and maintains the facility; 
Chapter 3—Refuge Resources and Description 87 

Road. We maintain parking space for several vehicles 

at a marked trailhead at our boundary with the 

Bridger-Teton National Forest.

Partnerships

The National Elk Refuge has a history of fostering partnerships that help accomplish the refuge 

programs. We have entered into various projects and 

activities with many partners including conservation 

organizations, private companies and businesses, 

other Federal agencies, State agencies, universities, 

local schools, and county and city governments. The 

refuge also has an active volunteer program, primarily for visitor services. The refuge could not begin to 

meet the needs of the thousands of refuge visitors 

without these volunteers.

Partnerships are essential for operating the Jackson Hole and Greater Yellowstone Visitor Center. 

Information about wildlife and the different missions 

and uses of the various Federal lands in Jackson Hole 

enhances the public’s understanding about the purpose of the refuge. In addition, the visitor center 

provides an important service to the public by providing information about area accommodations, services, and available recreational activities.

Partners have assisted in wildlife and habitat 

management, visitor services, land protection, law 

enforcement, and community outreach. Several of 

these relationships have developed into formalized 

partnerships with written agreements or memoranda of understanding, while others remain more 

informal. The following describes some of our ongoing partnerships:

■ Bridger-Teton National Forest and Grand 

Teton National Park

■ Craighead Beringia South

■ Grand Teton Association

■ Greater Yellowstone Coordinating 

Committee

■ Jackson District Boy Scouts

■ Jackson Hole Weed Management 

Association

■ Teton County

■ Wyoming Game and Fish Department

■ managing the center budget and ordering 

supplies (such as trash bags, light bulbs, 

office supplies for the information desk, rest 

room supplies, paper products, and maps)

■ taking care of routine maintenance and 

other center issues

■ serving as the refuge volunteer coordinator 

for the region’s largest volunteer program

Refuge Housing

Government housing is available for rent on the 

refuge for approximately six families and up to eight 

seasonal employees. Sharing a seasonal housing unit 

may limit or deter some employees or volunteers. All 

refuge housing suitable for permanent staff is occupied. Seasonal irrigators are housed in refuge travel 

trailers as part of their compensation package.

Parking sites for recreational vehicles and trailers 

with water, sewer, and electrical hookups are available to accommodate about 25 volunteers who can 

provide their own recreational travel trailers. We 

provide these sites free to volunteers who work a 

minimum of 20 hours per week per person.

Elk Refuge Road

Elk Refuge Road, Flat Creek Road, and the Curtis Canyon Road are open to the public for wildlife 

observation and access to the national forest from 

May 1 through November 30. During winter, 3.5 

miles of Elk Refuge Road are open to provide access 

to private property (and minor access to the national 

forest), as well as to provide wildlife-viewing opportunities such as for bighorn sheep.

Elk Refuge Road provides safe, reasonable, uninterrupted access (ingress and egress) for the refuge 

staff, the public, and private owners year-round. The 

road has 12 turnouts that are plowed by refuge staff 

during winter to encourage vehicles to move off the 

road to view wildlife. There is a no-stopping regulation for people driving on Elk Refuge Road. 

Teton County has an easement on Elk Refuge 

Road, retaining the responsibility for general maintenance and improvements to the road. Traffic on the 

road has no limits for the number of vehicles allowed, 

including people conducting commercial operations 

on the roadway. Magnesium chloride (salt)-treated 

water, applied by Teton County for dust abatement 

during the summer, remains on the road surface 

throughout the year.

The refuge has authority to control parking along 

a 30-foot right-of-way on either side of Elk Refuge 
88 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

the Grand Teton Association and the private sleigh 

ride contractor.

The visitor center and sleigh rides are integral to 

wildlife observation, photography, and interpretation 

on the refuge and generate revenue used to provide 

these programs.

Greater Yellowstone Coordinating 

Committee

The Greater Yellowstone Coordinating Committee is a coalition of all Federal land management 

agencies within the Greater Yellowstone Ecosystem. 

The refuge has been a member of the committee 

since 2002. Members include national wildlife refuge 

managers, national park superintendents, and 

national forest supervisors for their units within the 

ecosystem. A memorandum of understanding provides a vehicle for mutual cooperation and coordination in the management of these Federal lands. The 

committee periodically identifies resource management issues where coordination across the Greater 

Yellowstone Ecosystem is desirable. By leveraging 

financial and management efforts, these Federal land 

managers can best address ecosystem-wide threats 

and opportunities. 

Jackson District Boy Scouts

The refuge has enjoyed a 55-year partnership 

with the Jackson District Boy Scouts. Hundreds of 

Scouts have earned badges of achievement while conducting outdoor activities on the refuge. 

The most popular activity for the Scouts is helping 

the refuge with the collection of shed elk antlers each 

spring, which they do under special use permit. This 

program reduces damage to feeding equipment, prevents trespassing and antler poaching, and stops 

unnecessary disturbance to the elk herds. These antlers pose a hazard to refuge equipment because they 

can puncture vehicle tires and damage track assemblies, especially during the supplemental winter feeding operations and spring programs like harrowing 

and irrigating. The antlers can become obscured by 

snow and dried grasses, making them impossible to 

see and avoid by vehicle and equipment operators. 

The antlers are sorted, bundled, weighed, tagged, 

and sold at the Boy Scouts of America Elk Antler 

Auction in the Jackson town square on the Saturday 

before Memorial Day weekend each year. About 120 

bidders from 28 States, representing local buyers, 

western export houses, and regional crafts people, 

usually attend. The 10-year average is 8,369 pounds 

of antlers yielding $76,941. The Scouts donate 75 percent of the proceeds from the auction to the refuge. 

Bridger-Teton National Forest and Grand 

Teton National Park

Cooperative agreements between the refuge, the 

Bridger-Teton National Forest, and the Grand Teton 

National Park provide important wildfire suppression capability that the refuge does not have. Fire is 

a natural ecosystem process, but wildfires 

(unplanned) can be destructive to agency facilities 

and sometimes obstruct wildlife management efforts. 

For example, a wildfire in September that would 

remove most of the refuge forage intended for use by 

wintering elk and bison would be counterproductive 

to the refuge’s management strategy. This partnership helps prevent damage to wildlife habitat, refuge 

structures, and adjacent private lands.

Craighead Beringia South

The discovery of elevated blood-lead levels in 

scavenging birds on the refuge and Grand Teton 

National Park is a good example of positive involvement by a nongovernmental organization. Craighead 

Beringia South—a private, nonprofit, wildlife 

research organization—not only conducted the 

research that identified the blood-lead level problem, 

but they also obtained private money to help mitigate 

the problem. As a result of their involvement, a program for voluntary use of lead-free ammunition was 

established for Federal lands in Jackson Hole and is 

showing positive results in reducing lead exposure to 

specific wildlife populations.

Grand Teton Association

The Grand Teton Association has shown exceptional leadership and remarkable assistance in supporting the Jackson Hole and Greater Yellowstone 

Visitor Center. In 2011, the association completed the 

purchase of the visitor center building, which they 

promptly donated to the refuge, a gift valued at $1 

million. This facility serves more than 300,000 visitors annually and is a tremendous asset to Jackson’s 

tourist-based economy. Financial support from the 

association has been invaluable in providing temporary staff to run the visitor center when key positions are vacant. We use proceeds from the visitor 

center sales outlet that is run by the Grand Teton 

Association to support environmental education, 

interpretation, and wildlife research programs.

The Grand Teton Association coordinates with a 

private concessionaire to conduct winter sleigh ride 

tours that serve 20,000 to 25,000 refuge visitors each 

year. The refuge does not have the resources to provide this program to the public, and the sleigh rides 

are only made possible through our partnership with 
Chapter 3—Refuge Resources and Description 89 

interpretation on the refuge. The refuge works with 

Teton County and other private, nonprofit organizations to inform the public of use restrictions on the 

pathway that are necessary for compatibility. This 

has helped reduce conflicts with wildlife and has 

reduced violations. Public compliance with these 

restrictions helps ensure that use of the pathway 

remains a compatible use and that the pathway is 

open to the public in the future.

Wyoming Game and Fish Department

Cost sharing with partner organizations for projects of mutual interest and benefit is a common 

approach to leveraging limited refuge money. An 

example of cost sharing is our cooperation with 

WGFD to monitor chronic wasting disease on the 

refuge and in Jackson Hole. The refuge has contributed money to help defray the cost of seasonal technicians who collect samples from hunter-harvested 

deer and elk. The WGFD supervises these technicians, coordinates the sampling schedule, analyzes 

the samples, and writes the annual report. This costsharing partnership enables a disease detection program on the refuge that is vital to both agencies and 

likely could not be conducted at a high level of confidence without this collaboration.

We use this money primarily for habitat projects like 

the operation of the irrigation system to provide 

more forage for wintering elk. In the past, we have 

used the proceeds to acquire equipment to improve 

habitat and pay for seasonal irrigators.

Jackson Hole Weed Management 

Association

Invasive plants like spotted knapweed and cheatgrass reduce natural vegetation diversity and are a 

problem throughout Jackson Hole. Our participation 

and cooperation with the Jackson Hole Weed Management Association has resulted in a partnership to 

address this landscape problem on and off the refuge. 

These partners have given us technical and plant 

control assistance for eradication efforts on the refuge. In addition, control efforts for invasive plants in 

Jackson Hole, especially next to the refuge, help prevent new infestations on the refuge.

Teton County

Our coordination of the North Highway 89 Pathway with Teton County has expanded public opportunities for wildlife observation, photography, and 

our stakeholders and the public. The biological integrity, diversity, and environmental health policy provides directives for maintaining and restoring the 

biological integrity, diversity, and health of the Refuge System, whereas “Conserving the Future” 

articulates the desired roles for refuges and provides 

recommendations for the next decade and beyond 

(FWS 2011). This document states, “At the root of 

these challenges [that the Refuge System must 

address] is the increasing consumption of natural 

resources, which has caused loss, degradation and 

fragmentation of habitat around the world. Habitat 

loss is largely responsible for the current extinction 

event, in which the Earth may lose half of its species 

in the next 100 years.” 

This chapter describes the management focus of 

the CCP, followed by the objectives and strategies to 

achieve the refuge goals. The last sections of the 

chapter describe the staff needed to carry out the 

plan (section 4.10), stepdown management plans (section 4.11), monitoring and evaluation (section 4.12), 

and plan amendment and revision (section 4.13).

This chapter contains the specific objectives and 

strategies that will be used to carry out the final 

CCP for the National Elk Refuge. We are recommending this as the alternative that could best 

achieve the refuge’s purposes, vision, and goals while 

helping to fulfill the Refuge System mission. The 

stepdown management plans listed in section 4.11 

near the end of the chapter will provide implementation details for specific refuge programs. In addition, 

appendix E contains the compatibility determinations (required) for public and management uses 

associated with the final CCP.

The objectives and strategies presented in this 

chapter will be carried out over the next 15 years. 

This CCP will serve as the primary management 

document for the refuge until it is formally revised. 

We will carry out the final CCP with help from partner agencies, organizations, and the public. 

As stated in the Improvement Act, the primary 

mission of our Refuge System is wildlife conservation. Multiple policies and guidance documents have 

been developed to accomplish this mission, including 

the policy on biological integrity, diversity, and environmental health and the 2011 “Conserving the 

Future” document developed in collaboration with 

Ann Hough / FWS

Teton Mountain Range

Chapter 4—Management Direction
92 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

■ continued landscape change

■ our need to collaborate with the public and 

our partners on projects that extend beyond 

refuge boundaries

4.2 Overview of Goals and 

Objectives

Under each goal in this section, we describe the 

objectives and strategies that will serve as the steps 

needed to achieve the refuge vision. While a goal is a 

broad statement, an objective is a concise statement 

that indicates what is to be achieved, the extent of 

the achievement, who is responsible, and when and 

where the objective should be achieved—all to 

address the goal. The strategies are the actions 

needed to achieve each objective. Unless otherwise 

stated, the refuge staff will carry out the actions in 

the objectives and strategies. The rationale for each 

objective provides context such as background information, assumptions, and technical details. The plan 

has objectives for the following:

4.3 Climate Change

4.4 Landscape-Scale Conservation

4.5 Habitat and Wildlife Goal

4.6 Cultural Resources Goal

4.7 Visitor Services Goal

4.8 Visitor and Employee Safety and Resource

 Protection Goal

4.9 Administration Goal

4.3 Climate Change

The following objectives deal with our involvement in the landscape-scale and local aspects of climate change.

Climate Change Objective 1

For the life of the plan, continue involvement with 

partner organizations, especially land management 

agencies in the Greater Yellowstone Coordinating 

Committee, to stay apprised of the developing science 

of climate change and the resulting information that 

can have Greater Yellowstone Ecosystem–wide 

application.

4.1 Management Focus

Our focus and planning approach for the National 

Elk Refuge is consistent with the visions and principles promoted in the Improvement Act; the policy on 

biological integrity, diversity, and environmental 

health; and “Conserving the Future.” This includes 

conserving native communities and species of concern and developing “quantifiable objectives” that 

“integrate the conservation needs of the larger landscape (including the communities they support).”

Vision for the National Elk Refuge

Nestled below the majestic Teton Range, adjacent 

to the historic gateway town of Jackson, the National 

Elk Refuge provides crucial big game wintering 

habitat in the Greater Yellowstone Ecosystem. 

Across the refuge’s grassland, wetland, woodland, 

and sagebrush shrubland communities, visitors view 

wintering elk and other wildlife populations that are 

balanced with their habitats. The public enjoys quality hunting and fishing as well as year-round interpretative opportunities. Effective outreach and 

strong public and private partnerships ensure understanding and protection of refuge resources for 

future generations.

Promote Natural Habitats and Enhance 

Public Use

The CCP along with the vision and goals for the 

National Elk Refuge collectively focus objectives and 

associated management strategies on achieving sustainable, diverse, native communities that will conserve native species of concern at landscape and local 

scales. Achieving this vision represents the greatest 

contribution we at the refuge can make in addressing 

current and future threats to natural resources in 

the Greater Yellowstone Ecosystem. Threats include, 

but are not limited to, increasing habitat fragmentation and decreasing landscape connectivity, adverse 

effects on water quantity and quality, and cumulative 

risks associated with a changing climate and energy 

production. To alleviate these risks and to meet the 

purposes of the refuge require us to consider multiple perspectives:

■ Refuge System policies and guidance

■ the current understanding of native community ecology

■ increasing human demands on natural 

resources
Chapter 4—Management Direction 93 

Greater Yellowstone Coordinating Committee will 

enable us to collect long-term monitoring information 

that complements and adds value to ecosystem-wide 

efforts. Participation in climate change assessments 

conducted by other land management agencies on the 

committee will give the refuge the analysis expertise 

to address refuge-specific concerns.

Climate Change Objective 3

For the life of the plan, carry out mitigation 

actions identified in the Greater Yellowstone Area 

climate action plan (Fiebig 2011) to reduce the refuge’s carbon footprint.

Strategies

■ Continue to improve the energy efficiency of 

buildings and the vehicle fleet.

■ Use a gravity-flow irrigation system to 

reduce the energy-related costs of pumping.

Rationale

The Greater Yellowstone Coordinating Committee completed a comprehensive assessment of greenhouse gas emissions and corresponding mitigation 

plans for each Federal land management unit in the 

Greater Yellowstone Ecosystem. Following the specific mitigation recommendations for the refuge will 

reduce our carbon footprint. Reduction of greenhouse 

gas emissions will support the goals of our agency’s 

“Strategic Plan for Responding to Accelerating Climate Change, 2009” (FWS 2010).

4.4 Landscape-Scale 

Conservation

The following objectives describe our responsibilities for involvement in landscape-scale conservation.

Landscape-Scale Conservation 

Objective 1

For the life of the plan, participate in the Greater 

Yellowstone Coordinating Committee to support 

Strategies

■ Take part in climate change conferences, 

webinars, and seminars.

■ Engage in the Greater Yellowstone Coordinating Committee’s climate change planning efforts.

Rationale

The refuge’s limited staff will make it difficult for 

the refuge to remain current with the ever-growing 

knowledge of climate change and to conduct land 

management planning that reflects the latest science. 

The refuge could leverage our limited biological staff 

by staying involved with and relying on other Federal land management units in the Greater Yellowstone Coordinating Committee with large staffs to 

develop climate change expertise and coordinate 

ecosystem-wide planning efforts.

Climate Change Objective 2

For the life of the plan, participate in the climate 

change assessments and long-term monitoring 

efforts initiated by the Greater Yellowstone Coordinating Committee.

Strategies

■ Conduct vulnerability assessments on the 

refuge that correspond and complement 

efforts of the Greater Yellowstone Coordinating Committee in predicting climate 

change effects.

■ Collect long-term monitoring data for key 

habitats and wildlife populations, focusing 

on surrogate species when possible. (Note: 

Surrogate species is a recently adopted but 

yet to be implemented planning approach 

for the Refuge System. Surrogate species 

represent the needs of a wide array of wildlife species, and these needs will be used for 

conservation planning that supports multiple species and habitats within a defined 

landscape or geographic area.) 

Rationale

Cooperation and coordination with surrounding 

Federal land management agencies through the 
94 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Ann Hough / FWS

Spotted Sandpiper

■ Develop a preliminary project proposal.

■ Develop a land protection plan.

Rationale

Off-refuge resources and activities affect our ability to achieve refuge goals. Wildlife often travel 

across administrative boundaries to meet their seasonal life cycle needs. Protection of off-refuge 

resources will help meet these seasonal wildlife 

needs.

Landscape-Scale Conservation 

Objective 3

For the life of the plan, work with partners to use 

non-Service (private, nongovernmental organization, 

or other agency) easements to support refuge-specific 

conservation goals in the CCP and Bison and Elk 

Management Plan.

Strategies

■ Set up a program with the Jackson Hole 

Land Trust and others to establish conservation easements with refuge-specific conservation goals.

■ Consider partnership opportunities to build 

wildlife crossings for Highway 89.

landscape-scale conservation in the Greater Yellowstone Ecosystem.

Strategies

■ Participate on the board and committees of 

the Greater Yellowstone Coordinating 

Committee.

■ Contribute money as available toward priority projects that provide ecosystem-wide 

benefits.

■ Share information and resources such as 

equipment and staff.

Rationale

Working with others will improve our ability to 

coordinate management of Federal lands at a landscape scale.

Landscape-Scale Conservation 

Objective 2

Within 5 years, determine the feasibility of a Service conservation easement program, and if appropriate, pursue authority for conservation easements in 

Teton County.

Strategies

■ Inventory and identify tracts of high biological value that support the refuge vision.
Chapter 4—Management Direction 95 

refuge (for example, Dry Hollow section 36 and Crystal Butte section 36) and consider protection options.

Strategy

■ Work with local community to share information and effects.

Rationale

The potential sale of State of Wyoming lands next 

to or near the refuge to private landowners might 

have serious consequences to the management of the 

National Elk Refuge. Before lands are under consideration for sale, the refuge needs to determine and 

address the possible effects of access, rights-of-way, 

and human disturbance to elk and bison herds during 

sensitive winter and spring seasons.

Landscape-Scale Conservation 

Objective 6

Meet annually with the Regional Fisheries Supervisor for WGFD and the Jackson Hole Fish Hatchery 

Manager to explore cooperative project opportunities 

in the ecosystem. 

Strategy

■ Identify opportunities to leverage agency 

resources in ways that expand impacts of 

Snake River cutthroat trout conservation 

projects across the ecosystem. 

Rationale

The Greater Yellowstone native trout fishery will 

benefit from identifying cooperative projects that 

enhance the resiliency of Snake River cutthroat trout 

populations.

4.5 Habitat and Wildlife Goal

Adaptively manage bison, elk, and other wildlife 

populations and habitats as outlined in the Bison and 

Elk Management Plan. Contribute to the conservation of healthy native wildlife populations and their 

habitats. Restore and sustain a native fishery that 

provides quality fishing opportunities.

Rationale

Off-refuge resources and activities affect our ability to achieve refuge goals. Wildlife often travel 

across administrative boundaries to meet their seasonal life cycle needs. Protection of off-refuge 

resources will help meet these seasonal wildlife 

needs. Use of privately funded wildlife and habitat 

protection easements might be more desirable to 

some landowners than Government-funded easements. Furthermore, private money might be available to finance easement programs when 

Government money was unavailable. Wildlife crossings could reduce collisions between vehicles and 

animals.

Landscape-Scale Conservation 

Objective 4

Within 10 years, evaluate potential land 

exchanges with adjacent landowners (agencies and 

private landowners) to change the refuge boundary 

to improve the effectiveness of refuge programs.

Strategies

■ Discuss potential land exchanges with adjacent landowners.

■ Prioritize tracts for different refuge goals 

such as bison, elk, swan, bald eagle, or 

greater sage-grouse.

Rationale

Identifying and obtaining tracts of land that could 

improve wildlife benefits under our management will 

support refuge purposes. Some areas like the northeastern part of the refuge might better fit with other 

agency missions and provide benefits to the public 

(lands are managed by agencies according to different missions and policies).

Landscape-Scale Conservation 

Objective 5

Within 10 years, work with the State Land Board 

and WGFD to evaluate the effects of the potential 

sale of Wyoming State trust land and Wyoming 

Game and Fish Commission–owned lands near the 
96 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Rationale

Mapping of plant community types conducted 

between 2007 and 2009 identified 8,990 acres of 

sagebrush-associated plant communities on the refuge, but height and density of sagebrush within these 

areas has not been quantified at a fine scale. These 

communities on the refuge provide important habitat 

for the Jackson Hole greater sage-grouse population, 

and identifying and, when appropriate, protecting 

greater sage-grouse habitat is the highest priority 

for sagebrush-associated plant communities.

Sagebrush Shrublands Objective 2

Within 10 years, manage an estimated 1,000–

3,000 acres of sagebrush shrubland communities to 

promote desired habitat conditions of sagebrush at 

least 11 inches tall with more than 15-percent canopy 

cover to assure no net loss of these sagebrush areas. 

Strategies

■ Manage sagebrush shrublands to prevent 

degradation, maintain native structural and 

compositional characteristics, and allow 

degraded areas to recover, especially areas 

used by greater sage-grouse and other 

sagebrush-dependent species. 

■ Use wildland fire to help accomplish the 

objective and reduce hazardous fuel.

■ Minimize off-road vehicle use.

■ Limit elk feeding to current areas.

■ Conduct habitat treatments in greater sagegrouse core areas in accordance with Wyoming Executive Order 2011–5.

Rationale

Holloran and Anderson (2004) suggested greater 

sage-grouse wintering habitat was the principal limiting factor on the Jackson Hole greater sage-grouse 

population and recommended protecting mature 

sagebrush stands from disturbance. The “Upper 

Snake River Basin Sage-Grouse Conservation Plan” 

(WGFD 2014) recommended maintaining and protecting tall sagebrush (11- to 31-inch-high stands 

with more than 15-percent canopy cover) as forage 

sites for wintering greater sage-grouse. Because the 

refuge needs a detailed inventory of the sagebrush 

Native Grasslands Objective

Within 10 years, manage 500–1,000 acres of native 

grassland habitat on northern end of the refuge to 

increase elk and bison use of these areas.

Strategies

■ Use wildland fire to help accomplish the 

objective and reduce hazardous fuel.

■ Control invasive plant species.

■ Seed sites with desired plant species.

Rationale

The Bison and Elk Management Plan calls for 

reduced reliance on supplemental feeding. Encouraging elk and bison use of grassland habitats on the 

northern end of the refuge will reduce forage use and 

conserve forage on the southern end of the refuge, 

reducing the need for supplemental feeding. 

Sagebrush Shrublands Objective 1

Within 5 years, define existing structural characteristics of sagebrush shrubland communities on the 

refuge, and protect existing sagebrush shrubland 

communities from disturbance or degradation.

Strategies

■ Cooperate with other agencies to obtain 

imaging for the refuge using the light detection and ranging (LIDAR) technology.

■ Until the sagebrush shrubland habitat is 

defined, fully suppress wildfires in this 

habitat.

■ Conduct prescribed burns only after the 

current characteristics of sagebrush shrublands are defined.

■ Limit off-road vehicle use.

■ Do not expand feedgrounds into sagebrush 

shrubland communities on the northern end 

of the refuge.
Chapter 4—Management Direction 97 

Strategies

■ Gradually reduce water levels in spring and 

maintain low water levels until the following 

spring on a 4- to 7-year rotating schedule for 

each pond to increase pondweed cover.

■ Use wildland fire to help accomplish the 

objective and reduce hazardous fuel.

Rationale

Water management will develop nesting and 

brood-rearing habitat for trumpeter swans. Squires 

and Anderson (1995) suggested that pondweed 

tubers ranked among the highest in nutritional quality for trumpeter swans, and water level manipulations have been shown to promote sago pondweed 

(Kantrud 1990). Some emergent vegetation is preferred for swan breeding sites (Lockman et al. 1987).

Wetlands Objective 3

Within 5 years, inventory and map invasive plant 

species in the Flat Creek wetland complex, and for 

the life of the plan limit cover of listed noxious weeds 

to less than 1 percent of the Flat Creek wetland 

complex.

Strategies

■ Use high-resolution photography at peak 

flowering periods to search for large infestations of perennial pepperweed and purple 

loosestrife in inaccessible locations.

■ Inventory invasive plant species in the Flat 

Creek wetland complex using watercraft.

■ Pull, bag, and remove invasive plants if 

found.

■ Use appropriately labeled herbicide where 

applicable.

Rationale

Early detection of invasive plants is critical to the 

effective control of infestations (Dewey and Andersen 

2004).

shrubland plant community structure, 1,000–3,000 

acres is an imprecise estimate of the acreage that we 

will need to manage or provide special protection to 

meet management objectives. A more exact acreage 

will be determined through Sagebrush Shrublands 

Objective 1.

Wetlands Objective 1

Within 5 years, replace water control structures 

for the three existing Romney Ponds and Bill’s 

Bayou, and over the life of the plan construct two new 

ponds in the Romney Pond complex.

Strategies

■ Develop funding partnerships with WGFD 

and nonprofit organizations.

■ Evaluate the current and replacement 

water control structures for fish passage 

and screening.

■ Replace existing water control structures 

with inline water control structures with 

beaver-proof screens.

■ Construct two new ponds to the north of the 

existing Romney Ponds and use inline water 

control structures and beaver-proof screens.

Rationale

The ability to manipulate water levels is necessary to meet habitat management objectives for 

trumpeter swans, but water control structures in the 

Romney Pond complex and Bill’s Bayou are near the 

end of their operational life and vulnerable to beaver 

damage. The Gros Ventre River channel is shifting to 

the south and eroding the Pierre’s Pond dikes; maintaining these ponds is no longer practical. Unlike the 

Pierre’s Pond complex, the Romney Pond complex is 

not vulnerable to river damage. Construction of two 

new ponds in the Romney Pond complex will replace 

the swan habitat lost when Pierre’s Ponds fail.

Wetlands Objective 2

Within 10 years, maintain 30–50 percent pondweed cover and 10–20 percent emergent vegetation 

in artificial ponds that have water management 

capability.
98 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Strategies

■ Use separate exclosures to allow movement 

of elk and bison between the McBride and 

Chambers management units.

■ Consider using prescribed fire to stimulate 

regeneration in areas where exclosures are 

in place.

■ Install exclosures around high-priority 

mapped areas.

■ Consider planting willows within fenced 

exclosures to speed restoration.

■ Remove fences used to exclude elk and bison 

after vegetation recovery.

Rationale

Elk and bison browsing has modified the cottonwood plant community in the upper Flat Creek riparian zone to class 3 and class 4 conditions (Smith et al. 

2004). Even if elk and bison population objectives 

were met, the refuge will need to completely exclude 

elk and bison from these areas to recover to class 1 or 

class 2 condition.

Riparian Woodlands and Aspen 

Woodlands Objective 3

Within 10 years, inventory the class condition 

(refer to page 49 of the Bison and Elk Management 

Plan for definitions) of willow, cottonwood, and aspen 

stands in the Gros Ventre River riparian area and 

Gros Ventre Hills. For the life of the plan, maintain 

or increase the existing acreage of class 1 and class 2 

condition willows, cottonwood, and aspen. 

Strategies

■ Inventory existing structural characteristics using remote sensing (LIDAR) combined with field ground-truthing.

■ Limit elk and bison browsing pressure in 

class 1 and class 2 willow, cottonwood, and 

aspen by limiting prescribed burning next 

to these stands, maintaining high hunting 

pressure on the northern end of the refuge, 

Riparian Woodlands and Aspen 

Woodlands Objective 1

Within 5 years, identify and map sites within the 

lower Flat Creek riparian zone with the highest 

potential for willow restoration. Over life of the plan, 

restore 200 acres of willow communities in the lower 

Flat Creek riparian zone to class 1 or class 2 conditions (refer to page 49 of the Bison and Elk Management Plan for definitions).

Strategies

■ Map areas with existing willow along fishbearing stream channels in Flat Creek.

■ Install exclosures around high-priority 

mapped areas.

■ Consider planting willows within fenced 

exclosures to speed restoration.

■ Remove fences to exclude elk and bison 

around mapped areas after recovery. Rotate 

fences to restore new areas.

Rationale

Willow restoration will support fish habitat and 

habitat for birds. The Bison and Elk Management 

Plan indicates that 800 acres of willow habitat will be 

restored to class 1 or class 2 condition using 500- to 

1,000-acre exclosures, but the refuge has not begun 

any significant efforts to achieve this objective to 

date. Results from experimental exclosures (Smith et 

al. 2004, refuge unpublished data) suggest that, even 

with the complete exclusion of elk and bison, it will 

take at least 10 years for class 4 willow communities 

to recover to class 1 condition. Given these limitations, we need to limit restoration to areas with the 

greatest potential for restoration (existing class 4 

willow patches along fish-bearing stream channels). 

Riparian Woodlands and Aspen 

Woodlands Objective 2

Over the life of the plan, restore 100 acres of the 

riparian, narrowleaf cottonwood community to class 

1 or class 2 condition in the upper Flat Creek riparian 

zone (refer to page 49 of the Bison and Elk Management Plan for definitions).
Chapter 4—Management Direction 99 

Flat Creek Enhancement Objective 1

From 2014 to 2016, carry out the cooperative Flat 

Creek enhancement project by treating approximately 1.2 miles of Flat Creek each year. 

Strategies

■ Assess existing structures, tree revetments 

(streambank support), and other treatments 

for functionality and habitat values.

■ Remove, rehabilitate, or replace previously 

installed treatments with more suitable 

treatments, including removal of deteriorating instream structures, riprap, and an old, 

broken walkway.

■ Specify appropriate stream habitat structures based on lessons learned from failed 

structures.

■ Enhance riffle and pool habitats to increase 

spawning, rearing, and juvenile habitats for 

native Snake River cutthroat trout.

■ Modify meanders.

■ Stabilize severe streambank erosion where 

it jeopardizes project success.

■ Provide for continued irrigation and diversion activities such that habitat enhancement and channel restoration activities are 

not jeopardized.

■ Map, remove, treat, and control infestations 

of reed canarygrass along both sides of Flat 

Creek.

■ Install woody and sod vegetation.

■ Schedule construction during September to 

November to avoid cutthroat trout spawning, Flat Creek opening to anglers, elk and 

bison hunting and feeding periods, and the 

winter range restriction period. 

■ Continue to cooperate with WGFD and 

allow ample access to the refuge for fisheries management activities.

hazing elk and bison off the refuge during 

summer, using exclosure fences, and protecting wolf den sites from human 

disturbance.

■ Consider using prescribed fire to stimulate 

regeneration in areas where exclosures are 

in place.

Rationale

The refuge will need a comprehensive class condition inventory to figure out where and when restoration efforts should occur. Objectives in the Bison and 

Elk Management Plan call for restoration of 800 

acres of willow, 1,000 acres of cottonwood, and 1,000 

acres of aspen to class 1 or class 2 condition, with the 

greatest opportunity for cottonwood and aspen restoration on the northern end of the refuge. Although 

the analysis for the Bison and Elk Management Plan 

predicted that large-scale exclosures will be necessary to restore aspen in the Gros Ventre Hills, new 

data for this area suggests limited recovery of aspen 

has occurred without exclosures since 2005 (Keigley 

et al. 2009).

Ann Hough / FWS

Scarlet Paintbrush
100 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Flat Creek Enhancement Objective 3

Within 10 years, fully restore at least 1 mile of 

lower Flat Creek to improve fish habitat, support 

productive native trout populations, and promote 

natural and stable river morphology characteristics.

Strategies

■ Support and carry out the Flat Creek 

enhancement project as described in objectives 1 and 2.

■ Continue to cooperate with WGFD and 

allow ample access to the refuge for fisheries management activities.

Rationale

Part of the habitat and wildlife goal is to restore 

and sustain a native fishery that supports quality 

fishing opportunities. Restoration of this portion of 

Flat Creek to promote natural and stable river morphology characteristics will enhance cutthroat trout 

habitat, potentially increase cutthroat trout populations, and provide quality fishing opportunities for 

native trout.

Invasive Species Objective 1

Throughout the life of the plan, treat more acreage as needed to ensure that the total of all noxious 

weed and other invasive plant infestations does not 

exceed the current 1,100 acres. 

Strategies

■ Control the spread of invasive plant species 

to additional areas.

■ Control invasive plants using integrated 

pest management including biological, cultural, mechanical, and chemical methods.

■ Prevent new infestations of invasive plants 

including noxious weeds, nonnative grasses, 

and aquatic invasive species by preventing 

the artificial transportation of seeds and 

materials onto the refuge through efforts 

like public education, weed-free-hay rules, 

and the cleaning of all excavation and 

Rationale

Instream treatments along with riparian area 

restoration are necessary to restore stream form and 

function to Flat Creek, which will provide increased 

hydrologic stability as well as more habitat for all 

stages of the native Snake River cutthroat trout. 

WGFD, as the lead for the Flat Creek enhancement 

project, and the refuge have support for this project 

from several partners: Rocky Mountain Elk Foundation, Teton County Conservation District Board, and 

Trout Unlimited. 

Flat Creek Enhancement Objective 2

In 2015, after the initial enhancement work in 

Flat Creek (objective 1) is done, monitor the treatments for effectiveness and to make any needed 

adjustments.

Strategies

■ Assess the stability and functionality of 

structures.

■ Assess the bioengineering treatment (live 

material used in engineered treatments) 

establishment, such as willows used in bank 

stabilization.

■ Assess the disturbed area reclamation and 

revegetation.

■ Assess the achievement of overall project 

goals (described in chapter 3, “3.8 Alternative D” under “Flat Creek Enhancement” in 

the habitat section of the draft CCP).

Rationale

Based on the results of monitoring, we can apply 

adaptive management strategies to adjust the treatments, as needed, to increase the ecological benefits 

and better achieve the goals and objectives for the 

Flat Creek enhancement project. Monitoring can provide case study information, educational materials, 

and learning opportunities that we can use to make 

sure that future projects are carried out as effectively and efficiently as possible.
Chapter 4—Management Direction 101 

Rationale

Spotted knapweed is localized, infests 420 acres 

within the National Elk Refuge, and is mostly contained within the Gros Ventre River corridor and 

adjacent lands. The spotted knapweed population on 

the refuge represents a major risk for new infestations in other parts of the Greater Yellowstone Ecosystem. Within the refuge boundary, migration of 

spotted knapweed from the river corridor into the 

adjacent uplands will have a significant effect on 

existing greater sage-grouse populations and their 

habitat. Infestations will substantially degrade the 

vital, large ungulate, winter habitat and reduce the 

refuge’s winter population carrying capacity.

Data from elk radio collars and GPS collars suggest that 90 percent of elk migration routes from the 

refuge transect the Gros Ventre River corridor (Cole 

and Ketchum 2011, Smith and Robbins 1994). There 

is considerable evidence that wild and domestic ungulates facilitate the transport of invasive plant species 

seeds (Schiffmam 1997) and might be responsible for 

colonization of invasive plant species into new areas 

(Boulanger et al. 2011). Seed ingestion and viability 

in feces has been documented in various studies 

(Malo et al. 2000, Olson et al. 1997), and seed transport in the coats of wild and domestic ungulates is 

also substantiated (Constible et al. 2005, De ClerkeFloate 1997). Because elk that winter on the refuge 

migrate as far as Yellowstone Lake, the risk of seed 

transport by elk and colonization of spotted knapweed in uninfested parts of the Greater Yellowstone 

Ecosystem is significant. A major reduction in spotted knapweed density in the Gros Ventre River corridor will reduce the threat of new infestations in 

Grand Teton National Park, Teton Wilderness, and 

the southern part of Yellowstone National Park. 

Migratory Birds Objective

Within 5 years, institute a monitoring program 

for migratory birds to evaluate the effects of habitat 

management activities on trumpeter swan, longbilled curlew, and other migratory bird species 

potentially affected by refuge habitat management 

activities.

Strategies

■ Conduct post-treatment migratory bird surveys in K-Line experimental areas and compare to 2010 pretreatment data as defined 

by Dieni (2011).

angling equipment before entering the 

refuge.

■ Increase monitoring and rapid response for 

new infestations including invasive species 

of aquatic plants and animals.

■ Identify and consider removing invasive 

plants that are not considered noxious 

weeds, but are nonnative plant species such 

as crested wheatgrass, reed canarygrass, 

meadow foxtail, and yellow sweetclover.

Rationale

The National Elk Refuge has 1,100 acres of invasive plants, including noxious weeds, and no known 

occurrence of invasive animals or aquatic invasive 

species at this time. Noxious weed species threatening establishment and of greatest concern are Dalmatian toadflax, perennial pepperweed, and whitetop. 

Other weed species present and of concern include 

yellow toadflax; spotted, diffuse and Russian knapweed; sulfur cinquefoil; Dyer’s woad; oxeye daisy; 

plumeless thistle; black henbane; houndstongue; and 

common burdock. Weed species such as Canada and 

musk thistle are well established and of lower priority but still require control to prevent dense stands 

that negatively affect native vegetation and wildlife 

forage.

Invasive Species Objective 2

Over the life of the plan, reduce the existing 420-

acre spotted knapweed infestation along the Gros 

Ventre River corridor by 50 percent.

Strategies

■ Develop large-scale invasive plant eradication programs (greater than 100 acres of 

infestation) where possible.

■ Identify and develop suitable funding 

sources for monitoring, treatment, restoration, and public information.

■ Use existing partnerships and private 

contractors.

■ Focus efforts on proven methods with using 

effective herbicides and applicable mixes 

and insects.
102 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

allow managers to evaluate the effects treatments on 

bird communities and adaptively adjust treatments if 

necessary.

Aquatic Species Objective

Within the life of the plan, decrease nonnative 

trout prevalence in Flat Creek by 25 percent.

Strategies

■ Continue to cooperate with WGFD and 

allow ample access to the refuge for fisheries management activities.

■ Remove all nonnative trout captured during 

fish surveys.

■ Aggressively target brook trout for removal 

from Flat Creek during the fall spawning 

period using electrofishing and trapping 

techniques.

■ Continue angler education efforts about the 

effect of nonnative species on the native 

fishery and encourage angler harvest of 

nonnative trout. 

■ Design and install a fish passage screen at 

the Southpark diversion to prevent nonnative trout in the Gros Ventre River from 

entering Flat Creek.

■ Support and carry out habitat restoration of 

Flat Creek as described in the restoration 

plan (Biota 2013a) on file at the refuge. 

Rationale

Nonnative trout populations can be substantially 

reduced by direct removal, preventing their introduction into irrigation systems, and by improving stream 

habitat conditions that provide a competitive advantage to native trout populations.

Disease Management Objective 1

Within 5 years, develop a comprehensive disease 

contingency plan in coordination with WGFD and 

Grand Teton National Park.

Eric Cole / FWS

Wolf

■ Continue monitoring trumpeter swans during nesting season to determine the number 

of breeding pairs, number of active and successful nests, number of cygnets hatched 

per nest, and number of cygnets fledged per 

nest.

■ Continue monitoring long-billed curlews at a 

level sufficient to identify nesting territories 

and to avoid irrigating these areas until 

after birds have fledged.

■ Continue coordination with WGFD to monitor swans and long-billed curlews.

■ Conduct baseline surveys of breeding birds 

in areas subject to habitat management.

Rationale

Trumpeter swans and long-billed curlews are sensitive migratory species potentially affected by refuge management activities. Their small population 

sizes and relatively large breeding territories warrant species-specific monitoring. Large-scale habitat 

modifications are ongoing or planned in irrigated 

grasslands; sagebrush grasslands; and willow, aspen, 

and cottonwood plant communities. Baseline surveys 

of breeding birds in proposed treatment areas will 
Chapter 4—Management Direction 103 

Rationale

During routine monitoring in 2003, sampled sent 

to the WGFD laboratory tested positive for Myxololus cerebralis, the parasite that causes whirling disease. Infection levels were low and no 

population-level declines have been documented. No 

further testing has been done since 2003.

Federally Listed Species and State 

Species of Greatest Conservation 

Need Objective 1

Within 5 years, develop an inventory and monitoring plan for all federally listed threatened, endangered, and candidate species and State species of 

concern that potentially exist on the refuge.

Strategies

■ Create a list of potential Federal threatened 

and endangered species and State species of 

concern that exist on the refuge.

■ Document existing and historical records of 

occurrence and survey data for relevant 

species.

■ For species with sufficient available data, 

document the species’ status and trend.

■ For species with insufficient data, develop 

monitoring plans to supply information 

needs.

■ Follow and carry out Wyoming Executive 

Order 2011–5 for the greater sage-grouse.

Rationale

Habitat manipulations are proposed in many refuge plant communities, but the status and trend of 

Federal threatened and endangered species and 

State species of concern are unknown. Adequate 

baseline population information for these species will 

make sure that refuge actions could be adaptively 

managed to prevent negative effects on these 

populations.

Strategies

■ Identify current and potential wildlife 

diseases.

■ Develop response plans for disease 

outbreaks.

Rationale

Wildlife populations and associated pathogens do 

not recognize land management boundaries or 

agency jurisdictions. Developing interagency 

response plans to disease outbreaks before occurrence increases the likelihood of mitigating negative 

effects (Mörner et al. 2002).

Disease Management Objective 2

Within 5 years, quantify baseline patterns of elk 

group size, distribution, and density for elk on the 

refuge.

Strategy

■ Use high-resolution, photograph-based mapping to count elk groups on the refuge.

Rationale

There is considerable evidence that high animal 

density adds to disease risk (Gross and Miller 2001, 

Maichak et al. 2009), but there is no fine-scale data to 

evaluate current elk density conditions on the refuge. 

Quantifying elk density patterns will facilitate modeling to predict the potential effects of disease outbreaks and allow the refuge to adaptively manage elk 

density compared to baseline conditions (Gortazar et 

al. 2006).

Disease Management Objective 3

Retest fish for whirling disease in next 5 years.

Strategy

■ Conduct whirling disease sampling during 

electroshocking operations conducted by 

WGFD.
104 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

■ (Also refer to strategies for species of concern, migratory birds, and disease 

management.)

Rationale

The inventory and monitoring plan will help set 

priorities for research and monitoring tasks to make 

sure that critical information is being collected to 

guide management decisions.

4.6 Cultural Resources Goal

Preserve and interpret cultural resources in a 

way that allows visitors to connect to the area’s rich 

history and conservation heritage.

Cultural Resources Objective

Protect and preserve cultural resources on the 

refuge through coordination with the Region 6 cultural resources branch, which helps refuge staff in 

meeting the requirements of section 106 of the 

National Historic Preservation Act and other cultural resources–related legislation.

Strategies

■ Inform the Region 6 cultural resources staff 

of refuge projects early in planning by using 

the Cultural Resources Review Form.

■ Develop exhibits and signage to enhance 

educational opportunities.

■ Encourage collaboration with interested 

tribes in developing relevant materials and 

correct interpretation of cultural resources.

■ Identify facility needs for interpretive programs and assessment for any rehabilitation 

work done on the historic Miller Barn.

Rationale

It is important to protect the integrity of known 

cultural resources and make sure our activities do 

not affect unknown resources. Accurate information 

will help the refuge develop effective educational and 

interpretive materials for the public that will explain 

and encourage preservation of cultural resources.

Federally Listed Species and State 

Species of Greatest Conservation 

Need Objective 2

Within 1 year, develop a protocol to salvage, 

hatch, and return trumpeter swan cygnets to nests 

threatened by flooding in the Flat Creek Marsh.

Strategy

■ Cooperate with WGFD and the Wyoming 

Wetland Society to develop and implement 

the swan egg salvage protocol and to install 

floating nest structures near breeding territories most at risk to flooding.

Rationale

Past monitoring suggests that water diverted 

from the Gros Ventre River combined with spring 

runoff causes flooding that destroys swan nests in 

the Flat Creek Marsh. Egg salvage and installation 

of floating nest platforms will mitigate this effect and 

improve nest success and cygnet survival.

Research and Monitoring 

Objective

Within 5 years, develop a comprehensive inventory and monitoring plan designed to evaluate habitat management objectives, migratory bird 

populations, Federal threatened and endangered 

species, State species of concern, and Bison and Elk 

Management Plan objectives.

Strategies

■ Rank information needs and identify areas 

where insufficient information exists.

■ Develop study designs to answer questions 

of interest.

■ Work with cooperating agencies, nongovernmental organizations, and volunteers to 

pay for inventory and monitoring projects 

and help with fieldwork.
Chapter 4—Management Direction 105 

Figure 12. Map of visitor services on the southern end of the National Elk Refuge, Wyoming.
106 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Figure 13. Map of the elk hunting program on the National Elk Refuge, Wyoming.
Chapter 4—Management Direction 107 

Figure 14. Map of the bison hunting program on the National Elk Refuge, Wyoming.
108 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Strategies

■ Develop regulations that focus on reducing 

attractants to parking areas and vehicles.

■ Provide guidelines for refuge staff when a 

bear is present on the refuge.

■ Provide educational material and guidelines 

to hunters on bear behavior and what to do 

in the presence of a bear, including carrying 

and using bear spray.

■ Review refuge bear spray policy in 5 years 

instead of at the expiration of the CCP. If 

the potential for aggressive bear encounters 

with hunters increases and evidence of 

increased use of bear spray by hunters will 

result from a bear spray carry requirement, 

the refuge bear spray policy can be 

modified.

Rationale

A significant population of grizzly bear lives at 

Grand Teton National Park and Bridger-Teton 

National Forest. The bears are habituated to hunterkilled elk and bison and gut piles, and these food 

sources are an important part of their fall diet. The 

refuge hunting program produces large quantities of 

both carcass remains and gut piles throughout the 

refuge. Grizzly bears have discovered this food 

source and were present on the refuge after the bison 

hunt began in August 2013. 

Hunting Objective 3

Within 10 years, develop a hunting opportunity 

for bull elk on the refuge.

Strategies

■ Work cooperatively with WGFD to develop 

a bull elk license specifically for the refuge.

■ Provide educational and outreach material 

to other refuge users and the public to educate them about the Refuge System’s mandate to provide recreational hunting 

opportunities when they are compatible 

with the purpose of the refuge.

4.7 Visitor Services Goal

Enable a diverse audience to understand and 

appreciate the refuge’s wildlife conservation role in 

Jackson Hole, while safely enjoying year-round 

opportunities for wildlife-dependent recreation.

Visitor services are concentrated on the southern 

end of the refuge where most of the public use occurs 

because of the adjacency to the town of Jackson. Figure 12 shows this area, including several of the proposed uses. In addition, figures 13 and 14 reflect 

access and hunt areas during the elk hunting and 

bison hunting seasons, respectively.

Hunting Objective 1

Within 10 years, develop a hunting program for 

young people that provides quality hunting 

opportunities.

Strategies

■ Cooperate with WGFD to develop hunting 

season proposals.

■ Work with the Boy Scouts of America and 

other outdoor-focused youth groups to identify important traits for a youth hunt.

■ Move the existing youth hunt to a time later 

in the hunting season when there are likely 

large elk numbers present on the refuge.

Rationale

Recruiting young hunters into the hunting culture 

is critical for continued public support of hunting as 

an accepted wildlife-dependent recreational activity, 

continued use as a wildlife management tool, and as 

the primary funding source for modern wildlife management. Key elements of any hunt for young people 

are preventing competition for game from adult hunters, adult supervision and mentoring, and quality 

opportunities to see and interact with wildlife.

Hunting Objective 2

Within 5 years, develop regulations for proper 

storage of bear attractants and for bear-deterrent 

practices on the refuge that address hunters and 

hunting practices.
Chapter 4—Management Direction 109 

Rationale

Our current tools provide only minimum estimates of harvest and do not provide any data about 

hunter success or tag use on the refuge. More complete hunter use data will allow refuge staff to better 

manage refuge hunting opportunities and optimize 

refuge hunter use, distribution, and harvest 

management.

Hunting Objective 5

Within 5 years, develop and implement guidelines 

for a commercial guided hunting and retrieval.

Strategies

■ Coordinate with WGFD and Wyoming State 

Board of Outfitters and Guides.

■ Develop guidelines for outfitters to follow in 

an effort to minimize conflicts with 

unguided permit holders.

■ Set limits for the number of permits issued 

each season for guided hunting.

Rationale

Congress has identified hunting as a priority 

wildlife-dependent use for the Refuge System. The 

National Elk Refuge uses hunting as an important 

wildlife management tool. Other opportunities such 

as a limited-quota bull hunt could be made available 

to hunters as long as these opportunities supported 

the purpose of the refuge. A limited-quota bull hunt 

will increase hunting interest in the refuge, attract 

more hunters to participate in the annual cow hunt, 

and introduce more hunters to the purpose and vision 

of the National Elk Refuge.

Hunting Objective 4

Within 10 years, develop hunter-use management 

tools to better manage hunt program opportunities.

Strategies

■ Work cooperatively with WGFD to develop 

hunter checkpoints and hunter success 

surveys.

■ Consider requiring mandatory reporting of 

tag use and harvest.

Hunting is one of many wildlife-dependent activities available on the refuge.
110 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Strategies

■ Coordinate with WGFD to conduct an 

angler survey.

■ Set limits for the number of permits issued 

each season for guided fishing.

■ Set limits for the number of trips, guides, 

and clients per day per company.

■ Establish a permit fee for commercial fishing guides. 

■ Provide accessible opportunities for fishing.

Rationale

Unlimited commercial guiding has degraded the 

fishing experience for unguided individuals fishing on 

lower Flat Creek. Controls placed on the total number of guides permitted to work the refuge, as well as 

the total number of clients they are allowed to guide 

on each trip, will remove much of the congestion 

caused by large guided groups and improve the quality of experience had by all anglers on Flat Creek. 

Permit fees collected from commercial guides will 

help to pay for law enforcement activities and education and outreach materials.

Fishing Objective 2

Within 5 years, increase education of commercial 

guides and anglers on the negative effects of nonnative fish on the native Snake River cutthroat trout 

fishery and encourage angler harvest of nonnative 

trout.

Strategies

■ Work cooperatively with WGFD and Trout 

Unlimited to develop support for this 

program.

■ Through increased education of commercial 

guides and anglers, increase angler harvest 

of nonnative trout.

Rationale

Fish harvest systems have a powerful effect on 

fish populations. By encouraging guided anglers to 

harvest nonnative trout within creel limits, many 

■ Set limits for the number of trips, guides, 

and clients per day per company.

■ Establish a permit fee for commercial hunting guides. 

Rationale

Guided hunting and retrieval could increase 

hunter success and help meet population objectives 

for bison and elk.

Hunting Objective 6

Within 5 years, re-evaluate the voluntary nonlead ammunition program.

Strategies

■ Continue to review published literature pertaining to use of lead ammunition and the 

effects on wildlife.

■ Collect information to determine compliance 

with voluntary non-lead ammunition 

program.

■ Keep abreast of policy discussions regarding use of non-lead ammunition at the 

national level.

Rationale

Research conducted on the National Elk Refuge 

and the surrounding area indicates the use of lead 

ammunition by hunters results in elevated blood-lead 

levels in eagles and ravens, resulting in negative 

impacts on these species. Data from 2014 suggest 

that approximately 59 percent of the successful elk 

hunters on the refuge use non-lead ammunition.

Fishing Objective 1

Within 5 years, develop and implement guidelines 

for a commercial guided fishing program, with special attention to the lower Flat Creek area.
Chapter 4—Management Direction 111 

❏ Bert Raynes Boardwalk and remote-viewing platform near the visitor center.

❏ Turnout just north of the visitor center 

and Flat Creek Bridge.

❏ Elk jump turnout along Highway 89 (seasonal summer use only).

■ Support a contracted, winter interpretive 

sleigh ride program.

■ Allow wildlife-touring companies to operate 

on the refuge through a special use permit 

that outlines special conditions for 

operation.

■ Lead winter wildlife outings.

■ Loan equipment like binoculars, scopes, and 

backpacks through various Service initiatives and programs to increase opportunities for experiences and observation on the 

refuge.

Rationale

Visitor surveys conducted by the Jackson Hole 

Chamber of Commerce have consistently documented 

that 80–90 percent of valley tourists identify natural 

resource–based activities as their primary reason for 

visiting Jackson Hole. Viewing the mountains, bison, 

elk, birds, and other wildlife was rated as an important activity by local and nonlocal refuge visitors 

(Loomis and Caughlan 2004). Wildlife viewing and 

photography are two of the six priority public uses 

(wildlife-dependent recreational uses) of the Refuge 

System.

Wildlife Observation and 

Photography Objective 2

Over the life of the plan, implement at least five 

new, accessible wildlife observation opportunities on 

the refuge.

Strategies

■ Develop a more prominent access route 

across the visitor center lawn to the existing remote-viewing platform.

more will be removed than by employing management activities alone. The refuge will focus on guided 

anglers because they generally have better fish identification skills than the average angler.

Fishing Objective 3

Continue angler education about the negative 

effects of nonnative fish on the native Snake River 

cutthroat trout fishery and encourage angle harvest 

of nonnative trout. 

Strategies

■ Work cooperatively with WGFD and Trout 

Unlimited to develop support for this 

program.

■ Use public outreach to improve identification of fish species.

■ Update fishing regulations and refuge 

brochures.

Rationale

Fish harvest systems have a powerful effect on 

fish populations. By encouraging anglers to harvest 

nonnative trout within creel limits, many more will 

be removed than by employing management activities alone. The 10-year timeframe will give us ample 

time to develop outreach materials and identification 

aides.

Wildlife Observation and 

Photography Objective 1

For the life of the plan, enrich existing wildlife 

observation and photography opportunities on the 

refuge (25 percent of people report an enhanced 

experience).

Strategies

■ Maintain access to turnouts, trails, and 

other observation sites:

❏ Second-story, visitor center viewing 

platform.
112 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Rationale

Environmental education is a process designed to 

teach citizens and visitors of all ages the history and 

importance of conservation and scientific knowledge 

about the Nation’s natural resources. Through 

improved facilities and increased displays and presentations, we could better help to develop awareness, knowledge, attitudes, skills, motivation, and 

commitment for the public to work cooperatively 

toward conservation. 

Environmental Education and 

Interpretation Objective 2

For the life of the plan, use the North Highway 89 

Pathway to interpret the refuge purposes and mission of the Refuge System.

Strategies

■ Use the existing Jackson Hole Community 

Pathways to interpret wetland values. 

■ Coordinate with Jackson Hole Community 

Pathways about pathway traffic flow, 

develop trailside interpretive signage, and 

encourage wildlife viewing.

■ Cooperate with Jackson Hole Community 

Pathways to evaluate pathway effects on 

wildlife and habitat and adjust seasonal use 

as appropriate.

Rationale

Refuge staff will use the pathway during the open 

season as an interpretive venue. This will maximize 

the season and opportunity for interpretation without affecting wildlife.

Visitor Center Objective 1

Within 5 years, secure annual funding from visitor center partners to help with operation expenses, 

and document the financial assistance in a signed 

multiyear partnership agreement.

■ Develop a boardwalk through already disturbed wetlands near the visitor center.

■ Build a photo blind along the boardwalk for 

noncommercial photography.

■ Use webcams on the refuge to provide 

remote wildlife-viewing opportunities.

■ Incorporate accessible opportunities into 

wildlife observation and photography 

programs.

■ Develop a wildlife checklist.

Rationale

Public use will increase at area-specific, intensive 

use locations, resulting in increased development in 

some areas of the refuge. Visitors will have enhanced 

options to experience the refuge.

Environmental Education and 

Interpretation Objective 1

For the life of the plan, provide a variety of opportunities for environmental education and 

interpretation.

Strategies

■ Maintain and improve diverse and dynamic 

interpretive displays, new media, and handout literature that continually enhance and 

increase visitors’ interest in exploring the 

refuge.

■ Develop a self-guided, interpretive tour 

route on Elk Refuge Road.

■ Offer improved programs at the Jackson 

Hole and Greater Yellowstone Visitor Center, Miller House, and offsite areas with 

more permanent or seasonal interpreters.

■ Produce short video segments on a variety 

of topics related to the Service and share 

with audiences through multiple venues.

■ Use the Miller Barn as an interpretive site 

once stabilization and restoration work is 

completed.
Chapter 4—Management Direction 113 

contact location of their own. Sharing the financial 

burden among the agencies of operating the center, 

including purchasing supplies, will make it equitable 

for each of the partners.

Visitor Center Objective 2

Within 10 years, rehabilitate the existing building 

or build a new visitor center to address the aging 

building’s maintenance deficiencies.

Strategies

■ Document maintenance issues as they occur.

■ Continually evaluate and keep current the 

building condition assessment through the 

Service’s reporting procedures.

■ Prioritize the maintenance needs in our 

agency maintenance reporting systems.

■ Complete evaluations or surveys that will 

need to be done before new construction.

Strategies

■ Regularly meet with partners to provide an 

overview of visitor center visitation and 

expenses incurred for seasonal operational 

periods.

■ Provide partners with expense reports that 

detail the annual costs of goods and services 

needed for critical visitor center operations.

■ Use partner contributions as a sustainable 

way to pay for visitor center operations.

■ Monitor information desk questions to document the benefits of the visitor center operation to each agency.

■ Keep current a partnership agreement 

between the organizations and an annual 

operating plan.

Rationale

The Jackson Hole and Greater Yellowstone Visitor Center is an interagency facility, staffed and supported by area agencies and organizations. Each 

visitor center partner will continue to gain substantial financial benefit from our staff and visitor services rather than having to staff and provide a visitor 

Steve Miller / FWS

Environmental education at the refuge occurs at a variety of locations and events.
114 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

the reservation and fee-collection system for 

the picnic shelter.

■ Develop and provide public information 

about appropriate and compatible uses of 

the refuge.

■ Develop interpretive displays to support 

and explain the refuge purposes and Refuge 

System mission.

■ Renovate habitat to reduce the lawn and 

restore native vegetation.

Rationale

The refuge will work toward its goal of limiting 

public use to appropriate and compatible wildlifedependent recreational uses as identified our agency 

policies. The refuge will shift away from fringe uses 

or those that are prohibited by agency policy.

Other Uses Objective

Throughout the life of the plan, provide proper 

and compatible opportunities for wildlife-dependent 

recreation and non-wildlife-dependent recreation 

Rationale

The visitor center building was formerly owned 

by the Wyoming Department of Transportation and 

served as a State Information Center for the Wyoming Division of Tourism. The building is more than 

40 years old and has many significant maintenance 

issues such as deficiencies in the electrical system, 

annual flooding in the crawlspace, rotted wood on the 

remote-viewing platform, and noncompliance with 

the Architectural Barriers Act Accessibility Standard (United States Access Board 2013). A rehabilitated or new visitor center will also address the lack 

of space for interpretive programs or presentations 

to school or other large groups. 

North Park Objective

Within 3 years, manage North Park in accordance 

with Service policies, restore the park area to native 

habitat, and develop interpretive services.

Strategies

■ Revise the memorandum of understanding 

with the town of Jackson to do away with 

FWS

Ciliate Bluebells
Chapter 4—Management Direction 115 

■ Phase out commercial horseback trail rides.

■ Review requests for other non-wildlifedependent activities for compatibility and 

appropriateness case-by-case.

Rationale

The Improvement Act states that other uses can 

occur within the Refuge System, but they must support or not conflict with a priority public use. Furthermore, a use may not keep a refuge from 

accomplishing its purposes or the mission of the Refuge System.

Special Use Permit Objective 1

Within 5 years, identify an appropriate level of 

commercial operations on the refuge. Within 10 

years, manage commercial operations to achieve 

appropriate levels of use for guided fishing, guided 

hunting, and wildlife-viewing companies.

Strategies

■ Monitor ongoing commercial uses.

■ Limit special use permits for commercial 

operations (such as hunting, fishing, and 

wildlife-viewing tours) to reduce traffic and 

effects on the refuge.

■ Charge fees for commercial companies 

(guided hunting and fishing, hunting 

retrieval services, operation of commercial 

wildlife-viewing tours, and professional photography and videography) to offset administrative costs.

■ Include special conditions with each permit 

to reduce effects on resources and other 

activities.

■ Evaluate and potentially prohibit requests 

for special access that could be precedentsetting and will demand excessive refuge 

resources.

Rationale

We recognize that an appropriate level of commercial services can enhance visitor experience by 

providing programs that the refuge does not have the 

ability (resources) to provide. There will be no fee 

that support the six priority public uses or contribute 

to public appreciation of the refuge.

Strategies

■ Allow the following compatible and proper 

uses as long as wildlife is not disturbed and 

when areas are not closed for safety 

reasons:

❏ access to the Bridger-Teton National 

Forest

❏ North Park at the visitor center

■ Potentially adjust seasonal dates on the 

North Highway 89 Pathway prior to the 

15-year expiration of the CCP if there are 

notable, significant effects in the area due to 

climate change or other factors over an 

extended number of years; additionally, 

adaptively manage the pathway to minimize 

disturbance to wildlife and maximize seasonal use for the public based on the results 

of monitoring and data collection.

■ Allow under special use permit the following compatible and proper uses as long as 

wildlife is not disturbed:

❏ commercial photography

❏ commercial tours for wildlife viewing

❏ commercial guiding and game retrieval 

for hunting

❏ commercial guiding for fishing

❏ ceremonial tribal bison hunt up to five 

bison

■ Prohibit the following incompatible uses:

❏ general collection of shed antlers

❏ collection of berries, fruit, roots, wildflowers, and mushrooms

❏ collection of reptiles and amphibians

❏ weddings

❏ boating

❏ swimming
116 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Strategies

■ Maintain email contact lists for distribution 

of refuge information to elected officials, 

Federal and State partners, nonprofit conservation and partner organizations, key 

community and business leaders, and 

regional and national Service contacts.

■ Prepare and send out news releases via 

established email lists.

■ Prepare and send out articles via established email lists.

■ Use electronic media, including maintaining 

and keeping current the refuge Web site as 

well as using our agency’s new media and 

photo-sharing sites.

■ Conduct media interviews and accommodate film crews for local, national, and international audiences as workload allows.

■ Use refuge leaders in an ambassadorial and 

leadership role in the community, including 

extensive involvement in a variety of 

partnerships.

■ Coordinate with the Bridger-Teton National 

Forest on a winter closure to the public 

beyond the Twin Creek subdivision.

Rationale

Outreach is critical because of the National Elk 

Refuge’s high profile location, its “flagship refuge” 

status, and the complexity and controversial nature of 

many of the management issues. Effective outreach—

by giving the media a source of readily available 

resources and material—will streamline our response 

to the demand for information from local, regional, 

national, and international media and decrease the 

inaccuracy of stories compiled by others. 

4.8 Visitor and Employee 

Safety and Resource 

Protection Goal

Provide for the safety, security, and protection of 

visitors, employees, natural and cultural resources, 

and facilities throughout the refuge.

required when a special use is related to habitat 

improvement or wildlife research. If a special use 

permit resulted in a company profiting from the refuge, a fee to offset administrative costs will be justified. Charging a fee will help offset the costs of the 

administrative time involved in processing special 

use permits and compiling annual use information.

Special Use Permit Objective 2

Within 5 years, complete a special use permitting 

system that has a fee schedule for the processing of 

permits and the associated costs for accommodating 

commercial filming or photography activity.

Strategies

■ Work with the regional office to implement 

national guidance on a fee schedule for collecting fees associated with commercial photography and filming.

■ Communicate with the Grand Teton 

National Park permits office to make sure 

there is not a large discrepancy in the 

amount of fees charged on the refuge versus 

those same activities in the neighboring 

national park.

Rationale

The National Elk Refuge accommodates a large 

number of commercial photographers and film companies each year, especially during the winter 

months. Responding to media requests has become 

an increasing part of the winter duties for the visitor 

services staff. Making contacts with the permittee, 

evaluating the request, writing special conditions, 

completing the permit, and accommodating the 

request takes refuge staff a substantial amount of 

administrative time. A fee system will allow the refuge to recuperate some of the administrative costs 

associated with the activity.

Public Outreach Objective

For the life of the plan, disseminate information 

about elk and bison management, refuge management practices, and visitor services programs to 

increase awareness of the National Elk Refuge.
Chapter 4—Management Direction 117 

Strategies

■ Enforce no stopping and no parking in the 

roadway.

■ Improve signage.

■ Incorporate safety conditions in all special 

use permits.

■ Revoke special use permits when violations 

occur, and restrict or limit the ability of 

revoked permittees to obtain future special 

use permits.

Rationale

Visitor and employee safety is the refuge’s highest 

priority. We are required to provide a safe and hazard-mitigated environment for all refuge users and 

our employees.

Visitor and Employee Safety 

Objective 4

Within 5 years, document hunting accidents, violations, and unsafe practices. Over the life of the plan, 

reduce hunting accidents, violations, and unsafe practices in risk areas and activities by 50 percent.

Strategies

■ Revise hunt area boundaries.

■ Incorporate safety conditions in hunting 

publications.

■ Increase signage.

■ Notify hunters of other public users that 

might be using the area (such as birders, 

cyclists, and users of the auto tour route).

■ Increase the law enforcement presence during hunting season.

■ Revoke hunting permits when safety violations occur, and restrict or limit the ability 

of hunters with revoked permits to obtain 

future hunting permits.

Visitor and Employee Safety 

Objective 1

Over the life of the plan, eliminate lost-time worksite accidents and reduce all other accidents by 75 

percent.

Strategies

■ Continue to talk about safety procedures 

with employees and volunteers.

■ Continue to develop job hazard analyses for 

new activities.

Rationale

Visitor and employee safety is the refuge’s highest 

priority. We are required to provide a safe and hazard-mitigated environment for all refuge users and 

our employees.

Visitor and Employee Safety 

Objective 2

Within 5 years, document road hazards and vehicle accidents.

Strategy

■ Monitor and report accidents.

Rationale

Visitor and employee safety is the refuge’s highest 

priority. We are required to provide a safe and hazard-mitigated environment for all refuge users and 

our employees.

Visitor and Employee Safety 

Objective 3

Within 10 years, reduce road accidents in identified risk areas by 50 percent.
118 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Resource Protection Objective 2

Within 5 years, increase law enforcement patrols 

by 25 percent and develop shift coverage for highvisitor-use seasons.

Strategies

■ Detail (temporarily assign) officers from 

other refuges to the National Elk Refuge.

■ Hire a law enforcement officer.

■ Obtain a dual-function position.

■ Develop special operations for hunting and 

antler collecting seasons. 

Rationale

More law enforcement will be needed to manage 

the current public use as well as the additional use 

from increased visitor services programs.

4.9 Administration Goal

Provide facilities and effectively use and develop 

staff resources, funding partnerships, and volunteer 

opportunities to maintain the long-term integrity of 

habitats and wildlife resources of the refuge.

BJ Baker / FWS

Osprey

Rationale

Visitor and employee safety is the refuge’s highest 

priority. We are required to provide a safe and hazard-mitigated environment for all refuge users and 

our employees.

Resource Protection Objective 1

Protect wildlife and other natural and cultural 

resources from disturbance, damage, theft, or illegal 

taking to preserve resources for the public and to 

prevent their unnatural decline.

Strategies

■ Enforce hunting, fishing, and other regulations in accordance with the CFR, State 

laws, and refuge-specific regulations to protect habitat and wildlife.

■ Close areas and adjust hunting and fishing 

seasons to support wildlife management, 

promote migration, and protect wildlife 

from human disturbance when necessary.

■ Use law enforcement and education to protect 

cultural resources in accordance with Federal, 

State, and tribal laws, policies, and guidelines.

■ Keep a minimum of two dual-function law 

enforcement officers or one dual-function 

and one full-time, permanent law enforcement officer.

■ Provide ample and easy access to refuge 

regulations through various media such as 

printed leaflets, the Web site and social 

media, and six information kiosks located 

throughout the refuge.

Rationale

Adequately staffing refuges with sufficient officers to protect wildlife and habitat and to make refuges safe places for staff and visitors is a top priority 

for the Refuge System. “Conserving the Future” 

(FWS 2011), Recommendation 16, charges us to: Conduct a new, independent analysis of refuge law 

enforcement to measure progress and to name 

needed improvements.
Chapter 4—Management Direction 119 

Rationale

Current annual base funding is a minimum of 

$200,000 short for funding adequate staff and management. Establishing an adequate annual budget 

will ensure long-term stability in management programs for the refuge.

Facilities Objective 1

Over the life of the plan, increase refuge housing 

to accommodate an increase in staff.

Strategy

■ Brief our regional leaders about the need for 

increased refuge housing.

Rationale

The high cost of permanent and temporary housing in the Jackson area is an impediment to recruiting staff to work at the refuge. Having the option of 

reasonably priced, Government rental housing is an 

important factor in recruiting quality employees to 

fill lower-graded positions at the refuge.

The refuge will coordinate with Teton County when 

planning and constructing new buildings. However, we 

are under no legal obligation to follow county regulations; coordination with the county will be a courtesy 

rather than complying with a legal requirement.

Facilities Objective 2

Over the life of the plan, relocate the Calkins 

House to the Nowlin Gate area. 

Strategy

■ Move the Calkins House and all outbuildings to the Nowlin Gate area when money 

becomes available. 

Rationale

Relocation of the Calkins House will consolidate refuge housing and eliminate the need to maintain communications and transportation facilities to an outlying 

facility. This will also allow that part of the hunt unit 

around the Calkins House to be open for firearms, which 

could result in a minor increase in elk and bison harvest.

Funding and Staff Objective 1

Over the life of the plan, increase permanent staff 

by 16.5 FTE positions to help realize the enhancement potential of all refuge programs.

Strategies

■ Include more positions in the Refuge Operation Needs System to get future funding.

■ Brief our regional leaders about the refuge 

staff needed to accomplish the refuge goals 

and the effects of the current staff shortfall.

Rationale

Current Government staff levels are inadequate 

to accomplish the work of the refuge. The refuge 

relies on volunteers and positions paid by nongovernmental money to accomplish objectives. In 2011–2013, 

the refuge used more volunteer and nongovernmentally funded positions (12.5 FTEs) than Governmentfunded positions (10.5 FTEs). Although we are 

extremely fortunate to have volunteers and nongovernmentally funded positions, for the long term, the 

refuge cannot rely on these uncertain sources of 

assistance. The lack of a full-time assigned volunteer 

coordinator to conduct the recruiting, hiring, training, and logistics for the needed volunteers will continue to affect refuge programs. Providing necessary 

staff levels through Government-funded positions 

will provide the long-term consistency required for 

management excellence.

Funding and Staff Objective 2

Over the life of the plan, increase the refuge’s 

annual base funding to cover all operational costs and 

increased staff costs while maintaining a 75:25 staff 

to maintenance capacity ratio. 

Strategy

■ Brief our regional leaders about the need for 

an increased and stable budget to eliminate 

the severe staff shortfall and be able to 

accomplish the refuge goals.
120 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

■ Increase road maintenance (plowing, turnouts, sanding, and pulling ditches) in the 

winter for safety purposes.

■ Work with Teton County to reduce dust 

abatement.

■ Increase enforcement of current 

regulations.

■ Consider moving the entrance kiosk and 

parking area to the west side of the Elk 

Refuge Road entrance.

Rationale

High traffic volume and numbers of people using 

Elk Refuge Road for recreation and exercise creates 

user conflicts that might lead to safety issues. More 

signing, turnouts, and enforcement will increase user 

safety. Visitors will have more information available 

to learn about refuge resources.

Elk Refuge Road Objective 3

Within 5 years, eliminate overnight use of Elk 

Refuge Road for the opening of the national forest 

winter range.

Strategies

■ Prohibit overnight parking, camping, staging, and tailgating on the refuge associated 

with antler collection on national forest 

lands.

■ Consider alternate gate opening times, for 

example, opening the refuge access gate 

later than the other national forest access 

gates.

■ Use educational outreach to explain the 

change in management to the public.

Rationale

Refuge System policy does not allow overnight 

camping on the refuge. This use creates a safety hazard because it obstructs the road for emergency 

vehicles and other users and substantially increases 

law enforcement costs for the refuge. Enforcing the 

restriction on overnight use will help protect roadside resources, reduce traffic congestion, improve 

visitor and employee safety, and reduce refuge costs.

Elk Refuge Road Objective 1

Within 5 years, monitor winter use of Elk Refuge 

Road to identify the magnitude of use, safety issues, 

and visitor experience.

Strategies

■ Install traffic counters.

■ Conduct visitor surveys.

■ Share use information with Teton County 

and identify safety concerns.

Rationale

With baseline information on road use, the staff 

will be able to address safety concerns and other 

issues associated with the road.

Elk Refuge Road Objective 2

Within 10 years, manage year-round use of Elk 

Refuge Road to improve safety and the visitor 

experience.

Strategies

■ Add new regulatory signing to prohibit 

stopping or parking on or along roadway.

■ Permit parking only in designated lots and 

turnouts.

■ Add mounted scopes at turnouts to encourage people to get out of their cars.

■ Improve and increase the number of turnouts along the road for winter use.

■ Add numbered turnouts (ending at the Twin 

Creek subdivision) and interpretive information to correspond with a winter auto 

tour brochure.

■ Create and disseminate an interpretive brochure for a winter and summer auto tour 

route.
Chapter 4—Management Direction 121 

Table 13. Current and proposed staff at the National Elk Refuge, Wyoming.

Government-funded position

Current position 

(full-time 

equivalents [FTEs])

Proposed 

added position 

(FTEs)

Refuge manager (GS1–485–14) 1 —

Deputy refuge manager (GS–485–13) 1 —

Outdoor recreation planner (GS–0023–12) 1 —

Park ranger (GS–0025–9, visitor center manager) 1 —

Wildlife biologist (GS–486–12) 1 —

Refuge land management officer (GL2–1801–9) 1 —

Office assistant (GS–0303–5) 0.5 —

Heavy mobile equipment mechanic (WG3–5803–11) 1 —

Maintenance mechanic (WG–4749–9) 1 —

Engineering equipment operator (WG–5716–8) — 1

Budget analyst (GS–0560–11, business team) 1 —

Rangeland management specialist (GS–454–9) 1 —

Biological science technician (GS–404–5/7) — 1

Refuge land management officer (GL–1801–7/9) — 1

Environmental education specialist (GS–0025–7/9) — 1

Maintenance program supervisor (WG–5716–9) — 1

Three permanent seasonal park rangers (GS–0025–5/7, winter interpretive naturalists) — 1.5

Six permanent seasonal biological technicians (GS–404–4, irrigators) — 3

Eight permanent seasonal park rangers (GS–0025–4, visitor center ) — 4

Two permanent seasonal engineering equipment operators (WG–5716–7) — 1

Three permanent seasonal park rangers (GS–0025–5) — 2

1 GS=General Schedule classification and pay system.

2 GL= General Schedule classification and pay system for law enforcement officers.

3 WG= Wage Grade classification and pay system.

improve the fish-bearing streams for native 

cutthroat trout.

Rationale

Land use and habitat conditions off the refuge 

affect wildlife on the refuge. Teton County recently 

approved a comprehensive land use plan and will be 

developing regulations to carry out this plan. Sharing resources and close coordination between the 

refuge and the town of Jackson and Teton County 

through data sharing and project partnerships will 

help the refuge meet the habitat and wildlife goal.

4.10 Staff

Current staff within the complex consists of 10.5 

permanent full-time employees. Table 13 shows the 

current staff and additional staff required to fully 

Partnerships Objective

Work with partners to accomplish mutually beneficial projects including the nonmotorized pathway, 

aerial photography, GIS mapping, wildlife disease 

monitoring, and habitat and corridor protection and 

restoration.

Strategy

■ Participate with the town of Jackson and 

Teton County, and provide data if available, 

to identify relatively important wildlife habitat and understand the cumulative impacts 

of development and different development 

types on wildlife.

■ Continue to collaborate with Jackson Hole 

Trout Unlimited, Rocky Mountain Elk foundation, Snake River Fund, and WGFD to 
122 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Figure 15. The adaptive resource 

management process.

■ clearly defined management goals and 

objectives

■ a set of management actions with associated 

uncertainty as to their outcome

■ a suite of priority models representing various alternative working hypotheses describing the response of species or communities 

of interest

■ monitoring and assessment of the response 

of target organisms

■ use of monitoring and assessment information to direct future decisionmaking 

through the selection of a best model

The first three components (goals, actions, and 

models) are largely defined before initiating an adaptive resource management plan, while the latter two 

(monitoring and directed decisionmaking) comprise 

an iterative process, whereby each year the predictive ability of models are tested against what was 

observed during monitoring. This might result in a 

new best model, greater support for the existing best 

model, or new models constructed from emerging 

hypotheses. In this way, management can evolve as 

information is gained and uncertainty is reduced.

Development of adaptive resource management 

plans for habitat management will allow the refuge to 

“learn by doing,” while maintaining a focus on objectives. Knowledge gained from assessing management 

actions is as integral to the process as the management actions themselves. Emphasizing gaining 

knowledge about the refuge creates a situation where 

implement the CCP. Because of the area of responsibility and added complexities of this plan, we will 

evaluate all grade levels for current staff. If all positions were funded, the staff will be able to carry out 

all aspects of the CCP, which will provide the most 

long-term benefit to wildlife, habitat, and ecosystems; improve facilities; and provide visitor services. 

Projects that have adequate budgets and staff will 

receive priority for accomplishment.

4.11 Stepdown Management 

Plans

This CCP is a broad umbrella plan that provides 

general concepts and specific wildlife, habitat, visitor 

services, and partnership objectives over the next 15 

years. Stepdown management plans, in turn, provide 

detail for our managers and employees so they can 

more effectively carry out the specific actions and 

strategies in the CCP. Table 14 lists needed plans.

Table 14. Stepdown management plans for the 

National Elk Refuge, Wyoming.

Stepdown plan Planned 

completion

Comprehensive disease contingency 2016

Visitor services 2016

Habitat management 2017

Inventory and monitoring 2017

Hunt management 2018

Fire management 2018

Integrated pest management 2019

Cultural resource management 2020

4.12 Monitoring and Evaluation

Our agency proposes that the uncertainty surrounding habitat management can be dealt with most 

efficiently within the paradigm of adaptive resource 

management (figure 15) (Holling 1978, Kendall 2001, 

Lancia et al. 1996, Walters and Holling 1990). This 

approach provides a framework within which we can 

make objective decisions and reduce the uncertainty 

surrounding those decisions. The key components of 

an adaptive resource management plan follow:
Chapter 4—Management Direction 123 

we can refine its habitat management with feedback 

between management and assessment. Reducing the 

uncertainty of habitat management via adaptive 

resource management plans will greatly help us 

develop long-term habitat management plans.

4.13 Plan Amendment and 

Revision

The final CCP will be augmented by detailed 

stepdown management plans to address the completion of specific strategies in support of the CCP goals 

and objectives. To determine the need for revision, 

the CCP will be reviewed annually. A revision will 

occur if and when significant information became 

available, such as a change in ecological conditions. 

Revisions to the CCP and the stepdown management 

plans will be subject to public review and compliance 

with the National Environmental Policy Act. 

At a minimum, the final plan will be evaluated 

every 5 years and revised after 15 years.

have formerly been referred to as category 1 candidate species. From the February 28, 1996, Federal Register, page 7597: “those species for which 

the Service has on file sufficient information on 

biological vulnerability and threat(s) to support 

issuance of a proposed rule to list but issuance of 

the proposed rule is precluded.” 

canopy—A layer of foliage, generally the uppermost 

layer, in a vegetative stand; mid-level or understory vegetation in multilayered stands. Canopy 

closure (also canopy cover) is an estimate of the 

amount of overhead vegetative cover.

carrion—Dead animal body.

CCP—See comprehensive conservation plan.

CFR—See Code of Federal Regulations.

channel—The linear route along which surface water 

and ground water flow is concentrated.

channel morphology—the form and structure (such as 

width and depth) of a channel.

Code of Federal Regulations (CFR)—The codification of 

the general and permanent rules published in the 

Federal Register by the executive departments 

and agencies of the Federal Government. Each 

volume of the CFR is updated once each calendar 

year.

compatibility determination—See compatible use.

compatible use—A wildlife-dependent recreational 

use or any other use of a refuge that, in the sound 

professional judgment of the Director of the U.S. 

Fish and Wildlife Service, will not materially 

interfere with or detract from the fulfillment of 

the mission of the Refuge System or the purposes 

of the refuge (Draft Service Manual 603 FW 3.6). 

A compatibility determination supports the choice 

of compatible uses and identified stipulations or 

limits necessary to make sure that there is 

compatibility.

comprehensive conservation plan (CCP)—A document 

that describes the desired future conditions of the 

refuge and provides long-range guidance and 

management direction for the refuge manager to 

accomplish the purposes of the refuge, contribute 

to the mission of the Refuge System, and to meet 

other relevant mandates (Draft Service Manual 

602 FW 1.5).

concern—See issue.

cover, also cover type, canopy cover—Present vegetation of an area.

accessible—Pertaining to physical access to areas 

and activities for people of different abilities, 

especially those with physical impairments.

adaptive resource management—The rigorous application of management, research, and monitoring 

programs to gain information and experience necessary to assess and change management activities; a process that uses feedback from research, 

monitoring programs, and evaluation of management actions to support or change objectives and 

strategies at all planning levels; a process in 

which policy decisions are carried out within a 

framework of scientifically driven experiments to 

test predictions and assumptions inherent in management plan. Analysis of results helps managers 

decide whether current management should continue as is or whether it should be modified to 

achieve desired conditions.

Administration Act—National Wildlife Refuge System Administration Act of 1966.

alternative—A reasonable way to solve an identified 

problem or satisfy the stated need (40 CFR 

1500.2); one of several different means of accomplishing refuge purposes and goals and contributing to the Refuge System mission (Draft Service 

Manual 602 FW 1.5).

amphibian—A class of cold-blooded vertebrates 

including frogs, toads or salamanders.

annual—A plant that flowers and dies within 1 year 

of germination.

baseline—A set of essential observations, data, or 

information used for comparison or a control.

biological control—The use of organisms or viruses 

to control invasive plants or other pests.

biological diversity, also biodiversity—The variety of 

life and its processes, including the variety of living organisms, the genetic differences among 

them, and the communities and ecosystems in 

which they occur (Service Manual 052 FW 1.12B). 

The National Wildlife Refuge System’s focus is on 

indigenous species, biotic communities, and ecological processes.

biotic—Pertaining to life or living organisms; 

caused, produced by, or comprising living 

organisms.

candidate species, Federal—A plant or animal species proposed for addition to the Federal endangered and threatened species list. These species 

Glossary
126 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

forb—A broad-leaved, herbaceous plant; a seed-producing annual, biennial, or perennial plant that 

does not develop persistent woody tissue but dies 

down at the end of the growing season.

fragmentation—The alteration of a large block of 

habitat that creates isolated patches of the original habitat that are interspersed with a variety of 

other habitat types; the process of reducing the 

size and connectivity of habitat patches, making 

movement of individuals or genetic information 

between parcels difficult or impossible.

Friends group—Any formal organization whose mission is to support the goals and purposes of its 

associated refuge and the National Wildlife Refuge Association overall; Friends organizations 

and cooperative and interpretive associations.

FWS—See U.S. Fish and Wildlife Service.

geographic information system (GIS)—A computer 

system capable of storing and manipulating spatial data; a set of computer hardware and software for analyzing and displaying spatially 

referenced features (such as points, lines and 

polygons) with nongeographic attributes such as 

species and age.

GIS—See geographic information system.

GL—General Schedule classification and pay system 

for law enforcement officers. 

goal—Descriptive, open-ended, and often broad 

statement of desired future conditions that conveys a purpose but does not define measurable 

units (Draft Service Manual 620 FW 1.5).

GS—General Schedule classification and pay 

system.

habitat—Suite of existing environmental conditions 

required by an organism for survival and reproduction; the place where an organism typically 

lives and grows.

habitat disturbance—Substantial alteration of habitat 

structure or composition; may be natural (for 

example, wildland fire) or human-caused events 

(for example, timber harvest and disking).

habitat type, also vegetation type, cover type—A land 

classification system based on the concept of distinct plant associations.

hydrologic regime—The system of a water cycle and 

its changes with time. 

impoundment—A body of water created by collection 

and confinement within a series of levees or dikes, 

creating separate management units although not 

always independent of one another.

Improvement Act—National Wildlife Refuge System 

Improvement Act of 1997.

indigenous—Originating or occurring naturally in a 

particular place.

integrated pest management (IPM)—Methods of managing undesirable species such as invasive plants; 

education, prevention, physical or mechanical 

cultural resources—The remains of sites, structures, 

or objects used by people in the past.

cygnet—A young swan.

EA—See environmental assessment.

ecosystem—A dynamic and interrelating complex of 

plant and animal communities and their associated nonliving environment; a biological community, with its environment, functioning as a unit. 

For administrative purposes, the Service has 

designated 53 ecosystems covering the United 

States and its possessions. These ecosystems generally correspond with watershed boundaries and 

their sizes and ecological complexity vary.

emergent—A plant rooted in shallow water and having most of the vegetative growth above water 

such as cattail and hardstem bulrush.

endangered species, Federal—A plant or animal species listed under the Endangered Species Act of 

1973, as amended, that is in danger of extinction 

throughout all or a substantial part of its range.

endangered species, State—A plant or animal species 

in danger of becoming extinct or extirpated in a 

particular state within the near future if factors 

contributing to its decline continue. Populations of 

these species are at critically low levels or their 

habitats have been degraded or depleted to a substantial degree.

endemic species—Plants or animals that occur naturally in a certain region and whose distribution is 

relatively limited to a particular locality.

environmental assessment (EA)—A concise public 

document, prepared in compliance with the 

National Environmental Policy Act, that briefly 

discusses the purpose and need for an action and 

alternatives to such action, and provides sufficient 

evidence and analysis of effects to decide whether 

to prepare an environmental impact statement or 

finding of no significant impact (40 CFR 1508.9).

extinction—The complete disappearance of a species 

from the earth; no longer existing.

extirpation—The extinction of a population; complete 

eradication of a species within a specified area.

Federal trust resource—A trust is something managed by one entity for another who holds the ownership. The Service holds in trust many natural 

resources for the people of the United States of 

America as a result of Federal acts and treaties. 

Examples are species listed under the Endangered Species Act, migratory birds protected by 

international treaties, and native plant or wildlife 

species found on a national wildlife refuge.

Federal trust species—All species where the Federal 

Government has primary jurisdiction including 

federally endangered or threatened species, 

migratory birds, anadromous fish, and certain 

marine mammals.
Glossary 127 

ranges, wildlife management areas, and waterfowl production areas.

National Wildlife Refuge System Improvement Act of 

1997 (Improvement Act)—Sets the mission and the 

administrative policy for all refuges in the 

National Wildlife Refuge System; defines a unifying mission for the Refuge System; establishes 

the legitimacy and appropriateness of the six priority public uses (hunting, fishing, wildlife observation, wildlife photography, environmental 

education, and interpretation); establishes a formal process for determining appropriateness and 

compatibility; establishes the responsibilities of 

the Secretary of the Department of the Interior 

for managing and protecting the Refuge System. 

This Act amended parts of the Refuge Recreation 

Act and National Wildlife Refuge System Administration Act of 1966.

native species—A species that, other than as a result 

of an introduction, historically occurred or currently occurs in that ecosystem.

neotropical migrant—A bird species that breeds 

north of the United States and Mexican border 

and winters primarily south of this border.

nest success—The percentage of nests that successfully hatch one or more eggs of the total number 

of nests started in an area.

nongovernmental organization—Any group that is not 

comprised of Federal, State, tribal, county, city, 

town, local, or other governmental entities.

noxious weed, also invasive plant—Any living stage 

(including seeds and reproductive parts) of a parasitic or other plant of a kind that is of foreign origin (new to or not widely prevalent in the United 

States) and can directly or indirectly injure crops, 

other useful plants, livestock, poultry, other interests of agriculture, including irrigation, navigation, fish and wildlife resources, or public health. 

According to the Federal Noxious Weed Act (PL 

93–639), a noxious weed (such as invasive plant) is 

one that causes disease or has adverse effects on 

humans or the human environment and, therefore, 

is detrimental to the agriculture and commerce of 

the United States and to public health.

objective—A concise target statement of what will 

be achieved, how much will be achieved, when and 

where it will be achieved, and who is responsible 

for the work; derived from goals and provide the 

basis for determining management strategies. 

Objectives should be achievable and time specific 

and should be stated quantitatively to the extent 

possible. If objectives cannot be stated quantitatively, they may be stated qualitatively (Draft 

Service Manual 602 FW 1.5).

patch—An area distinct from that around it; an area 

distinguished from its surroundings by environmental conditions.

methods of control, biological control, responsible 

chemical use, and cultural methods.

introduced species—A species present in an area 

because of intentional or unintentional escape, 

release, dissemination, or placement into an ecosystem as a result of human activity.

invasive plant, also noxious weed—A species that is 

nonnative to the ecosystem under consideration 

and whose introduction causes, or is likely to 

cause, economic or environmental harm or harm 

to human health.

issue—Any unsettled matter that requires a management decision; for example, a Service initiative, opportunity, resource management problem, 

a threat to the resources of the unit, conflict in 

uses, public concern, or the presence of an undesirable resource condition (Draft Service Manual 

602 FW 1.5).

listed species—A species, subspecies, or distinct vertebrate population segment that has been added 

to the Federal lists of Endangered and Threatened Wildlife and Plants as they appear in sections 17.11 and 17.12 of Title 50 of the Code of 

Federal Regulations (50 CFR 17.11 and 17.12). 

management alternative—See alternative.

migration—Regular extensive, seasonal movements 

of birds between their breeding regions and their 

wintering regions; to pass usually periodically 

from one region or climate to another for feeding 

or breeding.

migratory birds—Birds that follow a seasonal movement from their breeding grounds to their wintering grounds. Waterfowl, shorebirds, raptors, and 

songbirds are all migratory birds.

mission—Succinct statement of purpose or reason 

for being.

mitigation—Measure designed to counteract an environmental effect or to make an effect less severe.

monitoring—The process of collecting information to 

track changes of selected parameters over time.

national wildlife refuge—A designated area of land, 

water, or an interest in land or water within the 

National Wildlife Refuge System, but does not 

include coordination areas; a complete listing of all 

units of the Refuge System is in the current 

“Annual Report of Lands Under Control of the 

U.S. Fish and Wildlife Service.”

National Wildlife Refuge System (Refuge System)—

Various categories of areas administered by the 

Secretary of the Department of the Interior for 

the conservation of fish and wildlife including species threatened with extinction, all lands, waters, 

and interests therein administered by the Secretary as wildlife refuges, areas for the protection 

and conservation of fish and wildlife that are 

threatened with extinction, wildlife ranges, game 
128 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

raptor—A carnivorous bird such as a hawk, a falcon, 

or a vulture that feeds wholly or chiefly on meat 

taken by hunting or on carrion (dead carcasses).

refuge purpose—See purpose of the refuge.

Refuge System—See National Wildlife Refuge 

System.

refuge use—Any activity on a refuge, except administrative or law enforcement activity, carried out 

by or under the direction of an authorized Service 

employee.

resident species—A species inhabiting a given locality throughout the year; nonmigratory species.

restoration—Management emphasis designed to 

move ecosystems to desired conditions and processes, such as healthy upland habitats and 

aquatic systems.

revetment—A structure to support a streambank.

riffle—The shallow zone between pools in a stream. 

riparian area or riparian zone—An area or habitat 

that is transitional from terrestrial to aquatic ecosystems including streams, lakes, wet areas, and 

adjacent plant communities and their associated 

soils that have free water at or near the surface; 

an area whose parts are directly or indirectly 

attributed to the influence of water; of or relating 

to a river; specifically applied to ecology, “riparian” describes the land immediately adjoining and 

directly influenced by streams. For example, 

riparian vegetation includes all plant life growing 

on the land adjoining a stream and directly influenced by the stream.

riprap—A loose foundation of irregular rock fragments used under water for streambed protection 

or in soft materials to prevent streamside 

erosion. 

scoping—The process of obtaining information from 

the public for input into the planning process.

section 7—The section of the Endangered Species 

Act that requires all Federal agencies, in consultation with the U.S. Fish and Wildlife Service, to 

ensure that their actions are not likely to jeopardize the continued existence of listed species or 

result in destruction or adverse modification of 

critical habitat.

sediment—Material deposited by water, wind, and 

glaciers.

Service—See U.S. Fish and Wildlife Service.

shelterbelt—Single to multiple rows of trees and 

shrubs planted around cropland or buildings to 

block or slow down the wind.

shorebird—Any of a suborder (Charadrii) of birds 

such as a plover or a snipe that frequent the seashore or mudflat areas.

spatial—Relating to, occupying, or having the character of space.

special use permit—A permit for special authorization from the refuge manager required for any 

perennial—Lasting or active through the year or 

through many years; a plant species that has a 

lifespan of more than 2 years.

plant community—An assemblage of plant species 

unique in its composition; occurs in particular 

locations under particular influences; a reflection 

or integration of the environmental influences on 

the site such as soil, temperature, elevation, solar 

radiation, slope, aspect, and rainfall; denotes a 

general kind of climax plant community, such as 

ponderosa pine or bunchgrass.

prescribed fire—The skillful application of fire to 

natural fuels under conditions such as weather, 

fuel moisture, and soil moisture that allow confinement of the fire to a predetermined area and 

produces the intensity of heat and rate of spread 

to accomplish planned benefits to one or more 

objectives of habitat management, wildlife management, or hazard reduction.

priority public use—One of six uses authorized by the 

National Wildlife Refuge System Improvement 

Act of 1997 to have priority if found to be compatible with a refuge’s purposes. This includes hunting, fishing, wildlife observation, wildlife 

photography, environmental education, and 

interpretation.

proposed action—The alternative proposed to best 

achieve the purpose, vision, and goals of a refuge 

(contributes to the Refuge System mission, 

addresses the significant issues, and is consistent 

with principles of sound fish and wildlife 

management).

public—Individuals, organizations, and groups; officials of Federal, State, and local government 

agencies; American Indian tribes; and foreign 

nations. It may include anyone outside the core 

planning team. It includes those who may or may 

not have shown an interest in Service issues and 

those who do or do not realize that Service decisions may affect them.

public involvement—A process that offers affected 

and interested individuals and organizations an 

opportunity to become informed about, and to 

express their opinions on, Service actions and 

policies. In the process, these views are studied 

thoroughly and thoughtful consideration of public 

views is given in shaping decisions for refuge 

management.

purpose of the refuge—The purpose of a refuge is 

specified in or derived from the law, proclamation, 

Executive order, agreement, public land order, 

donation document, or administrative memorandum establishing authorization or expanding a 

refuge, refuge unit, or refuge subunit (Draft Service Manual 602 FW 1.5).
Glossary 129 

enforces Federal wildlife laws, manages migratory bird populations, restores national significant 

fisheries, conserves and restores wildlife habitat 

such as wetlands, administers the Endangered 

Species Act, and helps foreign governments with 

their conservation efforts. It also oversees the 

Federal aid program that distributes millions of 

dollars in excise taxes on fishing and hunting 

equipment to State wildlife agencies.

U.S. Geological Survey (USGS)—A Federal agency 

whose mission is to provide reliable scientific 

information to describe and understand the earth; 

decrease loss of life and property from natural 

disasters; manage water, biological, energy, and 

mineral resources; and enhance and protect our 

quality of life.

USGS—See U.S. Geological Survey.

vision statement—A concise statement of the desired 

future condition of the planning unit, based primarily on the Refuge System mission, specific 

refuge purposes, and other relevant mandates 

(Draft Service Manual 602 FW 1.5).

wading birds—Birds having long legs that enable 

them to wade in shallow water including egrets, 

great blue herons, black-crowned night-herons, 

and bitterns.

waterfowl—A category of birds that includes ducks, 

geese, and swans.

waterfowl production area—Land that the National 

Wildlife Refuge System acquires with Federal 

Duck Stamp money for restoration and management, primarily as prairie wetland habitat critical 

to waterfowl and other wetland birds. 

watershed—The region draining into a river, a river 

system, or a body of water.

wetland management district (WMD)—Land that the 

Refuge System acquires with Federal Duck 

Stamp money for restoration and management 

primarily as prairie wetland habitat critical to 

waterfowl and other wetland birds.

WG—Wage Grade classification and pay system. 

WGFD—Wyoming Game and Fish Department. 

wildfire—A wildland fire originating from an 

unplanned ignition caused by lightning, volcanoes, 

unauthorized and accidental human-caused fires, 

and escaped prescribed burns.

wildland fire—A general term describing any nonstructure fire that occurs in the wildland. 

wildlife-dependent recreational use—Use of a refuge 

involving hunting, fishing, wildlife observation, 

photography, environmental education, or interpretation. The National Wildlife Refuge System 

Improvement Act of 1997 specifies that these are 

the six priority public uses of the Refuge System.

woodlands—Open stands of trees with crowns not 

usually touching, generally forming 25- to 60-percent cover.

refuge service, facility, privilege, or product of the 

soil provided at refuge expense and not usually 

available to the public through authorizations in 

Title 50 CFR or other public regulations (Refuge 

Manual 5 RM 17.6).

species of concern—Those plant and animal species, 

while not falling under the definition of special 

status species, that are of management interest 

by virtue of being Federal trust species such as 

migratory birds, important game species, or significant keystone species; species that have documented or apparent populations declines, small or 

restricted populations, or dependence on 

restricted or vulnerable habitats.

stepdown management plan—A plan that provides 

the details necessary to carry out management 

strategies identified in the comprehensive conservation plan (Draft Service Manual 602 FW 1.5).

strategy—A specific action, tool, or technique or combination of actions, tools, and techniques used to 

meet unit objectives (Draft Service Manual 602 

FW 1.5).

suppression—All the work of extinguishing a fire or 

confining fire spread.

threatened species, Federal—Species listed under the 

Endangered Species Act of 1973, as amended, that 

are likely to become endangered in the future 

throughout all, or a substantial part, of their 

range.

threatened species, State—A plant or animal species 

likely to become endangered in a particular state 

within the near future if factors contributing to 

population decline or habitat degradation or loss 

continue.

travel corridor—A landscape feature that facilitates 

the biologically effective transport of animals 

between larger patches of habitat dedicated to 

conservation functions. Such corridors may facilitate several kinds of traffic including frequent 

foraging movement, seasonal migration, or the 

once in a lifetime dispersal of juvenile animals. 

These are transition habitats and need not contain 

all the habitat elements required for long-term 

survival or reproduction of its migrants.

trust resource—See Federal trust resource.

trust species—See Federal trust species.

USDA—U.S. Department of Agriculture.

U.S. Fish and Wildlife Service (Service, FWS)—The 

principal Federal agency responsible for conserving, protecting, and enhancing fish and wildlife 

and their habitats for the continuing benefit of the 

American people. The Service manages the 

93-million-acre National Wildlife Refuge System 

comprised of more than 530 national wildlife refuges and thousands of waterfowl production 

areas. It also operates 65 national fish hatcheries 

and 78 ecological service field stations, the agency 

■ Foster understanding and instill appreciation of fish, wildlife, and plants, and their 

conservation, by providing the public with 

safe, quality, and compatible wildlife-dependent public use. Such use includes hunting, 

fishing, wildlife observation and photography, and environmental education and 

interpretation.

Guiding Principles

There are four guiding principles for management 

and general public use of the Refuge System established by Executive Order 12996 (1996):

■ Public Use—The Refuge System provides 

important opportunities for compatible 

wildlife-dependent recreational activities 

involving hunting, fishing, wildlife observation, photography, environmental education, 

and interpretation.

■ Habitat—Fish and wildlife will not prosper 

without quality habitat and without fish and 

wildlife, traditional uses of refuges cannot 

be sustained. The Refuge System will continue to conserve and enhance the quality 

and diversity of fish and wildlife habitat 

within refuges.

■ Partnerships—America’s sportsmen and 

women were the first partners who insisted 

on protecting valuable wildlife habitat 

within wildlife refuges. Conservation partnerships with other Federal agencies, State 

agencies, tribes, organizations, industry, 

and the general public can make significant 

contributions to the growth and management of the Refuge System.

■ Public Involvement—The public should be 

given a full and open opportunity to participate in decisions regarding acquisition and 

management of our national wildlife 

refuges.

This appendix briefly describes the guidance for 

the National Wildlife Refuge System and other policies and key legislation that guide the management of 

the National Elk Refuge.

A.1 National Wildlife Refuge 

System

The mission of the Refuge System is to administer a national network of lands and waters for 

the conservation, management, and where 

appropriate, restoration of the fish, wildlife, 

and plant resources and their habitats within 

the United States for the benefit of present and 

future generations of Americans.

(National Wildlife Refuge System Improvement Act 

of 1997)

Goals

■ Fulfill our statutory duty to achieve refuge 

purposes and further the Refuge System 

mission. 

■ Conserve, restore where appropriate, and 

enhance all species of fish, wildlife, and 

plants that are endangered or threatened 

with becoming endangered.

■ Perpetuate migratory bird, interjurisdictional fish, and marine mammal populations. 

■ Conserve a diversity of fish, wildlife, and 

plants. 

■ Conserve and restore, where appropriate, 

representative ecosystems of the United 

States, including the ecological processes 

characteristic of those ecosystems. 

Appendix A

Key Legislation and Policy
132 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

floods on human safety, and preserve the natural and 

beneficial values served by the floodplains.

Executive Order 12996, Management and General 

Public Use of the National Wildlife Refuge System 

(1996)—Defines the mission, purpose, and priority 

public uses of the National Wildlife Refuge System. 

It also presents four principles to guide management 

of the Refuge System.

Executive Order 13007, Indian Sacred Sites (1996)—

Directs Federal land management agencies to accommodate access to and ceremonial uses of American 

Indian sacred sites by American Indian religious 

practitioners, avoid adversely affecting the physical 

integrity of such sacred sites, and where proper, keep 

the confidentiality of sacred sites.

Federal Noxious Weed Act (1990)—Requires the 

use of integrated management systems to control or 

contain undesirable plant species and an interdisciplinary approach with the cooperation of other Federal and State agencies.

Federal Records Act (1950)—Requires the preservation of evidence of the Government’s organization, 

functions, policies, decisions, operations, and activities, as well as basic historical and other 

information.

Fish and Wildlife Coordination Act (1958)—Allows 

the U.S. Fish and Wildlife Service to enter into 

agreements with private landowners for wildlife 

management purposes.

Migratory Bird Conservation Act (1929)—Establishes procedures for acquisition by purchase, rental, 

or gifts of areas approved by the Migratory Bird 

Conservation Commission.

Migratory Bird Hunting and Conservation Stamp Act

(1934)—Authorizes the opening of part of a refuge to 

waterfowl hunting.

Migratory Bird Treaty Act (1918)—Designates the 

protection of migratory birds as a Federal responsibility; and enables the setting of seasons and other 

regulations, including the closing of areas, Federal or 

non-Federal, to the hunting of migratory birds.

National Environmental Policy Act (1969)—

Requires all agencies, including the Service, to examine the environmental impacts of their actions, 

incorporate environmental information, and use public participation in the planning and implementation 

of all actions. Federal agencies must integrate this 

Act with other planning requirements, and prepare 

A.2 Legal and Policy Guidance

Management actions on national wildlife refuges 

are circumscribed by many mandates including laws 

and Executive orders.

American Indian Religious Freedom Act (1978)—

Directs agencies to consult with native traditional 

religious leaders to figure out proper policy changes 

necessary to protect and preserve Native American 

religious cultural rights and practices.

Americans with Disabilities Act (1992)—Prohibits 

discrimination in public accommodations and 

services.

Antiquities Act (1906)—Authorizes the scientific 

investigation of antiquities on Federal land and provides penalties for unauthorized removal of objects 

taken or collected without a permit.

Archaeological and Historic Preservation Act 

(1974)—Directs the preservation of historic and 

archaeological data in Federal construction projects.

Archaeological Resources Protection Act (1979), as 

amended—Protects materials of archaeological interest from unauthorized removal or destruction and 

requires Federal managers to develop plans and 

schedules to locate archaeological resources.

Architectural Barriers Act (1968)—Requires federally owned, leased, or financed buildings and facilities 

to be accessible to persons with disabilities.

Clean Water Act (1977)—Requires consultation 

with the U.S. Army Corps of Engineers (404 permits) for major wetland modifications.

Dingell–Johnson Act (1950)—Authorized the Secretary of the Department of the Interior to provide 

financial help for State fish restoration and management plans and projects. Financed by excise taxes 

paid by manufacturers of rods, reels, and other fishing tackle. Known as the Federal Aid in Sport Fish 

Restoration Act.

Endangered Species Act (1973)—Requires all Federal agencies to carry out programs for the conservation of endangered and threatened species.

Executive Order 11988 (1977)—Requires Federal 

agencies to provide leadership and take action to 

reduce the risk of flood loss, decrease the effect of 
Appendix A—Key Legislation and Policy 133 

Refuge Recreation Act (1962)—Allows the use of 

refuges for recreation when such uses are compatible 

with the refuge’s primary purposes and when sufficient money is available to manage the uses.

Rehabilitation Act (1973)—Requires programmatic 

accessibility and physical accessibility for all facilities 

and programs paid for by the Federal Government to 

make sure that any person can take part in any 

program.

Rivers and Harbors Act (1899)—Section 10 of this 

Act requires the authorization of U.S. Army Corps of 

Engineers before any work in, on, over, or under 

navigable waters of the United States.

Volunteer and Community Partnership Enhancement 

Act (1998)—Encourages the use of volunteers to help 

in the management of refuges within the Refuge System; facilitates partnerships between the Refuge 

System and non-Federal entities to promote public 

awareness of the resources of the Refuge System and 

public participation in the conservation of the 

resources; and encourages donations and other 

contributions.

proper documents to facilitate better environmental 

decisionmaking. [From the Code of Federal Regulations (CFR), 40 CFR 1500]

National Historic Preservation Act (1966), as 

amended—Establishes as policy that the Federal 

Government is to provide leadership in the preservation of the Nation’s prehistoric and historic resources.

National Wildlife Refuge System Administration Act

(1966)—Defines the National Wildlife Refuge System 

and authorizes the Secretary of the Department of 

the Interior to allow any use of a refuge, provided 

such use is compatible with the major purposes for 

which the refuge was established.

National Wildlife Refuge System Improvement Act 

of 1997—Sets the mission and administrative policy 

for all refuges in the National Wildlife Refuge System; mandates comprehensive conservation planning 

for all units of the Refuge System.

Native American Graves Protection and Repatriation 

Act (1990)—Requires Federal agencies and museums 

to inventory, find ownership of, and repatriate cultural items under their control or possession.

This CCP is the result of extensive, collaborative, and enthusiastic effort by the members of the planning 

team shown below. In addition, many others have contributed time as subject matter experts and reviewers.

B.1 Planning Team

Team member Position Work unit

Patti Bennett-Taylor Budget analyst, former National Elk Refuge, Jackson, Wyoming

Eric Cole Wildlife biologist National Elk Refuge, Jackson, Wyoming

Carol Cunningham Technical writer and editor Grand Teton National Park, Moose, Wyoming

Cris Dippel Deputy refuge manager National Elk Refuge, Jackson, Wyoming

Mark Ely GIS specialist (former) U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Tim Fuchs Wildlife supervisor WGFD, Jackson Regional Office, Jackson, Wyoming

Toni Griffin Planning team leader U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Kirk HaYenga Heavy mobile equipment 

mechanic (former) National Elk Refuge, Jackson, Wyoming

Lori Iverson Outdoor recreation planner National Elk Refuge, Jackson, Wyoming

Steve Kallin Refuge manager National Elk Refuge, Jackson, Wyoming

Amanda Losch Staff biologist WGFD, Headquarters, Cheyenne, Wyoming

Marty Meyer Law enforcement officer 

(former) National Elk Refuge, Jackson, Wyoming

Alex Norton Senior planner Teton County Planning Department, Jackson, Wyoming

Deb Parker Writer-editor U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Paul Santavy Deputy refuge manager 

(former) National Elk Refuge, Jackson, Wyoming

Daniel Sharps 

(deceased)

Rangeland management 

specialist National Elk Refuge, Jackson, Wyoming

Amanda Soliday Engineering equipment 

operator National Elk Refuge, Jackson, Wyoming

Bryan Yetter Law enforcement officer National Elk Refuge, Jackson, Wyoming

Mitch Werner Writer-editor U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Appendix B

List of Preparers and Contributors
136 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

B.2 Contributors

Many organizations, agencies, and individuals helped prepare this CCP. We acknowledge the efforts of the 

following individuals and groups toward the completion of this plan. The diversity, talent, and knowledge contributed dramatically improved the vision and completeness of this document.

Contributor Position Work unit

Lara Gertsch Aquatic habitat biologist WGFD, Jackson Regional Office, Jackson, Wyoming

Shannon Heath Outdoor recreation planner U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Wayne King National Wildlife Refuge System 

biologist U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Lynne Koontz Economist U.S. Geological Survey, Fort Collins, Colorado

David Lucas Chief, Division of Refuge Planning U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Dean Rundle Refuge supervisor U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Richard Sterry Regional fire planner U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado

Meg Van Ness Regional archaeologist U.S. Fish and Wildlife Service, Region 6, Lakewood, Colorado
display a history of the Refuge System, an orientation to the National Elk Refuge, and an overview of 

the processes for comprehensive conservation planning and implementing NEPA. Staff answered questions on a variety of topics about refuge management 

and the CCP process. We encouraged the 40 attendees to ask questions and offer comments; planning 

team members recorded verbal comments and gave 

each attendee a comment form to submit additional 

thoughts or questions, which were due by February 

10, 2011.

We sent out a second planning update in March 

2011. The update summarized the public scoping 

efforts and the more than 200 comments that the 

planning team received during scoping. The update 

listed the key issues that we identified: landscapescale conservation, wildlife, habitat, scenic quality, 

and visitor services. We considered input from the 

public open house, letters, emails, and comment 

forms in developing the draft CCP and EA.

Although the public identified bison and elk management as an issue during scoping for the CCP, the 

issue is outside the scope of this planning process. We 

and NPS previously addressed this issue in an interagency environmental analysis process that had 

extensive public involvement. In 2007, we completed 

the resulting “Bison and Elk Management Plan: 

National Elk Refuge, Grand Teton National Park, 

and John D. Rockefeller, Jr. Memorial Parkway” 

(FWS and NPS 2007a), which has goals, objectives, 

and strategies for managing bison and elk at the 

National Elk Refuge and Grand Teton National Park 

for the next 15 years.

Review of the Draft Plan

The draft CCP and EA were released to the public on September 9, 2014, through a notice of availability published in the Federal Register. Copies of 

either the draft CCP and EA or a planning update 

were mailed to individuals on the mailing list. The 

document was also made available online through the 

Service’s Mountain-Prairie Region refuge planning 

Web site and the National Elk Refuge’s Web site. The 

public was offered 30 days to review this document 

and provide comments. At the request of several 

This appendix describes how the Service conducted public involvement and considered the resulting information for developing the CCP for the 

National Elk Refuge.

C.1 Public Involvement 

Activities

The Service began public involvement activities 

by developing a mailing list of more than 200 names 

during preplanning. The list includes private citizens; 

local, regional, and State government representatives 

and legislators; other Federal agencies; and interested organizations.

Public Scoping

A notice of intent to prepare the draft CCP and 

EA for the National Elk Refuge was published in the 

Federal Register on October 22, 2010 (65370, Vol. 75, 

No. 204). The notice provided information concerning 

the refuge and the CCP process along with information on how the public may provide comments concerning issues to consider in the environmental 

document and in development of the CCP. Written 

comments were accepted through November 22, 

2010. The notice indicated additional opportunities 

for providing comments would be announced in local 

news media throughout the CCP process.

We sent the first planning update to the mailing 

list addresses in early January 2011. The planning 

update provided information on the history of the 

National Elk Refuge and the CCP process, along 

with an invitation to an upcoming public open house 

January 11. We invited the public to meet with our 

staff, learn more about the planning process, and provide input on the planning process. The planning 

update told people how to submit written comments 

by letter, fax, or email, which were due February 10, 

2011.

At the January 11 open house, the planning team 

used informational posters, maps, and handouts to 

Appendix C

Public Involvement
138 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

National Park Service, Grand Teton National 

Park, Moose, Wyoming

National Park Service, Intermountain Regional 

Office, Denver, Colorado

U.S. Forest Service, Bridger-Teton National Forest, Jackson, Wyoming

Tribal Officials

Assiniboine and Sioux Tribes of Fort Peck, Popular, Montana

Cheyenne and Arapaho Tribes, Concho, 

Oklahoma

Cheyenne River Sioux Tribe, Eagle Butte, South 

Dakota

Crow Creek Sioux Tribal Council, Fort Thompson, South Dakota

Eastern Shoshone Tribal Council, Fort 

Washakie, Wyoming

Lower Brule Sioux Tribe, Lower Brule, South 

Dakota

Northern Arapaho Business Council, Fort 

Washakie, Wyoming

Northern Cheyenne Tribal Council, Lame Deer, 

Montana

Oglala Sioux Tribe, Pine Ridge, South Dakota

Rosebud Sioux Tribal Council, Rosebud, South 

Dakota

Santee Sioux Tribal Council, Niobrara, Nebraska

Shoshone—Bannock Tribes, Fort Hall, Idaho

Shoshone Business Council, Fort Washakie, 

Wyoming

Shoshone Cultural Center, Fort Washakie, 

Wyoming

Standing Rock Sioux Tribal Council, Fort Yates, 

North Dakota

State Officials

Governor Matt Mead, Cheyenne, Wyoming

Senator Leland G. Christensen, Alta, Wyoming

Senator Dan Dockstader, Afton, Wyoming

Representative Keith Gingery, Jackson, 

Wyoming

Representative Ruth A. Petroff, Jackson, 

Wyoming

Representative Jim Roscoe, Wilson, Wyoming

State Agencies

Wyoming Game and Fish Department, Cheyenne, Wyoming

Wyoming Game and Fish Department, Jackson, 

Wyoming

Wyoming Game and Fish Department, Lander, 

Wyoming

organizations and individuals, the comment period 

was extended to October 24, 2014, for a total of 45 

days.

Notification to the public included a press release 

distributed to Wyoming media contacts and outreach 

to congressional representatives and WGFD. The 

refuge also forwarded the news release to approximately 280 contacts, including regional media, nongovernmental organizations, Federal partners, 

business leaders, and other community members. 

The press release provided information for obtaining 

a copy of the draft CCP and EA and methods for submitting comments. A subsequent press release 

informed the public of the extension to the comment 

period. Press releases were posted on the National 

Elk Refuge and Mountain-Prairie Region refuge 

planning Web sites. Several Wyoming-based newspapers carried the announcements as well as a local 

radio station. A refuge staff member was interviewed by the Jackson Hole community radio station 

KHOL.

During the public review period, the Service held 

a public meeting on September 25, 2014, in Jackson, 

Wyoming. Turnout was moderate, with the meeting 

attended by 18 participants. A news release was 

issued, and planning updates were mailed providing 

details on where and when the meeting would be 

held. A short presentation was given on the draft 

CCP, followed by an opportunity for participants to 

ask questions and offer comments. In addition to the 

oral comments recorded at the meetings, 41 emails 

and letters were received. All comments were to be 

received or postmarked by October 24, 2014.

Public Mailing List

The Service sent planning updates to all agencies, 

individuals, and organizations on the mailing list. In 

addition, by written request many hard copies of the 

draft CCP and EA were distributed to the mailing 

list, and to honor additional requests received during 

the review period for copies.

Federal Officials

U.S. Congressman Cynthia Lummis, Washington, DC

U.S. Senator John Barrasso, Washington, DC

U.S. Senator Michael Enzi, Washington, DC

Federal Agencies

Bureau of Reclamation, Pacific Northwest 

Regional Office, Boise, Idaho
Appendix C—Public Involvement 139 

Jackson Hole Chamber of Commerce, Jackson, 

Wyoming

Jackson Hole Conservation Alliance, Jackson, 

Wyoming

Jackson Hole Historical Society and Museum, 

Jackson, Wyoming

Jackson Hole Land Trust, Jackson, Wyoming

Jackson Hole Wildlife Foundation, Jackson, 

Wyoming

The Murie Center, Moose, Wyoming

Northern Rockies Conservation Cooperative, 

Jackson, Wyoming

Rocky Mountain Elk Foundation, Missoula, 

Montana

Safe Wildlife Crossings for Jackson Hole, Jackson, Wyoming

Sportsmen for Fish and Wildlife, Jackson, 

Wyoming

Teton Raptor Center, Wilson, Wyoming

Teton Science Schools, Jackson, Wyoming

The Wildlife Society, Bethesda, Maryland

The Wildlife Society Wyoming Chapter, Lander, 

Wyoming

Wildlife Conservation Society, Bronx, New York

Wyoming Wetlands Society, Jackson, Wyoming

Wyoming Wildlife Federation, Lander, Wyoming

Universities

Northwestern University, Evanston, Illinois

Sinte Gleska University, Sicangu Heritage Center, Mission, South Dakota

Media

Associated Press, Cheyenne, Wyoming

Casper Star Tribune, Casper, Wyoming

Dubois Frontier, Dubois, Wyoming

Herald Journal, Logan, Utah

Idaho State Journal, Pocatello, Wyoming

Jackson Hole Magazine, Jackson, Wyoming

Jackson Hole News & Guide, Jackson, Wyoming

Jackson Hole Underground, Jackson Hole, 

Wyoming

K2TV, Casper, Wyoming

KCWY13, Mills, Wyoming

KHOL, 89.1, Jackson Hole Community Radio, 

Jackson, Wyoming

KID FM, Idaho Falls, Idaho

KIFI TV, Idaho Falls, Idaho

KPIN, Pinedale Radio, Pinedale, Wyoming

KPVI TV, Pocatello, Idaho

KTWO, Casper, Wyoming

KZ95, Jackson Hole Radio.com, Jackson, 

Wyoming

New York Times, New York, New York

Pinedale Online, Pinedale, Wyoming

Local Government

Teton Conservation District, Jackson, Wyoming

Teton County Board of Commissioners, Jackson, 

Wyoming

Teton County Building Department, Jackson, 

Wyoming

Teton County Sheriff, Jackson, Wyoming

Town of Jackson, Jackson, Wyoming

Businesses

Alta Planning and Design, Saratoga Springs, 

New York

Atkins, PBS&J, Missoula, Montana

Bear Creek Incorporated, Jackson, Wyoming

Biota Research and Consulting, Jackson, 

Wyoming

Brush Buck Guide Services, Jackson, Wyoming

Burton Design Incorporated, Jackson, Wyoming

Four Seasons Resort, Teton Village, Wyoming

Grizzly Country Wildlife Adventures, Jackson, 

Wyoming

Jackson Hole Eco Tour Adventures, Jackson, 

Wyoming

Jackson Hole Photo Tours, Jackson, Wyoming

Jackson Hole Wildlife Safaris, Jackson, Wyoming

Nelson Engineering, Jackson, Wyoming

Snake River Brewing Company, Jackson, 

Wyoming

Snowmobiletours.net, Wyoming

Spring Creek Ranch, Jackson Hole, Wyoming

Steady Jake Mobile DJ, Jackson, Wyoming

The Hole Hiking Experience, Jackson, Wyoming

UpStream Anglers and Outdoor Adventures, 

Jackson, Wyoming

Wyoming Photo Experience, Jackson, Wyoming

Organizations

Concerned Citizens for the Elk, Jackson, 

Wyoming

Craighead Beringia South, Kelly, Wyoming

Defenders of Wildlife, National Headquarters, 

Washington, DC

Ducks Unlimited, Conservation Program, Bismarck, North Dakota

Ducks Unlimited, National Headquarters, Memphis, Tennessee

Friends of Pathways, Jackson, Wyoming

Greater Yellowstone Coalition, Jackson, 

Wyoming

Teton County Weed and Pest District, Jackson, 

Wyoming

Jackson Hole and Greater Yellowstone Visitor 

Center, Jackson, Wyoming

Jackson Hole Art Initiative, Jackson, Wyoming
140 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

respond to specific nonsubstantive comments where 

the public displayed a strong interest.

A summary of the individual comments is presented below, followed by specific comments and 

responses. The Service developed responses to each 

of these comments after grouping them in the following topics:

■ Climate change

■ Landscape-scale conservation—wildlife 

crossings, land exchanges, easements, offrefuge conservation measures

■ Habitat management—riparian and aspen 

woodlands, Flat Creek enhancement project, wetlands, marshes and ponds

■ Wildlife—threatened and endangered species, migratory birds, amphibians and reptiles, beavers

■ Fire management

■ Disease management

■ Water resources

■ Inventory, monitoring, and research

■ Education and visitor services—hunting, 

mandatory carry of bear spray, non-lead 

ammunition, fishing, wildlife observation 

and photography, Highway 89 pathway, nonconsumptive uses

■ Administration and facilities—Elk Refuge 

Road, access to National Forest

■ Partnerships

■ NEPA compliance and planning process

■ Comments outside the scope of the plan—

bison and elk management

The following is a summary of the substantive 

comments received and the Service’s response to 

those comments.

Climate Change

Comment. The NER must compensate for the current and anticipated loss of habitat quality and 

security on nearby lands, including migration 

Pinedale Roundup, Pinedale, Wyoming

Planet Jackson Hole, Jackson, Wyoming

Post Register, Idaho Falls, Idaho

Star Valley Independent, Afton, Wyoming

Sublette Examiner, Pinedale, Wyoming

Teton Valley News, Driggs, Idaho

The Mountain Pulse, Jackson, Wyoming

The Valley Citizen, Driggs, Idaho

Valley Citizen, Driggs, Idaho

Wyoming Lifestyle Magazine, Laramie, 

Wyoming

Wyoming Public Radio, Laramie, Wyoming

Individuals

121 individuals

C.2 Public Comments on the 

Draft Plan

The public provided many comments during the 

public review period for the draft CCP and EA. The 

Service reviewed all comments and found the following to be substantive. As defined by 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 

assessment;

■ Cause changes or revisions in the proposal.

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, businesses, and organizations 

are excluded. Rather than print every letter from 

individuals and redact (black out) all personal information, the Service has summarized the general 

nature of the comments received and responded to 

each substantive comment. Some of the comments do 

not meet the definition of “substantive” (as defined 

previously), and those are shown as “comment 

noted.” In some instances, the Service has opted to 
Appendix C—Public Involvement 141 

Landscape-Scale Conservation

Wildlife Crossings

Comment. Support for installing wildlife crossings 

(overpasses or underpasses) over Highway 89.

Response. Comment noted.

Comment. Building wildlife crossings over Highway 

89 has the potential for unintended consequences. 

To direct elk off East Gros Ventre Butte and onto 

the NER, there would need to be a wildlife-proof 

fence on the west side of the highway stretching 

from the Town of Jackson to the top of Fish 

Hatchery Hill. The crossings would have to have 

“jumps” on the refuge side so as to allow elk to 

enter the refuge but not be able to leave via the 

same route. The other concern is for the mule 

deer population that winters on East Gros Ventre 

Butte. These animals would likely cross onto the 

refuge, abandoning good winter range while 

likely ending up competing with the bighorn 

sheep and few deer already wintering the NER’s 

Miller Butte. It would be important to know the 

summer range of both the elk and deer that would 

be moving onto the refuge from East Gros Ventre 

Butte—would their inability to move west off the 

refuge interfere with their spring migration to 

their traditional summer range?

Response. We agree that the effects of any future 

wildlife crossings will require careful evaluation. 

Alternatives to wildlife crossings such as reduced 

speed limits will be explored.

Comment. Oppose wildlife crossings for highway 89. 

They don’t work in other areas like the one on 

Route 93 north of Missoula, MT and cost money 

which our government doesn’t have.

Response. Comment noted.

Comment. The proposed overhead corridor for game 

sounds like a good idea. However, there is a wildlife overpass in Canada that reportedly is not 

being used by animals. Suggest funding several 

in high traffic areas and monitoring to see if the 

game animals will use.

Response. Comment noted.

corridors, and for the harmful effects of global 

warming. It is clear that elk have been and will be 

declining as a result of drought and deteriorating 

forage conditions in the Greater Yellowstone Ecosystem and the trends will show no signs of abating. Thus, elk, bears and other wildlife that uses 

NER lands will need more habitat and improved 

security, not less, in years to come.

Response. As climate change information for the 

greater Yellowstone area becomes available, it 

will provide an opportunity for the refuge to 

respond as outlined in the Service’s 2010 climate 

change strategy, “Rising to the Urgent Challenge: 

Strategic Plan for Responding to Accelerating 

Climate Change.” This plan identifies three categories of response: adaptation, mitigation, and 

engagement. 

Climate change science will continue to advance 

and eventually provide fine-scale information that 

will enable the refuge to formulate science-based 

adjustments to management to help reduce the 

impacts of climate change on fish, wildlife, and 

their habitats.

There is no indication that habitat quality is currently deteriorating on the National Elk Refuge. 

Refuge forage will continue to be stimulated 

through the expanded irrigation system, which 

will help compensate for reduced precipitation in 

the future due to climate change.

Approximately 97 percent of the land in Teton 

County is under Federal protection, providing 

habitat that meets the needs of resident wildlife 

species throughout their life cycles. Large blocks 

of public land are immediately adjacent to the 

north and east boundaries of the refuge. The protected status of these Federal lands is not anticipated to change, so the wildlife habitat they 

provide is considered secure. 

All acres on the refuge, except for buildings, 

roads, and parking lots, are considered habitat for 

wildlife. Increasing habitat managed by the refuge would require expanding the size of the refuge and the refuge acquisition boundary, actions 

which are outside the scope of this CCP. 

The National Elk Refuge is a signatory to and 

supporter of “The Path of the Pronghorn” and 

will continue to manage whenever practicable in a 

manner that does not impede wildlife migration.
142 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

likely nest predators for long-billed curlews. We 

favor restoring this area to native grassland vegetation over time.

Flat Creek Enhancement Project

Comment. Enhancement of Flat Creek is critical for 

meeting NER’s goals.

Response. Thank you for your comment. We agree 

enhancement of Flat Creek is important for meeting the refuge’s goals.

Comment. What effects will fish screens have on 

amphibians? What are the effects of actions to 

remove non-native fish? What effects with the 

Flat Creek enhancement project have on amphibians and their streamside habitats? For example, 

will stream bank restoration actions harm boreal 

toads by destroying their winter sites in bank 

cavities; will pools adjacent to Flat Creek be 

harmed by the project?

Response. We do not have data to evaluate effects of 

these activities on amphibians.

Wetlands, Marshes, and Ponds

Comment. Nowlin Ponds 1 and 4, and Romney 

Ponds 1 and 2 are source breeding areas for 

boreal toads and Columbia spotted frogs. Nowlin 

Pond 1 water levels are crucial to spotted frog 

breeding, and need to be adjusted each spring to 

flood the most productive egg-deposition sites. 

Nowlin Pond 4 is filling up with sediment and 

will wink out as a breeding site in the future. 

Romney ponds are targeted for structural work 

and new pond construction with unknown outcomes for amphibians. The effects of wetland 

actions need to be assessed for amphibians. Modifications of important breeding sites could affect 

amphibian source populations and have a strong 

impact on the persistence of amphibians on the 

NER. How will “improving water control structures” affect the habitat features that favor 

amphibians? Can a plan be put in place to ensure 

that amphibian breeding habitat adjacent to 

Nowlin Pond 1 is protected in the coming years? 

Can you include a plan to help ensure that Nowlin Pond 1 water levels are adjusted to facilitate 

frog breeding during the critical April/May 

breeding season? The Environmental Consequences section inexplicably leaves out the effects 

on amphibians of projects mentioned in Chapter 

6 (p. 203): new water control structures in Romney ponds, construction of two new ponds in the 

Land Exchanges, Easements, and OffRefuge Conservation Measures

Comment. Support for targeted land exchanges, easements or other off refuge conservation measures 

that increase/maintain habitat connectivity.

Response. Comment noted.

Habitat Management

Riparian and Aspen Woodlands

Comment. The preferred alternative (D) contains 

inconsistencies in that in one place it says “allow 

natural revegetation as ungulate populations 

allow” and use temporary exclosures to support 

restoration work. On page 59 it says “enclosures 

might be used”, but Table 4 (and Chapter 6) 

makes it seem more likely? The plan to restore 

and protect woody vegetation needs to be formulated and summarized clearly. To what extent 

will elk and bison browsing eliminate the supposed benefits of burning in restoring riparian 

areas, without effective exclosures?

Response. Use of exclosures to promote regeneration 

of woody plant communities will be site-specific 

and plant community–specific. Strategies to foster 

regeneration and height recovery in willow, aspen, 

and cottonwood plant communities will be developed in the forthcoming habitat stepdown management plan, which is scheduled to be completed 

in 2017.

Comment. I see no justification for removing the 

shelterbelt and exclosure in the headquarters 

management unit. Doing so would lead to the 

destruction of the enclosed woody plant community by elk and bison. Regardless of its original 

intent, its long history has undoubtedly established a nesting bird community that will be 

eliminated thereby impacting species diversity 

and abundance.

Response. There is no evidence that the shelterbelt 

and exclosure has been used by elk as intended (as 

a wind break to provide shelter and limit energy 

expenditure in the winter). The shelterbelt is composed of nonnative species and trees and shrubs 

that would not regenerate naturally at this site. 

Breeding bird surveys conducted within the shelterbelt and exclosure found ravens, magpies, 

house sparrows, green-winged teal, vesper sparrows, American robins, and Brewer’s blackbirds. 

None of these species are rare, and some are 
Appendix C—Public Involvement 143 

main food sources required for population 

growth, the Whitebark Pine Seed and the Cutthroat Trout. The last 2 remaining food sources 

are in jeopardy, the high altitude army cutworm 

moth habitat is in question due to climate warming, and pesticides and the elk and bison are 

drastically on the decline throughout the Greater 

Yellowstone Ecosystem and in the Southern 

Region, Grand Teton National Park. Continuing 

to reduce the elk herd when it is in decline 

throughout the ecosystem, likely due in part to 

climate change, and when it is the last predominant food source for the threatened grizzly bear is 

a violation of Executive Orders, National Environmental Policy Act, and Section 7 of the 

Endangered Species Act of 1973, (Act; 50CFR sec. 

402.12), 16 U.S.C. sec 1536 (a)(2).

Response. Comment noted.

Comment. Concern for protection of endangered and 

threatened species including grizzly bears and 

wolves. Adopt a plan which includes the best 

available hunter-grizzly bear education and 

information program.

Response. Comment noted.

Comment. I have concerns with the following comment on page 8 of the Draft CCP: “...in general, 

the plan moves elk and bison management 

toward reduces reliance on supplemental feeding, 

and, at some future time, total reliance on natural forage.” I have grave concerns that this openended comment does not reflect the intention of 

the 2007 Bison and Elk plan to end supplemental 

feeding in a timely manner—as opposed to at 

“some future time.”

Response. A stepdown management plan is currently 

being developed to address supplemental 

feeding.

Migratory Birds

Comment. A purpose of the NER is to provide a 

sanctuary and breeding ground for birds. As the 

plan states, dragging irrigation lines over the 

ground can have negative effects on the groundnesting birds such as curlew. How will these 

impacts be mitigated?

Response. We agree that one refuge purpose is to be 

a “refuge and breeding ground for birds.” However, the refuge was also established as a “winter 

elk (game) reserve” and a “winter elk refuge.” 

There is no assumption that all parts of the refuge 

will concurrently meet all purposes, and therefore 

it is appropriate that on some portions of the refuge, elk winter habitat is enhanced using irrigaRomney complex, and the abandonment Pierre’s 

Pond dikes. Please consider amphibians in the 

design, construction, and maintenance of ponds. 

For example, include shallow water zones along 

the edges, exclude fish if possible, retain springs 

and small streams in a large zone around ponds, 

maintain complexity and diversity in the surrounding uplands (willow stands, trees and 

woody debris, uncompacted soils), minimize use 

and access by heavy machinery, create dikes that 

eventually mimic natural land forms and host 

native vegetation, and ensure that inlet and outlet structures are amphibian-friendly.

Response. Management of pond water levels and 

water control structures will be evaluated in the 

forthcoming habitat stepdown management plan 

(scheduled for 2017), and amphibian populations 

and habitat will be considered as part of this process. It is important to note that constructed 

ponds require active management if they are to 

persist, and on occasion short-term loss of habitat 

is necessary to ensure availability of habitat in the 

long term.

Comment. The plan should include direction on how 

to evaluate and improve the deteriorating condition of the marsh and ponds adjacent to the Visitor Center. Flat Creek by the overlook before it 

leaves the refuge has become silted in since the 

bridge was improved some years ago.

Response. Comment noted. However, the refuge does 

not consider successional changes in wetlands to 

be deterioration.

Wildlife

Threatened and Endangered Species

Comment. Since the release of the Draft CCP, Wyoming’s gray wolf population has been placed 

under the jurisdiction of the U.S. Fish and Wildlife Service and now has the full protection of the 

Endangered Species Act. As long as this protection remains, the NER is required to manage for 

the gray wolf’s health and safety. Consequently, 

all sections within this Draft CPP referring to 

threatened and endangered species should now 

include the wolf and its management within the 

NER.

Response. Comment noted.

Comment. The Grizzly throughout the Greater Yellowstone Ecosystem has totally lost 2 of the 4 the 
144 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

NER); the species is most likely extirpated in 

Teton County rather than “vulnerable to population decline in Jackson Hole.” Finding any leopard frogs on the NER would be a very significant 

event, warranting evaluation and species/habitat 

protective measures if these frogs are found.

Bullfrogs have not been documented on the NER. 

The only bullfrogs in Teton County inhabit Kelly 

Warm Springs (Grand Teton National Park), just 

north of NER. Knowledge of this is important, 

because non-native bullfrogs could negatively 

affect native amphibians if they invade NER. The 

appearance of bullfrogs on the NER would be a 

significant event warranting rapid management 

recognition and response.

Boreal toads are widespread in portions of the 

NER, not across the entire refuge (p. 128). Only 2 

main breeding sites and a few minor, intermittently used breeding sites have been identified 

over the past 15 years. Monitoring of toads has 

been conducted nearly annually at one of breeding areas (Nowlin pond 4) over the past decade, 

and this breeding population appears to be 

robust. However, boreal toads should be considered particularly vulnerable on the NER due to 

the sparse number of breeding sites. Loss or degradation of the Nowlin Pond 4 breeding site 

(which hosts the source population) would negatively affect the persistence of this species on the 

southern portion of the NER (Flat Creek 

drainage).

Columbia spotted frogs appear to be declining in 

the region (Hossack et al. 2013) and in Yellowstone/Grand Teton national parks (analysis and 

paper in progress 2014). Western tiger salamanders suffered a large loss when the Fish Hatchery 

outflow pond was converted to a fishing pond. 

Degradation of the wetlands near the Visitor 

Center may have led to another salamander 

breeding site loss.

Three amphibian species (Columbia spotted 

frogs, boreal toads, and western tiger salamanders) are Wyoming Species of Concern. The 

boreal chorus frog is not on the state list, but 

should be of special concern and interest to NER 

because of its particular vulnerability to climate 

change, more so than the other amphibian species, due to preferred breeding habitat in shallow 

pools. This species is also vulnerable to chemical 

herbicides and pesticides and prescribed burning; chorus frogs forage and winter in habitats 

such as meadows and open woodlands which are 

tion techniques. Mitigation strategies to reduce 

the effect of the irrigation program on birds 

includes survey and identification of long-billed 

curlew nesting territories. Areas around these 

sites are not irrigated until August, when the bird 

breeding season has ended. Field observations 

also suggest that K-Line irrigation hoses ride 

over passerine bird ground nests because the 

nests are slightly recessed below surrounding terrain, although this effect has not been quantified.

Comment. I question why the strategies listed under 

the migratory bird objective only include monitoring. There are a number of habitat improvements that could be implemented including 

restoring willow and cottonwood riparian habitats on the refuge, and improving habitat in the 

Flat Creek main marsh and other wetlands. An 

objective to maintain high quality habitat for 

migratory birds needs to be developed.

Response. Specific habitat treatments for migratory 

birds will be considered in the forthcoming habitat management plan.

Comment. The refuge supplies the most important 

nesting habitat for swans in the Jackson area. 

There are a number of ways to increase swan 

nesting habitat through management of wetland 

vegetation and installing floating islands where 

nests are often flooded out. Additional ponds 

could be built along Flat Creek north of the Fish 

Hatchery.

Response. Comment noted.

Amphibians and Reptiles

Comment. Chapter 4 should describe the habitat 

requirements of amphibians, habitat types on the 

NER that support amphibians, which areas may 

be critical for species persistence, and how such 

habitats and areas may be vulnerable to various 

management actions, climate change, and ecological changes to wetlands and plant communities.

All existing amphibian species should be 

regarded as ‘vulnerable to decline’ due to climate 

change, habitat loss and fragmentation, diseases, 

lack of management attention to critical habitats, fishery management, and water pollution, 

chemical herbicides, pesticides, and wetland and 

stream bank disturbances (p. 128 in Chapter 4).

Northern leopard frogs, which are highlighted by 

the Draft CCP, have not been documented in 

Jackson Hole for decades (and never on the 
Appendix C—Public Involvement 145 

ponds provide breeding sites for amphibians as 

well as summer foraging and winter hibernation 

habitat for some species. Loss of beaver ponds 

created in tall willows plant communities and 

the lack of woody vegetation and woody debris 

are likely limiting factors for amphibians on the 

NER. Alternative D is said to have the “same 

effects as alternative A”, but the Alternative D 

section describes the beneficial effects of ‘more 

beaver ponds’. Elsewhere (Chapter 3 and Table 4) 

Alternative D leaves out beaver restoration (only 

included in Alternative C). Failure to restore beavers will lead inevitably to the continued diminishment of amphibians, as existing ponds fill 

with sediment over time and breeding sites are 

lost, but no new breeding sites are created.

Response. We agree that restoration of beavers 

would be beneficial to amphibian habitat. However, restoration of beaver will be contingent upon 

recovery of riparian woody vegetation. The timeline and specific strategies for recovery of woody 

vegetation will be developed in the forthcoming 

habitat stepdown management plan to be completed in 2017.

Comment. Will beavers be eradicated in some areas 

to protect the pond facilities? The CCP needs to 

disclose if beavers will not be tolerated in some 

areas, and what effects this may have on adjacent 

wetlands.

Response. There are no plans to eradicate beavers 

from pond facilities. Any new ponds will be 

equipped with structures designed to prevent 

beavers from clogging water control structures. 

This strategy has proven effective in other refuge 

ponds.

Comment. Why introduce beavers into refuge wetlands? There are no trees for food or dam 

construction.

Response. Any reintroduction would be predicated 

on recovery of appropriate woody habitat in riparian areas. Reintroduction implies natural dispersal and colonization of beavers from surrounding 

areas, which clearly would only occur if appropriate habitat existed on the refuge. Detailed strategies to promote the recovery of woody plant 

communities will be developed in the habitat stepdown management plan, which is planned for 2017.

Fire Management

Comment. Nesting areas for migratory birds (and 

non-migratory native birds) should not be part of 

subject to NER’s widespread and abundant management actions to increase elk winter habitat.

Response. Your detailed comments and suggested 

corrections are appreciated. We agree that 

amphibian species found on the refuge are vulnerable to population decline and noted this in chapter 4 of the draft CCP; however, we do not believe 

the level of detailed analysis and commentary that 

you recommend is necessary for each amphibian 

species because this level of detail was not used 

for any other species in the document. We agree 

that northern leopard frogs have likely been 

extirpated from Jackson Hole, and we have 

removed the paragraph that implied otherwise. 

Our reference to bullfrog presence concerned 

Jackson Hole in its entirety and not the refuge 

specifically. In general, we agree that all amphibian species are a taxa of special concern that we 

intend to conserve. However, conservation efforts 

are limited by available resources and conflicting 

management priorities.

Comment. Amphibian species on the NER depend on 

ponded (stagnant) water for breeding. Pond management actions, fish management, and hydrological changes thus could have a dramatic effect 

(positive or negative) on amphibian reproduction. 

In addition to breeding sites (ponds and pools), 

summer foraging and overwintering habitat are 

also critical for amphibians. Summer foraging 

includes wetlands, wet and moist meadows, 

marshes, riparian zones, pond and stream edges. 

Winter sites vary among species: spotted frogs 

winter in springs and spring-fed streams and 

ponds, while the other species winter terrestrially 

(e.g., toads overwinter in rodent burrows, and 

bank cavities). Loss or reduction of breeding, 

summer foraging, and hibernation habitats will 

adversely affect amphibians. Establishing buffer 

zones around breeding sites, probable overwintering sites, and migration zones is 

recommended.

Response. Comment noted.

Beaver

Comment. Support restoring beaver populations as 

critical to the establishment and maintenance of 

healthy wetlands. They were an important part of 

the natural ecosystem prior to trapping and they 

should be restored to help meet the NER’s goals.

Response. Comment noted.

Comment. Beavers are important for amphibians. 

Loss of beavers on the NER has adversely 

affected amphibians and their habitats. Beaver 
146 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

the development of the fire, habitat, integrated 

pest, and the inventory and monitoring stepdown 

management plans. Our professional fire and biological staff, with input from fire personnel from 

other agencies, will continue to prescribe burns in 

accordance with the best available science to 

achieve desired results. 

Disease Management

Comment. Feeding elk in concentrated areas is putting elk at greater risk for CWD. What is the 

“contingency plan for chronic wasting disease?” 

References should be provided for where this can 

be found. How will an outbreak of CWD impact 

the alternatives? The CCP should summarize 

and evaluate the best available scientific information on ungulate diseases, transmission risk, 

consequences of outbreaks, and existing action 

plans if outbreaks occur.

Response. The disease contingency stepdown management plan, which will be completed in 2016, 

will contain a detailed discussion of ungulate diseases and management responses.

Comment. Monitoring for amphibian chytrid disease 

is stated on pages 40 and 71 of the CCP. Monitoring for this disease on the NER is not practical 

and no longer of great interest, knowing that the 

fungal pathogen is so widespread across the 

region. What is needed is an action plan for 

reporting and responding to (e.g., collection and 

submission of specimens for pathology examination) any amphibian die-offs, which could be 

encountered by staff, visitors (anglers), fish biologists and other researchers. Also needed is a system to prevent the introduction and spread of 

aquatic diseases. Infectious amphibian diseases 

may be spread by humans working or fishing in 

aquatic environments on the NER. Diseases such 

as ranavirus and whirling disease can be spread 

by anglers and biologists, if waders and gear are 

not disinfected. Suggest a program to educate 

anglers about the need to clean their gear. The 

CCP needs to disclose and plan for the threat of 

aquatically-borne diseases, which can threaten 

fish, amphibians, and birds.

Response. Your comments are noted. We will consider your suggestions as part of the disease contingency stepdown management plan, which is 

scheduled for completion in 2016.

a spring-early summer prescribed fire management plan. If it is deemed necessary to conduct 

prescribed fires in these areas, they should be 

conducted in the fall.

Response. Historically, spring burns on the refuge 

have been conducted in April prior to most bird 

nesting activity. To minimize loss of forage 

resources for elk and bison, fall burns are generally not used on the refuge. Our professional fire 

and biological staff, with input from fire personnel 

from other agencies, will continue to prescribe 

burns in accordance with the best available science to achieve desired results. 

Comment. A long-term fire management plan should 

identify habitats and locations that can benefit 

from fire, and when a natural fire event occurs, 

management response can be directed by the 

plan. Prescribed fire should be used sparingly 

and only in the fall so as not to impact nesting 

birds. Existing sagebrush communities should be 

protected from all fires in order to support sage 

grouse and other sagebrush obligate species.

Response. We agree that any future fire management plan should promote using natural fire 

events when possible to meet management objectives. Historically, spring burns on the refuge 

have been conducted in April prior to most bird 

nesting activity. To minimize loss of forage 

resources for elk and bison, fall burns are generally not used on the refuge. We agree that existing sagebrush communities should be protected 

from all fires, and this is discussed in the plan.

Our professional fire and biological staff, with 

input from fire personnel from other agencies, will 

continue to prescribe burns in accordance with 

the best available science to achieve desired 

results. 

Comment. “Manage fire regimes that mimic preEuropean settlement fire-return intervals.” How 

can this be scientifically justified or logical, given 

the knowledge that the climate now and in the 

coming decades will be radically different than it 

was 150+ years ago? Please use the best available 

information, or at least state that this is a subject 

that needs much more study.

Response. We agree that this subject requires much 

more study. However, it is not clear that today’s 

plant communities are radically different from 

those 150 years ago, nor is it clear that responses 

of plant communities to fire would be radically different within the 15-year life of the CCP. All 

future CCP stepdown management plans (table 14 

of the final CCP) will encompass the guiding principles for responding to climate change. These 

guiding principles will be especially influential in 
Appendix C—Public Involvement 147 

and bison, not cattle as mentioned on page 102. 

Until these unnaturally high concentrations of 

elk and bison are eliminated and/or moved away 

from Flat Creek, its water quality will remain 

compromised.

Response. Comment noted.

Inventory, Monitoring and 

Research

Comment. Recommend the refuge does not wait five 

years to implement the post-treatment migratory 

bird surveys in the K-line irrigation experiment 

areas. This type of method compared to the former use of ditch/flood irrigation is likely causing 

large scale nest failure of grassland, ground nesting birds in the treated areas. The refuge should 

identify if this is occurring and then implement 

changes to protect nesting species including 

Long-billed Curlew.

Response. Comment noted. The monitoring plan for 

the K-Line irrigation system assumed that breeding bird communities would change with moderate- to long-term plant community changes 

associated with the irrigation system. Preliminary observations as of 2015 suggested that these 

plant community changes have not occurred; 

accordingly, delaying this monitoring is warranted. A study to evaluate breeding bird nest 

success and productivity in irrigated versus control areas would be much more expensive and is 

not planned.

Education and Visitor Services

Comment. I think the private sector can supply the 

needs of educating the public with the overseeing 

guidance of the Elk Refuge staff. I agree that 

boating and swimming on any water that is in 

the boundaries of the Elk Refuge should be 

stopped when it interferes with wildlife occupying 

the refuge. I agree with the idea of not allowing 

antler hunters on the refuge the night before the 

Forest Service opening.

Response. Comment noted.

Comment. The Service should use a cautious 

approach to increasing recreation opportunities. 

Impacts from these uses could pose a risk to 

resources on which they depend.

Water Resources

Comment. Protecting the quality of groundwater, 

which supplies the drinking water for the town of 

Jackson, needs to be addressed. In particular, 

how will the groundwater quality be protected 

from practices such as irrigation and potential 

use of fertilizers, pesticides, and or herbicides? 

Has a buffer zone been established around each 

well to protect the well head? Water quality monitoring by the town of Jackson should be discussed 

and data provided. What will be done if the water 

quality begins to show increasing trends in contaminant for pathogen concentrations from 

NEW irrigation and elk management practices?

Response. Your concerns are noted. Current sprinkler irrigation practices apply less water to the 

surface above the aquifer than was applied using 

the old flood irrigation system. No fertilizers are 

used on the refuge. Herbicides are used in compliance with labels in a manner to protect groundwater and surface water resources. The Town of 

Jackson tests drinking water supplies to ensure 

their safety.

Comment. The seasonal diversion of Gros Ventre 

water into Flat Creek creates an unnatural water 

flow regime and puts at risk any attempt to bring 

Flat Creek water flows back to natural patterns. 

Similarly, the off-take of water from Flat Creek 

for refuge irrigation adds to the improbability of 

ever mimicking the natural flow systems in Flat 

Creek (p. 59 and 67). The negative impact to Flat 

Creek’s water quality and subsequent impact to 

native fisheries from the Gros Ventre–Flat Creek 

irrigation diversion ditch needs to be addressed. 

A plan to re-route the section of the ditch responsible for the sediment loading should be completed. This can be done by either encasing the 

flow in a pipe or routing it over a water-proof 

ditch/structure. Until this is fixed, sediment will 

continue to be deposited in Flat Creek, a situation whose impact currently extends through the 

Town of Jackson.

Response. Comment noted.

Comment. Quality Water Resources (p. 23). Note that 

the first sentence of the second paragraph is contradicted later in the same paragraph.

Response. Thank you for your comment. The text 

will be edited to eliminate the contradiction in the 

final CCP.

Comment. Water quality, particularly on Flat Creek 

is likely influenced by run-off of fecal materials 

brought about by the large concentrations of elk 
148 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

mule deer, wolves, coyotes, and bears—frequently 

cross this border, it is only logical that the two 

agencies’ policies align.

The precedent to require hunters to carry bear 

spray is there. The NER worries about alienating 

hunters as a result of the increased burden associated with such requirements. What about the 

non-consumptive user? Wouldn’t wildlife photographers be alienated by the self-defense shooting 

of a grizzly bear because a hunter didn’t have 

bears spray on him/her? Fear of alienating a 

minority user-group by asking them to take on a 

small inconvenience for the sake of wildlife is not 

an acceptable reason to forego doing the right 

thing. If wildlife is truly of the utmost importance 

to the NER and USFWS, the preferred alternative must require hunters to carry bear spray.

Response. Please see the response to comment 1-8.

Non-lead Ammunition

Comment. Support for requiring the use of lead-free 

ammunition for all hunting and fishing activities 

on the refuge. Both grizzly bears and wolves are 

protected by the Endangered Species Act and 

both occur on the NER and both are known to 

consume hunter-created gut piles. In so doing, 

they are put at risk of suffering from lead poisoning. In addition, large numbers of bald eagle, 

golden eagles, coyotes, ravens and crows also 

utilize hunter-created gut piles and are also 

potential victims of lead poisoning.

The current system of encouraging hunters to use 

lead-free ammunition is inadequate, as more 

than 60% of hunters use lead ammunition (p. 76). 

Neighboring Grand Teton National Park has 

already banned lead ammunition. Given that the 

two protected areas share a border, and that 

many species—including elk, bison, pronghorn, 

mule deer, wolves, coyotes, and bears—frequently 

cross this border, it is only logical that the two 

agencies’ policies align. The precedent to require 

hunters to use lead-free ammunition and carry 

bear spray is there. The NER worries about 

alienating hunters as a result of the increased 

burden associated with such requirements. What 

about the non-consumptive user? Would the sight 

of lead-poisoned ravens or eagles not alienate 

birdwatchers? Fear of alienating a minority 

user-group by asking them to take on a small 

inconvenience for the sake of wildlife is not an 

acceptable reason to forego doing the right thing. 

If wildlife is truly of the utmost importance to the 

NER and USFWS, the preferred alternative must 

require hunters to use non-lead ammunition. 

Response. Comment noted.

Comment. Please honor Bert Rayne’s’ legacy such as 

the boardwalk by at least spelling his name 

correctly.

Response. Thank you for pointing out this error. We 

have corrected the spelling in the final CCP.

Hunting

Comment. Concern regarding hunting of species 

other than elk and bison to address management 

concerns. Hunting of predators runs counter to 

the goals outlined in the Refuge’s Bison and Elk 

Management Plan. Predators play a key role in 

maintaining balance in an ecosystem, by selecting old, physically impaired, and diseased animals. Additionally, they may reduce 

transmission and prevalence of diseases such as 

chronic wasting disease, as well as brucellosis, 

and assist the Service in meeting herd objectives 

for elk. Wolves and grizzly bears are protected 

while in Grand Teton National Park. It is known 

that there is reciprocal movement of these magnificent animals between GRTE and the NER. 

They are drawn to the food sources that the NER 

provides. There are serious ethical considerations about whether animals that are attracted 

to the NER by gut piles or a manmade concentration of prey should be hunted for doing so.

Response. We agree that predators provide benefits 

that support the mission of the refuge, and a hunting season specifically for predators is not envisioned. All references to the hunting of predators 

have been removed from the final CCP.

Mandatory Carry of Bear Spray

Comment. The NER grizzly bear management and 

protection plan must make it mandatory for all 

hunters to carry current bear spray and have it 

readily available for use. A growing body of scientific literature shows that bear-caused human 

injuries are significantly lessened when bear 

spray is deployed during a hunter/grizzly interaction. This will result in lower incidences of 

human injury and much lower chance of a 

hunter shooting a bear in self-defense.

Neighboring Grand Teton National Park already 

requires hunters to carry bear spray. Given that 

the two protected areas share a border, and that 

many species—including elk, bison, pronghorn, 
Appendix C—Public Involvement 149 

successful or if a refuge regulation requiring the 

use of non-lead ammunition is needed. Currently, 

there is no National Wildlife Refuge System policy requiring the use of non-lead ammunition 

while hunting big game on national wildlife 

refuges.

Comment. Trophy hunting (for bull elk and bison) is 

controversial and unpalatable, especially in such 

a visible area; and it contradicts your claims that 

hunting on the NER is primarily to meet ‘herd 

objectives’. Herd reduction is best accomplished 

through cow hunting; there is no biological reason to hunt bull elk. The bison hunt is already 

practically a trophy hunt, with low bull bison 

ratios and a high percent of bull killed each year 

(see Jackson Hole News & Guide Sept. 10, 2014, 

Bull bison count falls, p. 34A). Killing bulls does 

not make sense in terms of the objective to reduce 

the number of bison. Large bison herd reductions 

such as occurred in 2013 must have impacts on 

behavior, calf survival, and other aspects of the 

lives and well-being of these social mammals. 

Please evaluate.

Response. Comment noted. Hunting is a legislatively 

mandated priority public use on national wildlife 

refuges. We agree that over time the harvest of 

females has a greater effect on population reduction than harvest of males; however, harvest of 

males does in fact reduce the number of animals 

wintering on the refuge, which is consistent with 

our management objectives to reduce reliance on 

supplemental feeding.

Comment. Migrating waterfowl use the NER as both 

a year round inhabitation and a stopover for 

yearly migration. Because waterfowl generate 

such interest the NER, it is realistic that the 

inhabitation generates an economic income for 

management agencies. The NER should adopt a 

policy of adaptive management concerning 

waterfowl on the NER which would include hunting seasons for both ducks and geese.

Response. The CCP suggests that waterfowl hunting 

could be allowed on the refuge in the future if it is 

consistent with other management objectives.

Comment. I question promoting the NER for young 

hunters, which may increase the risk to non-target wildlife and have other consequences (e.g., 

young people contacting wildlife disease).

Response. Youth hunts require participants to be 

accompanied by an experienced non-hunting 

adult. This ensures mentoring is provided during 

the youth hunt. Youth hunters, like all other hunters on the refuge, must abide by all State and 

refuge regulations.

Nothing short of 100% compliance will protect the 

raptors, scavengers and carnivores of both GRTE 

and the NER from the avoidable risks of lead 

poisoning from ammunition.

Response. The refuge is concerned about the impacts 

of spent lead ammunition on scavengers, especially bald eagles and ravens. When this issue was 

brought to our attention through the research by 

Craighead Beringia South in 2008, we immediately began work to mitigate these impacts and 

organized a multiagency partnership program to 

promote the voluntary use of non-lead ammunition. This effort to engage the hunting community 

included Craighead Beringia South as a key partner and was implemented in 2009. At its inception, 

it was emphasized to the hunting community that 

this was a voluntary program.

Since that time, the voluntary use of non-lead 

ammunition has steadily increased to approximately 60 percent of successful elk hunters in 

2014. This was accomplished through the emphasis of educational materials promoting the use of 

non-lead ammunition and initially by distributing 

free non-lead ammunition to refuge hunters. The 

steady decline in cost and increase in availability 

of non-lead ammunition, combined with continued 

educational materials and emphasis by the refuge, 

is anticipated to continue to increase the voluntary participation in the use of non-lead 

ammunition.

We also believe the voluntary and educational 

approach provides an additional benefit over mandating the use of non-lead ammunition. Hunters 

who are informed and convinced of the benefits of 

non-lead ammunition through education, and who 

make the decision to voluntarily use non-lead 

ammunition, are more likely to voluntarily use 

that ammunition when they hunt off the refuge 

where there are no restrictions on ammunition 

type. There are hundreds of thousands of acres of 

public and private lands that surround the refuge 

and are open to hunting. The voluntary use of nonlead ammunition in these areas provides extended 

benefits to scavenging birds that may use the refuge and the surrounding lands.

Although the voluntary participation in this program has been very positive, we believe its effectiveness needs to be monitored and evaluated. We 

will continue to promote the voluntary use of nonlead ammunition while monitoring participation 

and collect data concerning impacts on refuge 

wildlife populations. Within 5 years, the refuge 

will determine if the voluntary approach to mitigating the impacts of lead ammunition has been 
150 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Comment. Based on my limited observations, the 

sleigh ride concession represents the greatest 

single source of disturbance to grazing animals, 

and resulted in periods of extensive agitation, 

and movement of the herd distances of upwards 

of 1⁄2 mile or more.

Response. The three surveys were all listed in the 

report as being conducted during the same week 

in April 2012. During that same year, supplemental feeding ended during the week of March 26. 

This indicates that green-up of spring growth 

may have started, and elk near the sleigh area 

may have been less settled than during much of 

the winter season. If the sleigh contractor had 

switched to using wagons rather than sleighs 

because of the spring-like conditions, the additional noise from the alternative vehicles could 

have been a factor. There may have also been elk 

in the sleigh area that had not been there during 

the early part of the season and thus were not 

acclimated to the sleigh operation. This is often 

the case if supplemental feeding has stopped earlier in other areas off the refuge.

The sleigh ride contractor is committed to minimizing disturbances to the elk herd. During the 

eight seasons the same company has held the contract, the refuge staff has not observed repeated, 

regular disturbances from the sleighs. Decades of 

observation have shown elk have exhibited a tolerance of sleighs and other refuge vehicles as long 

as an individual human form is not identifiable. 

Conversely, animals have routinely demonstrated 

an intolerance of the presence of humans on foot. 

Pedestrians illegally using the pathway and 

approaching the fence have caused noticeable and 

repeated disturbance to nearby elk, often causing 

the herd to bolt from the area and not return for 

up to 24 hours. This was repeatedly the case 

throughout much of December 2013 and December 2014, observed by the sleigh ride contractor 

and a number of refuge employees. Because no 

human violators of the pathway seasonal closure 

were observed during the three surveys done by 

Biota, no comparison could be made to the types 

of reaction each of the disturbances caused.

The refuge is not only concerned about stress to 

wintering and migrating animals but also the 

decrease in the amount of refuge areas used by 

elk, thereby further increasing density.

Highway 89 Pathway

Comment. Encourage additional data collection and 

adaptive management of the Highway 89 pathFishing

Comment. Concern for the future of the Snake River 

Fine-spotted cutthroat trout population in Flat 

Creek, and support for efforts to reduce competition from non-native species. Allowing the 

removal of trophy-size fish does not help the refuge meet its management goal of having trophysize trout alive in the population. When one 

considers how low population numbers are and 

the intense competition that exists from nonnative fish, allowing harvest does not seem justified. Given the wildlife first mission of the 

USFWS, a discussion with WGFD to reassess the 

scientific and social rationale for allowing harvest of trophy-sized cutthroat, as well as the 

potential need for mandatory catch-and-release 

regulations should occur. The Draft CCP notes 

that the vast majority of anglers on Flat Creek 

have “a catch-and-release conservation ethic.” 

The risk of alienating a small minority of 

anglers should not take on greater importance 

that the protection of a critical native fish population. Consider implementing catch-and-release 

regulations for Snake River Fine-spotted cutthroat trout in Flat Creek.

Response. We follow the state regulations when it 

comes to fishing bag limits. Most people fishing 

Flat Creek on the refuge are practicing catch and 

release.

Comment. Cutthroat trout have become idealized in 

the eyes of many recreationalists similar to the 

trophy of big game. Limited quota licenses should 

be considered for fishing privileges on the Flat 

Creek portion of the NER. General fishing 

licenses do not suffice for management of a fishery on the level of the NER.

Response. We follow the state regulations when it 

comes to fishing bag limits. Most people fishing 

Flat Creek on the refuge are practicing catch and 

release.

Wildlife Observation and Interpretation

Comment. Consider doing tours of Miller Butte.

Response. The refuge participated in archeological 

tours of Miller Butte in the past, in cooperation 

with the Jackson Hole Historical Society and 

Museum. The tours were specifically related to 

sensitive archeological sites located on the butte. 

Refuge staff would consider occasional guided 

tours that have a specific purpose again in the 

future. However, regular tours into closed areas 

for general interpretive programming would need 

to be assessed for compatibility.
Appendix C—Public Involvement 151 

since the emphasis on hunting has reduced the 

availability of non-consumptive opportunities 

due to cost and staffing needs.

Response. Consumptive uses will be adjusted as 

management goals are met. However, they will 

continue to be available as a management tool to 

address natural recruitment and population 

growth. The refuge has not eliminated nonconsumptive use programs as hunting programs have 

expanded.

Administration and Facilities

Comment. It is laudable that the refuge will try to 

reduce the carbon footprint, but it is laughable 

that the quantity of carbon consumed in irrigation and feeding practices is not calculated and 

shown. Efforts to reduce carbon footprints in 

buildings and travel probably pale in comparison 

to the carbon used to irrigate and artificially feed 

elk. This information should be provided.

Response. Irrigation on the refuge is strictly gravityfed; carbon emissions associated with irrigation 

have been substantially reduced because we no 

longer pump water using electricity. We do use 

utility task vehicles to haul irrigation lines; however, there is no other way to move lines in an 

efficient, cost-effective way with minimal impact. 

Comment. The need for employee housing is a challenge for every business in Teton County. New 

housing should be provided only at existing 

developed sites and where adequate infrastructure already exists. The prime location for more 

housing is within the NER headquarters campus. Second would be in the maintenance area 

north of Miller House. A third location is the 

National Fish Hatchery site, an already disturbed area and one that appears to be able to 

accommodate more housing.

Response. We agree employee housing should be provided at existing developed sites where infrastructure already exists. The draft CCP proposes 

additional employee housing at the headquarters 

campus, and we will consider and evaluate the 

suggested locations of the maintenance area north 

of Miller House and the National Fish Hatchery 

site.

Elk Refuge Road

Comment. Support additional pullouts along the Elk 

Refuge road. All turnouts should be gravel surway to minimize disturbance to wildlife and 

maximize seasonal use of pathway for public. 

Support opening the Highway 89 pathway earlier 

or closing it later in years when seasonal weather 

alters the timing of elk migration and bike activity on the pathway would not interfere with elk 

migration. Simultaneous bike and mule deer use 

within the pathway corridor can create a dangerous situation for highway users. In making a 

decision to open the pathway early, managers 

must take into account deer use in the highway 

corridor as well as elk activity on the refuge.

Response. A seasonal closure was clearly outlined as 

a critical condition prior to construction of the 

pathway. The season has already been expanded 

by 20 percent and as much as 31 percent in years 

when the refuge agrees to open the pathway as 

early as April 15 due to an early migration. Our 

data show the current pathway season is approximately 2 weeks of when regular migration occurs 

to and from the refuge. It would be difficult for 

the refuge or Jackson Hole Community Pathways 

to open and close the pathway every time there is, 

or is not, a potential conflict with elk, nor could an 

unplanned closure be implemented quickly to alleviate a problem. The pathway, open from May 1 

through October 31, is open during most of the 

traditional cycling season.

We will continue to monitor pathway use and collect data to evaluate disturbance to wildlife. We 

will adaptively manage the pathway to maximize 

seasonal use of pathway for public in a manner 

that does not interfere with elk migration or other 

wildlife needs.

We have edited chapter 4 the final CCP to reflect 

the pathway will be adaptively managed to minimize disturbance to wildlife and maximize seasonal use for the public based on the results of 

monitoring and data collection.

Comment. Agree the bicycle pathway should continue to be restricted during the winter months.

Response. Comment noted.

Nonconsumptive Uses

Comment. The needs of non-consumptive users must 

be balanced with the overarching commitment of 

the NER to satisfy consumptive demands. The 

NER is dedicated to wildlife first and consumptive use is regarded as a management tool. When 

the management goals are reached, what will 

happen to the consumptive opportunities? The 

CCP needs to address this question, especially 
152 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

to refuge resources and trails could be open only 

for the hunting season.

1. Miller barn parking NE along Elk Refuge road 

to north edge of section 26. Trail head due east 

along north edge of section to national forest 

boundary. Large existing parking at Miller 

barn.

2. Flat Creek parking lot northeast along Flat 

Creek road to southeast corner of section 33.

3. Nowlin parking lot from NE corner of section 

24. Walk due south along eastern edge of section 24.

Response. The CCP leaves the idea of new access 

open for future consideration. Additional access 

would have to be weighed against the Service’s 

mandate to put wildlife first. Any new access 

would be subject to a compatibility determination, 

which would address how new access would relate 

to our mission and purposes.

Partnerships

Comment. Work with Town of Jackson to request the 

street lights be dimmed at night (i.e., North Cache 

Street) for the wildlife sake.

Response. Comment noted.

NEPA Compliance and Planning 

Process

Comment. The initial comment period of 30 days for 

the review of the detailed 600 page document was 

unrealistic. The public information meeting on 

September 29th was the first time that the public 

was introduced to the plan. Why was the meeting 

not held shortly after the Plan was released for 

comment? I do not feel that the time allotted for 

public comment was sufficient, even with the 

week extension for so complicated an EA.

Response. A notice of availability was published in 

the Federal Register September 9, 2014, announcing that the draft CCP was available for public 

review and comment. At the request of several 

organizations and individuals, the comment period 

was extended to October 24, allowing 45 days 

total for reviewing and commenting on the draft 

CCP and EA. The public meeting was scheduled 

September 25, 2014, to provide time for the public 

to review the draft CCP prior to attending the 

face and delineated with large boulders and/or 

logs to discourage off-site parking.

Response. Thank you for your comment. The proposed action in the draft CCP includes additional 

pullouts along the Elk Refuge Road.

Comment. Reduce speed limits along the Elk Refuge 

Road and add speed bumps—encourage visitors 

to slow down and enjoy wildlife. Consider including a few places where people who walk the road 

can sit down and observe wildlife. The aging 

population in the community is precluded from 

enjoying access to the refuge on foot because there 

is nowhere to sit down. The Senior Center is 

facilitating a conversation throughout the community about this issue. I hope the NER will 

consider being a part of that conversation.

Response. We will discuss seating options as Elk 

Refuge Road improvements and additional pullouts are added. Seating options would have to be 

compatible with winter plowing operations.

Comment. Consider allowing Nordic skiing along 

the refuge road.

Response. Elk Refuge Road winter regulations do 

not restrict any type of nonmotorized pedestrian 

use. However, the Elk Refuge Road would not be 

specifically groomed or plowed in such a manner 

to accommodate Nordic skiing.

Access to National Forest

Comment. Strongly concur with the recommendation 

to prohibit overnight parking and camping associated with the antler collection April 30-May 1.

Response. Comment noted.

Comment. I understand that the road from the Town 

of Jackson through the Elk Refuge poses a problem for those wanting to access the forest lands 

but also keeping in mind that we are talking 

about two government agencies working out the 

sharing of the road for access. The building of a 

separate road for Forest Service access would be 

prohibitive in cost and would be extremely difficult to go around private land. The shared road 

is an extremely valuable asset to the community 

for winter wildlife viewing and should be continued with restrictions on how the road is accessed.

Response. Comment noted.

Comment. Propose three new national forest access 

trails be included in the Plan at the following 

locations. This proposal would not require new 

parking lots as existing refuge hunting parking 

lots can be used. There would be minimal impact 
Appendix C—Public Involvement 153 

ing to habitat conservation and restoration for 

‘other wildlife’ and with regards to the ecological 

concerns stemming from management decisions. 

The CCP needs to clearly formulate its relationship to other decisions and commitments. Where 

the CCP overrides, contradicts, or improves previous plans or mitigation measures, this needs to 

be clearly disclosed, and not in a piece-meal 

fashion.

Response. The CCP is written to complement other 

refuge NEPA documents and does not override or 

supersede the other completed plans that remain 

in effect. The planning team worked diligently to 

ensure contradictions between existing NEPA 

documents (that is, the Bison and Elk Management Plan and Irrigation Expansion EA) and the 

CCP do not occur. We have provided additional 

text in the final CCP to clarify the relationship of 

the CCP to other planning documents for the 

refuge.

Comment. Prefer alternative C to the others. The refuge is for wildlife. It should be much more than a 

feedlot for the game we like to hunt. Very little 

land remains that is protected in such a way and 

it would be lovely for tourism and personal gratification to see the management focus on improving the wilderness component of the refuge. I 

especially support the idea of beaver dams and 

overpasses for migrating ungulates.

Response. Comment noted.

Comment. All of the Alternatives increase elk reduction programs and hunt areas and leave less refuge, free of human disturbance, with no study of 

impact on the elk, the populations are on the 

decline throughout the GYE, and your provide no 

study of the impact on other species, including 

the food needs for reproduction, the distribution 

and the mortality/human caused of the threatened Grizzly Bear. Or the environmental impact 

on the visitors, business owners and residents in 

the town of Jackson and Teton County from the 

killing of elk adjacent to the road, alternatives, B, 

C, & D, promote additional hunts from the west 

end and Fish Hatchery at Highway 89 as well the 

Southern end of the Refuge, outside of the Hospital, not a conducive visual for health and rehabilitation. Highway 89 is the gateway into the 

town of Jackson. Shooting elk as folks enter town 

requires an EIS pursuant to National Environmental Policy Act, NEPA, 42 U.S.C. sec 4321. The 

impact on human life and the qualities pertaining to the refuge as a tourist icon for the valley 

shall be jeopardized and dramatically impacted. 

Alternatives B, C & D also call for expanding the 

public meeting. We believe the 45-day review 

period provided adequate time to review the document and provide meaningful comments. The 

review period was conducted in accordance with 

NEPA guidelines, and similar review periods 

have been provided for the majority of CCPs in 

the Mountain-Prairie Region.

Comment. The CCP alleges that a biological evaluation of the actions pursuant to section 7 of the 

Endangered Species Act has been completed. 

None is published for review in the Draft CCP.

Response. An Intra-Service Section 7 Biological 

Evaluation has been prepared for the preferred 

alternative and included as an appendix in the 

final CCP.

Comment. An Environmental Impact Statement is 

needed under NEPA. Management of the NER 

has significant potential environmental impacts 

and a comprehensive look at how to mitigate 

these issues over the next 15 years is needed. EAs 

are intended to be a concise document, which this 

clearly is not due to the complexity of the issues. 

Response. The preferred alternative (CCP) was not a 

major Federal action that would significantly 

affect the quality of the human environment 

within the meaning of Section 102(2)C of the 

National Environmental Policy Act of 1969. 

Accordingly, the preparation of an EIS was not 

required.

Comment. A true comprehensive conservation plan 

to address management of the refuge that 

includes elk and bison management, irrigation 

practices, and elements included in this plan. 

Elk and bison management should not be an 

issue outside the scope of the CCP as it is an integral and critical component. The EIS should 

include a detailed analysis of the effect of supplemental feeding and the resulting concentration of 

a large ungulate population on an already 

severely degraded habitat.

Response. The management of bison and elk is 

addressed in the Bison and Elk Management Plan 

that was completed in 2007 and remains in effect 

until 2022 (FWS and NPS 2007a). The effects of 

supplemental feeding were addressed in the EIS 

that was completed as part of the NEPA process 

for the Bison and Elk Management Plan.

Comment. There has been a plethora of NER NEPA 

documents over the past decade, leading to confusion about what the NER is doing, will do and 

when. The BEMP, Irrigation Expansion Project 

Environmental Assessment 2009, and Pathway89 EA contained mitigation measures relat-
154 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

promised comprehensive public review process 

before any further reduction of the Jackson herd. 

No CCP alternative can contradict BEMP in 

terms of the population objective of 11,000 elk in 

the Jackson Herd.

Response. Comment noted. The management direction in the final CCP does not conflict with management approved in the Bison and Elk 

Management Plan (FWS and NPS 2007a).

Comment. I am really concerned about our overall 

elk population that the goal of 5000 elk on the refuge will reduce the overall herd size by around 

2000 head. I would like to suggest that the idea of 

removing young elk from the refuge and placing 

them on other feed grounds in the heart of the 

winter so they would then follow the resident 

herds to their summer grounds. This would supplement these herds that are low in herd count. I 

am also concerned about the rising number of 

Buffalo on the refuge and what it will do to the 

overall management of our elk herd. In the past 

hunting just don’t seem to produce the herd 

reduction that is necessary to reduce the impact 

they have on the refuge. This would also bring to 

discussion of removing some of the healthy animals to other areas that are trying to increase 

their herds.

Response. Elk herd size and supplemental feeding of 

elk is addressed in the Bison and Elk Management Plan (FWS and NPS 2007a). The Bison and 

Elk Stepdown Management Plan is being developed as a stepdown plan to the Bison and Elk 

Management Plan. We are working with WGFD 

to prepare the adaptive management plan, and we 

will consider this suggestion during our planning 

discussions with WGFD.

Comment. I learned on October 15, 2014, of a 2013 

FWS Biological Opinion Addendum, or reassessment of the original Biological Opinion 

with the Bison and Elk Management Plan of 

2007, pursuant to the Endangered Species Act. 

This re-assessment is not attached.

Response. The biological opinion and subsequent 

addendum concerns the Grand Teton National 

Park’s Elk Reduction Program within the Grand 

Teton National Park. Management of the Jackson 

elk herd by the Service and NPS is addressed in 

the Bison and Elk Management Plan (FWS and 

NPS 2007a) that was completed in 2007. Because 

the management of bison and elk is outside the 

scope of the CCP and EA, the biological opinion 

and subsequent addendum are not included in the 

CCP.

Bison Hunt by directing hunters onto the Northern Portion of the Refuge through the town of 

Kelly and the Teton Highlands subdivision. This 

significant impact on the quality of human life in 

these neighborhoods requires a DEIS with scoping and public comment pursuant to the NEPA 

requirements.

Response. Based on the purposes of the refuge, the 

requirements of the Improvement Act, and other 

applicable laws, regulations, and policies, a full 

range of reasonable alternatives was considered. 

The planning team conducted several workshops 

involving staff and other professionals, mailed 

planning updates, posted information on our Web 

site, held a public meeting, listened to public comments, and analyzed the biological, visitor use, 

and socioeconomic data before determining the 

options for future management.

Comment. I have concerns with the following comment on page 8 of the Draft CCP: “...in general, 

the plan moves elk and bison management 

toward reduces reliance on supplemental feeding, 

and, at some future time, total reliance on natural forage.” I have grave concerns that this openended comment does not reflect the intention of 

the 2007 Bison and Elk plan to end supplemental 

feeding in a timely manner—as opposed to at 

“some future time.” It doesn’t appear much progress has been made over the last 7 years on this 

and in fact, the elk numbers are increasing. Is 

there a timeline for “some future time”?

Response. A stepdown management plan is currently 

being developed to address supplemental 

feeding.

Comments Outside the Scope of 

The CCP

Bison and Elk Management

Comment. The NER cannot increase elk reduction to 

only 5,000 wintering on the refuge if this number 

reduces the Jackson herd below 11,000. The 

BEMP is implemented collaboratively to maintain herd objectives while diminishing the use of 

supplemental feed as conditions allow, while still 

maintaining the herd population objective. I 

demand compliance with the population requirements of the 2007 Bison and Elk Management 

Plan and all Executive Orders that pertain to 

land management and wildlife. Specifically, the 
Appendix C—Public Involvement 155 

9. The Humane Society of the United States, 

Western Region, Arlington, Washington

10. Jackson Hole Conservation Alliance, Jackson, Wyoming

11. Safari Club International, Washington, DC

12. Sierra Club, Wyoming Chapter, Laramie, 

Wyoming

13. Western Watersheds Project, Wyoming 

office, Pinedale, Wyoming

14. The Wildlife Society, Wyoming Chapter, 

Laramie, Wyoming

15. Wyoming Pathways, Wilson, Wyoming

16. Wyoming Wildlife Advocates, Wilson, 

Wyoming

Letters 1–16 from agencies and organizations follow after this page. 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 appendix.

C.3 Comments from Agencies 

and Organizations

The Service received formal comments from the 

following Federal, State, and local government 

agencies.

1. National Park Service, Grand Teton 

National Park, Moose, Wyoming

2. Office of the Governor, State of Wyoming, 

Cheyenne, Wyoming

3. Wyoming Game and Fish Department, 

Cheyenne, Wyoming

4. Teton County Board of Commissioners, 

Jackson, Wyoming

5. Teton County Sheriff, Jackson, Wyoming

Formal comments were also received from the following organizations.

6. The Cougar Fund, Jackson, Wyoming

7. Friends of Animals, Centennial, Colorado

8. Greater Yellowstone Coalition, Bozeman, 

Montana
156 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 1-1. Thank you for your suggestion. We have added the text below to help clarify the relationships between the Bison and Elk Management Plan, the Bison and Elk Stepdown Management Plan, and CCP. Reference to specific information within the Bison and Elk Man- agement Plan is outside the scope of the CCP. “The Bison and Elk Management Plan was finalized in April 2007 after a 9-year public process. This compre- hensive conservation plan will complement, not replace, the Bison and Elk Management Plan. A step- down management plan is currently being drafted for the Bison and Elk Management Plan. This plan will outline, consistent with the Bison and Elk Manage- ment Plan, guidance to adaptively manage bison and elk herds to meet the goals and objectives outlined in the Bison and Elk Management Plan. Public comments will be solicited before the stepdown management plan is finalized.”

1-2. This is outside the scope of the CCP.1-3. This is outside the scope of the CCP.1-4. Thank you for your comment.1-5. Thank you for calling this to our attention. However, please note that the text appearing in chapter 3 

of the draft CCP and EA is not included in the final CCP; accordingly, this change cannot be made in the final CCP.

1-6. Predators provide benefits that support the mission of the National Elk Refuge, and a hunting season 

specifically for predators is not envisioned. All references to the hunting of predators have been removed from the final CCP. 

1-11-21-31-41-51-6

RESPONSE Comment number LETTER #1—National Park Service, page 1 of 4
Appendix C—Public Involvement 157 

However, additional hunting seasons could be considered in the future under the CCP. This would require the modification of the refuge’s hunting plan and an opportunity for public comment.1-7. We agree that coordinating with land management 

agencies is necessary before developing a framework for new hunting opportunities. This process will occur before the Refuge Hunting Plan is updated. We have also removed all references to “trophy bull hunt” and instead used “bull hunt.”

1-8. Thank you for your support for developing regulations to properly store bear attractants.

Grizzly bears (bears) were detected on the refuge during the 2013 hunting season for the first time since 1994. The refuge immediately took the following actions to reduce the potential for conflict between bears and hunters. 

■ Bear sighting signs were posted at all refuge 

parking lots to notify hunters of recent bear activity. All hunters are required to start their hunt at a designated refuge parking lot.

■ Bear sighting news releases were sent to local 

and regional media.

■ “Bear Aware” information to help hunters 

avoid bear encounters was provided during programs at the Jackson and Greater Yellowstone Visitor Center, presented verbally to hunters, and posted on the refuge’s Web site.

■ A recommendation for refuge hunters to carry 

bear spray was included in the refuge hunting brochure and posted on the refuge’s Web site and on WGFD’s Web site, where all hunters must visit to obtain a refuge hunting permit. 

1-71-81-91-10

RESPONSE Comment number LETTER #1—National Park Service, page 2 of 4
158 Comprehensive Conservation Plan—National Elk Refuge, Wyoming The refuge also partnered with a nonprofit conserva- tion organization to provide bear spray—free-of- charge—to all hunters who requested it. Hunters could also obtain free bear spray through a similar program with WGFD. All bear awareness programs from 2013 were contin- ued in 2014 despite no evidence of bear use on the ref- uge. Bear awareness programs will continue in the future. The presence of bears on the refuge in 2013 is considered a significant development, and bear use of the refuge is anticipated in the future. Many close encounters between bears and people do not occur in open areas, but rather in dense brush or forests (Smith et al. 2008). The conventional advice of avoiding bear encounters by avoiding areas of poor visibility was affirmed by Smith et al. 2012.

The refuge’s open hunt area has primarily open and gently rolling topography. Approximately 97 percent of the hunt area habitat is open and affords good visibility, with less than 3 percent dense habitat with limited visibility. Because of the refuge’s open terrain, the potential for a surprise encounter between grizzly bears and hunters is low.We are unaware of evidence that indicates that requiring hunters to “carry” bear spray increases the “use” of bear spray during bear encounters. There is clearly a difference between a hunter “carrying” bear spray and “using” bear spray during an encounter with an aggressive bear. A regulation requiring hunters to “carry” bear spray does not and cannot require that hunters “use” bear spray. Only information about the effectiveness of bear spray as a deterrent can convince 

RESPONSE Comment number LETTER #1—National Park Service, page 3 of 4
Appendix C—Public Involvement 159 

a person to “use” bear spray during an aggressive bear encounter. The refuge currently recommends that hunters “carry” bear spray and informs them of its history of effectiveness through informational materials and by providing free bear spray to hunters through a partnership with a nonprofit conservation organization. Requiring the carry of bear spray is not warranted at this time. The refuge will continue to monitor changes in bear use of the refuge and review new research concerning the use of bear spray by hunters and others. It will also attempt to gather information concerning hunter bear spray carry rates and attitudes concerning the use of bear spray. The refuge bear spray policy will be reviewed in 5 years instead of at the expiration of the CCP. If the potential for aggressive bear encounters with hunters increases and evidence of increased use of bear spray by hunters will result from a bear spray carry requirement, the refuge bear spray policy can be modified.1-9. Thank you for your support.1-10. Thank you for your support and insightful comments. We look forward to a continuation of our close 

relationship and coordination with the Grand Teton National Park.

RESPONSE Comment number LETTER #1—National Park Service, page 4 of 4
160 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 2-1. In order for compatible activities like wildlife viewing, wildlife photography, interpretation, and education to occur on the pathway, they cannot cause repeated disturbances to wildlife. The pathway sea- son opening on May 1 (or as early as April 15) and closure on November 1 are both within approxi- mately 2 weeks of typical migration and use of the area by elk and other species. The proposal does call for continued adaptive management by allowing for an adjusted season when spring green up and migra- tion occurs earlier than average. Winter use of the pathway is not being considered because pedestrians illegally using the pathway and approaching the fence have caused noticeable and repeated disturbance to nearby elk, often causing the herd to bolt from the area and not return for up to 24 hours. Not only does this stress the wintering animals, but it decreases the amount of refuge areas 

available for use by elk. Were this to occur regularly during the winter months, the negative effects would be significant.In 2013, the seasonal dates were modified, expanding use by the public for an additional 31 days. The adjustment was based on extensive monitoring done in collaboration with Jackson Hole Community Pathways and Teton County. 

We have added as a strategy 

in CCP chapter 4 that seasonal dates may be adjusted prior to the 15-year expiration of the CCP if there are notable, significant effects in the area due to climate change or other factors over an extended number of years. The Service has used GPS collar data to assess when use and movement to and from the refuge occurs rather than relying solely on observations. Thank you for your comments.

2-1

RESPONSE Comment number LETTER #2—Office of the Governor, page 1 of 1
Appendix C—Public Involvement 161 

3-1 3-1. Thank you for your comments. We have reproduced 

your comment form below and provided responses as appropriate. The planning team also read and considered the supplemental information you provided on the 

Jackson Lake Dam Mitigation Project.

RESPONSE Comment number LETTER #3—Wyoming Game and Fish Department, page 1 of 19
162 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #3—Wyoming Game and Fish Department, page 2 of 19
Appendix C—Public Involvement 163 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-2 xiii Suggested edit:

The last sentence should read “The Jackson core population area for greater sage-grouse as defined by the State of Wyoming Greater Sage-Grouse Core Area Protection Executive Order 2011-5 overlaps the refuge.”Suggested addition:A map or figure within the CCP should depict this overlap so the reader can identify the boundaries. Maps and shapefiles available at http://wgfd.wyo.gov/web2011/wildlife-1000817.aspx.

3-2. We have revised the final CCP 

text as suggested. Regarding the figure, the maps and figures were not available at the URL cited.

3-3 xiii Suggested addition:

Flat Creek on the National Elk Refuge provides a walk in and trophy Snake River Cutthroat trout fishery. No stocking occurs in Flat Creek making natural recruitment the only source of native trout. Suggested edit:“The refuge is the terminus of seasonal migrations for four celebrated large mammal species.”Suggested addition:Part of the Jackson bighorn sheep herd spends the winter on the refuge on Miller Butte and around Curtis Canyon and migrates to summer range in the Gros Ventre Mountains.Suggested edit:“Pronghorn summer on the refuge and winter south of Pinedale, Wyoming (more than 70 miles away), making one of the longest mammal migrations in the Western Hemisphere.” [Several mule deer migrations have recently been discovered in western WY that are longer]

3-3. We have revised the final CCP 

as suggested.

3-4 xiv Suggested addition:

Flat Creek on the National Elk Refuge provides a walk in and trophy Snake River Cutthroat trout fishery. No stocking occurs in Flat Creek making natural recruitment the only source of native trout. Flat and Nowlin creeks and the Gros Ventre River are managed as wild Snake River cutthroat trout fisheries and are important habitat for other native fish species. Flat and Nowlin creeks are important spawning and recruitment streams for native trout.

3-4. We have revised the final CCP 

as suggested, with some small changes.

3-5 xiv After mentioning elk, bison, pronghorn and Snake River cutthroat trout, it seems appropriate to 

add one final sentence: “The Flat Creek wetlands provide habitat for the highest density of nesting Trumpeter Swans in the Greater Yellowstone area.”

3-5. We have revised the final CCP 

as suggested.

3-6 5 Pacific Flyway Management Plan for the Rocky Mountain Population of Trumpeter Swans should 

be listed in this sectionThe NER is an important contributor to conservation efforts of the rocky mountain population of trumpeter swans

3-6. We have revised the final CCP 

as suggested.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 3 of 19 Comment number
164 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-7 7 Suggested edit: Wyoming Greater Sage-Grouse Conservation Plan “The National Elk Refuge lies within the Jackson core population area of the greater sage-grouse as designated by the State of Wyoming Greater Sage-Grouse Core Area Protection Executive Order 2011-5 signed by Governor Matt Mead in June 2011. Executive Order 2011-5 was issued by Governor Mead to update the process and policy embodied in former Governor Dave Freudenthal’s Executive Order 2008-2 and Executive Order 2010-4.” 3-7. We have revised the final CCP as suggested. 3-8 24 Suggested edit: “The refuge is the terminus of seasonal migrations for four celebrated large mammal species.” Suggested addition: Part of the Jackson bighorn sheep herd spends the winter on the refuge on Miller Butte and around Curtis Canyon and migrates to summer range in the Gros Ventre Mountains. Suggested edit: “Pronghorn summer on the refuge and winter south of Pinedale, Wyoming (more than 70 miles away), making one of the longest mammal migrations in the Western Hemisphere.” [Several mule deer migrations have recently been discovered in western WY that are longer] 3-8. We have revised the final CCP as suggested. 3-9 26 Suggested edit: “Threats to wildlife associated with development include loss of habitat, habitat fragmentation, 

vehicle collision mortality, loss of wildlife migration routes, poaching...”

3-9. We have revised the final CCP 

as suggested.

3-10 28 Suggested edit:

Remove sentence, “Although reduced reliance on supplemental feeding is an objective in the 2007 Bison and Elk Management Plan, feeding is often initiated earlier or terminated later than is biologically necessary to prevent the elk and bison from comingling with livestock on adjacent private lands.” [As stated on page 115, the joint decision between the refuge and WGFD to initiate and terminate feeding is based on forage production, elk and bison numbers, timing of migration, winter temperatures, and snow conditions.]Suggested addition:Biologists from the refuge and WGFD evaluate several factors to decide whether feeding is needed, and if so, when it should begin and end. The feeding start date primarily depends on the amount of standing forage that is accessible to elk, which is influenced by (1) forage production the previous growing season, (2) elk and bison numbers, (3) the timing of migration, (4) winter temperatures, and (5) snow conditions. Feeding typically ends within 1 week of the first day that snow has completely melted on the southern end of the refuge.Suggested addition:Suggest noting that brucellosis seroprevalence rates of unfed bison in Yellowstone National Park fluctuate between 40-60% (Cheville 1998). Jackson bison herd seroprevalances is approximately 60%.

3-10. We have revised the final CCP 

as suggested.

RESPONSE Comment number LETTER #3—Wyoming Game and Fish Department, page 4 of 19
Appendix C—Public Involvement 165 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-11 28-29 Suggested addition:

Lists as a concern irrigation system expansion effects on hydrology, ground-nesting birds, and amphibians. Later in the document under native grassland habitat description additional information could be included in the document regarding the number of irrigated acres, and map showing location of irrigated acres. 

3-11. Please see map on page 133 of 

the draft CCP (figure 11).

3-12 29

33

Suggested addition:The WGFD has statutory responsibility for damage caused by game birds and big and trophy game to private lands, and in FY12 paid nearly $750,000 in damage claims statewide. Wildlife damage management is a major component of the Department’s wildlife management program.Paragraph 3 – WGFD is also a partner on the Flat Creek Enhancement Project

3-12. Thank you for your comment.

We have revised the final CCP to include WGFD in this paragraph.

3-13 37-59 Suggested addition (all alternatives):

Streams should be added as a separate habitat type (i.e., water quantity management, channel types, hydrology, etc.) Please clarify in these alternatives whether or not irrigation will be increased/decreased to enhance management or to promote natural process.

3-13. Thank you for your comment. 

Please note that the text appearing in chapter 3 of the draft CCP and EA is not included in the final CCP; accordingly, edits to this text cannot be addressed in the final CCP.

3-14 39 Suggested edit:

Remove cheatgrass from the list of invasive plants that are not noxious weeds. Cheatgrass is now recognized as a noxious weed by Teton County.

3-14. Please see the response to comment 3-13.

3-15 40 Suggested edit:

“The refuge would continue to cooperate with the WGFD to monitor bighorn sheep and facilitate collection of biological samples during disease surveillance monitoring.” Suggested edit:“The refuge would attempt to reduce brucellosis transmission from elk and bison to livestock by concentrating elk and bison...” The refuge would attempt to reduce brucellosis transmission from elk and bison to livestock by working with the WGFD to maintain adequate habitat on federal lands and to attract bison and elk away from conflict situations. The refuge would complete a contingency plan for chronic wasting disease...We suggest the Refuge defer to the Wyoming Game and Fish Department’s CWD plan.

3-15. Regarding your first suggestion, please see the response to comment 3-13. Regarding your 

suggestion concerning the chronic wasting disease contingency plan, please note that all refuges complete a disease contingency plan that includes chronic wasting disease. The Wyoming State plan from 2007 is being updated at this time. We will continue to cooperate with WGFD on disease contingencies.

3-16 41 Suggested edit:

“The refuge provides elk and bison hunting consistent with the Bison and Elk Management Plan, including (1) working with WGFD to adaptively modify elk and bison hunting seasons on the refuge to achieve herd objectives,...”

3-16. Please see the response to comment 3-13. We intend to work with 

WGFD to adaptively manage hunting seasons to achieve herd objectives.

RESPONSE Comment number LETTER #3—Wyoming Game and Fish Department, page 5 of 19
166 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-17 41 Second bullet: change spelling of “Burt” to “Bert” Raynes Boardwalk 3-17. Please see the response to com- ment 3-13. We have verified the spelling elsewhere in the final CCP. 3-18 46 Suggested edit: “The refuge would continue to support and take part in multi-agency wildlife work groups such as the Jackson Cooperative Elk Studies Group, the Upper Snake River Basin Sage Grouse Working Group,...” 3-18. Please see the response to com- ment 3-13. 3-19 47 “...we would consider partnership opportunities to build wildlife crossings for Highway 89 – such as under-road tunnels, overpasses, or fences...” Wildlife crossings would have to be designed to prevent elk and bison from leaving the refuge to private lands during the winter spring and sum- mer. The Department has concerns regarding the potential to funnel animals off public land and onto private where the potential for conflict is higher. Options to facilitate animal movements off the Refuge should be vetted through the Game and Fish Department, the various land manage- ment agencies and private land owners. 3-19. We will collaborate with WGFD on wildlife crossings. 3-20 48 Clarification needed: The proposed comprehensive disease contingency plan would only apply to elk and bison on the ref- uge; the State already has Management Plans for chronic wasting disease and brucellosis. The State would consider input from the Refuge but will likely not follow a federal plan when elk and bison are outside of the refuge or Grand Teton National Park. We are willing to coordinate on this, 

but recommend it be removed from the CCP and defer decisions regarding disease to the WGFD.

3-20. Please refer to Disease Management, chapter 3, page 40, of the 

draft CCP. There is no intention to commit the State to follow the refuge disease contingency plan.

3-21 49 Clarification needed:

“Staff would develop management tools for assessing hunter use – such as hunter checkpoints, hunt success surveys....” Need clarification on whether this would be for bison or elk or both? WGFD already requires that all bison hunters submit a post-hunt survey and the agency conducts a post-hunt survey to estimate elk harvest. If hunter checkpoints are developed and mandatory harvest checks are required, will Refuge staff and the Refuge Office manage the volume of hunter contacts this service would create? We recommend the Refuge defer the hunter contacts and harvest estimates to the WGFD

3-21. The refuge will assume the 

burden of management tools to improve the hunt program.

3-22 50 “require commercial guides to kill non-native trout” – suggest revising to “encourage guides and 

their clients to harvest non-native trout within creel limits and provide educational materials to guides and their clients on threats to native trout.” This would allow increased education on why harvest is being encouraged.

3-22. Please see the response to comment 3-13. Elsewhere in the final CCP we have made it clear that we will encourage, not require, removal of nonnative trout. We do, however, retain the right to require removal if warranted by future conditions.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 6 of 19 Comment number
Appendix C—Public Involvement 167 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-23 50,57 Suggested addition:

With the increased use of drones in Yellowstone and Grand Teton we suggest the refuge address the use of drones for wildlife photography and hunting.

3-23. This issue is being addressed 

at the national level. We currently do not allow the use of drones due to wildlife disturbance issues.

3-24 55 “The refuge would seek to expand the approved acquisition boundary to include the Twin Creek 

and Spring Gulch areas, which would provide another tool to resolve off-refuge land use that conflicts with refuge resource protection.” The Department supports efforts to consolidate management boundaries along the east side of the Refuge. The WGFD is required to prevent comingling between elk, bison, and livestock and has statutory responsibility for damage caused by big game. The Spring Gulch area includes several traditional agricultural operations and if the refuge acquired lands in Spring Gulch as off-refuge wintering areas for elk and/or bison, damage and comingling incidents would likely be exacerbated in this area.

3-24. No easement would be fee title. 

The primary purpose of the easements would be to reduce the likelihood of comingling between 

livestock and wildlife.

3-25 56 An evaluation of the level of fish entrainment in ditches, especially South Park supply, should be 

included. Screening ditches is an expensive project and determining if screening is necessary should be completed prior to any screening.

3-25. Please see the response to comment 3-13. If screening is determined to be beneficial and 

cost-effective, we will work towards installing and use.

3-26 56 Suggested edit:

Remove cheatgrass from the list of invasive plants that are not noxious weeds. 

3-26. Please see the response to comment 3-13.

3-27 56 Suggested addition:

The refuge should develop a Habitat Management Plan that prioritizes areas for treatments with prescribed fire and/or wildland fire. The refuge should consider additional habitat treatment tools, including mechanical.

3-27. We will complete a fire management plan.

3-28 56 Suggested edit:

“Important aspects of wildlife management would be maintaining long-distance ungulate migrations and a full suite of native large carnivores.” [“A full suite” implies that the refuge will manage 

for grizzly bears. There is no other mention in the document of this intent.]

3-28. Management actions may occur 

for any species occurring on the refuge.

3-29 56 An evaluation of the level of fish entrainment in ditches, especially South Park supply, should be 

included. Screening ditches is an expensive project and determining if screening is necessary should be completed prior to any screening.

3-29. Please see the response to comment 3-25.

3-30 57 Majority of this paragraph relates to Aquatic Species Management section – suggest moving. 

Including angler education on threats to native trout and other native fish species, encouraging harvest of non-native trout would be better to include in this section.

3-30. Please see the response to comment 3-13.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 7 of 19 Comment number
168 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-31 59 Native Grasslands and Sagebrush Shrublands: should include how many acres of grasslands will be irrigated under this alternative Riparian Woodlands: refer to the mitigation measures from the Bison/Elk plan for woodland restoration. 3-31. The number of irrigated acres varies annually. The maximum capacity for the system is 4,500 acres at any one time. 3-32 59 Suggested additions: Add following the Bison and Elk Management Plan as an emphasis. Add manage for migratory birds and native aquatic species. Suggested edit: “An adaptive management approach on the Refuge would be used to evaluate hunting seasons on long-distance migratory elk.” 3-32. The CCP does not address the Bison and Elk Management Plan (FWS and NPS 2007a) or the adap- tive management plan process. 3-33 60 An evaluation of the level of fish entrainment in ditches, especially South Park supply, should be included. Screening ditches is an expensive project and determining if screening is necessary should be completed prior to any screening. 3-33. Please see the response to com- ment 3-25. 3-34 60 Migratory Birds: provide more specific details on how monitoring efforts for migratory birds would be increased. Add Heading “Trumpeter Swan and other Waterfowl” which specifies monitoring and manage- ment actions. 3-34. This will be addressed in the inventory and monitoring plan.

3-35 60 Wildlife Observation and Photography: in addition to creating a more accessible route to the Bert 

Raynes wildlife viewing platform and a boardwalk/photographic blind at the Visitor Center, water quality issues need to be addressed including the amount and timing of water flow into the ponds and marsh habitat at the center. Habitat quality has decreased in recent years with terrestrial vegetation becoming established where wetland plants existed.

3-35. Thank you for your comment 

on the Bert Raynes platform. We do not have plans to actively manage these areas and will allow for natural succession, which offers opportunity for environmental education and 

interpretation.

3-36 61 Hunting - Management actions would be the same as Alternative B. – When referring back to 

Alternative B it states at that management actions will be the same as Alternative A. Alternative A states that (3) prohibit the hunting of any other wildlife species other than elk and bison. We support alternative D and the narrative language referred to in Alternative B expanding hunting opportunities for youth hunters and for other species on the Refuge specifically for waterfowl hunting. We do not support a ceremonial bison hunt above 5 bison.

3-36. Thanks for your comment. In 

accordance with the Bison and Elk Management Plan, there is no intention of increasing ceremonial bison harvest to more than five bison.

3-37 65 Suggested edit (Alternative A):

“There would be increased wintering and nesting habitat for greater sage grouse, but a decline in lek sites and brood-rearing habitat.” [What evidence is there that current management will lead to 

loss of leks?]

3-37. Alternative A predicts an 

increase in sagebrush density and cover. Leks typically require some open space.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 8 of 19 Comment number
Appendix C—Public Involvement 169 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-38 70 Alternative A – Also include: Targeting rainbow trout and rainbow-cutthroat trout hybrids for 

removal in Gros Ventre River. Brook trout removal is conducted in Flat and Nowlin creeks.

3-38. Thank you for your comment.

3-39 70 Alternatives C and D – Evaluation of fish entrainment in ditches should be done prior to screening 

to determine if there is a need.

3-39. Please see the response to comment 3-25.

3-40 71 Alternatives C and D – Screening of ditches and increased maintenance costs to WGFD – If 

screening was determined to be necessary, WGFD would be a partner in the process but not sure how that would effect our costs for maintenance.

3-40. Thank you for your comment.

3-41 71 Alternatives C and D – Removal of non-native trout should not noticeably reduce fishing opportunity. Having fewer brook trout present may actually increase numbers of native trout. 3-41. Thank you for your comment.3-42 71 Suggested edit (Alternative A):

“Coordinate with WGFD on bighorn sheep disease surveillance and to detect sick bighorn sheep.”Recommend that references to a disease contingency plan defer to the WGFD disease plans.Suggested edit (Alternative A):“Concentrate elk and bison on the refuge during February and March by providing adequate habitat to prevent comingling and the potential transmission of brucellosis to livestock.”

3-42. The refuge disease plan will be

developed in collaboration with WGFD. 

Please note that the text 

appearing in chapter 3 of the draft CCP and EA is not included in the final CCP; accordingly, this suggestion cannot be addressed in the final CCP.

3-43 72 Last paragraph under Alternative A: “possibly limit management activities in swan and curlew 

habitat”. Recommend this be carried over into preferred alternative also. 

3-43. It is carried over.

3-44 73 Alt C listed species: environmental consequences: it is not clear why Trumpeter Swan productivity 

would be substantially lower than alternative B as management actions listed under Wetlands are the same for Alternative D and B. These include improved water control structures and more ponds.

3-44. Alternative B has more active 

management.

3-45 73 Clarification needed (Alternative A):

Alternative A states that “This alternative would have the greatest potential to support greater sage-grouse.” However, the habitat treatments in alternatives C and D could be equally or more beneficial for sage grouse if they are designed to improve the sagebrush understory for broodrearing habitat and protect mature sagebrush stands. We suggest removing this statement from Alternative A.

3-45. Research suggests that wintering habitat is the limiting factor in 

the population.

3-46 75 Suggested edit:

“Work with WGFD to adaptively revise elk and bison hunting regulations on the refuge to achieve herd size objectives.”We support efforts to allow hunting for other species and think hunting of migratory waterfowl could be addressed in Table 4.

3-46. Alternative B is the same as 

alternative A except we will consider other hunting opportunities.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 9 of 19 Comment number
170 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-47 Clarification needed (Alts. B, C, D): “Conduct hunter check points, surveys, and mandatory reporting of tag use to better manage hunting.” [The WGFD created the Hunter Management program in part to reduce the work load of NER staff and to address the USFWS confidentiality concerns the NER had regarding maintain- ing a file of hunter information. Which agency or agencies would staff hunter checkpoints? WGFD already has mandatory reporting for bison harvest and a post-hunt elk harvest survey.] 3-47. Hunter check points, surveys, and reporting would not commit WGFD to any additional work. We will continue to collaborate as needed to improve the hunting program. 3-48 76 Suggested edit (Alt. A): “There would be insufficient elk harvest on the refuge to meet winter distribution objectives of the Bison and Elk Management Plan.” [Incorrect as written. We have achieved the 11,000 elk post- hunt population objective, but not the goal of 5,000 elk on the refuge. If we can continue to achieve a reduction in the bison population by 25-50 animals/year, we would achieve the 500 objective within 15 years.] Clarification needed (Alt. C): “Nonhunters might be alienated because of more visible harvest in opened areas near Jackson, a bull elk harvest, and a predator harvest.” Why is the document referring to predatory species? The Refuge is not included in the Department’s trophy game seasons and the word “predatory” is confusing because predatory animals are defined by W.S. 23-1-101 and include: coyote, red fox, etc. that do not require a license or a hunting season. 

Suggested edit (Alt. B):“Encouraging use of bear spray could...” [Alternative B does not require use of bear spray by hunters.]

3-48. Please note that the text 

appearing in chapter 3 of the draft CCP and EA is not included in the final CCP; accordingly, this suggestion cannot be addressed in the final CCP. Additionally, the edit shown in the second sentence is outside the scope of the CCP and is already addressed in the Bison and Elk Management Plan.In the final CCP, the phrases “predator hunts” and “predatory hunts” are not used.

3-49 77 Alternative A – Lower Nowlin Creek and Lower Flat Creek are also open to fishing. 3-49. This is posted on the ground 

where fishing is open and closed.

3-50 78 Wildlife Observation and photography actions: Correct name from “Burt” to “Bert” Raynes here 

and throughout document. Include assessment of hydrology at visitor ponds and wetlands at visitor center and enhancement of water flow to wetlands and ponds where visitor access will be improved.

3-50. The spelling of Bert Raynes 

has been corrected in the final CCP. Regarding the hydrology assessment, thank you for your comment. Natural succession will provide opportunities for environmental education and interpretation.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 10 of 19 Comment number
Appendix C—Public Involvement 171 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-51 83 Suggested addition:

Special uses – actions Alt. B, C, DThe Proposed Action should include language that ensures SUPs issued in sage-grouse core area are vetted for compliance with E.O. 2011-5 with appropriate stipulations applied.Suggested edit:“Most sagebrush plant communities on the refuge fall within the greater sage-grouse core area as defined by the State of Wyoming Greater Sage-Grouse Core Area Protection Executive Order 2011-5.”

3-51. The word “vetted” implies permission. We will continue to work 

with WGFD and the local sagegrouse working group. We have revised the final CCP as suggested.

3-52 110 Suggested edit:

“Most sagebrush plant communities on the refuge fall within the greater sage-grouse core area as defined by the State of Wyoming Greater Sage-Grouse Core Area Protection Executive Order 2011-5.”

3-52. We have revised the final CCP 

as suggested.

3-53 111 Suggested edit:

“Findings by Keigley et al. (2009) suggest that limited-scale regeneration of aspen has occurred on the northernmost parts of the refuge since 2005. Possible but untested explanations of this regeneration include changes in ungulate distributions or migration patterns, changes in ungulate numbers, changes in precipitation and snow accumulation patterns, or some combination of these factors.” [The original explanations listed are too narrow and speculative and one is not supported by scientific consensus.]

3-53. We have revised the final CCP 

as suggested but omitted this phrase: “changes in precipitation and snow accumulation patterns.”

3-54 112 Clarification needed:

 “Riparian area restoration would be designed to modify bank and streambed structure and would not address ungulate browsing of willows or facilitate their recovery.” [This statement is not in line with the Flat Creek Enhancement Project. The refuge has agreed to use hunter management to discourage browsing and to test tools that will exclude ungulate browsing such as fencing.]

3-54. To date, the only strategy 

shown to be effective in promoting 

willow regeneration on the south end of the refuge is exclusion of ungulates. Small-scale fencing with corral 

panels and large-scale fencing with big-game fence are the most effective means. The experimental jackstraw approach is not practical on a large scale. Ungulate exclosures are planned for this area under the Bison and Elk Management Plan, but their exact locations and construction timing will be determined in the habitat stepdown management plan.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 11 of 19 Comment number
172 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-55 115 Suggested edit: “The 2014 winter population classification count for the Jackson elk herd was 11,423 animals (A. Courtemanch, biologist, WGFD, Jackson, Wyoming, personal communication, 2014). This is within 5% of the State’s population objective of 11,000 for the herd size.” A herd is considered at objective if the population estimate is within + 20% of the post-season objective. Suggested addition: The winter distribution of elk, including how many are on feed on the refuge is heavily influenced by annual snow conditions. 3-55. We have revised the final CCP as suggested. 3-56 115 Suggested edit: Update table with 2014 information as follows: National Elk Refuge on feed = 8,296, Gros Ventre drainage = 2,377, Other winter range = 750, Total = 11,423. Update averages column. 3-56. We have revised the final CCP as suggested. 3-57 118 “The State has jurisdiction over bison from the Jackson wild bison herd in “all lands in Lincoln, Sublette and Teton Counties west of the Continental Divide, excluding Grand Teton National Park, Yellowstone National Park and the National Elk Refuge.” This statement needs to be clarified in the document. The National Elk Refuge is defined as a portion of Wild Bison Area 2 in the Wyo- ming Game and Fish Commission regulation Chapter 15, Wild Bison Recreational Hunting Season. 

In addition, the Wyoming Game and Fish Commission and Wyoming Livestock Board, Chapter 41 Bison Designated as Wildlife further defines the “Jackson wild bison herd area” as all lands in Lincoln and Sublette counties and Teton County west of the Continental Divide, excluding Grand Teton National Park and Yellowstone National Park.Suggested edit:“Bison are counted annually on the refuge in the winter and in the park in the summer. WGFD also conducts annual aerial surveys of bison on native winter range.”

3-57. The wording in the CCP is consistent with the Bison and Elk Management Plan approved in 2007. 

WGFD was a cooperating agency in the development of that plan and was provided multiple opportunities to review it during the planning process.We have revised the final CCP as suggested.

3-58 119 Suggested edit:

“As of winter 2014, there were approximately 825 bison in the Jackson herd.”Suggested edit:“We are offering a 157-day season in 2014-2015, from August 15 through January 18.”Suggested edit:“The bison winter population has been reduced from approximately 1,250 in 2007 to approximately 825 in 2014.”

3-58. We have revised the final CCP 

as suggested.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 12 of 19 Comment number
Appendix C—Public Involvement 173 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-59 121 Suggested addition:

The herd has undergone two pneumonia outbreaks in the last 15 years, the first in 2001/2002 and the second in 2011/2012. The most recent outbreak resulted in an approximately 30% population reduction.

3-59. We have revised the final CCP 

as suggested.

3-60 121 Suggested edit:

“The Jackson moose herd was an estimated 500 animals in winter 2014.”

3-60. We have revised the final CCP 

as suggested.

3-61 121 Suggested edit:

“The gray wolf now falls under the management authority of WGFD...” [Need to remove all language in this section regarding State management of gray wolves due to the recent court decision. 

Move all wolf sections to Federally and State-Listed Species sections.]

3-61. We have revised the final CCP 

to reflect management of this species.

3-62 124 Suggested addition:

Include data from past refuge monitoring efforts for nesting waterfowl and raptors. These data should be referenced and used in this document. Periodic repeats of these monitoring efforts could provide comparisons to baseline data and help evaluate management actions. Partnerships and grants might be used to provide funding and volunteers for such efforts.

3-62. We do not have specific population objectives.

3-63 124 References from Craighead Beringia South and GTNP indicate that common raven populations 

are very high on the refuge.

3-63. Thank you for your comment.

3-64 127 1) Should include separate section on Trumpeter Swan and waterfowl and provide datasets available on refuge populations. Technically, the term “waterbirds” does not include waterfowl. Need to 

highlight the importance of the refuge for nesting swans as the refuge produces over 40% of the production of this rare species in the Snake River drainage (core area) of WY. Could also include some of the history of management of this species. 2) Virginia Rail-missing from list and also from species table end of document

3-64. Comment noted.

3-65 129 Change title of section “Federally and State-listed Species” top “Federally listed Species and 

State Species of Greatest Conservation Need”. WY does not have “listed” species. This is confusing the way it is written. 

Also State Wildlife Action Plan should be in capital letters.

3-65. We have revised the final CCP 

as suggested.

3-66 131 Use the correct name for the swan management plan: Pacific Flyway Management Plan for the 

Rocky Mountain Population of Trumpeter Swans Correct term: tri-State to “Tri-state”

3-66. We have revised the plan name 

in the final CCP as suggested. 

3-67 131 Change “species of concern” to “species of greatest conservation need”

Should mitigation measures for curlew be put into Table 4?

3-67. We have revised the final CCP 

as suggested, although table 4 of the draft CCP no longer appears in the final CCP.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 13 of 19 Comment number
174 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-68 139 Suggested edit: “From 2007 to 2011, WGFD issued an average of 3,724 hunting licenses for the Jackson elk herd, with an average of 1,465 elk harvested each season. In 2013, WGFD issued 3,082 licenses and 1,481 elk were harvested. Of that total, 186 were harvested on the refuge.” [The previous information was outdated.] 3-68. We have revised the final CCP as suggested. 3-69 140 Suggested edit: “Hunting on the refuge and the elk reduction program in Grand Teton National Park, along with harvest in Bridger-Teton National Forest and on non-Federal lands, takes place from late Septem- ber to mid-December.” 3-69. We have revised the final CCP as suggested. 3-70 155 First mention of irrigation system recently established on the refuge: this info should be presented earlier in document under description of refuge. 3-70. The irrigation system is men- tioned first on page 27 of the draft CCP and on page 27 of the final CCP. 3-71 161 Suggested edit (Alternatives C and D): “The effects on greater sage-grouse habitat and elk and bison distribution could be greater than alternative B. However, the core area policy for greater sage-grouse is to mitigate activities in the core area, and if the proposed management action complies with Executive Order 2011-5 process and stipulations, adverse affects on greater sage-grouse would be avoided.” 3-71. Please note that the text appearing in chapter 5 of the draft CCP and EA is not included in the final CCP; accordingly, edits to this text cannot be addressed in the final CCP.

3-72 168 Suggested addition:

Mention the collaboration between the refuge, WGFD, USFS and GTNP on research and monitoring through the Jackson Cooperative Elk Studies Group.

3-72. Thank you for your comment.

3-73 170 Suggested edit:

“Both historically and presently, elk harvest on the refuge has been insufficient to meet winter distribution objectives of the Bison and Elk Management Plan.” [Incorrect as written. We have achieved the 11,000 Jackson elk herd objective, but not the goal of 5,000 elk on the refuge. If we can continue to achieve a reduction in the bison population by 25-50 animals/year, we would achieve the 500 objective within 15 years.] A herd is considered at objective if the population estimate is within + 20% of the post-season objective. 

3-73. Please see the response to comment 3-48. 

3-74 171 Suggested edit:

“We may alienate some nonhunters with the more visible archery harvest in currently closed areas, a bull harvest that includes a trophy value, or the harvest of predatory species such as mountain lion.” [Why is the document referring to predatory species? The Refuge is not included in the Departments trophy game seasons and the word “predatory” is confusing because predatory animals are defined by W.S. 23-1-101 and include: coyote, red fox, etc. that do not require a license or a hunting season. 

3-74. See response to comment 1-6. 

All references to the hunting of predators have been removed from the final CCP. 

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 14 of 19 Comment number
Appendix C—Public Involvement 175 

Page Comment/Suggested Revision

3-75 185 Suggested edit:

Remove sentence, “Bighorn sheep close to the road could increase the potential for disease transmission to livestock or vice versa or lead to the spread of disease among the bighorn sheep herd itself.” [It is questionable how bighorn sheep along the road come into contact with livestock. There is no evidence that densities of bighorn sheep along the road are any higher than on native range, thus this does not support the notion that disease would spread more among the herd.]

3-75. Bighorn sheep may experience 

indirect contact through exposure to equipment used to transport livestock. 

3-76 186 Suggested edit:

“Reducing dust abatement on Elk Refuge Road would decrease the attractiveness of the road to bighorn sheep, which would reduce potential conflicts with humans and vehicles and reduce the likelihood of disease transmission in the herd and with domestic livestock.” [See reasoning in 

above comment]

3-76. Thank you for your comment. 

Please note that the text appearing in chapter 5 of the draft CCP and EA is not included in the final CCP; accordingly, edits to this text cannot be addressed in the final CCP.

3-77 199 Suggested addition:

As part of the long-term monitoring, stream temperatures and irrigation returns should be included.

3-77. Thank you for your comment.

3-78 199 “Collect long-term monitoring data for key habitats and wildlife populations, focusing on surrogate 

species when possible.” During other interagency meetings the use of surrogate species to monitor ecosystem health has been contested. We suggest working with the WGFD to monitor species with emphasis on species of greatest conservation need.

3-78. We already monitor WGFD 

species of concern. Monitoring surrogate species does not preclude that. The criteria for choosing each is different.

3-79 200 “Wildlife often travel across administrative boundaries to meet their seasonal life cycle needs. 

Protection of off-refuge resources would help meet these seasonal wildlife needs.”The WGFD is required to prevent comingling between elk, bison, and livestock and has statutory responsibility for damage caused by big game. Many off-refuge areas include traditional agricultural operations. If the refuge acquired lands in these areas to serve as off-refuge wintering areas for elk and/or bison, damage and comingling issues would likely be exacerbated.

3-79. The refuge will not own anything in fee title. Please see the 

response to comment 3-24.

3-80 201 “Set up a program with the Jackson Hole Land Trust and others to establish conservation easements with refuge-specific conservation goals.” See above comment. WGFD would be especially 

concerned about holding elk in the Spring Gulch area during the spring summer and winter periods.“Consider partnership opportunities to build wildlife crossings for Highway 89.” Same as our previous comments. Wildlife crossings would have to be designed to prevent elk and bison from leaving the refuge to private lands during the winter spring and summer. The Department has 

concerns regarding the potential to funnel animals off public land and onto private where the 

potential for conflict is higher. Options to facilitate animal movements off the Refuge should be vetted through the Game and Fish Department, the various land management agencies and private land owners. 

3-80. The strategy of the draft easement criteria was developed in collaboration with WGFD, and we will 

continue to work with WGFD.

RESPONSE Comment number LETTER #3—Wyoming Game and Fish Department, page 15 of 19
176 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-81 201 “Within 10 years, evaluate the effects of the potential sale of Wyoming State trust lands and Wyo- ming Game and Fish Commission-owned lands near the refuge and consider protection options.” It is unclear in the planning document which lands are identified as needing protection. We under- stand the importance of simplifying boundary lines and recommend the land parcels be identified and the State Land Board and Wyoming Game and Fish Commission are included when proposed protection measures are evaluated. 3-81. We have updated Landscape- Scale Conservation Objective 5 to identify lands potentially in need of protection. 3-82 202 Suggested edit: Remove the strategy, “Use wildland fire to help accomplish the objective and reduce hazardous fuel.” [This strategy doesn’t make sense since the objective is to manage tall, dense sagebrush and assure no net loss of mature sagebrush.] Recommend replacing with, “Use prescribed fire and/or mechanical methods to reduce hazardous fuels in targeted areas to protect mature sagebrush stands from wildfire.” Suggested edit: “The Upper Snake River Basin Sage-Grouse Conservation Plan (WGFD 2014) recommended...” [Need to update citation here and in bibliography with newest version of the plan] 3-82. Thank you for your comment. Regarding the sage-grouse conser- vation plan, we have revised the final CCP as suggested. 3-83 203 Reducing water level in spring would impact swan nesting habitat. Replace with drawn-downs in fall through winter and then refill in time for spring nesting season. This has been extremely suc- cessful at Seedskadee NWR. 3-83. Water levels are manipulated with consideration toward nesting swans.

3-84 203 Need to review mitigation project documents for Jackson Lake Dam that included improvements 

and construction of wetlands at Pierre Ponds. (See attached documents). If replacement of ponds is necessary these ponds need to be constructed in a site that would provide additional nesting habitat. Given the territorial behavior of nesting swans, additional ponds in the Romney area would likely not support an additional nesting pair. More summer habitat is needed for nesting and subadult summering swans at another location. Other areas such as the Flat Creek wetlands north of the Fish Hatchery should be evaluated and considered for wetland projects. The CCP should specify the acreage for the two new ponds proposed also.

3-84. Thanks for your comment. We 

will continue to work with WGFD on swan objectives.Because mitigation wetlands kept getting blown out by natural river channel changes, the refuge would like to consider constructing wetlands in other areas less susceptible to damage. Offsite mitigation is no longer allowed on refuge system lands by policy. The hatchery area contains conflicts with other resources and would likely not be suitable for wetland projects.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 16 of 19 Comment number
Appendix C—Public Involvement 177 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-85 204 Suggested addition:

Add strategy to consider planting willows within fenced exclosures to speed restoration.

3-85. We have revised the final CCP 

as suggested.

3-86 204 Suggested edit:

“For the life of the plan, maintain or increase the acreage of class 1 and 2 condition willows, cottonwood, and aspen.”Suggested edit:“...maintaining high hunting pressure on the northern end of the refuge, hazing elk and bison off the refuge during the summer, and using exclosure fences and encouraging wolf activity on the northern end of the refuge.” “encouraging” wolf activity is a meaningless management action.

3-86. Regarding this first edit, we 

have revised the final CCP as suggested.Regarding this second edit, we have revised the final CCP as suggested but with minor changes.

3-87 206 Suggested addition:

Aside from consideration for removal of invasive plants, the strategy should at least commit to treating to control the spread of invasive plant species to additional areas.Suggested edit:Remove cheatgrass from the list of invasive plants that are not considered noxious weeds. It is now listed as a noxious weed by Teton County.

3-87. We have revised the final CCP 

as suggested by both of these edits.

3-88 207 Include language that acknowledges coordination with WGFD to monitor swans and long-billed 

curlews since this has been ongoing for many years and will likely help the Refuge meet monitoring goals in the future.Also recommend including a strategy to repeat raptor nesting survey at specified intervals.

3-88. We have revised the final CCP 

as suggested, with the exception of the raptor nesting survey. That survey will be considered in the inventory and monitoring plan.

3-89 208 “Within 5 years, develop a comprehensive disease contingency plan in coordination with WGFD 

and Grand Teton National Park.” The proposed comprehensive disease contingency plan would only apply to elk and bison on the refuge; the State already has Management Plans for chronic wasting disease and brucellosis. The State could not be held to following a federal plan when elk and bison are outside of the refuge or Grand Teton National Park. We are willing to coordinate on this, but recommend it be removed from the CCP and that the refuge refer to the WGFD disease plans. 

3-89. Please see the response to comment 3-20.

3-90 210 Suggested edit:

“Cooperate with WGFD to develop hunting season proposals for the refuge.”

3-90. Please see the response to comment 3-16.

3-91 213 Suggested edit:

We would like to see more flexibility identified for bison and elk hunting areas. Adaptively managing areas open to hunting bison and elk will help the agencies respond to distribution shifts in the future.

3-91. This issue will be addressed in 

the stepdown hunting plan.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 17 of 19 Comment number
178 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page Comment/Suggested Revision 3-92 214 Suggested edit: Remove the bullet, “Develop an antler point restriction to make sure only mature bulls are har- vested.” We prefer that the document not identify management options for hunting seasons. The formulation of specific hunt recommendations can occur annually as the agencies adaptively man- age populations through hunting season recommendations. Recommendation spelled out in the CCP may limit the agencies in the future. 3-92. We have revised the final CCP as suggested. 3-93 214 Clarification needed: “Work cooperatively with WGFD to develop hunter checkpoints and hunter success surveys.” Need clarification on whether this would be for bison or elk or both? If hunter checkpoints are developed, which agency or agencies would staff these? WGFD already conducts a mandatory sur- vey for bison harvest and a post-hunt survey for elk harvest. See previous comments. “Consider requiring mandatory reporting of elk tag use and harvest.” Already have this in place for bison. If implemented for elk, which agency(ies) would be responsible for contacting hunters? Suggested edit: “Our current tools provide only minimum estimates of elk harvest and do not provide any data about elk hunter success or tag use on the refuge.” [Bison harvest reports are mandatory from every hunter and WGFD follows up on cards that aren’t turned in. The WGFD post-hunt elk hunter survey 

provides a statistically valid estimate of hunter participation and harvest on the refuge.]

3-93. Regarding checkpoints and 

surveys, please see the response to comments 3-21 and 3-47. Regarding mandatory reporting, we understand that WGFD results are valuable, but the refuge may want to supplement information with refugespecific and real-time data.

3-94 215 Suggested edit:

“Coordinate with WGFD and Wyoming State Board of Outfitters and Guides. ”Develop guidelines for outfitters to follow in an effort to minimize conflicts with unguided permit holders.

3-94. We have revised the final CCP 

as suggested.

3-95 215 Rationale – “By encouraging anglers to harvest all nonnative trout they catch...” Suggest rewording “By encouraging anglers to harvest nonnative trout within creel limits...” 3-95. We have revised the final CCP as suggested.3-96 216 Rationale – “By encouraging anglers to harvest all nonnative trout they catch...” Suggest rewording “By encouraging anglers to harvest nonnative trout within creel limits...” 3-96. We have revised the final CCP as suggested.3-97 219 Suggested edit (2nd bullet, 5th sub-bullet):

“ceremonial tribal bison hunt up to 5 bison

3-97. We have revised the final CCP 

as suggested.

3-98 219-

220

Clarification needed:Please clarify whether or not habitat improvement projects implemented with project partners will continue to need a special use permit.

3-98. Yes, these projects will continue to require a special use permit.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 18 of 19 Comment number
Appendix C—Public Involvement 179 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page Comment/Suggested Revision

3-99 222 Clarification needed (1st bullet):

“Revise hunt area boundaries.” We support modifying areas open to hunters within the area designated as Hunt Area 77 the National Elk Refuge. Suggested edit:“Revoke refuge access permits when safety violations occur...” [The way it is currently written suggests the refuge would revoke hunting licenses, which is the WGFD’s jurisdiction]

3-99. The CCP is specific to the refuge unless otherwise specified, so no 

further clarification would be needed.We will retain the right to deny access to the refuge. We are not referring to licenses issued by the State.

3-100 222 Suggested addition:

Recommend conducting all of these strategies in coordination with WGFD.

3-100. The refuge has a long history 

of communicating and coordinating with WGFD. We will continue to do so when appropriate.

3-101 226 Suggested edit:

Recommend removing comprehensive disease contingency plan from the table. If it will not be removed, change planned completion date to 2015 or later. 

3-101. We have revised the final CCP 

to indicate a completion date of 2016.

3-102 Aquatic Invasive Species are generally not addressed in the planning document. Flat Creek, Nowlin Creek, and Gros Ventre River have a lot of use by bank anglers, many who are from across the 

US, or from other countries. Strategies to educate anglers on AIS should be identified in the document. There are tanks for cleaning wading and fishing gear at the Flat Creek access gates, but information is largely unavailable at access points along the Gros Ventre River. 

3-102. Aquatic invasive species are 

an important issue to all. We will continue to work with WGFD, NPS, and the USDA Forest Service to improve education and outreach related to aquatic invasive species.

RESPONSE LETTER #3—Wyoming Game and Fish Department, page 19 of 19 Comment number
180 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE LETTER #4—Teton Board of Commissioners, page 1 of 2 Comment number
Appendix C—Public Involvement 181 

4-14-2

4-1. The proposal does call for adaptive management 

by allowing for an adjusted season when spring green up and migration occurs earlier than average. 

4-2. We look forward to continuing work with Jackson 

Hole Community Pathways and Teton County to reduce pathway user conflicts and increase opportunities for wildlife dependent recreation activities. Thank you for your comments.

RESPONSE LETTER #4—Teton Board of Commissioners, page 2 of 2 Comment number
182 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 5-1. The proposal does call for adaptive management by allowing for an adjusted season when spring green up and migration occurs earlier than average. In 2013, the seasonal dates were modified, expanding use by the public for an additional 31 days. The adjustment was based on extensive monitoring done in collabora- tion with Jackson Hole Community Pathways and Teton County. 5-2. Animals are very wary of the presence of humans on foot. Pedestrians illegally using the pathway and approaching the fence have caused noticeable and repeated disturbance to nearby elk, often causing the herd to bolt from the area and not return for up to 24 hours. Not only does this stress the wintering ani- mals, but it decreases the amount of refuge areas used by elk. Were this to occur regularly during the winter months, the negative effects would be significant.

Thank you for your comments.

5-15-2

RESPONSE LETTER #5—Teton County Sheriff, page 1 of 1 Comment number
Appendix C—Public Involvement 183 

Board of DirectorsMarc Bekoff, Ph.D.H. Webb BlessleyPatricio Robles GilDr. Jane Goodall, Ph.D., DBE

Rick Hopkins, Ph.D.Robert W. KoonsCara Blessley LoweThomas D. Mangelsen, Ph.D.

Corinne R. RutledgeJohn E. Swallow The	
  Cougar	
  Fund	
  

125	
  N.	
  Cache	
  St.	
  Upstairs

Box	
  122	
  

Jackson,	
  WY	
  83001-­‐0122	
  Please	
  accept	
  the	
  comments	
  of	
  The	
  Cougar	
  Fund	
  on	
  the	
  Draft	
  CCP/EA	
  for	
  the	
  National	
  

Elk	
  Refuge	
  (NER),	
  Jackson,	
  Wyoming.	
  

The	
  Cougar	
  Fund	
  is	
  dedicated	
  to	
  the	
  protection	
  of	
  cougars	
  and	
  other	
  large	
  carnivores	
  through	
  education,	
  advocacy	
  and	
  policy	
  monitoring.	
  We	
  have	
  grave	
  reservations	
  concerning	
  United	
  States	
  Fish	
  and	
  Wildlife	
  Service	
  (USFWS)	
  references	
  to	
  the	
  possibility	
  of	
  expanding	
  hunting	
  opportunities	
  on	
  the	
  National	
  Elk	
  Refuge	
  to	
  include	
  sport	
  hunting	
  of	
  predators	
  (CCP	
  Draft	
  hardcopy,	
  pg.	
  76;	
  Table	
  4).	
  While	
  the	
  initial	
  consideration	
  in	
  the	
  ‘actions’	
  proposal	
  is	
  vague,	
  predators	
  are	
  specifically	
  mentioned	
  in	
  the	
  consequences	
  and	
  further	
  identified	
  to	
  include	
  wolves	
  and	
  mountain	
  lions	
  in	
  the	
  expanded	
  analysis	
  on	
  page	
  171.	
  Since	
  wolves	
  were	
  delisted	
  at	
  the	
  time	
  the	
  CCP	
  was	
  written,	
  we	
  wonder	
  if	
  the	
  grizzly	
  bear	
  might	
  also	
  have	
  been	
  included	
  were	
  it	
  not	
  for	
  the	
  current	
  protection	
  of	
  being	
  a	
  threatened	
  species.

Predator	
  hunting	
  is	
  an	
  inappropriate	
  use	
  of	
  the	
  NER	
  for	
  the	
  following	
  reasons:	
  

• The	
  NER	
  has	
  already	
  identified	
  the	
  risks	
  of	
  large	
  concentrations	
  of	
  

ungulates	
  in	
  the	
  Bison	
  and	
  Elk	
  Management	
  Plan (BEMP) of	
  2007	
  (pg.	
  9;	
  

Purpose	
  and	
  Need)	
  and	
  also	
  identified	
  wolves	
  and	
  cougars	
  as	
  “mainly	
  

killing	
  the	
  most	
  vulnerable	
  prey,	
  the	
  young,	
  old	
  and	
  poorly	
  conditioned,”	
  (BEMP,	
  pg. 142;	
  Affected	
  Environment).	
  This	
  pattern	
  of	
  predation	
  is	
  a	
  tool	
  for	
  you	
  to	
  mitigate,	
  “increased	
  risk	
  of	
  potentially	
  major	
  outbreaks	
  of	
  exotic	
  diseases,”	
  (BEMP,	
  pg.	
  9;	
  Purpose	
  and	
  Need).	
  

• Predators	
  are	
  also	
  known	
  to	
  reduce	
  densities	
  by	
  dispersing	
  prey,	
  which	
  

also	
  ties	
  in	
  with	
  the	
  statement,	
  “Some	
  precautionary	
  measures	
  such	
  as	
  reducing	
  densities	
  and	
  number	
  of	
  elk	
  and	
  increasing	
  dispersion	
  could	
  reduce	
  the	
  chance	
  of major	
  adverse	
  impacts	
  if	
  the	
  disease	
  (CWD)	
  becomes	
  established,”	
  (BEMP,	
  pg. 140;	
  Affected	
  Environment).	
  

• FWS	
  also	
  displays	
  the	
  short	
  film	
  “How	
  Wolves	
  Change	
  Rivers”	
  on	
  it’s	
  

website,	
  http://www.fws.gov/endangered/about/vp-­‐145-­‐2014.html

The	
  film	
  showcases	
  improvements	
  not	
  unlike	
  your	
  goal	
  to	
  improve,	
  “damage	
  to	
  and	
  loss	
  of	
  habitat	
  due	
  to	
  browsing	
  of	
  willow,	
  cottonwood,	
  and	
  aspen	
  stands,	
  with	
  resultant	
  reductions	
  in	
  wildlife	
  associated	
  with	
  

RESPONSE Comment number LETTER #6—The Cougar Fund, page 1 of 6
184 Comprehensive Conservation Plan—National Elk Refuge, Wyoming6-1. We agree that predators provide benefits that support the mission of the refuge, and a hunting season specifically for predators is not envisioned. All references to the hunting of predators have been 

removed from the CCP. 

healthy	
  stands.”	
  This	
  indicates	
  how	
  beneficial	
  the	
  presence	
  of	
  wolves	
  is	
  to	
  habitat	
  of	
  the	
  NER.

• The	
  very	
  logistics	
  of	
  mountain	
  lion	
  hunting	
  involve	
  the	
  use	
  of	
  packs	
  of	
  

dogs,	
  which	
  are	
  most	
  effective	
  during	
  the	
  time	
  when	
  snow	
  cover	
  allows	
  the	
  hunters	
  to	
  identify	
  cougar	
  tracks	
  for	
  the	
  dogs	
  to	
  follow.	
  Snow	
  

covered	
  ground	
  on	
  the	
  refuge	
  is	
  synonymous	
  with	
  large	
  accumulations	
  of	
  elk.	
  It	
  is	
  not	
  hard	
  to	
  imagine	
  the	
  controversy	
  that	
  would	
  ensue	
  if	
  packs	
  of	
  dogs	
  were	
  running	
  around	
  among	
  the	
  elk	
  simply	
  for	
  the	
  

purpose	
  of	
  providing	
  a	
  ‘recreational	
  opportunity’.

• The	
  population	
  of	
  cougars	
  in	
  this	
  area	
  is	
  (<0.5	
  adults/100	
  km2),	
  about	
  

half	
  of	
  the	
  lowest	
  average	
  when	
  compared	
  with	
  mountain	
  lion	
  populations	
  across	
  North	
  America	
  (1-­‐1.5	
  adults/100	
  km2 in	
  Quigley	
  and	
  

Hornocker,	
  2010).	
  We	
  feel	
  that	
  you	
  are	
  ignoring	
  the	
  fact	
  that	
  the	
  

population	
  is	
  already	
  greatly	
  diminished,	
  further	
  supported	
  by	
  the	
  reduction	
  in	
  harvest	
  as	
  well.

The	
  Cougar	
  Fund	
  would	
  like	
  to	
  express	
  our	
  strong	
  opposition	
  to	
  the	
  possibility	
  of	
  predator	
  hunting	
  on	
  the	
  National	
  Elk	
  Refuge.	
  It	
  is	
  evident	
  that	
  references	
  to	
  predators	
  in	
  the	
  Bison	
  and	
  Elk	
  Management	
  Plan	
  (2007)	
  indicate	
  they	
  have	
  the	
  most	
  value	
  in	
  aiding	
  your	
  management	
  objectives	
  ALIVE.	
  We	
  respectfully	
  request	
  that	
  you	
  remove	
  all	
  references	
  to	
  the	
  hunting	
  of	
  predators	
  from	
  your	
  

final	
  plan.	
  

Comments	
  about	
  other	
  aspects	
  of	
  the	
  CCP	
  are	
  as	
  follows:Identify,	
  Examine	
  and	
  Maximize	
  Existing	
  Natural	
  Habitat:	
  

• The	
  CCP	
  addresses	
  many	
  partnerships	
  (CCP	
  Draft,	
  pg.	
  93).	
  Each	
  of	
  these	
  

are	
  important,	
  especially	
  jumpstarting	
  the	
  work	
  of	
  the	
  J.I.H.I.	
  whose	
  

goal	
  was	
  to,	
  “Maximize	
  effectiveness	
  of	
  native	
  winter	
  and	
  transitional	
  

range	
  for	
  ungulates	
  and	
  a	
  diversity	
  of	
  species	
  indigenous	
  to	
  the	
  region	
  through	
  identification	
  and	
  implementation	
  of	
  habitat	
  enhancement	
  

opportunities”	
  

• Identifying	
  and	
  possibly	
  improving	
  (by	
  burns	
  that	
  DO	
  NOT	
  threaten	
  the	
  

return	
  and	
  nesting	
  of	
  migratory	
  birds	
  or	
  calving	
  of	
  ungulates)	
  transitional	
  and	
  winter	
  habitat	
  is	
  imperative	
  but	
  must	
  be	
  followed	
  by	
  also	
  identifying	
  how	
  to	
  get	
  the	
  elk	
  on	
  to	
  the	
  natural	
  forage.

6-1

RESPONSE LETTER #6—The Cougar Fund, page 2 of 6 Comment number
Appendix C—Public Involvement 185 

6-2. Please see the response to comment 1-8.6-3. A program to promote the voluntary use of nonlead ammunition on the refuge was implemented by 

the refuge, other agencies, and nongovernmental organization partners in 2008. Since that time, the voluntary use of non-lead ammunition has steadily increased to approximately 59 percent of successful elk hunters in 2014. This was accomplished primarily through the emphasis of educational materials promoting the use of non-lead ammunition. The steady decline in cost and the increase in availability of nonlead ammunition, combined with continued educational materials and emphasis by the refuge, is anticipated to continue to increase the voluntary participation in the use of non-lead ammunition.We believe the voluntary and educational approach provides additional benefits over mandating the use of non-lead ammunition. Hunters who are informed and convinced through education of the benefits of nonlead ammunition are more likely to voluntarily use that ammunition on the hundreds of thousands of acres of public and private lands that are open to hunting and surround the refuge, such as BridgerTeton National Forest and State lands. This provides extended benefits to scavenging birds that may use the refuge and surrounding lands.The refuge will continue to monitor the effectiveness of its voluntary non-lead ammunition program and will re-evaluate this program after 5 years instead of at the expiration of the CCP. A regulation requiring the use of non-lead ammunition can be implemented if the progress of the voluntary non-lead ammunition policy does not meet refuge expectations.

• The	
  transitional	
  range	
  is	
  free	
  natural	
  capital	
  and	
  the	
  ways	
  in	
  which	
  

current	
  hunting	
  seasons	
  manipulate	
  how	
  elk	
  travel	
  through	
  the	
  landscape	
  must	
  be	
  examined	
  and	
  adapted	
  to	
  utilize	
  the	
  full	
  potential	
  of	
  the	
  habitat	
  that	
  many	
  groups	
  are	
  trying	
  so	
  hard	
  to	
  enhance.

• Maximization	
  of	
  natural	
  habitat	
  is	
  also	
  made	
  possible	
  by	
  construction	
  

of wildlife	
  crossings	
  (CCP	
  Draft,	
  pg.	
  93)	
  that	
  will	
  improve	
  public	
  safety,	
  

reduce	
  economic	
  loss,	
  reduce	
  insurance	
  compensation,	
  prevent	
  fragmentation	
  and	
  improve	
  connectivity	
  for	
  many	
  species	
  of	
  wildlife.	
  	
  

The	
  Cougar	
  Fund	
  fully	
  supports	
  including	
  wildlife	
  crossings	
  in	
  the	
  final	
  

plan.

Mandatory	
  Use	
  of	
  Bear	
  Spray	
  and	
  Lead-­‐free	
  Bullets:	
  

• We	
  concur	
  and	
  congratulate	
  FWS	
  on	
  including	
  this	
  in	
  Option	
  C	
  (CCP	
  

Draft,	
  pg.	
  74).	
  

• The	
  evidence	
  that	
  bear	
  spray	
  is	
  more	
  effective	
  and	
  results	
  in	
  less	
  injury	
  

to	
  humans	
  AND	
  bears	
  (98%	
  vs. <50%	
  firearms)	
  is	
  widely	
  promoted	
  by	
  local	
  managers	
  (Steve	
  Cain,	
  2013	
  &	
  2014;	
  from	
  GTNP	
  presentations).	
  While	
  the	
  NER	
  may	
  have	
  admirable	
  voluntary	
  compliance,	
  the	
  recent	
  tragic	
  example	
  near	
  Dubois,	
  when	
  one	
  person	
  with	
  no	
  bear	
  spray	
  was	
  killed	
  and	
  another	
  WITH	
  bear	
  spray	
  received	
  only	
  minor	
  injuries,	
  sadly	
  supports	
  mandatory	
  carry.	
  This	
  occurred	
  within	
  a	
  short	
  timeframe	
  in	
  the	
  same	
  region	
  and	
  is	
  evidence	
  that	
  100%	
  compliance	
  is	
  necessary.	
  

This	
  will	
  only	
  be	
  met	
  by	
  regulation.	
  The	
  alienation	
  of	
  hunters	
  (because	
  of	
  the	
  added	
  expense	
  of	
  having	
  to	
  carry	
  bear	
  spray)	
  would	
  be	
  mitigated	
  by	
  requiring	
  bear	
  spray	
  for	
  ANY	
  NER	
  constituent	
  whose	
  recreational

activities	
  elevate	
  the	
  chance	
  of	
  negative	
  encounters	
  with	
  predators.	
  

• The	
  same	
  is	
  true	
  of	
  lead-­‐free ammunition.	
  Anecdotally,	
  compliance	
  on	
  

the	
  NER	
  appears	
  to	
  be	
  encouraging (from	
  conversation	
  with	
  USFWS	
  

Cris	
  Dipple),	
  but	
  the	
  minority	
  still	
  using	
  lead	
  could	
  be	
  responsible	
  for	
  

serious	
  consequences	
  to	
  raptors,	
  scavengers	
  and	
  threatened	
  omnivores	
  alike.	
  If	
  compliance	
  is	
  already	
  good	
  then	
  the	
  number	
  of	
  hunters	
  being	
  alienated	
  by	
  your	
  commitment	
  to	
  ecological	
  best	
  practices	
  will	
  be	
  minimal!	
  There	
  is	
  frequent	
  travel	
  by	
  many	
  species	
  between	
  the	
  NER	
  

and	
  GRTE,	
  where	
  lead-­‐free is	
  mandatory.	
  Therefore,	
  failing	
  to	
  regulate	
  

the	
  use	
  of	
  lead-­‐free on	
  the	
  NER	
  prevents	
  other	
  federal	
  land	
  managers	
  

from	
  maximizing their	
  efforts	
  to	
  remove	
  harmful	
  lead	
  from	
  the	
  diets	
  of	
  scavengers,	
  carnivores	
  and	
  raptors	
  within	
  their	
  boundaries.	
  

6-26-3

RESPONSE LETTER #6—The Cougar Fund, page 3 of 6 Comment number
186 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 6-4. This has been done by the refuge in the past and will continue to be considered in the future. 6-5. Thank you for your comments. We’ve provided such opportunities in the past and will consider con- tinuing this practice in the future. 6-6. Responding to accelerating climate change is a Service priority as described in its 50-year strategic plan (see page 8 in the draft CCP). It is an integral part of the U.S. Department of the Interior’s strategy for addressing climate change as expressed in Secre- tarial Order 3289 (September 14, 2009). This strategic plan embeds guiding principles for responding to cli- mate change into Refuge System planning documents. The CCP provides “management direction” for the refuge over the next 15 years, and as mentioned on page 1 of the draft CCP, “detail will be provided in 

stepdown management plans as part of implementing the final CCP.” The refuge will not conduct climate change research. However, it will continue to conduct and collaborate with partners in the collection of long-term baseline data (page 37 of the draft CCP) through targeted wildlife, fisheries, disease, invasive plant, and habitat monitoring surveys. This information, combined with additional surveys to be identified in the inventory and monitoring stepdown plan, will assist the refuge in understanding and planning for the local impacts of climate change in the future.All future CCP stepdown plans (table 22, page 226 of the draft CCP) will encompass the guiding principles for responding to climate change. These guiding prin-

• Grants	
  are available	
  (The	
  Packard	
  Foundation	
  supported	
  Craighead	
  

Beringia	
  South	
  with	
  their	
  bullet	
  exchange	
  initiative).	
  Reach out	
  to	
  a	
  

partner	
  organization	
  to	
  help	
  with	
  co-­‐writing	
  a	
  grant	
  to	
  subsidize	
  lead-­‐free bullets.

Provision	
  for	
  Unique	
  Wildlife	
  Watching	
  Events:The	
  2007	
  BEMP	
  has	
  a	
  record	
  of	
  the	
  presence	
  of	
  a	
  female	
  cougar	
  and	
  her	
  three	
  kittens	
  that	
  made	
  the	
  cave	
  on	
  the	
  south	
  end	
  of	
  Miller	
  Butte	
  their	
  home	
  for	
  forty-­‐two	
  days.	
  The	
  mountain	
  lion	
  family	
  arrived	
  on	
  Valentine’s	
  Day	
  1999,	
  and	
  it	
  is	
  no	
  surprise	
  that	
  over	
  15,000	
  people (per	
  NER staff estimates) visited	
  and	
  quite	
  possibly	
  fell	
  in	
  love	
  with	
  them	
  during	
  this	
  time.This	
  is	
  the	
  type	
  of	
  experience	
  that	
  can	
  influence	
  members	
  of	
  the	
  public	
  for	
  the	
  rest	
  of	
  their	
  lives.	
  It	
  is	
  not	
  only	
  a	
  beneficial	
  economic	
  boost	
  for	
  local	
  communities	
  but	
  it	
  is	
  also	
  a	
  publicity	
  boost	
  for	
  the	
  federal	
  agency	
  upon	
  whose	
  land	
  the	
  event	
  takes	
  place.	
  In	
  a	
  time	
  of	
  short	
  budgets,	
  negative	
  media	
  coverage	
  of	
  the	
  role	
  of	
  federal	
  land	
  managers,	
  and	
  the	
  state of	
  Wyoming’sreluctance	
  to	
  accept	
  federal	
  jurisdiction,	
  an	
  event	
  like	
  the	
  presence	
  of	
  this	
  cougar	
  can	
  infuse	
  more	
  interest,	
  support,	
  and	
  good	
  will	
  for	
  the	
  NER	
  than	
  any	
  Madison	
  Ave	
  advertising	
  ever	
  could!The	
  Cougar	
  Fund	
  sincerely	
  requests	
  that	
  you	
  include	
  a	
  detailed	
  contingency	
  plan	
  for	
  future	
  unique	
  viewing	
  opportunities	
  that	
  could	
  be	
  adapted	
  to	
  the	
  presence	
  of	
  any	
  animal	
  that	
  inspires	
  public	
  interest.	
  Locations	
  that	
  allow	
  for	
  the	
  safe	
  approach	
  of	
  motor	
  vehicles	
  on	
  existing	
  roadways	
  on	
  the	
  NER	
  should	
  be	
  identified	
  together	
  with	
  ways	
  that	
  a	
  scene	
  could	
  be	
  managed	
  to	
  allow	
  the	
  greatest	
  number	
  of	
  people	
  the	
  greatest	
  amount	
  of	
  time	
  to	
  enjoy	
  THEIR	
  wildlife.	
  A	
  proactive	
  plan	
  would	
  include:	
  

• Above	
  all,	
  protection	
  of	
  the	
  animal

• Identification	
  of	
  suitable	
  parking

• Methods	
  of	
  transportation	
  to	
  allow	
  people	
  to	
  get	
  to	
  the	
  viewing	
  area	
  

(Start	
  bus?)

• Liberal	
  opportunities	
  to	
  photograph

• Information	
  about	
  the	
  animal

• Location	
  and	
  availability	
  of	
  extra	
  personnel	
  to	
  help	
  with	
  scene	
  

management	
  (including	
  other	
  federal	
  and	
  state	
  agencies	
  as	
  well	
  as	
  local	
  

NGO’s	
  who	
  would	
  be	
  willing	
  to	
  help)

6-46-5

RESPONSE LETTER #6—The Cougar Fund, page 4 of 6 Comment number
Appendix C—Public Involvement 187 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

ciples will be especially influential in the development of the fire, habitat, integrated pest management, and the inventory and monitoring stepdown plans.The refuge, as part of the Greater Yellowstone Coordinating Committee, is supporting the Northern Rockies Adaptation Partnership efforts to complete vulnerability assessments and adaptation strategies for the Greater Yellowstone Ecosystem. This is a step in the process of better understanding potential climate change impacts and adaptation strategies applicable to the refuge.It is also anticipated that the refuge will become part of a Landscape Conservation Design (LCD), a future subunit of a Landscape Conservation Cooperative (LCC), which will continue to emphasize the importance of climate change. LCDs must be concerned with climate change, because an LCD “is an assessment of the landscape’s current and potential future condition, a description of a desired future condition, and a suite of preliminary, coarse-scale management strategies that are developed by the greater conservation community” (FWS 2013b).6-7. To determine the need for revision, the CCP will 

be reviewed annually. A revision would occur if and when significant information becomes available, such as a change in ecological conditions (page 227 of the draft CCP).

6-8. In an era of flat or declining Federal operating 

budgets, the financial cost of implementing programs is always a consideration. The refuge strives to effectively use its limited operational resources such as funding and personnel.

It	
  is	
  especially	
  important	
  for	
  the	
  public	
  to	
  receive	
  positive	
  and	
  credible	
  education	
  about	
  the	
  contributions	
  of	
  predators	
  and	
  large	
  carnivores	
  to	
  

the	
  habitat	
  of	
  the	
  NER.	
  The	
  appearance	
  of	
  one	
  of	
  these	
  animals	
  should	
  not	
  

be	
  seen	
  as	
  a	
  ‘problem’,	
  but	
  as	
  an	
  opportunity	
  for	
  outreach	
  and	
  affirmation	
  of	
  the	
  role	
  of	
  the	
  NER.

Climate	
  Change	
  

Climate	
  change	
  receives	
  minimal	
  attention	
  (CCP	
  Draft,	
  pg.	
  62),	
  which	
  is	
  surprising	
  given	
  the	
  extent	
  of	
  the	
  effects	
  of	
  climate	
  change	
  both	
  on	
  a	
  landscape	
  and	
  planetary	
  scale.	
  Alternative	
  B	
  refers	
  to	
  focusing	
  on	
  bison,	
  elk	
  and	
  federal	
  trust	
  species.	
  We	
  encourage	
  you	
  to	
  take	
  a	
  more	
  proactive	
  approach	
  to	
  the	
  issue	
  of	
  climate	
  change.There	
  is	
  nothing	
  about	
  climate	
  change	
  that	
  can	
  be	
  classified	
  as	
  final,	
  so	
  instead	
  of	
  basically	
  ignoring	
  it,	
  please	
  acknowledge	
  that	
  it	
  will	
  be	
  an	
  adaptive	
  process.	
  The	
  NER	
  needs	
  to	
  plan	
  for	
  the	
  inclusion	
  of	
  implementation	
  of	
  the	
  Department	
  of	
  Interior’s	
  

directive	
  on	
  climate	
  change	
  policy	
  from	
  December	
  20th	
  2012	
  (DOI	
  Department	
  

Manual,	
  2012:	
  Part	
  523,	
  Chapter	
  1).	
  

Review	
  of	
  the	
  entire	
  CCP	
  must	
  be	
  scheduled	
  to	
  occur	
  at	
  regular	
  intervals.	
  The	
  intended	
  life	
  of	
  the	
  plan	
  is	
  15	
  years,	
  the	
  equivalent	
  of	
  two	
  elk	
  generations,	
  an	
  entire	
  bison	
  generation,	
  and	
  the	
  time	
  it	
  takes	
  for	
  the	
  slow	
  reproducing	
  grizzly	
  bear	
  to	
  mature.	
  Too	
  much	
  can	
  happen	
  in	
  this	
  timeframe	
  to	
  not	
  make	
  preparations	
  for	
  adapting	
  to	
  unpredicted	
  environmental	
  changes	
  or	
  events,	
  especially	
  those	
  originating	
  from	
  climate	
  change.

Non-­‐Consumptive	
  Use:	
  The	
  draft	
  CCP	
  illustrates	
  a	
  consistent	
  underlying	
  concern	
  about	
  expenses	
  related	
  to	
  

public	
  access	
  and	
  amenities	
  for	
  the	
  NER.	
  There	
  seems	
  to	
  be	
  a	
  bias	
  towards	
  the	
  advantage	
  of	
  consumptive	
  use	
  not	
  only	
  as	
  a	
  management	
  tool,	
  but	
  also	
  as	
  a	
  revenue	
  

source.	
  It	
  appears	
  that	
  there	
  is	
  no	
  revenue	
  from	
  any	
  of	
  the	
  hunting	
  activities,	
  yet	
  the	
  concessions	
  that	
  provide	
  sleigh	
  rides	
  for	
  20,000	
  non-­‐consumptive	
  visitors	
  per	
  year	
  provides	
  a	
  percentage	
  return	
  to	
  the	
  NER.	
  Additionally,	
  non-­‐consumptive	
  users	
  also	
  contribute	
  revenue	
  through	
  the	
  annual	
  Boy	
  Scouts	
  of	
  America	
  elk	
  antler	
  pick-­‐up	
  and	
  auction,	
  which	
  partially	
  subsidizes	
  feeding	
  on	
  the	
  NER.There	
  are	
  two	
  possible	
  conclusions	
  to	
  draw	
  from	
  this:

• Since	
  higher	
  equipment	
  and	
  labor	
  costs	
  are	
  associated	
  with	
  expanding	
  

hunting	
  opportunities	
  (Draft	
  CCP,	
  pg.	
  62),	
  then	
  it	
  can	
  be	
  assumed that	
  

the	
  NER	
  will	
  no	
  longer	
  hold	
  an	
  annual	
  elk	
  hunt	
  when	
  the	
  management	
  

goal	
  has	
  been reached.	
  

6-66-76-8

RESPONSE LETTER #6—The Cougar Fund, page 5 of 6 Comment number
188 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Both consumptive and nonconsumptive wildlife-depen- dent public use activities are considered in the CCP. Those activities that are consistent with the National Wildlife Refuge System Improvement Act and best support the purposes of the refuge receive primary consideration. 6-9. The Bison and Elk Management Plan (FWS and NPS 2007a) will be updated upon expiration, and con- sideration will be given to limit the update to match the remaining life of the CCP. Thank you for your comments.

• The	
  second	
  is	
  that	
  non-­‐consumptive	
  users are	
  greater	
  financial

contributors,	
  yet there	
  is	
  concern	
  about	
  higher	
  costs	
  to	
  provide	
  

programming	
  (Draft	
  CCP,	
  pg.	
  81).	
  

The	
  contributions	
  of	
  non-­‐consumptive	
  users	
  must	
  be	
  addressed	
  when	
  offering	
  wildlife-­‐based	
  recreation	
  on	
  the	
  NER.	
  Programming	
  and	
  access	
  for	
  non-­‐consumptive	
  

users	
  must	
  be	
  at	
  least	
  equal	
  to	
  the	
  opportunities	
  available	
  to	
  consumptive	
  users.

The	
  NER	
  accepts	
  the	
  presence	
  of	
  WGFD	
  staff	
  to	
  adjudicate	
  the	
  hunt.	
  Cooperation	
  with	
  partners	
  and	
  NGO’s	
  could	
  be	
  explored	
  to	
  provide	
  programming	
  and	
  environmental	
  education.	
  Temporal	
  Scales	
  and	
  Planning	
  of	
  Multiple	
  Management	
  Documents:	
  There	
  is	
  a	
  notable	
  discrepancy	
  between	
  the	
  longevity	
  of	
  the	
  NER	
  CCP	
  and	
  the	
  BEMP	
  (2007).	
  We	
  observe	
  that	
  the	
  CCP	
  is	
  written	
  to	
  complement	
  the	
  BEMP,	
  yet	
  only	
  half	
  of	
  the	
  CCP’s	
  projected	
  lifetime	
  corresponds	
  with	
  the	
  current	
  BEMP.	
  	
  We	
  request	
  that	
  you	
  address	
  this	
  discrepancy	
  and	
  provide	
  an	
  explanation	
  and	
  a	
  plan	
  for	
  your	
  intentions	
  to	
  rectify	
  this	
  inconsistency.In	
  conclusion,	
  The	
  Cougar	
  Fund	
  thanks	
  you	
  for	
  the	
  opportunity	
  to	
  comment.	
  We	
  appreciate	
  your	
  public	
  service	
  and	
  we	
  trust	
  that	
  you	
  will	
  review	
  and	
  consider	
  all	
  comments	
  with	
  the	
  same	
  respect	
  with	
  which	
  they	
  have	
  been	
  submitted.

Sincerely, Penelope Maldonado Managing Director 

6-9

RESPONSE LETTER #6—The Cougar Fund, page 6 of 6 Comment number
Appendix C—Public Involvement 189 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

7-1. Hunting is a legislatively mandated priority 

public use under the National Wildlife Refuge System Improvement Act. Current hunting seasons on the refuge and those proposed in the CCP are designed to meet management goals and objectives in the Bison and Elk Management Plan (FWS and NPS 2007a). Broadly, the goal of that plan is to reduce reliance on supplemental feeding, and this is to be achieved through reducing the number of elk wintering on the refuge to 5,000 and reducing the number of bison in the Jackson herd to 500. Hunting on the refuge was the management strategy deemed most effective to meet this management objective. 

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October 9, 2014 VIA ELECTRONIC MAIL (refuge_ccps@fws.gov) Toni Griffin Planning Team Leader 134 Union Boulevard, Suite 300 Lakewood, CO 80228 Re: National Elk Refuge CCP Comments Dear Toni Griffin: 

Friends of Animals (FoA) submits these comments on the Draft Comprehensive 

Conservation Plan and Environmental Assessment for the National Elk Refuge (hereinafter “EA” or “Conservation Plan”). 

FoA supports the National Elk Refuge (Refuge) as a place that protects land for 

the conservation of wildlife. Additionally, FoA supports efforts to promote wildlife education and viewing opportunities in the Refuge, to the extent that it is compatible with the conservation and protection of free living wildlife. However, FoA opposes the proposed action in the EA in so far as it promotes destructive activities by continuing to artificially feed wildlife and by expanding hunting and fishing on the Refuge. 

The word "refuge" includes the idea of providing a haven of safety for wildlife, 

and hunting undermines this idea. Hunting directly harms the species that the Refuge was intended to protect, it disturbs other species and the natural ecosystem, and it diminishes the ability of FoA members and the American people to enjoy this area. Instead of considering the purposes of the Refuge and the interest of the general public, the proposed Draft Conservation Plan caters to the interest of a few recreational hunters that want the Refuge to be managed in a way that maximizes their ability to kill wildlife. The EA failed to consider any alternatives that would eliminate or even reduce hunting and fishing on the Refuge. 

We urge the U.S. Fish and Wildlife Service (FWS) to consider an alternative that 

prohibits hunting in the Refuge. We also ask FWS to consider the ethical impacts of its actions, along with its legal obligations under the National Environmental Policy Act (NEPA) and the Refuge’s enabling legislation. 

7-1

RESPONSE LETTER #7—Friends of Animals, page 1 of 13 Comment number
190 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 7-2. Hunting is a critical management tool to meet Bison and Elk Management Plan goals and objectives, which are primarily to reduce the number of elk and bison to levels more in balance with available habitat and subsequently to reduce our reliance on supplemental feeding. These goals and objectives are consistent 

with refuge purposes.

Page 2 of 13

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FRIENDS OF ANIMALS 

FoA is an international animal rights organization incorporated in the state of 

New York since 1957. FoA has nearly 200,000 members worldwide, including many that live near or visit the National Elk Refuge and surrounding areas. FoA and its members seek to free animals from cruelty and exploitation around the world, and to promote a respectful view of non-human, free-living and domestic animals. FoA activities include educating its members on current threats to many species’ abilities to live in ecosystems 

free from human manipulation, exploitation, and abuse; and monitoring federal agency actions to ensure that laws enacted to protect the environment and wildlife are properly implemented. Hunting on the Refuge seriously disrupts FoA members’ experience and ability to enjoy this area. Not only does hunting directly affect the individual animals 

being hunting, it also disrupts the natural system and balance in these areas. Many 

members like to recreate on the Refuge and to observe and photograph wildlife there. These members cannot enjoy their time on the Refuge when they are aware that hunting occurs or when they observe hunting and its affects in these areas. 

HISTORY AND PURPOSE OF THE NATIONAL ELK REFUGE 

At the turn of the 20th century, increased human activities, such as construction 

and grazing cattle, along with a series of harsh winters, led to the starvation of thousands of elk near Jackson, Wyoming. In response, Congress established a “winter 

game reserve” in 1912, and in 1913, Congress designated the area “a winter elk refuge.” 16 U.S.C. 673, 37 Stat. 847. In 1921, all lands included in the Refuge or that might be 

added in the future were reserved and set apart as “refuges and breeding grounds for 

birds” (Executive Order 3596), which was affirmed in 1922 (Executive Order 3741). In 1927, the Refuge was expanded to provide “for the grazing of, and as a refuge for, American elk and other big game animals.” 16 U.S.C. 673a. 

The primary purpose of the Refuge is to conserve elk, big game animals, and 

birds. As stated in the EA, the Refuge should be a place where “wildlife comes first” andwhere “ecosystems, biodiversity, and wilderness are vital concepts in refuge 

management.” EA at 4. The National Wildlife Refuge System Improvement Act also states 

that wildlife conservation is the priority on Refuge System lands and that the Secretary of the Interior should ensure that the biological integrity, diversity, and environmental health of refuge lands are maintained. According to the Refuge Recreation Act, the Secretary of the Interior is authorized to administer areas for public recreation as “incidental or secondary use” only to the extent that they are not inconsistent with the primary objectives of the Refuge. 16 USCS § 460k. 

7-2

RESPONSE LETTER #7—Friends of Animals, page 2 of 13 Comment number
Appendix C—Public Involvement 191 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

7-3. Your comments are outside of the scope of the 

CCP. We disagree that hunting animals is inconsistent with the purposes and goals of the refuge. Please see the response to comment 7-2.

7-4. Regarding hunting, please see the response to 

comment 7-2. Regarding lead effects, please see response to comment 6-3.

Page 3 of 13

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PROPOSED ACTIONS ARE NOT COMPATIBLE WITH THE MISSION OF THE 

NATIONAL ELK REFUGE 

FWS cannot authorize recreational activates that are not compatible with the 

conservation mission of the Refuge. See 16 U.S.C. 668dd. The term "compatible use" 

means “a wildlife-dependent recreational use or any other use of a refuge that, in the 

sound professional judgment of the Director, will not materially interfere with or detract 

from the fulfillment of the mission of the System or the purposes of the refuge.” 16 USCS 

§ 668ee (emphasis added). Additionally, in developing comprehensive conservation

plans, FWS must identify and describe “significant problems that may adversely affect

the populations and habitats of fish, wildlife, and plants within the planning unit and theactions necessary to correct or mitigate such problems.” 16 USCS § 668dd(E). Artificialmanagement of wildlife, including feeding and hunting animals as proposed in theConservation Plan, are inconsistent with the purposes and goals of the Refuge andadversely affect wildlife on the Refuge.

Hunting 

All action alternatives proposed in the EA increase hunting on the refuge, and the 

proposed Conservation Plan makes significant changes that are not compatible with the Refuge’s conservation goals. In particular the proposed Conservation Plan would: deny elk access to “safe zones” in the refuge (EA at 170); expand hunting opportunities for 

young people, possibly adding a week after the end of the regular elk season; consider creating more hunting opportunities for species other than elk and bison; open currently closed areas to archery hunters; increase overall hunter access; and create designated parking lots for hunters (EA at 266). 

Although the National Wildlife Refuge System Improvement Act contemplates 

that hunting could be a compatible use on some national refuge areas, FWS is still required to make an individual compatibility determination for each recreational use and change or modification provided for in the Conservation Plan. 16 U.S.C. 668dd. The EA claims that hunting is not incompatible with the purpose of the Refuge “based on 

anticipated biological effects described above and in the EA.” However, the EA does not 

disclose the anticipated biological effects of hunting, or increasing hunting, on the 

Refuge. The only alleged justification for hunting found in the EA is the claim that the habitat produces “surpluses” and that hunting is necessary for wildlife management. There is no evidence to confirm this statement. In fact, the practice of artificially feeding elk creates that this “surplus” is disrupting the natural diversity and health of wildlife 

populations. In the 2007 Elk and Bison Management Plan, FWS rejected a plan to phase 

out the supplemental feeding program because it said the total Jackson elk and bison numbers could fall below Wyoming Game and Fish Department’s established objectives 

in some years. See FWS & National Park Service, Record of Decision for the Final Bison 

7-37-4

RESPONSE LETTER #7—Friends of Animals, page 3 of 13 Comment number
192 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 7-5. Your comments are outside of the scope of the CCP. The long-term goals and objectives of the Bison and Elk Management Plan are to reduce reliance on supplemental feeding and reduce transmission of den- sity-dependent diseases. The refuge and other agen- cies are currently engaged in an adaptive management 

planning process to reduce reliance on supplemental feeding on the refuge. This process is a stepdown plan of the Bison and Elk Management Plan. Strategies to mitigate the comingling of elk and bison with livestock will be part of the adaptive management plan. 

Page 4 of 13

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and Elk Management Plan. The practice of feeding wildlife to create larger populations than the area can support, and then shooting them as part of a “management” program perpetuates a destructive cycle that not only disturbs the natural balance of the Refuge, but also places the wildlife at a high risk for disease that could wipe out the very animals that Refuge was created to protect. 

Moreover, the disturbance of increased hunters in the Refuge, as well as the 

danger and lasting impact that they leave behind, including lead shots, is incompatible with the mission of the Refuge. The EA admits, and research confirms, the negative effect of lead ammunition (used by 60-80 percent of hunters on the Refuge) on 

scavenging bird populations such bald eagles and ravens (EA at 139; see also Pain, Fisher 

and Thomas 2009). The fact that hunting practices injure species of concern that the 

Refuge was intended to protect is further evidence that hunting should not qualify as a compatible use. 

Supplemental feeding Program 

While winter feeding fuels hunting opportunities on the Refuge by sustaining elk 

in numbers beyond available habitat and social constraints, this short-sighted management system is fraught with biological and ecological problems. The winter feeding serves neither the long-term health nor conservation of wildlife, and therefore is 

not consistent with the Refuge’s purpose. Nor is it based on a sound scientific principles and sustainable resource management policy, as required by the National Wildlife Refuge System Improvement Act. See 16 USCS § 668ee. 

The supplemental feeding practice interrupts natural migrations, destroys 

habitats, and feeds the perception that hay can be substituted for habitat (Smith 2001, 

2011). The supplemental feeding program also causes the animals to unnaturally 

congregate in a small area and significantly increases the risk of disease transmission. 

Abundant hosts packed close together creates an ideal environment for most pathogens 

to persist, spread, and to develop even more successful forms (McNeil 1989). A recent 

study comparing physiology of elk on 19 Wyoming feed grounds to 11 unfed, freeranging populations in Montana and Wyoming found that glucocorticoid concentrations (steroidal hormones that are escalated by inflammation and stress) excreted in feces of 

feed ground elk were 31-43 percent higher than among unfed elk. Likewise, rates of 

aggression increased significantly when elk were artificially fed (Forristal et al. 2011). Given the harmful effects that chronically elevated glucocorticoids have on immune function of mammals (Becker 2002), feeding may exacerbate diseases like scabies, 

hemorrhagic septicemia, foot rot, and bovine brucellosis of elk (Peterson 2003). 

Animal density also elevates the risk of Chronic Wasting Disease (CWD) 

transmission and infection rates in wild populations (Williams et al. 2002). A study in 

7-5

RESPONSE Comment number LETTER #7—Friends of Animals, page 4 of 13
Appendix C—Public Involvement 193 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

7-6. The issues that you discuss were analyzed using 

an EIS process in the Bison and Elk Management Plan and EIS (FWS and NPS 2007b). Proposed changes to hunting programs outlined in the CCP are relatively minor, and the EA process is sufficient to evaluate their effects.

Page 5 of 13

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Rocky Mountain National Park led researchers to infer that high density elk populations support relatively high rates of CWD and may substantially affect the dynamics of such populations (Monello et al. 2013). 

The claim that feeding is implemented to reduce the transmission of disease to 

livestock is not supported by sound management practices. First, the Refuge should base its policy on the interests of wildlife and not the desires of ranchers outside the Refuge. 

Second, the supplement feeding program actually increases the risk of disease and many states have actually banned winter feeding or baiting by citizens to reduce the transmission of both CWD and bovine tuberculosis (Dunkley and Cattet 2003). 

FWS SHOULD CONSIDER ITS OBLIGATIONS UNDER THE NATIONAL 

ENVIRONMENTAL POLICY ACT 

FWS Should Prepare in Environmental Impact Statement 

The fundamental purpose of NEPA is to improve the decision making of federal 

agencies by requiring an analysis of the environmental impacts of a proposed action and an exploration of alternatives to that action that would reduce or eliminate such impacts. 42 U.S.C. § 4332. The primary vehicle for this analysis is an Environmental Impact Statement (EIS). The EIS is the cornerstone of NEPA, and is required for all “major 

Federal actions significantly affecting the quality of the human environment.” 42 U.S.C. § 

4332(2)(C). The requirement to prepare an EIS is broad and intended to compel agencies to take seriously the potential environmental consequences of a proposed action. The Council on Environmental Quality (CEQ) defines “major federal action” to include “actions with effects that may be major and which are potentially subject to Federal control.” 40 C.F.R. § 1508.18 (emphasis added). 

Whether an agency action is “significant” enough to require preparation of an EIS 

requires “considerations of both context and intensity.” 40 C.F.R. § 1508.27. The context 

of the action includes factors such as “society as a whole (human, national), the affected region, the affected interests, and the locality.” 40 C.F.R. § 1508.27(a). Intensity “refers to the severity of the impact” and requires several factors to be considered, including: beneficial and adverse impacts, how the proposed action affects public health or safety, the unique characteristics of the geographic area affected, the controversial nature of the action, the degree to which the action may establish a precedent for future actions, the 

effect of the action an endangered or threatened species, and whether the action is related to other actions with individually insignificant but cumulative significant impacts. 40 C.F.R. §1508.27(b). 

The context and intensity of the proposed action in this case indicate that it is 

significant enough to require an EIS. First, the effects on the quality of the human 

environment are significant on a local, regional, and national level. The Refuge attracts 

7-6

RESPONSE LETTER #7—Friends of Animals, page 5 of 13 Comment number
194 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 7-7. Based on the purpose of the refuge, the require- ments in the Improvement Act, and other applicable laws, regulations, and policies, a full range of reasonable alternatives was considered. The planning team 

conducted several workshops involving staff and other professionals, mailed out planning updates, posted information on our 

Web site, held a public meeting, listened to public comment, and analyzed the biological, 

visitor use, and socioeconomic data before determining the options for future management. 

Page 6 of 13

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people from across the world. The primary reason that people come to the Refuge is to view the wildlife and unique habitat that is at issue in this Conservation Plan. 

Second, the severity of the impacts warrant preparation of an EIS. The 

Conservation Plan is highly controversial, as an increasing portion of Americans oppose 

hunting. See Smith 2011 at 216. The EA’s plan to target young people for hunting is also 

highly controversial due to potential public health and safety concerns. Moreover, the proposed action occurs on a critical geographic area with unique wildlife viewing opportunities. Because many of the hunters use lead-based ammunition, the continuation of this program could harm threatened and endangered species found on the Refuge. Lastly, the Conservation plan will likely last for 10 to 15 years and have precedential affect for continued management of the Refuge. 

The significance of the action, the unique environment, the impact on threatened 

or endangered species, and the controversial nature of the proposed Conservation Plan 

all indicate that it constitutes a major federal action. Thus, FWS should prepare an EIS to inform decision-makers and the public of all the reasonable alternatives and impacts associated with the Draft Comprehensive Conservation Plan. 

EA Failed to Include Adequate Range of Alternatives 

Environmental assessments and environmental impact statements should 

provide a full and fair discussion of the issues, and inform decision makers and the public of the reasonable alternatives that would avoid or minimize adverse impacts or enhance the quality of the human environment. See 40 C.F.R. § 1502.1. The EA at issue here only contains three action alternatives with little variation, and excludes reasonable alternatives. For example, none of the alternatives eliminate or even reduce hunting in the Refuge, and all three action alternatives consider expanding hunter access on the Refuge and eliminating sanctuaries on the Refuge where hunting is currently prohibited (EA at 85). The EA’s limited alternatives inhibit the decision making process and prevent the public from making meaningful comparisons and comments. 

In order to make an informed decision and fulfill the requirements of NEPA, FWS 

should consider and compare a broader range of alternative including: eliminating hunting on the Refuge, phasing out the supplemental feeding programs, and ensuring adequate habitat for species on the Refuge. While these are reasonable alternatives that would likely benefit wildlife on the Refuge and the American public, the Draft EA does not include them. 

The EA’s focus on hunting over other non-consumptive wildlife dependent 

activities does not reflect the best interest of the wildlife in the Refuge, nor does it reflect the interest of the public. Despite the EA’s visitor service goal to reach a diverse audience to understand and appreciate the refuge’s wildlife conservation role, the 

7-7

RESPONSE LETTER #7—Friends of Animals, page 6 of 13 Comment number
Appendix C—Public Involvement 195 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

7-8. The impact of hunting was adequately analyzed in 

the Bison and Elk Management Plan and EIS. The 500 bison objective was not arbitrary. The 500 bison population level was deemed sufficient to maintain genetic diversity, and the Bison and Elk Management Plan does not preclude the introduction of a small number of bison from other populations to ensure continued genetic diversity should it be deemed necessary. 

Page 7 of 13

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alternatives focus on a small interest group – hunters. For example, while the EA 

provides for hunting opportunities to accommodate disabled people, it does not 

prioritize updating the visitor center1 which lacks sufficient accommodations for 

persons with physical disabilities and does not meet the requirements of the Architectural Barriers Act Accessibility Standard (United States Access Board 2013) (EA 142). Additionally, the preferred action eliminates “safe zones” where people could view animals in areas not subject to hunting. The proposed plan also opens access to hunters, but imposes more limits on commercial wildlife-viewing tours to reduce road congestion and wildlife disturbance (EA at 61). This makes little sense when hunters also contribute to congestion and are far more disruptive to wildlife, as the goal of their activity is to kill and remove wildlife in the Refuge. 

The EA also attempts to involve youth in hunting activities. However, a study of 

children ages 8 to 17 done by the gun industry itself found that, much to their dismay, hunting is actually considered an unfavorable pastime among the majority of America’s youth. Nearly 50% of the young participants in the nationwide survey said they had “strongly to moderately” negative opinions about hunting and target shooting.2 While the hunting and gun industry may find this unacceptable because they consider children to be a portion of the population with huge profit-making potential, the Conservation Plan should not cater to the interests of the gun and hunting industries by furthering their campaign to engage youth in hunting. 

The EA should instead focus on non-hunting activities, as less Americans are 

hunting and a growing number disapprove of the practice. The vast majority of people who visit the park are not there to hunt. In 2001, 780,299 visitors participated in onsite interpretation and nature observation. EA at 141. In comparison, only 2,116 hunting permits were issued on average from 1997 to 2001. EA at 140. While hunting is allowed 

on the vast majority of public lands, FWS should try to preserve the Refuge as a haven for wildlife and a place that people can go to view wildlife in area safe from hunting. 

The EA Failed to Include Adequate Impact Analyses 

Under NEPA, FWS has an obligation to identify and disclose to the public all direct, 

indirect, and cumulative impacts of the proposed action and each reasonable alternative, 

(42 U.S.C. § 4332(2)(C); 40 C.F.R. §§ 1502.16, 1508.7 – 1508.8). Here, the EA is vague and 

the alternatives are not adequately described and analyzed. FWS should issue an EIS 

1 The Visitor Center, on the southern end of the refuge, plays a critical role in Jackson’s 

tourism-based economy, serving approximately 300,000 people each year and providing a wide range of visitor services. 

2 Meg McIntire, Putting Kids in the Crosshairs, Actionline (Fall 2013). Available from http://friendsofanimals.org/magazine/fall-2013/putting-kids-crosshairs. 

7-8

RESPONSE LETTER #7—Friends of Animals, page 7 of 13 Comment number
196 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page 8 of 13

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that adequately describes the impacts of all alternatives, including the impacts of 

hunting and supplemental feeding. 

 Impact of Hunting 

 The EA fails to consider how increased hunting will affect the distribution, 

migration patterns, and abundance of fish, wildlife, and plant populations in the Refuge. It does not analyze the health or viability of the elk or bison herds or how increased hunting access will disturb individual animals and the entire population. Nor are these issues adequately addressed in the Refuge’s Elk and Bison Management Plan. 

Bison in the greater Yellowstone area, including the Jackson bison herd, are the 

last remnants of the extensive wild herd that once roamed much of North America. If FWS continues to allow hunting of bison in the Refuge, it could damage the viability of the bison herds and cause long-lasting, irreparable damage to the herds. 

According to Gates et al., “the primary threat to long-term preservation of the 

herd is a loss of genetic diversity that can be very difficult, if not impossible, to restore. Therefore, thorough genetic evaluation [] is necessary before, during, and after planned large-scale herd reductions.” (2010 at 93). The Refuge arbitrarily set a population 

objective of 500 bison, which could significantly harm the genetic viability of these iconic 

animals. As protecting a minimum of 2,000 bison in each distinct bison subpopulation is considered a minimum for each population segment to retain genetic diversity over a 

200-year time period (Gross and Wang 2005; Gross et al. 2006). 

Maintaining sufficiently high levels of genetic diversity within the Refuge’s 

wildlife populations, as might be found within a natural population, is essential to ensuring that sufficient variation exists to allow the species to naturally evolve and adapt to a changing environmeny and retain important survival traits like natural migration and selection. However, the EA completely fails to consider the impact of the hunting program on the wildlife in the Refuge. 

The EA also vaguely states it will consider allowing hunters to kill other species in 

the Refuge, but does not mention what those species would be or how much hunting would be allowed. It is impossible to assess the impacts of this action without more information. 

Finally, the EA failed to adequately discuss many of the negative indirect effects of 

hunting, including: excessive disturbance to wildlife, damage to habitat, and conflicts 

with other visitor services and experiences. 

RESPONSE LETTER #7—Friends of Animals, page 8 of 13 Comment number
Appendix C—Public Involvement 197 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

7-9. Please see response to comment 6-3.7-10. In the interests of public health and safety, the 

State of Wyoming requires all hunters born on or after Jan 1, 1966, to take a hunting education class that strongly emphasizes firearm safety. The State also requires all hunters under the age of 14 to be accompanied by an adult who has passed this class or who has secured a big game license within the last 5 years.

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Impact to Threatened Species and Species of Conservation Concern 

The EA failed to adequately discuss the impact of the Conservation Plan on 

threatened or endangered species, and other species of concern. The EA estimates that more than 60% of hunters would not use lead-free ammunition (EA at 76). However, the EA failed to assess the impact that this would have on wildlife, nor did it propose any mitigation measures. Even though there is research to indicate lead ammunition can 

cause significant harm to waterfowl, raptors, and other animals of conservation concern in the Refuge. See Pain, Fisher, & Thomas 2009. 

It is also possible that the proposed Conservation Plan could disturb listed 

species under the Endangered Species Act, such as the grizzly bear. The EA mentions that FWS conducted a biological evaluation per section 7 of the Endangered Species Act, but it has not made that document available for public review. FoA requests FWS make that document available along with an EIS, so that we can make a more informed comment regarding the impact of the proposed action on grizzly bears. 

Public Health and Safety Impacts The proposed action would expand hunting opportunities for young people, 

possibly adding a week after the end of the regular elk season and adding mentoring programs for young hunters. The EA should consider the public health and safety impacts of expanding hunting and encouraging youth hunting on the Refuge. 

Federal data from the Centers for Disease Control indicate that between 2007 and 

2011, an average of 62 children age 14 and under were accidentally shot and killed each 

year.3 According to a study by Everytown for Gun Safety, two children die almost every 

week in unintentional shootings according to a new study. 4 Despite the raising concerns 

about hunting and gun safety in America, there is no analysis in the EA of the impacts of new youth targeted hunting programs. 

Cumulative Impacts If an agency is involved in several actions which, cumulatively, have a significant 

impact on the environment, then these actions should be considered in the same 

environmental document. See 40 C.F.R. § 1508.25(a)(2). Additionally, if agency actions 3 See DeFilippis, E. & Hughes, D. (2014, June 17). Guns Kill Children. Slate. Available from: http://www.slate.com/articles/health_and_science/medical_examiner/2014/06/gun_deaths_in_children_statistics_show_firearms_endanger_kids_despite_nra.html4 See DiBlasio, N. (2014, June 25). Report: More kids die in shootings than statistics show. 

USA Today. Retrieved from: 

http://www.usatoday.com/story/news/nation/2014/06/25/death-child-unintentionalshooting/11324717/ ; http://everytown.org/article/innocents-lost/

7-97-10

RESPONSE Comment number LETTER #7—Friends of Animals, page 9 of 13
198 Comprehensive Conservation Plan—National Elk Refuge, Wyoming 7-11. Ethics are subjective. The general management philosophy of the Refuge System as determined by current law and policy is to manage for healthy and sustainable wildlife populations and the communities that sustain them. Under the Bison and Elk Management Plan, we are committed to reducing our reliance 

on supplemental feeding to ensure that in the long term, elk and bison populations are in balance with their habitat. This is our definition of healthy and sustainable. Achieving this goal requires reducing current elk and bison populations. Because hunting is a legislatively mandated priority public use, it is the management tool of choice to achieve our goal to reduce elk and bison numbers and reliance on supplemental feeding. Thank you for your comments.

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are similar in that they share common timing or geography, such actions should also be addressed in the same environmental document so as to assess adequately their combined impacts. See 40 C.F.R. § 1508.25(a)(3). Importantly, an agency may not segment actions to unreasonably restrict the scope of the environmental review process. See Foundation of Economic Trends v. Heckler, 756 F.2d 143, 159 (D.C. Cir. 1985). The 

Refuge supports the preservation of large landscapes and migratory animals. With many of these animals imperiled around the globe to due climate change, human development, and habitat destruction, it is important to consider all impacts that could affect the wildlife and habitat at the Refuge. The EA analysis is generally vague and superficial, 

and it fails to consider the cumulative impacts for all actions. For example, it defers to 

the objectives set in the Elk and Bison Management plan, but does not analyze the impact of that plan. Additionally, the EA often includes a combination of all alternatives for the proposed action, but fails to provide an independent analysis of the cumulative 

impact when combining the alternatives. See e.g., EA at 163. 

Ethical Impacts 

 It is time for FWS to recognize that individual animals that may be subject to its actions have intrinsic value and this in turn demands that FWS incorporate ethics into its consideration of wildlife management activities. There is a growing recognition among conservationists and biologists that ethics must play a greater role in wildlife policy. See, e.g., Fox & Bekoff, Integrating Values and Ethics into Wildlife Policy and Management—Lessons 

from North America, 1 Animals 126-143 (2011). But as Fox and Bekoff point out: “[w]hile many agree that ethics must play a central role in any project involving [animals], it is often interesting to note that in many books on human-animal interactions . . . there is often no mention of ethics. This needs to change.” Id. at 129. The same must be said for the regulation of animals.  Undoubtedly, discussions in the context of policy development about ethics and animals can make some people uncomfortable. But, of course, just a generation ago it was also unheard of for an agency like FWS to incorporate the humane treatment of animals into its decision-making process. This has changed dramatically. Inclusion of ethical impacts and considerations allows federal, state, and local decision-makers, as well as the public, to better understand the impact of human actions on animal welfare, and allows for better decisions to be made.  Our generation needs to adopt the same approach to educating the decision-makers and the public as to the role of ethics in making decisions to “manage” animals. Indeed, it is our jobs as conservationists, animal advocates and scientists “to work toward public education and information dissemination to address real and perceived fears held” by others. 

Id. at 128. What is missing in FWS’s EA, is the viewpoint of the animals. Again, from Fox and Bekoff: 

7-11

RESPONSE LETTER #7—Friends of Animals, page 10 of 13 Comment number
Appendix C—Public Involvement 199 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page 11 of 13

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The growing body of literature on animal cognition and emotions demonstrates undeniably that animals have interests and points of view. Like us, they avoid pain and suffering and seek pleasure. They form close social relationships, cooperate with other individuals, and likely miss their friends when they are apart. Emotions have evolved, serving as “social glue,” and 

playing major roles in the formation and maintenance of social relationships among individuals. Emotions also serve as “social catalysts,” regulating behaviours that guide the course of social encounters when individuals follow different courses of action, depending on their situations. If we carefully study animal behaviour, we can better understand what animals are experiencing and feeling and how this factors into how we treat them. 

Id. at 131. 

The EA fails to include a serious discussion of the ethical implications of the proposed 

action, including hunting animals on the Refuge. 

FWS should prepare an EIS that includes a legitimate discussion of ethics and the 

rights of wildlife in order to assist the public and decision makers in fully considering the best alternative to choose. This approach would be consistent with the purposes of 

NEPA. 

Thank you for the opportunity to comment on this Draft EA. FoA hopes that you 

will reconsider the legal and ethical impacts of the proposed actions and prepare an EIS before approving a Final Comprehensive Conservation Plan for the National Elk Refuge. 

Sincerely, Jenni Barnes Associate Attorney Wildlife Law Program Friends of Animals Western Region Office 7500 E. Arapahoe Road, Suite 385 Centennial, Colorado 80112 jenniferbarnes@friendsofanimals.org 720-949-7791 

 Jenni Barnes

RESPONSE Comment number LETTER #7—Friends of Animals, page 11 of 13
200 Comprehensive Conservation Plan—National Elk Refuge, Wyoming Page 12 of 13

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References 

Becker, J. B. (Ed.). (2002). Behavioral endocrinology. MIT Press. DeFilippis, E. & Hughes, D. (2014, June 17). Guns Kill Children. Slate. Available from: 

http://www.slate.com/articles/health_and_science/medical_examiner/2014/06/gun_deaths_in_children_statistics_show_firearms_endanger_kids_despite_nra.html

DiBlasio, N. (2014, June 25). Report: More kids die in shootings than statistics show. USA 

Today. Retrieved from: 

http://www.usatoday.com/story/news/nation/2014/06/25/death-childunintentional-shooting/11324717/ ; http://everytown.org/article/innocentslost/ 

Dunkley, L., & Cattet, M. R. L. (2003). A comprehensive review of the ecological and 

human social effects of artificial feeding and baiting of wildlife. Canadian 

Cooperative Wildlife Health Centre: Newsletters & Publications, 21. 

Etter, R. P. & Mark L. Drew, M. L (2006). Brucellosis in Elk of Eastern Idaho. Journal of 

Wildlife Diseases: April 2006, Vol. 42, No. 2, pp. 271-278

Fisher, I. J., Pain, D. J., & Thomas, V. G. (2006). A review of lead poisoning from 

ammunition sources in terrestrial birds. Biological conservation, 131(3), 421-432. 

Forristal, V. E., Creel, S., Taper, M. L., Scurlock, B. M., & Cross, P. C. (2012). Effects of 

supplemental feeding and aggregation on fecal glucocorticoid metabolite concentrations in elk. The Journal of Wildlife Management, 76(4), 694-702.

Fox, C. H., & Bekoff, M. (2011). Integrating values and ethics into wildlife policy and 

management

—lessons from North America. Animals, 1(1), 126-143. 

Gross, J.E. and G. Wang. (2005). Effects of population control strategies on retention of 

genetic diversity in National Park Service bison (Bison bison) herds. National 

Park Service. Unpublished report. 

Gross, J.E., G. Wang, N.D. Halbert, P.A. Gogan, J.N. Derr, and J.W. Templeton. (2006). 

Effects of Population Control Strategies on Retention of Genetic Diversity in National Park Service Bison (Bison bison) Herds. Revised Final Report Submitted to Yellowstone Research Group, USGS-BRD, Department of Biology, Montana State University, Bozeman, MT. 

Gates, C. C., Freese, C. H., Gogan, P. J., & Kotzman, M. (2010). American bison: status survey 

and conservation guidelines 2010. IUCN. 

McIntire, M. (2013, Fall) Putting Kids in the Crosshairs. Actionline. Retrieved from

http://friendsofanimals.org/magazine/fall-2013/putting-kids-crosshairs. 

McNeill, W. H., & Kindleberger, C. P. (1989). Control and Catastrophe in Human Affairs. 

Daedalus, 1-15.

RESPONSE LETTER #7—Friends of Animals, page 12 of 13 Comment number
Appendix C—Public Involvement 201 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2

Page 13 of 13

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 WILDLIFE LAW PROGRAM  7500 E. ARAPAHOE ROAD SUITE 385  CENTENNIAL, CO 80112  T 720 949 7791 FRIENDSOFANIMALS.ORG

Monello, R. J., Powers, J. G., Hobbs, N. T., Spraker, T. R., O'Rourke, K. I., & Wild, M. A. 

(2013). Efficacy of antemortem rectal biopsies to diagnose and estimate prevalence of chronic wasting disease in free-ranging cow elk (Cervus elaphus 

nelsoni). Journal of Wildlife Diseases, 49(2), 270-278.

Pain, D. J., Fisher, I. J., & Thomas, V. G. (2009). A global update of lead poisoning in 

terrestrial birds from ammunition sources. Ingestion of Lead from Spent 

Ammunition: Implications for Wildlife and Humans. The Peregrine Fund, Boise, Idaho, 99-118. 

Peterson, M. J. (2003). Infectious agents of concern for the Jackson Hole elk and bison 

herds: an ecological perspective. College Station, Texas, USA: Department of Wildlife and Fisheries Sciences, Texas A&M University. 

Smith, B. L. (2001). Winter feeding of elk in western North America. The Journal of 

Wildlife Management, 173-190. 

Smith, B. L. (2011). Where Elk Roam: Conservation and Biopolitics of Our National Elk 

Herd. Globe Pequot. 

Williams, E. S., & Miller, M. W. (2002). Chronic wasting disease in deer and elk in North 

America. Revue scientifique et technique (International Office of Epizootics), 21(2), 305-316.

RESPONSE LETTER #7—Friends of Animals, page 13 of 13 Comment number
202 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 1 of 9 October 24, 2014 U.S. Fish and Wildlife Service Attn: Toni Griffin, Planning Team Leader 134 Union Boulevard, Suite 300 Lakewood, CO 80228 Re: National Elk Refuge Comprehensive Comprehensive Plan Please accept these comments on behalf of the Greater Yellowstone Coalition (GYC). GYC has over 48,000 supporters and constituents who support our mission of protecting the lands, waters and wildlife of the Greater Yellowstone Ecosystem (GYE), now and for future generations. The GYC was founded in 1983 on a simple premise: An ecosystem will remain healthy and wild only if it is kept whole and we advocate for the idea that ecosystem level sustainability and science 

should guide the management of the region’s public and private lands. This vast ecosystem includes 20 million acres of wild country that includes Yellowstone and Grand Teton National Parks, parts of six national forests, five national wildlife refuges, and state and private lands in Wyoming, Idaho, and Montana. The Greater Yellowstone Coalition works to ensure that a thoughtful and holistic approach is taken to managing the national and wildlife resources in harmony with people and modern development. We work to shape a future where wildlife populations maintain their full diversity and vitality, where ecological processes function on public lands with minimal intervention, where exceptional recreational opportunities abound for visitors and residents alike, and where communities can enjoy a healthy and diversified economy. Principals behind GYC’s comments 

GYC has a history of advocating for better management on the National Elk Refuge (NER) including reducing artificial concentrations of elk and bison and the phaseout of supplemental 
Appendix C—Public Involvement 203 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 2 of 9

feeding. We also provided comments during the scoping period for the Comprehensive Conservation Plan (CCP) on November 22, 2010. The National Wildlfe Refuge System Improvement Act requires that the U.S. Fish and Wildlife Service administer refuge lands to “provide for the conservation of fish, wildlife, and plants, and their habitats within the System” and to “ensure that the biological integrity, diversity, and environmental health of the System are maintained for the benefit of present and future generations of Americans.” 1 Conservation is defined as requiring the Service “to sustain and, 

where appropriate, restore and enhance, healthy populations of fish, wildlife, and plants utilizing, in accordance with applicable Federal and State laws, methods and procedures associated with modern scientific resource programs.” This direction requires management of the NER in a way that is ecologically sustainable into the future. The National Elk Refuge lies geographically in the center of the GYE and is literally in the town of Jackson’s backyard. It is integral to the quality of life of Jackson’s residents and also to the diversity of the flora and fauna of the ecosystem. One of the remarkable things about the NER is that for most of the year the refuge is completely free of human presence allowing for one of the few locations within the ecosystem where ecological processes are unimpeded by human actions. This value should be highlighted in the final CCP. The available human recreation, whether fly fishing on Flat Creek, elk hunting, or wildlife watching are all significantly enhanced by this management of human access. Many of our members and staff participate and greatly enjoy all of these activities at their current levels and feel that further expansion will degrade my experience. There is a pervasive management regime that limits the NER’s ability to meet the above requirements under the National wildlife Refuge System Improvement Act: Supplemental feeding of elk and bison. While the CCP does not address supplemental feeding or provide any management recommendations, actions, or environmental consequences as a result of supplemental feeding, it does span the life of the 2007 Elk and Bison Management Plan/EIS. Supplemental feeding directly limits the applicability of management actions within the proposed alternatives, such as improving riparian habitats, enhancing sagebrush communities, and aspen regeneration. The August 3, 2011 Federal Appeals Court decision 2 noted that “There 

is no doubt that unmitigated continuation of supplemental feeding would undermine the conservation purpose of the National Wildlife Refuge System.” Further, “over a fifteen-year period, “[a]s habitat and population objectives are achieved, [the agencies will aim to] decrease reliance on intensive the supplemental winter feeding, including complete transition to freestanding forage if and when several established criteria are met, including support from the Wyoming Game and Fish Department and the public.” Therefore we believe it would be timely to provide an analysis of the proposed actions within the CCP in light of progress made within the 15-year Elk and Bison Management Plan. At the end of 

1 16 U.S.C§668dd(a)(4)(A),(B)2 Defenders of Wildlife vs. Salazar. Case No. 10-5144 
204 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 3 of 9 8-1 8-2 the 15-year period, within the life of the CCP, some of the elements within Alternative C, emphasis on intact ecosystems and natural processes, could be more realistically attained within the preferred alternative including; landscape-scale conservation, benefits to native grasslands and sagebrush shrublands, wetlands, aspen habitats, migratory birds, and most importantly disease management. GYC supports the implementation of a CCP, but we believe that supplemental feeding is still the dominant paradigm on the landscape and providing a progress report on implementation of the Elk and Bison Management Plan is relevant to the application and benefits of having a CCP completed. Thus we offer our support for Alternative C, or adding some of the actions proposed in Alternative C included within the final preferred alternative. Support for Landscape-Scale Conservation GYC is very supportive of the Landscape-Scale Conservation efforts outlined in the CCP. There are great benefits to both the local community and ecosystem in collaborative efforts to protect valuable wildlife habitat beyond the boundaries of the NER. We offer our support in potential partnerships to realize these goals, particularly in protecting wildlife migration corridors. We also support the expansion of the refuge acquisition boundary into the proposed areas of Twin Creek and Spring Gulch to recognize these objectives. These efforts may recquire additionial staff capacity or reapportionment of time to meet these goals as well as working closely with non-governmental organizations and conservation groups, such as GYC. One issue that GYC is currently working on closely with our conservation partners is the possibility of utilizing wildlife crossings in promoting landscape scale conservation. The inclusion of wildlife crossings in the final preferred alternative is critical for moving wildlife crossings from concepts to completed projects. It should be included in the analysis of environmental consequences that the elk-proof fence along US HWY 89/28/191 is a significant 

barrier, currently, to landscape-scale connectivity and to connectivity on a local scale to NER property east of the highway. Also, the volume of traffic on the highway limits even one directional movements of wildlife onto the refuge with frequent wildlife vehicle collisions. Wildlife crossings will have real benefits for species such bighorn sheep, mule deer, elk, and potentially pronghorn as well as carnivores, small mammals, and even sage grouse. Reestablishing connections for species of concern, particularly bighorn sheep, to native winter ranges could provide great benefits by expanding the current limited wintering capacity of the available habitat to public and private lands that are under permanent easement east of the NER. Wildlife crossings may also mitigate impacts to migrating wildlife from the pedestrian pathway that is annually visited for closure dates and receives a great deal of public scrutiny. On a localscale crossings will connect the isolated parcels of the NER and promote additional winter range to species of conservation concern. On a larger landscape-scale, crossings will directly benefit wildlife migrations and the potential for long distance dispersing species to navigate a diverse landscape of public and private lands between large protected landscapes within Grand Teton National Park and Bridger-Teton National Forest Lands. 

8-1. Thank you for your comments.8-2. The CCP often serves—and in this case does 

serve—as an umbrella document that states in the preferred alternative, “Consider partnerships to build wildlife crossings over Highway 89.” The refuge has initiated the process of investigating wildlife crossing options for Highway 89 to improve landscape connectivity. A detailed analysis of this issue, which will include expertise from the Western Transportation Institute–Montana State University, will explore options for consideration.
Appendix C—Public Involvement 205 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 4 of 9

8-3 8-3. Please see the response to comment 6-6.

We are extremely supportive of these actions and are actively working on partnerships to make these visions a reality for Jackson Hole. We ask that steps towards meeting this objective such as completing an analysis of NER roadways and mitigation strategies and strategies for creating partnerships to implement wildlife crossings, be included in Chapter 6. Climate Change Climate change is the most significant long-term threat to the Greater Yellowstone Ecosystem and to the integrity of the NER. It is also one of the most difficult to address in planning efforts because of its scale and limits within agency direction. However, there have been several significant policy directives and strategy documents that would be beneficial to include within the CCP.On December 20, 2012, the Department of Interior issued a directive in climate change policy. 3 That policy states: “1.4. It is the policy of the Department to effectively and efficiently adapt to the challenges posed by climate change to its mission, programs, operations, and personnel. The Department will use the best available science to increase understanding of climate change impacts, inform decision making, and coordinate an appropriate response to impacts on land, water, wildlife, cultural and tribal resources, and other assets. The Department will integrate climate change adaptation strategies into its policies, planning, programs, and operations, including, but not limited to, park, refuge, and public land management; habitat restoration; conservation of species and ecosystems; services and support for tribes and Alaska Natives; protection and restoration of cultural, archeological and tribal resources; water management; scientific research and data collection; land acquisition; management of employees and volunteers; visitor services; construction; use authorizations; and facilities maintenance.” While the CCP does consider climate change, we feel there is an additional step in the planning process to adequately implement the DOI policy. Specific examples within this policy to consider are: (7) Use well-defined and established approaches, as appropriate, for managing through uncertainty, including: (1) vulnerability assessments, (2) scenario planning, (3) adaptive management, and (4) other risk management or structured decision making approaches. The Department’s Adaptive Management Implementation Policy is provided in 522 DM 1. (8) Avoid “maladaptive” actions, that is, actions intended to avoid or reduce vulnerability to climate change that negatively impact or increase the vulnerability of other systems, sectors, or social groups. (9) Promote landscape-scale, ecosystem-based management approaches to enhance the resilience and sustainability of linked human and natural systems. (10) Advance approaches to managing linked human and natural systems that help mitigate the impacts of climate change, including: (a) Protect diversity of habitat, communities and species; (b) Protect and restore core, unfragmented habitat areas and the key habitat linkages among them; (c) Anticipate and prepare for shifting wildlife movement patterns; 3 http://www.fws.gov/mountain-prairie/science/documents/Climate%20Change%20Policy_DM_523.pdf 
206 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 5 of 9 8-4 8-5 8-6

8-7

(d) Maintain key ecosystem services; (e) Monitor, prevent, and slow the spread of invasive species (defined in Executive Order 13112 as alien species whose introduction does or is likely to cause economic or environmental harm or harm to human health); and (f) Focus development activities in ecologically disturbed areas when possible, and avoid ecologically sensitive landscapes, culturally sensitive areas, and crucial wildlife corridors. This directive contains some considerations that would benefit the CCP, particularly protecting diversity of habitat, community, and species, avoiding maladaptive actions (such as water diversions), providing vulnerability assessments, and finally protecting and restoring core unfragmented habitat areas and key habitat linkages. We applaud the efforts of the NER to restore and improve aquatic habitats along Flat Creek with agency and non-governmental organizations. We encourage the NER to consider similar future restoration projects for aspen communities, wetland communities beyond Flat Creek, and utilizing wildland fire to restore habitats. We ask the NER to consider the effects of water diversion structures on the Gros Ventre River beyond the refuges boundaries. Connecting the Gros Ventre River drainage with the mainstem Snake River year-round could be considered a climate change adaptation strategy and have real benefits to natural wetlands. We hope additional attention to water diversion and actions to wetlands and natural flow systems of Flat Creek and the Gros Ventre River can be included in the final preferred alternative. An additional example of climate change planning direction that could benefit the final CCP is a recent publication on climate change adaptation: National Fish, Wildlife and Plants Climate Change Adaptation Strategy 4 (NFWPCAS), with USFWS and NPS listed as co-contributors. This document has numerous examples of effective measures that should be implemented to offset and adapt to the impacts of climate change. The NFWPCAS has specific recommendations that are described as initial steps towards climate change adaptation that could be useful for incorporation into the CCP. For example Action 1.1.1 (page 58), “identify and map high priority areas for conservation using information such as species distributions (current and projected), habitat classification, land cover, and geophysical settings (including areas of rapid change and slow change).” The NFWPCAS report also lists coordination as a critical step in addressing climate change and species conservation in Strategy 3.2 (page 65): “Facilitate a coordinated response to climate change at landscape, regional, national, and international scales across state, federal, and tribal natural resource agencies and private conservation organizations.” We ask that the NER take steps to address this coordination in the final CCP.Bear spray and Lead-Free Ammunition Alternative C outlines actions that would require carrying bear spray and use of lead free ammunition. We ask that these two actions be included in the preferred alternative. Bear spray is known to be an effective method for avoiding dangerous confrontations (such as charging when encountered at a gutpile or carcass) in 92% of encounters where it’s used correctly. It has shown 4 http://www.fws.gov/refuges/vision/pdfs/PlanningforClimateChangeontheNWRS.pdf

8-4. Thank you for your comment.8-5. Thank you for your comment.8-6. As mentioned above, the CCP often serves as an 

umbrella document that provides general guidance and direction. For complex topics and issues such as climate change, a more detailed planning and implementation document will need to be developed that provides more detail than can be addressed in the CCP.

8-7. Although requiring hunters to carry bear spray 

will increase their expenses, this is not the sole consideration for this topic. See the explanation for the bear spray decision in response to comment 1-8.
Appendix C—Public Involvement 207 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 6 of 9

8-88-9

to be 98% effective at avoiding human injury. 5 Additionally, bear pepper spray is more effective 

at deterring attacks than firearms, with the added benefit that it is non-lethal to bears. Conversely, use of firearms solely to deter attacks result in bears being killed in 60% of studied encounters. 6

GYC is currently involved in a partnership with the NER to provide bear spray to hunters voluntarily during 2013 and 2014. Grizzly bears continue to expand their distribution in the GYE and are becoming more common on the NER in recent years, with more frequent observations occurring during hunting season correlated to the availability of an important food source in gutpiles and carcasses. The CCP recognizes the value of bear spray in reducing conflicts with bears (pg. 49) but then dismisses the requirement of carrying bear spray because of added costs to hunters. Meanwhile, bear spray is required for the concurrent elk reduction program that occurs in Grand Teton National Park, with many hunters participating in both. Bear spray is readily available in the community for purchase. Finally, bear spray is a fraction of the expense of the average hunter. Based on USFWS statistics from a 2011 survey of hunting participation, the average annual hunter expenditures in Wyoming are $1,960. 7 The average cost of bear spray is around $40, 

making the increase of about 2% for those hunters who haven’t already purchased spray. The CCP doesn’t provide any information on the numbers of hunters who already carry bear spray and this research should be included within Hunter Objective 2. One discrepancy we found in the document is that in the description of Alternative B (pg. 49) it discusses that the NER “would consider enacting a bear spray carry requirement.” However, in Table 4 (pg. 75), Alternative B describes encouraging carry of bear spray. We would encourage the language from Page 49 be implemented in the final preferred alternative and that Hunting Objective 2 include a transition from voluntary carrying of bear spray to requiring bear spray. One of the strategies that could be explored is continuing partnerships with NGO’s like GYC in providing bear spray to hunters through this transition. Similarly, the use of lead free ammunition is required for hunters on GTNP lands and voluntary programs have been ongoing. Currently, it is estimated that between 20-40% of hunters are already using lead-free ammunition (pg. 139). The CCP goes on to state that “The large harvest of elk and bison on the refuge and the resultant boon of gut piles has altered the migration patterns in bald eagles and potentially other raptors, placing a large number of these scavengers 

5 Smith, T. S., S. Herrero, T. D. DeBruyn, and J. M. Wilder. 2008. Efficacy of bear deterrent spray in Alaska. 

Journal of Wildlife Management 72:640–645.

6 Smith TS, Herrero S, Strong CL, Larsen RT, Johnson K. Efficacy of firearms for bear deterrence in Alaska. The 

Journal of Wildlife Management. 2012 Jul;76:1021-1027. 

7 U.S. Department of the Interior, U.S. Fish and Wildlife Service, and U.S. Department of Commerce, U.S. Census 

Bureau. 2011 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation. 

8-8. Thank you for pointing out the confusion between 

pages 49 and 75. The final CCP reflects that we will evaluate our bear spray policy in 5 years. Please see the response to comment 1-8 for additional information concerning bear spray.

8-9. Thank you for your detailed review of the CCP. 

The statement that “20 and 40 percent of refuge hunters use lead-free ammunition” is no longer accurate. The 2014 refuge hunting reports indicate that approximately 60 percent of successful elk hunters are voluntarily using non-lead ammunition. For additional information about lead-free ammunition, please see the response to comment 6-3.
208 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 7 of 9 8-10 at risk of ingesting lead from bullets in gut piles.” In the interest of the directives of the National Wildlife Refuge System Improvement Act to sustain healthy populations of fish, wildlife and plants, it would be a logical goal to seek 100% participation of use of lead free ammunition through an additional requirement of hunters. Concerns Over Expanded Opportunities One concern on the proposed actions in Alternative D is the possibility of increased hunting opportunities on the NER. This proposal, while it may be in line with the NWRSIA in increasing opportunities specific to youth and discretion for the Secretary to expand opportunities for waterfowl hunting when it wouldn’t impact conservation of other species, would be contradictory to other elements of both the Elk and Bison Management Plan and disease management actions. The CCP briefly mentions that opportunities could be expanded to “consider hunting of species other than elk and bison to address management needs.” (pg. 76). Within the environmental consequences, Alternative B states that “Nonhunters might be alienated because of more visible harvest in opened areas near Jackson, a bull elk harvest, and a predator harvest.” On page 170 the CCP states that “We may alienate some nonhunters with the more visible archery harvest in currently closed areas, a bull harvest that includes a trophy value, or the harvest of predatory species such as mountain lion or wolf. GYC’s concern here is that the NER is contemplating allowing a predator harvest. One of the remarkable resources of the NER is that it contains a full complement of native carnivores and due to its proximity to Grand Teton National Park, these carnivores have provided a tremendous resource to the community in increased tourism and wildlife watching. Large carnivores also have proven ecological benefits in that they have resumed the important role of maintaining healthy wildlife herds in the Northern Rockies by selecting young, old, physically impaired, or diseased animals. 8 By reducing prey numbers, dispersing these animals on the landscape, and removing sick animals, wolves also may reduce the transmission and 

prevalence of wildlife diseases such as chronic wasting disease (CWD) and brucellosis. 9

Researchers in Colorado modeled the potential for spread of CWD and overlap with wolf populations and found that wolf predation may suppress disease emergence or limit prevalence.10

Similarly, research in Colorado found that mountain lions selectively preyed upon CWD infected mule deer, suggesting that the presence of mountain lions may slow the rate of prion 

8 Mech L.D., D.W. Smith, K. M. Murphy, and D. R. MacNulty. 2001. Winter severity and wolf predation on a 

formerly wolf-free elk herd. Journal of Wildlife Management 65:998-1003. 

9 Smith, B.L. 2005. Disease and Winter Feeding of Elk and Bison: A Review and Recommendations Pertinent to the 

Jackson Bison and Elk Management Plan and Environmental Impact Statement. 

10 Wild MA, Hobbs NT, Graham MS, Miller MW (2011) The role of predation in disease control: a comparison of 

selective and nonselective removal on prion disease dyanmics in deer. Journal of Wildlife Diseases 47: 78–93.

8-10. We agree that predators provide benefits that 

support the mission of the refuge, and a hunting season specifically for predators is not envisioned. All references to the hunting of predators have been 

removed from the final CCP.
Appendix C—Public Involvement 209 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 8 of 9

8-11. 8-11. Thank you for your comment.

transmission. 11 We suggest that the research on the topic of predation and limiting disease 

transmission is robust enough to consider the maintenance of populations of predators on the NER as a Disease Management Objective in Chapter 6. Additionally, allowing for predators to play their ecological role may assist the NER in meeting their bison and elk management objectives through the compensatory role of predation, especially during severe winters. In the completion of the Jackson Herd (Elk 102) Unit Brucellosis Management Action Plan 12

(BMAP) the Wyoming Game and Fish Department recommended as a best management practice that there is no harrassment or harvest of scavengers on feedgrounds. Research suggests that 

protection of scavengers on and adjacent to feedgrounds could reduce intraspecific transmission of brucellosis. Wyoming Game and Fish Department held meetings to discuss these options with the NER on January 20th 2011. Scavengers on the National Elk Refuge would include all predatory 

species. Finally, with gray wolves currently a listed species under the Endangered Species Act, the Service cannot legally propose expanding hunting opportunities to wolves. Allowing hunting of wolves would not only be illegal, but will certainly alienate non-hunters, conservation-minded hunters, wildlife watchers and the Jackson community. Any expanded hunting opportunities for species beyond elk and bison must undergo a thorough review under the National Environmental Policy Act. Increased Conservation efforts for other NER species 

GYC supports the efforts proposed around the conservation of bighorn sheep and trumpeter swans. One concern is how any additional human presence in the form of recreationists along the interior road or increased angling opportunities would effect these two species of conservation concern. We ask that before approving these activities a throrough analysis of risk to these species be completed. Conclusions I appreciate the opportunity to submit these comments on behalf of Greater Yellowstone Coalition on the Draft National Elk Refuge Comprehensive Conservation Plan. The NER is integral to the GYE and supports native species, water conservation, and ecosystem function for the vast neighboring lands of Grand Teton National Park and the Bridger Teton National Forest. GYC supports the implementation of the CCP and requests that modifications be made to the final preferred alternative to include some of the elements within Alternative C. We believe that after providing analsysis of the progress and timeline for the Elk and Bison Management Plan that additionial assistance to ecosystem function could be included in the final plan. Addmittedly, the NER is a special place for me personally. I successfully harvested my first elk in Wyoming on these lands, spend many enjoyable summer nights fishing on its waters, show 11 C. E. Krumm, M. M. Conner, N. T. Hobbs, D. O. Hunter, M. W. Miller. (2010) Mountain lions prey selectively on prion-infected mule deer. Biology Letters 6, 209-211. 12 http://wgfd.wyo.gov/web2011/Departments/Wildlife/pdfs/BMAP_JACKSONELK_UPDATED0001666.pdf
210 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #8—Greater Yellowstone Coalition, page 9 of 9 8-12. visitors their first wolf or bighorn sheep in the wild from its overlooks, and commute daily along its roadways envisioning the possibilities for wildlife crossings. Seeing the CCP successfully implemented and managed sustainably into the future is critical to GYC, the local community and to the integrity of the GYE. Thank you for your consideration of these comments, Sincerely, Chris Colligan Wildlife Program Coordinator, Greater Yellowstone Coalition 8-12. Thank you for your detailed review of the draft CCP and your insightful comments.
Appendix C—Public Involvement 211 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #9—The Humane Society, page 1 of 3

9-1 9-1. Thank you for your comments. Please see the 

response to comment 6-3.

October 9, 2014 Sent via Email (refuge_ccps@fws.gov)

Toni Griffin, Planning Team Leader Suite 300 134 Union Boulevard Lakewood, CO 80228 RE: National Elk Refuge, Wyoming Draft Comprehensive Conservation 

Plan/Environmental Assessment 

Dear Ms. Griffin: On behalf of The Humane Society of the United States (“The HSUS”) and our Wyoming supporters, I thank you for this opportunity to comment on the U.S. Fish and Wildlife Service’s (“the Service”) comprehensive conservation plan and environmental assessment (“CCP/EA”) for the National Elk Refuge, Wyoming (“the 

Refuge” or “NWR”). 79 Fed. Reg. 51,356 (Aug. 28, 2014). The HSUS offers the 

following comments in opposition to Alternatives A, B and D and in support of 

Alternative C. We commend the Service for addressing the serious threats posed to wildlife by the 

use of lead ammunition. The CCP for the National Elk Refuge states that: 

[R]esearch confirms the negative effect that lead ammunition has on scavenging bird populations such as bald eagles and ravens. The large harvest of elk and bison on the refuge and the resultant boon of 

gut piles have altered the migration patterns in bald eagles and potentially other raptors, placing a large number of these scavengers at risk of ingesting lead from bullets in gut piles.1

Given this, we oppose alternatives A, B, and D, which only promote the voluntary use of non-lead ammunition rather than solving the problem proactively by requiring the use of non-lead ammunition. We urge the Service to adopt Alternative C and implement a non-lead ammunition requirement for hunting on the Refuge. Use of Lead Ammunition on NWRs is Dangerous to Human Health and Wildlife. Every year, lead ammunition is discharged throughout Wyoming by hunters and 

others shooting wildlife, creating a poisonous environment for many species. More than 130 species of wild animals suffer the effects of lead poisoning from spent lead ammunition globally, either by foraging 

1 USFWS. 2014. Draft Comprehensive Conservation Plan—National Elk Refuge, Wyoming. Pg.139. 
212 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #9—The Humane Society, page 2 of 3 spent lead shot from the ground, feeding on the remains of lead-tainted gut piles, or scavenging the carcasses of animals shot with lead ammunition and left behind.2 A single ingested shotgun pellet or bullet fragment is sufficient to cause brain damage in birds, resulting in inhibition of critical neuromuscular, auditory, and visual responses. Lead poisoning can induce lethargy, blindness, paralysis of lungs and intestinal tract, various organ failure, seizure and death in wild animals. In fact, more than 500 scientific studies document the poisoning of wildlife from spent lead ammunition. Additionally, lead is a dangerous toxin to humans when consumed. The Center for Disease Control states there is no safe exposure level for humans.3 Individuals who consume meat from animals killed with lead ammunition are at risk for lead exposure.4 Several studies using x-ray imaging have shown lead ammunition is highly fragmentable and nearly impossible to completely remove from meat, even after professional processing.5 It is clear that use of lead ammunition is not only harmful to wildlife but to human health and safety. Voluntary Programs Do Not Eliminate the Threat of Lead Poisoning. The CCP/EA addresses the fact that “scavenging birds would be at risk of lead poisoning because more than 60% of hunters would not use lead-free ammunition.”6 Alternative C would address this issue by requiring the use of non-lead ammunition for hunting on the Refuge. Switching from lead to non-lead ammunition will provide greater protection for the Refuge’s ravens, eagles, and other wild animals from the dangers of lead poisoning. Voluntary programs still allow toxic lead ammunition to be dispersed throughout the environment with no accountability from those who refuse to use non-lead ammunition. In fact, voluntary programs have never proven to be successful at achieving full participation, leaving between 10-15 % of hunters who refuse to use non-lead ammunition. Further, the existing voluntary programs in other states are limited to geographic space and fail to encompass the entire state. Addressing this percentage of noncompliant hunters is crucial, given that even 

1 % of carcasses tainted with spent lead ammunition can cause 30-50% chance of exposure to California condors—one of the many scavenging species that feed off of gutpiles and carcasses left in the field.7Since 2008, 15 California condors have been confirmed killed by lead poisoning in Arizona where voluntary programs have been established. Six other recent condor deaths are awaiting necropsy and 20 additional condors have gone missing and are dead of unknown causes in the Arizona/Utah region in the same time period.8Furthermore, regulatory action has proven effective, as millions of animals have been saved through a single mandatory non-lead ammunition requirement implemented by the Service.9 In 1991, the use of lead 2 M.A. Tranel & R.O. Kimmel. 2009. Impacts of lead ammunition on wildlife, the environment, and human health – a literature 

review and implications for Minnesota. In Ingestion of Lead from Spent Ammunition: Implications for Wildlife and Humans. R.G. Watson, et al., eds. Boise, Idaho: The Peregrine Fund. 

3 Centers for Disease Control and Prevention. 2013. Lead Factsheet. National Biomonitoring Program. http://www.cdc.gov/biomonitoring/Lead_FactSheet.html. 4 D.J. Pain, et al. Potential hazard to human health from exposure to fragments of lead bullets and shot in the tissues of game 

animals. PLoS ONE 2010; 5: e10315. 5 U.S. National Park Service. 2011. Lead Bullet Risks for Humans & Wildlife. http://www.nps.gov/pinn/naturescience/leadinfo.htm. 

6 USFWS. 2014. Draft Comprehensive Conservation Plan—National Elk Refuge, Wyoming. Pg.76. 7 M. Finkelstein, et al. 2012. Lead poisoning and the deceptive recovery of the critically endangered California condor. 

Proceedings of the National Academy of Science Journal. DOI 10.1073/pnas.1203141109

8 Center for Biological Diversity. 2014. Arizona Game and Fish Department Tries to Spin Continued Condor Lead Poisonings Into "Success" Story. http://www.biologicaldiversity.org/news/press_releases/2014/california-condor-07-02-2014.html 9 W.L. Anderson, S.P. Havera & B.W. Zercher. 2000. Ingestion of lead and nontoxic shotgun pellets by ducks in the Mississippi flyway. Journal of Wildlife Management 64:848-857. 
Appendix C—Public Involvement 213 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #9—The Humane Society, page 3 of 3

shot when hunting migratory waterfowl was phased out by the Service after biologists and conservationists estimated that roughly 2 million ducks died each year from ingesting spent lead pellets.10And last year, California addressed the serious threats of this toxin by passing legislation (Assembly Bill 711) to phase out lead ammunition used for the take of all wildlife, citing not only harmful effects to the endangered California condor, but to other species as well.11Sportsmen and Women will not stop Hunting due to a Mandatory Non-Lead Requirement The CCP states that, “hunters would incur higher costs from the more expensive lead-free ammunition, and this requirement might alienate some hunters.”12 The 1991 mandatory non-lead shot requirement for hunting waterfowl did not discourage hunters from hunting waterfowl decades ago, and the 2008 non-lead ammunition requirement for big game hunting in California condor territory actually showed a slight increase in hunter participation after the non-lead requirement took effect.13 The small cost differential between lead and non-lead ammunition is miniscule when accounting for all the other equipment, clothing, and transportation costs associated with hunting, which is why waterfowl hunters and California big game hunters have continued to hunt after non-lead ammunition requirements took effect. Many hunters support the use of nontoxic ammunition and millions of hunters already use it not only for waterfowl, but for other game species. The availability, performance, and affordability of non-lead ammunition has never been greater than it is today. Many government entities like the U.S. Army and the National Park Service have already made commitments to eliminate most uses of lead ammunition, citing environmental and animal welfare concerns.14Therefore, we recommend that the Service address this important issue by rejecting Alternatives A, B, 

and D and adopting Alternative C to require the use of non-lead ammunition on the Refuge. Without a mandatory requirement to use lead-free ammunition for hunting, spent lead pellets and bullet fragments will undoubtedly be ingested causing the suffering or death of wildlife and effects on human health. With alternatives readily available, there is no reason to allow lead ammunition to be used for hunting on the Refuge. 

Thank you in advance for considering these comments. Sincerely, Jennifer Hillman Western Regional Director The Humane Society of the United States 10 Id.11 Brown, Edmund G. "AB 711." Letter to Members of the California State Assembly. 11 Oct. 2013. State of California. N.p., n.d. Web. 18 Sept. 2014. 12 USFWS. 2014. Draft Comprehensive Conservation Plan—National Elk Refuge, Wyoming. Pg.171. 13 California Department of Fish & Wildlife. Deer Harvest Data. 2007-2011. 

http://www.dfg.ca.gov/wildlife/hunting/deer/deerhunt.html 

14 D. Mikko. 1999. “U.S. Military Green Bullet”. Association of Firearm and Tool Mark Examiners Journal 31.4, Environment 

News Service. 19 Mar. 2009. http://www.ens-newswire.com/ens/mar2009/2009-03-16-093.html. 
214 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #10—Jackson Hole Conservation Alliance, page 1 of 4

10-1 10-1. Strategic habitat conservation (page 9 of the draft 

CCP) is an adaptive resource management approach that has been adopted by the Refuge System. Strategic habitat conservation in addition to the U.S. Fish and Wildlife Service’s “Strategic Plan for Responding to Accelerating Climate Change” contributes to the framework for this CCP and its stepdown plans. For more information about climate change, please see the response to comment 6-6.

October 24, 2014 U.S. Fish and Wildlife Service Attn: Toni Griffin, Planning Team Leader Division of Refuge Planning, 134 Union Boulevard, Suite 300 Lakewood, CO 80228 submitted via email: refuge_ccps@fws.govRe: Jackson Hole Conservation Alliance comments on the National Elk Refuge Draft Comprehensive Conservation Plan and Environmental Assessment Dear Ms. Griffin, The Jackson Hole Conservation Alliance (Alliance) thanks you for the opportunity to comment on the National Elk Refuge (NER) draft Comprehensive Conservation Plan (CCP) and Environmental Assessment. The Alliance represents over 2,000 constituents from Teton County who are strong advocates for the continued effective management of the NER and protection of wildlife and habitat in the NER. The NER represents a core part of the Greater Yellowstone Ecosystem (GYE) and is critical to the people and wildlife of Jackson Hole. Below, we provide our comments on the draft CCP. Our comments focus predominantly on two issues, which we feel are the most critical to the continued long-term effectiveness of the NER: climate change and landscape-scale conservation. Climate Change Simply put, climate change is the biggest threat to NER. It is the defining conservation threat of this generation. We also recognize the challenges for an individual refuge to plan under the threat of climate change without a landscape level or regional focus. However, various new documents (below) provide appropriate frameworks to begin down this path. We are glad to see that the refuge is considering climate change impacts and objectives under three objectives for Climate Change (Section 6.3). We urge the NER to go further and increase its focus to understanding the local impacts of climate change on ecological resources in the NER. Several of US Fish and Wildlife Service’s own planning documents require and/or provide guidance on how best to accomplish this: Secretarial Order 3289, Department of the Interior DM 523, US Fish and Wildlife Service Climate Adaptation Strategy (Rising to the Urgent Challenge), Planning for Climate Change on the National 
Appendix C—Public Involvement 215 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #10—Jackson Hole Conservation Alliance, page 2 of 4

10-2 10-2. Please see the response to comment 6-6.

Wildlife Refuge System (Czech et al 2014), and Considering Multiple Futures: Scenario Planning to Address Uncertainty in Natural Resource Conservation (Rowland et al 2014). General themes for planning outlined in these documents urge managers to use science to best predict future impacts on wildlife and habitat, carry out management in an adaptive framework using sound monitoring, and planning for resilience in ecological and social communities. We suggest taking specific strategic steps to incorporate such planning frameworks into the CCP and the step-down management plans (habitat, inventory and monitoring, fire, disease). Overall, we emphasize Climate Change Objective 2 (Chp 6, pg 199) – conducting vulnerability assessments. We urge that the NER not just participate in climate change assessment but initiate monitoring at the refuge level so that such assessments allow NER to best manage wildlife and habitat. A few specific climate impacts that we believe will be of particular importance to monitor and manage: 

• Hydrology and stream flow, for instance in the Gros Ventre River and Flat Creek and 

its impact on fisheries; 

• Disease and invasive species; • Wildlife habitat connectivity; and • Wildland fire and impacts on sage grouse habitat. 

We think that the refuge should actively seek ways to evaluate long-term impacts and use long-term monitoring data to best maintain ecological resilience in the face of climate change. Clearly, addressing climate change impacts will take a coordinated, landscape-level effort as identified in part under strategies outlined in Climate Change objectives 1 and 2. We applaud the refuge’s participation and work with the Greater Yellowstone Coordinating Committee. Climate impact science and decision support tools are also being developed at Regional Science Centers and the Landscape Conservation Collaborative, of which the refuge is a part. We encourage the refuge to seek out existing science from these institutions as a basis to understand and manage local impacts on refuge resources. Landscape-Scale Conservation A widely accepted strategy to increase the resilience of animal populations to withstand the effects of climate change is addressing landscape-scale connectivity between habitats. Specifically, we appreciate the refuge’s strategies to implement landscape-scale conservation objectives 3, 4 and 5. We strongly support the NER’s focus on protecting wildlife habitat beyond its boundaries. Several parcels around the NER, both privately or 
216 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #10—Jackson Hole Conservation Alliance, page 3 of 4 10-3

10-4

10-3. Thank you for supporting this approach and offering to provide assistance.10-4. Thank you for your willingness and commitment 

to work in partnership with the refuge. Please see the response to comment 8-2.

state-owned, currently provide key ecological functions – for instance as migratory or movement corridors. It is necessary to have strategies that will develop proactive solutions with surrounding landowners and managers, be they USFS, private, or state. We believe that targeted land exchanges, easements or other conservation measures (as described in strategies under objectives 3 and 4) for valuable land outside refuge boundaries are critical to the long-term effective functioning of the elk refuge as big game winter range. We offer the refuge our support and would be delighted to work with local refuge staff, other 

organizations, and citizens to find sustainable solutions to conserve habitat around the refuge. Specifically, we view wildlife crossings (over- or under-passes across roads) as one clearly demonstrated solution for increasing habitat connectivity and reducing wildlife-vehicle collisions. The fence along US Hwy 89 is a significant barrier to wildlife movement (for instance see recent study FHWA-WY-13/08F, Riginos et al Mule Deer Movement and Habitat Use Patterns in Relation to Roadways in Northwest Wyoming). Further, traffic along this road results in a significant number of wildlife collisions for elk and mule deer. 

Wildlife-vehicle collisions kill wildlife; make our roads less safe, and cost taxpayer money. 

Past research shows that the cost of just seven deer collisions per mile of road makes investments in crossings cost-effective in the long-term. Wildlife crossings have been unequivocally shown to reduce mortality associated with wildlife-vehicle collisions – saving wildlife and reducing property damage, while simultaneously providing connectivity across habitats fragmented by roads. Wildlife crossings over this highway will tangibly improve habitat connectivity for several species: elk, mule deer, and bighorn sheep, pronghorn, small mammals and potentially even sage grouse, a species under consideration for listing under the Endangered Species Act. Fostering such landscape-level habitat connectivity will have short-term habitat benefits by increasing the availability of winter habitat for several species as well as providing a longterm buffer against climate impacts. Given the new conservation easements along East Gros Ventre Butte, building wildlife crossings to link habitats on both sides of US Hwy 89 is a particularly effective strategy. More locally, this will also connect the two isolated refuge parcels on the west side of the road with more expansive habitat to the east. We urge the refuge to take more concrete steps toward building wildlife crossings, based on studies showing the cost-benefit and the location of collision hot spots. Completing analyses of NER roadways and mitigation will be a first important step toward this goal. We recognize that this is not without challenges associated with detailed planning of wildlife crossings. However, we are committed to working with the refuge, other agencies, partner organizations, and citizens to find durable crossings solutions that protect wildlife, improve habitat connectivity, and keep people safe on our roads. 
Appendix C—Public Involvement 217 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #10—Jackson Hole Conservation Alliance, page 4 of 4

10-510-610-7

10-5. Thank you for your comments.10-6. The CCP was written to be consistent with the 

goals, objectives, and strategies of the Bison and Elk Management Plan (FWS and NPS 2007a). These plans should complement, not conflict, with one another. 

10-7. Thank you for your informed and insightful comments. We appreciate the Jackson Hole Conservation 

Alliance’s past support and your commitment to work together as partners in the future.

We would be happy to support a final preferred alternative that a) ensures strong action to manage and monitor for the impacts of climate change, and b) recognizes the vital need for landscape-level conservation and takes concrete steps toward improving habitat connectivity. In addition, we recognize that this draft CCP proposes many new actions that would increase access for hunters, anglers and recreationists to the refuge. These are all wildlifedependent activities generally concordant with refuge purpose. However, without careful management these activities could pose a risk to the very resource on which they depend. We urge the refuge to take a cautious approach and carry out thorough analyses before allowing increased access and impacts. For example, how will new hunting/fishing or wildlife observation actions (new hunts, new boardwalk, etc.) affect wetlands, trumpeter swans, grizzly bears or other species of conservation concern? The Alliance is committed to ensuring that we as a community continue to live in balance with nature. Our actions must recognize and limit our impacts on wildlife. To that end, we are committed to working with the refuge to educate and inform people in Jackson about actions that help or harm wildlife. We are proud of our partnership with the refuge to educate pathway users about winter closures through our “Don’t Poach the Pathways” campaign (adapted from “Don’t Poach the Powder”). We encourage and support such campaigns and others around sensible actions to live in balance with nature: for example, bear-safe behaviors, lead-free ammunition while hunting, and responsible recreation. Finally, we realize that many objectives and strategies outlined in this CCP will depend on actions and outcomes from the 2007 Elk and Bison Management Plan. Please relate in this CCP how the objectives and strategies presented here will affect, and be affected by, actions in that plan. Thank you for the opportunity to submit these comments. We are committed to working with the refuge to ensure that this Comprehensive Conservation Plan and the actions that follow best protect our wildlife and wild lands. The National Elk Refuge is critical to the wildlife of Jackson Hole and we look forward to a preferred alternative that addresses climate impacts and contains strong strategies for landscape-scale conservation. Thank you for your consideration. Siva Sundaresan Conservation Director Jackson Hole Conservation Alliance PO Box 2728 Jackson, WY 83001 
218 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #11—Safari Club International, page 1 of 5 11-1

11-2

11-1. Thank you for the general support of the CCP, and 

thank you for your comments.

11-2. All refuges in the Refuge System are required to 

develop a hunt management plan as a stepdown plan to an approved CCP; this is required before any expansion of hunting can occur beyond what is already in place on any particular refuge. Any new hunting opportunities at the National Elk Refuge will be developed in coordination with WGFD.

October 24, 2014 Via e-mail: refuge_ccps@fws.govToni Griffin U.S. Fish and Wildlife Service Division of Refuge Planning 134 Union Blvd, Suite 300 Lakewood, CO 80228 

Re: Safari Club International Comments on the Draft Comprehensive 

Conservation Plan and Environmental Assessment for the National Elk Refuge 

Dear Ms. Griffin: Safari Club International (SCI) appreciates the opportunity to provide comments on the Draft Comprehensive Conservation Plan and Environmental Assessment for the National Elk Refuge (Draft CCP). SCI and its members support the expansion of hunting opportunities on this refuge and on the National Wildlife Refuge System generally for recreational, management and conservation purposes. Allowing increased hunting opportunities on the refuge will aid the U.S. Fish and Wildlife Service (Service) in its management and conservation of refuge wildlife resources and habitat, while providing additional recreational opportunities for the public. SCI supports the Service’s preferred alternative (Alternative D) because it will expand hunting opportunities and programs on the refuge. However, SCI believes that the Service should implement the additional opportunities more expeditiously than proposed in the Draft Plan. Safari Club International Safari Club International, a nonprofit IRC § 501(c)(4) corporation, has approximately 50,000 members worldwide, many of whom hunt on lands throughout the National Wildlife Refuge System. SCI’s missions include the conservation of wildlife, protection of the hunter, and education of the public concerning hunting and its use as a conservation tool. SCI has long been an active supporter of hunting opportunities on National Wildlife Refuges. For example, SCI participated as a Defendant-Intervenor in the almost decade-long litigation concerning the Service’s compliance with National Environmental Policy Act (NEPA) requirements regarding the opening of hunting opportunities on National Wildlife Refuge System (System) lands. Aided by SCI’s input, a federal district court upheld the legality of the Service’s NEPA compliance concerning the Environmental Assessments the Service prepared to analyze the impacts of hunting on over 70 refuges throughout the System. 
Appendix C—Public Involvement 219 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #11—Safari Club International, page 2 of 45

SCI Comments on National Elk Refuge Draft CCP and EA October 24, 2014 Page 2 of 5 

Safari Club International - Washington DC Office 

501 2nd Street, NE, Washington, DC 20002 • Phone 202 543 8733 • Fax 202 543 1205 • www.safariclub.org 

Hunting on National Wildlife Refuges Hunting has been recognized by the federal government as a priority use of the System. In 1996, the President, by Executive Order (EO), publicly affirmed the Service’s obligation to provide hunting opportunities on System lands. 

Section 2. Guiding Principles. To help ensure a bright future for its treasured national heritage, I hereby affirm the following four guiding principles for the management and general public use of the Refuge System: 

(a) Public Use. The Refuge System provides important opportunities for compatible wildlife-dependent recreational activities involving hunting, fishing, wildlife observation and photography, and environmental education and interpretation. 

EO No. 12996, 61 Fed. Reg. 13647 (Mar. 28, 1996). This EO prioritized hunting as a public use of National Wildlife Refuges and provided several “Directives to the Secretary of the Interior,” to facilitate this priority, including to: 

(a) recognize compatible wildlife-dependent recreational activities including hunting . . . as a priority general public use of the Refuge System “through which the American public can develop an appreciation for fish and wildlife. . . . (b) provide expanded opportunities for these priority public uses within the Refuge System when they are compatible and consistent with sound principles of fish and wildlife management, and are otherwise in the public interest. . . . (d) provide increased opportunities for families to experience wildlife-dependent recreation, particularly opportunities for parents and their children to safely engage in traditional outdoor activities, such as fishing and hunting. . . . 

EO No. 12996, 61 Fed. Reg. 13647 (Mar. 28, 1996). Congress expressly afforded statutory priority to hunting on refuges via the National Wildlife Refuge System Improvement Act of 1997 (NWRSIA). Like the President’s Executive Order, that law directed the Secretary, through the Service, to “provide increased opportunities for families to experience compatible wildlife-dependent recreation, particularly opportunities for parents and their children to safely engage in traditional outdoor activities, such as fishing and hunting.” 16 U.S.C. § 668dd(a)(4)(K) (1998). The legislative history leading to NWRSIA’s passage discussed the many positive benefits of the role that hunters and hunting play on the System: 

[T]he National Wildlife Refuge System Improvement Act for the first time establishes a conservation mission for America's 509 refuge units. Equally important, the measure establishes hunting, fishing, and environmental education, as legitimate and appropriate priority general public uses of the 92 million-plus acres of land and water that make up our refuge system. . . . [H]unters and 
220 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #11—Safari Club International, page 3 of 5 SCI Comments on National Elk Refuge Draft CCP and EA October 24, 2014 Page 3 of 5 

Safari Club International - Washington DC Office 

501 2nd Street, NE, Washington, DC 20002 • Phone 202 543 8733 • Fax 202 543 1205 • www.safariclub.org 

anglers are the unquestioned leaders when it comes to wildlife and fisheries restoration and conservation. America's hunters and anglers have contributed well over $6 billion to wildlife and fisheries restoration over the past 60 years. . . . And with this legislation, hunters and anglers are again leading the conservation movement. 

143 Cong. Rec. H7646-02 (daily ed. Sept. 23, 1997)(statement of Rep. Tanner). In 2006, the Service published a policy that recognized the priorities identified by the President and Congress. The Service’s policy stated that the Service “will provide visitors with quality hunting, fishing, wildlife observation and photography, and environmental education and interpretation opportunities on units of the National Wildlife Refuge System.” Final WildlifeDependent Recreational Uses Policy Pursuant to the National Wildlife Refuge System Improvement Act of 1997, 71 Fed. Reg. 36418 (June 26, 2006). In the years since adopting that policy, the Service has had many opportunities to acknowledge the cumulative value of hunting beyond its recreational purposes. In the planning documents for many refuges throughout the System, the Service has repeatedly documented the beneficial role that hunting plays in refuge wildlife resource and habitat conservation and management. For example, in planning documents prompted by legal challenges designed to close or limit hunting throughout much of the System, the Service wrote: 

the cumulative effect of closing refuges to hunting may result in decline in social and financial support for wildlife conservation, as hunters have provided, through purchases of hunting licenses and migratory bird conservation stamps, and taxes levied on purchases of hunting equipment, a steady stream of revenue to build the National Wildlife Refuge System, and to restore upland and wetland habitats on millions of acres of public and private lands across the country. (USFWS 2000). These habitat projects also benefit migratory songbirds and other wildlife. Conversely, the cumulative effect of closing refuges to hunting may result in decline in duck stamp and hunting license sales, leading to a decline in funds for conservation. The cumulative effect on closing refuges to hunting may be reduced conservation of wildlife habitats if the above revenues are not replaced by another source. 

Draft Environmental Assessment for Moosehorn National Wildlife Refuge 2007. Hunting on the National Elk Refuge As stated numerous times in the Draft CCP, hunting programs are important for the management, conservation, and sustainable use of the elk and bison populations in the National Elk Refuge. Hunting is an important management tool for both species. While elk and bison management are controlled mostly by the 2007 Bison and Elk Management Plan, the Service can use this CCP process to craft new and improved ways to manage both species. 
Appendix C—Public Involvement 221 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #11—Safari Club International, page 4 of 5

11-311-4

11-3. It is the intention of the proposed alternative to 

expand and improve youth hunting opportunities, which will be addressed in the hunting stepdown management plan scheduled to be completed in 2018. 

11-4. The CCP does not suggest that we increase the 

number of guided hunts. It suggests that better management of the current system could increase hunter success. The actual refuge area available for hunting is not big enough to handle a big increase in the number of guided hunts nor does the refuge have the staff resources to manage a significant increase in guided hunts.

SCI Comments on National Elk Refuge Draft CCP and EA October 24, 2014 Page 4 of 5 

Safari Club International - Washington DC Office 

501 2nd Street, NE, Washington, DC 20002 • Phone 202 543 8733 • Fax 202 543 1205 • www.safariclub.org 

The Draft CCP generally discusses a need to increase harvest rates of elk in the refuge. Elk population numbers are far above the desired herd objective. Draft CCP 115. SCI agrees with increasing hunting opportunities on the refuge and encourages the Service to select proposed Alternative D. However, Alternative D proposes expansions at too slow a pace. SCI recommends that the Service should work to provide those hunting opportunities more quickly than proposed in the Draft Plan. In the Draft Plan, the Service proposes to develop a youth elk hunting program within ten years. Recruiting youth hunters “is critical for continued public support of hunting as an accepted wildlife-dependent recreational activity, continued use as a wildlife management tool, and as the primary funding source for modern wildlife management.” Draft CCP 214. SCI could not agree more; however, the Service should set a deadline to provide this program in less than ten years. With assistance from the hunting community, the Service could reasonably plan and implement such a program within two years. For example, the Service could reach out to local hunting organizations, including the Jackson Hole SCI Chapter and the Idaho SCI Chapter in Idaho Falls. Similarly, according to the Draft Plan, the Service proposes to develop a trophy bull elk hunt within the next ten years. Draft CCP 214. Again, ten years is too long to wait for this program. If the Service authorized a bull elk hunt in addition to the existing elk hunts, more hunters would likely hunt in the refuge and more elk would be harvested. If the Service is serious about meeting its herd objective, it should implement a bull elk hunt within two years. The same is true for the Service’s proposal to increase the number of guided hunts allowed on the refuge. The Service has already issued two special use permits for guided hunting. Draft CPP 143. Developing and implementing guidelines for more guided hunts should not take as long as five years, as proposed in the Draft Plan. Draft CCP 215. SCI also appreciates that the Service is proposing to open new areas to hunting, including archery hunting, under Alternative D. Draft CCP 49. SCI encourages the Service to take even further steps to expand existing refuge hunting opportunities. For example, we support the Service’s consideration of creating hunting opportunities for species other than elk and bison. Draft CCP 49. A Canada goose hunt has already been suggested. Draft CCP 29. The Service should continue to develop other hunts in coordination with the Wyoming Game and Fish Department. Overall, SCI supports the Service’s proposed Alternative D. SCI is encouraged by National Elk Refuge’s full appreciation and understanding of the value that hunting and hunters bring to the National Wildlife Refuge System. SCI hopes that other refuge managers will read this Draft CCP and take note of the benefits that hunting brings to wildlife conservation. Thank you again for the opportunity to comment on this important planning decision. If you 

have any questions or need anything further, please contact Anna Seidman, Director of 
222 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #11—Safari Club International, page 5 of 5 SCI Comments on National Elk Refuge Draft CCP and EA October 24, 2014 Page 5 of 5 

Safari Club International - Washington DC Office 

501 2nd Street, NE, Washington, DC 20002 • Phone 202 543 8733 • Fax 202 543 1205 • www.safariclub.org 

Litigation, at aseidman@safariclub.org and/or Jeremy Clare, Litigation Associate at jclare@safariclub.org.

Sincerely, Craig KauffmanPresident, Safari Club International 
Appendix C—Public Involvement 223 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #12—Sierra Club, page 1 of 3

12-1 12-1. We agree that predators provide benefits that support the mission of the refuge, and a hunting season 

specifically for predators is not envisioned. All references to the hunting of predators have been removed from the final CCP.

October 23, 2014 

U.S. Fish and Wildlife Service Attn: Toni Griffin, Planning Team Leader 134 Union Boulevard, Suite 300 Lakewood, CO 80228 VIA EMAIL Re: National Elk Refuge (NER) Draft Comprehensive Conservation Plan (CCP) On behalf of the Sierra Club’s 2.4 million members and supporters nationwide, we submit the following comments on the National Elk Refuge Draft CCP. At the outset we note that the National Wildlife Refuge System Improvement Act states that “every unit of the Refuge System...must be managed....to consider the needs of fish and wildlife first” and that accordingly, “in addition to the mission for the Refuge System, the wildlife and habitat vision for each unit of the Refuge System supports the following principles: Wildlife comes first.” We strongly urge the U.S. Fish and Wildlife Service (USFWS) to stay true to that mission and vision in finalizing the NER CCP. Additionally, while the CCP does not address the issue of supplemental feeding on the Refuge, we stress that this outdated practice runs counter to the requirement of the Improvement Act that the USFWS administer refuge lands to “provide for the conservation of fish, wildlife, and plants, and 

their habitats within the System” and to “ensure that the biological integrity, diversity, and environmental health of the System are maintained for the benefit of present and future generations of Americans.” Supplemental feeding fundamentally influences many aspects of the NER and has an unquestionably negative impact on the balance of this ecosystem by artificially inflating elk and bison herds. It is an outdated practice that needs to be phased out in order to bring back any semblance of balance. Because it profoundly affects the balance of the NER and surrounding Greater Yellowstone ecosystem, any comprehensive plan for the NER should fully examine the impacts of this practice. Listed below are specific concerns that we have with the Draft CCP. Expanded hunting 

The Draft CCP includes language to “consider hunting of species other than elk and bison to address management needs” and specifically mentions “a predator harvest” (p. 76). On page 171, the Draft CCP goes farther in specifically mentioning wolves and mountain lions. We are extremely concerned about expanding hunting on the Refuge, particularly in regard to predators. Such a 
224 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #12—Sierra Club, page 2 of 3 12-2 12-2. Increased expense to hunters is one factor of many to consider for this topic. Please see the response to comment 1-8. “harvest,” if allowed, would directly contradict management objectives of the Bison and Elk Management Plan. Predators play a key role in maintaining balance in an ecosystem, by selecting old, physically impaired, and diseased animals.1 Additionally, they may reduce transmission and prevalence of diseases such as chronic wasting disease – a severe threat on the Refuge – as well as brucellosis. 2 Federal protections have been restored to wolves in Wyoming; the USFWS cannot legally propose hunting of this species. Even if not illegal, as noted in the Draft CCP, by allowing hunting of wolves and other native carnivores, “We may alienate some nonhunters with the more visible archery harvest in currently closed areas, a bull harvest that includes a trophy value, or the harvest of predatory species such as mountain lion or wolf.” Were it not for their status as a threatened species and corresponding Endangered Species Act protections, we can imagine that USFWS would have included grizzly bears as well. Bear Deterrents and Bear Attractants The Draft CCP notes that “Requiring bear spray could provide a safer environment for hunters, communities and bears but would increase costs to hunters.” (p. 76). First we remind the USFWS of its mission and vision of ‘wildlife comes first.’ The relatively small additional cost of bear spray compared to what hunters spend on a hunting experience would not be a hardship. On page 49, the Draft CCP states that the NER ‘would consider enacting a bear spray carry requirement.” The NER should do so. It has been well documented that bear spray is much more effective than firearms in reducing injuries to both bears and people. 3 4 A bear spray requirement in neighboring Grand Teton National Park for the Elk Reduction Program has long been in place and the NER should also implement such a requirement. Particularly because, as noted in the Draft CCP, grizzly bear 

presence on the Refuge has been documented and “we do anticipate that grizzly bear use of the refuge will increase based on the trends in current range expansion of this species.” (p.167). Last year, the USFWS increased incidental take of grizzly bears both on the Refuge and in Grand Teton National Park, based on this belief. A requirement to carry and have bear spray readily accessible is a minimal measure in terms of cost and burden to implement, but an important one in preventing injury to bears and people, and it should be implemented immediately. 

1 Mech L.D., D.W. Smith, K. M. Murphy, and D. R. MacNulty. 2001. Winter severity and wolf predation on a formerly wolf-free 

elk herd. Journal of Wildlife Management 65:998-1003. 

2 Smith, B.L. 2005. Disease and Winter Feeding of Elk and Bison: A Review and Recommendations Pertinent to the Jackson Bison 

and Elk Management Plan and Environmental Impact Statement. 

3 Smith, T. S., S. Herrero, T. D. DeBruyn, and J. M. Wilder. 2008. Efficacy of bear deterrent spray in Alaska. Journal of Wildlife 

Management 72:640–645. 

4 Smith TS, Herrero S, Strong CL, Larsen RT, Johnson K. Efficacy of firearms for bear deterrence in Alaska. The Journal of Wildlife 

Management. 2012 Jul;76:1021-1027. 
Appendix C—Public Involvement 225 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #12—Sierra Club, page 3 of 3

12-312-412-5

12-3. The proposal on page 49 of the draft CCP is 

included in the preferred alternative.

12-4. Please see the response to comment 6-3.12-5. Thank you for your comments.

The Draft CCP also notes that requiring proper storage of bear attractants could provide for a safer environment for hunters, communities and bears, yet again appears to dismiss any such requirement, despite its mission to “consider the needs of fish and wildlife first.” This, too, would be a very minimal cost to hunters and there is no reason proper storage of food and other attractants should not be required, particularly when the NER expects bear presence on the Refuge to increase. NER should “develop regulations for proper storage of bear attractants and bear deterrent practices when hunting on the refuge” as proposed on page 49. Lead-Free Ammunition The NER should require that all hunters use lead-free ammunition. The Draft CCP notes the negative impacts of lead bullets and that a fairly significant percentage of hunters are already using lead-free bullets. Grand Teton National Park implemented a ban on lead bullets last year. The NER should as well to protect eagles and other wildlife. Landscape Level Conservation Sierra Club supports efforts on landscape level conservation such as those proposed in the Draft CCP, including enhancing wildlife corridors, and seeking and implementing measures that would reduce uses off the Refuge that impact and conflict with protection of natural resources on the Refuge. Thank you for your consideration of our comments. Sincerely, Bonnie Rice Senior Representative, Our Wild America Campaign Sierra Club 

John Spahr, Executive Committee MemberWyoming Chapter Sierra Club 
226 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #13—Western Watersheds, page 1 of 1 13-1 13-2 13-3 13-4 13-1. Please see the responses to comments 6-1 through 6-9. 13-2. In developing the draft CCP the planning team referred to the Writing Refuge Management Goals and Objectives Handbook. We believe the objectives in the draft CCP follow the guidance provided in the handbook. 13-3. The intention of the CCP is to provide manage- ment direction for the refuge into the near future. The CCP does not address management actions that were already addressed and approved in the Bison and Elk Management Plan (FWS and NPS 2007a). That plan was court-approved (twice) and cannot be changed by the CCP. The two documents are meant to work together to guide refuge staff in making management decisions.

13-4. All refuges in the Refuge System are required to 

develop a disease management plan as a stepdown plan to an approved CCP. This plan will be developed in coordination with WGFD and will rely on the best available peer-reviewed science as it relates to disease management and prevention.Thank you for your comments.
Appendix C—Public Involvement 227 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1
228 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1 14-1 14-1. Thank you for your comments. NER DRAFT PLAN COMMENTS FROM WYTWS SCIENCE COMMITTEE Reviewer #1: TWS has asked the Science Committee to review and comment on the National Elk Refuge (NER) Comprehensive Conservation Plan (CCP). I have reviewed the document and compared all the details of the 4 alternatives. The mission of the refuge system and the NER focuses primarily on wildlife restoration and conservation, but the reality is that some recreation and I&E is necessary and desirable to promote those missions. As well, the relationship between NER and the community, with it swallowing up the NER physically where possible like an amoeba, necessitates some accommodation of the human element. In this document, the USFWS is attempting to adapt to and deal realistically and reasonably with a complex natural and anthropomorphic environment never imagined when the NER was established. Since its establishment, a variety of additional mandates through executive orders and federal laws have expanded the scope of NER’s purpose. It must now work to accommodate the needs of threatened and endangered species, species of special management concern, colonial nesting and marsh birds, fisheries, and landscape and habitat conservation, as well as satisfy the requirements of the Bison and Elk Management Plan. It must not only provide recreational opportunities and interpretation, but manage cooperative and uncooperative behavior of residents and tourists, sportspersons and wildlife viewers, and persons seeking to make a profit or conduct activities not really compatible with the NER’s mission. 

The alternatives for all the various activities contain a dizzying array of choices, and it is difficult for the reader to know the relative merits of each against other (sometimes) conflicting components and to know how to prioritize them (e.g., is a sufficient balance being struck between the original intent of the refuge (“The National Elk Refuge was established in 1912 as a ‘winter game (elk) reserve’”. pg. 21) and the more recent mandates. The NER must address a multitude of issues ranging from those directly related to its mission and original purpose to many that are not, and from the potential effects of climate change to managing an array of human dimension challenges and opportunities. Given this, the preferred alternative (Alternative D), which strikes a balance between Alternative B (enhanced public use and intensive resource management) and Alternative C (promoting intact ecosystems and natural processes) seems generally logical and well thought out. My primary concern is that the NER be managed first and foremost for wildlife, for that is its purpose, and it is a primary component of the mission of the refuge system (ref. Mission, pg 4). This is further supported by the mission’s emphasis on ”...support(ing)...biological integrity, diversity and environmental health....” and in authorizing managers to determine compatible human uses. These 3 elements should be the fundamental basis for decisions about NER management. 
Appendix C—Public Involvement 229 

RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1

14-214-314-414-514-614-7

14-2. Thank you for your comment.

14-3. We acknowledge that any emphasis on landscapelevel conservation issues will detract from refugespecific work. Implementation of the CCP will be 

dependent on available resources, and the refuge will have to remain flexible regarding how we prioritize future actions.

14-4. Thank you for recognizing the complexity of refuge operations.14-5. Monitoring priorities will be developed in more 

detail in the inventory and monitoring stepdown 

plan. Trumpeter swans are a high priority for monitoring and management because they are categorized by WGFD as a species of priority conservation need and they may act as an umbrella species for wetland communities.

14-6. We do not believe that jackstraw techniques could 

be implemented at a scale that would meet management objectives. If these techniques are implemented 

at a large scale, they may be difficult to maintain and also present an entanglement risk to elk and bison.

14-7. Thank you for your support.

All that said, following are some more specific observations and comments. I have no issues with much of the document, so I focus here on the comparison summary of actions and consequences in Chapter 3. Pg 62. I heartily endorse proposed actions related to climate change. Participating in landscape-scale conservation efforts is mentioned here and in at least 2 other proposed actions. However, in those other places those efforts and that concept are not included in proposed outreach efforts in the preferred alternative. Certainly the NER has more things to do than it can tackle, but the merits of and NER involvement in these activities warrants some acknowledgement and interpretation (providing information about it). The discussion of the environmental consequences of climate change provides much justification for some effort to promote public understanding of NER’s participation in interagency, interdisciplinary landscapescale work. I assume justification for not including interpretation is alluded to in the statement, “Emphasis on landscape-level projects would help ecosystem resilience, but would divert money and staff time away from refuge-specific work.” (pg 64). Pg 64. I agree with the decisions regarding native grasslands and sagebrush shrublands, but this is a case in point regarding trade-offs, especially for sensitive species. Whether fire is used/managed affects the amounts of grasslands and grassland patches and the amounts of older sagebrush versus a range of age classes. Only local managers understand the effects of these trade-offs. Similar choices are presented in the wetland actions. Pg 65. Again, are we at a point where focus should be redirected somewhat from Trumpeter Swans to other species in need while monitoring swans to ensure they continue to do well? Should resources now be dedicated to the acknowledged aquatic habitat improvement needs (could the money for more ponds here be better spent on the greater good of aquatic systems since there appear to be opportunities for swans around the outer bounds of their distribution in WY? I don’t know the answers to these questions. I understand funding and cooperation for different species come from different sources, but the NER staff and funding should be prioritized based on species’ relative need. Is there a NER species prioritization that is based on need and return on investment? Pg 66. Some of the choices in the alternatives for riparian and aspen woodlands are confusing. In one place it states (small-scale) enclosures and jackstraw techniques would have only modest benefits, yet elsewhere it states that without exclosures treatment areas would be used excessively by wild ungulates. Knowing nothing about the specific project, I found the statement in Alternative B (“Consider expanded willow regeneration techniques.”) contradicting the statement in Alternative C (“Eliminate the jackstraw willow regeneration project”). Based on the discussion on pp. 111-112, it appears anything that restores either of these community types would be desirable. Pg 68. I support the proposed actions for Flat Creek and invasive species. 
230 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1 14-8 14-9 14-9 14-10

14-1114-1214-13

14-8. Implementation of the CCP will be dependent on 

available resources, and the refuge will have to remain flexible regarding how we prioritize future actions. Monitoring priorities will be developed in more detail in the inventory and monitoring stepdown plan.

14-9. Strategies related to nonnative trout were 

designed to be consistent with existing WGFD fishing regulations. Unlike areas within Yellowstone National Park, fishing regulations on the refuge are set by WGFD.

14-9. The National Elk Refuge contains some of the 

most important wintering habitat in Jackson Hole for sage-grouse, and previous research has suggested that winter habitat is a primary limiting factor on the Jackson Hole sage-grouse population. The refuge is compelled to prioritize management for sagegrouse because it is a candidate species under the Endangered Species Act.

14-10. Given uncertainty about species-specific 

responses and uncertainty about future prioritization of existing actions, such an analysis has not been conducted.

14-11. Thanks for your support.14-12. In the past, restoration of the Miller Ranch was 

funded through a grant, and in the future we would likely continue looking for additional grant opportunities for other restoration projects.

14-13. Hunting of elk and bison on the refuge is critical 

to achieve the 5,000 elk and 500 bison objectives in 

the Bison and Elk Management Plan (FWS and NPS 2007a).

Pg 69. No indication of how actions for migratory birds relate to those for Sage-grouse, Trumpeter Swans and other high profile species that might be affected. What are the relative priorities? Difficult for a reviewer unfamiliar with the setting and interagency priorities to provide meaningful comment. Pg 71. Under Aquatic species – environmental consequences, the statement is made that, “Increased removal of non-native trout would benefit native fish and invertebrates. More removal would increase WGFD costs and further reduce fishing opportunities.” Can fishing regulations help with this? Can they be, somewhat like Yellowstone NP where non native fish caught MUST be killed? This wouldn’t be as aggressive or as effective as concerted agency efforts, but could be included as an action in the proposed alternative to help rather than be rejected as a component of another alternative. Pg 72. Again, given limited resources and a myriad of demands, can the refuge make significant additional contributions to Sage-grouse and Trumpeter Swan conservation, or should it do what it can do best for other species in need? It cannot be all things to all creatures. Just a question. Pg 73. Federally and State-listed species – environmental consequences. In the discussion of the relative merits of the preferred and other alternatives it states that Sage-grouse would benefit somewhat and benefits to trumpeter swans would be somewhat diminished. I assume someone has compared all the selected actions that will benefit or not benefit these species (and any others of high concern) to determine the net outcome and whether expenditures of resources in one action are not being offset (cancelled out) by different action(s) elsewhere in the plan. Pg 73. Research and monitoring. The NER is fortunate to be in a location where everything is high profile. The attention it and the species it provides habitat are important enough that there are many varied opportunities for research and for data collection to assess species status and trend. Given the availability of information on species there, the NER’s proposal to emphasize monitoring of public use and other refuge programs on habitat and wildlife (while continuing to partner with others or rely on them to collect status and trend information) is appropriate. Pg. 74. I understand the importance of and the desire to stabilize and restore cultural resources – specifically Miller Ranch, but do not know the situation well enough to be able to evaluate the cost/benefit of these actions in relation to other, pressing, natural resource related needs. Pg. 76. I am not knowledgeable enough about the NER and its ‘environment’ to be able to judge whether hunting species other than elk and bison is smart. However, considering the location of the NER and its many other needs and uses, including the most important – wildlife conservation, this appears to be yet another source of complexity and management challenges for an already ‘tapped out’ refuge. If it was Seedskadee NWR or Arapaho NWR in North Park, CO, this would probably not be such a people management morass and additional activities would not present such additional challenges. 
Appendix C—Public Involvement 231 

RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1

14-1414-1514-1614-1714-1814-19

14-14. Please see the response to comment 1-8.

14-15. Strategies related to nonnative trout were 

designed to be consistent with existing WGFD fishing regulations.

14-16. Thank you for your support.14-17. Thank you for your support.14-18. Thank you for your support.14-19. Thank you for your support.

Pg. 76. Hunting – environmental consequences. Requiring bear spray would provide (not could provide) a safer environment for hunters, etc. It might add a little cost, but not as much as a visit to the emergency room or a burial. Anyone now recreating in grizzly bear country should have it as a matter of course as part of their ‘survival’ gear. Requiring it is not onerous. However, this is somewhat irrelevant because in the proposed actions for the same alternative, it is suggested that carrying bear spray be only encouraged. Not sure why ‘requiring’ was brought up in the consequences. I also personally think it is time to be assertively encouraging hunters to use non-toxic projectiles no matter their quarry. Pg. 77. Fishing – actions. Again, maybe out of ignorance, I question why the fishing regulations can’t help remove nonnative fishes. It is not clear why this is not a component of each of the alternatives here. Pg. 78. I support the proposal to assess a fee and regulate permits for guided fishing for the reasons given. Fees might impact outfitters, but there are plenty of other opportunities in the area, and they should be glad to have the opportunity to use the NER. Pg 79. Wildlife observation and photography. I support the proposal to limit tour companies for the reasons provided. Yes, there may be some consequences for those tour companies, but their financial well being is not the primary mission of the NER. The goal should be to reduce administrative and other costs for non-essential things so those resources can be dedicated to the NER’s primary purposes. Pg. 80. Environmental education. My knowledge about the setting is insufficient for me know the limitations this would impose in accommodating outreach needs, but it seems very logical to confine disturbances to areas with nonnative vegetation. Their locations and the outreach needs may not be wholly compatible, but I support that proposal wherever possible. Pg 81 through 84. I support the preferred alternatives for the various special purpose areas for the reasons provided in the discussions of environmental consequences. I especially endorse those actions proposed in Alternative D for Special purposes. Again, wildlife comes first on the NER, and as is the case elsewhere, many of the activities some of the public would like to be allowed are not just incompatible with the mission of the NER, they are inappropriate. We are experiencing what I call theme park creep on many of our public lands. It isn’t enough to just experience and appreciate natural settings and resources. There has to be something to overtly entertain some people. Land managers are being pressured to allow more, from mountain bikes to pack boats and zip lines to festivities. The public has to be (gently but assertively) reminded that there are higher purposes of many of these lands, and those higher purposes ultimately affect them in ways that they may not be perceptive enough to appreciate without some (interpretive) help. 
232 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1 14-20 14-21 14-20. We agree that this is an important component of interpretive efforts. 14-21. Thank you for your comment. Pg. 86. Public outreach. Here, again, providing outreach about the NER role in landscape-scale management (its role in the greater Yellowstone Ecosystem) is mentioned, but then is not included in the preferred alternative. And, again, I understand there are only so many actions the NER can take given its resources, but including its role in a ‘bigger picture’ should be a low cost, matter-of-course component of its interpretive efforts. People are too prone to focusing on the small and immediate and need to be encouraged to look out and up. Pg. 89. Funding and staff. Again, not being knowledgeable about the details, I recommend revising the statement, “Increase refuge base funding by $200,000 to replace private contributions.” to “Increase refuge base funding by $200,000 to augment private contributions.” Use the additional money to do good things 
Appendix C—Public Involvement 233 

RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1

14-22

14-22. Thank you for your support of alternative D.

Reviewer #2:  (See highlighted portion and text following). I have listed the merits of alternative in bulleted format. Alternative B 

 Includes potential Hwy 89 overpass/underpass  Increased habitat management to reduce reliance on artificial feeding/improved woody 

vegetation component. 

 Prescribed fire use  Would develop a disease strategy with alternatives for carcass disposal  Increased research to increase confidence in management decisions  Hunting 

o Increased youth opportunity – allow youth only season after the general season 

(mid to late Dec.) 

o Require the use of bear spray while hunting on the refuge o Need to make hunter harvest reporting mandatory, require submission of teeth for 

aging to better monitor age of harvest during hunt 

o Increased opportunity to harvest other species o Addition of a bull elk hunt 

 Fishing 

o Reduce fishing pressure by reducing number of allowed guided trips and charge a 

yearly fee of $100 

o Requirment to kill non-native fish once caught 

 Special use permits – for commercial filming and photography (increased revinew and 

ability to regulate activities on Refuge) 

Alternative C 

 Reduce the promotion of refuge road to view big horn sheep  Limit the amount of tours during the winter to reduce congestion 

Alternative D – Once I realized that Alternative D covered the majority of high points between Alternatives B and C, I focused on the merits of this Alternative and feel this is a well thought out compromise between public use and preservation and would be the preferred alternative. 

 Increased work to improve the function of Flat Creek 
234 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1 14-23 14-24 14-23. Thank you for support of this monitoring priority. 14-24. Thank you for your support of the CCP’s hunting implementation plan. We agree that mandatory har- vest reporting would improve data quality. Ch. 6 Implementation I agree with the implementation of the disease monitoring in Alternative D. By quantifying elk movement and group size we will be better able to monitor disease transmission risk and model potential outbreaks into the future. Hunting implementation is also well throughout and will increase the experience and potentially the harvest while increasing youth involvement in the elk reduction program. I also think that the limit on guided hunts will improve to overall experience on the hunting public on the NER. Mandatory harvest reporting should be strongly considered in the near future. This would help wildlife managers track harvest and improve population models and subsequent hunting season’s quotas for the NER. Mandatory reporting also gives managers the opportunity to more easily collect biological data from harvested animals (i.e. CWD sampling, harvest age, blood collection). 
Appendix C—Public Involvement 235 

RESPONSE Comment number LETTER #14—The Wildlife Society, page 1 of 1

14-2514-2614-2714-2814-29

14-25. Food storage requirements will be implemented, 

but use of bear spray will be encouraged but not required. Please see the response to comment 1-8.

14-26. The National Elk Refuge initiated a voluntary 

non-lead ammunition program in 2008. This program 

will continue to be emphasized to encourage the use of non-lead ammunition.

14-27. Gray wolves are currently under the management 

authority of the U.S. Fish and Wildlife Service due to 

litigation.

14-28. This is largely beyond the scope of the CCP.14-29. We believe that some discussion of the Bison and 

Elk Management Plan was necessary to provide context for CCP decisions.

Reviewer #3:  - I like that they the preferred alternative would implement food storage and bear spray requirements in the hunting section - As a group advocating the management based on science, TWS should probably be advocating for the use of non-lead ammo for hunting on national wildlife refuges...the preferred alternative doesn't do that. Nontoxic shot is required for waterfowl everywhere and for upland birds Wyoming Game and Fish Department Habitat Units for example. - Update the wolf section on page 121, which currently says they are managed by WGFD and the 2012 management plan...recent changes in management authority due to litigation will need to be incorporated into the document. - The grizzly bear section is very brief and incomplete; even though in Bruce Smith's last elk neonate study on the refuge grizzly bears accounted for a significant portion of elk neonate predation and have been known to frequent the refuge during the late season hunts, hence their recommendation for food storage and mandatory bear spray in the hunting section. It would seem additional information about grizzly bear demographics would improve the merits of the draft plan. - Since bison and elk management are conducted under a separate management plan, anything about their management is not relevant to this plan. 
236 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #15—Wyoming Pathways, page 1 of 5

Wyoming Pathways phone 307-413-8464

PO Box 153 Wilson WY 83014 email tim@wyopath.org

Toni Griffin, Planning Team Leader U.S. Fish and Wildlife Service Division of Refuge Planning 134 Union Boulevard, Suite 300 Lakewood, Colorado 80228  [via email to: refuge_ccps@fws.gov, toni_griffin@fws.gov] Subject: Comment on Draft Comprehensive Conservation Plan for NER Dear Toni, Thank you for the opportunity to provide comments on the National Elk Refuge Draft Comprehensive Conservation Plan and Environmental Assessment (Plan). It was also helpful to attend the public open house meeting at Snow King Resort, thank you for providing the opportunity to learn more about the draft Plan. Wyoming Pathways is the statewide organization representing people who bicycle and walk. Our goal is to encourage bicycling and walking – helping to create thriving communities and enhance public land access across Wyoming. Bicycling and walking provide many benefits, including low impact climate-friendly transportation solutions and enjoyable recreation option to experience the National Elk Refuge. These modes of travel also enhance public health, support sustainable economic development, and align with the vision and goals of the USFWS “Conserving the Future–Wildlife Refuges and the Next Generation.” It is our understanding the Plan will address all aspects of the management, visitor use, natural resources, and cultural resources of the National Elk Refuge, with the exception of Elk and Bison issues, which were decided separately in 2007. The Draft EA is an important step in the planning process to gather public input on the alternatives proposed. With that in mind, Wyoming Pathways requests your consideration of the following comments as you develop the Final Plan and Environmental Assessment decision. Vision and Goals. Wyoming Pathways supports the vision stated, which includes the public having year round interpretive opportunities, and the Visitor Services Goal, to “Enable a diverse audience to understand and appreciate the refuge’s wildlife conservation role in Jackson Hole, while safely enjoying year-round opportunities for wildlife-dependent recreation.” People and the Refuge System. As the Plan notes on page 5, most people visit the Refuge System to observe wildlife in their natural habitats. As documented in public comments made during the Scoping phase of the plan, Refuge visitors currently enjoy using bikes and foot access where allowed to experience the National Elk Refuge. The new Comprehensive Conservation 

October 24, 2014
Appendix C—Public Involvement 237 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #15—Wyoming Pathways, page 2 of 5

15-1 15-1. We have added the following paragraph to section 

2.5 of the final CCP: “We provide a multiuse pathway to the public through a cooperative agreement with Teton County. The pathway is available to a wide variety of people seeking to experience the refuge on foot or via non-motorized vehicles, allowing them to enjoy views of the refuge and providing wildlife viewing and photography opportunities during three seasons of the year. The pathway also allows users to connect to destinations such as the National Wildlife Art Museum, Jackson Fish Hatchery, and Grand Teton National Park.”

Comment Draft CCP National Elk Refuge, Page 2 of 5 Plan offers the opportunity to improve this public benefit within the purpose and mission of the Refuge. Conserving the Future, The National Elk Refuge, and the North 89 Pathway. The North 89 Pathway is a very positive addition to the National Elk Refuge as well as the community pathways system. It has created a new opportunity for Refuge visitors to experience the Refuge without the need of a motor vehicle. The Pathway helps the USFWS accomplish “Conserving the Future” goals, which provides direction how to adapt to a positive new use like the Pathway. To quote from the USFWS plan, with key sections highlighted in bold: 

“Though our fundamental mission is wildlife conservation, we recognize that to be successful we must inspire the American people to connect with their wildlife heritage and participate as stewards of the System. As an integral part of local communities, refuges are great places to build a broader conservation constituency.” “Spending time outdoors is good for both our spirit and our health. Recreation and relaxation in nature reduces stress and anxiety, promotes learning and personal growth, nourishes the imagination, and provides mental and physical restoration. Direct experiences in the outdoors often lead to a commitment to, and involvement with, stewardship of our shared natural legacy. The Refuge System’s wildlife dependant uses promote getting outside and experiencing nature. Americans must learn anew that national wildlife refuges not only provide essential habitat for wildlife, but they also are beneficial and relevant places for people. We must actively encourage and provide new opportunities for people of all ages and backgrounds to connect with nature by visiting their national wildlife refuges, personally or virtually.” “Recommendation 18: Support and enhance appropriate recreation opportunities on national wildlife refuges by partnering with state fish and wildlife agencies, other governmental bodies, conservation organizations and businesses; and by updating relevant policies and infrastructure.” 

North 89 Pathway Function. The North 89 Pathway is located parallel to US Highway 26/89/191 and is compatible with four of the six wildlife dependent National Wildlife Refuge System Priority Public Uses. These are Wildlife Observation, Wildlife Photography, Environmental Interpretation, and Environmental Education. The Final Plan should better acknowledge this compatible use and embrace the pathway as beneficial for the Refuge. Because the pathway is located adjacent to the busy high-speed national highway that carries up to 20,000 motor vehicles per day and is outside the 8’ tall continuous Elk Refuge fence, the pathway has negligible impact on the Elk Refuge lands east of the highway ROW. The pathway does offer visitors and residents a wonderful and safe opportunity to enjoy the Refuge by bicycling and walking without impact to wildlife. It also gives employees and visitors 
238 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #15—Wyoming Pathways, page 3 of 5 15-2 15-3

15-4

15-2. Prior to construction of the pathway, a seasonal 

closure of the pathway was clearly outlined as a critical condition. The season has already been expanded by 20 percent and as much as 31 percent in years when the refuge agrees to open the pathway as early as April 15 due to an early migration. Our data show the current pathway season is within approximately 2 weeks of when regular migration occurs to and from the refuge. It would be difficult for the refuge or Jackson Hole Community Pathways to open and close the pathway every time there is or is not a potential conflict with elk, nor could an unplanned closure be implemented quickly to alleviate a problem. The pathway, open from May 1 through October 31, is open during most of the typical cycling season.

15-3. All our visitor service programs serve the needs 

of a wide variety of people seeking to experience the refuge for wildlife-dependent uses. Please see the response to comment 15-1.

15-4. In draft documents that explore a range of alternatives, we typically use the word “would” to describe 

potential activities. When the documents are finalized, we change instances of “would” to “will” as appropriate. This change has been made in the final CCP.

Comment Draft CCP National Elk Refuge, Page 3 of 5 at the motels one-mile north of Jackson and the National Wildlife Art Museum with the opportunity to walk or bike from town to the Motels and Museum while observing the Elk Refuge. Public safety is an important aspect of visitor use along the Elk Refuge. Wyoming Pathways believes the greater threat to public safety is to force pedestrians and cyclists onto US-26 when a safer alternative exists to use the adjacent pathway, which was constructed at significant public expense and should be available for public use when there is no impact to elk on the refuge. The Teton County Sheriff has publicly expressed concern with this safety hazard. The Final Plan should better acknowledge that the North 89 Pathway serves the needs of a wide variety of people seeking to experience the Elk Refuge for wildlife-dependent uses and also to connect to destinations such as the National Wildlife Art Museum, the Fish Hatchery, and to Grand Teton National Park to the north and the Town of Jackson to the south. Draft Plan Lacks Information on Pathways Studies. Wyoming Pathways is concerned that the Draft Plan did not include any information from the research study on pathway use that has been underway the past three years in partnership with Teton County. The draft Plan provides no data and no discussion to support the statement that “seasonal closure is essential.” The Draft Plan acknowledges on page 30 that the North 89 Pathway provides an opportunity for the public to “enjoy the beauty of the National Elk Refuge”, and that “some of the public would like...to extend the use of the pathway by eliminating or modifying the seasonal closure.” But then the Plan states, “However, the seasonal closure is part of the agreement with [Teton County]...and is believed to be an essential requirement for this activity to be compatible with the refuge purposes.” The Plan states that “The Refuge would explore a variety of data collection methods to assess wildlife movement across the pathway...The Refuge would explore a variety of data collection methods...” The word “would” implies the future. However, Biota Research, a professional environmental firm contracted by Teton County, has already conducted the pathway research during 2011, 2012, and 2013. Research was supported by additional data gathered by the Refuge staff. It is our understanding that the National Elk Refuge has been involved in all phases of this 

study; initially requiring that the study be done, then reviewing and approving the scope of the study, and finally in regularly reviewing the ongoing results. Public comment during the Scoping phase of the plan also highlighted the study was underway and expressed the need to include the results in the alternatives and analysis. We understand that science is important to the USFWS mission. The USFWS “Conserving the Future” agency plan states: “Science-driven management decisions use better information, improve efficiency, reduce uncertainty, and increase our ability to solve complex problems and adapt to changes in populations, habitats and systems. We must gather and integrate data from our robust inventory and monitoring efforts and directed research on refuges and use these data to inform our management decisions.” 
Appendix C—Public Involvement 239 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #15—Wyoming Pathways, page 4 of 5

15-5 15-5. Per the agreement with the National Elk Refuge, 

Teton County / Jackson Hole Community Pathways is responsible for the development, payment, and maintenance of interpretive signage for the pathway. The refuge’s outdoor recreation planner prepared a six-page document titled, “North Highway 89 Pathway Preliminary Interpretive Concepts” in August 2013 and presented the ideas to the Jackson Hole Community Pathways task force that same year. The document included sample photographs, recommended locations for panels, and key interpretive messages. In May 2014, the Pathways coordinator sent out a request for qualifications for designers interested in preparing, fabricating, and installing interpretive signage. A firm was selected that summer. The refuge has continued to express an interest in moving ahead with the project. A preliminary call is scheduled for January 2015.

Comment Draft CCP National Elk Refuge, Page 4 of 5 Therefore, it is puzzling as to why this well-known, high profile Teton County/Refuge Pathway Study has not been mentioned or included in the Draft Plan. This is an important issue that needs to be addressed in the Final Plan. We support the statement on page 177 that “The Refuge, in coordination with Teton County, could adjust the dates for the seasonal closure if data collected...provided solid justification for a change.” In fact the data available shows the pathway to be benign with no impacts to wildlife, and it is proving to be a great improvement for visitor safety and enjoyment of Elk Refuge visits. The Final Plan should acknowledge the pathway has been studied, with positive results that demonstrated the lack of impact of the North 89 Pathway on refuge resources. The research suggests the Pathway does not need the long closure proposed in the alternatives to be compatible with the refuge purposes. Teton County would also prefer that the seasonal closure be reduced or eliminated for public safety and need. Adaptive management of the pathway season would be more successful and should be a joint effort with Teton County and Refuge. A request for the study information completed so far was sent by email to the USFWS Plan contact person, but the request was not answered in time for this comment deadline. A copy of the contract Teton County has with the Biota Research firm is attached to summarize the study, and a letter from 2012 with summary data. Environmental Education and Interpretation. The new North 89 Pathway offers a superb opportunity to provide environmental education and interpretation of the Elk Refuge resources and for wildlife dependent public uses like watching wildlife and wildlife photography. So far, this is a missed opportunity. The North 89 Pathway was paved in the fall of 2010, yet four years later there is not a single educational message for pathway users to better understand the Elk Refuge. On the other hand, a huge effort is made every year to close the pathway to human use for 6-7 months, and to try and explain to a skeptical public why the closure is needed. We fully support the new pathway pull offs proposed in the action alternatives under Wildlife observation and photography, and Environmental education and interpretation sections. Requests for Changes in the Final Plan for North 89 Pathway. Wyoming Pathways requests the Final Plan and EA Findings include the option for extending the open season for the North 89 Pathway. We are not aware of data that suggests harm would occur with a longer season. We note other activities continue well into the fall, such as elk and bison hunting, winter-long sleigh rides, and year-round use of the Elk Refuge Road. The Final Plan should lengthen the season of use to encourage additional wildlife-dependent public enjoyment of the pathway and Refuge resources within the mission of the Refuge. We request the final plan allow the pathway to be open, and only closed for specific management reasons supported by the research. For example, it may be reasonable to close the pathway during the brief migration season in November and early December, but then it should be open 
240 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #15—Wyoming Pathways, page 5 of 5 15-6

15-7

15-6. The CCP notes that we would continue to promote 

visitor and employee safety.

15-7. The refuge was notified of the proposed North 

Cache Street development in August 2014 by Friends of Pathways, just prior to the item being placed on a municipal ballot in the upcoming election. This occurred after the draft CCP had been written and was being edited and prepared for printing. Two refuge staff members have since attended a Friends of 

Pathways board meeting and met with Friends of Pathways program director onsite to discuss development opportunities in the North Cache Corridor, which was approved by voters. The memorandum of understanding will expire in 2015, and this project will be discussed during memorandum of understanding renewal. In the area that is already paved and disturbed, the refuge is fine with change but will not give up any additional land to the North Cache project.Thank you for your comments.

Comment Draft CCP National Elk Refuge, Page 5 of 5 for the balance of the winter and spring. Winter weather in Jackson Hole, when snow and cold descent on the valley, would naturally limit public use on the pathway and maintain protection for wildlife during the most sensitive time, while allowing for wildlife-dependent public use to experience the Refuge resources for more of the year. We maintain the 6-month closure is unnecessary. Elk Refuge Road. Wyoming Pathways supports the continued, enhanced and safe public use of the Elk Refuge Road by runners, walkers and cyclists. The gravel road is maintained by Teton County for approximately the southern 3.5-miles. It is used and enjoyed by thousands of people each year that desire to experience the Refuge resources by walking, running, and bicycling. With the improvements planned to the Elk Refuge Road, there are concerns that the traffic speeds may increase. Actions should be included in the Plan to manage the road so as to continue to provide safe shared use by pedestrians and cyclists. The Final Plan should also explore providing an accessible trail directly next to the road (within existing road corridor) between East Broadway and the Miller House. This could provide enhanced opportunities for interpretation, education, and enjoyment of wildlife-dependent public uses and to provide separation from motor vehicle traffic, which during the busy summer season causes safety issues for nonmotorized Refuge visitors, especially children, older people, and people with disabilities trying to share the road with motor vehicles. Forest Service Ski Cabin Winter Access. We are pleased the Draft Plan continues to provide managed winter access from the Elk Refuge to the Bridger-Teton National Forest. The existing access near Nowlin Creek is a good location for Ski Cabin users, and the opportunity to cross the Refuge land in the winter is important to provide continued winter access to the National Forest. North Park. There is interest by the Town of Jackson to improve the North Cache Street frontage along North Park. This includes a need to improve parking for North Park, sidewalks, and to provide safe passage to access the North 89 Pathway. The Final Plan should acknowledge the Town’s interest and support the planning effort. Thank you again for the opportunity to comment on the Comprehensive Conservation Plan for the National Elk Refuge. Please contact me if you have any questions or need clarification on points in this comment letter. Sincerely, Tim Young, Executive Director Attachments: Teton County Contract and Study on North 89 Pathway 
Appendix C—Public Involvement 241 

RESPONSE Comment number LETTER #—Name of organization, page 1 of 2 RESPONSE Comment number LETTER #16—Wyoming Wildlife Advocates, page 1 of 2

16-116-2

16-1. Thank you for your comments. U.S. Fish & Wildlife Service Refuge Planning Policy (May 25, 2000) 

defines the vision statement as “A concise statement of what the planning unit should be, or what we hope to do, based primarily upon the Refuge System mission and specific refuge purposes and other mandates.” The vision statement for the National Elk Refuge is the synthesis of the refuge’s purposes, the Refuge System mission and goals, and other biological, legal, and social concerns in which the refuge has a role.

16-2. The management of bison and elk is addressed in 

the Bison and Elk Management Plan that was completed in 2007 and remains in effect until 2022 (FWS and NPS 2007a). The effects of supplemental feeding were addressed in the EIS that was completed as part of the NEPA process for the Bison and Elk Management Plan. The comprehensive conservation plan addresses other management issues such as public use and cultural resources and will serve as a complementary management document to the Bison and Elk Management Plan. The analysis of the proposed actions in the CCP did not identify significant impacts on the human environment; accordingly, the Service determined preparation of an EIS is not warranted. 
242 Comprehensive Conservation Plan—National Elk Refuge, Wyoming RESPONSE Comment number LETTER #16—Wyoming Wildlife Advocates, page 2 of 2
D.1 Lists of Federally Listed and State-Listed Plants and Animals

Plant species of concern listed in Wyoming are shown below.

Scientific name Common name

Aster borealis Rush aster

Astragalus terminalis Railhead milkvetch

Carex buxbaumii Buxbaum’s sedge 

Carex parryana Parry sedge 

Carex scirpoidea scripiformis Canadian single-spike sedge 

Eriophorum viridicarinatum Green-keeled cotton-grass 

Heterotheca villosa var. depressa Teton golden aster 

Lesquerella carinata Keeled bladderpod 

Muhlenbergia glomerata Marsh muhly 

Salix candida Hoary willow 

Scirpus rollandii Pygmy bulrush

Utricularia intermedia Flat-leaf bladderwort 

Animal species listed under the Federal Endangered Species Act and by the State of Wyoming (species of 

greatest conservation need), with documented occurrence on the National Elk Refuge in Wyoming follow: 

Federally threatened—a plant or animal species listed under the Endangered Species Act of 1973, as amended, 

that is likely to become endangered within the foreseeable future throughout all or a significant part of its 

range; Federal candidate—a plant or animal species proposed for addition to the Federal endangered and 

threatened species list; Wyoming tier 1—highest priority species of greatest conservation need: Wyoming tier 

2—moderate priority species of greatest conservation need.

Scientific name Common name Documented refuge use

Federally threatened

Ursos arctos Grizzly bear Incidental

Federal candidate

Centrocercus urophasianus Greater sage-grouse (also WY tier 1) Year-round, breeding documented

Wyoming tier 1

Anaxyrus boreas boreas Boreal toad Year-round, breeding documented

Athene cunicularia Burrowing owl Incidental

Buteo regalis Ferruginous hawk Seasonal

Gavia immer Common loon Incidental

Haliaeetus leucocephalus Bald eagle Year-round, breeding documented

Strix nebulosa Great gray owl Incidental

What follows are the names of animals and plants found on the National Elk Refuge.

Appendix D

Species Lists
244 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name Documented refuge use

Wyoming tier 2

Rana luteiventris Columbia spotted frog Year-round, breeding documented

Charina bottae Northern rubber boa Incidental

Thamnophis sirtalis fitchi Valley gartersnake Incidental

Anas acuta Northern pintail Seasonal

Asio flammeus Short-eared owl Seasonal

Aythya affinis Lesser scaup Seasonal, breeding documented

Aythya americana Redhead Seasonal, breeding documented

Botaurus lentiginosus American bittern Seasonal

Bucephala islandica Barrow’s goldeneye Seasonal

Buteo swainsoni Swainson’s hawk Seasonal

Calamospiza melanocorys Lark bunting Incidental

Cygnus buccinator Trumpeter swan Year-round, breeding documented

Dolichonyx oryzivorus Bobolink Seasonal, breeding documented

Falco peregrinus Peregrine falcon Seasonal

Hydroprogne caspia Caspian tern Incidental

Larus pipixcan Franklin’s gull Seasonal

Melanerpes lewis Lewis’s woodpecker Seasonal

Numenius americanus Long-billed curlew Seasonal, breeding documented

Nycticorax nycticorax Black-crowned night-heron Incidental

Rallus limicola Virginia rail Incidental

Spizella breweri Brewer’s sparrow Seasonal, breeding documented

Tympanuchus phasianellus 

columbianus Columbian sharp-tailed grouse Incidental

Alces alces Moose Year-round, breeding documented

Lontra canadensis Northern river otter Year-round, breeding documented

Myotis lucifugus Little brown myotis Seasonal

Ovis canadensis Bighorn sheep Year-round, breeding documented

Wyoming tier 3

Empidonax traillii Willow flycatcher Seasonal

Falco columbarius Merlin Seasonal

Grus canadensis Sandhill crane Seasonal, breeding documented

D.2 Plant Species

The following lists show the scientific and common names of the plant species that have been found on the 

National Elk Refuge in Wyoming. An asterisk (*) indicates a nonnative species.

Scientific name Common name

Achillea millefolium var. alpicola Common yarrow

Achnatherum hymenoides Indian ricegrass

Achnatherum nelsonii ssp. nelsonii Nelson’s needlegrass

Agoseris glauca var. glauca Short-beaked agoseris
Appendix D—Species Lists 245 

Scientific name Common name

Agoseris glauca var. laciniata Short-beaked agoseris

Agropyron cristatum Crested wheatgrass*

Agrostis stolonifera Redtop*

Allium cernuum Nodding onion

Allium schoenoprasum var. schoenoprasum Wild chives*

Alopecurus aequalis Shortawn foxtail

Alopecurus pratensis Meadow foxtail*

Alyssum alyssoides Pale alyssum*

Alyssum desertorum var. desertorum Desert alyssum*

Amaranthus albus White pigweed

Amelanchier alnifolia var. alnifolia Western serviceberry

Anemone multifida Cliff anemone

Angelica arguta Sharptooth angelica

Angelica pinnata Pinnate-leaved angelica

Antennaria dimorpha Low pussytoes

Antennaria microphylla Small-leaf pussytoes

Antennaria pulcherrima Showy pussytoes

Antennaria rosea Rosy pussytoes

Antennaria umbrinella Umber pussytoes

Arabis drummondii Drummond’s rockcress

Arabis glabra Towermustard

Arabis holboellii Holboell’s rockcress

Arenaria congesta Ballhead sandwort

Argentina anserina Silverweed

Arnica sororia Twin arnica

Artemisia biennis var. biennis Biennial wormwood*

Artemisia frigida Fringed sagewort

Artemisia ludoviciana ssp. ludoviciana Louisiana sagebrush

Artemisia tridentata ssp. tridentata Basin big sagebrush

Artemisia tridentata ssp. vaseyana Mountain big sagebrush

Artemisia tripartita ssp. tripartita Threetip sagebrush

Astragalus agrestis Field milkvetch

Astragalus argophyllus var. argophyllus Silver-leaved milkvetch

Astragalus canadensis var. brevidens Canada milkvetch

Astragalus diversifolius var. campestris Lesser rushy milkvetch

Astragalus eucosmus Elegant milkvetch

Astragalus miser var. decumbens Sagebrush weedy milkvetch

Astragalus miser var. tenuifolius Weedy milkvetch

Astragalus purshii var. purshii Wooly milkvetch

Astragalus terminalis Railhead milkvetch

Atriplex rosea Red orache*

Atriplex truncata Wedgescale orache

Balsamorhiza sagittata Arrowleaf balsamroot

Besseya wyomingensis Wyoming kittentails

Betula glandulosa Bog birch
246 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Betula occidentalis Water birch

Bidens cernua Nodding beggarticks

Bromus carinatus California brome

Bromus ciliatus Fringed brome

Bromus inermis ssp. inermis Smooth brome*

Bromus tectorum Cheatgrass*

Calamagrostis canadensis Bluejoint wheatgrass

Calamagrostis rubescens Pinegrass

Calamagrostis stricta Slimstem reedgrass

Callitriche palustris Spring water starwort

Calochortus nuttallii Sego-lily

Camelina microcarpa Littlepod falseflax*

Campanula rotundifolia Harebell

Capsella bursa-pastoris Shepherd’s purse*

Caragana arborescens Peatree*

Cardaria chalapensis Chalapa hoarycress, whitetop*

Carduus acanthoides Plumeless thistle*

Carduus nutans Musk thistle*

Carex aquatilis Water sedge

Carex aurea Golden sedge

Carex buxbaumii Buxbaum’s sedge 

Carex capillaris Hair sedge

Carex duriuscula Narrow-leaved sedge

Carex filifolia Thread-leaved sedge

Carex interior Inland sedge

Carex microptera Small-wing sedge

Carex nebrascensis Nebraska sedge

Carex parryana var. parryana Parry sedge

Carex pellita Woolly sedge

Carex praegracilis Clustered field sedge

Carex rossii Ross sedge 

Carex rostrata Beaked sedge

Carex sartwellii Sartwell’s sedge

Carex scirpoidea ssp. scirpoidea Canadian single-spike sedge

Carex simulata Analogue sedge

Carex viridula Green sedge

Castilleja angustifolia var. angustifolia Narrowleaf paintbrush

Castilleja angustifolia var. dubia Desert paintbrush

Castilleja flava Yellow paintbrush

Castilleja miniata Scarlet paintbrush

Catabrosa aquatica Brookgrass

Cerastium beeringianum ssp. earlei Alpine chickweed

Cercocarpus ledifolius var. ledifolius Curl-leaf mountain mahogany

Chaenactis douglasii var. douglasii Hoary dustymaiden

Chamerion angustifolium Fireweed
Appendix D—Species Lists 247 

Scientific name Common name

Chenopodium berlandieri var. zschackii Pitseed goosefoot

Chenopodium foliosum Smallhead goosefoot*

Chenopodium pratericola Mountain goosefoot

Chrysothamnus viscidiflorus ssp. lanceolatus Green rabbitbrush

Chrysothamnus viscidiflorus ssp. viscidiflorus Green rabbitbrush

Cirsium arvense Canada thistle*

Cirsium scariosum Elk thistle

Cirsium subniveum Snowy thistle

Cirsium vulgare Bull thistle*

Clematis hirsutissima Leatherflower

Clematis occidentalis var. grosseserrata Rock virgin’s bower

Collomia linearis Narrowleaf collomia

Comandra umbellata ssp. pallida Bastard toad-flax

Convolvulus arvensis Field bindweed*

Cordylanthus ramosus Bushy birdbeak

Cornus sericea Redosier dogwood

Corydalis aurea Golden-smoke

Crataegus douglasii Black hawthorn

Crepis acuminata Tapertip hawksbeard 

Crepis modocensis Siskiyou hawksbeard

Crepis runcinata ssp. glauca Meadow hawksbeard

Crepis runcinata ssp. hispidulosa Broad-leaved meadow hawksbeard

Dactylis glomerata Orchardgrass*

Dasiphora fruticosa ssp. floribunda Shrubby cinquefoil

Delphinium bicolor Little larkspur

Deschampsia cespitosa Tufted hairgrass

Descurainia incana ssp. procera Mountain tansymustard

Descurainia sophia Flixweed*

Dodecatheon pulchellum Dark-throat shooting star

Elaeagnus commutata Silverberry

Eleocharis acicularis Slender spikerush

Eleocharis palustris Common spikerush

Elymus albicans Griffith’s wheatgrass

Elymus elymoides Bottlebrush squirreltail

Elymus lanceolatus Thickspike wheatgrass

Elymus lanceolatus ssp. lanceolatus Riparian thickspike wheatgrass

Elymus repens Common quackgrass*

Elymus trachycaulus ssp. trachycaulus Slender wheatgrass 

Epilobium brachycarpum Panicled willow-herb

Epilobium ciliatum ssp. ciliatum American willow-herb

Epilobium hornemannii Hornemann’s willow-herb

Epilobium leptophyllum Swamp willow-herb

Equisetum hyemale var. affine Common scouring-rush

Equisetum laevigatum Smooth scouring-rush

Equisetum variegatum Northern scouring-rush
248 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Ericameria nauseosa ssp. nauseosa var. nauseosa Rubber rabbitbrush

Erigeron compositus Cut-leaved fleabane

Erigeron corymbosus Foothill daisy

Erigeron glabellus var. glabellus Smooth daisy

Erigeron lonchophyllus Spear-leaf fleabane

Erigeron pumilus Shaggy fleabane

Eriogonum brevicaule var. laxifolium Shortstem buckwheat

Eriogonum caespitosum Mat buckwheat

Eriogonum ovalifolium var. purpureum Cushion buckwheat

Eriogonum umbellatum var. majus Sulfur buckwheat

Eriophorum angustifolium ssp. subarcticum Many-spiked cottongrass

Eriophorum viridicarinatum Green-keeled cottongrass

Erysimum capitatum var. capitatum Sanddune wallflower

Erysimum cheiranthoides Treacle wallflower*

Eucephalus elegans Elegant aster

Festuca idahoensis Idaho fescue

Festuca ovina Sheep fescue

Fragaria virginiana Virginia strawberry

Frasera speciosa Monument plant

Frasera speciosa Green gentian

Fritillaria atropurpurea Checker lily

Galium boreale Northern bedstraw

Galium trifidum Small bedstraw

Gentiana affinis Prairie gentian

Gentiana fremontii Water gentian

Geranium viscosissimum var. incisum Sticky geranium

Geranium viscosissimum var. viscosissimum Sticky geranium

Geum macrophyllum var. perincisum Large-leaved avens

Geum triflorum Prairie-smoke

Glaux maritima Sea-milkwort

Glyceria grandis American mannagrass

Glyceria striata Fowl mannagrass

Glycyrrhiza lepidota Licorice-root

Gnaphalium palustre Lowland cudweed

Grindelia squarrosa Curly-cup gumweed

Gutierrezia sarothrae Broom snakeweed

Hackelia floribunda Many-flowered stickseed

Hedysarum boreale Northern sweet-vetch

Helianthella uniflora Rocky Mountain helianthella

Heracleum maximum Cow parsnip

Hesperostipa comata ssp. intermedia Needle and thread

Heterotheca villosa var. depressa Teton golden aster

Heuchera parvifolia Littleleaf alumroot

Hierochloe odorata Common sweetgrass

Hippuris vulgaris Common mare’s-tail
Appendix D—Species Lists 249 

Scientific name Common name

Hordeum brachyantherum Meadow barley

Hordeum jubatum Foxtail barley

Hypericum scouleri ssp. scouleri Western St. John’s-wort

Ipomopsis aggregata Scarlet gilia

Ipomopsis spicata ssp. orchidacea Mountain spicate-gilia

Juncus arcticus ssp. littoralis Baltic rush

Juncus longistylis Long-styled rush

Juncus nodosus Tuberous rush

Juncus saximontanus Rocky Mountain rush

Juncus tenuis var. dudleyi Slender rush

Juniperus communis var. depressa Common juniper

Juniperus scopulorum Rocky Mountain juniper

Koeleria macrantha Junegrass

Krascheninnikovia lanata Winterfat

Lactuca serriola Prickly lettuce*

Lappula occidentalis var. occidentalis Western stickseed

Lappula squarrosa European stickseed*

Lemna minor Lesser duckweed

Lepidium densiflorum Common peppergrass

Lepidium perfoliatum Clasping peppergrass*

Leptosiphon septentrionalis Northern linanthus

Lesquerella carinata var. carinata Keeled bladderpod

Leucopoa kingii Spikefescue

Leymus cinereus Great Basin wildrye

Linanthus pungens Common prickly-phlox

Linum lewisii Blue flax

Lithospermum ruderale Western gromwell

Lomatium foeniculaceum Fennel-leaved biscuitroot

Lomatium simplex var. simplex Nineleaf biscuitroot

Lonicera involucrata Bearberry honeysuckle

Lupinus argenteus ssp. argenteus Silvery lupine

Lupinus argenteus var. rubricaulis Silvery lupine

Lupinus sericeus Silky lupine

Machaeranthera canescens ssp. canescens Hoary aster

Mahonia repens Oregon-grape

Maianthemum stellatum Starry false Solomon’s-seal

Malcolmia africana Malcolmia*

Matricaria discoidea Pineapple-weed*

Medicago lupulina Black medic*

Medicago sativa ssp. sativa Alfalfa*

Melilotus officinalis White sweetclover*

Melilotus officinalis Yellow sweetclover*

Mentha arvensis Field mint

Mertensia ciliata Ciliate bluebells

Mertensia oblongifolia Leafy bluebells
250 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Mimulus guttatus Yellow monkeyflower

Minuartia nuttallii ssp. nuttallii Nutall’s sandwort

Monolepis nuttalliana Povertyweed

Muhlenbergia filiformis Pullup muhly

Muhlenbergia glomerata Marsh muhly

Muhlenbergia richardsonis Mat muhly

Myosotis scorpioides Common forget-me-not*

Myriophyllum sibiricum Common watermilfoil

Nassella viridula Green needlegrass

Nasturtium officinale Watercress

Oenothera caespitosa ssp. caespitosa Tufted evening-primrose

Oenothera pallida ssp. trichocalyx Pale evening-primrose

Opuntia polyacantha var. polyacantha Plains prickly-pear

Orthocarpus luteus Yellow owl-clover

Oxytropis deflexa var. sericea Nodding locoweed

Packera cana Woolly groundsel

Packera debilis Weak groundsel

Packera paupercula Balsam groundsel

Packera streptanthifolia Alpine meadow groundsel

Packera streptanthifolia Cleft-leaved groundsel

Parnassia palustris var. montanensis Northern grass-of-Parnassus

Pedicularis crenulata Meadow lousewort

Pedicularis groenlandica Elephanthead lousewort

Penstemon humilis Lowly beardtongue

Penstemon procerus var. procerus Small-flower beardtongue

Penstemon radicosus Matroot beardtongue

Penstemon subglaber Subglabrous beardtongue

Petrophyton caespitosum Rocky Mountain rockmat

Phacelia franklinii Franklin’s phacelia

Phalaris arundinacea Reed canarygrass

Phleum alpinum Alpine timothy

Phleum pratense Timothy*

Phlox hoodii Hood’s phlox

Phlox kelseyi ssp. kelseyi Kelsey’s phlox

Phlox longifolia Long-leaf phlox

Phlox multiflora Many-flowered phlox

Picea engelmannii Engelmann spruce

Picea pungens Blue spruce

Pinus contorta Lodgepole pine

Pinus flexilis Limber pine

Plantago eriopoda Alkali plantain

Plantago major Common plantain

Platanthera aquilonis Northern green bog-orchid

Poa annua Annual bluegrass*

Poa bulbosa Bulbous bluegrass*
Appendix D—Species Lists 251 

Scientific name Common name

Poa cusickii ssp. epilis Cusick’s bluegrass

Poa palustris Fowl bluegrass

Poa pratensis Kentucky bluegrass

Poa secunda Sandberg bluegrass

Polemonium occidentale Western Jacob’s-ladder

Polygonum achoreum Erect knotweed

Polygonum amphibium var. stipulaceum Water smartweed

Polygonum aviculare Common knotweed*

Polygonum douglasii ssp. douglasii Douglas’ knotweed

Polygonum viviparum Alpine bistort

Populus angustifolia Narrowleaf cottonwood

Populus tremuloides Quaking aspen

Potentilla arguta Glandular cinquefoil

Potentilla gracilis var. fastigiata Slender cinquefoil 

Potentilla gracilis var. pulcherrima Soft cinquefoil

Potentilla norvegica Norwegian cinquefoil

Potentilla ovina var. ovina Sheep cinquefoil

Potentilla pensylvanica Prairie cinquefoil

Primula incana Mealy primrose

Prunella vulgaris ssp. lanceolata Self-heal

Prunus virginiana var. melanocarpa Chokecherry

Psathyrostachys juncea Russian wildrye*

Pseudoroegneria spicata ssp. spicata Bluebunch wheatgrass

Pseudotsuga menziesii Douglas-fir

Pulsatilla patens ssp. multifida Pasqueflower

Purshia tridentata Bitterbrush

Pyrrocoma uniflora var. uniflora One-flowered goldenweed

Ranunculus aquatilis var. diffusus new name White water buttercup

Ranunculus cymbalaria Shore buttercup

Ranunculus glaberrimus var. ellipticus Sagebrush buttercup

Ranunculus hyperboreus Floating water buttercup

Ranunculus inamoenus var. inamoenus Unlovely buttercup

Ranunculus macounii Macoun’s buttercup

Ranunculus sceleratus var. multifidus Blister buttercup

Ribes aureum var. aureum Golden currant

Ribes cereum var. cereum Wax currant

Ribes oxyacanthoides ssp. setosum Missouri gooseberry

Rorippa curvipes var. truncata Wasatch yellowcress

Rosa acicularis ssp. sayi Prickly rose

Rosa woodsii var. woodsii Woods’ rose

Rumex aquaticus var. fenestratus Western dock

Rumex maritimus var. fueginus Golden dock

Rumex salicifolius var. mexicanus Willow dock

Salix bebbiana Bebb willow

Salix boothii Booth’s willow
252 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Salix brachycarpa Smallfruit willow

Salix candida Hoary willow

Salix drummondiana Drummond’s willow

Salix exigua Narrowleaf willow

Salix geyeriana Geyer willow

Salix lucida ssp. caudata Greenleaf willow

Salix lutea Yellow willow

Salix melanopsis Dusky willow

Salix planifolia Planeleaf willow

Salsola tragus Russian thistle*

Schoenocrambe linifolia Flax-leaved plainsmustard

Schoenoplectus acutus var. acutus Hardstem bulrush

Schoenoplectus tabernaemontani Soft-stem bulrush

Scutellaria galericulata Marsh skullcap

Sedum lanceolatum Lance-leaved stonecrop

Selaginella densa Compact spike-moss

Senecio hydrophilus Water groundsel

Senecio integerrimus var. exaltatus Western groundsel

Senecio serra Butterweed groundsel

Shepherdia canadensis Canada buffaloberry

Silene latifolia White campion*

Sisymbrium altissimum Tumblemustard*

Sisyrinchium idahoense var. occidentale Western blue-eyed grass

Sium suave Hemlock waterparsnip

Solidago canadensis var. salebrosa Canada goldenrod

Solidago missouriensis var. missouriensis Missouri goldenrod

Solidago nana Low goldenrod

Sonchus arvensis ssp. uliginosus Marsh sow-thistle*

Spiranthes romanzoffiana Hooded lady’s tresses

Stellaria crassifolia Thickleaved starwort 

Stellaria longipes Longstalk starwort

Stenotus acaulis Stemless goldenweed

Stuckenia filiformis ssp. filiformis Slender-leaved pondweed

Stuckenia pectinata Fennel-leaved pondweed

Swertia perennis Swertia

Symphoricarpos oreophilus var. utahensis Mountain snowberry

Symphyotrichum ascendens Long-leaved aster

Symphyotrichum boreale Boreal aster

Symphyotrichum eatonii Eaton’s aster

Symphyotrichum foliaceum var. apricum Leafybract aster

Symphyotrichum spathulatum var. spathulatum Western mountain aster

Taraxacum laevigatum Red-seeded dandelion*

Taraxacum officinale Common dandelion

Tetradymia canescens Gray horsebrush

Thalictrum alpinum Alpine meadowrue
Appendix D—Species Lists 253 

Scientific name Common name

Thalictrum venulosum Veiny meadowrue

Thelypodium paniculatum Panicled thelypody

Thinopyrum intermedium Intermediate wheatgrass*

Thlaspi arvense Field pennycress*

Townsendia nuttallii Nuttall’s Easter-daisy

Tragopogon dubius Yellow salsify*

Trichophorum pumilum Pygmy bulrush

Trifolium hybridum Alsike clover*

Trifolium pratense Red clover*

Trifolium repens White clover*

Triglochin maritima Seaside arrowgrass

Triglochin palustris Marsh arrowgrass

Typha latifolia Common cattail

Urtica dioica Stinging nettle

Utricularia intermedia Flat-leaf bladderwort

Utricularia macrorhiza Greater bladderwort

Valeriana edulis Tobacco-root

Valeriana occidentalis Western valerian

Verbascum thapsus Common mullein*

Verbena bracteata Bracted vervain

Veronica americana American brooklime

Veronica anagallis-aquatica Water speedwell

Vicia americana ssp. minor American vetch

Vicia cracca Bird vetch*

Viola adunca Early blue violet

Viola palustris Marsh violet

Viola praemorsa ssp. linguifolia Upland yellow violet

Zannichellia palustris Horned pondweed

Zigadenus paniculatus Panicled death-camas

Zizia aptera Heart-leaved Alexanders

D.3 Mammal Species

The following lists show the scientific and common names of the mammal species that have been found on 

the National Elk Refuge in Wyoming.

Scientific name Common name

Insectivora Insectivores

Sorex cinereus Masked shrew

Sorex merriami Merriam’s shrew

Sorex monticolus Dusky or montane shrew

Sorex palustris Water shrew
254 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Chiroptera Bats

Verspertilionidae

Eptesicus fuscus Big brown bat

Lasionycteris noctivagans Silver-haired bat

Lasiurus cinereus Hoary bat

Myotis ciliolabrum Small-footed myotis

Myotis evotis Long-eared myotis 

Myotis lucifugus Little brown myotis 

Myotis volans Long-legged myotis 

Plecotus townsendii Townsend’s big-eared bat

Lagomorpha Rabbits and Hares

Leporidae

Lepus americanus Snowshoe hare

Lepus townsendii White-tailed jackrabbit

Rodentia Rodents

Sciuridae (Squirrels)

Glaucomys sabrinus Northern flying squirrel 

Marmota flaviventris Yellow-bellied marmot 

Spermophilus armatus Uinta ground squirrel 

Tamias amoenus Yellow-pine chipmunk 

Tamias minimus Least chipmunk 

Tamiasciurus hudsonicus Red squirrel (pine squirrel, chickaree)

Geomyidae (Pocket gophers)

Thomomys talpoides Northern pocket gopher

Castoridae (Beavers)

Castor canadensis Beaver

Cricetidae

Neotoma cinerea Bushy tailed woodrat

Peromyscus maniculatus Deer mouse

Arvicolinae (subfamily)

Clethrionomys gapperi Southern red-backed vole

Lemmiscus curtatus Sagebrush vole

Microtus longicaudus Long-tailed vole 

Microtus montanus Montane vole 

Microtus pennsylvanicus Meadow vole

Microtus richardsoni Water vole 

Microtus richardsoni Richardson’s vole 

Ondatra zibethicus Muskrat 

Murinae (subfamily)

Mus musculus House mouse

Dipodidae

Zapus princeps Western jumping mouse

Erethizontidae (Porcupines)

Erethizon dorsatum Porcupine
Appendix D—Species Lists 255 

Scientific name Common name

Carnivora Carnivores

Canidae (Canids)

Canis latrans Coyote

Canis lupus Gray wolf

Vulpes vulpes Red fox

Ursidae (Bears)

Ursus americanus Black bear

Ursus arctos Grizzly bear

Procyonidae (Raccoons)

Procyon lotor Raccoon

Mustelidae (Mustelids)

Lutra canadensis Northern river otter 

Mephitis mephitis Striped skunk

Mustela erminea Ermine (short-tailed weasel)

Mustela frenata Long-tailed weasel 

Mustela vison Mink

Taxidea taxus Badger

Felidae (Felids)

Lynx rufus Bobcat

Puma concolor Mountain lion

Artiodactyla Hoofed mammals

Cervidae

Alces alces Moose 

Antilocarpa americana Pronghorn 

Cervus elaphus Elk (wapiti) 

Odocoileus hemionus Mule deer

Odocoileus virgianus White-tailed deer

Bovidae

Bison bison Bison (American buffalo)

Ovis canadensis Mountain sheep (bighorn sheep)

D.4 Bird Species

The following lists show the scientific and common names of the mammal species that have been found on 

the National Elk Refuge in Wyoming. An asterisk (*) indicates a nonnative species.

Scientific name Common name

Hummingbirds

Selasphorus platycercus Broad-tailed hummingbird 

Selasphorus rufus Rufous hummingbird 

Stellula calliope Calliope hummingbird
256 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Perching birds

Agelaius phoeniceus Red-winged blackbird

Thus rubescens American pipit

Bombycilla cedrorum Cedar waxwing

Bombycilla garrulus Bohemian waxwing

Carduelis pinus Pine siskin

Carduelis tristis American goldfinch

Carpodacus cassinii Cassin’s finch

Carpodacus mexicanus House finch

Catharus fuscescens Veery

Catharus guttatu Hermit thrush

Catharus ustulatus Swainson’s thrush

Certhia americana Brown creeper

Cinclus mexicanus American dipper

Cistothorus palustris Marsh wren

Contopus sordidulus Western wood-pewee

Corvus brachyrhynchos Common crow

Corvus corax Common raven

Dendroica petechia Yellow warbler

Dolichonyx oryzivorus Bobolink

Dumetella carolinensis Gray catbird

Empidonax minimus Least flycatcher

Empidonax oberholseri Dusky flycatcher

Empidonax occidentalis Cordilleran flycatcher

Empidonax trailii Willow flycatcher

Eremophila alpestris Horned lark

Euphagus cyanocephalus Brewer’s blackbird

Geothlypis trichas Common yellowthroat

Hirundo rustica Barn swallow

Icteria virens Yellow-breasted chat 

Icterus bullockii Bullock’s oriole

Junco hyemalis Dark-eyed junco

Lanius excubitor Northern shrike

Lanius ludovicianus Loggerhead shrike

Leucosticte tephrocotis Gray-crowned rosy finch

Loxia curvirostra Red crossbill

Loxia leucoptera White-winged crossbill

Melospiza melodia Song sparrow

Melospiza lincolnii Lincoln’s sparrow 

Molothrus ater Brown-headed cowbird 

Myadestes townsendi Townsend’s solitaire

Nucifraga columbiana Clark’s nutcracker

Oporornis tolmiei MacGillivray’s warbler

Passer domesticus House sparrow

Passerculus sandwichensis Savannah sparrow
Appendix D—Species Lists 257 

Scientific name Common name

Passerella iliaca Fox sparrow

Passerina amoena Lazuli bunting

Perisoreus canadensis Gray jay

Petrochelidon pyrrhonota Cliff swallow

Pheucticus melanocephalus Black-headed grosbeak

Pica hudsonia Black-billed magpie 

Pipilo chlorurus Green-tailed towhee

Piranga ludoviciana Western tanager 

Plectrophenax nivalis Snow bunting

Poecile atricapilla Black-capped chickadee 

Poecile gambile Mountain chickadee

Pooecetes gramineus Vesper sparrow

Regulus satrapa Golden-crowned kinglet

Regulus calendula Ruby-crowned kinglet

Riparia riparia Bank swallow

Salpinctes obsoletus Rock wren

Sayornis saya Say’s phoebe

Seiurus noveboracensis Northern waterthrush

Setophaga ruticilla American redstart 

Sialia currucoides Mountain bluebird 

Sitta canadensis Red-breasted nuthatch

Sitta carolinensis White-breasted nuthatch

Spizella breweri Brewer’s sparrow 

Spizella passerina Chipping sparrow 

Stelgidopteryx serripennis Northern rough-winged swallow

Sturnella neglecta Western meadowlark 

Sturnus vulgaris European starling*

Tachycineta bicolor Tree swallow 

Tachycineta thalassina Violet-green swallow 

Troglodytes aedon House wren

Turdus migratorius American robin 

Tyrannus tyrannus Eastern kingbird 

Tyrannus verticalis Western kingbird

Vermivora celat Orange-crowned warbler

Vireo gilvus Warbling vireo 

Wilsonia pusilla Wilson’s warbler 

Xanthocephalus xanthocephalus Yellow-headed blackbird

Zonotrichia leucophrys White-crowned sparrow

Woodpeckers

Colaptes auratus Northern flicker 

Melanerpes lewis Lewis’ woodpecker 

Picoides pubescens Downy woodpecker 

Picoides villosus Hairy woodpecker 

Sphyrapicus nuchalis Red-naped sapsucker 

Sphyrapicus thyroideus Williamson’s sapsucker
258 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Gallinaceous birds

Alectoris chukar Chukar*

Perdix perdix Gray partridge*

Tympanuchus phasianellus columbianus Columbian sharp-tailed grouse

Bonasa umbellus Ruffed grouse

Centrocercus urophasianus Greater sage-grouse

Dendragapus obscurus Blue grouse

Waterfowl

Anas acuta Northern pintail

Anas americana American wigeon

Anas clypeata Northern shoveler

Anas crecca Green-winged teal

Anas cyanoptera Cinnamon teal

Anas platyrhynchos Mallard

Anas strepera Gadwall

Aythya affinis Lesser scaup

Aythya americana Redhead

Aythya collaris Ringed-neck duck

Branta canadensis Canada goose

Bucephala albeola Bufflehead

Bucephala clangula Common goldeneye

Bucephala islandica Barrow’s goldeneye

Chen caerulescens Snow goose

Cygnus buccinator Trumpeter swan 

Cygnus columbianus Tundra swan

Lophodytes cucullatus Hooded merganser

Mergus merganser Common merganser

Oxyura jamaicensis Ruddy duck

Shorebirds

Actitis macularia Spotted sandpiper

Capella gallinago Common snipe

Catoptrophorus semipalmatus Willet

Charadrius vociferus Killdeer

Ereubetes mauri Western sandpiper

Eupoda montana Mountain plover

Himantopus mexicanus Black-necked stilt

Limnodromus scolopaceus Long-billed dowitcher

Limosa fedoa Marbled godwit

Numenius americanus Long-billed curlew

Phalaropus tricolor Wilson’s phalarope

Recurvirostra americana American avocet

Tringa flavipes Lesser yellowlegs

Tringa melanoleuca Greater yellowlegs

Rails and coots

Coturnicops noveboracensis Yellow rail
Appendix D—Species Lists 259 

Scientific name Common name

Fulica americana American coot 

Porzana carolina Sora

Cranes

Grus canadensis Sandhill crane

Bitterns, herons, and ibis

Plegadis chihi White-faced ibis

Ardea herodias Great blue heron 

Botaurus lentiginosus American bittern 

Bubulcus ibis Cattle egret 

Leucophoyx thula Snowy egret

Nycticorax nycticorax Black-crowned night-heron

Raptors

Accipiter cooperii Cooper’s hawk

Accipiter striatus Sharp-shinned hawk

Aquila chrysaetos Golden eagle

Buteo jamaicensis Red-tailed hawk

Buteo lagopus Rough-legged hawk

Buteo swainsoni Swainson’s hawk

Cathartes aura Turkey vulture

Circus cyaneus Northern harrier

Falco columbarius Merlin

Falco mexicanus Prairie falcon

Falco peregrinus Peregrine falcon 

Falco sparverius American kestrel 

Haliaeetus leucocephalus Bald eagle 

Pandion haliaetus Osprey

Owls

Aegolius acadicus Northern saw-whet owl

Asio flammeus Short-eared owl

Asio otus Long-eared owl

Athene cunicularia Burrowing owl 

Bubo virginianus Great-horned owl 

Strix nebulosa Great grey owl

Seabirds

Aechmophorus occidentalis Western grebe

Pelecanus erythrorhynchos White pelican 

Phalacrocorax auritus Double-crested cormorant 

Podiceps caspicus Eared grebe

Podilymbus podiceps Pied-billed grebe

Gulls and terns

Chlidonias niger Black tern

Larus californicus California gull

Larus philadelphia Bonaparte’s gull 

Larus pipixcan Franklin’s gull 

Sterna caspia Caspian tern
260 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Scientific name Common name

Sterna forsteri Forster’s turn

Other birds

Gavia immer Common loon

Ceryle alcyon Belted kingfisher

Chordeiles minor Common nighthawk

Columba livia Rock dove*

Streptopelia decaocto Eurasian collared dove*

Zenaida macroura Mourning dove

D.5 Amphibian and Reptile Species

The following lists show the scientific and common names of the amphibian and reptile species that have 

been found on the National Elk Refuge in Wyoming.

Scientific name Common name

Ambystoma tigrinum Tiger salamander

Bufo boreas boreas Boreal toad

Charina bottae bottae Rubber boa

Pseudacris maculate Boreal chorus frog

Rana luteiventris Columbia spotted frog

Thannophis elegans vagrans Intermountain wandering garter snake

Thamnophis sirtalis fitchi Valley garter snake

D.6 Fish Species

The following lists show the scientific and common names of the fish species that have been found on the 

National Elk Refuge in Wyoming. An asterisk (*) indicates a nonnative species.

Scientific name Common name

Catostomus discobolus Bluehead sucker

Catostomus ardens Utah sucker

Catostomus platyrhynchus Mountain sucker

Cottus bairdi Mottled sculpin

Cottus beldingi Paiute sculpin

Oncorhynchus clarkii Snake River cutthroat trout

Oncorhynchus clarkia ssp. x O. mykiss Snake River cutthroat trout x rainbow trout hybrid

Oncorhynchus mykiss Rainbow trout*

Pimephales promelas Fathead minnow*

Prosopium williamsoni Mountain whitefish

Richardsonius balteatus Redside shiner
Appendix D—Species Lists 261 

Scientific name Common name

Rhinichthys cataractae Longnose dace

Rhinichthys osculus Speckled dace

Salmo trutta Brown trout*

Salvelinus fontinalis Eastern brook trout*

Appendix E

Compatibility Determinations

E.1 Refuge Name and Date 

Established

■ National Elk Refuge

■ Established August 10, 1912

E.2 Refuge Purposes

The following excerpts describe the various purposes of the refuge as set in legal orders, laws, and 

regulations:

■ as “a winter game (elk) reserve” (16 U.S.C. § 

673, 37 Stat.293)

■ as “a winter elk refuge” (37 Stat. 847)

■ for “refuge and breeding grounds for birds” 

(Executive Orders 3596 and 3741)

■ for “the grazing of, and as a refuge for, 

American elk and other big game animals” 

(16 U.S.C. § 673a, 44 Stat. 1246)

■ for “the conservation of fish and wildlife” (16 

U.S.C. § 742[a–j], Fish and Wildlife Act of 

1956)

■ for “opportunities for wildlife-oriented recreational development oriented to fish and 

wildlife, the protection of natural resources, 

and the conservation of threatened or 

endangered species” (16 U.S.C., § 460[k–l], 

Refuge Recreation Act)

E.3 National Wildlife Refuge 

System Mission

The mission of the Refuge System is to administer a national network of lands and waters for 

the conservation, management, and where 

appropriate, restoration of the fish, wildlife, and 

plant resources and their habitats within the 

United States for the benefit of present and future 

generations of Americans.

E.4 Description of Uses

The following uses are evaluated for their compatibility on the refuge:

■ Hunting

■ Fishing

■ Wildlife Observation and Noncommercial 

Photography

■ Environmental Education and 

Interpretation

■ Research and Monitoring

■ Commercial Filming, Audio Recording, and 

Still Photography

■ Commercial Guiding, Outfitting, Game 

Retrieval, and Wildlife-Viewing Tours
264 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Hunting

The CCP proposes to continue to provide elk and 

bison hunting consistent with the Bison and Elk Management Plan, including adaptively modifying hunting regulations to achieve herd size objectives and 

extending accommodations for hunters with disabilities. The refuge will continue to allow elk and bison 

retrieval from the Bridger-Teton National Forest to 

Elk Refuge Road south and west of Twin Creek subdivision, allow a ceremonial tribal bison hunt with 

annual harvest of up to five bison, prohibit the hunting of any other wildlife species other than elk and 

bison, and promote voluntary use of lead-free 

ammunition.

In addition, the refuge will expand hunting opportunities for young people. We will work with partners 

to develop a hunter mentoring program. By scheduling the existing youth hunt to later in the season, 

young hunters will have a better chance of observing 

and harvesting elk. Options will include designating 

a weekend midseason (of the adult hunter season) for 

youth only or adding a weekend after the end of the 

regular elk season.

The refuge will provide more outreach for other 

refuge users to promote education and awareness of 

the refuge hunting program. Staff will develop bear 

attractant regulations for hunting on the refuge, 

encourage the carry of bear spray while hunting, and 

consider requiring hunters to carry bear spray. Staff 

may develop hunter-use management tools such as 

hunter checkpoints, hunter success surveys, and 

mandatory reporting of tag use to better manage 

hunt program opportunities.

Staff will coordinate with WGFD to develop specific refuge hunting opportunities by making available limited-quota type 6 tags in Hunt Area 77 on the 

refuge to increase cow elk harvest. We will also work 

with WGFD to develop a limited-quota antlered elk 

hunt on the refuge to provide more quality opportunities using limited-quota, type 1 tags in Hunt Area 

77. The refuge will open currently closed areas on the 

southern and western boundaries of the refuge to 

archery hunters to create more harvest 

opportunities.

We will analyze and consider more hunter access 

areas and designated parking lots. The staff will look 

at more access for bison hunters on the northern end 

of the refuge though the Teton Valley Highlands subdivision, either on the western end of the subdivision 

to hunt retrieval road 6 or on the eastern end to hunt 

retrieval road 7. We will consider access for archery 

hunters on the western boundary of the refuge next 

to the Jackson National Fish Hatchery.

Availability of Resources

The refuge updates with available resources the 

current directional signs and brochures. Maintenance of access roads, parking, hunting and information kiosks, and public use signs is closely tied to 

Maintenance Management System funding. The refuge’s base money will pay for the update and printing 

of brochures.

The refuge will need more law enforcement staff 

and resources (1) to manage significant changes in 

the hunting program to reduce disturbance to wildlife and habitat, (2) to carry out and encourage preventative law enforcement efforts, and (3) to check 

compliance with public use and hunting regulations.

Anticipated Impacts of Use

The hunting program will continue to provide 

hunters ample opportunity for quality hunting experiences without materially detracting from the mission of the Refuge System or the establishing 

purposes of the refuge. We will keep the public use 

brochures and the refuge’s Web site up-to-date and 

readily available to hunters. Staff will continue to 

monitor hunter success and satisfaction through random contacts with hunters in the field and in the refuge office.

Elk and bison hunting programs on the National 

Elk Refuge are essential to achieve the population 

objectives outlined in the Bison and Elk Management 

Plan. Although hunting directly affects the hunted 

species and might indirectly disturb other species, 

limits on harvest and access for recreational hunting 

would make sure that populations do not fall to 

unsustainable levels. By its nature, hunting creates a 

disturbance to wildlife and directly affects the individual animals being hunted. We will design and 

monitor hunting to offer a safe and quality program 

and to keep adverse effects within acceptable limits.

Other effects from hunting activity include conflicts with individuals participating in wildlife-dependent, priority public uses such as wildlife observation 

and photography. This could decrease the visitor 

satisfaction during the hunting season.

Public Review and Comment

This compatibility determination was presented 

for public review and comment as part of the 45-day 

public comment period for the draft CCP and EA for 

the National Elk Refuge.

Determination

Hunting is a compatible use on the National Elk 

Refuge.
Appendix E—Compatibility Determinations 265 

Stipulations Necessary for Compatibility

Hunters will be required to follow refuge-specific 

regulations for acquisition of hunting permits; access, 

parking, and travel restrictions; and weapons and 

ammunition limitations. Limiting access and monitoring the use could help limit any adverse effects.

Justification

The National Wildlife Refuge System Act of 1966, 

other laws, and the Service’s policy allow hunting on 

a national wildlife refuge when it is compatible with 

the purposes for which the refuge was established 

and acquired. Hunting is a form of wildlife-dependent 

recreation and is identified as a priority public use in 

the Improvement Act. Based on anticipated biological 

effects described above and in the EA, we find that 

hunting on the refuge in accordance with State regulations will not interfere with the purposes for which 

the refuge was established and will support management objectives. Special refuge regulations are in 

place to reduce negative effects on habitat and 

wildlife.

Mandatory 15-year Reevaluation Date: 2030

Fishing

This use will be a continuation of the historical 

activity of noncommercial fishing. Public use areas 

such as parking and fishing areas, as well as interpretive panels, signs, kiosks, and other structures might 

be installed and supported to facilitate the fishing 

program. Areas on the refuge that are seasonally 

sensitive to migratory birds will remain closed to 

public entry and use. The refuge will open only 

selected areas to fishing. Special refuge regulations 

governing fishing will be available in refuge 

brochures.

The CCP proposes to allow fishing on the refuge 

in accordance with State regulations. The refuge will 

provide fishing opportunities during daylight hours. 

We will maintain fishing access along Highway 89, 

along with the parking turnouts along upper Flat 

Creek. The Gros Ventre River, upper Flat Creek, 

lower Flat Creek, lower Nowlin Creek and Sleeping 

Indian Pond are open to fishing according to season 

dates and regulations set by WGFD. All other refuge 

ponds, Flat Creek downstream from the old Crawford Bridge site, and Nowlin Creek upstream from 

the posted fishing boundary will remain closed to 

fishing.

Besides sponsoring Kids’ Fishing Day with Jackson National Fish Hatchery and WGFD, the refuge 

will start programs that attract more young people 

to fish at the refuge. Future programs could include 

casting instruction, fishing skills clinics, and a mentoring program for young anglers.

The Flat Creek fishery is managed for a native, 

wild, and trophy-sized population of Snake River cutthroat trout. Long-time devotees of Flat Creek 

report a decline in the opportunity to fish for large 

cutthroats. Recent fish surveys show that nonnative 

trout (brook, brown, and rainbow) account for almost 

half of the trout population in Flat Creek. There is a 

need for management of this fishery to support the 

quality of the fishing experience.

Availability of Resources

The refuge has adequate administrative and management staff to support the fishing program.

Anticipated Impacts of Use

Temporary disturbance of wildlife may occur near 

fishing activity. Fishing will temporarily decrease 

the fish population until natural reproduction or 

stocking replenished the population. Frequency of 

use will be directly dependent on fish populations and 

their feeding activity. When fish populations were 

high and active, public use will increase. Minimal 

disturbance to ground-nesting birds might occur 

from anglers walking along rivers and streams. Littering could also become a problem. We anticipate no 

long-term negative effects on resources.

Public Review and Comment

This compatibility determination was presented 

for public review and comment as part of the 45-day 

public comment period for the draft CCP and EA for 

the National Elk Refuge.

Determination

Fishing is be a compatible use on the National Elk 

Refuge in accordance with State regulations.

Stipulations Necessary for Compatibility

Refuge regulations allow access to fishing areas 

during daylight hours only. A scheduled gate opening 

at daylight on the August 1 season opening will be 

consistent with refuge regulations. We will post 

access gates with opening time information and conduct public outreach.

The typical Flat Creek anglers are avid flycasters 

that have adopted catch-and-release principles as 

their conservation ethic. The refuge needs to create 

an educational component that will convince our 

anglers to harvest nonnative trout. Special refuge 
266 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

regulations might be necessary to require anglers to 

remove nonnative trout caught in Flat Creek to meet 

management objectives.

Justification

Fishing is a form of wildlife-dependent recreations and is identified as a priority public use in the 

Improvement Act. Based on the biological effects 

addressed above and in the EA, we find that fishing 

will not interfere with the purposes for establishment of the refuge. Current staff levels and money 

are adequate. Special refuge regulations are in place 

to reduce negative effects on refuge habitat and 

wildlife.

Mandatory 15-year Reevaluation Date: 2030

Wildlife Observation and 

Noncommercial Photography

A variety of habitats and many species of wildlife 

on the refuge provide observation and photography 

opportunities year-round. The refuge will continue to 

provide wildlife observation and photography opportunities such as (1) observation blinds, (2) an up-todate species list for the refuge, and (3) allowing the 

use of portable viewing and photography blinds 

through the issuance of special use permits. These 

activities may take place on foot, bicycle, automobile, 

horse, cross-country skis, and snowshoes.

Refuge facilities bring visitors closer to wildlife. 

New facilities for observing and photographing wildlife (such as observation platforms, trails, auto tour 

routes, photography blinds, and webcams) may be 

developed. In addition, the CCP proposes maintaining access to existing turnouts, trails, and other 

observation sites. The primary viewing turnouts and 

designated observation sites follow:

■ upper viewing platform on the second story 

of the visitor center

■ Bert Raynes Boardwalk and remote-viewing platform on the eastern side of the visitor center lawn

■ turnout north of the visitor center and the 

Flat Creek Bridge, which has a viewing 

platform and National Elk Refuge sign 

(turnout will continue to be plowed in winter, thus providing year-round access to the 

turnout)

■ turnout along Highway 89 north of Jackson, 

which has a kiosk and interpretive panel 

about the purpose of the fence and the elk 

“jumps” (refer to “Fencing” in chapter 3, 

section 3.3) (turnout will continue to be 

plowed in winter by the Wyoming Department of Transportation, giving travelers on 

Highway 89 a safe place to pull over and 

view wildlife; however, plowed snow would 

pile up on the northern end of the turnout, 

blocking access to the kiosk and interpretive 

panel)

■ with added turnouts, about 10 turnouts will 

be available on Elk Refuge Road. They will 

be plowed during winter months to encourage vehicles to move off the road to view 

wildlife

Elk Refuge Road and Flat Creek Road will be 

open to the public for wildlife observation and access 

to national forest lands from May 1 through November 30. During winter, 3.5 miles of Elk Refuge Road 

(from the refuge entrance to the Twin Creek subdivision) will be open to provide access to national forest 

lands and wildlife-viewing opportunities. Access to 

the refuge beyond the Twin Creek subdivision will 

continue to be restricted as part of an area closure to 

protect wintering wildlife and is coordinated with 

the Bridger-Teton National Forest.

In addition the refuge will use the Jackson Hole 

Community Pathways to develop a more prominent 

access route across visitor center lawn to the existing remote-viewing platform and develop a boardwalk through wetland areas near the visitor center. 

We may build a photo blind along the boardwalk for 

noncommercial photography. The refuge may use 

webcams to provide remote wildlife-viewing 

opportunities.

Availability of Resources

Sufficient resources are available to administer, 

manage, and check this use of wildlife observation 

and noncommercial photography. Existing refuge 

infrastructure will support these activities. The construction and maintenance of roadways, kiosks, 

observation platforms, and trails, as well as law 

enforcement activities to make sure that visitors 

comply with refuge regulations while conducting 

these activities, are the principle expenses associated 

with wildlife observation and photography. An extra 

park ranger, law enforcement officer, and maintenance worker, as proposed in the CCP, will enhance 
Appendix E—Compatibility Determinations 267 

public opportunities for these uses and improve the 

quality and quantity of opportunities.

Anticipated Impacts of the Use

The proposed wildlife observation and photography uses, including development of facilities to support those uses, will foster public appreciation and 

understanding of the Greater Yellowstone Ecosystem 

and the importance of refuge habitats for wildlife 

conservation.

Short-term effects may include the temporary 

displacement of bison, elk, birds, and other wildlife to 

adjacent habitats during the initial positioning and 

removal of portable blinds, cameras, and other equipment. Observation areas are in locations that provide 

consistent wildlife-viewing opportunity with minimal 

disturbance to wildlife. 

Hiking during the breeding season, when confined 

to open trails and roads will have little or no effect on 

wildlife. Bicycling will be restricted to roadways 

open to vehicular traffic to reduce disturbance to 

wildlife. Some animals and birds would be flushed 

from foraging or resting habitats by the approach of 

people on trails.

Winter disturbance to resident wildlife will be 

temporary and minor. The destruction of ground bird 

nests by horses (allowed only during hunting) and the 

disturbance to other wildlife will be minimal because 

of the seasonal restrictions inherent to the hunting 

season. 

The area affected by these disturbances will be 

small compared to the overall habitat available. Furthermore, all areas are available to wildlife for undisturbed use during closed hours, and we do not 

anticipate that disturbance caused by observation 

and photography will cause wildlife to leave the refuge. We find that disturbance from wildlife observation and noncommercial photography programs will 

be biologically insignificant. We expect no long-term 

effects if recommended stipulations are followed.

Public Review and Comment

This compatibility determination was presented 

for public review and comment as part of the 45-day 

public comment period for the draft CCP and EA for 

the National Elk Refuge.

Determination

Wildlife observation and noncommercial photography are compatible uses on the National Elk 

Refuge.

Stipulations Necessary for Compatibility

The refuge will issue special use permits to all 

individuals using blinds for observation and photography on the refuge. Staff will issue five special use 

permits for designated areas in any given year. The 

use of small observation blinds will be available on a 

first-come, first-serve basis. If the number of 

requests for blinds exceeded five, the permitting process will be reviewed and modified as necessary. 

Refuge staff will give information to visitors using 

permanent or portable observation and photography 

blinds on proper use and etiquette of these structures 

to reduce disturbance to wildlife and their natural 

environments and other refuge visitors:

■ Visitors need to notify refuge staff before 

arrival at the refuge for observation and 

photography. 

■ Refuge staff decides locations of blinds, 

which might be limited to areas next to public access roads.

■ Refuge staff decides if, when, where, and for 

how long access may be allowed to photograph at individual areas. 

■ Visitors need to erect and remove portable 

blinds daily.

The refuge will support seasonal closures to protect sensitive wildlife areas and reduce disturbance 

to fish and wildlife. We will restrict non-Service 

vehicles to county and public access roads in the 

refuge.

We will design viewing areas to reduce disturbance effects on wildlife and all refuge resources 

while providing a good opportunity to view wildlife 

in natural environments.

The refuge will allow foot traffic (hiking, crosscountry skiing, and snowshoeing) only on designated 

trails, roads open to motorized vehicles, and in the 

refuge hunt area during the refuge hunting season. 

We will restrict use of horses to the hunting program 

or to roadways open to motorized vehicles yearround. The refuge will restrict bicycling to designated trails and roadways open to motorized 

vehicles.

Justification

Wildlife observation and photography are forms 

of wildlife-dependent recreation and are identified as 

priority public uses in the Improvement Act. These 

uses, both existing and future enhanced programs as 

prescribed in the CCP, a compatible with the pur-
268 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

poses of the refuge and the mission of the Refuge 

System. These uses are not only justified but are 

encouraged by the Improvement Act. Wildlife observation and photography can instill, in citizens of all 

ages, a greater appreciation for wildlife and its habitat. This appreciation could extend to the Refuge 

System and other conservation agencies.

Disturbance from wildlife observation and photography is not expected to adversely affect wildlife 

populations. Most wildlife observation is confined 

within a set distance from existing roadways. In 

some locations, the infrastructure helps to concentrate visitors in areas that can allow wildlife observation and photography opportunities at safe 

distances that reduce disturbance to wildlife.

Based on anticipated biological effects described 

above and in the EA, we find that wildlife observation and noncommercial photography on the refuge 

will not interfere with the purposes for which the 

refuge was established. Limiting access and monitoring the uses could help limit any adverse effects.

Mandatory 15-year Reevaluation Date: 2030

Environmental Education and 

Interpretation

The refuge will provide opportunity for student 

field trips on an “as-arranged” basis. Temporary and 

impromptu outdoor classrooms may be established or 

used in wetland and riparian habitats; however, seasonal closures may occur to avoid effects on threatened and endangered species or sensitive habitats.

Interpretive panels and auto tour brochures will 

give visitors information about habitat, wildlife, management actions.

The CCP proposes to continue environmental education and interpretation and add the following to 

improve these programs to foster appreciation and 

understanding of the Refuge System and the 

resources of the refuge:

■ The refuge will develop a self-guided interpretive tour route on Elk Refuge Road and 

Flat Creek Road on the eastern side of the 

refuge, including interpretive turnouts, signage, brochures, or mobile technology. We 

will need to address safety mitigation during critical times of year (hunting and bison 

hazing). The refuge will need to update and 

replace interpretive signs as needed, with 

panels related to the tour route theme.

❏ First phase (winter route)—Develop the 

route from Elk Refuge Road entrance to 

Twin Creek subdivision for approximately 

3.5 miles.

❏ Second phase (summer route)—Develop 

the route from Twin Creek subdivision to 

the McBride area; open May 1–December 

1 with an interpretive kiosk at the 

McBride parking area. 

❏ Third phase—Increase traffic control 

signing from the McBride area to the 

eastern parking lot and include the traffic 

information in the brochure. (If we 

encouraged or promoted traffic to the east 

parking lot, we would need to make a 

major change to the road for safety. Currently, this is a one-lane road around 

McBride Ridge.)

■ We may develop short multimedia presentations that would be available on demand. 

This would respond to visitors’ needs and 

preferences as well as allow refuge staff to 

update segments with minimal cost and 

staff time.

■ We will emphasize the role of national wildlife refuges versus national parks and 

national forests.

■ The refuge will use the North Highway 89 

Pathway during open season to interpret 

wetland values or other messages. Refuge 

staff will cooperate with Teton County to 

evaluate pathway effects on wildlife and 

habitat and adjust use as appropriate.

■ Refuge staff will develop a more prominent 

access route across visitor center lawn to 

the existing remote-viewing platform and 

develop a boardwalk through wetland areas 

near the visitor center. A photo blind may 

be developed along the boardwalk for noncommercial photography. 

■ We will develop more accessible observation 

sites on the refuge.

■ Refuge staff may take part in special events 

and activities offsite to bring the refuge 

message to large numbers of people as time 

and staff allow.

■ The refuge will update interpretive panels, 

brochures, Web sites, and maps.
Appendix E—Compatibility Determinations 269 

Availability of Resources

The refuge will use annual operations money, 

grants, regional project proposals, and challenge 

cost-share agreements to enhance environmental 

education and interpretation activities, directional 

signs, and brochures.

The visitor services staff relies on a large residential volunteer workforce as the means to offer formal 

and informal interpretation during the summer 

months when visitor center visitation peaks. Volunteers also provide formal and informal interpretation 

during the winter months. The refuge will seek 

money for permanent or seasonal interpreters to 

improve programming at the visitor center, Miller 

House, and offsite programs.

To meet the demand for environmental education 

during the school year, we use money from nongovernmental partnerships to hire seasonal winter naturalists. Refuge volunteers offer environmental 

education programs in the spring.

Anticipated Impacts of the Use

We will continue to promote a greater public 

understanding and appreciation of the refuge 

resources, programs, and issues through interpretive, outreach, and environmental education programs. The refuge staff will continue to provide 

environmental education and interpretation both on 

and off refuge lands. Presentations, both on and off 

Service lands, will be provided to refuge visitors, 

school groups, and organizations, helping us reach a 

broader audience. 

Updated brochures, interpretive panels, and other 

educational materials will help visitors understand 

refuge resources, ecosystem processes, and land 

management. Features such as the proposed auto 

tour route and accessible observation sites will provide access to the many sights and sounds of the 

refuge.

We will manage onsite presentations to reduce 

disturbance to wildlife, habitat, and cultural 

resources.

We will manage onsite presentations to reduce 

disturbance to wildlife, habitat, and cultural 

resources; however, there might be a short-term, lowlevel effect on the immediate and surrounding area. 

Effects may include trampling of vegetation and temporary disturbance to nearby wildlife species during 

the activities. Development and implementation of 

interpretive and education programs will have minimal and biologically insignificant effects on refuge 

resources.

Public Review and Comment

This compatibility determination was presented 

for public review and comment as part of the 45-day 

public comment period for the draft CCP and EA for 

the National Elk Refuge.

Determination

Environmental education and interpretation are 

compatible uses on the National Elk Refuge.

Stipulations Necessary for Compatibility

The refuge will hold onsite activities where minimal effect on wildlife and habitats will occur.

All motor vehicles associated with environmental 

education and interpretation will remain on designated roads open to vehicular traffic.

Staff will check use patterns and will make 

adjustments in timing, location, and duration of activities as needed to limit disturbance to wildlife and 

habitat.

We will review new environmental education and 

interpretation activities to make sure these activities 

met program objectives and were compatible.

Justification

Environmental education and interpretation are 

forms of wildlife-dependent recreation and are priority public uses of the Refuge System. Environmental 

education and interpretation will increase public 

awareness and appreciation of the significant wildlife 

and habitat values of the refuge and the Refuge System. We anticipate that such appreciation and understanding will foster increased public support for the 

Refuge System and conservation of America’s wildlife resources.

Based on the anticipated biological effects 

described above and in the EA, we find that environmental education and interpretation on the refuge 

will not interfere with the purposes for which the 

refuge was established. Limiting access and monitoring the uses could help limit any adverse effects.

Mandatory 15-year Reevaluation Date: 2030

Research and Monitoring

The refuge will allow research and monitoring on 

a variety of biological, physical, and social issues and 

concerns to address management information needs 

or other issues. Studies will be conducted by Federal, 
270 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

State, and private entities, including the U.S. Geological Survey, State and private universities, and 

independent researchers and contractors.

Each year, the refuge issues special use permits 

for biological and physical research studies; normally, 

we get fewer than 10 requests each year. The refuge 

will give priority to studies that contribute to the 

enhancement, protection, preservation, and management of the refuge’s native plant, fish, and wildlife 

populations and their habitats. Research applicants 

must submit proposals that describe the following:

■ objectives of the study

■ justification for the study

■ detailed study methods and a schedule

■ potential effects on wildlife and habitat 

including short- and long-term disturbance, 

injury, or mortality

■ measures the researcher will take to reduce 

disturbances or other effects

■ personnel involved and their qualifications 

and experience

■ status of necessary permits (such as scientific collecting permits and endangered species permits)

■ costs to the refuge and refuge staff time 

requested, if any

■ anticipated progress reports and end products, such as reports or publications

Refuge staff will review research permit applications and issue special use permits if approved. 

Evaluation criteria for the issuance of special use 

permits will include, but not be limited to, the 

following:

■ We will give higher priority over other 

requests to research that will contribute to 

specific management issues, the purposes of 

the refuge, or the mission of the Refuge 

System.

■ We will not approve research that would 

conflict with other ongoing research, monitoring, or management programs.

■ We will be less likely to approve research 

projects that could be conducted off refuge 

lands.

■ We will likely not approve research that 

would cause undue disturbance or would be 

intrusive. The refuge will carefully weigh 

the degree and type of disturbance when 

evaluating a research request.

■ We will decide if the research evaluation 

made any effort to reduce disturbance 

through study design including adjusting 

location, timing, number of permittees, 

study methods, and number of study sites.

■ We will likely deny the request if staff levels 

or logistics make it impossible for refuge 

staff to check researcher activity in a sensitive area.

■ We will consider and agree on the length of 

the project before approval.

■ To reduce disturbance to wildlife, we will 

not permit researchers in closed areas, 

unless specifically authorized. The refuge 

will permit vehicular access only on roads 

and trails normally open to the public.

Availability of Resources

Current staff will be adequate to manage 

research and monitoring projects at anticipated levels. Reviewing a permit application, drafting and 

issuing the special use permit, and making compliance assessments will take an average of 15 hours of 

staff time per permit. 

Access points, vehicles, miscellaneous equipment, 

and limited logistical support may be available at the 

refuge manager’s discretion. Temporary housing on 

the refuge may be available for use by researchers 

while studying refuge resources, at the refuge manager’s discretion.

Anticipated Impacts of Use

We expect some degree of disturbance with all 

research activities, because researchers might use 

Service roads or enter areas that are closed to the 

public. Research activities might disturb fish and 

wildlife and their habitats. For example, the presence 

of researchers could cause waterfowl to flush from 

resting and feeding areas, cause disruption of birds 

and other wildlife on nests or breeding areas, or 

increase predation on individual nests and animals as 

predators follow human scent or trails. To wildlife, 

the energy cost of disturbance could be appreciable in 

terms of disruption of feeding, displacement from 

preferred habitat, and the added energy expenditure 

to avoid disturbance. Some research might require 
Appendix E—Compatibility Determinations 271 

collection of samples or handling of wildlife. Efforts 

to capture animals could cause disturbance, injury, or 

death to groups of wildlife or to individuals. 

Sampling activities could cause compaction of soils 

and the trampling of vegetation, the establishment of 

temporary foot trails through vegetation, and disruption of bottom sediments in wetlands. The removal of 

vegetation or sediments by core sampling methods 

could increase localized turbidity and disrupt nontarget plants and animals. Installation of posts, equipment platforms, collection devices, and other 

research equipment might present a hazard to heavy 

equipment operators if these items were not adequately marked and removed at the right times or on 

completion of the project.

Public Review and Comment

This compatibility determination was presented 

for public review and comment as part of the 45-day 

public comment period for the draft CCP and EA for 

the National Elk Refuge.

Determination

Research and monitoring are compatible uses on 

the National Elk Refuge.

Stipulations Necessary for Compatibility

Refuge staff will use the above criteria for evaluating and determining whether to approve a proposed study. Before conducting investigations, 

researchers will obtain a special use permit from the 

refuge that contained specific stipulations for when, 

where, and how the research would be conducted. If 

research methods were found to have potential 

effects on habitat or wildlife, it must be shown that 

the research was necessary for conservation management of resources on the refuge. The researchers will 

develop measures to reduce potential effects to be 

included as part of the study design; these measures 

will be conditions in the special use permit. The refuge manager will have the discretion to prohibit 

research that causes undo harm or disturbance or 

that would not contribute to the purposes of the refuge or the mission of the Refuge System.

Researchers will follow all refuge rules and regulations unless otherwise exempted by refuge management. Extremely sensitive wildlife habitats and 

species will be sufficiently protected from disturbance by limiting research activities in these areas. 

The refuge will review projects annually, and 

researcher will submit annual progress reports. Refuge staff will check research activities for compliance 

with conditions of the special use permit. At any 

time, refuge staff might accompany the researchers 

to determine potential effects. Staff could decide that 

approved research and special use permits be terminated because of observed effects. The refuge manager could also cancel a special use permit if the 

researcher was out of compliance or to make sure 

there is wildlife and habitat protection.

Specific stipulations in the special use permit will 

vary by research project, but will be designed to 

reduce impacts to wildlife and their habitats and to 

make sure visitors, researchers, and refuge staff 

were safe. To reduce potential safety hazards, 

researchers must clearly mark posts, equipment platforms, fencing materials, and other equipment left 

unattended. Such items must be promptly removed 

on completion of the research.

Researchers must possess all applicable State and 

Federal permits for the capture and possession of 

protected species, for conducting regulated activities 

in wetlands, and for any other regulated activities.

Research involving collections will be extremely 

restricted. Collections will be limited to type or 

voucher specimens only, require preapproval by the 

refuge manager, and include verification of compliance with all State and Federal collection permits 

and requirements.

Researchers will promptly submit findings, such 

as annual status reports and a final report, to the 

refuge manager for inclusion in the decisionmaking 

and management process.

Justification

Research and monitoring will be activities that 

provide essential information necessary for the 

appropriate and effective management of refuge 

resources:

■ Research can help provide answers to complex questions, when those answers are not 

readily apparent and are vital to determining effective management strategies. 

■ Monitoring will be necessary to quantify or 

qualify the results of management actions. 

This is a basic step in the adaptive resource 

management process and necessary to 

guide modifications to management actions 

for improved results.

We will issue research and monitoring permits 

only when the information they provided was so valuable that it outweighed the temporary disturbance 

and minor effects on wildlife and their habitats. We 

expect minimal effects on refuge wildlife and habitats with research studies, because special use permits will include conditions to make sure that these 

effects are kept to a minimum.
272 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Mandatory 10-year reevaluation date: 2025

Commercial Filming, Audio Recording, 

and Still Photography

Commercial motion pictures and audio recordings 

are defined as the digital or film recording of a visual 

image or sound recording by a person, business, or 

other entity for a market audience, such as for a documentary, television, feature film, advertisement, or 

similar project. It does not include news coverage or 

amateur and visitor use. 

Commercial photography is defined as a visual 

recording (motion or still) by firms or individuals 

other than news media representatives who intend to 

distribute their photographic content for money or 

other consideration. This includes the creation of educational, entertainment, or commercial enterprises as 

well as advertising audiovisuals for the purpose of 

paid product or services, publicity, and commercially 

oriented photo contests.

The National Elk Refuge provides tremendous 

opportunities for commercial filming and photography of bison, elk, migratory birds, and other wildlife. 

Each year, the refuge staff receives 6–15 requests to 

conduct commercial filming or photography on refuge 

lands. Refuge staff review requests for commercial 

photography, motion pictures, and audio recordings 

and issue special use permits for approved requests. 

We evaluate each request on an individual basis 

using several U.S. Department of the Interior, 

agency, and Refuge System policies (such as 43 CFR 

Part 5, 50 CFR 27.71, and 8 RM 16).

Evaluation criteria will include the following:

■ Commercial photography, motion pictures, 

and audio recordings must (1) show a means 

to increase public appreciation and understanding of wildlife or natural habitats, (2) 

enhance public knowledge, appreciation, and 

understanding of the Refuge System, or (3) 

facilitate outreach and education goals of 

the refuge. The refuge will deny the use and 

not issue a special use permit if none of the 

previous criteria were met.

■ We will not approve activities that cause 

undue disturbance to wildlife or habitat. 

Refuge staff will carefully weigh the degree 

and type of disturbance when evaluating a 

request.

■ We will not approve requests that would 

conflict with other management programs 

or would impair existing wildlife-dependent 

recreational uses.

■ If logistics or lack of staff made it impossible 

for the refuge staff to monitor the activity, 

we might deny the request, depending on 

the specific circumstances.

Availability of Resources

The commercial filming, audio recording, and still 

photography uses will be administered with current 

resources. Administrative costs for review of applications and issuance of special use permits and staff 

time to conduct compliance checks may be offset by a 

fee system designated for the agencies within the 

U.S. Department of the Interior.

Anticipated Impacts of Use

Wildlife filmmakers and photographers tend to 

create the greatest disturbance of all wildlife observers (Dobb 1998, Klein 1993, Morton 1995). While 

observers frequently stop to view wildlife, photographers are more likely to approach the animals; even a 

slow approach by photographers tends to have behavioral consequences to wildlife (Klein 1993). Photographers often remain close to wildlife for extended 

periods in an attempt to habituate the subject to 

their presence (Dobb 1998). Furthermore, photographers with low-power lenses tend to get much closer 

to their subjects (Morton 1995). This usually causes 

more disturbance to wildlife as well as habitat, 

including the trampling of plants. Handling of animals and disturbing vegetation (such as cutting 

plants and removing flowers) or cultural artifacts is 

prohibited on refuge lands.

Issuance of special use permits with strict guidelines and followup by refuge staff for compliance will 

help to reduce or avoid these effects. Permittees who 

did not follow the stipulations of their special use permits could have their permits revoked, and further 

applications for filming or photographing on the refuge would be denied. The refuge could issue a notice 

of violation to permittees who operate outside the 

conditions of their permits and violate refuge 

regulations.

Public Review and Comment

This compatibility determination was presented 

for public review and comment as part of the 45-day 

public comment period for the draft CCP and EA for 

the National Elk Refuge.
Appendix E—Compatibility Determinations 273 

Determination

Commercial filming, audio recording, and still 

photography are compatible uses on the National Elk 

Refuge.

Stipulations Necessary for Compatibility

We will use the evaluation criteria described earlier to decide if commercial filming, audio recording, 

or still photography was a compatible use. 

All commercial filming will require a special use 

permit that (1) describes conditions that protect the 

refuge’s values, purposes, resources, and public 

health and safety, and (2) prevents unreasonable disruption of the public’s use and enjoyment of the refuge. Such conditions may be, but are not limited to: 

specifying road conditions when access will not be 

allowed, establishing time limitations, and identifying routes of access. These conditions will be identified to prevent (1) excessive disturbance to wildlife, 

(2) damage to habitat or refuge infrastructure, or (3) 

conflicts with other visitor services or management 

activities. Staff and workloads will determine if special access to closed areas of the refuge will be 

allowed case-by-case.

The special use permit will stipulate that imagery 

produced on refuge lands will be made available for 

environmental education, interpretation, outreach, 

internal documents, or other suitable uses. In addition, any commercial products must include proper 

credits to the refuge, the Refuge System, and the 

Service.

Still photography will require a special use permit, with specific conditions as outlined above, if one 

or more of the following occurred:

■ Photography takes place at locations where 

or when members of the public are not 

allowed.

■ Photography uses models, sets, or props 

that are not part of the location’s natural or 

cultural resources or administrative 

facilities.

■ The refuge has higher administrative costs 

to provide management and oversight to 

avoid impairment of the resources and values of the site, limit resource damage, and 

decrease health and safety risks to the visiting public.

■ The photographer intentionally manipulates 

vegetation to create a shot, for example, cutting vegetation to create a blind.

To reduce the effects on refuge lands and 

resources, the refuge staff will make sure that all 

commercial filmmakers and commercial still photographers (regardless of whether a special use permit 

were issued) comply with policies, rules, and regulations. The staff will monitor and assess the activities 

of all filmmakers, audio recorders, and still 

photographers.

Justification

Commercial filming, audio recording, and still 

photography are economic uses that, to be compatible, must contribute to the achievement of the refuge 

purposes, mission of the Refuge System, and the mission of the Service. Providing opportunities for these 

uses should result in an increased public awareness 

of the refuge’s ecological importance as well as 

advancing the public’s knowledge and support for the 

Refuge System and our agency. The stipulations outlined above and conditions imposed in the special use 

permits issued to commercial filmmakers, audio 

recorders, and still photographers will make sure 

that these wildlife-dependent activities occur with 

minimal adverse effects to resources or visitors.

Mandatory 10-year reevaluation date: 2025

Commercial Guiding, Outfitting, 

Game Retrieval, and WildlifeViewing Tours

Flat Creek is a popular fishing destination especially in August, and some time periods seem to be 

overcrowded. Private anglers have asked us why we 

issue guided fishing permits since they can add to the 

crowding. Law enforcement has identified several 

unpermitted guiding outfitters in the past two seasons and suspects that there is little respect for the 

refuge permitting requirements. Creating a limit for 

the total number of permits and setting quotas of two 

trips, two guides, and a maximum of two clients per 

day could have a desired result of dispersing anglers. 

Charging a permit fee could create a sustained funding mechanism for maintaining fishing access signing 

and the printing of fishing regulations.

The refuge has allowed guided elk and bison hunts 

by special use permit since 2008. This service has 

helped young, novice, and elderly hunters and hunters with limited equipment to enjoy a quality, wellequipped hunting experience. Guided hunting will 

continue to increase the potential for hunters unfamiliar with the refuge to successfully harvest an 
274 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

animal, contributing to meeting the refuge population objectives. Fees collected will help offset the 

costs of administering this program.

The refuge has allowed game retrieval services by 

special use permit for decades. Elk and bison are 

large, making it challenging for a young, inexperienced, physically challenged, or ill-equipped hunter 

to field-dress or transport a large carcass from an 

area closed to motor vehicles to the hunter’s vehicle. 

We will continue to allow wildlife-viewing tour 

companies to operate on the refuge through a special 

use permit that outlined special conditions for operation including required safety mitigation. Several of 

the tour companies have attended National Elk Refuge–sponsored training to enable them to provide 

accurate, interpretive wildlife information. The visitor services staff will continue communication 

throughout the year with wildlife tour companies to 

give them with current information about management practices, operations, and issues.

The refuge will continue to support a contracted 

interpretive sleigh ride program in winter and work 

closely with the contractor to provide quality education and interpretation through a unique wildlifeviewing opportunity.

Availability of Resources

The refuge will administer commercial guiding, 

outfitting, game retrieval, and wildlife-viewing tours 

with current resources. Administrative costs for 

review of applications, issuance of special use permits, and staff time to make compliance checks may 

be offset by a fee system designated for the agencies 

within the U.S. Department of the Interior.

Anticipated Impacts of the Use

Fishing and hunting guides assist visitors by providing local knowledge and equipment to enhance 

their client’s chances for a successful outdoor experience. Limitations placed in the special use permits 

will restrict these guiding operations and prevent an 

exclusive right to an area or the exclusion of the public. Fishing guides can help clients catch and release 

fish in a manner that prevents injuries to the fish. 

Hunting guides likely improve the potential for their 

clients to harvest a bison or elk, which helps move the 

herds closer to the population objectives outlined in 

the Bison and Elk Management Plan; this will be a 

positive contribution to the refuge’s management 

efforts. 

Permittees for game retrieval services will be 

constrained by the same travel restrictions as hunters, operating only in areas and on routes that were 

open to hunters. Wildlife disturbance will be minimal 

in these areas, which are already subject to hunter 

activities. Game retrieval services will prevent carcass spoilage and provide a service to hunters who 

might be unable to process and retrieve a harvested 

elk or bison. These services will contribute to a quality hunting program and may help increase total 

harvest.

Wildlife-viewing tour companies provide wildlife 

observation and interpretation opportunities primarily to tourists visiting Jackson Hole, many of which 

arrive by aircraft and need ground transportation to 

wildlife-viewing areas. Tour company vehicles, along 

with tourists in personal vehicles, have parked along 

Elk Refuge Road in the winter to observe bighorn 

sheep and have caused traffic congestion. The proposed construction of additional parking areas along 

Elk Refuge Road near Miller Butte will help reduce 

this problem. 

The sleigh ride program will continue to provide a 

unique and spectacular setting to present a wildlife 

interpretive message that was important to the mission of the National Elk Refuge and raised awareness 

of National Wildlife Refuge System. This program is 

anticipated to continue to reach between 20,000 and 

25,000 people annually. Horse-drawn sleighs and 

wagons will cause insignificant disturbance to elk 

and other wildlife. 

The above commercial activities will require special use permits, which will include strict guidelines 

and conditions to prevent the exclusion of the public 

or damage and disturbance to wildlife and their habitats. Refuge staff monitoring these activities for 

compliance with restrictions will help prevent conflicts with wildlife or the public. Permittees who did 

not follow the conditions outlined in their special use 

permits could have their permits revoked and further 

applications denied.

Public Review and Comment

This compatibility determination was presented 

for public review and comment as part of the 45-day 

public comment period for the draft CCP and EA for 

the National Elk Refuge.

Determination

Commercial guiding, outfitting, game retrieval, 

and wildlife-viewing tours are compatible uses on the 

National Elk Refuge.

Stipulations Necessary for Compatibility

Commercial guiding, outfitting, game retrieval, 

and wildlife-viewing tours must (1) show a means to 

extend public appreciation and understanding of 

wildlife or natural habitats, (2) enhance education, 

appreciation, and understanding of the Refuge Sys-
Appendix E—Compatibility Determinations 275 

tem, or (3) facilitate outreach and education goals of 

the refuge. Failure to show any of these criteria will 

result in a special use permit being denied.

Special use permits for these uses will (1) describe 

conditions that protect the refuge’s values, purposes, 

resources, and public health and safety, and (2) prevent unreasonable disruption of the public’s use and 

enjoyment of the refuge. Such conditions may be, but 

will not be limited to, specifying road conditions 

when access will not be allowed, establishing time 

limitations, and identifying routes of access. 

For game retrieval services, we will prohibit offroad vehicles and require companies to operate only 

in areas and on routes that are open to hunters.

The refuge will set these conditions to prevent 

excessive disturbance to wildlife, damage to habitat 

or refuge infrastructure, or conflicts with other visitor services or management activities. To reduce the 

effects on our lands and resources, the refuge staff 

will make sure that all commercial guides, outfitters, 

game retrieval services, and wildlife-viewing tour 

companies (regardless of whether a special use permit is issued) comply with policies, rules, and 

regulations.

Justification

Commercial guiding, outfitting, game retrieval, 

and wildlife-viewing tours are economic uses that 

will need to contribute to the achievement of the refuge purposes, mission of the Refuge System, or the 

mission of the Service. Providing opportunities for 

these uses should result in an increased public awareness of the refuge’s ecological importance as well as 

advancing the public’s knowledge and support for the 

Refuge System and the Service. The stipulations outlined above and conditions imposed in the special use 

permits issued to commercial guides, outfitters, 

game retrieval services, and wildlife-viewing tour 

companies will make sure that these wildlife-dependent activities occur with minimal adverse effects to 

resources or visitors.

Mandatory 10-year Reevaluation Date: 2025

E.5 Approval of Compatibility 

Determinations

Submitted by:

Steve Kallin, Project Leader Date

National Elk Refuge

Jackson, Wyoming

Reviewed by:

Mike Blenden, Refuge Supervisor Date

U.S. Fish and Wildlife Service, Region 6

National Wildlife Refuge System

Lakewood, Colorado

Approved by:

Will Meeks, Assistant Regional Director Date

U.S. Fish and Wildlife Service, Region 6

National Wildlife Refuge System

Lakewood, Colorado

Appendix F

Environmental Compliance

Environmental Action Statement

U.S. Fish and Wildlife Service, Region 6

Lakewood, Colorado

Within the spirit and intent of the Council on 

Environmental Quality’s regulations for implementing the National Environmental Policy Act and other 

statutes, orders, and policies that protect fish and 

wildlife resources, I have established the following 

administrative record.

I have determined that the action of implementing 

the “Comprehensive Conservation Plan—National 

Elk Refuge” is found not to have significant environmental effects, as determined by the attached “finding of no significant impact” and the environmental 

assessment as found with the draft comprehensive 

conservation plan.

Noreen Walsh Date

Regional Director, Region 6

U.S. Fish and Wildlife Service

Lakewood, Colorado

Will Meeks Date

Assistant Regional Director, Region 6

National Wildlife Refuge System U.S. Fish and Wildlife 

Service

Lakewood, Colorado

Michael Blenden Date

Refuge Supervisor, Region 6

U.S. Fish and Wildlife Service

Lakewood, Colorado

Steve Kallin Date

Refuge Manager

National Elk Refuge

U.S. Fish and Wildlife Service

Jackson, WY
278 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Finding of No Significant Impact

U.S. Fish and Wildlife Service, Region 6

Lakewood, Colorado

Introduction

This finding of no significant impact provides the 

basis for management decisions for the final comprehensive conservation plan and environmental assessment for the National Elk Refuge, Wyoming. The 

comprehensive conservation plan (CCP) was prepared along with an environmental assessment (EA) 

in compliance with the National Environmental Policy Act and relevant planning policies. In preparing 

the final CCP, we worked closely with the Wyoming 

Game and Fish Department, Grand Teton National 

Park, Bridger-Teton National Forest, Teton County 

Planning Department, nongovernmental organizations and individuals who contributed input to the 

plan.

Alternatives

Based on an analysis of comments collected from 

the public, input from our staff, and a review of the 

needs of the Improvement Act and NEPA, we identified key issues for the National Elk Refuge. These 

were addressed in the alternatives for future management which are summarized below.

Alternative A (Current Management)

Alternative A is the no-action alternative, which 

represents the current management of the National 

Elk Refuge. This alternative provides the baseline 

against which to compare the other alternatives. It 

also fulfills a need of the National Environmental 

Policy Act of 1969. Under alternative A, our management activity would continue unchanged. We would 

not develop any new management, restoration, or 

education programs at the refuge. Current habitat 

and wildlife practices benefiting migratory species 

and other wildlife would not be expanded or changed. 

Habitat management would remain focused primarily on benefiting elk, bison, and nesting birds. Our 

staff would keep monitoring, inventory, and research 

activities at current levels. Budget and staff levels 

would remain the same with little change in overall 

trends. Programs would follow the same direction, 

emphasis, and intensity as they do now.

Alternative B (Enhance Public Use and Intensive 

Resource Management)

An important aspect of this alternative would be 

to limit public use to appropriate and compatible 

wildlife-dependent uses—hunting, fishing, wildlife 

observation, photography, environmental education, 

and interpretation—and shift away from non-wildlife-dependent uses. There would be increased development in some areas of the refuge to address 

increased public use at area-specific intensive use 

locations. Options to experience and observe would 

be enhanced. The other emphasis would be to meet 

habitat and wildlife population objectives through 

intensive management actions. Because of increased 

public opportunities, refuge staff would focus more 

on intensive refuge-specific monitoring, rather than 

ecosystem monitoring, to gauge the effects of public 

use on habitat and wildlife.

Alternative C (Emphasize Intact Ecosystems and 

Promote Natural Processes)

Given the National Elk Refuge is part of the 

Greater Yellowstone Ecosystem, one of the largest 

relatively intact ecosystems on the planet, refuge 

management would emphasize those qualities that 

make the ecosystem unique. Public use emphasizes 

interpretation, education, and outreach over recreational opportunities that are direct experiences. 

Educational and interpretive programs would include 

more experiences off the refuge.

Alternative D (Promote Natural Habitats and Balance 

Public Use) – PROPOSED ACTION

Refuge managers would strike a balance between 

management activity and allowing natural processes. 

We would need to identify priorities for research and 

monitoring—between refuge-specific monitoring and 

ecosystem-based monitoring—because increased 

public use would still require some refuge-specific 

monitoring. The proposed action represents balanced 

public use by providing some increase in developed 

areas while allowing other areas to remain undeveloped or to return to a natural state. In many cases, 

public use would emphasize outreach, interpretation, 

and education over recreational opportunities that 

involve direct experiences.

Public Involvement and Outreach

Public scoping started with a notice of intent to 

prepare the draft CCP and EA that we published in 

the Federal Register on October 22, 2010 (75 Federal 

Register 65370). We distributed information through 

news releases, issuance of the first planning update, 

and a public meeting held January 11, 2011, at Snow 

King Resort in Jackson, Wyoming, from 4 p.m. to 7 

p.m. Before this and early in the preplanning phase, 

we outlined a process that would be inclusive of 

diverse stakeholder interests and would involve a 
Appendix F—Environmental Compliance 279 

range of activities for keeping the public informed 

and ensuring meaningful public input. Information 

was distributed through news releases, planning 

updates, and public meetings. We received more than 

230 comments orally and in writing during the scoping process. There were letters from eight organizations and four agencies. The planning team 

considered all of the comments throughout the planning process.

Comments on the Draft Plan and EA

A notice of availability for the draft CCP and EA 

was published in the Federal Register on September 

9, 2014 (79 Federal Register 53440) announcing the 

availability of the draft CCP and EA, our intention to 

hold a public meeting, and a request for comments. 

During the public review the Service held one public 

meeting on September 25, 2014 in Jackson, WY. Public participation in the CCP review process was 

strong with more than 200 copies of the draft plan 

distributed to individuals on the mailing list. In addition to the oral comments recorded at the public 

meeting, 41 emails and letters were received. The 

comment period closed October 9, 2014.

Decision

Based on this assessment and comments received, 

I have selected the following preferred alternative:

■ A slightly modified Alternative D for refuge 

management

The preferred alternative was selected because it 

best meets the purposes for which the National Elk 

Refuge was established and is preferable to the “noaction” alternative in light of physical, biological, 

economic, and social factors. The preferred alternative will achieve a reasonable balance between significant resource management issues, the refuge 

purposes, National Wildlife Refuge System mission, 

management policies of the Service, and the interests 

and perspectives of all stakeholders.

We have considered the environmental and relevant concerns presented by agencies, organizations, 

and individuals on the proposed action to develop and 

implement a comprehensive conservation plan for the 

National Elk Refuge. The substantive issues and 

comments raised have been addressed in the final 

CCP.

Alternative D was revised from the proposed 

action after our consideration of many comments 

received from agencies, other stakeholder organizations, and the public during the comment period. 

Revisions to the key management actions of Alternative D for refuge management relate to hunting and 

habitat connectivity. The most significant revisions 

are listed below:

■ The Refuge and its partner organizations 

will continue to promote the voluntary nonlead ammunition program with a detailed 

review of the program in five years.

■ References to ‘predator harvest’ and ‘predator hunting season’ are removed from the 

CCP.

■ The Refuge program which provides free 

bear spray to hunters and promotes its use 

will continue with a detailed review of the 

program in five years.

■ The Refuge will consider partnership 

opportunities to build wildlife crossings for 

Highway 89 to reduce vehicle/wildlife collisions and improve habitat connectivity.

Management of the refuge will comply with all 

Federal laws and regulations that provide direction 

for managing units of the Refuge System. Various 

methods that involve rest, water level control, burning, mechanical, chemical, and cultural-related activities will be used to accomplish refuge goals and 

objectives.

Finding and Basis for Decision

I find that the preferred alternative is not a major 

Federal action that would significantly affect the 

quality of the human environment within the meaning of Section 102(2) (C) of the National Environmental Policy Act of 1969. Accordingly, the preparation of 

an environmental impact statement on the proposed 

actions is not required.

The following is a summary of anticipated environmental effects. The implementation of the preferred alternative will:

■ manage for wildlife as a priority, with 

emphasis on providing winter forage for elk 

and bison;

■ not adversely impact endangered or threatened species or their habitat;

■ increase the sustainability and resiliency of 

the refuge and improve ability to adjust to 

the uncertainty of climate change;

■ continue to control invasive species, especially species not native to the region;

■ reduce opportunities for the introduction 

and/or spread of non-native invasive plant 

species;
280 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

■ develop monitoring protocols to improve 

management decision-making, particularly 

related to habitat relationships of federally 

threatened and endangered wildlife species 

or selected wildlife species on Tier 1 & 2 of 

the State of Wyoming’s list of species of 

greatest conservation needs;

■ improve the coordination of the refuge with 

the Greater Yellowstone Coordinating Committee and/or other research groups to 

improve our understanding of the local 

impacts from climate change;

■ not adversely impact archaeological or historical resources;

■ enhance interpretation of cultural resources 

and restore the historic Miller Ranch 

buildings;

■ preserve refuge water rights, and explore 

opportunities to improve water use efficiency and other water-related factors 

within our water rights to support wildlife;

■ provide a balance between resource protection and providing wildlife-dependent recreational opportunity without negatively 

impacting natural resources;

■ improve both consumptive and non-consumptive public use opportunities;

■ enhance environmental education opportunities with improvements to staffing and the 

Jackson and Greater Yellowstone Visitor 

Center;

■ increase staffing to appropriate levels to 

accomplish goals and objectives;

■ not have a disproportionately high or 

adverse human health or environmental 

effect on minority or low-income 

populations;

■ maintain public and employee safety as a 

mission critical factor;

■ expand resource protection appropriately 

with increased public use opportunities.

The State of Wyoming has been notified and given 

the opportunity to review the comprehensive conservation plan and associated environmental 

assessment.

Noreen Walsh Date

Regional Director, Region 6

U.S. Fish and Wildlife Service

Lakewood, Colorado
Appendix G

Intra-Service Section 7 Consultation
282 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

United States Department of the Interior 

FISH AND WILDLIFE SERVICE

Ecological Services 

5353 Yellowstone Road, Suite 308A

Cheyenne, Wyoming 82009

In Reply Refer To: AOG 2 5 2015 

06E 13000-2015-F-0132 

Memorandum

To:

From:

Refuge Manager, U.S. Fish and Wildlife Service, National Elk Refuge,

Jackson, Wyoming 

Field Supervisor, U.S. ��11 life Service, Wy Field Office,

Cheyenne, Wyoming � a� 

U.S. �'ISH & WILDLIFE SERVICE 

ij 

Subject: Intra-Service Consultation for the National Elk Refuge Draft Comprehensive

Conservation Plan and Environmental Assessment 

Thank you for your memo and Intra-Service Section 7 Biological Evaluation Form (Biological

Evaluation Form) dated and received in our office on June 2, 2015, requesting Intra-Service 

section 7 consultation on the National Elk Refuge (Refuge) Draft Comprehensive Conservation 

Plan (CCP) and Environmental Assessment (hereafter, Project). Based on additional information

and subsequent conversations between our staffs, you requested formal section 7 consultation on

July 13, 2015, pursuant to the Endangered Species Act of 1973 (ESA), as amended, 16 U.S.C. 

1531 et seq. In the Biological Evaluation Form, the Refuge requested concurrence from the

U.S. Fish and Wildlife Service, Wyoming Ecological Services Field Office, for its 

determinations of "may affect, not likely to adversely affect" for the yellow-billed cuckoo 

(Coccyzus americanus) and the gray wolf (Canis lupis), and "may affect, not likely to 

jeopardize" the greater sage-grouse (Centrocercus urophasianus) and whitebark pine (Pinus

albicaulis), both candidates for listing under the ESA. The Biological Evaluation Form also 

included a "no effect" determination for the Canada lynx (Lynx canadensis) and a "may affect,

likely to adversely affect," determination for grizzly bear (Ursus arctos horribilis). 

The Project is located within all or portions of T41N and T42N, Rl 15W and 116W, all sections

within the Refuge boundary, Teton County, Wyoming. The CCP will guide management of the 

Refuge from 2015 to 2030. The CCP provides an overview of all management actions affecting

refuge habitats, wildlife populations, public use activities, facilities, and staffing that were not 

addressed in the 2007 Bison and Elk Management Plan and Environmental Impact Statement.

The CCP is intended to function as a general guidance document; therefore, the CCP lacks 

project-level detail that will be addressed in subsequent step-down plans.
Appendix G—Intra-Service Section 7 Consultation 283 

We have reviewed the information in the Biological Evaluation Form for potential effects to 

listed and candidate species, and we provide our concurrence in accordance with section 7(a)2) 

of the ESA (50 CFR §402.13). We have completed the attached Biological Evaluation Form 

accordingly. 

Pursuant to section 7(a)(2) of the ESA (50 CFR §402.14), the attached biological opinion 

addresses the effects of the Project on grizzly bears. The biological opinion is based on 

information provided in the Intra-Service Section 7 Biological Evaluation Form prepared by the 

Refuge, updated on July 13, 2015. 

Consultation History: 

• July 8, 2015-Lisa Solberg Schwab of my office and Eric Cole of the Refuge verbally

communicated about adding additional conservation measures that the Refuge has in

place to the Biological Evaluation Form;

• July 10, 2015-The Refuge made additional edits to the Intra-Service Consultation

memo;

• July 13, 2015-Lisa Solberg Schwab and Eric Cole discussed the impacts to the grizzly

bear and concluded that formal consultation was necessary to be consistent with the Elk

and Bison Management Plan;

• July 20, 2015-Additional correspondence was exchanged regarding the cumulative

impacts section of the Biological Opinion; and

• July 24, 2015-The Refuge provided a copy of the signed signature page of the IntraService memo to this office.

A complete administrative record of this consultation is on file at the Wyoming Ecological 

Services Field Office in Cheyenne, Wyoming. If you have any questions regarding this 

consultation, please contact Lisa Solberg Schwab of my office at the letterhead address or phone 

(307) 367-5340.

Attachment 1 (Biological Opinion) 

Attachment 2 (Intra-Service Section 7 Biological Evaluation Form) 

cc: FWS, National Elk Refuge, Jackson, WY (E. Cole) (eric_cole@fws.gov) 

WGFD, Statewide Non-Game Bird and Mammal Program Supervisor, Lander, WY 

(Z. Walker) (zack.walker@wyo.gov) 

WGFD, Statewide Habitat Protection Coordinator, Cheyenne, WY (M. Flanderka) 

(mary.flanderka@wyo.gov) 

WGFD, Habitat Protection Secretary, Cheyenne, WY (N.Stange) (nancy.stange@wyo.gov) 

WGFD, Statewide Large Carnivore Section Supervisor, Lander, WY (D. Thompson) 

( daniel.thompson@wyo.gov) 

2 
284 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Intra-Service Section 7 Biological Evaluation Form - Region 6 

Originating Person: Eric Cole, Refuge biologist 

Date Submitted: 2 June 2015 

Telephone Number: 307-201-5432 

I. Service Program and Geographic Area or Station Name: National Elk Refuge

II. Flexible Funding Program ( e.g. Joint Venture, etc) if applicable: Not applicable

III. Location: Location of the project including County, State and TSR (township, section &

range): Teton County, Wyoming, T41-T42, Rl 15-116, all sections within National Elk Refuge

(NER) boundary.

IV Species/Critical Habitat: List federally endangered, threatened, proposed, and candidate 

species or designated or proposed critical habitat that may occur within the action area. 

1) Grizzly bear, Threatened

2) Gray wolf, Experimental Population, considered Threatened on national wildlife refuges

3) Canada lynx, Threatened

4) Yellow-billed Cuckoo, Threatened

5) Greater sage-grouse, Candidate

6) Whitebark pine, Candidate

No critical habitat has been designated within the NER boundary 

V. Project Description: Describe proposed project or action or, if referencing other documents,

prepare an executive summary (attach additional pages as needed): The Comprehensive

Conservation Plan (CCP) for the NER will guide management ofNER from 2015 to 2030.

The CCP provides an overview of all management actions affecting refuge habitats, wildlife

populations, public use activities, facilities, and staffing that were not addressed in the 2007

Bison and Elk Management Plan and EIS. The CCP is intended to function as a general

guidance document, and therefore it lacks project-level detail that will be addressed in

subsequent step down plans. See section VI, Determination of Effects for a summary of the net

effects of the NER CCP on federally listed and candidate species.

VI. Determination of Effects:

(A) Description of Effects: Describe the action(s) that may affect the species and critical

habitats listed in item IV. Your rationale for the Section 7 determinations made below (B)

should be fully described here.

1) Grizzly bear (threatened); May Affect, Likely to Adversely Affect: This finding is
Appendix G—Intra-Service Section 7 Consultation 285 

consistent with the biological opinion issued for the Section 7 consultation associated 

with the 2007 Bison and Elk Management Plan. There have been only 2 confirmed 

grizzly bear observations on NER since 1994, but we predict increased use of NER by 

grizzly bears within the 15 year life of the CCP. Currently elk and bison hunting 

seasons result in approximately 150-300 elk gut piles from November-December 

and150-300 bison gut piles from August-January on NER, and this represents a 

significant food source for grizzly bears with interactions between bears and hunters 

likely to increase if grizzly bear activity increases on NER. CCP proposed actions are 

unlikely to affect the number of elk and bison carcasses on NER, but the following 

CCP actions are likely to minimize the risk of grizzly bear mortality due to human/bear 

interactions: 1) Increased education efforts including distribution of materials 

promoting the use of bear spay, techniques to minimize human/bear interactions, and 

proper food/game meat storage techniques for hunters; 2) Bear safety training for 

NER staff and volunteers. NER staff and volunteers are required to carry bear spray in 

the field; and 3) Food/Waste storage guidelines at NER facilities that are consistent 

with Teton County Wyoming regulations. These actions will be implemented within 

the first of year of the CCP. 2)CCP actions are also designed to encourage the use of 

non-lead rifle ammunition, which potentially could reduce lead exposure by bears 

scavenging on elk and bison gut piles, but research to support physiological or 

population benefits to Grizzly bears is lacking. 

2) Gray wolf (considered threatened on NER pending court decisions); May Affect, but

Not Likely to Adversely Affect: Gray wolves have consistently used NER during winter

months since 1999 and have consistently denned on NER since 2005. CCP proposed

actions codify existing NER policy of protecting wolf den sites from human disturbance.

We anticipate that this will have a net positive effect on wolf populations over time.

3) Canada lynx (threatened); No Effect: NER elevation ranges from 6,200 to 6,700 feet

with no suitable habitat for Canada lynx. NER does not have any LAU or critical habitat

designated, nor does the refuge share any LAU boundaries with Grand Teton National

Park. There have been no confirmed Canada lynx observations on NER in 103 years of

record keeping, and we do not anticipate any future habitat changes on NER that would

facilitate occupancy by Canada lynx.

4) Yellow-billed cuckoo (candidate); May Affect, but Not Likely to Adversely Affect:

Although there have been no confirmed Yellow-billed cuckoo observations on NER in 103 

years of record keeping, there is approximately 550 acres of cottonwood riparian habitat

on NER. CCP proposed actions will likely result in a slight increase in cottonwood

regeneration associated with exclosure construction. In the long term this may result in

modest increases in Yellow-billed cuckoo habitat and may positively affect cuckoo

populations should the species occupy the refuge in the future.

5) Greater sage-grouse (candidate); May Affect, but Not Likely to Jeopardize

Candidate or Proposed species/critical habitat: There is one sage-grouse lek on NER

and extensive use ofNER sagebrush plant communities has been documented. Local

research suggests winter habitat is the limiting factor on the Jackson Hole sagegrouse

population and that tall, dense sagebrush stands are a key habitat feature for this species.

CCP actions are designed to protect existing tall dense sagebrush stands from disturbance

and encourage an increase in the spatial distribution exhibiting these characteristics over
286 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

the 15-year life of the CCP. All habitat treatments will comply with the Wyoming 

Governor's Executive Order for habitat treatments in sage-grouse habitat. Public access is 

restricted on NER during winter months and during the strutting period. We anticipate that 

these CCP actions may results in a slight positive effect on the Jackson Hole sage-grouse 

population over the 15 year life of the plan. 

6) Whitebark pine (candidate); Not Likely to Jeopardize Candidate or Proposed

species/critical habitat: NER elevation ranges from 6,200 to 6,700 feet with no suitable

habitat for Whitebark pine. There have been no confirmed Whitebark pine observations

on NER in 103 years of record keeping, and we do not anticipate any future habitat

changes on NER that would facilitate occupancy by Whitebark pine.

(B) Determination: Determine the anticipated effects of the proposed project on species and critical

habitats listed in item IV. Check all applicable boxes and list the species (or attach a list) associated

with each determination.

Determination 

No Effect: This determination is appropriate when the proposed project 

will not directly or indirectly affect (neither negatively nor beneficially) X 

individuals of listed/proposed/candidate species or desig n ated/proposed 

critical habitat of such species. No concurrence from ESFO required. 

Canada lynx 

May Affect but Not Likely to Adversely Affect: This determination is X 

appropriate when the proposed project is likely to cause insignificant, 

discountable, or wholly beneficial effects to individuals of listed species 

and/or designated critical habitat. Concurrence from ESFO required. 

Gray wolf, Yellow-billed cuckoo 

May Affect and Likely to Adversely Affect: This determination is X 

appropriate when the proposed project is likely to adversely 

impact individuals of listed species and/or designated critical habitat. 

Formal consultation with ESFO required. Grizzly bear 

May affect but Not Likely to Jeopardize candidate or proposed X 

species/critical habitat: This determination is appropriate when the 

proposed project may affect, but is not expected to jeopardize the 

continued existence of a species proposed for listing or a candidate 

species, or adversely modify an area proposed for designation as critical 

habitat. Concurrence from ESFO optional., 

Greater sage grouse, Whitebark pine 

Likely to Jeopardize candidate or proposed species/critical habitat: 

This determination is appropriate when the proposed project is reasonably 

expected to jeopardize the continued existence of a species proposed for 

listing or a candidate species, or adversely modify an area proposed for 

desig n ation as critical habitat. Conferencing with ESFO required. 
Appendix G—Intra-Service Section 7 Consultation 287 

Signature &/, 

[Supervisor at originating station]

Date 

Reviewing Ecological Services Office Evaluation (check all that apply): 

A. Concurrence _X_ 

Explanation for nonconcurrence: 

B. Formal consultation required __ X_

List species or critical habitat unit 

Grizzly Bear 

C. Conference required _ _

List species or critical habitat unit 

Nonconcurrence 

Name of Reviewing ES Office: Wyoming Eco)ogjcal Services Field Office 

Signature Date 
288 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

BIOLOGICAL OPINION 

Effects to the Grizzly Bear 

from implementation of the National Elk Refuge's 

Comprehensive Conservation Plan 

Teton County, Wyoming 

06E13000-2015-F-0132 

Prepared by: 

U.S. Fish and Wildlife Service 

Wyoming Ecological Services Field Office 

August 25, 2015 
Appendix G—Intra-Service Section 7 Consultation 289 

TABLE OF CONTENTS 

BIOLOGICAL OPINION ............................................................................................................... 4 

DESRIPTION OF THE PROPOSED ACTION ......................................................................... .4 

Adaptive Management of Elk and Bison Populations ............................................................ .4 

Adaptive Management of the Habitat ...................................................................................... 5 

Chronic Wasting Disease/Brucellosis ...................................................................................... 5 

Strategies for Hunting/Reduction Programs ............................................................................ 6 

Reduced Reliance on Supplemental Feeding .......................................................................... 6 

Visitor and Employee Safety ................................................................................................... 7 

Conservation Measures ............................................................................................................ 7 

Action Area .............................................................................................................................. 8 

STATUS OF THE SPECIES/CRITICAL HABITAT ................................................................. 8 

Life History .............................................................................................................................. 9 

Population Dynamics, Status and Distribution ...................................................................... 11 

Conservation .......................................................................................................................... 15 

Threats ................................................................................................................................... 17 

ENVIRONMENTAL BASELINE ............................................................................................ 19 

Status of Species habitat within the Action Area .................................................................. 19 

Factors Affecting Species Environment within the Action Area ......................................... .20 

EFFECTS OF THE ACTION .................................................................................................... 21 

Habitat conservation .............................................................................................................. 21 

Sustainable populations/ Elk and bison numbers .................................................................. 21 

Bison hunt .............................................................................................................................. 22 

Disease management ............................................................................................................. 23 

Food Storage .......................................................................................................................... 23 

Education ............................................................................................................................... 23 

CUMULATIVE EFFECTS ....................................................................................................... 24 

Cumulative Effects within the Action Area ........................................................................... 24 

Cumulative Effects Adjacent to the Action Area and Grizzly Bear Recovery Zone ........... .24 

CONCLUSION .......................................................................................................................... 25 

2 
290 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

INCIDENTAL TAKE STATEMENT ........................................................................................... 26 

Amount or Extent of Take Anticipated ................................................................................. 26 

Effect of the take .................................................................................................................... 27 

Reasonable and prudent measures ......................................................................................... 27 

TERMS AND CONDITIONS ................................................................................................... 28 

CONSERVATION RECOMMENDATIONS ........................................................................... 28 

REINITIATION NOTICE ......................................................................................................... 29 

LITERATURE CITED .............................................................................................................. 30 

3 
Appendix G—Intra-Service Section 7 Consultation 291 

BIOLOGICAL OPINION 

DESRIPTION OF THE PROPOSED ACTION 

As defined in the Endangered Species Act (ESA) Section 7 regulations (50 CFR 402.02), 

"action" means "all activities or programs of any kind authorized, funded, or carried out, in 

whole or in part, by federal agencies in the United States or upon the high seas." The "action 

area" is defined as "all areas to be affected directly or indirectly by the federal action and not 

merely the immediate area involved in the action." The direct and indirect effects of the actions 

and activities must be considered in conjunction with the effects of other past and present 

federal, state, or private activities, as well as the cumulative effects of reasonably certain future 

state or private activities within the action area. 

The U.S. Fish and Wildlife Service (Service) manages the National Wildlife Refuge System. 

The National Wildlife Refuge System Improvement Act of 1997 requires that every refuge 

develop a Comprehensive Conservation Plan and revise it every 15 years, as needed. The 

National Elk Refuge (Refuge) Comprehensive Conservation Plan (CCP) will guide management 

of the Refuge from 2015 to 2030. The CCP provides an overview of all management actions 

affecting Refuge habitats, wildlife populations, public use activities, facilities, and staffing that 

were not addressed in the 2007 Bison and Elk Management Plan and Environmental Impact 

Statement. The CCP is intended to function as a general guidance document, and therefore, it 

lacks project-level detail that will be addressed in subsequent step down plans. 

The proposed action is identified as alternative Din the CCP. As such, the objectives and 

strategies presented in chapter 6 of the CCP will be carried out over the next 15 years, unless the 

CCP is formally revised. The CCP includes six broad goals: climate change, landscape-scale 

conservation, habitat and wildlife, visitor services, visitor and employee safety and resource 

protection, and administrative. Each of these goals includes two or more objectives, and each 

objective has one or more strategies. The goals, objectives and strategies are described in 

chapter 6 of the CCP and are incorporated by reference. The CCP also describes the affected 

environment ( chapter 4) and environmental consequences ( chapter 5). Information from the 

CCP and the Intra-Service Biological Evaluation Form relevant to grizzly bear are described 

below in more detail. 

Adaptive Management of Elk and Bison Populations 

The Refuge will adaptively manage bison, elk, and other wildlife populations and habitats as 

outlined in the Bison and Elk Management Plan (Plan). Goals of the Plan include habitat 

conservation, maintaining sustainable populations, managing numbers of elk and bison, and 

disease management. The proposed action will contribute to maintaining sustainable population 

of elk and bison that are healthy, at a reduced risk of contracting non-endemic diseases, and able 

to adapt to changing environmental conditions. Specific outcomes include: 

• Work in collaboration with the Wyoming Game and Fish Department (WGFD) to reduce

the Jackson elk herd and maintain an objective of 11,000 elk (after the initial reduction,

approximately 5,000 elk are expected to winter on the Refuge). As herd sizes and habitat

4 
292 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

objectives are achieved, further reduce feeding or elk numbers, based on established 

criteria and changing social, political, or biological conditions. Use hunting on the 

Refuge, and when necessary, the elk herd reduction program in the Grand Teton National 

Park (Park), to assist the state of W yuming in managing herd sizes, sex and age ratios, 

and summer distributions. 

• Work in collaboration with the WGFD to establish a genetically viable bison herd of

approximately 500 animals, with as close to an even sex ratio as possible to maximize

maintenance of genetic variation over time. Initiate a WGFD-administered bison hunt on

the Refuge.

Adaptive Management of the Habitat 

Under the proposed action, the Refuge will provide secure, sustainable ungulate grazing habitat 

characterized primarily by native vegetation that is healthy, productive and sustained for the 

benefit of elk, bison, and other native species. Activities included urnl r th proposed action will 

be implemented in concert with restoring and perpetuating natural ecosystem functions of native 

habitats used by bison and elk in the Refuge. Specific actions include: 

• Initiate habitat restoration projects to improve native and cultivated forage and achieve

desired conditions and goals. Continue to flood irrigate 800 to 2,000 acres per year

(324-809 ha/yr) of cultivated land, and convert up to 1,200 acres ( 445 ha) from flood to

sprinkler irrigation.

• Protect woody vegetation (willow, aspen, and cottonwood) on the Refuge by rotating

small exclosures until habitats have recovered. Prescribed fire could be used and logging

allowed on the Refuge inside exclosures.

• Work with private and agency partners to minimize bison and elk conflicts with adjacent

landowners ( e.g., by providing human and/or financial resources to manage co-mingling

and reduce crop depredation by elk and bison on private lands).

Chronic Wasting Disease/Brucellosis 

The Refuge will coordinate with the Wyoming Game and Fish Department (WGFD) to increase 

surveillance in elk for chronic wasting disease, a fatal transmissible disease of white-tailed deer, 

mule deer, and elk. The objective of surveillance is to provide a 95 percent confidence level of 

discovering infection at 1 percent prevalence in the Jackson elk herd. If infection is found, 

strategies from the state's Chronic Wasting Disease Management Plan (WGFD 2006) will be 

implemented to reduce transmission. These strategies include removing clinically consistent elk, 

removing 50 animals within 5 miles of the index case, and another 50 elk within 10 miles if an 

additional positive animal is found during collection of the first 50; enforcing carcass movement 

and disposal restrictions; decreasing duration of feeding and expanding the distribution of 

feeding to the extent possible; and potentially decreasing elk densities through hunting or other 

management strategies. 

The Refuge and Grand Teton National Park, John D Rockefeller, Jr., Memorial Parkway will 

work cooperatively with the state of Wyoming and others to reduce the prevalence of brucellosis 

in the elk and bison populations in order to protect the economic interests and viability of the 

5 
Appendix G—Intra-Service Section 7 Consultation 293 

livestock industry and reduce the risk of adverse effects for other non-endemic diseases not 

currently present in the Jackson elk and bison populations. 

• Allow the WGFD to vaccinate elk and bison for brucellosis on the Refuge as long as

logistically possible. The WGFD will use brucellosis vaccine Strain 19 on elk and RB5I

on calf and non-pregnant female bison along feedlines during feedline operations.

• Initiate a public education effort to build understanding of natural elk and bison behavior,

ecology, distribution, disease implications, and effects of other species.

Strategies for Hunting/Reduction Programs 

The Refuge and the National Park Service will work cooperatively with the WGFD to achieve 

populations objectives for elk and bison (including herd ratios and elk herd segment sizes), by 

establishing hunting seasons within hunting units or elk reduction areas. The WGFD will 

formally establish objectives and strategies after public review and approval by the Wyoming 

Game and Fish Commission. 

During the life of the CCP, elk hunting opportunities on the Refuge will decline from an average 

of733 hunters per year to 420 to 487 hunters per year. Areas outside of the Refuge will increase 

to an estimated 5,600 to 5,870 hunters per year, an increase of 29 to 35 percent. For the herd unit 

as a whole, the number of elk hunters could range from an estimated 6,793 to 7,314 per year, 

which is an increase of 2 to 10 percent compared to average baseline conditions. 

It is also anticipated that an estimated 140 to 150 bison will be harvested each year to reduce 

bison numbers to a herd of approximately 500 animals. Each year, about 50 bison will be 

harvested from the Bridger-Teton National Forest and the 90 to 100 bison on the Refuge. Based 

on previous success rates, it will take an average of about 175 to 190 bison hunters in Jackson 

Hole each year to achieve these harvest objectives. Once the bison herd reaches population 

objectives, the number of bison harvested each year will decline to about 70 bison. 

• Hunting regulations and program design would focus on the safety of the Refuge user and

surrounding community. Safety rules, procedures, job hazard analyses, reporting

requirements, and regional safety office oversight would help to keep Refuge employees

safe while working to achieve station objectives.

• Promote voluntary use of lead-free ammunition.

Develop regulations for storage of bear attracta.11.ts and bear-deterrent practices ai d 

encourage carry of bear spray.

Reduced Reliance on Supplemental Feeding 

The Bison and Elk Management Plan calls for reduced reliance on supplemental feeding. 

Encouraging elk and bison use of grassland habitats on the northern end of the Refuge would 

reduce forage use and conserve forage on the southern end of the Refuge, reducing the need for 

supplemental feeding. 

6 
294 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

• Identify criteria for beginning and ending feeding each year in consultation with the

WGFD.

• In collaboration with the WGFD, develop a structured framework of adaptive

management actions that include established criteria for progressively transitioning from

intensive supplemental winter feeding to greater reliance on free-standing forage, based

on some or all of the following considerations:

1. Level of forage production and availability on the Refuge;

2. Desired herd sizes and sex and age ratios;

3. Effective mitigation of bison and elk co-mingling with livestock on private

lands;

4. Prevalence of brucellosis, chronic wasting disease, and other wildlife diseases;

5. Winter distribution patterns of elk and bison; and

6. Public support.

Visitor and Employee Safety 

The proposed action includes providing for the safety, security, and protection of visitors, 

employees, natural and cultural resources, and facilities throughout the Refuge. 

• Develop bear regulations (food and trash handling) for resident employees and

volunteers.

• Offer improved programs at the visitor center, Miller House, and offsite areas with more

permanent or seasonal interpreters.

• Provide housing for staff and volunteers as available.

• Add up to five family houses and more seasonal housing.

Conservation Measures 

Conservation measures are actions to benefit or promote the recovery of listed species that are 

included by the federal agency as an integral part of the proposed action. These actions will be 

taken by the federal agency or applicant, and serve to minimize or compensate for, project 

effects on the species under review. These may include actions taken prior to the initiation of 

consultation, or actions which the federal agency or applicant have committed to complete in a 

biological assessment or similar document. The following are conservation measures 

implemented by the Refuge as part of the proposed action. 

• The Refuge will continue ongoing educational measures related to limiting the risk of

hunter-grizzly conflict and hunting-caused grizzly bear mortality, as well as bear safety

training for Refuge staff and volunteers.

• Refuge staff and volunteers will be required to carry bear spray in the field and adapt and

modify these measures as changing circumstances and information warrant.

• The Refuge will implement food/waste storage guidelines on Refuge facilities and with

any Refuge permitted activities such as hunting.

• The Refuge will encourage the use of non-lead rifle ammunition to reduce lead exposure

by grizzly bears scavenging on elk and bison gut piles.

7 
Appendix G—Intra-Service Section 7 Consultation 295 

Action Area 

The action area is defined as all areas to be affected directly or indirectly by the federal action 

and not merely the immediate area involved in the action. For the purposes of this biological 

opinion (BO), we have defined the action area to include the Refuge. The Refuge is a 24, 700-

acre (9,996 hectare) unit of the National Wildlife Refuge System administered by the Service. 

The action area includes the entire boundary for the National Elk Refuge located within Teton 

County, Wyoming, within Townships 41N and 42N, Ranges 115W and 116W, including all of 

the sections within this area. 

For purposes of this biological opinion, we will also consider portions of surrounding lands in 

the Bridger-Teton National Forest and the other areas outside of the Refuge as part of the action 

area due to the projected long-term increase in the number of hunters as a result of the proposed 

action. The action area will be discussed in terms of Game Management Units (GMU) or 

Existing Hunting Areas (Area). The following is a brief description of the Refuge GMUs' 

general locations within the action area: 

Area 77. National Elk Refuge. Beginning where U.S. Highway 26 crosses the Gros Ventre 

River; easterly up said river to the Bridger-Teton National Forest boundary; southerly along said 

boundary to Flat Creek; westerly along said creek approximately 3.5 miles to the second road 

crossing; southerly along said road 0.8 mile to a trail junction; westerly along a marked boundary 

to the Refuge fence; northerly along said fence to the Gros Ventre River. 

STATUS OF THE SPECIES/CRITICAL HABITAT 

Please note that the literature, the 1993 Recovery Plan, and other documents such as the 2007 

Conservation Strategy use three different ecosystem terms related to grizzly bears in 

northwestern Wyoming, southwestern Montana, and southeastern Idaho: Greater Yellowstone 

Area (G YA), Greater Yellowstone Ecosystem (G YE), and Yellowstone Grizzly Bear Ecosystem 

(YGBE). These terms all describe the Yellowstone ecosystem and for this BO, we regard them 

as more or less synonymous because the geographic scale at which any distinctions occur does 

not affect project analyses or potential impacts. 

Grizzly bears are among the largest terrestrial mammals in North America. South of the United 

States - Canada border, adult females range from 250 to 350 pounds and adult males range from 

400 to 600 pounds. Grizzly bears are relatively long-lived, living 25 years or longer in the wild. 

Grizzly bears are omnivorous, opportunistic feeders that require foods rich in protein or 

carbohydrates in excess of maintenance requirements in order to survive seasonal pre-and postdenning requirements. Grizzly bears are homeo-hypothermic hibernators, meaning their body 

temperature drops no more than nine degrees Fahrenheit (five degrees Centigrade) during winter 

when deep snow, low food availability, and low ambient air temperatures appear to make winter 

sleep essential to grizzly bears' survival (Craighead and Craighead 1972a, 1972b ). Grizzly bears 

excavate dens and require environments well covered with a blanket of snow for up to five 

months, generally beginning in fall (September to November) and extending until spring (March 

to April) (Craighead and Craighead 1972b; Pearson 1972). 

8
296 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

No critical habitat has been designated or proposed for grizzly bear; therefore, none will be 

affected. 

Life History 

Grizzly bears are large animals with great metabolic demands requiring extensive home ranges. 

The search for energy-rich food appears to be a driving force in grizzly bear behavior, habitat 

selection, and intra/inter-specific interactions. Grizzly bears historically used a wide variety of 

habitats across the North America, from open to forested, temperate through alpine and arctic 

habitats, once occurring as far south as Mexico. 

The grizzly bear is an opportunistic omnivore that uses a wide variety of plant and animal food 

sources. The literature provides comprehensive information on food items that grizzly bears 

consume. A recent synthesis of this information summarized that they consume up to 234 

different foods, 75 of which are eaten on a regular basis, with the higher caloric foods being 

army cutworm moths, various ungulate species such as elk and moose, cutthroat trout, and 

whitebark pine seeds (IGBST 2013). Combined food habit studies from the GY A show that 

grizzly bears not only display dietary plasticity among individuals and in different portions of the 

ecosystem, but also across seasonal, annual, and decadal time periods (IGBST 2013). 

Grizzly bears in the GY A have the highest percentage of meat consumption in their diet of any 

inland grizzly bear population with about 40 to 80 percent comprised of some form of animal 

matter (male bears tend to consume higher percentages of meat) (Jacoby et al. 1999 as cited in 

Robbins et al. 2006). Meat in the grizzly bear's diet varies by season and available forage. 

Ungulates are an especially important food source for bears in the spring and fall (Knight et al. 

1984), and use of carcasses in Yellowstone National Park is well documented (Podruzny and 

Gunther 200 I). 

Army cutworm moths are an important food source for some bears in the G YA (Mattson et al. 

1991). Army cutworm moths congregate in remote, high altitude alpine talus areas and feed on 

alpine flowers. These moths provide important dietary fat in the fall, when grizzly bears are 

preparing for hibernation, and are also positively correlated with bear reproductive success 

(Bjomlie and Haroldson 2001). During times of great moth abundance, White et al. (1999, as 

cited in Robison et al. 2006) estimated a grizzly bear may eat up to 40,000 moths per day and 

more than one million per month, representing 4 7 percent of its annual caloric budget. Army 

cutworm moth congregation sites are in remote areas and therefore, potentially reduce humanbear conflicts by isolating the bears. Spawning cutthroat trout in streams surrounding 

Yellowstone Lake have been an important food source for grizzly bears (Mattson and Reinhart 

1995). Grizzly bears will eat ants (Mattson 2001) and earthworms (Mattson et al. 2002); small 

mammals, such as pika and marmots, form a relatively minor portion of the bear's diet. In 

addition to eating wild ungulates, some grizzly bears consume domestic ungulates to varying 

degrees in some portions of the GYA, either in the form of carrion or as prey. 

Grizzly bears also eat a variety of vegetative foods. White bark pine seeds are an important fall 

source of food to some bears when seeds are available (as a masting species, whitebark pines 

9 
Appendix G—Intra-Service Section 7 Consultation 297 

only produce good crops every 2 to 3 years). Those bears with access to white bark pines 

consume the seeds that they scavenge from red squirrel cone caches (Mattson and Reinhart 

1997). Previous studies have demonstrated associations between whitebark pine cone production 

and survival of independent bears, fecundity (number of female cubs/female bear/yr), 

movements, and frequency of management actions (IGBC 2013). Cone crop failures influence 

foraging behavior that may increase vulnerability to human-caused mortality. When whitebark 

pine production is poor, grizzly bears tend to use lower elevations, where the risk of bear-human 

conflict is greater and survival is less (IGBST 2013). This is likely due to bears seeking 

alternative food sources, such as exotic clover species (Reinhart et al. 2001) and yampa, which 

occur at lower elevations and closer to humans. In addition to pine seeds supplying a food 

source high in fat, good whitebark pine seed crops also keep some grizzly bears occupied at high 

elevations far from intense human use. Other grizzly bear seasonal plant use includes roots 

(Mattson 1997), graminoids, horsetail, forbs, and fruits, such as whortleberry and huckleberry 

(Knight et al. 1984, Mattson et al. 1991 ). Bears also eat limited amounts of mushrooms. 

Grizzly bears generally construct dens in areas far from human disturbance at elevations of 

approximately 2,000 to 3,050 meters (6,500 to 10,000 ft). Grizzly bears den from the end of 

September to the last week in April or early May, with entrance and emergence dates affected by 

the gender and reproductive status of the bears. Denning bears can be disturbed by winter sport 

activities, such as snowmobiling; studies have focused on minimizing disturbance by controlling 

access to important denning areas (Haroldson et al. 2002, Podruzny et al. 2002). If pregnant 

female bears are disturbed in their dens and this disturbance causes them to relocate to a new den 

prior to parturition, negative consequences can occur in the form of reduced cub fitness and 

survival (Linnell et al. 2000, Swenson et al. 1997). 

Adult grizzly bears are normally solitary, except females with cubs or during short breeding 

relationships. They will tolerate other grizzly bears at closer distances when food sources are 

concentrated and siblings may associate for several years following weaning (Jonkel and Cowan 

1971; Craighead 1976; Egbert and Stokes 1976; Glenn et al. 1976; Herrero 1978). Across their 

range, home range sizes vary from about 50 square miles or more for females to a few hundred 

square miles for males. Overlap of home ranges is common. Grizzly bears have one of the 

lowest reproductive rates among terrestrial mammals, resulting primarily from the late age at 

first reproduction, small average litter size, and the long interval between litters. Mating occurs 

from late May through mid-July. 

Females in estrus will accept more than one adult male (Homocker 1962), and can produce cubs 

from different fathers the same year (Craighead et al. 1995). Age of first reproduction and litter 

size may be nutritionally related (Herrero 1978; Russell et al. 1978). Average age at first 

reproduction in the lower 48 states for females is 5.5 years and litter size ranges from one to four 

cubs that stay with the mother up to two years. Males may reach physiological reproductive age 

at 4.5 years but may not be behaviorally reproductive due to other dominant males preventing 

mating. 

Habitat fragmentation is significant to large carnivores requiring wide vegetative and 

topographic habitat diversity (Servheen 1986). Loss and fragmentation of habitat is particularly 

relevant to the survival of grizzly bears. Large expanses of unfragmented habitat are important 

10 
298 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

for feeding, breeding, sheltering, traveling and other essential behavioral patterns. Grizzly bears 

occur at low densities, have low reproductive rates, exhibit individualistic behavior, and are 

largely dependent on riparian habitats also used extensively by people; thus, grizzly bear 

populations are susceptible to human influences. Grizzly bears may avoid key habitats due to 

human generated disturbances, or become habituated and food conditioned, which may 

ultimately lead to the animal being destroyed. Historically, as human settlements, developments, 

and roads increased in grizzly bear habitat, grizzly bear populations became fragmented. As 

fragmented population segments become smaller and/or isolated, they are more vulnerable to 

extinction, especially when human-caused mortality pressures continue. Linkage zones, or zones 

of habitat connectivity within or between populations of animals, foster the genetic and 

demographic health of the species. Bader (2000) displayed potential secure areas that are 

spatially distributed within known male and female grizzly bear dispersal distances and he 

believes that the available information shows that effective linkages are possible for grizzly bear 

use and these linkage areas would increase persistence probabilities. 

Population Dynamics, Status and Distribution 

The grizzly bear originally inhabited a variety of habitats from the Great Plains to the mountains 

of western North America, from central Mexico to the Arctic Ocean. With the advent of 

Euroamerican colonization in the early nineteenth century, grizzly bear numbers were reduced 

from over 50,000 to less than 1,000 in North America south of the Canadian border. Today, the 

grizzly bear occupies less than two percent of its former range south of Canada (USFWS 1993). 

In the conterminous 48 States, only five remaining areas have either remnant or self-perpetuating 

populations. 

The grizzly bear was listed as a threatened species under the ESA in the lower 48 states on July 

28, 1975 ( 40 FR 31736). The Service identified the following as factors establishing the need to 

list: (1) present or threatened destruction, modification, or curtailment of habitat or range; 

(2) overutilization for commercial, sporting, scientific, or educational purposes; and (3) other

manmade factors affecting its continued existence. The two primary challenges in grizzly bear

conservation are the reduction of human-caused mortality and the conservation ofremaining

habitat (USFWS 1993).

The grizzly bear recovery plan (Recovery Plan) was completed on January 1982 and was revised 

in 1993 (USFWS 1993). The 1993 revised Recovery Plan delineated grizzly bear recovery zones 

in six mountainous ecosystems in the U.S. The Recovery Plan details recovery objectives and 

strategies for the grizzly bear recovery zones in the ecosystems where grizzly bear populations 

still persist. Four of the recovery zones are the Northern Continental Divide (NCDE), 

Yellowstone Grizzly Bear (YGBE), Cabinet-Yaak (CYE) and Selkirk (SE) Ecosystems. The 

Recovery Plan also includes recovery strategies for the North Cascades Ecosystem in 

Washington, where only a very fow grizzly bears are believed to remain, and for the SelwayBitterroot ecosystem of Idaho and Montana, where suitable grizzly bear habitat still occurs. 

Grizzly bear recovery zones (RZ) were established to include areas large enough and of 

sufficient habitat quality to support a recovered bear population in each zone. According to the 

11 
Appendix G—Intra-Service Section 7 Consultation 299 

1993 Recovery Plan, a recovery zone is defined as that area in each grizzly bear ecosystem 

within which the population and habitat criteria for achievement of recovery will be measured. 

However, the GY A RZ recovery criteria have since been updated to include criteria applicable to 

the entire GYA ecosystem, such as population estimates and mortality thresholds. 

Table 1. Estimated grizzly bear population size (individuals) and population growth rate by 

Recovery Zone or Ecosystem (USFWS 2011b, IGBST 2014c). 

Recovery Zone or Ecosystem Estimated Population Size Trend (% chan2e annually) 

Greater Yellowstone Area 674 and 839 +Oto 2%

Ecosystem 

Northern Continental Divide 930 +3%

RZ 

Cabinet-Yaak RZ 42 -3.8%

Selkirk RZ 88** +1.9%

North Cascades RZ <20 unknown 

Bitterroot RZ 0 n/a 

*Reflects two methods for estimating population (see Greater Yellowstone Area subsection

below.) This population estimate covers the entire ecosystem. The GYA includes our defined

action area.

**Estimate includes 30 in U.S. and 58 in Canada

Habitat degradation and fragmentation, and negative human/bear interactions are the primary 

factors responsible for grizzly bears' current threatened status (USFWS 201 la). Grizzly bears 

preferentially use large areas with a low density of roads and low levels of human activity. 

Secure habitat is an important component for minimizing habitat degradation and fragmentation, 

and is defined as areas larger than 4 hectares (ha) ( 10 acres) in size and greater than 5 00 meters 

(m) from an open road (Interagency Conservation Strategy Team 2007). The average amount of

secure habitat in each recovery zone ranges from 53 percent in the Selkirks to 86 percent in the

GYA (USFWS 201 lb).

Northern Continental Divide (NCDE): Grizzly bears are well distributed throughout the 

NCDE Recovery Zone and their range has expanded outside of the recovery zone boundary to 

the east, and somewhat to the west and south (USFWS 2013). The Grizzly Bear Management 

Plan for Western Montana identifies 37,460 square kilometers (sq km) (14,463 sq mi) of the 

NCDE as occupied, including some intervening habitat between the NCDE and the Cabinety aak. The estimate of average annual population growth was re-calculated in 2012 with a 

resulting rate of 3.03 percent per year across the time period from 2004-2011 and a total 

population estimate of approximately 930 to 942 bears. The NCDE population of grizzly bears 

is contiguous with grizzly bears in Canada, resulting in high genetic diversity (Proctor et al. 

2012, as cited in USFWS 2013). Grizzly bears are well distributed throughout the NCDE 

Primary Conservation Area and Zone I although density is higher inside the Primary 

Conservation Area (see Kendall et al. 2009; Mace and Roberts 2011, as cited in USFWS 2013). 

Cabinet-Yaak (CYE): The CYE Recovery Zone is estimated to contain at least 40 to 45 grizzly 

bears (Kasworm et al. 2007, as cited in USFWS 2011 b ). Separate population estimates were 

12 
300 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

made for the Cabinet Mountains and the Y aak River drainage because there is no documented 

movement of grizzly bears between these two portions of the RZ. The Cabinet Mountains lie 

south of the Y aak River drainage and contain about 60 percent of the RZ. There are 

approximately 15 individuals in the Cabinet Mountains and 25 to 30 individuals in the Yaak 

portion of the RZ (Kasworm et al.2007, as cited in USFWS 201 lb). There are another estimated 

24 grizzly bears in Canada directly across the border from the Yaak (Proctor et al. 2012, as cited 

in USFWS 201 lb). 

Selkirks (SE): The estimated population size is 88 grizzly bears in the SE RZ, with 30 in the 

U.S. and 58 in Canada (Proctor et al. 2012, as cited in USFWS 201 lb). While this population 

estimate represents a substantial increase in bears in the SE since 1999, it must be interpreted 

cautiously until more accurate data are available. The estimate for the U.S. portion of the SE is 

based on expert opinion (Wakkinen 2010, as cited in USFWS 201 lb). It is estim;:ited that the 

population of grizzly bears in the SE is slowly increasing at a rate of 1 .9 percent annually. 

North Cascades (NCASC): The population in the NCASC is estimated to be fewer than 20 

animals within the 24,605 sq km (9,500 sq mi) RZ. The population in adjacent British Columbia 

is estimated to be less than 25 grizzly bears within a 9,800 sq km (3,784 sq mi) art!a (North 

Cascades Grizzly Bear Recovery Team 2004, as cited in USFWS 2011 b ). The distribution of 

grizzly bears within the NCASC is unknown due to a lack of data (USFWS 2011 b ). 

Greater Yellowstone Area (GYA): The 23,828 sq km (9,209-sq mi or 5.89 million ac) OYA 

RZ includes portions of Wyoming, Montana, and Idaho and portions of six National Forests 

(Beaverhead, Bridger-Teton, Custer, Gallatin, Shoshone, and Caribou-Targhee), Yellowstone 

and Grand Teton National Parks, John D. Rockefeller, Jr. Memorial Parkway, Bureau of Land 

Management, and adjacent private and state lands. The range of grizzly bears in the entire GYA 

has increased, as evidenced by the 48 percent increase in occupied habitat between the 1970s and 

early 2000s, and it is still expanding (Pyare et al. 2004, Schwartz et al. 2002, IGBST 2013). The 

most recent estimate of the known area occupied by grizzly bears in the entire OYA is 

approximately 50,280 sq km (19,413 sq mi or 12,424,320 ac) (Bjornlie 2013). 

The GYA represents the most distant portion of the current grizzly bear range in the U.S. and has 

been the primary focus of grizzly bear recovery efforts to date. Range expansion and population 

increases, including into southern portions of the GYA, have been concurrent with the Refuge 

implementing many of the actions described in the proposed action, and with other federal and 

non-federal actions described in the baseline below. This means that historical activities 

comparable to the proposed action have had little to no discernible effect on the population's 

trend toward recovery. 

Recovery efforts have been very successful and the number and distribution of grizzly bears in 

this population have exceeded target recovery levels for nearly two decades. For example, the 

population of independent female grizzly bears has grown from less than 30 in 1983 to more than 

250 (Schwartz et al. 2011, Haroldson and Frey 2013). Recovery work continues to reduce 

grizzly bear mortalities and ensure habitat standards for maintaining a recovered population in 

this ecosystem. 

13 
Appendix G—Intra-Service Section 7 Consultation 301 

Best available science suggests the GY A ecosystem grizzly bear population is stable to slightly 

increasing. In 2014, estimates of the number of grizzly bears in the GYA were 674 or 839 

depending on the methods used to estimate population size ( see Conservation section for details) 

(IGBST 2014c). Current analysis indicates that this grizzly bear population grew an average of 4 

percent or more annually from 1983 to 2001. The population's rate of growth slowed to O to 2.2 

percent during 2002 to 2011, likely because of the increase in grizzly bear density in the GYA 

(IGBST 2012, IGBST 2013). The grizzly bear population in the GYA met its recovery goals in 

the mid- l 990s, has exceeded recovery goals every year since, and may be nearing carrying 

capacity (IGBST 2013). 

The Service proposed to establish a Distinct Population Segment of the grizzly bear for the GY A 

and surrounding lands and concurrently delist it from the ESA on November 17, 2005 (70 FR 

69854; USFWS 2005). The final rule to delist the grizzly bear was published on March 28, 

2007, and became effective April 30, 2007 (72 FR 14866; USFWS 2007). An order was issued 

by the Federal District Court in Missoula on September 21, 2009, which enjoined and vacated 

the delisting of the GYA grizzly population. In compliance with this order, the GYA grizzly 

population is again treated as a threatened population under the ESA. The District Court 

decision was appealed on two primary issues: (1) adequacy of regulatory mechanisms after 

delisting (i.e., the Conservation Strategy) and, (2) the potential threat of white bark pine decline 

on the GYA grizzly bear population. The 9th Circuit Court of Appeals rendered a decision in 

November 2011 and reversed the District Court decision regarding the adequacy of protections 

provided under the Conservation Strategy but upheld the District Court decision that the Service 

had not sufficiently articulated that whitebark pine decline was not a threat to the GYA grizzly 

population. In response to this the Interagency Grizzly Bear Committee and Yellowstone 

Ecosystem Subcommittee tasked the IGBST to provide information and further research relevant 

to whether grizzly bears do find alternative foods to whitebark pine seeds, literature to support 

this statement, and whether impacts can occur to individual bears without causing the overall 

population to decline (IGBST 2013). 

Human-grizzly bear interactions have been increasing in the GYA due, in part, to increasing 

human use and development, increasing bear numbers, and bears and people both expanding the 

range of occupancy, thereby increasing the chances of adverse encounters. The frequency of 

grizzly bear-human conflicts is inversely associated with the abundance of natural bear foods 

(Gunther et al. 2004). Mortalities from grizzly bear-human conflicts currently are a primary 

source of grizzly bear mortality (see IGBST annual reports and mortality database). Table 2 

summarizes the 461 known and probably grizzly bear mortalities from 1997 to 2014 in the G YA 

(IGBST 2014a). 

14 
302 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Table 2: Known and probable grizzly bear mortalities in the GYA, 1997-2014. 

Cause of Mortality Number of Bear Mortalities Percent of Total Mortality 

Natural injury or deformity 4 0.8 

Predation 35 7.3 

Malnutrition 3 0.6 

Old age 6 1.3 

Poached/malicious 24 5.0 

Hunting DLP* 104 21.8 

Backcountry camp illegal 3 0.6 

Backcountry camp DLP* 13 2.7 

Front Country DLP* 8 1.7 

Front country mgmt. removal 80 16.8 

Human aggr/injury/fatality- 11 2.3 

mgmt removal 

Sheep related illegal 1 0.2 

Sheep depredation mgmt. 8 1.7 

removal 

Cattle depredation mgmt. 43 9.0 

rm oval 

Mgmt capture mortality 3 0.6 

Research capture mortality 6 1.3 

Road kill 22 4.6 

Hunting related illegal 2 0.4 

Horse depredation mgmt. 1 0.2 

removal 

Specific undetermined 93 19.5 

Poisoning 1 0.2 

Non-hunting backcountry DL * 6 1.3 

Total 477 100.0 

*DL (and DLP) means Defense of Life (and DL or property)

Conservation 

In an effort to facilitate consistency in the management of grizzly bear habitat within and across 

ecosystems, the Interagency Grizzly Bear Guidelines were developed by the Interagency Grizzly 

Bear Committee (IGBC) (5 I FR 42863, November 26, 1986) for use by land managers. The 

IGBC developed specific land management guidelines for use in each of the five ecosystems 

including the YGBE. 

Recovery zones also have been established for the grizzly bear and include areas large enough 

and of sufficient habitat quality to support a recovered bear population. According to the Grizzly 

Bear Recovery Plan (USFWS 1993), a recovery zone is defined as that area in each grizzly bear 

ecosystem within which the population and habitat criteria for achievement of recovery will be 

measured. Areas outside of recovery zones may provide habitat that grizzly bears will use but 

are not considered necessary for the survival and recovery of this species. The area outside the 

15 
Appendix G—Intra-Service Section 7 Consultation 303 

recovery zone but within the 10-mile buffer area is managed to consider and protect grizzles and 

their habitat whenever possible recognizing that population and mortality data within this zone 

are collected and pertinent to recovery criteria. Beyond the 10-mile buffer, grizzly bear 

mortalities or populations are not considered when determining whether recovery goals have 

been met, although protection is still accorded to the grizzly bear under the ESA. 

The Yellowstone Grizzly Bear Recovery Zone (RZ) covers approximately 2,200,729 hectares 

(5,438,000 acres) of primarily NPS and National Forest Service (NFS) lands, roughly 89 percent 

of the currently known distribution of the grizzly bears in the YGBE. Yellowstone and Grand 

Teton National Parks make up 39 percent of the YGBE recovery zone. Private holdings and 

other ownership make up 2.1 percent of the recovery zone and the remaining 58.5 percent occurs 

on lands managed by the National Forest Service (ICST 2007). The Refuge is outside of the RZ. 

Areas within the Recovery Zone are stratified into Management Situation Zones 1, 2, or 3; each 

having a specific management direction according to the Interagency Grizzly Bear Guidelines 

(IGBC 1986). 

Management Situation 1 (MS 1 ): lands contain population centers of grizzlies are key 

to the survival of the species, and are where management decisions will favor the needs 

of the bear even when other land use values compete. 

Management Situation 2 (MS2): lands are those areas that lack distinct population 

centers and the need for this habitat for survival of the grizzly bear is more uncertain. 

The status of such lands is subject to review. Here, management will at least maintain 

those habitat conditions that resulted in the area being classified as MS2. 

Management Situation 3 (MS3): designation is intended for lands where grizzly bears 

may occur infrequently. There is high probability that federal activities here may affect 

the species survival and recovery. Management focus is on human-bear conflict 

minimization, rather than habitat maintenance and protection. 

All grizzly bear recovery zones were subdivided into smaller units to facilitate both the 

assessment of projects and recovery objectives. Bear management units (BMU) were formally 

delineated throughout each zone. The BMU were designed to: 

• Assess the effects of existing and proposed activities on grizzly bear habitat without

having the effects diluted by consideration of too large an area;

• Address unique habitat characteristics and grizzly bear activity and use patterns;

• Identify contiguous complexes of habitat which meet year-long needs of the grizzly bear;

and

• Establish priorities for areas where land use management needs would require cumulative

effects assessments.

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304 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

The low survival at adult females was identified as the single most important factor in causing 

the decline in the Yellowstone population prior to the mid-1980' s (Knight and Eberhardt 1985). 

The current Recovery Plan (USFWS 1993) outlines demographic goals to objectively measure 

and monitor the recovery of the Yellowstone grizzly bear population. That plan defines a 

recovered population as one that can sustain the existing level of known and unknown humancaused mortality that exists in the ecosystem and is well-distributed throughout the recovery 

zone. Demographic recovery criteria outlined for the Yellowstone recovery zone include: 

(1) Observation of 15 females with cubs of the year annually (unduplicated sightings)

over a 6-year running average;

(2) Occupation of 16 of the 18 BMUs by females with young from a running 6-year sum

of verified observations, and no 2 adjacent BMUs unoccupied with a study to be initiated

in the Plateau and Henry's Lake BMUs to determine the capability of these units to

support females with cubs;

(3) Known, human-caused mortality not to exceed 4 percent of the current population

estimate (based on most recent 3-year sum of females with young); with no more lhan 30 

percent of this total mortality limit incurred by females; and,

(4) These mortality limits cannot be exceeded during any 2 consecutive years.

Threats 

Isolation from human activities is extremely important for bear survival, due to the tendency of 

grizzly bears to rapidly habituate to human foods. Food-conditioned bears often must be 

eliminated or removed from developed areas. A voiding human-caused bear mortality is a goal 

of the Recovery Plan and is essential to maintaining a viable grizzly bear population (USFWS 

1993). 

Primary threats grizzly bears are associated with motorized and dispersed recreational use and 

forest management activities, including timber harvest. Recreation use includes hunting, fishing, 

camping, horseback riding, hiking, biking, off-road vehicle (ORV) use, and snowmobiling. 

Direct human-caused mortality is the most obvious threat to the grizzly bear. This kind of 

mortality can occur in several ways (1) defense of human life or property, (2) management 

removals, (3) mistaken identification by big game hunters, or (4) malicious killing. Nuisance 

bears are removed to defend human life or property, usually because they have become 

dangerously bold as a result of food conditioning and habituation at campsites, lodges, resorts, 

and private residences or they become habituated predators of livestock (Knight and Judd 1983). 

Human-grizzly bear interactions have been increasing in the YGBE due, in part, to increasing 

human use and development, increasing bear numbers, and bears and people both expanding 

their range of occupancy, increasing the chances of adverse encounters. The frequency of 

grizzly bear-human conflicts is inversely associated with the abundance of natural bear foods 

(Gunther et al. 2004). Most grizzly bear mortalities are directly related to grizzly bear-human 

conflicts. The Interagency Conservation Strategy Team (2014c) reported known human caused 

17 
Appendix G—Intra-Service Section 7 Consultation 305 

mortalities from 1997 to 2014. Of336 human-caused mortalities, 31.5 percent were hunting 

related, 7 .1 percent were poaching, and 15. 8 percent were related to livestock ( see table 2 for a 

complete list). The greatest increase in grizzly bear mortalities in recent years is self-defense in 

fall by big game hunters. 

There are a number of naturally or semi-naturally occurring factors that also may influence 

Yellowstone grizzly bear population levels. Whitebark pine provides an important food source 

for grizzly bears. Blister rust, which has severe consequences on whitebark pine in the Northern 

Continental Divide Ecosystem, has been observed in the Yellowstone area. The Yellowstone 

cutthroat trout, which is an important food source for grizzly bears to the area, has been 

negatively influenced by introduced lake trout, which are less available to bears due to their 

deeper water habits (Reinhart et al. 2001 ). Winter-killed ungulates are an important food supply 

but ungulate populations vary widely in numbers and are influenced by weather conditions. The 

reintroduction of wolves has increased competition for ungulate prey and winter-killed carrion. 

Recent fires may have impacts on available food and cover over the short term, particularly to 

individual bears with heavily burned home ranges. Fire, in general, over time stimulates many 

forage species and berries preferred by bears, provided alternate food supplies and cover is 

available to maintain bears through the immediate aftermath of the fire. 

Army cutworm moths (ACM) in some areas could be affected by agricultural pesticide use, and 

due to some bears' reliance on this food resource, there was a concern that certain pesticides may 

bioaccumulate in bears. Recent investigation into this possibility indicates that, while pesticides 

are present in ACMs to trace quantities they are most likely not sufficient to cause direct adverse 

effects on, or biomagnify in bears (Robinson et al. 2006). This study cautions, however, that 

pesticide use is a relevant concern when addressing bear conservation issues. Due to their 

unique physiology including hyperphagia (increased appetite), brown fat accumulation and 

torpor, bears may assimilate and excrete certain chemicals in unique ways. Further research is 

recommended including sampling and analysis of blood hair, and fat samples in order to monitor 

this, potential threat as available pesticides and their listed uses change. 

Grizzly bears have also experienced displacement from available habitat (loss of habitat 

effectiveness due to human disturbance) due to increased human uses from (1) expanding road 

access in wilderness areas (Kasworm and Manley 1989), (2) ORV use and (3) recreation use. 

They have also experienced loss of existing available habitat due to (I) increased development 

on private land related primarily to residential housing, and (2) potential for increased 

development on public land related primarily to oil/gas and recreation development. The grizzly 

bear also faces a decrease in value of available habitat due to (1) a loss of biodiversity ( especially 

early-succession related vegetative types), and (2) sub-optimal composition, structure, and 

juxtaposition of vegetation as a result of fire suppression management strategies and advancing 

succession. Finally the bear faces isolation due to fragmentation of available habitat due to (1) 

major development of private land (2) construction of major highways that block or restrict 

movement, (3) inadequate provision for linkage on minor roads and highways, and (4) large 

blocks of clearcuts. 

18 
306 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

ENVIRONMENTAL BASELINE 

Under the provisions of section 7(a)(2), when considering the "effects of the action" on listed 

species, the Service is required to consider the environmental baseline. Regulations 

implementing the Act (50 CFR 402.02) define the environmental baseline as the past and present 

impacts of all federal, state, or private actions and other human activities in the action area. Also 

included in the environmental baseline are the anticipated impacts of all proposed federal 

projects in the action area that have undergone section 7 consultation, and the impacts of state 

and private actions which are contemporaneous with the consultation in progress. 

Status of Species habitat within the Action Area 

The PCA, or grizzly bear recovery zone as it was initially described (USFWS 1993) was 

delineated to define an area within which to focus grizzly bear recovery efforts after the species 

were listed in 1975. At the time the boundary was delineated, grizzly bears were uncommon in 

Grand Teton National Park (GTNP) and surrounding areas, including the Refuge. 

Historically, incidental grizzly bear use was only documented on the northern parts of the 

Refuge. However, recent observations in the southern part of GTNP bordering the Refuge 

suggest that increased grizzly bear activity on the Refuge is likely in the near future. Grizzly 

bears had not been observed on the Refuge since 1994, but a sow and three cubs were observed 

feeding on a bison gut pile in August 2013. There have been incidental observations of grizzly 

bears in the northern part of the Refuge. Based on recent observations adjacent to and within the 

Refuge, there is an anticipation of increased use of the Refuge by grizzly bears. Grizzly bears 

have been seen within 5 miles of Refuge houses. As the GYE bear population continues to 

expand southward into presently unoccupied areas, and with continued habituation of bears to 

human presence and activity, the potential for the occurrence of bears on the Refuge will likely 

mcrease. 

Shifts in grizzly bear seasonal distribution within the GYE appear to be directly related to 

resource availability. Recent research indicates that bears in Yellowstone National Park (YNP) 

are 2 times more likely to be found outside of the park during the early hunting season. This 

movement occurred regardless of the relative yearly production and abundance of whitebark pine 

seed production (Haroldson et al. 2004). Elk hunting seasons in the GYE begin as early as 

September 10 and run through December 3. This period coincides with late hyperphagia in GYE 

grizzly bears, as well as the time period (September-October) during which the majority of 

hunting-related grizzly bear mortalities have occurred (Haroldson et al. 2004) 

Hunting related deaths resulting from human grizz 1 y conflict remain the most significant source 

of known grizzly bear mortality in the GYE (Haroldson et al. 2004, USFWS 2003). In the PCA 

itself: analysis of the potential correlation between hunter numbers and levels of known and 

probable grizzly bear mortality from 1987 to 1997 indicated little relationship (USFWS 2003). 

This analysis did not consider the relationship between hunter numbers and grizzly bear 

mortality in areas outside of the PCA. While the high level of hunting-related grizzly mortality 

19 
Appendix G—Intra-Service Section 7 Consultation 307 

has not been directly linked to hunter numbers in the PCA, it is nonetheless primarily the result 

of chance encounters between bears and hunters in the field, conflicts over ungulate carcasses 

and conflicts in hunter camps often as a result of game meat being kept in campsites (USFWS 

2003; Haroldson et al. 2004). 

Within the Refuge, Area 77 is dominated by mixed shrub and sagebrush shrubland interspersed 

with grassland. Riparian woodland habitat consists primarily of narrow leaf cottonwood 

(Populus angustifolia) and willow (Salix spp) stands. Aspen woodlands occur on many hillsides, 

often some distance from water sources. Small patches of conifer forest occur within the hunt 

area and consist of Douglas-fir (Pseudotsuga menziesii), lodgepole pine (Pinus 

contorta) and junipers. Agricultural areas and cultivated fields occur throughout the hunt area. 

The relatively even and open nature of terrain within the hunt area provides excellent foraging 

habitat for ungulates, but largely precludes grizzly-bear use and occupancy. 

Factors Affecting Speci_es Environment within the Action Area 

General Factors 

Past and ongoing actions within the action area and within the grizzly bear Recovery Zone are 

likely to affect GYE grizzly bears moving through the action area whether their home range is 

within or adjacent to the action area. These actions include: 

• Livestock grazing (which would impact grizzly bears through management actions),

• Private land development,

• Firewood cutting,

• Road use/management/improvements,

• Timber harvest,

• Recreation activities that lead to human-bear conflicts,

• Vegetation management,

• Wild and prescribed fire, and

• Loss or decline of important food sources ( e.g, whitebark pine seeds due to fire

suppression).

Past projects, their effects on grizzly bears, and the level of incidental take have also been 

considered in the environmental baseline. Previous formal consultation in the vicinity of the 

action area addressed transportation projects and grazing permits. The projects are: (1) the 

Grand Teton National Park Transportation Plan (WY003, February 9, 2007); (2) domestic 

livestock grazing in Grand Teton National Park (WY9351, May 2, 2006); (3) the Federal 

Highway Administration's Highway 287/26 Reconstruction project (i.e., Togwotee Pass 

Highway) (WY5998, August 22, 2003); (4) the Forest Service issuance of commercial 

grazing permits on the Bridger-Teton National Forest (WY4715, December 3, 2002); and (5) the 

Re-initiation of formal consultation on Grand Teton National Park and National Elk Refuge 

Bison and Elk Management Plan/EIS (WY13F0094, September 13, 2013). These pr jects, their 

affects to the grizzly bears, and the level of incidental take have been considered in the 

environmental baseline for this biological opinion. 

20 
308 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

EFFECTS OF THE ACTION 

Under section 7(a)(2) of the ESA, "effects of the action" refers to the direct and indirect effects 

of an action on the species or critical habitat, with the effects of other activities interrelated or 

interdependent with that action. Direct effects are immediate effects of the proposed action on 

the species or its habitat. Indirect effects are those caused by the proposed action and are later in 

time, but still are reasonably certain to occur (50 CFR 402.02). The effects of the action are 

added to the environmental baseline to determine the future baseline and to form the basis for the 

determination in this opinion. Should the federal action result in a jeopardy situation and/or 

adverse modification conclusion, the Service may propose reasonable and prudent alternatives 

that the federal agency can take to avoid violation of section 7(a)(2). The effects discussed 

below are the result of direct and indirect impacts of implementing the proposed action and are 

addressed according to the management goals outlined in the CCP. They are broken down and 

discussed further according to key actions occurring under each goal. 

Habitat conservation 

Under the proposed action 800 to 2,000 acres per year (324-809 ha/yr) of cultivated land will 

continue to be flood irrigated, while up to 1,200 acres (445 ha) will be converted from flood to 

sprinkler irrigation. Restoration of native species to 4,500 acres (1,821 ha) of existing 

agriculture fields will occur in GTNP and exclosures will be used on the Refuge to allow 

recovery of willow, aspen and cottonwood stands. These actions will likely result in an overall 

minor decrease in total herbaceous forage available for elk and bison but will improve the overall 

quality of available forage. While these actions may alter ungulate distributions and densities, 

and cause elk in the Jackson herd to alter their movements within and outside of the Refuge in 

response to the changes, it is unlikely that these factors would have any significant impact on the 

GYE grizzly bear population. These habitat alterations would not impact the elk herd size 

overall, the goal is to disperse the elk into other habitats providing more functional habitats 

within and outside of the Refuge. This would not change a grizzly bear food source, it may 

provide additional food opportunities for bears using the areas outside of the Refuge. 

Sustainable populations/ Elk and bison numbers 

Supplemental feeding 

Under the proposed action, supplemental feeding will be reduced from current levels and 

replaced by greater ungulate reliance on standing forage. A reduction in supplemental feeding 

may lead to changes in ungulate distribution and increased mortality and would likely cause elk 

and bison to return to a more natural pattern of sustenance influenced to a greater degree by 

factor such a climate and availability of native forage. Supplemental feeding likely reduces the 

effects of density in the Jackson elk herd (Lubow and Smith 2004); therefore, density-dependent 

effects on seasonal juvenile survival and dispersal may become more apparent as supplemental 

feeding is reduced. These effects, however, along with associated decrease in adult and juvenile 

elk survival rates, are likely to be negligible since the Jackson elk herd is maintained below 

carrying capacity (Lubow and Smith 2004). While minor increases in elk mortality as a result of 

reduced supplemental feeding may be beneficial to grizzly bears in the Project area due to 

increased availability of carcasses providing only be a temporary benefit. As the elk herds adjust 

21 
Appendix G—Intra-Service Section 7 Consultation 309 

to their change in food resources few elk will perish. In addition, the additional carcasses will 

comprise a small proportion of a bear's yearly diet due to other abundant food resources and the 

presence of other scavengers ( e.g., wolves, coyotes, ravens, etc.) on the landscape. 

Elk hunt 

The Jackson elk herd comprises one of the largest concentrations of elk in North America with 

an estimated 13,000 individuals whose seasonal distributions allow them to be considered as 

being divided into four herd segments (Grand Teton, Yellowstone, Teton Wilderness, and Gros 

Ventre). The elk migrate across several jurisdictional boundaries, including the Refuge, GTNP, 

JDR Memorial Park, Yellowstone National Park, Bridger-Teton National Forest, Bureau of Land 

Management resource areas and state and private lands. Because of its large size, wide 

distribution, effects on vegetation, and importance to the area's predators and scavengers, the 

Jackson elk herd contributes significantly to the ecology of the southern GYE. 

Elk hunting has been an annual event on the Refuge since 1955 and is the primary management 

tool used to control the Jackson elk herd population both on the Refuge and throughout the 

Jackson elk herd units. As part of the proposed action, there will be a short term increase in 

hunter numbers on the Refuge from 733 to 1,000 and an increase from 220 to 300 elk harvested 

annually. In the long term, overall hunter numbers on the Refuge will likely decrease to 470 to 

487, as will the number of elk harvested (126 to 146). Hunting on the Refuge currently occurs in 

Area 77; however, a small hunt area may potentially be added in the southern portion of the 

Refuge in order to force elk back into other hunt areas. Hunting will be strictly managed and the 

areas available to hunting frequently patrolled. Hunting permits issued for the Refuge are dayuse only and do not allow hunters to camp overnight. Hunters will be educated by the Refuge 

staff on bear safety and identification; hunters will be carrying bear spray, and will abide by food 

and game storage regulations. Despite these aforementioned factors and the fact that habitat on 

the Refuge is relatively open and generally lacks densely forested areas, it is becoming more 

likely that the risk of human-caused conflict resulting in hunting-caused grizzly bear mortality 

associated with elk hunts will be greater in either the short or long term as grizzly bears continue 

to expand their range and a result of the proposed action. 

Bison hunt 

A bison hunt will occur under the proposed action in order to reduce the herd size on the Refuge, 

increase bison distribution, limit bison conflict with elk along feed lines, and reduce the potential 

for disease transmission. A reduction in herd size will also contribute to enhancement of habitat 

through a decrease in the damage caused by excessive grazing and browsing of willow, aspen 

and cottonwood stands. Initially the bison hunt will reduce herd size by 140 to 150 bison per 

year, of which, 90 to 100 will be removed' on the Refuge and 50 will be removed from the 

Bridger-Teton National Forest. The hunts will involve an average of 175 to 190 bison hunters 

each year. In the long term, the Elk and Bison Management Plan estimates that average of 70 

bison will be killed ammally, with an average of 90 hunters participating in the hunt. This 

represents a substantial increase over recent numbers of bison being harvested and bison hunters 

on the Refuge. Despite the increase in the number of hunters on the Refuge, due to the 

aforementioned factors (i.e. livestock grazing, private land development, firewood cutting, 

22 
310 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

road/use/management/improvements, timber harvest, recreation activities, vegetation 

management, wild and prescribed fire, and loss or decline of important food sources) and 

conditions associated with hunts on Refuge, the risk of human-caused conflict resulting in 

hunting-caused grizzly bear mortality is considered to be low, both in the short and the long 

term. The risk of hunter-caused grizzly mortality associated with bison hunts in the BridgerTeton National Forest is considered to be higher than on the Refuge, especially in the northern 

portions of Area 81 east of Elk Ranch and between Buffalo Fork and Spread Creek. 

Disease management 

In order to maintain the health of elk and bison populations while continuing supplemental 

feeding at reduced levels, a variety of disease management techniques will be explored ( e.g., 

vaccination, selective fertility control, age- and sex-specific harvest). Under the proposed action, 

WGFD personnel will be allowed to use brucellosis vaccine Strain 19 on elk and RBSI on calf 

and nonpregnant female bison along feedlines during feedline operations. Grizzly bears may 

consume elk or bison exposed to these brucellosis vaccines; however, research indicates that 

there are no significant adverse effects of the RB5 l vaccine on non target species ( Januszewski et 

al. 200 I). No clinical trials have been executed to detennine if vaccine Strain 19 is safe for 

nontarget species; however, the vaccine has been used on WGFD feedgrounds for 17 years 

without any noticeable adverse clinical, histological or reproductive effects on nontarget species. 

Since vaccination activities will occur within the Refuge along feedlines it is not expected that 

there will be a risk of disturbance to grizzly bear associated with the action. 

Food Storage 

Grizzly bears have been seen within 5 miles of Refuge houses. Bears that become habituated to 

human garbage or other food rewards will need to be relocated or destroyed. Teton County 

passed local policies and practices to manage household garbage storage and disposal to prevent 

access by bears, which can quickly become habituated to this food source. The Refuge will 

develop garbage storage and disposal rules for Refuge residents and visitors that are consistent 

with the spirit of local regulations; these policies and practices will describe proper trash 

disposal, food storage, and use of bird feeders. These actions will be implemented within the 

first of year of the CCP. Implementation of these food/waste storage policies will help prevent 

grizzly bears foraging in the Refuge from developing associations with human food/waste and 

residences. 

Education 

Bear safety training for Refuge staff and volunteers has been in place for the last several years, 

and Refuge staff and volunteers are required to carry bear spray in the field. Under the CCP, the 

Refuge will provide education on grizzly bear/human interactions for staff and visitors including: 

distribution of materials promoting the use of bear spays, techniques to minimize human/bear 

interactions, and proper food/game meat storage techniques for hunters. Education, training, and 

use of bear spray will further reduce the likelihood of human-bear conflicts that would otherwise 

result in the relocation or removal of grizzly bears. Under the proposed action the Refuge will 

also education the public about the use of non-lead rifle ammunition, which potentially could 

23 
Appendix G—Intra-Service Section 7 Consultation 311 

reduce lead exposure to bears scavenging on elk and bison gut piles. Research specifically 

supporting physiological or population benefits to Grizzly bears from reduced lead exposure 

does not exist, but a change in ammunition type will not result in adverse effects and may be 

beneficial. 

CUMULATIVE EFFECTS 

Cumulative effects include the effects of future state, tribal, local or private actions that are 

reasonably certain to occur in the action area considered in this biological opinion. Future 

federal actions that are unrelated to the proposed action are not considered in this section because 

they require separate consultation pursuant to section 7 of the ESA. 

Cumulative Effects within the Action Area 

Potential activities that could cumulatively affect the grizzly bear within the Refuge planning 

area include: (1) livestock grazing on state or private lands, (2) residential development that may 

impact habitat through degradation, removal, and fragmentation or sedimentation of waterways, 

(3) expanded road networks on state and private lands that may result in fragmentation of habitat,

(4) infrastructure associated with urban expansion and mineral development including pipelines

and powerlines, (5) spread of invasive species on private and state lands in the planning area,

(6) actions undertaken by private landowners that impact the health and performance of

watersheds, (7) mineral and other development, the construction and maintenance of rights-ofway, and vegetation treatments (e.g., prescribed burns, mechanical, or chemical treatments) on

state and private lands contribute that may result in removal of vegetation and increased

sedimentation, and (8) other forms of surface disturbance on state or private lands that may result

in permanent facilities such as roads, well pads, mines, or quarries.

Certain components of these non-federal activities, if completed, could displace or modify the 

behavior of grizzly bears. Grizzly bear habitats could also be modified or degraded by the 

above-listed non-federal activities which are reasonably certain to occur within the Refuge 

planning area. Some of these activities could be situated near important grizzly bear habitats or 

linkages on Refuge-administered lands. 

Cumulative Effects Adjacent to the Action Area and Grizzly Bear Recovery Zone 

Cumulative effects of actions outside the action area and within the grizzly bear Recovery Zone 

are likely to affect resident grizzly bears moving through the action area whether their home 

range is within or adjacent to the action area. These actions include: 

• Livestock grazing (which would impact grizzly bears through management actions),

• Private land development,

• Firewood cutting,

• Road use/management/improvement.

• Timber harvest,

• Recreation activities that lead to human-bear conflicts,

• Vegetation management,

24 
312 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

• Wild and prescribed fire, and • Loss or decline of important food sources ( e.g., whitebark pine seeds due to fire

suppression),

The activities would cumulatively contribute to increased mortality risks reduce availability of 

secure habitat, and diminish habitat effectiveness for grizzly bears. However, the total 

cumulative impact of the above listed activities, as well as, other unidentified actions occurring 

within the grizzly bear recovery zone do not appear to be adversely affecting population 

recovery, as evidenced by the expanding grizzly bear population in the GYA (Eberhardt and 

Knight 1996; Schwartz et al. 2002; Pyare et al. 2004). 

CONCLUSION 

After reviewing the current status of the grizzly bear, the environmental baseline for the action 

area, the effects of the action and the cumulative effects, it is the Service's biological opinion 

that the effects of implementing the CCP on the Refuge on grizzly bears are not likely to 

jeopardize the continued existence of this species. No critical habitat has been designated for 

this species; therefore, none will be affected. Implementing regulations for section 7 (50 CFR 

402) define "jeopardize the continued existence of' as to "engage in an action that reasonably

would be expected, directly or indirectly, to reduce appreciably the likelihood of both the

survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or

distribution of that species." We base our conclusion that the proposed action is not likely to

jeopardize the continued existence of grizzly bears primarily on the information presented in the

Intra-Service Section 7 Biological Evaluation Form prepared for the proposed action and

information in our files. We have summarized our rationale for this non-jeopardy conclusion

below.

1. An accurate estimate of grizzly bear population size in the Greater Yellowstone

Ecosystem has always been elusive given the bear's normally isolated existence in remote

inaccessible terrain. However, this species has increased in numbers since the year of its

listing. The range of the grizzly bear in the Greater Yellowstone Ecosystem has also

increased dramatically since the 1970s (IGBST 2012, Pyare et al. 2004, Schwartz et al. 

2002, USFWS 2005).

2. Although the existing level of hunting on the Refuge has not previously resulted in

grizzly-human conflict, we anticipate some level of conflict will occur as a result of

hunting related activities, because the best available information suggests the GYE

grizzly bear population is stable to increasing and is expanding its range. During the 15-

year life of the CCP, we expect the number of bears on the Refuge will increase. The

number of conflicts resulting in relocation or removal of grizzly bears will be low,

however, due to the open nature of the terrain on the Refuge and high levels of human

activity and visibility, as well as implementation of hunter/grizzly bear education, use of

bear spray and proper food/game meat storage techniques. With the possibility of

increased grizzly bear numbers in this area there is a possibility of grizzly bears

becoming habituated to human residences on the Refuge due to human food/waste

however, management relocations and mortality due to management removals within the

25 
Appendix G—Intra-Service Section 7 Consultation 313 

area, is unlikely with the implementation of food/waste storage practices within the 

Refuge, it is our opinion that the proposed action will not appreciably reduce the 

likelihood of both the survival and recovery of grizzly bears. 

INCIDENTAL TAKE STATEMENT 

Section 4( d) and 9 of the ESA, as amended, prohibit the take of listed species of fish or wildlife 

without a special exemption. The ESA defines take as to harass, harm, pursue, hunt, shoot, 

wound, kill, trap, capture or collect, or attempt to engage in any such conduct. A special rule 

under the ESA is in effect for grizzly bears in the 48 conterminous states of the United States 

(50 CFR 17.40(b), Special Rule). Under the terms of the Special Rule, taking is prohibited 

except as provided in paragraphs 17.4(b)(l)(i)(B)through (F). The exceptions to the take 

prohibition include the defense of human life and the removal of nuisance bears when the taking 

conforms to the requirements specified in the regulations. Although there are exceptions to the 

take prohibition for grizzly bears, the exceptions do not address all sources of incidental take that 

may result from the proposed federal action. For example, harm is further defined by regulation 

(50 CFR 17.3) to include significant habitat modification or degradation that results in death or 

injury to wildlife by significantly impairing behavioral patterns such as breeding, feeding, or 

sheltering. Harass is defined as an intentional or negligent act or omission which creates the 

likelihood of injury to wildlife by annoying it to such an extent as to significantly disrupt normal 

behavior patterns which include, but are not limited to, breeding, feeding or sheltering. 

Incidental take is any take of listed animal species that results from, but is not the purpose of, 

carrying out an otherwise lawful activity conducted by the federal agency or the applicant. 

Under the terms of section 7(b )( 4) and section 7( o )(2), taking that is incidental to and not 

intended as part of the agency action is not considered a prohibited taking provided that such 

taking is in compliance with the terms and conditions of this Incidental Take Statement. 

The measures described below are non-discretionary, and must be undertaken by the Refuge so 

that they become binding conditions of any grant or permit issued, as appropriate, for the 

exemption in section 7(o)(2) to apply. The Refuge has a continuing duty to regulate the activity 

covered by this Incidental Take Statement. If the Refuge (1) fails to assume and implement the 

terms and conditions or (2) fails to require the applicant to adhere to the terms and conditions of 

the Incidental Take Statement through enforceable terms that are added to the permit or grant 

document, the protective coverage of section 7( o )(2) may lapse. In order to monitor the impact 

of the incidental take, the Refuge must report the progress of the action and its impact on the 

species to the Service as specified in the Incidental Take Statement [50 CFR 402.14(i)(3)]. 

Amount or Extent of Take Anticipated 

The Service anticipates that grizzly bears could be taken as a result of future management 

activities implemented under the Refuge CCP. The incidental take is expected to be in the form 

of harm that is tied to hunting activities. In 2013, the Refuge was included in the re-initiation of 

formal consultation on Grand Teton National Park and National Elk Refuge Bison and Elk 

Management Plan/EIS (Plan) (WY13F0094). Under that consultation the Service anticipated 

two grizzly bears on the Refuge may be incidentally taken directly or indirectly as a result of the 

Plan during the 9-year period of the biological opinion. The incidental take of two grizzly bears 

26 
314 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

exempted in the biological opinion for the Plan are not include in the biological opinion for the 

CCP, because that take is already exempted. 

At the broad scale of this consultation, the Service is unable to anticipate all other possible 

circumstances that may involve the take of grizzly bears due to the actions implemented under 

the CCP, because the CCP is a planning level document and does not authorize specific projects. 

Therefore, the Service conservatively anticipates that some level of incidental take, both lethal 

and non-lethal, may occur due to specific actions implemented under the CCP. However, the 

amount or extent of take is unquantifiable at this time. Any actions implemented under the CCP 

that may adversely affect the grizzly bear will require separate formal section 7 consultation at 

the project level. Therefore, incidental take will be assessed, and coverage under the terms of 

section 7(b)(4) and section 7(o)(2) of the ESA will be granted as appropriate, at the project level 

during formal consultation. 

EITect of the take 

In this biological opinion, the Service has determined that this level of anticipated take is not 

likely to result in jeopardy to the grizzly bear. This is based in part, on the fact that measured 

population parameters in past years have met established recovery plan levels, while bear 

mortality has generally been below the threshold levels established in the Recovery Plan. 

However, the Service anticipates that the direct and indirect effects of implementing hunting 

activities under the CCP along with implementation of the Interagency Grizzly Bear Guidelines 

and Refuge-committed conservation measures could result in incidental take. Take in the form 

of harm may occur as a result of lethal management actions to address nuisance bears associated 

with hunting conflicts, hunters shooting bears out of self-defense, or harm resulting from nonlethal relocation of grizzly bears from occupied habitats as a result of grizzly bear/human 

food/waste conflicts. Despite the amount of potential prey in the elk population using the 

Refuge, there have only been two confirmed grizzly bear observations since 1994; suggesting 

that the Refuge does not contain all of the necessary habitat requirements for grizzly bears to 

maintain a presence. Therefore, although this could change in the future with continued 

expansion of the grizzly bear, the effects to the GYA populations should be minimal compared to 

areas with high grizzly bear use. No critical habitat for the grizzly bear has been designated; 

therefore none will be affected. 

Reasonable and prudent measures 

Reasonable and prudent measures (RPMs) are nondiscretionary measures that are necessary and 

appropriate to minimize the impact of incidental take. Because the incidental take statement 

does not exempt any incidental take, no RMPs are necessary and appropriate to minimize the 

impacts of the incidental take. 

Instead, the Refuge will consult individually over the impacts of site-specific projects authorized 

by the CCP that "may affect" grizzly bears. These future consultations will provide a means for 

site-specific analysis and documentation of levels of any potential incidental take of grizzly 

bears. At the individual project level, the Refuge has committed to implement measures to 

minimize grizzly bear/human conflicts, and grizzly bear habituation to human activities in the 

27 
Appendix G—Intra-Service Section 7 Consultation 315 

CCP planning area. For site-specific projects that are likely to adversely affect grizzly bears, the 

Refuge will monitor impacts and prepare reports describing the progress of each such sitespecific project, including implementation of the associated project-specific reasonable and 

prudent measures, and impacts to the grizzly bear (50 C.F.R.§ 402.14[i][3]). 

TERMS AND CONDITIONS 

Because there are no reasonable and prudent measures, there are no terms and conditions. 

CONSERVATION RECOMMENDATIONS 

Sections 7(a)(l) of the ESA directs federal agencies to use their authorities to further the 

purposes of the ESA by carrying out conservation programs for the benefit of endangered and 

threatened species. Conservation recommendations are discretionary agency activities to 

minimize or avoid adverse effects of a proposed action on listed species or critical habitat, to 

help implement recovery plans or to develop information. The recommendations provided here 

relate only to the proposed action and do not necessarily represent complete fulfillment of the 

agency's section 7(a)(l) responsibility for the species: 

CRI. The Service recommends that the Refuge follow all management actions that minimize 

impacts to grizzly bears as identified in the CCP and the Bison and Elk Management Plan/EIS. 

CR2. The Service recommends that the Refuge include a clause on all use authorizations that 

allows for temporary cessation of activities, temporary cancellation, or as a last resort permanent 

cancellation if needed to resolve a grizzly-human conflict situation. 

CR3. The Service recommends the Refuge continue ongoing educational measures related to 

limiting the risk of hunter-grizzly conflict and hunting-caused grizzly bear mortality, as well as 

bear safety training for Refuge staff and volunteers. Refuge staff and volunteers will be required 

to carry bear spray in the field and adapt and modify these measures as changing circumstances 

and information warrant. 

CR4. The Service recommends that food/waste storage guidelines are implemented on Refuge 

facilities and with any Refuge permitted activities such as hunting. 

CR5. The Service recommends that CCP actions encouraging the use of non-lead rifle 

ammunition is implemented to reduce lead exposure by grizzly bears scavenging on elk and 

bison gut piles. 

CR6. In the event that a grizzly bear is killed within the action area as a result of hunting-related 

conflict, the Refuge will notify the Service's Wyoming Field Office (307-772-2374) and the 

Service's Law Enforcement Office (307-261-6365) within 24 hours. 

CR 7. In order for the Service to be kept informed of actions minimizing or avoiding adverse 

effects or benefiting listed species or their habitats, the Service requests notification of the 

implementation of any conservation recommendations. 

28 
316 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

CR8. The Refuge should parlicipale in ongoing interagency efforts to identify map 

and manage linkage habitats essential to grizzly bear movement. Please contact the Service's 

grizzly bear recovery coordinator for information. 

CRlO. If grizzly bears are sighted on the Refuge during the implementation period of the project 

all hunting acli v ilies uu the: Rc:fuge should be reassessed in order to determine the potential risk 

of hunter-grizzly conflict. 

CRl 1. The Service recommends the Refuge not allowing artificial elk calls, which can draw 

bears to hunters. 

CR12. The Service recommends the Refuge providing a secure camping area for participants 

where carcasses can be safely stored out ofreach of bears. 

REINITIATION NOTICE 

This concludes consultation on the action outlined in your July 13, 2015, request for consultation 

on the effects of the CCP on grizzly bears. As provided in 50 CFR 402.16, reinitiation of formal 

consultation is required where discretionary Federal agency involvement or control over the 

action has been maintained (or is authorized by law) and if: (1) the amount or extent of 

incidental is exceeded; (2) new information reveals effects of the agency action that may affect 

listed species or critical habitat in a manner or to an extent not considered in this opinion; (3) the 

agency action is subsequently modified in a manner that causes an effect to the listed species or 

critical habitat that was not considered in this opinion; or (4) a new species is listed or critical 

habitat designated that may be affected by the action. In instances where the amount or extent of 

incidental take is exceeded, any operations causing such take must cease pending reinitiation. 

29 
Appendix G—Intra-Service Section 7 Consultation 317 

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Wild Rockies special report no. 10. Missoula, Montana. 28pp. 

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Bjornlie, D. and M. Haroldson. 2001 . Grizzly bear use of insect aggregation sites documented 

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Eds. Yellowstone grizzly bear investigations: Annual report of the Interagency Grizzly Bear 

Study Team, 2000. U.S. Geological Survey, Bozeman, Montana. 

Craighead, F.C. Jr. 1976. Grizzly bear ranges and movement as determined by radio-tracking. 

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biology and management. IUCN Publ. New Series 23. 

Craighead, F.C., Jr., and J.J. Craighead. 1972b. Grizzly bear prehibernation and denning 

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Egbert, A.L. and A.W. Stokes. 1976. The social behavior of brown bears on an Alaskan salmon 

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318 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

Haroldson, M. 2013. Occupancy of bear management units by females with young. Page 19 in 

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Harol<lsun, M. Temant, K. A. Gunther, and C. C. Schwartz. 2002. Grizzly bear denning 

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Herrero, S. 1978. A comparison of some features of the evolution ecology, and behavior of black 

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Homocker, M.G. 1962. Population characteristics and social and reproductive behavior of the 

grizzly bear in Yellowstone National Park. M.S. Thesis. University of Montana, Missoula. 94 pp. 

Interagency Conservation Strategy Team (ICST). 2007. Final conservation strategy for the 

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2015. http://www.fws.gov/mountainprairie/species/mammals/grizzly/Final Conservation 

Strategy.pdf 

Interagency Grizzly Bear Committee. 1986. Interagency Grizzly Bear Guidelines. Interagency 

Grizzly Bear Committee. 100 pp. 

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population size and sustainable mortality limits for grizzly bears in the Greater Yellowstone 

Ecosystem. Interagency Grizzly Bear Study Team, U.S. Geological Survey, Northern Rocky 

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Interagency Grizzly Bear Study Team. 2013. Response of Yellowstone grizzly bears to changes 

in food resources: a synthesis. Report to the Interagency Grizzly Bear Committee and 

Yellowstone Ecosystem Subcommittee. Interagency Grizzly Bear Study Team, U.S. Geological 

Survey, Northern Rocky Mountain Science Center, Bozeman, Montana, USA. 

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322 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

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35 
Appendix G—Intra-Service Section 7 Consultation 323 

United States Department of the Interior 

FISH AND WILDLIFE SERVICE 

Ecological Services 

5353 Yellowstone Road, Suite 308A 

Cheyenne, Wyoming 82009 

SEP O 2 2015 

In Reply Refer To: 

06E 13000-2015-F-O 132a 

Memorandum 

To: 

From: 

Subject: 

Refuge Manager, U.S. Fish and Wildlife Service, National Elk Refuge, 

Jackson, Wyoming 

Field Supervisor, U.S. 1 life Service, 

Cheyenne, Wyoming 

Corrections to the Biological Opinion for the National Elk Refuge Draft 

Comprehensive Conservation Plan and Environmental Assessment 

On August 26, 2015, Lisa Solberg Schwab ofmy staff spoke with you regarding inconsistencies 

between current management on the National Elk Refuge (Refuge) and information in the 

biological opinion (BO) dated August 25, 2015. This memorandum transmits corrections to our 

BO on the National Elk Refuge Draft Comprehensive Conservation Plan (CCP) and 

Environmental Assessment. Corrections include minor technical changes and do not alter our 

conclusion that the effects of implementing the CCP on the Refuge are not likely to jeopardize 

the continued existence of the grizzly bear. 

1. Pages 5 and 21 of the BO states, "Initiate habitat restoration projects to improve native and

cultivated forage and achieve desired conditions and goals. Continue to flood irrigate 800 to 

2,000 acres per year (324-809 ha/yr) of cultivated land, and convert up to 1,200 acres (445 ha) 

from flood to sprinkler irrigation."

In July 2009 the Refuge wrote the Final Plan and Environmental Assessment (EA) for the 

Irrigation Expansion Project. This EA expanded the total acreage of irrigated land on the Refuge 

by 3,435 acres. The 1,200 acres of irrigated land in the BO included only those management 

units identified in the 2007 Bison and Elk Plan/EIS and not the additional acres from the 

Irrigation Expansion Project; therefore, the BO should state the total area covered by the 

sprinkler system at the National Elk Refuge as 5,035 acres. 
324 Comprehensive Conservation Plan—National Elk Refuge, Wyoming

2. Page 22 of the BO states, "hunters will be carrying bear spray." While it is true that "Refuge

staff and volunteers will be required to carry bear spray in the field" (p. 7), the Refuge will not

require hunters to use bear spray even though the Refuge will educate and encourage hunters to

use this approach. This approach was articulated under the proposed action (Alternative Din the

CCP) in that the refuge will "Develop regulations for storage of bear attractants and beardeterrent practices and encourage carry of bear spray" (Service 2014, p.76). This is confirmed in

the BO, which states the Refuge will "encourage carry of bear spray" (p. 6) and distribute

"materials promoting the use of bear sprays" (p. 23). Therefore, based on the preferred

alternative in the CCP, the BO should state, "The Refuge will educate, encourage and even at

times provide free bear spray for hunter use; however, hunters are not required to carry bear

spray."

We cite the use of bear spray in the rationale for our jeopardy analysis, but the use of bear spray 

is included within a long list of other physical conditions and management actions (p. 25). 

Cumulatively, these conditions and actions support the conclusion that the number of conflicts 

resulting in the relocation or removal of grizzly bears is low. The use of bear spray is only one 

small part of the list, and bear spray will be used by Refuge staff and volunteers. We expect 

some hunters will also carry bear spray. The fact that not every hunter will carry bear spray does 

not alter our conclusion. 

This concludes our updates to the BO for the National Elk Refuge Draft Comprehensive 

Conservation Plan and Environmental Assessment. If you have any questions regarding this 

consultation, please contact Lisa Solberg Schwab of my office at the letterhead address or phone 

(307) 367-5340.

cc: USFWS, Wildlife Biologist, National Elk.Refuge, Jackson, Wyoming 

(E. Cole) (eric_cole@fws.gov) 

WGFD, Statewide Non-Game Bird and Mammal Program Supervisor, Lander, WY 

(Z. Walker) (zack.walker@wyo.gov) 

WGFD, Statewide Habitat Protection Coordinator, Cheyenne, WY (M. Flanderka) 

(mary.flanderka@wyo.gov) 

WGFD, Habitat Protection Secretary, Cheyenne, WY (N.Stange)(nancy.stange@wyo.gov) 

WGFD, Statewide Large Carnivore Section Supervisor, Lander, WY (D. Thompson) 

(daniel.thompson@wyo.gov) 

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The mission of the National Wildlife 

Refuge System is to administer a 

national network of lands and waters 

for the conservation, management, 

and, where appropriate, restoration of 

the fish, wildlife, and plant resources 

and their habitats within the United 

States for the benefit of present and 

future generations of Americans.

The mission of the U.S. Fish and 

Wildlife Service is working with others 

to conserve, protect, and enhance fish, 

wildlife, plants, and their habitats for 

the continuing benefit of the American 

people.

The mission of the National Wildlife 

Refuge System is to administer a 

national network of lands and waters 

for the conservation, management, 

and, where appropriate, restoration of 

the fish, wildlife, and plant resources 

and their habitats within the United 

States for the benefit of present and 

future generations of Americans.

The mission of the U.S. Fish and 

Wildlife Service is working with others 

to conserve, protect, and enhance fish, 

wildlife, plants, and their habitats for 

the continuing benefit of the American 

people.

Cover photograph of the National Elk Refuge, Wyoming.

Ann Hough / FWS
National Elk Refuge

P.O. Box 510

Jackson, WY 83001

nationalelkrefuge@fws.gov

www.fws.gov/nationalelkrefuge

307 / 733 9212

April 2016