Environmental Assessment

Flint Hills Legacy Conservation Area 

Kansas

July 2010

Prepared by 

U.S. Fish and Wildlife Service

Flint Hills National Wildlife Refuge

530 West Maple Avenue

Hartford, Kansas 66854

620/392 5553

and

U.S. Fish and Wildlife Service

Mountain-Prairie Region

Division of Refuge Planning

Branch of Land Protection Planning

134 Union Boulevard, Suite 300

Denver, Colorado 80228

303/236 4345
In accordance with the National Environmental Policy Act and U.S. Fish and Wildlife Service policy, an 

environmental assessment and land protection plan have been prepared to analyze the effects of establishing 

the Flint Hills Legacy Conservation Area in eastern Kansas. This document is the final environmental 

assessment, revised after analyzing public comments. The land protection plan is a separate document.

■ The environmental assessment analyzes the environmental effects of establishing the Flint Hills Legacy 

Conservation Area. 

■ The land protection plan describes the priorities for purchasing up to 1,100,000 acres of easements 

within the proposed project boundary. 
Contents 

Abbreviations ............................................................................................................................................................. iii

1 Purpose of and Need for Action ..................................................................................

Proposed Action .......................................................................................................

Project Area .............................................................................................................

Purpose of and Need for Proposed Action ...........................................................

Decisions to be Made ...............................................................................................

.............................................

.............................................

.............................................

.............................................

.............................................

1

2

2

2

5

Issues Identified and Selected for Analysis .........................................................

Biological Issues .................................................................................................

Socioeconomic Issues .........................................................................................

.............................................

.............................................

.............................................

5

5

5

Issues Not Selected for Detailed Analysis .................................................................................................

National Wildlife Refuge System and Authorities ..........................................................................................

Related Actions and Activities ..........................................................................................................................

6

6

6

Habitat Protection and the Easement Acquisition Process .......................................................................... 7

2 Alternatives, Including the Proposed Action ...........................................................................................................

Alternative A (No Action)...................................................................................................................................

Alternative B (Proposed Action) ........................................................................................................................

Alternatives Considered but not Studied..........................................................................................................

9

9

9

10

Voluntary Landowner Zoning .......................................................................................

County Zoning .................................................................................................................

Fee-title Acquisition .......................................................................................................

Smaller Project Area ......................................................................................................

Larger Project Area .......................................................................................................

Expansion of Project ......................................................................................................

................................

................................

................................

................................

................................

................................

10

10

10

11

11

11

3 Affected Environment ............................................................................................................................................... 13

Biological Environment .......................................................................................................

Climate ..............................................................................................................................

................................

................................

13

13

Climate Change ...............................................................................................................

Adaptation, Mitigation, and Engagement ...................................................................

Geologic Resources .........................................................................................................

Habitat ..............................................................................................................................

................................

................................

................................

................................

13

14

14

14

Wildlife .............................................................................................................................................................. 17

Cultural Resources ............................................................................................................................................... 19

Socioeconomic Environment ............................................................................................................................... 20

Landownership ...............................................................................................................

Property Tax ...................................................................................................................

Public Use and Wildlife-dependent Recreational Activities ...................................

................................

................................

................................

20

20

20

4 Environmental Consequences ...................................................................................................................................

Effects on the Biological Environment ..............................................................................................................

Wildlife Habitat—Alternative A (No Action) .............................................................................................

Wildlife Habitat—Alternative B (Proposed Action) .................................................................................

Water and Soil Resources—Alternative A (No Action) ............................................................................

Water and Soil Resources—Alternative B (Proposed Action) ................................................................

Effects on the Socioeconomic Environment...................................................................................................... 

 21

21

21

23

24

25

 25

Landownership and Land Use—Alternative A (No Action).................................................................... 25
ii EA, Flint Hills Legacy Conservation Area, KS

Landownership and Land Use—Alternative B (Proposed Action) ........................................................ 25

Public Use—Alternative A (No Action) ...................................................................................................... 26

Public Use—Alternative B (Proposed Action) ........................................................................................... 26

Development—Alternative A (No Action) ................................................................................................. 26

Development—Alternative B (Proposed Action) ...................................................................................... 26

Value of Intact Ecosystems—Alternative A (No Action) ......................................................................... 27

Value of Intact Ecosystems—Alternative B (Proposed Action) ............................................................. 27

Unavoidable Adverse Impacts ............................................................................................................................ 27

Alternative A (No Action) ............................................................................................................................. 27

Alternative B (Proposed Action) .................................................................................................................. 27

Irreversible and Irretrievable Commitments of Resources........................................................................... 27

Alternative A (No Action) ............................................................................................................................. 27

Alternative B (Proposed Action) .................................................................................................................. 28

Short-term Use versus Long-term Productivity ............................................................................................. 29

Alternative A (No Action) ............................................................................................................................. 29

Alternative B (Proposed Action) .................................................................................................................. 29

Cumulative Impacts .............................................................................................................................................. 29

Past Actions ..................................................................................................................................................... 29

Present Actions ............................................................................................................................................... 29

Reasonably Foreseeable Future Actions .................................................................................................... 29

Development—Alternative A (No Action) ....................................................................................................... 30

Development—Alternative B (Proposed Action) ............................................................................................ 30

Conservation Efforts—Alternative A (No Action).......................................................................................... 30

Conservation Efforts—Alternative B (Proposed Action) .............................................................................. 30

5 Coordination and Environmental Review .................................................................................................................. 31

Agency Coordination ........................................................................................................................................... 31

Contaminants and Hazardous Materials ........................................................................................................... 31

National Environmental Policy Act ................................................................................................................... 31

Strategic Habitat Conservation and Landscape Conservation Cooperatives ............................................ 31

Strategic Habitat Conservation .................................................................................................................... 31

Landscape Conservation Cooperatives ....................................................................................................... 33

Distribution and Availability .............................................................................................................................. 34

Appendixes

A List of Plants and Animals............................................................................................................................. 35

B List of Preparers and Reviewers ................................................................................................................ 79

C Finding of No Significant Impact ................................................................................................................ 81

D Compliance Certificate .................................................................................................................................. 87

E Level 1 Report ............................................................................................................................................... 91

F Section 7 Biological Evaluation ................................................................................................................... 93

G Comments and Responses ........................................................................................................................... 101

Bibliography .............................................................................................................................................................. 143

Figures

1 Historical tallgrass prairie distribution ......................................................................................................... 1

2 Project map for the Flint Hills Legacy Conservation Area ...................................................................... 3

3 Land cover and habitat types in the Flint Hills Legacy Conservation Area .......................................... 15

4 Relative native and restored benefits of ecosystem goods and services ................................................. 28
Abbreviations

 

EA environmental assessment

FHLCA Flint Hills Legacy Conservation Area

GIS geographic information system

HAPET Habitat and Population Evaluation Team

KLT Kansas Land Trust

KDWP Kansas Department of Wildlife and Parks

LCC landscape conservation cooperative

LPP land protection plan

LWCF Land and Water Conservation Fund

NEPA National Environmental Policy Act

NLCD National Land Cover Database

NRCS Natural Resources Conservation Service

NREL National Renewable Energy Lab

NWR National Wildlife Refuge

NWRS National Wildlife Refuge System

PFW Partners for Fish and Wildlife program

RTK The Ranchland Trust of Kansas

Service U.S. Fish and Wildlife Service

SHC strategic habitat conservation

TLA Tallgrass Legacy Alliance

TNC The Nature Conservancy

USDA U.S. Department of Agriculture

USFWS U.S. Fish and Wildlife Service

1 Purpose of and Need for Action

“Conservation is a state of harmony between men and land.” 

—Aldo Leopold

Figure 1. Historical tallgrass prairie distribution.

The lands east of the Rocky Mountains were once 

a vast sea of grass extending as far east as the 

deciduous forests of Kentucky and Ohio. The eastern 

third of this vast grassland is called the tallgrass 

prairie, often called the “true” prairie. Tallgrass 

prairie once covered more than 170 million acres 

from Texas to Canada (Samson et al. 1999) (figure 

1). As America expanded westward during the 19th 

century, settlers found the rich soils associated 

with the tallgrass prairie ideal for growing crops 

and converted much of the original landscape for 

agriculture. 

Today, less than 4 percent of this once vast 

grassland region remains (Steinauer and Collins 

1996). Given that amount of loss, it is no wonder 

grassland birds are the fastest declining avian cadre 

in North America. Cultivation, agriculture, tree 

encroachment, and development activities have 

pushed grassland-dependent species into evershrinking areas of tallgrass prairie. Approximately 

three-fourths of the remaining tallgrass prairie lies 

within the Flint Hills ecoregion of eastern Kansas 

and northeastern Oklahoma, with about 6 million 

acres present in the Kansas portion. The outer 

edge of this region is presently suffering a rapid 

conversion to forest due in part to a declining fire 

culture within the agricultural communities of the 

region. The inner core of this region (approximately 

3.3 million acres) is relatively intact to date, offering 

potential for long-term social stability, and ecosystem 

function and value. 

The Flint Hills area is a treasured landscape of 

gently-sloping limestone and chert hills. Today, two 

hundred years after Zebulon Pike explored the Flint 

Hills, one can still witness the same unobstructed 

vistas that he described in his journal. The central 

core, running in a north-south configuration, has 

persisted as a relatively unfragmented expanse of 
2 EA, Flint Hills Legacy Conservation Area, KS

tallgrass prairie because of limestone outcrops that 

discouraged plowing, and because of a ranching 

culture that recognized the ecological importance 

of fire when living and working within a fire climax 

ecosystem. Since about 1860, the predominant use of 

the Flint Hills uplands has been cattle ranching.

The Flint Hills Legacy Conservation Area (FHLCA) 

is part of a landscape-scale, strategic habitat 

conservation effort to protect a unique, highly 

diverse, and largely unfragmented area of tallgrass 

prairie. Located in eastern Kansas, the region 

provides important habitat for a diverse array of 

native wildlife species, including the threatened 

Topeka shiner, greater prairie-chicken, Henslow’s 

sparrow, short-eared owl, Bell’s vireo, American 

golden-plover, grasshopper sparrow, dickcissel, 

eastern meadowlark, upland sandpiper, buff-breasted 

sandpiper, scissor-tailed flycatcher, loggerhead 

shrike, Smith’s longspur, Harris’ sparrow, northern 

harrier, Swainson’s hawk, and other grasslanddependent species. Rich with history, the Flint Hills 

ranching culture has maintained grazing and fire as 

necessary tools for tallgrass ecosystem health. 

While ranching has helped maintain the last intact 

portion of tallgrass prairie and much of the region’s 

biodiversity, there are concerns that incompatible 

industrial and residential development could 

threaten this unique landscape. Left unabated, such 

development will likely diminish this important 

agricultural and biological resource for future 

generations. 

PROPOSED ACTION

The U.S. Fish and Wildlife Service is proposing 

to establish a voluntary conservation easement 

program in eastern Kansas called the Flint Hills 

Legacy Conservation Area (figure 2). The project 

boundary encompasses roughly 3.3 million acres, 

within which the Service would strategically acquire 

conservation easements on up to 1.1 million acres of 

private land. 

The Service would seek all acquisition in the form 

of perpetual conservation easements from willing 

sellers. The project would not involve fee-title 

acquisitions. The easement program would rely on 

voluntary participation from landowners. Grazing 

and prescribed fires would continue on the land 

included in the easement contract. Landowners 

could continue to pursue development on properties 

without Service conservation easements. All 

land within an easement would remain in private 

ownership and, therefore, property tax and grassland 

management activities such as invasive plant and 

tree control, grazing and prescribed fires would 

remain the responsibility of the landowner. Public 

access to the land would also remain under the 

control of the landowner.

Easement restrictions may include but are not 

limited to preventing development (residential, 

commercial and industrial), altering the natural 

topography, converting native grassland to cropland, 

draining wetlands, and introducing plants that are 

not native to the Flint Hills.

The proposed easements would help maintain a 

relatively large, unfragmented block of habitat that 

would compliment efforts by other land trusts and 

entities, such as the Ranchland Trust of Kansas, 

Kansas Land Trust, The Nature Conservancy, 

National Park Service, Kansas Department of 

Wildlife and Parks, U.S. Department of Agriculture, 

and the U.S. Army Corps of Engineers. 

PROJECT AREA

The FHLCA project area consists of 3.3 million acres 

within the Flint Hills ecoregion of Kansas (Omernick 

1987). A narrow band running north-south, it is 

located within 21 counties in eastern Kansas (see 

figure 2), and stretches from the northern to the 

southern border of the state. Some tallgrass prairie 

extends south into Oklahoma, where it is referred to 

as the Osage Hills. As elsewhere in Kansas where 

less than 2 percent of the land area is federally 

owned, private ownership dominates the project 

area. The main habitat type found within the project 

area is eastern tallgrass prairie, represented by over 

ninety native grasses and 500 broadleaf species. 

The Flint Hills ecoregion contains the largest 

concentration of freshwater springs in Kansas 

(Kansas Geologic Survey 2008) and represents the 

ultimate source of the Caney, Cottonwood, Elk, Fall, 

Marais des Cygnes (Osage), Neosho, Verdigris, and 

Walnut rivers. 

The total area within the proposed project boundary 

represents over 3.3 million acres, roughly three times 

the long-term project goal. This physiographic region 

represents the world’s last intact tallgrass prairie 

landscape of sufficient size to offer full ecological 

function. The physical shape and juxtaposition of the 

up to 1.1 million acres in the priority area targeted 

for easements is an important component of the 

project’s long-term success. This remaining, high 

quality, ecologically functioning stretch of tallgrass 

prairie runs along a north-south axis and is as narrow 

as 20 miles wide (see figure 2). This narrowness is not 

a biological choice; it is by default that the project 

boundary takes this shape, constrained on the east 

and west by tillage agriculture, woody vegetation, 

and development.

PURPOSE OF AND NEED 

FOR PROPOSED ACTION

The purpose this project is to provide the landscapescale, strategic habitat conservation necessary to 

maintain ecological community function for eastern 
Chapter 1 — Introduction and Project Description 3

Figure 2. Project map for the Flint Hills Legacy Conservation Area.
4 EA, Flint Hills Legacy Conservation Area, KS

tallgrass prairie, including grassland-dependent 

wildlife. This is especially important for grasslands, 

because they do not have the localized diversity of 

geological and elevational gradients that most other 

ecosystems contain. (Kelly Kindscher, plant ecologist, 

University of Kansas; personal communication.) This 

conservation project is needed to help protect the 

Flint Hills prairie ecosystem from being drastically 

changed by widespread, unplanned residential 

or commercial development. The conversion of 

ranches and rural areas to residential, commercial, 

and industrial developments, along with forest 

encroachment, threatens the open expanses of 

native rangeland that many grassland birds and 

other prairie-associated wildlife are dependent upon 

(Huntsinger and Hopkinson 1996).

Based on known conservation principles of 

landscape ecology, the narrow north-south corridor 

of remaining tallgrass prairie is exceptionally 

vulnerable to ecological degradation associated with 

increased fragmentation. In essence, if this, the 

world’s largest remaining tract of tallgrass prairie 

becomes any narrower; its ecological functionality 

will be diminished, reducing the possibility of 

sustainable populations of fish and wildlife being 

maintained. The resiliency, or the capacity of the 

system to absorb changes and disturbances while 

maintaining its basic structure and function, will be 

lost.

Currently, the Flint Hills area provides essential 

breeding, wintering, and migrational habitat for 

migratory birds such as the greater prairie-chicken, 

Henslow’s sparrow, short-eared owl, Bell’s vireo, 

American golden-plover, grasshopper sparrow, 

dickcissel, eastern meadowlark, upland sandpiper, 

buff-breasted sandpiper, scissor-tailed flycatcher, 

loggerhead shrike, Smith’s longspur, Harris’ sparrow, 

Swainson’s hawk and northern harrier. Numerous 

other species of birds, mammals, reptiles and 

amphibians are known to use the habitat of the Flint 

Hills (see appendix A).

The Flint Hills represents North America’s only 

remaining landscape-scale expression of tallgrass 

prairie. Virtually all of what remains is threatened by 

some form of development—energy including wind 

and coaled methane development, residential, and 

general urban expansion. All express direct impacts 

to the ecosystem, and share a common threat of 

reducing the ability to use prescribed fire in a region 

dependent on fire for its existence—it is therefore 

prudent to conserve the largest, highest quality, 

feasible representation of this ecosystem. 

Due to these threats, the Partners for Fish and 

Wildlife (PFW) program recognized the Flint Hills 

as a focus area in their strategic habitat plan. The 

Service’s PFW program has been working with 

many landowners to help restore and enhance fish 

and wildlife habitat on private land. PFW activities 

include habitat restoration and improvement 

(invasive plant control and grazing, and prescribed 

fire modifications). However, without long-term 

landscape-scale protection, the results of current 

conservation efforts through this program and by 

many other partners will not be sustainable. The 

FHLCA program is necessary to protect additional 

habitat that is not eligible or covered by current 

Service programs, and will greatly enhance and 

augment efforts by other agencies and organizations 

to restore and protect habitats in the Flint Hills 

prairie region.

The purposes of the Flint Hills Legacy Conservation 

Area are to: 

■ preserve landscape-scale ecological integrity of 

the Flint Hills tallgrass prairie by maintaining, 

and enhancing the historical native plant, 

migratory bird, and other wildlife species 

at a landscape-scale with the support of the 

associated ranching culture;

■ support the recovery and protection of 

threatened and endangered species and reduce 

the likelihood of future listings under the 

Endangered Species Act;

■ protect the integrity of tallgrass prairieland 

associated prairie waters by preventing further 

habitat fragmentation; 

■ provide a buffer against climate change, 

by providing resiliency for the tallgrass 

prairie ecosystem through landscape-scale 

conservation;

■ protect an intact north-south migration corridor 

for grassland-dependent wildlife;

■ use the built-in resiliency to climate variability 

of native tallgrass prairie to ensure the 

continuation of wildlife habitat in the face of the 

uncertain effect of climate change.

Henslow’s sparrow.

Dave Rintoul/USFWS
Chapter 1 — Purpose of and Need For Action 5

DECISIONS TO BE MADE

The Service’s planning team (see appendix B) 

will complete an analysis of the environment and 

management alternatives. Based on the analysis, 

documented in this environmental assessment, the 

Service’s director of region 6, with the concurrence 

of the director of the U.S. Fish and Wildlife Service, 

will make three decisions:

■ Determine whether the Service should 

establish the Flint Hills Legacy Conservation 

Area.

■ If yes, select an approved, conservationeasement project boundary that best fulfills the 

habitat protection purposes.

■ If yes, determine whether the selected 

alternative would have a significant impact on 

the quality of the human environment. The 

National Environmental Policy Act of 1969 

requires this decision. If the quality of the 

human environment would not be significantly 

affected, a finding of no significant impact will 

be signed and made available to the public. 

If the alternative would have a significant 

impact, completion of an environmental impact 

statement would be required to address those 

impacts.

ISSUES IDENTIFIED AND 

SELECTED FOR ANALYSIS

Open houses were held in Alma, Cottonwood Falls, 

and Wichita Kansas in November and December 

2009. Public comments were taken to identify 

issues to be analyzed for the proposed project. 

Approximately 148 landowners, citizens, and 

elected representatives attended the meetings and 

most expressed positive support for the project. 

Additionally, ninety letters providing comments and 

identifying issues and concerns were also submitted. 

In addition, the Service’s field staff contacted local 

government officials, other public agencies, and 

conservation groups which have expressed an 

interest in and a desire to provide a sustainable 

future for the Flint Hills tallgrass region. 

Approximately 400 factsheet flyers were mailed out, 

and project information was also made available on 

the refuge and regional planning websites.

Many of the comments received addressed the 

need for a balance between natural and cultural 

systems. There are two main categories of commonly 

expressed issues and concerns.

Biological Issues 

■ Effects of wind energy development, oil and gas 

exploration and development, and residential 

development.

■ Concern that only a small percentage of 

tallgrass prairie remains.

■ Concern about the conservation of the 

remaining tallgrass prairie in Oklahoma.

■ Concern about short-term activities (including 

annual prescribed fires and early, intensive 

grazing) having long-term impacts to the 

tallgrass prairie.

■ Effects of tree encroachment from a lack of fire 

use due to absentee landowners, different land 

management priorities by some landowners, 

and development.

■ Possible reintroduction of species historically 

occurring in the region.

■ Possible effects to the air and water quality of 

the area with increasing development.

Socioeconomic Issues

■ Effect of wind energy development, and oil and 

gas exploration and development.

■ Possible tax implications of conservation 

easements.

■ Need to preserve the working ranches, and 

culture of the region.

■ Need to preserve history (natural, Native 

American and ranching heritage).

■ Possible long-term implications of easements on 

land management.

■ Potential impacts to the aesthetics, scenic 

vistas, and natural beauty of the area resulting 

from development.

■ Potential for the development of agri-tourism 

as a source of income.

Bluestem grass in tallgrass prairie.

USFWS
6 EA, Flint Hills Legacy Conservation Area, KS

■ Changing, aging population in rural areas.

■ Need for increased understanding and 

appreciation for the tallgrass prairie and area.

Issues Not Selected for Detailed Analysis

Historically, there has been concern about the 

amount of tax generated to the counties when land 

protection programs take place. Since the proposed 

project is a conservation easement program, the land 

enrolled in the program does not change hands and, 

therefore, the property taxes paid by the landowner 

to the county are not affected. Kansas property taxes 

are based on agricultural value. Since easements will 

not affect the agricultural value of the property, no 

changes to the tax base are anticipated.

Development of rural landscapes often leads to 

increased demand for services and higher costs to 

rural counties. There would generally be an offset 

of any perceived reduction in the tax base since the 

county would not incur the expense of providing 

services to rural developments. 

NATIONAL WILDLIFE REFUGE SYSTEM 

AND AUTHORITIES

The mission of the National Wildlife Refuge System 

is to preserve a national network of lands and waters 

for the conservation, management and, where 

appropriate, restoration of fish, wildlife, and plant 

resources and their habitats within the United States 

for the benefit of present and future generations of 

Americans. The Flint Hills Legacy Conservation 

Area project would be administered as part of the 

Refuge System in accordance with the National 

Wildlife Refuge System Administration Act of 1966 

and other relevant legislation, executive orders, 

regulations, and policies. 

Conservation of additional wildlife habitat in 

the Flint Hills region would also continue to 

be consistent with the following policies and 

management plans:

■ Land and Water Conservation Fund Act (1965)

■ Migratory Bird Treaty Act (1918)

■ Endangered Species Act (1973)

■ Bald Eagle Protection Act (1940) 

■ Migratory Non-game Birds of Management 

Concern in the U.S. (2002)

■ U.S. Fish and Wildlife Act (1956)

■ North American Waterfowl Management Plan 

(1994)

RELATED ACTIONS AND ACTIVITIES

The Service is working with other public and 

private entities to maintain wildlife habitat 

within the project area. Many organizations in 

Kansas have recognized the ecological significance 

of the Flint Hills and the need to bring about 

conservation in concert with the region’s ranching 

heritage. Ranchers, biologists, federal agencies, 

and nongovernmental organizations all see a 

need to protect this remaining tallgrass prairie. 

Grassroots organizations such as the Tallgrass 

Legacy Alliance have been working for more than a 

decade to conserve grasslands in the Flint Hills. The 

Ranchland Trust of Kansas, Kansas Land Trust, U.S. 

Department of Agriculture, Kansas Department of 

Agriculture, and The Nature Conservancy have all 

also been active in preserving portions of the Flint 

Hills using conservation easements. Organizations 

or agencies that are currently holding conservation 

easements within the conservation boundary include 

The Nature Conservancy, the Grassland Reserve 

Program, Ranchland Trust of Kansas, and Kansas 

Land Trust. 

The Nature Conservancy (TNC) is one of many 

stakeholders who wish to see the ecology and 

culture of the Flint Hills continue. As part of The 

Nature Conservancy’s ongoing efforts to preserve 

this impressive prairie landscape, a communitybased conservation program called the Flint Hills 

Initiative was launched in 2001. The Conservancy’s 

conservation goal for the Flint Hills is to maintain 

the unfragmented nature of this last expanse of 

tallgrass prairie and to improve the quality of sitespecific habitats for target species and natural 

communities. The Nature Conservancy currently 

holds 31,436 acres of conservation easements within 

the Service’s proposed project area.

The Grassland Reserve Program (GRP) is a voluntary 

conservation program administered through the U.S. 

Department of Agriculture that emphasizes support 

for working grazing operations, enhancement of plant 

and animal biodiversity, and protection of grassland 

under threat of conversion to other uses. Participants 

voluntarily limit future development and cropping 

uses of the land while retaining the right to conduct 

common grazing practices and operations related 

to the production of forage and seeding, subject to 

certain restrictions during nesting seasons of bird 

species that are in significant decline or are protected 

under federal or state law. A grazing management 

plan is required for participants. The easement 

acreage under the Grassland Reserve Program 

within the Service project area is currently 17,357 

acres.

Ranchland Trust of Kansas (RTK), which is an affiliate of 

the Kansas Livestock Association, was organized as 

an agricultural-based land trust to hold conservation 

easements in Kansas. Ranchland Trust of Kansas’s 

mission is to preserve Kansas’ ranching heritage 

and open spaces for future generations through the 

conservation of working landscapes. Ranchland Trust 

of Kansas currently has a 655-acre conservation 

easement in the project area.
Chapter 1 — Purpose of and Need For Action 7

Kansas Land Trust (KLT) is dedicated to conserving 

natural ecosystems, farm and ranch lands, and scenic 

open spaces; and preserving outdoor recreational 

opportunities and historical uses of land. Founded 

in 1990, the KLT advocated in its first years for 

the passage of conservation easement enabling 

legislation by the Kansas Legislature, which 

occurred in 1993. The Kansas Land Trust accepted its 

first easement in 1994, and has completed thirty-six 

easements, 3,311 acres of which are in the Service’s 

proposed project area. 

Tallgrass Legacy Alliance (TLA) is a not-for-profit 

grassroots organization dedicated to preserving 

the ecological, cultural and economic integrity of 

the tallgrass prairie. The Tallgrass Legacy Alliance 

is a diverse group with ecological and agricultural 

interests that has been active on a landscape 

scale providing information on issues of concern 

in regards to the Flint Hills region. The Tallgrass 

Legacy Alliance has also been providing assistance 

with innovative grazing systems, prescribed fire, 

and invasive species control (particularly sericea 

lespedeza) through the use of grants and cost-shares 

with landowners throughout the Flint Hills.

Private landowners and ranchers have been 

instrumental in working with the various 

organizations and agencies to implement 

conservation projects. More than 98 percent of the 

project area, including much of the critical habitat for 

wildlife, is in private landownership. 

The Kansas Department of Wildlife and Parks (KDWP) has 

been a strong partner in the Flint Hills by supporting 

effective grassland management through landowner 

technical assistance, Farm Bill implementation, and 

educational programs. 

Partners for Fish and Wildlife (PFW) is a program 

administered by the Service that provides financial 

and technical assistance to work cooperatively with 

landowners to voluntarily restore and enhance 

wildlife habitat on private land. Since the inception 

of the PFW program in 1992, the Service has a 

long and successful history of working with private 

landowners in Kansas. Since the inception of PFW in 

1992 over 349,342 acres of tallgrass prairie have been 

restored or enhanced. 

Infestations of invasive plants such as sericea 

lespedeza, eastern red cedar, and Osage orange 

currently are not pervasive in the Flint Hills project 

area. However, they are present in many watersheds 

and threaten to spread throughout the project area. 

In the absence of fire, woody species such as red 

cedar and Osage orange rapidly invade the tallgrass 

prairie. In an effort to control invasive plants, the 

Service’s PFW program, The Nature Conservancy, 

Tallgrass Legacy Alliance, county weed districts, 

and private landowners have initiated region-wide 

cooperative efforts. Current tools include educational 

efforts demonstrating the benefits of prevention with 

use of prescribed fire, as well as financial assistance 

for mechanical, biological, and chemical treatments. 

HABITAT PROTECTION AND EASEMENT 

ACQUISITION PROCESS

On approval of a project boundary, habitat protection 

would occur through the purchase of conservation 

easements. It is the long-established policy of the 

Service to acquire minimum interest in land from 

willing sellers to achieve habitat acquisition goals. 

The acquisition authority for the proposed Flint Hills 

Legacy Conservation Area is the Fish and Wildlife 

Act of 1956 (16 U.S.C.742 a-742j). The federal money 

used to acquire conservation easements is received 

from the Land and Water Conservation Fund, which 

is derived primarily from oil and gas leases on the 

outer continental shelf, motorboat fuel tax revenues, 

and sale of surplus federal property. 

There could be additional funds to acquire lands, 

waters, or interest therein for fish and wildlife 

conservation purposes through congressional 

appropriations and donations from non profit 

organizations and other possible sources.

The basic considerations in acquiring an easement 

interest in private land are the biological significance 

of the area, the biological requirements of wildlife 

species of management concern, existing and 

anticipated threats to wildlife resources, and 

landowner interest in the program. The purchase 

of conservation easements would occur with willing 

sellers only and will be subject to available funding. 

2 Alternatives, Including 

the Proposed Action

Tallgrass prairie flowers.

USFWS

This chapter describes the two alternatives identified 

for this project that were developed according to 

National Environmental Policy Act (NEPA) § 102(2)

(E) requirements to “study, develop, and describe 

appropriate alternatives to recommended courses 

of action in any proposal which involves unresolved 

conflicts concerning alternative uses of available 

resources.” In addition, alternatives which were 

eliminated from detailed study are briefly discussed 

as to the reasons they were not further examined: 

■ no-action alternative

■ proposed action, giving the Service the 

authority to create the Flint Hills Legacy 

Conservation Area

The alternatives consider the effects of a 

conservation easement program within the project 

area boundary identified in this environmental 

assessment.

ALTERNATIVE A (NO ACTION)

Habitat enhancement or restoration projects on 

private lands such as water developments, grazing 

systems, and grassland management could continue 

through cooperative efforts with private landowners.

Private efforts by land trusts would continue to 

secure conservation easements. 

ALTERNATIVE B (PROPOSED ACTION) 

The Service would establish the Flint Hills Legacy 

Conservation Area in eastern Kansas. The project 

boundary encompasses roughly 3.3 million acres, 

of which the Service would strategically acquire 

conservation easements on up to 1,100,000 acres of 

private land. The geographic project area extends 

north almost to the Nebraska state line, south to 

Oklahoma, west of Topeka, and east of Wichita 

(see figure 2 in chapter 1). The acquisition acreage 

total is based in part on the percent of anticipated 

participation and interest by landowners.

The Service would seek to purchase conservation 

easements from willing sellers on privately owned 

native tallgrass prairie grasslands. The easement 

contract would specify perpetual protection 

of habitat for trust species and would restrict 

development. 

Prioritization of areas considered for conservation 

easements within the project area will be based 

on the biological needs of the wildlife species of 

concern (grassland-dependent migratory birds and 

threatened and endangered species), the threat of 

development, connectivity with other protected 

lands, and the quality of native tallgrass prairie 

habitat for trust species. The land protection plan 

describes these priorities in detail. 
10 EA, Flint Hills Legacy Conservation Area, KS

Development for residential, and commercial or 

industrial purposes, such as energy and aggregate 

extraction may not be permitted on properties 

under a conservation easement. Alteration of the 

natural topography, conversion of native grassland to 

cropland, and the drainage of wetlands would also be 

prohibited. 

All land would remain in private ownership; property 

tax and land management, including invasive weed 

and tree control, would remain the responsibility of 

the landowner. The Service would seek to provide 

participating landowners with additional assistance 

for invasive plant control. Control of public access 

to the land would remain under the control of the 

landowner.

The easement program would be managed by staff 

located at the Flint Hills National Wildlife Refuge 

near Hartford, Kansas. The Service staff would 

be responsible for monitoring and administering 

of all easements on private land. Monitoring will 

include periodically reviewing land status through 

correspondence and meetings with the landowners 

or land managers to ensure that the stipulations of 

the conservation easement are being met. Photo 

documentation would be used at the time the 

easements are established to document baseline 

conditions. 

Flint Hills hillside.

© Kansas State University

ALTERNATIVES CONSIDERED 

BUT NOT STUDIED

There was no further analysis conducted for the 

following six alternatives.

Voluntary Landowner Zoning

Landowners would voluntarily petition the county 

commissioners to create a zoning district directing 

the types of development that can occur within an 

area. This is “citizen-initiated” zoning. For example, 

landowners would petition the county government to 

zone an area as agricultural, precluding certain types 

of non agricultural development such as residential 

subdivision. “Citizen initiatives” are rarely used and 

this alternative was not studied further. 

County Zoning 

In a traditional approach used by counties and 

municipalities, the local government would use 

zoning as a means of designating what type of 

development could occur in an area. Kansas law 

grants cities and counties the authority to regulate 

land use, and therefore engaging in planning and 

zoning activities is optional. Therefore, many 

counties in Kansas have opted to have no planning 

or zoning requirements and the alternative was not 

studied further. Comments received from county 

commissioners to date have expressed support 

instead for conservation easements (alternative 

B as a means of maintaining rural area values and 

potentially reducing the need for future zoning). 

Zoning would be subject to frequent changes, 

and would not ensure the long-term prevention 

of residential or commercial development in the 

conservation area.

Fee-title Acquisition

Some organizations and individuals have expressed 

an interest in Service-provided oversight and 

restrictions on management practices of prescribed 

fire, grazing, and herbicide application in the Flint 

Hills region. Fee-title purchase of land in the Flint 

Hills would be required to provide the Service 

with full authority and responsibility for planning 

and implementing these management activities. 

However, little to no public support was expressed 

for the possibility of fee-title acquisition by the 

Service in public meetings and correspondence 

received for the Flint Hills Legacy Conservation 

Area project. Additionally, recent efforts by 

the National Park Service to purchase land by 

fee-title for the establishment of the Tallgrass 

Prairie Preserve near Strong City met significant 

opposition due to “a deep seated philosophy that the 

government should not own land” and concerns about 

the possible use of eminent domain (National Park 

Service 2001). These concerns ultimately resulted in 

a greatly reduced federal ownership (approximately 

80 acres) by the National Park Service. 

The initial cost associated with fee title acquisition 

would be two to three times higher than the purchase 

of conservation easements. In addition, there would 

be substantial annual costs for staffing and materials 

needed by the Service to manage fee-title land. The 

much higher costs associated with this method would 

result in limiting acquisition to a much smaller area, 

making landscape scale conservation unlikely. 

It is the long-established policy of the Service to 

acquire minimum interest in land from willing 
Chapter 2 — Alternatives, Including the Proposed Action 11

sellers to achieve Service habitat acquisition goals. 

Fee-title acquisition is not preferable to the use 

of conservation easements, nor is this method of 

acquisition necessary to conserve tallgrass prairie 

habitat and trust wildlife resources in the Flint Hills 

region.

Smaller Project Area

During initial scoping, the FHLCA study area 

acquisition boundary was 2.2 million acres, with the 

possible purchase of easements on up to 1 million 

acres within that boundary based on preliminary 

assessments by Service biologists. Improved data 

and methods of analysis determined that using the 

physiographic boundary of tallgrass prairie, and 

assessing which portions that area still contain 

>95% prairie grassland provided more accurate, 

reproducible information (see the “Conservation 

Design” section on page 34 for specific details). This 

process determined that grassland prairie covers 

approximately 3.3 million acres, which became 

the revised approved acquisition boundary within 

which the Service would assess acquiring up to 

1.1million acres of conservation easements, based on 

anticipated interest and participation by landowners. 

A project area smaller than 1.1 million acres would 

make the conservation of the remaining narrow band 

of tallgrass prairie habitat and the migration corridor 

used by grassland-dependent wildlife less likely to 

succeed in the long term.

Larger Project Area

Initial internal discussions in 2005 included a project 

for tallgrass conservation easements throughout 

much (forty-one counties) of eastern Kansas. The 

Service decided that the project purpose needed 

further refinement and definition of the conservation 

objectives, and that the very large size of the 

potential acquisition boundary be reduced. 

Expansion of Project

After the initial phases of the Flint Hills Legacy 

Conservation Area project were well underway, 

the possibility of expanding the project area into 

Oklahoma to incorporate the tallgrass prairie 

(referred to as the Osage Hills) found there, was 

brought up. As the FHLCA project planning and 

outreach efforts had been addressed toward Kansas 

throughout the process, the Service determined 

that conservation efforts for the Oklahoma tallgrass 

will be conducted by region 2 (Southwest Region). 

The Mountain-Prairie Region, (region 6), will 

assist region 2 with any future conservation efforts 

undertaken in the Osage Hills.

3 Affected Environment

Threats to and Status of Resources

This chapter describes the biological, cultural, and 

socioeconomic resources most likely affected by 

establishing the Flint Hills Legacy Conservation 

Area.

The Flint Hills region provides habitat integral to 

larger national conservation efforts. Located in the 

Eastern Tallgrass Prairie Geographic Area, the Flint 

Hills region is a north-south migration corridor for 

many species. 

Wildlife species dependent on tallgrass habitat are 

dependent on an increasingly shrinking ecosystem; a 

factor contributing to the rapid decrease of grassland 

birds dependent on the tallgrass prairie, such as that 

found in the project area. Intact, open landscapes 

are essential habitat components for the greater 

prairie-chicken and other grassland birds that are the 

priority species guild for this project.

Grasslands once dominated central North America. 

The eastern third of this vast grassland ecosystem, 

from southern Manitoba to Illinois and south to 

Texas, is known as the tallgrass prairie region. The 

tallgrass prairie, like the Great Plains as a whole, 

was shaped under disturbances such as fire, grazing 

and drought. During these cycles of change and 

disturbance, deep-rooted prairie plants assimilated 

nutrients and returned them to the surface, creating 

rich, dark soils considered to be some of the most 

fertile in the world. 

The rich soils, combined with gently rolling 

topography, made the region prime for agricultural 

development. Much of the tallgrass prairie was 

converted to cropland in a single decade, 1870–80, 

as railroads and Land Acts provided economic 

incentives. The tallgrass prairie ecosystem has been 

plowed, fragmented, and in some cases severely 

degraded, making this once expansive, complex 

ecosystem one of North America’s most altered 

and endangered ecosystems (Noss et al. 1995). Still 

relatively unspoiled by the pressures of modern 

development is the greater Flint Hills landscape of 

eastern Kansas.

BIOLOGICAL ENVIRONMENT

In this section climate; climate change; adaptation, 

mitigation, and engagement responses to climate 

change; geologic resources; habitat; and wildlife of 

the Flint Hills are discussed.

Climate

The climate of Kansas is continental, with 

characteristic hot summers, subject to periodic 

drought coupled with very cold winters. 

Temperatures can range from –40oF to 121oF. 

There is a distinct east-west precipitation gradient 

across Kansas. The western edge of Kansas lies in a 

rain shadow of the Rocky Mountains, and receives 

only 16 inches of precipitation on average. The 

Flint Hills area receives approximately 33 inches of 

precipitation, most of which comes in the form of rain 

between the months of April and September. 

Moist Gulf of Mexico air flows over the eastern portion 

of the state, providing at the easternmost counties 

on average 42 inches of precipitation. Rainfall events 

often exceed 3 inches or more. The moist air flow and 

warm temperatures are the source for convectional 

thunderstorms and tornadic activity in the area.

Climate Change

Climate change presents additional challenges 

to habitat conservation in the Great Plains. 

Temperatures are predicted to increase in future 

decades throughout the Great Plains (Fagre et 

al. 2009). The FHLCA provides the elements 

necessary to minimize the impact on wildlife: 

resilience, redundancy, adaptation potential, habitat 

connectivity, drought-tolerant plant communities, 

large and connected ecosystem segments, and the 

presence of natural disturbances (fire and grazing).

Due to its plant diversity, tallgrass prairie has a 

built-in resilience to climate variability. The hundreds 

of grass and broadleaf species represent a wide range 

of tolerance for annual rainfall and air temperature. 

Dominated by perennials, many tallgrass prairie 

species withstand multiple years of drought, as 

evidenced by the droughts of the 1950s. Within 

this diverse plant community, a particular group of 

species usually grows well, regardless of weather 

conditions. 

Although the species composition of the prairie may 

shift if a multi-decade drought were to occur, the 

character of the tallgrass prairie would not be lost. 

During wet years, some species express themselves 

and show greater vigor. The same holds true for 

growing seasons with moderate rainfall and heat. 
14 EA, Flint Hills Legacy Conservation Area, KS

However, overall biomass is generally greater during 

years of abundant rainfall. Climate predictions vary, 

however some suggest warmer winters and similar 

spring precipitation in the mid-latitudes of the Great 

Plains (Fagre et al. 2009). Those rainfall events 

might be more episodic, bringing fewer, yet heavier 

rains. Whichever climate prediction holds true, 

the strength of the tallgrass prairie comes from its 

diverse species that are adapted to a wide range of 

climatic conditions.

With the species diversity providing resilience to 

climate change, the current condition of the Flint 

Hills region provides habitat representation and 

redundancy. Currently, the FHLCA provides 

a significant north-south migration corridor for 

grassland birds, and links many areas of high quality 

tallgrass habitat. Retaining migratory corridors is 

a key adaptation strategy for wildlife response to 

climate change (USFWS 2009). 

Adaptation, Mitigation, and Engagement

The Service’s strategic response to climate 

change involves three core strategies: adaptation, 

mitigation, and engagement (USFWS 2009). Through 

adaptation, the impacts of climate change on wildlife 

can be reduced by conserving habitats expected to 

be resilient. The FHLCA provides an anticipatory, 

rather than a reactive response. As preserving 

migratory corridors becomes increasingly important, 

the Flint Hills will provide a contiguous northsouth stand of tallgrass prairie within the Central 

Flyway. Furthermore, if spring/summer precipitation 

were to increase in a changing climate, tree 

encroachment would present an accelerating threat 

of fragmentation to the Flint Hills. Thus conservation 

actions are warranted to maintain the intactness of 

the tallgrass prairie character of the Flint Hills.

Carbon sequestration forms one of the key elements 

of mitigation. The FHLCA easement program 

could secure the carbon already stored within Flint 

Hills soils. Prairie vegetation stores carbon in its 

deep fibrous roots, with approximately 80% of the 

plant biomass located belowground. It is equally as 

important to protect existing carbon stores as it is to 

sequester atmospheric carbon.

Engagement involves cooperation, communication, 

and partnerships to address the conservation 

challenges presented by climate change 

(USFWS 2009). The FHLCA serves as a model 

for engagement by working with producers, 

nongovernmental organizations (Tallgrass Legacy 

Alliance, The Nature Conservancy, Quail Unlimited, 

and the Kansas Livestock Association). state and 

local agencies (KDWP, Kansas Department of 

Health and Environment, Kansas Farm Bureau, 

Kansas Association of Conservation Districts) and 

federal agencies including the Natural Resources 

Conservation Service.

Geological Resources

The eastern margin of the Flint Hills is marked by 

a major escarpment that is especially prominent 

in northwestern Greenwood, southeastern Chase, 

and eastern Butler counties. Maximum elevations 

exceed 1,600 feet, with local relief up to 320 feet, and 

deeply entrenched stream valleys. The prominent 

escarpment that defines the eastern edge of the Flint 

Hills is the most rugged surface feature in Kansas. 

The Walnut, Verdigris, Cottonwood, and Fall river 

drainage basins meet at divides on the Flint Hills 

crest in this region. From their eastern crest, the 

Flint Hills slope gently westward, down the regional 

bedrock dip, to the western limits of the Walnut and 

Cottonwood drainage basins. 

The Flint Hills are underlain by lower Permian 

limestone, shale, and evaporites. This bedrock 

generally dips gently toward the west or northwest. 

Local variations in bedrock dip are found over the 

crest of the buried Nemaha uplift. Erosion of shale 

and limestone strata has resulted in landscapes 

with steep east-facing escarpments separated by 

gentle west-sloping cuestas. Thick cherty limestone 

weathers to produce residual chert lag deposits that 

are highly resistant to chemical breakdown. Such 

residual chert, or flint, as it is commonly known, is 

responsible for maintaining high topographic relief 

and gives the Flint Hills their name. Unconsolidated 

sediments are common, especially within river 

valleys and on some upland areas. Soils are 

developed in residual (weathered) bedrock material, 

alluvial deposits, and loess sediment (Aber 1997).

The steep slopes and the thin, rocky soils of the Flint 

Hills limited crop cultivation to the flatter river 

and stream bottoms where there are deeper riverdeposited sediments. The same rocky limestone 

soils which made crop cultivation difficult helped to 

preserve the native characteristics of the Flint Hills, 

and made the area ideal for cattle grazing. In fact, 

over a period of time the calcium in the limestone 

erodes into the soil, making the native prairie plants 

highly nutritious for grazing animals. 

Habitat 

Numerous hydrological features bisect the Flint Hills 

eastward into the prairie. Many other tributaries 

provide a diversity of riparian plant communities. 

More than 600 species of vascular plants occur within 

the project boundary, representing roughly 25% of all 

the plant species found in Kansas and indicating the 

significant biological diversity of the Flint Hills. (See 

figure 3 for land cover and habitat types.)

Fire History

The historic tallgrass prairie, or “true” prairie, 

occurred along the eastern Great Plains, with Prairie 

Peninsula radiating north and east into Indiana and 
Chapter 3 — Affected Environment 15

Figure 3. Land cover and habitat types in the Flint Hills Legacy Conservation Area.
16 EA, Flint Hills Legacy Conservation Area, KS

Ohio during Pleistocene interglacials (Samson et al. 

1999) Tallgrass prairie is considered by ecologists 

as a “fire climax” system, meaning without fire the 

tallgrass prairie will begin to shift towards a forest 

environment (Heisler et al. 2003). The tallgrass 

prairie we know today began taking shape during 

the close of North America’s most recent glaciation 

period. This glacial epic, known as the Wisconsin 

period, caused dramatic topographical, climatic, and 

ecological changes across the landscape (Axelrod 

1985). Throughout this period, broad-scale climate 

gradients, driven by continental climate change, 

significantly influenced the composition, species 

richness, and distribution of the tallgrass prairie 

communities (Steinauer and Collins 1996). 

With an existing fire-climax prairie in place, 

prehistoric man first entered the North America 

continent approximately 12,000 years ago (Meltzer 

1989). Previously, lightning was the sole source of 

grassland fire ignition. It is noteworthy that the 

Flint Hills landscape experiences the second highest 

frequency per square kilometer of lightning strikes 

in North America (Higgens 1986). Lightning-caused 

fires presumably drove the region’s early beginnings 

as a fire- and herbivore-driven plant community 

(Mulchunas et al. 1998). As prehistoric man gained 

a landscape presence, it is suggested that fire 

frequency and temporal occurrence shifted from 

summer to a fall-dominated period (Shaw and Martin 

1995).

This altering of fire shaped the tallgrass eco-regional 

plant community for several thousands of years 

(Moore 1972). The advent of early Euro-American 

explorations, beginning with the Spanish, first 

penetrated the tallgrass region with members of 

Coronado’s expedition in 1541 (Haines 1970, Roe 

1970). Subsequent Native American ownership of 

the Spanish horse heralded great changes in their 

social behavior, biological success, and geographical 

coverage, initiating vast ecological change within 

the tallgrass region. An important component of this 

ecological change was fire, ignited for a variety of 

reasons, by an increasingly complex, more numerous, 

and more mobile Native American population. Over 

time, this increased use of fire is believed to have 

substantially accelerated an eastward expansion of 

the tallgrass region (Kozlowski and Ahlgren 1974, 

Howe 1993).

While historical fire records are scant; they do 

indicate that the period between 1535 and 1890 

supported a dominance of fall fires. Almost all 

fire records of this period are along major river 

systems due to the need for huntable game, fuel, and 

accessible water, all of which made the major rivers 

within the region the principal travel lanes for both 

Euro-American and Native American travelers of 

this time period (Moore 1972). 

Pre-1840 fire re-occurrence rates in tallgrass prairie 

vary from a possible annual regime (Pyne 1982) 

of 2–5 times per decade (Hulbert 1976), to every 

5–10 years (Wright and Bailey 1982). Cutter and 

Guyette (1994) suggest a 2.8 year fire interval 

for a Missouri savanna while Bragg (1986) and 

Hulbert (1976) suggest a 3–5 year pre-settlement 

fire interval for Nebraska and Kansas tallgrass 

prairie. Kelly Kindscher and Craig Freeman (Kansas 

Biological Survey, University of Kansas, Lawrence, 

Kansas, and Kansas Natural Heritage Inventory, 

respectively; personal communication) suggest a 3–5 

year return interval for the Flint Hills ecoregion.

Historical fire-return interval loses some of its 

relevancy unless discussed within the context 

of spatial scale and temporal events across the 

landscape. Historical fire-grazing interaction on the 

Great Plains was a shifting mosaic of disturbance, 

including areas that were burned and grazed, along 

with regions that were not disturbed. As an area 

burned and consequently greened up over time, 

herbivores of all kinds would concentrate on it. This 

burned area, if heavily used could leave other areas 

with very little grazing pressure. This fire-grazing 

interaction would repeat itself across the landscape 

creating a moving mosaic across both space and 

time. This random disturbance pattern allowed for a 

diverse assemblage of species to exist simultaneously 

(Weir et al. 2007).

Modern era settlement and livestock usage of the 

Kansas Flint Hills began in the mid-1800s. During 

initial settlement most cattle came from Texas and 

were driven across open range to Kansas. Around 

the 1880s Kansas enacted a fence law, and within a 

decade the majority of the region was fenced and 

drive routes were blocked off, much as it exists 

today (Jim Hoy, historian, Emporia State University, 

Emporia, Kansas; personal communication). As early 

as 1863, cattlemen recognized that burning prairies 

benefited both cattle weight gains and the condition 

of their pastures. 

In recent years, prescribed fires have largely been 

conducted by ranchers in the spring on an annual 

basis. Some ranchers have begun to use patch fires Riders and prescribed fire. © Jim Richardson
Chapter 3 — Affected Environment 17

that is more representative of historical fire regimes 

in the region.

Prairie Uplands 

The Flint Hills landscape is most often associated 

with bluestem grasses and about ninety native 

grass species are found here, with big bluestem, 

little bluestem, Indiangrass, switchgrass, eastern 

gamagrass and sideoats grama being some of the 

more important species from an ecological and 

livestock production perspective. The 500-plus native 

broadleaf prairie plant species (herbaceous forbs) 

documented as occurring in the Flint Hills are also 

important, not only for maintaining the ecological 

health of the prairie but also for providing added 

forage value. 

As the seasons progress, new species will flower 

each week from March through September. This 

floral diversity provides benefits such as pollen and 

nectar foods for a diverse assemblage of pollinators, 

and a seed source variable in size, shape, and amino 

acid complex, all spatially and temporally available 

across the landscape. This rich array of food choices 

provides a quality foraging opportunity to numerous 

migratory and resident trust species.

Late-season rains often give rise to luxuriant fall 

grasses, which in turn provide important winter 

thermal protection for grassland birds and offer 

unique water quality and quantity benefits to the 

region.

As a result of interactions among climate, 

topography, fire, and bison herbivory, the vegetative 

structure and composition of the prairie varied both 

temporally and spatially across the landscape. Thus, 

grassland birds evolved in an ever-changing mosaic 

of habitats, and as a result, bird communities were 

likely to have varied both temporally and spatially 

across the landscape.

Oak Savanna and Woodlands 

Although they represent a small percentage of the 

total acreage of the tallgrass prairie, native oak 

woodlands can be found throughout the project 

area. Species that are most commonly associated 

with these areas include white oak, post oak, and 

black oak, with a grass component including little 

bluestem. Post oak occurs as a dominant tree in 

savannas and in forests adjacent to grasslands, and 

will expand into adjacent prairies in the absence of 

fire.

Oak trees provide cover and habitat for birds and 

mammals. Cavities provide nest and den sites, and 

leaves are used for nest construction. Oak acorns 

provide food for numerous wildlife species including 

squirrels, mice, voles, white-tailed deer, and wild 

turkey. Bell’s vireo, Bewick’s wren, loggerhead 

shrike, and red-headed woodpecker use this woody 

habitat. 

Riparian Areas

The Flint Hills ecoregion, as defined by Chapman 

et al. (2001), contains the largest concentration of 

freshwater springs in Kansas (Kansas Geological 

Survey 2008) and is the source of the Caney, 

Cottonwood, Elk, Fall, Marais des Cygnes (Osage), 

Neosho, Verdigris, and Walnut rivers. This 

grassland region is drained by roughly 3,300 miles 

of perennially flowing streams and 14,000 miles of 

intermittent and ephemeral streams (USGS 1998). 

It boasts many of the state’s most pristine surface 

waters (for example Dodds and Oakes 2004) and 

supports a rich variety of native fish and shellfish 

species, including the world’s largest remaining 

populations of the federally protected Topeka shiner 

and Neosho madtom (Haslouer et al. 2005, Angelo 

et al. 2002a, 2009). Many streams in the Flint Hills 

currently serve as ecological “reference” systems in 

environmental monitoring programs administered 

by state and federal natural resource agencies (for 

example KDHE 2007). These streams approach 

the historical (pre-settlement) ecological condition 

and provide the physiochemical and biological data 

needed to assess changes in the state’s more heavily 

impacted surface waters (Angelo et al. 2002b, KDHE 

2008).

Wildlife

The Flint Hills prairie supports a wide variety of 

animal life. There are assemblages of amphibians and 

reptiles, fish, birds, mammals, and species of special 

concern in the project area. Appendix A contains the 

species list for the Flint Hills area.

Amphibians and Reptiles 

The tallgrass prairie and stream corridors that run 

throughout the project area provide food and shelter 

for a number of terrestrial or semi-aquatic animals 

including salamanders, toads, frogs, skinks, lizards, 

snakes, and turtles. 

Fish and Aquatic Species

The project area contains many of the state’s most 

pristine surface waters (for example Dodds and 

Oakes 2004) and supports a rich variety of native 

fish (over eighty species), and shellfish, including the 

world’s largest remaining populations of the federally 

protected Topeka shiner and Neosho madtom 

(Haslouer et al. 2005, Angelo et al. 2002a, 2009). 

Protection of this tallgrass landscape is essential 

to sustaining these aquatic species. A number 

of watersheds situated in the tallgrass prairie of 

eastern Kansas are the last remaining strongholds 

for the federally endangered Topeka shiner, a small 
18 EA, Flint Hills Legacy Conservation Area, KS

minnow that inhabits headwater prairie streams. 

While the number of known occurrences of Topeka 

shiner populations throughout its historical range 

in Iowa, Kansas, Minnesota, Missouri, Nebraska, 

and South Dakota has been reduced by more than 

80 percent, stable populations remain in many of 

the unfragmented prairie streams in the Flint Hills 

(Haslouer et al. 2005, Angelo et al. 2002a, 2009). 

Because the Topeka shiner is not negatively impacted 

by normal ranching practices, maintenance of native 

prairie watersheds through continued ranching, 

which Service conservation easements would allow, 

may be the best hope for long-term survival of the 

species. 

Another federally listed species endemic to the 

tallgrass prairie region is the Neosho madtom, a 

threatened catfish found primarily in about a 200-

mile stretch of the Neosho and Cottonwood rivers in 

eastern Kansas. Like the Topeka shiner, the Neosho 

madtom is dependent on healthy prairie watersheds.

Many of eastern Kansas’ prairie streams also 

harbor diverse assemblages of freshwater mussels. 

Freshwater mussels are the most imperiled animal 

group in North America, with thirty-six species 

believed to have become extinct during the past 

century. Unfortunately, mussels in Kansas have 

undergone a similar trend of decline. Of the fortyeight species known to have occurred in Kansas, at 

least five of these are now believed to be extirpated 

from the state, and twenty-one species are statelisted as either endangered, threatened, or as a 

species in need of conservation (Brian Obermeyer, 

Flint Hills project coordinator, The Nature 

Conservancy, Topeka, Kansas; face to face meeting, 

2009). While there are no federally listed mussels in 

Kansas, five species are classified by the Service as 

species of concern, and federal protection could soon 

be proposed for two of these—the Neosho mucket 

and the western fanshell—if their conservation 

status is further threatened. Protection of native 

prairie watersheds through the use of conservation 

easements may be one of the best defenses to 

preclude further listings and extirpations of aquatic 

mollusks in the Flint Hills. 

Birds 

The remaining portion of a once vast grassland 

provides essential habitat for numerous grassland 

bird species, including greater prairie-chicken, 

Henslow’s sparrow, short-eared owl, Bell’s vireo, 

American golden-plover, grasshopper sparrow, 

dickcissel, eastern meadowlark, upland sandpiper, 

buff-breasted sandpiper, scissor-tailed flycatcher, 

loggerhead shrike, Smith’s longspur, Harris’ sparrow, 

Swainson’s hawk and northern harrier. Among bird 

species, grassland birds have shown the fastest 

rate of decline. Of forty-six grassland-breeding bird 

species, 48% are species of conservation concern 

nationwide, including four populations that are 

federally endangered. Of the forty-two grassland 

species with sufficient monitoring, twenty-three 

are declining significantly (North American Bird 

Conservation Initiative 2009). 

Within the Flint Hills, birds require a mosaic of 

vegetation structure within the tallgrass prairie. The 

intent of the FHLCA is to maintain the contiguity 

of the tallgrass prairie, thus protecting it from 

fragmentation caused by woody encroachment or 

development. In large parcels of grassland habitat, 

bird diversity increases when grazing and fire create 

a mosaic of vegetation structure (Fuhlendorf et al. 

2006). When fire or grazing reduce the height and 

density of grasses, habitat becomes more suitable 

for grasshopper sparrow (Vickery 1996). Conversely, 

a 3-year absence of fire promotes habitat for 

Henslow’s sparrow (Zimmerman 1988). Grassland 

birds evolved under the combined influence of fire 

and grazing (Fuhlendorf et al. 2006). Those two 

disturbances are inseparable, interacting through 

positive and negative feedbacks to create a shifting 

mosaic of vegetation structure across the landscape 

(Fuhlendorf and Engle 2004). This diversity of 

vegetation height, structure, and location creates the 

heterogeneity necessary to support an entire guild 

of grassland birds: migrants, nesters, and wintering 

species. Homogenous grassland habitat, with similar 

vegetation height and litter depth, cannot support 

the entire community of grassland birds (Fuhlendorf 

and Engle 2004).

Several species within the Flint Hills are identified 

as grassland obligate birds: northern harrier, upland 

sandpiper, greater prairie-chicken, horned lark, 

Savanna sparrow, grasshopper sparrow, Henslow’s 

sparrow, dickcissel, eastern meadowlark (Ribic et 

al. 2009). Researchers at Konza Prairie found lowintensity cattle grazing to positively affect upland 

sandpipers, grasshopper sparrows, and eastern 

meadowlarks (Powell 2008). Grasshopper sparrows 

avoid areas with extensive shrub cover, selecting 

areas burned within the past 1–2 years (Powell 2008, 

Vickery 1996). Eastern meadowlarks use habitats 

with taller grasses of greater density, mixed with 

forbs (Powell 2008). 

Continuing along the spectrum of denser vegetation 

and greater time since disturbance, Henslow’s 

sparrows prefer significantly greater cover of 

standing dead vegetation created by a 2–3 year 

absence of fire (Zimmerman 1988). Dickcissels select 

areas of tall (10–59 inches) and dense (90–100%) cover 

(Powell 2008). Finally, Bell’s vireo nests in low-shrub 

vegetation within draws (Brown 1993). Although 

each species has different habitat needs, they share 

a common element—intact tallgrass prairie with a 

diversity of vegetation structure.

These grassland birds all require relatively large 

blocks of healthy tallgrass prairie at various 

ecological stages of succession. Project size becomes 

important within the context of providing adequate 
Chapter 3 — Affected Environment 19

numbers of suitable habitat units dispersed within 

the proper spatial scale, all of which are necessary to 

provide resilient, quality migrational and breeding 

habitat within the context of seasonal weather 

variations and the resultant plant community 

responses. Additionally, avian predator concerns and 

temporal shifts in migration further substantiate the 

need for large, well-dispersed areas of a mosaic of 

tallgrass habitat types along the entire migrational 

corridor for these species. The requirements of these 

tallgrass-dependent migrant birds make them a 

priority species guild for conservation management.

Important year-round avian species such as the 

greater prairie-chicken (a Flint Hills umbrella 

species) require a similar mosaic of habitat types. 

Specific successional stages of the tallgrass plant 

community are necessary for many different stages 

of the greater prairie-chicken’s life cycle. The greater 

prairie-chicken requires visually open areas with 

short vegetation for lek displays, dense almost 

shrubby habitat for nesting, moderate densities 

for brood rearing, and dense herbaceous cover for 

winter thermal protection. All of these habitat 

stages needed by greater prairie-chickens are 

representative of the various size and distribution 

requirements for avian migrants, making the 

prairie-chicken a useful umbrella species for habitat 

conservation management decisions. Home ranges 

of prairie-chicken flocks may be greater than 

9,900 acres during certain times of a year (Robel 

et al. 1970). The number of acres necessary for a 

genetically viable population of greater prairiechickens varies depending on large part on the 

quality and juxtaposition of habitats within a given 

area. Suggested size for a Minnesota population 

located in fragmented habitat was a minimum of 1 

million acres (Johnson et al. 2004). 

Unlike migrant species, the greater prairie-chicken 

must obtain all of its requirements within the context 

of tallgrass prairie. This affinity for open tallgrass 

makes it imperative to have habitat dispersed over 

as large a geographical area as possible.

Mammals

Uplands and stream corridors provide habitat for 

many small mammals including shrews, mice, voles, 

pocket gophers, ground squirrels, weasels, mink, and 

bats. These mammals provide critical food sources 

for prairie raptors such as bald eagles, ferruginous 

hawks, northern harriers, prairie falcons, and short 

eared owls. In addition, big game animals such as 

white-tailed deer, pronghorn, and the occasional mule 

deer use the upland prairie habitat. Mountain lion, 

badger, bobcat, coyote, and red fox are examples of 

carnivores that occur throughout the project area. 

Species of Special Concern

At the federal level, eleven Flint Hills species 

are listed as threatened and endangered, or are 

candidates for listing: these include the American 

burying beetle, piping plover, Topeka shiner, least 

tern, whooping crane, Neosho madtom, western 

prairie-fringed orchid, Arkansas River shiner, and 

the Arkansas darter, Neosho mucket, rabbitsfoot 

(candidates for listing). Refer to appendix A, which 

includes the federally listed animals documented as 

occurring in the project area. 

CULTURAL RESOURCES 

Current archaeological evidence indicates that 

the earliest humans, called the Paleoindians, 

migrated to the region at the close of the last Ice 

Age approximately 12,000 years ago. These people 

had a highly mobile lifestyle that depended on big 

game hunting, including mammoths and the huge 

now-extinct ancient bison. The hallmark of most 

Paleoindian sites are the beautiful but deadly spear 

points that are generally recovered from animal kill 

and butchering sites, and small temporary camps. 

Evidence of the Paleoindian occupation of the 

Flint Hills area is sparse and most often consists of 

isolated spear points. 

There was a gradual but definite shift in the pattern 

of human use of the region beginning about 9,000 

years ago. The changes are due to a combination 

of regional climatic fluctuations and an increasing 

population, coupled with tremendous social change 

and technological innovation. Although this stage, 

referred to as the Archaic and lasting until about 

2,000 years ago, is better represented in the 

archaeological record than the preceding PaleoIndian stage, the interpretation of the remains is 

difficult. Evidence of a greater diversity of tools and 

increased use of native plants is found on many sites 

but the remains also suggest a more localized and 

less mobile population.

By approximately 2,000 years ago the populations 

of the Flint Hills region exhibited a combination of 

distinctive local traits and the effects of contact with 

neighboring groups. This period is referred to as 

the Plains Woodland or Ceramic Period and lasted 

up to approximately 350 years ago. Along with an 

increasing population and regional variation came 

great changes and innovation, including the advent 

of pottery, the bow and arrow, and semi permanent 

dwellings. Small villages began to be established and 

evidence of early agriculture is found along some of 

the waterways.

When the Coronado expedition reached what would 

become central Kansas in 1541, the area was occupied 

by several of Native American groups. Over the 

next 300 years, various tribes lived in the Flint Hills 

region including the Pawnee, Wichita, Plains Apache, 

Kansa, Kiowa, and the Osage. Although many tribes 

moved, or were moved, in and out of the region, by 

the mid-1800s the influx of emigrants of European 

ancestry was prevalent. By the late 1870s many of 

the tribes had been relocated to Oklahoma.
20 EA, Flint Hills Legacy Conservation Area, KS

The Service has a trust responsibility to American 

Indian tribes that includes protection of the tribal 

sovereignty and preservation of tribal culture 

and other trust resources. Currently, the Service 

does not propose any project, activity, or program 

that would result in changes in the character of, or 

adversely affect, any historical cultural resource or 

archaeological site. When such undertakings are 

considered, the Service takes all necessary steps 

to comply with section 106 of the National Historic 

Preservation Act of 1966, as amended. The Service 

pursues compliance with section 110 of the act to 

survey, inventory, and evaluate cultural resources. 

SOCIOECONOMIC ENVIRONMENT

The project area includes portions of twenty-one 

counties; Butler, Chase, Chautauqua, Clay, Cowley, 

Dickinson, Elk, Geary, Greenwood, Harvey, Jackson, 

Lyon, Marion, Marshall, Morris, Pottawatomie, Riley, 

Shawnee, Washington, Woodson, and Waubansee. A 

number of small communities are within the project 

area, mostly located adjacent to Highway I-35 and 

the eastern portion of I-70. Some of the largest 

communities in the state are immediately adjacent 

to the project area. Wichita has a population of over 

366,000, Kansas City 142,562, and Topeka 123,446. 

Over 2.8 million persons live in the state of Kansas 

(U.S. Census Bureau 2009). Although there are 

several large communities adjacent to the FHLCA, 

the economy of the project area is tied to ranching 

and agriculture.

The strong agricultural tradition in Kansas has been 

contributing to the economies of small towns and 

the state’s overall well-being since before statehood. 

Known as “cow towns,” many towns in Kansas were 

dependent on the large cattle drives of the mid- and 

late-eighteenth century. As the drives changed and 

eventually disappeared, these cow towns had to change 

their economic base to survive—towns such as Abilene 

and Dodge City had to reinvent themselves. Though 

not totally dependent on the cattle industry now, 

many towns still rely on the economics of the industry. 

The grasslands of the Flint Hills provide summer 

grazing grounds that provide cattle to the numerous 

feed lots in other portions of Kansas. 

The importance of the Flint Hills to the cattle 

industry cannot be overstated. The Flint Hills 

grasslands provide cattle to the feedlots that supply 

the processing facilities, thus supporting a state-wide 

cattle industry. With Kansas ranking second in cattle 

and calves, the Flint Hills plays a major role in the 

$6.24 billion cattle industry in Kansas, processing 

over 22% of all beef in the United States (Kansas 

Department of Agriculture 2010). The Flint Hills 

ranchers’ livelihood depends on natural resources 

(grass, water, and open space) and these ranchers 

have a deep-rooted attachment to the land. 

Unlike many other areas in the country, the key 

to protecting the tallgrass prairie lies primarily in 

sustaining the current land use pattern of livestock 

ranching and the use of prescribed fire. 

Reasonably foreseeable actions are actions and 

activities that are independent of the conservation 

area proposed action but could result in the 

cumulative or additive effects when combined with 

the proposed alternatives. They are anticipated to 

occur regardless of which alternative is selected. The 

cumulative effects of these activities are described 

in the “Cumulative Impacts” sections in chapter 

4. Energy development (oil and gas, and wind) 

and residential development, and future prairie 

conservation efforts by a variety of organizations are 

the primary, reasonably foreseeable actions occurring 

in the Flint Hills region and are also discussed in 

chapter 4.

Landownership 

More than 98 percent of the property within the 

project boundary is in private ownership. Many Flint 

Hills properties are in the possession of absentee 

landowners, with ranch managers controlling the 

day-to-day operations.

Property Tax

Currently, landowners pay property taxes on their 

private lands to the counties. Since the proposed 

project is a conservation easement program, the 

land does not change hands and, therefore, the 

property taxes paid by the landowner to the county 

are not affected. Kansas property taxes are based on 

agricultural value, and as easements will not affect 

the agricultural value of the property, no changes to 

the tax base are anticipated.

Public Use and Wildlife-dependent 

Recreational Activities 

Visitors to the Flint Hills are attracted by 

opportunities for bird and other wildlife viewing, 

nature photography, canoeing, fishing, hunting, 

wildflower touring, hiking, and horseback riding. 

The 2006 National Survey of Fishing, Hunting, and 

Wildlife-Associated Recreation found that $5.58 

million were spent in Kansas on equipment and 

various trip-related expenditures for hunting and 

fishing. An additional $1.56 million was spent on food, 

lodging, and various equipment used for wildlife 

watching. In 2008, the sale of hunting and fishing 

licenses alone in Kansas generated approximately 

$10.8 million in revenue (Kansas Department of 

Revenue 2008).

There is increasing interest in developing agritourism opportunities in the Flint Hills. Many 

tourists travel on the Native Stone Scenic Byways 

and Flint Hills Scenic Byway located within the 

project area.
4 Environmental Consequences

This chapter assesses the environmental impacts 

expected to occur from the implementation of 

alternatives A or B, as described in chapter 2. 

Environmental impacts are analyzed by issues for 

each alternative and appear in the same order as 

discussed in Chapter 2.

EFFECTS ON THE BIOLOGICAL 

ENVIRONMENT

This section describes the estimated effects on 

wildlife habitat and water and soil resources of 

carrying out alternatives A and B.

Wildlife Habitat—Alternative A 

(No Action)

Current Service programs such as Partners for 

Fish and Wildlife (PFW) would continue within 

the conservation project area. The Service would 

continue to work cooperatively with landowners to 

voluntarily improve habitat on private land. 

Although efforts by the Service’s PFW program and 

partners would continue to enhance habitat on some 

private lands, degradation of resources on many 

unprotected lands would continue. These potential 

impacts could result in the further decline of 

migratory birds, resident wildlife, and listed species. 

Wildlife species, particularly grassland birds, would 

continue to decline due to habitat fragmentation 

resulting from intensification of agricultural 

processes, conversion to forest cover, or residential 

and commercial development. Stream quality could 

be become degraded from development, impacting 

the Topeka shiner, Neosho madtom, and mollusk 

species.

Subsequent effects, including those listed below, 

would likely impact wildlife:

■ Fragmentation of habitat and loss of migration 

corridors for wildlife

■ Reduction or elimination of grazing and 

prescribed fire used to maintain intact tallgrass 

prairie

■ Increased non-native and invasive species

Habitat Fragmentation

Habitat fragmentation can be defined as a 

“landscape-level process in which a specific habitat is 

progressively sub-divided into smaller, geometrically 

altered, and more isolated fragments as a result of 

both natural and human activities, and this process 

involves changes in landscape composition, structure, 

and function at many scales and occurs on a backdrop 

of a natural patch mosaic created by changing 

landforms and natural disturbances (McGarigal and 

McComb 1999).”

Habitat loss and fragmentation is the greatest 

threat to the Flint Hills tallgrass ecosystem, and is 

much more likely to occur under this alternative. 

Fragmentation is primarily caused by commercial, 

industrial, and residential development, which 

reduces the use of prescribed fire and results 

in the encroachment of trees. Habitat loss and 

fragmentation may also act synergistically with 

climate change and other factors to magnify 

deleterious effects to species and ecosystems by 

limiting the ability of species to adapt or migrate 

(Hill et al. 2006, Ewers and Didham 2006). Habitat 

loss and fragmentation are considered the most 

significant threat to global biodiversity, with 

infrastructure development playing a key role 

(Wilcove et al. 1998).

Flint Hills grassland species are dependent on open 

expanses of intact tallgrass prairie habitat. As a 

non-migratory bird species, the greater prairiechicken must be able to meet all life requirements 

within a relatively limited area of prairie, and 

are therefore useful as an umbrella species for 

evaluating habitat for other grassland bird species. 

Habitat requirements of prairie-chickens are 

thought to magnify the impact of fragmentation 

and other agents of habitat change (Leitner et al. 

1991, Knick and Rotenberry 2000), and declining 

grouse populations have been linked to broad spatial 

landscape changes (Woodward et al. 2001, Fuhlendorf 

et al. 2002). Patten et al. (2005) suggested that 

landscape fragmentation would result in a need for 

greater home range size for greater prairie-chickens, 

which could decrease survivorship due to increased 

predation, collisions, and energy expenditures. It 

is essential to maintain contiguous habitat for the 

maintenance of prairie grouse populations in order 

to provide connectivity of multiple leks (Woodward 

et al. 2001); as much as 15,000 acres is required to 

support a single prairie-chicken lek (Hagen and 

Giesen 2005). Intact grassland habitats like the Flint 

Hills may not be able to sustain prairie-chicken 

and other grassland-interior specialist species if 

fragmentation goes unchecked. 
22 EA, Flint Hills Legacy Conservation Area, KS

A 6-year study in southwestern Kansas found 

that lesser prairie-chickens strongly avoid certain 

anthropogenic features, resulting in sizable areas of 

habitat being rendered less suitable (Pitman 2005, 

Robel et al. 2004). Similarly, Braun et al. (2002) found 

that greater sage-grouse abandoned portions of their 

habitats affected by oil production activity, including 

areas adjacent to regularly traveled oil field service 

roads. Edges of habitat caused by roads may create 

an avenue for predators and the spread of invasive 

weeds (Hansen and Clevenger 2005, Lockwood et al. 

2007). Robel et al (2002). Observed mean avoidance 

buffers (mean distances based on 90% avoidance by 

187 nesting lesser prairie-chicken hens) of 1,191feet 

from transmission lines, 581 feet from oil or gas 

wellheads, 4,114 feet from buildings, 1,007 feet from 

center pivot irrigation fields, and 2,579 feet from 

either side of improved roads (95 feet from 2-track 

ranch trails) were measured. Likewise, 18,866 

radio telemetry locations of lesser prairie-chickens 

revealed strong avoidance behavior (95% absence 

ratio) from human intrusions; for example, prairiechickens avoided buildings and transmission lines by 

mean distances of 1,978 and 2,081 feet, respectively. 

Large arrays of turbines may also serve as a barrier 

to birds (Drewitt and Langston 2006), potentially 

altering migratory corridors, local flight paths, and 

immigration and emigration among populations. 

The disturbance of tall foreign structures and noise 

may also disrupt mating vocalizations. Lesser 

prairie-chicken vocalizations, for example, are high 

frequency (approximately 750 Hertz) and antiphonal, 

and thus are easily drowned out by peripheral noise 

(Bain and Farley 2002). Braun et al. (2002) reported 

that Gunnison and greater sage-grouse were 

particularly susceptible to noise near leks. 

Many more acres of land would likely be developed 

for residential home sites or isolated commercial 

uses, as economic forces change in the future. The 

project area has more than 3,000,000 privately owned 

acres, with the majority remaining in large ranch 

ownership. Under Kansas state law, the subdivision 

process is not difficult. Moreover, with no county 

zoning in place, small lot subdivisions are possible. 

The Flint Hills prairie is essentially surrounded 

by urbanized areas and areas of commercial 

development. Residential development around 

Wichita, Topeka, Manhattan, and Emporia has been 

claiming thousands of acres of tallgrass prairie 

annually. Long-time family ranches are beginning 

to be sold and are commanding high prices for 

residential properties. 

Habitat and travel corridors for key geographic and 

functional biological linkages can be lost, and wildlife 

populations isolated, once an area is fragmented by 

subdivisions or other development. Studies have 

shown that an increase in urbanization and associated 

fragmentation has a negative effect on the abundance 

of grassland nesting birds. In one study, all species 

of song birds reviewed decreased with an increase 

in urbanization. For two species, the horned lark 

and Savanna sparrow, no birds were observed in 

plots where 4–7% of the surrounding landscape 

was urbanized, suggesting a high sensitivity to 

urbanization and associated fragmentation of 

habitat. Grasshopper sparrows declined abruptly in 

abundance at approximately 10% urbanization (Bock 

et al. 1999).

Additionally, human settlement results in the 

introduction of trees which spread and provide 

habitat for non-native perching birds which 

exacerbate the rate of spread. Woody species, such as 

the red cedar, have been increasing in the Flint Hills 

since around 1970 (Smith et al. 1978). Research has 

shown that the increase in woody species is a result 

of reduction in the use of fire, along with human 

population growth and resultant land fragmentation 

(Hoch 2000). Habitat loss, fragmentation, and the 

resulting genetic isolation constitute the most serious 

threats to grassland biological diversity. These 

factors have been repeatedly shown to decrease 

species richness. Ecologists use two theoretical 

frameworks to explain this phenomenon: the theory 

of island biogeography and metapopulation dynamics. 

The relationship of fragmentation and lost diversity 

holds especially true in grassland ecosystems, where 

many grassland interior specialists, such as the 

prairie-chicken, require large expanses of relatively 

unfragmented habitat. (Brian Obermeyer, Flint 

Hills project coordinator, The Nature Conservancy, 

Topeka, Kansas; personal communication).

Wind power offers an emission-free source of 

electricity and lacks many of the environmental 

hazards associated with fossil fuels (Therkelsen et 

al. 1998). However, impacts to grassland-dependent 

wildlife habitat resulting from wind infrastructure 

are of particular concern in the Flint Hills due to 

the high potential for wind energy development. 

Development of wind power poses a high risk of 

habitat fragmentation for the Flint Hills because 

economically viable wind resource areas and 

conservation priority areas show a high level of 

geographic congruence. 

Red cedar invasion of prairie.

© Kansas State University
Chapter 4 —Environmental Consequences 23

Prairie-chickens are prairie-interior specialists, 

exhibit high site fidelity, require extensive grasslands 

and open horizons (Giesen 1994, Fuhlendorf et al. 

2002), and are thought to be especially vulnerable to 

wind energy development. Robel (2002) predicted 

utility scale (1.5 megawatt) wind turbines would 

create an approximate 1-mile radius avoidance zone 

for greater prairie-chicken nesting and brood rearing 

activities. Based on this estimate, he projected that 

a proposed 100 megawatt wind facility in the Flint 

Hills of Kansas would render 15,000–17,990 acres 

of very good to excellent tallgrass prairie habitat 

unsuitable for nesting and brood-rearing purposes; 

the actual project size of this proposed project was 

roughly half this area. 

Other Fragmentation Issues

Today’s Flint Hills tallgrass prairie landscape is 

considered by ecologists to be a “fire climax” system. 

When tallgrass prairie remains unburned for ten 

or more years it begins to convert to woodlands 

(Abrams and Gibson 1991) and will become 

unsuitable habitat for the many grassland species 

currently associated with the tallgrass prairie region. 

With the currently increasing encroachment of 

residential and commercial development, and 

fragmentation by road networks it is becoming 

much more difficult to use the combination of 

prescribed fire and grazing necessary to maintain 

a healthy mosaic of tallgrass prairie habitat 

in a fire climax ecosystem like the Flint Hills. 

Increased development could make prescribed fire 

activities more difficult to implement, allowing tree 

encroachment in the surrounding areas around these 

developments. 

No action would result in loss of opportunity to 

protect important tallgrass prairie and riparian 

habitats. Without the protection of private land 

with conservation easements, the future of tallgrass 

habitat for wildlife in the project area would be 

uncertain. The increased likelihood of development in 

the Flint Hills under alternative A, and the resultant 

fragmentation, would further exacerbate grassland 

bird declines and ultimately speed the listing of 

grassland-dependent species. 

Wildlife Habitat —Alternative B (Proposed 

Action)

Through the proposed conservation easement 

program, up to 1,100,000 acres of privately owned 

native tallgrass prairie habitat would be added to the 

approximately 35,000 acres within the project area 

that already have some level of protection through 

the efforts of other conservation organizations. 

The Service would work with other agencies and 

organizations seeking tallgrass prairie habitat 

conservation. This would have long-term positive 

impacts on wildlife habitat and result in the long 

term conservation of migratory birds, threatened 

and endangered species, native plants, and the 

overall biological diversity of the Flint Hills tallgrass 

prairie. Through the PFW program, the management 

practices on easement lands could potentially be 

improved to provide better tallgrass prairie habitat 

for grassland species. 

Habitat Fragmentation

Establishing the Flint Hills Legacy Conservation 

Area would provide for the conservation of up to 

1,100,000 acres of the only remaining landscape-scale 

expression of tallgrass prairie. This program would 

provide protection and prevent the fragmentation 

of essential tallgrass habitat, and prairie-dependent 

resident and migratory wildlife species. 

Under the proposed action, areas with FHLCA 

conservation easements would not permit 

commercial and industrial-scale development, 

including wind energy development, new residential, 

oil and gas developments, or commercial aggregate 

extraction projects on easement lands due to the 

serious fragmentation effects on grassland species 

associated with these types of activities and their 

associated infrastructure (wind towers, roads, 

and transmission lines). Perpetual conservation 

easements would restrict new development in order 

to prevent the resultant habitat fragmentation, and 

thereby protect key biological linkages, facilitate 

wildlife movement, and provide for wildlife habitat 

requirements. Additionally, the use of conservation 

easements would support management activities 

such as prescribed fire, grazing, and other efforts to 

control the spread of woody vegetation and invasive 

weeds. Retaining large, unfragmented areas would 

also greatly reduce potential for human–wildlife 

conflicts. 

Because the conservation area currently benefits 

from minimal habitat fragmentation, the project 

seeks to retain the intact status of the habitat. The 

habitat loss and fragmentation from roads, power 

lines, turbines, and other associated infrastructure 

that is probably the most pressing issue for wind 

projects sited in relatively intact, natural landscapes 

(Kuvlesky et al. 2007, McDonald et al. 2009) would 

be greatly reduced in the project area under this 

alternative.

The Service supports the development of renewable 

energy (see Secretarial Order 3285) in areas that 

have minimal impacts to the trust wildlife resources 

on public lands. However, available research shows 

the grassland interior species of the Flint Hills to be 

especially vulnerable to infrastructure from various 

forms of development. Service Interim Guidance 

on Avoiding and Minimizing Wildlife Impacts from 

Wind Turbines (USFWS 2003) recommends avoiding 

“placing turbines in habitat known to be occupied by 

prairie grouse or other species that exhibit extreme 

avoidance of vertical features or structural habitat 
24 EA, Flint Hills Legacy Conservation Area, KS

fragmentation. In known prairie grouse habitat, 

avoid placing turbines within 5 miles of known 

leks.” While wind turbines may be compatible with 

some wildlife species in other areas of Kansas, the 

Flint Hills tallgrass prairie dependent species have 

demonstrated sensitivity to vertical structures and 

habitat fragmentation. 

Compatible agricultural practices such as livestock 

grazing, prescribed burning, and haying would 

continue, while sod busting (breaking of native 

grassland) would be prohibited. Easements would 

maximize the connectivity with other protected 

grasslands and decrease the negative impacts of 

habitat fragmentation on grassland birds. 

For easements that have been put in place on land 

where the owner has not sold or leased the mineral 

or subsurface estates (oil and gas deposits), the 

U.S. Fish and Wildlife Service easement would be 

senior to any subsurface interests later acquired by 

a developer. Since development of the mineral estate 

could significantly impact the resources the Service 

is attempting to protect, the Service would require 

a developer to access minerals from off-site. Surface 

occupancy of the easement for mineral development 

would be prohibited.

In many places where the subsurface estate has 

been severed, including along the Flint Hills, the 

landowner does not own the subsurface rights; this 

means that the easement that the Service acquires 

from the landowner is subject to the outstanding 

mineral rights. In those cases, the Service would 

work on a voluntary basis with the developer to 

minimize surface degradation and would seek 

restoration of disturbed sites.

Conserving the unfragmented nature of North 

America’s interior grassland habitats, which have 

steadily become more fragmented by a variety of 

human-induced influences (Samson and Knopf 1994, 

Knopf and Samson 1997), is essential for the longterm conservation of grassland-dependent wildlife.

The Flint Hills region provides habitat integral to 

larger national conservation efforts. The region is a 

north-south migration linkage for many migratory 

birds. Wildlife species dependent on tallgrass habitat 

are being increasingly compressed into a shrinking 

ecosystem, a factor contributing to the rapid 

decrease of grassland birds; the fastest declining of 

all of the North American bird guilds. Intact, open 

landscapes are essential habitat components for the 

greater prairie-chicken and other grassland birds 

that are the umbrella species for this project. These 

open landscapes are also essential for the viability of 

ranching communities in the Flint Hills, and in turn 

provide habitat at the scale necessary for grassland 

interior specialists. 

Establishing the Flint Hills Legacy Conservation 

Area would provide for the conservation of up to 

1,100,000 acres of important tallgrass habitat on 

private land. This program would help maintain the 

intactness of the Flint Hills tallgrass prairie region 

and complement conservation efforts of Ranchland 

Trust of Kansas, Tallgrass Legacy Alliance, Kansas 

Land Trust, The Nature Conservancy, KDWP, and 

other federal and state agencies.

Other Fragmentation Issues 

Conservation easements within the Flint Hills 

Tallgrass Legacy Conservation Area would help 

reduce habitat fragmentation resulting from a lack 

of fire and encroachment by woody species. Key 

biological linkages that facilitate wildlife movement 

and provide for wildlife habitat requirements 

would be maintained. The conservation of large, 

unfragmented blocks of tallgrass prairie would allow 

the continued use of prescribed fire to maintain 

healthy habitat. In particular, patch or rotation 

burning provides the mosaic of habitat conditions 

required by grassland birds.

One of the greatest threats to the tallgrass 

region is forestation due to fire suppression. 

Fire also maintains overall prairie health and 

in turn promotes heterogeneity, a precursor to 

biodiversity. Maintaining fire in the Flint Hills 

would be maintained through objective, voluntary 

management in this alternative.

Water and Soil Resources—Alternative A 

(No Action) 

The prospect of residential development in the Flint 

Hills area represents a potentially significant threat 

to the aquatic habitat. Sewage-derived nutrient 

additions to streams could have detrimental effects 

on the aquatic ecology (Wernick et al. 1998). Housing 

developments can also result in water diversion, and 

introduction of invasive species. Development could 

also change drainage patterns or rate of surface runoff, 

increasing soil erosion and nonpoint source pollution. 

As demand for potable water increases for new 

subdivisions, water rights could be questioned 

and challenged to a greater extent in the future. 

Groundwater aquifers would receive more demand, 

resulting in potential degradation to the hydrology of 

some wetland areas. 

Conversion of grasslands to cropland has been 

documented to increase sedimentation and pesticide 

runoff into wetlands. Tillage increases the sediment 

load into wetlands when compared to grasslands 

(Gleason and Euliss 1998, Kantrud et al. 1989), 

primarily due to wind erosion (Natural Resources 

Conservation Service 1992). 
Chapter 4 —Environmental Consequences 25

Carbon Sequestration Effects

Although eastern red cedar forests may provide 

strong regional carbon sinks, these sinks are 

vulnerable to significant losses through volatilization 

in fire, as well as losses through soil erosion caused 

by reduced herbaceous cover in these forests.

Water and Soil Resources—Alternative B 

(Proposed Action) 

Water resources on up to 1,100,000 acres would 

be protected from increased non-point source 

pollution from residential subdivision, commercial 

development, increased erosion, and draining of 

wetlands, all of which are prohibited under the 

proposed easement program. 

Compatible agricultural practices such as livestock 

grazing or haying would continue, while sod busting 

would be prohibited. The landowner would continue 

to own and control water rights.

Carbon Sequestration Effects

Carbon sequestration is cited as a goal of the 

USFWS Action Plan for Climate Change (USFWS 

2009). Tallgrass prairie is well known for its ability 

to store carbon within soils. In addition, research at 

Konza Prairie identifies tallgrass prairie as a carbon 

sink under elevated CO2 concentrations (Williams et 

al. 2004). Therefore, conservation of the Flint Hills 

grasslands would not only ensure the storage of 

existing soil CO2, but also provide a place for future 

sequestration if atmospheric CO2 concentrations 

increase. Some studies have indicated under 

conditions of elevated levels of CO2 carbon is stored 

in greater proportions belowground and productivity 

increases in plant systems like the tallgrass prairie 

found in the Flint Hills (Canadell et al. 1996, Williams 

et al. 2004). Grasslands store the majority of carbon 

within the soil, whereas forests hold the greatest 

abundance of carbon in aboveground biomass. While 

projects that sequester carbon through reforestation 

receive much attention, equal attention should be 

focused on retaining carbon that is currently stored 

in soils.

EFFECTS ON THE SOCIOECONOMIC 

ENVIRONMENT

This section describes the estimated effects of 

alternatives A and B on landownership, land use, 

public use, development (including oil and gas, wind 

energy, and residential), and intact ecosystems 

values.

Landownership and Land Use—

Alternative A (No Action)

More than 90 percent of the Flint Hills prairie would 

remain in private ownership. Ranching opportunities 

could be reduced when landowners begin to split 

tracts into smaller lots for residential and commercial 

development. However, landowners that subdivide 

could increase their revenue by developing 

recreational home sites. With subdivision, tracts 

could potentially increase in value if there is desire 

to cluster housing or to keep open space for future 

housing developments. 

The community would lose open space and the 

aesthetics of the tallgrass prairie, and the stunning 

scenic vistas would be diminished. 

Landownership and Land Use—

Alternative B (Proposed Action)

The easement program would maintain the 

aesthetics of the tallgrass prairie while providing 

protection of trust resources through conservation of 

wildlife habitat and protection of land from surface 

disturbance or development, and fragmentation. 

In 2006, the Outdoor Industry Foundation reported 

that wildlife and bird watching contributed $730 

billion annually to the United States economy, with 

an estimated 66 million American participating in 

wildlife viewing (Southwick Associates 2007).

 The proposed action would only affect lands on 

which the Service has acquired a conservation 

easement. The location, distribution, and sale of 

development rights by landowners on adjacent lands 

without Service easements would not be affected. 

Ongoing, traditional agricultural uses such as 

livestock grazing would allow ranching to continue 

on easements. This alternative would maintain 

open space on a large landscape scale, thereby 

preserving the rural lifestyle and associated tourism 

and economic activities of the area. The purchase of 

an easement would not result in a transfer of land 

title, and private landowners would continue to pay 

property taxes. 

Positive effects may occur from increased public 

wildlife viewing, tourism, fishing, and hunting 

opportunities. Open space also may enhance property 

values on adjoining lands as people begin to seek out 

undeveloped lands in the future.

In addition, maintaining intact tallgrass prairie 

habitat would provide “ecosystem services” that are 

often unrecognized, or considered “free” (for example 

pollination, water purification, nutrient cycling, 

carbon sequestration, soil conservation, and control 

of pest insect populations by birds) that would not be 
26 EA, Flint Hills Legacy Conservation Area, KS

provided in areas that have undergone residential or 

commercial development.

The easement program would have no effect on tribal 

jurisdiction or tribal rights because it is outside 

of reservation lands and deals only with private 

landowners willing to sell an easement.

Public Use—Alternative A (No Action)

The Service would not purchase conservation 

easements, and landowners would manage public use.

Public Use—Alternative B (Proposed 

Action)

Conservation easements purchased on private tracts 

would not change the landowner’s right to manage 

public access to their property. 

Under the proposed easement program private 

landowners would retain full control over their 

property rights, including allowing or restricting 

hunting and fishing on their lands. 

Development—Alternative A (No Action)

The incremental increases in infrastructure 

construction resulting from commercial (oil and gas, 

wind) and residential development in the Flint Hills 

will likely result in the fragmentation of habitat 

currently used by grassland-dependent wildlife. Over 

the long-term, the combined effect of these activities 

will likely result in the continuation, and possibly the 

acceleration, of the decline of grassland bird populations.

Over time, subdivision and development would 

reduce agri-tourism, hunting, and wildlife 

observation opportunities, resulting in diminished 

economic benefits associated with these activities to 

local communities. 

Those landowners and the surrounding communities 

would lose open space, and the aesthetics of the wide 

open vistas in the conservation area would diminish 

with the anticipated increase in development. 

Development could reduce tourism, hunting, and 

wildlife observation opportunities, and diminish 

revenue associated with these activities to local 

communities. 

Oil and Gas Exploration and Development

Oil and gas development would continue to occur 

on private lands in the Flint Hills. Stipulations to 

protect the surface estate would be governed by 

existing state regulations.

Wind Energy Development

The Flint Hills Conservation Area project would 

remain in private ownership, having no additional 

Service restrictions. Landowners could potentially 

profit by allowing wind energy development 

infrastructure to be developed on their land. 

Residential Development

During the 1960s, demographers documented 

that, for the first time in American history, higher 

proportions of people were leaving cities for rural 

areas than were making the return trip (Fuguitt 

1985). Residential development and subdivision tend 

to fragment wildlife habitat, and generally increase 

the costs to county governments that have to provide 

services to rural subdivisions. 

Development—Alternative B (Proposed 

Action)

The proposed alternative will protect up to 1.1 

million acres of tallgrass prairie from the combined 

effects of various future development activities by 

precluding surface occupancy, and the resultant 

infrastructure from fragmenting tallgrass habitat. 

The Service’s proposed FHLCA is the only presently 

known action of similar scope and scale that is 

seeking landscape-scale conservation of the tallgrass 

prairie in the Flint Hills.

Ongoing, traditional agricultural uses such as 

livestock grazing would allow ranching to continue. 

This alternative would maintain open space on a 

large landscape scale, thereby preserving the rural 

lifestyle of the area.

Oil and Gas Exploration and Development

The proposed easement program would preclude oil 

and gas exploration or development requiring surface 

occupancy on easement land. Typically, conservation 

easements do not affect subsurface estates (oil and 

gas deposits) because the Service only acquires 

rights associated with surface ownership. In many 

places where the subsurface estate has been severed 

from surface ownership, including along the Flint 

Hills, the landowner does not own the subsurface 

rights; and this means that the easement that the 

Service acquires from the landowner is junior to the 

subsurface rights. 

For easements that have been put in place on land 

where the owner has not sold or leased the mineral 

or subsurface estates (oil and gas deposits), the 

U.S. Fish and Wildlife Service easement would be 

senior to any subsurface interests later acquired by 

a developer. Since development of the mineral estate 

could significantly impact the resources the Service 

is attempting to protect, the Service would require 

a developer to access minerals from off-site. Surface 

occupancy of the easement for mineral development 

would be prohibited.
Chapter 4 —Environmental Consequences 27

Wind Energy Development

The easement program would enhance the 

protection of tallgrass prairie-dependent wildlife 

species through conservation of wildlife habitat and 

protection from surface disturbance or development 

of wind energy infrastructure, while providing 

some financial compensation to landowners 

through the sale of easements, to offset some of the 

potential revenue loss from the sale of wind energy 

development leases. 

The project will only affect lands on which the 

Service has acquired a conservation easement. 

Location and distribution on adjacent lands without 

Service conservation easements will not be affected. 

Over 89% of Kansas has the potential for the 

development of wind energy (National Renewable 

Energy Lab 2010) most of which (over 45 million 

acres) would still be available for development under 

the proposed alternative.

Residential Development

Preventing subdivision and development could 

decrease future tax revenues in a defined market 

area. However, open space could actually provide 

a net savings to local governments when compared 

to the revenues generated and costs of services 

associated with residential development (Haggerty 

1996).

Value of Intact Ecosystems—Alternative A 

(No Action)

Under the no action alternative, the threat of 

grassland fragmentation will continue unabated. 

Landowners may continue to face economic 

pressures to subdivide their ranches. Tree 

encroachment and urban fragmentation will 

compress the Flint Hills region, leaving fewer larger 

parcels of tallgrass prairie.

Value of Intact Ecosystems—Alternative B 

(Proposed Action)

Under the proposed action, the Flint Hills grasslands 

would remain intact, continuing to provide 

ecosystem goods and services to landowners and 

local communities. Ecosystem services include: 

soil erosion control, water supply, hay production, 

biodiversity, and carbon sequestration. Researchers 

have attached dollar values to the ecosystem services 

provided by the grasslands of the Great Plains 

(Dodds et al. 2008). Overall, the native grasslands of 

the Great Plains produce $1,189 billion per year of 

ecosystem goods and services. Compared to other 

habitat types in the United States (eastern forests, 

deserts, wetlands), Great Plains grasslands have 

substantial value because of their significant acreage 

and their high quality (Dodds et al. 2008).

Great Plains grasslands stand out in other ways 

as well. Compared to other terrestrial ecosystems, 

grasslands provide the highest commodity value 

because of hay production. In addition, they show 

high economic value for biodiversity, due to the 

abundance of insect pollinators (Dodds et al. 2008). 

Beneficial insects from grasslands can provide 

pollination services to surrounding agricultural crops. 

More locally, Kansas State Research and Extension 

conducted a watershed protection strategy for the 

Neosho River headwaters, most of which originates 

in the Flint Hills. The models for erosion control 

make comparisons between urban, cropland, and 

grassland cover types. Intact grassland provides a 

95% reduction in soil erosion when compared to other 

cover types (Kansas State University Research and 

Extension 2009). This ecosystem service retains 

soil productivity and improves water quality for 

surrounding communities.

The proposed action would help protect valuable 

ecosystem services as shown in figure 4. 

Furthermore, it would prevent the prohibitively high 

cost of restoration.

UNAVOIDABLE ADVERSE IMPACTS

Any adverse effects that may be unavoidable while 

carrying out alternatives A and B are described 

below.

Alternative A (No Action)

The adverse impacts of degradation and habitat 

fragmentation would be expected to be more 

widespread and prevalent in the project area. 

Alternative B (Proposed Action) 

No direct or indirect unavoidable adverse impacts 

to the environment would result from the selection 

of alternative B. The easement program would 

not result in unavoidable adverse impacts on the 

physical or biological environment. The selection of 

an approved boundary would not, by itself, affect any 

aspect of landownership or values. 

IRREVERSIBLE AND IRRETRIEVABLE 

COMMITMENTS OF RESOURCES

Any commitments of resources that may be 

irreversible or irretrievable as a result of carrying 

out alternatives A and B are described as follows.

Alternative A (No Action)

There would be no additional commitment of 

resources by the Service if no action is taken. 
28 EA, Flint Hills Legacy Conservation Area, KS

Figure 4. Relative native and restored benefits of ecosystem goods and services. 

The relative value (RI) is determined as the ratio of estimated benefits derived from native and restored 

acreages per year. (Source: Dodds et al. 2008.)

The likely introduction of new residential and 

commercial infrastructure to the Flint Hills tallgrass 

prairie would be an irretrievable loss of habitat for as 

long as the structures are in place. The irretrievable 

loss of habitat caused by the development of new 

residential and commercial infrastructure in the Flint 

Hills could eventually lead to an irreversible loss of 

both species and habitat. 

The new infrastructure could effectively cause an 

irretrievable loss of habitat for tallgrass prairie bird 

species because of their avoidance of tall structures. 

With the loss of habitat some of these bird species 

could be pushed towards threatened or endangered 

status. Without other suitable habitat being 

available, there could be an irreversible loss of some 

bird species.

With new residential and commercial infrastructure 

development in the Flint Hills prescribed fire activity 

to maintain tallgrass prairie habitat could be further 

reduced. Without prescribed fire, tree encroachment 

would continue to reduce the tallgrass prairie habitat 

for the greater prairie-chicken and other grassland 

bird species, possibly leading to an irreversible loss 

of habitat. 

Alternative B (Proposed Action) 

There would not be any irreversible or irretrievable 

commitments of resources associated with 

establishing the conservation easement program. 

Once easements are acquired, irreversible and 

irretrievable commitments of funds to protect these 

lands (such as expenditure for fuel and staff for 

monitoring) would exist. 

The introduction of new residential and commercial 

infrastructure to the Flint Hills tallgrass prairie 

would be greatly restricted on conservation 

easement lands, reducing the likelihood of an 

irretrievable loss of habitat associated with 

development. The irretrievable loss of habitat 

caused by the development of new residential and 

commercial infrastructure in the Flint Hills that 

would eventually lead to an irreversible loss of both 

species, and habitat could be minimized under the 

proposed action. 

With the restrictions on residential and commercial 

infrastructure development on conservation 

easement lands, prescribed fire could be more easily 

utilized to maintain tallgrass prairie. Prescribed 
Chapter 4 —Environmental Consequences 29

fire is necessary to limit tree encroachment and to 

maintain tallgrass prairie habitat for the greater 

prairie-chicken and other grassland bird species, and 

to prevent an irreversible loss of habitat.

SHORT-TERM USE VERSUS LONG-TERM 

PRODUCTIVITY

This section describes the short-term effects versus 

long-term production from the expected actions in 

alternatives A and B.

Alternative A (No Action)

Ranches may be sold to developers for short-term 

gains, which would have a negative impact on the 

long-term biological productivity of the area. 

Over the long-term, the costs to counties to sustain 

development in rural areas could be significant (see 

the “Landownership and Land Use” section on 

page 27). Wind energy development, and oil and gas 

development would provide short-term income gains, 

but would have a long-term adverse impact on the 

tallgrass ecosystem.

Alternative B (Proposed Action) 

The proposed conservation easement program would 

maintain the long term biological productivity of the 

Flint Hills prairie grassland and riparian ecosystems, 

increased protection of endangered and threatened 

species, and maintenance of biological diversity. 

The nation would gain the protection of tallgrass 

prairie species for future generations of Americans. 

The public would gain long term opportunities for 

wildlife dependent recreational activities. 

Greater prairie-chicken.

USFWS

CUMULATIVE IMPACTS

Cumulative impacts are defined by NEPA policy as 

the impacts on the environment which result from 

the incremental impact of the action when added 

to other past, present, and reasonably foreseeable 

future actions regardless of what agency (federal or 

non-federal) or person undertakes such other actions 

(40 CFR § 1508.7) 

This section describes the cumulative impacts on the 

environment that may result from the combination 

of reasonably foreseeable actions in alternatives A or 

B, together with other biological and socioeconomic 

conditions, events, and developments.

Past Actions 

Past land protection efforts within the Flint Hills 

ecoregion have included the establishment of the 

Tallgrass Prairie National Preserve in 1996 by 

the National Park Service; the U.S. Department 

of Agriculture Grassland Reserve Program which 

currently holds approximately 17,000 acres of 

easements; an informal moratorium on wind 

development by a past governor; and the acquisition 

of approximately 35,000 acres of conservation 

easements by nonprofit organizations. The PFW 

program has worked with private landowners to 

restore or enhance 349,342 acres of tallgrass prairie 

to date.

Present Actions 

The Service’s proposed action to establish an 

approximately (but not to exceed) 1.1 million acre 

conservation easement program is the only known 

present action of similar scope and scale for land 

protection in the Kansas portion of the Flint Hills 

ecoregion. Once approved, it will take a number of 

years for the program to begin to have a noticeable 

effect. Securing initial funding and completing real 

estate transactions will take time. 

Reasonably Foreseeable Future Actions 

Reasonably foreseeable actions are actions and 

activities that are independent of the conservation 

area proposed action but could result in cumulative 

or additive effects when combined with the proposed 

alternatives. They are anticipated to occur regardless 

of which alternative is selected. Energy (oil and 

gas, and wind) and residential development, and 

future prairie conservation efforts by a variety of 

organizations are the primary, reasonably foreseeable 

actions occurring in the Flint Hills region.
30 EA, Flint Hills Legacy Conservation Area, KS

Oil and Gas Development

Kansas ranks among the top 10 crude oil producing 

states with production occurring throughout the 

state. In addition, Kansas also produces a substantial 

quantity of natural gas, and its infrastructure 

is a transportation hub for supplies moving 

throughout the country. (U.S. Energy Information 

Administration 2010)

Wind Energy Development

Over 89% of Kansas has been determined by 

National Renewable Energy Lab (NREL) to show 

potential for development of wind energy (National 

Renewable Energy Laboratory 2010). Second only 

to Nebraska, Kansas has extremely high wind 

energy potential with 47.1 million acres (190,474 

km2) available with the installed capacity of 952,371 

megawatts and an annual generation of 3.7 million 

gigawatt-hours. The FHLCA proposed the creation 

of a program to acquire conservation easements on 

up to 1.1 million acres, which represents 0.21% of the 

national or 2.34% of Kansas’ total wind potential.

Current estimates of windy land area and wind 

energy potential developed by the NREL state that 

approximately 517 million acres (2.092 million km2) 

of land within the 48 contiguous states of the United 

States have an installed capacity of 10.5 million 

megawatts and an annual generation of 36.9 million 

gigawatt-hours.

Residential Development

Total land in farms in Kansas from 1969 to 2007 

declined from about 49.4 million acres to about 46.3 

million acres, a decrease of more than 6 percent, 

while the urban population in the state increased 

from 1.29 million people to 1.8 million people between 

1980–2009 (USDA 2010). As urban areas spread into 

the surrounding prairie areas, the tallgrass habitat 

becomes increasingly fragmented by trees and 

buildings and roads.

Other Conservation Efforts

Ongoing efforts by a variety of organizations and 

agencies including TNC, RTK, TLA, Natural Resources 

Conservation Service (NRCS), and PFW have led to 

the successful conservation of approximately 35,000 

acres of tallgrass prairie, and the enhancement and 

restoration of another 349,342 acres. Based on potential 

success of the proposed action in achieving land 

protection, it is anticipated that the Service will also 

consider protecting lands in Oklahoma within the Flint 

Hills (Osage Plains) ecoregion. The Kansas Legislature 

may continue to consider a large-scale moratorium on 

wind development within the Flint Hills. Currently, 

there is not a solid base for analysis, and it would 

therefore be speculative to try to determine any 

effects in relation to the proposed action. The Service 

does not plan additional land protection in eastern 

Kansas beyond existing programs at the Marais des 

Cygnes NWR and a smaller set of options being 

explored to preserve some lands along the Missouri 

River. Lastly, we expect nonprofit organizations to 

continue to be active in the Flint Hills ecoregion, 

but based on past experience, it is anticipated that 

their role will shift in part from easement acquisition 

to a partnership in achieving the Service’s goal of 

protecting up to 1.1 million acres.

DEVELOPMENT—ALTERNATIVE A 

(NO ACTION)

The incremental increases in infrastructure 

construction resulting from development activities 

(oil and gas, wind and residential) in the Flint Hills 

will likely result in the fragmentation of habitat 

currently utilized by grassland-dependent wildlife. 

Over the long-term, the combined effect of these 

activities will likely result in the continuation, and 

possibly the acceleration, of the decline of grassland 

bird populations. 

DEVELOPMENT—ALTERNATIVE B 

(PROPOSED ACTION) 

The proposed alternative will protect up to 1.1 

million acres of tallgrass prairie from the combined 

effects of various future development activities by 

precluding surface occupancy, and the resultant 

infrastructure from fragmenting tallgrass habitat. 

The Service’s proposed FHLCA is the only presently 

known action of similar scope and scale that is 

seeking landscape-scale conservation of the tallgrass 

prairie in the Flint Hills.

CONSERVATION EFFORTS—

ALTERNATIVE A (NO ACTION)

Current Service programs such as Partners for Fish 

and Wildlife would continue within the conservation 

project area. The Service would continue to work 

cooperatively with landowners to voluntarily 

improve habitat on private land. 

CONSERVATION EFFORTS—

ALTERNATIVE B (PROPOSED ACTION) 

Through the proposed easement program, up to 

1,100,000 acres of privately owned native tallgrass 

prairie habitats would be added to the 31,000 acres 

within the project area that already have some level 

of protection. This would have long term positive 

impacts on wildlife habitat and result in the long 

term conservation of migratory birds, threatened and 

endangered species, native plants, and the overall 

biological diversity of the Flint Hills tallgrass prairie.
5 Coordination and Environmental Review

The Service coordinated within the agency, as well 

as with other federal agencies and local agencies, 

while developing this environmental assessment. 

The analysis and documentation was prepared by a 

combination of field and regional Service staff, along 

with partners (refer to appendix B). In addition, the 

coordination effort for contaminants and hazardous 

materials is described below.

The Service conducted this environmental analysis 

under the authority of the National Environmental 

Policy Act. The resulting document will be 

distributed to the project mailing list; copies can 

be requested. Appendix C contains the Finding 

of No Significant Impact, appendix D contains the 

Compliance Certificate, appendix E contains the 

Level 1 Report, and appendix F contains the Section 

7 Biological Evaluation. 

AGENCY COORDINATION

The Service has discussed the proposal to establish 

the Flint Hills Legacy Conservation Area with 

landowners; conservation organizations; other federal 

agencies; tribal, state, and county governments; and 

other interested groups and individuals. 

The Service held six public meetings to provide 

information and discuss the proposal with 

landowners and other interested citizens. 

Information on the FHLCA project has been made 

available to county commissioners in each of the 

twenty-one counties included in the project area. 

At the federal level, Service staff has briefed 

Senators Brownback and Roberts, as well as the 

Congressional delegation, and coordinated with 

representatives from other federal agencies such 

as the U.S. Department of Agriculture (Natural 

Resources Conservation Service), Department of 

Defense (Fort Riley Army Installation), National 

Park Service, and the Environmental Protection 

Agency. At the state level, Governor Parkinson’s 

staff and Kansas’ State Congressional delegation, 

along with KDWP, were briefed on the project. In 

addition, the Service provided information to eleven 

tribes on this project. 

Nongovernmental conservation groups are vital to 

the success of the proposed project. Service staff has 

coordinated with partner organizations such as The 

Nature Conservancy, Tallgrass Legacy Alliance, The 

Ranchland Trust of Kansas, and Kansas Land Trust.

Appendix G lists the comments and responses from 

the public review.

CONTAMINANTS AND HAZARDOUS 

MATERIALS

Fieldwork for the pre acquisition contaminant 

surveys would be conducted on a tract-by-tract 

basis, prior to the purchase of any land interest. 

Any suspected problems or contaminants 

requiring additional surveys would be referred to 

a contaminants specialist located in the Service’s 

ecological services office in Manhattan, Kansas.

NATIONAL ENVIRONMENTAL POLICY 

ACT

As a federal agency, the Service must comply with 

provisions of the National Environmental Policy Act. 

An environmental assessment is required under the 

act to evaluate reasonable alternatives that will meet 

stated objectives, and to assess the possible impacts 

to the human environment. The environmental 

assessment serves as the basis for determining 

whether implementation of the proposed action 

would constitute a major federal action significantly 

affecting the quality of the human environment. 

The analysis for, and development of this 

environmental assessment, facilitated the 

involvement of government agencies and the public 

in the decision-making process. 

STRATEGIC HABITAT CONSERVATION 

AND LANDSCAPE CONSERVATION 

COOPERATIVES 

Strategic habitat conservation (SHC) is a means 

of applying adaptive management across large 

landscapes. Landscape conservation cooperatives 

will facilitate strategic habitat conservation (USFWS 

2008).

Strategic Habitat Conservation

The FHLCA will apply the strategic habitat 

conservation framework as outlined in the National 

Ecological Assessment Team report. SHC involves 

an ongoing cycle of biological planning, conservation 

design, conservation delivery, outcome-based 
32 EA, Flint Hills Legacy Conservation Area, KS

monitoring, and assumption-based research. It is 

also the process by which the Service continues to 

develop and apply science focused on improving 

the ability to apply conservation delivery actions 

which results in landscapes capable of supporting 

populations of priority species at desired levels. 

Additionally, SHC provides the framework by which 

the Service develops and applies science to inform 

and continually improve conservation delivery 

by addressing landscape-level population limiting 

factors in an adaptive manner.

The U.S. Fish and Wildlife Service Region 6 Refuges 

Program has co-located Habitat and Population 

Evaluation Team Office of Conservation Science 

(HAPET) staff and equipment at Flint Hills NWR 

to provide support for the biological planning, 

conservation design, conservation delivery, and 

monitoring/research elements of SHC necessary to 

implement the FHLCA project. The preparation of 

the Flint Hills project environmental assessment 

addresses the four key elements of strategic habitat 

conservation: planning, design, delivery, and 

monitoring and research. 

Biological Planning

Trust resources have been described in earlier 

chapters of this document. Biological planning 

requires the identification of priority species, 

development of population objectives, and 

identification of landscape-level limiting factors 

keeping priority trust species populations below 

desired levels. Initial biological planning will be 

conducted using the greater prairie-chicken as a focal 

species. This approach is based on the assumption 

that delivery of grassland conservation easements 

targeted at minimizing and reducing population 

limiting factors of greater prairie-chicken will also 

adequately address the limiting factors of priority 

grassland dependent federal trust species (that 

is dickcissel, grasshopper sparrow, Henslow’s 

sparrow, upland sandpiper) throughout the Flint 

Hills ecoregion. Conceptual and quantitative models 

will be developed predicting greater prairie-chicken 

population response to landscape-level habitat 

conditions to aid in initial conservation design 

and delivery efforts. Priority species, along with 

associated population goals, will continually be 

defined and updated throughout the implementation 

of this project, and additional landscape models will 

be developed for priority trust species.

Conservation Design

Service biologists identified and mapped the core 

area containing the highest quality, least fragmented 

tallgrass habitat within the Flint Hills of Kansas 

(see figure 2 in chapter 1). This remaining tallgrass 

prairie runs between the southern and northern 

borders of the state, and is as narrow as 20 miles 

wide, constrained on the east and west by tillage 

agriculture. This narrow north-south corridor reflects 

the shape of the remaining intact Flint Hills tallgrass. 

The identification of priority grasslands for inclusion 

in the project area was based on a conceptual model 

representing greater prairie-chicken response 

to landscape-level habitat conditions. Using a 

geographic information system (GIS) and existing 

data from the National Land Cover Database 

(NLCD) (Homer et al. 2007) an 800 meter moving 

window analysis was applied to all grassland habitat 

within the Flint Hills ecoregion. All areas consisting 

of >95% grassland were selected as potential priority 

areas. The selection of a 95% grassland threshold is 

similar to that used for development of a Grassland 

Bird Conservation Area (GBCA) conceptual model 

which was found to be very effective at identifying 

priority areas for some grassland birds in the Prairie 

Pothole Region. Applying the greater prairie-chicken 

conceptual model to NLCD 2001 land cover data 

resulted in a spatially explicit decision support tool 

identifying approximately 3.3 million acres of priority 

grassland within the Flint Hills ecoregion.

The following assumptions are associated with the 

conceptual model used to identify priority grasslands 

for the FHLCA project area:

1. The greater prairie-chicken is an appropriate 

focal species for other Service priority trust 

species in the Flint Hills ecoregion.

2. The greater prairie-chicken serves as a focal 

species and adequately represents habitat 

requirements for priority federal trust species, 

which are below desired population levels or 

declining (as measured by some population 

response metric such as probability of 

occurrence, density, survival, recruitment, or 

population persistence). Potential declining 

priority federal trust species include dickcissel, 

grasshopper sparrow, Henslow’s sparrow, 

upland sandpiper, and other species that may be 

deemed appropriate when data are obtained.

3. The greater prairie-chicken responds to 

landscapes as quantified with an 800-meter 

radius.

4. The greater prairie-chicken show the strongest 

response to landscapes with >95% grassland 

habitat.

5. NLCD 2001 land cover data adequately 

represents Flint Hills landscape conditions.

New decision support tools will be developed 

through refinements of the greater prairiechicken model, additions of new priority species, 

development of additional priority species models, 

setting of population objectives, and evaluations 

of conservation delivery through the elements 

of biological planning, conservation delivery, and 

monitoring and research. These new tools may result 

in challenges to currently held paradigms about 

the best conservation approach for target species 

(Reynolds et al. 2001).
Chapter 5 — Coordination and Environmental Review 33

Conservation Delivery

Partners for Fish and Wildlife biologists have worked 

for years developing partnerships that provide the 

foundation for a successful easement program. The 

ongoing involvement of the PFW program, and the 

many partner organizations and agencies will be 

essential for the effective delivery of sustainable 

conservation program. Application of the SHC 

framework will build on existing partnerships and 

support the development of new partnerships for 

delivering conservation throughout the Flint Hills 

ecoregion. Results from the biological planning and 

conservation design elements will be used to target 

conservation delivery, while the monitoring and 

research element will evaluate the effectiveness 

and improve conservation delivery over time. The 

biological planning element will engage partners 

in the identification of priority species, population 

objectives, and the development of biological models 

which will be directly linked to conservation delivery 

actions. The conservation design element will involve 

the development of spatially explicit decision support 

tools for targeting conservation delivery actions. 

These spatially explicit decision support tools, which 

can be tailored to specific treatments or locations 

based on the priorities and needs of different 

partners, will allow for greater flexibility, increased 

responsiveness, and improved efficiency in meeting 

Service and partner conservation delivery needs.

Monitoring and Research

Monitoring and research efforts for the FHLCA will 

use model-based approaches to measure conservation 

effectiveness and will focus on three key areas:

■ Developing, improving, and assessing landscape 

models for priority trust species. Emphasis 

will be placed on the highest priority species 

with the greatest degree of uncertainty 

regarding limiting factors and the effectiveness 

of management actions at minimizing and 

reducing limiting factors. Data from existing 

surveys such as the Breeding Bird Survey 

will be evaluated and incorporated into spatial 

models. When necessary, additional data will 

be collected to evaluate assumptions used in 

the modeling process and assessments will 

be adjusted accordingly. These methods will 

provide an estimate of population response of 

trust species on project (easement) lands and 

on non-easement properties. Similar modeling 

approaches may be developed or incorporated 

for priority non-trust species (for example, 

greater prairie-chicken) in cooperation 

with partners such as nongovernmental 

organizations and universities.

■ Evaluating assumptions and addressing 

uncertainties identified through the 

biological planning, conservation design, 

and conservation delivery elements. When 

warranted, assumptions such as increased 

nesting success in larger blocks of grass will 

be evaluated in cooperation with partners 

such as nongovernmental organizations and 

universities. 

■ Assessing the contribution of grassland 

conservation easements and other management 

actions toward meeting population goals 

for priority trust species. Spatially explicit 

models will allow estimation of population size 

on conservation easements and other land 

parcels of interest. This will allow the Service 

and conservation partners to evaluate the 

contribution of the program to the meeting of 

population goals, and to refine conservation 

delivery to ensure maximum efficiency. 

Spatially explicit models will also enable the 

Service to demonstrate the contribution of the 

FHLCA to national and continental population 

goals for priority species similar to how the 

HAPET office and cooperators have assessed 

the contribution of landscape-level conservation 

in the Prairie Pothole Region (See Reynolds et 

al. 2001, Reynolds et al. 2006 and Niemuth et al. 

2009). 

Landscape Conservation Cooperatives

The Service will use landscape conservation 

cooperatives (LCCs) as a means of implementing 

strategic habitat conservation. LCCs will be 

formal science and management partnerships 

between the Service, U.S. Geological Survey, other 

federal agencies, states, tribes, nongovernmental 

organizations, universities, and others to increase 

applied conservation science capacity in support 

of fish and wildlife management within specific 

landscapes (Secretarial Order Number 3289). The 

tools developed by the LCCs will allow Service 

offices, and our many partners, to implement on-theground actions in the most effective locations to meet 

their goals. 

The FHLCA is part of the Tallgrass Prairie and 

Big Rivers LCC, which is in the process of being 

developed. This project meets the criteria of 

the LCC initiative—cooperation among private 

landowners and other agencies (federal, state, local, 

and nongovernmental organizations). In addition to 

fostering partnerships, these cooperatives provide 

science support to managers. The FHLCA will 

benefit from much of the science generated by the 

Konza Prairie Long-Term Ecological Research site. 

This land is owned by The Nature Conservancy, but 

is operated under an agreement with Kansas State 

University. The FHLCA would receive further 

science support from the Geographic Information 

System capacity at the Service’s Ecological Services 

Office in Manhattan, Kansas. As a final support 

for the strategic habitat conservation approach 

to conservation, it is notable that the Flint Hills 

represents the largest intact tallgrass prairie within 
34 EA, Flint Hills Legacy Conservation Area, KS

the Geographic Framework of Bird Conservation 

Region #22, a treasured landscape.

The Secretary of the Interior recently outlined the 

importance of landscape conservation cooperatives 

as a response to climate change (USFWS 2009). 

Landscape conservation cooperatives reach across 

broad landscapes, involve many partners, and 

function at a scale necessary to address wildlife 

adaptation in response to climate change. The 

FHLCA would link existing Flint Hills conservation 

easement areas held by The Nature Conservancy 

and the U.S. Department of Agriculture. The Council 

Grove Wildlife Area (KDWP) also manages land 

within the easement boundary. 

These cooperatives will continue to grow as a 

means of delivering strategic habitat conservation. 

The Service and U.S. Geological Survey signed a 

memorandum of understanding to strengthen the 

science–management relationship in landscape-level 

conservation. This further commitment to strategic 

habitat conservation improves the stature for the 

type of landscape conservation being proposed for 

the Flint Hills Legacy Conservation Area. 

DISTRIBUTION AND AVAILABILITY

Copies of the environmental assessment were sent 

to federal and state legislative delegations, tribes, 

agencies, landowners, private groups, and other 

interested individuals.

Additional copies of the document are available from 

the following offices and websites.

U.S. Fish and Wildlife Service

Flint Hills National Wildlife Refuge

530 West Maple Avenue

Hartford, Kansas 66854

620/392 5553

http://flinthills.fws.gov

U.S. Fish and Wildlife Service 

Region 6, Division of Refuge Planning

Branch of Land Protection Planning

P.O. Box 25486–DFC

Denver, Colorado 80225 

303/236 4345

303/236 4792 fax

http://mountain-prairie.fws.gov/planning/lpp.htm
Appendix A

List of Plants and Animals

PLANTS

SCIENTIFIC NAME COMMON NAME

Acanthaceae Acanthus Family

Dicliptera brachiata dicliptera

Justicia americana water willow

Ruellia humilis fringeleaf ruellia

Ruellia strepens limestone ruellia

Aceraceae Maple Family

Acer negundo boxelder

Acer saccharinum silver maple

Acorus calamus calamus sweetflag

Adiantaceae Fern Family

Argyrochosma dealbata powdery cloak fern

Cheilanthes lanosa hairy lip fern

Pellaea atropurpurea purple cliff-brake

Pellaea glabella ssp. glabella smooth cliffbrake

Agavaceae Agave Family

Yucca arkansana Arkansas soapweed

Yucca filamentosa limp soapweed

Yucca glauca small soapweed

Alismataceae Water Plantain Family

Alisma subcordatum smallflower water plantain

Alisma triviale northern water-plantain

Echinodorus berteroi erect burhead

Echinodorus cordifolius creeping burhead

Sagittaria brevirostra short-beak arrowhead

Sagittaria graminea var. graminea grassy arrowhead

Sagittaria latifolia common arrowhead

Sagittaria montevidensis ssp. calycina giant arrowhead

Amaranthaceae Pigweed Family

Amaranthus albus tumbleweed amaranth

Amaranthus arenicola sandhill pigweed

Amaranthus blitoides prostrate pigweed

Amaranthus hybridus slender pigweed

Amaranthus palmeri Palmer’s pigweed

Amaranthus retroflexus rough pigweed
36 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Amaranthus rudis water hemp

Amaranthus tuberculatus tall water-hemp

Froelichia gracilis slender snakecotton

Iresine rhizomatosa bloodleaf

Anacardiaceae Sumac Family

Rhus aromatica fragrant sumac

Rhus copallinum dwarf sumac

Rhus glabra smooth sumac

Toxicodendron radicans ssp. negundo poison-ivy

Annonaceae Custard-apple Family

Asimina triloba Pawpaw

Apiaceae Parsley Family

Ammoselinum popei plains sand parsley

Berula erecta var. incisa cut-leaf water-parsnip

Bupleurum rotundifolium thoroughwax

Chaerophyllum procumbens spreading chervil

Chaerophyllum tainturieri erect chervil

Cicuta maculata common water hemlock

Conium maculatum poison-hemlock

Cryptotaenia canadensis honewort

Daucus carota Queen Anne’s lace

Eryngium leavenworthii Leavenworth’s eryngo

Eryngium yuccifolium button snakeroot

Lomatium foeniculaceum fennel-leaf desert-parsley

Osmorhiza longistylis long-style sweet-cicley

Pastinaca sativa garden parsnip

Polytaenia nuttallii prairie parsley

Sanicula canadensis var. canadensis Candian sanicle

Sanicula odorata cluster sanicle

Spermolepis inermis spreading spermolepis

Torilis arvensis hedge parsley

Zizia aurea golden zizia

Apocynaceae Dogbane Family

Apocynum cannabinum hemp dogbane

Vinca major periwinkle

Vinca minor common periwinkle

Araceae Arum Family

Arisaema dracontium green dragon

Arisaema triphyllum ssp. triphyllum Indian Jack-in-the-pulpit

Peltandra virginica Virginia arum

Pistia stratiotes water lettuce

Asclepiadaceae Milkweed Family

Asclepias amplexicaulis bluntleaf milkweed
Appendix A — List of Plants and Animals 37

SCIENTIFIC NAME COMMON NAME

Asclepias asperula ssp. capricornu milkweed

Asclepias incarnata ssp. incarnata swamp milkweed

Asclepias pumila plains milkweed

Asclepias speciosa showy milkweed

Asclepias stenophylla narrow-leaf milkweed

Asclepias sullivantii Sullivant’s milkweed

Asclepias syriaca common milkweed

Asclepias tuberosa ssp. interior buttefly milkweed

Asclepias verticillata whorled milkweed

Asclepias viridiflora green milkweed

Asclepias viridis green milkweed

Cynanchum laeve climbing milkweed

Vincetoxicum nigrum Louise’s swallow-wort

Aspleniaceae Fern Family

Asplenium platyneuron ebony spleenwort

Asplenium resiliens black-stemmed spleenwort

Asplenium rhizophyllum walking fern

Asplenium trichomanes ssp. trichomanes maidenhair spleenwort

Asteraceae Aster Family

Achillea millefolium western yarrow

Acroptilon repens Russian knapweed

Ageratina altissima white snakeroot

Ambrosia artemisiifolia common ragweed

Ambrosia bidentata lanceleaf ragweed

Ambrosia psilostachya western ragweed

Ambrosia trifida giant ragweed

Amphiachyris dracunculoides annual broomweed

Antennaria neglecta field pussytoes

Antennaria parlinii ssp. fallax Parlin’s pussytoes

Anthemis cotula camomile

Arctium minus common burdock

Arnoglossum atriplicifolium pale Indian-plantain

Arnoglossum plantagineum tuberous Indian-plantain

Artemisia ludoviciana Louisiana sagewort

Bidens aristosa var. retrorsa bearded beggarticks

Bidens bipinnata Spanish needles

Bidens cernua nodding beggartick

Bidens comosa leafybract beggartick

Bidens frondosa devil’s beggartick

Bidens vulgata tall beggartick

Boltonia asteroides white doll’s daisy

Brickellia eupatorioides var. corymbulosa false boneset

Carduus nutans musk-thistle
38 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Centaurea cyanus bachelor‘s-button

Chrysanthemum leucanthemum ox-eye daisy

Chrysopsis pilosa soft goldenaster

Cichorium intybus common chicory

Cirsium altissimum tall thistle

Cirsium arvense Canada thistle

Cirsium undulatum wavyleaf thistle

Cirsium vulgare bull thistle

Conyza canadensis Canada horseweed

Conyza ramosissima lawn horseweed

Coreopsis grandiflora bigflower coreopsis

Coreopsis palmata finger coreopsis

Cyclachaena xanthifolia bur-weed marshelder

Diaperia prolifera var. prolifera bighead pygmy cudweed

Dyssodia papposa foetid dogweed

Echinacea angustifolia narrow-leaf purple-coneflower

Echinacea atrorubens Topeka purple coneflower

Echinacea pallida pale purple coneflower

Echinacea purpurea purple coneflower

Eclipta prostrata yerba de tajo

Engelmannia peristenia Engelmann’s daisy

Erechtites hieraciifolia American burnweed

Erigeron annuus annual fleabane

Erigeron philadelphicus Philadelphia fleabane

Erigeron strigosus daisy fleabane

Eupatorium altissimum tall joe-pye-weed

Eupatorium perfoliatum boneset

Eupatorium serotinum late eupatorium

Euthamia gymnospermoides viscid euthamia

Gaillardia pulchella rose ring gaillardia

Grindelia ciliata —

Grindelia lanceolata spinytooth gumweed

Grindelia squarrosa curly-cup gumweed

Helenium amarum bitter sneezeweed

Helenium autumnale common sneezeweed

Helianthus annuus common sunflower

Helianthus ciliaris texas blueweed

Helianthus grosseserratus sawtooth sunflower

Helianthus hirsutus hairy sunflower

Helianthus maximiliani Maximilian‘s sunflower

Helianthus mollis ashy sunflower

Helianthus pauciflorus var. pauciflorus stiff sunflower

Helianthus petiolaris prairie sunflower
Appendix A — List of Plants and Animals 39

SCIENTIFIC NAME COMMON NAME

Helianthus salicifolius willowleaf sunflower

Helianthus tuberosus Jerusalem artichoke

Helianthus X kellermanii —

Helianthus X laetiflorus —

Heliopsis helianthoides var. occidentalis smooth oxeye

Heliopsis helianthoides var. scabra smooth oxeye

Heterotheca canescens goldenaster

Heterotheca latifolia broad-leaf golden-aster

Heterotheca stenophylla var. angustifolia narrow-leaf golden-aster

Heterotheca subaxillaris ssp. latifolia camphorweed

Hieracium gronovii Gronovius’ hawkweed

Hieracium longipilum longbeard hawkweed

Hymenopappus scabiosaeus var. corymbosus flat-top woolly-white

Iva annua annual sumpweed

Krigia cespitosa common dwarf dandelion

Lactuca canadensis Canada lettuce

Lactuca floridana Florida lettuce

Lactuca ludoviciana Louisiana lettuce

Lactuca saligna willowleaf lettuce

Lactuca serriola prickly lettuce

Leucanthemum vulgare common ox-eye daisy

Liatris aspera rough gayfeather

Liatris mucronata pointed gayfeather

Liatris punctata dotted gayfeather

Liatris pycnostachya thickspike gayfeather

Liatris squarrosa var. hirsuta —

Matricaria discoidea disc mayweed

Microseris cuspidata prairie false dandelion

Packera plattensis plains groundsel

Packera pseudaurea var. semicordata false golden ragwort

Parthenium integrifolium var. hispidum wild quinine

Pluchea odorata purple marsh-fleabane

Prenanthes aspera rough rattlesnakeroot

Pseudognaphalium obtusifolium fragrant false-cudweed

Pyrrhopappus carolinianus Carolina false dandelion

Pyrrhopappus grandiflorus tuberous false dandelion

Ratibida columnifera yellow prairie coneflower

Ratibida pinnata grayhead prairie coneflower

Rudbeckia amplexicaulis clasping coneflower

Rudbeckia hirta var. pulcherrima black-eyed Susan

Rudbeckia laciniata cutleaf coneflower

Rudbeckia triloba brown-eyed Susan

Senecio plattensis plains groundsel
40 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Silphium integrifolium whole-leaf rosinweed

Silphium laciniatum compass plant

Silphium perfoliatum cup plant

Silphium speciosum whole-leaf rosinweed

Solidago altissima —

Solidago altissima var. altissima —

Solidago canadensis var. hargeri Canadian goldenrod

Solidago delicatula —

Solidago gigantea Late goldenrod

Solidago missouriensis Missouri goldenrod

Solidago nemoralis gray goldenrod

Solidago petiolaris downy goldenrod

Solidago rigida ssp. rigida stiff goldenrod

Solidago speciosa —

Solidago ulmifolia —

Sonchus arvensis ssp. uliginosus —

Sonchus asper prickly sowthistle

Symphyotrichum divaricatum southern annual saltmarsh aster

Symphyotrichum drummondii Drummond’s aster

Symphyotrichum ericoides var. ericoides white heath aster

Symphyotrichum hesperium lance-leaf aster

Symphyotrichum laeve var. laeve smooth aster

Symphyotrichum lanceolatum var. lanceolatum lance-leaf aster

Symphyotrichum novae-angliae New England aster

Symphyotrichum oblongifolium aromatic aster

Symphyotrichum oolentangiense azure aster

Symphyotrichum parviceps Smallhead aster

Symphyotrichum patens var. gracile spreading aster

Symphyotrichum pilosum frost-weed aster

Symphyotrichum praealtum var. praealtum willowleaf aster

Symphyotrichum sericeum silky aster

Taraxacum laevigatum red-seeded dandelion

Taraxacum officinale common dandelion

Thelesperma filifolium var. filifolium —

Thelesperma megapotamicum Rio Grande greenthread

Tragopogon dubius western salsify

Tragopogon porrifolius oyster salsify

Verbesina alternifolia wingstem crownbeard

Verbesina encelioides ssp. exauriculata —

Verbesina virginica white crownbeard

Vernonia arkansana Arkansas ironweed

Vernonia baldwinii ssp. baldwinii western ironweed

Vernonia fasciculata —
Appendix A — List of Plants and Animals 41

SCIENTIFIC NAME COMMON NAME

Xanthium strumarium common cocklebur

Azollaceae Water Fern Family

Azolla mexicana Mexican mosquito fern

Balsaminaceae Touch-me-not Family

Impatiens capensis spotted touch-me-not

Berberidaceae Barberry Family

Berberis thunbergii Japanese barberry

Podophyllum peltatum may-apple

Betulaceae Birch Family

Corylus americana American hazelnut

Ostrya virginiana hop-hornbeam

Bignoniaceae Trumpet-creeper Family

Campsis radicans trumpet creeper

Catalpa bignonioides common catalpa

Catalpa speciosa catalpa

Boraginaceae Borage Family

Cynoglossum officinale common hounds’-tongue

Hackelia virginiana Virginia stickseed

Heliotropium tenellum pasture heliotrope

Lappula redowskii flatspine stickseed

Lappula squarrosa European stickseed

Lithospermum arvense corn gromwell

Lithospermum canescens hoary gromwell

Lithospermum incisum plains gromwell

Myosotis verna Virginia forget-me-not

Onosmodium bejariense var. occidentale western marbelseed

Brassicaceae Mustard Family

Alliaria petiolata garlic mustard

Barbarea vulgaris bitter wintercress

Boechera canadensis sicklepod

Brassica juncea Indian mustard

Brassica nigra black mustard

Camelina microcarpa small-seeded false flax

Capsella bursa-pastoris shepherd‘s purse

Cardamine concatenata toothwort

Cardamine parviflora var. arenicola —

Chorispora tenella blue mustard

Conringia orientalis hare’s-ear mustard

Descurainia intermedia pinnate tansy-mustard

Descurainia pinnata pinnate tansy-mustard

Descurainia sophia flixweed

Diplotaxis muralis sand rocket

Draba brachycarpa shortpod draba
42 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Draba cuneifolia wedgeleaf draba

Draba reptans white whitlow-wort

Erysimum asperum plains wallflower

Erysimum repandum bushy wallflower

Hesperis matronalis dame’s rocket

Iodanthus pinnatifidus purple rocket

Lepidium campestre field peppergrass

Lepidium densiflorum peppergrass

Lepidium draba —

Lepidium oblongum oblong pepper-grass

Lepidium virginicum Virginia peppergrass

Microthlaspi perfoliatum —

Nasturtium officinale common watercress

Physaria gordonii ssp. gordonii —

Physaria gracilis ssp. nuttallii —

Rorippa fernaldiana —

Rorippa palustris ssp. fernaldiana —

Rorippa sessiliflora stalkless yellowcress

Rorippa sinuata spreading yellowcress

Sibara virginica Virginia rockcress

Sinapis arvensis wild mustard

Sisymbrium altissimum tumble-mustard

Thlaspi arvense field pennycress

Thlaspi perfoliatum thorowort pennycress

Cactaceae Cactus Family

Coryphantha missouriensis Missouri foxtail cactus

Opuntia macrorhiza bigroot prickly pear

Callitrichaceae Water-starwort Family

Callitriche heterophylla —

Callitriche terrestris —

Campanulaceae Bellflower Family

Campanula americana American bellflower

Lobelia cardinalis cardinal flower

Lobelia siphilitica great lobelia

Lobelia spicata palespike lobelia

Triodanis biflora —

Triodanis holzingeri —

Triodanis leptocarpa slender-fruit Venus’-looking-glass

Triodanis perfoliata clasping-leaf Venus’-looking-glass

Cannabaceae Hemp Family

Cannabis sativa domestic hemp

Humulus japonicus Japanese hops

Humulus lupulus var. pubescens —
Appendix A — List of Plants and Animals 43

SCIENTIFIC NAME COMMON NAME

Capparaceae Caper Family

Polanisia dodecandra ssp. trachysperma —

Caprifoliaceae Honeysuckle Family

Lonicera flava yellow honeysuckle

Lonicera japonica Japanese honeysuckle

Lonicera maackii Maack’s honeysuckle

Lonicera morrowii —

Lonicera sempervirens trumpet honeysuckle

Lonicera tatarica tatarian honeysuckle

Sambucus canadensis common elderberry

Symphoricarpos orbiculatus buckbrush

Triosteum perfoliatum clasping horse-gentian

Viburnum prunifolium blackhaw

Viburnum rufidulum rusty blackhaw

Caryophyllaceae Pink Family

Arenaria serpyllifolia thyme-leaved sandwort

Arenaria serpyllifolia var. serpyllifolia thyme-leaved sandwort

Cerastium brachypodum shortstalk cerastium

Cerastium fontanum ssp. vulgare —

Cerastium pumilum —

Dianthus armeria Deptford pink

Holosteum umbellatum jagged chickweed

Minuartia patula —

Paronychia fastigiata var. fastigiata forked nailwort

Saponaria officinalis bouncingbet

Silene antirrhina sleep catchfly

Silene latifolia —

Silene stellata starry campion

Stellaria media chickweed

Stellaria pallida pale chickweed

Celastraceae Bittersweet Family

Celastrus scandens American bittersweet

Euonymus atropurpurea wahoo

Euonymus fortunei Chinese wintercreeper

Ceratophyllaceae Hornwort Family

Ceratophyllum demersum common hornwort

Ceratophyllum echinatum prickly hornwort

Chenopodiaceae Goosefoot Family

Chenopodium album lamb’s-quarters

Chenopodium berlandieri var. zschackii pit-seed goosefoot

Chenopodium glaucum oak-leaved goosefoot

Chenopodium missouriense Missouri goosefoot

Chenopodium pallescens pale goosefoot
44 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Chenopodium pratericola field goosefoot

Chenopodium simplex maple-leaf goosefoot

Chenopodium standleyanum Standley’s goosefoot

Cycloloma atriplicifolium winged pigweed

Dysphania ambrosioides worm-seed goosefoot

Dysphania anthelmintica wormseed

Kochia scoparia broom kochia

Monolepis nuttalliana Nuttall’s poverty-weed

Salsola collina Russian thistle

Salsola iberica —

Cistaceae Rock-rose Family

Helianthemum bicknellii Bicknell’s frostweed

Lechea tenuifolia narrowleaf pinweed

Clusiaceae Mangosteen Family

Hypericum drummondii nits-and-lice

Hypericum perforatum common St. John’s-wort

Hypericum punctatum spotted St. John’s-wort

Hypericum sphaerocarpum round-fruit St. John’s-wort

Commelinaceae Spiderwort Family

Commelina erecta erect dayflower

Tradescantia bracteata bracted spiderwort

Tradescantia occidentalis prairie spiderwort

Tradescantia ohiensis Ohio spiderwort

Tradescantia tharpii Tharp’s spiderwort

Convolvulaceae Morning-glory Family

Calystegia macounii Macoun’s bindweed

Calystegia sepium —

Calystegia silvatica ssp. fraterniflora —

Convolvulus arvensis field bindweed

Evolvulus nuttallianus Nuttall’s evolvulus

Ipomoea coccinea red morning-glory

Ipomoea hederacea ivy-leaf morning-glory

Ipomoea lacunosa white morning-glory

Ipomoea leptophylla bush morning-glory

Ipomoea pandurata bigroot morning-glory

Ipomoea purpurea common morning-glory

Ipomoea shumardiana Shumard’s morning-glory

Cornaceae Dogwood Family

Cornus amomum ssp. obliqua pale dogwood

Cornus drummondii roughleaf dogwood

Crassulaceae Stonecrop Family

Crassula drummondii —

Penthorum sedoides ditch stonecrop
Appendix A — List of Plants and Animals 45

SCIENTIFIC NAME COMMON NAME

Cucurbitaceae Cucumber Family

Citrullus lanatus var. lanatus watermelon

Cucurbita foetidissima buffalo gourd

Echinocystis lobata wild mock-cucumber

Melothria pendula creeping cucumber

Sicyos angulatus bur cucumber

Cupressaceae Cypress Family

Chamaecyparis lawsoniana —

Juniperus virginiana var. virginiana eastern red-cedar

Cuscutaceae Dodder Family

Cuscuta coryli hazel dodder

Cuscuta glomerata cluster dodder

Cuscuta indecora var. indecora —

Cuscuta pentagona —

Cyperaceae Sedge Family

Bolboschoenus fluviatilis river tuberous-bulrush

Bolboschoenus maritimus ssp. paludosus saltmarsh tuberous-bulrush

Bulbostylis capillaris hairsedge bulbstyle

Carex aggregata cluster sedge

Carex albicans var. albicans white-tinge sedge

Carex annectens yellow-fruit sedge

Carex austrina southern sedge

Carex bicknellii Bicknell’s sedge

Carex blanda woodland sedge

Carex brevior short-beak sedge

Carex bushii Bush’s sedge

Carex crus-corvi raven-foot sedge

Carex davisii Davis’ sedge

Carex emoryi emory sedge

Carex festucacea fescue sedge

Carex fissa —

Carex frankii Frank‘s sedge

Carex gravida heavy sedge

Carex grisea narrow-leaf sedge

Carex hirsutella —

Carex hyalinolepis thinscale sedge

Carex hystericina bottle-brush sedge

Carex inops ssp. heliophila sun sedge

Carex laeviconica smoothcone sedge

Carex leavenworthii Leavenworth‘s sedge

Carex lupulina hop sedge

Carex meadii Mead‘s sedge

Carex microdonta littletooth sedge
46 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Carex molesta pest sedge

Carex muehlenbergii var. enervis —

Carex oligocarpa straight-fruit sedge

Carex pellita woolly sedge

Carex shinnersii —

Carex umbellata umbellate sedge

Carex vulpinoidea fox sedge

Cyperus acuminatus tapeleaf sedge

Cyperus bipartitus brook flatsedge

Cyperus echinatus globe flatsedge

Cyperus erythrorhizos redroot flatsedge

Cyperus esculentus yellow nutsedge

Cyperus lupulinus slender-stem flat-rush

Cyperus odoratus slender flatsedge

Cyperus pseudovegetus falsegreen flatsedge

Cyperus schweinitzii Schweinitz’s flat-sedge

Cyperus setigerus —

Cyperus squarrosus awned flatsedge

Cyperus strigosus false nutsedge

Cyperus X mesochoreus intermediate flat-sedge

Eleocharis acicularis needle spike-rush

Eleocharis compressa flat-stem spike-rush

Eleocharis engelmannii Engelmann’s spike-rush

Eleocharis erythropoda bald spike-rush

Eleocharis macrostachya longstem spikesedge

Eleocharis montevidensis —

Eleocharis obtusa blunt spike-rush

Eleocharis palustris marsh spike-rush

Fimbristylis annua annual fimbristylis

Fimbristylis autumnalis slender fimbristylis

Fimbristylis puberula var. puberula —

Fimbristylis vahlii Vahl’s fimbristylis

Fuirena simplex var. aristulata —

Lipocarpha aristulata pointed lipocarpha

Lipocarpha drummondii Drummond’s lipocarpha

Schoenoplectus acutus var. acutus hard-stem twine-bulrush

Schoenoplectus heterochaetus slender bulrush

Schoenoplectus pungens common threesquare twine-bulrush

Schoenoplectus tabernaemontani soft-stem twine-bulrush

Scirpus atrovirens green bulrush

Scirpus georgianus Georgia bulrush

Scirpus pallidus pale bulrush

Scirpus pendulus rusty bulrush
Appendix A — List of Plants and Animals 47

SCIENTIFIC NAME COMMON NAME

Dipsacaceae Teasel Family

Dipsacus laciniatus cutleaf teasel

Dryopteridaceae Wood Fern Family

Cystopteris protrusa southern bladder fern

Cystopteris tennesseensis Tennessee bladder fern

Dryopteris marginalis marginal wood fern

Onoclea sensibilis sensitive fern

Polystichum acrostichoides Christmas fern

Woodsia obtusa —

Ebenaceae Ebony Family

Diospyros virginiana persimmon

Elatinaceae Waterwort Family

Bergia texana Texas bergia

Equisetaceae Horsetail Family

Equisetum arvense field horsetail

Equisetum hyemale ssp. affine common scouring-rush

Equisetum laevigatum smooth scouring rush

Equisetum X ferrissii Ferriss’ scouring rush

Euphorbiaceae Spurge Family

Acalypha deamii Deam’s copperleaf

Acalypha monococca slender copperleaf

Acalypha ostryifolia rough-pod copperleaf

Acalypha rhomboidea rhombic copperleaf

Acalypha virginica Virginia copperleaf

Argythamnia mercurialina Mercury’s argythamnia

Chamaesyce glyptosperma ridge-seed mat-spurge

Chamaesyce humistrata spreading spurge

Chamaesyce maculata spotted spurge

Chamaesyce missurica Missouri spurge

Chamaesyce nutans eyebane

Chamaesyce prostrata prostrate spurge

Chamaesyce serpens round-leaf mat-spurge

Chamaesyce stictospora slim-seed mat-spurge

Croton capitatus var. capitatus woolly croton

Croton glandulosus var. septentrionalis tropic croton

Croton monanthogynus one-seeded croton

Croton texensis Texas croton

Croton willdenowii rush-foil

Euphorbia corollata flowering spurge

Euphorbia cyathophora painted spurge

Euphorbia davidii western toothed spurge

Euphorbia dentata eastern toothed spurge

Euphorbia hexagona six-angled spurge
48 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Euphorbia marginata snow-on-the-mountain

Euphorbia spathulata warty spurge

Euphorbia virgata —

Ricinus communis castor bean

Tragia betonicifolia nettleleaf noseburn

Tragia ramosa stalked noseburn

Fabaceae Pea Family

Acacia angustissima var. hirta —

Albizia julibrissin silktree

Amorpha canescens lead plant

Amorpha fruticosa false indigo

Amorpha nana dwarf wild indigo

Amphicarpaea bracteata hog peanut

Apios americana American potato bean

Astragalus crassicarpus ground-plum milk-vetch

Astragalus lotiflorus lotus milk-vetch

Astragalus plattensis Platte River milk-vetch

Baptisia alba var. macrophylla —

Baptisia australis var. minor blue wild-indigo

Baptisia bracteata var. leucophaea plains wild-indigo

Baptisia leucophaea plains wild-indigo

Baptisia X bicolor —

Cercis canadensis redbud

Chamaecrista fasciculata showy partridge pea

Chamaecrista nictitans ssp. nictitans var. nictitans —

Colutea arborescens bladder senna

Crotalaria sagittalis rattlebox

Dalea aurea golden prairie-clover

Dalea candida var. candida white prairie-clover

Dalea enneandra nine-anther prairie-clover

Dalea lanata var. lanata —

Dalea leporina hare’s-foot prairie-clover

Dalea multiflora roundhead prairie-clover

Dalea purpurea purple prairie-clover

Dalea villosa var. villosa —

Desmanthus illinoensis Illinois bundleflower

Desmanthus leptolobus slenderlobe bundleflower

Desmodium canadense Canada tickclover

Desmodium canescens hoary tickclover

Desmodium ciliare slender tickclover

Desmodium cuspidatum long-leaf tickclover

Desmodium glabellum —

Desmodium glutinosum large-flowered tickclover
Appendix A — List of Plants and Animals 49

SCIENTIFIC NAME COMMON NAME

Desmodium illinoense Illinois tickclover

Desmodium paniculatum —

Desmodium perplexum Dillen’s tick-clover

Desmodium sessilifolium sessile-leaf tickclover

Gleditsia triacanthos honey locust

Glycyrrhiza lepidota wild licorice

Gymnocladus dioicus Kentucky coffee-tree

Kummerowia stipulacea Korean clover

Lespedeza capitata round-head lespedeza

Lespedeza cuneata sericea lespedeza

Lespedeza formosa —

Lespedeza procumbens trailing lespedeza

Lespedeza repens creeping lespedeza

Lespedeza stuevei tall bush lespedeza

Lespedeza violacea prairie lespedeza

Lespedeza virginica slender bush lespedeza

Lespedeza X simulata — 

Lotus corniculatus bird’s-foot trefoil

Lotus unifoliolatus var. unifoliolatus —

Medicago lupulina black medick

Medicago minima prickly medick

Medicago sativa ssp. sativa alfalfa

Melilotus albus white sweet clover

Melilotus officinalis yellow sweet clover

Mimosa quadrivalvis var. nuttallii cat-claw mimosa

Oxytropis lambertii Lambert’s crazyweed

Pediomelum argophyllum silver-leaf scurfpea

Pediomelum esculentum prairie-turnip

Psoralidium argophyllum —

Psoralidium lanceolatum lemon scurfpea

Psoralidium tenuiflorum many-flowered scurf-pea

Robinia pseudoacacia black locust

Securigera varia —

Senna marilandica Maryland senna

Strophostyles helvula wild bean

Strophostyles leiosperma slick-seed bean

Tephrosia virginiana goat’s rue

Trifolium campestre low hop clover

Trifolium hybridum alsike clover

Trifolium hybridum ssp. elegans —

Trifolium pratense red clover

Trifolium repens white clover

Vicia americana American vetch
50 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Vicia villosa ssp. villosa hairy vetch

Fagaceae Beech Family

Quercus imbricaria shingle oak

Quercus macrocarpa bur oak

Quercus marilandica blackjack oak

Quercus muehlenbergii chinquapin oak

Quercus prinoides dwarf chinquapin oak

Quercus rubra —

Quercus shumardii Shumard’s oak

Quercus stellata post oak

Quercus velutina black oak

Quercus X bushii —

Fumariaceae Fumitory Family

Corydalis crystallina mealy corydalis

Corydalis micrantha ssp. micrantha —

Dicentra cucullaria Dutchman’s breeches

Gentianaceae Gentian Family

Gentiana puberulenta downy gentian

Sabatia campestris prairie rose gentian

Geraniaceae Geranium Family

Erodium cicutarium filaree

Geranium carolinianum Carolina cranesbill

Geranium pusillum small cranesbill

Grossulariaceae Currant Family

Ribes aureum var. villosum —

Ribes missouriense Missouri gooseberry

Haloragaceae Watermilfoil Family

Myriophyllum heterophyllum water milfoil

Myriophyllum pinnatum green parrot’s feather

Hippocastanaceae Horse Chestnut Family

Aesculus glabra var. arguta Ohio buckeye

Hydrocharitaceae Waterleaf Family

Najas guadalupensis common naiad

Najas guadalupensis ssp. guadalupensis common naiad

Hydrophyllaceae Waterleaf Family

Ellisia nyctelea waterpod

Hydrophyllum virginianum Virginia waterleaf

Iridaceae Iris Family

Iris flavescens —

Iris germanica bearded iris

Iris pseudacorus yellow-flag iris

Iris pumila —

Nemastylis geminiflora nemastylis
Appendix A — List of Plants and Animals 51

SCIENTIFIC NAME COMMON NAME

Sisyrinchium angustifolium common blue-eyed grass

Sisyrinchium campestre prairie blue-eyed grass

Isoetaceae Quillwort Family

Isoetes butleri Butler’s quillwort

Juglandaceae Walnut Family

Carya cordiformis bitternut hickory

Carya illinoinensis pecan

Carya ovata shagbark hickory

Juglans nigra black walnut

Juncaceae Rush Family

Juncus acuminatus tapertip rush

Juncus diffusissimus slimpod rush

Juncus dudleyi Dudley’s rush

Juncus interior inland rush

Juncus marginatus shore rush

Juncus nodatus stout rush

Juncus tenuis path rush

Juncus torreyi Torrey’s rush

Luzula bulbosa wood rush

Lamiaceae Mint Family

Agastache nepetoides catnip giant hyssop

Glechoma hederacea ground ivy

Hedeoma hispida rough false pennyroyal

Lamium amplexicaule henbit

Lamium purpureum deadnettle

Leonurus cardiaca common motherwort

Lycopus americanus American bugleweed

Marrubium vulgare common horehound

Mentha arvensis field mint

Monarda bradburiana Bradbury bee-balm

Monarda citriodora lemon bee-balm

Monarda fistulosa wild bergamot bee-balm

Nepeta cataria catnip

Physostegia angustifolia false dragonhead

Prunella vulgaris self-heal

Pycnanthemum tenuifolium slender mountain mint

Salvia azurea blue sage

Salvia reflexa lanceleaf sage

Scutellaria lateriflora sideflower skullcap

Scutellaria parvula small skullcap

Stachys tenuifolia slenderleaf betony

Teucrium canadense American germander

Trichostema brachiatum false pennyroyal
52 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Lemnaceae Duckweed Family

Lemna aequinoctialis equinox duckweed

Lemna minor lesser duckweed

Lemna obscura obscure duckweed

Lemna perpusilla minute duckweed

Lemna turionifera turion duckweed

Spirodela polyrrhiza greater duckmeat

Wolffia columbiana Columbia watermeal

Lentibulariaceae Bladderwort Family

Utricularia macrorhiza common bladderwort

Liliaceae Lily Family

Allium canadense Canadian onion

Allium sativum wild onion

Allium stellatum pink wild onion

Allium vineale field garlic

Androstephium coeruleum blue funnel lily

Asparagus officinalis garden asparagus

Camassia angusta wild hyacinth

Camassia scilloides wild hyacinth

Erythronium albidum white dogtooth violet

Erythronium mesochoreum prairie dogtooth violet

Hemerocallis fulva day lily

Hypoxis hirsuta yellow star grass

Maianthemum racemosum feathery false Solomon’s seal

Maianthemum stellatum starry spikenard

Muscari neglectum —

Nothoscordum bivalve false garlic

Ornithogalum umbellatum star-of-Bethlehem

Polygonatum biflorum Solomon’s seal

Toxicoscordion nuttallii —

Linaceae Flax Family

Linum pratense Norton’s flax

Linum sulcatum grooved flax

Loasaceae Loasa Family

Mentzelia oligosperma stick-leaf chickenthief

Lythraceae Loosestrife Family

Ammannia auriculata earleaf ammannia

Ammannia coccinea red ammannia

Ammannia robusta purple ammannia

Didiplis diandra water purslane

Lythrum alatum winged loosestrife

Lythrum californicum California loosestrife

Lythrum salicaria purple loosestrife
Appendix A — List of Plants and Animals 53

SCIENTIFIC NAME COMMON NAME

Rotala ramosior rotala

Malvaceae Mallow Family

Abutilon theophrasti velvet-leaf

Callirhoe alcaeoides pale poppy mallow

Callirhoe involucrata purple poppy mallow

Callirhoe leiocarpa hairy-fruited poppy mallow

Hibiscus laevis halberd-leaved rose mallow

Hibiscus trionum flower-of-an-hour

Malva neglecta common mallow

Malva pusilla running mallow

Malvastrum hispidum hairy false mallow

Sida spinosa prickly sida

Marsileaceae Water Clover Family

Marsilea vestita western water-clover

Menispermaceae Moonseed Family

Cocculus carolinus Carolina snailseed

Menispermum canadense moonseed

Molluginaceae Carpetweed Family

Mollugo verticillata carpetweed

Moraceae Mulberry Family

Maclura pomifera Osage orange

Morus alba white mulberry

Morus rubra red mulberry

Nelumbonaceae Lotus-lily Family

Nelumbo lutea American lotus

Nyctaginaceae Four-o’clock Family

Mirabilis albida white four-o’clock

Mirabilis linearis narrowleaf four-o’clock

Mirabilis nyctaginea wild four-o’clock

Nymphaeaceae Water-lily Family

Nymphaea odorata ssp. odorata fragrant water-lily

Oleaceae Olive Family

Fraxinus americana white ash

Fraxinus pennsylvanica green ash

Fraxinus quadrangulata blue ash

Syringa vulgaris common lilac

Onagraceae Evening Primrose Family

Calylophus serrulatus plains yellow evening-primrose

Circaea lutetiana ssp. canadensis broadleaf enchanter’s nightshade

Epilobium coloratum purple-leaved willow-herb

Epilobium X wisconsinense Wisconsin willow-herb

Gaura coccinea scarlet butterfly-weed

Gaura longiflora biennial gaura
54 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Gaura mollis velvet butterfly-weed

Ludwigia alternifolia var. pubescens —

Ludwigia palustris water purslane

Ludwigia peploides floating seedbox

Oenothera biennis common evening primrose

Oenothera laciniata cutleaf evening primrose

Oenothera linifolia narrow-leaved evening primrose

Oenothera macrocarpa ssp. macrocarpa Missouri evening-primrose

Oenothera pilosella meadow evening primrose

Oenothera rhombipetala fourpoint evening primrose

Oenothera speciosa white evening primrose

Oenothera triloba stemless evening primrose

Oenothera villosa hairy evening-primrose

Stenosiphon linifolius stenosiphon

Ophioglossaceae Fern Family

Botrychium virginianum rattlesnake fern

Ophioglossum engelmannii limestone adder’s-tongue

Orchidaceae Orchid Family

Platanthera praeclara—Threatened western prairie fringed orchid

Spiranthes cernua nodding ladies’-tresses

Spiranthes lacera slender ladies’-tresses

Spiranthes magnicamporum Great Plains ladies’-tresses

Spiranthes tuberosa little ladies’-tresses

Spiranthes vernalis upland ladies’-tresses

Spiranthes vernalis upland ladies’-tresses

Osmundaceae Royal Fern Family

Osmunda regalis var. spectabilis —

Oxalidaceae Wood-sorrel Family

Oxalis dillenii green wood sorrel

Oxalis stricta yellow wood-sorrel

Oxalis violacea violet wood sorrel

Papaveraceae Poppy Family

Argemone polyanthemos prickly poppy

Papaver rhoeas field poppy

Phytolaccaceae Pokeweed Family

Phytolacca americana var. americana American pokeweed

Pinaceae Pine Family

Pinus nigra —

Pinus ponderosa —

Pinus sylvestris —

Plantaginaceae Plantain Family

Plantago aristata bottlebrush plantain

Plantago elongata ssp. elongata slender plantain
Appendix A — List of Plants and Animals 55

SCIENTIFIC NAME COMMON NAME

Plantago lanceolata English plantain

Plantago patagonica var. patagonica woolly plantain

Plantago pusilla tiny plantain

Plantago rhodosperma red-seeded plantain

Plantago rugelii Rugel’s plantain

Plantago virginica pale-seeded plantain

Platanaceae Sycamore Family

Platanus occidentalis sycamore

Poaceae Grass Family

Aegilops cylindrica jointed goatgrass

Aegilotriticum sancti-andreae —

Agrostis elliottiana awned bentgrass

Agrostis gigantea redtop

Agrostis hyemalis winter bent grass

Agrostis stolonifera creeping bent grass

Alopecurus carolinianus Carolina foxtail

Andropogon gerardii big bluestem

Andropogon hallii sandhill bluestem

Andropogon scoparius little bluestem

Andropogon virginicus broomsedge bluestem

Aristida basiramea forktip threeawn

Aristida dichotoma var. curtissii —

Aristida longespica var. geniculata —

Aristida oligantha old-field threeawn

Aristida purpurascens arrow feather threeawn

Avena fatua var. sativa —

Bothriochloa bladhii Caucasian bluestem

Bothriochloa ischaemum var. songarica Turkestan bluestem

Bothriochloa laguroides ssp. torreyana silver bluestem

Bouteloua curtipendula side-oats grama

Bouteloua gracilis blue grama

Bouteloua hirsuta hairy grama

Bromus catharticus rescuegrass

Bromus commutatus hairy chess

Bromus inermis smooth brome

Bromus japonicus Japanese brome

Bromus pubescens Canada brome

Bromus secalinus rye brome

Bromus tectorum downy brome

Buchloe dactyloides buffalo grass

Calamovilfa longifolia var. longifolia prairie sand-reed

Cenchrus incertus coast sandbur

Cenchrus longispinus field sandbur
56 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Chasmanthium latifolium sea oats

Chloris verticillata windmillgrass

Chloris virgata showy chloris

Cynodon dactylon bermudagrass

Dactylis glomerata orchardgrass

Danthonia spicata poverty oat grass

Diarrhena obovata American beakgrass

Dichanthelium acuminatum —

Dichanthelium malacophyllum soft-leaf dichanthelium

Dichanthelium oligosanthes ssp. scribnerianum Scribner’s dichanthelium

Dichanthelium ovale ssp. praecocius —

Dichanthelium perlongum long-spike dichanthelium

Dichanthelium sphaerocarpon roundseed dichanthelium

Digitaria ciliaris southern crabgrass

Digitaria cognata ssp. cognata fall witch grass

Digitaria filiformis slender crabgrass

Digitaria ischaemum smooth crabgrass

Digitaria sanguinalis hairy crabgrass

Echinochloa colona jungle-rice

Echinochloa crus-galli barnyard grass

Echinochloa esculenta —

Echinochloa muricata rough barnyard grass

Eleusine indica goosegrass

Elymus canadensis Canada wildrye

Elymus glabriflorus smooth wildrye

Elymus macgregorii McGregor’s wild rye

Elymus repens quack grass

Elymus submuticus Virginia wild-rye

Elymus villosus hairy wildrye

Elymus virginicus Virginia wild-rye

Elymus X maltei —

Eragrostis capillaris lacegrass

Eragrostis cilianensis stink grass

Eragrostis curtipedicellata gummy lovegrass

Eragrostis frankii sandbar lovegrass

Eragrostis hypnoides teal lovegrass

Eragrostis intermedia plains lovegrass

Eragrostis minor little lovegrass

Eragrostis pectinacea Carolina love grass

Eragrostis spectabilis purple lovegrass

Eragrostis trichodes sand lovegrass

Eriochloa contracta prairie cupgrass

Festuca subverticillata nodding fescue
Appendix A — List of Plants and Animals 57

SCIENTIFIC NAME COMMON NAME

Glyceria striata fowl mannagrass

Glyceria striata var. striata fowl mannagrass

Gymnopogon ambiguus bearded skeletongrass

Hesperostipa comata ssp. comata needle-and-thread

Hesperostipa spartea porcupine grass

Hordeum jubatum foxtail barley

Hordeum pusillum little barley

Koeleria macrantha prairie June grass

Leersia oryzoides rice cut grass

Leersia virginica whitegrass

Leptochloa fascicularis bearded sprangletop

Leptochloa fusca fascicularis bearded sprangletop

Leptochloa mucronata red sprangletop

Leptochloa panicea ssp. mucronata red sprangletop

Lolium perenne var. perenne —

Melica nitens threeflower melic

Muhlenbergia bushii Bush’s muhly

Muhlenbergia capillaris hairgrass

Muhlenbergia cuspidata plains muhly

Muhlenbergia frondosa wirestem muhly

Muhlenbergia mexicana Mexican muhly

Muhlenbergia racemosa marsh muhly

Muhlenbergia schreberi nimblewill

Muhlenbergia sobolifera rock muhly

Muhlenbergia sylvatica forest muhly

Neeragrostis reptans —

Panicum anceps beaked panicum

Panicum capillare common witch grass

Panicum dichotomiflorum fall panicum

Panicum flexile wiry witchgrass

Panicum obtusum vine-mesquite

Panicum philadelphicum Philadelphia witchgrass

Panicum rigidulum redtop panicum

Panicum virgatum switchgrass

Pascopyrum smithii western wheatgrass

Paspalum floridanum var. glabratum —

Paspalum laeve var. circulare —

Paspalum pubiflorum var. glabrum hairy-seed paspalum

Paspalum setaceum var. muhlenbergii thin paspalum

Paspalum setaceum var. stramineum —

Phalaris arundinacea reed canarygrass

Phalaris caroliniana Carolina canarygrass

Phleum pratense timothy
58 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Phleum pratense ssp. pratense timothy

Phragmites australis common reed

Poa annua annual bluegrass

Poa bulbosa bulbose bluegrass

Poa compressa Canada bluegrass

Poa pratensis Kentucky bluegrass

Poa sylvestris woodland bluegrass

Saccharum ravennae plumegrass

Schedonnardus paniculatus tumblegrass

Schedonorus arundinaceus tall rye grass

Schedonorus pratensis meadow rye grass

Schizachyrium scoparium little bluestem

Sclerochloa dura hardgrass

Setaria faberi Chinese foxtail

Setaria glauca —

Setaria italica foxtail millet

Setaria parviflora knotroot bristlegrass

Setaria pumila yellow bristle grass

Setaria viridis green foxtail

Sorghastrum nutans Indiangrass

Sorghum bicolor sorghum

Sorghum halepense Johnsongrass

Spartina pectinata prairie cordgrass

Sphenopholis obtusata var. obtusata wedgescale

Sporobolus airoides alkali sacaton

Sporobolus asper var. drummondii rough dropseed

Sporobolus clandestinus —

Sporobolus compositus rough dropseed

Sporobolus cryptandrus sand dropseed

Sporobolus heterolepis prairie dropseed

Sporobolus neglectus puffsheath dropseed

Sporobolus ozarkanus Ozark dropseed

Sporobolus pyramidatus whorled dropseed

Sporobolus vaginiflorus povertygrass

Thinopyrum ponticum tall sand-wheat

Tridens flavus purpletop

Tridens muticus var. elongatus —

Tridens strictus longspike tridens

Triplasis purpurea purple sandgrass

Tripsacum dactyloides eastern gammagrass

Triticum aestivum bread wheat

Vulpia octoflora sixweeks fescue
Appendix A — List of Plants and Animals 59

SCIENTIFIC NAME COMMON NAME

Polemoniaceae Phlox Family

Phlox divaricata wild blue phlox

Phlox oklahomensis Oklahoma phlox

Phlox pilosa ssp. pilosa downy phlox

Polygalaceae Milkwort Family

Polygala incarnata slender milkwort

Polygala verticillata whorled milkwort

Polygonaceae Buckwheat Family

Eriogonum annuum annual eriogonum

Fagopyrum esculentum buckwheat

Fallopia convolvulus black bindweed

Fallopia scandens climbing false-buckwheat

Persicaria amphibia water smartweed

Persicaria bicornis pink smartweed

Persicaria hydropiperoides swamp smartweed

Persicaria lapathifolia pale smartweed

Persicaria maculosa spotted lady’s-thumb, redshank

Persicaria pensylvanica Pennsylvania smartweed

Persicaria punctata dotted smartweed

Persicaria virginiana jumpseed

Polygonum aviculare prostrate knotweed

Polygonum erectum erect knotweed

Polygonum ramosissimum bush knotweed

Polygonum tenue slender knowtweed

Rumex acetosella sheep sorrel

Rumex acetosella ssp. pyrenaicus sheep sorrel

Rumex altissimus pale dock

Rumex crispus curly dock

Rumex maritimus golden dock

Rumex patientia patience dock

Rumex stenophyllus narrow-leaf dock

Pontederiaceae Pickerel-weed Family

Eichhornia crassipes —

Heteranthera limosa blue mud plantain

Heteranthera multiflora —

Heteranthera rotundifolia —

Pontederia cordata common pickerelweed

Portulacaceae Purslane Family

Claytonia virginica Virginia spring beauty

Phemeranthus calycinus rock-pink fameflower

Phemeranthus parviflorus prairie fameflower

Portulaca oleracea common purslane

Portulaca pilosa hairy purslane
60 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Potamogetonaceae Pondweed Family

Potamogeton diversifolius water-thread pondweed

Potamogeton foliosus leafy pondweed

Potamogeton nodosus long-leaf pondweed

Potamogeton pusillus —

Stuckenia pectinata sago pondweed

Primulaceae Primrose Family

Anagallis arvensis scarlet pimpernel

Androsace occidentalis western rock-jasmine

Dodecatheon meadia var. meadia —

Lysimachia ciliata fringed loosestrife

Lysimachia nummularia moneywort

Ranunculaceae Buttercup Family

Anemone canadensis meadow anemone

Anemone caroliniana Carolina anemone

Anemone cylindrica candle anemone

Anemone virginiana tall anemone

Aquilegia columbine

Aquilegia canadensis American columbine

Clematis pitcheri Pitcher’s clematis

Clematis terniflora virgin’s bower

Consolida ajacis rocket larkspur

Delphinium carolinianum Carolina larkspur

Delphinium tricorne dwarf larkspur

Enemion biternatum false rue anemone

Myosurus minimus mousetail

Ranunculus abortivus early wood buttercup

Ranunculus aquatilis var. diffusus white water crowfoot

Ranunculus hispidus var. hispidus —

Ranunculus sardous hairy buttercup

Ranunculus sceleratus var. sceleratus cursed crowfoot

Ranunculus testiculatus bur buttercup

Thalictrum dasycarpum purple meadow-rue

Rhamnaceae Buckthorn Family

Ceanothus americanus New Jersey tea

Ceanothus herbaceus inland ceanothus

Ceanothus ovatus —

Rhamnus lanceolata var. glabrata —

Rosaceae Rose Family

Agrimonia parviflora many-flowered agrimony

Agrimonia pubescens downy agrimony

Amelanchier arborea tall service berry

Amelanchier sanguinea —
Appendix A — List of Plants and Animals 61

SCIENTIFIC NAME COMMON NAME

Crataegus coccinioides Kansas hawthorn

Crataegus crus-galli cockspur hawthorn

Crataegus mollis summer hawthorn

Crataegus pruinosa frosty hawthorn

Fragaria virginiana wild strawberry

Geum canadense white avens

Malus ioensis —

Potentilla arguta tall cinquefoil

Potentilla recta sulphur cinquefoil

Potentilla rivalis brook cinquefoil

Potentilla simplex old-field cinquefoil

Prunus americana wild plum

Prunus angustifolia chickasaw plum

Prunus cerasus sour cherry

Prunus mahaleb mahaleb plum

Prunus mexicana Mexican plum

Prunus munsoniana wild-goose plum

Prunus persica peach

Prunus rivularis creek plum

Prunus serotina black cherry

Prunus virginiana choke cherry

Pyrus communis pear

Rosa arkansana prairie wild rose

Rosa blanda smooth rose

Rosa multiflora multiflora rose

Rosa setigera climbing rose

Rosa X rudiuscula —

Rubus aboriginum one-flower dewberry

Rubus curtipes —

Rubus discolor Himalayan blackberry

Rubus enslenii small dewberry

Rubus flagellaris American dewberry

Rubus frondosus leafy highbush blackberry

Rubus hancinianus Hancin’s dewberry

Rubus laudatus praiseworth blackberry

Rubus meracus dryslope dewberry

Rubus mollior soft blackberry

Rubus occidentalis black raspberry

Rubus ostryifolius highbush blackberry

Rubus pensilvanicus highbush blackberry

Rubus roribaccus Lucretia dewberry

Rubiaceae Madder Family

Cephalanthus occidentalis buttonbush
62 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Diodia teres rough buttonweed

Galium aparine catchweed bedstraw

Galium circaezans woods bedstraw

Galium concinnum shining bedstraw

Galium obtusum bluntleaf bedstraw

Galium pedemontanum foothill bedstraw

Galium pilosum hairy bedstraw

Galium triflorum sweet-scent bedstraw

Galium virgatum southwestern bedstraw

Hedyotis nigricans narrow-leaf bluet

Houstonia pusilla small bluets

Rutaceae Rue Family

Poncirus trifoliata —

Ptelea trifoliata common hop tree

Zanthoxylum americanum common prickly ash

Salicaceae Willow Family

Populus deltoides ssp. monilifera cottonwood

Populus nigra black poplar

Populus X canadensis Carolina poplar

Salix amygdaloides peach-leaved willow

Salix caroliniana Carolina willow

Salix eriocephala ssp. eriocephala eriocephala diamond willow

Salix exigua ssp. interior sandbar willow

Salix humilis var. humilis —

Salix nigra black willow

Santalaceae Sandalwood Family

Comandra umbellata umbellate bastard toad-flax

Sapindaceae Soapberry Family

Cardiospermum halicacabum common balloon vine

Sapindus saponaria var. drummondii southern soapberry

Sapotaceae Sapodilla Family

Bumelia lanuginosa var. oblongifolia gum bully

Saxifragaceae Saxifrage Family

Heuchera richardsonii Richardson’s alumroot

Scrophulariaceae Figwort Family

Agalinis aspera rough agalinis

Agalinis fasciculata fascicled agalinis

Agalinis gattingeri Gattinger’s purple false foxglove

Agalinis heterophylla stiff purple agalinis

Agalinis tenuifolia slender agalinis

Bacopa rotundifolia roundleaf water hyssop

Buchnera americana blue hearts

Castilleja sessiliflora downy paintbrush
Appendix A — List of Plants and Animals 63

SCIENTIFIC NAME COMMON NAME

Chaenorrhinum minus lesser dwarf-snapdragon

Collinsia violacea violet collinsia

Cymbalaria muralis Kenilworth ivy

Dasistoma macrophylla mullein foxglove

Gratiola neglecta golden hedge hyssop

Leucospora multifida paleseed

Lindernia dubia yellow false pimpernel

Mimulus alatus sharpwing monkeyflower

Mimulus ringens Alleghany monkeyflower

Nuttallanthus texanus Texas toad-flax

Penstemon cobaea cobaea beardtongue

Penstemon digitalis smooth beardtongue

Penstemon grandiflorus shell-leaf beardtongue

Penstemon tubiflorus tube beardtongue

Scrophularia marilandica Maryland figwort

Tomanthera densiflora fine-leaf hairy-foxglove

Verbascum blattaria moth mullein

Verbascum thapsus woolly mullein

Veronica americana American speedwell

Veronica anagallis-aquatica blue water speedwell

Veronica arvensis corn speedwell

Veronica catenata pink water speedwell

Veronica peregrina purslane speedwell

Veronica polita wayside speedwell

Selaginellaceae Spike-moss Family

Selaginella rupestris rock spike-moss

Simaroubaceae Quassia Family

Ailanthus altissima tree-of-heaven

Smilacaceae Catbrier Family

Smilax herbacea —

Smilax hispida bristly greenbrier

Smilax lasioneura —

Smilax tamnoides —

Solanaceae Nightshade Family

Datura stramonium jimsonweed

Lycium barbarum matrimony vine

Physalis angulata var. pendula cut-leaf ground-cherry

Physalis heterophylla clammy groundcherry

Physalis hispida —

Physalis longifolia common ground-cherry

Physalis missouriensis Missouri groundcherry

Physalis pumila prairie ground-cherry

Physalis virginiana —
64 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Physalis virginiana var. virginiana —

Solanum carolinense Carolina horse nettle

Solanum elaeagnifolium silverleaf nightshade

Solanum interius plains black nightshade

Solanum ptychanthum black nightshade

Solanum rostratum buffalo bur

Solanum sarrachoides viscid nightshade

Sparganiaceae Bur-reed Family

Sparganium eurycarpum giant bur-reed

Staphyleaceae Bladder-nut Family

Staphylea trifolia American bladdernut

Tamaricaceae Tamarix Family

Tamarix parviflora small-flowered tamarisk

Tamarix ramosissima salt cedar

Taxodiaceae Taxodium Family

Taxodium distichum var. distichum bald cypress

Thelypteridaceae Marsh Fern Family

Thelypteris palustris var. pubescens —

Tiliaceae Linden Family

Tilia americana American basswood

Typhaceae Cattail Family

Typha angustifolia narrow-leaved cattail

Typha domingensis southern cattail

Typha latifolia common cattail

Ulmaceae Elm Family

Celtis laevigata sugarberry

Celtis occidentalis common hackberry

Celtis tenuifolia dwarf hackberry

Ulmus americana American elm

Ulmus pumila Siberian elm

Ulmus rubra slippery elm

Urticaceae Nettle Family

Boehmeria cylindrica bog hemp

Laportea canadensis wood nettle

Parietaria pensylvanica Pennsylvania pellitory

Pilea pumila clearweed

Urtica dioica ssp. gracilis stinging nettle

Valerianaceae Valerian Family

Valerianella radiata corn salad

Verbenaceae Verbena Family

Glandularia bipinnatifida var. bipinnatifida —

Glandularia canadensis rose vervain

Phryma leptostachya lopseed
Appendix A — List of Plants and Animals 65

SCIENTIFIC NAME COMMON NAME

Phyla cuneifolia wedgeleaf frogfruit

Phyla lanceolata lanceleaf frogfruit

Verbena bipinnatifida —

Verbena bracteata prostrate verbena

Verbena canadensis Canada verbena

Verbena hastata blue verbena

Verbena simplex narrowleaf verbena

Verbena stricta woolly verbena

Verbena urticifolia white verbena

Verbena X engelmannii Engelmann’s verbena

Verbena X moechina pasture vervain

Vitex agnus-castus —

Violaceae Violet Family

Hybanthus verticillatus North American calceolaria

Viola bicolor Johnny-jump-up

Viola pedata bird’s-foot violet

Viola pedatifida prairie violet

Viola pratincola meadow violet

Viola pubescens downy yellow violet

Viola sororia downy blue violet

Viola striata —

Vitaceae Grape Family

Ampelopsis cordata raccoon grape

Parthenocissus inserta Virginia creeper

Parthenocissus quinquefolia Virginia creeper

Vitis cinerea graybark grape

Vitis riparia riverbank grape

Vitis vulpina winter grape

Zannichelliaceae Horned Pondweed Family

Zannichellia palustris horned pondweed

Zygophyllaceae Creosotebush Family

Tribulus terrestris puncture vine

ANIMALS

SCIENTIFIC NAME COMMON NAME

Invertebrates

Nicrophorus americanus—Endangered American burying beetle

Probythinella emarginata Delta hydrobe

Unionid Mussels

Amblema plicata Threeridge

Elliptio dilatata Spike

Fusonaia flava Wabash pigtoe

Lampsilis cardium Plain pocketbook
66 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Lampsilis rafinequena Neosho mucket

Lampsilis siliquoidea Fat mucket

Lampsilis teres Yellow sandshell

Lasmigona complanata White heelsplitter

Leptodea fragilis Fragile papershell

Ligumia subrostrata Pondmussel

Obliquaria reflexa Threehorn wartyback

Pyganodon grandis Floater

Quadrula cylindrica Rabbitsfoot

Quadrula metanevra Monkeyface

Quadrula nodulata Wartyback

Quadrula pustulosa Pimpleback

Quadrula quadrula Mapleleaf

Strophitus undulatus Creeper

Toxolasma parvus Lilliput

Tritogonia verrucosa Pistolgrip

Truncilla donaciformis Fawnsfoot

Truncilla truncata Deertoe

Uniomerus tetralasmus Pondhorn

Utterbackia imbecilis Paper pondshell

Amphibians and Reptiles

Ambystoma texanum Smallmouth Salamander

Necturus maculosus Mudpuppy

Bufo americanus American Toad

Bufo cognatus Great Plains Toad

Bufo woodhousii Woodhouse’s Toad

Acris crepitans Northern Cricket Frog

Hyla chrysoscelis Cope’s Gray Treefrog

Pseudacris clarkii Spotted Chorus Frog

Pseudacris triseriata Western Chorus Frog

Gastrophryne olivacea Great Plains Narrowmouth Toad

Spea bombifrons Plains Spadefoot

Rana blairi Plains Leopard Frog

Rana catesbeiana Bullfrog

Rana sphenocephala Southern Leopard Frog

Chelydra serpentina Snapping Turtle

Macrochelys temminckii Alligator Snapping Turtle

Chrysemys picta Painted Turtle

Graptemys ouachitensis Ouachita Map Turtle

Pseudemys concinna River Cooter

Terrapene ornata Western Box Turtle

Trachemys scripta Slider

Kinosternon flavescens Yellow Mud Turtle
Appendix A — List of Plants and Animals 67

SCIENTIFIC NAME COMMON NAME

Sternotherus odoratus Common Musk Turtle

Apalone mutica Smooth Softshell

Apalone spinifera Spiny Softshell

Ophisaurus attenuatus Slender Glass Lizard

Crotaphytus collaris Collared Lizard

Holbrookia maculata Lesser Earless Lizard

Phrynosoma cornutum Texas Horned Lizard

Sceloporus undulatus Fence/prairie/plateau Lizard

Eumeces fasciatus Five-lined Skink

Eumeces septentrionalis Prairie Skink

Eumeces obsoletus Great Plains Skink

Scincella lateralis Ground Skink

Cnemidophorus sexlineatus Six-lined Racerunner

Coluber constrictor Racer

Diadophis punctatus Ringneck Snake

Elaphe guttata Corn Snake

Elaphe obsoleta Rat Snake

Heterodon nasicus Western Hognose Snake

Heterodon platirhinos Eastern Hognose Snake

Lampropeltis calligaster Prairie Kingsnake

Lampropeltis getula Common Kingsnake

Lampropeltis triangulum Milk Snake

Masticophis flagellum Coachwhip

Nerodia erythrogaster Plainbelly Water Snake

Nerodia rhombifer Diamondback Water Snake

Nerodia sipedon Northern Water Snake

Opheodrys aestivus Rough Green Snake

Pituophis catenifer Pine or Gopher Snake

Regina grahamii Graham’s Crayfish Snake

Sonora semiannulata Ground Snake

Storeria dekayi Brown Snake

Tantilla gracilis Flathead Snake

Tantilla nigriceps Plains Blackhead Snake

Thamnophis proximus Western Ribbon Snake

Thamnophis radix Plains Garter Snake

Thamnophis sirtalis Common Garter Snake

Tropidoclonion lineatum Lined Snake

Agkistrodon contortrix Copperhead

Crotalus horridus Timber Rattlesnake

Sistrurus catenatus Massasauga

Fish

Scaphirhynchus platorynchus Shovelnose Sturgeon

Lepisosteus osseus Longnose Gar
68 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Lepisosteus platostomus Shortnose Gar

Anguilla rostrata American Eel

Dorosoma cepedianum Gizzard Shad

Hiodon alosoides Goldeye

Esox lucius Northern Pike

Campostoma anomalum Central Stoneroller

Carassius auratus Goldfish

Ctenopharyngodon idella Grass Carp

Cyprinus carpio Common Carp

Hybognathus argyritis Western Silvery Minnow

Hybognathus placitus Plains Minnow

Nocomis asper Redspot Chub

Nocomis biguttatus Hornyhead Chub

Notemigonus crysoleucas Golden Shiner

Notropis atherinoides Emerald Shiner

Notropis boops Bigeye Shiner

Notropis buchanani Ghost Shiner

Notropis giradi—Threatened Arkansas River Shiner

Notropis stramineus Sand Shiner

Notropis topeka—Endangered Topeka Shiner

Notropis volucellus Mimic Shiner

Notropis percobromus Rosyface Shiner

Phenacobius mirabilis Suckermouth Minnow

Phoxinus erythrogaster Southern Redbelly Dace

Pimephales notatus Bluntnose Minnow

Pimephales promelas Fathead Minnow

Pimephales tenellus Slim Minnow

Pimephales vigilax Bullhead Minnow

Semotilus atromaculatus Creek Chub

Cyprinella camura Bluntface Shiner

Cyprinella lutrensis Red Shiner

Erimystax x-punctatus Gravel Chub

Luxilus cardinalis Cardinal Shiner

Luxilus cornutus Common Shiner

Lythrurus umbratilis Redfin Shiner

Macrhybopsis gelida Sturgeon Chub

Macrhybopsis storeriana Silver Chub

Macrhybopsis hyostoma Speckled Chub

Carpiodes carpio River Carpsucker

Carpiodes cyprinus Quillback

Catostomus commersoni White Sucker

Cycleptus elongatus Blue Sucker
Appendix A — List of Plants and Animals 69

SCIENTIFIC NAME COMMON NAME

Ictiobus bubalus Smallmouth Buffalo

Ictiobus cyprinellus Bigmouth Buffalo

Ictiobus niger Black Buffalo

Minytrema melanops Spotted Sucker

Moxostoma carinatum River Redhorse

Moxostoma erythrurum Golden Redhorse

Moxostoma macrolepidotum Shorthead Redhorse

Ictalurus furcatus Blue Catfish

Ictalurus punctatus Channel Catfish

Noturus flavus Stonecat

Noturus nocturnus Freckled Madtom

Noturus placidus—Threatened Neosho Madtom

Noturus exilis Slender Madtom

Pylodictis olivaris Flathead Catfish

Ameiurus melas Black Bullhead

Ameiurus natalis Yellow Bullhead

Fundulus notatus Blackstripe Topminnow

Fundulus zebrinus Plains Killifish

Gambusia affinis Western Mosquitofish

Labidesthes sicculus Brook Silverside

Morone chrysops White Bass

Morone saxatilis Striped Bass

Lepomis cyanellus Green Sunfish

Lepomis humilis Orangespotted Sunfish

Lepomis macrochirus Bluegill

Micropterus dolomieu Smallmouth Bass

Micropterus punctulatus Spotted Bass

Micropterus salmoides Largemouth Bass

Pomoxis annularis White Crappie

Pomoxis nigromaculatus Black Crappie

Etheostoma cragini Arkansas Darter 

Etheostoma flabellare Fantail Darter

Etheostoma nigrum Johnny Darter

Etheostoma spectabile Orangethroat Darter

Etheostoma whipplei Redfin Darter

Perca flavescens Yellow Perch

Percina caprodes Logperch

Percina copelandi Channel Darter

Percina maculata Blackside Darter

Percina phoxocephala Slenderhead Darter

Stizostedion vitreum Walleye

Aplodinotus grunniens Freshwater Drum
70 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Birds

Anseriformes • Anatidae • Anserinae Geese

Anser albifrons Greater White-fronted Goose

Chen caerulescens Snow Goose 

Chen rossii Ross's Goose 

Branta bernicla Brant

Branta canadensis Canada Goose 

Anseriformes • Anatidae • Anatinae Ducks

Aix sponsa Wood Duck 

Anas strepera Gadwall 

Anas americana American Wigeon 

Anas rubripes American Black Duck 

Anas platyrhynchos Mallard 

Anas discors Blue-winged Teal 

Anas clypeata Northern Shoveler

Anas acuta Northern Pintail 

Anas crecca Green-winged Teal 

Aythya valisineria Canvasback 

Aythya americana Redhead 

Aythya collaris Ring-necked Duck 

Aythya marila Greater Scaup 

Aythya affinis Lesser Scaup 

Melanitta fusca White-winged Scoter

 Bucephala albeola Bufflehead

Bucephala clangula Common Goldeneye

Lophodytes cucullatus Hooded Merganser

Mergus merganser Common Merganser 

Oxyura jamaicensis Ruddy Duck 

Galliformes • Odontophoridae New World Quails

Colinus virginianus Northern Bobwhite Quail

Galliformes • Phasianidae • Phasianinae Pheasants

Phasianus colchicus Ring-necked Pheasant 

Galliformes • Phasianidae • Tetraoninae Grouses

Tympanuchus cupido Greater Prairie-Chicken 

Galliformes • Phasianidae • Meleagridinae Turkeys

Meleagris gallopavo Wild Turkey 

Gaviiformes • Gaviidae Loons

Gavia immer Common Loon 

Podicipediformes - Podicipedidae Grebes

Podilymbus podiceps Pied-billed Grebe

Podiceps auritus Horned Grebe 

Podiceps nigricollis Eared Grebe 
Appendix A — List of Plants and Animals 71

SCIENTIFIC NAME COMMON NAME

Pelecaniformes • Pelecanidae Pelicans

Pelecanus erythrorhynchos American White Pelican

Pelecaniformes • Phalacrocoracidae Cormorants

Phalacrocorax auritus Double-crested Cormorant

Ciconiiformes - Ardeidae Bitterns, Herons, and Egrets

Botaurus lentiginosus American Bittern 

Ixobrychus exilis Least Bittern 

Ardea herodias Great Blue Heron 

Ardea alba Great Egret 

Egretta thula Snowy Egret 

Egretta caerulea Little Blue Heron 

Bubulcus ibis Cattle Egret Héron 

Butorides virescens Green Heron 

Nycticorax nycticorax Black-crowned Night-Heron 

Nyctanassa violacea Yellow-crowned Night-Heron

Ciconiiformes • Threskiornithidae • Threskiornithinae Ibises and Spoonbills

Plegadis chihi White-faced Ibis 

Falconiformes • Cathartidae New World Vultures

Coragyps atratus Black Vulture 

Cathartes aura Turkey Vulture 

Falconiformes • Accipitridae • Pandioninae Ospreys

Pandion haliaetus Osprey 

Falconiformes • Accipitridae • Accipitrinae Hawks and Eagles

Elanoides forficatus Swallow-tailed Kite 

Ictinia mississippiensis Mississippi Kite 

Haliaeetus leucocephalus Bald Eagle 

Circus cyaneus Northern Harrier 

Accipiter striatus Sharp-shinned Hawk 

Accipiter cooperii Cooper’s Hawk 

Buteo platypterus Broad-winged Hawk 

Buteo swainsoni Swainson’s Hawk 

Buteo jamaicensis Red-tailed Hawk 

Buteo regalis Ferruginous Hawk 

Buteo lagopus Rough-legged Hawk 

Falconiformes • Falconidae • Falconinae Falcons

Falco sparverius American Kestrel 

Falco columbarius Merlin 

Falco peregrinus Peregrine Falcon 

Falco mexicanus Prairie Falcon 

Gruiformes • Rallidae Rails

Laterallus jamaicensis Black Rail 

Rallus elegans King Rail 

Rallus limicola Virginia Rail 
72 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Porzana carolina Sora 

Fulica americana American Coot

Gruiformes • Gruidae • Gruinae Cranes

Grus americana—Endangered Whooping Crane

Charadriiformes • Charadriidae • Charadriinae Plovers

Pluvialis squatarola Black-bellied Plover 

Pluvialis dominica American Golden-Plover 

Charadrius alexandrinus Snowy Plover 

Charadrius semipalmatus Semipalmated Plover

Charadrius melodus Threatened Piping Plover

Charadrius vociferous Killdeer

Charadriiformes • Recurvirostridae Stilts and Avocets

Himantopus mexicanus Black-necked Stilt 

Recurvirostra americana American Avocet 

Charadriiformes • Scolopacidae • Scolopacinae Sandpipers

Actitis macularius Spotted Sandpiper 

Tringa solitaria Solitary Sandpiper 

Tringa melanoleuca Greater Yellowlegs 

Tringa semipalmata Willet 

Tringa flavipes Lesser Yellowlegs 

Bartramia longicauda Upland Sandpiper 

Numenius americanus Long-billed Curlew 

Limosa haemastica Hudsonian Godwit 

Limosa fedoa Marbled Godwit 

Calidris alba Sanderling 

Calidris pusilla Semipalmated Sandpiper 

Calidris mauri Western Sandpiper 

Calidris minutilla Least Sandpiper

Calidris fuscicollis White-rumped Sandpiper 

Calidris bairdii Baird’s Sandpiper

Calidris melanotos Pectoral Sandpiper 

Calidris alpina Dunlin

Calidris himantopus Stilt Sandpiper 

Tryngites subruficollis Buff-breasted Sandpiper 

Limnodromus griseus Short-billed Dowitcher 

Limnodromus scolopaceus Long-billed Dowitcher 

Gallinago gallinago Common Snipe 

Scolopax minor American Woodcock 

Charadriiformes • Scolopacidae • Phalaropodinae Phalaropes

Phalaropus tricolor Wilson's Phalarope 

Phalaropus lobatus Red-necked Phalarope 

Charadriiformes • Laridae • Larinae Gulls

Xema sabini Sabine's Gull
Appendix A — List of Plants and Animals 73

SCIENTIFIC NAME COMMON NAME

Chroicocephalus philadelphia Bonaparte's Gull

Leucophaeus atricilla Laughing Gull 

Leucophaeus pipixcan Franklin's Gull 

Larus delawarensis Ring-billed Gull 

Larus argentatus Herring Gull

Larus hyperboreus Glaucous Gull

Charadriiformes • Laridae • Sterniae Terns

Sternula antillarum anthalassos–Endangered Interior Least Tern 

Hydroprogne caspia Caspian Tern 

Chlidonias niger Black Tern 

Sterna forsteri Forster's Tern 

Columbiformes • Columbidae Ducks

Zenaida macroura Mourning Dove

Cuculiformes • Cuculidae • Cuculinae Cuckoos

Coccyzus americanus Yellow-billed Cuckoo 

Coccyzus erythropthalmus Black-billed Cuckoo 

Strigiformes • Tytonidae Barn Owls

Tyto alba Barn Owl

Strigiformes • Strigidae Typical Owls

Megascops asio Eastern Screech-Owl 

Bubo virginianus Great Horned Owl 

Bubo scandiacus Snowy Owl 

Athene cunicularia Burrowing Owl 

Strix varia Barred Owl 

Asio otus Long-eared Owl 

Asio flammeus Short-eared Owl 

Caprimulgiformes • Caprimulgidae • Chordeilinae Nightjars

Chordeiles minor Common Nighthawk 

Phalaenoptilus nuttallii Common Poorwill 

Apodiformes • Apodidae • Chaeturinae Spine-tailed Swifts

Chaetura pelagica Chimney Swift

Apodiformes • Trochilidae • Trochilinae Hummingbirds

Archilochus colubris Ruby-throated Hummingbird

Coraciiformes • Alcedinidae • Cerylinae Kingfishers

Megaceryle alcyon Belted Kingfisher 

Piciformes • Picidae • Picinae Woodpeckers

Melanerpes erythrocephalus Red-headed Woodpecker 

Melanerpes carolinus Red-bellied Woodpecker 

Sphyrapicus varius Yellow-bellied Sapsucker 

Picoides pubescens Downy Woodpecker 

Passeriformes • Tyrannidae • Fluvicolinae Flyvicoline Flycatchers

Contopus cooperi Olive-sided Flycatcher 

Contopus sordidulus Western Wood-Pewee 
74 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Contopus virens Eastern Wood-Pewee 

Empidonax virescens Acadian Flycatcher 

Empidonax traillii Willow Flycatcher 

Empidonax minimus Least Flycatcher 

Sayornis phoebe Eastern Phoebe 

Passeriformes • Tyrannidae • Tyranninae Tyrannine Flycatchers

Myiarchus crinitus Great Crested Flycatcher 

Tyrannus verticalis Western Kingbird

Tyrannus tyrannus Eastern Kingbird

Tyrannus forficatus Scissor-tailed Flycatcher 

Passeriformes • Laniidae Shrikes

Lanius ludovicianus Loggerhead Shrike

Passeriformes • Vireonidae Vireos

Vireo griseus White-eyed Vireo

Vireo bellii Bell’s Vireo

Vireo flavifrons Yellow-throated Vireo

Vireo solitarius Blue-headed Vireo

Vireo gilvus Warbling Vireo

Vireo philadelphicus Philadelphia Vireo

Vireo olivaceus Red-eyed Vireo

Passeriformes - Corvidae Crows, Jays, and Magpies

Cyanocitta cristata Blue Jay 

Gymnorhinus cyanocephalus Pinyon Jay 

Pica hudsonia Black-billed Magpie 

Passeriformes - Alaudidae Larks

Eremophila alpestris Horned Lark 

Passeriformes • Hirundinidae • Hirundininae Swallows

Progne subis Purple Martin 

Stelgidopteryx serripennis Northern Rough-winged Swallow

Riparia riparia Bank Swallow

Passeriformes • Paridae Chickadees and Titmice

Poecile carolinensis Carolina Chickadee

Baeolophus bicolor Tufted Titmouse

Passeriformes • Sittidae • Sittinae Nuthatches

Sitta canadensis Red-breasted Nuthatch 

Passeriformes • Certhiidae • Certhiinae Tree Creepers

Certhia Americana Brown Creeper

Passeriformes • Troglodytidae Wrens

Troglodytes aedon House Wren 

Troglodytes troglodytes Winter Wren 

Passeriformes • Cinclidae Dippers

Cinclus mexicanus American Dipper 
Appendix A — List of Plants and Animals 75

SCIENTIFIC NAME COMMON NAME

Passeriformes • Regulidae Kinglets

Regulus satrapa Golden-crowned Kinglet 

Regulus calendula Ruby-crowned Kinglet 

Passeriformes • Sylviidae • Polioptilinae Gnatcatchers

Polioptila caerulea Blue-gray Gnatcatcher

Passeriformes • Turdidae Thrushes

Sialia sialis Eastern Bluebird 

Sialia currucoides Mountain Bluebird 

Myadestes townsendi Townsend's Solitaire 

Catharus fuscescens Veery 

Catharus minimus Gray-cheeked Thrush 

Catharus ustulatus Swainson's Thrush 

Hylocichla mustelina Wood Thrush 

Turdus migratorius American Robin 

Passeriformes • Sturnidae Starlings

Sturnus vulgaris European Starling 

Passeriformes • Motacillidae Pipits

Anthus rubescens American Pipit 

Anthus spragueii Sprague's Pipit 

Passeriformes • Bombycillidae Waxwings

Bombycilla garrulus Bohemian Waxwing 

Bombycilla cedrorum Cedar Waxwing 

Passeriformes • Parulidae Wood Warblers

Vermivora pinus Blue-winged Warbler 

Vermivora chrysoptera Golden-winged Warbler 

Vermivora peregrina Tennessee Warbler 

Vermivora celata Orange-crowned Warbler 

Vermivora ruficapilla Nashville Warbler 

Parula americana Northern Parula 

Dendroica petechia Yellow Warbler 

Dendroica pensylvanica Chestnut-sided Warbler 

Dendroica magnolia Magnolia Warbler 

Dendroica coronata Yellow-rumped Warbler 

Dendroica virens Black-throated Green Warbler 

Dendroica fusca Blackburnian Warbler 

Dendroica dominica Yellow-throated Warbler 

Dendroica palmarum Palm Warbler 

Dendroica castanea Bay-breasted Warbler 

Dendroica striata Blackpoll Warbler 

Mniotilta varia Black-and-white Warbler 

Setophaga ruticilla American Redstart 

Protonotaria citrea Prothonotary Warbler 
76 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Helmitheros vermivorum Worm-eating Warbler 

Seiurus aurocapilla Ovenbird 

Seiurus noveboracensis Northern Waterthrush 

Seiurus motacilla Louisiana Waterthrush 

Oporornis formosus Kentucky Warbler 

Oporornis philadelphia Mourning Warbler 

Geothlypis trichas Common Yellowthroat 

Wilsonia pusilla Wilson's Warbler 

Wilsonia canadensis Canada Warbler 

Icteria virens Yellow-breasted Chat 

Passeriformes • Emberizidae Sparrows and Towhees

Pipilo erythrophthalmus Eastern Towhee 

Spizella arborea American Tree Sparrow 

Spizella passerina Chipping Sparrow 

Spizella pallida Clay-colored Sparrow 

Spizella pusilla Field Sparrow 

Pooecetes gramineus Vesper Sparrow 

Chondestes grammacus Lark Sparrow 

Passerculus sandwichensis Savannah Sparrow 

Ammodramus savannarum Grasshopper Sparrow 

Ammodramus bairdii Baird's Sparrow 

Ammodramus henslowii Henslow's Sparrow 

Ammodramus leconteii Le Conte's Sparrow 

Passerella iliaca Fox Sparrow 

Melospiza melodia Song Sparrow 

Melospiza lincolnii Lincoln's Sparrow 

Melospiza georgiana Swamp Sparrow 

Zonotrichia albicollis White-throated Sparrow 

Zonotrichia querula Harris's Sparrow 

Zonotrichia leucophrys White-crowned Sparrow 

Junco hyemalis Dark-eyed Junco 

Calcarius lapponicus Lapland Longspur 

Calcarius pictus Smith's Longspur 

Calcarius ornatus Chestnut-collared Longspur 

Passeriformes • Cardinalidae Tanagers, Cardinals, Grosbeaks, and Allies

Piranga rubra Summer Tanager 

Piranga olivacea Scarlet Tanager 

Cardinalis cardinalis Northern Cardinal 

Pheucticus ludovicianus Rose-breasted Grosbeak 

Passerina caerulea Blue Grosbeak 

Passerina cyanea Indigo Bunting 

Passerina ciris Painted Bunting 

Spiza americana Dickcissel
Appendix A — List of Plants and Animals 77

SCIENTIFIC NAME COMMON NAME

Passeriformes • Icteridae Blackbirds and Orioles

Dolichonyx oryzivorus Bobolink 

Agelaius phoeniceus Red-winged Blackbird 

Sturnella magna Eastern Meadowlark 

Sturnella neglecta Western Meadowlark 

Xanthocephalus xanthocephalus Yellow-headed Blackbird 

Euphagus carolinus Rusty Blackbird 

Euphagus cyanocephalus Brewer's Blackbird 

Quiscalus quiscula Common Grackle 

Quiscalus mexicanus Great-tailed Grackle 

Molothrus ater Brown-headed Cowbird 

Icterus spurius Orchard Oriole 

Icterus galbula Baltimore Oriole 

Passeriformes • Fringillidae • Carduelinae Finches

Carpodacus purpureus Purple Finch 

Loxia curvirostra Red Crossbill 

Acanthis flammea Common Redpoll 

Spinus pinus Pine Siskin 

Spinus tristis American Goldfinch 

Passeriformes • Passeridae Old World Sparrows

Passer domesticus House Sparrow 

Mammals

Didelphis virginiana Virginia Opossum

Sorex haydeni Hayden’s Shrew

Cryptotis parva Least Shrew

Scalopus aquaticus Eastern Mole

Myotis lucifugus Little Brown Myotis

Myotis septentrionalis Northern Myotis

Pipistrellus subflavus Eastern Pipistrelle

Eptesicus fuscus Big Brown Bat

Lasiurus borealis Eastern Red Bat

Lasiurus cinereus Hoary Bat

Nycticeius humeralis Evening Bat

Tadarida brasiliensis Brazilian Free-tailed Bat

Nyctinomops macrotis Big Free-tailed Bat

Dasypus novemcinctus Nine-banded Armadillo

Sylvilagus floridanus Eastern Cottontail

Lepus californicus Black-tailed Jack Rabbit

Marmota monax Woodchuck

Spermophilus tridecemlineatus Thirteen-lined Ground Squirrel

Spermophilus franklinii Franklin’s Ground Squirrel

Cynomys ludovicianus Black-tailed Prairie Dog

Sciurus carolinensis Eastern Gray Squirrel
78 EA, Flint Hills Legacy Conservation Area, KS

SCIENTIFIC NAME COMMON NAME

Sciurus niger Eastern Fox Squirrel

Glaucomys volans Southern Flying Squirrel

Geomys bursarius Plains Pocket Gopher

Perognathus flavescens Plains Pocket Mouse

Chaetodipus hispidus Hispid Pocket Mouse

Castor canadensis American Beaver

Reithrodontomys montanus Plains Harvest Mouse

Reithrodontomys megalotis Western Harvest Mouse

Peromyscus maniculatus Deer Mouse

Peromyscus leucopus White-footed Mouse

Peromyscus attwateri Texas Mouse

Onychomys leucogaster Northern Grasshopper Mouse

Sigmodon hispidus Hispid Cotton Rat

Neotoma floridana Eastern Woodrat

Microtus ochrogaster Prairie Vole

Microtus pinetorum Woodland Vole

Synaptomys cooperi Southern Bog Lemming

Zapus hudsonius Meadow Jumping Mouse

Erethizon dorsatum Common Porcupine

Canis latrans Coyote

Vulpes vulpes Red Fox

Urocyon cinereoargenteus Common Gray Fox

Procyon lotor Common Raccoon

Mustela nivalis Least Weasel

Mustela frenata Long-tailed Weasel

Mustela vison Mink

Taxidea taxus American Badger

Spilogale putorius Eastern Spotted Skunk

Mephitis mephitis Striped Skunk

Puma concolor Mountain Lion

Odocoileus virginianus White-tailed Deer

Antilocapra americana Pronghorn
Appendix B

List of Preparers and Reviewers

Author’s Name Position Work Unit

Vic Elam Legacy project 

coordinator USFWS, Flint Hills National Wildlife Refuge, Hartford, KS

Mark Ely Geographic information 

systems (GIS) specialist USFWS, Region 6, Planning Division, Lakewood, CO

Mike Estey

Habitat and Population 

Evaluation Team 

biologist

USFWS, Flint Hills National Wildlife Refuge, Hartford, KS

Kelly Kindscher Associate scientist Kansas Biological Survey, University of Kansas, 

Lawrence, KS

David Lucas Chief of planning USFWS, Region 6, Planning Division, Lakewood, CO

Tim Menard Wildlife biologist

USFWS, Flint Hills National Wildlife Refuge, Hartford, 

KS; Marais de Cygnes National Wildlife Refuge, 

Pleasanton, KS

Jim Minnerath Wildlife biologist USFWS, PFW, Flint Hills National Wildlife Refuge, 

Hartford, KS

Brian Obermeyer Flint Hills project 

director The Nature Conservancy, Topeka, KS

Sue Oliveira Chief of realty USFWS, Region 6, Realty Division, Lakewood, CO

Mike Rich Project leader for Flint 

Hills NWR USFWS, Flint Hills National Wildlife Refuge, Hartford, KS

Mike Spratt Former chief of 

planning USFWS, Region 6, Planning Division, Lakewood, CO

Amy Thornburg Wildlife refuge 

specialist

USFWS, Region 6, Branch of Land Protection Planning, 

Lakewood, CO

Meg VanNess Regional historic 

preservation officer USFWS, Region 6, Refuges, Lakewood, CO

Reviewer’s Name Position Work Unit

Laurel Bowen Writer/editor TBC Solutions, Clinton, TN

Noreen Walsh Deputy regional 

director USFWS, Region 6, Lakewood, CO

Finding of No Significant Impact

Appendix C
82 EA, Flint Hills Legacy Conservation Area, KS
Appendix C — Finding of No Significant Impact 83
84 EA, Flint Hills Legacy Conservation Area, KS
Appendix C — Finding of No Significant Impact 85
86 EA, Flint Hills Legacy Conservation Area, KS
Compliance Certificate

Appendix D
88 EA, Flint Hills Legacy Conservation Area, KS
Appendix D — Compliance Certificate 89
90 EA, Flint Hills Legacy Conservation Area, KS
Appendix E

Level 1 Report

Due to the large project size, Level 1 Site Assessments will be conducted on a tract-by-tract basis prior to 

acquisition.

Section 7 Biological Evaluation

Appendix F
94 EA, Flint Hills Legacy Conservation Area, KS
Appendix F — Section 7 Biological Evaluation 95
96 EA, Flint Hills Legacy Conservation Area, KS
Appendix F — Section 7 Biological Evaluation 97
98 EA, Flint Hills Legacy Conservation Area, KS
Appendix F — Section 7 Biological Evaluation 99

Appendix G

Comments and Responses

General Support

Comment 1. I like the landscape/regional-scale 

approach that should result in a regional awareness 

of the need for conservation across the area. I like the 

voluntary nature of conservation easements.

Response 1. The U.S. Fish and Wildlfe Service 

(Service) agrees that a regional approach will be 

critical to conservation of the tallgrass prairie and 

grassland-dependent wildlife species.

It is Service policy to seek easements from willing 

sellers only.

Comment 2. I strongly support the U.S. Fish and 

Wildlife’s plan to purchase conservation easements 

as described in your draft EA and land protection 

plan. This is a very effective way of protecting the 

wildlife habitat in the Flint Hills, allowing for 

consistent corridors for birds and wildlife. It will 

provide protection for an extremely endangered 

ecosystem—the tallgrass prairie. It also allows 

for the local ranching economy to participate in 

one’s own destiny, without compromising outright 

ownership. From a political and conservation 

standpoint, I applaud the plan. Please register my 

support for the plan.

Response 2. Thank you for your comments.

Comment 3. You did a good job on the meetings I 

attended as well as the drafts presented. I think the 

initiative is a very positive one. Thank you.

Response 3. Thank you for your comments. 

Comment 4. We support the draft of the USF&WS 

[U.S. Fish and Wildlife Service] Flint Hills Legacy 

Conservation Area initiative and applaud their 

efforts to preserve the Flint Hills tallgrass prairie.

Response 4. Thank you for your comments.

Comment 5. You presented at Alma, Kansas last 

week and I wanted to thank you for your excellent 

presentation and answers to our questions.

I also wanted to thank [the U.S.] Fish and Wildlife 

[Service] for this superb effort. The draft plan and 

environmental assessment look excellent. We are 

especially pleased with the affirmation of good 

prairie management (fire, etc.) and the banning of 

destructive intrusions, such as industrial-scale wind 

facilities. We in the Flint Hills are so encouraged 

by this effort that could make a hugely significant 

difference for wildlife in the tallgrass prairie.

Response 5. Thank you for your comments.

Comment 6. [I am pleased about] protecting the Flint 

Hills of Kansas. 

Response 6. Thank you for your comments.

Comment 7. I was unable to attend any of the 

meetings, but I read completely the land protection 

plan and environmental assessment. I am very 

supportive of them in their entirety. I believe that 

this is a very well-conceived plan that may be the 

best way to achieve the goals of effective large scale 

conservation in the Flint Hills, to the landscape 

objectives mentioned. I am hopeful that this will 

be successfully implemented. Please keep up the 

communication as to progress and issues being 

encountered, and help needed.

Response 7. Thank you for your comments.

As a part of communication and outreach efforts for 

the project, the Flint Hills National Wildlife Refuge 

has established a mailing list for persons wishing 

to receive information on the project in the future. 

Please feel free to contact the refuge or the website 

for additional project information.

Comment 8. I want to go on record as a supporter 

of the Flint Hills Legacy Conservation Area as 

proposed by the U.S. Fish and Wildlife Service.

I live less than 25 miles from the Kansas Flint Hills 

that is part of the North American tallgrass prairie 

and own 3200 acres near Maple Hill, Kansas. I can 

attest to the beauty of the area and the dire need to 

conserve the last 4% of this endangered original 

ecosystem that is now and should remain in private 

hands.

Past experience has proven that conservation 

easements are one of the most efficient and cost 

effective methods of preserving the tallgrass prairie 

for future generations of Americans. Conservation 

easements in the Flint Hills are funded by several 

organizations including Kansas Department of 

Wildlife and Parks, Ranchland Trust of Kansas, 

The Nature Conservancy, Kansas Land Trust, and 
102 EA, Flint Hills Legacy Conservation Area, KS

the USDA [U.S. Department of Agriculture]. To 

preserve the tallgrass habitat on a large landscape 

scale, the above listed organizations need the 

assistance of the USFWS [U.S. Fish and Wildlife 

Service].

If the USFWS’s goal of 1.1 million acres of 

conservation easements can be met in conjunction 

with private landowners and land trusts, the Flint 

Hills tallgrass ecosystem will be ensured protection 

and can remain largely unfragmented.

Response 8. Thank you for your comments.

Wind Energy and Oil and Gas Development

Comment 9. I do understand there are no wind farms 

allowed in a broad context, but the second paragraph 

on page 28 [of the draft EA] where it reads, 

“The proposed action would affect location and 

distribution, but not rate or density, of wind energy 

infrastructure development.” I don’t understand 

what that sentence means, the “rate or density” part. 

Response 9. The language has been changed to 

clarify it.

Funding

Comment 10. I just learned of your Flint Hills 

Legacy Conservation Area. This is going to cost 

money to set up and manage. Is there a Friends 

group set up so the public can provide support 

directly to this FWS initiative?

Response 10. Currently there is not an established 

Friends group, but one may be established in the 

future. The Land and Water Conservation Fund 

(LWCF) will be the primary funding source for 

this project. Currently, LWCF money is derived 

primarily from offshore oil development in the Gulf of 

Mexico.

Comment 11. Am I correct in understanding that 

the only planned federal money would be Land 

and Water Conservation Funds; if other money is 

involved, it would come from various non-federal 

groups or individuals? If the Land and Water 

Conservation Fund is not the only source of funding, 

what other sources are being considered/have been 

selected?

Response 11. The main source of funding for the 

Flint Hills Legacy Conservation Area project would 

be Land and Water Conservation Funds, which are 

derived primarily from oil and gas leases on the outer 

continental shelf, motorboat fuel tax revenues, and 

sale of surplus federal property. However, as with 

other conservation projects, it is possible that nonprofit organizations or individuals may wish to donate 

easements, or that some funds may be appropriated 

by Congress at some point. The Service hopes to 

work with a variety of conservation organizations 

and agencies that already have successful projects 

underway, and would take into consideration any 

opportunities to work with these groups.

The other traditional source of funding for 

conservation projects, the Migratory Bird 

Conservation Fund (duck stamp) would not be 

available for the Flint Hills Legacy Conservation 

Area. There is a possibility that grants or other 

funding opportunities may present themselves down 

the road.

Small Holdings vs. Large Holdings

Comment 12. We were unable to attend the second 

round of community forums regarding the Flint 

Hills initiative, so [we] want to take this means to 

express our approval of the initiative and its form 

as we understand it. Particularly for its exclusion 

of industrial wind turbines, oil and gas exploration, 

and subdivision development, because allowing such 

would defeat the purpose of protecting this unique 

remnant of a (what is now an even more) vital 

ecosystem. 

At the same time we hope you will not rigidly follow 

the numbers that say large holdings are cheaper per 

acre to acquire than small ones, for three reasons:

■ Including some small holdings should increase 

general public interest in and support of the 

initiative;

■ Some small holdings could have strategic 

locations; and

■ Some small holdings could be useful adjuncts 

to larger ones.

We thank you for all the time, thought, and work that 

has been given.

Response 12. Using ranking criteria, the Service 

will acquire the most intact, highest quality habitat 

available from willing sellers. The Fish and Wildlife 

Service will work to obtain the highest quality 

tallgrass prairie habitat available for purchase with 

the available funding. A variety of property sizes 

will likely need to be acquired in order to provide 

the up to 10,000-acre total patch size the Service 

seeks to provide. Properly managed grassland will 

have a mosaic of prairie vegetation and minimal tree 

encroachment.

Expansion of Flint Hills Legacy 

Conservation Area

Comment 13. The North American tallgrass prairie 

is one of our most endangered ecosystems. Less than 

4% of the original ecosystem remains and most of it 

is located in the Kansas Flint Hills. I do wish that 

in the future, the U.S. Fish and Wildlife Service will 
Appendix G — Comments and Responses 103

include the southern Flint Hills which go down into 

Oklahoma. I don’t feel that it should have been left 

out because it is in a different district office.

Conservation easements are cost effective methods 

of preserving the tallgrass prairie for future 

generations of Americans. Many organizations fund 

conservation easements in the Flint Hills; however, 

these organizations need the assistance of the 

USFWS if the tallgrass habitat is to be preserved on 

a large landscape scale.

The U.S. Fish and Wildlife’s goal of 1.1 million acres 

of conservation easements will, in conjunction with 

private landowners and land trusts, ensure that 

the Flint Hills tallgrass ecosystem remains largely 

unfragmented.

I fully support the creation of the Flint Hills Legacy 

Conservation Area and am eager to help the United 

States Fish and Wildlife Service make the plan a 

reality.

Response 13. Several comments were received 

from the public on the possibility of the addition of a 

conservation program for the tallgrass prairie habitat 

located in the state of Oklahoma. Region 2 of the 

Service will take into consideration the possibility of 

future tallgrass conservation efforts in Oklahoma.

Thank you for your comments.

Multiple Comments

Comment 14.1. I am very pleased with landscapescale protection of the Flint Hills! 

Comment 14.2. I am very pleased with the 

preservation of ranching culture. 

Response 14.1–14.2. A landscape-scale approach with 

the ranching culture’s use of appropriate grazing 

and fire regime is essential to the conservation of the 

tallgrass prairie and its grassland-dependent wildlife.

Comment 14.3. I am very pleased with prohibition 

of industrial-scale wind energy, and oil and gas 

development.

Response 14.3. The Fish and Wildlife Service fully 

supports the Department of the Interior alternative 

energy development initiatives. However, the 

incorrect siting of energy development infrastructure 

could have serious impacts on grassland birds.

Comment 14.4. Well done!

Response 14.4. Thank you for your comment.

Comment 15.1 I support the assessment and plan 

as developed and presented. The Flint Hills are 

truly deserving [of] protection and conservation 

easements are the logical approach to provide this 

protection. This is a great use of Land and Water 

Conservation Funds.

Response 15.1. Thank you for your comments.

Comment 15.2. I hope through time you will expand 

the acreage beyond the initial 1+ million acres.

Comment 15.3. I also hope you will target land along 

the interstate to protect that corridor. That land is 

under a lot of pressure for development (Topeka to 

Kansas).

Response 15.2–15.3. The Flint Hills landscape is 

worthy of protecting with conservation easements 

using LWCF. The Service will carefully consider 

the location of areas of acquisition to address 

development pressure and to assess the need for 

expansion of potential conservation efforts in the 

future.

Comment 16.1. I would like to see the tallgrass 

prairie not go to houses and development. I would 

also like to preserve the prairie.

Response 16.1. Thank you for your comments.

Comment 16.2. Forever is a long time. I think 

generational easements may let each generation...

Response 16.2. Perpetual conservation easements are 

utilized instead of short-term contracts to provide 

long-term protection of the habitat and wildlife 

resources.

Comment 16.3. Is water considered a mineral right? 

Response 16.3 Water rights are not being pursued 

as a part of this project, but would be considered 

separately from any mineral resources in a Service 

easement.

Comment 16.4. Your figure 2 map needs to add 

easements from the Grassland Reserve program.

Response 16.4. The project area map includes only 

conservation areas under a permanent form of 

protection.

Comment 16.5. I think people would be more willing 

to do easements by parcels, maybe by farm and 

tract, like FSA [Farm Service Agency] and NRCS 

[Natural Resources Conservation Service].

Response 16.5. The easement program will allow 

some flexibility for landowners on what portions of 

their land is covered in the easement.

Comment 17.0. First, let me say that I am very 

impressed by the amount of research and effort put 

into your study, the history of the area, ecology, and 

culture of the Flint Hills. I know your time was 

limited, but feel you did a thorough job and covered 
104 EA, Flint Hills Legacy Conservation Area, KS

all aspects well. The aspects of the plan I am most 

pleased about include:

Comment 17.1. The actual area targeted is correctly 

identified as the Flint Hills in Kansas.

Comment 17.2. The priority areas targeted are well 

identified and should help in choosing easements.

Response 17.0–17.2. Thank you for your comments.

Comment 17.3. The projection that without additional 

conservation easements the Flint Hills will be 

increasingly fragmented, encroached by trees, 

residential units, industrial and commercial 

development, is correct. The tallgrass prairie would 

be lost. In particular, it is essential to prevent future 

industrial wind complexes from fragmenting the 

prairie. In addition, future residential or “ranchette” 

development could soon turn Flint Hills into brush 

country as has been seen in the Texas Hill Country.

Response 17.3. The Service agrees that Flint Hill’s 

tallgrass prairie habitat is likely to be increasingly 

fragmented by trees and development if current 

trends continue without an overall, landscape-scale 

conservation effort.

Comment 17.4. The projection that these conservation 

easements will help protect the culture and ranching 

heritage, which in turn will help protect and manage 

the tallgrass prairie is also correct.

Response 17.4. The fire-climax tallgrass prairie 

ecosystem and grassland-dependent wildlife require 

an appropriate fire and grazing regime for long-term 

sustainability. The ranching culture provides these 

essential management practices.

Comment 17.5. The proposal that any land under 

the conservation easement agreement must not 

increase the amount of tree or brush coverage, and 

the landowner will be encouraged to decrease the 

amount of woody invasion is a very good one.

Comment 17.6. The proposal that landowners 

with easements will be assisted with advice and 

information in noxious weed control and best 

management practices is good.

Response 17.5–17.6. Control of woody plants and 

other invasive plants is vital to maintaining healthy 

prairie habitat. The programs and assistance offered 

by Partners for Fish and Wildlife (PFW), and the 

NRCS have been very important to these control 

efforts. 

Comment 17.7. The proposal that all easements 

must be from willing sellers and no fee-title land 

acquisitions will be made is essential.

Comment 17.8. The fact that public access remains in 

the hands of the landowners is essential.

Response 17.7–17.8. The Service only obtains 

conservation easements from willing sellers. It is 

clear from input by landowners and the public that 

the acquisition program in the Flint Hills would need 

to be through a conservation easement program, and 

not by fee-title. Service easement acquisitions are 

with willing sellers only, and allow the landowner to 

retain control of public access.

Comment 17.9. The mosaic pattern of 10,000-acre 

parcels separated by a maximum distance of 20 

miles concerns me. The 10,000-acre parcels may 

be fine, but a distance between them of 20 miles is 

too far. That allows for an entire wind complex 

in that space, or much commercial or residential 

development. I would rather see a tighter network of 

easements, even if it includes smaller parcels, either 

contiguous or at 5 or 10 miles apart.

Response 17.9. Placement of easements will be 

determined by the biological needs of the trust 

resources of the Flint Hills—grassland birds. As 

more scientific information becomes available over 

time, the prioritization strategy will be refined to 

incorporate new information.

Comment 17.10. Ranchers must be certain that future 

policy changes by the USFWS or the Department 

of the Interior do not rescind any of the land use 

rights that are provided in these easements. The 

government has a habit of putting different people 

in charge of established programs and changing the 

game rules. It must not happen that some future 

politician can come along and decide the Flint Hills 

should be an ungrazed public park. 

Response 17.10. Service conservation easements 

are legal, binding contracts for both the landowner 

and the Service. The terms defined in the easement 

document will remain constant despite changes in 

refuge personnel.

Comment 17.11. Access to water and all existing 

water rights is essential and should be included in 

the wording of the easements.

Response 17.11. Flint Hills Legacy Conservation 

Area (FHLCA) conservation easement terms do not 

limit access to water, or address water rights usage.

Comment 17.12. Historically proven and generally 

accepted ranching practices including fire, must be 

acceptable and that wording should be included in 

the easements. 

Response 17.12. The appropriate use of prescribed 

fire is essential for maintaining healthy tallgrass 

prairie. Easement language will not dictate fire 

practices by the landowner, but will state that the 

end-state/purpose of the easement is for providing 

intact tallgrass prairie.

Comment 17.13. Equal considerations should be 

given for large or small tracts of land. Reasoning: the 
Appendix G — Comments and Responses 105

smaller ranchers need the lease fee as much or more 

than the larger ranches, otherwise smaller ranchers 

might be more easily enticed to sell to developers 

or residential buyers creating a patchwork of 

fragmentation.

Response 17.13. The Service recognizes that to 

obtain approximately 10,000-acre blocks of high 

quality habitat, consideration will need to be given to 

a variety of ranch sizes.

Comment 17.14. Since preserving the large landscape 

habitat and ecology of the prairie is the goal of these 

easements, splits and carve-outs should be kept at a 

minimum, although the size of the property under 

easement should be considered. My recommendation 

would be that on acreage of one section or less (640 

acres), there should only be one 5-acre carve-out 

allowed and one agricultural split with possibly one 

additional future family residence, not to be in the 

center of the easement.

Comment 17.15. Larger contiguous easements two 

sections or less (1280 acres) that do not already have 

established home sites on them, should be allowed the 

same; one 5-acre carve-out, one agricultural split, 

and one possible future family residence, preferably 

in the existing carve-out and not to be in the center of 

the easement.

Comment 17.16. Easements of over two contiguous 

sections could be allowed one more agricultural split, 

but I would not recommend any more residences.

Comment 17.17. Easements that are not contiguous 

acreage could be allowed agricultural splits of the 

separate parcels (but the parcels themselves should 

not be split), which would allow for neighbors or 

family members to purchase them, but I would not 

allow any more residences. A possible exception 

could be made if a parcel already had an old existing 

home site or a former home site on it.

Response 17.14–17.17. Careful consideration will 

be given to the number of splits (agricultural or 

residential carve-outs) from the footprint covered by 

the easements. It will be essential for the landowner 

and Service staff to discuss future needs and plans 

for any parcel being considered for an easement. 

Local zoning requirements will also determine the 

minimum size of parcels.

Comment 17.18. Easements should allow for access 

to streambed gravel for ranching roads or ranching 

purposes only.

Comment 17.19. Easements should allow for 

reshaping and general erosion management of creek 

crossings regularly used for vehicles, livestock, or 

fences.

Response 17.18–17.19. Easements terms will allow 

for traditional (non-commercial) ranching practices 

such as use of streambed gravel on the landowner’s 

roads, and for general erosion control management.

Comment 17.20. Easements should allow for erosion 

control in creeks and watersheds; for example 

streambed erosion control as approved by NRCS.

Response 17.20. Service conservation easement areas 

will be available for NRCS funding and assistance.

Comment 17.21. Initial applications will be slow in 

coming due to general distrust of the government. 

But if you present a stable, open, and honest upfront program, you will get applications. Once a few 

easements have been accepted and [are] in place, 

area landowners will closely watch the results. Good 

results will yield many more easements.

I hope these suggestions will assist you in your final 

planning. We certainly hope you are successful 

in your proposal for the Flint Hills Legacy 

Conservation Area. It would lend a great amount 

of stability to the ranching community and the 

tallgrass prairie.

Response 17.21. We have implemented similar 

conservation easement projects in other areas. The 

Service looks forward to working with landowners in 

the Flint Hills to develop a successful program. 

Thank you for your comments.

Comment 18.1. I am pleased that no commercial wind 

projects would be allowed in the proposed easements. 

Also it appears there is some flexibility on the lease 

agreement language regarding splits.

Response 18.1. The biological needs of grassland bird 

species dependent on prairie preclude wind (or other 

tall vertical structures) on conservation easement 

lands.

See also the response to comment 17.14–17.17.

Comment 18.2. [The environmental assessment] 

needs to address watershed issues, especially the 

federal-funded watersheds.

Response 18.2. See the response to 17.11 and 17.20.

Comment 18.3. On page 28, second paragraph, first 

sentence [of the draft EA] reads, “the proposed 

action would affect location and distribution, but 

not rate or density, of wind energy infrastructure 

development.”

Response 18.3. The language has been changed to 

clarify it in the final EA (see page 28).

Comment 18.4. Good meeting you have hosted. Keep 

up the good work.

Response 18.4. Thank you for your comments.
106 EA, Flint Hills Legacy Conservation Area, KS

Comment 19.1. I am generally supportive of the idea 

of using conservation easements to preserve wildlife 

in the Flint Hills. However, I have some concern 

about how the U.S. Fish and Wildlife Service plans to 

implement this program.

After reading the proposed Flint Hills Legacy 

Conservation Area (FHLCA) material (September 

2009) and attending scoping meetings held last fall, 

several issues come to mind. They can be sorted into 

three categories: ecological, economic, and cultural.

Although the material mentions flora and fauna 

that may benefit from said easements, no metrics 

are mentioned that would actually substantiate this 

claim over time. 

Response 19.1. The benefits to flora and fauna are 

substantiated by research that points out that the 

native species are negatively impacted by habitat 

fragmentation in a number of ways that this project 

hopes to prevent (Kuvlesky et al. 2007, McDonald et 

al. 2009, Giesen 1994, Fuhlendorf et al. 2002, Robel 

2002). See specific information on ecological impacts 

and responses of fragmentation pages 23–26 of the 

final EA. 

There are a variety of levels of tallgrass prairie 

habitat quality throughout the Flint Hills. Using 

ranking criteria for evaluation, the Service will 

acquire the highest quality, most intact tallgrass 

habitat available from willing sellers with the funds 

that are available. 

Comment 19.2. Further, there appears to be no level 

of accountability regarding range health asked 

of landowners who participate in the program. 

Preserving the “status quo” is an inadequate result 

for such an extensive venture.

Response 19.2. It is generally accepted that reducing 

or eliminating habitat fragmentation is the first 

step toward protecting the Flint Hills habitat. If 

the conditions of the easement are so restrictive to 

landowners that they are unwilling to participate, 

then there is no chance for project success. The 

Service had discussions with landowners during the 

scoping process about requirements to maintain tree 

encroachment at or below the current level and to 

restrict herbicide application to spot treatments.

Comment 19.3. The effects of annual and excessive 

range burning in the Flint Hills have come into 

question. There was even a time (1950s) when the 

practice was discouraged. 

Response 19.3. We recognize that while grazing 

and prescribed burning practices are essential to 

maintaining tallgrass prairie in the Flint Hills, they 

can also degrade habitat when not used properly. 

The fire-climax tallgrass prairie ecosystem and 

grassland-dependent wildlife require appropriate 

fire and grazing regimes for long-term sustainability. 

The ranching culture provides these essential 

management practices.

 The PFW program and other conservation programs 

have been working with Flint Hills ranchers to alter 

management practices in ways that benefit habitat 

but do not significantly decrease ranch profitability.

Also, see the response to comment 19.2.

Comment 19.4. Preserving “ranching lifestyles and 

economies” may be in direct contradiction to the 

stated “preserve and protect’ mission of the USFWS.

Response 19.4. See the response to comment 19.2.

Comment 19.5. More specifically, there appears to 

be a direct correlation between Early Intensive 

Stocking, which began in the 1980s, and the decline of 

the greater prairie-chicken.

Response 19.5. See the response to comment 19.3.

Comment 19.6. The easements prohibit residential 

and commercial development, but do not prohibit 

further extraction of petroleum resources as they are 

grandfathered as a “traditional” use. This too, flies 

in the face of the stated purpose of the FHLCA which 

is “to help maintain the integrity of ... stream water 

quality.”

Response 19.6. The Service has no authority to 

prevent mineral extraction from property where 

the mineral rights have already been sold (severed 

estate) (USFWS Manual 612 FW2). If the mineral 

rights are not severed, the easement that the Service 

acquires will require any mineral extraction (or other 

energy development) to occur off-site to prevent 

habitat fragmentation.

Comment 19.7. If an easement permanently severs 

and removes distinct economic values from the 

landscape, it is short sighted to allow that event to 

benefit the initial generation only.

Response 19.7. The easements will be obtained 

from willing sellers only. Maintaining healthy 

tallgrass prairie and its aesthetic values for future 

generations can provide economic benefits for 

wildlife recreationists and for agri-tourism in the 

region. Conserving tallgrass prairie may even 

increase land values on adjacent properties. The 

easement program would to a large extent maintain 

the existing conditions for landowners and the 

general public, and will not significantly affect the 

quality of the human environment, and will not have 

a close causal connection to a change in the physical 

environment (40 CFR 1508.27). 

Comment 19.8. An easement that is perpetual should 

pay in perpetuity. The same money currently 

designated to make one-time payments for easements 

could be pooled, invested wisely, and made to 
Appendix G — Comments and Responses 107

produce an enduring stream of income for current 

and future landowners.

Response 19.8. This comment is received and 

considered, however, the Service’s normal practice 

is to make a one-time payment. How that income is 

managed or invested will be left to the individual 

landowner. 

Comment 19.9. Stripping off development rights 

in one generation will depress the value of land 

carrying an easement and therefore the easement 

will negatively affect local tax rolls.

Comment 19.10. However, land that has kept this 

value intact through a pre-established flow of 

easement funds (as suggested in item #4 [comment 

19.8]) will have an elevated value just as land sold 

with an ongoing mineral royalty is more highly 

valued.

Response 19.9–19.10. Tax valuation is based on the 

agricultural value of the land, which would not be 

impacted by an easement. Land values can actually 

increase if there are protected viewsheds and lands 

adjacent to a property.

Comment 19.11. If there are measurable 

improvements in the flora and fauna due to the 

implementation of an easement, an enhanced 

recreational value will emerge. Many “traditional” 

ranches in Texas now garner more return from 

hunting and fishing than from cattle (the “historic” 

use). FHLCA easements now being considered 

would make it more difficult, if not impossible, for a 

landowner to develop any additional infrastructure 

to capture the economic benefit of an enriched 

landscape.

Response 19.11. Landowners may have some limited 

options for carving out portions of their property 

from the easement, thereby allowing other uses 

or future structures/building construction. The 

easement will only limit the construction of additional 

structures in areas that are not located in carveout portions of the property. The landowners will 

retain access control, including public recreational 

activities.

Comment 19.12. FHLCA easements will disallow 

all local and regional power of eminent domain 

regarding electrical transmission lines. Only the 

federal Department of Energy would have the 

authority to require a transmission easement across 

affected property.

Comment 19.13. Essentially, the FHLCA easements 

could present a significant barrier between the rich 

wind energy resource in western Kansas and load 

centers in the eastern U.S. eager for renewable power.

Response 19.12–19.13. Of the 3.3 million acre 

acquisition boundary we would have authority to 

purchase easements on one third of that area, leaving 

the remainder as avenues for any necessary energy 

transmission routes. Currently there are already a 

number of transmission lines in place throughout the 

Flint Hills region and Kansas. (A map is available 

at http://kec.kansas.gov/chart_book/Chapter6/02_

KSWindEnergyElectricTransMap.pdf)

Also, Service easements would not affect areas with 

a utility right-of-way already in place.

Comment 19.14. The greatest impediment to broadscale cultural acceptance of these easements will be 

the perpetual nature of them: people are generally 

uncomfortable about compromising an asset’s value 

in the face of the uncertain needs of the future. 

USFWS may wish to allow an “opt-out” window 

every 25 years. 

Comment 19.15. It is unlikely that a landowner will 

opt-out of the easement for the following reasons.

■ Having received a steady cash flow (item #4 

[comment 19.8]) for 25 years, landowners 

would be unlikely to relinquish that income.

■ Penalties for opting out should be severe; for 

example, four times the amount received over 

the past 25 years. 

Response 19.14–19.15. This comment is taken under 

advisement. The current easement acquisition 

strategy permanently prevents habitat destruction 

resulting from residential and commercial 

development activities. The easements will be 

acquired from willing sellers only.

Comment 19.16. USFWS may find its objectives better 

served by a long-term contract as implemented in 

the USDA’s Conservation Reserve Program that has 

been well accepted by the agricultural community.

Response 19.16. In addition to the option of shorterterm programs such as the USDA program, there is 

now interest in a Flint Hills conservation program 

that can provide perpetual preservation of tallgrass 

prairie.

Perpetual conservation easements are preferred by 

the Service instead of short-term contracts in order 

to provide long-term protection of the habitat and 

wildlife resources.

Comment 20.1 The draft environmental assessment 

of the proposed Flint Hills Legacy Conservation 

Area says that the project “would be monitored as 

part of the Refuge System in accordance with the 

National Wildlife Refuge System Administration 

Act of 1966.” Does that meant that NWRSAA 

[National Wildlife Refuge System Administration 

Act of 1966] regulations would apply, just as if this 

were in fact a refuge?
108 EA, Flint Hills Legacy Conservation Area, KS

Response 20.1 If approved, the Flint Hills Legacy 

Conservation Area will be established as a unit 

of the National Wildlife Refuge System (NWRS). 

The National Wildlife Refuge System is the largest 

network of lands in the world dedicated to the 

protection of wildlife and its habitats. The NWRS 

has now been in existence more than one hundred 

years and there are numerous designations, legal 

authorities, etc., that have been used to create what 

we have today. You will notice we have national 

wildlife refuges, waterfowl production areas, 

conservation areas, wetland management districts, 

etc. The NWRS also has a wide variety of interests 

in lands—ranging from unique deed relationships 

with states, for example, the Rockefeller Refuge in 

coastal Louisiana—to management responsibilities 

associated with New Deal programs. The Flint Hills 

Legacy Conservation Area will be managed as a unit 

of the National Wildlife Refuge System consistent 

with the mission of the NWRS. 

Although FHLCA would be managed as a unit of 

the National Wildlife Refuge System, conservation 

easement refuges differ from traditional national 

wildlife refuges in that the landowner retains 

ownership, control of public access and land 

management practices, and no additional fencing or 

posting of signage is required by the NWRS.

In this EA, the Service has determined that 

conservation easements are the appropriate manner 

to enhance population goals where fragmentation 

and degradation of habitat is a limiting factor on 

declining species. The Service has a long history of 

success using conservation easements to support 

the biological needs of such species. Strategic 

habitat conservation is essential across such large 

landscapes and we hope the document allows readers 

to understand that it is possible to best achieve the 

conservation protections we desire by working with 

landowners in the Flint Hills to develop a long-term 

(multi-generational) approach to preserve a very 

important piece of the American landscape. 

Comment 20.2. The draft EA says what the Refuge 

System’s mission is, but doesn’t appear to articulate 

the proposed [Flint Hills Legacy] Conservation 

Area’s mission. It does state the area’s purpose. Is 

the mission the same as the purpose? If there is a 

separate mission statement, can you send that to 

me? If it has not yet been drafted, what is the time 

frame for creating it and who will draw it up?

Response 20.2. There is not a mission statement for 

each land designation. Specifically you ask if there 

is a mission for conservation areas. No, all units of 

the National Wildlife Refuge System mission will 

be managed in accordance with existing laws and 

regulations and under the mission statements of the 

Service and the National Wildlife Refuge System.

Comment 20.3. Has it been determined where the 

funding will come from? If the Land and Water 

Conservation Fund is not the only source of funding, 

what other sources are being considered/have been 

selected.

Response 20.3. The main source of funding for 

the Flint Hills Legacy Conservation Area will be 

Land and Water Conservation Funds, which are 

derived primarily from oil and gas leases on the 

outer continental shelf, motorboat fuel tax revenues, 

and sale of surplus federal property. However, 

as with other conservation projects, it is possible 

that non-profit organizations, or individuals may 

wish to donate easements, or that some funds may 

be appropriated by Congress at some point. The 

Service hopes to work with a variety of conservation 

organizations and agencies that already have 

successful projects underway, and would take into 

consideration any opportunities to work with these 

groups.

Comment 21.1. I agree with the terms of these 

easements as outlined in the draft. 

Response 21.1. Thank you for your comments.

Comment 21.2. Prioritization for large blocks of 

intact property in the heart of the Flint Hills is 

important in that it will provide for ample habitat 

for tallgrass prairie wildlife such as the “key” lesser 

prairie-chicken species. 

Response 21.2. Conservation of large blocks of intact 

tallgrass prairie will be essential to providing habitat 

for grassland-dependent birds and maintaining a 

migration corridor.

Comment 21.3. I was pleased to hear that the plan 

will preclude wind energy development. Turbines 

and towers have no place in a natural ecosystem 

conservation project such as this one.

Response 21.3. Preliminary studies indicate tall 

vertical structures fragment large tracts of otherwise 

appropriate habitat, making it unsuitable for some 

grassland bird species.

Comment 21.4. On the same note, your approach 

to existing oil and gas operations and mineral 

royalty rights seems practical in that non-mineral 

owners with existing operations will be managed 

to minimize impact, while owned minerals will be 

valued and paid for to preclude development.

Comment 21.5. Maybe the same approach being used 

with oil and gas could be used concerning power 

lines and other easements that might exist. 

Response 21.4–21.5. On properties where wind, oil 

and gas, or mineral rights have already been sold 

(severed from the estate), the Service will work with 

landowners and developers to minimize any negative 

impacts of development and extraction activities (50 

CFR 25.11). On land where the rights for wind, oil 
Appendix G — Comments and Responses 109

and gas, or mineral development have not been sold 

(estate is still intact), conservation easements would 

require non-surface occupancy (off-site development) 

for any future development activities. The Service 

would consider development of energy and mineral 

resources on the easement properties, if they can 

be implemented without disturbing the surface or 

creating vertical barriers, which would fragment the 

grassland habitat for wildlife.

Comment 21.6. Concerning management practices, 

I strongly believe that three things must exist 

to sustain a tallgrass prairie: fire, grazing, and 

substantial spring precipitation. Therefore, I was 

happy to hear that restrictions on burning are not 

anticipated. Fire is important to prairie habitat and 

as smaller acreage properties encroach upon the 

Flint Hills prairie there seems to be an undertone of 

detractors to the use of fire. 

Response 21.6. The fire-climax tallgrass prairie 

ecosystem and grassland-dependent wildlife require 

an appropriate fire and grazing regime for long-term 

sustainability. The ranching culture provides these 

essential management practices.

Comment 21.7. Additionally, there are recent claims 

that prairie fire has some correlation with the 

reduction in prairie-chicken numbers. I would be 

careful in concluding that this issue is a result of 

fire. Fire has occurred on this specific prairie for 

hundreds of years, and the Flint Hills remain as the 

last 2% of the tallgrass prairie that once stretched 

from Canada to Mexico.

Response 21.7. We recognize that while grazing 

and burning practices are essential to maintaining 

tallgrass prairie in the Flint Hills, they can also 

degrade habitat when not used properly. The PFW 

program and other conservation programs have 

been working with Flint Hills ranchers to alter 

management practices in ways that benefit habitat 

but do not significantly decrease ranch profitability.

Comment 21.8. Reasons why the Flint Hills and the 

prairie chickens have remained include continued 

use of fire, grazing, and un-interruption of large 

blocks of prairie lands. Areas that were once 

tallgrass prairie and have discontinued using 

grazing and fire have lost prairie-chickens and 

prairie to woody plant species. Prairie-chickens 

need prairie and and healthy prairie needs fire and 

grazing.

Response 21.8. The fire-climax tallgrass prairie 

ecosystem and grassland-dependent wildlife require 

an appropriate fire and grazing regime for long-term 

sustainability. The ranching culture provides these 

essential management practices.

Comment 21.9. All in all, I believe you have 

generated a sound environmental assessment and 

land protection plan. I hope Congress appropriates 

sufficient funding for this project and easement 

purchases begin soon.

Response 21.9. Thank you for your comments. 

Comment 22.0. I was excited to hear that the U.S. 

Fish and Wildlife Service was considering a 

conservation easement program to preserve prairie 

in the Flint Hills. However, after reviewing the draft 

document, I am disappointed to see the apparent 

exclusion of required range management practices 

in the easements; specifically, the lack of prohibition 

of annual burning and early intensive stocking as 

currently practiced by most Flint Hills landowners. 

I would, therefore, like to submit the following 

comments: 

Comment 22.1. The fact that only two alternatives 

(no action and the proposed action) were considered 

is in my experience quite unusual. Obviously, 

an alternative requiring best range management 

practices should have been included. In fact, it is not 

even mentioned in the alternatives considered but 

not studied (draft EA, page 10).

Response 22.0–22.1. Typically, Conservation Area 

land protection plans (LPPs) typically involve two 

alternatives, a no action (non-acquisition alternative), 

or an acquisition option that will establish a new unit 

of the National Wildlife Refuge System. 

The text of the draft EA has been revised to reflect 

the additional alternatives that were considered 

but not studied further, such as fee-title acquisition, 

or options considering smaller and larger project 

boundaries (see page 10 of the final EA).

Specifically, Service-defined range management and 

prescribed fire management practices would have to 

be implemented on lands owned in fee-title by the 

Service, such as Quivira National Wildlife Refuge. 

Conservation Areas, such as the Flint Hills Legacy 

Conservation Area, are easement refuges with 

minimal interest (typically just non-development 

rights) acquired. Although the Flint Hills Legacy 

Conservation Area will be considered a part of the 

National Wildlife Refuge System, the land will still 

remain in private ownership and as such cannot be 

held to the same requirements and limitations placed 

upon a refuge owned in fee-title. 

Comment 22.2. As cited in the draft environmental 

assessment, the prairie ecosystem developed under 

burns estimated to have occurred at 3–5 year 

intervals and in a patch pattern, resulting in the 

mosaic of habitats the plan claims to want to achieve. 

In fact, FWS uses patch, or rotational burning on 

its own properties (for example Quivira National 

Refuge) and specifies land management practices on 

easements it holds in other areas. Why then would 

FWS not require use of such management practices 

on the easements it is seeking under this program? 
110 EA, Flint Hills Legacy Conservation Area, KS

FWS personnel stated at both meetings I attended 

that management practices are subject to change 

and therefore cannot be included in a perpetual 

easement. In face of the fire history record (as cited), 

best management practices should be required and 

be modeled after those conditions under which the 

ecosystem developed. 

Response 22.2. The fire-climax tallgrass prairie 

ecosystem and grassland-dependent wildlife require 

an appropriate fire and grazing regime for long-term 

sustainability. The ranching culture provides these 

essential management practices.

Comment 22.3. FWS must certainly be aware that 

Kansas is under mandate by the Environmental 

Protection Agency to develop a smoke management 

plan because of the impacts of the Flint Hills 

burns. These annual, spring burns have resulted in 

exceedence of Clean Air Act standards in Kansas 

City and Wichita, and impact air quality in areas 

several states away. Surely, requiring less burning 

each year could be part of such a smoke management 

plan and should be incorporated into the proposed 

FWS easements.

Response 22.3. The Service considered that there 

would likely be little to no change in the impact 

to human health as a result of this project and 

maintains that we are not requiring landowners to 

change their burning practices (see the response to 

comment 22.1). The Service hopes to work through 

the PFW program to influence landowners to 

burn less frequently, but there is no evidence that 

decreasing frequency would result in decreased air 

quality problems—if an area is burned once every 

three years, it may produce three times the amount 

of smoke as when it is burned annually because of 

the increased fuel load. This may result in a no net 

gain across the region. Future programs such as 

the BlueSkyRAINS program through Kansas State 

propose to provide information on smoke and air 

quality effects from prescribed fires in the Flint Hills.

Comment 22.4. At both meetings I attended, FWS 

indicated that current range management practices 

would be considered in selecting properties for 

potential easement and that burning practices 

would be part of that consideration. If that is so, why 

shouldn’t that be spelled out in the draft as part of 

the easement acquisition process parameters (draft 

EA, page 8)?

Response 22.4. There are a variety of levels of 

habitat quality for tallgrass prairie throughout the 

Flint Hills. Using ranking criteria the Service will 

acquire the most intact, highest quality habitat 

available from willing sellers. Properly managed 

grassland will have a mosaic of prairie vegetation and 

minimal tree encroachment.

The Service has determined that local landowners, 

with few exceptions, would be unwilling to 

accept an easement if it involves giving up such 

management practices as burning or determining 

their own stocking rates. In order to have control of 

management activities such as stocking rates and 

burning, we would have to own the property in feetitle. Fee-title sales of land to the federal government 

would not be supported by Flint Hills landowners. 

Additionally, fee-title would cost approximately three 

times the amount of a conservation easement. Annual 

operation and maintenance costs for the Service 

would also be considerable. While not specifically 

addressed in the final EA, the Service will include 

provisions in the easement for maintaining tree 

encroachment at no more than current status when 

the easement is established. The Service expects 

local and state requirements for noxious and invasive 

weed control to be observed, and plans to work with 

landowners through the PFW program to assist 

them in accomplishing weed control.

Comment 22.5. Finally, no mention is made in the 

draft environmental assessment of the documented, 

extremely negative impact annual burning has 

had on wildlife habitat that FWS is supposed to 

be protecting. One could easily argue, that current 

range management practices in the Flint Hills 

are the single greatest cause of habitat reduction, 

particularly that needed for grassland birds such as 

the greater prairie-chicken. Such lack of control of 

management practices on land under jurisdiction of 

FWS is counter to the FWS mission. 

Response 22.5. While the Service recognizes 

that there are examples of land mismanagement 

across the 3.3 million acre project area, and that 

mismanagement often leads to habitat degradation, 

the most important contribution the Service can 

make is to protect the land from fragmentation. 

Service policy is to acquire land only when other 

means, such as zoning or regulation, of achieving 

program conservation goals and objectives are not 

appropriate, available, or effective. When lands are 

to be acquired, the minimum interest necessary 

to reach management objectives is to be acquired 

or retained. If fee-title ownership is required, 

full consideration will be given to extended use 

reservations, exchanges, or other alternatives that 

will lessen impact on the owner and the community. 

Also see response to comment 22.4.

Comment 22.6. Thank you for your consideration 

of these comments. I hope that the agency sees fit to 

make appropriate changes in the final documents.

Response 22.6. Thank you for your comments.

Comment 23.1. It is critical that individuals with a 

demonstrated experience of successfully working 

with ranchers and landowners in the Flint Hills 

region be directly involved in the development and 

drafting of the conservation easement document 
Appendix G — Comments and Responses 111

and the ranking process/procedures for determining 

those properties on which USFW will purchase a 

conservation easement. One size does not fit all and 

without the direct influence of “local knowledge,” I 

am concerned that the initial easement document 

and ranking process will miss the mark and make it 

more difficult for USFW to establish the credibility 

and trust needed for this project to be a long-term 

success.

Response 23.1. The Service will continue to involve 

local partners/landowners in the planning process, 

along with local Service personnel who have local 

experience or expertise working with conservation 

easements.

Comment 23.2. Fragmentation and fire exclusion 

are the two most dangerous enemies of Flint 

Hills conservation. I would prefer that the USFW 

easement did not allow for future building envelopes. 

That said, in order to preserve the ranching culture 

of the Flint Hills (which culture, in turn, preserves 

the Flint Hills), it may be prudent to allow a very 

limited number of future building sites ... if so, 

please mandate that such sites be located in already 

disturbed areas that are not capable of carrying 

fire and are located below the horizon line. It’s 

important that any future building sites do not 

become additional physical or psychological barriers 

to fire and that they do not contribute to the further 

degradation and fragmentation of the natural 

viewshed. A good rule of thumb would be to locate 

future building envelopes only in timbered locations 

proximate to nineteenth century home sites. 

Response 23.2. The Service agrees that a landscapescale approach with the ranching culture’s 

appropriate use of a grazing and fire regime is 

essential to the conservation of the tallgrass prairie 

and its grassland-dependent wildlife.

Landowners may have some limited options for 

carving out portions of their property from the 

easement, thereby allowing other uses or future 

structures/building construction. The easement will 

only limit the construction of additional structures in 

areas that are not located in carve-out portions of the 

property. The landowners will retain access control, 

including public recreational activities. Carve-outs 

would be allowed along already fragmented areas, 

for example, roads and buildings, and on cropland 

that is not important to the overall intactness of the 

landscape.

Comment 23.3. It is critical that the final plan and 

conservation easement explicitly prohibit any 

development of wind energy, oil/gas (including coalbed methane) or any other industrial or commercial 

development. Properties that already have oil/gas 

development should not be excluded from the project, 

but should rank lower than a comparable property 

that is not encumbered by such development.

Response 23.3. Industrial and commercial 

development that fragments the grasslands will not 

be allowed. The Service would consider development 

of energy and mineral resources on the easement 

properties, if they can be implemented without 

disturbing the surface or creating vertical barriers, 

which would fragment the grassland habitat for 

wildlife. 

Comment 23.4. The exception to allow stream bed 

gravel use should apply to all existing ranch uses—

not just to the homesite. For example, a sizeable 

ranch may have many miles of two-track ranch 

roads and property owners should be allowed to 

continue to maintain these roads with their own 

gravel. Cattle pens are also a place where creek 

gravel is commonly used and such use should be 

allowed to continue.

Response 23.4. A number of comments were 

received during public meetings on the maintaining 

landowner access to gravel resources. Stream 

bed gravel extraction will be allowed for ranching 

processes. No commercial gravel extraction activities 

will be allowed. Stream bed gravel extractions 

will be subject to all local, state, and federal laws. 

Individual landowners will need to determine any tax 

implications.

Comment 23.5. The USFW should not require 

a landowner to offer all of her land holdings to 

be placed under easement at the same time. For 

practical and personal reasons, it is likely that many 

interested landowners may not be willing or able 

to sell an easement on all of their otherwise eligible 

land at any one time.

Response 23.5. Conservation easements will be 

acquired from willing sellers. No one will be forced 

to offer land they do not wish to place under an 

easement.

Comment 24.1. I am disappointed to know that the 

30 day comment period started, apparently, when 

the EA was posted on the web and not when the first 

public meetings were held. I understand the legalities 

involved, but what’s right isn’t always what’s correct.

Response 24.1 The draft EA and LPP were provided 

prior to the public meetings to provide the public 

with an opportunity to review the documents in 

advance of the public meetings and to have the time 

to provide substantive comments on the specific 

information in the plans.

Comment 24.2. I support the concept of the plan BUT 

I have great concerns over the EA document itself, 

and what that casts on the entire plan. The bird 

list in the appendix is a horrible mess and I think 

it reflects very badly on the entire document. Any 

biologist that really looks at this and pays attention 

will notice this and wonder what’s up with the rest of 

the document. Whomever put the document together 
112 EA, Flint Hills Legacy Conservation Area, KS

did not use a current American Ornithologists 

Union taxonomic order as a guide. At least once, a 

bird is listed twice and some species have the wrong 

scientific name associated with them. Species that 

are commonly found in the Flint Hills region are 

omitted and species that are far less common are 

included. In at least one case (American Dipper, 

Cinclus mexicanus) you have a species that isn’t 

even documented to have ever occurred in Kansas, 

let alone in the Flint Hills. I started reading this list 

and to be right honest, I was appalled. There are lots 

of resources and people, myself included, available to 

make this list a correct list. Just give us the chance!

Response 24.2. The EA species appendix has been 

modified to correct the errors in the bird species list.

Comment 24.3. I continue to be concerned by the 

lack of coordination with entities that could make 

or break this project. For this to be successful many 

groups need to buy in to it and support it. As this 

has been ran so far, it looks quickly and shoddily 

thrown together and driven from the top down. That 

doesn’t fly well in this state where private property 

rights and local control are so highly valued. I fear 

that this project has started off on the wrong foot and 

will make it very difficult for a potentially extremely 

valuable program to have success.

Thank you for taking the time to listen to my 

concerns. As always, I am available to help make 

this a positive program with countless benefits to the 

Flint Hills ecoregion and its residents.

Response 24.3. The Service became involved in the 

Flint Hills tallgrass conservation effort due in a 

large part to the interest expressed by a variety of 

organizations and agencies for an overall landscapescale Service-led conservation effort in the region. 

The Service believes that ongoing coordination 

and communication regarding conservation of 

tallgrass prairie resources is essential to the success 

of the project. The Service will continue to work 

collaboratively with individuals, nongovernmental 

organizations, federal, state, and local agencies on 

a variety of issues, including renewable energy 

development. Also, the Service has initiated 

a program using Landscape Conservation 

Cooperatives (LCCs) as a means of addressing 

conservation and climate change challenges through 

partnership opportunities (see page 35 of the final 

EA). 

Thank you for your comments.

Agency, Organizations, and Commercial 

Corporation Comments

Agency comments received include the original letter 

received and our responses. Comment 25 is on the 

following page.

Comment 25. Attachments included in the letter are 

as follow:

■ NOAA Hazard Mapping System graphic

■ Downwind Monitors with Ozone Exceedances 

in Smoke Plumes by Satellite Imagery table

■ Unlabeled map

■ USFWS Real Property Part 341, Chapter 6, 

Directors Orders 164 and 170

■ Major Negative Impacts of Early Intensive 

Cattle Stocking on Tallgrass Prairies: The 

Case of the Greater Prairie-Chicken. North 

American Birds, Volume 56 (2002) Number 2 

pp. 239–244

■ Location and Success of Lesser Prairie-chicken 

Nests in Relation to Vegetation and Human 

Disturbance. Journal of Wildlife Management 

69: 1259–1269; 2005

■ Sample Grassland Easement (Region 6)

■ Sample Habitat Easement (Form 1) 

■ Sample Habitat Easement (Form 2) 

■ Sample Habitat Easement (Form 4) 

■ Article by Jan Stiles, Birds declining in the 

Flint Hills 

■ Article by Jan Stiles, Prairie chicken habitat 

being lost
Appendix G — Comments and Responses 113

 Comment

#

25.1

Letter # 25 Response

ildlife Service would like to take this 

Response 25. Thank you for your interest in the FHLCA project. The U.S. Fish and Wopportunity to address some concerns and misinformation and/or misconceptions that the Sierra Club perceives as part of the 

While the Service recognizes that there are examples 

FHLCA project.Response 25.1. of land mismanagement across the 3.3 million acre project area, and that the mismanagement often leads to habitat degradation, the most important contribution the Service can make is to protect the land from fragmentation. In addition to the importance of proper grazing practices, one of the management implications 

ildlife Management article submitted suggested in the Journal of W

with the Sierra Club comments is the protection of lesser prairiechicken habitat from development, and acquisition of lands without anthropogenic features present. A number of other authors have addressed the fragmentation effects of infrastructure on prairie grouse (Kuvlesky et al. 2007, McDonald et al. 2009, Giesen 1994, Fuhlendorf et al. 2002, Robel 2002).Service policy is to acquire land only when other means, such as zoning or regulation, of achieving program conservation goals and objectives are not appropriate, available, or effective. When lands are to be acquired, the minimum interest necessary to reach management objectives is to be acquired or retained. If fee-title ownership is required, full consideration will be given to extended use reservations, exchanges, or other alternatives that will lessen impact on the owner and the community. The Service has determined that local landowners, with few exceptions, would be unwilling to accept an easement if it involves giving up such management practices as burning or determining their own stocking rates. In order to have control of management activities such as stocking rates and burning, we would have to own the property in fee-title. Fee-title sales of land to the federal government would not be supported by Flint Hills landowners. 

, fee-title would cost approximately three times Additionally

the amount of a conservation easement. Annual operation and maintenance costs for the Service would also be considerable. While not specifically addressed in the draft EA, the Service will include provisions in the easement for maintaining tree encroachment at no more than current status when the easement is established. The Service expects local and state requirements for noxious and invasive weed control to be observed, and plans to work with landowners through the PFW program to assist them in accomplishing weed control.

Appendix G — Comments and Responses 113
114 EA, Flint Hills Legacy Conservation Area, KS Comment

#

25.2

Letter # 25 Response

ildlife Service The mission of the U.S. Fish and W Response 25.2. 

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

ildlife Refuge the American people. The mission of the National W

System is to preserve a national network of lands and waters for the conservation, management, and, where appropriate, restoration of fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans. Although the FHLCA will be considered a unit of the National Wildlife Refuge System, the land will still remain in private ownership and as such cannot be held to the same requirements and limitations placed upon a refuge owned in fee-title. There are a variety of levels of habitat quality for tallgrass prairie throughout the Flint Hills. Using ranking criteria the Service will acquire the most intact, highest quality habitat available from a willing seller with the funding that is available. By preventing additional fragmentation, the Service and other conservation partners plan to help preserve tallgrass prairie habitat for future 

 There is not a National Environmental Policy Act 

generations. Also, see the response to comment 20.Response 25.3.requirement to conduct scoping meetings, or how to specifically incorporate comments. Scoping comments were used to develop the draft EA, and were consolidated into broad categories of interest included in the “Issues Identified and Selected for 

o address substantive comments on the draft Analysis” on page 5. T

EA and page 91 of this final EA, the Service decided to use the format used here to address the comments in more detail.The text will be revised to read, “Concern about short-term 

, intensive grazing) activities, (including annual burning and early

are having long-term impacts to the tallgrass prairie.” To address the more specific, substantive comments received for the draft EA and LPP, individual comments and responses are included in 

The Service did not construct additional alternatives 

Appendix G of the final EA and LPP documents. Response 25.4. for controlling burning and stocking rates because as mentioned 

, for the Service to use earlier, it is not feasible, or necessary

fee-title acquisition in the Flint Hills. The text of the draft EA has been revised to reflect additional alternatives that were 

, such as fee-title acquisition, or considered, but not studied further
 Comment

#

25.325.425.525.6

Appendix G — Comments and Responses 115

Letter # 25 Response

-

a smaller or a much larger project boundary in the “Alternatives Considered but not Studied” section (see page 10 of this final EA).

. The Service considered that there would likely be Response 25.5

little to no change in the impact to human health as a result of this project and maintains that we are not requiring landowners to change their burning practices. The Service hopes to work with 

ildlife program 

, but there is no 

landowners through the Partners for Fish and Wto influence landowners to burn less frequentlyevidence that decreasing frequency would result in decreased air quality problems—if an area is burned once in three years it may produce three times the smoke when it is burned because of the increased fuel load, which may result in a no net gain across the region. Future programs such as the BlueSkyRAINS program through Kansas State propose to provide information on smoke and air quality effects from prescribed fires in the Flint Hills.Concerning the affects of burning on bird viewing, photography, 

s easements will not control burning timing and hiking; the Service’

or frequency, so little or no change is expected as a result of the conservation easement, and therefore, no change to human health 

o ensure that tallgrass prairie and 

the grassland-dependent wildlife species are available for viewing, it is necessary to conduct prescribed burning at regular intervals to 

 The Service focused on what is within the scope of 

-

maintain the fire climax prairie ecosystem.Response 25.6.the FHLCA conservation easement project. The Service recognizes that fragmentation is a serious existing condition, and that efforts to reverse the decline in greater prairie-chicken populations 

, the Service considers the preser

and environment is expected. Tface serious challenges. Howevervation of tallgrass prairie, resident and migratory birds, and other wildlife which may benefit from this effort, a worthy cause. The research referred to here is based on the lesser prairiechicken. The Flint Hills are currently populated with greater prairie-chickens, and we have found no research that indicates that we cannot be successful in protecting greater prairie-chickens and other grassland-dependent bird species with a landscape level conservation effort supported by private landowners and other partners.
116 EA, Flint Hills Legacy Conservation Area, KS Comment

#

25.725.8

Letter # 25 Response

See the response to comments 25.1 and 25.5.

 On page 29 of the final EA, “Cumulative Impacts—

Response 25.7. Response 25.8.Alternative B” in fact does refer to the impact to the program goals, “This would have long-term positive impacts on wildlife habitat and result in the long-term conservation of migratory birds, threatened and endangered species, native plants, and the overall biological diversity of the Flint Hills tallgrass prairie.” The other comments were previously addressed.The Service will send a copy of the final EA to the Kansas chapter of the Sierra Club, when it becomes available.
 Comment

#

25.9

Appendix G — Comments and Responses 117

Letter # 25 Response

See the responses to comments 25.1, 25.2, 25.4. 25.5, 

See the responses to comments 25.1 and 25.5.Response 25.9. and 25.6. The Service did not develop additional alternatives for controlling burning and stocking rates because as mentioned in the response to 

, for the Service to use comment 25.1, it is not feasible, or necessary

fee-title acquisition in the Flint Hills. The text of the draft EA has been revised to reflect the alternatives that were considered, but 

, such as fee-title acquisition, or a much larger not studied further

project boundary.The conservation easement program would seek to limit additional construction of infrastructure that would result in further habitat fragmentation. Ranking criteria will be used to select the most intact, high quality tallgrass habitat. It is not within the scope of the FHLCA project to assess the impacts of existing fragmentation from roads (or other structures) throughout the entire Flint Hills.Assessing the measure of success for the LPP will be a long-term process and will use ongoing, adaptive management strategies outlined in the Strategic Habitat Conservation strategies outlined on page 33 of the final EA. As new data and science become available, the information will be incorporated into the initial prioritization model and will be used to adjust the ranking criteria for potential acquisition parcels.
118 EA, Flint Hills Legacy Conservation Area, KS Comment 

# Letter # 25 Response
Appendix G — Comments and Responses 119

Response Comment 

# Letter # 26

Appendix G — Comments and Responses 119
120 EA, Flint Hills Legacy Conservation Area, KS Comment

#

26

26.1

Letter # 26 Response

ind energy (Background and general comments) W

development is not inherently compatible, or incompatible, with wildlife and habitat protection. An assessment needs to be made based on the requirements of the species involved. Preliminary studies indicate tall vertical structures fragment large tracts of otherwise appropriate habitat, making it unsuitable for interior grassland species such as greater prairie-chickens in Kansas. A number of authors have addressed the fragmentation effects of infrastructure on prairie grouse (Kuvlesky et al. 2007, McDonald et al. 2009, Giesen 1994, Fuhlendorf et al. 2002, Robel 2002). See specific information on ecological impacts and responses of 

ildlife Service The mission of the U.S. Fish and W

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

ildlife Refuge System is to preserve 

a national network of lands and waters for the conservation, management and, where appropriate, restoration of fish, wildlife, and plant resources and their habitats within the United States for the benefit of present and future generations of Americans. The Flint Hills Legacy Conservation Area project would be administered as part of the Refuge System in accordance with 

ildlife Refuge System Administration Act of 1966 

, the strategies contained in these 

Response 26. fragmentation on pages 23–26 of the final EA. Response 26.1.American people.The mission of the National Wthe National Wand other relevant legislation, executive orders, regulations, and policies (page 6 of the final EA).The Service supports the U.S. Department of the Interior policy on renewable energy development, including Secretarial Orders 3285 and 3289. HoweverSecretarial Orders are to be addressed for appropriate areas on public lands and the outer continental shelf. The Flint Hills Legacy Conservation Area project would be administered as part of the 

ildlife Refuge Refuge System in accordance with the National W

System Administration Act of 1966 and other relevant legislation, executive orders, regulations, and policies (see page 6 of the final EA). A significant directive of the Refuge Administration Act 

ildlife Service maintains 

, and environmental health of 

is to ensure that the U.S. Fish and W

, diversity

ildlife Refuge System for present and future 

the biological integritythe National Wgenerations of Americans. Fragmentation of the National Wildlife 

s wildlife habitats is a direct threat to the integrity 

ildlife Refuge System, both today and in the 

Refuge System’of the National Wdecades ahead. Uses that we reasonably anticipate may reduce 
Appendix G — Comments and Responses 121

 Comment

#

26.226.326.4

Letter # 26 Response

the quality or quantity or fragment habitats on a national wildlife refuge would not be consistent with Service policy.The FHLCA project would use voluntary conservation easements 

. The easement 

program would to a large extent maintain existing conditions for landowners and the general public, and will not significantly affect the quality of the human environment, and will not have a close causal connection to a change in the physical environment (40 CFR 

ildlife Service will continue to work 

collaboratively with individuals, nongovernment organizations, federal, state, and local agencies on a variety of issues, including renewable energy development. The Service has initiated a program using LCCs as a means of addressing conservation and climate change challenges through partnership opportunities (see 

, through the FHLCA project the Service seeks 

. Landowners could continue 

that would be acquired from willing sellers only1508.27). The U.S. Fish and Wpage 35 of the final EA). Additionallyto conserve part of remaining 4% of relatively intact tallgrass prairie habitat, thereby providing more system resiliency in a changing climate by maintaining a migration corridor for migratory grassland birds, and also by providing carbon sequestration benefits (page 27 of the final EA). Currently the FHLCA provides a significant north-south migration corridor for grassland birds, and links many areas of high quality tallgrass habitat (page 14 of the final EA). Retaining migratory corridors is a key adaptation strategy for wildlife response to climate change (S03289, USFWS 2009). The FHLCA project would use voluntary conservation easements that would be acquired from willing sellers onlyto pursue energy development on their land without Service conservation easements. The easement program would to a large extent maintain the existing conditions for landowners and the general public, and will not significantly affect the quality of the human environment, and will not have a close causal connection to a change in the physical environment (40 CFR 1508.27).
122 EA, Flint Hills Legacy Conservation Area, KS Comment

#

26.526.626.7

Letter # 26 Response

 Although the Service supports renewable Response 26.2.

energy development, it is beyond the scope of this project to incorporate a discussion of all national policies, energy programs, recommendations, and initiatives. Through the FHLCA project the Service seeks to conserve part of a remaining 4% of relatively intact tallgrass prairie habitat, thereby providing more system resiliency in a changing climate by maintaining a migration corridor for migratory grassland birds, and by providing carbon sequestration benefits (page 25 of the final 

, the FHLCA provides a 

EA). From the final EA page 14, “Currentlysignificant north-south migration corridor for grassland birds, and links many areas of high quality tallgrass habitat. Retaining migratory corridors is a key adaptation strategy for wildlife response to climate change (S03289, USFWS 2009).” 

 The Service is not proposing a buffer zone, or Response 26.3.

any development restrictions other than areas where Service conservation easements are in place. The conservation easements are voluntary and in no way restrict use on neighboring lands. All federal, state, and local regulations would still apply whether the Service has an easement in the area or not. Rather than increase the likelihood of additional requirements under the Endangered Species Act, one of the purposes of the FHLCA is to support the recovery and protection of threatened and endangered species and reduce the likelihood of future listings under the Endangered 

 The Service is not biased against wind, or other 

Species Act (final EA page 4). Response 26.4.forms of energy development. The Service would consider development of energy and mineral resources on the easement properties, if they can be implemented without fragmenting the 

abaunsee) has passed an 

grassland habitat. Although at least one Kansas county (Wordinance banning commercial wind farms countywide, it would be speculative to anticipate potential secondary impacts for the Flint Hills. The Service is not promoting oil and gas extraction over other forms of energy development. On properties where wind, oil and gas, or mineral rights have already been sold (severed from the estate), the Service will work with landowners and developers to minimize any negative impacts of development and extraction activities (50 CFR 25.11). On land where the rights for wind, oil and gas, or mineral development have not been sold (estate is 
Appendix G — Comments and Responses 123

 Comment

#

26.826.9

26.10

Letter # 26 Response

still intact), conservation easements would require non-surface occupancy (off-site development) for any future development activities. The Service would consider development of energy and mineral resources on the easement properties, if they can be implemented without disturbing the surface or creating vertical barriers, which would fragment the grassland habitat for wildlife. The Service respectfully disagrees that the proposed action 

ildlife . The U.S. Fish and W is inconsistent with energy policy

supports the U.S. Department of Interior policy on renewable energy development, including Secretarial Orders 3285 and 

, the strategies contained in these Secretarial 3289. However

Orders are to be addressed for appropriate areas on public lands and the outer continental shelf. The Flint Hills Legacy Conservation Area project would be administered as part of the 

ildlife Refuge Refuge System in accordance with the National W

System Administration Act of 1966 and other relevant legislation, executive orders, regulations, and policies (see page 6 of the final EA). A significant directive of the Refuge Administration Act 

ildlife Service maintains 

, and environmental health of 

is to ensure that the U.S. Fish and W

, diversity

ildlife Refuge System for present and future 

the biological integritythe National Wgenerations of Americans. Fragmentation of the National Wildlife 

s wildlife habitats is a direct threat to the integrity 

ildlife Refuge System, both today and in the 

, or fragment habitats on a national 

.

 See responses to comments 26.1 and 26.2 regarding 

The Service respectfully disagrees with this 

. Upon approval, the Service 

.

ind Turbine Guidelines Advisory Committee 

, and are not approved policy

Refuge System’of the National Wdecades ahead. Uses that the Service reasonably anticipates may reduce the quality or quantitywildlife refuge would not be consistent with Service policyResponse 26.5.Service mission and policyResponse 26.6. assessment. Although wind energy and grassland habitat preservation may be compatible, the biological requirements vary for wildlife species and location. In some areas, such as some areas of North and South Dakota, initial studies indicate that waterfowl are able to use areas with wind energy developments. The proposed Wrecommendations are currently under review by the Secretary of Interiorwill incorporate the policy for the FHLCA project, including the proposed Tier 1 evaluation and the considerations listed for sage and prairie grouse that merit special attention for several reasons. 
124 EA, Flint Hills Legacy Conservation Area, KS Comment

#

26.1026.1126.1226.13

Letter # 26 Response

“[The] scale and biotic nature of habitat requirements, ranges, and 

s richest inland wind 

resources, known impacts of anthropogenic features (tall buildings, 

urbine Advisory ind T

The text of the draft EA has been revised to include Service 

ildlife Impacts voiding and Minimizing W

urbines (2003) which recommends avoiding “placing 

turbines in habitat known to be occupied by prairie grouse or other species that exhibit extreme avoidance of vertical features or structural habitat fragmentation (see page 26 of the final EA). In known prairie grouse habitat, avoid placing turbines within 5 miles of known leks (communal pair formation grounds).” While wind turbines may be compatible with some wildlife species in other areas of Kansas, the Flint Hills tallgrass prairie dependent species have demonstrated sensitivity to vertical structures and habitat 

 See responses to comments 26.1, 26.5, and 26.6.

. The Service respectfully disagrees with this 

habitats are highly congruent with the nation’structures, energy facilities, roads, etc.) (WCommittee Draft, USFS 2010).”Interim Guidance on A

ind T from W

fragmentation.See also the response to comment 26.2.Response 26.7.Response 26.8statement. The decision of whether to establish a new unit 

ildlife Refuge System is a Conservation Area of the National W

decision of whether to proceed with establishment, or not. Thus, Conservation Area LPPs typically involve two alternatives, a no action (non-acquisition alternative), and an acquisition option that 

ildlife Refuge System. 

, such as 

will establish a new unit of the National WThe text of the EA has been revised to reflect the additional alternatives that were considered, but not studied furtherfee-title acquisition, or an option considering a much larger project boundary.When the decision to establish a new refuge is being made, Service policy is to acquire land only when other means, such as zoning or regulation, of achieving program conservation goals and objectives are not appropriate, available, or effective. When lands are to be acquired, the minimum interest necessary to reach management objectives is considered. If fee-title is required, full consideration will be given to extended use reservations, exchanges, or other alternatives that will lessen impact on the owner and the community. 
 Comment

#

26.1426.1526.1626.17

Appendix G — Comments and Responses 125

Letter # 26 Response

A rationale of why the Service has decided to use conservation easements to achieve its conservation purposes for the FHLCA project instead of other alternative is given under the “Alternatives Considered but not Studied” section on page 10 of the final EA. The analysis and information provided throughout the draft EA led to the definition of the project-approved acquisition boundary and the maximum acreage to be acquired by the Service for the FHLCA. Some of the factors considered in the EA include the narrowness of the intact prairie habitat in the north-

, the rapid encroachment by trees, and 

residential and commercial development. The project acquisition acreage represents less than 1% of the physiographic boundary of the historic range of tallgrass prairie and only 2% of the potential The Service acquires easements from willing sellers only. Landowners could continue to pursue energy development on their land without Service conservation easements. As a result, the eventual conservation mosaic/pattern will in large part be driven by the availability of willing sellers. Acquisition within the project area is based on the level of participation by willing sellers and available funding. It is an inherent fact that considerably fewer acres may be acquired within the FHLCA, resulting in a much 

 It is beyond the scope of this project to incorporate 

details of all individual Department of the Interior strategic goals in this, or any other EA. See the response to comment 26.1 on the 

ildlife Refuge ildlife Service and the National W

 The EA addresses only the restrictions that would 

south migration corridorwind energy development in Kansas. smaller project area. Response 26.9.U.S. Fish and WSystem missions.The “Affected Environment” section is a discussion of the existing biological and socioeconomic environment conditions and potential effects of the alternatives on those conditions. Any discussion of beneficial economic impacts of wind energy development on local communities would be speculative, due in part to the voluntary nature of landowner participation in selling wind leases. See also the response to comment 26.4.Response 26.10.result from the proposed conservation easement program. All other local, state, and federal restrictions and laws would still be applicable.The text will be revised to remove the first sentence of the statement of the draft EA that states, “if projects are sited without regard to ecological resources, wind power poses a serious 
126 EA, Flint Hills Legacy Conservation Area, KS Comment

#

26.18

Letter # 26 Response

s most diminished and 

ecologically sensitive habitats” (see page 28 of the final EA).

 The Service respectfully disagrees with the 

 sited without will be

ext in the draft EA says, “if

risk to wildlife in some of North America’See also the response to comment 26.3.Response 26.11.assessment that it is assumed that the project regard for ecological resources. Tprojects are sited without regard to ecological resources, wind power poses a serious risk to wildlife in some of North America’s most diminished and ecologically sensitive habitats.” This text will 

ind Turbine Guidelines Advisory Committee 

, describe a number of concerns 

be removed. The proposed Wguidelines, currently under reviewand considerations associated with wind energy development that would affect grassland wildlife species found in the FHLCA, based on biological and habitat requirements. See the response to comment 26.6. The EA addresses only the restrictions that would result from the proposed conservation easement program. All other local, state, and federal restrictions and laws would still be applicable. 

urbine Guidelines Advisory In addition, the proposed Wind T

Committee recommendations are currently under review by the 

, and hence cannot be , are not approved policy

 The Service respectfully disagrees with the 

Secretary of Interiorincluded in the EA.Response 26.12.assertion that overly broad and invalid assumptions have been made regarding coordination and cooperation. The Service believes that coordination and communication regarding conservation of ecological resources is essential. The Service will continue to work collaboratively with individuals, nongovernment organizations, federal, state, and local agencies on a variety of issues, including renewable energy development. The Service has initiated a program using Landscape Conservation Cooperatives (LCCs) as a means of addressing conservation and climate change challenges through partnership opportunities (see page 35 of the final EA). 

 The language of the draft EA will be changed to 

 restrictions, Service

See also the response to comment 26.6.Response 26.13.reflect that there would not be any additional and that landowners could potentially profit by allowing wind energy infrastructure on land that does not have conservation easements (see page 28 of the final EA).
Appendix G — Comments and Responses 127

 Comment

#

27

Letter # 27 Response

The EA addresses only the restrictions that would result from the proposed conservation easement program. All other local, state, and federal restrictions and laws would still be applicable. 

 Any discussion of beneficial economic impacts Response 26.14.

of wind energy development on local communities would be speculative, due in part to the voluntary nature of landowner 

 See the response to comment 9. Discussion of the impact of wind energy facilities 

participation in selling wind leases.Response 26.15.Response 26.16.outside of the FHLCA is beyond the scope of the EA. 

 The FHLCA project will utilize voluntary Response 26.17.

conservation easements that would be acquired from willing sellers only. Landowners could continue to pursue energy development on their land without Service conservation easements. The easement program would to a large extent maintain the existing conditions for landowners and the general public, and will not significantly affect the quality of the human environment, and will not have a close causal connection to a change in the physical environment (40 CFR 1508.27).Although it is not necessary to address “the relationship between 

s environment and the enhancement 

abaunsee) has passed an 

 Thank you for your comments. 

short-term uses of man’of long-term productivity” and “irreversible or irretrievable commitments of resources” in an EA, the text has been revised to include additional information on “Irreversible and Irretrievable Commitments of Resources” in the final EA (see page 30).Response 26.18.Response 27. (Background and general comments) The Service believes that wind energy development is not inherently compatible, or incompatible, with wildlife and habitat protection. Preliminary studies indicate tall vertical structures fragment large tracts of otherwise appropriate habitat, making it unsuitable for interior grassland species such as greater prairie-chickens in Kansas. A number of authors have addressed the fragmentation effects of infrastructure on prairie grouse (Kuvlesky et al. 2007, McDonald et al. 2009, Giesen 1994, Fuhlendorf et al. 2002, Robel 2002). See specific information on ecological impacts and responses of fragmentation on pages 23–26 of the final EA. Although at least one Kansas county (Wordinance banning commercial wind farms countywide it would be speculative to anticipate potential additional restrictions in other areas. 
128 EA, Flint Hills Legacy Conservation Area, KS Comment

#

27.127.2

Letter # 27 Response

ildlife supports U.S. Department The Fish and W Response 27.1. 

of Interior policy on renewable energy development, including 

, the strategies Secretarial Orders 3285 and 3289. However

contained in these Seretarial Orders are to be addressed for 

 lands and the outer continental public appropriate areas on 

shelf. The FHLCA project would be administered as part of the 

ildlife Refuge Refuge System in accordance with the National W

System Administration Act of 1966 and other relevant legislation, executive orders, regulations, and policies (see page 6 of the final EA). A significant directive of the Refuge Administration Act is to 

ildlife Service maintains the 

ildlife 

, and environmental health of 

ensure that the U.S. Fish and W

, diversity

ildlife Refuge System for present and future 

s wildlife habitats is a direct threat to the integrity 

ildlife Refuge System, both today and in the 

.

The Service respectfully disagrees with the 

biological integrity

ind Turbine Guidelines Advisory Committee 

. Upon approval, the Service , and are not approved policy

the National Wgenerations of Americans. Fragmentation of the National WRefuge System’of the National Wdecades ahead. Uses that the Service reasonably anticipates may reduce the quality or quantity or fragment habitats on a national wildlife refuge would not be consistent with Service policyCurrently the FHLCA provides a significant north-south migration corridor for grassland birds, and links many areas of high quality tallgrass habitat (page 14 of the final EA). Retaining migratory corridors is a key adaptation strategy for wildlife response to climate change (USFWS 2009).Response 27.2. assessment that an overbroad presumption has been made. Although wind energy and grassland habitat preservation may be compatible, the biological requirements vary for wildlife species and location. In some areas, such as some areas of North and South Dakota, initial studies indicate that waterfowl are able to use areas with wind energy development. The proposed Wrecommendations are currently under review by the Secretary of Interiorwill incorporate the policy for the FHLCA project, including the proposed Tier 1 evaluation and the considerations listed for sage and prairie grouse that merit special attention for several reasons. 
Appendix G — Comments and Responses 129

 Comment

#

27.3

Letter # 27 Response

“[The] scale and biotic nature of habitat requirements, ranges and 

s richest inland wind habitats are highly congruent with the nation’

resources, known impacts of anthropogenic features (tall buildings, 

urbine Advisory structures, energy facilities, roads, etc.)” (Wind T

Committee Draft, USFWS 2010).Text on page 26 of the draft EA has been revised to include Service 

ildlife Impacts voiding and Minimizing W Interim Guidance on A

ind Turbines (USFWS 2003) which recommends avoiding from W

“placing turbines in habitat known to be occupied by prairie grouse or other species that exhibit extreme avoidance of vertical features and/or structural habitat fragmentation. In known prairie grouse habitat, avoid placing turbines within 5 miles of known leks (communal pair formation grounds).” While wind turbines may be compatible with some wildlife species in other areas of Kansas, the Flint Hills tallgrass prairie-dependent species have demonstrated sensitivity to vertical structures and habitat fragmentation. 

ildlife Service will continue to work The US Fish and W

collaboratively with individuals, nongovernment organizations, federal, state, and local agencies on a variety of issues, including renewable energy development. The Service has initiated a program using LCCs as a means of addressing conservation and climate change challenges through partnership opportunities (see page 35 of the final EA). Although all of the LCCs have not been formally initiated yet, the FHLCA will be an active partner in the 

allgrass and Big Rivers LCC. 

 After receiving largely supportive comments 

Eastern TResponse 27.3.and input from public scoping meetings and discussions with a number of organizations, state, and federal agencies, the Service determined that the appropriate National Environmental 

A) document to prepare for the FHLCA Protection Agency (NEP

project was an EA. Significant controversy has been defined as “circumstances where a substantial dispute exists as to the environmental consequences of the proposed action and does not refer to the existence of opposition to a proposed action, the effect of which is relatively undisputed” (43 CFR 73 page 61299).The FHLCA project will utilize voluntary conservation easements 

. Landowners could that would be acquired from willing sellers only

continue to pursue energy development on their land without Service conservation easements. The easement program would to a large extent maintain the existing conditions for landowners and the general public, and will not significantly affect the quality of the 
130 EA, Flint Hills Legacy Conservation Area, KS Comment

#

27.427.5

Letter # 27 Response

human environment, and will not have a close causal connection to a change in the physical environment (40 CFR 1508.27).Under DOI Departmental Manual 516 DM 8.6, Actions Normally Requiring an EA include proposals to establish most new refuges and fish hatcheries; and most additions and rehabilitations to 

, Departmental Manual, Part 51, 

existing installations.U.S. Department of InteriorChapter 8.7B:“If, for any of the above proposals it is initially determined that the proposal is not a major federal action significantly affecting the quality of the human environment, an EA will be prepared and handled in accordance with 40 CFR 1501.4(e)(2). If the EA subsequently indicates the proposed action will cause significant impacts, an EIS will be prepared.”The FHLCA project is one of the larger units of the refuge system in the continental United States, but there are several larger management areas in the continental United States. For accurate information on national wildlife refuge lands see the Service 

.fws.gov/refuges/land/LandReport.html). website (http://www

Response 27.4. Pages 23–26 of the final EA contain general language on fragmentation and the increased difficulty of conducting prescribed fire, which is necessary to limit tree encroachment, when the level of infrastructure development is increased. The text will be changed in the final EA to say that fragmentation from wind energy infrastructure “could make prescribed fire more difficult to implement” instead of “would limit”. Although wind energy developers may not ask landowners to refrain from burning, the logistics and feasibility of burning around structures and roads makes prescribed fire more difficult (see page 25 of the final EA).The Tallgrass Legacy Alliance information on the Partners for Fish and Wildlife webpage lists fragmentation as the number two threat to tallgrass prairie. As is described in the EA, fragmentation of prairie habitat for grassland-dependent wildlife can result from a number of sources, including wind energy infrastructure.The FHLCA is a voluntary participation program for landowners. Energy and infrastructure development would only be restricted on the parcels offered by willing sellers that are accepted by the Service as an appropriate conservation easement purchase. Landowners could continue to pursue energy development on their land without Service conservation easements.
Appendix G — Comments and Responses 131

 Comment

#

27.6

Letter # 27 Response

-

The decision to not allow wind energy structures on conservation easements in the FHLCA was based on available research that indicates while wind turbines may be compatible with some wildlife species in other areas, the Flint Hills tallgrass prairie dependent species have demonstrated sensitivity to vertical structures and 

 See the responses to comments 27.1 and 27.2. 

ildlife supports U.S. Department of Interior 

habitat fragmentation.Response 27.5.The Fish and Wpolicy on renewable energy development, including Secretarial 

, the strategies contained in these Orders 3285 and 3289. However

Secretarial Orders are to be addressed for appropriate areas on public lands and the outer continental shelf. The FHLCA project would be administered as part of the Refuge System in accordance 

ildlife Refuge System Administration Act of with the National W

1966 and other relevant legislation, executive orders, regulations, and policies (see page 6 of the final EA). A significant directive of the Refuge Administration Act is to 

ildlife Service maintains the 

, and environmental health of 

ensure that the U.S. Fish and W

, diversity

ildlife Refuge System for present and future 

biological integritythe National Wgenerations of Americans. Fragmentation of the National Wildlife 

s wildlife habitats is a direct threat to the integrity 

ildlife Refuge System, both today and in the 

Refuge System’of the National Wdecades ahead. Uses that the Service reasonably anticipates may reduce the quality or quantity or fragment habitats on a national wildlife refuge would not be consistent with Service policyThe FHLCA project would use voluntary conservation easements 

. Landowners could 

Service conservation easements. The easement program would to a large extent maintain the existing conditions for landowners and the general public, and will not significantly affect the quality of the human environment, and will not have a close causal connection to Although wind energy development is not inherently compatible, 

- or incompatible, with wildlife and habitat protection, an assess

species in

.

that would be acquired from willing sellers onlycontinue to pursue energy development on their land without a change in the physical environment (40 CFR 1508.27).

the requirements of the on based made be to needs ment 

volved. Available studies indicate tall vertical structures fragment large tracts of otherwise appropriate habitat, making it unsuitable for interior grassland species such as greater prairie-chicken in Kansas. A number of authors have addressed the fragmentation effects of infrastructure on prairie grouse (Kuvlesky et al. 2007, 
132 EA, Flint Hills Legacy Conservation Area, KS Comment

#

27.7

Letter # 27 Response

McDonald et al. 2009, Giesen 1994, Fuhlendorf et al. 2002, Robel 2002). See additional specific information on ecological impacts and responses of fragmentation pages 23–26 of the final EA. The statement that current biological information “indicated that a low density of wind turbines would not have any significant impact to grassland habitat and its value to migrating birds or other wildlife” is not made in the Interim Guidance, page 40. It is stated that “information available at this time indicates that turbine densities at this level will not materially interfere with or detract from the purposes of the easement (Attachment 2). The species list referred to in Appendix 6, Attachment 2 is for North and South Dakota, and largely for different bird species than the priority species guild for the tallgrass prairie habitat of FHLCA. The Service examines species habitat requirements for each particular area.The Bureau of Land Management 2005 Biological Opinion does not cover the state of Kansas, or the wildlife and habitat resources that wind energy development would affect in the Flint Hills. Additionally, BLM has a “multiple use” mission including the development of minerals and energy production, which is a 

s “wildlife first” mission. See the 

 Although the Service supports renewable energy 

. Landowners could 

different focus from the Service’response to comment 27.1.Also, see the response to comment 27.4.Response 27.6.development, the EA analyzes the impact from fragmentation on the trust resources in general, and it is not within the scope of the project to provide an analysis of the impact of all forms of energy development. It is also beyond the scope of this project to incorporate a discussion of all national policies, energy programs, recommendations, and initiatives. See also the response to comment 27.4. It is not within the scope of this project to determine how much energy can or would be generated by the development of wind, oil and gas, or any other type of energy within the FHLCA. The energy, and any revenues generated, will be determined by the number of landowners willing to sell the development rights on their non-easement property.The FHLCA project will utilize voluntary conservation easements that would be acquired from willing sellers onlycontinue to pursue energy development on their land without Service conservation easements. The easement program would to a large extent maintain the existing conditions for landowners and 
Appendix G — Comments and Responses 133

 Comment

#

27.827.9

Letter # 27 Response

the general public, and will not significantly affect the quality of the human environment, and will not have a close causal connection to a change in the physical environment (40 CFR 1508.27). Although the Service supports renewable energy development, it is beyond the scope of this project to incorporate a discussion of all national policies, energy programs, recommendations, and initiatives. Through the FHLCA project the Service seeks to conserve part of remaining 4% of relatively intact tallgrass prairie habitat, thereby providing more system resiliency in a changing climate by maintaining a migration corridor for migratory grassland birds, and also by providing carbon sequestration benefits (page 27 of the final EA). The statement that “developing renewable resources and preserving valuable habitat is usually compatible” needs to be assessed with specific information on the species potentially 

 The Service respectfully disagrees with the 

affected.Response 27.7.assessment that it is biased against wind, or other forms of energy development. On properties where wind, oil and gas, or mineral rights have already been sold (severed from the estate), the Service will work with landowners and developers to minimize any negative impacts of development and extraction activities (50 CFR 25.11). On land where the rights for wind, oil and gas, or mineral development have not been sold (estate is still intact), conservation easements would require nonsurface occupancy (off-site development) for any future development activities. The Service would consider development of energy and mineral resources on the easement properties, if they can be implemented without disturbing the surface or creating vertical barriers, which would fragment the grassland habitat for wildlife. The easement program would to a large extent maintain existing conditions for landowners and the general public, will not significantly affect the quality of the human environment, and will not have a close causal connection to a change in the physical environment (40 CFR 1508.27). In effect, the conditions and consequences of precluding wind energy are currently being 

 The language has been revised in the final EA to 

realized. Response 27.8.provide clarification (see page 28 of the final EA).
134 EA, Flint Hills Legacy Conservation Area, KS Comment

#

27.1027.11

Letter # 27 Response

There is no expectation of relocation of any infrastructure covered by permits or leases that are already in place. Additionally, there is an established transmission grid in Kansas already (see the map at http://kec.kansas.gov/chart_book/Chapter6/02_

ransMap.pdf) indEnergyElectricT

 The easement document is not a required NEPA 

KSWResponse 27.9.component of the EA, and is not a description of a project. The possible terms, conditions, and requirements of Service conservation easements in general and specific issues for the FHLCA were discussed extensively in all of the public meetings. As is with other Service easements, and other conservation organization easements in the Flint Hills, the FHLCA easements 

, such 

will contain restrictions on development (residential and commercial structures), and will be in perpetuity. The final easement document developed by the Realty Division will incorporate the requirements and biological needs of the trust wildlife resources in the FHLCA, with what landowners have indicated through comments at meetings and letters will be acceptable to them. Most of the comments the Service received related to wind energy expressed support for the exclusion of 

 The decision of whether to establish a new unit 

ildlife Refuge System is 

, Conservation Area LPPs typically involve two 

, or 

commercial development in the Flint Hills. 

, project boundary.

Response 27.10.Conservation Area of the National Wa decision of whether to proceed with establishment, or not. Thus, typicallyalternatives, a no action (non-acquisition alternative), or an acquisition option that will establish a new unit of the National Wildlife Refuge System. The text of the draft EA has been revised to reflect the additional alternatives that were considered, but not studied furtheras fee-title acquisition, or an option considering a much largersmallerWhen the decision to establish a new refuge is being made, Service policy is to acquire land only when other means, such as zoning or regulation, of achieving program conservation goals and objectives are not appropriate, available, or effective. When lands are to be acquired, the minimum interest necessary to reach management objectives is considered. If fee-title is required, full consideration will be given to extended use reservations, exchanges, or other alternatives that will lessen the impact on the landowner and the community. 
Appendix G — Comments and Responses 135

 Comment

#

27.1227.13

Letter # 27 Response

A rationale of why the Service has decided to use conservation easements to achieve its conservation purposes for the FHLCA project instead of other alternative is given under the “Alternatives Considered but not Studied” section on page 10 of the final EA. The analysis and information provided throughout the EA led to the definition of the project approved acquisition boundary and the maximum acreage to be acquired by the Service for the FHLCA. Some of the factors considered in the EA include the narrowness of the intact prairie habitat in the north-south 

, the rapid encroachment by trees, residential, migration corridor

and commercial development. The project acquisition acreage represents less than 1% of the physiographic boundary of the historic range of tallgrass prairie and only 2% of the potential wind energy development in Kansas. Less than 4% of intact tallgrass habitat remains in North America, the majority of which is located in the Flint Hills of Kansas. To adequately maintain the grassland bird migration corridor, genetic viability of the greater prairie-chicken, the minimum goal is the conservation of what amounts to less than 1% of the remaining tallgrass prairie, when fully appropriated.A ‘balanced use approach” that would allow wind infrastructure 

 See response to comment 27.1 and 27.8.

, while excluding other types of development would still only

fragment grassland habitat and would not be appropriate for this project.Response 27.11.Several comments were received from the public on the possibility of the addition of a conservation program for the tallgrass prairie habitat located in Oklahoma. Region 2 of the Service will take into consideration the possibility of future tallgrass conservation efforts 

 The FHLCA project will utilize voluntary 

in Oklahoma.Response 27.12.conservation easements that would be acquired from willing sellers only. Landowners could continue to pursue energy development on their land without Service conservation easements. The easement program would to a large extent maintain the existing conditions for landowners and the general public, and will not significantly affect the quality of the human environment, and will not have a close causal connection to a change in the physical environment (40 CFR 1508.27).Although it is not necessary to address “the relationship between 

s environment and the enhancement short-term uses of man’

of long-term productivity” and “irreversible or irretrievable 
136 EA, Flint Hills Legacy Conservation Area, KS Comment

#

27.14

Letter # 27 Response

commitments of resources” in an EA, the text has been revised to include additional information in the “Irreversible and Irretrievable Commitments of Resources” section on page 30 of the 

 The first sentence under “Decisions to be Made” 

final EA.Response 27.13.states that the Service planning team will complete an analysis (EA), and then based on this analysis, will proceed with the 

 Thank you for your comments.

decision-making process.Response 27.14.
Appendix G — Comments and Responses 137

 Comment

#

28

Letter # 28 Response

Response 28. Thank you for your comments.
138 EA, Flint Hills Legacy Conservation Area, KS Comment

#

29

29.129.229.329.429.5

Letter # 29 Response

. 

-

 Thank you for your comments. The Service believes that these are important 

Response 29.1.Response 29.2.ranking factors and will use many of these factors in the ranking 

 Comment noted. As new data and science become 

criteria for the FHLCA.Response 29.3.available, the information will be incorporated into the initial prioritization model and will be used to adjust the ranking criteria for 

 Comment noted. A number of comments were 

potential acquisition parcels.Response 29.4.received during public meetings on maintaining landowner access to gravel resources. Stream bed gravel extraction will be allowed for ranching processes. No commercial gravel extraction activities will be allowed. Stream bed gravel extractions will be subject to all local, state, and federal laws. Individual landowners will need to 

. Landowners may have some limited options for 

determine any tax implications.Response 29.5carving out portions of their property from the easement, thereby allowing other uses or future structures/building construction. The easement will only limit the construction of additional structures in areas that are not located in ‘carve-out’ portions of the propertyThe landowners will retain access control, including public recreational activities. 
Appendix G — Comments and Responses 139

 Comment

#

29.629.729.8

Letter # 29 Response

ree expansion will be addressed in the easement Response 29.6. T

language to include provisions for maintaining tree encroachment at no more than the current level when the easement is estabHerbicide use was discussed at several of the public lished. Response 29.7. meetings. The Service anticipates using language similar to the language used by The Nature Conservancy to address herbicide 

 Thank you for your comments.

application.Response 29.8.
140 EA, Flint Hills Legacy Conservation Area, KS Comment

#

30

Letter # 30 Response

Response 30. Thank you for your comments.
Appendix G — Comments and Responses 141

 Comment

#

31

Letter # 31 Response

Response 31. Thank you for your comments. 
142 EA, Flint Hills Legacy Conservation Area, KS Comment

#

32

Letter # 32 Response

Response 32. Thank you for your comments.
Bibliography

Aber, J.S. 1997. [Geology, geomorphology, and 

geohydrology of the Flint Hills]. Revised 2008. 

<http://academic.emporia.edu/aberjame/field/flint/

flint.htm> [Access date unknown].

Abrams, M.D.; Gibson, D.J. 1991. Effects of fire 

exclusion on tallgrass prairie and gallery forest 

communities in eastern Kansas. In: Nedvin, C.; 

Waldrop, T., editors. Symposium on fire and the 

environment: ecological and cultural perspectives. 

General Technical [Place of publication unknown]: 

U.S. Department of Agriculture, Forest Service 

General Technical Report SE-69. 3–10. 

Angelo, R.T.; Cringan, M.S.; Fry J.E. 2002a. 

Distributional revisions and new and amended 

occurrence records for prosobranch snails in 

Kansas. Transactions of the Kansas Academy of 

Science 105(3–4):246–257.

Angelo, R.T.; Cringan, M.S.; Haslouer, S.G. 2002b. 

Response of stream biological communities to 

agricultural disturbances in Kansas: an historical 

overview with comments on the potential for 

aquatic ecosystem restoration. In: Proceedings 

of the Central Plains Aquatic Bioassessment and 

Biocriteria Symposium. Proceedings: Central 

Plains Aquatic Bioassessment and Biocriteria 

Symposium; 2002 September 18–19; University of 

Kansas, Lawrence, KS. Lawrence, KS: University 

of Kansas. 1–22.

Angelo, R.T.; Cringan, M.S.; Goodrich, C.A.; Hays, 

E.; Miller, E.J.; Simmons, B.R.; VanScoyoc, M.A. 

2009. Historical changes in the occurrence and 

distribution of freshwater mussels in Kansas. 

Great Plains Research (in press, on file at 

bangelo@kdhe.state.ks.us).

Axelrod, D. I. 1985. Rise of the grassland biome, 

Central North America. Botanical Review 51:163–

201.

Bain, M.R.; Farley, G.H. 2002. Display by apparent 

hybrid prairie-chickens in a zone of geographic 

overlap. Condor 104:683–687.

Bock, C.E.; Bennett, B.C.; Bock, J. H. 1999. 

Songbird abundance in grasslands at a suburban 

interface on the Colorado high plains. Ecology 

and conservation of grassland birds. [Place of 

publication unknown]: [Publisher unknown]. 

[Number of pages unknown].

Bragg, T.B. 1986. Fire history of a North American 

sandhills prairie. Congress of Ecology 4:99.

Braun, C.E.; Aldrich, C.L.; Oedekoven, O.O. 2002. Oil 

and gas development in Western North America: 

effects of sagebrush steppe avifauna with 

particular emphasis on sage grouse: Proceedings, 

67th North American Wildlife and Natural 

Resources Conference; [Date of conference 

unknown]; [Place of conference unknown]. In: 

Transactions 67th North American Wildlife and 

Natural Resources Conference 337–349.

Brown, B.T. 1993. Bell’s vireo (Vireo bellii). In: Poole, 

A.; editor. The birds of North America. Ithaca, 

New York: Cornell Lab of Ornithology. [Internet]. 

Birds of North America Online. <http://bna.

birds.cornell.edu/bna/species/35> [Access date 

unknown].

Canadell, J.P.; Ingram, J.S.; Pitelka, L.F. 1996. The 

effects of elevated CO2 on plant-soil carbon belowground: A summary and synthesis. Plant and Soil 

187:391–400.

Chapman, S.S.; Angelo, R.T.; Freeman, C.C.; 

Freeouf, J.A.; Huggins, D.G.; McCauley, J.R.; 

Omernik, J.M.; Schlepp, R.L.; Steinauer, G. 2001. 

Ecoregions of Nebraska and Kansas (1:1,950,000 

scale map with color poster, descriptive text, 

summary tables, and photographs). Reston, VA: 

United States Geological Survey.

Cutter, B.E.; Guyette, R.P. 1994. Fire frequency on 

an oak hickory ridgetop in the Missouri Ozarks. 

American Midland Naturalist 132:393–398.

Dodds, W.K.; Oakes, R.M. 2004. A technique for 

establishing reference nutrient concentrations 

across watersheds affected by humans. Limnology 

and Oceanography: Methods 2:333–341.

Dodds, W.K.; Bertrand, K.N.; Dalgleish, H.J.; Falke, 

J.A.; Knight, G.L.; Rehmeirer, R.L.; Wiggam, S.; 

Wilson, K.C. 2008. Comparing ecosystem goods 

and services provided by restored and native 

lands. Bioscience 58:837–845.

Drewitt, A.L.; Langston, R.H.W. 2006. Assessing the 

impacts of wind farms on birds. Ibis 148:29–42.

Ewers, R.M.; Didham, R.K. 2006. Confounding 

factors in detection of species responses to habitat 

fragmentation. Biological Reviews 81:117–142.
144 EA, Flint Hills Legacy Conservation Area, KS

Fagre, D.B.; Allen, C.D.; Birkeland, C.; Chapin III, 

F.S.; Charles, C.W.; Groffman, P.M.; Guntenspergen, 

G.R.; Knapp, A.K.; McGuire, A.D.; Mullholland, P.J.; 

Peters, D.P.C.; Roby, D.D.; Sugihara, G. 2009. 

Thresholds of climate change in ecosystems; a 

report by the U.S. Climate Change Science Program 

and the Subcommittee on Global Change Research. 

Reston, VA: U.S. Geological Survey, U.S. Global 

Climate Change Research Program. 156 p. 

Fuguitt, G.V. 1985. The nonmetropolitan population 

turnaround. Annual Review of Sociology 11:259–80.

Fuhlendorf, S.D.; Leslie, D.M.; Shackford, J.S.; 

Woodward, A.J.W. 2002. Multi-scale effects of 

habitat loss and fragmentation on lesser prairiechicken populations of the U.S. Southern Great 

Plains. Landscape Ecology 17(7):617–628.

Fuhlendorf, S.D.; Davis, C.A.; Engle, D.E.; Hamilton, 

R.G.; Harrell, W.C.; Leslie, D.M. 2006. Should 

heterogeneity be the basis for conservation? 

Grassland bird response to fire and grazing. 

Ecological Applications 16(5):1706–1716.

Fuhlendorf, S.D.; Engle, D.M. 2004. Application of 

the fire-grazing interaction to restore a shifting 

mosaic on the tallgrass prairie. Journal of Applied 

Ecology 41:604–614.

Giesen, K.M. 1994. Movements and nesting habitat 

of lesser prairie-chicken hens in Colorado. The 

Southwestern Naturalist 39(1): 96–98.

Gleason, R.A.; Euliss Jr., N.H. 1998. Sedimentation of 

prairie wetlands. Great Plains Research 8(1):97–112. 

Hagen, C.A.; Giesen, K.M. 2005. Lesser prairiechicken (Tympanuchus pallidicinctus). In: Poole, 

A.; editor. The birds of North America No. 364. 

Ithaca, New York: Cornell Lab of Ornithology. 

[Internet]. Birds of North America Online. <http://

bna.birds.cornell.edu/BNA/account/lesserprairiechicken > [Access date unknown].

 Haggerty, M. 1996. Costs of county and educational 

services in Gallatin County, Montana. Bozeman, 

MT: Local Government Center, Montana State 

University. 9 p.

Haines, F. 1970. The Buffaloe. New York: Thomas Y. 

Crowell Co. [Number of pages unknown].

Hansen, M.J.; Clevenger, A.P. 2005. The influence of 

disturbance and habitat on the presence of nonnative plant species along transport corridors. 

Biological Conservation 125:249–259.

Haslouer S.G.; Collins, J.T.; Distler, D.A.; Eberle, 

M.E.; Edds, D.R.; Gido, K.B.; Huggins, D.G.; 

Mammoliti, C.S.; Stark, W.J.; Triplett, J.R. 2005. 

Current status of native fish species in Kansas. 

Transactions of the Kansas Academy of Science 

108(1–2):32–46.

Heisler, J.L.; Briggs, J.M.; Knapp, K.A. 2003. Fire 

frequency and the dynamics of shrub cover and 

abundance. American Journal of Botany 90(3):423–

428.

Higgens, K.F. 1986. Interpretation and compendium 

of historical fire accounts in the Northern Great 

Plains. Resource Publication 161. Washington DC: 

U.S. Department of the Interior, U.S. Fish and 

Wildlife Service. [Number of pages unknown].

Hill, J.K.; Dytham, C.; Hughes, C.L.; Searle, J.B. 

2006. Genetic diversity in butterflies: interactive 

effects of habitat fragmentation and climate-driven 

range expansion. Biology Letters 2(1):152–154.

Hoch, G.A. 2000. Patterns and mechanisms of eastern 

redcedar (Juniperus virginiana) expansion into 

tallgrass prairie in the Flint Hills Kansas [PhD 

dissertation]. Manhattan, KS: Kansas State 

University. 110 p.

Hoch, G.A.; Briggs, J.M. 1999. Expansion of eastern 

red cedar in the northern Flint Hills, Kansas. 

In: Proceedings, 16th North American Prairie 

Conference; [Date of conference unknown]; 

[Place of conference unknown]. Springer, J.T.; 

editor. Proceedings of the Sixteenth North 

American Prairie Conference. [Place of publication 

unknown]: [Publisher unknown]. [Number of 

pages unknown].

Homer, C.; Coan, M.; Dewitz, J.; Fry, J.; Herald, N.; 

Hossain, N.; Larson, C.; McKerrow, A.; VanDriel, 

J.N.; Wickham, J. 2007. Completion of the 2001 

national land cover database for the conterminous 

United States. Volume 73. No. 4. [Place of 

publication unknown]: American Society for 

Photogrammetry and Remote Sensing. 337–341. 

Howe, H.F. 1993. Managing species diversity in 

tallgrass prairie: assumptions and implications. 

Conservation Biology 8(3):691–704.

Hulbert, L. C. 1976. Woody plant invasion of 

unburned Kansas bluestem prairie. Journal of 

Range Management 29:19–23.

Huntsinger, L.; Hopkinson, P. 1996. Sustaining 

rangeland landscapes: a social and ecological 

process. Journal of Range Management. 49(2):167–

173.

Johnson, D.H.; Lawrence D.I.; Dechant Shaffer, J.A., 

series coordinators. 2004. [Effects of management 

practices on grassland birds]. Revised August 

2004. <http://www.npwrc.usgs.gov/resource/

literatr/grasbird/index.htm> [Access date 

unknown]. 

Kansas Department of Agriculture. 2010. Kansas 

statistics. [Internet]. <http://www.nass.usda.gov/

Statistics_by_State/Kansas/index.asp> [Access 

date unknown].
 Bibliography 145

Kansas Department of Revenue. 2008, [Internet]. 

[Revision date unknown]. <http://www.ksrevenue.

org/> [Access date unknown].

[KDHE] Kansas Department of Health and 

Environment. 2007. Kansas stream probabilistic 

monitoring program quality assurance 

management plan. In: Division of Environment 

quality management plan. Part III: Program level 

quality assurance management plans. Topeka, KS: 

Kansas Department of Health and Environment, 

Bureau of Environmental Field Services. 85 p.

———. 2008. [Kansas integrated water quality 

assessment].[Revision date unknown]. <http://

www.kdheks.gov/befs/index.html> [Access date 

unknown].

Kansas Geological Survey. 2008. [Kansas springs]. 

KGS Public Informational Circular 11. [Revision 

date unknown]. <http://www.kgs.ku.edu/

Publications/ pic11/pic11_1.htm > [Access date 

unknown].

Kansas State University Research and Extension. 

2009. Watershed restoration and protection 

strategy, Neosho Headwaters Watershed. [Place 

of publication unknown]: Kansas State University 

Research and Extension. [Number of pages 

unknown]. 

Kantrud, H.A.; Krapu, G.L.; Swanson, G.A. 

1989. Prairie basin wetlands of the Dakotas: a 

community profile. Biological Report 85 (7.28). 

[Place of publication unknown]: U.S. Department 

of the Interior, U.S. Fish and Wildlife Service. 116 p.

Knick, S.T.; Rotenberry, J.T. 2000. Ghosts of habitats 

past: contributions of landscape change to current 

habitats used by shrubland birds. Ecology 

81(1):220–227.

Knopf, F.L.; Samson, F.B. 1997. Ecology and 

conservation of Great Plains vertebrates. 

Ecological Studies 125:340 p.

Kozlowski, T.T.; Ahlgren, C.E. 1974. Fire and 

ecosystems. New York: Academic Press, Inc. 552 p.

Kuvlesky Jr., W.P.; Ballard, B.M.; Boydston, K.K.; 

Brennan; Bryant, A.C.; Leonard, F.; Morrison, 

M.L.; 2007. Wind energy development and wildlife 

conservation: challenges and opportunities. 

Journal of Wildlife Management 71:2487–2498.

Leitner, L.A.; Dunn, C.P.; Guntenspergen, G.R. 1991. 

Effects of site, landscape features, and fire regime 

on vegetation patterns in presettlement southern 

Wisconsin. Landscape Ecology 4(4):203–217.

Lockwood, J.L.; Hoopes, M.F.; Marchetti, M.P. 

2007. Invasion Ecology. Volume 7. UK: Blackwell 

Scientific Press. 312 p.

McDonald, R,I.; Fargione, J.; Kiesecker, J.; Miller, 

W.M.; Powell, J. 2009. Energy sprawl or energy 

efficiency:climate policy impacts on natural habitat 

for the United States of America. Journal of 

Conservation Planning 1–14.

McGarigal, K.; McComb, W.C. 1999. Forest 

fragmentation effects on breeding bird 

communities in the Oregon coast range. In: 

Rochelle, J.B., editor. Forest fragmentation: 

wildlife and management implications. Leiden, 

Netherlands: Koninklijke Brill NV. 223–246.

Meltzer, D.J. 1989. Why don’t we know when the 

first people came to North America. American 

antiquity 54(3) 471-490. 

Moore, C.T. 1972. Man and fire in the Central North 

American grassland 1535–1890: A documentary 

historical geography. [Place of publication 

unknown]: University of California. [Number of 

pages unknown].

Mulchunas, D.G.; Burk, I.C.; Lauenoth, W.K. 1998. 

Livestock grazing; animal and plant biodiversity 

in the short grass steppe and the relationship to 

ecosystem function. Okos 83:65-74.

National Park Service. 2001. [The Spring Hill Z Bar 

Ranch Option: 1988–1990]. Revised October 28, 

2001. <http://www.nps.gov/history/history/online_

books/tapr/tapr_7.htm> [Access date unknown]. 

National Renewable Energy Lab. 2010. [Wind 

resource assessment]. Revised April 14, 2010. 

<http://www.nrel.gov/wind/resource_assessment.

html> [Access date unknown].

Natural Resources Conservation Service. 1992. 

Estimated average annual wind erosion in relation 

to T value on nonfederal rural land, by land cover/

use and by year; table 215. [Place of publication 

unknown]: U.S. Department of Agriculture, 

Natural Resources Conservation Service. 

[Number of pages unknown].

Niemuth, N.D.; Estey, M.E.; Reynolds, R.E. 2009. 

Data for developing spatial models: criteria for 

effective conservation. In: Rich, T.D.; Arizmendi, 

C.; Demarest, D.; Thompson, C.D. Proceedings 

of the fourth international Partners in Flight 

conference. 396–411. 

North American Bird Conservation Initiative, 2009. 

The state of the birds, United States of America. 

Washington, DC: U.S. Department of the Interior. 

36 p.

Noss, R.F.; LaRoe III, E.T.; Scott, J.M. 1995. 

Endangered ecosystems of the United States: a 

preliminary assessment of loss and degradation. 

[Place of publication unknown]: National Biological 

Service. [Number of pages unknown].
146 EA, Flint Hills Legacy Conservation Area, KS

Omernick, J.M. 1987. Ecoregions of the conterminous 

United States. Corvallis, OR: U.S. Environmental 

Protection Agency, Environmental Research 

Laboratory. [Number of pages unknown].

Patten, M.A.; Sherrod, S.K.; Shochat, E.; Wolfe, D.H. 

2005. Habitat fragmentation, rapid evolution, and 

population persistence. Evolutionary Ecology 

Research 7:23–249.

Pitman, J.C.; Applegate, R.D.; Hagen, C.A.; Loughin, 

T.M.; Robel, R.J. 2005. Location and success 

of lesser prairie-chicken nests in relation to 

vegetation and human disturbance. Journal of 

Wildlife Management 69(3):1259–69. 

Powell, A.F. 2008. Responses of breeding birds in 

tallgrass prairie to fire and cattle grazing. Journal 

of Field Ornithology 79(1):41–52.

Pyne, S.J. 1982. Fire in America: a cultural history of 

wildland and rural fire. Princeton, NJ: Princeton 

University Press. [Number of pages unknown]. 

Reynolds, R.E.; Batt, B.D.J.; Bruce, D.J.; Renner, 

R.W.; Shaffer, T.L.; Newton, W.E. 2001. Impact 

of the conservation reserve program on duck 

recruitment in the U.S. prairie region. The Journal 

of Wildlife Management 65(4):765–80. 

Reynolds, R.E.; Cox Jr., R.R.; Loesch, C.R.; Shaffer, 

T.L. 2006. The Farm Bill and duck production 

in the Prairie Pothole Region: increasing the 

benefits. Wildlife Society Bulletin 34(4):963–74.

Ribic, C.A.; Bakker, K.K.; Herkert, J.R.; Johnson, 

D.H.; Koford, R.R.; Naugle, D.E.; Neimuth, 

N.D.; Renfrew, R.B.; Sample, D.W. 2009. Area 

sensitivity in North American grassland birds: 

patterns and process. The Auk 126(2):233–44.

Robel, R.J. 2002. Expected impacts on greater 

prairie-chickens of establishing a wind turbine 

facility near Rosalia, Kansas. On file at Zikha 

Renewable Energy, [Location unknown].

Robel, R.J.; Briggs, J.N.; Cebula, J.J.; Silvy, N.J.; 

Viers, C.E.; Watt, P.G. 1970. Greater prairiechicken ranges, movements, and habitat usage 

in Kansas. The Journal of Wildlife Management 

34(2):286–306.

Robel, R.J.; Hagen, C.A.; Harrington, J.A.; Pitman, 

J.C.; Recker, R.R. 2004. Effect of energy 

development and human activity on the use of 

sand sagebrush habitat by lesser prairie-chickens 

in southwestern Kansas. In: Transactions of the 

North American Wildlife National Resource 

Conference. [Date of conference unknown].

[Location of conference unknown]. [Place of 

publication unknown]: [Publisher unknown]. 

69:251–66.

Roe, F.; 1970. The North American buffalo; a critical 

study of the species in its wild state. 2nd edition. 

Toronto: University of Toronto Press. 991 p.

Samson, F.B.; Knopf, F.L.; 1994. Prairie conservation 

in North America. Bioscience 44(6):418–21.

Samson, F.B.; Knopf, F.L.; Ostlie, W.R. 1999. 

Grasslands. In: Mac, M.J.; Doran, P.D.; Opler, P.A.; 

Puckett Haecker, C.E.; editors. Status and trends 

of the nation’s biological resources. 2 volumes. 

Reston, VA: U.S. Geological Survey, Biological 

Resources Division. 437–45. 

Shaw, J.H.; Martin, L. 1995. Ecological interpretation 

of historical accounts of bison and fire on the 

southern plains with emphasis on tallgrass prairie. 

Stillwater, OK: Oklahoma State University, 

Department of Zoology. [Number of pages 

unknown].

Smith, E.F.; Owensby, C.E. 1978. Intensive-early 

stocking and season-long stocking of Kansas 

Flint Hills range. Journal of Range Management 

31(1):[Page number unknown]. 

Southwick Associates. 2007. State-level economic 

contributions of active outdoor recreation—

technical report on methods and findings. Boulder, 

CO: Outdoor Industry Foundation. 162 p. 

Steinauer, E.M.; Collins, S.L. 1996. Prairie ecology—

the tallgrass prairie. In: Samson, F.; Knopf, 

F.; editors. Prairie conservation: preserving 

North America’s most endangered ecosystem. 

Washington DC: Island Press. 39–65.

Therkelsen, B.; Bain, D.; Davis, A.; Grant, B.; Gray, 

T.; MaIntyre, D.; Ugoretz, S. 1998. Permitting of 

wind energy facilities. Washington DC: National 

Wind Coordinating Committee. [Number of pages 

unknown].

[USDA] U.S. Department of Agriculture. 2010. State 

Fact Sheets: Kansas. [Internet]. Revised July 

30, 2010. <http://www.ers.usda.gov/StateFacts/

KS.htm> [Access date unknown].

U.S. Census Bureau. 2009. Census of agriculture; 

volume 1—geographic area series; part 31—

Kansas, state and county data. Washington DC: 

U.S. Census Bureau. [Number of pages unknown].

U.S. Energy Information Administration. 2010. 

Kansas Quick Facts. [Internet]. Revised July 22, 

2010. <http://tonto.eia.doe.gov/state/state_energy_

profiles.cfm?sid=KS> [Access date unknown]. 

U.S. Environmental Protection Agency. 2008. U.S. 

Global Change Research Program. A preliminary 

review of adaptation options for climate sensitive 

ecosystems and resources. Washington DC: U.S. 

Environmental Protection Agency. 873 p.
 Bibliography 147

 [USFWS] U.S. Fish and Wildlife Service. 2003. 

[U.S. Fish and Wildlife Service interim guidance 

on avoiding and minimizing wildlife impacts from 

wind turbines]. [Revision date unknown]. <http://

www.fws.gov/habitatconservation/wind.pdf> 

[Access date unknown].

 ———. 2008. Strategic habitat conservation 

handbook—a guide to implementing the 

technical elements of SHC. Washington DC: U.S. 

Department of the Interior, U.S. Fish and Wildlife 

Service. 22 p.

———. 2009. Strategic plan for responding to 

accelerating climate change in the 21st century. 

Washington DC: U.S. Department of the Interior, 

U.S. Fish and Wildlife Service. 41 p.

———. 2010. Wind Turbine Guidelines Advisory 

Committee recommendations. Draft. [Internet]. 

Revised March 4, 2010. < http://www.fws.

gov/habitatconservation/windpower/Wind_

Turbine_Guidelines_Advisory_Committee_

Recommendations_Secretary.pdf> [Access date 

unknown].

[USGS] U.S. Geological Survey. 2008. Trends 

in peak flows of selected streams in Kansas. 

Water-Resources Investigations Report 01-4203. 

[Internet]. [Revision date unknown]. <http://

ks.water.usgs.gov/pubs/reports/wrir.01-4203.html> 

[Access date unknown].

Vickery, P.D. 1996. Grasshopper Sparrow 

(Ammodramus savannarum). In: Poole, A.; 

editor. The birds of North America. Ithaca, New 

York: Cornell Lab of Ornithology. [Internet]. Birds 

of North America Online. <http://bna.birds.cornell.

edu/bna/species/239> [Access date unknown].

Weir, J.R.; Fuhlendorf, S.D.; Engle, D.M.; Bidwell, 

T.G.; Cummings, D.C.; Elmore, E. 2007. Patch 

burning: integrating fire and grazing to promote 

heterogeneity. Department of Natural Resource 

Ecology and Management. Oklahoma Cooperative 

Extension Service publication E-998. [Place of 

publication unknown]: Department of Natural 

Resource Ecology and Management. 25 p.

Wernick, B.G.; Cook, K.E.; Schreier, H. 1998. Land use 

and streamwater nitrate-N dynamics in an urbanrural fringe watershed. Journal of the American 

Water Resources Association 43(3):639–50.

Wilcove, D.S.; Dubow, A.; Losos, E.; Phillips; 

Rothstein, J. 1998. Quantifying threats to 

imperiled species in the United States. BioScience 

48:607–615

Williams, M.A.; Owensby, C.; Rice, C.W. 2004. Carbon 

and nitrogen pools in a tallgrass prairie soil under 

elevated carbon dioxide. Soil Science Society of 

America Journal 68:184–153.

Woodward, A.J.W.; Fuhlendorf, S.J.; Leslie Jr., 

D.M.; Shackford, J. 2001 Influence of landscape 

composition and change on lesser prairie-chicken 

(Tympanuchus pallidicinctus) populations. The 

American Midland Naturalist 145(2):261–274. 

Wright, H.A.; Bailey, A.W. 1982. Fire ecology. New 

York: John Wiley and Sons. [Number of pages 

unknown].

Zimmerman, J.L. 1988. Breeding season 

habitat selection by the Henslow’s sparrow 

(Ammodramus henslowii) in Kansas. Wilson 

Bulletin 100(1):17–24.